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Home My WebLink AboutDEQp00020483September 12, 2017 VIA EMAIL William F. Lane, Esq. General Counsel NC Department of Environmental Quality 217 West Jones Street Raleigh, NC 27603 ROBINSON BRADSHAW sdegeorge@robinsonbradshaw.com 704.377.8380 : Direct Phone 704.373.3980 : Direct Fax Francisco J. Benzoni Assistant Attorney General NC Department of Justice 114 W. Edenton Street Raleigh, NC 27603 Re: Chemours' First Response to DEQ's September 10, 2017 List of Priority Requests Dear Messrs. Lane and Benzoni: On behalf of The Chemours Company FC, LLC ("Chemours"), this letter and enclosed materials are submitted in response to DEQ's September 10, 2017 request that Chemours prioritize certain of DEQ's pending requests for information related to Chemours' Fayetteville facility ("Fayetteville Works"). This submission supplements Chemours' August 4th, August 18th, August 25th, and September 1st productions to DEQ. Within DEQ's requested two-day deadline, this submission responds to requests numbered 1 - 3 in DEQ's September 10th list of priorities as follows: • Request 1: Provide a schematic of Chemours' process areas showing sumps, quench baths, and all points of discharge to the WWTP. Response: See CH -FW -DEQ -0057683. This schematic reflects current points of discharge within Chemours' operations at the Fayetteville Works that lead to the wastewater treatment plant ("WWTP") and includes approximate daily wastewater flows. • Request 2: Provide 2017 production data for June, July, and August showing what was being manufactured at Chemours while recent sampling campaigns were occurring. Response: See CH -FW -DEQ -0057684. Please note that, for these 2017 production data: (1) not all of these production processes generate process wastewater that is discharged to the WWTP or to Outfalls 001 or 002; and (2) ROBINSON, BRADSHAW & HINSON, P.A.: robinsonbradshaw.com ' Charlotte Office : 101 N. Tryon St., Ste. 1900, Charlotte, NC 28246 : 704.377.2536 September 12, 2017 Page 2 Chemours has included only those membrane products that generate process wastewater (Chemours produces approximately 50 additional membrane products at the Fayetteville Works that either discharge no water or only non -contact cooling water; Chemours can provide production data for these additional products upon request). These 2017 production data supplement the 2015 and 2016 production data Chemours produced on August 18th. See also CH -FW -DEQ -0000001 to CH - FW -DEQ -0000046. • Request 3: Provide a revised mass flow balance schematic that reflects the actual long-term average discharge from Outfalls 001 and 002. Response: See CH -FW -DEQ -0057685. As requested in DEQ's September 10th list of priorities, Chemours has revised the water balance it included in its April 27, 2016 permit application to: (1) reflect the long-term average discharge from Outfalls 001 and 002 (as opposed to the maximum 30 day values used in the 2016 permit application); (2) subtract wastestreams that Chemours began capturing for offsite incineration after it submitted its 2016 permit application (approximately 38,000 gallons labeled for "Off -Site Disposal"); and (3) include DuPont's estimates of the flows from its reverse osmosis and capacitive deionization processes (see streams labeled "RO/CDI Reject Water"). As with any such water balances, some of the flows depicted in CH -FW -DEQ -0057685 are approximations. Chemours has identified each page of these enclosed documents that contains Confidential Business Information. Should any person or agency request an opportunity to inspect or copy the confidential portions of this submission, Chemours requests that it be notified immediately of any such request and be furnished promptly with all written materials pertaining to such request. Chemours further requests that it thereafter be notified promptly of any DEQ determinations with respect to such request and be given ten business days' written notice prior to any intended release so that it may submit additional material substantiating this claim. If DEQ or any other regulatory agency determines that confidential treatment is not warranted with respect to the submission, Chemours respectfully requests ten business days' notice prior to any intended release so that it may pursue any available remedies. Finally, Chemours expects that neither DEQ nor any other regulatory agency will release any material designated confidential until a final judicial determination is made, in accordance with applicable law, including N.C.G.S. § 143-215.3C(d). We are providing the attached information on an expedited basis and Chemours will correct and/or supplement this submission to the extent additional relevant information or analyses become available. September 12, 2017 Page 3 We look forward to continuing to work with DEQ cooperatively on this matter and to the technical call scheduled tomorrow at 3:30pm between DEQ and Chemours. If you have any questions about this submission, please let me know. Sincerely, ROBINSON, BRADSHAW & HINSON, P.A. R. Steven DeGeorge Enclosures cc: Linda Culpepper DEQ Evelyn Brantley The Chemours Company, FC LLC John Savarese Wachtell, Lipton, Rosen & Katz Ralph Levene Wachtell, Lipton, Rosen & Katz Lester Sotsky Arnold & Porter Kaye Scholer Joel Gross Arnold & Porter Kaye Scholer Redacted Redacted FORM 2C ITEM 0-A; LINE DRAWING NPDES PERMIT RENEWAL APPLICATION Chemours Company - Fayetteville Works WATER BALANCE (Revised 09-12-2017) NPDES Permit No. NC0003573 Flow Unita: Gallons per Day Basis: (1) All Manufacturing Units operating (2) Longterm average of Outfall 001 flows (January 2014 -July 2017) minus reduced process wastewater flows from Chemours Fluoroproduct Manufacturing Processes (3) Longterm average of Outfall 002 Rows (January 2014 -July 2017) (4) Filtered Water, Demineralized Water, and Non -Contact River Water Cooling Water flows, water associated with solids handling, and evaporation rates are estimates �_► _� Fear River amatw�reR eaou+o warm rorrrom rtli heua� •-- NaOCI 3 5D0 000 Sediment Removal Fihered Water FlLTERED SD 000 WATER SYSTEM 2400 000 Demineralized Water YAMIRICA ANE FAE SAMI •••• FLUOROPRODUCT PO I I I I K A I IPO YVINYL I �.U WARLrDUPONT UPROCPOLYVINYL MANUFACTURING NUFACURG RLLAMINATE RESIN FLUORIDE BOILERS I MANUFACTURING NROCES9S T., ESS so��q�h r „ ��zt v.vsr lu,usr r- ia.uuu T I sl e,00u i �s� h,�,. 3 1.7 88,OOD) T MAW TgA 1 15,725,102 + NomCOMe4 Coolhg Webr 7 Nomprocvas 791533 co1wemero r eb�eo..n OUTFALL AC AGED CLARIFI- OUTFAL 3 002 r SDG CATION 001 324 000 W TP bII S ¢� S Enporelbn 8104 &OSOUDS DEWATERI 781 234 BloaoRrh NbhNro 2 00 DRYING CH -FW -DEQ -0057685