HomeMy WebLinkAboutDEQ-CFW_00075959September 22, 2017
VIA EMAIL
William F. Lane, Esq.
General Counsel
NC Department of Environmental Quality
217 West Jones Street
Raleigh, NC 27603
ROBINSON
BRADSHAW
sdegeorge@robinsonbradshaw.com
704.377.8380 : Direct Phone
704,373.3980 : Direct Fax
Francisco J. Benzoni. Esq.
Assistant Attorney General
NC Department of Justice
114 W. Edenton Street
Raleigh, NC 27603
Re: Chemours' Fifth Response to DEQ's September 10, 2017 List of Priority
Requests
Dear Messrs. Lane and Benzoni:
On behalf of The Chemours Company FC, LLC ("Chemours"), this letter and
enclosed materials are submitted in response to DEQ's September 10, 2017 request
that Chemours prioritize certain of DEQ's pending requests for information related to
Chemours' Fayetteville facility ("Fayetteville Works").'
Chemours has enclosed its second progress report under the sampling plan it
submitted to DEQ on September 15, 2017. See CH-FW-DEQ-0057829 to CH-FW-
DEQ-0057830. Chemours is available to discuss this progress report during the call
scheduled with DEQ for this afternoon.
We look forward to continuing to work with DEQ and the Attorney General's
office cooperatively on this matter and receiving DEQ's confirmation of its availability for
the weekly sampling plan teleconferences Chemours has requested. If you have any
questions about this submission, please let me know.
Sincerely,
ROBINSON, BRADSHAW & HINSON, P.A.
R. Steven DeGeorge
1 This submission supplements Chemours' August 4th, August 18th, August 25th, September 1st,
September 12th, September 14th, September 15th, September 18th responses to DEQ.
ROBINSON, BRADSHAW & HINSON, P.A.: robinsonbradshaw.com
Charlotte Office : 101 N. Tryon St., Ste. 1900, Charlotte, NC 28246 : 704.377.2536
DEQ-CFW 00075959
September 18, 2017
Page 2
Enclosures
cc:
Linda Culpepper
DEQ
Evelyn Brantley
The Chemours Company, FC LLC
John Savarese
Wachtell, Lipton, Rosen & Katz
Ralph Levene
Wachtell, Lipton, Rosen & Katz
Lester Sotsky
Arnold & Porter Kaye Scholer
Joel Gross
Arnold & Porter Kaye Scholer
DEQ-CFW 00075960
♦ . f
PROGRESS REPORT #2
Date: September 22, 2017
To: North Carolina Department of Environmental Quality ("DEQ")
From: The Chemours Company FC, LLC ("Chemours")
Re: Wastewater Sampling Plan - Progress Report #2
I. INTRODUCTION
On September 15, 2017, Chemours submitted to DEQ a Sampling Plan for Chemours'
Fayetteville, North Carolina facility ("Fayetteville Works") to respond to DEQ's request for
certain wastewater sampling. This is Progress Report #2 under the Sampling Plan. Chemours
intends to continue to provide additional progress reports to DEQ on a periodic basis as
additional data and information becomes available.
II. REMAINING ANALTICAL RESULTS FOR TABLE I COMPOUNDS
Pursuant to the Sampling Plan, this week Chemours began providing DEQ the remaining
Phase 1 Sample Set results for the Table 1 compounds as follows:
1. In Progress Report #1 (submitted September 19th), Chemours provided DEQ results for
the Table 1 compounds from a September 13, 2017 sample collected from the Common
Waste Tank.
2.
Chart 1 below provides preliminary results for HFPO Dimer Acid, PFOA, and PFOS
from samples collected from Outfalls 001 and 002 on September 13, 2017. Please note
that these results are preliminary (i.e., we have not completed the standard QA/QC
process) and are in addition to the Outfall 002 results Chemours previously provided
DEQ.
CHART 1- PRELIMINARY RESULTS
Outfall 001- Sample Collected 9-13-2017
ANALYSIS
PRELIM. RESULT
UNITS
HFPO Dimer Acid
0.42
ug/L
PFOA
0.020
ug/L
PFOS
<0.0020
ug/L
Outfall 002 - Sample Collected 9-13-2017
ANALYSIS
PRELIM. RESULT
UNITS
HFPO Dimer Acid
0.064
ug/L
PFOA
0.015
ug/L
PFOS
0.012
ug/L
1 of 2 CH-FW-DEQ-0057829
DEQ-CFW 00075961
3. Chart 2 below provides results for Table 1 compounds from a sample collected from the
Cell Lab Effluent on September 13, 2017. Please note that some of these results are
preliminary (i.e., we have not completed the standard QA/QC process) and are in addition
to the Cell Lab Effluent data results Chemours previously provided DEQ, including the
HFPO Dimer Acid result of 0.99 ug/L from a July 19th sample that Chemours provided
to DEQ by letter dated July 28, 2017.
CHART 2 - Cell Lab Effluent - Sample, Collected,: September 13, 2017
ANALYSIS
RESULT
UNITS
HFPO Dimer Acid
0.091(preliminary
result)
ug/L
PFOA
0.0024 (preliminary
result)
ug/L
PFOS
0.0029 (preliminary
result)
ug/L
Total Suspended Solids
37.6
mg/L
Chemical Oxygen
Demand
5,920
mg/L
Antimony
<0.020
mg/L
Arsenic
<0.020
mg/L
Beryllium
<0.020
mg/L
Cadmium
<0.020
mg/L
Chromium
0.454
mg/L
Copper
0.021
mg/L
Lead
<0.020
mg/L
Nickel
0.129
mg/L
Selenium
<0.020
mg/L
Siver
<0.020
mg/L
Thallium
<0.020
mg/L
Mercury
<0.0002
mg/L
Zinc
<0.10
mg/L
With this Progress Report #2 and consistent with the September 15th Sampling Plan, Chemours
believes that it has completed its response for the Table 1 compounds for the Phase 1 Sample
Set.
2 of 2 CH-FW-DEQ-0057830
DEQ-CFW 00075962