HomeMy WebLinkAbout2020.09.30_CCOA.p4b_StormwaterSamplingPlan
STORMWATER TREATMENT
SYSTEM SAMPLING PLAN
Chemours Fayetteville Works
Prepared for
The Chemours Company FC, LLC
22828 NC Highway 87 Fayetteville, NC 28306
Prepared by
Geosyntec Consultants of NC, P.C. 2501 Blue Ridge Road, Suite 430
Raleigh, NC 27607
Project Number TR0795
September 2020
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9/30/2020
SW Sampling Plan_20200930 ii September 2020
TABLE OF CONTENTS
1 INTRODUCTION ................................................................................................ 1
2 TREATMENT SYSTEM DESCRIPTION .......................................................... 1
3 SCOPE OF WORK............................................................................................... 2
3.1 Sampling Schedule ...................................................................................... 2
3.2 Sample Types and Locations ....................................................................... 3
3.3 Flow Measurement Scope ........................................................................... 3
3.4 Associated Data Recording Scope ............................................................... 3
4 METHODS ........................................................................................................... 3
4.1 Sample Collection........................................................................................ 3
4.2 Equipment Decontamination ....................................................................... 4
4.3 Flow Measurement Methods ....................................................................... 4
4.4 Field QA/QC Samples ................................................................................. 4
4.5 Sample Packing and Shipping ..................................................................... 5
5 CALCULATIONS ................................................................................................ 6
6 REPORTING ........................................................................................................ 7
7 POTENTIAL ADJUSTMENTS ........................................................................... 8
8 REFERENCES ..................................................................................................... 9
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LIST OF TABLES
Table 1: Sampling and Analysis
LIST OF FIGURES
Figure 1: Proposed Stormwater Treatment System Location
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LIST OF ABBREVIATIONS
CO Consent Order
EQ equalization
GAC granular activated carbon
gpm gallons per minute
HFPO-DA hexafluoropropylene oxide dimer acid
IX ion exchange
ng/L nanograms per liter
NCCW non-contact cooling water
NCDEQ North Carolina Department of Environmental Quality
NPDES National Pollutant Discharge Elimination System
O&M operation and maintenance
PFAS per- and polyfluoroalkyl substances
PFMOAA 2,2-difluoro-2-(trifluoromethoxy) acetic acid
PMPA perfluoromethoxypropyl carboxylic acid
QAPP Quality Assurance Project Plan
QA/QC quality assurance/quality control
SOP standard operating procedure
TSS total suspended solids
USGS United States Geological Survey
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1 INTRODUCTION
Geosyntec Consultants of NC, PC (Geosyntec) has prepared this Stormwater Treatment
System Sampling Plan (“Sampling Plan”) on behalf of The Chemours Company FC, LLC
(Chemours) pursuant to the requirements of Paragraph 4(b) of the Addendum to Consent
Order Paragraph 12 (CO Addendum). This paragraph requires that Chemours submit a
stormwater sampling plan to quantify the effectiveness of the stormwater capture and
treatment system (Treatment System), as measured by concentrations of indicator
parameters hexafluoropropylene oxide dimer acid (HFPO-DA), perfluoromethoxypropyl
carboxylic acid (PMPA), and 2,2-difluoro-2-(trifluoromethoxy) acetic acid (PFMOAA).
The CO Addendum specifies that Chemours shall install and operate a system that
captures and treats stormwater from the area (by June 30, 2021, as noted in Paragraph
4[a]). Implementation of this Sampling Plan is intended to achieve the following
objectives:
• Characterize the stormwater influent to the Treatment System (flow and
concentration);
• Characterize the stormwater effluent from the Treatment System (concentration);
and
• Assess the Treatment System PFAS removal efficiency for comparison to the CO
Addendum requirement of 99% removal.
2 TREATMENT SYSTEM DESCRIPTION
The Treatment System will treat stormwater runoff from 11.8 acres within the area shown
on Attachment 6 of the CO Addendum for per- and polyfluoroalkyl substances (PFAS)
and is planned to be installed adjacent to the cooling water channel. As of September
2020, the Treatment System design and vendor selection are ongoing.
Stormwater will be captured, collected, and transferred to an equalization (EQ) Tank. The
diversion system, pump, EQ Tank, and Treatment System will be collectively sized to
capture stormwater runoff from the North Carolina Department of Environmental Quality
(NCDEQ) 1-inch, 24-hour design storm (as reflected in NCDEQ stormwater permits and
as implemented in NCDEQ’s statewide Stormwater Design Manual) from the drainage
area shown in Figure 1.
A design storm is a hypothetical discrete rainstorm (in this case, characterized by a
specific rainfall depth of 1 inch and 24 hours of duration) that is used in the design of a
stormwater control measure. Sizing a stormwater control measure involves calculating
the volume of runoff resulting from the specified design storm, that will drain to the
control measure. Therefore, the Treatment System will be sized to capture and treat runoff
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equivalent to the design storm volume. The Treatment System will not necessarily capture
and treat all runoff from larger storms or a series of storm events that occur in close
proximity to each other, including successive 1 inch in 24-hour storm events.
The Treatment System will treat the collected stormwater in the EQ Tank, up to the design
flowrate, to achieve the effluent targets for the indicator parameters HFPO-DA, PMPA,
and PFMOAA. The Treatment System will use granular activated carbon (GAC) to
remove PFAS but may include features for other treatment also. For storm events larger
than the design storm, stormwater flows that bypass the in-line diversion structure to the
Treatment System will combine (untreated) stormwater with non-contact cooling water
(NCCW) in the cooling water channel that flows to Outfall 002.
The Treatment System will also potentially include the following: (i) prefiltration to
remove total suspended solids (TSS), turbidity, and other constituents that clog and
potentially reduce PFAS removal by downstream unit operations; (ii) settling tanks and
solids handling system for the backwash waste from the prefiltration system (including
chemical dosing skids); and (iii) a post-filtration system to remove GAC fines.
3 SCOPE OF WORK
This Sampling Plan addresses the need to characterize stormwater influent to and effluent
from the Treatment System and assess its effectiveness in removing indicator PFAS. This
scope of work involves collecting influent and effluent samples from the Treatment
System during rain events when the Treatment System is treating stormwater. The
sampling scope and schedule presented herein may be modified based on changes in Site
conditions, adjustments in understanding of Site conditions, or potential sampling
requirements in future permits such as a National Pollutant Discharge Elimination System
(NPDES) permit.
3.1 Sampling Schedule
Sampling will be performed during wet weather, when the Treatment System is
discharging treated stormwater from the drainage area. For the first two months after the
Treatment System begins operating, sampling will be conducted up to four times per
month. Following the first two months of operation, sampling will be conducted up to
twice per month. The ability to collect samples will depend on the occurrence of rainfall
events of sufficient volume to enable sampling. Sampling events in a given month are
intended to occur at least three days apart.
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3.2 Sample Types and Locations
Time-weighted composite samples will be collected from the influent and the effluent to
the Treatment System and each will be analyzed for HFPO-DA, PMPA, and PFMOAA.
This is summarized in Table 1.
3.3 Flow Measurement Scope
Continuous flow measurements at appropriate time intervals (e.g., 5 or 15 minute) will
be taken from the influent (discharge from the EQ Tank) and water levels will be
measured in the EQ Tank during every sampling event. This is summarized in Table 1.
Flow measurements will also be taken to measure any stormwater flow that bypasses the
Treatment System.
3.4 Associated Data Recording Scope
The following types of data will be recorded during Treatment System operation:
• Precipitation during a given evaluation period will be monitored by using either
the existing United States Geological Survey (USGS) weather monitoring station
at the W.O. Huske Dam (gage 02105500) or the onsite meteorological station;
• Total stormwater volume treated by the stormwater Treatment System;
• Total stormwater volume bypassing the system;
• Capacity of EQ Tank throughout the evaluation period; and
• Other recorded field data or observations.
4 METHODS
This section describes the field methods and specific procedures for collecting samples
and field measurements.
4.1 Sample Collection
Influent and effluent samples will be collected as time-weighted composite samples using
autosamplers. Samples will be collected from subsamples collected every two hours.
Collection will continue for a total of three subsamples or the duration of a storm,
whichever occurs first. For all samples, care will be taken to avoid collecting settled/bed
sediment or other materials which may be potentially present in the sample. Other
relevant sampling procedure information can be found in the Poly and Perfluoroalkyl
Substance Quality Assurance Project Plan (AECOM, 2018).
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4.2 Equipment Decontamination
All non-dedicated or non-disposable sampling equipment will be decontaminated
immediately before sample collection in the following manner:
• De-ionized water rinse;
• Scrub with de-ionized water containing non-phosphate detergent (i.e.,
Alconox®);
• De-ionized water rinse; and
• Disposable equipment (e.g. gloves, tubing, etc.) will not be reused.
4.3 Flow Measurement Methods
The Treatment System will include instrumentation to collect flow and water level
measurements. The flow meter will be installed at the Treatment System influent
(discharge from the EQ Tank) and will represent both influent and effluent flows for the
Treatment System. Additionally, flow measurements will be collected of any stormwater
flow that bypasses the Treatment System. This flow will potentially be measured at the
overflow weir from the diversion sump/lift station. Alternatively, flow may be measured
both in the channel just downstream of the diversion sump/lift station and in the pipe
conveying NCCW, just upstream of discharge into the channel, where the difference in
these two flows represents stormwater flow bypassing the Treatment System, or some
other method that can measure this flow.
Water level will also be measured within the EQ Tank. Both readings will be recorded
during every sampling event.
4.4 Field QA/QC Samples
Quality assurance/quality control (QA/QC) samples will be collected at an overall
frequency of at minimum twenty percent (20%) for the program. QA/QC samples may
not be collected during each sampling event. The following types of QA/QC samples will
be collected:
• Equipment Blanks: At the sample location, laboratory-supplied, analyte-free
water will be poured over or through the clean, non-dedicated sampling
equipment, and collected in a sample container. The equipment blank samples
will then be shipped, stored, and handled with the other samples and will be
analyzed for the same parameters as other samples collected using the same
device.
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• Field Blanks: The field blank will be collected by transferring laboratory-
supplied, analyte-free water into a sample container in the vicinity of a sample
location without contacting any other sampling equipment.
• Field Duplicates: The duplicate will be collected in the same manner as the other
samples and the duplicate sample will be analyzed for the same parameters as the
co-located samples. Duplicates will be numbered sequentially with the other
samples, so they are not identifiable by the analytical laboratory (i.e., “blind”
duplicates).
• Matrix Spike/Matrix Spike Duplicate: The matrix spike and matrix spike
duplicate sample will be collected in the same manner as the other samples. At
the laboratory an appropriate spike of PFAS will be added to the sample and the
sample analyzed for the same parameters as the other co-located samples.
4.5 Sample Packing and Shipping
Upon sample collection, each containerized sample will be labeled and placed as soon as
possible into an insulated sample cooler. The cooler will serve as a shipping container
and will be provided by the laboratory along with the appropriate sample containers. Wet
ice will be placed around the sample containers within heavy-duty plastic bags within the
sample cooler. Samples will be maintained at a cool temperature (optimum 4°Celsius ±
2°Celsius) from the time of collection until the coolers arrive at the laboratory (if
required). Plastic “bubble wrap” and/or polystyrene foam may also be used to protect the
samples during shipping.
Prior to shipment of the samples to the laboratory, a chain-of-custody form will be
completed by the field sample custodian. Sample locations, sample identification
numbers, description of samples, number of samples collected, and specific laboratory
analyses to be run on each sample will be recorded on the chain-of-custody form.
Samples for the first two months of sampling will be shipped to either TestAmerica
Sacramento, TestAmerica Denver, or Lancaster Laboratories depending on laboratory
availability at the time of sampling. After the first two months, samples will be sent to
the onsite laboratory for analysis provided the detection limits at the onsite laboratory
have been demonstrated to be sufficiently sensitive to demonstrate a 99% reduction in the
concentration of the three indicator parameters by the Treatment System.1 Samples will
be analyzed using the methods shown in Table 1.
1 As of September 2020, the Fayetteville Works Onsite laboratory had a detection limit of 100 nanograms per liter (ng/L) i.e. parts per trillion for most Table 3+ compounds. The ability to demonstrate a 99% reduction will therefore be contingent upon the concentration of influent samples being above 10,000 ng/L.
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5 CALCULATIONS
The Treatment System PFAS removal efficiency will be calculated using information
collected as part of this sampling program. Treatment System PFAS removal
effectiveness will be defined by the percentage removal of the combined concentrations
of the three indicator parameters (HFPO-DA, PFMOAA and PMPA). Removal
effectiveness will be determined on a quarterly average basis using composite influent
and effluent samples. The system PFAS removal efficiency calculation uses volume
weighted concentrations of the influent and effluent samples to calculate the percentage
of mass removal. Volume weighted concentrations were developed in the event that either
the influent and effluent autosamplers have different compositing durations or that the
composite sampling periods in the quarter have different durations (e.g. 12 hours and 32
hours). Both circumstances could arise due to a potential equipment malfunction or severe
weather event. Weighting by volume provides a representative assessment of mass
present in both the influent and effluent over time; samples corresponding to greater flow
volumes will have a proportionately higher weight. The Treatment System PFAS removal
efficiency will be calculated using Equation 1 below.
Equation 1: System Removal Effectiveness for Indicator Parameters 𝐸𝐸𝑇𝑇𝑇𝑇−𝐼𝐼𝐼𝐼𝐼𝐼−𝐼𝐼𝐼𝐼𝐼𝐼= �1 −𝑐𝑐𝑒𝑒𝑒𝑒𝑒𝑒𝑐𝑐𝑖𝑖𝐼𝐼𝑒𝑒�× 100%
= �1 −∑∑𝑐𝑐𝑒𝑒𝑒𝑒𝑒𝑒,𝑚𝑚,𝑖𝑖× 𝑤𝑤𝑚𝑚i=3𝑖𝑖=1𝐼𝐼𝑚𝑚=1∑∑𝑐𝑐𝑖𝑖𝐼𝐼𝑒𝑒,𝐼𝐼,𝑖𝑖× 𝑤𝑤𝐼𝐼i=3𝑖𝑖=1𝑁𝑁𝐼𝐼=1 �× 100%
= �1 −∑∑𝑐𝑐𝑒𝑒𝑒𝑒𝑒𝑒,m,𝑖𝑖× 𝑉𝑉𝑚𝑚∑𝑉𝑉𝑚𝑚𝐼𝐼𝑚𝑚=1i=3𝑖𝑖=1𝐼𝐼𝑚𝑚=1∑∑𝑐𝑐𝑖𝑖𝐼𝐼𝑒𝑒,𝐼𝐼,𝑖𝑖× 𝑉𝑉𝐼𝐼∑𝑉𝑉𝐼𝐼𝑁𝑁𝐼𝐼=1i=3𝑖𝑖=1𝑁𝑁𝐼𝐼=1 �× 100%
where, 𝐸𝐸𝑇𝑇𝑇𝑇−𝐼𝐼𝐼𝐼𝐼𝐼−𝐼𝐼𝐼𝐼𝐼𝐼 = is the Treatment System PFAS removal efficiency for the three
indicator parameters HFPO-DA, PMPA, and PFMOAA; 𝑐𝑐𝑒𝑒𝑒𝑒𝑒𝑒= is the volume weighted effluent concentration for a given evaluation period; 𝑐𝑐𝑖𝑖𝐼𝐼𝑒𝑒 = is the volume weighted influent concentration for a given evaluation period;
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𝑚𝑚 = represents an individual effluent composite sample time interval during a given
evaluation period; 𝑀𝑀 = is the total number of effluent composite sample time intervals during a given
evaluation period; 𝑛𝑛 = represents an individual influent composite sample time interval during a given
evaluation period; 𝑁𝑁 = is the total number of influent composite sample time intervals during a given
evaluation period;
i = represents the three indicator parameters HFPO-DA, PMPA, and PFMOAA; 𝑐𝑐𝑒𝑒𝑒𝑒𝑒𝑒,𝑚𝑚,𝑖𝑖 = is the measured concentration of the three indicator parameters for each
effluent composite samples2; 𝑐𝑐𝑖𝑖𝐼𝐼𝑒𝑒,𝐼𝐼,𝑖𝑖 = is the measured concentration of the three indicator parameters for each
influent composite samples2; 𝑤𝑤𝑚𝑚 = is the effluent concentration volumetric weighting factor calculated for and
applied individually to each effluent composite sample concentration; 𝑉𝑉𝑚𝑚 = is the volume of water entering (and exiting) the Treatment System during the
effluent composite sample collection period; 𝑤𝑤𝐼𝐼 = is the influent concentration volumetric weighting factor calculated for and
applied individually to each influent composite sample concentration; and 𝑉𝑉𝐼𝐼 = is the volume of water entering (and exiting) the Treatment System during the
influent composite sample collection period.
6 REPORTING
By September 30, 2021 Chemours will submit to DEQ a report evaluating the Treatment
System’s capture of stormwater from the drainage area for rain events up to the 1-inch,
24-hour design storm and removal of PFAS compounds as measured by concentrations
of indicator parameters HFPO-DA, PMPA, and PFMOAA.
2 Non-detect influent and effluent sample results will be assigned a value of zero for the calculation and the values from duplicate samples will be averaged together.
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7 POTENTIAL ADJUSTMENTS
The sampling and calculation methodologies described in this report have been outlined
based on the present understanding of Site conditions. If conditions or methods change,
modifications may need to be made to this plan. Any modifications made will be
described in future submitted reports.
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8 REFERENCES
AECOM, 2018. Poly and Perfluoroalkyl Substance Quality Assurance Project Plan for
the Chemours Corporate Remediation Group.
Geosyntec, 2020. Site Conveyance Network and Outfall 002 PFAS Mass Loading
Calculation Protocol. 31 August 2020.
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TABLES
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TABLE 1
SAMPLING AND ANALYSIS
Chemours Fayetteville Works, North Carolina
Geosyntec Consultants of NC P.C.
Bypassc EQ Tank Influent Effluent
HFPO-DA, PMPA, PFMOAA Time-weighted
composite Lab Analysis Table 3+ Lab SOP X X
Flow X X
Water Level X
Notes:
b Continuous measurements will be collected at appropriate intervals (e.g., 5 or 15 minutes).
c Bypass flow will be measured at the overflow weir from the diversion sump/lift station, or both in the channel just downstream of the diversion sump/lift station and in the pipe conveying
NCCW, just upstream of discharge into the channel, where the difference represents stormwater flow bypassing the Treatment System, or some other method.
--
a Sampling will be performed during wet weather, when the Treatment System is discharging treated stormwater. Samples will be collected up to four times per month during the first two
months. Following the first two months of operation, sampling will be conducted up to twice per month.
Parameter/Measurement Sample Type Measurement Type Analytical Method Sample Collectiona
Continuousb Field Parameter
TR0795 September 2020
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FIGURES
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Proposed Stormwater Treatment System Location
Chemours Fayetteville Works, North Carolina
Figure
1Raleigh
125 0 12562.5 Feet
³Path: P:\GIS\Chemours\MXDs\TreatmentSystem_SamplingPlan_Fig1.mxd Last Revised: 8/12/2020 Author: TReederSeptember 2020
Projection: NAD 1983 StatePlane North Carolina FIPS 3200 Feet; Units in Foot US
Legend
Proposed Stormwater Treatment System Location
Drainage area to the Stormwater Treatment System
Cooling Water Channel
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