DEQ-CFW_00003177

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Grzyb, Julie
From: Grzyb, Julie
Sent: Tuesday, June 13, 2017 2:43 PM
To: Emily Barnes (Sen. Michael Lee)
Cc: Culpepper, Linda
Subject: RE: Follow up - GenX
Emily,
Regarding this question:
Our office is researching what is required of a company before they discharge chemicals or substances into a river, as well as
what they are required to show. If you have any information that is readily available to us, it would be greatly appreciated!
Here is some general information that I hope will help walk you through the process.
NC Administrative Code requires (15A NCAC 02H .0101) a permit for control of sources of water pollution by providing the
requirements and procedures for application and issuance of state NPDES permits for a discharge from an outlet, point source,
or disposal system discharging to the surface waters of the state. These rules reflect Federal NPDES permitting laws under 40
CFR 122 which the State implements.
Major industrial discharges, such as Chemours, are required to complete EPA NPDES applications which require a certain
amount of sampling as described in 48 FR 14153, Apr 1, 1983. Applicants evaluate effluent for priority pollutants as defined by
EPA. Link to application forms: https://deg.nc.gov/permitting-applications
EPA has established effluent guidelines for over 57 different types of Industrial categories. Chemours is subject to the Organic
Chemicals, Plastics, and Synthetic Fibers (OCPSF) Point Source Category (40 CFR Part 414). Each industrial applicant must
characterize their wastestreams (define each source and provide test analysis of the contaminants contained in each
wastestream). The applicant is required to give the discharge volume of each wastestream and what treatment will be
provided to meet State and Federal Standards for the receiving stream to which they propose to discharge.
The applicant may be required to perform a model for its oxygen consuming wastes — to protect dissolved oxygen in the
stream. Also, depending on the receiving stream classification (use) they may have to perform a treatability study to confirm
treatment levels and/or a nutrient response model to protect Nutrient Sensitive Waters.
Federal Categorical Guidelines often have set technology based effluent limitations that NPDES puts in the permit. In addition,
limits and/or monitoring for pollutants of concern for particular types of wastewaters are put in the permit. And last, the
discharge characterization supplied in the application (each chemical sampled per the list supplied by EPA) is compared against
State and Federal Standards or Criteria to see if there is potential to violate any standards/ criteria. If so, additional limitations
are added to the permit.
If the permittee identifies a unique contaminant, NPDES reviews EPA databases for guidance on how to regulate the
contaminant. As described in rule 15A NCAC 02B .0208 "For carcinogens, the concentrations of toxic substances shall not
result in unacceptable health risks and [... ] An unacceptable health risk for cancer shall be considered to be more than one case
of cancer per one million people exposed (1-6 risk level)..." Therefore if EPA has a study that has determined this risk level,
than this is the concentration NPDES would use to determine a NPDES permit limitation.
The draft permit is sent to public notice, EPA, and the permittee - all at the same time for a minimum of thirty days. Anyone
can comment or request a hearing. If no hearing is requested the permit can be issued 15 days after the end of the public
notice period provided any changes made to address comments are not significant (do not make the permit less stringent).
Please let me know if you need additional information,
DEQ-CFW 00003177

Julie
VA
Julie A Grzyb
Supervisor
NPDES Complex Permitting
NC DEQ / Division of Water Resources / Water Quality Permitting
919 807 6390 office
919 707 9000 main office
iulie grzyb(qncdenr.gov
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617
-^---"Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Culpepper, Linda
Sent: Monday, June 12, 2017 10:30 PM
To: Emily Barnes (Sen. Michael Lee) <[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: Follow up - GenX
Emily — I apologize for the delay due to meetings most of the day on the same topic.
Hope that DHHS will have their health statements available to help with the risk perspective.
Julie — please help Emily with information when you get in tomorrow.
Thank you both.
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: Emily Barnes (Sen. Michael Lee) [mailto:Leela ncga.state.nc.us]
Sent: Monday, June 12, 2017 10:39 AM
To: Culpepper, Linda <linda.culpepper(@ncdenr.gov>
Subject: RE: Follow up - GenX
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DEQ-CFW 00003178

Good morning Linda,
Our office is researching what is required of a company before they discharge chemicals or substances into a river, as well as
what they are required to show. If you have any information that is readily available to us, it would be greatly appreciated!
Thank you,
Emily Barnes
Legislative Assistant
Office of Senator Michael Lee
91h District — New Hanover
[phone]
From: Culpepper, Linda[mailto:linda.culpepper(a)ncdenr.aov]
Sent: Friday, June 09, 2017 5:55 PM
To: Emily Barnes (Sen. Michael Lee)
Cc: Godreau, Jessica; Grzyb, Julie; Miller, Anderson
Subject: Follow up - GenX
Emily — thank you for sharing the below with Sen. Lee and Rep. Grange. Appreciated the opportunity to talk with them this
afternoon.
Sen. Lee and Rep. Grange:
We certainly understand the public concerns surrounding the issue with GenX and are working with the EPA and others to
learn more about the chemical compound and any potential impacts it may have.
It's important for the public to know that drinking water from the Cape Fear Public Utility Authority meets all state and federal
drinking water standards.
EPA has established standards for many pollutants impacting water quality and public health. North Carolina and other states
are in communication with EPA as further guidance and research is developed that
will provide the state Department of Environmental Quality with the information needed to begin developing regulatory limits
for GenX.
The EPA is the sole agency responsible for establishing drinking water standards nationwide and has extensive resources
necessary to determine the nature, extent and potential impacts of chemicals such as GenX.
When EPA establishes guidance for emerging contaminants such as GenX, this triggers the process used by EPA and states like
North Carolina to develop regulations for these contaminants.
People should be assured that there are steps that DEQ staff are taking while we're awaiting guidance from the EPA. DEQ
officials are talking with Chemours to assess waste streams containing GenX and determine
if the company can reduce the amount of the chemical compound being discharged to the river.
DHHS has drafted a summary of their review and I have asked them to share that with you directly so that you can follow up
with them as needed.
Thank you for your time this afternoon.
Linda Culpepper
Deputy Director
DEQ-CFW 00003179

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.
DEQ-CFW 00003180