2019.03.11_CCO.p19_Parsons-Report-Public-Water-Letter

March 11, 2019 via email: [e-mail]

Mr. Kevin P. Garon
Principal Project Director
Chemours Corporate Remediation Group

Subject: Provisions for Public Water
Chemours Fayetteville Plant
Dear Mr. Garon,
On February 25, 2019, Chemours entered into a consent order with the NCDEQ dealing with several items
related to perfluoroalkyl and polyfluoroalkyl substances (PFAS) at the Chemours Fayetteville Works site. In
particular condition 19 requires Chemours:
establish and properly maintain permanent replacement drinking water supplies in the form of public
water or a whole building filtration system for any party (i.e., household, business, school, or public
building) with a private drinking water well that has been found through testing validated by DEQ to be
contaminated by concentrations of GenX compounds in exceedance of 140 ng/L, or any applicable
health advisory, whichever is lower. Under this provision, permanent replacement water supplies shall
be established by connection to a public water supply…
The consent order allows for exceptions to providing public water where the homeowner rejects the offer,
elects to receive a whole house or under sink filtration system, or “if DEQ determines that connection to a
public water supply to an affected party would be cost-prohibitive (i.e., greater than $75,000) or unsafe…”
In June 2018, Parsons prepared a report estimating the cost to provide public water to these residents1. The
purpose of this letter is to provide updated cost and technical feasibility information for providing public water
to residents as outlined above.
BACKGROUND
Chemours has had several meetings and phone calls with representatives of Bladen and Cumberland Counties
to discuss issues and timing related to possible connections of impacted homeowners to municipal water.
Most recently, on December 10, 2018, Chemours and Parsons had phone conversations with officials from
both counties to get updated cost and schedule information.
Bladen County
Bladen County operates a public water system that draws water from groundwater and that currently serves
select areas of the county as well as providing wholesale water to Cumberland County to service a small
neighborhood in southwestern Cumberland County (SouthPoint). Bladen County has several wells located
around the county. The system is divided into geographic areas, and service is currently available in the
northwestern portion of the county and a small area in southwestern Cumberland County. Parsons has been
working with the county to obtain maps and determine requirements for expanding the existing systems. Two
proposals were provided by Bladen County to Chemours in late 2017 for providing service to the area west of

1 Feasibility Study Report for Public Water Services, Chemours Fayetteville Works, Fayetteville, North Carolina.
June 29, 2018 (Attached).
Kevin Garon
Chemours Corporate Remediation Group
Provisions for Public Water
March 11, 2019
Page 2 of 5

the Cape Fear River. Parsons estimated the costs to provide water to the residences on the east side of the
river based on the location of existing water mains and the distance to impacted homes.
Cumberland County
Cumberland County currently operates a small public water system serving the SouthPoint neighborhood
located off Chicken Foot Road in southwest Cumberland county. The county purchases water from Bladen
County to service this small neighborhood of less than 50 homes. The County has identified the expansion of
municipal water as a priority and is conducting an evaluation of such an expansion. Currently, the only water
service in southern Cumberland County is in the South Point neighborhood. While Cumberland County operates
the system, wholesale water is purchased from Bladen County for this small system.
Cumberland County evaluated expanding municipal water to residences as part of a proposed bond issue,
prepared a preliminary engineering report (PER) for providing public drinking water to various areas of the
county not currently served by the utility (Cumberland County Rural Water Feasibility Study Preliminary
Engineering Report, August 2009). The PER outlined the cost to expand the system to rural areas located
outside the current areas of service.
Parsons has been in discussions with representatives from Cumberland County about this study, a portion of
which is being updated. The County is updating the portion of the study related to the Grays Creek Water and
Sewer District (the southwest portion of the county). While the report has not been finalized, the County
provided updated cost estimates to Chemours for this area.
COST ESTIMATES
For this analysis the area around the Fayetteville works site has been divided into four service areas as shown
on Figure 1. The service areas are based on the most likely service provider and geography (Bladen County
east of the Cape Fear River, Bladen County west of the Cape Fear River, Cumberland County east of the Cape
Fear River, and Cumberland County west of the Cape Fear River).
Bladen County East of the Cape Fear River
As shown on Figure 1, there are only five residences whose drinking water sampling results are at or above
140 parts per trillion (ppt) within this area. To provide service to Bladen County east of the Cape Fear River
from existing sources, installation of an approximately 16,100 linear foot (LF), 6-inch water main would be
required to bring water to the area from the existing water service on River Road. An existing groundwater well
feeds this system and is assumed to be sufficient for the limited number of homes (five) at which the health
advisory level has been exceeded. As an alternative, a water line could be extended from the existing Bladen
County system west of the Cape Fear River. However, the length of the line, the need to acquire significant
right-of-way, and the cost of drilling underneath the Cape Fear River make this option infeasible. Regardless,
the long water main and limited number of customers would require that flushing hydrants be installed to
maintain the water quality. The flushing hydrants would result in wasting significant amounts of water. The
hydraulics and system capacity indicate that it would be extremely difficult to maintain appropriate water
quality over this distance given the number of homes.
The construction of a new and long water main to carry water to the five homes in Bladen County east of the
Cape Fear River, along with connecting the five homes, is estimated to cost $1,770,000 – approximately
$354,000 per house. The cost details are summarized in the June 2018 Feasibility Study. In addition, Parsons
estimates that design, permitting, and construction of this system would take two to four years to complete.
Kevin Garon
Chemours Corporate Remediation Group
Provisions for Public Water
March 11, 2019
Page 3 of 5

Based on the cost, schedule, and technical limitations, it remains impractical to provide public water to this
area.
Bladen County West of the Cape Fear River
As shown on Figure 1, there are 492 residences whose drinking water sampling results are at or above 140 ppt
within this area. It is anticipated that municipal water could be expeditiously provided to impacted homes in
this area, since existing water service lines are already present in much of the area, and only moderate water
main additions are necessary to extend the water service lines to all impacted homes. The existing Bladen
County water supply well is reportedly nearing capacity, and the expansion of municipal water service to
additional homes likely will require drilling a new well.
Based on information provided by Bladen County, Chemours estimates the cost of installing municipal water to
all 49 homes in Bladen County west of the Cape Fear River at $3,470,000 -- approximately $70,816 per home.
The new well accounts for approximately 25% of the total cost for extending service in Bladen County west of
the river. It is estimated that construction of the system would require two to four years to complete (assuming
the State will fast track the permitting process).
Of the 49 homes, there are approximately 13 homes that appear to have an existing water main in front of the
property. Assuming that the County confirms this and that any approvals and permits can be quickly obtained,
it should be possible to provide these homes with water quickly and with only minimal costs (within
approximately 9 months and below the $75,000 per home threshold). The remaining 36 homes require
significant infrastructure installation (a new well and additional distribution mains) to connect to public water.
In addition, for the cost to stay below the “cost prohibitive” threshold, at least 30 of these homes would have
to agree to be connected to public water. Given that, we recommend:
• The 13 homes requiring only a lateral connection water would be offered either a public water hook up (with water bills to be paid by Chemours for 20 years), a whole house filtration system, or reverse
osmosis systems on every kitchen and bathroom sink.
• For the remaining 36 homes, assuming that NCDEQ agrees to an extension to the time required for
installation, Chemours would ask the homeowners preference, and if at least 30 homeowners opted
for public water, then that option would be available. If fewer than 30 of homes agree to be
connected to public water, all homes would be provided with the options of a GAC system or reverse osmosis units on every kitchen or bathroom sink.
• If no extension for implementation is granted, the 36 homes would be provided with the options of a
GAC system or reverse osmosis units on every kitchen or bathroom sink.
• If a sufficient number of homes agree to a public water connection such that the cost remains below
the “cost prohibitive” threshold, these homes would be offered reverse osmosis systems while waiting
for the installation of public water.
Cumberland County East of the Cape Fear River
As shown on Figure 1, there are 44 residences whose drinking water sampling results are at or above 140 ppt
within this area. To provide municipal water to these homes, a water main must be extended from Fayetteville
PWC to the south. This service area would require extending a 31,500 LF, 12-inch main from the intersection
of NC 210 and Cedar Creek Road (in addition to the smaller mains to service the homes). The long water main
and limited number of customers may result in water quality issues within the service area. Parsons’s initial
analysis indicates that appropriate water quality would be difficult to maintain, given the hydraulics and
capacity of the system.

2 Two additional homes have eligible wells but are already connected to public water and therefore are not
included in this analysis.
Kevin Garon
Chemours Corporate Remediation Group
Provisions for Public Water
March 11, 2019
Page 4 of 5

The estimated cost of providing municipal water to the 44 residences in Cumberland County east of the Cape
Fear River, is $12,000,000. This is over $272,000 per house. The main cost driver is the long distance from
an existing public water source. Given the current lack of municipal water infrastructure, a new and long water
main must be constructed to reach these 44 households. Parsons estimates that such installation would take
approximately five to eight years to construct.
It is not feasible, technically or in terms of cost and timeliness, to install municipal water east of the Cape Fear
River in Cumberland County. Given the existing lack of municipal water infrastructure, distance to the nearest
water mains, and the lower density of homes, installing municipal water means that these residences will be
on bottled water for years. Further, servicing these areas from the existing PWS will require long dead-end
water mains that add significant cost to the system and may not provide a water supply of adequate quality.
Cumberland County West of the Cape Fear River
As shown on Figure 1, there are 84 residences whose drinking water sampling results are at or above 140 ppt
within this area. As previously mentioned, Parsons met by phone with Jeffrey Brown from Cumberland County
on December 10, 2018 to discuss their updated cost estimates for providing water to this area of the county
(designated the Grays Creek Water and Sewer District or the Southwest District by the County). Cumberland
county provided updated cost estimates for providing water service to the entire district as well as only the
area where wells have exceedances of the health goal. Based on these estimates, the cost to provide water to
the 84 residents in this area would be approximately $19,640,000 or $233,800 per home. Mr. Brown
estimated that construction of this system would take approximately three to four years to complete.
Based on the cost (greater than $75,000 per home) and the schedule (three to four years), it is considered
impractical to provide public water to homeowners in this area.
● ● ●
Parsons appreciates the opportunity to assist Chemours with addressing this very important project. If you
have any questions or concerns with this plan, please do not hesitate to contact me at 704-558-4255.

Sincerely,

Michael G. Robinson, P.E.
Parsons Principal Environmental Engineer

cc Tracy Ovbey – Parsons Project Manager
Allison Rumsey, Arnold and Porter

ATTACHMENT

June 29, 2018 Feasibility Study Report for Public Water Services
Chemours Fayetteville Works, Fayetteville, North Carolina