DEQ-CFW_00070923

Name:
Nathaniel D. Thornburg
Title:
Environmental Program Supervisor III
Section:
Water Quality Permitting
Branch:
Non -Discharge Permitting
Phone:
919-807-6453
Email:
[e-mail]
Office:
Archdale — 640K

Thornburg, Nathaniel Thornburg, Nathaniel
From:
Goodrich, David
From:
Johnson, Michael E<[e-mail]>
Sent:
Friday, August 28, 2015 8:05 AM
Sent:
Friday, August 28, 2015 2:15 PM
To:
[e-mail]
To:
Goodrich, David
Cc:
Thornburg, Nathaniel
Cc:
Thornburg, Nathaniel
Subject:
Requesting review of Draft Permit W00035431
Subject:
RE: Requesting review of Draft Permit W00035431
Attachments:
W00035431dp150000.docx
Attachments:
W00035431dp150000(MEJComments).doc
Follow Up Flag:
Follow up
Follow Up Flag:
Follow up
Flag Status:
Completed
Flag Status:
Completed
Hello Mr. Johnson,
Please find the attached draft of the subject permit which reflects the change in ownership from DuPont Company —
Fayetteville Works to The Chemours Company FC, LLC, which I am transmitting for your review and comment. Please
examine this document and send me your comments / approval, as appropriate, on or before September 4, 2015.
Thank you.
Regards,
David Goodrich
Central Office
NC Division of Water Resources
NC Department of Environment and Natural Resources
Hi David.
Attached is a marked up (via Track Changes) copy of the draft permit you sent me.
In summary, the only needed revision is changing our location from Cumberland County to Bladen County
(cover letter pages 1 and 2; Permit page I and Attachment A).
I realize that the current permit has us listed in Cumberland County, which might have been semi -
understandable in 2011 because we were land applying our river sediment (that was located in Bladen County)
to a part of our property that is located in Cumberland County (our entrance road is named County Line Road
for a reason). However, the entire manufacturing facility is in Bladen County and any future land application
will be done in Bladen.
Putting on my RCRA hat, allow me to point out a regulatory issue with Section IV(2) of the permit, which
states: "The analyses [corrosivity, ignitability, reactivity and toxicity characteristic leaching procedure
(TCLP)] shall be performed..." to demonstrate the residuals are non -hazardous.
However, there are no analytical test methods available for determining reactivity. With regard to the eight
categories for a reactive waste in 40 CFR 261.23(a), it is either a subjective determination (ex; "It reacts
violently with water" and "When mixed with water, it generates toxic gases, vapors or fumes in a quantity
sufficient to present a danger") or it is a definitive fact (ex: "It is a forbidden explosive as defined in 49 CFR
173.54, or is a Division 1.1, L2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53"). Bottom line is an
analytical determination for reactivity does not exist.
I am sure that the four RCRA characteristics are merely lumped together in this paragraph for ease of language,
however I think the current language could confuse the layperson. The other three characteristics are undeed
determined via an analytical method, but only if the residual is a liquid... the dry river sediment that we will be
land applying cannot be analyzed for ignitability nor corrosivity as specified under the RCRA regulations.
Thanks for your assistance and I hope you have a great weekend.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company— Fayetteville Works
[phone]
DEQ-CFW 00070924

hemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Goodrich, David [mailto:[e-mail]]
Sent: Friday, August 28, 2015 8:05 AM
To: Johnson, Michael E<[e-mail]>
Cc: Thornburg, Nathaniel <[e-mail]>
Subject: Requesting review of Draft Permit W00035431
Hello Mr. Johnson,
Please find the attached draft ofthe subject permit which reflects the change in ownership from DuPont Company —
Fayetteville Works to The Chemours Company FC, LLC, which I am transmitting for your review and comment. Please
examine this document and send me your comments / approval, as appropriate, on or before September 4, 2015.
Thank you.
Regards,
David Goodrich
Central Office
NC Division of Water Resources
NC Department of Environment and Natural Resources
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours_Home/en_US/email_disclaimer.html
Thornburg, Nathaniel
From: Goodrich, David
sent: Friday, August 28, 2015 2:26 PM
To: Johnson, Michael E
Cc: Thornburg, Nathaniel
Subject: RE: Requesting review of Draft Permit WQ0035431
Follow Up Flag: Follow up
Flag Status: Completed
Hello Michael,
Thank you for your review and comments. I appreciate your advice on the "reactivity analysis" requirement, and it is
apparent that some form of change and/or clarification is in order. Your assistance is appreciated.
Regards,
David Goodrich
NC Division of Water Resources
From: Johnson, Michael E [malito:[e-mail]]
Sent: Friday, August 28, 2015 2:15 PM
To: Goodrich, David
Cc: Thornburg, Nathaniel
Subject: RE: Requesting review of Draft Permit W00035431
Hi David
Attached is a marked up (via Track Changes) copy of the draft permit you sent me.
In summary, the only needed revision is changing our location from Cumberland County to Bladen County
(cover letter pages I and 2; Pen -nit page I and Attachment A).
I realize that the current permit has us listed in Cumberland County, which might have been semi -
understandable in 2011 because we were land applying our river sediment (that was located in Bladen County)
to a part of our property that is located in Cumberland County (our entrance road is named County Line Road
for a reason). However, the entire manufacturing facility is in Bladen County and any future land application
will be done in Bladen.
Putting on my RCRA hat, allow me to point out a regulatory issue with Section IV(2) of the permit, which
states: "The analyses [corrosivity, ignitability, reactivity and toxicity characteristic leaching procedure
(TCLP)] shall be performed..." to demonstrate the residuals are non -hazardous.
However, there are no analytical test methods available for determining reactivity. With regard to the eight
categories for a reactive waste in 40 CFR 261.23(a), it is either a subjective determination (ex; "It reacts
violently with water" and "When mixed with water, it generates toxic gases, vapors or fumes in a quanti
sufficient to present a danger") or it is a definitive fact (ex: "It is a forbidden explosive as defined in 49 CFR
173.54, or is a Division 1.1, 1.2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53"). Bottom line is an
analytical determination for reactivity does not exist.
DEQ-CFW 00070925

I am sure that the four RCRA characteristics are merely lumped together in this paragraph for ease of language,
however I think the current language could confuse the layperson. The other three characteristics are undeed
determined via an analytical method, but only if the residual is a liquid... the dry river sediment that we will be
land applying cannot be analyzed for ignitability nor corrosivity as specified under the RCRA regulations.
Thanks for your assistance and 1 hope you have a great weekend.
Mike
Michael E, Johnson, PE
Environmental Manager
Chemours Company— Fayetteville Works
[phone]
0 aw
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306.7332
From: Goodrich, David[mailto:david.eoodrich(@ncdenr.eov]
Sent: Friday, August 28, 2015 8:05 AM
To: Johnson, Michael E <MICHAEL.E.JOHNSON chemours.com>
Cc: Thornburg, Nathaniel <nathaniel.thornbure ncdenr.eov>
Subject: Requesting review of Draft Permit WQ0035431
Hello Mr. Johnson,
Please find the attached draft of the subject permit which reflects the change in ownership from DuPont Company —
Fayetteville Works to The Chemours Company FC, LLC, which I am transmitting for your review and comment. Please
examine this document and send me your comments / approval, as appropriate, on or before September 4, 2015.
Thank you.
Regards,
David Goodrich
Central Office
NC Division of Water Resources
NC Department of Environment and Natural Resources
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours Home/en US/email disclaimer.html
DEQ-CFW 00070926

Thornburg, Nathaniel
From:
Johnson, Michael E<[e-mail]>
Sent:
Friday, August 28, 2015 3:18 PM
To:
Goodrich, David
Cc:
Thornburg, Nathaniel
Subject:
RE: Requesting review of Draft Permit WQ0035431
Follow Up Flag:
Follow up
Flag Status:
Completed
Thanks for the note, David.
As long as I am sticking my nose where it does not belong and I have my amateur -lawyer hat on, how about the
following to address the RCRA issue:
A demonstration shall be made that the residuals Residuals ,
are non -hazardous under the Resource Conservation and Recovery Act (RCRA). Residuals that
tests or areis classified as a hazardous er-toxie waste under 40 CFR Part 261 shall not be used or
disposed under this permit. The demonstration that the residuals are not characteristically
hazardous for 1"lie-anal;yes -[corrosivity, ignitability, reactivity, and/or toxicity eltarae.Bt�ristic
Itaehiiig-•proc-edef-L (FC1,P)} shall be performed as specified by 40 CFR 261.21 through 261.24
res-pectivciv and at the frequency specified in Attachment A, and the Permittee shall maintain these
results for a minimum of five years. Any exceptions from the requirements in this condition shall
be specified in Attachment A.
The first two sentences would cover both listed and characteristic hazardous wastes. The third sentence gives
guidance as to how to determine if the residuals are a characteristically hazardous waste. Under RCRA there is
not a "toxic" waste .... wastes are either hazardous or non -hazardous... and I would remove that word. There is
no need to mention the TCLP method, because that is spelled out in Part 261.24(a), and the Permittee has
already been directed to that section.
Something to consider.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
Chemours
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Goodrich, David [mailto:[e-mail]]
Sent: Friday, August 28, 2015 2:26 PM
To:Johnson, Michael E<[e-mail]>
Cc: Thornburg, Nathaniel<[e-mail]>
Subject: RE: Requesting review of Draft Permit WQ0035431
Hello Michael,
Thank you for your review and comments. I appreciate your advice on the "reactivity analysis" requirement, and it is
apparent that some form of change and/or clarification is in order. Your assistance is appreciated.
Regards,
David Goodrich
NC Division of Water Resources
From: Johnson, Michael E (mailto:MICHAEL.E.JOHNSONCilchemours.coml
Sent: Friday, August 28, 2015 2:15 PM
To: Goodrich, David
Cc: Thornburg, Nathaniel
Subject: RE: Requesting review of Draft Permit W00035431
Hi David.
Attached is a marked up (via Track Changes) copy of the draft permit you sent me.
In summary, the only needed revision is changing our location from Cumberland County to Bladen County
(cover letter pages 1 and 2; Permit page 1 and Attachment A).
I realize that the current permit has us listed in Cumberland County, which might have been semi -
understandable in 2011 because we were land applying our river sediment (that waslocated in Bladen County)
to a part of our property that is located in Cumberland County (our entrance road is named County Line Road
for a reason). However, the entire manufacturing facility is in Bladen County and any future land application
will be done in Bladen.
Putting on my RCRA hat, allow me to point out a regulatory issue with Section IV(2) of the permit, which
states: "The analyses [corrosivity, ignitability, reactivity, and toxicity characteristic leaching procedure
(TCLP)] shall be performed..." to demonstrate the residuals are non -hazardous.
However, there are no analytical test methods available for determining reactivity. With regard to the eight
categories for a reactive waste in 40 CFR 261.23(a), it is either a subjective determination (ex; "It reacts
violently with water" and "When mixed with water, it generates toxic gases, vapors or fumes in a quanti1y
sufficient to present a danger") or it is a definitive fact (ex: "It is a forbidden explosive as defined in 49 CFR
173.54, or is a Division 1. 1, 1.2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53"). Bottom line is an
analytical determination for reactivity does not exist.
I am sure that the four RCRA characteristics are merely lumped together in this paragraph for ease of language,
however I think the current language could confuse the layperson. The other three characteristics are undeed
determined via an analytical method, but only if the residual is a liquid.., the dry river sediment that we will be
land applying cannot be analyzed for ignitability nor corrosivity as specified under the RCRA regulations.
DEQ-CFW 00070927

Thanks for your assistance and I hope you have a great weekend.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
u
h�:ai ours'"
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Goodrich, DavidImailto:[e-mail]
Sent: Friday, August 28, 2015 8:05 AM
To: Johnson, Michael E<MICHAEL.E.JOHN50NOchemours.com>
Cc: Thornburg, Nathaniel<nathaniel.thornburgPncdenr.gov>
Subject: Requesting review of Draft Permit WQ0035431
Hello Mr. Johnson,
Please find the attached draft of the subject permit which reflects the change in ownership from DuPont Company —
Fayetteville Works to The Chemours Company FC, LLC, which I am transmitting for your review and comment. Please
examine this document and send me your comments / approval, as appropriate, on or before September 4, 2015.
Thank you.
Regards,
David Goodrich
Central Office
NC Division of Water Resources
NC Department of Environment and Natural Resources
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours Home/en US/email disclaimer.html
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours_Home/en_US/email_disclaimer.html
to
DEQ-CFW 00070928

Thornburg, Nathaniel
From: [e-mail]
Sent: Wednesday, September 16, 2015 12:32 PM
To: Thornburg, Nathaniel
Subject: Message from KMBT 423
Attachments: SKMBT_42315091611290.pdf
Thornburg, Nathaniel
From: Thornburg, Nathaniel
Sent: Wednesday, September 16, 2015 12:34 PM
To: Goodrich, David
Subject: WQ0035431 - The Chemours Company FC, LLC
Attachments: WQ0035431p150916.pdf
David,
The subject permit has been signed. Please send the attached scanned copy to all electronic recipients.
Thank you,
Nathaniel
»rx+r+a���r:+�nrr*rr�x•�x»w. �.s pr+e+++ar++
Nathaniel 1). Thornburg-- Supervisor
Division of Water Resources
Water Quality Permitting Section -- Non -Discharge Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
9t9-807-6453
919-807.6496 FAX
hitp,//portal ncdenr orS/webhva/a Oau
DISCLAIMER: All a -mails sent to and from this account are subject to the North Carolina Public Records Law and may be disclosed
to third parties,
DEQ-CFW 00070929

Thornburg, Nathaniel
From: Goodrich, David
Sent: Wednesday, September 16, 2015 1:06 PM
To: Thornburg, Nathaniel
Subject: RE: WQ0035431 - The Chemours Company FC, LLC
Nathaniel,
Thank you for your transmission. I have sent the signed permit to all of the electronic recipients
David
From: Thornburg, Nathaniel
Sent: Wednesday, September 16, 2015 12:35 PM
To: Goodrich, David
Subject: WQ0035431 - The Chemours Company FC, LLC
David,
The subject permit has been signed. Please send the attached scanned copy to all electronic recipients.
Thank you,
Nathaniel
Nathaniel D. Thornburg- Supervisor
Division of Water Resources
Water Quality Permitting. Section -Non-Discharge Permitting Unit
1617 A4ail Service Center
Raleigh, NC 27699-1617
919-807-6453
919-807-6496 FAX
17(tp;_/ portal ncdenr:o-ra/web/wa/aps/lau
DISC I.,AIMF.R. All e-mails sent to and from this account are sul�icct to the North Carolina Public Records Law and may be disclosed
to third parties.
Thornburg, Nathaniel
From: Thornburg, Nathaniel
Sent: Tuesday, October 04, 2016 3:24 PM
To: Glazier, Patrick K
Subject: WQ0035431 - Chemours Company Renewal
Kipp.
We received the permit renewal for the subject facility. You can close out the NOV for this facility.
Thank you!
PS - Does this type of notification work for you? Do I need to do something else? Also, when was/is the deadline for
the remaining residuals permits with NOVs that are expired?
Nathaniel D. Thornburg
Environmental Program Supervisor III
Non -Discharge Permitting Unit
Department of Environmental Quality
919 807 6453 office
nathaniel.thornbureCo)ncdenr.gov
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
�Nt thfrtg;
Email correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to third parties.
14
DEQ-CFW 00070930

Thornburg, Nathaniel
From: Glazier, Patrick K
Sent: Tuesday, October 04, 2016 3:30 PM
To: Thornburg, Nathaniel
Subject: RE: WQ0035431 - Chemours Company Renewal
This works fine for notification.
I need to look each USPS tracking number up for the exact date. Most will be the week of Oct. 10th
Kipp Glazier
Environmental Sr. Specialist
Non -Discharge Permitting, Division of Water Resources
Department of Environmental Quality
919.807.6319
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
From: Thornburg, Nathaniel
Sent: Tuesday, October 04, 2016 3:24 PM
To: Glazier, Patrick K <[e-mail]>
Subject: WQ0035431- Chemours Company Renewal
Kipp,
We received the permit renewal for the subject facility. You can close out the NOV for this facility
Thank you I
PS — Does this type of notification work for you? Do I need to do something else? Also, when was/is the deadline for
the remaining residuals permits with NOVs that are expired?
Nathaniel D.Thornburg
Environmental Program Supervisor III
Non -Discharge Permitting Unit
Department of Environmental Quality
919 807 6453 office
nathaniel.thorn [e-mail]
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
IR
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
16
DEQ-CFW 00070931

Thornburg, Nathaniel
From: Ooby, Troy
Sent: Thursday, October 06, 2016 11:33 AM
To: [e-mail]
Cc: Thornburg, Nathaniel
Subject: WQ0035431 - Chemours Company - Fayetteville Works
Mr. Johnson,
I have received your renewal package. The cover letter explained the situation very clearly and I would like to ask a
question about permit language considering you are applying to your own land.
In the 2015 permit, there was language for distributing the residuals to another party (Conditions 111.10 and 11). Do you
wish to keep this language? It is standard language in our permits, but if you do not need it, there is no reason to have it
in the permit.
Thanks in advance.
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/lau
Thornburg, Nathaniel
From: JOHNSON, MICHAEL E<[e-mail]>
Sent: Wednesday, October 12, 2016 9:41 AM
To: Doby, Troy
Cc: Thornburg, Nathaniel
Subject: RE: W00035431 - Chemours Company- Fayetteville Works
Hi Troy.
Sorry for the delay. I have been a little behind on email due to Hurricane Matthew.
I cannot imagine any scenario where we would be distributing the river water treatment residuals to another
party.
Therefore you can feel free to eliminate Conditions 11I.10 and I 1 from the renewal permit.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company— Fayetteville Works
[phone]
�'1et'1"' ours"
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Doby, Troy (mailto:[e-mail]]
Sent: Thursday, October 06, 2016 11:33 AM
To: JOHNSON, MICHAEL E <[e-mail]>
Cc: Thornburg, Nathaniel <[e-mail]>
Subject: WQ0035431- Chemours Company - Fayetteville Works
Mr. Johnson,
1 have received your renewal package. The cover letter explained the situation very clearly and I would like to ask a
question about permit language considering you are applying to your own land.
In the 2015 permit, there was language for distributing the residuals to another party (Conditions 111.10 and 11). Do you
wish to keep this language? It is standard language in our permits, but if you do not need it, there is no reason to have it
in the permit.
Thanks in advance.
Troy Doby, PhD, PE
18
DEQ-CFW 00070932

Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http_([port111.nc;denr_or webLwgLa:s Lau
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours_Home/en_US/email_disclaimer.html
19
Thornburg, Nathaniel
From: Doby, Troy
Sent: Thursday, October 13, 2016 7:56 AM
To: JOHNSON, MICHAEL E
Cc: Thornburg, Nathaniel
Subject: RE: WQ0035431 - Chemours Company - Fayetteville Works
Mike,
Glad you survived the storm, floods and power outages. Slowly getting back to normal here as well.
I have made all the appropriate language changes for your particular circumstances. A shorter permit.
Troy
.
From: JOHNSON, MICHAEL E[mailto:[e-mail]]
Sent: Wednesday, October 12, 2016 9:41 AM
To: Doby, Troy <[e-mail]>
Cc: Thornburg, Nathaniel <[e-mail]>
Subject: RE: WQ0035431- Chemours Company - Fayetteville Works
Hi Troy.
Sorry for the delay. I have been a little behind on email due to Hurricane Matthew.
I cannot imagine any scenario where we would be distributing the river water treatment residuals to another
party.
Therefore you can feel free to eliminate Conditions III.10 and 11 from the renewal permit.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company— Fayetteville Works
[phone]
gf: Chemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Doby, Troy [mailto:[e-mail]
Sent: Thursday, October 06, 2016 11:33 AM
To: JOHNSON, MICHAEL E<[e-mail]>
20
DEQ-CFW 00070933

Cc: Thornburg, Nathaniel<[e-mail]>
Subject: WQ0035431 -Chemours Company - Fayetteville Works
Mr. Johnson,
I have received your renewal package. The cover letter explained the situation very clearly and I would like to ask a
question about permit language considering you are applying to your own land.
In the 2015 permit, there was language for distributing the residuals to another party (Conditions 111.10 and 11). Do you
wish to keep this language? It is standard language in our permits, but if you do not need it, there is no reason to have it
in the permit.
Thanks in advance.
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http;j[portal.ncdenr or:Jweb/walaps/lau
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https;[[www.chemours.ct�,rn/Chemours_Horr.�e[en USLem�il disclaimer:htrt�(
21
Thornburg, Nathaniel
From:
Doby, Troy
Sent:
Thursday, December 29, 2016 7:22 AM
To:
[e-mail]
Cc:
[e-mail]; Barber, Jim; Thornburg, Nathaniel; Henson, Belinda
Subject:
W00035431 - Chemours Company- Fayetteville Works
Attachments:
WQ0035431a161229.pdf; NDSDAL 09-15 - Copy.docx
Mr. McGaughy,
Please find attached a copy of an additional information letter and a copy of the NDSDAL 09-15 form to answer the
additional information letter.
If you have any questions, please do not hesitate to contact me.
Hope you have a good New Year!
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/lau
22
DEQ-CFW 00070934

Thornburg, Nathaniel
From: Doby, Troy
Sent: Thursday, December 29, 2016 7:26 AM
To: Thornburg, Nathaniel
Subject: W00035431 - Chemours Company - Fayetteville Works
Nathaniel,
Will you correct Ellis McGoughey's email address in BIMS. It doesn't have the "r" in Chemours.
Thanks]
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/lau
23
Thornburg, Nathaniel
From:
Doby, Troy
Sent:
Tuesday, January 03, 2017 9:04 AM
To:
Barber, Jim
Cc:
Thornburg, Nathaniel
Subject:
W00035431 - Chemours Company - Fayetteville Works
Attachments:
DRAFTWQ0035431.pdf
Jim,
Have reviewed your staff report and it looks as though there isn't anything to add to the shell. Even though there is an
additional information request out, this does not affect the permit either.
So I'd like to send you the draft permit and get your input. If you have any comments, questions or concerns, please let
me know by next Monday, the 10tb of January. If everything is ok, please let me know that as well.
Thanksl
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/iau
24
DEQ-CFW 00070935

Thornburg, Nathaniel
From:
JOHNSON, MICHAEL E<[e-mail]>
Sent:
Tuesday, January 03, 2017 9:12 AM
To:
Doby, Troy
Cc:
Barber, Jim; Thornburg, Nathaniel; Henson, Belinda; ellis.mcgaughy@chemous,com
Subject:
RE: WQ0035431 - Chemours Company - Fayetteville Works
Attachments:
Chemours Delegation of Authority.pdf
Good morning, Troy.
Attached you will find this site's Delegation of Authority whereby Paul Kirsch, The Chemours Company
Fluoroproducts President, has delegated to the Plant Manager of the Chemours Company —Fayetteville Works
Plant "the authority to sign or execute any permit application".
This Delegation of Authority was effective as of August 1, 2016.
I trust this will satisfy the NC-DWR request.
If you need any additional information, please let me know.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company —Fayetteville Works
[phone]
P10 Chemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Doby, Troy [mailto:[e-mail]]
Sent: Thursday, December 29, 2016 7:22 AM
To: [e-mail]
Cc: JOHNSON, MICHAEL E<[e-mail]>; Barber, Jim <[e-mail]>; Thornburg,
Nathaniel<[e-mail]>; Henson, Belinda <[e-mail]>
Subject: WQ0035431 - Chemours Company - Fayetteville Works
Mr. McGaughy,
Please find attached a copy of an additional information letter and a copy of the NDSDAL 09-15 form to answer the
additional information letter.
If you have any questions, please do not hesitate to contact me.
25
Hope you have a good New Year!
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
htto:!/aortal ncdenr.ore/web/wa/aos/lau
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours_Home/en_US/emal l_disclaimer.htmi
26
DEQ-CFW 00070936

Thornburg, Nathaniel
From: Doby, Troy
Sent: Tuesday, January 03, 2017 9:14 AM
To: JOHNSON. MICHAEL E
Cc: Barber, Jim; Thornburg, Nathaniel; Henson, Belinda; [e-mail]
Subject: RE: W00035431 - Chemours Company- Fayetteville Works
Good morning, Mike:
It is perfect and exactly what I needed to move the permit along.
Thanks for rapid response.
Hope you had a good Christmas and New Years.
Troy
From: JOHNSON, MICHAEL [e-mail]
Sent: Tuesday, January 03, 2017 9:12 AM
To: Doby, Troy <[e-mail]>
Cc: Barber, Jim <[e-mail]>; Thornburg, Nathaniel<[e-mail]>; Henson, Belinda
<[e-mail]>; [e-mail]
Subject: RE: WQ0035431- Chemours Company - Fayetteville Works
Good morning, Troy.
Attached you will find this site's Delegation of Authority whereby Paul Kirsch, The Chemours Company
Fluoroproducts President, has delegated to the Plant Manager of the Chemours Company — Fayetteville Works
Plant "the authority to sign or execute any permit application".
This Delegation of Authority was effective as of August 1, 2016.
1 trust this will satisfy the NC-DWR request.
If you need any additional information, please let me know.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company— Fayetteville Works
[phone]
Cit@t'T'1Ciurs-
27
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Doby, Troy lmailto:[e-mail]
Sent: Thursday, December 29, 2016 7:22 AM
To: gllis.mcgau_&,hy (Z1_jtmo1As,com
Cc: JOHNSON, MICHAEL E <[e-mail]>; Barber, Jim <jim.barber ncdenr.eov>; Thornburg,
Nathaniel<nathaniel.thornbure@ncdenceov>; Henson, Belinda <belinda.hensonCla ncdenr.gov>
Subject: WQ0035431- Chemours Company - Fayetteville Works
Mr. McGaughy,
Please find attached a copy of an additional information letter and a copy of the NDSDAL 09-15 form to answer the
additional information letter.
If you have any questions, please do not hesitate to contact me.
Hope you have a good New Yearl
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
htto://oortal.ncdenr,orpJweb/wq/ans/lau
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
htt s: Lwww.chemours_comlChemours Home en USLgmail disclajmer.html
28
DEQ-CFW 00070937

Thornburg, Nathaniel
From: Doby, Troy
Sent: Wednesday, January 04, 2017 8:59 AM
To: Ghiold, Joe
Cc: Thornburg, Nathaniel; Allen, Trent; Honeycutt, Tony; White, Kenneth B; Barber, Jim
Subject: FW: WQ0035431 - Chemours Company- Fayetteville Works
Attachments: 2L IMACs PFOA.pdf; DRAFTWQ0035431.pdf
Joe,
Jim Barber said I should contact you about the renewal of the Chemours Class A residuals permit to obtain your input
regarding Perfluorooctanoic acid, PFOA, and land application of their residuals.
Several questions come to mind:
• Currently the permit does not contain any requirement for PFOA testing. Should this be added?
• If the PFOA concentration is above a certain concentration, should there be a requirement that the residuals be
taken to a hazardous waste disposal facility?
• Should there be a blanket ban on land application of the residuals?
If there are other requirements you would suggest, please do so.
I am attaching a copy of the draft permit as well as the 2L limits for PFOA.
Thanks in advance.
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/lau
From: Barber, Jim
Sent: Tuesday, January 03, 2017 5:01 PM
To: Doby, Troy <[e-mail]>
Cc: Allen, Trent <[e-mail]>; Honeycutt, Tony <[e-mail]>; White, Kenneth 8
<kenneth.white @ncdenr.gov>
Subject: RE: WQ0035431- Chemours Company - Fayetteville Works
Troy;
The only comment I have is related to the sampling parameters for the material. The issue with the Class A material
staying on the Chemours (formerly DuPont) site was related to PFOA (C8). The former project manager in the Haz.
Waste Section was Larry Stanley (retired after initial permit was issued). He didn't want the water treatment residuals to
29
leave the site due to the possibility of PFOA being in the river sediment/alum residual. Might want to check with
Nathaniel to see if we need to add PFOA to the sampling parameter list to see if or how much PFOA is being spread
around the site verses being contained in the lagoons. There are dozens of wells on the site that Haz. waste section may
require monitoring on and I don't recall the number located around the 30 ac. +/- area in the middle of the plant site.
With the low standard groundwater standard of 2ppb, it may be of some benefit to know what the concentration of
PFOA is in the residuals in the event Haz. waste monitoring wells start detecting PFOA.
The new project manager for the site is Joe Ghiold. Here is his contact information per Julie Woosley (Haz. Waste Section
Chief):
Office #: 919-707-8375 or [e-mail]
DWM-Hazardous Waste Section
1646 Mail Service Center
Raleigh, NC 27699-1646
He may or may not have an issue with the Class A residuals being spread throughout the plant site or he may not be
aware of the history and could have heartburn with land application. If so, then it would be Haz. waste responsibility to
require disposal at a lined, Subtitle D landfill and not allowing land application. Robeson County and Sampson County
have a lined landfill that could take the material if that's the direction Haz. waste wants to take.
Jim Barber
Environmental Engineer
NCDEQ-DWR-WQRO
Fayetteville Regional Office
910-433-3340 voice
910-486-0707fax
Iim.barberg.ncden r.ciov
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.
AGo Greenl Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
••e•e••eses+•••r•**
From: Doby, Troy
Sent: Tuesday, January 03, 2017 9:04 AM
To: Barber, Jim <jim,barber@ncdenr.�o_v>
Cc: Thornburg, Nathaniel<[e-mail]>
Subject: WQ0035431- Chemours Company - Fayetteville Works
Jim,
Have reviewed your staff report and it looks as though there isn't anything to add to the shell. Even though there is an
additional information request out, this does not affect the permit either.
So I'd like to send you the draft permit and get your input. If you have any comments, questions or concerns, please let
me know by next Monday, the 10t1 of January. If everything is ok, please let me know that as well.
Thanksl
30
DEQ-CFW 00070938

Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
htt p://t)ortal.ncd enr.orp/weblwo//aos/iau
Thornburg, Nathaniel
From:
Barber, Jim
Sent:
Thursday, February 09, 2017 11:53 AM
To:
Doby, Troy
Cc:
Culpepper, Linda; Thornburg, Nathaniel; Allen, Trent
Subject:
Chemours formerly DuPont Fayetteville Works
Attachments:
Chemours River mud alum Class A sites.jpg; FW: WQ0035431 - Chemours Company -
Fayetteville Works
Troy;
As we discussed on Tuesday; my interest in reaching out to DWM — Haz. Waste Section was to give them the opportunity
to make comments on the proposal to land apply the Class "A" material within the plant site ( see attached map and
location labeled class "A" site ). Larry Stanley was the project manager with DWM — HW when the original permit was
issued for the land application area outside of the plant fence (class "A" area 2012). Larry was adamant that the material
stay on DuPont property and or if it left, that it go to a proper disposal site ( i.e. lined landfill either in Robeson or
Sampson County). There are numerous monitoring wells inside the plant site scattered amongst the different business
units. The issue was the potential to introduce PFOA onto other areas of the plant site that could have monitoring wells
and the well(s) detect PFOA when historically they haven't.
Based on your contact/correspondence with Joe Ghiold, new project manager of the Chemours site, is fine with the
proposed plan; please draft the renewed permit and send to Mike Johnson for review and comment.
I'm copying Linda Culpepper with this email since she may have insight or comments related to this site.
Jim Barber
Environmental Engineer
NCDEQ-DWR-WQRO
Fayetteville Regional Office
910-433-3340 voice
910-486-0707fax
ilm.barber0mcdenngov
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.
A Go Greenl Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
DEQ-CFW 00070939

Thornburg, Nathaniel
From:
Doby, Troy
Sent:
Thursday, February 09, 2017 2:39 PM
To:
[e-mail]
Cc:
Thornburg, Nathaniel
Subject:
WQ0035431 - Chemours Company - Fayetteville Works
Attachments:
DRAFTWQ0035431.pdf
Mr. Johnson,
Please find attached a copy of the draft permit for Chemours, WQ0035431. If you have any comments, questions or
concerns, please let me know by next Thursday, Feb. 16". If everything is ok, please let me know that as well.
Thanks!
Troy Doby, PhD, PE
Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/web/wq/aps/lau
IE
Thornburg, Nathaniel
From: JOHNSON, MICHAEL E<[e-mail]>
Sent: Monday, February 13, 2017 10:30 AM
To: Doby, Troy
Cc: Thornburg, Nathaniel
Subject: RE: WQ0035431 - Chemours Company- Fayetteville Works
Troy:
Thank you for the opportunity to review and comment of the subject draft land application permit.
Here is the only needed correction I found:
Page 1: In two (2) locations in the first paragraph, the company name is shown as "The Chemours Company
Fc, LLC" whereas it should be "The Chemours Company FC, LLC".
Thanks again.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
go Chemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Doby, Troy [mailto:[e-mail]]
Sent: Thursday, February 09, 2017 2:39 PM
To: JOHNSON, MICHAEL E<[e-mail]>
Cc: Thornburg, Nathaniel<[e-mail]>
Subject: WQ0035431- Chemours Company - Fayetteville Works
Mr. Johnson,
Please find attached a copy of the draft permit for Chemours, WQ0035431. If you have any comments, questions or
concerns, please let me know by next Thursday, Feb. 16th. If everything is ok, please let me know that as well.
Thanksl
Troy Doby, PhD, PE
34
DEQ-CFW 00070940

Non -Discharge Permitting Unit
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http;/1partal_nc:denr�org web/tva/a>s_!au
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
Francais Deutsch Italiano Espanol Portugues Japanese Chinese Korean
https://www.chemours.com/Chemours_Home/en_US/email_disclaimer.html
35
Thornburg, Nathaniel
From: Thornburg, Nathaniel
Sent: Tuesday, March 07, 2017 3:07 PM
To: Doby, Troy
Subject: WQ0035431 - Fayetteville Works
Please put the draft permit for the subject residuals management system on the shared drive
Thank you,
Nathaniel D. Thornburg
Environmental Program Supervisor III
Non -Discharge Permitting Unit
Department of Environmental Quality
919 807 6453 office
[e-mail]
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
K''C&
Email correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to third parties.
36
DEQ-CFW 00070941

Thornburg, Nathaniel
From: Doby, Troy
Sent: Tuesday, March 07, 2017 3:24 PM
To: Thornburg, Nathaniel
Subject: RE: WQ0035431 - Fayetteville Works
Done.
From: Thornburg, Nathaniel
Sent: Tuesday, March 07, 2017 3:07 PM
To: Doby, Troy <[e-mail]>
Subject: WQ003S431 - Fayetteville Works
Please put the draft permit for the subject residuals management system on the shared drive
Thank you,
Nathaniel D. Thornburg
Environmental Program Supervisor III
Non -Discharge Permitting Unit
Department of Environmental Quality
919 807 6453 office
nathaniel.thornburgtancdenr.gov
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
.�t ozhingComp:ares.,k,..,_
Fm[;ii rorresponderu:e to and from, ttvs 0<if>'11'S.$ t.S 5idrljf.?t f' Ef the
North i orofino Public Records Law urnd rnoy be disclosed to third parties.
37
Thornburg, Nathaniel
From: [e-mail]
Sent: Tuesday, March 07, 2017 4:17 PM
To: Thornburg, Nathaniel
Subject: Scanned page
Attachments: SKMBT_42317030716150.pdf
38
DEQ-CFW 00070942

Thornbura. Nathaniel
From: Thornburg, Nathaniel
Sent: Tuesday, March 07, 2017 4:17 PM
To: Doby, Troy
Subject: WQ0035431 - Fayetteville Works
Attachments: W0003543lpl70307.pdf; WQ0035431revl70307.docx; WQ003543ldpl70307.docx
Troy,
Please send the attached permit to the electronic recipients.
Thank you,
Nathaniel D.Thornburg
Environmental Program Supervisor III
Non -Discharge Permitting Unit
Department of Environmental Quality
919 807 6453 office
nathaniel.thornbureCancdenr.gov
512 N. Salisbury St.
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
'a.
Eenoil correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to third parties.
DEQ-CFW 00070943