2019.03.19_CCO.p11_ChemoursSamplingPlan

From:Holman, Sheila
To:Peterson, Kyle R
Subject:FW: Chemours - Sampling Plan - dated 12-28-2018 CO 11(b)
Date:Tuesday, March 19, 2019 5:44:50 PM
fyi

Sheila Holman
Assistant Secretary for the Environment
NCDEQ
1601 Mail Service Center
Raleigh, NC 27699-1601
Phone/Fax: [phone]
deq.nc.gov
[e-mail]

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Grzyb, Julie 
Sent: Tuesday, March 19, 2019 5:38 PM
To: Compton, Christel E <[e-mail]>
Cc: Lane, Bill F <[e-mail]>; Benzoni, Francisco <[e-mail]>; Abraczinskas,
Michael <[e-mail]>; Scott, Michael <[e-mail]>;
Culpepper, Linda <[e-mail]>; Long, Brian D <[e-mail]>;
Dave <[e-mail]>; [e-mail]; [e-mail];
[e-mail]; [e-mail]; Joel M. <[e-mail]>; Holman, Sheila
<[e-mail]>
Subject: Chemours - Sampling Plan - dated 12-28-2018 CO 11(b)

To: Christel Compton, Program Manager, The Chemours Company- Fayetteville Works
From : Julie Grzyb, Supervisor, NPDES Complex Permitting
Subject: Chemours’ Sampling Plan submitted per Consent Order Requirement 11(b)
Date: 3/19/2019

The Division of Water Resources, NPDES Complex Permitting has reviewed the sampling plan
submitted by Chemours on Dec. 31, 2018 as part of the CO and we have the following comments:

1) The influent to the Wastewater Treatment Plant should be included as one of the
sampling locations.
2) The effluent from whichever sedimentation basin is discharging (only one basin is in use
at a time) should be included as one of the sampling locations.
3) Page 6 : Process Wastewater
Process wastewater samples will be collected as grab samples from the Chemours Monomers
IXM Area, Chemours PPA Area, Kuraray and DuPont (Locations 16 to 19). The project team is
working with Chemours, Kuraray and DuPont facility staff to identify and access the
appropriate sampling points for the combined process wastewater from each of these areas.
Discrete process wastewater samples should be collected from Kuraray and DuPont.
4) All PFAS reported as a result of the 537.1 test method shall be reported in the results
including PFOS and PFOA (i.e. Table 1 seems incomplete only one compound is listed for
Method 537).
5) Page 8: Equipment, Trip and Field Blanks.
Equipment blanks will be collected at a frequency of one per day during the Initial
Characterization, then their frequency and the need for other blanks will be re-evaluated for
Ongoing Sampling.
Because contamination can be random as well as systemic, analysis of all three types of
blanks, not just if there is a value above the PQL for Equipment Blank should be required.
6) On the first page,
a. it should say “requirements specified in Paragraph 11(b)” (rather than
“Paragraph 11” since there are additional requirements and plans due under
Paragraph 11);
b. off-site disposal is for all Chemours process wastewater (not just process
wastewater containing GenX);
c. Chemours uses “emissions” to refer to both air and water; should it be
“discharges” for water?

NPDES recommends that Chemours proceed with the Sampling Plan provided sampling points
identified in comments number 1, 2, and 3 are added and all PFAS compounds analyzed using the
modified 537.1 test method are reported including PFOS and PFOA. Item number 5 should be
addressed as standard QA QC procedures.
The Division has a site visit planned on March 29th and reserves final approval of the sampling
plan until comments that may result from that visit can be stated and addressed. Items listed in
number 6 can be addressed with any additional comments and revisions resulting from the site
visit.
Please let me know if you would like to discuss any of these items in more detail.

Julie A Grzyb
Supervisor
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting

919 707 3605 office
919 707 9000 main office
[e-mail]

Physical Address: 512 North Salisbury St., Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.