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HomeMy WebLinkAboutDEQp00021335• Biennial Report for APFO Manufacture , Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works LETTER OF INTENT SUBMISSION Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 E.I. du Pont de Nemours and Company Fayetteville Works Site Bladen County, North Carolina Page 1 of 11 July 25, 2006 Note: The information contained in this document is submitted voluntarily and may be subject to future revision and/or modification. CONFIDENTIAL BL-SINESS INFORMATION IS BRACKETED This report is submitted pursuant to commitments made by E.I. du Pont de Nemours and Company (DuPont) in a March 14, 2003, Letter of Intent (LOI) to Stephen L. Johnson, Assistant Administrator, United States Environmental Protection Agency (EPA), entitled "Voluntary Actions to Evaluate and Control Emissions of Ammonium Perfluorooctanoate (APFO)". Pursuant to Addendum III, provision 5, of this LOI, a facility manufacturing APFO will, beginning in the year after production commences, and continuing for five consecutive years following, for the prior calendar year, report to EPA biennially the following information on a calendar year basis: 1. Annual production volume of APFO; 2. Emissions per facility (air, water, waste); 3. Summary report of groundwater monitoring results; 4. Summary report of surface water monitoring results; 5. Workplace industrial hygiene monitoring; and 6. Summary data on employee blood monitoring results. This report provides the above information for calendar years 2004 and 2005, and includes data received as of May 15, 2006, for the Fayetteville Works site ("the site"). General Facility Information Company Name: E. I. du Pont de Nemours and Company Site Location: Site where APFO is manufactured: DuPont Company — Fayetteville Works 22828 NC Highway 87 W Fayetteville, NC 28306-7332 Contains Confidential Business Information • Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works 1. Annual production volume of APFO Page 2 of 11 July 25, 2006 The following table shows the total production volume of APFO for calendar years 2004 and 2005. Calendar Year APFO Production 2004 Confidential Business 2005 Information 2. Emission per facility (air, water, waste) For air emissions, the quantity of APFO emitted to the atmosphere in 2004 and 2005 from the site was estimated using engineering calculations. For surface water emissions, annually a sample of the site's final surface water discharge to the Cape Fear River is tested for the presence of APFO1. For 2004 and 2005, results showed APFO to be less than the analytical method's quantification limit of 0.050 µg/L (0.050 parts per billion). The reported emissions were calculated using this analytical result (<0.050 pg/L) and the average discharge flow rate (12.397 million gallons per day in 2004 and 10.441 million gallons per day in 2005). The waste emissions are the quantities of APFO, on a dry basis, that are estimated to have been present in the various solid waste streams transferred from the Fayetteville Works site. The following table gives the estimated emissions of APFO to specific media from the Fayetteville Works during the subject years: Media 2004 2005 Air 47.3 lb. 55.5 lb. Water <1.9 lb. <1.6 lb. Waste 9,914 lb. 10,019 lb. 3. Summary report of groundwater monitoring results In 2004, 2005, and 2006, the Fayetteville Works site continued the annual groundwater monitoring for APFO that began in 2003. The monitoring involved both newly installed wells and existing monitoring wells. All groundwater and surface water concentrations are reported as APFO (see footnote 1 on this page). This report also provides results available as of May 30, 2006. While APFO is the substance manufactured at the facility, the substance measured by analytical techniques is the perfluorooctanoate anion (PFO-). The commercial laboratory converts this analytical result to an APFO value via molecular weight calculations. For consistency with the previously submitted biennial report for this site, results are reported as the calculated APFO values. Contains Confidential Business Information Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works Page 3 of 11 July 25, 2006 The following table reports the groundwater monitoring analytical results, both onsite and offsite, for 2004, 2005, and year-to-date 2006: Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (gg/L) MW -1S 02/03/04 NQ (<0.050) Onsite monitoring well located near the inactive Biosludge Lagoon area in the perched groundwater above a local clay 06/20/05 NQ (<0.050) 01/24/06 0.038 feature; South of the APFO Manufacturing Facility. MW -2S Onsite monitoring well located near the inactive Biosludge Lagoon area in the perched groundwater above a local clay 06/20/05 NQ (<0.050) feature; South of the APFO Manufacturing Facility. MW -5D Onsite monitoring well located near the inactive Biosludge Lagoon area in the surficial groundwater beneath a local clay 06/20/05 NQ (<0.050) feature; South of the APFO Manufacturing Facility. MW -7S Onsite monitoring well located near the inactive Biosludge Lagoon area in the perched groundwater above a local clay 10/18/05 0.047 feature; South of the APFO Manufacturing Facility. MW -101) Onsite monitoring well located near the inactive Biosludge Lagoon area in the surficial groundwater beneath a local clay 06/20/05 ND (<0.100) feature; South of the APFO Manufacturing Facility. NAF -01 02/04/04 0.062 Onsite monitoring well located upgradient of the Nafion® 06/15/05 0.104 Common Sump in the perched groundwater above a local clay feature; Southeast of the APFO Manufacturing Facility. 10/13/05 0.151 02/01/06 0.115 NAF -02 02/04/04 0.307 Onsite monitoring well located downgradient of the Nafion® 06/15/05 0.338 Common Sump in the perched groundwater above a local clay feature; Southeast of the APFO Manufacturing Facility. 10/14/05 0.246 02/01/06 0.316 NAF -03 02/04/04 1.530 Onsite monitoring well located downgradient of the Nafion® 06/15/05 0.663 Common Sump in the perched groundwater above a local clay feature; Southeast of the APFO Manufacturing Facility. 10/14/05 0.872 01/25/06 0.434 gg/L = micrograms per liter or parts per billion Contains Confidential Business Information Biennial Report for APFO Manufacture Page 4 of 11 Calendar Years of 2004 and 2005 July 25, 2006 DuPont Company — Fayetteville Works Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (gg/L) NAF -04 02/04/04 0.124 Onsite monitoring well located downgradient of the Nafion® 06/17/05 0.093 Common Sump in the perched groundwater above a local clay feature; Southeast of the APFO Manufacturing Facility. 10/18/05 0.212 02/01/06 0.065 NAF -05A Onsite monitoring well located downgradient of the Nafion® 11/11/04 0.239 10/13/05 0.187 Common Sump in the perched groundwater above a local clay feature; Southeast of the APFO Manufacturing Facility. NAF -05B Onsite monitoring well located downgradient of the Nafion® Common Sump in the surficial groundwater beneath a local 11/11/04 ND (<0.010) clay feature; Southeast of the APFO Manufacturing Facility. NAF -06 Onsite monitoring well located northeast of the 06/16/05 0.262 Fluoromonomers production area in the perched groundwater 10/14/05 0.535 above a local clay feature; Southeast of the APFO Manufacturing Facility. 01/31/06 0.303 NAF -07 Onsite monitoring well located northeast of the 06/16/05 NQ (<0.050) Fluoromonomers production area in the perched groundwater 10/14/05 0.085 above a local clay feature; Southeast of the APFO Manufacturing Facility. 01/31/06 0.065 NAF -08A Onsite monitoring well located southeast of the 06/17/05 0.072 Fluoromonomers production area in the perched groundwater 10/13/05 0.172 above a local clay feature; Southeast of the APFO Manufacturing Facility 01/31/06 0.053 NAF -08B Onsite monitoring well located southeast of the 06/21/05 ND (<0.010) Fluoromonomers production area in the surficial groundwater 10/13/05 NQ (<0.011) beneath a local clay feature; Southeast of the APFO Manufacturing Facility 01/31/06 NQ (<0.012) NAF -09 06/16/05 0.080 Onsite monitoring well located south of the Fluoromonomers production area in the perched groundwater above a local clay 10/13/05 0.121 02/01/06 0.086 feature; Southeast of the APFO Manufacturing Facility. gg/L = micrograms per liter or parts per billion Contains Confidential Business Information • Biennial Report for APFO Manufacture Page 5 of 11 Calendar Years of 2004 and 2005 July 25, 2006 DuPont Company — Fayetteville Works Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (n/1L) NAF -10 06/16/05 0.122 Onsite monitoring well located south of the Fluoromonomers production area in the perched groundwater above a local clay 10/13/05 0.134 02/01/06 0.088 feature; Southeast of the APFO Manufacturing Facility. NAF -11A Onsite monitoring well located northeast of the 07/05/05 NQ (<0.05) Fluoromonomers production area in the perched groundwater 10/17/05 0.021 above a local clay feature; Southeast of the APFO Manufacturing Facility. 01/26/06 0.048 NAF -1113 Onsite monitoring well located northeast of the 07/05/05 ND (<0.010) Fluoromonomers production area in the surfcial groundwater beneath a local clay feature; Southeast of the APFO Manufacturing Facility. 10/17/05 ND (<0.002) 4328MLR 11/16/05 0.011 Offsite private residential drinking water well; Northeast of the APFO Manufacturing Facility. 11/16/05 NQ (<0.022) 6999PED 11/16/05 ND (<0.005) Offsite private residential drinking water well; Northwest of the APFO Manufacturing Facility. 11/16/05 ND (<0.002) PW -01 Offsite private residential drinking water well; West of the 01/25/06 ND (<0.002) APFO Manufacturing Facility. PW -02 Offsite transient noncommunity public water system; West of 01/25/06 ND (<0.002) the APFO Manufacturing Facility. PW -03 Offsite transient noncommunity public water system; 01/25/06 ND (<0.002) Southeast of the APFO Manufacturing Facility. PW -04 Onsite transient noncommunity public water system; 01/25/06 ND (<0.002) Northwest of the APFO Manufacturing Facility. PW -05 Offsite transient noncommunity public water system; North- 01/25/06 NQ (<0.012) northwest of the APFO Manufacturing Facility. µg/L = micrograms per liter or parts per billion Contains Confidential Business Information Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Page 6 of 11 July 25, 2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (gg/L) PW -06 Offsite transient noncommunity public water system; North- 01/25/06 ND (<0.002) northwest of the APFO Manufacturing Facility. PW -07 Offsite private residential drinking water well; South- 03/30/06 ND (<0.001) southwest of the APFO Manufacturing Facility. PZ -04 Onsite monitoring well located southeast of Nafion® Common Sump in the perched groundwater above a local clay feature; 02/01/06 0.617 Southeast of the APFO Manufacturing Facility. PZ -12 10/17/05 0.021 Onsite monitoring well located southeast of the APFO Manufacturing Facility in the perched groundwater above a 12/13/05 0.015 01/26/06 0.018 local clay feature. PZ -15 Onsite monitoring well located northwest of the PMDF Facility in the perched groundwater above a local clay feature; 01/26/06 0.032 South-southeast of the APFO Manufacturing Facility. PZ -16 Onsite monitoring well located southeast of the PMDF Facility in the perched groundwater above a local clay feature; South- southeast of the APFO Manufacturing Facility. SMW-01 02/03/04 ND (<0.010) Onsite monitoring well located east of the Construction Gate entrance near Highway 87 in the surficial aquifer; Southwest 06/20/05 ND (<0.010) 01/24/06 ND (<0.002) of the APFO Manufacturing Facility. SMW-02 02/03/04 ND (<0.010) Onsite monitoring well located north of the River Pump Road, 06/20/05 ND (<0.010) north of the Fluoromonomers manufacturing area, in the 09/06/05 NQ (<0.007) perched groundwater above a local clay feature; East of the APFO Manufacturing Facility. 10/17/05 ND (<0.002) 01/26/06 NQ gg/L = micrograms per liter or parts per billion Contains Confidential Business Information Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Page 7 of 11 July 25, 2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (gg/L) SMW-02B Onsite monitoring well located north of the River Pump Road, north of the Fluoromonomers manufacturing area, in the 10/17/05 ND (<0.022) surficial groundwater beneath a local clay feature; East of the APFO Manufacturing Facility. SMW-04B 10/17/05 2.25 Onsite monitoring well located north of the River Pump Road, 11/10/05 2.51 north of the APFO Manufacturing Facility, in the surficial 01/24/06 1.30 groundwater beneath a local clay feature. SMW-05 10/17/05 147 Onsite monitoring well located north of and adjacent to the APFO Manufacturing Facility, in the perched groundwater above a local clay feature. 12/13/05 765 SMW-05P Onsite monitoring well located north of and adjacent to the 02/22/06 6.5 APFO Manufacturing Facility, in the surficial groundwater beneath a local clay feature. SMW-06 Onsite monitoring well located east of and adjacent to the 12/13/05 0.224 APFO Manufacturing Facility, in the perched groundwater above a local clay feature. 01/26/06 0.261 SMW-07 10/17/05 0.019 Onsite monitoring well located south of and adjacent to the 12/13/05 NQ (<0.012) APFO Manufacturing Facility, in the perched groundwater above a local clay feature. 01/26/06 NQ (<0.012) #562877 - Domestic H2O Inactive onsite drinking water well located near the Powerhouse area, screened in the Upper Cape Fear confined 07/15/04 ND (<0.010) aquifer; South of the APFO Manufacturing Facility. #562878 — Domestic H2O Inactive onsite drinking water well located near the Powerhouse area, screened in the Upper Cape Fear confined 07/15/04 ND (<0.010) aquifer; South of the APFO Manufacturing Facility. INSITU #1 Shallow Onsite monitoring well located near the facility's northern property line in the upper level of the surficial groundwater; 12/20/05 NQ (<0.013) North-northeast of the APFO Manufacturing Facility. µg/L = micrograms per liter or parts per billion Contains Confidential Business Information Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works Summary of Groundwater Analytical Results DuPont Fayetteville Works 2004 —2006 Page 8 of 11 July 25, 2006 Sample ID Monitoring APFO (Groundwater Monitoring Well Description) Date (µg/L) INSITU #2 Deep Onsite monitoring well located near the facility's northern property line in the lower level of the surficial groundwater; 12/20/05 ND (<0.027) Northwest of the APFO Manufacturing Facility. INSITU #2 Shallow Onsite monitoring well located near the facility's northern property line in the lower level of the surficial groundwater; 12/20/05 NQ (<0.013) Northwest of the APFO Manufacturing Facility. LTW-01 Onsite monitoring well located near the facility's eastern property line along the Cape Fear River in the surficial 02/02/06 0.033 groundwater; East of the APFO Manufacturing Facility. LTW-02 Onsite monitoring well located near the facility's eastern property line along the Cape Fear River in the surficial 02/02/06 ND (<0.002) groundwater; East-southeast of the APFO Manufacturing Facility. LTW-03 Onsite monitoring well located near the facility's eastern property line along the Cape Fear River in the surficial 02/01/06 ND (<0.002) groundwater; East-southeast of the APFO Manufacturing Facility. LTW-04 Onsite monitoring well located near the facility's eastern property line along the Cape Fear River in the surficial 01/24/06 ND (<0.002) groundwater; Southeast of the APFO Manufacturing Facility. LTW-05 Onsite monitoring well located near the facility's eastern 02/02/06 ND (<0.002) property line along the Cape Fear River in the surficial groundwater; Southeast of the APFO Manufacturing Facility. µg/L = micrograms per liter or parts per billion 4. Summary report of surface water monitoring results The Fayetteville Works facility annually monitors for APFO in the site's surface water discharge to the Cape Fear River. This monitoring location is the site's final effluent Contains Confidential Business Information Biennial Report for APFO Manufacture Page 9 of 11 Calendar Years of 2004 and 2005 July 25, 2006 DuPont Company — Fayetteville Works discharge at the NPDES permitted Outfall 002. The results of that monitoring are shown in the following table: Surface Water Sample ID Monitoring APFO (Sample Description) Date (gg/L) Outfall 002 02/03/04 NQ (<0.050) Final NPDES permitted wastewater discharge; Located south of the central wastewater treatment plant and south of 06/20/05 NQ (<0.050) 01/24/06 0.025 the APFO Manufacturing Facility. gg/L = micrograms per liter or parts per billion Monitoring of stagnant water in a stormwater conveyance ditch was conducted in 2005. While this stagnant water meets the definition of a surface water, it should be noted that this water consisted of exclusively non -flowing puddles of water at the time of the sampling. The results of that monitoring are shown in the following table: Surface Water Sample ID (Sample Description) Monitoring Date APFO (gg/L) SW -01 Stormwater ditch north of Fluoromonomers area; East of the APFO Manufacturing Facility. 06/20/2005 0.100 09/06/2005 0.129 10/07/2005 0.068 SW -02 Stormwater ditch north of Fluoromonomers area; East of the APFO Manufacturing Facility. 06/20/2005 0.135 09/06/2005 0.302 10/07/2005 0.157 SW -03 Stormwater ditch north of Fluoromonomers area; East of the APFO Manufacturing Facility. 06/21/2005 0.142 09/06/2005 0.298 10/07/2005 0.149 SW -04 Stormwater ditch north of Fluoromonomers area; East of the APFO ManufacturingFacility.10/07/2005 06/20/2005 0.093 0.147 SW -05 Stormwater ditch north of Fluoromonomers area; East of the APFO Manufacturing Facility. 10/07/2005 0.139 gg/L = micrograms per liter or parts per billion Sampling of two unnamed tributaries to the Cape Fear River, and two streams flowing to one of those tributaries, was conducted in 2006. It is believed that the base flow in these tributaries is primarily from expressed groundwater, with additional episodic flow from stormwater runoff. The surface water samples described in the table that follows were taken Contains Confidential Business Information Biennial Report for APFO Manufacture Calendar Years of 2004 and 2005 DuPont Company — Fayetteville Works Page 10 of 11 July 25, 2006 during base flow conditions. The results of that monitoring are shown in the following table: Surface Water Sample ID Monitoring APFO (Sample Description) Date (99/L) SW -06 Located east of the Fluoromonomers area, in an unnamed 01/25/2006 0.027 tributary (#1) to the Cape Fear River SW -07 Located east of the Fluoromonomers area, in a stream (#1) 01/25/2006 0.040 flowing into the unnamed tributary #1 09/06/2005 0.083 SW -08 Located east of the Fluoromonomers area, in a stream (#2) 01/25/2006 0.032 flowing into the unnamed tributary #1 SW -09 09/06/2005 0.081 Located east of the PMDF manufacturing area, in an 01/25/2006 0.027 unnamed tributary (#2) to the Cape Fear River µg/L = micrograms per liter or parts per billion In 2005, the site's non -contact cooling water and the influent and effluent of the river water sediment basin were sampled. Both of these waters ultimately discharge through the site's NPDES permitted Outfall 002. The non -contact cooling water is raw river water that is pumped from the Cape Fear River, through equipment to remove heat, and then back to the river. The river water sediment basins receive river water and its sediment that has been removed from the river water as a result of clarification. The results of that monitoring are shown in the following table: Surface Water Sample ID Monitoring APFO (Sample Description) Date (n/L) NR -01 Non -contact, once -through cooling water flowing in the 09/06/2005 0.077 open ditch south of the Fluoromonomers area; East of the APFO Manufacturing Facility RW -01 Influent to the filtered river water sediment basin located 09/06/2005 0.083 west of the Fluoromonomers area; East of the APFO Manufacturing Facility RW -02 Effluent from the filtered river water sediment basin located 09/06/2005 0.081 west of the Fluoromonomers area; East of APFO the Manufacturing Facility µg/]L = micrograms per liter or parts per billion Contains Confidential Business Information Biennial Report for APFO Manufacture Page 11 of 11 Calendar Years of 2004 and 2005 July 25, 2006 DuPont Company — Fayetteville Works 5. Workplace industrial hygiene monitoring The DuPont Company — Fayetteville Works began workplace monitoring for perfluorooctanoic acid (PFOA) with the start up of the APFO Manufacturing Facility in 2002. The workplace monitoring in 2004 and 2005 consisted of stationary area monitors that sampled the building air space for twelve (12) continuous hours. These sampled locations are limited access restricted areas in which personnel wear both respiratory and dermal personnel protection. The 12 -hour time weighted average (TWA) PFOA concentration values are shown in the following table: mg/m3 = milligrams per cubic meter 6. Summary data on employee blood monitoring results At the DuPont Company — Fayetteville Works, blood serum levels of PFOA have been measured since 2002. A summary of results of employees with identified APFO exposure potential in 2004 and 2005 is shown in the following table: Number PFOA PFOA PFOA Year Sample Type of Minimum Maximum Average Concentration Concentration Samples Conc. Conc. Conc3 (ppm) (ppm) 2004 56 (mg/m) (mg/m) (mg/m ) 2004 Area 12 -hour TWA 85 0.00021 1.9 0.041 2005 42 <0.00021 0.061 0.0081 mg/m3 = milligrams per cubic meter 6. Summary data on employee blood monitoring results At the DuPont Company — Fayetteville Works, blood serum levels of PFOA have been measured since 2002. A summary of results of employees with identified APFO exposure potential in 2004 and 2005 is shown in the following table: ppm = parts per million Additional monitoring information Additional APFO monitoring information that is not specified by the LOI is being reported in Appendix A of the site's Phase II RCRA Facility Investigation (RFI) Report. This additional information will be the analytical results for APFO concentrations of samples taken of soil, sediment, ambient air, and the Cape Fear River. A copy of the Phase II RFI Report was submitted to the N.C. Division of Waste Management on June 30, 2006 and will be provided to EPA Docket OPPT-2003-0012 as a separate submission. Contains Confidential Business Information PFOA PFOA PFOA Number of Minimum Maximum Average Year Samples Concentration Concentration Concentration (ppm) (ppm) (ppm) 2004 56 0.0027 1.87 0.437 2005 64 0.0031 4.54 0.504 ppm = parts per million Additional monitoring information Additional APFO monitoring information that is not specified by the LOI is being reported in Appendix A of the site's Phase II RCRA Facility Investigation (RFI) Report. This additional information will be the analytical results for APFO concentrations of samples taken of soil, sediment, ambient air, and the Cape Fear River. A copy of the Phase II RFI Report was submitted to the N.C. Division of Waste Management on June 30, 2006 and will be provided to EPA Docket OPPT-2003-0012 as a separate submission. Contains Confidential Business Information I OUp�NT DuPont Fluoroproducts ® 22828 NC Highway 87 W Fayetteville, NC 28306-7332 CERTIFIED MAIL — RETURN RECEIPT REQUESTED June 28, 2006 Mr. Alan W. Klimek, P.E. Director NCDENR — Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 SUBJECT: Revised Cape Fear River APFO Sampling Results Dear Mr. Klimek: On April 3, 2006, the DuPont Company — Fayetteville Works reported to the Division of Water Quality the results of sampling in the Cape Fear River basin for the compound ammonium perfluorooctanoate (APFO or C8). DuPont subsequently learned that an unvalidated analytical method was used to generate those results. The retained river water samples were then analyzed with the correct validated method, and those results are given on the attached table. You will see that the attached results are similar to what was reported to you in April. If you have any questions regarding this information, or if you need more details, please feel free to call me at (910) 678-1155. Environmental Manager Attachment cc: Ms. Belinda Henson — NCDENR Division of Water Quality — Fayetteville Ms. Jessica Miles — NCDENR Division of Environmental Health — Raleigh Ms. Debra Benoy — NCDENR Division of Environmental Health — Wilmington Mr. Larry Stanley — NCDENR Division of Waste Management — Raleigh Ms. Mary Dominiak — EPA — Washington DC (via dominiak.mary@epamail.epa.gov) E.I. du Pont de Nemours and Company O� N O O 110 O U O N � �, " o 0 0 O 00 O C:) O C:) W rig tet O00 N O O 110 kr) t— 00 00 00 00 �+ �. cg 4, o cd N c U ; En � cl % 0 03 03 N N ° N N ctj N N x 00 [� 00 0) (1) t3w N U bbD ct o U o U vow o U Q o° `o xz xz o Y o z _ U w o 0 0 0 0 0 �A o 0 0 0 0 0 rl O U O N O 0 o o U U Cd U O ro Ln cri a �+ �. cg 4, o cd N c U ; En � % 0 03 03 3�z 1 / � — cJ rra�be - ?tVnd-,iC- C npckrd s - PPA- +b+a phanals -;p <o4 wV k Cit QQ,Q < f,• aa2Ccl� 1.0 14/L wQs Clean Water for27! 1!� North Carolina 2009 Chapel Hill Rd. Durham, NC 27707 Teresa Rodriguez NC Div. of Water Quality - NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 January 25, 2007 Comments on Draft NPDES Permit NC0003573 for DuPont -Fayetteville Works, Bladen County Dear Ms. Rodriguez: On behalf of Clean Water for North Carolina, we wish to submit the following comments on the draft renewal permit for DuPont -Fayetteville Works. The DuPont facility is not only the site of six manufacturing processes, including the newly - added polyvinyl flouride process, but it is also a neighbor to the Fayetteville community and all other downstream and downwind communities. We believe that it is vital for the protection of these residents' drinking water supplies that the testing requirements in this permit are strengthened to not only test existing parameters more frequently but also to add parameters that are either new, have been previously overlooked, or which have been removed as a result of demonstration of compliance several years ago. The detail and straightforwardness of the fact sheet have been very helpful to us in reviewing the permit and understanding the DuPont facility. However, there are several inconsistencies throughout the draft permit regarding testing frequency. All parameters with daily maximum limits should be sampled and analyzed daily to ensure that the maximum is not exceeded. Total suspended solids and BOD, for example, are being discharged from Outfall 001 and, though they have daily maxima, they are not tested for on a daily basis. Another critical example of this is the testing for hexachlorobenzene, which is currently done only annually. This toxin is a likely human carcinogen and once released, it lingers in the environment and accumulates in plants, animals, and soil. Hexachlorobenzene should be tested for daily, to ensure the safety of Cape Fear River Basin residents. Furthermore, the permit's language regarding the testing of hexachlorobenzene ("sufficiently sensitive") must be more explicit in its requirements for analytical methodology. We are aware that such non-specific language has allowed some facilities to use analytical methods that are not capable of detecting down to NC water quality standards. Wherever possible, analytical methods should be prescribed to ensure their appropriateness. All listed parameters should have monthly averages as well as daily maxima to ensure that safe levels are not being exceeded. From Outfall 002, BOD, COD, dissolved oxygen, total phosphorous, and total nitrogen should have stated limits. A major fault in the draft permit is that carries over a waiver regarding testing requirements from the previous permit. Any monitoring previously waived should not be automatically carried through to the next permit, as the current permit states that the waiver is "good only for the term of the permit." Permittees should have to prove compliance at least as often as every permit renewal to have requirements waived. Preferably, compliance should be proven annually, or within 30 days after the introduction of any new processes at the facility. The substances listed in A (2) Subpart I, for example, include many hazardous toxins, which if in use, or potentially in stormwater discharges, should be tested for regularly to ensure public safety. This is especially critical given the addition of the PVF process at the Fayetteville Works. The daily maximum fluoride discharge from Outfall 002 is extremely alarming. Excess fluoride in drinking water can have serious health impacts for humans, as it accumulates in bones, damages teeth, and is a suspected neurotoxin. Studies have shown that both aquatic and terrestrial ecosystems can be severely damaged by fluoride toxicity as well. The maximum must be lowered significantly to safeguard both downstream residents' drinking water and the health of the Cape Fear River and fluoride discharge levels must be limited and tested on a daily basis. The downstream "mixing zone" of 4500 feet should be removed, and instream testing should be done immediately below the discharge point to prevent the River from diluting wastewater and allowing degradation of the River within that than permitted. If there are financial constraints on the mixing zone being removed, the statutory requirement for a "variance," which this effectively constitutes, requires that these be completely documented and available to the public. A compliance point must not be placed nearly a mile downstream of the facility simply for the convenience of a monitoring entity. Wastewater must be tested for vinyl fluoride at the most upstream compliance discharge point, and at final Outfall 02, as the facility is adding the PVF process. This is especially critical since DuPont acknowledges that some amount of unreacted vinyl fluoride will be discharged. Vinyl fluoride is a suspected human carcinogen and has been shown to cause numerous types of cancers in mice and rats, in much the same way as vinyl chloride and vinyl bromide. Though all PFOA wastes are reported to be transported off-site for disposal, the permit should include monitoring requirements and limitations for PFOA and related compounds, as PFOA has been linked to cancer and birth defects in animals and is being increasing regulated in groundwater and drinking water standards and action levels. Even small discharges of a substance as toxic as PFOA into the Cape Fear River can impact downstream drinking water, so limiting and testing for PFOA in wastewater discharges is an important step in protecting the area's water supply sources. The required off-site disposal of waste from the PFOA plant should be included in the permit, as should the identity of the off-site facility. The permit should also require proof, such as a signed affidavit of receipt from an appropriate facility, that all waste from the PFOA process is taken off-site for hazardous waste disposal. Additionally, any water intake for the PFOA process should be included in the water balance sheet regardless of off-site waste treatment DWQ's interim groundwater standard of 2.0 ppb for PFOA is almost certainly not sufficiently protective of human health. It relieves DuPont of all but very limited monitoring and clean-up responsibilities at the Fayetteville works (only immediately around the PFOA plant) and potentially endangers North Carolina residents' well water. The setting of this standard by DWQ prematurely, before conclusion of review by the NC Science Advisory Board, and using safety factor calculations regarding which an EPA official recently described PFOA as a "poster child" for their inappropriateness, is a dangerous precedent, While NC regulations require the Director to initiate permanent rulemaking for a standard within 3 months, once an interim standard is set, DWQ knows there will be considerable resistance from the regulated entity to setting a standard that is more protective, making this "interim" limit highly problematic. Most states are looking at far more protective groundwater standards or action levels of 0.5 ppb or less. DuPont -Fayetteville Works is the only manufacturer of PFOA in the country; therefore North Carolina should take a leading role in regulating this toxin and protecting the state's residents. The ongoing violation of NC's instream turbidity standard and accumulation of sediments carried by the wastewater and stormwater flows through the eroding long ditch to the Cape Fear River, have been facilitated by this distant downstream monitoring point. Aerial photographs showing the flow of sediments into the River from this ditch and buildup of sediment have been presented at a 2005 meeting where DWQ Director Alan Klimek and other staff were present This is a situation which has been developing for years, a clear Clean Water Act violation and we have seen no enforcement action on the part of the Division. Turbidity, which was listed on the fact sheet but absent from the permit monitoring requirements, must be included and measured daily at a specified point immediately downstream of the discharge point, given the acknowledged problems being caused by the erosion of the ditch. Upon reviewing the permit application materials, We found several additional issues to be addressed. The most pressing of these is sample retention. An aliquot of all testing samples should be retained in case the need for retesting arises. The DWQ should not accept any "data remediation' by the Permittee in response to abnormal test results. For example, the abnormal phosphorous test results that occurred in March and December of 2005 were simply adjusted to appear within a normal range. There is an obvious conflict of interest for the Permittee in these instances, and sample retention allows for cases like these to be soundly resolved with retesting. Furthermore, while we understand the Division's routine reliance on self-reported discharge monitoring data, personnel from the Division of Water Quality should carry out at least one annual split sampling on an unannounced visit to assure reliable analysis of all water quality parameters. We also have some concerns about the public notification process. The permittee's name should be prominently shown at the beginning of all public notices; in DuPont's case it was not mentioned until the final paragraph. Legal notices are a largely ineffective way to ensure that the public is aware of coming permit public comment periods, but given the requirements of NC statute, all efforts must be made to increase the likelihood that the public will actually see them. Most residents, who have the right to be informed, will simply not read the entire notice without knowing what it actually refers to. Public notices will be much more informative when the permittee's name is in the heading. Finally, we noticed in the permit application materials that Mr. Michael Johnson corrected a possible error regarding testing frequency that would have resulted in less frequent testing. We concur with the need for this correction and appreciate his vigilance in this matter. Because of the numerous concerns regarding this permit and significant public interest we have found in contacts with residents near and downriver from this facility, we are requesting that a public hearing be held. Please notify us (see below) as to when the hearing is scheduled. Thank you for the opportunity to comment on this draft permit. Sincerely, Jill eman and Hope Taylor -Guevara ✓ Clean Water for North Carolina Phone: (919) 401-9600 E-mails: 0125(a-duke.edu and htaylor gloryroad_net Comments on DuPont Fayetteville NPDES Permit Subject: Comments on DuPont Fayetteville NPDES Permit From: "Steven Skavroneck" <skavroneck@earthlink.net> Date: Tue, 23 Jan 2007 15:40:19 -0500 To: <teresa.rodriguez@ncmail.net> I am forwarding the attached comment letter on the proposed reissuance of the NPDES permit for the DuPont Fayetteville Works on behalf of the Cape Fear River Watch Inc. Steven Skavroneck Board Member Cape Fear River Watch Inc. DuPont Permit 012307.doc', Content -Type: application/msword Content -Encoding: base64 of 1 1/29/2007 2:51 PM 617 Surry Street Wilmington, NC 28401 (910) 762-5606 1-800-380-3485 cfrw@ecoisp.com www.cfrw.us ->W^ w,47%ex"R&e A144 &1Cfi MOADER Printed on Recycled Paper January 23, 2007 Sue Hayes Environmental Management Commission/ NPDES Unit OFFICERS 1617 Mail Service Center Paul Nelson, President Raleigh, NC 27699-1617 Chuck Crawford, Vice President Re: Draft Permit NC0003573 Audrey Albrecht, Secretary for PFOA. There is nothing in the proposed permit to prevent DuPont Dave Pyle, Treasurer from treating the PFOA discharge on site and if this is done there would Business Manager To Whom it May Concern: BOARD OF DIRECTORS Richard Cecelski Thank you for the opportunity for Cape Fear River Watch Inc. to Fred crouch comment on this draft permit. Cape Fear River Watch has been a proponent of water quality in southeastern North Carolina since 1993. Joe Gaughan Our mission is to protect and improve the water quality of the Lower Tom Haney Cape Fear River Basin through education, advocacy, and action. We Jane Hartley have the following comments relating to the draft NPDES permit for the DuPont Fayetteville Works wastewater treatment plant. Sharon Hatton Sue Hayes The permit should require monitoring and compliance with effluent Rob Moul limits for PFOA (C8). The company has indicated that all the discharge from the PFOA plant is treated off site. This should either be made a Paula May Murray requirernent of the renewed permit or else effluent limits promulgated Jeff Newman for PFOA. There is nothing in the proposed permit to prevent DuPont Jennifer O'Keefe from treating the PFOA discharge on site and if this is done there would Business Manager be no requirement for them to monitor for PFOA in the discharge. Brad Rosov Steve Skavroneck In addition, the interim groundwater standard of 2.0 parts per billion for Dave Thomas PFOA is too lax. This standard relieves DuPont of nearly all clean up responsibilities for the discharge that has been previously reported. Mark westenaorff North Carolina state health officials have stated that the standard for STAFF PFOA should be zero until the health risks are fully understood. Dick Ehrhart Elsewhere, the standard has been set at 0.5 ppb. This would serve as a Business Manager more appropriate interim standard. Joe Abbate Greenfield lake Director The downstream mixing zone of 4,500 feet should be removed. Instead, monitoring should be required at the point where the DuPont discharge enters the Cape Fear River. The daily maximum limitation for fluoride (7,917 pounds per day) seems extremely high. This is a concern because fluoride accumulates in animal bones, in plants and in the soil. If this limit remains in the final permit, the permit should also require monitoring of fluoride accumulation in river sediment and additional bioaccumulation studies on lower trophic catfish since they concentrate fluorides and some metals in their tissues. For hexachlorobenzene, the phrase "sufficiently sensitive" relating to testing method is too ambiguous. The required method sensitivity should be more discretely defined. In addition, we request a public hearing on this permit, and that we be notified about the date, time and place of the hearing when it is scheduled. Thank you for your consideration of these comments. Sincerely, Paul Nelson President �Y�-��tIN�:G��' � /1'r`-D� h�C-tC�-� C�-� � �j1� " �t- y�� �e-dv✓� Cf��. � 001' 1, a�4c z mac► - JAA IC '411 X/. "- �,/ lo�?Ie-x—a /cot