DEQ-CFW_00042520

azarous Waste Compliance Data Entry For
EPA ID Number: NCD 047 368 642
Facility Name: DuPont Fluoroproducts
Street: 2228 NC Highway 87 West
City: Fayetteville ZIP: 28306 County: Cumberland
Contact Name: Mike Johnson Phone#: [phone]
EVALUATION DATA New: X Change: Delete:
Date: 04/27/2009 Evaluation Type: CEI
Date: S' / Zo/ Le,,T Evaluation Type: CS,�
Inspector ID #: 036
Evaluation Comments:
Date Determined:
Branch: 07 Person: 036
Return to Compliance: 5/27/09 S" / 2 0
Scheduled Actual
Regulation Description: 40 CFR 262,34(a) 265,16(c)
Comment: Except as provided in paragraphs (d), (e), and (f) of this section, a generator may accumulate hazardous
waste on -site for 90 days or less without a permit or without having interim status, provided that: (4) The generator
complies with the requirements for owners or operators in Subparts C and D in 40 CFR part 265, with §265.16, and
with 40 CFR 268.7(aX5).
265.16(c) Facility personnel must take part in an annual review of the initial training required in
paragraph (a) of section 265.16.
DEQ-CFW 00042520

STATE OF NOP
DEPARTMENT OF ENVIRONMENT AND NATURAL UPSUAl 1 RCIWQ
Div tbiON OF WASTE MANAGEMENT
nALARDOUS WASTE SECTION
11,TJ I U IN 31 ! 1 1111 111111i'51 iiv 515111:11i jj r
11 -.-- i--i- - V-.% -OP z-!kV.,-tjb I It IAT tMATION:
Name: DuPont Flouroproducts
EPA ID Number: NCD 047 368 642
Type of Facility: Large Quantity Generator
Facility Location: 22828 NC Highway 87 West
Fayetteville, NC 28306
Telephone Number: [phone]
Ownership: DuPont Corp.
2. FACILITY CONTAM
3. SURVEY PARTICIPANTS:
Dianne Fields, Eddie Vega
Robeh K. Nelms — i , Nt—UrIN.Irs.
44- DATE ,OF INSPECTION: 27 April 2009
5. PURPOSE OF INSPECTION: Unannounced audit to determine compliance with
regulations described at 40 CFR 261, 262, 265, 268, 273 and 279 and the facility's
permit.
6. FACILITY DESCRIPTION: DuPont — Fayetteville works — manufactures resin and
intermediates including Butacite polyvinyl butyral sheeting and membrane. 'fhe
facility is a Large Quantity Generator and holds a Part B permit for storage of waste in
containers and tanks.
7. HAZARDOUS WASTE STREAMS INCLUDE: Acid Fluorides and
F005, D003, DOO I — 1,2 Dichloroethene and Trichlorotrifluoroethane F002, D028 —
Dichloromethane and Acid Fluorides D029, D002 — Potassium Hydroxide, Sodium
Hyroxide.
DEQ-CFW-00042521

DuPont Fluoroproducts
(over)
8. AREAS OF REVIEW AND INSPECTION:
➢ Emergency Preparedness
➢ Contingency Plan — The most recent copy of the contingency plan and related
revisions was reviewed. No violations were noted.
➢ Manifests / L — 2009 Manifests were reviewed. No violations were noted.
➢ Biennial Report — The 2007 biennial report was on site and available for
inspection.
➢ Training Records
➢ Training records for Eddie Vega, William Partrette, Russell Locklear, Kenneth
McNeill and Pamela Richardson were reviewed during the inspection. Of the
five, only Russell klear's training was up to date. The facility recently
switched computer systems which automatically send reminders of required
training dates to employees. The new system failed to be on line in January 2009
which has delayed all reminders.
➢ Inspection Records (storage)
➢ 2009 inspection records for tank inspections, the storage pad, 90 day storage area
and subpart BB requirements were reviewed.
Transporters:
Suttles Truck Leasing ALD 095 704 011
Sentinel Trans. DER 000 002 741
➢
➢ TD's:
DuPont Co. NJD 002 385 730
Clean Harbors ARD 069 748 192
Heritage OHD 980 613 541
Chem Waste Mgmt. ALD 000 622 464
> Accumulation Areas: The satellite area near the Nafibn Polymers area was
observed during the inspection. In this area, three separate waste streams are
managed in three separategallon drums. Each drum has its own secondary
containment 1 distinguishes each Johnson,
Dianne Fields and I discussed the interpretation of the rule and decided that the
containers should be treated as a 90 day storage area if at all possible to avoid
violation of the <55 gallons
DEQ-CFW 00042522

'DuPont EPA I.D. # NDC 047 368 642
CEI Report, page 3
A Storage Areas: Waste is stored in four subpart J units, in containers on the
permitted pad and in an ISO container. All of these areas were inspected and no
violations were observed.
➢ External Condition of Facility: No adverse conditions noted.
. WASTE MINIMIZATION: Source Reduction
10. SITE DEFICIENCIES:
40 CFR 262.34 (a) Except as provided in paragraphs (d), (e), and (f) of this section, a generator
may accumulate hazardous waste on -site for 90 days or less without a permit or without having
interim status, provided that: (4) The generator complies with the requirements for owners or
*perators in Subparts C and D in 40 CFR part 265, with §265.16, and with 40 CFR 268.7(a)(5).
40 CFR 265.16(c) Facility personnel must take part in an annual review of the initial
training required in paragraph (a) of section 265.16.
.�._ DATE:28 April 2009
Robert K. Nelms
Environmental Senior specialist, NCDENR
Facility Representative
DATE: „ April 2009
DEQ-CFW 00042523

Waste Management Division
Hazardous Waste Section
NOTICE OF VIOLATION
To: DuPont Fluoroproducts Docket# 2009-
22828 NC Highway 87 West Inspection Date: 28 April 2009
Fayetteville, NC 28306-7332 Facility Type: LQG/TSDF
EPA ID # NCD 047 368 642
*n December 18, 1980, The State of North Carolina, Hazardous Waste Section (State)
was authorized to operate the State RCRA hazardous waste program under the Solid
Waste Management Act (Act), N.C.G.S. 130A, Article 9 and rules promulgated thereto at
15A NCAC 13A (Rules) in lieu of the federal RCRA program.
On 27 April 2009, Robert K. Nelms, representing the N.C. Hazardous Waste Section,
inspected your facility for compliance with North Carolina Hazardous Waste
Management Rules. During that inspection, the following violations were noted.
40 CFR 262.34(a) - 265.16(c) Except as provided in paragraphs (d), (e), and (f) of this
section, a generator may accumulate hazardous waste on -site for 90 days or less without a
permit or without having interim status, provided that: (4) -fhe generator complies with
the requirements for owners or operators in Subparts C and D in 40 CFR part 265, with
§265.16, and with 40 CFR 268.7(a)(5).
265-16(c) Facility personnel must take part in an annual review of the initial
training required in paragraph (a) of section 265.16.
You are hearby required to comply with the noted violations by 9 January 2005, at which
time a reinspection will be performed. If compliance with the violations noted above are
not met, pursuant to N.C.G.S. 130A-22(a) and 15A NCAC 13B .0701-.0707. an
administrative penalty of up to $32,500 per day may be assessed for violation of
hazardous waste law or regulations.
2 141-011114<71
(Date) Robert K. Nelms
Environmental Senior Specialist
Hazardous Waste Section, NCDENR
Copies to: File
Ted Cashion - Eastern Area Compliance Branch Supervisor
Central Files
DEQ-CFW-00042524

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
Name: DuPont Floroproducts
EPA ID Number: NCD 047 368 642
Type of Facility: Large Quantity Generator
Facility Location: 22828 NC Hwy 87 West
Fayetteville, NC 28306
Telephone Number: [phone]
2. FACILITY CONTACT: Mike Johnson
3. SURVEY PARTICIPANTS: Mike Johnson
Bobby Nelms - NCDENR
5. PURPOSE OF EVALUATION: Follow-up inspection to determine the status of the
compliance schedule given in the Notice of Violation, Docket # 2009-075. The NOV was issued
subsequent to the RCRA inspection conducted on 27 April 2009.
im
NXIN Me
AREAS RE -INSPECTED DURING EVALUATION:
(OK = previous deficiency corrected; V = violation observed; NA = not applicable to this inspection)
Contingency Plan = N/A
Personnel Training Records = OK
Accumulation Areas = N/A
Storage Areas = N/A
Inspection Logs = N/A
Manifests = N/A
OTHER = N/A
(over)
DEQ-CFW-00042525

8. PREVIOUS VIOLATIONS / DEFICIENCIES:
Violation(s) previously cited pertained to the following regulation(s):
40 CFR 262.34(a) - 265.16(c) Except as provided in paragraphs (d), (e), and (f) of this section, a
generator may accumulate hazardous waste on -site for 90 days or less without a permit or
without having interim status, provided that: (4) The generator complies with the requirements
for owners or operators in Subparts C and D in 40 CFR part 265, with §265.16, and with 40 CFR
268.7(a)(5).
265.16(c) Facility personnel must take part in an annual review of the initial training
required in paragraph (a) of section 265.16.
111111111111",
DuPont Floroproducts is in compliance with the requirements of the Notice of Violation
docket # 2009-075.
11111_111Z'14�z_ DATE: Emailed to Mike Johnson DATE:
Bobby Nelms Facility Representative
Environmental Senior Specialist, NCDENR
DEQ-CFW-00042526