2020.04.24_CCO.p28_Consent Order Progress Report for First Quarter 2020

Consent Order Progress Report For First Quarter 2020 Submissions to the State of North Carolina and Cape Fear River Watch The following table identifies submissions made by Chemours pursuant to the Consent Order for the period of January 1, 2020 through the end of the first quarter on March 31, 2020.1 CO Section Submitted To Title Submitted Date 7 & 8 NCDEQ Thermal Oxidizer Destruction Efficiency Compliance Report, Cover Letter, and Attached Test Reports 3/30/2020 8 NCDAQ 92 Percent Reduction Report CBI Spreadsheet 1/21/2020 8 NCDAQ 92 Percent Reduction Report Letter 1/21/2020 8 NCDAQ Final - Division Stack Report 11 2019 1/21/2020 8 NCDAQ Final - E2 Stack Report 12 2019 1/21/2020 11 NCDEQ PFAS Characterization Quarterly Report Cover Letter 1/31/2020 11 NCDEQ PFAS Characterization Quarterly Report 1/31/2020 11.2 NCDWR Sediment Characterization Plan Responses to Comments 1/22/2020 11.2 NCDWR Sediment Characterization Plan RTC Cover Letter 1/22/2020 11.2 NCDWR Sediment Characterization Plan Updated Table 1 1/22/2020 12 CFRW Cape Fear River PFAS Loading Reduction Plan - Supplemental Information Report - Responses to CFRW Comments Cover Letter 1/31/2020 12 CFRW Cape Fear River PFAS Loading Reduction Plan - Supplemental Information Report - Responses to CFRW Comments 1/31/2020 12 NCDEQ Cape Fear River PFAS Loading Reduction Plan - Supplemental Information Report - Responses to DEQ Comments Cover Letter 1/31/2020 12 NCDEQ Cape Fear River PFAS Loading Reduction Plan - Supplemental Information Report - Responses to DEQ Comments 1/31/2020 12 NCDEQ November 2019 Mass Loading Model Summary Update 3/16/2020 12 NCDEQ Old Outfall 002 GAC Pilot Addendum and Cover Letter 1/15/2020 28 NCDEQ Quarterly Progress Report Cover Letter 1/22/2020 28 NCDEQ Quarterly Progress Report 1/22/2020 32 NCDEQ Consent Order Coronavirus Letter 3/19/2020 1 Consent Order submissions by Chemours from lodging of the Proposed Consent Order in November 2018 through March 31, 2019 were presented in the 1st quarter report, April 1, 2019 through June 30, 2019 in the 2nd quarter report, July 1, 2019 through September 30, 2019 in the 3rd quarter report, and October 1, 2019 through December 31, 2019 in the 4th quarter report.
Consent Order Progress Report For First Quarter 2020 2020 First Quarter Residential Summary
Item
Cumberland
County
(East of River)
Cumberland
County
(West of River)
Bladen
County
(East of River)
Bladen
County
(West of River)
Robeson
County Total
Total Number of Residences Sampled 370 851 22 17 59 1319
Residences Exceeding GAC Criteria (GenX
>= 140 ng/L) 2 8 0 1 0 11
Residences Exceeding RO Criteria (∑PFAS
>= 70 ng/L) 177 347 4 13 23 564
Residences Exceeding RO Criteria (PFAS >=
10 ng/L) 120 328 4 1 24 477
Residences Drinking Water Well Detections
(Results < 10 ng/L) 7 14 0 0 1 22
Residences Drinking Water Well Non-
Detections 73 172 14 3 11 273 Note: The total number of residences sampled may not equal the sum of the values in each column because (1) the residences sampled may share drinking water wells; therefore there may be more than one filtration system or bottled water delivery per well sampled, (2) the residence’s lab results are pending because the sample is still being analyzed at the lab, (3) counts are only included for the timeframe 1/1/2020 through 3/31/2020, and (4) quarterly data is based on sample date.
Consent Order Progress Report For First Quarter 2020 Replacement Drinking Water Actions (Replacement drinking water actions from November 20182 - March 31, 2020)

2 The date the proposed Consent Order was lodged.
Consent Order Progress Report For First Quarter 2020 Consent Order Progress Details This section summarizes the activities that have been undertaken by Chemours pursuant to the Consent Order Compliance Measures for the period from January 1, 2020 through the end of the first quarter of 2020 (March 31, 2020). Section 7 Control Technology Improvements The Thermal Oxidizer (see photo at right) continues to control process emissions from the HFPO, Vinyl Ethers North, Vinyl Ethers South, Polymers, RSU, TFE and MMF processes. Destruction efficiency tests were run in February 2020 and a compliance report showing an average PFAS destruction efficiency of 99.99981% was submitted on March 30, 2020. Section 8 GenX Emissions Reduction Milestones On January 21, 2020, Chemours submitted the 92% GenX Compounds emissions reduction report for Calendar Year 2019. As noted above, during the first quarter of 2020, Chemours also completed and reported the results of testing of the thermal oxidizer. Section 10 No Discharge of Process Wastewater from Chemours’ Manufacturing Areas Chemours continues to not discharge its process wastewater and to ship its process wastewater offsite for disposal. Section 11 Characterization of PFAS in Process and Non-Process Wastewater and Stormwater at the Facility During the first quarter of 2020, Chemours’ consultant Geosyntec prepared the 2019 fourth quarter report describing and analyzing characterization sampling of process water, non-process wastewater and stormwater that occurred in October and December 2019. Chemours submitted the report to NCDEQ on January 31, 2020. Additional sampling under Paragraph 11 was conducted on January 29th and 31st, 2020. Samples were collected from 20 locations during the January 2020 event. Geosyntec is preparing the 2020 first quarter report for submission under separate cover by April 30, 2020 to include data from this event. The quarterly report will include a discussion of data collected from the facility’s wastewater treatment plant influent and effluent.
Consent Order Progress Report For First Quarter 2020 During the first quarter of 2020, Chemours completed non-targeted testing on two sets of samples collected during June, August, October, and December 2019 and January 2020. Samples were collected from eight locations (4, 8, 9, 15, 16, 17, 20 and 42; See Appendix A Figure A-1). There were no detections on any new analytes in samples collected from locations 8, 15, and 20. Sample Number Sample Location Description 8 Outfall 001 non-Chemours treated process wastewater discharged to open channel to Outfall 001 15 Combined stormwater and NCCW discharge from eastern portion of the Facility 20 Outfall 002 to Cape Fear River There were detections in initial testing for analytes in samples collected from locations 4, 9, 16, 17 and 42. Initial testing presented analytes detected that are not on the Table 3+ list. Chemours is in the process of determining the structure of the new analytes and will communicate its findings when available. Sample Number Sample Location Description 4 Combined stormwater discharge from Kuraray northern leased area and Chemours PPA area 9 Chemours Monomers IXM NCCW and stormwater discharge including stormwater from Vinyl Ethers South and Vinyl Ethers North 16 Chemours Monomers IXM Area combined process Wastewater 17 Chemours PPA Area combined process wastewater 42 Stormwater from rooftop gutters from the Chemours Monomers IXM area going to the Cooling Water Channel Section 11.2 Characterization of PFAS Contamination in River Sediment Chemours responded to NCDEQ comments on the Sediment Characterization Plan on January 22, 2020. Chemours and NCDEQ representatives also discussed comments on the sampling plan after submittal of the responses to comments. Chemours received NCDEQ approval to proceed with the sampling plan with the inclusion of an additional transect downgradient of Kings Bluff in the Cape Fear River in an e-mail from Mr. Michael Scott dated April 6, 2020. Chemours plans to perform this sampling in the second quarter of 2020.
Consent Order Progress Report For First Quarter 2020 Section 12 Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes On January 31, 2020, Chemours submitted repsonses to both NCDEQ and Cape Fear River Watch in response to letters received from both parties on December 19, 2019. Chemours submitted a memorandum describing the November 2019 Mass Loading Sampling event on March 16, 2020. Section 14 Toxicity Studies Chemours has now procured sufficient quantities for testing of four of the five test substances and will be sending those to the test companies to start the range finding study. Section 16 Groundwater Remediation Chemours conducted a baseline mass loading monitoring event described in the Corrective Action Plan (CAP) by collecting groundwater, surface water and river samples and measuring flows in surface water bodies at and around the Site between late February and early April 2020. These results will be described in the first quarterly report for this program to be submitted in the second quarter of 2020. Sections 19 and 20 Provision of Public Water Supplies, Whole Building Filtration Systems, and Reverse Osmosis Drinking Water Systems Chemours continues to meet the Consent Order requirements. During most of the quarter, Chemours’ contractors continued to install GAC whole building filtration systems and RO drinking water systems at residences. Statistics are provided in the “Replacement Drinking Water Actions” section above. In response to the coronavirus (COVID-19) pandemic, and in alignment with federal and state guidelines limiting personal contact, the routine installation of new RO and GAC systems has been temporarily suspended as of March 26, 2020. During the postponement period, Chemours contractors will continue to provide bottled water and conduct other limited activities, including collecting quarterly performance samples at GAC installations and providing necessary operation and maintenance on existing systems. Section 21 Private Well Testing The Adaptive Step Out and Infill Sampling Program has been ongoing since the 3rd quarter of 2019. Two to five stages of step out sampling have occurred across the sectors and the current step out distance intervals range from 5.5-6.5 miles to 10.5-11.5 miles from the Site. Results for some of the current stage of Step Out sampling are still pending. Two of the sectors have been delineated (i.e., no further step outs for these two sectors are needed). Distance intervals for current infill sampling for all sectors range from 2.5-7.5 miles to 5.5 to 10.5 miles from the Site. Statistics are provided in the “2020 First Quarter Residential Summary” table above.
Consent Order Progress Report For First Quarter 2020 In response to the coronavirus (COVID-19) pandemic, and in alignment with federal and state guidelines limiting personal contact, the routine sampling program has been temporarily suspended as of March 26, 2020. During the postponement period, Chemours will continue to conduct limited activities, including verifying contact information and obtaining approval to sample drinking water wells once the sampling program resumes. Pursuant to Paragraph 21 and the Drinking Water Compliance Plan and the Drinking Water Compliance Plan Responses to Comments, Chemours conducted the annual PFAS contamination extent retest, by randomly selecting and analyzing samples from 20 wells that previously had GenX concentrations that were non-detect and from 20 wells where previous GenX concentrations were between 70 ppt and 140 ppt. Section 22 Provision of Sampling Results Chemours provided (and continues to provide) sampling results to NCDEQ and residences as required under the Consent Order. Chemours has provided sampling results to NCDEQ by sending a courtesy email notification and by uploading sampling results to the state Equis database. Chemours has also provided final lab reports to NCDEQ. Chemours has provided sampling results to residents by including preliminary results with water filtration system initial offer letters and sending the final lab reports to residents within the following 30 days. Chemours has also provided non-detect sampling results to residents. Section 23 Interim Replacement of Private Drinking Water Supplies All residences eligible to receive the interim replacement drinking water supplies have received the supplies (i.e., bottled water). As of March 31, 2020, there are 2,609 residences receiving bottled water. Section 26 Total Organic Fluorine Please see Appendix B for the quarterly progress report from Dr. Susan D. Richardson. Section 28 Reporting Chemours submitted the Consent Order 4th quarter progress report on January 22, 2020. Sections 29 and 30 Public Information Chemours has continued to post its Consent Order submissions at https://www.chemours.com/Fayetteville-Works/en-us/c3-dimer-acid/compliance-testing/.
Appendix A

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")
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Du Po n t A reaWoodLinedTrench
Ope n Cha nn e l t o Ou tfal l 0 02
Co oli n g Wat er Ch a nn el
Wastewater
TreatmentPlant Discharge Cape Fear
R
iver
4*
8
9*
20**
16
17
42*
Paragraph 11(a) Non-Targeted Analysis Sample Locations
Chemours Fayetteville Works, North Carolina
Figure
A-1Raleigh
500 0 500250 Feet
³Path: P:\PRJ\Projects\TR0795\Database and GIS\Illustrator\Outfall002 Reductions\TR0795_WorkplanLocations_Apr2020.aiApril 2020
Projection: NAD 1983 StatePlane North Carolina FIPS 3200 Feet; Units in Foot US
Notes:*- Locations 4, 9, and 42 are collected during rain events only.**- Location 20 is collected during dry and rain events.
Sample numbers 4, 8, 9, 15, 16, 17 and 20 correspond to locationsidentified in the May 2019 PFAS Characterization Plan. Sample
number 42 corresponds to the location identified in the September2019 Stormwater Grab Sampling Workplan.
Legend
!(Temporal Composite Sample
")Grab Sample
Sample Location Category
Stormwater
Ditch Types
Wood Lined Trench
Cooling Water Channel
Open Channel to Outfall 002
Non-process wastewater
DuPont Area
Process wastewater
Outfall 002
Wastewater Treatment Plant Discharge
15
"
"
"
Appendix B

1
2nd Progress Report
Development of a Total Organic Fluorine (TOF) Method for the Analysis of Process
Wastewater Streams and Air from Fayetteville Works (NC)
Susan D. Richardson and Ying Zhang, University of South Carolina
April 4, 2020

Since the last progress report (November 27, 2019), we have obtained a newly created
low-fluorine activated carbon (from Mitsubishi) and tested its fluorine background,
and it is much lower than activated carbons that were available previously. In addition,
we also purchased 14 PFAS standards, and along with the standards we already had
and Chemours has provided, we have 28 PFAS standards in total, and we plan to test
the recoveries of each standard and their mixture. Below is a summary of the TOF
method development work up-to-date.

1. New carbon background and TOF of the system blank
As we noted in the last report, the activated carbons that were commercially available
had relatively high fluorine backgrounds, which will increase the background of the
whole system. So, we have been looking for carbons with lower fluorine background.
In December 2019, we received the new Mitsubishi carbon (made in Japan), and tested
its background. The fluorine background of the carbon is from non-detect (ND) to 26
ng/cartridge (n=6, mean=4.3 ng ).
Also, in order to improve the accuracy of the TOF method, we adjusted the pre-flushing
protocol. Before sample testing, the adsorption unit was flushed with Milli-Q water at
ten times the sample volume (usually 500 mL, pH<2), and the whole fluorine system
background decreased to ND-13.5 ppb (n=6, mean=6 ppb).

2. Recoveries of several standards
The PFAS standards in our lab are listed in Table 1.

Table 1. List of PFASs standards
Compound Formula CAS number
PFPrA C3HF5O2 422-64-0
PFBA C4HF7O2 375-22-4
2
PFPeA C5HF9O2 2706-90-3
PFHxA C6HF11O2 307-24-4
PFHpA C7HF13O2 375-85-9
PFOA C8HF15O2 335-67-1
PFNA C9HF17O2 375-95-1
PFDA C10HF19O2 335-76-2
PFUdA C11HF21O2 2058-94-8
PFDoA C12HF23O2 307-55-1
PFTeDA C14HF27O2 376-06-7
PFBS C4HF9O3S 375-73-5
PFHxS C6HF13O3S 355-46-4
PFOS C8HF17O3S 1763-23-1
GenX C6HF11O3 13252-13-6
HFPO-TA C9HF17O4 13252-14-7
PFO3OA C5HF9O5 39492-89-2
PFO4DA C6HF11O6 39492-90-5
PFO5DA (PFO5DoA) C7HF13O7 39492-91-6
PEPA C5HF9O3 863090-89-5
PMPA C4HF7O3 13140-29-9
EVE Acid C8HF13O4 69087-46-3
Hydro-EVE Acid C8H2F14O4 Produced by Chemours
R-EVE C8H2F12O5 Produced by Chemours
NVHOS C4H2F8O4S Produced by Chemours
Byproduct 4 (BP4) C7H2F12O6S Produced by Chemours
Byproduct 5 (BP5) C7H3F11O7S Produced by Chemours
Byproduct 6 (BP6) C6H2F12O4S Produced by Chemours

Up to now, we have tested recoveries of six PFAS standards (Figure 1). The average
recoveries of PFASs are 29% for PFOA, 40% for PFOS, 29% for GenX, 30% for HFPO-TA,
45% for PMPA, and 78% for NVHOS.

3

Figure 1. Recoveries of six PFASs standards (pH<2, compound concentration = 50 ppb)

Because the recoveries are not very high, we are adjusting some parameters to
improve it. First, we changed the sample pH from <2 to <1. We expect a lower pH to
aid adsorption on the activated carbon for those compounds that have low pKa. This is
because neutral molecules should sorb better on the carbon than charged species,
which will favor partitioning in the water. After that sample pH adjustment, we were
only able to test PFOA and PFOS once (triplicates) due to our shortage of low-F
activated carbons and the outbreak of Covid-19 (see Figure 2). Note that we had
ordered more low-F activated carbons from Mitsubishi several weeks ago, but they
have not yet been delivered. With the lower sample pH prior to adsorption on the
activated carbon, we observed an increase of the recoveries (average recovery of PFOA
is 55%, and that of PFOS is 37%). However, the results are not consistent, and we will
test more times to confirm. Note that PFOS, which contains a negatively charged
sulfonate group, is an anion at pH <1 (it has a negative pKa estimated to be -3.3), so
there may be a limit to how well we can recover low- pKa compounds such as PFOS.

4

Figure 2. Recoveries of PFOA and PFOS (pH<1, compound concentration = 50 ppb)