2018.12.18_CCO.p21_ChemoursApprovalRequest-ConsentDecree-Laboratories

The Chemours Company FC, LLC
22828 NC Hwy 87 W
Fayetteville, NC 28306-7332

December 18, 2018
Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Information Pursuant to Paragraph 21 of Proposed Consent Order
Dear Ms. Holman,
Paragraph 21 of the proposed Consent Order states that:
Chemours shall fund sampling by a third party laboratory approved by DEQ of
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. Such testing shall be completed within eighteen
(18) months of entry of this Order. Additionally, by December 31, 2018,
Chemours shall fund re-analysis by a third party laboratory approved by DEQ for
all PFAS listed in Attachment C of any previously collected groundwater samples
that were analyzed only for GenX, GenX Compounds, or a subset of the PFAS
listed in Attachment C.
Pursuant to that paragraph, Chemours hereby notifies the North Carolina
Department of Environmental Quality (“DEQ”), and hereby seeks DEQ’s approval, that
Chemours intends to use TestAmerica Laboratories, Inc. and Lancaster Laboratories Inc.
as third-party laboratories to implement the testing described in Paragraph 21. To ensure
prompt receipt of results, Chemours will utilize either one of the two laboratories at any
given time based on its availability. Chemours has also executed purchase orders with
both laboratories for re-analysis of groundwater samples, meeting the deadline in
Paragraph 21 to “fund re-analysis by a third party laboratory” by December 31, 2018.

2

Please provide us as soon as you are able, as we would like to proceed with the
analysis required, with DEQ’s approval of the utilization of these laboratories pursuant to
Paragraph 21.

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

Cc:
William F. Lane, General Counsel
Francisco Benzoni, Special Deputy Attorney General
Sheila Holman, Assistant Secretary for the Environment
Michael Abraczinskas, Director, NCDAQ
Michael Scott, Director, NCDWM
Linda Culpepper, Interim Director, NCDWR
David C. Shelton, Senior Vice President, General Counsel, Chemours
John F. Savarese, Wachtell, Lipton, Rosen & Katz
Kemp Burdette, Cape Fear Riverkeeper
Geoff Gisler, Counsel For Cape Fear River Watch