2019.05.30_CCO.p11.a.b_ResponsesToCommentsOnSubmissions

From:Culpepper, Linda
To:Martin, Allen D
Cc:Johnson, Chris; Peterson, Kyle R
Subject:FW: [External] RE: Paragraph 11a review -- RE: Responses to Comments on Paragraphs 11.a and 11.bSubmissions
Date:Saturday, June 1, 2019 3:58:43 PM
Attachments:image001.pngEurofins_EPA537Mod_SOP.pdfTestAmerica_EPA537Mod_SOP.pdf
Allen – realized I had not forwarded info. received Thurs. on Method SOPS.

Linda

Linda Culpepper
Director, NC DEQ Division of Water Resources

Email: [e-mail]
Phone: [phone]

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Garon, Kevin P <[e-mail]>
Sent: Thursday, May 30, 2019 3:46 PM
To: Culpepper, Linda <[e-mail]>; Long, Brian D <[e-mail]>
Cc: Holman, Sheila <[e-mail]>; Lane, Bill F <[e-mail]>; Benzoni,
Francisco <[e-mail]>; Abraczinskas, Michael <[e-mail]>; Scott,
Michael <[e-mail]>; Shelton, Dave <[e-mail]>;
[e-mail]; [e-mail]; [e-mail]; Compton, Christel E
<[e-mail]>; Gross, Joel M. <[e-mail]>; Tom
Santoro <[e-mail]>; Allison Rumsey
<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: [External] RE: Paragraph 11a review -- RE: Responses to Comments on Paragraphs 11.a and
11.b Submissions

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]

Dear Ms. Culpepper,

Please find attached the revised SOPs for Method 537 v1.1 Mod from Eurofins and TestAmerica. We
are providing these SOPs on behalf of the laboratories. These attachments should satisfy the
remaining request noted in the second bullet in the May 24th response to you.

Respectfully submitted,
Kevin

From: Garon, Kevin P
Sent: Friday, May 24, 2019 2:01 PM
To: 'Culpepper, Linda' <[e-mail]>; Long, Brian D
<[e-mail]>
Cc: Holman, Sheila <[e-mail]>; Lane, Bill F <[e-mail]>; Benzoni,
Francisco <[e-mail]>; Abraczinskas, Michael <[e-mail]>; Scott,
Michael <[e-mail]>; Shelton, Dave <[e-mail]>;
[e-mail]; [e-mail]; [e-mail]; Compton, Christel E
<[e-mail]>; Gross, Joel M. <[e-mail]>; Tom
Santoro <[e-mail]>; Allison Rumsey
<[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: Paragraph 11a review -- RE: Responses to Comments on Paragraphs 11.a and 11.b
Submissions

Dear Ms. Culpepper,

Thank you for your comments on the Chemours Response to Comments on Paragraphs 11.a and
11.b.. Below are Chemours’ responses in blue text to your comments. Please feel free to call Brian
Long, Plant Manager at [phone], or me at 704-560-6435 if you have questions.

Experiments on stabilities tests are indicated as being planned – what is the anticipated timing
for the results?
Chemours is planning to begin stability testing on Table 3+ standards within the next 2-3
months. To assess stability, one set of duplicate standards will be stored at room
temperature and a second set of duplicate standards will be stored under refrigeration
(approximately 4 to 6°C). Standards will be analyzed once a month for up to one year. The
results of the experiment will be available 1-2 months after the last analysis with interim
updates provided based on data availability.
There’s an indication in T3-3 that revised SOPs from both Test America and Eurofins
laboratories will be provided in the near future – what is the anticipated timing?
The revised SOPs for Table 3+ were provided to NCDEQ via email on May 6th by Brian Long
along with the revised workplan for Paragraph 11(b) Characterization Plan and the table of
Responses to Comments. The revised SOPs for Method 537 v1.1 Mod will be provided in the
next couple weeks following final revisions and review.
Regarding synthesized compounds, DEQ requests them to be submitted to NCDEQ and EPA
R4/ORD as they are developed, rather than upon request.
Chemours will provide synthesized compounds to NCDEQ and EPA R4/ORD as they are
developed. Please provide us a contact and shipping location as to where you would like
these materials sent.
In addition DEQ requests Q-TOF-MS data files and chromatograms to be submitted to NCDEQ
with all results, rather than upon request.
Chemours will provide Q-TOF-MS data files and chromatograms to NCDEQ as they are
available.

Respectfully submitted,
Kevin

From: Culpepper, Linda [mailto:[e-mail]]
Sent: Monday, May 13, 2019 12:05 AM
To: Long, Brian D <[e-mail]>
Cc: Holman, Sheila <[e-mail]>; Lane, Bill F <[e-mail]>; Benzoni,
Francisco <[e-mail]>; Abraczinskas, Michael <[e-mail]>; Scott,
Michael <[e-mail]>; Shelton, Dave <[e-mail]>;
[e-mail]; [e-mail]; [e-mail]; Compton, Christel E
<[e-mail]>; Gross, Joel M. <[e-mail]>; Tom
Santoro <[e-mail]>; Allison Rumsey
<[e-mail]>; Garon, Kevin P <[e-mail]>; Grzyb, Julie
<[e-mail]>
Subject: ⚠ Paragraph 11a review -- RE: [External] Responses to Comments on Paragraphs 11.a and
11.b Submissions

External email. Confirm links and attachments before opening.

Brian – thank you for the response to the comments to Paragraph 11a components. Many areas
have been addressed by incorporating the suggested changes.

We do have a few follow up questions on the submittal:
Experiments on stabilities tests are indicated as being planned – what is the anticipated timing
for the results?
There’s an indication in T3-3 that revised SOPs from both Test America and Eurofins
laboratories will be provided in the near future – what is the anticipated timing?

I have asked EPA R4 and ORD to follow up on whether use of spiked field samples should be
required, and will forward information on that topic and any other
remaining items from EPA upon receipt.

Regarding synthesized compounds, DEQ requests them to be submitted to NCDEQ and EPA R4/ORD
as they are developed, rather than upon request.
In addition DEQ requests Q-TOF-MS data files and chromatograms to be submitted to NCDEQ with
all results, rather than upon request.

Linda

Linda Culpepper
Director, NC DEQ Division of Water Resources

Email: [e-mail]
Phone: [phone]

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Long, Brian D <[e-mail]>
Sent: Monday, May 6, 2019 1:42 PM
To: Culpepper, Linda <[e-mail]>
Cc: Holman, Sheila <[e-mail]>; Lane, Bill F <[e-mail]>; Benzoni,
Francisco <[e-mail]>; Abraczinskas, Michael <[e-mail]>; Scott,
Michael <[e-mail]>; Shelton, Dave <[e-mail]>;
[e-mail]; [e-mail]; [e-mail]; Compton, Christel E
<[e-mail]>; Gross, Joel M. <[e-mail]>; Tom
Santoro <[e-mail]>; Allison Rumsey
<[e-mail]>; Garon, Kevin P <[e-mail]>
Subject: [External] Responses to Comments on Paragraphs 11.a and 11.b Submissions

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]

Dear Ms. Culpepper,

Please see the attached responses to comments on Paragraphs 11 (a) and 11(b) submissions.

Sincerely,

Brian D. LongPlant Manager – Fayetteville Works, Chemours™ Fluoroproducts
[phone] o+1 302 668 8818 m
The Chemours Company22828 NC Highway 87W Fayetteville, NC 28306
LinkedIn | Twitter | Chemours.com

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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
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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.

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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.

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