HomeMy WebLinkAbout2022.01.28_CCO.p.28_NCDEQ_Quarterly Progress ReportConsent Order Progress Report For
Fourth Quarter 2021
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 and
Addendum (COA) for the period of October 1, 2021 through the end of the fourth quarter on
December 31, 2021.1
CO Section
Title
Submitted Date
11a PFAS Non-Targeted Analysis and
Methods Interim Report #4
12/23/2021
12 – COA 1b Cape Fear River PFAS Mass Loading
Assessment Report – Third Quarter 2021
12/23/2021
12 – COA 2a Interim Seep Remediation Seep B
Effectiveness Demonstration Report
11/04/2021
12 – COA 2a Interim Seep Remediation Seep D
Effectiveness Demonstration Report
10/21/2021
12 – COA 2a Interim Seep Remediation O&M Report
#5
11/30/2021
26 Final TOF Report 12/31/2021
28 Quarterly Progress Report 10/29/2021
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,
January 1, 2020 through March 31, 2020 in the 2020 1st quarter report, April 1, 2020 through June
30, 2020 in the 2020 2nd quarter report, July 1, 2020 through September 30, 2020, in the 2020 3rd
quarter report, October 1, 2020 through December 31, 2020 in the 2020 4th quarter report, January
1, 2021 through March 31, 2021 in the 2021 1st quarter report, April 1, 2021 through June 30, 2021
in the 2021 2nd quarter report, and July 1, 2021 through September 30, 2021 in the 2021 3rd quarter
report.
Consent Order Progress Report For
Fourth Quarter 2021
2021 Fourth 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
Sampson
County Total
Total Number of Residences
Sampled 659 253 14 31 14 26 997
Residences Exceeding GAC
Criteria (GenX >= 140 ng/L) 1 1 0 0 0 0 2
Residences Exceeding RO
Criteria (∑PFAS >= 70 ng/L) 51 16 2 3 1 0 73
Residences Exceeding RO
Criteria (PFAS >= 10 ng/L) 250 63 5 9 4 4 335
Residences Drinking Water Well
Detections (Results < 10 ng/L) 140 82 1 2 5 6 236
Residences Drinking Water Well
Non-Detections 46 26 2 5 2 5 86
Consent Order Progress Report For
Fourth Quarter 2021
Replacement Drinking Water Actions
(Replacement drinking water actions from November 20182 ‐ December 31, 2021)
2 The date the proposed Consent Order was lodged.
Consent Order Progress Report For
Fourth Quarter 2021
Consent Order Progress Details
This section summarizes the activities that have been undertaken by Chemours pursuant to the
Consent Order Compliance Measures and Addendum for the period from October 1, 2021 through the
end of the fourth quarter of 2021 (December 31, 2021). On August 13, 2020, Chemours signed the
Addendum to Consent Order Paragraph 12, and the Addendum was entered by the Bladen County
Superior Court on October 12, 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%.
Section 10 No Discharge of Process
Wastewater from Chemours’
Manufacturing Areas
Chemours does not discharge its process
wastewater and instead collects and ships its
process wastewater offsite for disposal or
recycles treated water internally within several
manufacturing processes.
Section 11 Characterization of PFAS in
Process and Non‐Process Wastewater and Stormwater at the Facility
During the fourth quarter of 2021, one sampling event was conducted during December 8 ‐ 10, 2021
(the December 2021 event). Samples were collected from 27 locations during the December 2021
event. Data from the August 2021, September 2021, and December 2021 events were evaluated and
compiled for presentation in the next semi‐annual report, to be submitted by March 31, 2022.
Pursuant to Paragraph 11.a of the Consent Order, the PFAS Non‐Targeted Analysis and Methods
Interim Report #4 was submitted on December 23, 2021.
Section 12 Accelerated Reduction of PFAS Contamination in the Cape Fear River and
Downstream Water Intakes, and Addendum to Consent Order Paragraph 12
Chemours continued operation of the treatment system for the Old Outfall (Outfall 003) pursuant to
Consent Order Paragraph 12(e) and a NPDES permit issued by NCDEQ.
As noted above, the Addendum to Consent Order Paragraph 12 was signed in the third quarter of 2020
and entered by the Court during the fourth quarter of 2020. Chemours’ Addendum implementation
activities during the fourth quarter of 2021 included:
Consent Order Addendum Paragraph 1
On December 23, 2021, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear River
PFAS Mass Loading Assessment – Third Quarter 2021 Report pursuant to Consent Order Addendum
Consent Order Progress Report For
Fourth Quarter 2021
Paragraph 1(b). The report describes sampling activities and mass loading results for the Cape Fear
River and PFAS loading pathways from the third quarter of 2021. This submission was also pursuant to
quarterly reporting of mass loading sampling outlined in the Corrective Action Plan (Paragraph 16). In
each of October, November, and December 2021, Chemours conducted monthly mass loading sampling
required by Consent Order Addendum Paragraph 1.
Consent Order Addendum Paragraph 2
During the fourth quarter of 2021, Chemours operated and maintained the four flow‐through cells, i.e.,
the interim remediation systems, at Seeps A‐D. On November 30, 2021, Chemours submitted the
Interim Seep Remediation Operation and Maintenance Report #5. The Operation and Maintenance
report describes the operations and maintenance activities at the flow‐through cells over the
bimonthly reporting period of September/October. Additionally, on October 21 and November 4, 2021,
Chemours submitted the Interim Seep Remediation Effectiveness Demonstration Reports for Seeps D
and B, respectively. These reports provided a record of construction completion and demonstration of
interim effectiveness for the Seep B and Seep D systems.
Consent Order Addendum Paragraph 3
As required by the Addendum, the Black Creek Aquifer interim measure system to extract groundwater
from the seven existing Black Creek Aquifer monitoring wells (BCA‐01, BCA‐02, PW‐11, PW‐14, PW‐15R,
PIW‐9D, and PIW‐10DR) continued to operate in the fourth quarter as designed. During the fourth
quarter of 2021 (October, November, and December), the system extracted 700,732 gallons of water
for a total of 1,951,632 gallons since startup on November 30, 2020. The replacement of the electric
submersible pumps with piston pumps in the four deeper extraction wells (BCA‐01, BCA‐02, PW‐14,
and PW‐15R) has significantly improved the system and resulted in a 60 percent increase in the amount
of water extracted. The wells have continued to operate as designed with only minor, routine
shutdowns for maintenance or equipment issues.
On October 5, 2021, Chemours submitted responses to NCDEQ comments on the 60 percent design
submittal package and the PDI Report received on September 15, 2021. The responses provided
additional clarification on details of the remedy design, rationale for methods employed in the 60%
design submittal, and discussion of how the submitted design package meets the requirements of the
CO Addendum. NCDEQ and Chemours conducted a Site visit on December 16, 2021 to discuss
performance monitoring for the remedy.
Consent Order Addendum Paragraph 4
Consistent with the Stormwater Sampling Plan, Chemours conducted two sampling events in October
2021, one sampling event in November 2021, and two sampling events in December 2021 during the
stormwater treatment system operation for removal of PFAS compounds. The monthly monitoring
reports for September 2021 – December 2021 will be submitted in the first quarter of 2022. The
treatment system also consistently captured stormwater runoff from precipitation events of up to the
1‐inch, 24‐hour design storm during the fourth quarter of 2021.
Consent Order Progress Report For
Fourth Quarter 2021
Section 14 Toxicity Studies
Following a technical meeting between NCDEQ, Chemours, and Eurofins (the aquatic toxicity contract
laboratory), NCDEQ provided final comments on the aquatic protocols. Eurofins is incorporating these
comments into their protocols and addressing some additional requests from NCDEQ.
The 28‐day immunotoxicity study draft protocols were submitted to NCDEQ during the fourth quarter.
Chemours requested confirmation of the intended guideline for the 90‐day study and received a reply
in late December, which is under review.
Section 16 Groundwater Remediation
On December 23, 2021, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear River
PFAS Mass Loading Assessment – Third Quarter 2021 Report pursuant to Consent Order Addendum
Paragraph 1(b). This submission was also pursuant to quarterly reporting of mass loading sampling
outlined in the Corrective Action Plan (Paragraph 16). On‐going groundwater remediation activities are
being conducted pursuant to Consent Order Addendum Paragraph 3 and are described earlier in this
document under that paragraph.
Sections 19 and 20 Provision of Public Water Supplies, Whole Building Filtration
Systems, and Reverse Osmosis Drinking Water Systems
As shown in the summary tables above, Chemours continues to make significant progress in
implementing the Consent Order requirements of Paragraphs 19 and 20. Since resuming RO
installations in June 2020, following the COVID‐19 postponement period, the pace of RO acceptance
rates and installations has been on the rise. O&M activities for installed GAC systems continues
uninterrupted. Bottled water services continue uninterrupted for 2,696 homes. In September 2021,
Chemours entered into an agreement with Bladen County to fund public water system upgrades and
connections associated with providing permanent replacement drinking water supplies under the
Consent Order, and Chemours proceeded with implementation of the agreement during the fourth
quarter of 2021.
Section 21 Private Well Testing
As of December 31, 2021, 13,467 residences have been identified within the current study area, of
which 8,542 have been sampled and 3,547 additional residences have received at least one initial
sample offer letter. Results of sampling that occurred throughout the fourth quarter of 2021 (997
residences) are presented at the beginning of this progress report. Current Step‐out and Infill distance
intervals range from 2.5 miles to 18.5 miles from the Site.
Chemours continues to follow the private well cold calling protocol (i.e., to confirm residences,
tenant/owner name and phone number, addresses, not connected to public water, and residents’
willingness to have a sample collected from their drinking water well).
Section 22 Provision of Sampling Results
Chemours provided (and continues to provide) sampling results to NCDEQ and residents 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
Consent Order Progress Report For
Fourth Quarter 2021
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 or voucher card for bottled water). As of December 31, 2021, there are
2,696 residences receiving bottled water services.
Section 24 Drinking Water Compliance Plan
As discussed above, the off‐site replacement drinking water program continues. The Drinking Water
Compliance Plan is currently under review and some of the protocols are being revised based on
discussions with NCDEQ. The following revised procedures are currently implemented based on
approval by NCDEQ:
Point‐of‐Use (POU) Granular Activated Carbon (GAC) filtration systems for commercial
establishments that were eligible for RO systems, pursuant to NCDEQ’s approval letter dated
January 5, 2021.
Chemours connected six homes in Cumberland County to public water as part of a pilot program
and a report was submitted to NCDEQ on June 25, 2021 and approved by NCDEQ on September
22, 2021. The program is now expanding to include additional residences for public water
connection in the study area.
Starting in the second quarter of 2020, the GAC OM&M sampling has been revised to include
quarterly sampling in between the lead and lag carbon vessel and one annual raw water sample.
Chemours met with NCDEQ on October 5, 2021 via teleconference. The purpose of this meeting was to
discuss ongoing challenges with the private well sampling and replacement drinking water program and
a proposed path forward. Topics included:
Residents who continue to be non‐responsive to treatment system offers;
NCDEQ sampling of private wells; and
Chemours sampling and consensus on delineation of the private well testing program.
Section 26 Total Organic Fluorine
The Total Organic Fluorine Final Report was submitted on December 31, 2021.
Section 28 Reporting
Chemours submitted the Consent Order 3rd quarter 2021 progress report on October 29, 2021.
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/.