DEQ-CFW_00050480

From: Henson, Belinda [/O=NCMAIL/OU=EXCHANGE ADMINISTRATIVE GROUP
(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BELINDA.HENSON]
Sent: 3/28/2014 4:26:11 PM
To: Brantley, Mark [/o=NCMAIL/ou=Exchange Administrative Group
(FYD1 BO H F23SPDLT)/cn=Recip ients/cn =mark. bra ntl eyl]
Subject: FW: Hexachlorobenzene Analytical Method
Attachments: Method_608.pdf
Fyi
From: Henson, Belinda
Sent: Friday, March 28, 2014 12:26 PM
To: Satterwhite, Dana
Subject: FW: Hexachlorobenzene Analytical Method
Dana,
Please review the attached email and give us guidance on what EPA Method Dupont should be using for
hexachlorobezene in the effluent. Thank You for YOUr assistance for this.
Belinda
From: Michael. E.Joh [e-mail] [ma i Ito: Michael. E.Joh nson @d u pont.corn]
Sent: Friday, March 28, 2014 1049 AM
To: Henson, Belinda; Brantley, Mark
Cc: Jarnie.R.Lewis_0d_dup tcorn
Subject: Hexachlorobenzene Analytical Method
Belinda and Mark:
This note is a continuation of a telephone conversation I had with you (Belinda) last week regarding the
appropriate or required analytical method for hexachlorbenzene and is a request for some guidance on the
appropriate analytical method for that compound.
Our NPDES Permit has the following requirement under the list of the OCPSF priority pollutants:
" The most sensitive analytical method available shall be employed for determining the presence of
hexachlorobenzene in the effluent. "
In 2013 the commercial lab (ESC) analyzed this compound using EPA Method 608 titled
"ORGANOCHLORINE PESTICIDES AND PCBS" which, as the title suggests, is for a number of
pesticides and PCBs (see attached pdf titled "Method_608"). In 2012 the lab used EPA Method 8270, which is
a solid waste method.
DEQ-CFW-00050480

According to 40 CFR 136 Table IC, which is the list of approved test procedures for non -pesticide organic
compounds, the EPA -approved methods for hexachlorobenzene in water are:
EPA Method 612 (GC method)
EPA Method 625 (GC/MS method)
EPA Method 1625B (GC/1\4S method)
Std Method 6410 B (GC/MS method)
I contacted our commercial lab (TBL) and received the following response from Pam Hester:
"As in 2013 , 608 was used and "is the most sensitive analytical method" for Hexachlorobenzene with a detection
limit of 0.00005 mg/L. Your permit does not specify a method only that the method be the most sensitive . 600
series are for wastewater. 8270D was chosen in 2012, the update from 8270C which was the method that Dupont's
Hexachlorobenzene was analyzed by in at least two prior years , dating back to 2009 . ESC does not do nor is
certified by 612 . I've not ever had a request for 612 at TBIL , so I would have to outside of my normal sub lab
network to find a lab that was certified for it.
"From this point going forward , I would ask for Dupont to advise me if it wants a confirmatory method or a desired
reporting limit. The COC should include a method request for the compound Hexachlorobenzene, which has not
been the case in the past."
While Method 608 might be a sensitive method, the fact that it is not identified as an EPA approved method for
hexachlorobenzene is concerning to me and might not be viewed as acceptable to WQP.
I am asking NCDENR DWR WQP for some guidance as to the correct analytical method(s) that should be
specified for the hexachlorobenzene analysis.
I believe Jamie Lewis normally takes the annual sample for hexachlorobenzene during the summer, so there is
not a urgent need for this answer.
Thank you in advance for any assistance you can provide with this question.
Mike
Michael E. Johnson
Environmental Manager
DuPont Company — Fayetteville Works
[phone]
This communication is for use by the intended recipient and contains
information that may be Privileged, confidential or copyrighted under
applicable law. If you are not the intended recipient, you are hereby
formally notified that any use, copying or distribution of this e-mail,
in whole or in part, is strictly prohibited. Please notify the sender by
return e-mail and delete this e-mail from your system. Unless explicitly
and conspicuously designated as "E-Contract Intended", this e-mail does
DEQ-CFW-00050481

not constitute a contract offer, a contract amendment, or an acceptance
of a contract offer. This e-mail does not constitute a consent to the
use of sender's contact information for direct marketing purposes or for
transfers of data to third parties.
The dupont.com web address will continue in use for a
transitional period for communications sent or received on behalf of DuPont
Performance Coatings., which is not affiliated in any way with the DuPont Company.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
htt.i)://www.DuPont.com/coi-i)/email disclainier.html
DEQ-CFW-00050482