NCS000386_Emails RE Stormwater Outfall Status and Rescission_20210114

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Thursday, January 14, 2021 8:54 AM
To: Bryson, Stacy (S)
Cc: Lucas, Annette; Khan, Zahid
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit
NCS000386
Stacy,
If there is definitely no industrial activity and no remaining materials or exposure, stormwater discharges should not be
subject to any NPDES stormwater permit requirements. It becomes like an outfall from an employee parking lot that is
entirely segregated from manufacturing or other industrial activity at an active industrial site (outside the scope of the
permit).
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
DES-"
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From: Bryson, Stacy (S) [mailto:[e-mail]]
Sent: Thursday, January 14, 2021 8:47 AM
To: Georgoulias, Bethany <[e-mail]>
Subject: FW: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Hoping you can help me out. I know the permit rescission is in process, but I want to be sure we are OK in the
interim. Per the note below, there is no activity on site (except environmental investigation by buyer). We have no one
on site on a normal basis with the exception of security. We do have a Dow rep on site the next two days to meet with
the buyer's representatives.
My question is whether we can leave the outlet valve to the stormwater outfall open since there is no ongoing Dow
activity at the site and there is no one on site to manage the outfall?
We anticipate closure on the property in mid -February.
Thank you in advance for the input! I hope you are doing well and had a great holiday!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Bryson, Stacy (S)
Sent: Monday, January 4, 2021 11:23 AM
To: james moore <[e-mail]>; Chandler, Jeffrey A <[e-mail]>
Cc: Khan, Zahid <[e-mail]>; Kreps, Sandra (SE) <[e-mail]>; Gamble, Aana C
<[e-mail]>; Lucas, Annette <[e-mail]>; McCoy, Suzanne
<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
Just wanted to touch base to see if any additional information is needed for recission of this permit. To confirm the
earlier discussion, we ceased manufacturing at this facility in August 2019. Chemicals have been removed from the site
and vessels have been "air gapped".
Thanks and hope you had a great holiday!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Bryson, Stacy (S)
Sent: Friday, December 11, 2020 11:38 AM
To: james moore <[e-mail]>; Chandler, Jeffrey A <[e-mail]>
Cc: Khan, Zahid <[e-mail]>; Kreps, Sandra (SE) <[e-mail]>

Subject: FW: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
Importance: High
Thanks again for working with us to make a site visit this week! To confirm the earlier discussion, we ceased
manufacturing at this facility in August 2019 and have been working to decommission the site since that
time. Chemicals have been removed from the site and vessels have been "air gapped".
Please let us know if any additional information or input is needed to proceed with the rescission of the NPDES permit.
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Bryson, Stacy (S)
Sent: Tuesday, December 8, 2020 8:34 AM
To: 'Khan, Zahid' <zahid. khan@ ncdenr.gov>; 'McCoy, Suzanne'<[e-mail]>;'Georgoulias, Bethany'
<[e-mail]>; James moore' <[e-mail]>; 'Chandler, Jeffrey A'
<[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; 'Lucas, Annette' <[e-mail]>; 'Gamble, Aana C'
<[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
Importance: High
Attached please find the rescission request. I will be sending the hard copy by Fed Ex today.
Mr. Moore/Mr. Chandler: Do you think there is any way possible the site visit could occur sometime between this
afternoon and Friday?
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonOdow.com
From: Bryson, Stacy (S)
Sent: Friday, December 4, 2020 1:21 PM
To: 'Khan, Zahid' <[e-mail]>; McCoy, Suzanne <[e-mail]>; Georgoulias, Bethany
<[e-mail]>; james moore <[e-mail]>; Chandler, Jeffrey A
<ieffrey.chandler@ncdenr.�ov>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386

Update: WWT demo is done except for final debris removal and clean up. I plan on putting in the recission request this
afternoon if time permits (or Monday if not).
Mr. Moore/Mr. Chandler: Do you think there is any way possible the site visit could occur sometime between Tuesday
afternoon and Friday.
Again, I apologize as I hate "drop everything and help me" requests myself. We anticipate that there will be no Dow
employees on site after Friday, December 11. Unfortunately, we've had little ability ourselves to modify the pre-
defined decommission and sale schedule.
THANKS!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Khan, Zahid <[e-mail]>
Sent: Wednesday, December 2, 2020 11:34 AM
To: Bryson, Stacy (S) <[e-mail]>; McCoy, Suzanne <[e-mail]>; Georgoulias, Bethany
<[e-mail]>; james moore <[e-mail]>; Chandler, Jeffrey A
<[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
This email originated from outside of the organization.
James and Jeffrey,
If you can take a lead on this one. Thanks
From: Bryson, Stacy (S) [mailto:[e-mail]]
Sent: Wednesday, December 2, 2020 11:31 AM
To: McCoy, Suzanne <[e-mail]>; Georgoulias, Bethany <[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>; Khan, Zahid <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
The good news is that the final decommission of the waste water system is going quickly, and we hope to have it done
by this weekend or next Monday. That will allow me to make the recission request earlier. We plan on having Dow
representatives on site until the end of next week. As of now, we anticipate the sale going through before the holidays.

Zahid: Do you think there is any way someone could do the site inspection later next week? I do apologize for the
request as I understand everyone is very busy. We have not been given much latitude with the decommission and sale
schedules.
THANKS!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: McCoy, Suzanne <[e-mail]>
Sent: Tuesday, November 17, 2020 1:14 PM
To: Bryson, Stacy (S) <[e-mail]>; Georgoulias, Bethany <[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>; Khan, Zahid <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
This email originated from outside of the organization.
You will need to follow these Rescission Instructions. There is a link to the form, see the blue font.
Rescind an Existing Industrial Permit
Complete the Rescission Request Form and mail one hard copy of the form to Suzanne McCoy, 1612 MSC,
Raleigh, NC 27699-1612. In addition, e-mail the form to Suzanne McCoy. There is no fee for industrial
permit rescissions. Please note that it can take 1-2 months to process the request because we cannot rescind the
permit until DEQ staff conduct a site visit.
Suzanne McCoy
Stormwater Program Administrative Specialist
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Physical: 512 N. Salisbury Street, Office 640K, Raleigh, NC 27604
Mailing: 1612 Mail Service Center, Raleigh, NC 27699-1612
Email: Suzanne. mccoy�ncdenr.goy
Phone: [phone]
Website: http://deg.nc.gov/about/divisions/energy-mineral-land-resources/stormwater

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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Before printing this email, please consider your budget and the environment.
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From: Bryson, Stacy (S) [mailto:[e-mail]]
Sent: Tuesday, November 17, 2020 11:36 AM
To: Georgoulias, Bethany <[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>; Khan, Zahid <[e-mail]>; McCoy, Suzanne <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
If you can let us know the anticipated date of inspection as soon as possible after submittal of the recission request, that
would be great. We will not have anyone on site and will need to make arrangements for someone to be there. We
are really hoping the demolition will be done sooner which would make things much easier. Will keep everyone in the
loop. THANKS!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Georgoulias, Bethany <[e-mail]>
Sent: Tuesday, November 17, 2020 11:16 AM
To: Bryson, Stacy (S) <[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>; Lucas, Annette <[e-mail]>; Gamble, Aana C
<[e-mail]>; Khan, Zahid <[e-mail]>; McCoy, Suzanne <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
This email originated from outside of the organization.

Stacy,
The company will need to do its best to request rescission as soon as possible upon completion of demolition activities
on 12/17. 1 am copying the Regional Engineer with the Mooresville Regional Office so he can be prepared to send staff
to verify closure for a rescission inspection ahead of the 12/23 sale. Thank you for letting us know about the probable
timeframe.
Regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
D, E
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your
requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.
From: Bryson, Stacy (S) [mailto:[e-mail]]
Sent: Monday, November 16, 2020 5:01 PM
To: Georgoulias, Bethany<[e-mail]>
Cc: Kreps, Sandra (SE) <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Touching base to provide the most recent update on site activities. We have completed decommission of the site with
the exception of the pump out of one maintenance wastewater sump (to be shipped as waste via vacuum truck), and
that is anticipated to occur next week. Since my last communication, we have learned that the wastewater treatment
area will be demolished as a stand-alone activity versus a full demolition project. This will consist of removal of
structures with heavy equipment and fill in of basins with gravel (no excavation). As a result, the potential stormwater
impact is primarily the use of heavy equipment (e.g., oil leaks). We intended to manage this as we have the other
decommission activities with an addendum to our SWPPP outlining the demolition plan information, hazards, and
safeguards to be employed.

The wastewater treatment demolition is to begin this week and be complete by 12/17 with closing on the final sale of
the site tentatively slated for 12/23. That timeframe leaves very little time to apply for rescinding the permit and site
inspection following the end of the demolition activities. In addition, we will have no personnel on site after demolition
is completed. Any advice you can provide on how to manage this situation to ensure ongoing compliance and also meet
the permit closure process considering the current timeline is GREATLY appreciated.
I will be at the Charlotte site all day Thursday and Friday morning this week if you would like to see the current site
status. I can also be reached at the number below and on my cell at 865-207-1157.
Thanks in advance for your input!
Stacy Bryson
EH&S Leader, Knoxville Site
The Dow Chemical Company
730 Dale Avenue, Knoxville TN 37921
[phone] 1 SBrysonadow.com
From: Georgoulias, Bethany <[e-mail]>
Sent: Tuesday, October 13, 2020 12:23 PM
To: Bryson, Stacy (S) <[e-mail]>
Subject: RE: [External] RE: Rohm and Haas Chemicals LLC - Charlotte Site - NPDES Permit NCS000386
This email originated from outside of the organization.
Thank you for the update, Stacy.
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or
are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your

requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging
time.