PFAS from an Air Perspective - TN.gov

Department of Environmental Quality

PFAS from an Air Perspective May 17, 2019

Mike Abraczinskas, Director, NC Division of Air Quality

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Emerging Compounds

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O

FO

F F

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Emerging Compounds?

•No specific limit in environmental regulations.

•Sparse knowledge about how they behave in the environment or their effects on human health and environment.

•Communication?

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Emerging Compounds

Emerging Compounds

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144,000,000

83,000

5,000

187

97

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• 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

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GenX – Not a Generational Thing

Emerging Compounds History of the source

• DuPont began chemical manufacturing at the plant along the border of Cumberland and Bladen Counties in 1971.

• Around 1980, DuPont began manufacturing products using fluorinated compounds.

• GenX manufacturing began after a 2009 Consent Agreement under TSCA was signed by EPA and the company. GenX has been a byproduct of the vinyl ether production line.

• DuPont transitions site ownership to Chemours.

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Emerging Compounds – GenX Case History

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Private Well Sampling Results

near Chemours:

GenX: NC health goal = 140 ppt

No color = not tested

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Role of air emissions and atmospheric deposition played in the groundwater contamination?

Hypothesis and conceptual model, but no data.

• Magnitude of emissions?

• Ambient air measurements?

• Ability to control?

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Emerging Compounds

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Department of Environmental Quality

Need Emissions Data ! • Started with only estimates. 3 pounds ????

• 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



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Air Emissions Testing or “Stack Testing”

• Target compound – C3 Dimer Acid (GenX)

• Week of:

• 1/8/18 – PPA & Vinyl Ethers (VE) North

• 1/22/18 - PPA & VE North

• 2/26/18 - PPA & VE South

• 3/19/18 - VE North, Polymers, Semiworks

• 4/3/18 – VE South & VE North for HFPO

• 4/23/18 – VE North HFPO

• 5/14/18 – Polymers for E1

• 6/11/18 – PPA & VE North Carbon bed

• 7/16/18 – PPA scrubber efficiency

• VE North carbon bed & Scrubber

• 7/23/18 – PPA scrubber & carbon bed efficiency

• 8/20/18 – VE South & VE North

• 11/12/18 – VE North

• 12/3/18 – VE North

• 1/7/19 – VE South, PPA & Semiworks

• 1/14/19 – Polymers, VE North & Semiworks

https://deq.nc.gov/news/hot-topics/genx-

investigation/airquality

What about ambient air measurements?

•No agreement on appropriate methods. •But, we knew we could measure it in water.


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Summary of facts:

DAQ established a link between the emissions of GenX, the deposition through rainwater and dry deposition, and contributions to GenX in the groundwater nearfield to the facility.


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.


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


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Emerging Compounds – GenX Case History Carbon Adsorbers in place – late May 2018

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Emerging Compounds Summary of latest on GenX – Consent Order

• 2/25/19 - Court order approved.

• Comprehensive resolution regarding PFAS originating from Chemours.

• Requires Chemours to pay a $12 million civil penalty and $1 million for investigative costs.

• https://deq.nc.gov/news/key-issues/genx-investigation


• Chemours will install a thermal Oxidizer for control of all PFAS from HFPO, VEN, VES, RSU, TFE, MMF, IXM processes by December 31, 2019

• Test report demonstrating 99.99% control efficiency for all PFAS within 90 days of installation/connection.

GenX Emissions Reduction Milestones

1. 82% facility-wide reduction of GenX compounds relative to

2017 total reported emissions by October 6, 2018 and 12-month period that follows.

2. 92% facility-wide reduction of GenX compounds relative to 2017 total reported emissions by December 31, 2018 and 12-month period that follows.

3. 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.

Stipulated penalties for #1, 2 & 3: $200,000, $350,000, and $1,000,000, respectively.


• Network of seven background sites generally oriented near our regional offices

• Asheville – start 11/20/18

• Fayetteville (Candor) – start 10/24/18

• Mooresville – start 3/12/19

• Raleigh – start 4/24/18

• Washington – start 2/12/19

• Wilmington – start 1/8/19

• Winston Salem – start – 3/19/19

• One detection of Perfluoro-n-butanoic acid (PFBA) at 7.4 ng/L during the week of 5/29/18-6/5/18 at the Raleigh sampling location.

• All other samples for 28 analytes have been non detect.

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Background PFAS Rainwater Network

• Eye-opening experience to the world of emerging compounds.

• Having real data and following the scientific process is very powerful.

• Industry: Know what’s in your air emissions, waste and water streams!

• State programs: Better lab capabilities – agency needs to be able to replicate what 3rd parties drop in our lap.

• Background database development – quantifying role of atmospheric deposition.

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Wrap-up

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Thanks!

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Mike Abraczinskas, EIT, CPM

Director, Division of Air Quality

NC DEQ

919-707-8447

[email protected]

Twitter: @airmikeab

mailto:[email protected]

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PFAS from an Air Perspective - TN.gov