DEQ-CFW_00022245

From: Goyt,Ju|ie [/O=EXCHANGELABS/OU=EXCHANGEADMINISTRATIVE GROUP
(FYD|BOHF2]SPDLT)/CN=REOP|ENTS/CN=75D1654D45154C2A8BO859GA2C9AF282-JAGRZY8]
Sent: 7/10/I0I74:52:34PW1
To: Culpepper, Linda [/b=ExchanXeLabs/ou=[xchangeAdministrative Group
(FYD|8OHFZ33PDO)/cn=Redpient$cn=73d475cbae3Z4aI9687e171Idc9a79c5'|mcu|pepper]
Subject: RE: Kemp 8urdetterequest —FVV:GenXand ChemoursPermit
Linda,
|amworking onanswering these questions. #7isastandards question so|sent ittoConnie for her input. Assoon as|
finish I'll send them toyou.
Julie
From: Culpepper, Linda
Sent: Sunday, July O9,IOl7S:S3PK4
To: Grryb,Julie ^ju|ie.gr4/[e-mail]>
Cc: Munger, Bridget <brid8et.mun8er0Dncdenr.8o*,;Kritzer, Jamie "[e-mail]>
Subject: Kemp Burdetterequest —FVV:GenXand [hemoursPermit
I've sent the first part ofquestion 3) to R4 (Carol and Becky) asking them to develop the response or tell me who to
coordinate with atEPA.
Can you take the lead onthe other questions? Copying Bridget and Jamie incase they have already responded tosimilar
requests, and for their knowledge.
Unda Culpepper
Deputy Director
Division of Water Resources
North Carolina Department ofEnvironmental Quality
1611Mail Service Center
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From: Kemp Burdette
Sent: Saturday, July O8,2D171O:36PK8
To: Culpepper, Linda
Subject: Re: GenXand [hemounPermit
Thank you Linda. lwasn't expecting ureply over the weekend! lfyou can work with EPA that would be great.
Thanks again.
KemnBurdette
Cape Fear Riverkeeper
Please excuse message brevity and typos; sent from my smartphone.
On Jul 0, 2017 9:449M- " Linda" wrote:
Hi Kemp -Julieandlwill work on the responses to your follow up questions on Monday.The question
regarding the EPA Consent Agreement will need an EPA response. Want usto work with EPA on the

IMP-1
Sent from my iPhone
On Jul 8, 2017, at 12:08 PM, Kemp Burdette <kemp@ ,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 9 NC0003573? 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 43) 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 D14HS regarding
the presence of perfluorinated compounds in the Cape Fear River? Please explain how the
DHHS assessment will influence the renewal of NPDES Permit 4 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.
DEQ-CFW-00022246

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?
Thanks for your assistance with this important issue.
On Fri, Jul 7, 2017 at 2:51 PM, Holman, Sheila <sheila-holmanL�bnedenr. grov> wrote:
Kemp,
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.
Sheila
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-------- Original message --------
From: Kemp Burdette <kempr& cfrw.us>
Date: 7/7/17 2:38 PM (GMT-05:00)
To: "Holman, Sheila" <sheila.holman(2(ncd.enLgov>
Subject: Re: GenX and Chemours Permit
Thanks Sheila,
I know you are very busy and I appreciate the hard work you do. Could you connect me to the
best person in central permitting regarding questions about the DuPont/Chemours permit?
There are a few things I am confused about and I'd like to speak with someone who could help
me understand as soon as possible. Thank you.
On Thu, Jul 6, 2017 at 7:18 A-N/1, Holman, Sheila <slieila.holriiatioa.riedenr.gov> wrote:
im
Thank you for the reminder. Last week was very busy. Let me discuss 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.
DEQ-CFW-00022247

all M I I Eff •
Assistant Secretary for the Environment
MON]
deq.nc,Boy
[e-mail]
From: Kemp Burdette [mailto:[e-mail]]
Sent: Wednesday, July 5, 2017 7:34 PM
To: Holman, Sheila <[e-mail]>
Subject: Re: GenX and Chemours Permit
Sheila,
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" <kempCiPcfrw.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!
DEQ-CFW-00022248

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- 910-264-8036
Kemp Burdette
Cape Fear Riverkeeper
617 Surry Street
Wilmington, NC 28401
o- 910-762-5606
c- 910-264-8036
DEQ-CFW-00022249