2020.07.21_CCO.p28_Consent Order Progress Report for Second Quarter 2020

Consent Order Progress Report For Second 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 April 1, 2020 through the end of the second quarter on June 30, 2020.1 CO Section Submitted To Title Submitted Date 7 & 8 NCDEQ Clarification Letter regarding Thermal Oxidizer Emission Test Reports 4/03/2020 11 NCDEQ PFAS Characterization Quarterly Report 4/30/2020 11 NCDEQ Updates to Laboratory Analytical Test Methods 6/10/2020 11 NCDEQ PFAS Non-Targeted Analysis and Methods Interim Report 6/30/2020 19 & 21 (25) NCDEQ Request for Extension of Deadlines 5/19/2020 26 NCDEQ Request for Extension of Deadline 6/08/2020 28 NCDEQ Quarterly Progress Report 4/24/2020
1 Consent Order submissions by Chemours from lodging of the Proposed Consent Order in November 2018 through March 31, 2019 were presented in the 2019 1st quarter report, April 1, 2019 through June 30, 2019 in the 2019 2nd quarter report, July 1, 2019 through September 30, 2019 in the 2019 3rd quarter report, October 1, 2019 through December 31, 2019 in the 2019 4th quarter report, and January 1, 2020 through March 31, 2020 in the 2020 1st quarter report.
Consent Order Progress Report For Second Quarter 2020 2020 Second 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 118 224 2 2 6 352
Residences Exceeding GAC
Criteria (GenX >= 140 ng/L) 0 2 0 0 0 2
Residences Exceeding RO
Criteria (∑PFAS >= 70 ng/L) 41 34 0 0 1 76
Residences Exceeding RO
Criteria (PFAS >= 10 ng/L) 14 39 0 0 1 54
Residences Drinking Water Well
Detections (Results < 10 ng/L) 2 14 0 0 1 17
Residences Drinking Water Well
Non-Detections 62 135 2 2 3 204 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 4/1/2020 through 6/30/2020, and (4) quarterly data is based on sample date.
Consent Order Progress Report For Second Quarter 2020 Replacement Drinking Water Actions (Replacement drinking water actions from November 20182 - June 30, 2020)

2 The date the proposed Consent Order was lodged.
Consent Order Progress Report For Second 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 April 1, 2020 through the end of the second quarter of 2020 (June 30, 2020). Section 7 Control Technology Improvements The thermal oxidizer (see photo at right) continues to control process emissions at an average PFAS destruction efficiency exceeding 99.99%. On June 2, 2020, Chemours identified vents on three vessels located in the Polymers Process area as not routing to the thermal oxidizer. Chemours promptly shut down the Polymers Process to make modifications to the vents and promptly contacted DEQ. The Polymers Process remained down until all of the vent modifications were completed on July 4, 2020. The modifications were as follows:
· Two of the vessels had conservation vents, which relieved when the vessel was over-pressurized and could occur during normal operations. The conservation vents on these two vessels were modified to pressure relief valves, which relieve only in emergency conditions.
· The third vessel has a pressure relief valve (which relieves only in emergency conditions) and a process control valve. The venting of the process control valve was modified to direct it to the IXM waste gas compressor, which then routes to the thermal oxidizer. Section 8 GenX Emissions Reduction Milestones On April 3, 2020, Chemours submitted a letter to NCDEQ clarifying that its March 30, 2020 submittal of the Thermal Oxidizer Performance Test Report satisfies both Paragraphs 7.c and 8.c.i of the Consent Order. 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. Chemours is recycling treated water internally within several
Consent Order Progress Report For Second Quarter 2020 manufacturing processes. Section 11 Characterization of PFAS in Process and Non-Process Wastewater and Stormwater at the Facility During the second quarter of 2020, Chemours’ consultant Geosyntec prepared the 2020 first quarter report describing and analyzing characterization sampling of process water, non-process wastewater and stormwater that occurred in January 2020. Chemours submitted the report to NCDEQ on April 30, 2020. Additional sampling under Paragraph 11 was conducted on April 28, 2020, May 20 and 21, 2020, and June 3 and 5, 2020. Geosyntec is preparing the 2020 second quarter report for submission under separate cover by July 31, 2020 to include data from these sampling events. On June 10, 2020, Chemours submitted to NCDEQ updates to laboratory analytical test methods for PFAS in aqueous samples collected by Chemours pursuant to the Consent Order. On June 30, 2020, Chemours submitted to NCDEQ the PFAS Non-Targeted Analysis and Methods Interim Report describing results to date and next steps in the non-targeted analysis program pursuant to Paragraph 11(a) of the Consent Order. Section 11.2 Characterization of PFAS Contamination in River Sediment During the second quarter of 2020, Chemours’ contractors performed field sampling of Cape Fear River surface water and sediment pursuant to the Sediment Characterization Plan. Sampling events were completed on June 30, 2020. Samples collected from the last three river transects were collected in duplicate and split with NCDEQ. Samples are presently undergoing laboratory analysis and will be subsequently reported in a Sediment Characterization Report to be submitted to NCDEQ. Section 12 Accelerated Reduction of PFAS Contamination in the Cape Fear River and Downstream Water Intakes During the second quarter of 2020, Chemours continued significant work to reduce the remaining PFAS loadings from surface water and groundwater to the Cape Fear River, including continued design of proposed corrective actions and mass loading sampling. Section 14 Toxicity Studies Chemours has now provided four of the five test substances to the contract laboratory and the fifth is going through final purification. The arrival of the test substances will be followed by the generation of the Phase 1 testing schedule. Phase 1 includes the analytical method development and initial range finding studies necessary to set appropriate dose levels for the Consent Order studies.
Consent Order Progress Report For Second Quarter 2020 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 in May 2020. These results will be described in the second quarterly mass loading report. Sections 19 and 20 Provision of Public Water Supplies, Whole Building Filtration Systems, and Reverse Osmosis Drinking Water Systems Chemours continues work to meet the Consent Order requirements. 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 installation of new RO and GAC systems was temporarily suspended on March 26, 2020. During the postponement period, Chemours contractors continued to provide bottled water, collect quarterly performance samples at GAC installations and provide necessary operation and maintenance on existing systems. After a review of updated health and safety guidance from the local, state, and federal governments, Chemours’ contractors resumed residential installation of RO drinking water systems on June 22, 2020 and GAC whole building filtration systems on July 7, 2020. Section 21 Private Well Testing In response to the coronavirus (COVID-19) pandemic, and in alignment with federal and state guidelines limiting personal contact, Chemours temporarily suspended private well testing on March 26, 2020. Chemours resumed private well testing on May 26, 2020. The method of seeking permission from residences for private well testing has changed due to COVID-19 protocols. Specifically, Chemours is no longer making cold calls by walking up to the residence for private well testing, and instead a letter seeking permission for sampling with a return post card is mailed out to all eligible residences. Other than during the COVID-19 postponement period noted above, the Adaptive Step Out and Infill Sampling Program has been ongoing since the 3rd quarter of 2019. Two to seven 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 12.5-13.5 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) and an additional four are near delineated (results pending). Distance intervals for current infill sampling for all sectors range from 2.5-6.5 miles to 5.5 to 13.5 miles from the Site. Statistics for sampling during the second quarter of 2020 are provided in the “2020 Second Quarter Residential Summary” table above. 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
Consent Order Progress Report For Second Quarter 2020 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 residences by including preliminary results with water filtration system initial offer letters and sending the final lab reports to residences within the following 30 days. Chemours has also provided non-detect sampling results to residences. These practices were continued during the private well testing postponement period caused by the coronavirus (COVID-19) pandemic as results from previous testing became available. 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 June 30, 2020, there are 2,293 residences receiving bottled water. Section 25 Extension of Deadlines On May 19, 2020, pursuant to Paragraph 25 of the Consent Order, Chemours submitted to NCDEQ a request for extension of deadlines under Paragraphs 19 and 21. Specifically, Chemours requested: 1) an extension to August 25, 2020 to meet the Paragraph 19 requirements in Bladen and Cumberland Counties west of the Cape Fear River, and 2) an extension to November 25, 2020 to complete the Adaptive Step Out and Infill Sampling Program pursuant to Paragraph 21. On May 22, 2020, NCDEQ granted the requested extensions. Section 26 Total Organic Fluorine Please see Appendix A for the quarterly progress report from Dr. Susan D. Richardson. On June 8, 2020, Chemours submitted to NCDEQ a request for an extension of the deadline for submission of the Total Organic Fluorine (TOF) methodology by Dr. Richardson to June 30, 2021. On June 17, 2020, NCDEQ granted the requested extension. Section 28 Reporting Chemours submitted the Consent Order 1st quarter 2020 progress report on April 24, 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

1
3rd 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
June 22, 2020

Since the last progress report (April 4, 2020), we have mainly focused on the repair
and update of the instruments, including a new TOF adsorption unit and a new ion
chromatograph (IC). While we wait for the purchase and installation of a new IC (see
below), we are shifting our focus to liquid chromatography (LC)-mass spectrometry
(MS)/MS analyses for target and non-target PFASs (which is also part of our proposal).
For most of this quarter, the University of South Carolina was partially shut down due
to the Covid-19 situation, so that our progress was significantly delayed. Below is a
summary of the TOF method development work up-to-date.

1. Update of the TOF adsorption unit
In order to improve the efficiency of the TOF adsorption unit, we purchased two new
lines for this instrument, which brings the total lines to four, doubling the pretreatment
capacity of our system. Also, we washed the new lines with Milli Q water to decrease
the fluorine background.

2. Update of the ion chromatograph
The type of the ion chromatograph we used before is a Dionex 1600 with a sodium
carbonate eluent. During the partial shutdown of the University caused by Covid-19,
this IC started leaking, and we contacted the company (ThermoFisher) to get it fixed.
The instrument has since been successfully repaired and the leak eliminated, but the
sensitivity of fluoride is decreased. In order to improve its sensitivity and stability (and
also better separate the fluoride signal from the “water dip”), we decided to update
the IC to enable a potassium hydroxide eluent (which requires a new instrument with
an eluent generator). Thus, we are purchasing a whole new IC with an eluent
generation system that will allow potassium hydroxide eluents. I just received word
today that the purchase order has been issued to ThermoFisher, and we expect
delivery and installation of the new instrument in the next 1-2 months.