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HomeMy WebLinkAboutDEQp00020698September 22, 2017 VIA EMAIL William F. Lane, Esq. General Counsel NC Department of Environmental Quality 217 West Jones Street Raleigh, NC 27603 ROBINSON BRADSHAW sdogeorge@robinsonbradshaw.com 704.377.8380 : Direct Phone 704.373.3980 : Direct Fax Francisco J. Benzoni. Esq. Assistant Attorney General NC Department of Justice 114 W. Edenton Street Raleigh, NC 27603 Re: Chemours' Fifth Response to DEQ's September 10, 2017 List of Priority Requests Dear Messrs. Lane and Benzoni: On behalf of The Chemours Company FC, LLC ("Chemours"), this letter and enclosed materials are submitted in response to DEQ's September 10, 2017 request that Chemours prioritize certain of DEQ's pending requests for information related to Chemours' Fayetteville facility ("Fayetteville Works").' Chemours has enclosed its second progress report under the sampling plan it submitted to DEQ on September 15, 2017. See CH -FW -DEQ -0057829 to CH -FW - DEQ -0057830. Chemours is available to discuss this progress report during the call scheduled with DEQ for this afternoon. We look forward to continuing to work with DEQ and the Attorney General's office cooperatively on this matter and receiving DEQ's confirmation of its availability for the weekly sampling plan teleconferences Chemours has requested. If you have any questions about this submission, please let me know. Sincerely, ROBINSON, BRADSHAW & HINSON, P.A. R. Steven DeGeorge 1 This submission supplements Chemours' August 4th, August 18th, August 25th, September 1st, September 12th, September 14th, September 15th, September 18th responses to DEQ. ROBINSON, BRADSHAW & HINSON, P.A.: robinsonbradshaw.com Charlotte Office : 101 N. Tryon St., Ste. 1900, Charlotte, NC 28246 : 704.377.2536 September 18, 2017 Page 2 Enclosures cc: Linda Culpepper DEQ Evelyn Brantley The Chemours Company, FC LLC John Savarese Wachtell, Lipton, Rosen & Katz Ralph Levene Wachtell, Lipton, Rosen & Katz Lester Sotsky Arnold & Porter Kaye Scholer Joel Gross Arnold & Porter Kaye Scholer M . f PROGRESS REPORT #2 Date: September 22, 2017 To: North Carolina Department of Environmental Quality ("DEQ") From: The Chemours Company FC, LLC ("Chemours") Re: Wastewater Sampling Plan - Progress Report #2 I. INTRODUCTION On September 15, 2017, Chemours submitted to DEQ a Sampling Plan for Chemours' Fayetteville, North Carolina facility ("Fayetteville Works") to respond to DEQ's request for certain wastewater sampling. This is Progress Report #2 under the Sampling Plan. Chemours intends to continue to provide additional progress reports to DEQ on a periodic basis as additional data and information becomes available. II. REMAINING ANALTICAL RESULTS FOR TABLE 1 COMPOUNDS Pursuant to the Sampling Plan, this week Chemours began providing DEQ the remaining Phase 1 Sample Set results for the Table 1 compounds as follows: 1. In Progress Report #1 (submitted September 19th), Chemours provided DEQ results for the Table 1 compounds from a September 13, 2017 sample collected from the Common Waste Tank. 2. Chart 1 below provides preliminary results for HFPO Dimer Acid, PFOA, and PFOS from samples collected from Outfalls 001 and 002 on September 13, 2017. Please note that these results are preliminary (i.e., we have not completed the standard QA/QC process) and are in addition to the Outfall 002 results Chemours previously provided DEQ. CHART 1 -PRELIMINARY RESULTS Outfall 001- Sample Collected 9-13-2017 ANALYSIS PRELIM. RESULT UNITS HFPO Dimer Acid 0.42 ug/L PFOA 0.020 ug/L PFOS <0.0020 ug/L Outfall 002 - Sample Collected 9-13-2017 ANALYSIS PRELIM. RESULT UNITS HFPO Dimer Acid 0.064 ug/L PFOA 0.015 ug/L PFOS 0.012 ug/L 1 of 2 CH -FW -DEQ -0057829 3. Chart 2 below provides results for Table 1 compounds from a sample collected from the Cell Lab Effluent on September 13, 2017. Please note that some of these results are preliminary (i.e., we have not completed the standard QA/QC process) and are in addition to the Cell Lab Effluent data results Chemours previously provided DEQ, including the HFPO Dimer Acid result of 0.99 ug/L from a July 19th sample that Chemours provided to DEQ by letter dated July 28, 2017. CHART 2 -Cell Lab Effluent - Sample, Collected,: September 13, 2017 ANALYSIS RESULT UNITS HFPO Dimer Acid 0.091 (preliminary result) ug/L PFOA 0.0024 (preliminary result) ug/L PFOS 0.0029 (preliminary result) ug/L Total Suspended Solids 37.6 mg/L Chemical Oxygen Demand 5,920 mg/L Antimony <0.020 mg/L Arsenic <0.020 mg/L Beryllium <0.020 mg/L Cadmium <0.020 mg/L Chromium 0.454 mg/L Copper 0.021 mg/L Lead <0.020 mg/L Nickel 0.129 mg/L Selenium <0.020 mg/L Siver <0.020 mg/L Thallium <0.020 mg/L Mercury <0.0002 mg/L Zinc <0.10 mg/L With this Progress Report #2 and consistent with the September 15th Sampling Plan, Chemours believes that it has completed its response for the Table 1 compounds for the Phase 1 Sample Set. 2 of 2 CH -FW -DEQ -0057830