NCS000149_Email RE Chemours Additional Data and Revised Plan_20171218

Georgoulias, Bethany
From: Lawyer, Mike
Sent: Monday, December 18, 2017 1:40 PM
To: Vinson, Toby; Lucas, Annette
Cc: Culpepper, Linda; Allen, Trent; Risgaard, Jon; LaBounty, Tim L
Subject: RE: [External] Chemours - Additional Data and Revised Storm Water Plan
Attachments: Rescission Request_NCS000149_DuPont- Fayetteville Works.pdf; Rescission of
NCS000149_DuPont- Fayetteville Works.pdf
Toby,
Upon reviewing our stormwater permit files, the Chemours facility (previously permitted under DuPont) was issued
coverage under individual stormwater permit NCS000149 on August 31, 1994 with an effective date of October 1, 1994
and expiration date of August 31, 1999. A permit renewal application was submitted by DuPont in April 1999. Prior to
permit renewal, DuPont submitted a letter dated October 11, 1999 requesting that the stormwater permit be rescinded.
DuPont's reasons for requesting rescission are detailed in the attached document titled Rescission
Request _NCS000149_DuPont-Fayetteville Works. The rescission was granted with a letter dated November 3, 1999 a
copy of which is also attached.
If we can be of any further assistance in this matter, please contact us.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike.lawyer(cancdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Vinson, Toby
Sent: Monday, December 18, 2017 12:07 PM
To: Lucas, Annette <[e-mail]>; Lawyer, Mike <[e-mail]>
Cc: Culpepper, Linda <[e-mail]>; Allen, Trent <[e-mail]>; Risgaard, Jon
<[e-mail]>; LaBounty, Tim L <[e-mail]>
Subject: FW: [External] Chemours - Additional Data and Revised Storm Water Plan
Mike and Annette,
I just received this email and attachment from Linda.

From my conversation last week with Mike in Fayetteville, if I'm remembering correctly, this site rolled all their
Stormwater into their Wastewater Permit such that we no longer have a SW Permit on this site. Mike can you verify and
provide the documentation you spoke about last week so that we can determine if we in DEMLR need to be involved
with this site to assist DWR in their efforts?
Thanks,
Toby
William E. Toby Vinson, Jr., PE, CPESC, CPM
Chief of Program Operations
Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
512 N Salisbury St
1612 Mail Service Center
Raleigh, NC 27699
Phone: [phone]
Email: [e-mail]
--!.'�Nothmg Compares]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Culpepper, Linda
Sent: Monday, December 18, 2017 11:44 AM
To: Vinson, Toby <[e-mail]>
Cc: Risgaard, Jon <[e-mail]>; Allen, Trent <[e-mail]>
Subject: Fwd: [External] Chemours - Additional Data and Revised Storm Water Plan
Forwarding to you for your staff review. Who will be working on this? We will get them up to speed on the site
conditions.
Sent from my iPhone
Begin forwarded message:
From: "Culpepper, Linda" <[e-mail]>
Date: December 15, 2017 at 2:36:01 PM EST
To: "Risgaard, Jon" <[e-mail]>, "Allen, Trent" <[e-mail]>, "Brantley,
Mark" <[e-mail]>, "Cox, Heidi" <[e-mail]>
Subject: Fwd: [External] Chemours - Additional Data and Revised Storm Water Plan
Jon - do we need to send the storm water plan to DEMLR?
Sent from my iPhone

Begin forwarded message:
Resent -From: <SRSO=UWIv=DL=chemours.com=[e-mail]>
From: "Compton, Christel V<[e-mail]>
Date: December 15, 2017 at 2:20:54 PM EST
To: "[e-mail]" <[e-mail]>
Cc: "[e-mail]" <[e-mail]>, "Gross, Joel M."
<[e-mail]>, "[e-mail]" <[e-mail]>,
"[e-mail]" <[e-mail]>
Subject: [External] Chemours - Additional Data and Revised Storm Water Plan
CAUTION: External email. Do not click links or open attachments unless verified. Send all
suspicious email as an attachment to [e-mail].
Linda,
Please find below: (1) additional Outfall 002 results; (2) results from the two storm
water ditches that were sampled over the weekend; (3) an update on Chemours' plans
for Outfall 002 sampling moving forward; and (4) an explanation for Chemours' attached
and revised December 13, 2017 stormwater sampling plan.
1. Additional Outfall 002 Results
Please find below additional Outfall 002 results analyzed by Chemours' Fayetteville
Works laboratory for HFPO Dimer Acid.
Date Sample Collected
Results
(Daily Composite, Unless
(Ppt)
Otherwise Noted)
11-Dec
1,602
11-Dec (multi -day
composite)
2,510
12-Dec
423
13-Dec
<100
Chemours believes the increases observed in the December 11t" samples are due to the
large rain fall event that occurred on Friday and into the weekend (2.37 inches of rain on
12/8 and 0.36 inches of rain on 12/9). The chart below lists the daily rainfall as reported
by the USGS at the nearby William O. Husk Lock and Dam. See
https://waterdata.usgs.gov/nwis/uv?site no=02105500.
Date
Rainfall Measured at
Lock and Dam (Inches)
6-Dec
0.23
7-Dec
0.08
8-Dec
2.37
9-Dec
0.36
10-Dec
0
11-Dec
0

12-Dec 0
13-Dec 0
2. Stormwater Ditch Results
As mentioned in my Monday, December 12t" letter to Mr. Allen (DEQ), Chemours
sampled the two storm water ditches on either side of the secondary containment from
which a leak occurred on Saturday. The HFPO Dimer Acid concentrations detected in
the two storm water ditches were 2,665 ppt (west side of the road) and 2,241 ppt (east
side of the road). Chemours continues to believe that the leak did not reach these
ditches because (1) the previously reported field observation that the pH of the soil
turned neutral prior to these ditches; and (2) these storm water ditch results are
generally consistent with the Outfall 002 results above during this rain event.
3. Chemours' Outfall 002 Sampling Approach Beginning Week of December 18th
On November 29th, Chemours severed the pipe feeding process wastewater from the
Fluoromonomers/Nafion Membrane manufacturing area to the wastewater treatment
plant. Chemours has continued to collect and analyze both multi -day and daily
composites at Outfall 002 since November 29t". Beginning next week, Chemours will
continue to collect both the multi -day and the daily composites at Outfall 002, but will
only analyze the multi -day composites, unless the results from multi -day composite are
anomalous, in which case Chemours will then analyze the relevant daily composites to
better define the scope of the anomaly. Chemours will continue to provide DEQ the
Outfall 002 analytical results it generates internally or receives from Test America.
4. Revised Stormwater Sampling Plan
Finally, please find attached a revised December 13, 2017 stormwater sampling
plan. The primary differences between the December 13t" version and the prior version
dated and sent to DEQ on November 29 are: (1) in response to DEQ's request,
Chemours added a sample of the rain water itself (see page 3); (2) Chemours added
sampling of the existing groundwater wells LTW-1 through LTW-5 (see page 3); (3) due
the accessibility and other concerns, Chemours revised the offsite tributary sampling
locations (see pages 3 - 4); and (4) Chemours added a stream gauging/flow
measurement component to the tributary sampling (see page 4).
Christel Compton
Program Manager
The Chemours Company — Fayetteville Works
(o) 910-678-1213
(m) 910-975-3386
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