DEQ-CFW_00046241

Hazardous Waste Section
�-F-r �-vr
1. Identification:
Fill out form completely and accurately before sendinc j it to File Room
----------
Larry Stanley
--------- --------------
Print Your Name Above (Last, First)
101
8 6 4 2 U N C D 0 4 7 3 6
. . ......... .
Du Pont- Fayettevi Ile Works
111. Document Type:
- t�L�fiqht, check o!CjDM=
Document Type below
General (G)
Permit (P)
Corrective Action (A)
11 Notification 8700 (8700)
1-1 Part A Application (PA)
LJ Corrective Action Information (CAI)
11 Hazardous Waste Report (HWR)
Ll Part B Application (PB)
11 RCRA Facility Assessment (RFA)
El Fees/invoices (F)
11 Notice of Deficiency (NOD)
F1 Confirmatory Sampling (CS)
-1 Technical Assistance (TA)
El Permitting Information (PI)
El PXM&f;adft Investigation (RFQ
11 Compliance Assistance Visit (CAV)
El Alternative to Post -Closure Permit (APQ
D Interim Measures Study/Plan/implemented (IM)
E Correspondence (C)
'__1 Modification (MOD)
0, Corrective Measure Plan/Design (CMP)
F1 Other (0)
E Correspondence (C)
E Land Use Restriction, Institutional Controls (LUR)
F-1 Other (0)
r-i Remediation System Effective Reports (RSER)
0 Corrective Measures Study (CMS)
Closure (C)
Groundwater (W)
Ll Closure information (Cl)
F1 Groundwater Monitoring Report (GMR)
Ll HSWA Remedy (HSWA)
E Closure Plan (CP)
Ll Comprehensive Monitoring Event (CME)
11 Environmental Indicators (EI)
Ll Closure Report/Certification (CR)
11 Correspondence (C)
El Correspondence (C)
D Correspondence (C)
D Other(0)
F1 Other (0)
Other (0)
Financial (F)
Inspection/investigation (1)
Enforcement (E)
11 Financial Record Review (FRR)
Ei Complaint Investigation (CMP)
0 Ticket Notice of Violation (TNOV)
D Mechanisms and instruments (MI)
11 Compliance Evaluation Inspection (CEI)
11 Notice of Violation (NOV)
F1 Financial statements (FS)
1-1 Case Development Inspections (CDI)
L Immediate Action Notice of Violation (IANOV)
D Balance sheets (BS)
Ll Compliance Schedule Evaluation (CSE)
El Enforcement Package (EP)
El Tax returns (TR)
F1 Focused Compliance Inspection (FCI)
Ll Compliance Order (CO)
El insurances (1)
E Sampling Event (SPQ
11 Administrative Order on Consent (AOC)
11 Correspondence (C)
-1 Emergency Response (EMR)
[I Settlement Agreement (SA)
C Other (0)
'❑1 Correspondence (C)
11 Correspondence (C)
I
E Other (0)
E Other (0)
Miscellaneous (M)
Ill. Description:
Use up to 256 characters to describe the document. Every word below can be used as a searchable index to locate the document
NOD for Phase Ill RFI work plan A"
......... .. ..................... . ­­­­ ............... ­­­ . . ....... . ..... . ........ .. . ............
IV. Date of Document: Date when the document generated, the date typed or printed on the front page of doMonth I ❑ay ;Year
cument
Date on Docu n 05
V. File Boo
Hazardous Waste Section Updated: 1010612010 File Room Document Transmittal Sheet (Form: LK-600)
DEQ-CFW-00046241

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Waste Management
Dexter R. Matthews Dee Freeman
Director Secretary
January 5, 2011
Mr. Jarnie A. VanBuskirk
Project Director
DuPont Corporate Remediation Group
6324 Fairview Road
Charlotte, NC 28210
Re: NOD for Phase III RCRA Facility Investigation Work Plan
DuPont Fayetteville Facility
Fayetteville, NC
EPA ID # NCD 047 368 642
Dear Mr. VanBuskirk:
The North Carolina Hazardous Waste Section (HWS) has reviewed Phase III RCRA
Facility Investigation Wark Plan. Due to technical questions raised by this review, the HWS has
concluded that the document does not constitute an acceptable work plan and is issuing this
Notice of Deficiency (NOD). Comments intended to aid with revisions to the plan are listed
below.
Section 1.1.2
Regulatory History
1) In September 2005, Dexter Matthews, who is Director of the NC Division of Waste
Management (D WM), indicated in a letter to Michael E. Johnson that C-8 releases to
groundwater and soil at the Fayetteville Works would be addressed under a RCRA permit issued
by DWM. In a similar letter, DENR's Assistant Secretary for Planning and Policy, Robin W.
SBnith, communicated this information to the C8 Working Group. Copies of the letters are
attached to these comments.
Section 2.3.3
SWMU 9A &_B — Former Wastewater Treatment Lagoons
2) The work plan indicates that the concentrations of bromoform and dibromochloromethane in
groundwater samples collected at monitoring well MW-1 I exceeded the NC 2L Groundwater
1646 Mad Service Center, Raleigh, North Ca,ohna 27699-1646
Ph one 919 508-840" i FAX: 91 + 715-4061 ,'Internet. ww write;)otnc.org
k Dqud Gpper' r,4y . A` ra'; e Act n - rpbyer
DEQ-CFW 00046242

Mr. Vansbuskirk
Page 2
January 5, 2011
Standards for these compounds. DuPont did not discuss (a) the constituents' fate and transport,
(b) their horizontal and vertical extent in groundwater, or (c) the possibility of a source for the
compounds other than SWMU 9. The HWS believes the concerns mentioned in this comment
should be addressed in the work plan.
Section 3. 1.1
Existing Information and Identified SCM Data Gaps
3) Mounding of the water table caused by SWMUs 21 A & B (River Water Sediment Retention
Basins) is a major influence on the transport of contaminated groundwater at the DuPont -
Fayetteville site. Eventually these basins will be taken out of service, and the groundwater
system will return to steady-state conditions. DuPont -Fayetteville should predict the fate and
transport of hazardous waste and/or hazardous constituents in groundwater as the transient
stresses imposed on the aquifer system by the basins are removed.
.Section 3.4
Comp
lete. gation of TPH at the Site
4) Groundwater samples collected for the purpose of determining TPH impacts should be
analyzed for hydrocarbons by the Massachusetts (MADEP) methods. The samples should also,
as proposed in the work plan, also be analyzed for specific TPH-related constituents.
Section 3.5
Conduct Site -Wide Groundwater Monitoring
5) A table that summarizes SWMU-specific and site -wide groundwater constituents of concern
(COCs) should be added to the work plan.
Section 4.1
Field Investigation Methodologies
6) DuPont should discuss Stage I investigations in more detail. Information such as the most
likely geophysical techniques to be used in a specific area and the placement of geophysical
surveys (locations and number of lines or grids) should be discussed, even if the proposed tasks
are tentative. Once details of the Stage I investigation are finalized, DuPont should
communicate this information to the HWS before field operations begin.
DEQ-CFW-00046243

Mr. Vansbuskirk
Page 3
January 5, 2011
Section 4.2.5
Soil Sampling Methodology
7) Soil samples that will be analyzed for volatile organic compounds (VOCs) should not be
homogenized during collection. Samples that have been mixed or homogenized may exhibit
decreased concentrations of volatile compounds and as a result, may not be representative of the
impacts to soil. The recommended method of sample collection is with a small coring tool (for,
example, an Encore sampler), but any method that efficiently transfers the soil sample to a
laboratory -supplied collection bottle is acceptable.
Section 6.3.2
Waste Management Plan
8) As with any corrective action activity that generates significant quantities of waste, the HWS
would like to receive a copy of the site -specific waste management plan before remedial
activities are implemented.
DuPont-CRG should submit three copies of responses to comments and/or a revised work
plan within ninety (90) days of the receipt of this letter. If your office has questions concerning
this correspondence, please call me at [phone].
Sincerely,
Larry Stanley
NC Hazardous Waste Section
Enclosures
cc: John Johnston, US EPA, Region IV
Mike Johnson, DuPont Fayetteville Works
Bobby Nelms
Larry Stanley
re: Bud McCarty
Vance Jackson
N' Carl Utterback,i,_767
Larry Stanley Fop�
DEQ-CFW-00046244

I � I I
Nodlh Carohna
A1LrTiz_Wa*Wj
NCDENR,
DO�D,�]ntrnent of Environment and
Division of Waste klanagenierit
September 23, 2005
Mr. Michael E. Johnson
Envirom-nental Manager
DuPont Fluoroproducts — Fayetteville Works
22828 N.C. Highway 87W
Fayetteville, NC 28306-7332
Dear Mr. Johnson:
Naturcal ReSOUI'N'S
V
G� sel,(:
The purpose of this letter is to follow-up on our meeting of August 5, 2005
concerning the DuPont Fayetteville Works RCRA pen -nit and the C-8 levels that have
been found in groundwater and surface water samples taken at the site. As we discussed,
RCRA provides the State broad authority to incorporate into permits any terms and
conditions deemed necessary to protect human health and the environment. In addition,
15A NCAC 02L establishes groundwater quality standards for the State, and also
regulates contaminants where no specific 2L standard exists.
As acknowledged in our meeting, C-8 releases to groundwater and soil at the
Fayetteville Works facility will be addressed under the Division of Waste Management's
RCRA pen -nit. As you are aware, Larry Stanley is managing the Corrective Action
program under the permit and all documents relating to the C-8 sampling program should
be sent to his attention.
zSincer
Dexter R. Matthews
cc: Larry Stanley
Karim Pathan
Elizabeth Cannon
O
-d eMof, IR 1 i,, No,;
'A
�o
b
x U
DEQ-CFW-00046245

ffl��030"Zzgl
A4
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
September 23, 2005
C8 Working Group c/o
Ms. Hope Taylor -Guevara
Clean Water for North Carolina
2009 Chapel Hill Road
Purham, N.C. 27707
Dear Hope:
William G. Ross Jr,, Secretary
Enclosed please find a copy of the letter from Dexter Matthews to Michael E.
Johnson, Environmental Manager at DuPont's Fayetteville Works, The letter confirms
that any C8 releases to groundwater and soil at the facility will be addressed under the
RCRA permit.
The Department has also talked with DuPont about the need for installation of
additional groundwater monitoring wells (particularly around the APFO facility) as well
as surface water sampling and soil tests. DuPont will submit a workplan for DENR's
review and approval as required by RCRA.
It may be a good idea for us to give you all an update in mid -October.
Robin W. Smith, Assistant Secretary
Planning and Policy
Cc: Dexter Matthews
One
1601 Mali Service Center, Raleigh, North Carolina 27699-10601 NofthCarohna
Phone- 919-733-4984 \ FAX: [phone] \ Internet: www.enr.state,nc,us/ENR/ Naturally
An Equal Opportunity / Affirmative Action Employer - 50 % Recycied1 10 % Post Consumer Paper
DEQ-CFW-00046246