NC0003573_Alternate Schedule Request_20151020

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�TThe Chemours Company 910-483-46810
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Fluoroproducts Chemours Com
22828 NC Highway 87 W
Fayetteville,NC 28306-7332
RECEIVEDIDENRIDWR
OCT 2 3 2015
Water Quality
Permitting Section
CERTIFIED MAIL ARTICLE NUMBER 7002 0860 0006 9104 7521
RETURN RECEIPT REQUESTED
October 20, 2015
Dr. Sergei Chernikov
NCDENR Division of Water Resources
NPDES Complex Permitting Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
•
SUBJECT: Alternate Schedule Request for §316(b) of the Clean Water Act
NPDES Permit No.NC0003573
Dear Dr. Chernikov:
Final regulations implementing §316(b)of the Clean Water Act, which establish requirements for
cooling water intake structures at existing facilities, were published in the Federal Register on
August 15, 2014 with an effective date of October 14, 2014.
The, Chemours Company — Fayetteville Works ("Chemours") operates a cooling water intake
structure on the Cape Fear River that is subject to this new Federal Cooling Water Intake Structure
Rule ("the Rule") as codified in 40 CFR Part 125.
Chemours operates under NPDES Permit No. NC0003573, which expires on October 31, 2016.
The application to renew this permit must be submitted to NCDENR at least 180•days prior to the
expiration of the current permit, which is May 4, 2016.
Pursuant to 40 CFR 125.95(a)(2),the owner or operator of a facility subject to Part 125 Subpart J,
"Requirements Applicable to Cooling Water Intake Structures for Existing Facilities Under
Section 316(b) of the Clean Water Act", whose currently effective permit expires prior to July 14,
2018, may request the Director to establish an alternate schedule for the submission of the
information required•in 40 CFR122.21(r)•when applying for a subsequent (renewed)permit.
The below information is the demonstration"that Chemours cannot develop the required
information by the May 4, 2016,regulatory deadline for submission of the renewal application for
the subject NPDES permit.

Dr. Sergei Chernikov Page 2 of 3
NCDENR Division of Water Resources
October 20, 2015
The design intake flow of the Chemours' cooling water intake structure is 21.6 million gallons per
day ("MGD"), which is greater than two (2) MGD and less than 125 MGD, and therefore, the
following submittals are expected to be required by the Rule:
§122.21(r)(2) Source Water Physical Data
The required information includes physical configuration of the source water body used by
this facility, including areal dimensions, depths, salinity, and temperature regimes. In
addition, the facility must identify and characterize the source waterbody's hydrological and
geomorphological features. This information is not readily available and would have to be
obtained through either publication searches or direct measurements.
§122.21(r)(3) Cooling Water Intake Structure Data
The required information regarding the current cooling water intake structure is available and
could be submitted as part of the 2016 renewal application. However, since a request for an
alternate schedule is being made via this letter, it would be appropriate to submit this
information as part of the complete §316(b) submittal in 2021.
§122.21(r)(4) Source Water Baseline Biological Characterization Data
The required information includes a list of species for all life stages and their relative
abundance in the vicinity of the cooling water intake structure; identification of the species
and life stages that would be most susceptible to impingement and entrainment; identification
and evaluation of the primary period of reproduction, larval recruitment, and period of peak
abundance for relevant taxa; data representative of the seasonal and daily activities of
biological organisms in the vicinity of the cooling water intake structure; identification of all
threatened, endangered, and other protected species that might be susceptible to impingement
and entrainment; and a list of fragile species at the facility. This information is not readily
available and would be a huge and costly undertaking to obtain.
§122.21(r)(5) Cooling Water System Data
The required information regarding the current cooling water system is available and could
be submitted as part of the 2016 renewal application. However, since a request for an alternate
schedule is being made via this letter, it would be appropriate to submit this information as
part of the complete §316(b) submittal in 2021.
§122.21(r)(6) Chosen Method(s) of Compliance with the Impingement Mortality Standard
This facility may choose to comply with the modified traveling screens option of 40 CFR
125.94(c)(5),which requires an impingement technology performance optimization study that
includes two years of biological data collection. This data cannot possibly be collected by the
May 4, 2016, regulatory deadline for submission of the renewal application for the subject
NPDES permit.

Dr. Sergei Chernikov Page 3 of 3
NCDENR Division of Water Resources
October 20, 2015
§122.21(r)(7) Entrainment Performance Studies
The required information submittal includes studies obtained from other facilities addressing
technology efficacy, through-facility entrainment survival, and other entrainment studies.
This information is not readily available and would have to be obtained through publication
searches or direct inquiries.
§122.21(r)(8) Operational Status
The required information regarding the current cooling water system is available and could
be submitted as part of the 2016 renewal application. However,since a request for an alternate
schedule is being made via this letter, it would be appropriate to submit this information as
part of the complete §316(b) submittal in 2021.
In summary, Chemours believes it will require at least four (4) years to collect the above listed
information and prepare the necessary submittals required by the Rule.
The Rule requires the owner or operator of a facility subject to Subpart J whose currently effective
permit expires after July 14, 2018, to submit to the Director the information required in the
applicable provisions of 40 CFR 122.21(r)when applying for a subsequent permit.
The Chemours' currently effective permit expires nearly 21 months prior to July 14, 2018,
therefore as allowed under §125.95(a)(2), Chemours requests an alternate schedule whereby all
the materials required by the Rule will be submitted with the 2021 renewal application.
Should you have any questions, please feel free to call me at(910) 678-1155.
Sincerely,
Michael E. Johnson, PE
Environmental Manager