DEQ-CFW_00003150

Grzyb, Julie
From: Culpepper, Linda
Sent: Sunday, June 25, 2017 11:54 PM
To: Shehee, Mina; '[e-mail]'; Cris Harrelson; [e-mail]; [e-mail]; Moore, Zack; Brower,
Connie
Cc: Grzyb, Julie; Risgaard, Jon; Holman, Sheila
Subject: Summary - DEQ/Chemours conf. call 6/23/17
Sharing a summary of the conf. call with Michael Johnson of Chemours on Friday June 23, 2017.
Sheila Holman (DEQ Assistant Secretary), Julie Grzyb (DWR NPDES Complex Permitting Branch Head) and I talked with Michael Johnson, Chemours' Environmental
Manager, for about 1 % hours late Friday afternoon to answer questions we listed on our Friday morning call. Michael had inadvertently declined the meeting notice
while intending to accept and contacted me to re-establish the conference call so we could discuss the below questions:
• How is Chemours containing the GenX wastestream? Chemours is using temporary storage tanks in the manufacturing areas to hold the waste as they are
working on final out of state disposal options. Chemours sent a waste characterization to a commercial incinerator in Arkansas, and shipped one trailer there
on Thurs. (June 22) for a trial burn.
• The NPDES permit renewal application indicates 160,000 gallons of fluor -monomer wastewater is generated each day. Is all of it being contained in the
tanks? Michael Johnson indicated the volume wastewater being contained in the temporary tanks is 13,000 gallons per day. He is going to look back at the
permit renewal application to clarify how much wastewater is generated by the Vinyl Ether process area.
• Is Chemours keeping the process air vents closed as Michael Johnson had indicated was initiated the prior week? Michael indicated they have kept the
process air vents closed since Thurs. June 151", the day of the public meeting in Wilmington. The manufacturing process seems to be working well under those
conditions, so they have kept them closed as a way to reduce emissions.
• Is there air deposition? Michael indicated he does not think the acid fluoride gas would be an air deposition concern.
• Kuraray and DuPont wastestreams—what is Chemours monitoring? Chemours is monitoring Biological Oxygen Demand and Chemical Oxygen Demand in the
Kuraray and DuPont effluent. The two companies are billed for wastewater treatment by Chemours. Vinyl fluoride is a gas used to make poly vinyl fluoride
resin (a powder). Chemours is not monitoring for vinyl fluoride in the effluent. We indicated that a professor has indicated Kuraray is discharging C-8/POFA —
Michael indicated that most of the C-8 is coming from the water intake (upstream). Chemours is monitoring the intake water as grab samples and reporting in
their a-DMR to Julie's Branch. Michael indicated that in the vinyl ether process, some fraction will assemble into C-8, which is monitored in Chemour's effluent
testing in the NPDES permit.
Julie let Michael Johnson know she had been made aware that a search of the EPA database for NPDES permits indicated Kuraray is the name of the permit
holder for the facility — she notified EPA to make the correction to indicate the permit is held by Chemours.
How is Chemours anticipate changing its NPDES renewal permit application to reflect the new process changes to reduce the release of GenX? Chemours is
considering what the permanent process changes will be. We discussed the need for the permit to reflect current conditions at the time of permitting. Julie
also asked about testing stormwater to evaluate if GenX has entered the stormwater system and if it is being controlled. A revised process flow schematic
could be submitted as an addendum to the renewal application to depict current conditions.
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• Why did Chemours install the gas permeator in 2013? Chemours was controlling the CO2 in the wastewater and voluntarily reducing the overall GenX
emissions.
• Who is purchasing GenX for use? Michael indicated there are no GenX customers in North Carolina. Customers are in West Virginia, New Jersey, the
Netherlands, Japan, China, and India.
• What has been and will be the production schedule for the Vinyl Ether campaign? Michael Johnson is going to send us the production records so we can
determine if all of Dr. Knappe's samples were taken during the Vinyl Ether production campaigns, including his more recent sampling in Dec. 2016 and May
2017.
• Will Chemours agree to additional well sampling? Brunswick County is interested in having their 211 well sampled for GenX. The County has indicated the
well is not under the influence of surface water but they would like the assurance of having the water tested. Michael will ask whether or not Chemours would
pay for the testing. We discussed that groundwater typically flows to surface water. During flood conditions flow patterns may change but would shift back to
normal after flooding recedes.
• Will Chemours agree to waive Confidential Business Information (CBI) protection for DEQ and DHHS? Initial reactions by Chemours to the request was
"No". EPA is looking into whether or not the health studies were under the CIB, and at the same time Sean Gannon, with Chemours, is sharing information
with Dr. Amy Risen on the health studies so that Dr. Risen had access to the complete study information rather than just study summaries. DEQ will continue
seeking CBI clearance to see what chemicals are managed onsite as byproducts or in some other way are entering the wastewater so that the state can fully
evaluate the NPDES permitting needs. TSCA statutes changed last fall and EPA Head Quarters is working on the process and guidance for states to be granted
access to CBI. EPA considers whether the need is for response to a release, or if it is for regulatory purposes such as permitting. DEQ will need to list who
needs to see what information and why.
• Does Chemours achieve any removal of GenX in their wastewater treatment? No, bacteria do not like fluorides. The acid fluorides are hydrophilic and stay in
water. Chemours assumes the concentration that goes into the wastewater treatment also comes out of the wastewater treatment. There may be some air
emission from the wastewater aeration.
I've asked Julie and Jon Risgaard, the Water Quality Regional Operations Section Chief, if they could join our 9:30am call to better explain what type of compliance
monitoring is done for NPDES permits.
Linda Culpepper
Deputy Director
Division of Water Resources
North Carolina Department of Environmental Quality
1611 Mail Service Center
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.
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