DEQ-CFW_00047359

1) Can you explain the relationship between DuPont, Chemours, and Kuraray?
productsa fluorinated chemicals manufacturer. Chemours'
fluorinated monomers and fluorinated vinyl ethers, Nafion", membranes and dispersion, and
fluoropolymer•
provideboilers, which •
locatedAlso ♦DuPont♦.
Kuraray operates the ButaciteO polyvinyl butyral (PVB) thermoplastic sheet and resin manufacturing
unit and the SentryGlasO ionoplast interlayer manufacturing unit. DuPont operates two polyvinyl
fluoride (PVF) resin manufacturing units.
sent to Chemours' wastewater treatment plant. Chemours is responsible for the treatment and
discharge of all wastewaters. These process wastewaters alongand
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 -
Which company(s) is/are actually producing GenX either as a commercial product or a waste byproduct?
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For each company that is producing GenX, please explain how GenX is captured and/or treated?
product. r • understands that wastewaters from this area have always been -. and
incinerated ♦ No discharge of wastewaters occurs
fluorinatedThe Chemours' vinyl ethers process discharges GenX as a byproduct
beganChemours . Process' on June 21, 2017.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 Wastewater Treatment Plant where all other process
wastewaters are being discharged.
DEQ-CFW 00047359

What companies are contributing GenX to the waste stream that is treated on site and then discharged
per NPDES Permit # NC0003573. (I understand that Chemours has recently agreed to
capture/truck/incinerate GenX, but I am interested in the process immediately prior to this voluntary
decision).
to June 21, 2017I11 to 15,000 gallons per ♦.y frr process were discharged
to the Activated Sludge Wastewater Treatment Plant where all other process wastewaters are being
discharged. Treated wastewaters fromplant are mixed with non-contactcooling
stormwater, and boiler blowdown and discharged through Outfall 002 to the Cape Fear River
under• r' Discharge permit NCO003573.
2) Please confirm that Chemours, per NPDES Permit # NC0003573, is ultimately responsible for any
substance that is discharged from the site, regardless of which of the three companies adds that
substance to the waste -stream.
♦A responsibmi,♦ r r ♦ ♦-
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?
•S • #I •I swam ape ' ' ♦ • • •
Did NC DEQ take this document into consideration when writing NPDES Permit # NC0003573? If so,
please explain how this document was considered and whether it influenced the terms of the permit.
statedNPIDES files show that on August 26, 2010 a meeting was held between DuPont, DWM and DWQ. The
meeting summary the following:
emissionsDuPont 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
• ► product content
rpm 0 r r • •a • • • .• • I1 ! '• PT
DuPont's planned environmental exposure control technologies will reduce the potential for
environmental release and exposure.
s • . • ' • . `' • • • • • • •.. ic"�_tj
USEPA TSCA Office granted DuPont approval t• commercially manufacture,process, • r
distribute GenX under• • r • • Consent Order.
DEQ-CFW 00047360

low acute toxicityI !!: and aquatic
low repeated dosetoxicitytesting;
it is not mutagenicor /'::1 /
it is not a skin sensitizer
GenX technology ! I production offluoropolymer♦ ! r articles
and expects to meet the 2015 commitment to phase out PFOA.
impact
It is unclear what • • had on - permit renewal, if any. `. • ` sampling
maintained in the permit underOutfall 002.
4) Please explain how the current NPDES permit allows for the discharge of GenX. It is present in the
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?
According to Chemours, GenX was to be a replacement compound considered to have a low potential
mutagenic or genotoxic; and it is not a skin sensitizer. EPA supported the replacement of PFOA with
GenX. Currently, there are no EPA drinking water standards,or
which could be used to develop NPDES permit limits for GenX or Perfluorinated compounds (PFCs).
However there is a US EPA established lifetime health advisory level of 70 ng/L for the sum of PFOA
and PFOS — two PFCs. One PFC, perfluorooctanoic acid (or PFOA) monitoring is required at the
facility's effluent discharge r • Outfall 10• A. of J permit. Unregulated
compounds such as GenX or other perfluorinated compounds are not regulated under EPA's Organic
Chemicals, Plastics and Synthetic Fibers (OCPSF) Effluent Guidelines and Standards (40 CFR Part 414)
which the Chemours Facility is subject
publiclyAll 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
DEQ-CFW 00047361

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 - permit. • • was aware Chemours. • reduce global• . 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 • make sure PFOA was being reduced.
A review of effluent data shows a slight increase of PFOA between the water withdrawal intake at
Chemours' facility verses the PFOA measured at the discharge point, effluent. This will be evaluated
as the part of the permit renewal process. A review of the Chemours' effluent data from 5-4-2016 thru
4-12-2017 shows the average discharge of PFOA from Chemours' Outfall 002 is 0.014 ug/L or 14 ng/L.
PFOA and PFOS. Low legacy Per- and Polyfluoroalkyl Substances (PFAS) in the Cape Fear River which
are being sampled in the upstream intake waters at Chemours are consistent with 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.
♦ -. a. •+
Standardsunder EPA's Organic Chemicals, Plastics and Synthetic Fibers (OCPSF) Effluent Guidelines and
,f •.
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
r •
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?
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?
DEQ-CFW 00047362

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 cause an exceedance of a determined instrearn limitation. If there
sourcesare additional ♦ ♦ for,Pr
7) What is the process for establishing Water Quality Based Effluent Limits for perfluorinated
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
to ensure that this discharge is not resumed by the company?
• wants to analyze all the samplingcollected,. DHHS to understand an
acceptabler be determined), and make sure there is a complete
characterizations of all wastewaters being discharged at the Chemours facility before a permit
re Ir2ftel. Mik,♦ ♦ •) c(ixtixue♦ ♦2XY
Vinyl Ether process wastewaters until a better understanding of this compound is achieved.
DEQ-CFW 00047363