DEQ-CFW_00050564

From: K8ichaei[[e-mail][yWichaeiEJohneon4pdupont.com]
Sent: 6/I7/20141223:I2PyW
To: Satterwhite, Dana [/o=NCMA]L/ou=ExchanXeAdministrative Group
(FYD|BOHFI]3PDLT)/cn=Kecipients/cn=dana.sattenwhite]
CC: Henson, Belinda [/h=NCMA|L/ou=ExchangeAdministrative Group
(FYDIBOHF23SPDLT)/cn=Recipients/cn=belinda.henson]; Brantley, Mark [/o=NCMAlL/ou=Exchange Administrative
Group (FYD|8OHFZ33PDLT)/cn=Redpient$cn=mark.bra nt|eyI];]amie.Rlewis@dupontzom
Subject: RE: Hexach|orobenzeneAnalytical Method
Thank you for your response and the news that onlab iuNC iucertified for method bl2. That iswhat lwas
discovering as I tried to find a lab.
Weuse ESCfor all ofthis site's volatile organics analyses and they are certified for Method b25. Since your
attached note indicates that Method 625 is the next best method forhexochlorohenzcnc, and l um assuming that
it would satisfy our NPDES Permit requirement of employing "the most sensitive analyticalznothodnvailahln",
then wewill just specify that ESC use Method 025 for our annual analysis of hexachlorobonzenc.
Therefore you donot need to have someone query the NC-LCB database for alab.
Thank you again.
MiohaelB. Johnson, PE
Environmental Manager
DuPmuCmnpany—FaycttcvUcWorka
To: 3ohnson, Michael E
Cc: Henson, Belinda
Subject: RE: Hexachlorobenzene Analytical Method
Hi Michael,
I got your voicemail message and I am terribly sorry I overlooked responding to this email, I had someone query our
database and we do not currently have anyone certified for EPA Method 612. 1 will have Nick query the database
tomorrow for labs certified for EPA Method 625 for you and send it: to you, This would be the next best: available
technology.
Dana Satterwhite

Environmental Program Supervisor III
NC WW/(;W Laboratory Certification Branch
0: [phone] ext. 243
F: (919) 733-67.4J.
NC DENR/Mvis� on of Water Resources
Water Sciences :Section
1623 Mail Service Center
Raleigh, NC 27699-1623
http://portal.ncdenr.org/web/­­wq/­­lab/­`cert
Have you signed up to receive automatic email notices of changes to policies, regulations and resources pertaining to the NC
Wastewater/Groundwater Laboratory Certification program that could have an impact on your day-to-day operations" If not,
send a blank email to the following address:
DENR.DWQ.Lab [e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third
parties unless the content is exempt by statue or other regulation.
Michael.E.Johnson,@dupont.comr: Michael. E.Joh nson• U •o•
Sent: Wednesday, May 14, 2014 8:30 AM
To: Satterwhite, Dana
Henson,.Brantley,
Subject: RE: Hexachlorobenzene Analytical Method
This is a follow-up to your attached email which confirms that our annual analysis for hexachlorobenzene needs
to be done using EPA Method 612.
Our North Carolina commercial lab and our DuPont analytical support group have both been unsuccessful in
finding a NC certified laboratory that is approved to run Method 612. The following is the response I received
from my DuPont analytical contact:
"Compuchem confirmed that they do not run 612 - it's an older gas chromatography method, and not one
that we come acrossoften.does not run it either, bcanut e e d Pace to
easterncheck their •/ (possibly Y' • . •
I assume that there is at least one NC lab out there that does run Method 612 and is approved by your unit to run
that method.
Would it be possible for you or someone in your unit to send me a list of certified laboratories that are approved
to run Method 612?
Thank you for any assistance you can provide.
Mike
Michael E. Johnson
Environmental Manager
DuPont Company — Fayetteville Works
[phone]
DEQ-CFW 00050565

From: Henson, Belinda
w
Friday, April 04, 2014 t t
L: 3ohnson,Michael
Subject: ! ob :o
Fyi
From: .
Sent: Friday, April 04, 2014 10:12 AM
To: 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 `lean Water Act approved method in 40 CFR Bart 136. The methods Mr. Johnson listed frorn
Table IC are accurate with the clarification that the Standard Method should be the 2000 version of 64-10 B.
In general, CC methods (e.g., EPA Method 612) are more sensitive than GC/MS methods (e.g., 525, 162513, 6410 B-2000),
but with newer instruments, this is not always the case, However, for a chlorinated pesticide, I believe it is. As an
example, the MDLs listed in methods 612 and 625 are 0.05 ppb and 1.9 ppb, respectively. 8o, it appears that the most
sensitive CWA approved method would be the CC method, EPA 512.
Dana
Dana Satterwhite
Environmental Program Supervisor III
NC WW/GW Laboratory Certification Unit
0: [phone] ext. 243
F: (91.9) 733-6241.
NC DENR/Division of Water Resources
Water .Sciences Section
1623 Mail Service Center
Raleigh, NC 27E139-1623
http://portal.ncdc,nr.org/web/wq/lab/cert
Have you signed cep to receive automatic email notices of changes to policies, regulations and resources pertaining to the NC
Wastewater/Groundwater Laboratory Certification program that could have an impact on your day-to-day operations? If not,
send a blank email to the following address-
DENR.DWQ.Lab_Cert-joinC7a lists.ncmail.net
Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Henson,- ..
Friday, March 28, 2014• PM
L Dana
• : ! obMethod
DEQ-CFW 00050566

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.Johnson,@dupont.com [ma i Ito: Michael. E.Joh nson @d u pont.com]
Sent: Friday, March 28, 2014 10:49 AM
To: Henson, Belinda; Brantley, Mark
Cc: Jamie.R.LewisCa)dupont.com
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 (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 (GC/MS method)
EPA Method 1625B (GUMS 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 mg1L. 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
DEQ-CFW-00050567

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
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
llttD://www.DuPotit.Com/Corte/ernail disclainier.html
This communication is for use by the intended recipient and contains
information that may be Privileged, confidential or copyrighted under
DEQ-CFW-00050568

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
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
littp://www.DuPorit.com/corp/email disclaimer.html
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
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 http://dupont.com web address may be used for a limited period of time by the following
divested businesses that are no longer affiliated in any way with DuPont:
Axalta Coating Systems
Kuraray Co., Ltd
DuPont accepts no liability or responsibility for the content or use of communications
sent or received on behalf of such divested businesses or for the consequences of
any actions taken on the basis of such communications.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
http://www.DuPont.com/corp/email—disclaimer.html
DEQ-CFW-00050569