DEQ-CFW_00003172

Grzyb, Julie
From:
Grzyb, Julie
Sent:
Wednesday, June 14, 2017 8:30 PM
To:
Culpepper, Linda
Cc:
Trent Allen ([e-mail])
Subject:
RE: Gen X Sampling
Linda,
Want to clarify why we should sample at 002:
In accordance with EPA NPDES Permit Writing Guidelines only Technology Based Effluent Limits (TBEL)are placed on internal outfalls (i.e. Outfall 001). TBEL's exist to
demonstrate removal of contaminants as expected by a certain treatment level - usually regulated and determined by Federal Categorical standards (in this case
Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) Effluent Guidelines and Standards (40 CFR Part 414)).
OCPSF regulations do not regulate GenX and the WWTP at Chemours is not designed to treat GenX.
Any limitation the Division places on GenX is likely to be Water Quality Based to protect stream usage. Therefore, in accordance with EPA NPDES Permit Writing
Guidelines a Water Quality Based Effluent Limitation (WQBEL) would be placed at the point of discharge (i.e. Outfall 002).
Non -contact cooling water, stormwater and boiler blowdown are blended with WWTP wastewaters and discharged through Outfall 002 to the Cape Fear. The non -
contact cooling water, stormwater and boiler blowdown are not expected to have GenX in them. WQBELs include all the wastestreams and the limit is calculated so
the total volume discharged to the receiving stream meets the instream water quality standard/criteria that is protective of stream usage.
I am not sure what a sample from the internal outfall would mean to us or how to interpret/assess it. However, I would suggest that the sample taken from Outfall
002 be taken during dry weather, if possible.
Hope this helps clarify my point,
Julie
From: Culpepper, Linda
Sent: Wednesday, June 14, 2017 7:00 PM
To: Shehee, Mina <[e-mail]>; [e-mail]; Cris Harrelson <[e-mail]>; '[e-mail]'
<[e-mail]>; [e-mail]; Staley, Danny <[e-mail]>; Wooten, Maribeth T <[e-mail]>;
Moore, Zack <[e-mail]>; Langley, Rick <[e-mail]>; Risen, Amy J <Amy.Risen @dhhs.nc.gov>; Holt, Kennedy
<[e-mail]>; Gregson, Jim <[e-mail]>; Allen, Trent <[e-mail]>
Cc: Munger, Bridget <[e-mail]>; Brower, Connie <[e-mail]>; Manning, Jeff <[e-mail]>; Godreau, Jessica
DEQ-CFW 00003172

<[e-mail]>; Grzyb, Julie <[e-mail]>; Sink, Marla <[e-mail]>; Holman, Sheila <[e-mail]>
Subject: FW: Gen X Sampling
Jim — I promised to forward the sampling locations to all those on the public health call this morning, so I am using your email below.
Trent — in discussion with local governments later this morning, an attorney George House, indicated they thought the Chemour sampling
location should be at outfall 001 rather than outfall 002. After Sheila and I discussed it further, I now understand that wastewater from
outfall 001 and other wastewaters flow into the collection line for outfall 002 within the plant site. Clutfall 002 is the point the combined
wastewater actually enters the river. Therefore the sampling should be done at outfall 002. If not, we will be losing potential contributions
from other parts of the wastewater that also flow into outfall 002. We want to make sure you agree before discussing this further.
Appreciate everyone's time in all the discussions today.
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.
From: Gregson, Jim
Sent: Wednesday, June 14, 2017 12:34 PM
To: Kritzer, Jamie <[e-mail]>
Subject: Gen X Sampling
Jamie,
My proposal was to sample once per week to coincide with Chenours' samples at the four intakes, the five water treatment plants (CFPUA, Pender
County, Brunswick County, International Paper, and Smithfield Packing) finished water, the CFPUA ASR well and one Wrightsville Beach Well. There
would be three sets of samples over a three week period.
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
2
DEQ-CFW 00003173

Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Jim. gregson ckncdenr.gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
DEQ-CFW 00003174

Grzyb, Julie
From: Culpepper, Linda
Sent: Wednesday, June 14, 2017 7:00 PM
To: Shehee, Mina; [e-mail]; Cris Harrelson; '[e-mail]'; [e-mail]; Staley, Danny; Wooten,
Maribeth T; Moore, Zack; Langley, Rick; Risen, Amy J; Holt, Kennedy; Gregson, Jim; Allen, Trent
Cc: Munger, Bridget; Brower, Connie; Manning, Jeff; Godreau, Jessica; Grzyb, Julie; Sink, Marla; Holman, Sheila
Subject: FW: Gen X Sampling
Jim — I promised to forward the sampling locations to all those on the public health call this morning, so I am using your email below.
Trent — in discussion with local governments later this morning, an attorney George House, indicated they thought the Chemour sampling
location should be at outfall 001 rather than outfall 002. After Sheila and I discussed it further, I now understand that wastewater from
outfall 001 and other wastewaters flow into the collection line for outfall 002 within the plant site. Outfall 002 is the point the combined
wastewater actually enters the river. Therefore the sampling should be done at outfall 002. If not, we will be losing potential contributions
from other parts of the wastewater that also flow into outfall 002. We want to make sure you agree before discussing this further.
Appreciate everyone's time in all the discussions today.
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.
From: Gregson, Jim
Sent: Wednesday, June 14, 2017 12:34 PM
To: Kritzer, Jamie <[e-mail]>
Subject: Gen X Sampling
Jamie,
1
DEQ-CFW 00003175

My proposal was to sample once per week to coincide with Chenours' samples at the four intakes, the five water treatment plants (CFPUA, Pender
County, Brunswick County, International Paper, and Smithfield Packing) finished water, the CFPUA ASR well and one Wrightsville Beach Well. There
would be three sets of samples over a three week period.
Jim Gregson
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7386 Direct
910.350.2004 Fax
Jim. gre gsongncdenr. gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
DEQ-CFW 00003176