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Department of Environmental Quality
Emerging Compounds – GenX Case - UPDATEMike Abraczinskas, Director,
North Carolina Division of Air Quality
November 29, 2018
What do we mean when we say Emerging Compounds?
• No specific limit in environmental regulations.
• Sparse knowledge about how they behave in the environment.
• Little known about their effects on human health and environment.
• Significant challenge for regulatory agencies.
• How to prioritize? Research? Minimize impacts? Communicate?
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Emerging Compounds
Emerging Compounds
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Unregulated compounds: What do you do?
• National regulatory standards (EPA)
• State Standards (DEQ/Environmental Management Commission)
• National health advisories or other health values (EPA, CDC)
• Other governmental guidance (other states or countries)
• If all of the above are not available… can consider establishing a
state-specific health goal
• GenX = C3 Dimer Acid = C6HF11O3
• GenX is a trade name for a man-made and unregulated chemical used in manufacturing nonstick coatings and for other purposes.
• In a family of chemicals known as per- and poly- fluorinated alkyl substances (PFAS)
• Produced and emitted by one company in NC – Chemours (formerly Dupont)
• Has been discharged into the Cape Fear River for 30+ years.
• Until the past couple of years, labs couldn’t measure it.
• Toxicology
• DHHS Public Health Goal = 140 ppt
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GenX – Not a Generational Thing
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Emerging Compounds – GenX Case History
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Private groundwater wells
>140 ppt GenX
10-140 ppt GenX
ND GenX
Emerging Compounds – GenX Case History
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• Early-mid 2017: focus on surface water issues
• Mid 2017: groundwater issues discovered
• Mid-late 2017: air emission contributions
Emerging CompoundsDAQ’s investigation involving GenX and other PFAS from Chemours
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Department of Environmental Quality
• GenX emissions data • Started with only estimates
• Required stack tests
• Method development
• First of its kind measurements
Chemours 2016
emissions estimates
as originally reported
to DAQ
Chemours revised
2016 emissions
estimates as of
October 2017
Latest calculations of
annual emissions,
including stack test
measurements
66.6 lb/yr 594 lb/yr 2302.7 lb/yr
What about ambient air measurements???
• No agreement on appropriate methods.
• But, we knew we could measure it in water.
• Why not collect rainwater samples to get a sense of atmospheric contributions groundwater issues?
• Purchased temporary rain collection equipment.
• Used lab protocols to prepare equipment.
Emerging Compounds – GenX Case History
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Emerging CompoundsDAQ’s investigation involving GenX and other PFAS from Chemours
Summary of facts:
• The measured air emissions of GenX compounds are significantly higher than previously understood and reported.
• DAQ has measured GenX deposition through rainfall as far as 20 miles from the facility.
• The evidence of atmospheric deposition of GenXshows a geographic footprint that is similar to the detection of GenX in groundwater samples.
Emerging CompoundsGenX – Review of Actions
April 6, 2018:
• 60 day notice of intent to modify Chemours’ air permit:
• Requires demonstration that emissions of GenX compounds do not or will not cause or contribute to violations of groundwater rules.
The science and data collected informed this action.
Emerging CompoundsGenX – Review of Actions
April 27, 2018:
• Chemours response to 60 day notice
• Chemours committed to:
• Install & operate a Thermal Oxidizer by 2020
• Expected 99% reduction of GenX emissions
Emerging CompoundsGenX - Recent Actions
Carbon Adsorbers in place – late May 2018
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ND
ND
W
ND
June 5 – June 12, 2018
Rainwater GenX ppt
W – Wet Deposition
D - Dry Deposition, 600ml
PFAS free water added
ND
W
ND
D
ND
D
ND
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GenX – Proposed Consent Order
November 21, 2018:
• Announced the publication of a proposed consent order between NC DEQ, Chemours and Cape Fear River Watch.
• Comprehensive resolution regarding PFAS originating from Chemours.
• Requires Chemours to pay a $12 million civil penalty and $1 million for investigative costs.
GenX – Proposed Consent Order
Control Technology Improvements – part 1
1. Add 2nd packed bed scrubber by November 7, 2018
2. Test report demonstrating 72% control efficiency for GenX by February 6, 2019
Failure on #1: $5,000/day for days 1-14; $30,000/day thereafter.
Failure on #2: $50,000 for 1st failed stack test + $25,000/week until a compliant stack test.
GenX – Proposed Consent Order
Control Technology Improvements – part 2
1. Route emissions from 2nd scrubber to carbon adsorber by December 31, 2018 (except for 1 chemical campaign – process hazard concerns)
2. Test report demonstrating 93% control efficiency for GenXwithin 90 days of installation/connection.
Failure on #1: $5,000/day for days 1-14; $30,000/day thereafter.
Failure on #2: $50,000 for 1st failed stack test + $25,000/week until a compliant stack test.
GenX – Proposed Consent Order
Control Technology Improvements – part 3
1. Thermal Oxidizer for control of all PFAS from HFPO, VEN, VES, RSU, TFE, MMF, IXM processes by December 31, 2019
2. Test report demonstrating 99.99% control efficiency for all PFAS within 90 days of installation/connection.
Failure on #1: $5,000/day for days 1-14; $30,000/day thereafter.
Failure on #2: $50,000 for 1st failed stack test + $25,000/week until a compliant stack test.
GenX – Proposed Consent Order
GenX Emissions Reduction Milestones – part 1
1. 82% facility-wide reduction of GenX compounds relative to 2017 total reported emissions by October 6, 2018 and 12-month period that follows.
Failure on #1: $200,000
GenX – Proposed Consent Order
GenX Emissions Reduction Milestones – part 2
1. 92% facility-wide reduction* of GenX compounds relative to 2017 total reported emissions by December 31, 2018 and 12-month period that follows.
Failure on #1: $350,000
*Conduct stack tests from GenX compounds emissions sources to determine emission rates for each product campaign. All test reports due to DAQ w/in 45 days of completing the test. Compliance report due to DAQ by February 28, 2020.
GenX – Proposed Consent Order
GenX Emissions Reduction Milestones – part 3
1. 99% facility-wide reduction* of GenX compounds relative to 2017 total reported emissions by December 31, 2019 and for each consecutive 12-month period following that date.
Failure on #1: $1,000,000
*Conduct stack tests from GenX compounds by March 31, 2020. Compliance report to DAQ by February 28, 2021. Repeat this compliance demonstration for each subsequent calendar year unless and until DAQ issues a modified air permit incorporating a 99% or greater reduction requirement.
GenX – Proposed Consent Order
Emissions Disclosure
• Any identified previously undisclosed PFAS and emission rates for those PFAS, and
• Any new process or production that may lead to the addition of any previously undisclosed PFAS in the facility’s air emissions
• For any such PFAS, provide DAQ with any available analytical test methods and lab standards
GenX – Proposed Consent Order
Research
• Fund development of a sampling and analytical methodology for the measurement of total organic Fluorine in its process air emissions and process wastewater by December 31, 2020.
• Fund development of a study… analyzing the fate and transport of ID’ed PFAS originating from the facility in air, surface water and groundwater by June 30, 2019.
GenX – Proposed Consent Order
Other key elements:
• Provide permanent drinking water supplies in the form of either a public waterline connection or whole building filtration system for those with drinking water wells with GenX above 140 parts per trillion or applicable health advisory.
• Provide, install and maintain three under-sink reverse osmosis drinking water systems for well owners with combined PFAS levels above 70 parts per trillion or any individual PFAS compound above 10 parts per trillion.
GenX – Proposed Consent Order
Other key elements:
• Continue to capture all process wastewater from its operations at the facility for off-site disposal until an National Pollutant Discharge Elimination System (NPDES) permit is issued that authorizes discharge of process wastewater.
• Conduct health studies to determine potential health risks associated with release of PFAS compounds into the environment.
• Sample drinking water wells at least one-quarter mile beyond the closest well that had PFAS levels above 10 parts per trillion as well as annually retest wells that were previously sampled.
• Submit and implement a plan for sampling all process and non-process wastewater and stormwater streams to identify any additional PFAS.
GenX – Proposed Consent Order
Other key elements:
• Submit to DEQ for approval a Corrective Action Plan that, once approved, is implemented and reduces PFAS contributions in groundwater along the Cape Fear River by at least 75 percent.
• Notify and coordinate with downstream public water utilities when an event at the facility has the potential to cause a discharge of GenX compounds into the Cape Fear River above the health goal of 140 parts per trillion.
Summary
• Think about how you might handle this WHEN it happens in your jurisdiction.
• Emerging/unregulated compounds are prevalent in the environment.
• At what concentration? Can you measure? Can someone else measure it?
• What are you going to do with that measurement when you get it?
• What’s the toxicity and potential human health impacts?
• Risk communication is a must !!!
Thank you!
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Department of Environmental Quality
Mike Abraczinskas, EIT, CPM
Director
NC Division of Air Quality
919-707-8447
Michael Pjetraj, P.E.
Deputy Director
NC Division of Air Quality
919-707-8497
