DEQ-CFW_00050488

From: [e-mail] [[e-mail]]
Sent: 4/4/2014 3:02:34 PM
To: Henson, Belinda [/o=NCMAIL/ou=Exchange Administrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=belinda.henson]
CC: [e-mail]
Subject: RE: Hexachlorobenzene Analytical Method
Thank you for following up with Dana on this question.
Based on Dana's last sentence, is it a correct interpretation that for us to comply with the requirement of our
NPDES Permit, Method 612 is the required method for hexachlorobenzene?
If so, since the ESC Laboratory (Mt. Juliet, TN) is not certified to run Method 612, then another NC -approved
lab would have to be located that is certified to run Method 612.
Let me know if you agree with my interpretation of Dana's note.
Thanks,
Mike
Michael E. Johnson
Environmental Manager
DuPont Company — Fayetteville Works
[phone]
From: Henson, Belinda [mailto:[e-mail]]
Sent: Friday, April 04, 2014 10:43 AM
To: 3ohnson, Michael E
Subject: FW: Hexachlorobenzene Analytical Method
Fyi
From: Satterwhite, Dana
Sent: Friday, April 04, 2014 10:12 AM
To: Henson, Belinda
Subject: RE: Hexachlorobenzene Analytical Meth]
Hi Belinda,
Sorry for the delayed response. The first fork in the road (as Mr. Johnson alluded to) is that since it is for NPDES
monitoring, it must be a Clean Water Act approved method in 40 CFR Part: 1.36. The methods Mr. Johnson listed from
Table IC are accurate with the clarification that the Standard Method should be the 2000 version of 6410 B.
DEQ-CFW-00050488

In general, GC methods (et.€ ., EPA Method 6 2) are more sensitive than CC:/MS methods (e.g., 525, 152513, 5410 13-2000),
but with newer instruments, this is not: always the case. However, for a chlorinated pesticide, I believe it is. As an
example, the VIDLs listed in methods 612 and 625 are 0.05 ppb and 1.9 ppb, respectively. So, it appears that the most
sensitive CWA approved method would be the GC method, EPA 512.
Dana
Dana Satterwhite
Environmental Program Supervisor III
NC: WWGW laboratory Certification Unit
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NC: DEI R/Division of Water Resources
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From: Belinda
Friday,1 . '
To: Satterwhite, Dana
Subject: FW: Hexachlorobenzenet - s•
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
Michael.E.Johnson,@dupont.comr o' . ro •
Friday,i ' l '• .
To: Henson, Belinda; Brantley, Mark
Cc: [e-mail]
Subject: Hexachlorobenzene Analytical Method
Belinda and Mark:
DEQ-CFW 00050489

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 (ESQ 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.
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 (GUMS method)
EPA Method 1625B (GC/1\4S method)
Std Method 6410 B (GUMS 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
DEQ-CFW-00050490

Michael E. Johnson
Environmental Manager
DuPont Company — Fayetteville Works
[phone]
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DEQ-CFW-00050491