DEQ-CFW_00075952

ROBINSON
BRADSHAW
[e-mail]
September 19, 2017 704.377.83W: DiraotPhone
704.373.3930: Direct Fax
VIA EMAIL
William F. Lane, Esq. Francisco J. Benzoni, Esq.
General Counsel Assistant Attorney General
NC Department of Environmental Quality NC Department of Justice
217 West Jones Street 114 W. Edenton Street
Raleigh, NC 27603 Raleigh, NC 27603
Re: Chemours' Fourth Response to DEQ's September 10, 2017 List of Priority
Requests
Dear Messrs. Lane and Benzoni:
On behalf of The Chemours Company FC, LLC ("Chemours"), this letter and
enclosed materials are submitted in response to DEQ's September 10, 2017 request
that Chemours prioritize certain of DEQ's pending requests for information related to
Chemours' Fayetteville facility ("Fayetteville Works").'
Chemours has enclosed its first progress report under the sampling plan it
submitted to DEQ on September 15, 2017- See CH-FW-DEQ-0057824 to CH-FW-
DEQ-0057827_ Chemours is available to discuss this progress report during the
teleconference Chemours requested with DEQ for this Wednesday afternoon.
In addition, on September 16th, Chemours voluntarily began segregating the
approximately 300 gallons per day from the Cell Lab Effluent to the waste water
treatment plant in an effort to further reduce its HFPO Dimer Acid discharges. Please
find enclosed a revised schematic of Chemours' process areas showing the current
points of discharge that lead to the wastewater treatment plant('WWTP") and including
approximate daily wastewater flows. See CH-FW-DEQ-0057828_ The only difference
between this schematic and the one Chemours provided DEQ on September 12th (CH-
FW-DEQ-0057683) is the removal of the Cell Lab Effluent. Because the flow volume
leaving the WWTP still rounds to 23,000 gallons, the water balance Chemours provided
on September 12th (CH-FW-DEQ-0057685) does not need to be revised.
This submission supplements Chemours' August 4th, August 18th, August 25th, September 1st,
September 12th, September 14th, and September 15th responses to DEQ.
ROBINSON, BRADSHAW R HINSON, P.A . robinsonbiadshaw_com'
,, arlljrre Ctrt:-'p ` 101 N Try-,r) St, Sie 19Cail, Charir,rT, W; 2.12416: 704 3772535
DEQ-CFW 00075952

4
September 19, 2017
Page 2
We look forward to continuing to work with DEQ and the Attorney General's
office cooperatively on this matter and to receiving DEQ's confirmation of its availability
for the weekly sampling plan teleconferences Chemours has requested. If you have
any questions about this submission, please let me know.
Enclosures
CC'
Linda Culpepper
DEQ
Evelyn Brantley
The Chemours Company, FC LLC
John Savarese
Wachtell, Lipton, Rosen & Katz
Ralph Levene
Wachtell, Lipton, Rosen & Katz
Lester Sotsky
Arnold & Porter Kaye Scholer
Joel Gross
Arnold & Porter Kaye Scholer
W & HINSON, P.A.
DEQ-CFW 00075953

PROGRESS REPORT #1
Date: September 19, 2017
To: North Carolina Department of Environmental Quality ("DEQ")
From: The Chemours Company FC, LLC ("Chemours")
Re: Wastewater Sampling Plan - Progress Report #1
I. INTRODUCTION
On September 15, 2017, Chemours submitted to DEQ a Sampling Plan for Chemours'
Fayetteville, North Carolina facility ("Fayetteville Works") that responded to DEQ's request for
certain wastewater sampling. This is Progress Report #1 under the Sampling Plan, covering the
period from September 15th to September 19th.
Chemours intends to continue to submit weekly progress reports each Tuesday in order to
facilitate the weekly teleconference Chemours requested be scheduled with DEQ each
Wednesday regarding the progress and results of the Sampling Plan.
II. ACTIONS TAKEN FROM SEPTEMBER 15th to 19th
below:
Activities relevant to the Sampling Plan conducted during this period are described
1) On September 15th, Chemours segregated and ceased sending the Cell Lab Effluent
to the waste water treatment plant.
2) The morning of September 18th, representatives from DEQ and EPA visited the
Fayetteville Works in order to collect samples from all of the sampling points noted
in the Sampling Plan, except the Cell Lab Effluent. After informing the DEQ and
EPA representatives on site that Chemours ceased sending the Cell Lab Effluent to
the waste water treatment plant, the DEQ and EPA representatives agreed it was no
longer necessary to collect a sample from the Cell Lab Effluent.
3) While samples were being collected for DEQ and EPA, Chemours collected
contemporaneous samples as specified in the Sampling Plan, except for the Cell Lab
Effluent for the reasons noted in #2 above.
4) Chemours received analytical results for the Table 1 compounds for a September 13,
2017 sample collected from the Common Waste Tank.' Chemours has enclosed these
results as Appendix 1 to this Progress Report #1. Please note that the results for
1 The pH of the Common Waste Tank was sampled on September 19, 2017.
1 of 2
CH-FW-DEQ-0057824
DEQ-CFW 00075954

PFOA, PFOS, and HFPO Dimer Acid are preliminary and have not completed going
through the standard QA/QC process.
III. ACTIONS SCHEDULED FOR NEXT REPORTING PERIOD
below:
Actions scheduled for the period between September 20th and September 26th are listed
1) Chemours anticipates submitting the remaining analytical results for the Table 1
compounds as specified in the Sampling Plan.
2) As specified in the Sampling Plan, Chemours will continue to analyze the Phase 1
Sample Set (excluding the Cell Lab Effluent) for the Table 2 compounds.
3) As specified in the Sampling Plan, Chemours will continue to investigate internal and
external capabilities for analyzing the Phase 1 Sample Set (excluding the Cell Lab
Effluent) for the Table 3 Compounds.
2 of 2
CH-FW-DEQ-0057825
DEQ-CFW 00075955

APPENDIX 1
CH-FW-DEQ-0057826
DEQ-CFW 00075956

ANALYTICAL RESULTS
COMMON WASTE TANK
DATE SAMPLED: 09-13-2017
ANALYSIS
Number
of
Analyses
AVERAGE
UNITS
HFPO Dimer Acid
1
4.8
ug/L
PFOA
1
3.6
ug/L
PFOS
1
0.0087
ug/L
Total Suspended Solids
1
16.5
mg/L
Chemical Oxygen Demand
1
232
mg/L
pH
1
9.54
SU
Antimony
1
0.016
mg/L
Arsenic
1
<0.010
mg/L
Beryllium
1
<0.010
mg/L
Cadmium
1
<0.005
mg/L
Chromium
1
0.084
mg/L
Copper
1
0.017
mg/L
Lead
1
<0.005
mg/L
Nickel
1
0.047
mg/L
Selenium
1
0.019
mg/L
Siver
1
<0.005
mg/L
Thallium
1
<0.005
mg/L
Mercury
1
<0.0002
mg/L
Zinc
1
<0.05
mg/L
Preliminary Result
Preliminary Result
Preliminary Result
CH-FW-DEQ-0057827
DEQ-CFW 00075957

Redacted
DEQ-CFW 00075958