DEQ-CFW_00078772

From: Kritzer, Jamie [/D=[XCHANG[LAB5/OU=EXCHANGEADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=C[E9]C49D01445A]B541B8327DCDCD4O-JBKR|TZ[R]
Sent: 6/20/I0I78:I0:29PW1
To: Sink, Marla [/h=ExchangeLabs/ou=[xchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=14436cd[33f147acad6%db9cb7dcfQIb'Mar|a.Sink]
CC: Kritzer, Jamie [/o=ExchangeLabs/ou=ExchanXeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=cee93c49dOI445a3b54Ibb3Z7dcdc84O-jbkritzer]
Subject: RE: Story I'm writing today onChemoursGenX,NPDES
Marla,
Can you send the questions Vaughn asked and then all ofour answers?
I didn't see it in all these emails.
Jamie Kritzer
Communications Director
N.C. Department of Environmental Quality
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From: Sink, Marla
Sent: Tuesday, June JU,JOl7]:O4PM
To: Kritzer, Jamie <[e-mail]>
Subject: FVV:Story I'm writing today un[hemouru,GenX,NPDES
Hi Jamie,
Julie was able to answer one question from Vaughn— (see info below.) He may want to include this in his story.
"Therefore, | have to say that [hemours did identify this compound in its wastewaters in the current and previous
app|ications."
Marla Sink
Public Information Officer
Department ofEnvironmental Quality
Division ofWater Resources
9197079033 office
512 North Salisbury Street

Fnmrn:Grryb Julie
Sent: Tuesday, June 2O,2O17l2:52PK4
To: Sink, Marla
Subject: RE: Story I'm writing today on Chemours, GenX, NPDES
In reviewing the current and previous NPDES applications from Chemours/Dupont in a supplemental Information section
they describe the five different process lines that discharge tuthe VVVVTP. Under the Nafion Membrane Manufacturing
area the application states —
"The HFPO monomer and the Vinyl Ether monomers are used to manufacture various fluorochemical
products such as Chemours Teflon. Wastewater generated from this manufacturing facility is discharged
tothe [hemourswastewater treatment p|ant."
Therefore, | have to say that Chemoumdid identify this compound in its wastewaters in the current and previous
applications.
Julie
From: Sink, Marla
Sent: Tuesday, June ZU,ZO17O:36AM
To: Grzyb,Julie
Cc: Kritzer, Jamie
Subject: FW: Story I'm writing today on Chemours, GenX, NPDES
Please see Vaughn Hagerty'sinformation onpermitting from aformer EPA attorney.
Marla Sink
Public Information Officer
Division of Water Resources
9197079033 office
Fromn:Vaughn Hagerty
Sent: Tuesday, June ZU,ZO176:O9AM
To: Kritzer, Jamie ��ink�K4ar|a Munger, BridgetSubject: Story I'm writing today on Chemours, GenX, NPDES
All
As I indicated to Marla yesterday afternoon, I'm writing a story today regarding Chemours'NPDES permit.
lhad afuirly extensive conversation yesterday with aformer EPA attorney who teaches environmental law
focused on regulations and policy. He also has written a number of texts and course materials for teaching this

He essentially said that Dupont and now Chemours would have to have mentioned GenX (perhaps using a
different name) in its applications for NPDES permits in force since 1980 regardless of whether it is a
"regulated substance." The company has said GenX is discharged at its point source, which the permit covers.
If Chemours or DuPont has not listed GenX, then that may constitute violations under the Clean Water Act.
The company also should have listed the "novel" substances mentioned in Sun, et al., on the permit
applications. My understanding is that, based on sampling above and below the Fayetteville Works, those
appear to be emanating from the Fayetteville Works. Chemours holds the permit governing those discharges
and, as such, is responsible for such reporting.
1) Does DEQ agree with this assessment? If not, please let me know which parts are incorrect and what the
correct interpretation should be.
2) Has GenX ever been mentioned as part of the Fayetteville Works NPDES permit or permit application?
3) What about any of the "novel" substances listed in Sun, et al.? Have they ever appeared in the company's
NPDES permit or permit application? If so, when and how were they mentioned? If not, why not?
4) GenX does not appear in the April 2016 permit renewal application. Can you confirm that and help me
understand why it does not and what that means in terms of that application?
5) If what I describe above is correct, then according to Section 402 of the CWA, the state is bound to "abate
violations of the permit or the permit program, including civil and criminal penalties and other ways and means
of enforcement." Please let me know how the state plans to proceed in this case.
Again, I'm writing this story today. In fact, I'll have most of it finished before noon.
Regards,
Vaughn Hagerty
DEQ-CFW-00078774