2021.11.10_CCO.p.21_Letter re CO Para. 21 Deadline

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

November 10, 2021
Sushma Masemore
Assistant Secretary
N.C. Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Consent Order Paragraph 21 - Request for Extension of Deadline
Dear Ms. Masemore,
Following up on previous discussions and correspondence with DEQ, I am writing on
behalf of Chemours to seek an extension of the deadline under paragraph 21 of the Consent
Order entered by the Bladen County Superior Court on February 25, 2019. Paragraph 25 of the
Consent Order states: “For good cause shown, Chemours may submit to DEQ one or more
requests for extensions of up [to] three months each for any deadline specified in paragraphs 19-
24.”

Paragraph 21 of the Consent Order requires that Chemours sample “drinking water wells
for a distance of at least one-quarter (1/4) mile beyond the nearest well with test results showing
a quantifiable level of any PFAS listed in Attachment C above 10 ng/L” and that “[s]uch testing
shall be completed within eighteen (18) months of entry of this Order” (i.e., by August 25,
2020). On May 19, 2020, Chemours requested a deadline extension of 3 months, to November
25, 2020, and, on May 22, 2020, DEQ granted the requested extension. On October 29, 2020,
Chemours requested a deadline extension of 3 months, to February 25, 2021, and, on November
23, 2020, DEQ granted the requested extension. On February 3, 2021, Chemours requested a
deadline extension of 3 months, to May 25, 2021, and, on February 23, 2021, DEQ granted the
requested extension. On May 17, 2021, Chemours requested a deadline extension of 3 months,
to August 25, 2021, and, on May 25, 2021, DEQ granted the requested extension. On August 13,
2021, Chemours requested a deadline extension of 3 months, to November 25, 2021, and, on
August 24, 2021, DEQ granted the requested extension.

As described in the previous request letters and discussed with DEQ, the paragraph 21
sampling program is ongoing, and we understand that extension requests will continue to be
considered in 3-month intervals. Chemours continues to devote substantial resources to
complete the paragraph 21 sampling program as expeditiously as practicable and continues to
make significant progress.

As shown on the enclosed sampling program map, Chemours has sampled drinking water
wells at over 7,800 residences across an area of approximately 300 square miles surrounding

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Fayetteville Works. Areas with potential GAC-qualifying residences have been delineated, and
nearly all residences within the infill sampling area (approximately 3,100 additional residences)
have been offered sampling.

Based on existing data, and as shown on the enclosed map, delineation has been
completed in sectors 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, and 15. Delineation remains in
progress in sectors 1, 2, and 16. For these three in-progress sectors, Chemours is continuing to
collect additional data by scheduling residences located beyond the current step out area for
sampling and sending additional sample offer letters to residences within one quarter mile of the
last RO-qualifying residence. Chemours has been in discussions with DEQ regarding
delineation, understands that DEQ is currently reviewing delineation information, and will
continue to keep DEQ informed as the sampling program proceeds.

For the reasons set forth above as well as in previous discussions and correspondence
with DEQ, pursuant to paragraph 25 of the Consent Order, Chemours hereby requests another
extension of 3 months, to February 25, 2022, for the paragraph 21 sampling program.

If you have any questions or would like to discuss this matter further, please contact me
at [e-mail].

Sincerely,

Dawn M. Hughes
Plant Manager
Chemours – Fayetteville Works

Enclosure
Sampling Program Map

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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