DEQ-CFW_00070787

Mccartv, Bud
From: Utterback, Carl
Sent: Monday, June 30, 2014 5:01 PM y�
To: Mccarty, Bud /' t
Subject: FW: DuPont EPA ID Number + „A
Bud,
Finally, here's some info on "SpinCo" — I will read through these and ponder a bit and then run the answers by you &
Larry before responding to Mike. Also forwarded to Larry since it didn't look like Mike emailed him directly.
Thanks,
Carl
From: [e-mail][mailto:Michael. E.Johnson(Uupont.com]
Sent: Monday, June 30, 2014 3:21 PM
To: Utterback, Carl
Subject: DuPont EPA ID Number
Hi Carl.
As you remember, I made a presentation to NC-HWS on the future splitting of the DuPont Company —
Fayetteville Works into three separate companies:
• Kuraray Americas with the Butacite® and SentryGlas® businesses;
• Performance Chemicals ("SpinCo") with the Fluoromonomers, Nafion® membrane, and the Polymer
Processing Aid Process; and
DuPont with the Polyvinyl Fluoride ("PVF") business.
The Kuraray America's sale was formally final on June 1, 2014, therefore those two businesses are no longer
part of DuPont.
The latest timing I have heard is that SpinCo will be officially made into a wholly owned subsidiary of DuPont
on February 1, 2015. Then after successfully demonstrating the financial viability of the SpinCo entity, SpinCo
will be officially spit from the DuPont Company and become a completely separate legal entity around July 1,
2015.
As we discussed, SpinCo will become the owner and operator of all of the permitted hazardous waste units at
this site, and hence will become the new owner of the current DuPont RCRA Hazardous Waste Management
Permit. I will at some point in the future submit to NC-HWS the needed paperwork and applications for this
change of ownership (see Question 4 below).
The DuPont PVF Facility will generate more than 100 kg and less than 1,000 kg of hazardous waste per month,
and will therefore be a Small Quantity Generator. As a SQG, DuPont will need an EPA Identification Number.
Finally my four questions:
DEQ-CFW 00070787

1. During our meeting, NC-HWS was strongly emphatic that the current EPA ID Number (NCD 047 368
642) would remain with the holder of the RCRA Permit, in other words the NCD 047 368 642 EPA ID
Number would be transferred to SpinCo. Is that still the position of NC-HWS?
2. Assuming the answer to Question 1 is "Yes, SpinCo would have EPA ID Number NCD 047 368 642",
then when would DuPont need to get their new EPA ID Number? On February 1, 2015 when SpinCo
becomes a wholly owned subsidiary, or on July 1, 2015 when SpinCo and DuPont become two totally
separate companies?
3. Part II(C) of the RCRA Permit, "Receipt of Off -Site Wastes" states that the "Permittee shall not accept
shipments of hazardous waste from off -site." When SpinCo becomes a wholly owned subsidiary of
DuPont on February 1, 2015, will this prohibition apply to the DuPont PVF Unit and the SpinCo
subsidiary? In other words, can the drum of D001 PVF hazardous waste be stored on the site's
Hazardous Waste Container Area that is located in the SpinCo Facility? .
4. Given the timing that I show above, when would you recommend that we submit to NC-HWS the
application to transfer the ownership of the RCRA Permit from DuPont to SpinCo? Our corporate leads
have stated that it is the goal to have the SpinCo environmental permits in place when the February 1,
2015, subsidiary is formed. FIAXI � II L Q-4L
Thank you in advance for your words of wisdom on these questions!
Mike
Michael E. Johnson, PE
Environmental Manager
DuPont Company — Fayetteville Works
[phone]
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