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Home My WebLink AboutDEQ-CFW_00013725From: Kemp Burdette[kemp@cfrwus] Sent: 7/I8/2017 1:14:33AyW To: Snyb,]u|ie [/o=ExchanXeLabs/ou=[xchangeAdministrative Group (FYD|BOHFI]3PDLT)/cn=Kecipients/cn=75dI654d45154cIabbO8596aIc9af%8%-jagoyb] CC: Culpepper, Linda Dh=ExchangeLabs/ou=ExchanXeAdministrative Group (FYD|BOHFI]3PD[n/cn=Kedpients/cn=7]d475cbae324aZ9687eI7I1dc9a79c5-|mcu|pepped;Brower, Connie [/o=ExchanXeLabs/ou=ExchanXeAdministrative Group (FYD|BOHFI]3PD[n/cn=Kedpients/cn=7ee8dbQ4d95643Ic9a1f78If5597ba6I-cubrower] Subject: Re: 6enXand ChemoursPermit I'm sorry, lcan't do|tomorrow. lwill try and send some times tomorrow. Kemp Burdette Cape Fear Riverkeeper Please excuse message brevity and typos; sent from my smartphone. On Jul 16 2017 8:50 AM "(]rzvb, Julie" wrote: HIM To: Kemp Burclette Cc: Grzyb, Julie; Brower, Connie Subject: RE: GenX and Chemours Permit Hi Kemp — Julie and Connie were working on your questions this week. Probably easier for all of us to talk through them since they have several parts. I could be available Monday at 4pm. I am not certain of Connie and Julie's availability so copying them as well. I'll be out of the office but able to see emails Monday morning. Respond back with other suggestions ifthe time/date need toshift. Right now Tuesat OEQ-CFVV_00013725 Linda Culpepper Deputy Director Division of Water Resources North Carolina Depart nent of Environmental Quality 1611 Mail Service Center Phone: 919-707-9014 .1 n From: Kemp Burdette [mailto:kemp@cfrw.us] Sent: Thursday, July 13, 2017 3:10 PM To: Culpepper, Linda <1 inda.cul pepper@ ncdenr.gov> Subject: Re: GenX and Chemours Permit Hi Linda, I hope you are well. Any update on the questions I sent? Thank you. Kemp Burdette Cape Fear Riverkeeper Please excuse message brevity and typos; sent from my smartphone. On Jul 8, 2017 9:44 PM, "Culpepper, Linda" <linda.culpeppergncdenr.gov> wrote: Hi Kemp - Julie and I will work on the responses to your follow up questions on Monday. The question regarding the EPA Consent Agreement will need an EPA response. Want us to work with EPA on the response, or would you like to work with EPA directly? Either can work for us. Linda Sent from my iPhone DEQ-CFW-00013726 On Jul 8, 2017, at 12:08 PM, Kemp Burdette <kemp La),cfrw.us> wrote: Thank you Sheila, Hi Linda, Jeff, and Julie. Thank you for your help with Chemours permit, NC 0003573. 1 have a few questions. 1) Can you explain the relationship between DuPont, Chemours, and Kuraray? 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? 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). 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. 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? Did NC DEQ take this document into consideration when writing NPDES Permit 4 NC00035739 If so, please explain how this document was considered and whether it influenced the terms of the permit. 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 1. 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? 5) (similar to #3) Please explain how the current NPDES permit allows for the discharge of C8 or PFOA. 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? 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? Has there been communication between DEQ and DHHS regarding the presence of perfluorinated compounds in the Cape Fear Fiver? Please explain how the D14HS assessment will influence the renewal of NPDES Permit 9 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. 7) What is the process for establishing Water Quality Based Effluent Limits for perfluorinated compounds, like GenX? DEQ-CFW-00013727 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? Thanks for your assistance with this important issue. On Fri, Jul 7, 2017 at 2:51 PM, Holman, Sheila <sheiIa.holman@ncdenr. .gov> wrote: I =0 I am copying Linda Culpepper, Jeff Poupart and Julie Grzyb on this message. Jeff and Julie can answer the NPDES permitting questions. Sorry for the delay in responding. Seni from my Vctrizon, Sainsuno &Aaxy sinarlphone -------- Original message -------- From: Kemp Burdette <kempLa)cfrw.us> Date: 7/7/17 2:38 PM (GMT-05:00) To: "Holman, Sheila" <sheiIa.holmanLa)ncdenr. ,gov> Subject: Re: GenX and Chemours Permit Thanks Sheila, DEQ-CFW-00013728 lknow you are very busy and l appreciatethe hard work you do. Could you connect cnctnthe best person incentral permitting regarding questions about the I}uPont/Chcmnurupermit? There are ofew things lon/confused about and I'd like tnspeak with someone who could help conunderstand ousoon ampossible. Thank you. On Thu, Jul 62O|7a17:|8Nyd Holman, Sheila wrote: im Thank you for the reminder. Last week was very busy. Let mediscuss the public notice and hearing process with DWR staff and I will get back to you on your questions and recommendation for a public hearing. Sheila Sheila Holman Assistant Secretary for the Environment 1601 Mail Service Center Phone/Fax: 919-707-8619 From: Kemp 8urdette[maiko Sent: Wednesday, July 5,2Ul77:34PK4 To: Holman, Sheila « Subject: Re: GenXand [hemoursPermit OEQ-CFVV_00013729 Just wanted to make sure you saw my previous email. Thanks. Kemp Burdette Cape Fear Riverkeeper Please excuse message brevity and typos; sent from my smartphone. On Jun 29, 2017 1:41 PM, "Kemp Burdette" <kemp((Tefi-w us> wrote: ------------------------- Hi Sheila, Good to see you twice yesterday. I wanted to check on one thing related to Chemours Permit. Will the public have an opportunity to give comments on that? Will there be a hearing? I think it would be an important way to show folks that DEQ is listening to their concerns and that the process is transparent. Also, do you have a timeline on any of this and/or for when the permit might be renewed. Feel free to call my cell if that's easier. 910-264-8036. Thanks again! Kemp Burdette Cape Fear Riverkeeper Please excuse message brevity and typos; sent from my smartphone. Kemp Burdette Cape Fear Riverkeeper 617 Surry Street Wilmington, NC 28401 o- 910-762-5606 c-910:264-80-36 DEQ-CFW-00013730 KemnBurclette Cape Fear Riverkeeper Wilmington, NC 28401 o-9!O-7b2-5hO0 c-9|O-264-8030 OEQ-CFVV_00013731