NC0003573_Request for Additional Information_20170818

Water Resources
ENVIRONMENTAL QUALITY
ROY COOPER
Govenlo,
MICHAEL S REGAN
Seci etar},
S JAY ZIMMERMAN
Du ecla
August 18, 2017
Mr. Ellis H. McGaughy
Plant Manager
The Chemours Company
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Subject: Request for Additional Information
NPDES Application NC0003573
Fayetteville Works
Dear Mr McGaughy:
The Division has reviewed your application for the subject permit. To enable us to complete our review
in accordance with N.C.G.S. 143-215.1 and 15A NCAC 2H.0105, please provide additional or revised
information to address the following comments:
1. Revise the renewal application to update the description of the wastewaters discharged to the
WWTP addressing the removal of all process wastewaters containing HFPO dimer acid and any
other changes since the application was submitted in 2016.
2 Sample and provide test results from Outfalls 001 and 002 for pH, TSS, COD, PFOA, PFOS,
manufacturing operations specific organics, metals, all the chemicals on the handout provided to
DEQ on the July 27, 2017 site visit, and PFECAs compounds. The PFECAs compounds at a
mimmum shall include the list provided in the August 16, 2017 letter to R. Steven DeGeorge,
Esq. Sampling shall be performed during dry weather.
3. Provide a flow schematic of Chemours process areas showing sumps, quench baths, and all points
of discharge to the WWTP. The schematic should reflect actual average flows. Estimated peak
flows can be submitted on a separate schematic.
4. Provide a description and characterization of the wastewaters from each point of discharge to the
WWTP. The wastewater characterization shall include an analysis of pH, TSS, COD, PFOA,
PFOS, manufacturing operations specific organics, metals, and PFECAs compounds.
Specifically, testing shall be performed at each discharge point for the parameters listed above
and the chemicals on the list provided to DEQ on the July 27, 2017 site visit, if believed to be
present at that discharge point.
5. If not all the manufacturing processes are running during the time of sampling, identify the
processes that were sampled and submit a schedule to sample so that wastewaters from all
manufacturing processes that run-in campaigns are tested. Submit this data to DEQ as it is
received from the laboratory.
6. Provide a revised mass flow balance schematic that reflects the actual long-term average
discharge from Outfalls 001 and 002. Estimates on peak flows can be provided separately.
7. Provide a revised flow balance for the DuPont wastewater treatment discharges including flows
from water treatment units as well as process wastewater flows.
8. Provide an electronic copy of the site's BMP plan addressing spill response procedures.
State of North Carolina I Environmental Quality I Water Resources
1617 Mail service Center I Raleigh, North Carolina 27699-1617
919 707 9000

Historical sampling data, no greater than 4.5 years old, may be submitted provided it is representative of
the current wastewaters being discharged.
Please provide your response within 60 calendar days. All the responses shall be submitted to:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: NPDES Complex Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If you have any questions, please contact me at 919-807-6387 or email at Teresa.rodriez ,ncdenr.gov.
Sincerely,
Teresa Rodriguez
NPDES Complex Unit
Division of Water Resources/NCDENR
cc: Linda Culpepper, Division of Water Resources

Environmental
Quality
August 16, 2017
R. Steven DeGeorge, Esq.
Robinson, Bradshaw, & Hinson, P.A.
101 N. Tryon Street, Suite 1900
Charlotte, North Carolina 28246
ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
WILLIAM F. LANE
General Counsel
RE: DEQ Request for Information, including Confidential Business Information
Dear Mr. DeGeorge:
We received your letter dated August 2, 2017, that you submitted on behalf of Chemours. In
your letter, you requested clarification on DEQ's intended meeting of "emerging contaminants."
For purposes of this inquiry, DEQ's reference to "emerging contaminants" includes the
following analytes:
Nothing Compares
State of North Carolina I Environmental Quality
217 West Jones Street 11601 Mall Service Center I Raleigh. North Carolina 27699-1601
919 707 8600
FORMULA
CAS No. if available
Monoether PFECAs
C3HFs03
C4HF703
CsHF903
863090-89-5
C6HF1103
13252-13-6
C7HF1303
C8HF1s03
Polyether PFECAs
C7HFis07
39492-91-6
C6HF1106
39492-90-5
CsHF90s
39492-89-2
C41IF704
39492-88-1
PFESAs
C7HF1305S
66796-30-3
C7H2F140SS
Other
CF20
CF2
PFOS
CBHF1703S
1763-23-1
PFOA free acid
CoHF1502
335-67-1
All chemicals identified in
the handout that was
provided by Chemours to
DEQ during a site visit on
Jul 27, 2017.
Nothing Compares
State of North Carolina I Environmental Quality
217 West Jones Street 11601 Mall Service Center I Raleigh. North Carolina 27699-1601
919 707 8600

R. Steven DeGeorge, Esq.
August 16, 2017
Page 2
Please provide the information requested in our letter of July 21, 2017 by August 30, 2017 and
sooner if possible.
Additionally, and as we discussed in last week's meeting, the State of North Carolina has
requested that Chemours provide access to information that has been submitted to EPA as
Confidential Business Information (CBI). The State reiterates its request for Chemours to
provide DEQ with the following information, or alternatively, to give consent for EPA to
provide such information to DEQ:
• Information, including CBI, submitted to EPA by Chemours or its predecessors related
to the TSCA chemical registration for manufacturing of GenX at the Fayetteville, North
Carolina facility;
• Information, including CBI, submitted to EPA by Chemours or its predecessors related
to all TSCA chemical registrations at the Fayetteville, North Carolina facility,
• All chemical analyses, including CBI, conducted by Chemours or its predecessors for all
manufacturing areas and wastewater outfalls 001 and 002 described in the current
NPDES permit, and
• All human health, toxicity, and aquatic life studies or related information, including CBI,
submitted to EPA by Chemours or its predecessors relating to chemical processes at the
Fayetteville facility.
Please provide a response to this request for TSCA related information by August 23, 2017,
indicating whether Chemours will provide the requested information or consent to EPA's
release of this information to DEQ.
Thank you for your attention to this important matter.
Sincerely,
William F. Lane
cc: Linda Culpepper, Division of Water Resources