Our Official Comments Regarding NC DEQ’s Virtual Public Forum on Chemours
On Thursday, August 13, 2020 NC DEQ will host a Virtual Public Forum regarding Chemours. This public forum will discuss three major action items:
1. Chemours NPDES discharge permit: Since June 2017, Chemours has not been allowed to discharge their process waters into our river. They've been putting their toxic waste streams on tanker trucks and sending it to Deer Park, TX for deep well injection. Chemours recently built a new water treatment system onsite. This is a necessary step. NC DEQ must now decide how to issue the required NPDES discharge permit.
WHAT WE BELIEVE:
We believe DEQ needs to set strict, health protective limits on this permit. Chemours can, and should, use the best available technologies to reduce the amount of total PFAS released into our primary source of drinking water to no greater than 20 ppt; with a goal to get these forever chemicals fully eliminated as new technologies are made available.
Weekly water samples should be taken from the discharge pipes and split between Chemours and an independent laboratory so DEQ and downstream communities can monitor PFAS releases. This data should be placed online and easily accessible to the general public.
We also believe this permit should safely address where and how the diverted PFAS chemicals are disposed. At this time, there are no proven, safe disposal methods for these forever chemicals. They should not be land applied, incinerated, or sent to other communities ill-equipped to handle these toxic chemicals.
2. Paragraph 12 of consent order: In 2017, Cape Fear River Watch sued NC DEQ and Chemours for failure to follow the Clean Water Act. In 2019, all parties entered into a consent order. Paragraph 12 of this order addresses short term, immediate, actions Chemours should take to protect downstream residents from continued exposures to their toxic PFAS chemicals. Unfortunately, downstream residents are still drinking some of the highest levels of PFAS in the nation per a recent EWG tap water study.
WHAT WE BELIEVE:
We demand Chemours create a relief fund for all downstream impacted communities. Because of DuPont/Chemours' irresponsibility we should not be forced to pay for, or drink, water containing their chemical waste.
The current consent order requires Chemours to provide private well owners with water alternatives such as under-sink filters, whole house filtration, or access to public utility hookups if their groundwater contains 10 ppt of one single PFAS chemical or 70 ppt of total PFAS. Downstream residents have exceeded those thresholds for the majority of 2019. In fact, on July 24, 2020 Brunswick County residents still had 272 ppt of total PFAS in their tap water.
We deserve immediate actions and protections. Our river's ongoing high levels of PFAS are coming from groundwater contamination underneath Chemours; therefore, we believe DEQ should also protect downstream residents from continued and chronic exposures by requiring Chemours to immediately set up a relief fund for all impacted communities. A community advisory board should be established to determine how these funds are maintained and equitably distributed.
3. Chemours Corrective Action Plan: The consent order requires Chemours to submit an action plan to clean up the mess they've made and make sure it never happens again. Chemours submitted a Corrective Action Plan many thought was illegal and did not uphold the legally binding commitments Chemours made under the consent order. DEQ dismissed the plan and is requiring Chemours to submit a better one.
WHAT WE BELIEVE:
We encourage DEQ to hold Chemours accountable for the decades of harm they caused and the clean-up--regardless of cost. The burden should not fall on innocent NC residents, downstream utilities or their ratepayers. We are asking for the following:
Private well contamination should be determined based on PQLs for the various PFAS chemicals.
Chemours should set up an immediate relief fund for all impacted communities--both downstream and private well owners.
Chemours should not be allowed to escape responsibility for historical contaminations created by DuPont.
Chemours must stop the continued loading of contaminated groundwater into our river.
Chemours must clean up the river sediment in the 50 mile stretch between its facility and the intake pipe for downstream water utilities.
Mitigation efforts should address Willis and Georgia creeks which run from the Chemours facility to the Cape Fear River.
Remediation should be clearly addressed for the entire contaminated radius discovered, and yet to be discovered, from decades of PFAS air emissions caused by the DuPont/Chemours Fayetteville Works Site.
All tenants of Chemours' Fayetteville Works site, including DuPont and Kuraray, should be monitored and held accountable for any PFAS chemical releases.
Chemours must pay for independent toxicity studies on all PFAS detected in the river, process waters, groundwater, private wells, and sediment regardless of molecular weight. If a PFAS chemical has a separate CAS Number it must be studied for its toxicity. Mixture studies should be conducted since we were exposed to many of these forever chemicals at the same time. Sensitive endpoints, such as fetuses during pregnancy, infants, mammary glands, and lactating women should be included in all toxicity studies.
Thank you for taking the time to read this. More importantly, thank you for taking ACTION. Together we will heal our communities!
We also support the recommendations provided by Cape Fear River Watch. Click here to review their suggestions.