2020.09.04_CCO.p19_ChemoursExtensionRequest

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

September 4, 2020
Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Consent Order Paragraph 19 Extension Request
Dear Ms. Holman,
This letter is provided in response to your August 25th, 2020 letter, requesting further
information with respect to the potential availability and provision of public water in Bladen
County and Cumberland County.
For background, the Feasibility Study Report for Public Water Services, submitted by
Chemours on March 11th, 2019, explained that provision of connections to Paragraph 19 eligible
residences was not feasible in Cumberland County, or in Bladen County east of the Cape Rear
River. Chemours proposed to offer whole house GAC to qualifying residences in those areas, and
to offer public water connections if there were sufficient levels of acceptance in Bladen County
west of the River. DEQ has approved this plan for both Counties east of the River and in Bladen
County west of the River, and has continued to consider the proposal for Cumberland County west
of the River. Chemours has sought and obtained a series of three month extensions of the Consent
Order deadline for providing alternate water to those eligible under Paragraph 19. The last such
request was submitted on August 21st, 2020, and NCDEQ agreed to a one month extension for
that request, through September 25th, 2020.
As indicated in Chemours’ August 21st, 2020 Paragraph 19 extension request letter, we
have continued discussions with both Bladen and Cumberland Counties regarding the potential
expansions of their public water systems to supply affected parties west of the Cape Fear River.
Bladen County West of the Cape Fear River
The qualifying properties for replacement drinking water supplies under Paragraph 19 of
the Consent Order in Bladen County are largely within the northern area of the County, and on the
west side of the Cape Fear River there is a public water system served by the Tobermory well (on
the east side of the river there is a smaller public water system served by the Live Oak well). The
2019 feasibility analysis submitted to NCDEQ was based on approximately fifty properties located
on the west side of the Cape Fear River being served by private wells and eligible for the options
of Paragraph 19, and that 90% of such homeowners would need to accept public water to make it
cost effective under the criteria set forth in the Consent Order. Presently, there are fifty-seven

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properties in this area that have had well sampling results for GenX compounds above the limit
set in Paragraph 19, however of these properties: (a) twelve have had a GAC system installed, (b)
eighteen already receive public water service, and (c) five are connected to public water service
but not receiving it. While Chemours continues to conduct private drinking water well sampling,
based on the present number of Paragraph 19 eligible properties that are not already connected to
a public water supply, the 90% basis for the 2019 feasibility analysis cannot be met.
Notwithstanding this, Chemours continues to discuss with Bladen County the ability to
provide a public water connection option for replacement drinking water supplies under Paragraph
19. This discussion includes both potential expansion of Bladen County’s public water system,
and the ability to connect Paragraph 19 eligible properties to the existing Tobermory well system.
As part of these discussions, we have discussed with Bladen County the future capacity and water
treatment for PFAS compounds of the two existing well systems (Tobermory and Live Oak). If
this public water connection option is established, a schedule will be set for connecting Paragraph
19 eligible properties on the west side of the Cape Fear River to the existing well system, and
Chemours anticipates that these connections will be completed within two years for those
properties requiring new public water lines to be run.
Cumberland County West of the Cape Fear River
There are presently one hundred and twenty-two qualifying properties for replacement
drinking water supplies under Paragraph 19 of the Consent Order in Cumberland County west of
the Cape Fear River, of which thirty-six have a GAC system already installed. In addition to these
Paragraph 19 eligible properties, there are approximately 2,500 qualifying properties under
Paragraph 20 of the Consent Order for provision of reverse osmosis drinking water systems, of
which approximately 760 have one or more RO systems installed.
Earlier this year, Cumberland County allocated funds toward creating a public water
system in the Gray’s Creek area of the county. Since that time, Chemours has communicated with
Cumberland County regarding providing a contribution toward such public water system and such
system providing a public water connection for Paragraph 19 and Paragraph 20 eligible properties.
Cumberland County is presently conducting engineering evaluations for a system and will provide
more detailed information to Chemours as its analysis is finalized.
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We hope that the foregoing responds to your request. In light of the ongoing status, we
hereby request an additional three month extension to meet the Paragraph 19 requirements in
Bladen and Cumberland Counties west of the Cape Fear River.
If you have any questions, please contact me at [e-mail].

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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