2019_CCO.p28_Consent Order Progress Report

Consent Order Progress Report Through First Quarter 2019 Consent Order Submissions to the State of North Carolina and Cape Fear River Watch The following table identifies Consent Order submissions by Chemours for the period following the lodging of the proposed Consent Order in November 2018 through the end of the first quarter of 2019. CO Section Submitted To Title Submittal Date 7bii NCDAQ VEN Carbon Adsorber Project Completion Notification 12312018 7biii NCDAQ Final Report VEN Carbon Adsorber Unit > 93% Efficiency 02152019 8bi NCDAQ Final PPA Stack Test Report 02222019 8bi NCDAQ Final Semi-Works Stack Test Report 02222019 8bi NCDAQ Final VES Stack Test Report 02222019 8bi NCDAQ Final Division Stack Test Report 03042019 8bi NCDAQ Final Polymers Stack Test Report 03042019 8bi NCDAQ Final Semi-Works Stack Test Report 03042019 8d NCDAQ Monthly Emissions Report 03222019 9 NCDAQ E1 and 2-MTP (HFPO Monomer) GC Method SOP 12202018 9 NCDAQ HFPO Dimer Acid LCMSMS Method SOP 12202018 9 NCDAQ HFPO Dimer Acid Preparation Method SOP 12202018 9 NCDAQ PFAS Extraction Protocol SOP 12202018 9 NCDAQ PFAS Test Methods Lab Standards Submittal 12202018 11a NCDWR PFAS Non-Targeted Analysis and Methods Work Plan 01302019 11a NCDWR Modified Method 537 PFAS Analytical and Test Methods 01302019 11a NCDWR Table 3+ Compounds Analytical and Test Methods 01302019 11b NCDWR PFAS Characterization Sampling Workplan 12302018 12c and 27 NCDEQ Geosyntec Approval Request 01142019 14 NCDEQ Request for Laboratory Approval 03012019 14 NCDEQ Toxicity Study Work Plan 03272019 17 NCDWM Permanent Lining of North Sedimentation Pond Notification 12312018 19 NCDEQ GAC Approval Request Enclosure 03062019 19 NCDEQ GAC Approval Request Letter 03062019 19 NCDEQ Public Water Feasibility Analysis 03112019 19 and 20 NCDEQ RO Approval Request Enclosure 03062019 19 and 20 NCDEQ RO Approval Request Letter 03062019 19 and 20 NCDEQ Request for Approval of Drinking Water Letters to Residents 01282019 21 NCDEQ Request for Laboratory Approval and Funding Notification 12182018 22 NCDEQ Residential Sampling Results Multiple and Ongoing Other NCDEQ Final Creeks and Seeps Work Plan 02272019
Consent Order Progress Report Through First Quarter 2019 Replacement Drinking Water Actions Through First Quarter 2019
Bottled
Water Residences
Receiving
Additional
Residences
1Q19 Refused Vacant
Already
Connected
to Public
Water
600 407 13 6 2
RO
Eligible
(including
houses that
share a
well)
Systems to
Install
407 407
GAC
Eligible
Already
Connected
to Public
Water
Public
Water
Readily
Available
Public
Water
Feasible
Systems to
Install
183 2 13 36 132

Initial
Interview
Conducted?
Signed
Access
Agreement?
Total Sheds
Dropped Completed
Initial
Sampling
Complete
GAC
Change
Outs
51 37 37 29 35 1
Drinking
Water
Data to
State
Sample
Delivery
Group
(SDG)
Emailed or
Uploaded
% Within 7
days of
Final Data
151 100%
Drinking
Water
Data to
Residents Samples
% Within
Timeframe
(7 or 30
days)
Delivered or
Attempted
668 100%
Consent Order Progress Report Through First 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 following the lodging of the proposed Consent Order in November 2018 through the end of the first quarter of 2019. Paragraph 7 - Control Technology Improvements Paragraph 7a - Second Phase Scrubber
· Chemours completed installation of a packed bed scrubber ("Second Phase Scrubber") to control emissions from the Division Waste Gas Scrubber on November 7, 2018. Paragraph 7bi - Vinyl Ethers North Carbon Adsorber Project
· On October 19, 2018, Chemours submitted to DAQ a process hazard assessment pertaining to the Vinyl Ethers North Carbon Adsorber Project. Paragraph 7bii - Vinyl Ethers North Carbon Adsorber Project
· On December 26, 2018, Chemours completed construction of the Vinyl Ethers North Carbon Adsorber Project.
· All emissions from the Second Phase Scrubber are controlled by the Vinyl Ethers North Carbon Adsorber Unit subject to such unit downtime as may be required by the process hazard assessment or as necessary for maintenance of the unit. Chemours is using its best efforts consistent with safe operations to minimize unit downtime and downtime has been minimal to date. Paragraph 7biii - Vinyl Ethers North Carbon Adsorber Project
· On February 15, 2019, Chemours submitted a report documenting a 93.9% control efficiency for the Vinyl Ethers North Carbon Adsorber Unit. Paragraph 7c - Thermal Oxidizer
· A new Title V air permit (including for the thermal oxidizer) was issued by DAQ on March 14, 2019.
· Chemours construction activities continue on schedule for completion of installation of the thermal oxidizer by December 31, 2019, with foundations having been formed and poured at the facility and the construction of the equipment continuing offsite by the supplier for delivery and installation later this year. Paragraph 8 - GenX Emissions Reduction Milestones
· On March 22, 2019, Chemours submitted its first monthly emissions report as required under the Consent Order, showing the details of emissions to date for the two annual reporting periods (one starting October 6, 2018 and one starting December 31, 2018) and how the facility plans to meet the Consent Order’s 82% and 92% requirements for plant-wide interim reductions of air emissions of GenX Compounds.
Consent Order Progress Report Through First Quarter 2019
· Emissions testing of the first product campaigns in 2019 have been conducted for all products except for EVE and IXM CR. The first campaigns for these products will not occur until later in 2019, and will be tested then. All emissions test reports have been submitted to DAQ within forty-five days of completion of the emissions test, as required. Paragraph 9 - Disclosure of PFAS Emissions
· On December 20, 2018, Chemours provided DAQ with analytical test methods and lab standards for PFAS compounds in air emissions from the Fayetteville Works. Paragraph 10 - No Discharge of Process Wastewater from Chemours' Manufacturing Area
· Chemours continues to not discharge its process wastewater and to ship all of its process wastewater offsite for disposal. Paragraph 11 - Characterization of PFAS in Process and Non-Process Wastewater and Stormwater at the Facility Paragraph 11a - Test Methods and Lab Standards
· On January 30, 2019, Chemours submitted analytical test methods and lab standards for PFAS in process and non-process wastewater and stormwater at the Facility as well as a plan and schedule for conducting non-targeted analysis.
· Comments from NCDEQ and USEPA on the non-targeted analysis plan have been received and are being addressed.
· Chemours plans to submit a response to comments table alongside updated TestAmerica and Eurofins Lancaster Table 3+ SOPs to facilitate discussion and approval of the non-targeted analysis plan.
· Chemours plans to collect samples for non-targeted analysis during its first sampling event pursuant to Consent Order paragraph 11c. Paragraph 11b - Sampling Plan
· On December 30, 2018, Chemours submitted its sampling plan.
· Comments from NCDEQ, USEPA and Cape Fear River Watch on the sampling plan have been received and are being addressed.
· Chemours plans to submit a response to comments table to facilitate discussion and approval of the sampling plan. Chemours also plans to submit a revised set of figures and tables for review. Paragraph 11c - Initial Characterization
· Chemours has conducted planning for its first round of initial characterization sampling, including the purchase of auto-samplers, coordination with analytical laboratories, and refining sample collection methods.
Consent Order Progress Report Through First Quarter 2019
· A dry sampling event was scheduled for late April 2019 (it was conducted on April 24, 2019) and the first stormwater sampling event will be conducted soon. Paragraph 11.1 - Characterization of PFAS Contamination in Downstream Raw Water Intakes
· Chemours’ contractor Geosyntec is preparing a recommendation of suggested raw water samples to collect to perform the analysis required under the Consent Order. Paragraph 11.2 - Characterization of PFAS Contamination in River Sediment
· Chemours’ contractor Geosyntec has identified task leads and prepared a proposed scope of work to complete this effort. Paragraph 12 - Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes Paragraph 12a - Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes
· Chemours and its contractors Geosyntec and Parsons have reviewed existing data (including from the seep and creek investigation), potential actions, and estimated reductions. Paragraphs 12b and 12c - Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes
· By the end of March 2019, Chemours and its contractors had prepared a draft modeling scope of work document (the final document was submitted to DEQ and Cape Fear River Watch on April 11, 2019). Paragraph 12e - Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes
· Chemours’ contractor Parsons prepared a work plan for sampling in Old Outfall 002. The first sampling event was conducted on March 21, 2019.
· REGENESIS pilot study:
o Trees have been removed to facilitate the installation of performance verification monitoring wells and subsequent injections.
o A geophysical survey was completed to determine the presence of utilities.
o A driller was contracted to install performance verification testing monitoring points in April 2019.
o Injections are scheduled to begin in early May 2019.
· Chemours continues to work on the plan to be submitted within 90 days of Consent Order entry as well as the pilot study for capture and treatment.
Consent Order Progress Report Through First Quarter 2019 Paragraph 13 - Facility Site Visit
· The facility site visit with DEQ and Cape Fear River Watch occurred on January 3, 2019. Paragraph 14 - Toxicity Studies
· In March 2019, Chemours submitted its request for laboratory approvals as well as its toxicology workplan. Chemours is working to respond to DEQ’s questions about the laboratories. Paragraph 16 - Groundwater Remediation
· Chemours’ contractor Geosyntec has started to develop the Corrective Action Plan, which will be submitted by the deadline of December 31, 2019. Paragraph 17 - Lining of Nafion Ditch and Sedimentation Ponds
· These items have been completed, as stated in the Consent Order. Paragraph 18 - On and Off-site Assessment
· Chemours’ contractor Geosyntec has started to prepare the comprehensive site assessment, which will be submitted by the deadline of September 30, 2019. Paragraphs 19 and 20 - Provision of Public Water Supplies, Whole Building Filtration Systems, and Reverse Osmosis Drinking Water Systems
· On March 11, 2019, Chemours submitted its public water feasibility analysis.
· On March 22, 2019, Chemours met with the Bladen County utilities department to discuss the process for making public water connections.
· On March 25, 2019, Chemours received DEQ’s approval for the Granular Activated Carbon (GAC) whole building filtration system and the Reverse Osmosis (RO) drinking water systems that Chemours plans to install. Paragraph 21 - Private Well Testing
· On December 18, 2018, Chemours submitted its request for laboratory approval and notification of funding. Paragraph 22 - Provision of Sampling Results
· Chemours provided (and continues to provide) sampling results to DEQ and residences as required under the Consent Order.
· Chemours’ contractor AECOM also prepared and transmitted level 4 lab reports for the sampling results to DEQ (and continues to do so).
Consent Order Progress Report Through First Quarter 2019 Paragraph 23 - Interim Replacement of Private Drinking Water Supplies
· As of March 31, 2019, Chemours had provided bottled water to 600 residences. Of these, 407 residences were added to the bottled water distribution program in the first quarter of 2019. Paragraph 24 - Drinking Water Compliance Plan
· During the first quarter of 2019, Chemours drafted the Drinking Water Compliance Plan (the Plan was submitted on April 26, 2019). Paragraph 26 - Total Organic Fluorine
· During the first quarter of 2019, Chemours obtained and reviewed proposals from third-parties to conduct this work (Chemours will soon submit for approval a proposal from the scientist to be recommended to conduct this study). Paragraph 27 - Fate and Transport Study
· Chemours’s contractor Geosyntec performed a fate and transport literature review and identified relevant literature papers to support development of this study. The study will be submitted by the deadline of June 30, 2019. Paragraphs 29 and 30 - Public Information
· Chemours has posted its Consent Order submissions at https://www.chemours.com/Fayetteville-Works/en-us/c3-dimer-acid/compliance-testing/index.html.