DEQ-CFW_00047354

1) Can you explain the relationship between DuPont, Chemours, and Kuraray?
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productsa fluorinated chemicals manufacturer. Chemours'
fluorinated monomers and fluorinated vinyl ethers, Nafion", membranes and dispersion, and
fluoropolymer•
boilers, which provide steam for
Also located at this facility are two tenant companies:DuPont
Company. Kuraray operates the ButaciteO polyvinyl butyral (PVB) thermoplastic sheet and resin
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two polyvinyl fluoride
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sent ♦ ♦ plant. Chemours•. e for the treatment and
discharge of all wastewaters. These process wastewaters along
stormwater collected from process areas, are treated in the Chemours'owned and operated
wastewater treatment plant. Treated wastewaters from the wastewater plant are mixed with non -
contact cooling water, stormwater, and boiler blowdown from all three facilities and discharged
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Which company(s) is/are actually producing GenX either as a commercial product or a waste byproduct?
For each company that is producing GenX, please explain how GenX is captured and/or treated?
DEQ understandsbeen -. and
incinerated off -site. No discharge of wastewaters occurs from this area.
The Chemours' fluorinated vinyl ethers process discharges GenX as a byproduct
Chemours began capturing. on June 21, 2017.r r
understanding that all wastewaster from the Vinyl Ethers Process, approximately 13,000 to 15,000
gallons per day, are held in temporary storage tanks until they are hauled to Arkansas for
were discharged to the Activated Sludge Wasterwater Treatment Plant where all other process
wastewaters are being discharged.
DEQ-CFW 00047354

What companies are contributing GenX to the waste stream that is treated on site and then discharged
per NPDES Permit # NCO003573. (I understand that Chemours has recently agreed to
capture/truck/incinerate GenX, but | am interested in the process immediately prior to this voluntary
2) Please confirm that Chemours, per NPIDES Permit # NCO003573, is ultimately responsible for any
substance that is discharged from the site, regardless of which of the three companies adds that
substance tothe vvaste*tream.
facility under NPIDES Permit No. NCO003573.
3) Please explain the 2009 Consent Order between EPA and DuPont, and the 2017 First Amendment to
Order on Consent. Does this consent order allow for the discharge of GenX as a by-product at the
Fayetteville Works site?
response or tell NC DEQ who to coordinate with at EPA to get an answer.
Did NC DEQ take this document into consideration when writing NPIDES Permit # NCO003573? If so,
please explain how this document was considered and whether it influenced the terms of the permit.
NPIDES files show that on August 26, 2010 a meeting was held between DuPont, DWIVI and DWQ. The
meeting summary stated the following:
DuPont gave an update on the 2010115 PFOA Stewardship Program, an EPA sponsored
of PFOA and related chemicals by 95 percent by 2010, and to work toward eliminating
emissions and product content by 2015.
DuPont is currently testing a new product called GenX, to replace PFOA. DuPont stated that
DuPont's planned environmental exposure control technologies will reduce the potential for
environmental release and exposure.
USEPA TSCA Office granted DuPont approval to commercially manufacture, process, and
distribute GenX under conditions setforth in a Consent Order. , al

low repeated dose toxicity in mammalian testing;
it is not mutagenic or genotoxic;
it is not a skin sensitizer
GenX technology will enable the production offluoropolymer resins, and end -use articles
and expects to meet the 2015 commitment to phase out PFOA.
It is unclear what impact this information had on the permit renewal, if any. PFOA sampling was
maintained in the permit under Outfall 002.
4) Please explain how the current NPDES permit allows for the discharge of GenX.|tbpresent inthe
discharge but does not appear to be listed in the Effluent Limitations and Monitoring Requirements
Subpart i If reporting or monitoring is not required by the NPDES permit are there other requirements
for the company to report its discharge of GenX or other perfluorinated compounds and if so, what are
those requirements and where can the public access this data?
ethers process. These wastewaters are discharged to the Activated Sludge Wastewater Treatment
Plant where all other process wastewaters are being discharged.
body (elimination in 12-24 hours compared with months for PFOA); low acute toxicity in marnmalia
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it
and aquatic testing; low repeated dose toxicity in mammalian testing; it is not mutagenic or
its
genotoxic; and it is not a skin sensitizer. Currently, there are no NPDES permit limits or monitoring
requirements for unregulated compounds such as GenX or other perfluorinated compounds.
All discharge data is available via the monthly Discharge Monitoring Reports (DMRs) submitted to
DEQ. The last three years of DMRs have been attached as a file along with these responses. All DMRs
are publicly available.
5) (similar to #3) Please explain how the current NPDES permit allows for the discharge of C8 or PFOA.
PFOA monitoring is required at the facility's effluent discharge point - Outfall 002, see Section A. (3.)
of the permit. DEQ was aware Chemours was working to reduce global facility emissions and product
content of PFOA and related chemicals by 95 percent by 2010, and toward eliminating emissions and
product content by 2015. Monitoring for PFOA was maintained in the NPDES permit on Outfall 002 as
a check to make sure PFOA was being reduced.

A review of effluent data shows a slight increase of PFOA between the water withdrawal intake at
Chemours'• ° measured at the discharge point,be • r
as the part of the permit renewal process. A review of the Chemours' effluent data from 5-4-2016 thru
4-12-2017 showsdischarge of • from • Outfall 002 0.014 or r
PFOA • PFOS. LowPFAS in the Capea of •consistent
the findings of the US EPA UCMR3 data collected in this part of the Cape Fear.
The 2009 EPA consent order appears to prohibit the discharge of C8 or PFOA and yet it also appears to
be present in the discharge. These compounds also do not appear to be listed in the Effluent Limitations
and Monitoring Requirements - Subpart I.
If reporting or monitoring is not required by the NPDES permit are there other requirements for the
company to report its discharge of C8 or PFOA or other perfluorinated compounds and if so, what are
those requirements and where can the public access this data?
All discharge data is available via the monthly Discharge Monitoring Reports (DMRs) submitted to
DEQ.
6) DEQ's sister agency DHHS has determined, based on one European study, that GenX poses a low
health risk at levels at or below 70,909 ppt (although among researchers there is a growing consensus
that GenX is as toxic as C8 suggesting this level may be high). If DHHS determines that a compound is
present at unsafe levels in drinking water how does that finding impact DEQ's permitting process?
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could potentially be used to determine a permit limitation until EPA criteria are developed.
Has there been communication between DEQ and DHHS regarding the presence of perfluorinated
compounds in the Cape Fear River?
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Please explain how the DHHS assessment will influence the renewal of NPDES Permit # NC0003573. How
would DEQ respond if DHHS were to lower the safe concentration determination for GenX, or other
perfluorinated compounds, below the concentrations currently found in the river.
discharged in the Outfall will not-.. of a determined instrearn limitation. If there
are additional sources to be accounted for, NPDES can consider background concentrations in the
DEQ-CFW 00047357

7) What is the process for establishing Water Quality Based Effluent Limits for pedluohnated
compounds, like GenX?
8) Chemours voluntarily ceased discharging GenX into the Cape Fear River. Given the uncertainty of the
impacts to downstream drinking water supplies, what steps is DEQ taking in the permit renewal process
toensure that this discharge isnot resumed bythe company?
DEQ wants to analyze all the sampling results recently collected, work with DHHS to understand an
acceptable level in drinking water (if this can be determined), and make sure there is a complete
characterizations of all wastewaters being discharged at the Chemours facility before a permit
Vinyl Ether process wastewaters until a better understanding of this compound is achieved.