DEQ-CFW_00070901

Ghiold, Joe
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From: GARON, KEVIN P <[e-mail]>
Sent: Friday, July 07, 2017 3:28 PM
To: Ghiold, Joe; JOHNSON, MICHAEL E; HARTTEN, ANDREW S
Cc: Ovbey, Tracy
Subject: Chemours Fayetteville Works CMS request
Joe, ZoIS
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As described in the CMS work plan, the project team for the C emours Fayetteville Works site recently collected
sampling data from monitoring well LTW-05. This samples s collected to confirm an earlier concentration of 11
pg/L of PFPe� A (C-5) that was detected in the well in 2015. Chemours has received the results of this sampling, and
the results indicated a concentration of 2.9 pg/L of PFPeA in the well (the duplicate sample = 3.8 pg/L). The
Parsons field team then returned to the site on Thursday, June 151h to collect several additions samples to confirm
the earlier results. The team collected samples from monitoring w lis LTW-04 and LTW-05, along with an effluent
sample from the site's outfall (we have not received these results as of the time of this note).
A Fayetteville Works site chemist believes that PFPer A (C_5) was potentially discharged in the site's final effluent until
2013 when a process change was installed, and the June 15th sampling will confirm the C-5 compound is no longer
present in the final effluent.
Due to this re -sampling effort, along with the sampling for additional compounds that you requested last week (in an
email to the plant Environmental Manager, Michael Johnson), we are requesting a delay in the completion of the
CMS and associated report as we collect more data. The current schedule (as presented in the work plan) calls for
the submittal of the CMS Report three months after receipt of the final analytical data from the initial sampling. The
project team would like to also include the re-sampling/additional sampling data in the CMS evaluation. Once the
additional sampling has been completed and all of the final analytical data has been received, Chemours will work
with NCDEQ to develop an appropriate revised schedule for completion of the CMS/CMS Report.
Please let me know if you have any questions about our proposed path forward.
Respectfully submitted,
Kevin
Kevin P. Garon t
Principal Project Director
Chemours Corporate Remediation / •�r
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704-560-6435
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DEQ-CFW 00070901

CLIP"" AI Fitt4 f
CORRECTIVE MEASURES STUDY WORK PLAN4� CURRENT SITE CONCE TUAL MODEL
applicable RSLs. However, the NCDENR (now NCDEQ) indicated that, in order to
compare arsenic concentrations in soil to background concentrations, the project team
must collect site -specific background soil samples and calculate site -specific background
levels. As requested and to confirm the risk determination, site -specific background soil
samples will be evaluated as part of the CMS.
In 2015, six soil borings were advanced in the wooded area southwest of the
manufacturing area in order to collect background soil samples to meet other facility
objectives. Two samples were collected from each boring (one from surface to 1 foot
and another from 4 feet to six feet bgs). The samples were submitted for laboratory
analysis of inorganics including arsenic. During the CMS, these new analytical data will
be used to calculate background concentrations of arsenic for surface (0 to 1 foot bgs)
and subsurface (4 to 6 feet bgs) soil. The concentrations will be calculated using the
USEPA ProUCL software. If the analysis determines that more than the existing six
samples are required, additional soil borings will be collected in another undeveloped
area of the Site.
2.4.2 Additional Groundwater Investigation
In 2005, surface water samples were collected from the Cape Fear River during an
investigation conducted by a third -party. Results of the 2005 sampling event showed an
increase in concentrations of several compounds, including perfluoropentanoic acid
(�, from a spot on the river just north of the Site to a spot on the river adjacent to the
Site's river water intake. The NCDEQ suggested that these compounds could potentially
be present in groundwater that may have been traveling beneath Willis Creek from the
Site and discharging into the Cape Fear River or in aquifer water discharging to Willis
Creek and then to the River. Therefore, after completion of the RFI activities, the
NCDEQ requested supplemental groundwater sampling to confirm that the
concentrations that were detected in the river were not indicative of releases from the
Site via groundwater discharge
Although these compounds were not likely to be a result of site activities, supplemental
groundwater sampling was conducted in 2015 to gather additional data from a selection
of monitoring wells near Willis Creek and the Cape Fear River. The results of these
sampling activities confirmed that the concentrations detected in the River near the river
water intake were not a result of site activities. However, one sample collected from
monitoring well LTW-05 several thousand feet south of the river water intake had a
detection of C5. To further investigate this analytical result, an additional groundwater
sample will be collected from this well and will be submitted for laboratory analysis of C5
in accordance with the procedures presented in the Supplemental Sampling Work Plan
Technical Memorandum (Parsons 2015).
PARSONS
DEQ-CFW 00070902

1-773-717-339i
•
Ghiold, Joe ` �, 3 o,7 7s�
From: Ghiold, Joe
Sent: Friday, June 30, 2017 10:20 AM
To: 'Michael.e [e-mail]'
Cc: '[e-mail]'
Subject: Request for GW Sampling Work Plan at Chemours facility NCD 047 368 642
Michael,
As discussed today. See e-mail below. It appears Kevin received it.
Joe
From: Ghiold, Joe
Sent: Wednesday, June 21, 2017 3:41 PM
To: Michael e.; [e-mail]
Cc: Mccarty, Bud; Woosley, Julie; Mort, Sandra L
Subject: Request for GW Sampling Work Plan at Chemours facility NCD 047 368 642
Dear Michael,
I hope all is going well.
I just wanted to confirm your conversation this week with our Director of the Division of Waste Management, Michael
Scott, regarding the sampling of groundwater wells at the site. So that we are all on the same page we are requesting a
Ground water Sampling Work Plan be sent to my attention for our review and approval as soon as possible, but not
later than July 3, 2017. In this way we can assure that sampling can commence in early July of this year and will
accomplish all our goals. Please include in your Sampling Work Plan the following:
1)Reference USEPA Method 537 revision 1.1 for sample container specifications & preparation, sample collection,
storage and analysis protocols, analyte identification & quantitation protocols
2)Method 537 revision 1.1 analytical QCQA performance criteria are to be met, including calibration standard protocols
3)Sample preparation should follow referenced method & performance
4) The analysis should include all Method 537 revision 1.1 specified compounds, GenX and all related compounds, all
TICs
5)Sample reporting levels should be equivalent or lower than method specified
6) Have the laboratory report all detected compounds
We also reserve the right,to split samples with your consultant and send the samples to a laboratory of our choosing
while observing the sampling collection process performed by your consultant. We may also request to have the
laboratory results sent to us just prior to the submittal of the finished Groundwater report.
Should you have any questions please use the information below to contact me
Thank you for your assistance in this matter.
Sincerely,
Joe Ghiold
DEQ-CFW 00070903