2019.01.14_CCO.p12.c and p.27_Long to Holman re Notification Pursuant

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

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

Re: Notification Pursuant to Proposed Consent Order Paragraphs 12(c) and 27

Dear Ms. Holman,

Pursuant to the requirements of Paragraphs 12(c) and 27 of the proposed Consent Order,
Chemours is notifying the Department of Environmental Quality (“DEQ”) of the third-party that
it has selected to undertake certain obligations in the Consent Order. The Consent Order requires
that these selected contractors be approved by DEQ. Although the Consent Order has not been
entered by the Court, and DEQ is still reviewing public comments, we are seeking your approval
of these contractors at this time so that the necessary work can proceed on schedule.

Paragraph 12(c) would require Chemours to fund development by a third party of a
model accounting for all sources of PFAS (including identification and mass loading of all
PFAS) from the Facility contributing to the loading of PFAS into the Cape Fear River, Willis
Creek, Georgia Branch, and Old Outfall 002.

Paragraph 27 would require Chemours to fund development by a third party of a study,
based on the best available data and information, analyzing the fate and transport of identified
PFAS originating from the Facility in air, surface water and groundwater.

Chemours has selected Geosyntec Consultants to perform from these two projects, and
requests your approval. Detailed information about Geosyntec’s expertise and qualifications,
including their 1,200 engineers, geologists, scientists, and other technical specialists, can be
found at their website https://www.geosyntec.com. The CVs of the engineers and scientists at
Geosyntec who would be expected to lead the projects are attached, although others would be
added as needed during the course of the project.

We also note that: (i) Geosyntec has been working with Chemours on environmental
studies and projects related to the Fayetteville Works site since 2017, so they already have
invaluable expertise related to the site; (ii) Chemours intends to contract with Geosyntec to assist
with other studies and projects required by the Consent Order, for which DEQ approval of the
contractor is not required, so having them perform these two projects as well will result in
greater efficiency; and (iii) we had notified DEQ during the negotiation of the Consent Order
that Chemours intended to rely on Geosyntec for the paragraph 12(c) modelling work.

Please confirm that Geosyntec is acceptable to DEQ for performance of the Paragraph
12(c) and 27 projects. If you have any questions or need further information, please let me know.

We note that Paragraphs 14 and 26 of the proposed Consent Order also require DEQ
approval of Chemours’s selection of third parties to perform studies of, respectively: (i) toxicity

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

of specified compounds, and (ii) analysis for Total Organic Fluorine. We will inform you of our
proposed selections for those studies and seek your approval after the Consent Order is entered.

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works