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HomeMy WebLinkAbout2019.06.18_CCO.p11_NCDWRFollowUpLetterRE-MTP.MMF.DFSA.PPFAcid The Chemours Company Fayetteville Works 22828 NC Highway 87 W Fayetteville, NC 28306 June 18, 2019 Linda Culpepper Interim Director, Division of Water Resources 1611 Mail Service Center Raleigh, NC 27699-1611 linda.culpepper@ncdenr.gov Re: Laboratory Analyses for MTP, MMF, DFSA, and PPF Acid Dear Ms. Culpepper, I am writing to follow up on our June 10 letter and June 12 conference call with DEQ in regard to the four PFAS compounds shown below: Acronym Name Molecular Formula CASN Chemical Structure MTP Perfluoro-2- methoxypropanoic acid CH3-O- CF2-CF2- COOH 93449- 21-9 MMF Difluoromalonic acid HOOC- CF2- COOH 1514- 85-8 DFSA Difluoro-sulfo- acetic acid HOOC- CF2- SO3H 422-67- 3 PPF Acid Perfluoropropionic acid CF3-CF2- COOH 422-64- 0 2 As we noted in our letter and discussed on our conference call, the laboratory analytical methods for these four compounds are new and not refined (and previously did not exist), and the resulting data quantifications are not accurate. Our external testing laboratories, Eurofins Lancaster Laboratories (“Lancaster”) and TestAmerica, have prepared summaries of the technical issues they have encountered, and these summaries are enclosed. Accordingly, to prevent the collection and dissemination of inaccurate and misleading data, we have instructed Lancaster and TestAmerica to stop analyzing and reporting for these four compounds under their current laboratory analytical methods (referred to as “Table 3+”). We will continue to work with these labs on analytical method development and finding an appropriate testing methodology for these four compounds, and we will keep you apprised of our progress. Please let me know if you have any questions. Sincerely, Brian D. Long Plant Manager Chemours – Fayetteville Works Enclosures Lancaster Technical Summary TestAmerica Technical Summary 3 Cc: Sheila Holman, DEQ William F. Lane, DEQ Francisco Benzoni, NC DOJ Michael Abraczinskas, DAQ Michael Scott, DWM David C. Shelton, Chemours John F. Savarese, WLRK Kemp Burdette, CFRW Geoff Gisler, SELC