GenX Discharge Into The Cape Fear River: Breaking Down the Chemours NPDES Permit
Analies Dyjak | Policy Analyst
In last weeks blog post, we discussed what a National Pollution Discharge Elimination System (NPDES) permit should look like. This article discusses the major problems with the 2015 Chemours-Fayetteville NPDES permit issued by the North Carolina Department of Environmental Quality.
History Of PFAS Discharge By Dupont/Chemours
In 2015, the North Carolina Department of Environmental Quality issued a renewal NPDES permit to the Chemours Dupont manufacturing plant in Fayetteville, North Carolina. Prior to the media spotlight of GenX in the Cape Fear River in the summer of 2017, Chemours (and Dupont) had been receiving permit renewals since the plant was built in the 1970’s. This particular Chemours plant had been illegally discharging PFAS compounds for years. Similar compounds were not listed or identified in the NPDES permit, which immediately raised a red flag. Our team has taken the time to analyze each section of this 2015 NPDES permit renewal.
Problems With The 2015 Chemours Renewal Permit
First off, there are no units next to the values in the table. The 2015 NPDES permit almost completely lacked uniformity among units. The reader needs to clearly identify if allowable discharge is in mg/kg/day (parts per million), ug/kg/day (parts per billion), and so on. However, Chemours Dupont used “pounds per day” which isn’t constant with the EPA's normal standards of mg/kg/day or ppm. As we discussed in the overview of NPDES permit article, when a permitting agency fails to include units/dosage, they are allowing chemical discharge at any concentration, so long as the total mass does not exceed the stated value. In doing so, they opened up the door for the permit holder to coordinate discharge schedules with their sampling. More on this below.
The second issue is sampling. Chemours mainly used a grab sampling technique to test the surrounding Cape Fear water quality. Grab sampling is a daily one-time collection of water at any given location. This means that Chemours was able to determine the location and time for collecting a sample. As you can probably infer, this would allow Chemours to collect their daily grab sample as far away from the point of discharge as possible. Additionally, this sampling method allows Chemours to collect samples at a time when operation was halted or during a low-discharge period. Either of these sampling tricks could skew concentration levels and water quality being sent to the EPA.
No Plan To Reduce Discharge:
Finally, the National Pollutant Discharge Elimination System was created to help reduce pollution in US waterways. Permitting agencies should include a plan on how they’re working to reduce chemical discharge in their NPDES permit.
The Chemours NPDES permit is one of many inadequate documents distributed by state governments. Although it’s easy to blame the permitting agency, it’s really the fault of the federal government for not supplying an improved uniform template. Federal and state governments should demand more stringent practices from polluters in terms of allowable limits, uniformity in terms of units, and consistent, thorough, sampling techniques.
Although this particular permit seems is inadequate, there are hundreds of active permits in the US that are much worse. In future articles, we'll be shining some light onto these permits as well.
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Recap of January 25, 2017 H2GO Town Hall Meeting/Expert Panel
Analies Dyjak, Hydroviv Policy Analyst.
This past Thursday, January 25th, H2GO and a local news agency hosted an informative meeting to update the public on the GenX crisis that’s unfolding in Brunswick County, North Carolina. The forum consisted of 3 scientists, 2 representatives from the North Carolina Department of Environmental Quality (NCDEQ), local utility providers, and a packed audience of concerned citizens. The mission of the meeting was to communicate to residents any recent actions and discoveries in this public health debacle.
Meeting Topic: Growing Concern About Other PFASs
The public forum made it clear that the scientists and Brunswick County residents are becoming more and more concerned with other perfluroalkyl and polyfluroalkyl subscances (PFASs) that are also present in the Cape Fear River. The scientists concluded that they know even less about these contaminants, which is troubling considering how little is known about GenX.
Our Take: While the presence of other PFASs are new to the nationwide press, they are not new to the scientific community. Dr. Knappe's work has been going on for quite some time, and is highly-respected by the environmental science community (including our science team). It's likely that GenX captured more attention than many other chemicals because it has an ominous (but easy to pronounce) nickname.
Meeting Topic: Comments From State Regulatory Agencies
A representative from the North Carolina Department of Environmental Quality (NCDEQ) shared the three requests made by the Governor to the Environmental Protection Agency; expedite water quality data on GenX, expedite the risk assessment so that national and state standards could be set, and review the consent order under the Toxic Substance Control Act.
Our Take On This: This feels a bit like grandstanding, becasue there are thousands of unregulated contaminants that are currently “in review” by the EPA, and the Clean Water Act only allows a MAXIMUM of 30 unregulated contaminants to be monitored in drinking water every 5 year period. The timescales for progress in these types of things are measured in decades, not months. For reference, chromium 6, whose toxicity and occurrence in US drinking water systems has been established for decades, is still not regulated. This is despite being the fact that it was made famous by the Erin Brockovich Movie (released in 2000).
What Is Hydroviv Doing To Help Remediate Perfluorinated Compounds (Including GenX) In Drinking Water?
As a company, we're not really in a position to push for long-term regulatory changes, but we have heavily invested in a rapid R&D program to develop an under sink water filtration system that is optimized for GenX removal. Unlike reverse osmosis filters, our system does not require the user to drill a hole in their drain pipe or countertop, so our water filters can be used by homeowners and renters alike.
Of course, our Water Nerds are also standing by to answer questions about GenX, PFASs, regulatory policy.... even if you have no intention of purchasing one of our filters. Open a chat line on our homepage with one of our Water Nerds or send us an email at firstname.lastname@example.org.Other Articles We Think You'll Enjoy
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GenX Contamination In Drinking Water: What You Need To Know
There has been some major news coverage about "GenX" and other pre GenX perfluoroalkyl/polyfluoroalkyl substances (PFASs) contamination in North Carolina. Whenever something like this makes it into the news, the facts can quickly become obscured, so the aim of this article is to summarize a few key things to know about GenX and other PFASs in drinking water.
What Is GenX?
GenX is a trade name for a chemical (deduced structure shown above) that went into production around 2010 as an alternative to a perfluorooctanoic acid (also known as PFOA or C8) in the synthesis of PTFE (ie Teflon). GenX is therefore essential for the production of common household products including non-stick pans, firefighting foam, and common outdoor fabrics (e.g. Gore-Tex).
Why Do We Care About GenX And Chemicals Like It?
It's pretty simple: 1. These chemicals are known to be toxic (and this link too) 2. They are persistent in the environment, which means that they don't break down, and can contaminate water far from the contamination source.
Is GenX Regulated By EPA?
No. Which means that there are no regulatory limits, and municipalities are not required to test for it. There are a lot of chemicals that fall into this category.
Why Is This Such A Big Problem In North Carolina?
Are There "Safe" Levels of GenX And Other PFAS In Drinking Water?
Remember, while it's uncomfortable to think about chemicals of any kind existing in drinking water at any concentration, we try and remind people that the dose makes the poison. The example that we like to use is that drinking seawater will kill you from the high salt levels, but putting a pinch of salt in your soup broth is completely fine. The same is true for any chemical. The most credible information that exists at this time on toxicity of PFAS comes from a toxicological profile done by US Center For Disease Control (CDC). In this report, CDC establishes a health advisory level of 20 parts per trillion for the cumulative sum of all PFAS in drinking water, using lifetime exposure levels.
How To Filter GenX And Other PFAS From Drinking Water
If you live in an area that has PFAS levels over the CDC's Health Advisory Levels, you have a few options to remove PFAS. Obviously, as a water filter company, we're partial to our under sink water filtration system and refrigerator and ice maker water filter that were shown to effectively remove GenX in the home of a Wilmington, NC customer under real-world conditions (Reports Can Be Viewed HERE and HERE). These tests were part of an ongoing monitoring program, and we did not pay for the testing. These reports show that the systems effectively filtered GenX and other PFAS under real-world conditions, for the entire 6 month filter lifetime. Other systems that use reverse osmosis have also been shown to be effective, but they are not without downsides. Our advice to consumers is to demand data collected in real-world conditions (real tap water), not testing in otherwise pure water.
Note: Hydroviv is not affiliated in any way with CFPUA or NC State.
At Hydroviv, we custom-build water filters using a different approach than reverse osmosis, because of the real-world problems encountered by reverse osmosis users. Instead, our scientists custom-formulate our filter cartridges so they are optimized for each customer's water. There's a lot of proprietary stuff behind what we do, but in the name of transparency we wanted to give more information that we'd normally give about what we are doing to formulate filters for highly soluble compounds like GenX.
1. We formulate our submicron filter blocks with a blend of activated carbons and elevated levels of a highly porous metal oxide sorbants that other fluoroalkyl compounds have been shown to stick to in the scientific literature.
2. We tighten up the pore sizes of our filters, which slows down the flow and increases the amount of time that the water is in contact with the filtration media, so we get much better removal efficiency when compared to granular or powdered media.
Our filters can be ordered through our product pages, and our experts will automatically use your shipping address to know if you are part of the impacted region.
What Are Official Positions On The Situation?
Dupont: In summary, they are saying that even though Chemours is a Dupont spinoff company, they have no comment because it's now a separate entity.
Chemours: Deafening silence
Municipalities in Southeast North Carolina: "We are in full compliance of Federal Regulations"
Hydroviv: No kidding. You can't be out of compliance if it's not a regulated chemical.
Want More Information About GenX and PFAS In Drinking Water?
We recommend that people take advantage of our "Help no matter what" approach to technical support. Our Water Nerds are happy to discuss our products, or point you to our competitors' products that have also been shown to work. We have been staffing our live chat line through extended hours to answer questions that people may have. If our chat line is busy, you can drop us an email at email@example.com.
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