HomeMy WebLinkAbout2022.04.01_CCO.p.18_Chemours Revised Interim Four Counties Plan
Interim Four Counties Sampling and
Drinking Water Plan (New Hanover,
Brunswick, Columbus and Pender Counties)
Chemours Fayetteville Works
Prepared for
The Chemours Company FC, LLC 22828 NC Highway 87 Fayetteville, NC 28306
Prepared by
Geosyntec Consultants of NC, PC 2501 Blue Ridge Road, Suite 430 Raleigh, NC 27607
Project Number TR0795A
Version 1: February 1, 2022 Version 2: April 1, 2022
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works i April 2022
TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................... 2
1.1 Interim Plan Objectives ............................................................................................ 2
1.2 Progress Reports during the Interim Plan Period ...................................................... 3
1.3 Four Counties Sampling and Drinking Water Plan Workflow .................................. 3
2.0 PRIVATE WELL SAMPLING ................................................................................ 6
2.1 Step 1A – Representative Sampling ......................................................................... 6 2.1.1 Representative Sampling Approach ........................................................... 6
2.1.2 Call Center ................................................................................................ 8 2.1.3 Resampling of Private Wells in New Hanover ........................................... 8 2.1.4 Sampling Methods ..................................................................................... 8
2.1.5 Provision of Sampling Results and Interim Drinking Water Replacement .. 9
2.2 Step 1B - Compilation of Private Well and Other Supporting Information ............... 9
3.0 REPLACEMENT OF PRIVATE DRINKING SUPPLIES ..................................... 11
3.1 Interim Replacement Drinking Supplies ................................................................. 11 3.1.1 Bottled Water and Letter Delivery ........................................................... 11 3.1.2 Bottled Water Voucher Card .................................................................... 11
3.2 Permanent Replacement Drinking Supplies ............................................................ 11
4.0 SCHEDULE AND REPORTING .......................................................................... 12
5.0 REFERENCES ...................................................................................................... 13
LIST OF TABLES
Table 1 Attachment C PFAS Compounds
Table 2 Summary of Data Needs
LIST OF FIGURES
Figure 1 Four Counties Sampling and Drinking Water Plan Workflow Diagram
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works ii April 2022
LIST OF APPENDICES
Appendix A Private Drinking Water Well Sampling Procedures and Community Outreach
Letter
Appendix B County Maps and List of Additional Analytes
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 1 April 2022
ACRONYMS AND ABBREVIATIONS
HFPO-DA hexafluoropropylene oxide dimer acid
NCDEQ North Carolina Department of Environmental Quality
ng/L nanograms per liter
PFAS per- and polyfluoroalkyl substances
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 2 April 2022
1.0 INTRODUCTION
This Interim Four Counties Sampling and Drinking Water Plan has been prepared by Geosyntec
Consultants of NC, P.C. (Geosyntec) for The Chemours Company FC, LLC (Chemours). This
document presents an interim plan for sampling private wells and implementing mitigation
measures in New Hanover, Brunswick, Columbus, and Pender Counties (the counties) of North
Carolina.
In a letter from the North Carolina Department of Environmental Quality (NCDEQ) on 3
November 2021 (NCDEQ, 2021), NCDEQ requested that Chemours submit an updated Drinking
Water Compliance Plan pursuant to Paragraph 24 of the Consent Order (CO) between Chemours,
NCDEQ, and Cape Fear River Watch, which was entered by the Court on 25 February 2019. In
this letter, NCDEQ also requested that the updated Drinking Water Compliance Plan include a
sampling plan for drinking water wells in the counties and identify the methods to provide
replacement drinking water to qualifying parties. To address these requests from NCDEQ, this
revised Interim Sampling and Drinking Water Plan has been prepared specifically for the four
counties.
NCDEQ also posted to their website1 on 3 November 2021 per- and polyfluoroalkyl substances
(PFAS) data from groundwater samples collected from NCDEQ and Cape Fear Public Utility
Authority public supply wells between 2019 and 2021. These data were supplemented with
additional PFAS data from groundwater samples collected from different wells, including private,
public supply and emergency wells, which were provided to Chemours on behalf of NCDEQ via
email on 5 December 2021.
The Drinking Water Compliance Plan for the area surrounding the Fayetteville Works Facility
(Facility; Parsons, 2019) was developed to identify private wells with CO Attachment C PFAS
(Attachment C PFAS; Table 1) from Facility air emissions and methods to provide a replacement
drinking water supply. As such, not all elements of that Drinking Water Compliance Plan,
including the sampling design, are relevant to the private wells in the four specified counties. As
a result, a Sampling and Drinking Water Plan specific to the four counties is needed to fulfill the
request from NCDEQ. Further, there is currently very limited PFAS and other information
concerning private wells in the four counties.
1.1 Interim Plan Objectives
Over the 2,900 square miles of the four counties, little is known about the spatial distribution of
Attachment C PFAS. Actively collecting data about the spatial distribution of Attachment C PFAS
across the four counties is essential to develop a data-driven, systematic Four Counties Sampling
and Drinking Water Plan. Therefore, this Interim Plan has been developed to fulfill the request
from NCDEQ and actively collect these needed data. The objectives of this Interim Plan are to:
1 https://deq.nc.gov/dwr-gwr-lcfr-pfas-data-2019-2021
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 3 April 2022
1. Initiate the delineation of Attachment C PFAS contamination in the four counties by
sampling a representative group of private wells,
2. Identify methods to provide replacement drinking water to identified qualifying private
wells (properties with private wells as the primary source of drinking water will be
considered, including households, businesses, schools and public buildings), and
3. Use representative sampling to characterize the distribution of exceedances of
Attachment C CO criteria in private wells to allow for the development of a data-driven
systematic program as described below.
This Interim Plan will be superseded with an Updated Four Counties Sampling and Drinking Water
Plan. Based on the data and information gathered during the Interim Plan, the Updated Four
Counties Sampling and Drinking Water Plan will include a comprehensive sampling design to
complete, if necessary, the delineation of contamination by Attachment C CO PFAS in the four
counties, and to sample private wells within the delineated areas. The Updated Plan may also
propose updates to the process by which permanent replacement drinking water supplies are
provided.
1.2 Progress Reports during the Interim Plan Period
The sampling approaches described in this document have been developed based on presently
available data and current understanding of the PFAS distribution in each of the counties. As more
data become available in each of the counties, modifications may need to be made to this Interim
Plan.
Data and results from the Interim Plan sampling program will be provided to NCDEQ in a progress
report on a quarterly basis, where the first quarter will start on April 1, 2022. The progress report
for the previous quarter will be provided within ninety (90) days of the end of the previous quarter.
It is anticipated that the sampling will be conducted for at least twelve (12) months.
1.3 Four Counties Sampling and Drinking Water Plan Workflow
To fulfill the 3 November 2021 request from NCDEQ, while also gathering information for each
of the counties, a workflow has been developed as shown in Figure 1.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 4 April 2022
Figure 1 Interim Four Counties Sampling and Drinking Water Plan Workflow Diagram
The workflow includes three steps, where Steps 1A and 1B will occur concurrently and represent
the private well sampling and information gathering that will occur under this Interim Plan. It is
anticipated that sampling will be conducted for at least twelve (12) months.
Step 1A (Representative Sampling) includes sending a letter that requests information from and
offers sampling to addresses located within eligible areas across the four counties (Section 2.1.1).
Private well sampling will be scheduled for those who respond to the letter indicating that their
private well is the primary source of drinking water on their property and their consent to having
their well tested. Step 1A also includes sampling of eligible private wells received through the
call line, and resampling of the 11 private wells sampled by NCDEQ (Sections 2.1 and 3.0). Step
1B (Data gathering) includes compilation of private well and other supporting information to
address the current limitations in knowledge of the distribution of PFAS in the four counties
(Section 2.2).
Step 2 (Data evaluation) will include a summary of the findings from sampling conducted under
the Interim Plan. Finally, Step 3 will be the preparation of an Updated Four Counties Sampling
and Drinking Water Plan.
For the private wells sampled during this Interim Sampling and Drinking Water Plan, bottled water
and a voucher card will be offered as an interim drinking water replacement if Attachment C PFAS
concentrations exceed the criteria outlined in Paragraphs 19 and 20 of the CO2. Qualified residents
will be offered permanent replacement drinking water (e.g., public water connection, water
filtration system, etc.) within the timeframe set forth in the CO (see Section 3.2).
2 Any single Attachment C PFAS compound is greater than or equal to 10 nanograms per liter (ng/L), the sum of the Attachment C PFAS compounds is greater than or equal to 70 ng/L, or hexafluoropropylene oxide dimer acid (HFPO-DA) is greater than equal to 140 ng/L.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 5 April 2022
Table 1 Attachment C PFAS Compounds
Common Name Chemical Name CASRN Chemical Formula
HFPO-DA1 Hexafluoropropylene oxide dimer acid 13252-13-6 C6HF11O3
PEPA Perfluoro-2-ethoxypropionic acid 267239-61-2 C5HF9O3
PFECA-G Perfluoro-4-isopropoxybutanoic acid 801212-59-9 C12H9F9O3S
PFMOAA Perfluoro-2-methoxyacetic acid 674-13-5 C3HF5O3
PFO2HxA Perfluoro-3,5-dioxahexanoic acid 39492-88-1 C4HF7O4
PFO3OA Perfluoro-3,5,7-trioxaoctanoic acid 39492-89-2 C5HF9O5
PFO4DA Perfluoro-3,5,7,9-tetraoxadecanoic acid 39492-90-5 C6HF11O6
PMPA Perfluoro-2-methoxypropionic acid 13140-29-9 C4HF7O3
PFO5DA Perfluoro-3,5,7,9,11-pentaoxadodecanoic acid 39492-91-6 C7HF13O7
PS Acid Ethanesulfonic acid, 2-[1-[difluoro[(1,2,2-trifluoroethenyl)oxy]methyl]-1,2,2,2-
tetrafluoroethoxy]-1,1,2,2-tetrafluoro-
29311-67-9 C7HF13O5S
Hydro-PS Acid
Ethanesulfonic acid, 2-[1-[difluoro(1,2,2,2-
tetrafluoroethoxy)methyl]-1,2,2,2-tetrafluoroethoxy]-1,1,2,2-tetrafluoro- 749836-20-2 C7H2F14O5S
PFHpA1 Perfluoroheptanoic acid 375-85-9 C7HF13O2
Notes:
1 HFPO-DA and PFHpA can be analyzed under methods Table 3+ Standard Operating Procedure (SOP) and Environmental Protection Agency (EPA) Method 537 Mod.
CASRN - Chemical Abstract Service Registry Number
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 6 April 2022
2.0 PRIVATE WELL SAMPLING
2.1 Step 1A – Representative Sampling
Representative sampling will be conducted by offering sampling of eligible private wells in the
four counties as described below. This sampling, Step 1A will be completed in conjunction with
the data gathering stage (Step 1B). The objectives of the representative sampling step are three-
fold. First sampling will be provided to eligible addresses which call in requesting sampling.
Second sampling will be conducted in areas where attachment C PFAS are potentially present in
private wells based on prior NCDEQ sampling efforts or information from hypotheses about the
source of these PFAS. Third, representative sampling will be conducted across the four counties
to better characterize the spatial extent and distribution of Attachment C PFAS to inform
development of the Updated Plan.
2.1.1 Representative Sampling Approach
Representative sampling efforts will include testing eligible private wells identified through:
1. Extensive community outreach across the four counties (Appendix A);
2. Proximity to existing and future CO exceedances3 (i.e., within a quarter mile of a private
well where Attachment C PFAS concentrations exceed CO criteria);
3. Requests received via the call line; and
4. Resampling of the 11 private wells sampled by NCDEQ.
As part of the community outreach, certain potentially eligible addresses will be contacted by mail
to request information related to public water connection and to offer sampling. This list of
potentially eligible addresses will include properties with private wells as the primary source of
drinking water such as households, businesses, schools and public buildings.
The following criteria will be used to determine eligibility addresses (referred to herein as
sampling eligibility criteria; see Appendix B that contains a map for each county) that will be
contacted by Chemours:
• The private well is the primary source of drinking water on the property, and
3 Any single Attachment C PFAS compound is greater than or equal to 10 nanograms per liter (ng/L), the sum of the Attachment C PFAS compounds is greater than or equal to 70 ng/L, or hexafluoropropylene oxide dimer acid (HFPO-DA) is greater than equal to 140 ng/L.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 7 April 2022
• The private well is located within the 100-year floodplain associated with Cape Fear
River4,5, or
• The private well is within a quarter mile of public water service lines6 or sanitary sewer
networks7, including areas where PFAS may have seeped into surrounding aquifers, such
as areas of leaking utility pipes, or direct injection or application of Cape Fear River water.
Information obtained to date show that these areas are within the public water distribution
areas and captured by this criterion; or
• The private well is within a quarter-mile radius of known Attachment C PFAS
concentrations in private and non-private wells exceeding CO criteria.
If additional areas outside of the present areas of eligibility, i.e., areas of the counties that are
defined by the sampling eligibility criteria, are identified during the data gathering step (Step 1B
of this Interim Plan and the Assessment Framework), then the eligibility criteria will be revised
to include these areas.
Mailed letters will request well owners/residents to provide a response on whether they are
connected to public water (if the status of public water connection is unknown) and if their primary
source of drinking water is a private well (Appendix A). The letter will also offer sampling of their
private well. Well owners/residents can then respond by mail (prepaid return envelope) or by
contacting the call line (Section 2.1.3). Once the well owners/residents provide the requested
information, and indicate their consent to sampling their wells, Chemours will contact the well
owners/residents that use their private well as the primary source of drinking water to schedule
sampling. Letters will not be sent to owners/residents that are known to be connected to public
water.
If after 90 days, the well owner/resident has not contacted Chemours to provide a response, a
second letter will be mailed. Letter deliveries, messages and conversations will be documented in
electronic logs and uploaded to the project database.
4 As described in the Soil and Groundwater Assessment Framework (Geosyntec, 2022), Cape Fear River water withdrawals and usage may potentially be responsible for Table 3+ PFAS detected in samples collected by NCDEQ. One hypothesis identified in the framework is Table 3+ PFAS originating from aquifer recharge by Cape Fear River including recharge in Floodplain areas.
5 In addition to the extent of the 100-year floodplain associated with Cape Fear River (provided by the Federal Emergency Management Agency; FEMA), limits of saltwater marshes in the areas where Black River and Northeast Cape Fear River meet Cape Fear were included to account for the possibility of tidal backwash of Cape Fear River into these rivers. This criterion also includes the last half mile floodplain of each tributary before it joins the Cape Fear River.
6 Presently available data for public water service lines are incomplete across the four counties. Where public water service lines are not currently available, eligibility will be determined based on known public service areas. The quarter mile buffer will be placed around the public water service lines, as additional data become available.
7 As described in the Soil and Groundwater Assessment Framework (Geosyntec, 2022), one hypothesis being evaluated is Table 3+ PFAS originating from leaks in water distribution and sanitary sewer lines. If during the assessment, this hypothesis is refined or not supported, then this criterion will be changed accordingly.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 8 April 2022
Samples collected will be analyzed for Attachment C PFAS compounds (Table 1) and may also
be analyzed for other parameters (e.g., other PFAS, other contaminants, other water quality
parameters, etc.) such as those listed in Tables B.1 and B.2 (Appendix B). Samples will be
analyzed by a third party laboratory approved by NCDEQ.
Based on the analytical results from the sampling described above, additional private wells will be
sampled within a quarter mile radius of Attachment C PFAS concentrations exceeding CO criteria.
The results of the private well sampling will be evaluated on a quarterly basis, and adjustments
will be made to the sampling approach, as necessary. Sampling results and updates made to the
sampling approach (if any) will be documented in quarterly progress reports that will be
transmitted to NCDEQ (Sections 1.2 and 4.0). Specifically, the spatial distribution of the private
wells and PFAS results collected during the representative sampling will be reviewed after six (6)
months to assess the need for further delineation. Updates to the sampling approach, if needed,
will be included in the quarterly progress report transmitted to NCDEQ.
2.1.2 Call Center
An information call line was activated by Chemours on 15 February 2022. This call line has been
used to answer questions about the activities covered in this plan and for residents to request
sampling of their private wells. Residents can call (910) 678-1100 at any time to leave a message
requesting additional well sampling information or to leave questions about any step in the interim
drinking water replacement process. Messages to the call line are monitored during regular
business hours (Monday through Friday, 9am to 5pm). Calls requiring follow-up are usually
returned within 24 to 48 hours starting on the next business day.
Well owners/residents that request sampling via the call center will be screened against the
eligibility criteria described in Section 2.1.1. If the private well meets the criteria, Chemours will
contact the resident/owner and schedule them for sampling.
2.1.3 Resampling of Private Wells in New Hanover
Chemours will resample the 11 private wells sampled by NCDEQ to confirm the Attachment C
PFAS analytical results. Based on the analytical results, if an owner/resident qualifies for interim
replacement drinking water, then bottled water and a voucher card will be provided (see Section
3.0).
2.1.4 Sampling Methods
Private well sampling will be completed by Chemours subcontractor Parsons of NC (Parsons)
using procedures outlined in Appendix B. Data collected during a sampling team visit will be
uploaded to the project database. Well owners/residents, regardless of eligibility, will be logged
throughout the duration of the sampling program.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 9 April 2022
2.1.5 Provision of Sampling Results and Interim Drinking Water Replacement
On an ongoing basis and within seven (7) days of receipt of final laboratory results, Chemours will
provide new groundwater sampling results to NCDEQ, with samples identified by both address
and sample identification code. In addition, within seven (7) days of receipt of final laboratory
results, Chemours will also provide the results in the form of a certified summary certificate to the
party who had their well tested. Results may also be provided to the individual counties or other
state and local government agencies.
Correspondence will be sent to each well owner/resident providing them with their sampling
results for Attachment C PFAS compounds. If analyzed for additional compounds (Appendix B),
a separate letter will be sent which will include the laboratory analytical report. If the well
owner/resident has any questions regarding results of the analytical results, they will be told that
they can contact their local health department or NCDEQ. Parsons may also attempt to hand deliver
returned letters. For parties who Chemours knows to be represented by legal counsel,
communications will be made through counsel.
Based on the analytical results, bottled water and a voucher card will be offered to qualifying well
owners/residents as an interim replacement to private drinking water supply in accordance with
procedures in Section 3.0. The process by which the appropriate permanent replacement drinking
water delivery means will be identified and provided is discussed in Section 3.0.
2.2 Step 1B - Compilation of Private Well and Other Supporting
Information
During the Interim Plan and as needed afterwards, Chemours will continue to advance data
gathering. Data gathering includes two types of requests (Table 2). The first request type is for
information from NCDEQ, the counties and utility providers about which addresses in the four
counties are supplied by public water. These data are important to infer which addresses in the
four counties have private wells, thus making overall efforts of this Interim Plan and upcoming
Updated Plan more efficient and targeted.
The second type of data request is related to understanding the presence and distribution of PFAS
in the four counties. These requests were described in the Framework to Assess Table 3+ PFAS in
New Hanover, Brunswick, Columbus and Pender Counties (Geosyntec, 2022). These requests
include such items as locations of water main leaks, sanitary sewer network locations and known
users of Cape Fear River water. These knowledge from these requests is important to help prepare
an Updated Four Counties Sampling and Drinking Water Plan that uses a data-driven approach
informed by knowledge of how and where Attachment C PFAS may have been introduced to
groundwater in the four counties.
Chemours appreciates NCDEQ’s support of data gathering activities and may request additional
help facilitating teleconferences and data sharing requests with certain public entities in the four
counties.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 10 April 2022
Table 2 Summary of Data Needs by Request Type
Data Needs Request Type
Residential parcels, tax detail data, and building footprint in digital form 1
A consolidated list containing private well location information (such as eastings, northings, address and/or tax parcels), well owner, elevations, screen interval depths, and hydrogeological data (including, without limitation, start and end depth of each hydrogeological unit)
1
Digital computerized map of potable water distribution networks 1
Database of addresses using public water, i.e., not using private well as the primary source of drinking water 1
Records regarding the numbers, locations, registrations, usages, and well service and operation histories of private and public drinking water supply wells 1
Any data (and relevant information, including but not limited to laboratory electronic data deliverables and sample collection information, etc.) indicating the presence of PFAS in water sources
1
Data about water distribution system leaks since 1979 (including known water mains with leaks, and leak and repair locations)
2
Information since 1979, on a per year basis, of the proportion of Cape Fear River water versus groundwater or other water sources used in each distribution system
2
Locations where surface water from the Cape Fear River was injected into subsurface aquifers
2
List of parties permitted to withdraw Cape Fear River water since 1979 (NCDEQ) 2
Records of customers of Lower Cape Fear Water & Sewer Authority 2
Identification of golf courses, cemeteries and parks using Cape Fear River water for irrigation 2
Identification of farmland practices and locations using Cape Fear River water for irrigation 2
Records of Aquifer Storage and Recovery program (volumes injected, dates operational, etc.) 2
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 11 April 2022
3.0 REPLACEMENT OF PRIVATE DRINKING SUPPLIES
Bottled water and a voucher card will be offered as an interim drinking water replacement if the
Attachment C PFAS concentrations in the private wells sampled during the Interim Sampling and
Drinking Water Plan exceed the criteria outlined in Paragraphs 19 and 20 of the CO8.
3.1 Interim Replacement Drinking Supplies
3.1.1 Bottled Water and Letter Delivery
Upon notification that a resident qualifies for replacement drinking water, Chemours
representatives (Parsons) will provide initial replacement drinking water within three (3) days by
visiting the property and delivering up to one (1) month’s supply of bottled water along with a
letter explaining the path forward for obtaining interim bottled water. If the team is not able to
deliver the initial replacement drinking water, a scheduler will attempt to call the resident and
make an appointment for the team to return and make the delivery.
Water and letter delivery, as well as all delivery attempts, messages, and conversations, will be
documented in the project database.
3.1.2 Bottled Water Voucher Card
After bottled water and letter delivery, the well owner/resident will receive a bottled water voucher
card for purchasing drinking water. The voucher card will be preloaded with $225 for three (3)
months of drinking water, which equates to $75 per month. The voucher card will continue to be
loaded for the duration of this Interim Plan, until permanent drinking water supply is provided.
This voucher card is only to be used for purchasing bottled water. Well owners/residents will
receive detailed voucher card instructions, customer service contact information, and the
Chemours Call Line phone number, along with the voucher card.
3.2 Permanent Replacement Drinking Supplies
Qualified owners/residents will be offered permanent replacement drinking water within the
timeframe set forth in the Consent Order. This offer may include connection to public water where
Chemours determines that is appropriate. For addresses where Chemours does not offer, or the
owner/resident does not accept, connections to public water, Chemours will offer water filtration
systems consistent with CO paragraph 20. Chemours may propose updates to this process in the
Updated Plan.
8 Any single Attachment C PFAS compound is greater than or equal to 10 nanograms per liter (ng/L), the sum of the Attachment C PFAS compounds is greater than or equal to 70 ng/L, or hexafluoropropylene oxide dimer acid (HFPO-DA) is greater than equal to 140 ng/L.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 12 April 2022
4.0 SCHEDULE AND REPORTING
Sample results will be provided to each resident and to NCDEQ when final data are available.
Information is provided to the resident via mail, and to the property owner when Chemours is
made aware that the resident is not the owner. Residents who are not the property owner will
receive notification indicating eligibility and will be offered interim replacement drinking water
(if applicable).
Chemours will also provide notification to NCDEQ (as requested) via email of each resident that
declines interim replacement drinking water within seven (7) days or as soon as practicable
thereafter of the resident declining. The notification will include the names, addresses, and contact
information for all the residents who have declined.
Quarterly reports documenting the implementation of the Interim Four Counties Sampling and
Drinking Water Plan will be submitted to NCDEQ. These quarterly reports will include summaries
of the sampling activities completed and the residents who are eligible for interim replacement
drinking water. These quarterly reports may be submitted separately to NCDEQ or will be included
as a separate section in the current quarterly report that is required under Paragraph 28 of the CO.
As mentioned in Section 1.2, the results of the private well sampling conducted under this Interim
Plan will be evaluated on a quarterly basis, and adjustments will be made to the sampling approach,
as necessary. The data and results will be summarized in quarterly progress reports, separate from
the quarterly report required under CO Paragraph 28, that will be provided to NCDEQ, where
findings for the previous quarter are provided within ninety (90) days of the end of the previous
quarter.
No later than 120 days after the end of the last quarter of sampling (tentatively one year from April
1, 2022), the Updated Four Counties Drinking Water and Sampling Plan will be prepared and
submitted based on the findings from the Interim Plan.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works 13 April 2022
5.0 REFERENCES
Geosyntec Consultants of NC, P.C. 2021a. Response to NCDEQ Comments on Consent Order
Paragraph 18 On and Offsite Assessment Report. June 14, 2021.
Geosyntec Consultants of NC, P.C. 2022. Framework to Assess Table 3+ PFAS in New Hanover,
Brunswick, Columbus and Pender Counties: Chemours Fayetteville Works. DRAFT.
February 1, 2022.
NCDEQ. 2021. “Re: Notice Regarding Chemours’ Obligations Under Consent Order and 15A
NCAC 02L .0106 – Offsite Groundwater Assessment and Provision of Replacement Drinking
Water Supplies.” North Carolina Department of Environmental Quality, Assistant Secretary
for the Environment. November.
Parsons. 2019. Drinking Water Compliance Plan: Chemours Fayetteville Works. April.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works
Appendix A
Private Drinking Water Well Sampling
Procedures and Community Outreach Letter
TR0795A – Interim Four Counties Sampling and Drinking Water Plan 1
APPENDIX A
PRIVATE DRINKING WATER WELL SAMPLING PROCEDURES
The purpose of this appendix is to describe the general sampling procedures to be used for private
well sampling as outlined in the Interim Drinking Compliance Plan.
Sampling Notification and Documentation
To conduct the sampling, Chemours subcontractor representatives (Parsons of NC) will go to the
identified residence, knock on the door, and deliver a notification letter from Chemours. The
notification letter (i) describes the private well sampling program; (ii) requests the resident’s
participation if applicable; and (iii) includes a phone number that the resident can call to request
information about the program and/or to schedule sampling of their private well. Notifications and
responses to notifications (e.g., accept or decline) will be documented on electronic field forms.
If the resident is at home and accepts the offer to have their private well sampled, then the resident
can choose to either have the sample collected at that time or reschedule sampling for a later time.
If the resident declines the offer of sampling, then the decline will be noted in the electronic field
form.
If no one is home, the sampling team will leave the notification letter in a prominent location and
the notification will be noted in the electronic field form.
For residents that either have not called to request sampling or whose residence was inaccessible,
Chemours subcontractor representatives will attempt to make contact again via a mailed letter sent
after the initial visit. The mailed letter will again offer sampling of private wells. If needed, the
project team may also make a return visit to the residence to deliver another copy of the notification
letter. If no communication is received from the resident after the letter is mailed, follow-up letters
will be sent each quarter for the next three quarters (a total of 4 letters will be mailed to the
resident).
Chemours subcontractor representatives will maintain a database that includes addresses, the dates
and status of attempts to contact each resident, resident’s contact information (name, mailing
address, phone number), sampling completed, and any declines of the offer to sample.
Sample Collection Methodology
The procedure for sampling private wells is as follows:
1. Record available information about the resident (name, contact number, etc.), the
property owner, and the well (well age, depth, construction history, presence/location
of any filters or other systems, etc.).
2. Don a new pair of powderless, disposable nitrile (or similar) gloves for each sample
being collected.
3. Find the spigot closest to the well head.
Appendix A
Private Drinking Water Well Sampling Procedures
TR0795A – Interim Four Counties Sampling and Drinking Water Plan 2
4. Turn on water at the selected spigot and purge the well until the pump turns on (usually
approximately 5 to 10 minutes).
5. Hold the high-density polypropylene sampling bottle by the body. Do not touch or
handle the bottle by the neck and mouth. Remove the bottle cap and do not set it down
at any point, place the bottle under the spigot, and fill completely. Do not allow the
neck or the mouth of the bottle to touch the spigot. Do not use a secondary container
to fill the bottle.
6. Recap the sample bottle and secure cap completely.
7. Affix a pre-printed sample label to the bottle (unless already affixed by the laboratory).
If the label is not pre-printed, fill out relevant sample information on the label.
8. Place the sample in a cooler of wet ice or in cold storage for future shipping.
9. Record the sample name, date, and time in the electronic field form.
10. Complete the chain of custody form(s), secure the cooler, and ship the samples to the
analytical laboratory.
11. Information related to collection of each private well sample will be recorded on an
electronic data collection form. Drinking water will be sampled directly from the well
head (or as close as possible) at private wells. To ensure against cross-contamination
between drinking water sampling locations, the sampler collecting the samples will
wear clean, disposable latex and/or nitrile gloves and limit his/her contact with the
samples. Sample bottles and containers appropriate for PFAS analysis will be prepared
by the contracted laboratory and will be sealed to ensure cleanliness. Sample bottles
will not be cleaned or reused in the field.
Preservation and Handling of Samples
Each containerized sample will be labeled and placed as soon as possible into an insulated sample
cooler, which will serve as a shipping container. Wet ice will be placed in the sample containers
within heavy-duty plastic bags. Samples will be maintained at a cool temperature (optimum 4°C
2°C) from the time of collection until the coolers arrive at the laboratory (if required). Plastic
“bubble wrap” and/or polystyrene foam may also be used to protect the samples during shipping.
Prior to shipment of the samples to the laboratory, a chain of custody form will be completed by
the sample team. Sample locations, sample identification numbers, description of samples, number
of samples collected, and specific laboratory analyses to be run on each sample will be recorded
on the chain of custody form.
Appendix A
Private Drinking Water Well Sampling Procedures
TR0795A – Interim Four Counties Sampling and Drinking Water Plan 3
Quality Assurance/Quality Control
Associated quality control samples as required by the laboratory/analytical method will be
collected and analyzed throughout the duration of the project. These may include field duplicates,
matrix spikes/duplicates, and field blanks.
The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306
19_4C_ResidenceWellInfoLetter
«ResID».«LetterTrackingID».«BatchID»
«TodaysDate»
«RecipientName»
«RecipientAddressStreet»
«RecipientAddressCity», «RecipientAddressState» «RecipientAddressZip»
RE: Residential Drinking Water Well Information Request
Dear Owner/Resident/Tenant:
Chemours has begun a drinking well testing program in New Hanover, Brunswick, Columbus and Pender
counties. The testing is being performed per the Interim Four Counties Sampling and Drinking Water Plan
(Plan). The Plan was submitted to North Carolina Department of Environmental Quality (NCDEQ;
https://deq.nc.gov/) on February 1, 2022.
The purpose of this letter is to request information about the source of your drinking water. Chemours is
in the process of identifying private drinking water wells that may qualify for testing. The water will be
tested for the 12 per- and polyfluoroalkyl substances (PFAS) compounds listed in the Consent Order
(CO).1 If you are using a private well for drinking water purposes, Chemours will call you to schedule
sampling. For more information, please check the Fayetteville Works website at:
https://www.chemours.com/en/about-chemours/global-reach/fayetteville-works.
Sincerely,
Dawn M. Hughes, Plant Manager
Chemours – Fayetteville Works
Please complete the form below and return in the envelope provided or call (910) 678-1100 and leave a
message. A team member will call you back within three business days.
Name: «RecipName2»
If incorrect, add correct name here: ______________________________________
Address: «ResidentAddressStreet»
«ResCityStateZip»
If incorrect, add correct address here: ____________________________________
I own this residence: Yes ☐ No ☐ I live at this residence: Yes ☐ No ☐
This home is connected to public water: Yes ☐ No ☐
Primary source of drinking water is a private well: Yes ☐ No ☐
Phone: ________________________ Can we text this number: Yes ☐ No ☐
1 Chemours entered into a Consent Order with NCDEQ and Cape Fear River Watch. The Superior Court for Bladen
County approved Consent Order on February 25, 2019.
TR0795A – Interim Four Counties Sampling and Drinking Water Plan, Chemours Fayetteville Works
Appendix B
County Maps and List of Additional Analytes
Brunswick County
Chemours Fayetteville WorksNorth Carolina
Figure
B.1Raleigh
Path: \\guelph-01\data\PRJ\Projects\TR0795\Database and GIS\Four Counties Programs\Private Well Program\GIS\NC Eligible Areas By County.mxd Last Revised: 4/1/2022 Author: NBarNahoumApril 2022
Projection: NAD83 North Carolina ftUS; Units in Foot US
Notes:1. In addition to the extent of the 100-year floodplain associated with Cape Fear River (provided by the Federal Emergency Management Agency; FEMA), limits of saltwater marshes in the areas where Black River and Northeast Cape Fear River meet Cape Fear were included to account for the possibility of tidal backwash of Cape Fear River into these rivers. This criterion also includes the last half mile floodplain of each tributary before it joins the Cape Fear River.2. Public Water Service Area was downloaded from The Drinking Water Resilience Interactive Project (DRIP) site (http://drip.unctv.org/maps/maps-051716/).3. County Boundaries was downloaded from OneMap site (https://www.nconemap.gov).4. The outline of the River shown on this figure is approximate (River outline basedon compilation of open data sources from ArcGIS online service and North Carolina Department of Environmental Quality Online GIS - Major Hydro shapefile).5. Basemap source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community.
BRUNSWICK
COLUMBUS
NEW HANOVER
PENDER
BLADEN Legend
Cape Fear River
County Boundary
Surrounding North Carolina County
100-Year Floodplain Associated with Cape Fear River1
Brunswick County Public Water Service
NWWTP Service
211 WTP Service
³
4 0 42 Miles
Columbus County
Chemours Fayetteville WorksNorth Carolina
Figure
B.2Raleigh
Path: \\guelph-01\data\PRJ\Projects\TR0795\Database and GIS\Four Counties Programs\Private Well Program\GIS\NC Eligible Areas By County.mxd Last Revised: 4/1/2022 Author: NBarNahoumApril 2022
Projection: NAD83 North Carolina ftUS; Units in Foot US
Notes:1. In addition to the extent of the 100-year floodplain associated with Cape Fear River (provided by the Federal Emergency Management Agency; FEMA), limits of saltwater marshes in the areas where Black River and Northeast Cape Fear River meet Cape Fear were included to account for the possibility of tidal backwash of Cape Fear River into these rivers. This criterion also includes the last half mile floodplain of each tributary before it joins the Cape Fear River.2. Public Water Service Area was downloaded from The Drinking Water Resilience Interactive Project (DRIP) site (http://drip.unctv.org/maps/maps-051716/).3. County Boundaries was downloaded from OneMap site (https://www.nconemap.gov).4. The outline of the River shown on this figure is approximate (River outline basedon compilation of open data sources from ArcGIS online service and North Carolina Department of Environmental Quality Online GIS - Major Hydro shapefile).5. Basemap source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community.
COLUMBUS
BLADEN
BRUNSWICK
ROBESON
PENDER
SAMPSON Legend
Cape Fear River
County Boundary
Surrounding North Carolina County
100-Year Floodplain Associated with Cape Fear River
Public Water Service
Columbus County WD I
Columbus County WD II
Columbus County WD III
Riegelwood Sanitary District
Tabor City
Town Of Bolton
Town of Brunswick
Town of Cerro Gordo
Town of Chadbourn
Town of Fair Bluff
Town of Lake Waccamaw
Town of Whiteville
³
4 0 42 Miles
New Hanover County
Chemours Fayetteville WorksNorth Carolina
Figure
B.3Raleigh
Path: \\guelph-01\data\PRJ\Projects\TR0795\Database and GIS\Four Counties Programs\Private Well Program\GIS\NC Eligible Areas By County.mxd Last Revised: 4/1/2022 Author: NBarNahoumApril 2022
Projection: NAD83 North Carolina ftUS; Units in Foot US
Notes:1. Any single Attachment C PFAS compound is greater than or equal to10 nanograms per liter (ng/L), the sum of the Attachment C PFAS compounds is greater than or equal to 70 ng/L, or hexafluoropropylene oxide dimer acid (HFPO-DA) is greater than equal to 140 ng/L.2. In addition to the extent of the 100-year floodplain associated with Cape Fear River (provided by the Federal Emergency Management Agency; FEMA), limits of saltwater marshes in the areas where Black River and Northeast Cape Fear River meet Cape Fear were included to account for the possibility of tidal backwash of Cape Fear River into these rivers. This criterion also includes the last half mile floodplain of each tributary before it joins the Cape Fear River.3. Public and Private well data provided by The North Carolina Department of Environmental Quality (NCDEQ) on November and December 2021.4. Public Water Service Areas for the Towns of Carolina Beach, Kure Beach, and Wrightsville Beach was downloaded from The Drinking Water Resilience Interactive Project (DRIP) site (http://drip.unctv.org/maps/maps-051716/).5. Water service areas for the Monterey Heights Groundwater, Sweeney Treatment Plant, and Richardson Nano Filtration from Cape Fear Public Utility Authority (CFPUA) site was downloaded from ArcGIS Online Feature service(https://services.arcgis.com/UfH3YtFuVFnIN4Zz/ArcGIS/rest/services/Water ServiceArea/FeatureServer/0).6. Cape Master Water System is based on North Carolina Water Quality Report (https://www.ncwaterquality.com/media/The-Cape-2021-Flushing-Master-Maps.pdf).7. County Boundaries was downloaded from OneMap site (https://www.nconemap.gov).8. The outline of the River shown on this figure is approximate (River outline basedon compilation of open data sources from ArcGIS online service and North Carolina Department of Environmental Quality Online GIS - Major Hydro shapefile).9. Basemap source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community.
BRUNSWICK
PENDER
NEW HANOVER
COLUMBUS
BLADEN Legend
NCDEQ Private Well Sampling Locations (Above the ConsentOrder Criteria1)
NCDEQ Private Well Sampling Locations (Below the ConsentOrder Criteria1)NCDEQ PFAS Sampling Locations (Above the Consent OrderCriteria1)NCDEQ PFAS Sampling Locations (Below the Consent OrderCriteria1)
Cape Fear River
County Boundary
Surrounding North Carolina County
100-Year Floodplain Associated with Cape Fear River2
New Hanover County Public Water Service
Town of Carolina Beach
Town of Kure Beach
Town of Wrightsville Beach
Monterey Heights Groundwater
Sweeney Treatment Plant
Richardson Nano Filtration
Cape Master
³
4 0 42 Miles
Pender County
Chemours Fayetteville WorksNorth Carolina
Figure
B.4Raleigh
Path: \\guelph-01\data\PRJ\Projects\TR0795\Database and GIS\Four Counties Programs\Private Well Program\GIS\NC Eligible Areas By County.mxd Last Revised: 4/1/2022 Author: NBarNahoumApril 2022
Projection: NAD83 North Carolina ftUS; Units in Foot US
Notes:1. In addition to the extent of the 100-year floodplain associated with Cape Fear River (provided by the Federal Emergency Management Agency; FEMA), limits of saltwater marshes in the areas where Black River and Northeast Cape Fear River meet Cape Fear were included to account for the possibility of tidal backwash of Cape Fear River into these rivers. This criterion also includes the last half mile floodplain of each tributary before it joins the Cape Fear River.2. Public Water Service Areas and the Public Water Supply Source were downloaded from The Drinking Water Resilience Interactive Project (DRIP) site (http://drip.unctv.org/maps/maps-051716/).3. Public Water Supply Lines was downloaded from Pender County GIS data (https://gis.pendercountync.gov/arcgis/rest/services/Layers/MapServer/50).4. County Boundaries was downloaded from OneMap site (https://www.nconemap.gov).5. The outline of the River shown on this figure is approximate (River outline basedon compilation of open data sources from ArcGIS online service and North Carolina Department of Environmental Quality Online GIS - Major Hydro shapefile).6. Basemap source: Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community.
PENDER
ONSLOW
DUPLIN
SAMPSON
NEW HANOVERBRUNSWICK
BLADEN
COLUMBUS
Legend
Cape Fear River
County Boundary
Surrounding North Carolina County
100-Year Floodplain Associated with Cape Fear River
Public Water Supply Lines
Public Water Service
Maple Hill Water District
Rocky Pt/Topsail WS Dist
Town of Burgaw
Town of Surf City
Town of Topsail Beach
³
4 0 42 Miles
TABLE B.1PFAS ANALYTES Chemours Fayetteville Works, North CarolinaGeosyntec Consultants of NC, P.C.Attachment C (Table 3+ SOP and Table 6)Table 3+ (Table 3+ SOP)Other PFAS (Method 537 Mod)HFPO-DA1✔✔✔Hexafluoropropylene oxide dimer acid 13252-13-6 C6HF11O3PEPA✔✔--Perfluoro-2-ethoxypropionic acid 267239-61-2 C5HF9O3PFECA-G✔✔--Perfluoro-4-isopropoxybutanoic acid 801212-59-9 C12H9F9O3SPFMOAA✔✔--Perfluoro-2-methoxyacetic acid 674-13-5 C3HF5O3PFO2HxA✔✔--Perfluoro-3,5-dioxahexanoic acid 39492-88-1 C4HF7O4PFO3OA✔✔--Perfluoro-3,5,7-trioxaoctanoic acid 39492-89-2 C5HF9O5PFO4DA✔✔--Perfluoro-3,5,7,9-tetraoxadecanoic acid 39492-90-5 C6HF11O6PMPA✔✔--Perfluoro-2-methoxypropionic acid 13140-29-9 C4HF7O3Hydro-EVE Acid--✔--2,2,3,3-tetrafluoro-3-({1,1,1,2,3,3-hexafluoro-3-[(1,2,2,2-tetrafluoroethyl)oxy]propan-2-yl}oxy)propionic acid 773804-62-9 C8H2F14O4EVE Acid--✔--2,2,3,3-tetrafluoro-3-({1,1,1,2,3,3-hexafluoro-3-[(1,2,2-trifluoroethenyl)oxy]propan-2-yl}oxy)propionic acid69087-46-3 C8HF13O4PFECA B--✔--Perfluoro-3,6-dioxaheptanoic acid 151772-58-6 C5HF9O4R-EVE--✔--Pentanoic acid, 4-(2-carboxy-1,1,2,2-tetrafluoroethoxy)-2,2,3,3,4,5,5,5-octafluoro-2416366-22-6 C8H2F12O5PFO5DA✔✔--Perfluoro-3,5,7,9,11-pentaoxadodecanoic acid 39492-91-6 C7HF13O7R-PSDA--✔-- Pentanoic acid, 2,2,3,3,4,5,5,5-octafluoro-4-(1,1,2,2-tetrafluoro-2-sulfoethoxy)- 2416366-18-0 C7H2F12O6SR-PSDCA--✔--Ethanesulfonic acid, 1,1,2,2-tetrafluoro-2-[1,2,2,3,3-pentafluoro-1-(trifluoromethyl)propoxy]- 2416366-21-5 C6H2F12O4SHydrolyzed PSDA--✔--Acetic acid, 2-fluoro-2-[1,1,2,3,3,3-hexafluoro-2-(1,1,2,2-tetrafluoro-2-sulfoethoxy)propoxy]- 2416366-19-1 C7H3F11O7SNVHOS--✔--1,1,2,2,4,5,5,5-heptafluoro-3-oxapentanesulfonic acid; or 2-(1,2,2,2-ethoxy)tetrafluoroethanesulfonic acid; or 1-(1,1,2,2-tetrafluoro-2-sulfoethoxy)-1,2,2,2-tetafluoroethane 801209-99-4 C4H2F8O4SPES--✔--Perfluoro-2-ethoxyethanesulfonic acid 113507-82-7 C4HF9O4SPS Acid✔✔--Ethanesulfonic acid, 2-[1-[difluoro[(1,2,2-trifluoroethenyl)oxy]methyl]-1,2,2,2-tetrafluoroethoxy]-1,1,2,2-tetrafluoro- 29311-67-9 C7HF13O5SHydro-PS Acid✔✔--Ethanesulfonic acid, 2-[1-[difluoro(1,2,2,2-tetrafluoroethoxy)methyl]-1,2,2,2-tetrafluoroethoxy]-1,1,2,2-tetrafluoro- 749836-20-2 C7H2F14O5SPFHpA1✔--✔Perfluoroheptanoic acid 375-85-9 C7HF13O2Common NamePFAS Grouping (Method)Chemical Name CASRN Chemical FormulaTR0795APage 1 of 3April 2022
TABLE B.1PFAS ANALYTES Chemours Fayetteville Works, North CarolinaGeosyntec Consultants of NC, P.C.Attachment C (Table 3+ SOP and Table 6)Table 3+ (Table 3+ SOP)Other PFAS (Method 537 Mod)Common NamePFAS Grouping (Method)Chemical Name CASRN Chemical FormulaPFBA-- --✔Perfluorobutanoic acid 375-22-4 C4HF7O2PFPeA-- --✔Perfluoropentanoic acid 2706-90-3 C5HF9O2PFHxA-- --✔Perfluorohexanoic acid 307-24-4 C6HF11O2PFOA-- --✔Perfluorooctanoic acid 335-67-1 C8HF15OPFNA-- --✔Perfluorononanoic acid 375-95-1 C9HF17O2PFDA-- --✔Perfluorodecanoic acid 335-76-2 C10HF19O2PFUnA-- --✔Perfluoroundecanoic acid 2058-94-8 C11HF21O2PFDoA-- --✔Perfluorododecanoic acid 307-55-1 C12HF23O2PFTriA-- --✔Perfluorotridecanoic acid 72629-94-8 C13HF25O2PFTeA-- --✔Perfluorotetradecanoic acid 376-06-7 C14HF27O2PFHxDA-- --✔Perfluorohexadecanoic acid 67905-19-5 C16HF31O2PFODA-- --✔Perfluorooctadecanoic acid 16517-11-6 C18HF35O2PFBS-- --✔Perfluorobutanesulfonic acid 375-73-5 C4HF9SOPFPeS-- --✔Perfluoropentanesulfonic acid 2706-91-4 C5HF11O3SPFHxS-- --✔Perfluorohexanesulfonic acid 355-46-4 C6HF13SO3PFHpS-- --✔Perfluoroheptanesulfonic acid 375-92-8 C7HF15O3SPFOS-- --✔Perfluorooctanesulfonic acid 1763-23-1 C8HF17SO3PFNS-- --✔Perfluorononanesulfonic acid 68259-12-1 C9HF19O3SPFDS-- --✔Perfluorodecanesulfonic acid 335-77-3 C10HF21O3SPFDoDS-- --✔Perfluorododecanesulfonic acid 79780-39-5 C12HF25O3STR0795APage 2 of 3April 2022
TABLE B.1PFAS ANALYTES Chemours Fayetteville Works, North CarolinaGeosyntec Consultants of NC, P.C.Attachment C (Table 3+ SOP and Table 6)Table 3+ (Table 3+ SOP)Other PFAS (Method 537 Mod)Common NamePFAS Grouping (Method)Chemical Name CASRN Chemical Formula4:2 FTS-- --✔4:2 Fluorotelomer sulfonic acid 757124-72-4 C6H5F9O3S6:2 FTS-- --✔6:2 Fluorotelomer sulfonic acid 27619-97-2 C8H5F13SO38:2 FTS-- --✔8:2 Fluorotelomer sulfonic acid 39108-34-4 C10H5F17O3S10:2 FTS-- --✔10:2 Fluorotelomer sulfonic acid 120226-60-0 C12H5F21O3NEtFOSAA-- --✔N-ethyl perfluorooctane sulfonamidoacetic acid 2991-50-6 C12H8F17NO4SNEtPFOSA-- --✔N-ethylperfluoro-1-octanesulfonamide 4151-50-2 C10H6F17NO2SNEtPFOSAE-- --✔N-ethyl perfluorooctane sulphonamidoethanol 1691-99-2 C12H10F17NO3SNMeFOSAA-- --✔N-methyl perfluorooctane sulfonamidoacetic acid 2355-31-9 C11H6F17NO4SNMePFOSA-- --✔N-methyl perfluoro-1-octanesulfonamide 31506-32-8 C9H4F17NO2SNMePFOSAE-- --✔N-methyl perfluorooctane sulfonamidoethanol 24448-09-7 C11H8F17NO3SPFOSA-- --✔Perfluorooctane sulfonamide 754-91-6 C8H2F17NO2SF-53B Major-- --✔Perfluoro(2-((6-chlorohexyl)oxy)ethanesulfonic acid) 756426-58-1 C8HClF16O4SF-53B Minor-- --✔Perfluoro(2-((8-chlorooctyl)oxy)ethanesulfonic acid) 763051-92-9 C10HClF20O4SDONA-- --✔2,2,3-Trifluoro-3-(1,1,2,2,3,3-hexafluoro-3-(trifluoromethoxy)propoxy)propanoic acid919005-14-4 C7H2F12O4Notes:1 - HFPO-DA and PFHpA can be analyzed under methods Table 3+ SOP and EPA Method 537 Mod.CASRN - Chemical Abstract Service Registry NumberEPA - Environmental Protection AgencyPFAS - Per- and Polyfluoroalkyl substances SOP - Standard Operating ProcedureTR0795APage 3 of 3April 2022
TABLE B.2
ADDITIONAL ANALYTES
Chemours Fayetteville Works, North Carolina
Geosyntec Consultants of NC, P.C.
Other Analytes Lab Method
Antimony 200.7 Rev. 4.4
Arsenic 200.7 Rev. 4.4
Barium 200.7 Rev. 4.4
Beryllium 200.7 Rev. 4.4
Cadmium 200.7 Rev. 4.4
Calcium 200.7 Rev. 4.4
Chromium 200.7 Rev. 4.4
Cobalt 200.7 Rev. 4.4
Copper 200.7 Rev. 4.4
Iron 200.7 Rev. 4.4
Lead 200.7 Rev. 4.4
Magnesium 200.7 Rev. 4.4
Manganese 200.7 Rev. 4.4
Molybdenum 200.7 Rev. 4.4
Nickel 200.7 Rev. 4.4
Potassium 200.7 Rev. 4.4
Selenium 200.7 Rev. 4.4
Silver 200.7 Rev. 4.4
Sodium 200.7 Rev. 4.4
Strontium 200.7 Rev. 4.4
Vanadium 200.7 Rev. 4.4
Zinc 200.7 Rev. 4.4
Chloride 300.0
Fluoride 300.0
Nitrate 300.0/353.2
Nitrite 300.0/353.2
Sulfate 300.0
1,4-Dioxane 522
Total Coliforms by Presence/Absence 9222B
Total Dissolved Solids SM 2540 C
Total Phosporus 200.7 Rev. 4.4
TR0795A Page 1 of 1 April 2022