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Sands, Heather
From: Johnson, Michael E <[e-mail]>
Sent: Monday, June 08, 2015 8:42 AM
To: Sands, Heather
Subject: RE: Temporary Boiler (ID No. PS -TEMP)
Good morning Heather. I hope your knee is improving and you soon will be kicking field goals again.
See my answers below. In summary, our occasional use of a rental boiler would absolutely meet the definition
of a "temporary boiler".
Mike
Michael E. Johnson, PE
Environmental Manager
The Chemours Company FC, LLC
Chemours Company — Fayetteville Works
[phone]
A boiler is not a temporary boiler if:
(1) The equipment is attached to a foundation. The rental boiler we receive is attached to a mobile
(wheeled) trailer and is never removed from that trailer. The trailer is parked outside of our
Powerhouse, natural gas is piped out to the boiler, and insulated lines connect the boiler to our steam
header. Therefore, the boiler is NOT attached to a foundation.
(2) The boiler or a replacement remains at a location within the facility and performs the same or similar
function for more than 12 consecutive months, unless the regulatory agency approves an extension. An
extension may be granted by the regulating agency upon petition by the owner or operator of a unit specifying
the basis for such a request. Any temporary boiler that replaces a temporary boiler at a location and performs
the same or similar function will be included in calculating the consecutive time period. The rental boiler we
receive is brought on -site to allow maintenance or inspection of one of the permitted permanent
boilers. At most the rental boiler is sited at the facility for two months. Therefore, the boiler does NOT
remain within the facility for more than 12 consecutive months.
(3) The equipment is located at a seasonal facility and operates during the full annual operating period of the
seasonal facility, remains at the facility for at least 2 years, and operates at that facility for at least 3 months
each year. The Chemours Company — Fayetteville Works is not a seasonal facility. Therefore this
requirement is NOT applicable to our facility.
(4) The equipment is moved from one location to another within the facility but continues to perform the
same or similar function and serve the same electricity, steam, and/or hot water system in an attempt to
circumvent the residence time requirements of this definition. The rental boiler, when on -site, is exclusively
located at the facility's Powerhouse. Therefore, the boiler is NEVER moved to another location within
the facility.
DEQ-CFW 00067523

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DEQ-CFW 00067524