2020.11.30_CCOA.p4d_Outfall002ChannelGroundwaterUpwellingInvestigationCoverLetter

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

November 30, 2020
Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Consent Order Addendum - Submission Pursuant to Paragraph 4(d)
Dear Ms. Holman,
Paragraph 4(d) of the Addendum to Consent Order Paragraph 12 requires that Chemours
complete an investigation to determine whether DuPont non-contact cooling water is causing
groundwater containing PFAS to infiltrate into the outfall channel. Please find enclosed the
Outfall 002 Channel Near DuPont – Groundwater Upwelling Investigation report, prepared by
Chemours’s consultant, Geosyntec Consultants of NC, P.C., which describes the series of
investigations and analyses completed to assess additional loadings along the outfall channel
near the DuPont area at the Fayetteville Works facility. Overall, the results of the investigation
demonstrated that Table 3+ PFAS mass loads increased in the outfall channel near the DuPont
area, groundwater containing Table 3+ PFAS upwelled into the channel in this area, and the
infiltration of DuPont non-contact cooling water to groundwater contributes to increasing water
levels in this area. However, both the groundwater upwelling rates and mass discharge increases
associated with the groundwater upwelling in this area were very small compared to outfall flows
and Cape Fear River mass loads respectively.
Pursuant to Paragraph 4(d) of the Addendum to Consent Order Paragraph 12, if DuPont
non-contact cooling water is causing significant groundwater infiltration, then either such water
is to be re-routed to prevent infiltration or other appropriate action taken to address the
infiltration, as approved by DEQ. Based upon the results of the investigation, Chemours has not
identified the DuPont non-contact cooling water as causing significant groundwater infiltration
into the outfall channel at this time.
If you have any questions, please contact me at [e-mail].

2
Sincerely,
Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Cc:
William F. Lane, DEQ
Francisco Benzoni, NC DOJ
Michael Abraczinskas, DAQ
Michael Scott, DWM
Danny Smith, DWR
David C. Shelton, Chemours
John F. Savarese, WLRK
Kemp Burdette, CFRW
Geoff Gisler, SELC