In October of 2013, DuPont submitted information to the agency's Division of Air Quality indicating they planned to make important changes to the Fluorochemicals Plant "scrubber" system. DuPont indicated they expected the changes would reduce the amount of chemical pollutants in DuPont's wastewater discharge. Since 2005, DuPont's annual reports to the Division of Air Quality specified that the wastewater associated with the scrubber systems at the Fluorochemicals Plant (Nafion Vinyl Ethers) contained GenX and PFAS chemical pollutants.
There is no indication in the DEQ files that the Division of Air Quality shared this important information with the Division of Water Quality and the Division of Waste Management. This is especially surprising because the DEQ has numerous engineers who are very familiar with scrubber systems. It is important to note that the DuPont Fluorochemical Plant's scrubbers are "control devices" regulated under the Title V inspection and permit program within the DEQ Division of Air Quality.
In addition, the agency staff in Fayetteville has nearly always included several individuals with degrees in chemistry or chemical engineering. Also, there are multiple employees in the Raleigh central office of the Division of Air Quality with degrees in chemistry or chemical engineering. Did anyone in the agency ask DuPont specific questions and try to gain a full understanding of the changes to the scrubber system and how it would reduce GenX and PFAS chemical pollutants in the wastewater? Was this information documented by a DEQ engineer? If not, why not?
Reviewing the DEQ documents of 2012 and 2013, it is not clear which state agency director, deputy director, or upper-level manager was responsible for looking at the "big picture" of the Dupont Fayetteville Fluorochemicals Plant (Nafion Vinyl Ethers) and its discharges of chemical pollutants (fluorocarbons, acid fluorides, GenX, PFAAs, PFAS, etc.) into the wastewater, to the air, and in their waste.
... to eliminate wastewater discharge from the vinyl ethers north process NS-B ...