DEQ-CFW_00003169

A. The GenX manufacturing area for FRD 902 "GenX" and FRD 905 "GenX" referred to as PPA is closed loop and does not have a discharge. All process
wastewaters generated in this area are shipped to AR or OH for incineration. Yes
What you thought was primarily measured in the Cape Fear was HFPO dimer acid — which is what is used to make FRD 903 "GenX".
Is this process closed loop as well? No. HFPO dimer acid fluoride is produced in the Vinyl Ethers Process as an intermediate for the
perfluoropropyl vinyl ether ("PPVE") finished product (produced in the Vinyl Ethers Process) and also is sent to the PPA Manufacturing
area as the raw material for GenX (produced in the PPA Process). The Vinyl Ethers Process does have wastewater discharges, so it would
not be "closed loop". In the Vinyl Ethers Process, unreacted HFPO dimer acid fluoride comes in contact with water and is converted to
HFPO dimer acid, and that is what was detected in the river.
C. In addition, you stated that the HFPO dimer acid fluoride is possibly discharged in the wastewaters from two manufacturing areas -
1. the VINYL ETHERS PROCESS because it is a byproduct
2. and the manufacturing of PPVE because it's feedstock
The Vinyl Ethers Process produces PPVE as a finished product. Unreacted HFPO dimer acid fluoride (a byproduct of the process) during
the PPVE campaign comes in contact with water and is converted to HFPO dimer acid.
D. The samples being collected will be tested for HFPO dimer acid (can I assume this is the same as HFPO dimer acid fluoride)? Is the fluoride left out because it's
redundant?
The HFPO dimer acid fluoride immediately reacts with water and is converted to HFPO dimer acid. The scrubber system uses an aqueous
solution of potassium hydroxide (KOH), so the chemistry is the HFPO dimer acid fluoride reacts with water to become HFPO dimer acid
and HF, then the HF is immediately reacted with the KOH to form potassium fluoride (KF).
Trying to clarify the process in my mind.
Thanks,
Julie A Grzyb
Supervisor
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
New 919 807 6390 office
919 707 9000 main office
6ulie.arzyb(c-)ncdenr.gov
Physical Address: 512 North Salisbury St., Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
DEQ-CFW 00003169

Grzyb, Julie
From: JOHNSON, MICHAEL E <[e-mail]>
Sent• Thursday, June 15, 2017 7:07 AM
To: Grzyb, Julie
Subject: RE: questions
Hi Julie.
See my answers below in bold.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
r�.
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Grzyb, Julie[mailto:[e-mail]]
Sent: Wednesday, June 14, 2017 5:26 PM
To: JOHNSON, MICHAEL E<[e-mail]>
Subject: questions
Michael,
Are statements A and C correct ? And can you answer B and D?
1
DEQ-CFW 00003170

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