2019.05.06_CCO.p26_Long to Holman Approval Request for TOF

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

May 6, 2019
Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Request for Approval Pursuant to Consent Order Paragraph 26
Dear Ms. Holman,
Paragraph 26 of the Consent Order states: “Chemours shall fund development by a third
party contractor(s) of a sampling and analytical methodology for the measurement of Total
Organic Fluorine in its process air emissions and process wastewater. Chemours’ contractor(s)
shall (i) be approved by DEQ, (ii) submit quarterly reports to DEQ, and (iii) submit the
completed methodology to DEQ for review by December 31, 2020.”

Chemours is hereby seeking DEQ’s approval of the third party Chemours proposes to
retain for developing the Total Organic Fluorine (TOF) methodology under Paragraph 26.
Chemours proposes to retain Dr. Susan D. Richardson, the Arthur Sease Williams Professor of
Chemistry in the Department of Chemistry and Biochemistry at the University of South Carolina.
Dr. Richardson’s CV, as well as her detailed proposal for developing the TOF methodology, are
enclosed. Further information about Dr. Richardson and links to her publications are available
online, at https://sc.edu/study/colleges_schools/artsandsciences/our-people/faculty-
staff/richardson_susan.php.

Dr. Richardson is well known and well regarded in the field of analytical environmental
chemistry. Her laboratory at the University of South Carolina has approximately ten graduate
students to support her research efforts, as well as all of the sophisticated instrumentation that
will be needed to perform the requisite scientific analyses. Prior to joining the University of
South Carolina, Dr. Richardson worked for nearly 25 years as a Research Chemist at U.S. EPA’s
National Exposure Research Laboratory in Athens, Georgia.

Also enclosed is an accompanying sampling plan prepared by Chemours’ consultant,
Geosyntec Consultants of NC, P.C. (“Geosyntec”). The sampling plan sets forth how samples
for the development of the TOF methodology will be collected during air and process wastewater
sampling events at Fayetteville Works performed pursuant to other Consent Order provisions,
and how those samples will be provided to Dr. Richardson for her analyses.

To protect the intellectual property and proprietary interests of Dr. Richardson and the
University of South Carolina, Chemours will not be further distributing this submission or
posting it on Chemours’ website. Chemours respectfully requests that DEQ and Cape Fear River

2
Watch, and their respective counsel, likewise maintain the confidentiality of this submission.
After work is underway, Chemours will post the quarterly reports on its website.

Please confirm that Dr. Richardson’s proposal and the accompanying sampling plan
prepared by Geosyntec are acceptable to DEQ, so that this work may timely proceed. We would
also appreciate receiving your confirmation that you will maintain this submission as
confidential. If you have any questions or need further information, please let me know.

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Enclosures
CV of Dr. Susan D. Richardson
Dr. Susan D. Richardson, Proposal for Development of a Total Organic Fluorine Method for
the Analysis of Process Wastewater Streams and Air from Fayetteville Works (NC)
Geosyntec Consultants of NC, P.C., Consent Order Paragraph 26 Total Organic Fluorine
Method Development Sample Collection Plan

Cc:
William F. Lane, DEQ
Francisco Benzoni, NC DOJ
Michael Abraczinskas, DAQ
Michael Scott, DWM
Linda Culpepper, DWR
David C. Shelton, Chemours
John F. Savarese, WLRK
Kemp Burdette, CFRW
Geoff Gisler, SELC