HomeMy WebLinkAbout2022.04.28_CCO.p.28_NCDEQ_Quarterly Progress ReportConsent Order Progress Report For
First Quarter 2022
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 January 1, 2022 through the end of the first quarter on March
31, 2022.1
CO Section Title Submitted Date
11 Characterization of PFAS In Process and
Non-Process Wastewater and Storm
Water Semi-Annual Report
03/31/2022
12 ‐ COA 1b Mass Loading Assessment – Fourth
Quarter 2021
03/31/2022
12 ‐ COA 2a Interim Seep Remediation Operation &
Maintenance Report #6
01/31/2022
12 ‐ COA 2a Interim Seep Remediation Operation &
Maintenance Report #7
03/31/2022
12 ‐ COA 3b 90 Percent Design Report 03/25/2022
28 Quarterly Progress Report 01/28/2022
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, July 1, 2021 through September 30, 2021 in the 2021 3rd quarter
report, and October 1, 2021 through December 31, 2021 in the 2021 4th quarter report.
Consent Order Progress Report For
First Quarter 2022
2022 First 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 328 376 18 49 27 35 833
Residences Exceeding GAC
Criteria (GenX >= 140 ng/L) 0 0 0 1 0 0 1
Residences Exceeding RO
Criteria (∑PFAS >= 70 ng/L) 18 35 4 10 2 0 69
Residences Exceeding RO
Criteria (PFAS >= 10 ng/L) 94 70 8 15 8 10 205
Residences Drinking Water Well
Detections (Results < 10 ng/L) 56 117 1 6 9 8 197
Residences Drinking Water Well
Non-Detections 41 50 3 16 7 7 124
Consent Order Progress Report For
First Quarter 2022
Replacement Drinking Water Actions
(Replacement drinking water actions from November 20182 ‐ March 31, 2022)
Fayetteville Counties Area Summary
Number of
Residences
on Bottled
Water
GAC Systems
Online
& Confirmation
Sample
Complete
Number of
Residences
w/ RO
Systems
Installed
Homes
Connected
to Public
Water by
Chemours
Total 2797 111 3214 86 Bottled Water
Residences
Eligible for
Bottled
Water
Eligible
Residences
Receiving
Bottled Water
Services
1Q
2022 306 322
Total 2937 2797
GAC
Residences
Eligible for
GAC
Residents
Declined GAC GAC to Install
Residences
Responded
to GAC Offer
(Interview
Conducted
or Offer
Declined)
1Q
2022 2 0 1 1
Total 271 7 125 123
GAC to
Install but
Resident
has not
Responded
to Offer
Number of GAC
Decommissioned
Confirmation
Sampling
Complete
GAC Offer
Letters Sent
to
Residences
Call Team
Interactions
w/ GAC
Residents
GAC
Residence
Response
Rate
1Q
2022
Not
Applicable 1 0 2 143
Not
Applicable
Total 104 8 108 271 4032 45% RO
Residences
Eligible for
RO
(including
shared well
homes)
Residences
Responded to
RO Offer
Residents
Declined RO
RO to Install
but Resident
has not
Responded
to Offer
RO Residence
Response
Rate
1Q
2022 419 565 10 166
Not
Applicable
Total 6135 4315 128 1645 70%
Residences
with RO
Installed
Residences
where RO
Systems to be
Installed
RO Offer
Letters Sent
to Residences
Call Team
Interactions
w/ RO
Residents
1Q
2022 342 419 419 3095
Total 3214 2547 6135 32663
2 The date the proposed Consent Order was lodged.
Consent Order Progress Report For
First Quarter 2022
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 January 1, 2022 through the
end of the first quarter of 2022 (March 31, 2022). 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 first quarter of 2022, one sampling event was conducted during January 16‐19, 2022 (the
January 2022 event). Samples were collected from 23 locations during the January 2022 event. Data
from the August 2021, September 2021, and December 2021 events were evaluated and compiled in
the semi‐annual report, submitted on March 31, 2022.
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 first quarter of 2022 included:
Consent Order Addendum Paragraph 1
On March 31, 2022, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear River
PFAS Mass Loading Assessment – Fourth Quarter 2021 Report pursuant to Consent Order Addendum
Paragraph 1(b). The report describes sampling activities and mass loading results for the Cape Fear
River and PFAS loading pathways from the fourth quarter of 2021. This submission was also pursuant to
quarterly reporting of mass loading sampling outlined in the Corrective Action Plan (Paragraph 16). In
Consent Order Progress Report For
First Quarter 2022
January 2022, Chemours conducted quarterly mass loading sampling required by Consent Order
Addendum Paragraph 1.
Consent Order Addendum Paragraph 2
During the first quarter of 2022, Chemours operated and maintained the four flow‐through cells, i.e.,
the interim remediation systems, at Seeps A‐D. On January 31, 2022, Chemours submitted the Interim
Seep Remediation Operation and Maintenance Report #6; and on March 31, 2022, Chemours
submitted the Interim Seep Remediation Operation and Maintenance Report #7. The two Operation
and Maintenance reports describe the operations and maintenance activities at the flow‐through cells
over the bimonthly reporting periods of November/December 2021 and January/February 2022,
respectively.
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 first quarter as designed. During the first quarter
of 2022 through March 28, 2022 (the last reading taken during the reporting period), the system
extracted 619,959 gallons of water for a total of 2,571,591 gallons since startup on November 30, 2020.
The wells have continued to operate as designed with only minor, routine shutdowns for freezing
weather, maintenance, or equipment issues.
On January 13, 2022, Chemours submitted a Groundwater Remedy and Treatment System Net Benefit
Assessment Memorandum. The memorandum described how the groundwater remedy will provide
long‐lasting benefits by reducing the Table 3+ PFAS mass loading to the Cape Fear River and also
provide mass loading reduction benefits during remedy initiation and after commissions.
On January 13, 2022, Chemours submitted a request to NCDEQ to abandon wells PIW‐9S, PIW‐9D, EW‐
2, OW‐6 which pose conflicts with the remedy construction. On February 1, 2022, NCDEQ approved the
request to abandon these wells. On March 8, 2022, Chemours submitted an additional request to
abandon wells P‐7, P‐8, MW‐31, MW‐32, and MW‐33. On March 17, 2022, NCDEQ approved the
request to abandon these additional five wells with requirements regarding sampling and
abandonment records.
On February 18, 2022, Chemours submitted to NCDEQ a Response to DEQ Draft NPDES Permit for
Chemours Company Fayetteville Works – Outfall 004.
On March 17, 2022, Chemours submitted responses to NCDEQ comments on the Quality Assurance
Plan for the barrier wall installation and the Performance Monitoring Plan (PMP) received on February
15, 2022 from NCDEQ. In addition, on March 25, 2022, Chemours submitted responses to NCDEQ
comments on the groundwater model received on February 15 and additional comments received
March 14, 2022. A teleconference was held with NCDEQ on March 14, 2022 to discuss the groundwater
model. The submitted responses on March 17 and 25, 2022 provided additional clarification on details
of the Quality Assurance Plan, PMP, and groundwater model.
On March 25, 2022, Chemours submitted the 90% Design report to NCDEQ in advance of the Consent
Order Addendum required date of March 31, 2022. This submission included a revised PMP and an
updated groundwater model report.
Consent Order Progress Report For
First Quarter 2022
Construction activity on the remedy continues to proceed. NCDEQ and Chemours conducted a Site visit
on February 11, 2022 to observe extraction well installation for the remedy. In the first quarter of 2022
Chemours installed 52 extraction wells. In addition, two retaining walls along the remedy have been
completed and barrier wall roadway grading continues.
Consent Order Addendum Paragraph 4
Consistent with the Stormwater Sampling Plan, Chemours conducted five sampling events in January
2022, three sampling events in February 2022, and two sampling events in March 2022 during the
stormwater treatment system operation for removal of PFAS compounds. The monthly monitoring
reports for January 2022 – March 2022 will be submitted in the second 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 first quarter of 2022.
On March 25, 2022, Chemours submitted Stormwater Treatment System Monthly Monitoring Reports
for the months of September 2021 through December 2021, as well as a Stormwater Capture and
Removal Efficiency Report for September 2021 (October through December did not have bypass flows).
Chemours also submitted to NCDEQ the Updated Stormwater Collection and Treatment System O&M
Plan and the Updated Stormwater Treatment System Sampling Plan.
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 has addressed the
comments and Chemours submitted the protocols to NCDEQ for final approval.
The 28‐day immunotoxicity study draft protocols were submitted to NCDEQ during the fourth quarter
of 2021 and are awaiting comments from NCDEQ. Chemours requested confirmation of the intended
guideline for the 90‐day study and received comments from NCDEQ in late December 2021. The
comments were reviewed and a response was sent by Chemours to NCDEQ in March 2022.
Section 16 Groundwater Remediation
On March 31, 2022, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear River
PFAS Mass Loading Assessment – Fourth 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, RO acceptance rates and
installations have maintained a steady pace. O&M activities for installed GAC systems continue
uninterrupted. Bottled water services continue uninterrupted for 2,797 homes. In September 2021,
Chemours entered into an agreement with Bladen County to fund public water system upgrades and
Consent Order Progress Report For
First Quarter 2022
connections associated with providing permanent replacement drinking water supplies under the
Consent Order, and Chemours proceeded with implementation of the agreement during the first
quarter of 2022.
Section 21 Private Well Testing
As of March 31, 2022, 13,833 residences have been identified within the current study area, of which
9,313 have been sampled and 3,329 additional residences have received at least one initial sample
offer letter. Results of sampling that occurred throughout the first quarter of 2022 (833 residences) are
presented at the beginning of this progress report. Current Step‐out and Infill distance intervals range
from 2.5 miles to 25.5 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
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 March 31, 2022, there are
2,797 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 pilot program is now expanding to include additional residences for public water
connections in the study area. Chemours has identified potential additional residences for public
water connections. Chemours is working with counties and water providers to facilitate the
public water connections where feasibility has been determined. One residence was connected
to public water in February 2022. Seventeen additional homes are slated for public water
connections in April/May 2022.
Consent Order Progress Report For
First Quarter 2022
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.
Section 28 Reporting
Chemours submitted the Consent Order 4th quarter 2021 progress report on January 28, 2022.
Sections 29 and 30 Public Information
Chemours has continued to post its Consent Order submissions at
https://www.chemours.com/en/about‐chemours/global‐reach/fayetteville‐works/compliance‐testing.
Consent Order Progress Report For
First Quarter 2022
Four Counties Sampling Program
On February 1, 2022, Chemours submitted a “Framework to Assess Table 3+ PFAS in New Hanover,
Brunswick, Columbus, and Pender Counties” (the “Assessment Framework”) and an “Interim Four
Counties Sampling and Drinking Water Plan (New Hanover, Brunswick, Columbus, and Pender
Counties)” (the “Interim Plan”) for the sampling of groundwater from private wells in the four counties
as requested by the well owners. Both documents were prepared by Chemours’s Consultant
Geosyntec Consultants of NC, PC.
Interim Sampling and Drinking Water Plan for Four Counties
On March 2 and March 28, 2022, Chemours received letters containing comments from NCDEQ on the
Interim Plan. Chemours prepared a response to NCDEQ comments and a revised Interim Plan, which
were transmitted to NCDEQ on April 1, 2022.
An information call line was activated by Chemours on February 15, 2022. This call line has been used
to answer questions about the activities covered in the Interim Plan and for residents to request
sampling of their private wells. Well owners/residents that request sampling via the call center are
screened against the eligibility criteria described in the Interim Plan. As of March 31, 2022, of the 77
requests received for sampling, 61 met the eligibility criteria and were sampled. Chemours is also
resampling certain locations previously sampled by NCDEQ. Of the 58 samples for which analytical
results were received, 54 showed no exceedances of Consent Order Attachment C criteria. Bottled
water has been provided to the two residents/owners that qualified. The two other results that
showed exceedances were resamples of wells that were sampled by NCDEQ and these locations are
already connected to a public water source.
Consent Order Progress Report For
First Quarter 2022
2022 First Quarter Residential Summary
Item
New
Hanover
County
Brunswick
County
Pender
County
Columbus
County Total
Total Number of Residences
Sampled 55 0 2 1 58
Residences Exceeding GAC
Criteria (GenX >= 140 ng/L) 0 0 0 0 0
Residences Exceeding RO
Criteria (∑PFAS >= 70 ng/L) 2 0 0 0 2
Residences Exceeding RO
Criteria (PFAS >= 10 ng/L) 2 0 0 0 2
Residences Drinking Water Well
Detections (Results < 10 ng/L) 8 0 0 0 8
Residences Drinking Water Well
Non-Detections 43 0 2 1 46
Replacement Drinking Water Actions
(Replacement drinking water actions from February 15, 20223 ‐ March 31, 2022)
Four Counties Area Summary
Residences
Requested
Sampling4
Residences
Sampled
Residences
Eligible for
Bottled
Water
Residences
Receiving
Bottled
Water
Voucher
Card
Total 66 58 2 2
3 The start date of the Chemours Call Line in the Four Counties Area.
4 Includes five NCDEQ resampled locations which are not all residences (i.e., country clubs, parks).