2020.01.22_CCO.p28_Consent Order Progress Report for Fourth Quarter 2019

Consent Order Progress Report For Fourth Quarter 2019 Submissions to the State of North Carolina and Cape Fear River Watch The following table identifies submissions made by Chemours pursuant to the requirements of the Consent Order for the period of October 1, 2019 through the end of the fourth quarter on December 31, 2019.1 CO Section Submitted To Title Submitted Date 8 NCDAQ 82% Facility-Wide Reduction of GenX Compounds Emissions Pursuant to Consent Order Paragraph 8.a 12/03/2019 8 NCDAQ Vinyl Ethers North Carbon Bed and Stack Test Report and Polymers Stack Test Report 10/25/2019 8 NCDAQ Monthly Emissions Report 10/21/2019 8 NCDAQ Monthly Emissions Report 11/20/2019 8 NCDAQ Monthly Emissions Report and Vinyl Ethers South Carbon Bed and Stack Test Report 12/20/2019 11 NCDEQ Quarterly Report for Characterization of PFAS in Process and Non-Process Wastewater and Stormwater 10/31/2019 12 NCDEQ Cape Fear River PFAS Loading Reduction Plan – Supplemental Information Report 11/04/2019 16 NCDEQ Corrective Action Plan 12/31/2019 18 NCDEQ Updated On and Offsite Assessment Report 10/31/2019 26 NCDEQ Total Organic Fluorine First Quarterly Report 12/10/2019 28 NCDEQ Consent Order Quarterly Progress Report 10/17/2019 2019 Year-End Residential Drinking Water Well Summary
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, and July 1, 2019 through September 30, 2019 in the 3rd quarter report.
Consent Order Progress Report For Fourth Quarter 2019 Replacement Drinking Water Actions (Replacement drinking water actions from November 20182 - December 31, 2019)

2 The date the proposed Consent Order was lodged.
Consent Order Progress Report For Fourth Quarter 2019 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 October 1, 2019 through the end of the fourth quarter of 2019 (December 31, 2019). Section 7 Control Technology Improvements Chemours successfully completed installation and startup of its new thermal oxidizer facility (see photo at right) on December 27, 2019. Construction was mechanically complete in November, and after routine commissioning activities and tests for the facility, the thermal oxidizer became fully operational on December 27. Chemours switched to the permitted operating scenario for the thermal oxidizer on December 31. Within 90 days of installation, Chemours and the North Carolina Division of Air Quality will conduct testing to confirm that the thermal oxidizer is destroying 99.99% of all PFAS air emissions routed to it (from the HFPO, Vinyl Ethers North, Vinyl Ethers South, Polymers, RSU, TFE and MMF processes). Section 8 GenX Emissions Reduction Milestones During the fourth quarter, Chemours submitted monthly emissions reports in October, November, and December, which provided the details of emissions to date to meet the Consent Order requirements of 82% and 92% for plant-wide interim reductions of air emissions of GenX Compounds. A final report demonstrating compliance with the Consent Order Section 8.a 82% reduction requirement was submitted on December 3, 2019. Pursuant to Consent Order Section 8.b.i., Chemours completed testing of the facility’s 2019 product campaigns with testing for E2 in December 2019, which was the first run of that product in 2019. Chemours submitted the E2 emissions test report on January 21, 2020. Section 10 No Discharge of Process Wastewater from Chemours’ Manufacturing Areas Chemours continues to not discharge its process wastewater and to ship all of its process wastewater offsite for disposal.
Consent Order Progress Report For Fourth Quarter 2019 Section 11 Characterization of PFAS in Process and Non-Process Wastewater and Stormwater at the Facility Chemours’ consultant Geosyntec prepared its second quarterly report describing and analyzing characterization sampling of process water, non-process wastewater and stormwater that occurred in August 2019, as well as samples from April 2019 and June 2019 that were re-analyzed to achieve lower reporting limits. Chemours submitted the report to NCDEQ on October 31, 2019. Additional bimonthly sampling under Paragraph 11 was conducted on October 9 and 10 as well as December 20 and 23, 2019. Samples were collected from 19 locations during the October 2019 sampling event and from 22 locations during the December 2019 event. Geosyntec is preparing the next quarterly report for submission by January 31, 2019 to include data from these events. During the fourth quarter, Chemours also completed non-targeted testing on two sets of samples collected during June and August 2019. Samples were collected from five locations. There were no detections of any new analytes in samples collected from locations 8, 15, and 20. Sample Location 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 of new analytes in initial testing of samples collected from locations 16 and 17 (process wastewaters sent for offsite disposal). Chemours is in the process of determining the structure of the new analytes and will communicate its findings when available. Sample Location Number Sample Location Description 16 Chemours Monomers IXM Area combined process wastewater 17 Chemours PPA Area combined process wastewater Section 11.2 Characterization of PFAS Contamination in River Sediment Chemours received from NCDEQ comments on the Sediment Characterization Plan on November 20, 2019. Chemours is preparing responses to these comments and will submit the responses in January 2020.
Consent Order Progress Report For Fourth Quarter 2019 Section 12 Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes On November 4, 2019, Chemours submitted the Cape Fear River Loading Reduction Plan – Supplemental Information Report prepared by Chemours’ consultants Geosyntec and Parsons. On December 19, 2019, Chemours received comments from NCDEQ and Cape Fear River Watch. Chemours is preparing responses to these comments and will submit the responses in January 2020. Section 14 Toxicity Studies During the fourth quarter, Chemours discussed its plan for the studies with NCDEQ. Study protocol development has started, and data collection is targeted to begin in March or April 2020. Section 16 Groundwater Remediation Chemours submitted the Corrective Action Plan (CAP), prepared by Geosyntec, on December 31, 2019. The CAP describes proposed remediation activities to address legacy PFAS in groundwater and surface waters at Fayetteville Works, in accordance with the requirements of the Consent Order and the North Carolina 2L Rules. The CAP also contains supporting documentation, including ecological and human health screening level exposure assessments (SLEAs). Section 18 On and Off-site Assessment Chemours submitted to NCDEQ an updated version of the On and Offsite Assessment Report on October 31, 2019. The updated report included newly available data from on and offsite soil and groundwater samples and a synoptic groundwater level collection event. Associated text, tables, figures and appendices were also updated. Sections 19 and 20 Provision of Public Water Supplies, Whole Building Filtration Systems, and Reverse Osmosis Drinking Water Systems 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. Section 21 Private Well Testing The Adaptive Step Out and Infill Sampling Program has been ongoing since the 3rd quarter of 2019. Two to four stages of step out sampling have occurred across the sectors and the current step out distance intervals from the Site range from 4.5-5.5 miles to 9.5-10.5 miles. Results for the current stage of step out sampling are pending. Infill sampling is ongoing for all sectors and distance intervals from the Site range from 2.5-6.5 miles to 5.5-9.5 miles. Since the Consent Order was signed, the project team has made a total of 8,248 visits to 4,651 residences and collected 2,492 samples. This quarter (October 2019 through December 2019) there have been 5,356 visits made to 3,347 residences and 1,463 samples have been collected.
Consent Order Progress Report For Fourth Quarter 2019 Section 22 Provision of Sampling Results Chemours provided (and continues to provide) sampling results to NCDEQ and residences as required under the Consent Order. 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 December 31, 2019, there are 1,478 residences receiving bottled water. Section 26 Total Organic Fluorine Chemours submitted to NCDEQ the Total Organic Fluorine first quarterly progress report on December 10, 2019, following NCDEQ’s approval on October 2, 2019 of Dr. Susan D. Richardson as the third party contractor for the Total Organic Fluorine study. Section 28 Reporting Chemours submitted the Consent Order 3rd quarter progress report on October 17, 2019. 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/.