2020.01.06_CCO.p16_PublicCommentsCAPthru04062020From:Jamie Bowers
To:Holman, Sheila
Cc:Theodore Leopold; S. Douglas Bunch; Alison Deich; Steven Seigel; Steve Morrissey; Neal Weinfeld; Jordan
Connors; Ben Manne; Vineet Bhatia; Gary Jackson; Andy Whiteman; Abraczinskas, Michael; Scott, Michael;
linda.culpepper@ncdenr.gov; Lane, Bill F; Benzoni, Francisco; ggisler@selcnc.org; SVC_DENR.publiccomments
Subject:[External] RE: Comments on Corrective Action Plan from Counsel in Carey v. E.I. du Pont de Nemours and Co.,No. 7:17-cv-189-D (E.D.N.C.)
Date:Wednesday, April 8, 2020 1:49:09 PM
Attachments:Carey Counsel Comments on Corrective Action Plan.pdfLetter to Assistant Secretary Holman re Comments on the Corrective Action Plan.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
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Good afternoon,
I’m writing to confirm receipt of the comments on the Corrective Action Plan (reattached here) from
counsel in Carey v. E.I. du Pont de Nemours & Co., No. 7:17-cv-189-D (E.D.N.C.), and the attached
letter. Thank you.
Best regards,
Jamie Bowers
From: Jamie Bowers
Sent: Thursday, March 12, 2020 11:26 AM
To: sheila.holman@ncdenr.gov
Cc: Theodore Leopold <tleopold@cohenmilstein.com>; S. Douglas Bunch
<dbunch@cohenmilstein.com>; Alison Deich <ADeich@cohenmilstein.com>; Steven Seigel
<sseigel@susmangodfrey.com>; Steve Morrissey <smorrissey@susmangodfrey.com>; Neal Weinfeld
<NHW@dedendumgroup.com>; Jordan Connors <jconnors@susmangodfrey.com>; Ben Manne
<BManne@susmangodfrey.com>; Vineet Bhatia <vbhatia@susmangodfrey.com>; Gary Jackson
<gjackson@farrin.com>; Andy Whiteman <aow@whiteman-law.com>;
michael.abraczinskas@ncdenr.gov; michael.scott@ncdenr.gov; linda.culpepper@ncdenr.gov;
bill.lane@ncdenr.gov; fbenzoni@ncdoj.gov; kemp@cfrw.org; ggisler@selcnc.org
Subject: Comments on Corrective Action Plan from Counsel in Carey v. E.I. du Pont de Nemours and
Co., No. 7:17-cv-189-D (E.D.N.C.)
Good morning,
Please find attached comments on the Corrective Action Plan from counsel in Carey v. E.I. du Pont de
Nemours and Co., No. 7:17-cv-189-D (E.D.N.C.), and the attached letter.
Best regards,
Jamie Bowers
Jamie Bowers Cohen Milstein Sellers & Toll PLLC
Associate
[cohenmilstein.com]
1100 New York Ave. NW | Fifth Floor
Washington, DC 20005
phone 202.408.4600
fax 202.408.4699
website [cohenmilstein.com] | map [google.com]
Powerful Advocates. Meaningful Results.
This e-mail was sent from Cohen Milstein Sellers & Toll PLLC. It may contain information that is privileged and confidential. If you suspect
that you were not intended to receive it, please delete it and notify us as soon as possible.
Theodore Leopold
(561) 515-1400
tleopold@cohenmilstein.com
March 12, 2020
VIA ELECTRONIC MAIL
The Honorable Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
sheila.holman@ncdenr.gov
Re: Comments on the Corrective Action Plan dated December 31, 2019. pursuant to
the Consent Order Paragraph 16, State of North Carolina, ex rel., Michael S.
Regan, Secretary, North Carolina Dept. of Envtl. Quality v. The Chemours
Company FC, LLC, No. 17-CVS-580
Dear Assistant Secretary Holman:
We are the Court-appointed interim co-lead counsel for the putative Class in Carey v. E.I.
du Pont de Nemours & Co., No. 7:17-CV-00189-D, currently pending in the U.S. District Court
for the Eastern District of North Carolina. The Carey action plaintiffs (“Plaintiffs”) seek to hold
Chemours and its predecessor, DuPont, liable for polluting North Carolina residents’ bodies and
property with GenX and other Per- and Polyfluoroalkyl Substance (“PFAS”) compounds
originating from Chemours’ Fayetteville Works plant, thereby endangering these residents’ health.
Plaintiffs seek to represent several putative classes of individuals—including property owners who
receive their water from wells as well as property owners who receive their water from public
utilities—whose health and property have been injured by Chemours’ and DuPont’s wrongful
contamination of the Cape Fear River area with PFAS.
On behalf of those putative Classes, Plaintiffs respectfully submit the attached comments
in response to the December 31, 2019, Corrective Action Plan (“CAP”), prepared by Geosyntec
Consultants of NC, P.C. (“Geosyntec”) for The Chemours Company FC, LLC (“Chemours”). The
CAP was prepared pursuant to the February 2019 Consent Order (“CO” or “Consent Order”) in
the above-referenced matter brought by the State of North Carolina against Chemours for its
unlawful contamination (the “DEQ Action”).
March 12, 2020
Page 2
The CAP is regrettably deficient in numerous respects. As explained in the attached
Comments, the CAP’s proposed remedies do not and will not address the full extent of the PFAS
contamination originating from Chemours’ Fayetteville Works plant, and fail to adequately protect
the human health of residential users of municipal water supplies drawn from the Cape Fear River,
including in New Hanover, Brunswick, Pender, and Columbus Counties, who are putative class
members in the Carey action. In brief:
• ISSUE: The CAP offers no protection to downstream residential consumers
(“DRCs”) who obtain water from public utilities and whose water remains
contaminated with PFAS above the Consent Order’s Action Level. During the summer
and fall of 2019, experts working for the putative class counsel collected and analyzed
drinking-water samples from 27 residences in Brunswick, Columbus, New Hanover, and
Pender Counties serviced by municipal water. All of the samples collected from these
residences exceed the Consent Order’s Action Level—i.e., the threshold for triggering
Chemours’ obligation to install reverse-osmosis (“RO”) filters pursuant to Consent Order
¶ 20. Despite the fact that municipal water customers’ water has PFAS concentrations
exceeding the Consent Order’s 10/70 Action Levels, the remedies proposed in the CAP
will not prevent PFAS from contaminating DRC’s properties and water supplies for years
to come, leaving these citizens’ homes and bodies exposed to harmful toxins for the
indefinite future.
o RECOMMENDATION: Pursuant to Consent Order ¶ 16 which requires
Chemours to “comply with the requirements of the 2L Rules and guidance provided
by [the North Carolina Department of Environmental Quality (“DEQ”)]”, Consent
Order ¶ 16 (see 15A NCAC 02L .0103 (“2L Rules”)), and in order to treat equally
all North Carolina residents who have been harmed by Chemours’ illegal behavior,
DEQ should compel Chemours to pay for (a) the acquisition, installation, operation,
and maintenance of three under-sink RO systems for each residence in the
municipal water supply districts where tap water has been found to exceed the 10/70
Action Levels, and (b) bottled water pending the installation of such systems.
• ISSUE: Chemours admits that it does not know when or whether its remedies will
effectively abate PFAS contamination above the 10/70 Action Levels. Chemours’
proposed remedies in the CAP are inadequate to prevent PFAS from contaminating DRCs’
residences above the 10/70 Action Levels for years to come. Specifically, for PFAS that
continue to migrate into the Cape Fear River from the contaminated Fayetteville Works
facility, Chemours has not even completed investigating—let alone implemented—any
measures necessary to abate or prevent ongoing PFAS contamination. All of the ten
remedial actions proposed in the CAP are expected to take between 5 and 10 years, and
likely longer, to complete. Moreover, Chemours admits that it does not know whether its
long-term remedies will be effective, stating that “the proposed long-term groundwater
remedy is still highly conceptual,” that “it is not presently possible to conclude with
March 12, 2020
Page 3
confidence whether this alternative is economically feasible,” and that “[t]he state of
knowledge regarding the fate and transport properties, toxicological characteristics, and
potential remedial approaches for PFAS and Table 3+ PFAS are continuing to evolve
and advance.” See CAP at xvii & p. 1.
o RECOMMENDATION: Pursuant to Consent Order ¶ 16, the requirements of the
2L Rules, and in order to treat equally all North Carolina residents who have been
harmed by Chemours’ illegal behavior, DEQ should compel Chemours to pay for
(a) the acquisition, installation, operation, and maintenance of three under-sink RO
systems for each residence in the municipal water supply districts where tap water
has been found to exceed the 10/70 Action Levels, and (b) bottled water pending
the installation of such systems.
• ISSUE: Chemours suggests that remediation may be impossible. In the CAP,
Chemours openly states that, in the future, “NCDEQ and Chemours may need to consider
alternate cleanup standards,” and that the appropriate standard is one that alleviates
Chemours’ obligations in light of the costliness of remediation. See CAP at 58 (stating that
the goal of corrective action is “restoration to the level of the standards, or as closely
thereto as is economically and technologically feasible”).
o RECOMMENDATION: It is Chemours’ legal obligation under the Consent
Order to “submit . . . a plan demonstrating maximum reductions in PFAS loading”
within two years, or a longer plan “if significantly greater reductions can be
achieved.” See Consent Order ¶ 12. Although the Consent Order acknowledges that
the economic and technological feasibility of Chemours’ remediation are important
considerations, DEQ cannot allow Chemours to use that as an escape hatch to avoid
its obligations to achieve and demonstrate maximum PFAS reductions to ensure
that all North Carolina residents can drink and use water free of Chemours’ harmful
PFAS contamination.
• ISSUE: Chemours fails to propose any plan to remediate groundwater and PFAS-
contaminated land outside of Fayetteville Works. PFAS will continue to migrate to
groundwater and into the Cape Fear River even if Chemours manages to remediate
contamination from its Fayetteville Works facility. This is because (as Chemours admits)
its PFAS air emissions have contaminated over 70 square miles of the Cape Fear watershed,
and this contamination has vertically migrated from the soil into groundwater that flows
directly into the Cape Fear River. Chemours presents no plan to address this extensive
contamination, suggesting instead that it cannot be addressed at all. See CAP p. 58 (“the
costs for on and off-site remediation . . . would exceed billions to potentially tens of
billions of dollars and the timeframe would be on the order of multiple decades.”). Instead
of addressing this contamination, Chemours simply states that it’s too expensive, and
proposes no reduction in PFAS loadings to the Cape Fear River from aerial deposition
March 12, 2020
Page 4
outside Fayetteville Works. Consequently PFAS will continue to impact surrounding and
downstream water users for decades.
o RECOMMENDATION: DEQ should require Chemours to present a plan for
reducing PFAS loadings to the groundwater and Cape Fear River over the Cape
Fear River watershed, and until such loadings are decreased, compel Chemours to
pay for (a) the acquisition, installation, operation, and maintenance of three under-
sink RO systems for each residence in the municipal water supply districts where
tap water has been found to exceed the 10/70 Action Levels, and (b) bottled water
pending the installation of such systems.
ISSUE: Chemours’ risk assessment is flawed, biased, and inadequate to comply with
the requirements of the Consent Order. Chemours has yet to complete satisfactory risk
assessments as required by Consent Order ¶ 14. In particular, Chemours has neither quantified the
risks of PFAS exposure to DRCs and all other individuals affected by Chemours’ contamination
nor complied with Consent Order ¶ 14’s requirement to establish that Attachments B and C PFAS
do not pose an unacceptable risk to human health. Chemours has also failed to calculate toxicity
values (and risks) for 19 out of 20 PFAS, focusing all of its efforts on GenX, the one PFAS for
which DuPont and Chemours have produced at least some toxicity evaluations. In addition,
Chemours’ analysis fails to (a) follow standard U.S. Environmental Protection Agency (“EPA”)
guidance for deriving toxicity values; (b) adequately address the past decade of scientific literature
on GenX’s toxicity; (c) properly weigh and account for the toxicity and human health risks of
GenX, including immunotoxicity; and (d) account for all necessary risks and toxicity information
associated with drinking contaminated water. Chemours also manipulates its conclusions by
making improper and scientifically unsound assumptions that mask the true risks associated with
drinking PFAS-contaminated water and fail to account for exposure risks to sensitive
subpopulations.
• RECOMMENDATION: DEQ should require Chemours to rectify all of these
deficiencies, recalculate the risks posed to DRCs, and design remedial actions, including
the provision of RO and bottled water to achieve these objectives.
In sum, in addition to failing to comply with the Consent Order requirements, the CAP
demonstrates conclusively that Chemours has no plan to remediate the PFAS contamination it has
caused in the immediate or even long term. Property owners and individuals who rely on the Cape
Fear River for their water cannot wait the many years—if not decades—that will be required before
PFAS contamination drops below acceptable levels. It is therefore critical that Chemours address
the consequences of its actions now.
For the reasons set forth below, Plaintiffs respectfully request that DEQ compel Chemours
to pay for the acquisition, installation, operation and maintenance of three under-sink RO systems
for each residence in the municipal water supply districts where tap water was found to exceed the
10/70 Action Levels (described below), and bottled water pending the installation of such systems.
March 12, 2020
Page 5
Plaintiffs believe that this relief, which they are also seeking as part of their pending case against
Chemours and DuPont, is needed to remediate damage resulting from the trespasses upon their
persons and properties resulting from the unauthorized release of PFAS into the drinking water
supply, and to address ongoing threats to their health resulting from exposure to PFAS at levels
found in the water supply in the area.
Respectfully submitted,
/s/ Theodore J. Leopold /s/ Stephen E. Morrissey
Theodore J. Leopold Stephen E. Morrissey
Cc:
Mr. Michael Abraczinskas
Director, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
michael.abraczinskas@ncdenr.gov
Mr. Michael Scott
Director, Division of Waste Management
1646 Mail Service Center
Raleigh, NC 27699-1646
michael.scott@ncdenr.gov
Ms. Linda Culpepper
Interim Director, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
linda.culpepper@ncdenr.gov
William F. Lane, Esq.
General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
bill.lane@ncdenr.gov
Francisco Benzoni, Esq.
Special Deputy Attorney General
P.O. Box 629
March 12, 2020
Page 6
Raleigh, NC 27602
fbenzoni@ncdoj.gov
Mr. Kemp Burdette
Cape Fear River Watch
617 Surry Street
Wilmington, NC 28401
kemp@cfrw.us
Mr. Geoff Gisler
Southern Environmental Law Center
601 West Rosemary Street, Suite 220
Chapel Hill, NC 27516-2356
ggisler@selcnc.org
1
COMMENTS ON
CHEMOURS’ CORRECTIVE ACTION PLAN (DEC. 31, 2019)
SUBMITTED PURSUANT TO THE CONSENT ORDER IN
State of North Carolina v. The Chemours Company FC, LLC, Case No. 17-CVS 580
(Bladen County Superior Court)
I. Executive Summary
These comments—which have been prepared by counsel for plaintiffs and the proposed
class in Carey, et al. v. E.I. du Pont de Nemours and Co. and The Chemours Co. FC, LLC, No.
7:17-cv-00189 (E.D.N.C. filed Oct. 23, 2017), in consultation with experts Dr. Stephen B.
Ellingson of Vatten Associates and Dr. Richard DeGrandchamp of Scientia Veritas—address
Chemours’ failure to “comply with the requirements of the 2L Rules and guidance provided by
[the North Carolina Department of Environmental Quality (“DEQ”)].” Consent Order ¶ 16; see
15A NCAC 02L .0103 (“2L Rules”) (“The rules established in this Subchapter are intended to
maintain and preserve the quality of the groundwaters, prevent and abate pollution and
contamination of the water of the state, protect public health, and permit management of the
groundwaters for their best usage by the citizens of North Carolina.”).
As explained in detail below, Chemours’ proposed Corrective Action Plan (“CAP”):
1) fails to adequately protect the human health of residential users of municipal water
supplies drawn from the Cape Fear River in Brunswick, Columbus, New Hanover, and
Pender Counties (“Downstream Residential Consumers” or “DRCs”);
2) fails to adequately address the full extent of PFAS contamination originating from
Fayetteville Works (both from the decades that DuPont operated the facility, and since
Chemours took over its operations after DuPont spun Chemours off as a separate
company); and
3) fails to provide an adequate, unbiased, and scientifically sound risk assessment.
2
For these reasons, the only way to adequately protect the human health and property of
DRCs is to require Chemours to provide the same level of protection it has agreed to provide well
owners with PFAS contamination: installation of RO filtration to the same extent required by
Paragraph 20 of the Consent Order, with bottled water provided until filters are installed.
Additionally, to protect human health in the Cape Fear River area, Chemours (and its predecessor
DuPont) should be directed to: (1) fund and participate in independent toxicity assessments for
each of the chemicals of concern, as well as any synergistic effects between those chemicals; and
(2) fund and participate in epidemiological studies regarding the effects of contamination of
residents in the Cape Fear River area, including contamination resulting from well-established
toxic PFOA and PFOS that have been found in residents’ blood as a result DuPont’s and
Chemours’ conduct.
A. The CAP Fails to Protect Human Health.
An important starting point for understanding the failings of Chemours’ CAP is Paragraph
20 of the Consent Order in State of North Carolina v. The Chemours Company FC, LLC, Case No.
17-CVS 580 (the “Consent Order” or “CO”). Paragraph 20 requires Chemours to install reverse
osmosis (“RO”) filtration systems at homes that obtain water from private drinking water wells if
the wells are contaminated with:
a. combined quantifiable concentrations of PFAS listed in
Attachment C [of the CO] in exceedance of 70 ng/L [or parts per
trillion, “ppt”]; or
b. quantifiable concentrations of any individual PFAS listed in
Attachment C [of the CO] in exceedance of 10 ng/L.
CO ¶ 20. These requirements are referred to in these comments as the “10/70 Action Levels” or
“Action Levels.” The twelve specific PFAS underlying those Action Levels are set forth in
3
Attachment C to the CO, which is reproduced below. These twelve PFAS are referred to in these
comments as “Attachment C PFAS.”
The 10/70 Action Levels are consistent with standards needed to protect human health. In
prior litigation stemming from its predecessor DuPont’s contamination of the Ohio River Valley
with PFAS originating from the Parkersburg, West Virginia manufacturing facility (“Washington
Works”), a Science Panel jointly appointed by DuPont found a probable causal link between
PFOA, or C8, and testicular cancer, kidney cancer, ulcerative colitis, thyroid disease, high
cholesterol, and pregnancy-induced hypertension at exposure levels in excess of 50 parts per
trillion. DuPont moved its production of toxic C8 to the Fayetteville Works facility in 2002 and
continued manufacturing C8 at that facility until 2013. The Attachment C PFAS at issue in this
case are closely related to C8 and have been linked to similar adverse health effects: the chemicals
4
that have resulted in contamination throughout the Cape Fear River area result from manufacturing
C8 and its successor, GenX, at Fayetteville Works. As detailed below, the Attachment C PFAS
share toxicity characteristics with C8, and the 10/70 Action Levels are appropriate and necessary
measures to protect human health throughout the area, particularly in view of the fact they are
being distributed to and consumed by a population that already has been exposed to PFOS and
PFOA contamination emanating from Fayetteville Works.
Chemours has made a binding contractual commitment to remediate the effects of its
PFAS contamination for residents who obtain water from private wells with test results in excess
of the Action Levels. Yet, Chemours has failed to take any measures to protect residential
properties served by utilities who draw their water from the Cape Fear River downstream of
Chemours’ Fayetteville Works plant—even though those residences are contaminated with
Attachment C PFAS above the 10/70 Action Level.
In the summer and fall of 2019, Plaintiffs’ counsel and their consulting technical experts
collected and analyzed water samples from 36 residences in Bladen, Brunswick, Columbus,
Cumberland, New Hanover, and Pender Counties to determine whether and at what concentrations
these homes were contaminated with Attachment C PFAS. All 27 residences that were sampled in
Brunswick, Columbus, New Hanover, and Pender Counties are serviced by municipal water
providers including the Cape Fear Public Utility Authority (“CFPUA”) and Brunswick County
Public Utilities (“BCPU”). The samples were collected from either the tap or water heaters of the
residences.
All samples collected and analyzed from Brunswick, Columbus, New Hanover, and Pender
Counties show contaminant concentrations exceeding the threshold for installation of RO systems
pursuant to Paragraph 20 of the CO; every single sample had PFAS concentrations exceeding
5
the 10/70 Action Levels. Alarmingly, these residential water supplies are contaminated two years
after Chemours claims to have ceased discharging PFAS into the Cape Fear River from Outfall
002.
The residential samples collected by plaintiffs’ counsel and their experts are consistent with
results published by municipal water providers in the area. Tests of finished water by the
Brunswick County and the Cape Fear Public Utility Authority water systems consistently have
identified Attachment C PFAS in finished water at levels well in excess of the 10/70 Action
Levels.1
Importantly, the residents serviced by municipal water with PFAS contamination
exceeding the 10/70 Action Levels receive drinking water that has already been treated by the
municipal water providers. PFAS contamination nonetheless persists. Moreover, there is no date
certain as to when these municipal water service providers will provide replacement treatment
systems designed to remediate PFAS. Nor is there any certainty that such replacement systems—
when installed—will be able to remove PFAS concentrations to below the health-based criteria
required by the Consent Order.
The public health concerns associated with continuing contamination of the water supply
with PFAS originating from Fayetteville Works are particularly acute in light of the GenX
Exposure Study PFAS Blood Sample Results published on November 18, 2018.2 That study
involved an analysis of blood samples from 310 Wilmington residents (44 of whom were sampled
1 See https://www.cfpua.org/761/Emerging-Compounds (showing combined Attachment C PFAS levels in
CFPUA finished water exceeding 100 ppt and as high as 300 ppt since June 2019);
https://www.brunswickcountync.gov/genx/ (showing finished water at Brunswick treatment plant
exceeding 400 ppt for combined Attachment C PFAS in August 2019 and exceeding 100 ppt through
December 2019).
2 North Carolina State University Center for Human Health and the Environment, GenX Exposure Study
PFAS Blood Sample Results, available at https://chhe.research.ncsu.edu/wordpress/wp-content/uploads/
2018/11/Community-event-BLOOD-slides.pdf (published November 18, 2018).
6
twice) for 23 PFAS. The results consistently showed newly identified PFAS (including Nafion
Byproduct 2, PFO4DA, and PFO5DoDA) in residents’ blood.3 Additionally, the sample found that
legacy PFAS (including well-established toxins PFOA and PFOS, as well as PFHxS, PFNA, and
PFDA) that were previously used at Fayetteville Works remain in residents’ blood at levels
substantially in excess of background levels for the United States years after C8 manufacturing
was discontinued, suggesting that area residents historically were exposed to high levels of those
chemicals in their drinking water.4 As part of the class action, the Carey plaintiffs allege that
residents in the area should be entitled to blood tests to ascertain the amount of PFAS in their blood
as a result of DuPont’s and Chemours’ conduct and determine whether additional medical
treatment is needed. It is uncertain when or whether that relief (which Chemours opposes) may be
available in the class action, and the CAP currently does not include any measures to address the
health of area residents. As part of the CAP, Chemours should be required to (a) fund blood tests
to ascertain the amount of PFAS in area residents’ blood; (b) fund a public health study to assess
the health effects of PFAS in residents’ blood, including the prevalence of health conditions linked
with PFAS in the community and any synergistic effects between newer PFAS and historical PFAS
such as PFOA and PFOS that remain in residents’ blood; and (c) toll the statute of limitations for
any personal injury claims that may exist as a result of PFAS contamination until after the
completion of those public health studies.
B. The CAP Fails to Provide Adequate Plans to Remediate Ongoing PFAS
Contamination from the Site.
There are three primary flaws in the CAP’s remedial proposal with respect to remediation
of ongoing PFAS contamination originating from the Fayetteville Works site.
3 Id., slide 26.
4 Id., slide 39.
7
First, the CAP proposes no reduction in PFAS loadings to the Cape Fear River from aerial
deposition on more than 70 square miles of the Cape Fear River watershed. Although Chemours
maintains that it has reduced loadings to the environment over the last two years, it has taken at
best nominal measures to abate the thousands, if not hundreds of thousands of tons of PFAS
already emitted into the air. The PFAS deposited on the ground surface has vertically migrated
into groundwater that is flowing into the Cape Fear River. As a result, PFAS will continue to
impact the DRCs for an indefinite time unless and until RO systems are installed.
Second, the effectiveness of Chemours’ measures to remediate PFAS at its own
Fayetteville Works facility are highly speculative, unlikely to work, and are projected to extend
over an indefinite period. Chemours has not implemented—or even completed investigating—any
of the temporary or permanent measures necessary to prevent PFAS contamination from migrating
into the Cape Fear River. On the contrary, Chemours’ own documentation indicates that PFAS
contamination will continue to migrate to the underlying groundwater and into the Cape Fear River
even if Chemours manages to prevent contamination from migrating directly into the Cape Fear
River from its Fayetteville Works facility. As discussed in further detail below, none of the
remedies proposed in the CAP will prevent PFAS from contaminating residences at concentrations
exceeding the 10/70 Action Levels for many years. Chemours maintains throughout the CAP that
it is impracticable to remediate the large tracts of the Cape Fear River watershed contaminated
with PFAS. This PFAS has entered the groundwater and is discharging directly into the Cape Fear
River and will do so for decades to come. Because this source of PFAS contamination will continue
to affect DRCs for the foreseeable future, there is all the more need to protect DRCs by installing
RO systems now.
8
Third, the CAP fails to account for the differing rates of PFAS migration through air, soil,
groundwater, sediment, and river water. PFAS will reach the DRCs not as a single “slug” but rather
gradually over many years. This means that even if GenX concentrations in the DRCs’ tap water
declines below the 140 ppt provisional level or the 10/70 Action Levels, other PFAS will continue
to impact the DRCs’ tap water for years to come.
Providing the DRCs with the same level of protection afforded to residents drinking well
water near the facility is the only means of protecting human health. Chemours admits that RO
systems remove more than 92% of HFPO-DA, ensuring human receptor exposures remain below
regulatory limits. There is no reason why the DRCs should not be provided with the same level of
protection afforded to residents drinking well water near Fayetteville Works. In order to protect
the DRCs, the only viable option is to provide them with RO systems including replacement of
filters until such time that at a minimum PFAS concentrations decline below the 10/70 Action
Levels.
C. The CAP Fails to Provide an Adequate, Scientifically Sound, and
Unbiased Risk Assessment.
Chemours has yet to complete satisfactory risk assessments as required by paragraph 14 of
the CO. Chemours has yet to properly quantify the risks of PFAS exposure to DRCs and all other
individuals affected by Chemours’ contamination. Chemours has failed to comply with CO
Paragraph 14’s requirement to establish that Attachments B and C PFAS do not pose an
unacceptable risk to human health. Chemours fails to calculate toxicity values (and risks) for 19
out of 20 PFAS, focusing all of its efforts on GenX, the one PFAS for which DuPont and Chemours
have produced at least some toxicity evaluations. Chemours’ analysis fails to (a) follow standard
EPA guidance for deriving toxicity values; (b) adequately address the past decade of scientific
literature on GenX’s toxicity; (c) properly weigh and account for the toxicity and human health
9
risks of GenX, including immunotoxicity; and (d) account for all necessary risks and toxicity
information associated with drinking contaminated water. Chemours also manipulates its
conclusions by making improper and scientifically unsound assumptions that mask the true risks
associated with drinking PFAS-contaminated water and fail to account for exposure risks to
sensitive subpopulations.
D. DEQ Must Require Chemours to Implement the Economically and
Technologically Feasible Solution of Installing RO Filters for DRCs.
Chemours’ claims of technical and economic infeasibility are deeply flawed. Underlying
Chemours’ claims is an assumption that, if source-based remediation is infeasible for any reason,
then no remedial actions may be required. This is simply false. Even assuming remediation is not
feasible, Chemours has failed to analyze or propose any alternative means of protecting human
health, property, and the environment, including solutions that Chemours has already admitted
are both technologically and economically feasible: installing household-level RO filters to
protect all citizens and homes from ongoing PFAS contamination. Chemours’ failure to consider
this alternative is a glaring defect in its CAP, and one that must be addressed particularly given
Chemours’ repeated suggestions that other remedial measures are or will be either technically or
economically infeasible.
Chemours admits that installing RO systems is the only practical method for protecting
homes near its facility on well water with PFAS concentrations exceeding the 10/70 Action Levels.
This is the only practical method for protecting the DRCs as well. Therefore, the CAP should also
require Chemours to pay for the acquisition, installation, operation and maintenance of RO systems
for all residences in the counties above that are serviced by municipal water authorities drawing
water from the Cape Fear River. During the interim period until Chemours compensates the DRCs
for installing RO systems, Chemours should also compensate the DRCs for the cost of purchasing
10
bottled water. Additionally—and particularly in light of Chemours’ inadequately supported
excuses for failing to propose adequate remedial measures—DEQ must seek to hold Chemours’
predecessor, DuPont, liable for its role in contaminating the Cape Fear River watershed with
PFAS. As yet, DuPont has not been required to account for or contribute to the remediation of the
contamination caused by its activities, for which it is jointly liable along with its successor,
Chemours. Chemours’ claims of economic infeasibility cannot be properly evaluated without
considering DuPont’s joint and several liability for the historical discharges of PFAS, which have
spanned decades, and for which DuPont must also be held responsible.
* * *
The comments below provide further detail on the points raised above, including an
introductory section briefly summarizing the history of Chemours’ and DuPont’s production of
toxic PFAS and subsequent contamination of surrounding water supplies with these harmful
chemicals for decades. This history is critical, as it shows DuPont’s and Chemours’ historical
disregard for the health and safety of residents affected by their unlawful discharges and emissions
of PFAS and the significant health risks posed by these chemicals (including the Attachment C
PFAS or “second generation PFAS,” such as GenX). More important is that it also reveals that
Chemours’ recent and ongoing communications with North Carolina residents affected by
Chemours’ contamination are misleading in their claims that the PFAS are non-toxic and not
harmful to human health.
II. DuPont’s and Chemours’ History of PFAS Contamination and Corporate
Irresponsibility
In evaluating the CAP and, more generally, the accountability of DuPont and Chemours
for PFAS contamination throughout the Cape Fear River area, understanding DuPont’s long
history of PFAS contamination and legacy of corporate irresponsibility in addressing serious
11
threats to human health and the environment is critical. In particular, the CAP must be evaluated
alongside: (a) the state of scientific knowledge regarding the toxicity of PFAS, including DuPont’s
stipulated acknowledgement that exposure to C8 (the predecessor chemical to GenX and other
Attachment C PFAS that was manufactured at Fayetteville Works until 2010) in drinking water at
concentrations of 50 ppt and above presents risks to human health; (b) the growing body of
scientific literature confirming that second generation PFAS, such as those originating from
Fayetteville Works, pose health risks substantially identical to those posed by C8; and (c) that the
mishandling of these toxic chemicals by DuPont and Chemours has resulted in the presence of
PFAS in drinking water throughout the area at levels exceeding 70 ppt, significantly above the
level at which C8 was determined to be dangerous to human health by a jointly appointed C8
Science Panel (“C8 Panel”) in prior litigation.
DuPont’s and Chemours’ history with PFAS began in 1951, when DuPont began using C8
at its Washington Works plant in Parkersburg, West Virginia.5 C8 was used as a manufacturing
aid in the production of Teflon™.6 Concerns about the toxicity of C8 surfaced internally within
DuPont as early as 1954, and DuPont confirmed C8’s toxicity to animals at least as of 1961.7 By
1978, the manufacturer of DuPont’s C8, the 3M Company, had confirmed that C8 was detectable
in workers’ blood, and by 1980, DuPont confirmed it was toxic to humans, accumulated in human
bodies, and that exposure to C8 was intolerable.8 Despite the toxicity of C8, DuPont continued
using it as a processing aid.
5 See Leach v. E.I. du Pont de Nemours & Co., No. 01-C-608, 2002 WL 1270121, at *3 (W. Va. Cir. Ct.
Apr. 10, 2002) (findings of fact from Order on Class Certification).
6 See In re E. I. du Pont de Nemours & Co. C-8 Pers. Injury Litig., No. 2:13-CV-170, 2016 WL 659112, at
*1 (S.D. Ohio Feb. 17, 2016).
7 Leach, 2002 WL 1270121, at *4.
8 Id at 4.
12
DuPont began discharging PFAS, including both C8 and newer PFAS such as
hexafluoropropylene oxide dimer acid (HFPO-DA) (also known as GenX), from its vinyl ether
manufacturing process at Fayetteville Works into the Cape Fear River as early as 1980. Yet,
DuPont did not make any comprehensive report of its historical discharges or conduct any health-
based study on any of these PFAS discharged into the Cape Fear River, there is not yet a
comprehensive study of the PFAS to which Cape Fear River area residents have been exposed as
a result of the historical discharges from Fayetteville Works, and there has not yet been any study
of any epidemiological impacts caused by DuPont and Chemours.
In May of 2000, when the 3M Company announced it would stop manufacturing C8 (after
internal studies increasingly raised concerns about its biopersistence and toxicity), DuPont made
the decision to manufacture C8 at Fayetteville Works in North Carolina.9 According to DEQ’s
internal timeline of DuPont’s Clean Water Act National Pollution Discharge Elimination System
(“NPDES”) permitting changes, DuPont’s May 2001 NPDES permit application sought to permit
discharges of process wastewater containing C8 from a “new Teflon® facility” at Fayetteville
Works.10
Around the time when DuPont began manufacturing PFAS in North Carolina in 2000/2001,
a series of lawsuits were filed against DuPont to hold it accountable for contaminating a drinking
water supply in West Virginia with C8 and for causing personal and property injury as a result of
that contamination.11 The Leach case in particular involved a class action brought by a group of
individuals who alleged common law tort claims (under West Virginia law) for equitable,
injunctive, and declaratory relief, along with compensatory and punitive damages, as a result of
9 Id.
10 See Chemours NPDES Permit File Timeline, https://assets.adobe.com/public/08e2e4d7-eeca-4164-70fb-
8b9cee2d3629.
11 See Leach, 2002 WL 1270121, at *1.
13
alleged drinking water contamination. The Wood County Circuit Court certified the class in April
2002.12 After several years of litigation, the parties reached a settlement (the “Leach Settlement
Agreement”) that established a procedure to decide whether the approximately 80,000 class
members would be permitted to proceed with individual actions against DuPont based on any of
the human diseases alleged to have been caused by exposure to C8.13
The procedure required the parties to establish a Science Panel composed of three
independent epidemiologists to study whether there was a link between exposure to C8 in drinking
water (of .05 parts per billion, or 50 ppt over the course of one year) and human disease among
the Leach class.14 The Settlement Agreement contractually bound both parties to the results of the
Science Panel’s findings. Specifically, if the Science Panel issued a “Probable Link Finding”—
that is, a finding that it was more likely than not that there is a link between exposure to C8 and a
particular human disease (for class members exposed to C8 at 50 ppt over the course of one year)—
then DuPont waived its right to challenge in individual cases whether a particular Class Member’s
dose of C8 (at 50 ppt) was sufficient to be capable of causing a disease with a “Probable Link”
finding.15 “Probable Link” findings ultimately were issued for kidney cancer, testicular cancer,
thyroid disease, ulcerative colitis, diagnosed high cholesterol (hypercholesterolemia), and
pregnancy-induced hypertension and preeclampsia.16
12 Id.
13 See Class Action Settlement Agreement, Leach v E.I. du Pont de Nemours & Co. (Nov. 17, 2004) (No.
01-C-608), https://www.hpcbd.com/dupont/Settlement-Agreement.pdf.
14 See Leach Settlement Agreement §§ 2.1.1; 12.
15 In re E. I. du Pont de Nemours & Co. C-8 Pers. Injury Litig., 314 F. Supp. 3d 868, 873 (S.D. Ohio 2014)
(“If the Science Panel found that it was ‘more likely than not that there is a link between exposure to C–8
and a particular Human Disease among Class Members,’ the Panel then issued a Probable Link Finding for
that specific disease and DuPont waived its right to challenge whether ‘it is probable that exposure to C–8
is capable of causing’ the Linked Disease, i.e., general causation. ([Settlement Agreement] § 3.3).”).
16 See C8 Probable Link Reports, C8 Science Panel, http://www.c8sciencepanel.org/prob_link.html.
14
Because the Science Panel made numerous Probable Link findings, the Settlement
Agreement provided that individual class members could pursue personal injury claims
individually.17 Following several bellwether trials—first for Carla Bartlett (resulting in a $1.6
million jury verdict), and second for David Freeman (resulting in a $5.1 million jury verdict)—
DuPont and its new spin-off, Chemours, agreed to a joint global settlement of the individual
personal injury suits flowing out of the Leach settlement, to the tune of $670 million, split evenly
between DuPont and Chemours.18
DuPont was also being pursued by the U.S. Environmental Protection Agency (“EPA”) to
remediate the harmful effects of its contamination of the water supply in West Virginia. In March
2009, DuPont and the EPA reached a Consent Order (“West Virginia 2009 Consent Order”) in
which DuPont agreed to offer water treatment or bottled water to people on private or public water
systems if the level of C8 reached 40 ppt.19
In an attempt to shed future liabilities associated with C8, DuPont began searching for
replacements to C8. In 2009—shortly before it agreed to remediate water contaminated with C8
at 40 ppt—DuPont and the EPA reached a separate Consent Order under Section 2619 of the Toxic
Substances Control Act (the “2009 TSCA Consent Order”) that permitted DuPont to begin
manufacturing GenX as a replacement PFAS for C8.20 EPA noted that the scientific studies
submitted by DuPont were “insufficient to permit a reasoned evaluation” of the human health
17 See Leach Settlement Agreement § 3.3.
18 See The Chemours Company, Investor Presentation at 2, 10 (March 2017),
https://s21.q4cdn.com/411213655/files/doc_presentations/March-2017-Chemours-Investor-
Presentation.pdf.
19 See EPA Order on Consent, In the Matter of E.I. du Pont de Nemours and Company, No. SDWA-05-
2009-0001; SDWA-03-2009-0127 DS (Mar. 10, 2009), https://www.epa.gov/sites/production/files/2016-
05/documents/dupont-finalorder09.pdf.
20 See Consent Order and Determinations Supporting Consent Order, In the Matter of DuPont Company,
Premanufacture Notice Nos. P-08-508 and P-08-509 (Jan. 28, 2009), https://chemview.epa.gov/chemview/
proxy?filename=sanitized_consent_order_p_08_0508c.pdf.
15
effects of GenX, and “in light of the potential risk of human health and environmental effects,”
limited the manufacture, distribution, and disposal of the chemical.21 In particular, it was obliged
to “recover and capture (destroy) or recycle” GenX “at an overall efficiency of 99% from all
effluent process streams and . . . air emissions.”22
But as DEQ well knows, the Consent Order in this case is attributable to the fact that
DuPont and its successor, Chemours, failed to follow the EPA Order and NPDES permit it agreed
to abide by, discharging untold sums of PFAS into the Cape Fear River watershed and placing the
health and safety of affected residents at risk.
Equally problematic is the fact that Chemours is representing to local residents and the
general public that “there is no indication of any harmful health effects of PFAS at these low
levels,” with “low levels” referring to “any household with per- and polyfluoroalkyl substances
(‘PFAS’) that are (1) at or above 10 ppt for any one PFAS, or (2) at or above 70 ppt for total
PFAS.”23 It has made this representation despite agreeing specifically in the Consent Order to
conduct third party toxicity studies “informative to human health,” see Consent Order ¶ 14, despite
the fact PFAS have been found in the water supply at levels well in excess of the 50 ppt exposure
standard identified in the “probable link” findings by the Science Panel in the C8 litigation, and
despite the availability of numerous studies demonstrating the harmful health effects of GenX and
newer, second-generation PFAS.24 And the California Department of Toxic Substances Control
has reviewed emerging scientific studies on GenX and found that
21 Id. at xv, 36.
22 Id. at 36.
23 See, e.g., C3 Dimer Acid and PFAS, The Chemours Company, https://www.chemours.com/en/about-
chemours/global-reach/fayetteville-works/fayetteville-works-toxicology (last visited Feb. 26, 2020); Letter
2B to local residents, https://files.nc.gov/ncdeq/GenX/consentorder/paragraph19/Letter-2B-offering-RO-
and-Table-3-results-Over-10-ppt---represented.docx.
24 See, e.g., Melisa Gomis et al., Comparing the toxic potency in vivo of long-chain perfluoroalkyl acids
and fluorinated alternatives, 113 Environ. Int’l 1 (2018); Gloria Post et al., Key scientific issues in
16
PFECAs and shorter-chain PFAAs may have similar or higher toxic
potency than the longer-chain PFAAs they are replacing. Using a
toxicokinetic model and existing toxicity data sets, a recent study
found that PFBA, PFHxA, and PFOA have the same potency to
induce increased liver weight, whereas GenX is more potent. The
authors concluded that previous findings of lower toxicity of
fluorinated alternatives in rats were primarily due to the faster
elimination rates and lower distribution to the liver compared to
PFOA and other longer-chain PFAAs.25
Chemours’ representations that there is “no indication” of any harmful health effects of PFAS at
the Action Levels set by the Consent Order is highly misleading at best, particularly without a
disclosure or explanation that there is no indication that PFAS at the Action Levels are not harmful
to human health. Chemours should be required to make corrective disclosures to area residents
regarding the potential adverse health effects resulting from exposure to PFAS at levels in excess
of the Action Levels, and the lack of any basis to represent that there is not a risk of adverse health
effects from exposure at those levels.
Geography
As the CAP states, “The Cape Fear River is a water source for a number of communities
downstream of the Site. Raw water intakes are located at Bladen Bluffs and Kings Bluff Intake
Canals, located approximately 5 miles and 55 miles downstream from the Site, respectively.”26
developing drinking water guidelines for perfluoroalkyl acids: Contaminants of emerging concern, 15
PLoS Biol e2002855 (2017); Melissa Gomis, From emission sources to human tissues: modelling the
exposure to per- and polyfluoroalkyl substances, (2017); Nan Sheng et al., Cytotoxicity of novel fluorinated
alternatives to long chain, 92 Archives of Toxicol. 359 (2017); Melisa Gomis et al., A modeling assessment
of the physicochemical properties and environmental fate of emerging and novel per- and polyfluoroalkyl
substances, 505 Sci. of the Total Environ. 981 (2014); J.M. Rae et al., Evaluation of chronic toxicity and
carcinogenicity of ammonium 2,3,3,3- tetrafluoro-2-(heptafluoropropoxy)-propanoate in SpragueDawley
rats, 2 Toxicol. Rep. 939 (2015).
25 Product – Chemical Profile for Perfluoroalkyl and Polyfluoroalkyl Substances (PFASs) in Carpets and
Rugs at 29, California Department of Toxic Substances Control (2018).
26 CAP at xii
17
These raw water intakes supply water to the CFPUA, the BCPU, and the Pender County Utility,
among others.
The PFAS in the Fayetteville Works facility’s wells and surface water drainage features,
and found in the drinking water supplies of DRCs, originated from both Chemours and DuPont.
DuPont began discharging GenX and other PFAS into the Cape Fear River as early as 1980. Such
releases continued to occur after Chemours was spun off from DuPont in 2015.
Historically there have been three release routes of PFAS from Fayetteville Works to the
environment, and these release routes continue to impact DRCs:
1) emissions to air that have settled on more than 70-plus square miles in the Cape Fear
River watershed, and migrate into the Cape Fear River;
2) releases of process water to subsurface soil and groundwater that migrates into the Cape
Fear River; and
3) releases of process wastewater directly into the Cape Fear River.
These release pathways are now being controlled by Chemours, and as Chemours states,
they “have resulted in secondary sources of PFAS in the environment to groundwater and surface
water receptors.”27 As stated in the CAP:
Historical releases resulted in the following secondary sources of
PFAS being present in the environment:
• PFAS in unsaturated soils from aerial deposition infiltrating to
groundwater. Aerial deposition has resulted in a distributed, non-
point source of PFAS in onsite and offsite soils that represent a
secondary source to groundwater. Infiltrating rainfall has
transported these PFAS downward to groundwater.
• PFAS in soils and groundwater from Site process water releases.
Process water leaks in the manufacturing areas resulted in PFAS in
Site soil and groundwater. Based on the hydrogeology of the Site,
these PFAS are detected in the Perched Zone, Surficial Aquifer, or
27 CAP at xii.
18
Black Creek Aquifer and then migrate towards primarily the Cape
Fear River and Old Outfall 002 with some component reaching
Willis Creek.28
III. The CAP Fails to Protect Human Health
The CAP fails to protect human health, because it does nothing to address the ongoing
contamination of DRCs’ water supplies with PFAS.
To address PFAS in the environment from past (i.e., legacy) releases, the CAP developed
objectives and cleanup goals to guide the evaluation and selection of corrective actions. The CO’s
remedial and management goals for Fayetteville Works are:
• reduce the total loading of PFAS originating from the facility to the Cape Fear River
by at least 75 % from 2017 levels (CO paragraph 16);
• provide whole-building filtration units and RO units to qualifying surrounding
residents with water exceeding the 10/70 Action Levels (CO paragraphs 19 and 20);
• comply with 15A NCAC 02L .0103 (“2L Rules”) (CO paragraph 16), including
following the policy for the intention of the 2L Rules “to maintain and preserve the
quality of the groundwaters, prevent and abate pollution and contamination of the water
of the state, protect public health, and permit management of the groundwaters for their
best usage by the citizens of North Carolina”; and
• comply with other requirements of the CO.29
However, nowhere in the CAP does Chemours comply with the 2L Rules, including following the
policy for the intention of the 2L Rules to “prevent and abate pollution and contamination” of the
Cape Fear River so that is safe for consumption by the DRCs.
28 CAP at 19-20.
29 CAP at 48.
19
A. DRC Sampling Results.
DRCs’ water remains contaminated with PFAS approximately two years after Chemours
ceased discharging PFAS directly into the Cape Fear River watershed via Outfall 002.
In August and October 2019, Plaintiffs’ counsel collected and analyzed samples from 36
residences in Bladen, Brunswick, Columbus, Cumberland, New Hanover, and Pender Counties.
Samples were collected from residences serviced by private well water and municipal water. Most
of the residences that were sampled are serviced by municipal water providers including the
CFPUA and the BCPU. All residences were sampled for PFAS listed in Attachment C to the
Consent Order filed in State of North Carolina, ex rel., Michael S. Regan, Secretary, North
Carolina Dept. of Envtl. Quality v. The Chemours Company FC, LLC, No. 17 CVS 580.30 The
results are summarized in the spreadsheet attached as Appendix A.
Twenty-seven (27) residences serviced by municipal water providers including the CFPUA
and BCPU were sampled in Brunswick, Columbus, New Hanover, and Pender Counties. The
samples were collected from either the tap or water heaters of the residences.
All samples collected from the taps of these residences had contaminant concentrations
exceeding the threshold for installation of RO systems pursuant to Paragraph 20 of the CO; every
single sample had PFAS concentrations exceeding the 10/70 Action Levels. It is important to
recognize that the residents serviced by municipal water exceeding the Paragraph 20 criteria are
drinking water that has already been treated by the municipal water providers. Further, these
residences are contaminated two years after Chemours purportedly ceased its discharge from
Outfall 002.
30 Samples collected in June 2018 and March 2019 were analyzed in accordance with EPA Method 537 and
samples collected in August 2019 and October 2019 were analyzed in accordance with EPA Method 537.1.
All analysis was conducted by GEL Laboratories, LLC (Charleston, SC).
20
IV. The CAP Fails to Provide Adequate Plans to Remediate PFAS Contamination
The CAP fails to provide adequate plans and proposals to remediate ongoing PFAS
contamination in order to protect DRCs. In some instances, Chemours offers no solution to a major
source of continuing PFAS contamination (from aerial depositions outside Fayetteville Works),
and in others offers proposals that are so tentative and under-investigated as to provide no
assurance of any remedial efficacy at all. Nowhere in the CAP has Chemours calculated how long
the Cape Fear River will continue to be impacted by PFAS migrating from the Cape Fear River
watershed or the seeps at and near Fayetteville Works. Nor has Chemours determined how long
the DRCs’ water will continue to exceed the 10/70 Action Levels. Given the absence of such
critical information, it is safe to assume that Chemours knows that the river and the DRC water
supplies will be exceeded for decades, if not indefinitely.
Three major flaws are highlighted in the subsections that follow.
A. The CAP Proposes No Reduction in PFAS Loadings to the Cape Fear
River from Aerial Deposition on the Cape Fear River Watershed and
Consequently PFAS Will Continue to Impact the DRCs for an
Indefinite Time Until RO Systems Are Installed.
The CAP proposes no reduction in PFAS loadings to the Cape Fear River from aerial
deposition on the Cape Fear River watershed. As a result, PFAS will continue to impact the DRCs
for an indefinite time unless and until RO systems are installed.
Aerial depositions of PFAS are a substantial source of ongoing PFAS contamination. In
addition to PFAS being discharged directly into the Cape Fear River from outfalls and groundwater
seeps at and near Fayetteville Works, Chemours also discharged PFAS into the air from its process
operations. These PFAS then settled on the surrounding land within the Cape Fear River
21
watershed. As stated in the CAP, “the aerial PFAS signature [sic] are diffuse, at lower
concentrations over a 70+ square mile area. . . ”31
PFAS deposition on land makes its way into groundwater. As the CAP itself states,
“Historical releases resulted in . . . PFAS in unsaturated soils from aerial deposition infiltrating to
groundwater. Aerial deposition has resulted in a distributed, non-point source of PFAS in onsite
and offsite soils that represent a secondary source to groundwater. Infiltrating rainfall has
transported these PFAS downward to groundwater.”32 Below is a diagram from the CAP
showing, with blue dots, the location of groundwater contamination—detected to date—caused by
the vertical migration of PFAS from aerial deposition on the surface down to the groundwater
below:
31 CAP at 23 (emphasis added).
32 CAP at 19 (emphasis added).
22
Source: CAP at 24.
The contribution of these PFAS from aerial deposition on the Cape Fear River watershed
over such a large area means that the PFAS which has now migrated vertically into the
groundwater will continue to be discharged from the groundwater and over-land flow into the Cape
Fear River for years to come.
The CAP acknowledges that, at a minimum, the deposition of PFAS-contaminated air
emissions from Fayetteville Works have reached and contaminated soil and groundwater over 70
23
square miles.33 This is a low estimate. Groundwater samples from an offsite drinking water well
approximately 9.3 miles away from the Fayetteville Works facility (Well Cumberland-1D) tested
positive for GenX.34 35 Therefore, the areal extent of PFAS impacts to soil and groundwater is at
least 272 square miles (using the 9.3 mile distance from the facility to the contaminated well as
the radius).36
Although Chemours maintains that it has reduced loadings to the environment over the last
two years, it has taken at best nominal measures to abate the thousands of pounds, if not tons of
PFAS already emitted into the air. For example, Chemours admits that its air emissions likely
contained 5 tons per year of HFPO-DA (GenX): “Air emission reductions to date, on an annualized
basis for 2019, have resulted in an estimated yearly reduction of 2,150 pounds of HFPO-DA, a
greater than 93% reduction.”37 Chemours has provided no information on the amount of other
PFAS that was emitted into the air over the years and settled on the Cape Fear River watershed.
The PFAS deposited on the soil have already migrated a significant downward distance to
the underlying groundwater. Although discontinuous is some areas, there is a subsurface confining
layer of lower permeability silty or sandy clay that separates the surficial, shallow aquifer from a
more extensive, deeper aquifer.38 For example, offsite Well Bladen-2D was screened at 70 to 75
feet below the ground surface in the more extensive, deeper Black Creek Aquifer.39 Groundwater
samples from this well are contaminated with GenX and other PFAS.40 This and many other of the
33 CAP at xii, xvi, 23, 56, 57 and 76; and Table 4.
34 CAP at App. A – On and Offsite Assessment Tables, Table A 9-4.
35 CAP at App. A – On and Offsite Assessment Tables, Figure A4-2B. Chemours incorrectly shows on this
figure that samples from Well Cumberland-1D contains < 3.8 ng/L of GenX. Samples from this well
actually contain up to 5 ng/L of GenX; see Table A 9-4.
36 9.32 x π = 271.
37 CAP at 29.
38 CAP at 11.
39 CAP at App. A – On and Offsite Assessment Tables, Table A 6-3.
40 CAP at App. A – On and Offsite Assessment Tables, Table A 9-4.
24
deep on- and offsite wells were screened in the Black Creek Aquifer.41 This aquifer is composed
of high permeability fine to medium sand.42 This aquifer is hydraulically connected to the Cape
Fear River,43 and groundwater in this aquifer can flow toward the Cape Fear River at 28.0 feet per
day.44
Rather than address this extensive source of contamination, Chemours has thrown up its
hands: Chemours plainly believes that it simply may never be possible to remediate the PFAS that
has been deposited on the surface—and migrated through the groundwater—into the Cape Fear
River. In the CAP, it maintains that:
The technical and economic infeasibility of Table 3+ PFAS
remediation is driven by two factors, (a) the large areal extent PFAS
are detected and (b) the lack of remedial technologies that are
effective over large areas and effectively destroy PFAS mass in-situ
at a technically achievable and affordable scale. To date Table 3+
PFAS have been detected over an area of 70+ square miles (over
45,000 acres). The size of the area encompasses hundreds of
private land parcels and any remedial construction activities using
currently available remedial technologies (excavation and
groundwater extraction) would be very disruptive to the local
community and this disruption would continue for a lengthy
period of time. Any remedy which in principle could help make
progress towards PQLs over this large area would cost in the
billions to tens of billions of dollars. . . . Additionally, there are no
currently available remedies that are expected to be able to meet
PQLs over an area this large.”45
Simply put, Chemours is proposing no measures to remediate the 70+ square miles of
historic PFAS contamination that has percolated down into the groundwater and remains a source
of contaminant loading to the river.
41 CAP at App. A – On and Offsite Assessment Tables, Table A 6-3.
42 CAP at 11.
43 CAP at 12 and 70.
44 CAP at App. A – On and Offsite Assessment Tables, Table A 6-4.
45 CAP at 56.
25
To avoid taking any measures to remediate this contamination, Chemours has simply said,
first, that it is not technologically and economically feasible, and second, that its Human Health
Screening Level Exposure Assessment (HH-SLEA) and Ecological Assessment show that there is
no need to do anything to remedy these harms.
Chemours is wrong. Not only are its assessments flawed, see Section V below, but it is
clear that these sources of contamination continue to contaminate the Cape Fear River water
supply and, as a result, the homes of DRCs. What Chemours has not addressed is the
technological and economic feasibility of installing RO systems for DRCs. And it is clear that, in
fact, the only means of protecting these DRCs is to provide them with RO systems.
B. Remediation of the Groundwater Seeps at Fayetteville Works Will Also
Span an Indefinite Timeframe Further Necessitating the Installation of
RO Systems at the DRCs.
Unlike the offsite aerial depositions discussed above, Chemours has agreed to engage in
some remedial measures to clean up PFAS at its own Fayetteville Works facility. But as explained
below, these measures are highly speculative, unlikely to work, and are projected to extend over a
long period of time. Because this source of PFAS contamination will continue to affect DRCs for
the foreseeable future, there is all the more need to protect DRCs by installing RO systems now.
The CAP presents nine purported remedial actions and two interim actions for discharges
at and near Fayetteville Works including groundwater seeps, Willis Creek, Georgia Branch Creek
and Old Outfall 002. The overall schedule for implementation and expected reductions are shown
below in Table ES2.
26
Source: CAP at xix.
As can be seen from Table ES2, many of these 11 actions have merely “planned action
implementation period[s],” or “time periods for contingent actions” with no definitive end dates—
and will take an indeterminate amount of time.46 In fact, the only remedial measures that have been
implemented—namely, Air Abatement Controls and Thermal Oxidizer, and Conveyance and
Capture Sediment Removal—collectively mitigates less than a 2% reduction in loadings to the
Cape Fear River.47
Even longer time frames are indicated in Consent Order Table 10 (site cleanup goals), in
which many items have planning periods and contingency periods that extend beyond 5 years:
46 CAP at xvii.
47 CAP at 33, Table 7.
27
28
Source: CAP at 53, et seq.
Even worse, the CAP couches much of its language about the efficacy of its remedial plans
in highly tentative language filled with caveats and escape hatches.
For instance, according to the CAP, the full extent of offsite PFAS contamination
originating from Fayetteville Works is still being investigated.48 Chemours acknowledges that
extensive investigations and design adaptations will be necessary before contamination can be
remediated.
As another example, Chemours states that before groundwater discharges to the Cape Fear
River can be addressed, it must “proceed in developing the detailed design, including collection
of extensive pre-design data, for a long-term groundwater containment approach.”49 Chemours
continues:
Extensive investigation, analysis, and numerical model
refinement would be required to properly design a remedy of this
scale. A geotechnical investigation would be required along the
alignment (anticipated boring frequency every 100 linear feet) to
48 CAP at 34, Sec. 4.1.1.
49 CAP at xvii.
29
determine the depth and penetration resistance of the confining unit.
Additional delineation consisting of borings, wells, and in-river flux
analyses may also be utilized to properly target the optimal areas for
containment needed to achieve the corrective action objectives.
Finally, pilot testing, consisting of extraction well drilling and
aquifer testing at multiple locations along the alignment, would be
performed to determine the optimal well spacing and extraction
rates. It is anticipated that in the course of two years, these activities
would allow for model refinement and completion of design and
permitting effort. In the absence of this pre-design data, the
following discussion of a long-term groundwater remedy is still
highly conceptual.50
The CAP is replete with other examples of Chemours’ signaling that its remediation plans
are indefinite and will take a long time. The CAP proposes both short term interim remedial
measures and long-term remedial alternatives, but both types of measures have long time horizons.
As an example, the long-term remedial alternative for Black Creek Aquifer consists of the
construction, operation and maintenance of a barrier wall and groundwater capture. But Chemours
proposes no deadline for this proposal. As another example, the “interim remedial alternative
advanced for groundwater consists of installing submersible electric pumps in seven existing Black
Creek monitoring wells and pumping the water to the OOF2 treatment plant for treatment and
discharge.”51 Chemours estimates that this interim remedial measure will take two years to
complete.
Critically, Chemours states openly that it has no estimated time for completion of this
remedy: “The schedule for implementation of a groundwater remedy is included in Section 6.5 of
this document; the pre-design investigation through detailed design and permitting is expected to
take two years. At the conclusion of the effort, Chemours would present a detailed onsite remedial
design to DEQ for approval.”52
50 CAP at 71.
51 CAP at 70.
52 CAP at 75
30
Even more problematic than the extended timeline is that these proposed remedial actions
are unlikely to be effective. As an example, the CAP proposes an interim action of extracting
groundwater from existing monitoring wells screened in the Black Creek Aquifer—which has one
of the largest PFAS loading contributions to the Cape Fear River—and treatment prior to
discharge. As an interim remedial approach, Chemours proposes to place small submersible pumps
in seven existing onsite groundwater monitoring wells. In an effort to capture a small portion of
the PFAS-contaminated groundwater before it reaches the Cape Fear River, these wells would be
pumped at a total of 14 gallons per minute (gpm).53 Following DEQ’s approval of the CAP,
Chemours expects it will take 12 months to install and operate these small submersible pumps.
The operation of these pumps would be monitored for another 12 months. These two years are
considered by Chemours to be a “contingent action” and apparently could be modified or
discontinued if the pumps do not operate appropriately.54 Regardless, this interim remedial
approach or contingent action is unlikely to measurably mitigate the discharge of PFAS-
contaminated groundwater to the Cape Fear River. Chemours’ own analysis states that a series of
purpose-built extraction wells spaced at 50-foot intervals near the Cape Fear River would have to
pump at least 4,430 gpm to effectively remediate PFAS contamination.55 This groundwater
pumping rate is 317-times higher than Chemours’ proposed interim measure of 14 gpm. The
contrast between Chemours’ plan and the reality of its implementation is highlighted in the table
below:
Pumping Rate Needed to
Remediate PFAS
Pumping Rate Proposed
by Chemours
4,430 gallons per minute 14 gallons per minute
53 CAP at 70.
54 CAP at Table 13.
55 CAP at Table 8.
31
With respect to long-term permanent remedial measures, in an effort to downplay
Chemours’ commitment to effectively remediate onsite contamination, the CAP states openly that
the efficacy of a long-term remedy is simply uncertain:
The corrective actions proposed in this CAP will be refined over time
as both remedial technologies and understanding advance. PFAS are
an emerging class of contaminant, with the Table 3+ PFAS present
at the Site from this facility one of the newer sets of PFAS being
examined by the remediation industry. The state of knowledge
regarding the fate and transport properties, toxicological
characteristics, and potential remedial approaches for PFAS and
Table 3+ PFAS are continuing to evolve and advance.56
In addition, the CAP also states openly that the time horizon for remediation is highly
uncertain:
Extensive investigation, analysis, and numerical model refinement
would be required to properly design a remedy of this scale, including
but not limited to geotechnical borings, contamination distribution
investigations, in-river flux analyses, and pilot testing. It is
anticipated that in the course of two years, these activities would
allow for model refinement and completion of the design and
permitting effort. In the absence of this data, the proposed long-
term groundwater remedy is still highly conceptual, and it is not
presently possible to conclude with confidence whether this
alternative is economically feasible. At the conclusion of the PDI,
Chemours will either present a detailed onsite remedial design or a
remedial alternative to DEQ for approval . . .57
In other words, even though the Consent Order required concrete plans for remedial action,
Chemours has effectively said: more studies are needed, and, even if we conduct them, there’s no
guarantee they will be technically or economically feasible.
Most alarming, however, is Chemours’ suggestion that it should not be held to the 2L Rules
at all. Specifically, the CAP states that “NCDEQ and Chemours may need to consider alternate
cleanup standards conceived under 15A NCAC 02L .0106 (a) and (i) together and 15A NCAC
56 CAP at 1.
57 CAP at xvii.
32
02L .0106 (k) individually or risk-based remediation as described by N.C.G.S. § 130A-310.66 et
seq.”58 Chemours suggests rewriting the Consent Order rather than complying with its obligations
to protect public health, as required by the 2L Rules and the Consent Order. In short, Chemours
is reserving its rights to never restore the Cape Fear River to levels that will protect the DRCs.
In light of Chemours’ sidestepping of its responsibilities under the Consent Order—and the
tenuousness of the proposals made in the CAP—the only method to protect the DRCs in the short
and foreseeable future is for them to be provided with RO units.
There is also no certainty that total loadings from groundwater into the Cape Fear River
will decrease within a certain timeframe. That is, there is no definitive decreasing trend in PFAS-
contaminated water reaching the Cape Fear River. For example, PFAS-contaminated surface water
is present in Georgia Branch Creek, which discharges to the Cape Fear River. For example, while
“Total Table 3+ PFAS concentrations from wells PW-02 and PW-14 were approximately 100
times lower in the resampled results compared to the original samples (15,000,000 to 140,000 ng/L
and 18,000,000 to 160,000 ng/L respectively),”59 there is no indication that the purported decrease
is due to factors outside of chemical loadings, such as dilution from increased groundwater flowage
rates and volumes.
Chemours also has not evaluated whether the decrease is asymptotic and will reach a
plateau which still contributes extensive loadings to the Cape Fear River—in other words,
Chemours has provided no analysis of whether PFAS reductions have stabilized and are likely to
decrease only nominally over time, or whether PFAS reductions will follow a downward trend.
Indeed, Chemours has not even attempted to conduct this analysis at all. Accordingly, all that
Chemours can offer is that “The concentrations in these wells will continue to be monitored as part
58 CAP at xvi.
59 CAP at 20.
33
of monitoring plan activities described in Section 7.”60 As another example, according to the CAP,
in some instances, the concentration of PFAS in monitoring wells is actually increasing with time.
As stated in the CAP, “Total Table 3+ PFAS concentrations for wells PIW-7S and PW-06
following redevelopment and resampling were greater than previous results. For example, total
Table 3+ PFAS concentrations for well PW-06 increased from 3,000 ng/L to 4,400 ng/L while
well PIW-7S increased from 17,000 ng/L to 54,000 ng/L.”61
There is also no certainty that total loadings from groundwater into the Cape Fear River
will decrease with distance from Fayetteville Works. As stated in the CAP:
Onsite there are four seep features with channelized flow that enter
the Cape Fear River. In October 2019, ten offsite groundwater seeps
- the Lock and Dam Seep and Seeps E to M - were identified on the
west bank of the Cape Fear River to the south of the Site. The seeps
were identified by performing a visual survey from a boat on the
western side of the Cape Fear River between Old Outfall 002 and
Georgia Branch Creek. Flow from these seeps ranged from seeping
water from an embankment (i.e. trickles) to a visible small stream in
one of the seeps. Results from samples collected from the seeps
indicate Total Table 3+ PFAS concentrations ranged between 2,600
to 6,800 ng/L. The seven southernmost seeps (G to M) had similar
concentrations to the mouth of Georgia Branch Creek sampled
in September (2,100 ng/L).62
Chemours incorrectly states that there is a decreasing trend in PFAS concentrations while moving
southward toward Georgia Branch Creek.63 Although the first few seeps near the Old Outfall 002
(i.e., Seeps E to G) do exhibit higher PFAS concentrations (average 1,000 ng/L of GenX), all of
60 CAP at 20.
61 CAP at 21.
62 CAP at 21.
63 CAP at App. D – Southwestern Offsite Seeps Assessment, Offsite Seeps Assessment Memo, December
31, 2019, at 3.
34
the next six downstream seeps over the next 0.6 miles exhibit similar PFAS concentrations
(average 572 ng/l GenX).64
Further, although the ongoing discharge of PFAS-containing water from Outfall 002 has
been reduced, the outfall is still providing about 5 percent of the mass-loading to surface water in
the adjacent Cape Fear River. And the concentration of GenX and other PFAS in samples collected
from Outfall 002 remain elevated.
Figure 1. GenX Concentrations in Samples Collected from Outfall 002 at Chemours
Fayetteville Works.
Source: GenX Surface Water Sampling Sites, North Carolina Department of Environmental
Quality, https://deq.nc.gov/news/key-issues/genx-investigation/genx-surface-water-sampling-
sites, last visited Jan. 25, 2020.
64 CAP at App. D – Southwestern Offsite Seeps Assessment, Offsite Seeps Assessment Memo, December
31, 2019, at Table 1 and Figure 2.
35
The CAP makes the completely unsupported statement that PFAS contamination will
naturally reduce over time, stating, “While other media were not identified as significantly
contributing to overall intake, human exposure to PFAS in all environmental media will continue
to decrease over time as a result of Facility air emissions reductions.”65 However, Chemours has
provided no analytic data, statistics, calculations or regression analyses to support this
conclusion. In fact, as discussed elsewhere throughout these comments, it is likely that the
reservoirs of PFAS existing in soil, groundwater and discharges throughout the Cape Fear River
watershed will discharge into the Cape Fear River and be consumed by the DRCs for years if not
decades to come. Conversely, according to the CAP, “Table 3+ PFAS are not expected to degrade
in a reasonable time period in the environment, and therefore this is not a mechanism that will
support concentration reductions.”66 In short, the CAP states: “Based on professional opinion the
costs for on and offsite remediation to PQLs would exceed billions to potentially tens of billions
of dollars and the timeframe would be on the order of multiple decades.”67 (emphasis added)
Once again, Chemours’ inability to remediate the Cape Fear River within any given
timeframe means that DRCs will be exposed to PFAS unless they are provided with RO systems.
The DRCs simply cannot wait until Chemours eventually—if ever—effectively implements these
permanent remedial measures. In the meantime, the DRCs should be provided with RO systems
and bottled water. This solution is both economically and technologically feasible, and DEQ
should order it pursuant to Chemours’ obligations under the CO.
65 CAP at 38.
66 CAP at 58.
67 CAP at 58.
36
C. The Differing Rates of PFAS Migration Through Air, Soil,
Groundwater, Sediment and River Water Means That PFAS Will
Reach the DRCs Not as a Single “Slug” but Rather over Many Years.
The differing rates of PFAS migration through air, soil, groundwater, sediment, and river
water means that PFAS will reach the DRCs not as a single “slug” but rather gradually over many
years. In lay terms, each PFAS has a different “stickiness” coefficient, meaning that although some
PFAS adhere strongly to surfaces, others are less adherent. The technical term for this is
“retardation.” Chemours neglects to consider these disparate migration rates.
To explain their variations, Section 3.2 of the CAP provides a description of the physical
and chemical properties of Table 3+ PFAS found in the air, soil, groundwater, sediment, and river
water and their fate and transport. This table makes clear that PFAS will continue to reach DRCs
for an indefinite amount of time due to the differing retardation rates for different PFAS. Pursuant
to CO Paragraph 27, Chemours funded a study analyzing the fate and transport characteristics of
identified PFAS compounds originating from Fayetteville Works in air, surface water, and
groundwater.68 The findings of this study establish that although many of the Attachment C PFAS
are highly mobile (which explains why they will continue to migrate from and near Fayetteville
Works to the municipal water intakes), some of the other Attachment C PFAS are less mobile and
thus will continue to be released and reach the intakes for years to come.
Section 3.2 of the CAP summarizes the PFAS values for the octanol-water partition
coefficient (Kow), organic carbon-water partition coefficient (Koc), and surface tension of water,
which determine the propensity and degree to which PFAS bind to organic carbon in the soil,
groundwater, sediment, and river water:
Generally, Table 3+ PFAS are expected to be mobile in the
environment given the presence of charged head groups and ether
68 Geosyntec, 2019c. Site Associated PFAS Fate and Transport Study Pursuant to Consent Order Paragraph
27 (June 24, 2019).
37
bonds, but they will experience some retardation due to sorption to
soils. For some Table 3+ PFAS, mobility may be enhanced relative
to straight-chain, non-ether PFAS by their branched structure and the
presence of two charged head groups. The mobility of the Table 3+
PFAS will be retarded by various chemical processes but will likely
have lower retardation than long-chain PFAS without ether bonds.
Chemical processes expected to have the most impact on mobility are
sorption to naturally occurring organic carbon in soil and, in the
unsaturated soil zone, preferential partitioning to the air-water
interface.69
The CAP continues, “Kow is a standard parameter used for estimating bioconcentration
factors. . . Other mechanisms of sorption can also include the potential for PFAS, including Table
3+ compounds to bioaccumulate in organisms.”70
Finally, Chemours’ Table 2 demonstrates that PFAS has differing “Measured Log Kow and
Calculated Log Koc Values” which indicates that Chemours’ PFAS will reach the DRCs over an
extended period of time.
69 CAP at 13.
70 CAP at 14.
38
Source: CAP at 15.
Thus, Chemours itself admits that different PFAS will be transported at different rates due
to different retardation factors. As provided in the CAP, “The retardation factor estimates suggest
in the saturated zone approximately half of the Table 3+ PFAS will experience minimal
retardation where travel times will be similar to groundwater travel times; i.e., factors were close
to 1.”71 The remaining half will experience a wide array of travel times with many likely taking
years to reach the DRCs’ water supply.
71 CAP at 28.
39
This means that different PFAS, traveling at different speeds, will continue to impact the
water consumed by the DRCs at differing times for years if not decades to come. The only means
to protect the DRCs during this extended time period is to provide them with RO systems.
V. The CAP Fails to Provide an Adequate, Scientifically Sound, and Unbiased
Risk Assessment as Required by CO Paragraph 14.
Chemours has yet to properly quantify the risks of PFAS exposure to DRCs and all other
individuals affected by Chemours’ contamination. In particular, Chemours has failed to comply
with CO Paragraph 14’s requirement to establish that Attachments B and C PFAS do not pose an
unacceptable risk to human health. And more importantly, because there is no basis to conclude
that consumption of water contaminated with Attachment C PFAS at levels in excess of the Action
Levels does not pose an unacceptable risk to human health, Chemours must provide the DRCs
with RO systems and bottled water while an evaluation of the health risks and toxicity values is
being executed.
Chemours’ toxicity assessment found in Appendix F to the CAP, also referred to as the
HH-SLEA, contains numerous errors and underestimates risks to human health. In particular,
Chemours has yet to properly quantify the risks of PFAS exposure to DRCs and all other
individuals affected by Chemours’ contamination. Chemours fails to calculate toxicity values (and
risks) for 19 out of 20 PFAS, focusing all of its efforts on GenX, the one PFAS for which DuPont
and Chemours have produced at least some toxicity evaluations. In addition to Chemours’
complete failure to assess toxicity for most of the chemicals at issue (or the interplay between those
chemicals amongst one another and with legacy PFAS contamination that remains in area
residents’ bodies), Chemours’ analysis fails to (a) follow standard EPA guidance for deriving
toxicity values; (b) adequately address the past decade of scientific literature on GenX’s toxicity;
40
(c) properly weigh and account for the toxicity and human health risks of GenX, including
immunotoxicity; and (d) account for all necessary risks and toxicity information associated with
drinking contaminated water. Chemours also manipulates its conclusions by making improper and
scientifically unsound assumptions that mask the true risks associated with drinking PFAS-
contaminated water and fail to account for exposure risks to sensitive subpopulations.
Incredibly, Chemours also fails to address its own data, identified in its TSCA Section 8(e)
submissions, demonstrating that GenX-induced toxic effects include liver toxicity (e.g.,
hypertrophy, single-cell necrosis, peroxisome proliferation, and increased liver weight relative to
body weight), hematological effects (e.g., decreased red blood cell count, hemoglobin, and
hematocrit), kidney toxicity (e.g., increased kidney weight, necrosis, and hyperplasia),
developmental effects (e.g., body weight changes), immune effects (e.g., T cell-dependent
antibody response [TDAR] suppression and lymphocyte increases), and suggestive evidence of
tumor formation (e.g., liver and pancreatic acinar cell tumors).72 Yet the HH-SLEA fails to address
any of these impacts.
Chemours’ deeply flawed HH-SLEA purports to quantify the risks of exposure of offsite
human receptors to 20 PFAS listed in Table 3+ of the HH-SLEA (only one of which is GenX) but
not the synergistic effect of these chemicals upon one another (or indeed other PFAS and chemicals
found in the DRCs’ tap water) or together with PFAS (including PFOS and PFOA) that have
bioaccumulated in residents’ bodies as a result of DuPont’s and Chemours’ historical
contamination of the water supply. The HH-SLEA purports to quantify exposures of offsite human
receptors to released PFAS for several receptor-exposure scenarios, and to provide a provisional
72 Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium
Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as ‘GenX Chemicals’, EPA-823-P-18-001
Public Comment Draft at 47, U.S. EPA (Nov. 2018), https://www.epa.gov/sites/production/files/2018-
11/documents/genx_public_comment_draft_toxicity_assessment_nov2018-508.pdf.
41
human health hazard characterization for GenX (HFPO-DA) based on quantified intakes and the
North Carolina Department of Health and Human Services (“DHHS”) 2017 draft oral reference
dose (RfDo).
The HH-SLEA violates fundamental, generally accepted principles of toxicology and risk-
assessment practice and ignores standard regulatory guidance, as the below subsections make
clear.
First, Chemours fails to calculate toxicity values (and risks) for 19 out of 20 PFAS listed
in Table 3+, focusing all of its efforts on GenX, the one PFAS for which DuPont and Chemours
have produced at least some toxicity evaluations.73
Second, even setting aside Chemours’ failure to adequately analyze the toxicity of 95% of
the PFAS listed in Table 3+, Chemours’ analysis itself is deeply flawed, including by its failure to
(a) follow standard EPA guidance for deriving toxicity values; (b) adequately address the past
decade of scientific literature on GenX’s toxicity; (c) properly weigh and account for the toxicity
and human health risks of GenX, including immunotoxicity and potential carcinogenicity; and (d)
account for all necessary risks and toxicity information associated with drinking contaminated
water.
Third, Chemours also manipulates its conclusions by making improper and scientifically
unsound assumptions that mask the true risks associated with drinking PFAS-contaminated water.
Fourth, Chemours fails to consider its own studies prepared pursuant to its consent decree
with the EPA pursuant to Section 8(e) of TSCA.
Fifth, Chemours’ methodological flaws are underscored by its failure to account for
exposure risks to sensitive subpopulations.
73 CAP at xv; Section 4.2.
42
A. The HH-SLEA Violates Generally Accepted Principles of Toxicology
and Risk-Assessment and Ignores Standard Regulatory Guidance.
The CAP and HH-SLEA provide an insufficient analysis of the toxicity associated with
both GenX exposures and exposure to the other 19 PFAS. Chemours has also failed to account for
the synergistic effects of the 19 PFAS—as well as other contaminants in the DRCs’ water supply
and, critically, with PFOS, PFOA and other legacy PFAS that remain in residents’ blood as a result
of historical contamination of the water supply by DuPont and Chemours, as was found in the
blood samples taken as a part of the GenX Exposure Study. The HH-SLEA does not meet generally
accepted standards of toxicology and risk assessment. Considerable and fundamental efforts must
be made to conduct adequate toxicity studies to reduce the uncertainty in the current GenX
toxicological database, and Chemours must also conduct the necessary toxicity studies to derive
toxicity values for the 19 PFAS compounds listed in Table 3+ for which no toxicity information
is presented in the CAP or HH-SLEA. In the meantime, Chemours must provide the DRCs with
bottled water and RO systems because as admitted by Chemours in the CAP, “supplying whole
building filtration systems and reverse osmosis units for qualifying residents offsite reduces
HFPO-DA (and Table 3+ PFAS) intake by over 92%, ensuring human receptor exposures remain
below hazard limits for HFPO-DA, based on the NC DHHS draft RfDo.”74
1. Chemours fails to calculate toxicity values (and risks) for 19 out
of 20 PFAS listed in Table 3+, focusing all of its efforts on GenX,
the one PFAS for which DuPont and Chemours have produced
at least some toxicity evaluations.75
The HH-SLEA provides little information regarding actual human health risks. This is
because, although the 20 PFAS contaminants listed in Table 3+ have been identified, Chemours
74 CAP at xv.
75 CAP at xv; Section 4.2.
43
has only presented toxicity information and data for a single PFAS (GenX), while omitting any
such information for the other 19, despite the fact that thousands of North Carolina residents have
been drinking water contaminated with these PFAS for years if not decades. Chemours appears to
dismiss the absence of toxicity data for these 19 PFAS compounds listed in Table 3+ as
unimportant; however, it is likely one or more of them, alone or in the combinations present in
area drinking water, may be shown to be even more toxic than GenX alone. For this reason, the
HH-SLEA does not even meet the standard of a screening risk assessment. Chemours’ conclusions
about the risks of drinking water contaminated with GenX and other PFAS are incorrect and
grossly underestimate the risks of such exposure, including the fact that Chemours fails to
differentiate between the hazard of being exposed to a single PFAS versus the hazards associated
with exposure to multiple PFAS at the same time (i.e., the combined effect of PFAS exposure) and
with introducing additional PFAS into the blood of residents who already have accumulated PFOS,
PFOA, and other PFAS in their blood.
In its HH-SLEA, Chemours states that the calculated hazard quotients, or “HQs,” were
“less than 1 for residents, farmers, and gardeners exposed to soil, produce, and well water in
exposure unit (“EU”) 1 through EU 12, indicating potential HFPO-DA exposure is unlikely to
pose a hazard, even in the absence of drinking water treatment.”76
This conclusion—of a HQ for GenX of less than 1—is wholly unsupported for the simple
reason that Chemours has yet to derive any toxicity values for 19 of the 20 PFAS listed in Table
3+. And even accepting the existence of some toxicity values for GenX, significant uncertainty
exists even as to that data. By its own admission, Chemours states that the toxicity data—which
was taken from DuPont’s 2010 EPA TSCA Section 8(e) filing—may well underestimate GenX’s
76 CAP at Section 4.2.4.
44
risks because (1) the studies are outdated; (2) they are based only on liver pathology (when the
immune system is likely a more sensitive target organ); (3) there is no human data; and (4) toxicity
was based on subchronic rather than chronic animal studies. Chemours states:
Toxicity Data. The SLEA provisional hazard characterization is
based on the HFPO-DA RfDo of 1E-04 mg/kg-day adopted by the
NC DHHS, which is predicated on liver toxicity endpoints from two
subchronic studies in mice. There is inherent uncertainty in the use
of animal toxicity data to characterize potential human health
hazards and the RfDo could potentially change as new information
becomes available. (emphasis added)77
Chemours’ statement both (a) acknowledges that the current value could potentially change
as “new information becomes available,” and (b) that Chemours intends to wait for other entities
to generate new toxicity information (RfD) for GenX.78 Chemours is responsible for GenX
pollution, and should be responsible for funding the independent studies needed to generate “new”
toxicity information.
Chemours also downplays the impact of the lack of toxicity information for the 19 other
PFAS compounds listed in Table 3+ by referring to it as mere “uncertainty”:
In addition to the uncertainty associated with the HFPO-DA RfDo,
the lack of toxicity information for other Table 3+ PFAS also
introduces uncertainty to the HH-SLEA but data are not available to
evaluate the potential effect, if any, on the conclusions [of the]
hazard characterization [sic].79
With regard to the “screening” levels of GenX, Chemours also insinuates that a 10 ppt
GenX level in drinking water is “safe” because it is based on an agreement:
[Hazard Quotient] estimates based on an assumption of 10 ng/L of
HFPO-DA in drinking water, which is the maximum concentration
in well water that would not require a treatment system, range from
77 CAP at 39.
78 Id. at 39.
79 Id. at 39-40.
45
0.003 to 0.07 and, hence are more than an order of magnitude below
a level of concern (unity or 1).80
Although an agreement of treatment may have been reached with the State, a drinking
water level of 10 ppt for GenX may be insufficiently protective of human health. For example, the
Natural Resources Defense Council (“NRDC”) conducted an independent analysis to calculate the
“safe” concentration of GenX in drinking water and concluded the level should be less than 1 ppt.
This is 10 times less than the current 10/70 Action Level for GenX. Furthermore, the NRDC’s
analysis was based on DuPont’s 2010 TSCA Section 8(e) and toxicity studies:
If uncertainty factors that properly reflected the deficiencies in
toxicity data (database, sub-chronic to chronic, children’s
vulnerability, human variability, animal to human differences) were
used, the combined uncertainty factor could be as high as 100,000,
which would result in a MCLG of less than 1 ppt for GenX
chemicals (see Appendix F for calculations). This highlights the
current considerable level of uncertainty in determining a safe level
of exposure for GenX chemicals.81
The last point underscores the importance of summing health risks when multiple
contaminants are present in drinking water, as set forth in the EPA’s risk assessment guidance and
generally accepted toxicology practice.82 Chemours’ assumption that a GenX concentration in
drinking water is safe is based on an underlying (incorrect) assumption that GenX is the only PFAS
contaminant to which a population is exposed. When there are multiple contaminants, the EPA
requires further reductions in screening risk assessments to account for similar contaminants that
may also pose risks. The EPA guidance states:
5.15 Screening Sites with Multiple Contaminants
80 Id. at 39.
81 A. Reade, T. Quinn, and J. S. Schreiber, PFAS in Drinking Water 2019: Scientific and Policy Assessment
for Addressing Per-and Polyfluoroalkyl Substances (PFAS) in Drinking Water at 43, Natural Resources
Defense Council (Apr. 12, 2019), https://www.nrdc.org/sites/default/files/media-uploads/
nrdc_pfas_report.pdf.
82 Regional Screening Levels (RSLs) User’s Guide at 5.15, U.S. EPA (Nov. 2019),
https://www.epa.gov/risk/regional-screening-levels-rsls-users-guide.
46
The screening levels in the tables are calculated under the
assumption that only one contaminant is present. Users needing to
screen sites with multiple contaminants should consult with their
regional risk assessors. The following sections describe how target
risks can be changed to screen against multiple contaminants and
how the ratio of concentration to RSL can be used to estimate total
risk.83
The EPA provides guidance on how to adjust the HQs for single chemicals when multiple
contaminants are present (which depends on how many of the other 19 PFAS listed in Table 3+
are detected):
The calculator on this website can be used to generate SLs based on
any THQ [target hazard quotient] or target cancer risk (TR) deemed
appropriate by the user. The THQ input to the calculator can be
modified from the default of 1. How much it should be modified is
a user decision, but it could be based upon the number of
contaminants being screened together. For example, if one is
screening two contaminants together, then the THQ could be
modified to 0.5. If ten contaminants are being screened together,
then the THQ could be modified to 0.1. The above example weights
each chemical equally; it is also possible to weight the chemicals
unequally, as long as the total risk meets the desired goal. The
decision of how to weight the chemicals is likely to be site-specific,
and it is recommended that this decision be made in consultation
with the regional risk assessor.84
The other option the EPA provides for assessing the risk of exposure to multiple, related
chemical compounds (and which Chemours also failed to follow) is to first develop “safe” drinking
water concentrations for each of the 20 PFAS listed in Table 3+ (which are sometimes referred to
as maximum contaminant level goals [MCLGs] or screening levels [SLs], as shown below). The
detected concentration in drinking water for each of the individual PFAS compounds is then
divided by those concentrations (shown as Cx, Cy,…Cz); finally, the quotients are added together,
or summed. If the summed THQ exceeds 1.0, the contaminants may pose an unacceptable risk.
83 Id.
84 Id. at 5.15.1.
47
What is important to recognize about this approach is that the summed THQ can far exceed
acceptable risk levels even when each of the individual PFAS compounds does not exceed its own
MCLG (or SL).
Source: Regional Screening Levels (RSLs) User’s Guide at 5.15.1, U.S. EPA (Nov. 2019),
https://www.epa.gov/risk/regional-screening-levels-rsls-users-guide.
This error is critical. This issue is compounded because other chemicals have been found
in the DRCs’ water supply that originated from Fayetteville Works. Chemours followed none of
these approaches, and its assertion that the Action Level for GenX is safe is unsupported and
contrary to the established methodological approaches when populations are exposed to multiple,
similar compounds.
Chemours should be required to generate adequate toxicity information for the 19 untested
PFAS listed in Table 3+ that DuPont (and later Chemours) emitted and discharged into the
environment. Chemours, as the manufacturer, is not only most familiar with the chemical/physical
properties of its own chemical products, but has profited from their use or sale for more than a
decade, which is more than sufficient time to have completed toxicological testing on the
remaining 19 PFAS compounds listed in Table 3+. The HH-SLEA and CAP do not explain why
DuPont and Chemours failed to perform any such testing in the past, and there is no explanation
for why Chemours continues to delay testing today. It is incumbent on Chemours to explain how
48
it intends to finalize the HH-SLEA and CAP risk assessments and the necessary underlying data.
Simply put, no risk assessment can be conducted without PFAS-specific toxicity studies and the
toxicity values that are extracted from those studies. Those studies do not yet exist, and there is no
concrete plan for their completion.85
Moreover, given the similarity of the molecular structure of the Table 3+ PFAS to PFOA
(also known as C8) and GenX, Chemours should also be required to comply with the requirement
in Section 8(e) of TSCA to immediately notify the EPA when substances or mixtures present a
substantial risk of injury to health or the environment. TSCA Section 8(e) states, “Any person who
manufactures, [imports,] processes, or distributes in commerce a chemical substance or mixture
and who obtains information which reasonably supports the conclusion that such substance or
mixture presents a substantial risk of injury to health or the environment shall immediately inform
the [EPA] Administrator of such information unless such person has actual knowledge that the
Administrator has been adequately informed of such information.” 15 U.S.C. § 2607(e). EPA’s
guidance states that such “Substantial Risk Notifications” under TSCA Section 8(e) should be
submitted within 30 calendar days.
Until Chemours conducts foundational toxicity tests on the 19 PFAS compounds listed in
Table 3+, there is no path forward to derive toxicity values. And without this information, human
health risks cannot be determined, the current calculated risks are not even a good faith guess, and
85 Chemours and its predecessor, DuPont, are well equipped to generate such data. DuPont contends that
its Haskell Laboratory for Toxicology and Industrial Medicine is one of the most advanced industrial
toxicology testing facilities in the world. Indeed, in its very first mission statement in 1935, Haskell
Laboratory stated that the purpose of its facilities was to test DuPont’s chemical products before they were
placed on the market. Haskell Laboratory of Industrial Toxicology, 13 Chem. Eng. News 3, 44-46 (1935)
(The purpose of Haskell Labs is “to test thoroughly from a health standpoint all products produced by the
company before they are placed on the market.”) (emphasis added).
49
to ensure they are adequately protected from the future health risks of these toxic chemicals, DRCs
are entitled to the installation of RO systems and bottled water.
2. The Carcinogenetic Impacts of GenX and PFAS Must Be
Addressed
In addition to noncancer systemic toxicity, however, the HH-SLEA does not address or
discuss whether GenX or any of the other 19 PFAS listed in Table 3+ are, like their closely
related predecessor C8, likely carcinogens. Indeed, the EPA’s draft toxicity assessment of GenX
(which Chemours relies on) states:
[T]here is Suggestive Evidence of Carcinogenic Potential of oral
exposure to GenX chemicals in humans, based on the female
hepatocellular adenomas and hepatocellular carcinomas and male
combined pancreatic acinar adenomas and carcinomas.86
Moreover, because the cancer studies the EPA refers to were rat studies, even the EPA’s
assessment may underestimate GenX’s cancer risk, as it is well-known that mice are more sensitive
to the effects of GenX than rats. GenX’s potential carcinogenicity was not even mentioned in the
HH-SLEA.
A review of DuPont’s and Chemours’ knowledge of the carcinogenicity of GenX is
instructive.
a. Pursuant to the 2009 consent decree between DuPont and the EPA, DuPont was
required to conduct a series of tests on GenX. The tests demonstrated significant health and
environmental dangers associated with GenX, and yet DuPont concealed, misrepresented, and
downplayed these dangers, all while continuing to discharge toxic chemicals into the Cape Fear
River.
86 Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium
Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as ‘GenX Chemicals’, EPA-823-P-18-001
Public Comment Draft at 47, U.S. EPA (Nov. 2018), https://www.epa.gov/sites/production/files/2018-
11/documents/genx_public_comment_draft_toxicity_assessment_nov2018-508.pdf.
50
b. On July 15, 2010, pursuant to the consent decree, DuPont submitted a letter report
to the EPA summarizing the results of studies of the impacts of GenX on both fetal and adult
laboratory rats. The study found a direct correlation between the dosage of GenX and early
deliveries, fetal weight, and skeletal deformations:
There was a dose-related increase in the number of dams [female
mice] found with early deliveries on GD 21.
In addition, mean fetal weight was 8 and 28% lower (statistically
significant) than controls at 100 and 1000 mg/kg/day, respectively.
A higher mean litter proportion of 14th rudimentary ribs was
observed in the 1000 mg/kg/day group, resulting in a higher mean
litter proportion of total skeletal variations and total
developmental variations. . ..
c. As for the maternal laboratory rats, the study found that:
Focal necrosis [small areas of dead tissue such as cysts] of the
liver was noted in some females in the 100 and 1000 mg/kg/day
groups in a dose-related manner.
d. On July 20, 2010, pursuant to the consent decree, DuPont submitted a report to the
EPA on a further rodent study which found numerous instances of cellular deformation indicative
of liver disease and early-stage cancer. Pathological findings included focal necrosis, which are
small areas of dead liver cells undergoing disintegration, and an increase of peroxisome
proliferators which have been shown to cause liver disease and induce tumors in livers.
e. To address these adverse findings, DuPont performed a follow-up study which it
reported to the EPA on January 28, 2011. The results differed little from the July 20, 2010 letter
report and portended the results of a far more detailed analysis in 2014:
Hepatocellular hypertrophy was characterized by cytoplasmic
eosinophilic stippling that is consistent with peroxisome
proliferation. In the 5 mg/kg/day F0 males and females, other liver
lesions included increases in single cell necrosis, mitotic figures,
lipofuscin pigment, and focal necrosis (females only).
51
Increases in mitotic figures indicate that a cell population is proliferating and is
used as an index of tumor aggression.
f. On January 8, 2013, DuPont completed another study. The results further
confirmed the dangerous health effects of exposure to GenX:
Under the conditions of this study, the no-observed-adverse-effect
level (NOAEL) was considered to be 1 mg/kg/day in male and
female rats. Test substance-related neoplastic changes were
observed at the high dose (500 mg/kg/day in females; 50 mg/kg/day
in males) and included hepatocellular tumors in females and, in
males, equivocal increases in pancreatic acinar cell tumors and
testicular interstitial cell tumors.
But DuPont dismissed the results as not being relevant to human health:
Based on the high dose threshold for these tumor responses in this
study, the lack of genotoxicity of the test material across a battery
of in vitro and in vivo tests, and the known responses of the rat versus
other species, including humans, to these PPAR(a) associated tumor
responses, these tumor findings are not considered relevant for
human risk assessment.
g. The January 2013 study also found uterine polyps, which is a potential indicator of
uterine cancer, but dismissed the results on statistical grounds. DuPont did not, however, provide
a basis for selecting the statistical tests or any evidence that it had run the tests, or the results of
the tests. DuPont swept its own dire findings under the rug, while citing no authority and
conducting no tests supporting these broad dismissals. Moreover, DuPont failed to acknowledge
the large body of science that is contrary to DuPont’s purported conclusion that its rodent studies
are irrelevant to human health.
h. In 2014, DuPont scientists conducted yet another evaluation of the toxic effects of
GenX, “Evaluation of chronic toxicity and carcinogenicity of ammonium 2,3,3,3-tetrafluoro-2-
(heptafluoropropoxy)-propanoate in Sprague–Dawley rats” (“GenX Report”). This study was
52
designed to be far more detailed than the last half-dozen studies, and was presumably designed to
put to bed any lingering doubts about the carcinogenicity of GenX. But the opposite occurred. The
GenX Report found “[i]ncreases in enzymes indicative of liver injury. . .” It also found a gradual
deterioration of specific tissues, cells, and organs with a corresponding impairment of function,
and small areas of dead liver tissue. Blood sampling analysis and results also found that the rats
were in a diseased state.
i. Tumors were also discovered in the rats:
At the interim necropsy, non-neoplastic test substance-associated
effects were present in the liver of males at 50 mg/kg and in the liver
and kidneys of females at 500 mg/kg.
j. “Non-neoplastic” refers to new growth in tissue that does not serve a useful purpose
– i.e., tumors. Neoplasms may be malignant or benign; some benign tumors may progress to
malignancy. The report later indicated that these tumors were indeed carcinogenic. DuPont also
found the livers to be enlarged, lesions and dying cells—all indicators of liver disease.
k. DuPont also found cells in the early stages of kidney cancer:
Kidney changes in females at 500 mg/kg included tubular dilation,
edema of the renal papilla, transitional cell hyperplasia in the
renal pelvis, tubular mineralization, renal papillary necrosis and
CPN. Tubular dilation frequently occurred in an ascending pattern
extending from the papilla to the outer cortex, while at other times
it was present only in the papilla. Edema of the papilla was
characterized by increased rarefaction or myxomatous change in the
papillary interstitium, sometimes with polypoid protrusions from
the lateral surface of the papilla. The edema and tubular dilation
were often associated with hyperplasia of the transitional cell
epithelium lining the papilla and pelvis. Small foci of tubular
mineralization were often present and, in some animals, necrosis of
the tip of the papilla was present.
Transitional cell hyperplasia in the kidney is often an initial stage in the development of cancer.
53
l. The report also found that, in addition to tumors in the liver, tumors were also found
in the kidney, stomach, and tongues of females:
In addition, in female rats given 500 mg/kg, statistically significant
increases in hyperplasia of squamous epithelium were observed in
the nonglandular stomach (limiting ridge only) and tongue (in
association with subacute/chronic inflammation in the tongue).
Hyperplasia is the enlargement of an organ or tissue caused by an increase in the reproduction rate
of its cells, often as an initial stage in the development of cancer.
m. DuPont ultimately concluded that the lesions in the liver were carcinomas—that
GenX caused liver disease and cancer in the livers of females and males:
Compound-related neoplastic changes occurred in the livers of
females administered 500 mg/kg and included increased
incidences of hepatocellular adenoma and carcinoma. These
tumors occurred in association with the degenerative and necrotic
liver lesions observed at this dose as described above.
Hepatocellular tumors and test substance-associated degenerative
and necrotic lesions were not observed in females at lower doses and
the incidences of hepatocellular tumors were similar in all male
groups.
n. The report also found that in males, GenX causes pancreatic cancer, but then
attempted to minimize the impact of its findings:
In males administered 50 mg/kg, a statistically significant increase
in the combined incidence of pancreatic acinar cell adenomas
and carcinomas was seen, but neither the incidence of adenoma or
carcinoma alone was statistically increased, although the incidence
of carcinomas (2.9%) was slightly outside the historical range of 0-
1.7%.
o. DuPont’s study also found evidence of testicular cancer, but again tried to minimize
its significance:
The incidence of Leydig cell adenomas (11.4%) was increased
above historical control ranges for this tumor (0-8.3%) in males
administered 50 mg/kg, although this increase was not statistically
significant compared to controls. In addition, a Leydig cell adenoma
54
was present in 1 male at the interim necropsy in the 50 mg/kg group.
The incidence of Leydig cell hyperplasia was also increased above
historical control range in this group at terminal sacrifice (also 0-
8.3%, although again, this incidence was not statistically significant
versus controls. However, comparison to within-study controls was
complicated by the fact that controls had a relatively high incidence
of Leydig cell hyperplasia (10%). Based on the above considerations
and the known activity of PPARα agonists to produce Leydig cell
hyperplasia and adenomas in rats, the relationship to the test
compound for these lesions was considered equivocal in this
study.
Leydig cell tumors are usually benign, but approximately 10% are malignant. As with germ cell
tumors, they spread throughout the lymphatic system. However, unlike germ cell tumors, Leydig
cell tumors show relative lack of sensitivity to radiotherapy and chemotherapy agents.
p. DuPont likewise tried to minimize its finding on pancreatic cancer and Leydig cell
tumors by claiming that “less robust” evidence “suggests” that the results were “likely” not
relevant to humans:
While there is less definitive mechanistic data on the role PPARα
plays in the induction of pancreatic acinar cell tumors in rats, the
available data involving altered bile flow and increased
cholecystokinin suggests that this mode of action is also likely to be
non-relevant for humans. While less robust, research considering
comparative biology and mechanism of action of Leydig cell tumor
induction in rodents by a wide variety of chemical classes suggests
these tumors most likely have low relevance to humans.
q. DuPont’s GenX report ultimately concluded: “The test chemical belongs to a class
of compounds known as peroxisome proliferators (PPARα agonists) which are known to produce
liver, pancreatic, and testicular tumors in rats and liver tumors in mice.” However, faced with its
findings that GenX is carcinogenic, DuPont concluded, without any epidemiological study on
rodents impregnated with human proteins, that “these compounds have not been shown to be
carcinogenic in other species including humans. Based on the extensive research into the
comparative biology of peroxisome proliferator-induced hepatic carcinogenesis, the induction of
55
liver tumors in rodents by non-genotoxic peroxisome proliferators (this compound was shown to
be inactive in a battery of genotoxicity assays) is not considered relevant to humans.”
r. DuPont never tested for the synergetic impact of GenX and other PFASs.
s. DuPont wrongly dismissed all these results as not being relevant to human health.
DuPont claimed that the observed increase in cancer in rodents exposed to GenX was irrelevant
based on the single argument that the PPAR mode of action in rodents is irrelevant to human
cancers. But DuPont ignored the fact that the PPAR mode of action only applies to liver cancer
and not to pancreatic and testicular cancer. Moreover, it was DuPont who selected the rodents for
the cancer study, and DuPont ignored the fact that there are rodents with modified signaling that
are more conducive to determining the test’s applicability to humans. Scientific studies by
independent researchers have found carcinogenic impacts from PFOA exposure to these modified
rodents. DuPont also concluded that the high doses used in the rodent studies were not
representative of human exposures. This argument is not only scientifically untrue but defies
common sense for several reasons. First, all two-year cancer rodent studies follow the protocol
developed by the U.S. National Toxicology Program, which requires dosing rodents at elevated
dose. This requirement is necessary to increase the probability of detecting cancers in humans.
Further, humans in many instances are even more susceptible to cancer and other pathologies than
laboratory rodents. Moreover, it has been well-established that when exposures to carcinogens
occur during the early-life stage, critical exposure carries a much greater risk of developing cancer.
The EPA requires a factor of 10 to be applied to calculating risk for these early life exposures.
Finally, DuPont’s claim that rodent cancers only occur at high doses and are therefore irrelevant
to human exposures is absurd from a common-sense standpoint—the EPA required DuPont to
conduct the studies on rodents because they were relevant to determining health impacts of GenX
56
exposure to humans. Nevertheless, DuPont dismissed its toxicology results as not being relevant
to human health, and DuPont neglected to notify area residents, drinking water providers, or state
and local officials of the significant dangers posed by the polluted water supply.
t. In 2012, a series of studies further demonstrated the negative health impacts of
exposure to PFOA and perfluorooctanesulfonic acid (PFOS). Tests showed immunotoxic effects
in a variety of species and models. Additionally, the C8 Health Project, which was created as part
of the settlement of another lawsuit against DuPont, found a significant positive exposure-response
relationship between PFOA and kidney cancer.
u. A 2013 population-based case-control analysis supported the association between
PFOA exposure and both kidney and testicular cancer and suggested an association with prostate
and ovarian cancer and non-Hodgkin lymphoma.
v. Despite all of this scientific evidence that DuPont’s secret dumping of GenX into
the Cape Fear River posed serious health consequences for the hundreds of thousands of people
who depended on the river for their water supply, DuPont continued to conceal its actions and
failed to warn regulators or the public.
w. As noted above, DuPont developed GenX primarily because it was thought to be
more biodegradable than PFOAs, which had spawned extensive litigation. DuPont’s logic was that
GenX would pass through the body more quickly, and thus cause less damage than PFOAs.
x. According to DuPont’s own March 15, 2010 report, however, written pursuant to
its consent decree with the EPA, GenX is not inherently biodegradable. The purpose of this test
was to evaluate the inherent biodegradability of the test substance via a 28-day test. The test was
designed to meet the requirements of SEPA HJIT 153-2004, “the guidelines for the testing of
chemicals,” OECD Procedure 302C, “Inherent Biodegradability: Modified MITI Test (II),”
57
adopted May 1981. The report concluded that: “. . . Based on the residue analysis, the
biodegradation of the test substance was 0% and there was hardly any change for the test
substance in the ‘abiotic’ vessel during the testing period. The BOD results showed that
biodegradation of the test substance was both <1% after 14 and 28 days. The test was valid
because the level of biodegradation of the reference substance aniline exceeded 40% after 7 days,
and 65% after 14 days. Therefore, the test substance was not inherently biodegradable under this
test condition.” In other words, DuPont’s own test found that GenX was not biodegradable, that
is, it was not capable of being broken down (decomposed) rapidly by the action of microorganisms.
The implications for North Carolina residents—who depend on the Cape Fear River for their water
supply—was that their exposures would be long-lasting.
y. DuPont’s results were consistent with those of other researchers, which have found
that GenX is not only not biodegradable, but that it bonds with protein in the cells of living
organisms and adheres to sediment, scale and pipes, and then reenters the water supply. These
living cells include biofilms that cling to pipes and water heaters. Moreover, there is no method
that is known with any degree of certainty that will remove the biofilms from the water heaters
and plumbing in homes.
Furthermore, even though the EPA has determined that GenX causes liver and pancreatic
cancers in animals, no carcinogenic toxicity value (i.e., a cancer slope factor) has yet been
developed for GenX, let alone for the other 19 PFAS listed in Table 3+. Thus, most efforts to
derive toxicity values for the purpose of establishing safe exposure levels for soils, surface and
groundwater, tap water, air, and biota are limited to noncancer health effects, which by itself is a
source of great scientific uncertainty. The HH-SLEA should identify this data or information gap
and should explain why the issue of GenX-induced cancer was not included in its comments.
58
The issue of GenX-induced cancer will be of critical importance in the future because
epidemiology studies must focus on both noncancer systemic toxicity (i.e., organ damage) and
cancer when such studies are finally undertaken.
3. GenX Is Likely More Toxic Than PFOS and PFOA
Recent studies—which Chemours entirely omitted from the HH-SLEA and CAP—indicate
the toxicity of GenX has already been underestimated. For example, Gomis et al.87 compared the
toxic potency of long-chain perfluoroalkyl acids to the shorter-chain, second-generation
fluorinated compounds in 2018; based on the severity of liver pathology, she concluded that GenX
was even more toxic than the first-generation PFAS compounds it was designed to replace because
it was “thought” to be less toxic. She stated:
Dose-response curves of liver enlargement from sub-chronic oral
toxicity studies in male rats were converted to internal dose in serum
and in liver to examine the toxicity ranking of [PFAS] and
fluorinated alternatives. Converting administered doses into
equivalent serum and liver concentrations reduced the variability in
the dose-response curves for PFBA, PFHxA, PFOA and GenX. The
toxicity ranking using modeled serum (GenX > PFOA > PFHxA >
PFBA) and liver (GenX > PFOA≈PFHxA≈PFBA) concentrations
indicated that some fluorinated alternatives have similar or higher
toxic potency than their predecessors when correcting for
differences in toxicokinetics.88
The researchers concluded that “some fluorinated alternatives have similar or higher toxic
potency than their predecessors when correcting for differences in toxicokinetics.” Neither the
HH-SLEA nor the CAP, however, discuss toxicokinetic differences for any of the 20 PFAS
compounds, and Gomis’ analysis showing GenX is more toxic than PFOA means that the
current 140 ppt Health Advisory Level for GenX is far too high. The GenX level should be set
87 M. I. Gomis, R. Vestergren, D. Borg, and I. T. Cousins, Comparing the Toxic Potency in Vivo of Long-
Chain Perfluoroalkyl Acids and Fluorinated Alternatives, 113 Environ. Int. 1-9 (Jan. 2018).
88 Id.
59
even lower than the current safe drinking water levels that some states have developed for PFOA
of 10 to 15 ppt.
Because Chemours did not conduct a detailed toxicokinetic study, it inferred that
elimination of GenX from the body is rapid. However, Chemours’ analysis does not and cannot be
interpreted to mean that the recent blood sampling tests performed by the N.C. State University—
in which GenX was not detected in participants’ blood—should be interpreted to mean that the
exposed population does not have elevated levels of GenX in their bodies. It has now been well
established that PFAS compounds bioaccumulate in different organs and tissues in the body and
that this bioaccumulation essentially prevents PFAS from circulating in the blood. It is thus
possible to have an undetectable level of GenX based on blood tests because GenX has
bioaccumulated in different organs. Thus, while the blood levels for GenX may be low or
undetectable, there may be noncirculating GenX stored in organs bound to tissue.
Examples of this toxicokinetic phenomenon abound. A similar phenomenon was described
by Perez et al.,89 and their following illustration shows that different organs bioaccumulate
different types of PFAS; although blood levels for PFAS compounds like GenX may be low or
non-detectable, that in itself does not mean that the body burden is insignificant.
89 F. Pérez, et al., Accumulation of Perfluoroalkyl Substances in Human Tissues, 59 Environ. Int. 354-62
(2013).
60
Source: F. Pérez, et al., Accumulation of Perfluoroalkyl Substances in Human Tissues, 59 Environ.
Int. 354-62 (2013).
Finally, it is a fundamental toxicological principle that the absence of a detectable amount
of a toxin in blood samples does not mean there is no ongoing risk of health hazards. This is
because toxic compounds may simply trigger toxic effects: that is, once a toxin triggers disease,
continuous exposures to that toxin are not necessary for illness and disease to manifest. For
example, a heavy smoker may smoke for decades and quit; even though the person no longer
smokes (exposure stops), he or she can develop lung cancer. That is, lung cancer is triggered by
cigarette smoke, but cancer may develop even in the absence of ongoing exposure, as the latency
period between smoking and the onset of lung cancer is about 45 years. Thus, setting aside the
toxicokinetic principles discussed above, and even if blood levels of GenX do not show current
exposure, the toxicological damage may have already been triggered. Illness and disease can
progress even when exposure to GenX stops. It should also be emphasized that the HH-SLEA and
61
CAP do not calculate any risks associated with past historical exposures—which were very high
for GenX and related PFAS compounds—because Chemours uses current PFAS levels to predict
the future risks. This vastly understates the risk associated with past exposures to PFAS, which
occurred at a time when Chemours was dumping directly into the Cape Fear River, emitting to the
air and spilling to ground.
4. Chemours Failed to Follow EPA Standards for Deriving
Toxicity Values for GenX and Other PFAS.
Chemours did not follow, let alone cite or reference, EPA or North Carolina guidance that
toxicity values must be derived from primary peer-reviewed toxicity studies. For GenX, Chemours
made no attempt to verify toxicity values and instead used draft preliminary noncancer RfD levels
developed by the EPA and DHHS, which were based on DuPont’s 2009-2010 toxicity study
submissions provided to the EPA pursuant to the TSCA premanufacture notice procedure, often
referred to as “8(e).” Despite the fact that many toxicology studies have been published in the
past decade, Chemours did not conduct a literature review to identify any of these subsequent
studies; these studies might have resulted in a different RfD for one or more of the 20 PFAS
compounds identified by Chemours in its Appendix F, Table 1 shown below.
62
Source: CAP, App. F, Table 1. Note that there is an error in this table: PFHpA is listed in the CO
but was omitted from the table.
Further, by not conducting toxicological analyses of the 19 PFAS compounds listed in
Table 3+, Chemours is simply assuming—with no basis for doing so, and contrary to the body of
available evidence—they are not toxic at any concentration. The sole purpose of a quantitative
risk assessment is to establish the concentration or dose at which contaminants are toxic and then
determine whether the site-related dose exceeds the toxicity value.
Chemours’ false and completely baseless assumption—that the 19 PFAS compounds listed
in Table 3+ do not produce toxic effects at any dose—is deeply troubling from a practical
standpoint. Although many risk assessments are conducted based on a hypothetical assumption
that people could be exposed to contaminants, it is a fact that thousands of North Carolina residents
63
and DRCs have been exposed to the 19 PFAS compounds listed in Table 3+, likely for many years
and at doses much higher than the present levels that Chemours relies on for its exposure
assessment. The associated health risks from this known exposure are therefore not hypothetical
but rather are an established fact.
Chemours’ failure to follow basic EPA or North Carolina risk assessment guidance is both
inexplicable and indicative of the HH-SLEA’s inadequacy. In both the HH-SLEA and the CAP,
Chemours makes no mention of EPA or North Carolina risk assessment guidance that must be
followed to properly derive toxicity values for the 19 PFAS compounds listed in Table 3+. This
omission is untenable. The HH-SLEA and CAP do not cite this EPA directive, nor does Chemours
cite the detailed and more recent guidance developed by the EPA to guide the derivation of a
toxicity value.90
Chemours also fails to discuss, follow, or cite the more than 10 EPA guidance documents
that have since been issued which present in great detail how primary peer-reviewed studies should
be evaluated, together with the protocols and methods for extrapolating toxicity data from animal
studies to characterize human toxicity. Toxicity values form the basis of not only human health
risk assessments but drinking water standards and advisories. Without toxicity values, neither
assessment can be completed.
The HH-SLEA and CAP do not discuss why Chemours deviated from the hierarchal
procedures required by the EPA in the OSWER Directive 9285.7-Memorandum to derive toxicity
values. Chemours does not explain why it did not contact the Office of Research and
Development/National Center for Environmental Assessment/Superfund Health Risk Technical
Support Center (STSC)—which is responsible for assisting the scientific community in developing
90 Tier 3 Toxicity Value White Paper, Regional Tier 3 Toxicity Value Workgroup, OSWER Human Health
Regional Risk Assessors Forum, U.S. EPA (May 16, 2013), https://semspub.epa.gov/work/HQ/163525.pdf.
64
provisional toxicity values—to request technical assistance in developing provisional toxicity
values. Nor did Chemours discuss whether it conducted a review of other available Tier 3 sources
of toxicity information as required by EPA guidance. Rather, Chemours is waiting for others in
the scientific community to develop toxicity values for chemical products that Chemours itself
produced and profited from. Chemours’ “wait and see” approach is a prime example of its
corporate irresponsibility and, more importantly, has resulted in an incomplete risk assessment.
5. The HH-SLEA Underestimates the Toxicity and Human Health
Risks for GenX.
Despite Chemours’ failure to conduct toxicity testing for the 19 PFAS compounds, it did
conduct toxicity studies on GenX. But these toxicity and human health risk assessments are flawed
and starkly underestimate the actual risk to human health of exposure to GenX.
As shown below in CAP Appendix F, Table 4 (highlighted cells), the values were based
on three sources of GenX animal toxicity data compiled by the EPA,91 DEQ/DHHS,92 and
Thompson et al.93 These include the following RfDs: EPA draft RfDo = 0.00008 mg/kg-day;
DHHS RfDo = 0.00010 mg/kg-day; and Thompson, et al. RfDo = 0.01000 mg/kg-day:
91 Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium
Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as ‘GenX Chemicals’, EPA-823-P-18-001
Public Comment Draft at 47, U.S. EPA (Nov. 2018), https://www.epa.gov/sites/production/files/2018-
11/documents/genx_public_comment_draft_toxicity_assessment_nov2018-508.pdf.
92 Secretaries’ Science Advisory Board Review of the North Carolina Drinking Water Provisional Health
Goal for GenX, N.C. DEQ/DHHS (2018).
93 C. M. Thompson, S. E. Fitch, C. Ring, W. Rish, J. M. Cullen, and L. C. Haws, Development of an Oral
Reference Dose for the Perfluorinated Compound GenX, 39 J. Appl. Toxicol. 9, at 1267-82 (2019).
65
Source: CAP at App. F, Table 4.
The toxicity values derived by the EPA and DEQ/DHHS are largely based on the toxicity
data presented in the documents Chemours submitted in the TSCA Section 8(e) consent order.
These studies are both old and limited in scope, and the EPA concluded that:
Data from these available studies indicate that the liver is the most
sensitive target of GenX chemicals toxicity. Liver effects were
observed in both male and female mice and rats at varying durations
of exposures and doses. These effects occurred at the lowest doses
of exposure to GenX chemicals.94
Likewise, DHHS also primarily relied on the decade-old Chemours studies and concluded that the
liver was the most sensitive organ and determined where liver pathology (hepatotoxicity) occurred
at the lowest dose.
94 Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium
Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as ‘GenX Chemicals’, EPA-823-P-18-001
Public Comment Draft at 47, U.S. EPA (Nov. 2018), https://www.epa.gov/sites/production/files/2018-
11/documents/genx_public_comment_draft_toxicity_assessment_nov2018-508.pdf.
USEPA Draft
RfDo =
8.00E-05
NC DHHS
RfDo =
1.00E-04
Thompson et al.
RfDo =
1.00E-02
USEPA
Draft
RfDo =
8.00E-05
NC DHHS
RfDo =
1.00E-04
Thompson
et al.
RfDo =
1.00E-02EU12.5 km, Northeast 8.00E-05 7.00E-06 1 0.8 0.008 0.08 0.07 0.0007
EU2 2.5 km, Southeast 6.00E-05 5.00E-07 0.7 0.6 0.006 0.006 0.005 0.00005
EU3 2.5 km, Southwest 3.00E-05 1.00E-06 0.4 0.3 0.003 0.02 0.01 0.0001
EU4 2.5 km, Northwest 1.00E-05 5.00E-07 0.1 0.1 0.001 0.006 0.005 0.00005
EU5 5 km, Northeast 2.00E-05 5.00E-07 0.3 0.2 0.002 0.006 0.005 0.00005
EU6 5 km, Southeast 9.00E-06 5.00E-07 0.1 0.09 0.0009 0.006 0.005 0.00005
EU7 5 km, Southwest 2.00E-05 5.00E-07 0.2 0.2 0.002 0.006 0.005 0.00005
EU8 5 km, Northwest 5.00E-06 5.00E-07 0.06 0.05 0.0005 0.006 0.005 0.00005
EU9 10 km, Northeast 5.00E-06 5.00E-07 0.07 0.05 0.0005 0.006 0.005 0.00005
EU10 10 km, Southeast 1.00E-06 5.00E-07 0.01 0.01 0.0001 0.006 0.005 0.00005
EU11 10 km, Southwest 2.00E-06 5.00E-07 0.03 0.02 0.0002 0.006 0.005 0.00005
EU12 10 km, Northwest 1.00E-06 5.00E-07 0.01 0.01 0.0001 0.006 0.005 0.00005
EU13 CFR, 10 mi. Upstream 5.00E-09 n/a 0.00006 0.00005 0.0000005 n/a n/a n/a
EU14 CFR, Site-Adjacent 3.00E-08 n/a 0.0004 0.0003 0.000003 n/a n/a n/a
EU15 CFR, 4 mi. Downstream ND n/a ND ND ND n/a n/a n/a
EU16 CFR, Bladen Bluffs 1.00E-05 n/a 0.2 0.1 0.001 n/a n/a n/a
EU17 CFR, Kings Bluffs 2.00E-08 n/a 0.0002 0.0002 0.000002 n/a n/a n/a
EU18 Onsite Pond 1 8.00E-07 n/a 0.01 0.008 0.00008 n/a n/a n/a
EU19 Offsite Pond B 3.00E-07 n/a 0.004 0.003 0.00003 n/a n/a n/a
EU16 (Intake Point)CFR, Bladen Bluffs 2.00E-05 n/a 0.2 0.2 0.002 n/a n/a n/a
EU17 (Intake Point)CFR, Kings Bluffs 9.00E-07 n/a 0.01 0.009 0.00009 n/a n/a n/a
Offsite Child
Gardener
(Age 0-6)
Offsite Child
Recreationalist
(Age 0-6)
Offsite Child
Resident
(Age 0-6)
HFPO-DA Intake (mg/kg-day) [2]HFPO-DA Hazard
Exposure
Unit (EU)
EU Description Receptor [1]Untreated Well
Water
(RME EPC)
Current
Conditions
(10 ng/L)
Untreated Well Water (RME EPC) [3,5]Current Conditions (10 ng/L)
66
Source: Secretaries’ Science Advisory Board Review of the North Carolina Drinking Water
Provisional Health Goal for GenX – Final, DEQ/DHHS (Oct. 30, 2018).
EPA has noted that there were significant deficiencies in the toxic endpoints that Chemours
studied. Most importantly, Chemours did not evaluate immunotoxicity, particularly with regard
to antibody response. In identifying this deficiency, the EPA noted that although gross
(nonspecific) hematological damage was investigated, specific immunotoxicity involving
antibody production in response to an antibody challenge was not evaluated:
[I]mmune and hematological effects were also observed at low
doses; however, these endpoints are not as consistently observed
compared to liver effects… Evaluation of additional immune
function assays, histopathology, and immune endpoints such as
antibody levels are not available. The combined dataset was found
to be weak as it did not include sufficient measures of
immunopathology, humoral immunity, cell-mediated immunity,
nonspecific immunity, or host resistance. Data on the potential for
these GenX chemicals to impact aspects of immune function beyond
immunosuppression are lacking. Additional studies, therefore,
67
would be useful to support a more conclusive determination of
immunotoxic potential. (emphasis added)95
Rectifying this gap in knowledge is critical and underscores the need for further analysis
of GenX’s immunotoxicity to ensure adequate protection of human health from the effects of
GenX exposure.
The absence of this information—and its failure to be incorporated into the risk assessment
for GenX—follows the historical pattern that DuPont followed in the case of C8. Like GenX, early
studies of C8 appeared to indicate that the most sensitive toxic effect identified in PFOA studies
was liver damage. Because there were no immunotoxicity studies available for C8 to assess this
important toxicological endpoint, however, the C8 toxicity values were based on limited studies
in which only liver pathology was identified. Since those early incomplete studies, immunotoxicity
has been shown to have a significant impact, especially in children – particularly their ability to
effectively immunize against disease.
North Carolina experts like Dr. DeWitt (East Carolina University) concur that
immunotoxic effects are the most sensitive toxic endpoints for deriving toxicity values for PFOA
or PFOS, which suggests that the immunotoxic effects of GenX must be considered when deriving
its toxicity value. Dr. DeWitt recently delivered a December 2, 2019 presentation to the North
Carolina Secretaries’ Science Advisory Board entitled, Immunotoxicological Findings of PFAS: A
Focus on PFOA and PFOS. The graph below from one of her studies shows that there is a striking
decrease in the circulating antibody blood levels with increasing PFOA dose, which means that
there is a reduction in the ability of humans to effectively immunize against disease.
95 Human Health Toxicity Values for Hexafluoropropylene Oxide (HFPO) Dimer Acid and Its Ammonium
Salt (CASRN 13252-13-6 and CASRN 62037-80-3) Also Known as ‘GenX Chemicals’, EPA-823-P-18-001
Public Comment Draft at 47, U.S. EPA (Nov. 2018), https://www.epa.gov/sites/production/files/2018-
11/documents/genx_public_comment_draft_toxicity_assessment_nov2018-508.pdf.
68
Source: J. C. DeWitt, C. B. Copeland, M. J. Strynar, and R. W. Luebke, Perfluorooctanoic Acid-
Induced Immunomodulation in Adult C57BL/6J or C57BL/6N Female Mice, 116 Environ. Health
Perspect. 5, at 644-50 (May 2008).
Just as DuPont did with C8, Chemours in its HH-SLEA relies on deficient and incomplete
toxicological databases in conducting its risk assessments—a practice that is unacceptable in light
of the established health risks from exposure to similar PFAS. In a recent publication, Grandjean
characterizes the problems with relying on deficient and incomplete toxicological databases for
risk assessments. Even though Chemours has produced a wide range of PFAS compounds for 60
years—including the 20 PFAS listed in Table 3+ at issue here—Chemours has done little to
conduct the type of toxicity studies needed to assess their risks and protect human health:
Identification and characterization of environmental hazards that
impact human health must rely on the best possible science to
inform and inspire appropriate public health intervention. The
perfluorinated alkylate substances (PFASs) are persistent emerging
pollutants that are now being recognized as important human health
hazards. Although the PFASs have been produced for over 60 years,
academic research on environmental health aspects has appeared
only in the most recent 10 years or so. . . .
Some early studies, e.g., on population exposures and toxicity, were
not released to the public until after year 2000. Still, the first PFAS
risk assessments ignored these reports and relied on scant journal
publications. The first guidelines and legal limits for PFAS
exposure, e.g., from drinking water, were proposed 10 years ago.
69
They have decreased substantially since then, but remain higher than
suggested by data on human adverse effects, especially on the
immune system, that occur at background exposure levels. . . .
By now, the best-known PFASs are being phased out, and related
PFASs are being introduced as substitutes. Given the substantial
delays in discovery of PFAS toxicity, in dissemination of findings,
and in regulatory decisions, PFAS substitutes and other persistent
industrial chemicals should be subjected to prior scrutiny before
widespread usage.96
6. The HH-SLEA’s Conceptual Exposure Model Ignores Key
Exposure Pathways and Manipulates Inputs to Artificially
Minimize Risk.
In addition to the analytical flaws in Chemours’ toxicology assessments, Chemours also
underestimates exposure risks by ignoring—or purposefully omitting—key exposure pathways.
Specifically, in preparing the HH-SLEA, Chemours prepared a “Conceptual Exposure Model
[“CEM”] for Human Exposure to PFAS Historically Deposited Offsite.”97 The CEM purportedly
identifies a complete set of exposure pathways by which human receptors could come into contact
with PFAS in environmental media offsite. But the CEM limits the scope of these pathways to
only those receptors that are within 10 kilometers (6.2 miles) of Fayetteville Works (i.e., EU 1 to
12), or at specific locations along the Cape Fear River (EU 13 to EU 19). The CEM thus excludes
DRCs that consume tap water supplied to them by local water utilities whose treated water exceeds
the CO’s 10/70 Action Levels. Risks to these other receptors must be considered.
In the HH-SLEA, Chemours also mathematically attenuated the actual concentration of
GenX present in the drinking water from individual wells near Fayetteville Works by using
aggregation. Chemours accomplishes this by first grouping individual wells into arbitrarily
96 P. Grandjean, Delayed Discovery, Dissemination, and Decisions on Intervention in Environmental
Health: a Case Study on Immunotoxicity of Perfluorinated Alkylate Substances, 17 Environ. Health 62
(2018) (emphasis added).
97 CAP at App. F, Section 3 - Conceptual Exposure Model, at 10 et seq., and App. F, Figure 2.
70
assigned EU, which ranged in size from 0.48 to 5.2 square miles.98 Once the numerous wells were
grouped into these large EUs, either the average PFAS concentration or an upper-bound estimate
of the PFAS concentration was calculated. These two calculations, whose results were
incorporated into subsequent risk estimates by Chemours, artificially diminished the elevated
PFAS concentrations detected in many of the well samples. These aggregated and mathematically
attenuated GenX results were used by Chemours to estimate non-cancer risks to older children and
adults drinking this contaminated well water. For example, Chemours’ EU 1, located northeast of
Fayetteville Works, included 24 sample results from 22 different wells.99 Samples of drinking
water from 17 of the 22 (77 percent) different wells in EU 1 contained GenX at a concentration
above the DEQ/DHHS Health Advisory Level (“HAL”) of 140 ng/L. In addition, the HH-SLEA
only estimates risks from exposure to GenX. In EU 1, for example, eight other PFAS listed in the
CO were detected in well samples, but they are not included in Chemours’ risk estimates. The
highest concentration of these other Attachment C PFAS was 4,400 ppt. All of these eight
residences contained other (non GenX) individual PFAS above the 10/70 Action Levels.
By not considering these other (non GenX) PFAS, the HH-SLEA underestimates the risk
to those drinking contaminated water. Chemours should not group individual wells into arbitrary
EUs and then aggregate the GenX concentrations before estimating risks to the residences. Rather,
they should estimate risks (and the applicability of the 10/70 Action Levels in the CO) from
drinking water from each individual well.
Chemours also failed to consider important exposure routes accounted for in the State’s
140 ppt HAL. Specifically, the HAL incorporates a relative source contribution factor for PFAS
98 CAP at App. F, Section 4 and Figure 3.
99 CAP at App. F, Table F-3-2.
71
exposure via drinking water.100 This means that 20 percent of a receptor’s PFAS exposure is from
drinking contaminated water and the other 80 percent is from air and food. However, Chemours
did not consider these other exposure routes.101 Instead, Chemours assumes that the only source
of PFAS is from drinking water, thus excluding the risk of exposure from air and food. By not
considering the ongoing and background exposure to PFAS in air and food, Chemours
substantially underestimates the risk contribution to receptors from Fayetteville Works-related
PFAS.
B. Chemours Must Provide RO Systems Until an Adequate Risk
Assessment Is Prepared, and Must Conduct Additional
Epidemiological and Toxicity Testing.
Chemours is currently far short of fulfilling its obligations under Paragraph 14 of the CO.
As a result, the population of exposed residents continues to be exposed to PFAS contamination
without the underlying data necessary to ensure human health and safety. Because adequate
toxicity and risk assessments are unlikely to be completed for many years, DEQ should require
Chemours to install RO systems and purchase bottled water for DRCs until Chemours’ Paragraph
14 obligations are satisfied.
Paragraph 14 grants DEQ “the right to seek additional toxicity studies or additional health,
chemical persistence and environmental fate information beyond the scope of the initial set of
studies required by this paragraph. DEQ shall consider public comments in determining what
additional toxicity studies or additional health, chemical persistence and environmental fate
information are needed.” Chemours’ own studies have found significant instances of a variety of
carcinogenic and non-carcinogenic impacts from GenX, and numerous epidemiological studies
100 Methodology for Deriving Ambient Water Quality Criteria for Protection of Human Health, U.S. EPA
Office of Water (Oct. 2000).
101 There is no Relative Source Contribution factor incorporated into Chemours’ equations to calculate the
intake of drinking water. See CAP at App. F, Table F-2-1.
72
have been conducted in large communities where DuPont has manufactured PFAS compounds,
contaminating regional air and public and private drinking water.
Paragraph 14 of the CO requires Chemours to conduct toxicology studies of the chemicals
listed in Attachment B of the CO. Such studies should also be expanded to include epidemiological
studies. To ensure transparency and reliability, the studies should be conducted under the auspices
of a truly independent science panel of neutral experts, similar to the process used in connection
with DuPont’s contamination of the Ohio River Valley area surrounding its Washington Works
plant with C8. In addition, Chemours should also be required to conduct toxicological and
epidemiological studies on all chemicals listed in Attachment C of the CO.
C. Parallels Between the Health Studies for C8 (i.e., PFOA) Conducted for
DuPont’s Washington Works plant in West Virginia and the Present
Investigation Now Being Conducted for the Chemours Fayetteville
Works plant.
There are important parallels between the early health studies for C8 conducted for
DuPont’s Washington Works plant in West Virginia and the present investigation now being
conducted for the Chemours Fayetteville Works plant. The lessons that were learned in the
Washington Works investigation should be addressed by the current HH-SLEA and the CAP or at
least identified as areas of uncertainty. By ignoring those earlier extensive and robust animal and
epidemiology studies, it appears that the mistakes DuPont made in the Washington Works
investigations are being repeated in the current HH-SLEA. Lessons learned from the C8
investigation should be applied in assessing the risk of second generation PFAS like GenX and the
Attachment C PFAS. Specifically, in the case of C8, early past studies that relied solely on animal
studies significantly underestimated the risks to human health, particularly for those exposed to
PFAS-contaminated drinking water. Indeed, past PFAS health studies that relied solely on animal
studies were disastrous because numerous illnesses and diseases that went completely undetected
73
in animals produced a high incidence of disease (including cancer) in the human cohort that was
actually exposed (for decades) to PFAS. Chemours in its HH-SLEA fails to learn from these past
lessons, which have been heeded by most toxicologists and health professionals, and continues to
rely solely on animal studies that are incomplete or nonexistent (i.e., they have not yet been
performed).
Like the present CAP, which presents the early screening stages of investigations into the
health risks posed by PFAS based on incomplete animal toxicity studies, the early DuPont
Washington Works studies (which focused on PFOA toxicity and threats to human health) made
similar conclusions.
This conclusion was ultimately rejected by one of the largest epidemiological studies of all
time. As noted above in Section II, the C8 Science Panel emerged as a result of DuPont’s
settlement with a class of plaintiffs in the Leach action. Leach v. E. I. du Pont de Nemours & Co.,
No. 01-C-698 (Wood County W. Va. Cir. Ct.). The three epidemiologists appointed to the C8
Science Panel studied the toxicity of C8 to characterize human exposure risks for actual residents,
and found a “probable link” between human illness and exposure to C8 (at a dose of 50 parts per
trillion (ppt) or nanograms per liter (ng/L) over the course of one year) for the following diseases
among exposed residents:
• High cholesterol;
• Ulcerative colitis;
• Thyroid disease;
• Testicular cancer;
• Kidney cancer; and
74
• Pregnancy-induced hypertension.102
The C8 Science Panel’s findings made crystal clear that the animal studies DuPont relied on in the
Washington Works studies vastly underestimated the health threat to humans of exposure to even
small quantities of PFAS. Indeed, many of the toxic effects, illness, and disease that were
ultimately characterized in the human cohort exposed to PFOA at Washington Works were never
even identified in the animal studies DuPont relied on in its earlier health assessments.
With each passing year, the field of toxicology concludes that more and more PFAS are
far more toxic than previously thought. For example, the following graph shows how the
“assumed” safe level of PFAS in drinking water has dropped precipitously over the past decade,
which parallels the advancement of toxicological research. It shows that the “health-protective”
exposure levels deemed safe by the EPA for PFOA and PFOS in drinking water in 2009 decreased
from 400 and 200 ppt, respectively, to 70 ppt in 2016.
102 See C8 Probable Link Reports, C8 Science Panel, http://www.c8sciencepanel.org/prob_link.html (last
visited Feb. 21, 2020).
75
Source: P. Grandjean and E. Budtz-Jorgensen, Immunotoxicity of Perfluorinated Alkylates:
Calculation of Benchmark Doses Based on Serum Concentration in Children, 12 Environ. Health
35 (2013).
Moreover, even the EPA’s four-year-old level of 70 ppt (for the combined levels of PFOA
and PFOS) has now been shown to significantly underestimate the health threat of these PFAS.
Many states are urgently taking swift action to protect their citizens by setting acceptable levels
far below 70 ppt. Indeed, many are setting permissible levels of PFOA and PFOS at parts-per-
trillion levels in the low teens.
Because the current state-of-the-science toxicological database for GenX is in its infancy,
the toxicity values used in the HH-SLEA to calculate risks are highly uncertain and likely under-
protective; most certainly, future studies will show our current knowledge is very limited.
Therefore, the CAP and the HH-SLEA must include a commitment by Chemours to continue to
update its risk assessment as new toxicity and epidemiological information becomes available.
It is likely that these PFAS will be shown to produce similar toxic effects as listed above
when such studies become available. This assumption is based on the physical/chemical structural
similarities of all PFAS compounds, which toxicologists rely on to determine or predict whether
similar toxic effects will occur. For example, the NRDC states:
However, issues related to the entire PFAS class, which has now
grown to an estimated 4,700 chemicals, have been of increasing
concern for researchers and health authorities. Although there is not
a robust toxicity database for the suite of PFAS, it is generally
recognized that these chemicals are structurally similar, and it is
reported that the health risks associated with one PFAS are
expected for other PFAS as well.103
103 A. Reade, T. Quinn, and J. S. Schreiber, PFAS in Drinking Water 2019: Scientific and Policy Assessment
for Addressing Per-and Polyfluoroalkyl Substances (PFAS) in Drinking Water at 9, Natural Resources
Defense Council (Apr. 12, 2019), https://www.nrdc.org/sites/default/files/media-uploads/
nrdc_pfas_report.pdf.
76
VI. Providing the DRCs with the Same Level of Protection Afforded to Residents
Drinking Well Water Near Fayetteville Works Is the Only Means for
Protecting Human Health
Providing the DRCs with the same level of protection afforded to residents drinking well
water near Fayetteville Works is the only means of protecting human health. As stated in the CAP,
“Untreated well water was identified as the primary source of potential PFAS intake and
hazard.”104 When the HH-SLEA accounts for the effectiveness of the Chemours-provided drinking
water treatment systems that are currently in place, PFAS intake via drinking water and associated
hazards are substantially reduced and may be as low as zero.”105 But the HH-SLEA fails to
recognize the same risks posed to the DRCs. The same approach should be taken with respect to
DRCs, who should also be provided with point-of-use treatment. Chemours’ studies indicate “that
supplying whole building filtration systems and reverse osmosis units for qualifying residents
offsite reduces HFPO-DA (and Table 3+ PFAS) intake by over 92%, ensuring human receptor
exposures remain below hazard limits for HFPO-DA, based on the NC DHHS draft RfDo.”106
There is no reason why the DRCs should not be provided with the same level of protection afforded
to residents drinking well water near Fayetteville Works.
A. RO Is the Only Reliably Effective Point-of-Use PFAS Exposure
Reduction Method.
A recent study107 evaluated the effectiveness of point-of-use (POU) (i.e., at the drinking
water tap) in removing a suite of three perfluoroalkyl sulfonic acids, seven perfluoroalkyl
carboxylic acids, and six per- and polyfluoroalkyl ether acids in homes in central and southeastern
104 CAP at 35.
105 CAP at 35.
106 CAP at xv.
107 Herkert, N.J., et al., Assessing the Effectiveness of Point-of-Use Residential Drinking Water Filters for
Perfluoroalkyl Substances (PFASs), 2020 Environ. Sci. and Technol. Lett.,
https://dx.doi.org/10.1021/acs.estlett.0c00004.
77
North Carolina. POU filtration systems included countertop and pitcher filters, faucet-mounted
filters, activated carbon block refrigerator filters, activated carbon block under-sink filters, under-
sink dual-stage filters, and under-sink RO filters. The study found that “PFASs are difficult to
remove in full-scale water treatment systems because of their physicochemical properties.” But it
also found that the under-sink dual-stage and RO filters tested showed near complete removal of
all PFASs evaluated. In contrast, it found that all other filters containing activated carbon exhibited
variable PFAS removal. In these filters, PFAS removal efficiency was dependent on chain length,
with long-chain PFASs (∼60-70% removal) being more efficiently removed than short-chain
PFASs (∼40% removal). A few whole-house activated carbon POE systems (n = 8) were also
evaluated; however, results were variable, and in some cases (four of eight systems), increased
PFAS levels were observed in the filtered water.
RO is superior to these POU and POE methods, and is the only reliably effective method
to protect DRCs.
CONCLUSION
For the forgoing reasons, Plaintiffs respectfully request that DEQ compel Chemours to pay
for the acquisition, installation, operation and maintenance of three under-sink RO systems for
each residence in the municipal water supply districts and the past and future costs of bottled water
pending the installation of such systems.
Appendix A - Summary of PFAS Detected in Water Heater and Tap Water Sampling near
Wilmington, NC.
Appendix A
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilmington, NC. units = ng/LProperty: A A A A B B BSmpl ID: WAMP WAMP WAMP WAMP SAND SAND SANDLocation: Tap‐F Tap‐S Heat‐B Heat‐T Heat‐B.a Heat‐B.b Heat‐T.cWtr. Source: Municipal Municipal Municipal Municipal Municipal Municipal MunicipalCity: Calabash Calabash Calabash Calabash Hampstead Hampstead Hampstead Chemical County: Bruns. Bruns. Bruns. Bruns. Pend. Pend. Pend. Formula Smpl Date: 8/29/19 8/29/19 8/29/19 8/29/19 3/13/19 3/13/19 3/13/19 C3HF5O329.4 30.3 30.0 37.1 33.1 35.8 36.3PMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1 C4HF7O38.15 8.9911.4 13.56.71 6.31 8.82 C4HF7O422.4 25.4 21.2 30.44.18 3.75 4.90PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5C5HF9O39.3611.9 12.0 18.1ND ND2.13 C5HF9O5 6.9710.67.33 7.97 5.09 5.21 5.61C6HF11O6 3.47 2.92 2.77 2.53ND ND NDC7HF13O5SND ND ND ND ND ND ND C7H2F14O5S 2.11 2.17 1.53 1.98ND ND NDC7HF13O3ND ND ND ND ND ND NDC7HF13O7 1.55 1.92 1.45 1.50ND ND ND C7HF13O219.4 27.1 20.9 24.72.22 2.04 2.46 C6HF11O319.8 26.3 22.1 25.85.95 5.34 6.75Attachement C Total (Exceeds 70 ppt):123 148 131 164 57 58 67Notes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outside spigot/tap, Out‐F = First‐flush from outside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap water sample.Hexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEPA) Method 537 and samples collected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL Laboratories, LLC (Charleston, SC). Wtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAC:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 1 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpABC CCCCCDDSAND ERGE ERGE ERGE ERGE ERGE ERGE HAMP HAMPHeat‐T.d Heat‐B Heat‐T Heat‐B.a Heat‐B.b Heat‐T.c Heat‐T.d Heat‐B.a Heat‐B.bMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipal MunicipalHampstead Leland Leland Leland Leland Leland Leland Leland LelandPend. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns.3/13/19 6/21/18 6/21/18 3/12/19 3/12/19 3/12/19 3/12/19 3/12/19 3/12/1939.0 21.5 13.75.87X5.75X8.22X5.21X9.52X9.70X9.58ND ND16.7X7.01X6.03X6.27X8.76X8.42X4.5717.18.89 6.44X6.47X6.52X5.89X7.71X7.87X3.80ND ND NDUXNDUXNDUXNDUX2.85JXNDUX6.0514.16.61 2.35JX2.1JX1.36JX1.81JX2.25JX2.81JXND4.98 2.57NDUXNDUXNDUNDUXNDUXNDUXND2023.37NDUXNDUXNDUXNDUXNDUXNDUXND8.40ND NDUXNDUXNDUXNDUXNDUXNDUXND ND ND NDUXNDUXNDUXNDUXNDUXNDUXND7.89ND NDUXNDUXNDUXNDUXNDUXNDUX2.6416.8 18.11.79J1.62J1.92 1.96 2.54 1.99J6.8415.3 16.78.70 8.79 7.71 7.7110.1 10.072 308 70 42 32 32 29 44 41 C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 2 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpADDDDDDEEHAMP HAMP HAMP HAMP HAMP HAMP LEE LEEHeat‐B.a/Dup_cHeat‐B.b/Dup_dHeat‐T.e Heat‐T.fHeat‐T.e/Dup_gHeat‐T.f/Dup_hTap‐F Tap‐SMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalLeland Leland Leland Leland Leland Leland Leland LelandBruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns.3/12/19 3/12/19 3/12/19 3/12/19 3/12/19 3/12/19 10/24/19 10/24/199.90X9.38X8.16X9.54X6.68X8.6653.1 56.68.15X8.42X7.38X7.67X7.04X7.7114.1 16.68.64X7.96X6.83X7.14X3.91X6.5645.3 44.8NDUXNDUXNDUXNDUXNDUXND12.0 12.43.24JX2.59JX2.35JX1.99JX2.33JX1.7215.4 18.0NDUXNDUXNDUXNDUXNDUXND6.06 5.70NDUXNDUXNDUXNDUXNDUXND2.41 2.23NDUXNDUXNDUXNDUXNDUXND3.07 2.95NDUXNDUXNDUXNDUXNDUXNDND NDNDUXNDUXNDUXNDUXNDUXND2.7 2.741.70J1.63J1.78 2.25 1.87 1.5230.2 30.19.5610.18.67 8.90 8.50 8.2547.8 46.441 40 35 37 30 34 232 239C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 3 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAE E EFFFFGGLEE LEE LEE FOUR FOUR FOUR FOUR SELL SELLHeat‐BHeat‐B/Dup_2Heat‐T Tap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐SMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipal MunicipalLeland Leland Leland Oak Is. Oak Is. Oak Is. Oak Is. Oak Is. Oak Is.Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns.10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 10/24/1936.7 42.9 53.8 32.3 43.6 27.89.7576.5 73.417.2 20.5 23.7ND8.3111.24.1118.6 15.035.4 43.3 51.1 24.0 33.3 26.8 10.3 57.1 61.54.96 5.56 6.64 7.1 8.0ND ND13.4 13.311.3 12.3 15.19.1413.89.39 3.8521.1 20.63.93 3.46 4.05 3.39 4.23 2.37 1.4 7.03 8.06ND ND1.40ND1.47ND ND1.94 2.001.57 1.68 2.03 2.49 2.74ND ND5.02 4.67ND ND ND ND ND ND ND ND ND1.19 1.54 2.75ND2.3ND ND3.88 3.2319.6 23.2 26.0 14.6 21.3 13.45.4936.1 37.426.5 30.9 37.1 21.5 32.2 187.6952.4 54.2158 185 224 115 171 10943293 293C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 4 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAGGHHHH I I ISELL SELL WATE WATE WATE WATE GOOS GOOS GOOSHeat‐B Heat‐T Tap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐BMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipal MunicipalOak Is. Oak Is. Ocean Isle Ocean Isle Ocean Isle Ocean Isle Riegelwood Riegelwood RiegelwoodBruns. Bruns. Bruns. Bruns. Bruns. Bruns. Colum. Colum. Colum.10/24/19 10/24/19 8/29/19 8/29/19 8/29/19 8/29/19 10/24/19 10/24/19 10/24/1917.6 14.429.7 29.1 35.2 30.359.3 63.5 52.45.01 5.527.00 6.19 7.56 6.8422.7 19.1 22.616.9 13.624.1 23.2 27.9 26.347.0 51.8 50.0ND ND11.6 13.44.69 3.3511.4 11.03.945.13 4.378.99 9.21 9.01 8.1916.9 18.2 15.22.00 1.284.09 4.07 4.06 3.015.89 5.89 5.41ND NDND ND ND ND1.82 1.51NDND ND1.99 1.79 1.69 1.913.39 3.85 3.02ND NDND ND ND NDND ND NDND NDND2.03 1.42 1.772.60 2.34 2.838.51 8.8318.5 17.0 16.8 17.731.2 31.4 24.39.0211.320.9 21.6 20.7 20.341.2 44.5 33.664 59127 128 129 120 243 253 213C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 5 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAI JJJJKKKKGOOS ODEL ODEL ODEL ODEL RIVE RIVE RIVE RIVEHeat‐T Tap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐B Heat‐TMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipal MunicipalRiegelwood Shalotte Shalotte Shalotte Shalotte Shalotte Shalotte Shalotte ShalotteColum. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns. Bruns.10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 8/29/19 8/29/19 8/29/19 8/29/1948.1 20.6 15.3 64.0 98.322.4 31.6 36.3 34.017.92.71ND19.3 24.16.06 7.97 8.17 8.6743.8 15.99.6457.8 74.218.9 25.4 29.6 26.25.34 5.38 2.5312.5 17.214.38.49 4.55 5.6813.96.97 4.3719.5 26.05.3510.78.89 9.114.73 2.56 1.23 5.98 7.542.23 4.39 3.62 3.541.26ND ND1.66 1.71ND ND ND ND3.55 1.76ND4.32 5.311.79 2.22 2.21 2.05ND ND ND ND NDND ND ND ND3.29ND ND3.00 3.2ND2.69 1.85 1.7524.7 12.86.9335.4 39.514.0 18.9 20.2 21.933.1 17.69.4348.5 63.316.2 22.7 20.9 20.7200 86 49 272 360 101 135 136 134 C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 6 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAK L L L L MMMRIVE ADAM ADAM ADAM ADAM ARBO ARBO ARBOHeat‐T/Dup_4Tap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐BMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalShalotte Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonBruns. New Han. New Han. New Han. New Han. New Han. New Han. New Han.8/29/19 10/24/19 10/24/19 10/24/19 10/24/19 10/25/19 10/25/19 10/25/1931.163.9 68.9 55.9 72.3 71.6 68.7 62.88.9025.9 17.8 30.4 36.4 28.4 36.5 27.826.757.9 56.5 54.5 70.9 68.5 72.6 46.818.411.3 11.29.6611.88.4712.67.449.7818.7 17.1 15.4 23.9 18.1 21.5 16.53.874.56 4.21 3.40 5.28 4.18 4.78 3.58NDND ND ND ND ND ND ND2.012.14 2.04 1.54 1.77 1.71 2.21 1.84NDND ND ND ND ND ND ND1.921.56ND ND ND ND1.31 1.4018.821.6 20.5 15.3 19.9 16.7 20.8 15.120.040.3 40.2 27.1 32.7 29.8 33 28.3141 248 238 213 275 247 274 212C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 7 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAMNNNNOOOARBO BOHN BOHN BOHN BOHN BOTS BOTS BOTSHeat‐T Tap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐BMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.10/25/19 8/28/19 8/28/19 8/28/19 8/28/19 8/27/19 8/27/19 8/27/1957.441.2 38.5ND ND43.9 47.0 45.627.611.5 11.8ND ND16.2 15.5 13.152.336.1 35.7ND ND42.6 41.2 37.38.578.37 6.03ND ND8.01 6.03 5.2817.712.4 11.3ND ND11.0 10.9 11.42.932.35 2.50ND ND2.17 1.86 2.04NDND ND ND ND ND ND ND1.77ND ND ND ND ND ND NDNDND ND ND ND ND ND NDNDND ND ND ND ND ND ND17.110.19.89ND ND9.91 9.78 8.0226.318.0 16.8ND ND20.2 19.0 16.8212 140 133‐ ‐ 154 151 140C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 8 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAOPPQQQQRBOTS CARR CARR HYAN HYAN HYAN HYAN JAYBHeat‐T Tap‐F Tap‐S Tap‐F Tap‐S Heat‐B Heat‐T Tap‐FMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.8/27/19 10/24/19 10/24/19 10/25/19 10/25/19 10/25/19 10/25/19 8/28/1946.079.6 78.8 68.0 71.1 63.6 65.842.514.228.9 25.4 22.3 23.3 21.5 20.611.643.868.4 68.2 64.8 60.5 55.5 61.339.46.6411.6 12.3 10.7 11.0 10.7 11.56.1712.019.3 20.2 18.3 18.7 16.7 21.010.73.103.64 4.62 4.86 4.02 4.37 3.972.68NDND ND ND ND ND NDNDND1.91 2.48 2.24 2.32 1.90 2.25NDNDND ND ND ND ND NDNDNDND ND1.55ND ND NDND9.5520.2 22.6 19.5 18.1 18.9 19.69.6318.835.6 40.6 36.8 34.5 34.9 39.816.7154 269 275 249 244 228 246 139C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 9 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpARRRRSSSSJAYB JAYB JAYB JAYB LAUR LAUR LAUR LAURTap‐F/Dup_1Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐B Heat‐TMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.8/28/19 8/28/19 8/28/19 8/28/19 8/27/19 8/27/19 8/27/19 8/27/1945.7 47.1 28.8 44.2 35.8 43.7ND46.913.1 12.57.6112.9 15.7 13.7ND13.542.2 43.4 23.1 37.8 34.4 39.1ND41.65.93 5.69 2.99 5.70 4.72 6.24ND4.7712.8 10.76.6410.26.6812.1ND9.222.08 3.13 1.59 2.54 2.63 3.19ND2.31ND ND ND ND ND ND ND NDND ND ND ND ND ND ND NDND ND ND ND ND ND ND NDND ND ND ND ND ND ND ND9.82 8.63 6.33 7.98 8.70 9.76ND9.9816.8 18.8 12.3 16.2 20.0 19.2ND17.7148 150 89 138 129 147 ‐ 146C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 10 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpATTTTUUUULULL LULL LULL LULL MASO MASO MASO MASOTap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐B Heat‐TMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.10/24/19 10/24/19 10/24/19 10/24/19 10/25/19 10/25/19 10/25/19 10/25/1970.9 63.9 54.4 59.6 73.5 63.3 67.8 72.523.0 20.5 25.7 29.7 37.7 34.3 34.9 38.366.6 55.4 49.8 62.7 68.1 66.1 69.1 74.312.7 10.19.30 9.6712.7 11.1 11.8 12.820.8 17.3 17.4 17.4 20.7 20.0 19.7 24.25.62 3.85 3.4 3.21 3.87 4.53 4.35 4.45ND ND ND ND ND ND ND ND2.3 2.11 1.48 1.71 2.15 1.86 2.10 2.10ND ND ND ND ND ND ND NDND1.24ND1.63ND1.41 1.67ND17.7 19.4 15.5 17.7 18.4 17.9 20.1 21.244.2 35.7 27.8 29.7 32.4 30.1 31.7 34.5264 230 205 233 270 251 263 284C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 11 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAVVVVWWWWONEI ONEI ONEI ONEI OYST OYST OYST OYSTTap‐F Tap‐S Heat‐B Heat‐T Tap‐F Tap‐S Heat‐B Heat‐TMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.8/27/19 8/27/19 8/27/19 8/27/19 10/25/19 10/25/19 10/25/19 10/25/1938.9 43.4 51.3 46.456.3 59.3 64.5 72.522.0 12.8 14.4 13.732.0 33.0 31.3 34.333.4 43.1 40.1 41.058.9 59.3 69.1 67.68.18 4.08 4.67 4.1110.4 10.4 10.5 10.46.512.2 10.4 11.217.3 16.5 18.2 17.62.09 3.21 2.9 2.324.29 4.47 4.46 4.29ND ND ND NDND ND ND NDND1.22ND ND1.87 1.88 1.75 2.07ND ND ND NDND ND ND NDND ND ND NDND ND1.44ND5.7110.2 10.69.9316.7 18.4 18.6 20.518.7 18.3 21.1 16.428.4 29.1 29.9 35.0135 149 155 145 226 232 250 264C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 12 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAXXXXXYYZRAND RAND RAND RAND RAND TREE TREE WINDTap‐F Tap‐STap‐S/DUP_1Heat‐B Heat‐T Tap‐F Tap‐S Heat‐B.aMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Wilmington Wilmington Wilmington WilmingtonNew Han. New Han. New Han. New Han. New Han. New Han. New Han. New Han.10/24/19 10/24/19 10/24/19 10/24/19 10/24/19 10/25/19 10/25/19 3/13/1967.9 60.3 62.7 74.0 72.0 48.0 60.921.7X22.4 18.6 18.9 21.9 24.3 29.6 32.75.01X62.5 55.2 60.5 64.4 62.4 47.4 60.96.6211.3 11.0 11.1 12.5 11.06.7411.72.74JX18.4 16.5 17.4 19.2 16.7 13.5 22.412.5X4.6 3.74 4.63 3.69 4.3 3.16 4.844.74JXND ND ND ND ND ND NDNDUX2.25 1.89 2.12 2.16 2.49ND1.84NDUXND ND ND ND ND ND NDNDUX1.25ND ND1.47ND ND NDNDUX21.2 21.0 20.8 19.5 19.0 12.7 18.92.43J38.4 36.5 39.8 40.8 40.5 26.7 31.25.05250 225 238 260 253 188 24561C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 13 of 14
Table A‐1. Summary of PFAS Detected in Water Heater and Tap Water Sampling near Wilminunits = ng/LPMPA PFMOPrA Perfluoro‐2‐methoxypropanoic acidPerfluoro‐3‐methoxypropanoic acid13140‐29‐9377‐73‐1PEPA PFMOBA 2,3,3,3‐Tetrafluoro‐2‐(pentafluoroethoxy) propanoic acidPerfluoro‐4‐methoxybutanoic acid267239‐61‐2863090‐89‐5AttachemNotes/Comments:9 9 9 = Sample result for single PFAS above 10 ng/L limit in Consent Order (Para. 20.a)9 9 9 = Sample result for combination of PFAS above 70 ng/L limit in Consent Order (Para. 20.b)CASN = Chemical abstracts service registry numberng/L = Nanograms per liter (a.k.a. parts per trillion or pptr)ND = Not detectedPFAS = Per‐ and polyfluoroalkyl substancesCounty ‐ Bruns = Brunswick, Col. = Columbus, New Hand = New Handover, and Pend = Pender.Common Name Chemical Name CASN Perfluoro(3,5,7,9‐tetraoxadecanoic) acid 39492‐90‐5 Perfluoro‐ 2‐methoxyacetic acid 674‐13‐5Perfluoro(3,5‐dioxahexanoic) acid 39492‐88‐1 Perfluoro(3,5,7‐trioxaoctanoic) acidDetected PFAS listed in Attachment C of 2/25/19 Consent OrderLocations ‐ Dup = Blind duplicate, Heat‐B = Bottom of water heater sample, Heat‐T = Top of water heater sample, O.S. = Outsidoutside tap, Out‐S = Follow‐up outside tap water sample, Tap‐F = First‐flush sample from tap, and Tap‐S = Follow‐up tap waterHexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic acid, 2,2,3,3,4,4‐ hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐174767‐10‐3; 801212‐59‐9Perfluoro(3,5,7,9,11‐pentadodecanoic) acidHFPO‐DA / PFPrOPrA / “GenX”2,3,3,3‐Tetrafluoro‐2 (1,1,2,2,3,3,3‐heptafluoropropoxy)‐propanoic acid13252‐13‐639492‐91‐6 Perfluoroheptanoic acidSamples collected in June 2018 and March 2019 tested consistent with U.S. Environmental Environmental Protect Agency (USEcollected in August 2019 and October 2019 tested consistent with USEPA Method 537.1. All tests completed by GEL LaboratorWtr. Source ‐ Municipal = Minicipal water provider. PFESA‐BP1 / Nafion BP #1PFESA‐BP2 / Nafion BP #239492‐89‐2PFMOAA PFO2HxA PFO3OAPFO4DANafion Byproduct 1 66796‐30‐3; 29311‐67‐9Nafion Byproduct 2 749836‐20‐2375‐85‐9PFECA‐G TAFN4 / PFO5DAPFHpAZZZZAAAAAAAAWIND WIND WIND WIND LIBE LIBE LIBE LIBEHeat‐B.b Heat‐B.c Heat‐T.e Heat‐T.f Tap‐F Tap‐S Heat‐B Heat‐TMunicipal Municipal Municipal Municipal Municipal Municipal MunicipalMunicipalWilmington Wilmington Wilmington Wilmington Winnabow Winnabow Winnabow WinnabowNew. Han. New. Han. New. Han. New. Han. Bruns. Bruns. Bruns. Bruns.3/13/19 3/13/19 3/13/19 3/13/19 8/27/19 8/27/19 8/27/19 8/27/1921.9X20.7X18.2X19.3X42.4 37.5 42.5 36.67.15X7.36X7.27X8.46X11.5 9.849.3810.14.87 3.69 3.03 2.5234.0 30.6 34.6 30.82.77JX2.71JX2.05JX2.43JX7.29 5.84 7.12 5.9112.0X11.3X10.2X9.83X11.2 10.6 10.3 10.84.94JX5.03X3.32JX3.41JX4.91 4.19 4.26 4.68NDUXNDUXNDUXNDUXND ND ND NDNDUXNDUXNDUXNDUX2.66 2.58 2.34 2.48NDUXNDUXNDUXNDUXND ND ND NDNDUXNDUXNDUXNDUX1.81 2.00ND1.861.95J1.68J1.51J1.31J24.8 24.9 27.2 26.34.74 5.01 5.50 5.2127.7 25.1 25.0 25.260 57 51 52168 153 163 155C:\Users\dhamel\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\79AGHQ0D\Sampling Summ Wtr Heat Tap 2020‐02‐17, SummPrinted: 2/20/2020 at 9:56 AMPage 14 of 14
From:Mihaela Henderson
To:SVC_DENR.publiccomments
Subject:[External] Non-concurrence with Corrective Action Plan
Date:Monday, April 6, 2020 7:07:31 PM
Attachments:Corrective_Action_Plan_MH.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Hello,
Please find attached my comments of non-concurrence with Chemours’ proposed groundwater
corrective action plan.
Mihaela Henderson
April 6, 2020
Re: Chemours Corrective Action Plan
Dear NC DEQ,
I am a resident of Gray’s Creek and live in a household recently determined to be affected by
PFAS contamination. I DO NOT CONCUR with the Corrective Action Plan. Additionally, for the
record, I ALSO DO NOT CONCUR with the 2018 Consent Order NC DEQ entered allegedly on my
behalf, without my knowledge or consent, and which grossly overlooks my interests and those
of other people directly affected by PFAS contamination.
I request that:
1. Instead of hiding behind claims that off-site groundwater remedying is economically and
technologically infeasible, Chemours should provide permanent home solutions in the
form of municipal water connection or upgraded whole house water treatment systems.
As a victim of Chemours contamination and NC deregulation, I do not think I should
carry the burden of limited water supply and logistical hassle associated with the 3
under-the-sink RO systems. That Chemours can shirk its responsibility to Gray’s Creek
residents with 3 RO systems and disingenuous excuses that a $90k municipal water
connection is cost prohibitive over a $70k connection is unacceptable. Cumberland
County and, basically, Cumberland County residents, should not be saddled with the
cost of running water lines to Gray’s Creek. Nor should the people affected have to wait
their turn for years as the county may scramble to find money and complete
connections in phases. As an “affected party” per 15A NCAC 02L .0202(c) and § 143-
215.2A (Relief for contaminated private drinking water wells), I demand that the
Secretary of NC DEQ and the Governor of the State of North Carolina direct Chemours
to provide a permanent solution for all wells found to be contaminated in exceedance
of the NC groundwater standards based on the admission that Chemours has no plan
for remediation of contaminated properties.
2. NC DEQ respect and enforce NC Groundwater Quality Standards. 15A NCAC 02L
.0202(b.1.) states that “Where the standard for a substance is less than the practical
quantitation limit, the detection of that substance at or above the practical quantitation
limit constitutes a violation of the standard.” Yet NC DEQ’s actions suggest at times that
these standards are mere suggestions. Companies like Chemours show complete
disregard for the law and public health. Please take actions that enforce groundwater
quality standards and promote compliance.
3. Chemours make all efforts to remedy on-site contamination and attain the maximum
reduction in onsite groundwater PFAS contamination that is achievable.
4. Chemours reduce PFAS contamination of Cape Fear River in the shortest time possible.
Four to five or longer years is not acceptable.
5. Chemours test for all PFAS chemical compounds that can be detected/tested and that
were produced, either directly or indirectly, on site. There seems to be an inconsistency
in current testing with NC DEQ and Chemours testing some compounds in Attachment C
of the Consent Order but not all. Testing should consider all the compounds that are
either manufactured or by-products of Chemours activities and that currently can be
detected by lab tests.
In my opinion, the goal of the proposed Corrective Action Plan is to make things right for
Chemours not the people affected by its PFAS contamination. Charging an offender with the
task of crafting a plan that remedies the offense can hardly be a sound plan. As a taxpayer, I
expect NC DEQ to do its job, develop and maintain expertise, and protect and safeguard the
environment and, implicitly, the well-being of NC residents. While I realize NC DEQ is vastly
underfunded and understaffed, I urge NC DEQ staff to carefully consider the implications
oversights may have for those directly affected by Chemours’ history of deception and PFAS
contamination. Along with all other individuals struggling with PFAS contamination, I rely on NC
DEQ to seek and promote remediation solutions that serve the interests of the people and not
of the contaminators. Please fulfill the responsibilities associated with your office and request a
Corrective Action Plan that benefits the victims not the villain.
Thank you,
Mihaela Henderson
2911 Chicken Foot Rd
Hope Mills NC 28348
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Subject:FW: [External] Fwd: Clean Cape Fear"s response to Chemours Corrective Action Plan
Date:Monday, April 6, 2020 5:08:08 PM
Attachments:Chemours CAP_Clean Cape Fear comments .pdf
From: Emily Donovan <esdonovan@gmail.com>
Sent: Monday, April 6, 2020 3:36 PM
To: Holman, Sheila <sheila.holman@ncdenr.gov>
Subject: [External] Fwd: Clean Cape Fear's response to Chemours Corrective Action Plan
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Dear Ms. Holman, Please find attached the official response from Clean Cape Fear regarding Chemours'Corrective Action Plan.
Due to the global pandemic of COVID-19, our ability to participate in three public
hearings regarding this corrective action plan was lost when they were all canceled.
Unless DEQ is fully committed to following the advice and comments submitted by
Clean Cape Fear, SELC and CFPUA, we cannot support any actions being taken until the public has been given their right to access public hearings, fully learn from
experts what’s at stake with this next phase of the consent order, and be given a
chance to self-advocate for their own families.
We appreciate the ability to be allowed to submit this public comment. We request an opportunity to be heard in person at public hearings and for the scientists involved in
the ongoing research process to be heard as well. We support the recommendations
made by SELC and CFPUA and believe that the proposed corrective action plan
should not be approved in its current form.With gratitude, Emily DonovanCo-FounderClean Cape FearFB/Twitter: @CleanCapeFearwww.cleancapefear.org [cleancapefear.org]704.491.6635 | cell
"Above all, maintain constant love for one another, for love covers a multitude of
sins." 1 Peter 4:8
April 6, 2020
Dear Ms. Holman:
Please consider this the comment by our group, Clean Cape Fear , on the proposed Chemours 1
Corrective Action Plan.
Chemours and DuPont were allowed, for decades, to commit a crime of epic proportions in
North Carolina. They knowingly subjected over a quarter of a million residents to large
quantities of unnatural, human-made synthetic PFAS chemicals which ended up in our drinking
water. A study published in October 2019 by Dr. Detlef Knappe’s lab estimates that
approximately 130,000 ppt of total PFAS were detected in the Cape Fear River near the intake
pipes for our public water systems . This water system provides drinking water for nearly 2
300,000 residents living in Brunswick, Pender, and New Hanover counties . 3
Chemours knowingly admits that PFAS chemical discharges into our primary source of drinking
water occurred since their Fayetteville Works facility began fluorochemical operations in North
Carolina in 1980. We gave this water to our children--to our babies. We drank this water
ourselves. Pregnant women drank this water, cancer patients, immunocompromised residents, the
elderly--all drank this water, consumed it with food and otherwise used it. Doctors and dentists
unknowingly encouraged us to drink more of this water--assured us it was safe and healthy for
our bodies and our families.
We trusted our local government. We trusted our state regulators. We trusted our federal laws.
We trusted each of these entities were doing their jobs to uphold existing laws and protect us
from irresponsible corporations. That public trust was broken in June 2017 when we learned
DuPont and Chemours failed to follow existing laws and put our lives, our environment and the
peace of mind of our communities in harm’s way.
Not only did DuPont, and later Chemours, fail to follow existing state and federal laws, but they
also failed to proactively stop PFAS discharges at their Fayetteville, NC facility while under
intense legal scrutiny in Parkersburg, WV at their Washington Works location. DuPont knew as
early as 20 years ago about technologies like the thermal oxidizer, which existed and worked.
1 https://www.cleancapefear.org/
2 https://pubs.acs.org/doi/abs/10.1021/acs.estlett.9b00525
3 https://www.lcfwasa.org/
They knew because they installed similar air abatement technology at their Washington Works
facility between 2000 - 2001--yet failed to do the same for their Fayetteville Works facility until
Chemours was legally forced to by the state of North Carolina in 2018 . 4
This current corrective action plan falls way too short considering the proportion of harm
committed by DuPont and Chemours. It fails to address interim solutions and interventions for
the existing and on-going exposure of PFAS chemicals for downstream surface water users.
Since the initial February 2019 consent order was signed, it has been revealed the groundwater
contamination beneath Chemours’ Fayetteville Works facility is so severely contaminated this
seepage into the Cape Fear River is causing chronically high levels of PFAS detected in finished
tap water for downstream users. A January 2020 Environmental Working Group report revealed
Brunswick County residents were drinking some of the highest levels of PFAS chemicals in their
finished tap water than any other location tested in this nationwide study. 5
Under the current consent order, Chemours is legally required to provide interim water
immediately, and a permanent solution within 6 months, for any groundwater well contaminated
with 70 ppt of total PFAS or 10 ppt of any individual PFAS listed in Attachment C. These
protections are not being afforded to surface water users and it is creating an inequity between
surface water and groundwater users. Residents, regardless of where their water is sourced,
should be able to turn on their faucets and trust the water they use--water they pay for—not to
have any PFAS chemicals in it. Chemours must begin providing immediate interim water for all
downstream communities who rely on the chronically contaminated Cape Fear River as their
primary source of drinking water. This is our river. It belongs to the public. The state of North
Carolina let DuPont and Chemours borrow it for their manufacturing processes. Chemours and
DuPont failed to follow the rules and return the river water they borrowed to the same or better
quality it was given to them. That’s their problem. Not ours. We should not be forced to pay for
water we don’t feel safe using. We should not be forced to send our children to school with
bottled water because they are afraid to drink from the water fountains at the school. Both
Chemours and DuPont are multi-billion dollar companies with annual revenues well capable of
funding the necessary and on-going clean-ups we need and deserve to feel whole and maintain
peace of mind.
Chemours should be held accountable to PFAS chemical groundwater clean-up standards at PQL
(Practical Quantitative Levels) which is the law and established for a reason. These safeguards
4
https://www.northcarolinahealthnews.org/2018/10/08/regulators-prepare-crackdown-dupont-chemours-ge
nx/
5 https://www.ewg.org/research/national-pfas-testing/
are in place to protect us from exposures to human-made chemicals which have not been fully
researched for their toxicological effects. It should not be the burden of North Carolina residents
to determine if any PFAS chemicals are safe for consumption after we’ve been chronically
exposed to them.
We also feel the corrective action plan should include toxicological studies for PFAS chemicals
already detected in human blood of Wilmington residents who participated in the NC State GenX
Exposure Study as well as a few other compounds. These toxicological studies should determine 6
the effects of mixtures and cumulative effects because residents were not exposed to one
isolated PFAS chemical. We were chronically exposed to a “cocktail” of Chemours and DuPont’s
chemical waste. Hydro-Eve, NVHOS, PFO3OA, PFO4DA, and PFO5DoDA should be added to
the list of PFAS chemicals required for toxicological study by the February 2019 consent order.
Since the Consent Order was filed, numerous scientific studies have continued to come out
throughout the world exposing the health and environmental dangers of these chemicals. Yet in
its proposed corrective action plan, Chemours would blithely assure the State that the chemicals
are safe. What needs to happen is for Chemours to be forced to pay for the needed science to be
done, by scientists like Dr. DeWitt, Dr. Stapleton, and other leading, independent, PFAS
toxicologists and epidemiologists, at Chemours’ expense - not the public’s expense - so we can
all learn the full extent of the problem. The data generated from these studies should be publicly
available and easily accessible.
Under the current consent order, Chemours is performing ecotoxicology studies for a limited
number of PFAS that were emitted into the Cape Fear River. However, under the current action
plan, it is unclear how Chemours will face consequences for the harming of our wildlife. Should
their ecotoxicology studies reveal harmful effects, what is the plan for remedying these effects on
our wildlife? A recent study from NC State University has shown that Striped Bass in the Cape 7
Fear River had elevated levels of total PFAS in their serum when compared to a reference
population, including PFOS, GenX, Nafion byproduct 2, among others. This study also showed
that these fish had elevated markers of kidney and liver damage and displayed altered immune
function. Chemours has not only poisoned our coworkers, neighbors, and loved ones; they have
also poisoned the animals that depend on the Cape Fear River. This also begs the question of
how consumption of fish from the Cape Fear River impacts exposure. It is widely established
that PFAS bioaccumulate, so how does the impact on our wildlife in turn impact the health of
those who consume the fish? This is just one of many questions raised by the Corrective Action
Plan that should be addressed by NC DEQ immediately. In an abundance of caution, fish
advisories should be put in place if they do not already exist. Chemours should also be forced to
6 https://chhe.research.ncsu.edu/the-genx-exposure-study/
7 https://www.sciencedirect.com/science/article/pii/S0160412019334762
pay for the repopulation of certain fish and other wildlife populations in the Cape Fear River
basin should it be determined their PFAS chemical waste caused reproductive harm.
The recent COVID-19 outbreak shows what happens when risks to human health are not
understood and controlled but instead are allowed to permeate the environment. Here, neither
DuPont nor Chemours did the necessary science or took the necessary steps to prevent the
dangers of PFAS in our communities. The lessons we are even now learning from the pandemic
tell us that the last thing we should do is let Chemours off the hook.
Lastly, due to the global pandemic of COVID-19, our ability to participate in three public
hearings regarding this corrective action plan was lost when they were all canceled. Unless DEQ
is fully committed to following the advice and comments submitted by Clean Cape Fear, SELC
and CFPUA, we cannot support any actions being taken until the public has been given their
right to access public hearings, fully learn from experts what’s at stake with this next phase of
the consent order, and be given a chance to self-advocate for their own families.
We appreciate the ability to be allowed to submit this public comment. We request an
opportunity to be heard in person at public hearings and for the scientists involved in the ongoing
research process to be heard as well. We support the recommendations made by SELC and
CFPUA and believe that the proposed corrective action plan should not be approved in its
current form.
With gratitude,
Emily Donovan
Co-Founder of Clean Cape Fear
From:gostby.nc@gmail.com
To:SVC_DENR.publiccomments
Subject:[External] FW: Chemours Corrective Action Plan
Date:Monday, April 6, 2020 5:04:10 PM
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attachment to report.spam@nc.gov
Hello,
The definition of what chemicals should be allowed is very simple: ONLY chemicals that break down
in the human or animal digestive tracts should be allowed. These digestive systems have been
defined for millions of years. They are very simple chemical processes. If a chemical substance that is
ingested cannot be broken down by the digestive process, it gets lost in the digestive tract, gets
stored somewhere in the body, and ultimately creates some type of health issue, depending on the
toxicity of the chemical substance and where it is stored. It is not magic, it is basic chemistry 101.
There is no reason that the cost of the cleanup of the chemical discharges from Chemours should be
paid by anyone other than Chemours. This was in fact a chemical spill, and should be treated no
differently than any other chemical spill.
DEQ must have the health and safety of the citizens of NC as their first priority. From that
perspective, your decisions should be very simple.
Gary
Gary Ostby
1156 Leesburg Drive
Leland, NC 28451
910-371-3966
From:Hope Taylor
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan--Clean Water for NC
Date:Monday, April 6, 2020 5:01:02 PM
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attachment to report.spam@nc.gov
April 6, 2020
Submitted by electronic mail to publiccomments@ncdenr.gov
Comments of Clean Water for North Carolina on Corrective Action Plan to Chemours,
Fayetteville Works
Clean Water for North Carolina previously commented on the draft Consent Order proposed
for control of air emissions of PFAS compounds by Chemours Fayetteville Works, stating that
project control of a certain percentage of air emissions of these compounds was inadequate
to protect drinking water and public health, and stating that operations to produce PFAS
compounds at Chemours should be completely stopped. First DuPont, and now Chemours
have shown themselves to be as slippery in their approaches to accountably reducing their
impacts on air and water emissions and human health as the compounds they have been
producing. Both entities have taken advantages of regulatory loopholes of several types to
avoid being held accountable. Just as cities and states throughout the country are regretting
the failure to attend to warnings about the impact of a novel virus on our nation’s health,
health systems and to maintain critical protective equipment, North Carolina’s ecosystems
and public health may well suffer deeply for failure to take truly protective measures and hold
major polluters, such as Dupont and Chemours, accountable for the consequences of their
highly profitable production, grossly inadequate controls of air and water emissions of
uncharacterized and inadequately studied compounds that should never have been permitted
to be released to the environment in any amount.
1) The CAP plan is inadequate to achieve significant reductions to ground and surface
water in timely manner to assure safety of drinking water supplies. Moreover, the fact
that this class of compounds undergoes almost no degradation in the environment
should mandate the cessation of their production. Even if emissions are significantly
reduced, they will continue to accumulate in the environment, presenting a long term
risk of remobilizing in the environment with continued exposure of human and non-
human receptors. There is no amount of convenience of stain resistance or non stick
attributes that can justify allowing the continued accumulation of these substances in
the environment.
2) The CAP fails to even specify the base time period for most of the anticipated percent
reductions in releases to air or water, a shameless invitation to failed accountability for
any consent order.
3) In the Performance Monitoring plan, there is no provision for split sampling between
the company and the DEQ, much less between DEQ and parties providing water
services to the public, such as CFPUA. This should be a minimal requirement for
independence in monitoring conditions of source water.
4) As the species of PFAS included in various health assessments are inconsistent and the
assumptions applied to exposure scenarios are not conservative, the statement that
health impacts of given concentrations will be insignificant must be challenged.
5) The justification of proposed remedies to on-site sources of contamination is not
presented rationally and, given the unsubstantiated models presented, the public has
no assurance that those proposed remedies will in fact capture and remove sources of
long term contamination to the Cape Fear River and groundwater.
6) We are particularly concerned about the impact of Chemours and Kuraray operations
on regional groundwater as a source of groundwater for most rural residents in the
area. The fact that the cost of remediation of groundwater, as compared to the cost of
water filtration systems, is considered to rise into the billions give some indication of
the value of the groundwater that these industries have so massively contaminated.
Rather than simply allowing the responsible party to provide whole house filtration
systems, while continuing to deepen the damage to NC’s groundwater should be
considered criminal behavior and never tolerated.
Yours truly,
Hope Taylor, MSPH,
hope@cwfnc.org
Executive Director, Clean Water for NC
Durham and Ashevill
www.cwfnc.org [cwfnc.org].
From:Grady McCallie
To:SVC_DENR.publiccomments; Holman, Sheila
Cc:Lane, Bill F; Scott, Michael; Abraczinskas, Michael; Smith, Danny
Subject:[External] comments on Chemours" Corrective Action Plan
Date:Monday, April 6, 2020 3:08:38 PM
Attachments:Env ltr re CAP 4-6-20.pdf
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attachment to report.spam@nc.gov
We are grateful for the chance to offer public comments on Chemours’ proposed Corrective Action
Plan. I’m attaching a letter from 10 environmental groups asking the Department to reject the Plan,
and to hold the company to the requirements of the Consent Order and state law. I’ll be glad to
answer any questions about our comments.
With appreciation,
Grady
Grady McCallie, Policy Director
NC Conservation Network
234 Fayetteville, 5th floor
Raleigh, NC 27601
919-802-7592
http://www.ncconservationnetwork.org/ [ncconservationnetwork.org]
Center for Environmental Health ● Environment North Carolina ●
Haw River Assembly ● League of Women Voters – Lower Cape Fear ●
League of Women Voters – Wake County ● Natural Resources Defense Council ●
NC Child ● NC Conservation Network ● NC Sierra Club ● Toxic Free NC
April 6, 2020
VIA E-MAIL
Sheila Holman
Assistant Secretary for the Environment
North Carolina Department of Environmental Quality
1601 Mail Service Center
Raleigh, N.C. 27699-1601
publiccomments@ncdenr.gov
Re: Comments on Chemours Corrective Action Plan
Dear Assistant Secretary Holman:
Thank you for the opportunity to comment on Chemours’ severely inadequate Corrective
Action Plan (“plan”) for the Fayetteville Works Facility. Collectively, our organizations represent
tens of thousands of North Carolinians who live in or visit the Cape Fear basin downstream
from the Fayetteville Works or the area around the plant. As long as Dupont’s and Chemours’
contamination remains in the ground and continues to ooze into the Cape Fear River, our
members and supporters will face potential exposure.
For the past few years, communities in southeastern North Carolina have faced the reality that
Chemours and DuPont polluted their air, drinking water, rivers and streams, soil, and
groundwater for decades with per- and polyfluoroalkyl substances (“PFAS”). Now, Chemours
has submitted its Corrective Action Plan, a document that is supposed to describe how the
company will clean up its pollution.1 Yet instead of meeting the mandatory requirements of the
state groundwater laws, or the consent order it agreed to, Chemours says that the pollution it
caused is too severe and widespread, and therefore, too expensive for the company to clean up
as required to meet its commitments or state law. With its Corrective Action Plan, Chemours
again puts its bottom line ahead of the health and safety of communities and residents. We
urge DEQ to stand firm, protect these people and communities, and hold Chemours to the law
and to its obligations.
1 15A N.C. Admin. Code 02L.0202(c).
State law requires that “[w]here groundwater quality has been degraded, the goal of any
required corrective action shall be restoration to the level of the standards, or as closely
thereto as is economically and technologically feasible as determined by the Department in
accordance with this Rule.”2 PFAS “shall not be permitted in concentrations at or above the
practical quantitation limit,”3 which is the “lowest concentration of a given material that can be
reliably achieved among laboratories within specified limits of precision and accuracy by a given
analytical method during routine laboratory analysis.”4 State law thus mandates that Chemours
clean up its PFAS groundwater pollution to the lowest concentration level detectable by
laboratories, or as close to that level as is “economically and technologically feasible.”5
The Consent Order also requires cleanup. Paragraph 12 of the Consent Order requires
Chemours to achieve the “maximum reductions in PFAS loading” from groundwater to all
surface waters “that are economically and technologically feasible, and can be achieved within
a two-year period.”6 Paragraph 16 of the Consent Order integrates the stringent requirements
of state law and provides that the long-term cleanup be described in Chemours’ Corrective
Action Plan. As a backstop to the rules, Paragraph 16 mandates that “[a]t minimum, the
Corrective Action Plan must require Chemours to reduce the PFAS loading to surface water (Old
Outfall 002, Willis Creek, Georgia Branch, and the Cape Fear River), for the PFAS for which test
methods and lab standards have been developed, by at least 75% from baseline.”7 State law
and the Consent Order require Chemours to take aggressive action to achieve the maximum
cleanup, even in the face of uncertainty.
Based on Chemours’ analysis, groundwater contamination is the largest source of PFAS
pollution in the Cape Fear River. Yet in its Corrective Action Plan, the company does not commit
to any action that will clean up its groundwater pollution, in violation of both the Consent
Order and state law. Instead, Chemours offers excuses. First, the company argues that “PFAS
have been detected over an area of 70+ square miles (over 45,000 acres)” and any remedy
would cost the company “in the billions to tens of billions of dollars.”8 So, as the circular logic
goes, Chemours’ pollution is too widespread and the cleanup too costly to hold the company to
its commitments or state law.
Next, the company argues that its toxic PFAS contamination is not harming people or the
environment, and therefore “hypothetical remedies” that would clean up its pollution “are not
considered necessary.”9 Chemours supports its claim with human health and ecological
2 15A N.C. Admin. Code 2L .0106(a).
3 15A N.C. Admin. Code 02L .0202(c).
4 15A N.C. Admin. Code 02L .0102(15).
5 15A N.C. Admin. Code 2L .0106(a).
6 Consent Order, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 22 (N.C. Super. 2019) (“Consent
Order”).
7 Consent Order at 22.
8 The Chemours Company FC, LLC, Corrective Action Plan – Chemours Fayetteville Works, xvi (Dec. 2019)
(“Corrective Action Plan”).
9 Corrective Action Plan at 56.
assessments that are based only on the health goal for GenX10—ignoring decades of exposure
to GenX and numerous other PFAS, at times to levels over 10,000 times higher than any of the
health values and standards being proposed and promulgated for these chemicals.11
Chemours’ claim also ignores that communities have been, and continue to be, exposed to
mixtures of PFAS that neither Chemours nor any other entity has ever studied.12 By relying on a
human health assessment that is supported by data on only one PFAS in order to claim that
nobody will be hurt by the dozens of PFAS from Chemours pollution, the company continues to
attempt to profit from the lack of publicly-available information about these harmful chemicals.
As has been the companies’ practice, Chemours puts the burden of its pollution on families that
have already suffered from the company’s actions. DEQ must not allow Chemours to shirk its
commitments or the law.
Finally, Chemours’ proposed Corrective Action Plan fails to adequately address North
Carolinians’ multiple pathways of exposure to the company’s contamination. PFAS from this
facility do not merely threaten groundwater wells and downstream water users. The
contamination also presents a threat via transport through soil into plants, livestock, and game
on surrounding lands. The Corrective Action Plan says that residents’ exposure through these
paths will be less than the GenX health value recommended by NCDHHS, and drops any further
discussion of mitigation measures. Again, that approach neglects the sensitivity of a population
that has already been exposed for decades. It also relies on soil samples averaged across large
areas, without discussion of the possibility that contamination concentrates in certain soils and
environmental receptors. The only way to protect residents around the Fayetteville Works
facility, short of denying them significant uses of their properties, is to require the company to
fully remediate the soil and groundwater contamination it has caused.
Chemours has made it clear that it will not honor its commitments under the Consent Order or
comply with state law unless forced to do so. We urge DEQ to exercise its full authority under
the Consent Order to seek penalties for Chemours’ violations of paragraphs 12 and 16, reject
Chemours’ proposed Corrective Action Plan, and:
Require that Chemours achieve the maximum possible reductions of PFAS in onsite soil
and groundwater;
10 Corrective Action Plan, Appendix F – Offsite Human Health Screening Level Exposure Assessment (SLEA) of
Table 3+ PFAS, at 35 (“The hazard characterization is limited to an assessment of [GenX] based on the current
availability of toxicity criteria.”) (referring to Chemours’ human health assessment); see also Corrective Action Plan
at 42. (“[T]his analysis was unable to assess hazards to exposed receptors for Table 3+ PFAS other than [GenX]”)
(referring to Chemours’ ecological assessment).
11 Adam Wagner, NC State-led study shows Cape Fear River had ‘incredibly high’ levels of chemicals, The News &
Observer, Oct. 10, 2019, available at https://www.newsobserver.com/article235963052.html (last visited Feb. 25,
2020).
12 Chemours has identified 22 PFAS from non-targeted sampling. The Chemours Company FC, LLC., Site
Associated PFAS Fate and Transport Study Chemours Fayetteville Works, 3 (June 2019). Chemours has also stated
that over 150 different PFAS could be present at the facility. The Chemours Company FC, LLC, Chemours
Fayetteville Works NPDES Permit Application Update, Attachment F-4, “List of PFAS Compounds” (July 2019).
Prevent PFAS-contaminated groundwater from reaching the Cape Fear River or the on-
site streams that flow into it; and
Require Chemours to provide municipal water supplies or upgraded treatment capacity
to residents whose drinking water has been contaminated by the company’s widespread
PFAS pollution.
Thank you for considering these comments. Please contact Grady McCallie at
grady@ncconservationnetwork.org if we can answer any questions about this letter.
Sincerely,
Grady McCallie Emily Sutton
Policy Director Haw Riverkeeper
NC Conservation Network Haw River Assembly
Michelle Hughes Dustin Chicurel-Bayard
Executive Director Interim Director
NC Child NC Sierra Club
Clarice Reber Michael Green
President Executive Director
League of Women Voters - Lower Cape Fear Center for Environmental Health
Dianna Wynn Drew Ball
President Director
League of Women Voters - Wake County Environment North Carolina
Lior Vered Cori Bell
Policy Advocate Program Attorney, Water
Toxic Free NC Natural Resources Defense Council
cc:
Bill Lane, DEQ
Michael Abraczinskas, DAQ
Michael Scott, DWM
Danny Smith, DWR
From:kayreibold
To:SVC_DENR.publiccomments
Subject:[External] Clean up Plan for Chemours
Date:Monday, April 6, 2020 2:07:39 PM
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attachment to report.spam@nc.gov
I am concerned that there does not appear to be a mechanism that reflects and
considers the feedback from homeowners whose wells have been contaminated. Are
these consumers satisfied with the Chemours intervention to provide bottled water
and other measures? A survey should be conducted to determine the impact on
affected homeowners whose water has been contaminated.
The Chemours plant should be shut down permanently. The contamination of groundand surface water should have been prevented in the first place.
Thank you.
Kay ReiboldRaleigh
Sent from my Verizon, Samsung Galaxy smartphone
From:Maple O
To:SVC_DENR.publiccomments
Subject:[External] PFAS Chemours
Date:Monday, April 6, 2020 2:06:40 PM
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attachment to report.spam@nc.gov
Corrective Action Monitoring
The contamination of ground and surface water by Chemours should have been PREVENTED,
rather than allowing a compromised Action Plan due to economic feasibility.
I know you will keep doing what you can to put responsibility where it belongs.
Maple Mary Ann Osterbrink
603 MLK Blvd 1E
Chapel Hill
NC
From:Guidry, Virginia T
To:SVC_DENR.publiccomments
Cc:Moore, Zack; Dittman, Beth; Lee Pow Jackson, Crystal; Pritchett, Jamie R
Subject:Public comment on the Corrective Action Plan submitted by Chemours
Date:Monday, April 6, 2020 1:01:28 PM
Attachments:image001.pngNCDHHS Public Comment on CAP April2020.pdf
Please see the attached submission of a public comment from NC DHHS regarding the Corrective
Action Plan (CAP) submitted in December 2019 by Chemours to the North Carolina Department of
Environmental Quality (NC DEQ).
Sincerely,
Virginia Guidry
Virginia Guidry, PhD, MPH
Branch Head, Occupational and Environmental Epidemiology
Division of Public Health, Epidemiology Section
North Carolina Department of Health and Human Services
Office: 919-707-5920
Cell: 919-623-1756
virginia.guidry@dhhs.nc.gov
5505 Six Forks Road
1912 Mail Service Center
Raleigh, NC 27699-1912
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ROY COOPER • Governor
MANDY COHEN, MD, MPH • Secretary
MARK T. BENTON • Assistant Secretary for Public Health
Division of Public Health
NC DEPARTMENT OF HEALTH AND HUMAN SERVICES • DIVISION OF PUBLIC HEALTH
LOCATION: 5505 Six Forks Road, Building 1, Raleigh, NC 27609
MAILING ADDRESS: 1912 Mail Service Center, Raleigh, NC 27699-1912
www.ncdhhs.gov • TEL: 919-707-5900 • FAX: 919-870-4807
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER
April 6, 2020
To Whom It May Concern:
The North Carolina Department of Health and Human Services (NC DHHS) reviewed the
Corrective Action Plan (CAP) submitted in December 2019 by Chemours to the North Carolina
Department of Environmental Quality (NC DEQ), with a specific focus on the human health
screening level exposure assessment (HH-SLEA) portion of the CAP, located in Appendix F.
The HH-SLEA makes broad conclusions about potential risk to people living, working, or
playing near the site. The limitations of the data and analysis used to support these conclusions
are summarized below and detailed in Attachment A:
1) The HH-SLEA did not include all appropriate exposure pathways, such as air, swimming
in pools, and subsistence fishermen who may also live near the plant and use private
wells. Pathways with insufficient data to quantify exposure should still be acknowledged
and accounted for when making conclusions.
2) The HH-SLEA did not assess the full scope of per- and polyfluoroalkyl substances
(PFAS) in the affected community and surrounding environment. Many environmental
media were not tested for all Table 3+ PFAS. In addition, given the history of PFAS
production at the site, legacy PFAS (i.e. PFAS listed in EPA Method 537) should be
considered in the HH-SLEA.
3) The exposure point concentrations (EPCs) chosen for certain environmental media will
underestimate potential exposure to PFAS for off-site receptors. The HH-SLEA often
relied on “current condition” assumptions, where it was assumed that all drinking water
exposures were minimized by filtration systems and air emissions were decreased by
facility air scrubbers. These assumptions do not account for past exposures and risks,
future scenarios where current control methods may fail, groundwater migration, or
future residents who may install new wells without awareness of the underlying
groundwater contamination.
4) Exposure factors chosen for certain exposure pathways will underestimate potential
exposure to PFAS for off-site receptors.
5) Several scientific assumptions were made without referencing the appropriate citations or
evidence.
6) The CAP cleanup goals and HH-SLEA hazard assessment are based solely on HFPO-DA
(also known as GenX), which may underestimate total risk from other PFAS that
currently lack toxicity data.
2
There are several significant data gaps and uncertainties as documented by this public comment
and in Section 8 of Appendix F which currently preclude a robust and meaningful risk
characterization for this site. These gaps include an incomplete exposure assessment and a lack
of toxicity data for most PFAS that were assessed in the CAP. Given this, NC DHHS disagrees
with the assertion in section 6.2.4 of the CAP that the HH-SLEA is sufficient to conclude that
offsite groundwater remediation is not needed to protect human health.
NC DHHS appreciates the opportunity to evaluate the Corrective Action Plan in detail and has
reviewed our concerns with NC DEQ. Given the pace of current research, as toxicology and
treatment technology knowledge expand, the corrective action plan should be periodically
revised and updated. NC DHHS looks forward to continued collaboration with NC DEQ to
respond to public health concerns from the affected community near the Fayetteville Works
Facility.
Sincerely,
Virginia T. Guidry, PhD, MPH
Branch Head, Occupational and Environmental Epidemiology
Division of Public Health, Epidemiology Section
North Carolina Department of Health and Human Services
3
Attachment A
The North Carolina Department of Health and Human Services (NC DHHS) reviewed the
Corrective Action Plan (CAP) submitted in December 2019 by Chemours to the North Carolina
Department of Environmental Quality (NC DEQ), with a specific focus on the human health
screening level exposure assessment (HH-SLEA) portion of the CAP, located in Appendix F
titled “Offsite Human Health Screening Level Exposure Assessment (SLEA) of Table 3+
PFAS”.
A detailed list of NC DHHS concerns about the HH-SLEA follows. Unless otherwise noted, all
section, figure, and table numbers refer to those found in Appendix F.
1) The HH-SLEA did not include all appropriate exposure pathways.
a) The evaluation did not address inhalation of ambient air in the surrounding community
during and after facility stack emissions. Since it is known that air emissions from this
site were significant enough to affect groundwater in the surrounding community, it may
be assumed that there is also exposure via inhalation. Two footnotes on Table F-2-1 seem
to indicate that at one point in the development of the HH-SLEA the inhalation route was
considered; however, no data are included to estimate ambient air levels or estimated
dose. The conceptual site model (Figure 2) has a footnote that vapors in ambient air are
not evaluated because “this pathway is unlikely to be significant” but no supporting
documentation is provided to show how this conclusion was made.
b) Many families in the community use well water to fill their swimming pools, but this
potential exposure pathway was not considered. Although swimming is not likely to be a
significant pathway of exposure in isolation, a “reasonable maximum exposure” scenario
should account for individuals potentially exposed through multiple pathways.
c) Residents were excluded from also being considered recreationalists. It is fair to assume
people with contaminated well water living near the Fayetteville Works facility also
recreate in the area, including swimming and fishing, and consume fish from affected
waterways. Total exposure from all these combined pathways should be assessed.
d) Lack of available data precluded evaluation of exposure through consumption of
livestock or local wildlife. The HH-SLEA acknowledges that this is a presumed complete
exposure pathway, but no effort was made to quantify these pathways or account for
them when drawing conclusions about potential health hazards.
2) The HH-SLEA did not assess the full scope of per- and polyfluoroalkyl substances (PFAS) in
the affected community and surrounding environment.
a) Given the documented history of PFAS production at this site, NC DHHS suggests that
the HH-SLEA includes analysis of both legacy (EPA Method 537) and emerging (Table
3+) PFAS.
b) Home-grown produce was not collected and directly analyzed for PFAS concentrations.
The rationale for this decision provided in the CAP was that harvest-ready produce could
not be collected due to seasonal limitations. However, various harvest-ready produce is
available year-round.
c) Levels of HFPO-DA in produce were estimated using a model. Given that the physical
and chemical properties of PFAS differ from other organic pollutants, it is unclear that
the model used is appropriate for this purpose and been validated for PFAS at other sites.
4
d) Several environmental media were not assessed for all listed Table 3+ PFAS. This
includes untreated well water, surface water used for public drinking water, and home-
grown produce. Throughout the HH-SLEA, (ex: Section 5.2.2) data for Table 3+ analytes
are mentioned, but the dataset only includes some of the Table 3+ PFAS, not all. This is
misleading, and for each media and exposure unit, the analytes being considered should
be clearly and explicitly stated. Wherever possible, environmental media should be
analyzed for legacy and emerging PFAS.
e) A limited number of fish were collected from the Cape Fear River. The data provided in
the HH-SLEA are insufficient to determine if the samples are truly representative of fish
populations in the river. NC DHHS recommends a minimum of five fillet samples from
individual fish per species per sampling site, or three composite samples per species per
sampling site, with each composite consisting of tissue from three to seven fish of the
same species. Additionally, fish were not collected from Kings Bluffs (55 miles
downstream) even though PFAS have been historically detected in the surface water here.
There is also inconsistent reporting of fish collected between the text (Section 5.4.1),
Figure 7, and Table B-4.
3) The exposure point concentrations (EPCs) chosen for certain environmental media will
underestimate potential exposure to PFAS for off-site receptors.
a) Well water concentrations were averaged over each exposure unit to calculate EPCs. This
approach may significantly underestimate potential exposures for residents with the
highest levels of PFAS in their water. Averaging multiple private well results is
inappropriate for calculating an EPC for a private well user because they do not receive
their drinking water from multiple wells. A reasonable maximum exposure scenario
should consider maximum measured contaminant levels in each exposure unit.
b) The HH-SLEA also presented a “current conditions” scenario where it was assumed that
all drinking water exposures were minimized by filtration systems and air emissions were
decreased by facility air scrubbers. It is important not to overstate the conclusions from
that scenario and continue to consider cases where filtration systems may fail,
groundwater migrates toward untreated wells, or new wells are drilled in the area
resulting in exposure to untreated drinking water. Further, the results from the
performance testing of the thermal oxidizer have not yet been received, preventing
confirmation of its effectiveness at the time of this review.
c) Surface soil samples were taken at 30 locations in each exposure unit and composited
into a single sample that was assumed to be representative of surface soils for the whole
exposure unit. This approach could greatly underestimate soil exposure in certain areas
where PFAS deposition is higher. Multiple discrete surface soil samples should be taken
and analyzed throughout each exposure unit, with higher sampling density in areas that
correspond with suspected deposition patterns.
d) Underestimating soil PFAS concentrations by compositing 30 samples into one could
also lead to underestimating the level of PFAS in produce, since soil concentration is an
important factor in the model used to estimate PFAS levels in produce.
e) Most surface soil samples were collected from right-of-way areas near roads. A
hydrogeologist should be consulted to determine if proximity to a roadway and ensuing
5
runoff would affect PFAS residence times in surface soil compared to residence times in
the areas of yards used to grow produce.
4) Exposure factors chosen for certain exposure pathways will underestimate potential exposure
to PFAS for off-site receptors.
a) In Table F-2-4, the exposure frequency for swimming is listed as 12 events per year
based on professional judgement. This might underestimate the reasonable maximum
exposure to PFAS while swimming, such as residents who may swim multiple times a
week during the summer.
b) In Table F-2-4, the exposure factors used to evaluate exposure while swimming do not
match the footnotes. Specifically, footnote 4 indicates that the exposure time for children
is 270 minutes (4.5 hours), but the table lists 3.5 hours/event as the exposure time for
children. Additionally, footnote 4 indicates that the exposure time for adults is 210
minutes (3.5 hours), but the table lists 7.5 hours/event as the exposure time for adults.
c) In Table F-2-2, the soil ingestion rates for adults is listed as 330 mg/day per EPA 2014.
When looking at this reference, the adult soil ingestion rate for outdoor workers is 100
mg/day. This discrepancy should be corrected.
d) In Table F-2-5, the fish ingestion rates given are for recreational fishermen. There are
portions of the North Carolina population who are subsistence fishermen, and intake rates
for subsistence fishermen should be used to account for these populations. Using
recreational fishermen intake rates will significantly underestimate potential exposure
from this pathway.
5) Appropriate citations or evidence should be referenced for statements about physical and
chemical properties of PFAS with ether bonds discussed in Section 2.6; statements about the
effectiveness of filtration systems such as Section 5.2; and statements about dermal exposure
presented in Section 8.3.1.
6) There are several significant data gaps and uncertainties which currently preclude a robust
and meaningful risk characterization for this site.
a) Because there are no toxicity data for most Table 3+ PFAS, NC DHHS recommends
removing “noncarcinogenic human health hazard from assumed exposure to Table 3+
PFAS in the vicinity of the Facility” from the stated goals in the executive summary of
the HH-SLEA.
b) The characterization of potential risk to the affected community presented in the HH-
SLEA does not adequately account for the deficiencies listed in this public comment, as
well as the lack of toxicity data for most Table 3+ PFAS.
c) It would be helpful to explicitly clarify what fraction of total PFAS exposure is
attributable to HFPO-DA compared to other Table 3+ PFAS.
d) Regarding footnote 13, which references the relative source contribution, the conclusions
made may be premature given the data gaps surrounding other potential exposure routes
such as household dust and inhalation.
7) The NC DHHS derived oral reference dose is currently the appropriate toxicity value to use
for HFPO-DA based on the following considerations:
a) The NC Secretaries’ Science Advisory Board has reviewed the NC DHHS oral reference
dose for HFPO-DA and recommended its use as the foundation for protecting affected
and sensitive populations and providing corresponding risk assessments and advice.
6
b) The Thompson et al. 2019 oral reference dose was derived from a rat study, which has
been shown to be a less sensitive species for some effects of PFAS compared to mice
models.
c) The USEPA draft oral reference dose is still in draft form, and USEPA has explicitly
stated that it should not be used since it is not final and may change following public
comment1.
d) Although the DHHS derived oral reference dose should be used for calculations, it is
incorrect to say the NC DHHS determined the use of the reference dose “in a regulatory
context” (ex: Section 7.1 in Appendix F) since NC DHHS is not a regulatory agency.
1 https://www.epa.gov/sites/production/files/2018-11/documents/factsheet_pfbs-genx-
toxicity_values_11.14.2018.pdf
From:Rcrybaby3
To:SVC_DENR.publiccomments
Subject:[External] Fwd: Non-Concurrence Groundwater Corrective Action Plan 1601
Date:Sunday, April 5, 2020 11:58:03 AM
Attachments:Non-Concurrence with Corrective Action Plan (2).odt
Chemours Test Results.pdf
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Dated form
From: rcrybaby3@aol.com
To: publiccomments@ncdenr.com
Sent: 4/5/2020 11:24:49 AM Eastern Standard Time
Subject: Non-Concurrence Groundwater Corrective Action Plan 1601
Secretary Michael Regan,
Dear Mr. Regan,
Attached is the Written Non-Concurrence Action Plan 1601 plus our results from the testing
done by Chemours/DuPont also there is signature with my husband Ronnie Napier and my
signature Audrey Napier. We live at 1739 John McMillan Road, Hope Mills, NC.
Our test results are not complete. There were 4 test that were not done! Now I must contact
another department of NCDEQ in order to have it done. This is UNACCEPTABLE!!. We feel the
state has let our community down. We have been living here for 28 years and from it sounds like
this has been going on for the last 40 years!! No one wanting to say anything until it can't be
covered up anymore.
You as the Secretary of EPA in N.C. need to get the ball rolling on and protect we the people.
We truly would appreciate more cooperation from the state in making Chemours/DuPont more
accountable. The R.O systems is just a band-aid on a gunshot wound. The R.O. systems
doesn't even keep our hot water clean when taking showers.They need to provide GAC systems
to everyone affected!!! You need to make this deal happen.
We would truly appreciate help from you.
Sincerely,
Ronnie and Audrey Napier
910-429-2576
From:Mark Vaughan
To:SVC_DENR.publiccomments
Subject:[External] Michael Regan-Public Comment to the proposed Groundwater Corrective Action Plan
Date:Sunday, April 5, 2020 10:27:07 AM
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To: Department of Environmental Quality
Secretary Michael Regan
Written Non-Concurrence to the proposed Groundwater Corrective Action
Plan 1601 Mail Service CenterRaleigh, N.C. 27699-1601
1. I am one of the “affected parties: per 15A NCAC 02L .0202(c) and § 143-215.2A.
(Relief for contaminated private drinking water wells). I DO NOT CONCUR with the
Corrective Action Plan (CAP) as written. I am providing my non-concurrence
IAW15A NCAC 02L .0106(k) (3) and provide my written notification to the
Secretary of DEQ and Governor of the State of North Carolina. I demand equal
treatment under the laws of North Carolina and demand Secretary Regan
force Chemours and/or Dupont to provide a Permanent Solutions for all wells
found to be contaminated in exceedance of NC Groundwater Standards listed in
15A NCAC 02L .0202. It is the belief that § 143-215.2A, which was enacted in June
2018 and became a State Statute can still be used to
force Chemoursand/or Dupont to run water at their expense. Paragraph 34
utilized the verbiage Session Law 2018-5 Sec 13.1(c) when it was signed and
enacted in February 2019 over 8 months after § 143-215.2A had been enacted as
a State Law. Referring to it as Session Law 2018-5 Sec 13.1 (c) thus makes the
limitations that DEQ attempted to place on the use of § 143-215.2A invalid. Since
the enactment of the Consent Order Chemourshas been in violation in all testing
of wells as they are not testing for all chemicals agreed upon in Attachment C as
both PFMOPrA (Perfluoro-3- methoxypropanoic acid) & PFMOBA (Perfluoro-
4- methoxybutanoic acid) are not tested for. GEL Labs can test for these two
compounds as they are tested for during NC DEQ testing of wells.
2. As an adjacent property owner IAW the requirements of 15A NCAC 02L .0106(k)
(3) I DO NOT consent to the proposed Corrective Action Plan. It is required by the
provisions of 15A NCAC 02L .0106(k)(3) to gain approval of the property owners
for the Corrective Action Plan that was submitted for the Chemours i.e. the
Fayetteville Works Facility (GeosyntecProject Number TR0795). To date not one
property owner that has been requested to provide consent.
Unless Chemoursand/or Dupont provides equal solutions for all “affected parties”
i.e. anybody with a Well that has been found to have any PFAS contamination
from the Fayetteville Works Facility (not limited to Attachment C of the consent
order) in the means of a Whole Home Solution be it Granular Activated Carbon
Systems or Public Water. I nonconcur with the Corrective ActionPlan. Chemours & Dupont cannot be permitted to contaminate ourgroundwater wells, soil and vegetation without being required to remediate
what they have damaged or a Permanent whole home water solution. Cost to
remediate or Public water should be the only feasible solution regardless of
costs i.e. the $75K DEQ imposed limit.
3. 15A NCAC 02L .0106(k)(3) is very clear and it states:
15A NCAC 02L .0106(k)(3) Any person required to implement an approved
corrective action plan for a site subject to Paragraphs (c) or (e) of this Rule may
request that the Secretary approve such a plan without requiring groundwater
remediation to the standards. A request submitted to the Secretary under this
Paragraph shall include a description of site-specific conditions, including
information on the availability of public water supplies for the affected area; the
technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7)
of this Paragraph. The person making the request shall demonstrate:
(1) that all sources of contamination and free product have been removed or
controlled pursuant to Paragraph (f) of this Rule;
(2) that the time and direction of contaminant travel can be predicted with
reasonable certainty;
(3) that contaminants have not and will not migrate onto adjacent properties, or
that:
(A) such properties are served by an existing public water supply system
dependent on surface waters or hydraulically isolated groundwater; or
(B) the owners of such properties have consented in writing to the request;
4. There is still contamination in our trees specifically pine type trees and our soil
that Chemours has no intention of remediating. This will continue to have pass
through contamination caused by rainfall passing thru the vegetation. As such (1)
will not be achieved and neither will (2) above. Contaminants have migrated off of
the Fayetteville Works Facility to the adjacent properties as far as 11 miles from
the center of the facility covering an area in excess of 125 square miles and
growing. All properties could be provided public water supply IAW 15A NCAC 02L
.0106 (k) at far less in cost that the cost to remediate an area over 125 square
miles. Of whole home water filtration could be provided to all homes with
detection of PFAS in exceedance of the NC Ground Water Quality
Standards. Chemours can make the choice to fund billion to tens of billions of
dollars of cleanup or millions for providing permanent whole home solutions. I do
not consent IAW (3)(B) until Chemours provides that resolution voluntarily or
forced by the State.
5. Per 15A NCAC 02L .0106(b) Any person conducting or controlling an activity that
results in the discharge of a waste or hazardous substance or oil to
the groundwaters of the State, or in proximity thereto, shall take action upon
discovery to terminate and control the discharge, mitigate any hazards resulting
from exposure to the pollutants and notify the Department, as defined in 15A
NCAC 02C .0102, of the discharge. Chemours and Dupont violated 15A NCAC 02L
.0106 (d) Any person conducting or controlling an activity that is conducted under
the authority of a permit initially issued by the
Department on or after December 30, 1983 pursuant to G.S. 143-215.1 or G.S.
130A-294 and that results in an increase in concentration of a substance in excess
of the standards. This was known by NC DEQ as far back as December 2016
when Chemours delivered the Corrective Measures Study to DEQ. So for three
years Chemours failed to address a Corrective Action Plan, and has only done so to
meet a requirement of a Consent Order.
5. IAW 15A NCAC 02L .0106 (k) Any person required to implement an approved
corrective action plan for a site subject to Paragraphs (c) or (e) of this Rule may
request that the Secretary approve such a plan without requiring groundwater
remediation to the standards. A request submitted to the Secretary under this
Paragraph shall include a description of site-specific conditions, including
information on the availability of public water supplies for the affected area; the
technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7)
of this Paragraph.
6. The manner in which the consent order lists § 143-215.2A an State Law that was
enacted in June of 2018 prior to the Enactment of the Consent Order in February of
2019. Session Law 2018-5 Sec 13.1 (c) is irrelevant as it had been enacted as a State
Law prior upon ratification in June of 2018. So it should not have been referred to
as Session Law 2018-5, but as the State Statute and since listed incorrectly in
Paragraph 34 of the Consent Order is invalid and the Secretary of DEQ can still force
the polluters to pay for permanent whole solution be that Whole Home Granular
Activated Carbon or the running of Public water Systems to all homes found with a
well in violation of the NC Ground Water Standards.
7. 15A NCAC 02L .0106 (a) Where groundwater quality has been degraded, the goal
of any required corrective action shall be restoration to the level of the standards,
or as closely thereto as is
economically and technologically feasible as determined by the Department in accordance
with this
Rule. If Chemours and/or Dupont cannot remediate all wells they have contaminated in
violation of the
15A NCAC 02L .0202 standards. For corrective action under 2L rules when no
groundwater standard exists, groundwater must, to the extent technologically and
economically feasible, be restored to practical quantitation limits (PQLs) except as
otherwise provided in the rules. At present, restoring groundwater to PQLs onsite
or offsite is technologically and economically infeasible. The size of the area
encompasses thousands of private land parcels and any remedial construction
activities using currently available remedial technologies (excavation and
groundwater extraction) would be very disruptive to the local community and this
disruption would continue for a lengthy period of time. Any remedy which in
principle could help make progress towards PQLs over this large area would cost in
the billions to tens of billions of dollars.
8. I as one of the “affected parties” are demanding that NC DEQ protect our rights
and force Chemours and/or Dupont the polluters to either remediate the damages
to our Groundwater Wells or provide permanent whole home solutions i.e. Whole
Home Granular Activated Carbon or Public Water connections with a defined period
of the polluter paying for the water bills. The same solution provided for the Coal
Ash “Affected Parties”.
9. Areas of Corrective Action Plan that indicate why Chemoursand/or Dupont should
be forced to provide Whole Home Filtration or Public Water for all those with wells
that indicate exceedance of the NC Groundwater Standards 15A NCAC 02L .0202(c).
When referring to the costs associated with providing the above remediation it
must be taken into account that Chemours is gaining a cost savings of $5,000,000
per month in cost savings for the elimination of shipping the Waste Water to Texas.
It must also be taken into account the processing of the Waste from the
Netherlands in determining the feasibility of providing public water or Whole Home
Solutions to all “affected parties”. Affected Party is any property found with a
groundwater well in exceedance of the NC Ground Water Standards established by
the NC Environmental
Page xiv
Comply with 2L Rules (CO paragraph 16), including following the policy for the
intention of the 2L Rules
“to maintain and preserve the quality of the groundwaters, prevent and abate
pollution and contamination of the water of the state, protect public health, and
permit management of the groundwaters for their best usage by the citizens of
North Carolina” (15A NCAC 02L .0103)1; and comply with other requirements of the
CO.
Response to Page xiv
Chemours is not in compliance with the Consent Order as they are not testing for all
of the Chemicals listed on Attachment C. The two compounds that are not tested
for are PFMOPrA(Perfluoro-3- methoxypropanoic acid) & PFMOBA (Perfluoro-
4- methoxybutanoic acid). This should be a complaint that all address to Michael
Scott and Michael Regan @ NC DEQ. Prior to approval of a Corrective Action Plan
NC DEQ should ensure that the Consent Order is actually enforced and that a
permanent remediation solution or permanent whole home water solutions are
provided.
Page xvi
Because the results of the HH-SLEA and Ecological SLEA indicate that exposures to
HFPO-DA in offsite environmental media do not pose a hazard to human health or
the environment, site-specific, risk-based cleanup goals were not developed; rather,
cleanup goals are based on CO and 2L rules. ****
For corrective action under 2L rules when no groundwater standard exists,
groundwater must, to the extent technologically and economically feasible, be
restored to practical quantitation limits (PQLs) except as otherwise provided in the
rules. At present, restoring groundwater to PQLs onsite or offsite is technologically
and economically infeasible.
For offsite groundwater receptors, provide public water connections or whole
building filtration units or reverse osmosis units to qualifying surrounding residents
(CO paragraphs 19 and 20);
Response: to Chemours CAP Page xvi
Most all wells tested have multiple Chemicals in the wells. Some as many as 9- 16
yet in documents like this Corrective Action Plan you will see Chemours discussion
relate to only HFPO-DA. In the Ground Water Quality Standard of the State of North
Carolina under 15A NCAC 02L .0202(b)(2) Where two or more substances exist in
combination, the Director shall consider the effects of chemical interactions as
determined by the Division of Public Health and may establish maximum
concentrations at values less than those established in accordance with Paragraphs
(c), (h), or (i) of this Rule. In the absence of information to the contrary, in
accordance with Paragraph (d) of this Rule, the carcinogenic risks associated with
carcinogens present shall be considered additive and the toxic effects associated
with non-carcinogens present shall also be considered additive.
I as an “affected party”: per 15A NCAC 02L .0202(c) and § 143-215.2A (Relief forcontaminated private drinking water wells) demand that the Secretary of DEQ
and Governor of the State of North Carolina force Chemours and/or Dupontto
provide a Permanent Solution for all wells found to be contaminated in
exceedance of the NC Groundwater Standards as the remedy for ourcontaminated wells based on the admission that Chemours has no plan for
remediation of our contaminated properties. Secretary Regan needs to follow NC
Groundwater Quality Standards as well as enforce the Consent Order. Failure to
do so is a failure to perform the duties of office.
Thank you Mark Vaughan
C'mon
From:lgarvey
To:SVC_DENR.publiccomments
Subject:[External] Clean up your polluted water! Why are they allowed to do this? They should be shut down! Why
should we have to buy water to drink because ours it polluted? It"s not right!
Date:Sunday, April 5, 2020 6:42:58 AM
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From:happyhealth15@gmail.com
To:SVC_DENR.publiccomments
Subject:[External] Chemour pollution
Date:Saturday, April 4, 2020 6:54:27 PM
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Whatever is necessary needs to be done to stop all pollution of the Cape Fear water supply. The ongoing discharge
of pollutants are putting the health and safety of the citizens and wildlife downstream at risk. In addition, the
pollution is risking lowering property values and the appeal of Wilmington as a vacation and activities destination.
If more research indicates the current and ongoing pollution creates even more risk than has been stated to date, the
financial implications for the area could be devastating.
We understand macro-economics, but ethics of residents’ health and safety must take precedence!
Tanya Bush
Leland, NC
Sent from my iPhone
From:Carl Parker
To:SVC_DENR.publiccomments
Subject:[External] New Hanover - Brunswick County Branches of the NAACP comments regarding Chemours Corrective
Action Plan
Date:Saturday, April 4, 2020 1:40:10 PM
Attachments:Chemours CAP Comments.pdf
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Please accept our comments to the Chemours Corrective Action Plan
1
Mr. Carl L. Parker, President
Brunswick County Branch #5452
Ms. Deborah Dicks Maxwell, President
New Hanover County Branch #5424
April 4, 2020
Sheila Holman
North Carolina Department of Environmental Quality
1601 Mail Service Center
Raleigh, NC 27699
Re: Chemours’ Corrective Action Plan (CAP) comments.
On behalf of the all of the active members of the Brunswick County Branch and New Hanover Branch
of the National Association for the Advancement of Colored People who are seamlessly a part of our
2,200 branches and some half million members worldwide, we offer this joint letter containing our
collective comments because we believe that protecting our drinking water resources from pollution
is a basic human right and vital necessity for a healthy and productive society. Unfortunately, the
chemicals that Chemours and others have dumped into our primary drinking water source, the Cape
Fear River, now jeopardizes that human right. Regrettably, the real tragedy here in our Lower Cape
Fear River area will be the challenge of the high costs of advanced water treatment associated with
making our river water source drinkable again.
To compound that problem, water rates are already unaffordable for many of the households in our
area and is forecasted to be more severe in the next five years to financially vulnerable households
in our Lower Cape Fear River area. Access to clean, safe water is critical to all of us living downstream
of Chemours. Affordable access to this basic service is essential to protecting the health and wellness
of vulnerable or disadvantaged populations. And yet, this so-called CAP totally fails to address this
unfolding tragedy. There is not one single passage, chapter or reference in this CAP that addresses
the environmental injustice caused by the discharge of Chemours chemicals to our water supply. It
is clear to us that communities of all sizes downstream of Chemours will be struggling to reliably
provide clean, safe drinking water at reasonable rates. However, we also know that our
disadvantaged families will face a disproportionate share of those economic and environmental
burdens.
When water bills become unmanageable for a low-income household, missed payments and a
delinquent account can turn into disconnection or shut-off from the system, an outcome with many
negative impacts for both the customer and our utilities. A disconnected water service practically
makes a home uninhabitable and can have the same effect as eviction. Alternatively, some low-
2
income households may absorb the cost of rising rates in the form of rent increases. As water rates
rise, more and more our households will lack the ability to pay for services that are critical to human
life.
It is our understanding that under the Title VI Section of the Civil Rights Act of 1964, any agency
receiving federal money cannot discriminate on the basis of race, color or national origin. It is a basic
accountability system: if a recipient receives federal funds, that recipient cannot use those funds to
discriminate. Discrimination need not be intentional. It includes any decision that has an unjustified,
unequal impact. We believe that any federal funds used by NC DEQ or your contractors for any
matter, action or oversight related to this CAP effort establishes a responsibility for the State of North
Carolina to adhere to Title VI section of the Civil Rights Act of 1964.
History has clearly defined that where we live has direct bearing on our well-being. For us living in
the Lower Cape Fear region it seems that our postal code will now determine the health of our
citizens who live here. We know that our poorer communities will continue to bear the physical,
emotional and financial brunt of Chemours harmful pollution of our drinking water source delivered
by way of the Cape Fear River. Chemours’ mistreatment of marginalized communities downstream
of its Fayetteville plant is unconscionable and discriminatory.
We believe that the State of North Carolina must undertake multi-pronged actions and solutions to
the Chemours caused environmental catastrophe that go far beyond this meagerly drafted correct
action plan. With that, we ask you please respond to our comments:
Comment 1: Please explain why there is a total failure to address issues of Environmental Justice
in the Chemours CAP. Nowhere in the entire consent document is the term
Environmental Justice even mentioned. Environmental Justice is defined by the EPA
as “the fair treatment and meaningful involvement of all people regardless of race,
color, national origin, or income with respect to the development, implementation
and enforcement of environmental laws, regulations and policies.” The EPA further
explains, “Fair treatment means that no group of people should bear a
disproportionate share of the negative environmental consequences resulting from
industrial, governmental and commercial operations or policies.” The pollution
caused by Chemours and others represents “a disproportionate share of negative
environmental consequences” falling on the backs of the nearly 130,000 people who
are at or below the federal poverty line in five counties from Cumberland to Brunswick
County along the Cape Fear River. To us, the down-streamers, this is an untenable
situation that neither NC DEQ nor Chemours has had the inclination or desire to
address.
3
Comment 2: Please explain why we who live and work downstream of the Chemours Fayetteville
facility have to pay excessive and unjustified utility rates for so-called “potable” water
that we can’t drink.
Comment 3: Do you agree with CFPUA and Brunswick County utilities position that our proposed
state-of-the-art water treatment plants are not optional and are desperately needed
for those that live downstream to remove Chemours, et al contaminates from our
drinking water?
Comment 4: Do you agree with our position that higher water service rates will have a
disproportional impact on our marginalized groups and individuals, such as those
among us living in poverty including the disabled, pregnant or lactating women,
veterans, homeless people, and residents of unincorporated areas of our county?
Comment 5: Do you agree with our opinion that raising our water rates is not a sustainable solution
to clean up the pollution caused by those like Chemours that make large profits from
abusing our critical drinking water resource?
Comment 6: Do you agree with our position that drinking water “sustainability” means giving us
our water back as clean as or cleaner than it was given to Chemours in the first place?
Comment 7: Considering the circumstances surrounding the Chemours pollution, can you explain
why the State of North Carolina has not yet enacted any “anti-shutoff” legislation that
states that no water service disconnect for customers at or below the Federal poverty
level or if the customer is blind, disabled, handicapped or households with a baby 24
months old or younger that has discharge papers from a hospital on which the
attending physician indicated utility service is a necessity for the health and wellbeing
of the baby?
Comment 8: We believe that the “GAC Flow-Through Cell” design is fatally flawed. It is known that
Granular Activated Carbon (GAC) “adsorbs” PFAS compounds. It is also known that
GAC has a limited ability to adsorb PFAS. The GAC that is designed to fill wire baskets
will have an unpredictable design life. When GAC breakthrough occurs, we can find
no method that is proposed in this plan to adequately and safely clean out and replace
the expired GAC from the cells in such a way to prevent large slug loads of PFAS or
other contaminates from sluffing into the river and traveling downstream into our
watersheds and drinking water system intakes.
Comment 9: Why was there absolutely no mention or reference to any industry wide standards or
“Best Management Practices” (BMPs) for the proposed corrective actions offered in
this plan? BMPs are tried and true methods that have been determined to be the
most effective and practical means of preventing or reducing non-point source
4
pollution to help achieve water quality goals. BMPs include both measures to prevent
pollution and measures to mitigate pollution.
Comment 10: Why did you not perform risk and uncertainty analysis as part of this CAP? It would
seem that by analyzing the risk and uncertainty of the probable outcomes of the key
components of this CAP could lead to identifying ways in which the project could be
made more robust and to ensure that the risks that remain are well managed.
Please know that we, the members of the NAACP Branches of Brunswick and New Hanover Counties,
constantly strive to improve and empower the lives of the people we serve. For all of those that we
serve and our members we ask for your kind consideration and actions on each of the comments
that we have brought forward to you in this letter.
Sincerely,
__________________________________
Carl Parker, President
NAACP - Brunswick County Branch #5452
P.O. Box 364, Supply, NC 28462
______________________________________
Ms. Deborah Dicks Maxwell, President
NAACP - New Hanover County Branch #5424
PO Box 2199, Wilmington, NC 28402.
From:Sen. Harper Peterson
To:Vaughn Hagerty
Cc:Jim Flechtner; SVC_DENR.publiccomments; Hicks, Joy A; Rita Harris (Sen. Harper Peterson); Nunna, Shrikar
Subject:[External] Re: CFPUA comments on Chemours" proposed CAP
Date:Saturday, April 4, 2020 9:53:19 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Hello Vaughn:
Thank you for your comments and concerns and the study performed by Tetra Tech regarding Chemours’ submittedCAP.I am anxious to receive NCDEQ’s response to your concerns.Please know the seriousness with which I consider this ongoing saga of toxic discharge into our public waters, ourair and our soils by Chemours, the complete compliance by Chemours of the Consent Order and the serious healthimpacts this situation continues to have on our populations downstream.Anything I can do to help remediate these problem, please do not hesitate to contact me.
Sincerely,Senator Harper Peterson
.
Sent from my iPad
On Apr 3, 2020, at 1:02 PM, Vaughn Hagerty <Vaughn.Hagerty@cfpua.org> wrote:
Attached are comments on Chemours’ proposed Corrective Action Plan submitted by Cape Fear Public UtilityAuthority.
Vaughn HagertyPublic Information OfficerCape Fear Public Utility Authority(P) 910-332-6704(M) 910-264-8338Vaughn.Hagerty@cfpua.org<mailto:Vaughn.Hagerty@cfpua.org>
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may bedisclosed to third parties.
<CFPUA-CAP-Comments-4-3-2020.pdf>
From:donna pritchett
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Saturday, April 4, 2020 8:30:27 AM
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attachment to report.spam@nc.gov
I am writing in response to the latest development in the Chemours plant water
contamination situation. Although I have not read the entire document presented by
Chemours and their representatives, my understanding is that Chemours does not
want to be financially responsible for cleaning up the groundwater that they
contaminated. Although I don't live in the affected area this concerns me for the future
of our state. If Chemours is allowed to get by with this, what could it mean for the
future of North Carolina? My concern is that this sets a precedent for othermanufacturers, industries, utilities, etc. in the future. If Chemours isn't held
responsible, why should other companies be held responsible? I'm afraid for what
this might mean for the environmental future of our great state.
Donna Pritchett
Sent from my Verizon, Samsung Galaxy smartphone
From:Linda Gessner
To:SVC_DENR.publiccomments
Subject:[External] Chem ours
Date:Saturday, April 4, 2020 6:19:44 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Chem ours must pay for the pollution they caused to the water and land affected by their manufacturing and use of
forever chemicals. They must also follow the laws in place to protect the lives and health of all the people affected
by their carelessness. They are responsible for causing cancer in people and polluting rivers, streams and ground
water. This is a must! Our legislators and elected officials must make them stop polluting and pay for all damages.
Sent from my iPhone
From:A Graham
To:SVC_DENR.publiccomments
Subject:[External] Chemours"
Date:Friday, April 3, 2020 8:24:04 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
I want to comment on this Chemours' of PFAS. It is frustrating and
annoying to continue to hear something that has happened before in the
past. Just drop the damn negativity and work on the positives. Start
commenting on the positive things. At least the company has admitted
and took actions to correct it. To be honest, the PFAS has been in
the water forever. Has anyone died or ever proven to got sick from
that? NO.....Humans will die from far more worse things than this
PFAS chemical. So will you please stop with bs and began to promote
the positivity?
My dad has worked for at the Fayetteville Works plant for over 30
years. He has a successful career as an electrical engineer and
foreman electrician. That company has been great to my dad. He has
worked for Flour Daniel, Dupont and other projects and now Chemours'.
I am proud of my dad and there are alot of things he has made for the
company. Just thing of the rubber protective film that you find in
the windshields of vehicles that prevent it fromn cracking in an
accident. I am proud to say my dad has worked in that plant.
Even with the COVID-19 and virus and other economic struggles my dad
still has a job and is supporting me and my mother. So without him
having this job, my dad would be miserable and I would not have such a
good life.
So for the last time, can you please drop the negativity?
*I do not want my name, this email or this message to appear on any
media outlet, newspaper, social network, tv network and or anything*
Thank you
From:Esther Murphy
To:SVC_DENR.publiccomments
Subject:[External] Chemours is not above the law
Date:Friday, April 3, 2020 6:46:10 PM
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I demand the people who have poisoned my water be punished.
Death Penalty on Chemours and the owners, managers, all those
complicit in poisoning my environment.
Esther Murphy
New Hanover County, NC
From:Joseph A. Ponzi
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, April 3, 2020 4:16:22 PM
Attachments:EXECUTED - Holman - NCDEQ Letter re Comments on Chemours Corrective Action Plan 4814-6981-4457 v.1.pdf
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Please find attached this firm’s comments on Chemours’ Corrective Action Plan, as counsel for
CFPUA. A hard copy is following by mail.
Joey
________________________________
Joseph A. Ponzi [brookspierce.com], Partner
[brookspierce.com]
t: 336.271.2560
f: 336.232.9060
2000 Renaissance Plaza
230 North Elm Street
Greensboro, NC 27401
P.O. Box 26000 (27420)
Confidentiality Notice:
The information contained in this e-mail transmittal is privileged and confidential intended for the addresseeonly. If you are neither the intended recipient nor the employee or agent responsible for delivering this e-mail to the intended recipient, any disclosure of this information in any way or taking of any action inreliance on this information is strictly prohibited. If you have received this e-mail in error, please notify theperson transmitting the information immediately.
This email has been scanned for viruses and malware by Mimecast Ltd.
From:Vaughn Hagerty
To:SVC_DENR.publiccomments
Cc:Jim Flechtner; Senator Bill Rabon; Harper.Peterson@ncleg.net; Deb.Butler@ncleg.net; Rep. Ted Davis;
Holly.Grange@ncleg.net
Subject:[External] CFPUA comments on Chemours" proposed CAP
Date:Friday, April 3, 2020 1:01:37 PM
Attachments:CFPUA-CAP-Comments-4-3-2020.pdf
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attachment to report.spam@nc.gov
Attached are comments on Chemours’ proposed Corrective Action Plan submitted by Cape Fear
Public Utility Authority.
Vaughn Hagerty
Public Information Officer
Cape Fear Public Utility Authority
(P) 910-332-6704
(M) 910-264-8338
Vaughn.Hagerty@cfpua.org
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
Technical Review of Cape Fear River
PFAS Corrective Action Plan for Cape
Fear Public Utility Authority (CFPUA)
February 28, 2020
PREPARED FOR PREPARED BY
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Tetra Tech
One Park Drive, Suite 200
PO Box 14409
Research Triangle Park, NC 27709
Tel 919-485-8278
Fax 919-485-8280
www.tetratech.com
(This page was intentionally left blank.)
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
1
1.0 EXECUTIVE SUMMARY
This report is a technical review of the Corrective Action Plan (CAP; Geosyntec, 2019a) for remediation of
per- and polyfluoroalkyl substances (PFAS) discharged by the Chemours Company Fayetteville Works
facility. Comments regarding the technical soundness of the assessments presented in the CAP and
critical gaps are discussed in Section 3.0. The main concerns relevant to the Cape Fear Public Utility
Authority’s (CFPUA) downstream raw water intake are summarized below. Based on the information
provided and information lacking, the adequacy of the modeling and CAP cannot be judged.
• The CAP and past reports use an inconsistent application of PFAS analyte groups for monitoring,
loading analyses, and remediation planning (Section 3.1 #1). It is stated that, except for HFPO-DA,
Modified EPA 537 method PFAS do not originate from onsite manufacturing; however, this is
inconsistent with some process water samples presented in Characterization of PFAS in Process and
Non-process Wastewater and Stormwater Quarterly Report #1 (Table 4, Location ID 16). Loads from
the Modified EPA 537 method PFAS are excluded from the mass balance model. As a result, the
model may underestimate PFAS loading from the site that impacts downstream water quality.
• The CAP does not clearly define a baseline period. The PFAS Loading Reduction Plan and CAP
are also missing important information; relative contributions are presented by transport pathway,
however, flows, concentrations, and loads to the river (mass of total PFAS per time) are not specified.
Without a clear definition of the baseline period and loads, results could be interpreted in a manner
that misrepresents progress and the effectiveness of remediation strategies (Section 3.1 #2).
• Multiple technical issues related to the numerical groundwater model are discussed in Section
3.1 #7 and Section 3.2 #2 that raise questions about the validity of the model and simulated
remediation strategies. The model lacks a validation period to establish the robustness of the
calibration. The report does not provide a rationale for the selection of proposed remedies and,
based on the limited information provided, it is uncertain if the strategies will effectively capture and
treat the PFAS-contaminated groundwater plumes.
• The onsite treatment strategies described in the CAP neglect components of onsite pathways that
may continue to contribute PFAS to the river (Section 3.2 #1). The strategy specified for Old
Outfall 002, for example, targets dry weather flows for treatment and excludes the treatment of wet
weather flows that have the potential to transport contaminated sediment to the river. No creek-
specific controls are planned for Willis Creek and Georgia Creek and no treatment plans are
described for the newly identified seeps (E to M) south of the site. The effectiveness of the proposed
treatment measures is uncertain and cannot be evaluated from the material provided in the CAP.
• There is a gap regarding the extent, magnitude, and loading of PFAS from offsite contaminated
soils and groundwater that could act as long-term sources of PFAS to the river, continuing to impact
the quality of raw intake water for CFPUA (Section 3.2 #1 and #4). PFAS contamination from
Chemours has been detected in an area of 70 square miles (or more) surrounding the facility.
However, because of the extent of the contamination, lack of scalable remediation technologies, and
because no groundwater standards have been issued, it is claimed in the CAP that restoring
groundwater conditions to PQLs is not feasible, which does not seem to comply with 2L Rules as
required by the CO (paragraph 16). PFAS contamination of sediment in the bed and riparian
wetlands of the river also remains uncertain. A comparative PFAS loading assessment just
downstream of the site and at the CFPUA raw water intake is needed to evaluate offsite loading
contributions to the river.
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
2
2.0 BACKGROUND
Chemours Company submitted the Cape Fear River PFAS Corrective Action Plan (Geosyntec, 2019a) to
the North Carolina Department of Environmental Quality (NCDEQ) and Cape Fear River Watch (CFRW)
on December 31, 2019, in response to the Consent Order (CO) entered by the Bladen County Superior
Court (paragraphs 11.1 and 12) on February 25, 2019. The CO was issued regarding emissions and
discharges of PFAS, including HFPO-DA and the ammonium salt of HFPO-DA, which has the trade name
of GenX®, from the Fayetteville Works facility. GenX is used to manufacture high-performance
fluoropolymers. GenX replaces the ammonium salt of perfluorooctanoic acid (PFOA), which was phased
out of production in 2009 because PFOA is persistent in the environment, bioaccumulates, and is toxic.
At that time the Fayetteville Works facility was owned and operated by E.I. du Pont de Nemours and
Company (DuPont). The Chemours Company was founded in July 2015 as a spin-off from DuPont.
In 2009 EPA authorized the manufacture of GenX; however, EPA also issued an order that required
DuPont to capture new chemical substances from wastewater effluent and air emissions at an overall
efficiency of 99 percent (premanufacture notice numbers P-08-508 and P-08-509). News broke regarding
elevated levels of GenX and PFAS in the Cape Fear River in 2017 – spurring further environmental
investigations and facility inspections. Shortly thereafter, NCDEQ filed a Complaint alleging violations of
Title 15A of the North Carolina Administrative Code Subchapter 02L .0202 Groundwater Quality
Standards due to evidence of PFAS discharges by Chemours and DuPont, ultimately leading to the CO.
The Fayetteville Works facility is in Bladen County, North Carolina, on the west side of the Cape Fear
River just upstream of the William O. Huske Lock and Dam (Lock and Dam #3). The facility includes two
Chemours manufacturing areas, the Monomers IXM area and the Polymer Processing Aid Area (PPA
area), as well as an onsite process wastewater treatment plant (WWTP) and power area (Geosyntec,
2019b). Manufacturing areas on the facility grounds are leased to Kuraray America Inc. for Butacite® and
SentryGlas® production and to DuPont for polyvinyl fluoride (PVF) resin manufacturing.
The Chemours Fayetteville Works facility is located about 55 miles upstream of the Kings Bluff water
intake on the Cape Fear River where the Cape Fear Public Utility Authority (CFPUA) withdraws water for
treatment and potable use distribution. Elevated levels of PFAS have been observed in both the raw
source water from the Cape Fear River and finished water at the CFPUA’s Water Treatment Plants
(WTPs). Traditional water treatment processes do not successfully remove GenX and other PFAS
(Hopkins et al., 2018). The effectiveness of currently implemented and proposed PFAS pollution control
strategies adopted by Chemours directly impacts the quality of CFPUA’s intake water and community
exposure to these substances.
Chemours submitted the Cape Fear River PFAS Loading Reduction Plan (Geosyntec, 2019b) in August
2019 and CFPUA engaged Tetra Tech to conduct a technical review of the report (Tetra Tech, 2019).
The review evaluated the technical soundness of the modeling, the reasonableness of the assumptions
applied in the analyses, the reasonableness of the proposed strategies for reducing PFAS loads,
identified critical gaps, and recommended additional studies related to reducing PFAS loads. Comments
most pertinent to CFPUA’s downstream water intake included the lack of groundwater data, insufficient
extents and lack of information about the extent, magnitude, and impact of offsite groundwater and soil
contamination, lack of information necessary to characterize PFAS contamination in the sediment of the
riverbed and riparian wetlands, and lack of information regarding the effectiveness of the proposed
treatment measures.
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
3
A technical review of the CAP is presented in this report. The CAP describes site information, recent
receptor monitoring details, a numerical hydraulic groundwater model, PFAS signatures source
assessment, recent corrective actions summary, human health and ecological exposure and hazard
assessments, proposed remediation activities by source pathway, and performance monitoring plans.
The appendices relevant to the fate and transport of PFAS in the environment were also reviewed. This
includes Appendix A - On and Offsite Assessment Tables; Appendix B - Additional Corrective Action Plan
Tables and Figures; Appendix C - Kow, Koc and Mass Distribution Calculations; Appendix D -
Southwestern Offsite Seeps Assessment; Appendix E - PFAS Signatures Assessment; and Appendix H -
Numerical Groundwater Modeling Report. CFPUA plans to collaborate with expert Dr. Jamie Dewitt for
elements related to human exposure and toxicity, as described in Appendix F - Human Health Screening
Level Exposure Assessment of Table 3+ PFAS. The ecological assessment, discussed in Appendix G –
Ecological Screening Level Exposure Assessment of Table 3+ PFAS, and Appendix I – Detailed Costs
were not reviewed as part of the technical assessment described in this report.
3.0 TECHNICAL REVIEW
Key comments from the technical review of the CAP and supporting appendices are discussed in the
following sections. The adequacy of the modeling and CAP cannot be evaluated due to the reasons
summarized below.
3.1 TECHNICAL SOUNDNESS
This section summarizes concerns regarding the technical soundness of data and analyses cited to
support conclusions in the Cape Fear River PFAS CAP and supporting appendices.
1. Information provided in the quarterly reports indicate that monitoring conducted aligns with
specifications in the approved monitoring plan. However, results from the PFAS monitoring tests
are inconsistently applied in the assessments. On page xii of the CAP, it states “The PFAS that
originate from the Site are referred to as Table 3+ PFAS. The Table 3+ analytical method was
developed to analyze PFAS specific to the Site that were identified through non-targeted
chemical analyses. Currently, the Table 3+ method can quantitate for 20 PFAS compounds
including HFPO-DA, i.e., “GenX”. When examining PFAS at the Site, the sum of these
compounds, i.e., total Table 3+ PFAS compounds, is often used to evaluate trends and
distributions.” However, in some analysis components Table 3+ PFAS are applied, in other
components the assessment is limited to HFPO-DA, and sometimes Modified EPA Method 537
compounds are evaluated. This inconsistency hinders comparison between sources and
components of the study (i.e., not always apples-to-apples). Example instances and impacts of
this are described below.
o The CO specifies the PFAS to be monitored for public drinking water and private wells
(paragraphs 19-21 and 24) in Attachment C. According to paragraph 11 in the CO,
ongoing sampling for process and non-process wastewater and stormwater at the facility
is to be conducted for “all” PFAS for which test methods and lab standards have been
developed, although these are not explicitly listed. The results described in the quarterly
reports seem to include the Table 3+ PFAS and Modified EPA 537 PFAS for most sites,
which matches specifications in the monitoring plan. Chemours claims that the Modified
EPA 537 PFAS (excluding HFPO-DA) did not originate from the site as these were
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
4
already present in the intake water. Modified EPA 537 PFAS other than HFPO-DA are
assigned a concentration of zero for onsite transportation pathways in the PFAS mass
loading model. However, based on analytical results from the April 2019 monitoring
event described in Chemours’ first quarterly report, other PFAS (e.g., Perfluoropentanoic
Acid) were found in process water from the Chemours Monomers IXM Area (site 16,
page 3 of Table 4) at much higher concentrations than found in the background/intake
water (later monitoring reports do not include samples from process wastewater). This
suggests that some of the other Modified EPA 537 PFAS may originate from
manufacturing on the site, but Modified EPA 537 PFAS (except for HFPO-DA) are
excluded from the mass loading model and assessments discussed in the CAP (e.g.,
PFAS signatures). Therefore, it is unclear if the approach abides by the CO
requirements and if the approach characterizes PFAS loads from the site accurately.
Monitoring results, such as those from onsite and offsite groundwater wells, indicate that
the relative proportions of PFAS compounds vary spatially, thus, it cannot be assumed
that evaluating HFPO-DA in isolation is representative of other/total PFAS as has been
assumed for atmospheric deposition modeling.
o Table 3+ and Modified EPA 537 PFAS methods exclude two PFAS listed in Attachment
C of the CO, PFMOPrA, and PFMOBA, which are isomers that have the same chemical
formulae as PMPA and PEPA, respectively, but have different chemical structures and
CASN numbers. PFHpA listed in Attachment C is not included in the Table 3+ method,
although it is included in the Modified EPA 537 method. Monitoring and assessments
that are limited to Table 3+ PFAS exclude PFMOPrA, PFMOBA, and PFHpA from
Attachment C of the CO.
2. Throughout the report and appendices, reduction targets are expressed as a relative percent
reduction compared to an undefined baseline period. Appropriate quantification of the reductions
achieved with the implementation of treatment technologies requires a clear definition of the
baseline period and associated baseline loads for each PFAS transport pathway. In both the
CAP and PFAS Loading Reduction Plan, baseline loading rates have not been specified; instead,
relative percent contributions from the various onsite transport pathways are described (e.g., 22
percent for onsite groundwater in May 2019 as listed in Table 7 in the CAP). Without a clear
definition of the baseline period and loads, results could be interpreted in a manner that
misrepresents progress. For example, monitoring data from a single day were extrapolated to
generate an annual HFPO-DA load. The river flow that was applied to estimate the load for 2019
was less than one-third of the river flow applied for 2017. This caused an overestimation of the
reported reduction in loading to the Cape Fear River that was described in the technical review
report for the PFAS Loading Reduction Plan. It is recommended that a) a clear and consistent
baseline period is defined and b) for past and future monitoring events, that the flow, PFAS
concentration, and load associated with each transport pathway should be presented.
3. Reductions for aerial deposition were estimated for HFPO-DA and the report states there are
“expected comparable reductions for other PFAS”, although information to justify this important
assumption is lacking (e.g., measured pollutant removal efficiencies for other PFAS through the
application of air control technologies). Indeed, differences in adsorption and volatility
characteristics among PFAS compounds suggests that rates will differ. Previous comments
regarding the atmospheric deposition modeling described in the technical review of the PFAS
Loading Reduction Plan do not appear to have been addressed and, thus, remain a concern.
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
5
4. Although the analysis time period is not specified in the CAP, historical process water releases
are estimated to account for 76 to 86 percent of the Table 3+ PFAS detected in the Cape Fear
River with the remainder coming almost entirely from historic air emissions (14 to 24 percent).
This implies that no significant loading of Table 3+ PFAS to the river originates from other
background sources, although information is not presented to justify this assumption. As
described in other comments, only the relative percent contributions are listed and actual load
estimates are not presented (i.e., in mass of PFAS per time interval). It is also important to
determine how both the magnitude and relative contributions of PFAS loads have shifted over
time in response to halting releases of process water in 2017 and subsequent implementation of
other control measures.
5. Figure 3 in the CAP shows the total Table 3+ PFAS mass distribution in a normalized volume of
the unsaturated and saturated soil zones (kg/m3). For several of the assessed locations (11 of
18), a result is not shown for the unsaturated zone because no Table 3+ compounds were
detected (Table C-3); however, the text does not specify the detection limit.
6. The PFAS signatures assessment component of the CAP evaluated the make-up and distribution
of PFAS compounds in onsite and offsite groundwater. Two main categories identified included
1) aerial deposition PFAS signature from emissions to air and 2) combined process water PFAS
signature from historic releases of process water to soil and groundwater. The latter signature is
only detected onsite, affects approximately 1 square mile, exhibits Table 3+ PFAS concentrations
of 2,900 to 18,000,000 ng/L onsite, and is estimated to contribute 76 to 86 percent of Table 3+
PFAS loading to the river. The former (aerial) signature is detected on and offsite, affects >70
square miles, exhibits lower Table 3+ PFAS concentrations (15 to 13,000 ng/L onsite and 10 to
4,500 ng/L offsite) and is estimated to contribute 14 to 24 percent of Table 3+ PFAS loading to
the river. Comments related to the PFAS signatures assessment are summarized below:
o Three PFAS signatures were established for aerially deposited PFAS from a hierarchical
cluster analysis. These include 1) predominantly PMPA (perfluoromethoxypropyl
carboxylic acid); 2) predominantly HFPO-DA (hexafluoropropylene oxide dimer acid); and
3) mixed PMPA and HFPO-DA. Another signature, predominately PFMOAA (perfluoro-1-
methoxyacetic acid), is described to be the signature representative of process water
contamination. A physical/chemical/geological explanation for the distribution of the
signatures is missing and a discussion regarding the interactions and transformations of
PFAS (precursors to degradation resistant PFAAs (perfluoroalkyl acids) via abiotic or
biotic mechanisms) over time is lacking, although the report generically states that
transformation of most PFAS substances in the environment is negligible. For example,
why is PFMOAA primarily associated with process waste contamination? Are there
atmospheric transport mechanisms that influence the distribution of the aerial signatures?
The rate at which rainfall scours a substance from the air will vary according to the
Henry’s law constant, which varies across the PFOA/PFOS substances in Appendix G,
however, the CAP does not describe this phenomenon (note that the Table 2-3 in
Appendix G lists the Henry’s law constants and includes a footnote stating the estimates
originate from the CAP, but that does not appear to be correct). This contradicts previous
statements that claim atmospheric deposition modeling of HFPO-DA is directly applicable
to other PFAS. What other biogeochemical transformations in the environment influence
the distribution of the aerial signatures?
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o The thresholds used to differentiate the signatures (e.g., what constitutes an aerial
mixture signature versus a predominately PMPA or HFPO-DA aerial signature) is vague
and should be explicitly described.
o The signatures assessment did not attempt to distinguish the portion of the PFAS
signatures attributed to background, or non-Chemours, sources (e.g., biosolids
applications, fire response chemicals, atmospheric deposition from other regional or
global sources).
o The report does not describe how the findings from the signature assessment will inform
future studies and remediation efforts.
o We suggest that the analysis could be improved and clarified through the application of a
fugacity analysis with a model such as QWASI (Mackay et al., 1983) to determine the
likely theoretical distribution of compounds of interest between air, soil, and water (e.g.,
Kong et al., 2018).
7. To simulate groundwater hydraulics, an EVS geologic model (seven hydrostatic and
heterogenous units) and a FEFLOW 3D finite element groundwater model were developed for the
site. Comments regarding the development and calibration of the numerical groundwater model
(Appendix H) include:
o As noted in the numerical groundwater modeling report, the subsurface hydraulic
conductivity (K) values listed in Table 2 for the Surficial and Black Creek aquifers are well
outside of the typical range presented in Table 1. Anomalous K values would have
implications for the estimation of groundwater discharge and pumping rates. Were
calibrations attempted with lower K values and, if so, what were the outcomes? Also, the
model sensitivity test ranges for K (±20 percent) appear low given the modeled versus
typical range values presented in the report. Were the much higher K values derived
from the groundwater model calibration subsequentially incorporated into the
contaminant mass loading estimates that were generated separately? If not, the mass
loading flux to the river due to groundwater discharge may be significantly
underestimated.
o The numerical groundwater modeling report describes the data source for specifying the
upper layer boundary (site precipitation and evapotranspiration estimates for the Mid-
Atlantic Coastal Plain from USGS) but does not present the initial rainfall recharge rates
used in the model. It is inferred from the wording that these served as initial rates that
were adjusted during the model calibration, however, the final calibrated rates are not
provided. On page 12 it is stated that the final hydraulic parameters are provided in
Table 3, although Table 3 instead lists the final calibration statistics for the three zones
(Perched Zone, Surficial Aquifer, and Black Creek Aquifer), not the hydraulic parameters.
o It is stated that localized anthropogenic stormwater recharge (a second upper layer
boundary in addition to rainfall recharge described in the previous bullet) and historic
infiltration from previously unlined sedimentation basins is included in the top boundary
condition. The sedimentation basins have been lined so it is unclear why the basins are
assumed to contribute infiltration water to the Perched Zone for the simulation period of
October 2019. In addition, the rate is presented as 80,000 GPD and this should be
correspondingly presented as a depth-based rate (e.g., inches per day/month).
o Bluff seep discharge rates were evaluated but the report lacks presentation of
performance metrics. Based on the information provided (Table 6.2), the model
underpredicts Cape Fear River bluff seeps by about 88 percent and overestimates Old
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Outfall 002 flow by 60 to 140 percent (range provided for measured/estimated flow).
Therefore, the model seems to provide a weak correlation of these outflow features
although the implications are not discussed.
o It is not clear from the numerical groundwater modeling report and CAP whether the
onsite seeps originate from the perched zone, surficial aquifer, or both – this is important
information for the development of a groundwater remediation strategy. It is also unclear
what groundwater flow unit the offsite seeps described in Section 3.5 of the CAP
discharge from.
o There is no quantification of the groundwater flux into the river from each of the
groundwater flow units included in the model. Such fluxes should inform the basis for
developing groundwater extraction and treatment scenarios.
o The daily median water elevation for the Cape Fear River measured at the W.O. Huske
Dam is used to set the hydraulic head for the eastern boundary condition. It is not stated
if this is the median water elevation for October 2019 or another period, although the
former is preferable for the steady-state application described.
o On page 13 it is stated that an overall error of 10 percent or less is considered acceptable
for the intended application (although no reference is provided) and that the groundwater
model achieves this target (overall and for the Surficial and Black Creek Aquifers).
Contradictorily, the calibration resulted in a Normalized Root Mean Square (NRMS) error
of 12.5 percent for the final groundwater model (Table 5). Therefore, the calibration effort
did not achieve the target performance metric. Additional information regarding model
performance and justification that the calibrated model is acceptable is needed. For
example, it would be preferable to report performance metrics (such as NRMS) for each
borehole calibration site to assess spatial variability in model performance. NRMS errors
are presented for the three vertical zones, and the error for the Perched Zone is quite
high, 25.2 percent – it is noted that additional calibration efforts may be required to
improve the representation of hydraulics in this zone. It is also stated that the calibrated
FEFLOW model meets the requirements of the NCDEQ 2007 Groundwater Modeling
Policy, however, these are not presented or discussed. The first step in the guidance
(Define Study Objectives) is not addressed – specific and detailed objectives are called
for in the guidance but not provided in the modeling report, although these are critical for
producing a technically sound and appropriate model.
o The model was calibrated for steady-state conditions in October 2019. It would be
preferable to complete a model validation using monitoring and conditions from an
alternative period to demonstrate that the calibrated parameters are robust and the model
responds correctly to different conditions. This is important because, as discussed in
Section 7, the model was run for a forecast period of 1 year for the purpose of evaluating
remedy scenarios given that conditions vary throughout the year (e.g., precipitation and
recharge, boundary condition hydraulic heads including the Cape Fear River).
o The rationale and logic behind the selection of remedy simulations is missing. The
scenario set should be identified based on clear objectives and technical/hydrogeologic
analysis. In Section 5.4 of the CAP, it is stated that the hydraulic containment objectives
are presented in Table 8, however, the table lists a summary of the six predictive
simulations without describing the objectives. For example, no information is provided
about:
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▪ The groundwater discharge rates to the river under ambient conditions from each
hydrogeologic unit, which would be necessary to establish the minimum required
pumping rates for plume capture.
▪ The expected unit-specific maximum sustainable pumping rates for extraction
wells based on hydrogeologic analyses and calculations.
▪ The hydrogeologic units from which the extraction wells draw water. Is it just the
Black Creek Aquifer or are the wells screened across the Surficial Aquifer too?
▪ Capture zone calculations for wells in the initial well placement scheme.
▪ The rationale behind groundwater extraction rates being selected for the different
scenarios. For example, there is a scenario with 41 wells pumping at 20 gpm
each (820 gpm total) and another with 31 wells pumping at 30 gpm (930 gpm
total), although the Black Creek Aquifer groundwater discharge for each scenario
is presented as 1551 gpm. If the pumping scheme extracts substantially less
groundwater compared to the discharge rate, then the entire plume will not be
captured.
o There is no information provided regarding the locations of the extraction wells nor the
constraints on the placement of the extraction wells in Appendix H or Section 5 of the
CAP. Shifting the wells back from the river will alter capture processes and impact the
assessment of feasibility. The groundwater units that the extraction wells will capture
water from is not clear in the documentation. Comparisons are made for the Black Creek
Aquifer. It is unclear if the perched and surficial aquifers are also targeted.
o It is not clear what is represented in column 5 of Table 7, labeled “Black Creek
Groundwater Capture Flow into the Cape Fear River – By Simulated Pumping (GPM)”.
Manipulating the numbers in the other columns does not shed light on what the value is
supposed to represent.
o It is unclear where the flow diverted by the groundwater barrier will go (e.g., will
groundwater reemerge downstream of the wall terminus?). This should be described. It
remains uncertain if a groundwater barrier to limit interactions between onsite
contaminated groundwater and the Cape Fear River would be feasible and effective.
8. Comments related to the measured and calculated partition and mass distribution coefficients
(Appendix C and Section 3.7 of the CAP) include:
o In Section 3.7 it is stated that detailed calculations for the mass estimates are provided in
Appendix C, however, Appendix C describes the process but does not include sufficient
data/spreadsheets to verify the calculations.
o In this appendix, Log Kow values were used to derive Log Koc values for various PFAS
compounds. Contradictorily, in the 2018 Interstate Regulatory Technology Council
(IRTC) guidance document “Naming Conventions and Physical and Chemical Properties
of Per- and Polyfluoroalkyl Substances” it specifically states that “It should be noted that
although the Kow for some organic contaminants can be used for estimating Koc, this
cannot be performed for estimating values for PFAS”. This calls into question the
technical approach used in Appendix C and the results obtained.
o For HFPO-DA, the Table C-2 Log Koc value is 1.1, while in Table 2 of the CAP it is 1.69.
Which (if either) of these is correct and used for the calculations?
o Throughout Table C-2, as the Log Kow increases, the Log Koc increases as well. This is
true except when comparing PFBA and PFPeA – what is unique about these
compounds? The specific calculations are not provided for review and evaluation.
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9. In the monitoring well redevelopment and resampling section, it is stated that 17 wells were
redeveloped onsite, and 45 wells were resampled onsite based on recommendations issued in
the Onsite and Offsite Assessment Report. The CAP does not provide summary level statistics
for the groundwater monitoring effort, which would be very informative (e.g., mean and range of
concentrations observed).
10. As described in the updated PFAS characterization sampling plan for process and non-process
wastewater and stormwater, the raw intake point onsite is used to characterize background PFAS
levels. However, water from the Cape Fear River at the intake point may be influenced by legacy
atmospheric emissions and contaminated groundwater attributable to the site. Samples collected
further upstream are needed to better characterize background PFAS concentrations.
3.2 CRITICAL GAPS
1. Concerns regarding the planned strategies to meet the cleanup goals described in Table 10 in the
CAP include:
o Old Outfall 002. The cleanup goal and proposed capture and treat strategy are solely
designed to handle dry weather flows, thus, wet weather flows that may facilitate erosion
of contaminated sediment are excluded. Based on the three 2019 monitoring events
(May, June, and September), the relative contribution of Old Outfall 002 is estimated to
be 26 percent of the total onsite PFAS load to the Cape Fear River. In Table 14, 26
percent of the planned loading reduction to the Cape Fear River is attributed to the
capture and treatment of Old Outfall 002. This implies that 100 percent of PFAS will be
treated by 2020 for the outfall, which conflicts with only targeting groundwater with the
process wastewater signature.
o Willis Creek and Georgia Creek. Indirect air abatement controls and onsite
groundwater remedies are listed as strategies, but no creek specific controls are planned
(e.g., removal of PFAS elevated sediment, flow capture and treatment).
o Onsite Groundwater. The cleanup goal for groundwater describes mitigation of PFAS
with a process water signature, thus, inherently excluding remediation of onsite
groundwater exhibiting an aerial deposition signature. As shown in Figure 2, some of the
groundwater wells onsite exhibit the latter. Based on the three 2019 monitoring events
(May, June, and September), the relative contribution of onsite groundwater is estimated
to be 18 percent of the total onsite PFAS load to the Cape Fear River. In Table ES2, 18
percent of the planned loading reduction to the Cape Fear River is attributed to onsite
groundwater treatment. This implies that 100 percent of PFAS in groundwater will be
treated by 2024, which conflicts with only targeting groundwater with the process
wastewater signature.
o Offsite Groundwater and Offsite Soils. It is stated that PFAS contamination has been
detected in an area of 70 square miles (or more) surrounding the facility. However,
because of the extent of the contamination, lack of scalable remediation technologies,
and because no groundwater standards have been issued, it is claimed in the CAP that
restoring groundwater conditions to PQLs is not feasible. A lack of management of
offsite pollution does not seem to comply with 2L Rules as required in the CO Paragraph
16. It is also stated that PFAS are not expected to degrade in a reasonable time period
in the environment. This is a concern because contaminated soils and groundwater will
contribute legacy PFAS to the Cape Fear River in the future, continuing to impact the
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quality of raw intake water for CFPUA. PFAS loading just downstream of the site and at
the CFPUA intake should be quantified and compared to better understand the potential
for long-term contamination from offsite sediment erosion, resurfacing groundwater, and
releases from sediment in the riverbed and riparian areas. The assessment should
compare loading at the two locations under varied conditions (e.g., dry/low flow periods,
storm events). Also, the CAP describes several newly identified seeps, labeled E to M,
south of the site, although no treatment plans are prescribed.
o Onsite Soils. Contamination in onsite soils remains unclear and no remediation
strategies have been suggested in the CAP.
o Outfall 002. The remediation strategies for Outfall 002 are too vague, stating that
compliance with NPDES permit requirements will be completed. Information regarding
the PFAS-related requirements that will be included in Chemours’ NPDES permit should
be requested from DEQ.
2. As discussed in Section 5.1 of the CAP, the groundwater numerical model is only intended to
simulate subsurface hydraulic processes, not associated PFAS fate and transport, for the
purpose of remedy costing and design. Therefore, in its current state, the model provides limited
insight in terms of PFAS loading and potential remediation effectiveness. In addition, the
groundwater model covers the limited domain of the site. Thus, groundwater hydraulics are not
represented for the surrounding vicinity contaminated by PFAS due to legacy atmospheric
deposition. Since offsite seep data is attributed to aerial PFAS deposition, it could be used to
estimate groundwater PFAS discharges to the river throughout the area (including upstream and
downstream of the site) by using a distance-versus-concentration gradient approach and
including discharge from both sides of the river due to airborne transport processes. This
analysis would be informative, although it is not discussed.
3. There is a very limited discussion of PFAS transformations in the environment and the
implications for ongoing contamination, exposure risk, and remediation activity effectiveness
(e.g., presence of precursors that can degrade to PFAS analytes over time). It is noted in Section
3.4, that total Table 3+ concentrations in wells are comparable to prior results (within ± 25
percent), however, temporal monitoring records have not been applied to explore transformations
of PFAS, nor has available and relevant information from the literature been summarized.
4. As noted in the previous technical review, a critical gap is that the extent, magnitude, and impact
(loading) of PFAS contamination in offsite groundwater and soils are poorly quantified. Releases
of contaminated groundwater, diffusion from contaminated sediment, and erosion of
contaminated soils may contribute PFAS to the CFPUA’s intake water following the
implementation of the proposed onsite control strategies. PFAS contamination of sediment in the
Cape Fear River bed and riparian wetlands remains uncertain and diffusion from these stores
could act as a long-term source of PFAS to the river. A river sediment sampling plan was issued
in August 2019 and it is anticipated that monitoring will be conducted at several riverine locations,
including near CFPUA’s raw water intake site, and a report released in 2020.
5. At this time, a comprehensive flow mass balance that represents all inflow and outflows at the site
has not been developed. It is stated in Section 3.4 of Appendix H that the numerical groundwater
model will eventually be used to support the development of an initial water budget. However,
this is a current information gap.
6. In the CAP, the onsite Willis Creek to the north and Georgia Branch Creek to the south are
described as being erosional channels that empty to the Cape Fear River. PFAS accumulated in
the creek beds that is eroded during storm events may contribute to ongoing PFAS loading to the
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river, yet the report does not attempt to measure bed contamination and model sediment
transport (net deposition and scour) for the purpose of characterizing particulate-associated
PFAS transport. Note that deeper soil samples (depths of 8.5 to 11 feet) have been collected in
the vicinity of Willis Creek at a single location (Figure A7-1). The results for the analytes reported
were either flagged as “UJ” (defined as “Analyte not detected. Reporting limit may not be
accurate or precise”) or flagged as “<” (defined as “Analyte not detected above associated
reporting limit”).
7. It was noted in the technical review for the PFAS Loading Reduction Plan and the CAP (Section
3.3.3) that discharge of Chemours’ process wastewater has been halted and the waste is injected
into subsurface storage out-of-state. However, elevated HFPO-DA and PFMOAA concentrations
were also observed in Kuraray process wastewater, which continues to be discharged from the
onsite WWTP via Outfall 002, as discussed in the PFAS Loading Reduction Plan and previous
technical review. Loading from Kuraray process wastewater remains unquantified and untreated.
8. Another gap, although perhaps minor, is related to process wastewater. Before June 21, 2017
process wastewater was discharged to the Cape Fear River and after November 29, 2017
process wastewater was captured, stored, and transported offsite for disposal. The report does
not describe what was done with process wastewater in the interim, between June 22 and
November 28, 2017.
3.3 OTHER COMMENTS
Other comments related to vulnerabilities pertaining to CFPUA’s intake water include:
1. No manufacturing process changes have been required for Chemours to date. Spills or unknown
leaks or emissions at the facility remain a risk to CFPUA’s source water.
2. All monitoring applied in the assessment appears to have been conducted by Geosyntec and
contracted labs for Chemours. DEQ can require split sampling (samples provided to DEQ for
parallel testing) per the CO. Split sampling would be beneficial from the perspective of CFPUA
for quality assurance and control checking, therefore, CFPUA should inquire about completed
split sampling and the findings.
4.0 REFERENCES
Geosyntec. 2019a. Cape Fear River PFAS Corrective Action Plan, Chemours Fayetteville Works.
Prepared for Chemours Company FC, LLC. by Geosyntec Consultants of NC, P.C., Raleigh, North
Carolina.
Geosyntec. 2019b. Cape Fear River PFAS Loading Reduction Plan. Prepared for Chemours Company
FC, LLC. by Geosyntec Consultants of NC, P.C., Raleigh, North Carolina.
Hopkins, Z. R., M. Sun, J.C. DeWitt, and D.R.U. Knappe. 2018. Recently detected drinking water
contaminants: GenX and other per- and polyfluoroalkyl Ether Acids. Journal of the American Water Works
Association, 110(7), https://doi.org/10.1002/awwa.1073.
Technical Review of Cape Fear River PFAS Corrective Action Plan February 28, 2020
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IRTC. 2018. Naming Conventions and Physical and Chemical Properties of Per- and Polyfluoroalkyl
Substances (PFAS). Interstate Regulatory Technology Council. https://pfas-1.itrcweb.org/wp-
content/uploads/2017/10/pfas_fact_sheet_naming_conventions_11_13_17.pdf.
Kong, X., W. Liu, W. He, F. Xu, A.A. Koelmans, and W.M. Mooij. 2018. Multimedia fate modeling of
perfluorooctanoic acid (PFOA) and perfluoroctane sulphonate (PFOS) in the shallow lake Chaohu, China.
Environmental Pollution, 237: 339-347.
Mackay, D., M. Joy, and S. Paterson. 1983. A quantitative water, air, sediment interaction (QWASI)
fugacity model for describing the fate of chemicals in lakes. Chemosphere, 12: 981-997.
Tetra Tech. 2019. Technical Review of Cape Fear River PFAS Loading Reduction Plan for Cape Fear
River Public Utility Authority (CFPUA). Prepared for Cape Fear River Public Utility Authority by Tetra
Tech, Research Triangle Park, North Carolina.
Limited Review of “APPENDIX F: Offsite Human Health
Screening Level Exposure Assessment (SLEA) of Table 3+
PFAS” (authored by Geosyntec Consultants) for the
Cape Fear Public Utility Authority.
February 21, 2020
Prepared for:
Cape Fear Public Utility Authority
235 Government Center Drive
Wilmington, NC 28403
Prepared by:
Jamie C. DeWitt, PhD, DABT
Independent Consultant
Greenville, NC 27834
Voice: 919-608-2373
Email: dewittj@ecu.edu
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Brief Summary of Appendix F and Overview of Charge
“Appendix F” is a support document for the Corrective Action Plan (CAP) for the Chemours
Fayetteville Works Facility in Bladen, County, North Carolina (referred to as “the Facility” in
Appendix F). The “Screening Level Exposure Assessment” (SLEA) contains numerical estimates
of human exposure to per- and polyfluoroalkyl substances (PFAS) originating from air emissions
and/or past process water releases from the Facility. These numerical estimates of human
exposure come from PFAS estimated or measured from a variety of environmental media – soil,
well water, homegrown produce, offsite surface water and fish tissue, onsite surface water and
fish tissue, and surface water from an offsite pond. Where possible, the consulting company
hired by Chemours (Geosyntec Consultants of NC, P.C.) calculated “exposure point
concentrations” (EPCs) for these environmental media using models from the U.S.
Environmental Protection Agency (EPA).
EPCs were calculated from environmental media to estimate PFAS exposure to different groups
of people through these environmental media. The groups of people included in Appendix F
were adult and child residents, farmers, and gardeners. Some PFAS exposures also were
calculated for adult and child recreational consumers of surface waters and fish tissues.
Exposure was therefore based on how much PFAS these groups of people would take into their
bodies through these various environmental media (defined as “intake”). As with EPCs,
assumptions about intake were based on values available from the U.S. EPA (i.e., how much
water an adult drinks per day or how much incidental ingestion of soil occurs for a child).
Once the total intake of PFAS was calculated for each group of people, the consulting company
compared the values to the North Carolina Department of Health and Human Services (NC
DHHS) 2017 draft oral reference dose (oral RfD) for “GenX,” or hexafluoropropylene oxide
dimer acid (HFPO-DA), which is 1 x 10-4 mg/kg/day. This comparison was made to determine if
intake was greater or lesser than this RfD. The U.S. EPA (1993) defines a RfD as “an estimate
(with uncertainty spanning perhaps an order of magnitude) of a daily exposure to the human
population (including sensitive subgroups) that is likely to be without an appreciable risk of
deleterious effects during a lifetime.” The U.S. EPA (1993) further clarifies the RfD by indicating
that it should not be categorically concluded that all doses below the RfD are without risk and
that all doses in excess of the RfD will result in adverse effects. In other words, the RfD can be
used as a guide to determine if intake of PFAS is above or below an acceptable level but does
clearly and unquestionably separate groups “with risk” from groups “without risk.”
I have been asked to prepare a brief memorandum evaluating specific points in Appendix F that
concern surface water consumption from offsite surface water. This evaluation will include a)
components not considered or gaps in the assessment that have the potential to impact the
results and b) additional studies that should be conducted to strengthen the assessment.
This memorandum reflects my professional opinion based on my extensive knowledge of
toxicology and the risk assessment process and the toxicology of PFAS. It does not reflect the
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opinion of the Department of Pharmacology and Toxicology, the Brody School of Medicine, East
Carolina University, or any other organization or entity to which I belong.
Section 3: Conceptual Exposure Model (pp 10-14 in Appendix F)
PFAS evaluated in the SLEA are listed in Table 1 of Appendix F and are included here as a
reference point.
This section defined the groups of people who were included in the “conceptual exposure
model.” This type of model draws the connections between levels of PFAS in environmental
media with how much PFAS groups of people will take in from those environmental media.
These connections were highlighted in Figure 2 of Appendix F. Connections that were
considered incomplete were not evaluated. These were based on whether or not data were
available on 1) a source of PFAS or release of PFAS from a source, 2) a mechanism of release
and transport of PFAS, 3) a point of contact of the groups of people to the environmental media
containing PFAS, 4) and exposure route (i.e., ingestion, inhalation, dermal), and 5) the presence
of groups of people. Note that groups of people were referred to as “receptors” or “receptor
populations” throughout Appendix F. This is standard terminology for conceptual exposure
models.
Components not considered/gaps in the assessment/additional studies: Three groups of people
were not considered in the SLEA: fetuses during pregnancy, infants, and lactating women. The
U.S. EPA Health Advisory Level for two PFAS, perfluorooctanoic acid (PFOA) and
perfluorooctane sulfonate (PFOS) were based on protection of fetuses during pregnancy and
breastfed infants. The Health Advisory Level was calculated based on drinking water intake of
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lactating women who drink a higher volume of water than other people and who can pass PFAS
to their nursing infants through breastmilk (U.S. EPA, 2017). In addition, the NC DHHS drinking
water exposure limit (DWEL) for HFPO-DA also was based on protection of bottle-fed infants.
Therefore, the populations at the highest risk from adverse health effects arising from PFAS
exposure, fetuses during pregnancy and infants, were not considered in the SLEA.
Section 4: Identification of Offsite Exposure Units (pp 15-16 in Appendix F)
The conceptual exposure model also included a description of the environmental media that
contained PFAS as identified in environmental investigations in and around the Facility. Only
surface waters are considered in this memorandum and they include all identified exposure
units (EUs) of the Cape Fear River (EUs 13-17). These surface waters included upstream and
Facility-adjacent locations as well as locations 4, 8, and 55 miles downstream from the Facility.
Components not considered/gaps in the assessment/additional studies: None identified.
Section 5: Environmental Datasets and EPCs; 5.3: Surface Water (pp 23-26 in Appendix F)
Information of PFAS detected in surface waters was collected from locations depicted in Figure
7, which included upstream, Facility-adjacent, and downstream (4, 8, and 55 miles from the
Facility) and included nine discrete sampling events between September of 2017 and the
Summer of 2019. These events included months in the spring, summer, fall, and winter seasons
and also appear to have included weather events such as Hurricane Florence. The water
samples were analyzed with Method 537, which is a method developed by the U.S. EPA for
evaluation of up to 18 different PFAS in water samples (EPA, 2018a). Additional methods were
employed for some samples to evaluate Table 3+ PFAS. The surface water data were then
segregated to develop EPCs for recreational and drinking water uses.
Components not considered/gaps in the assessment/additional studies: Additional sampling
locations between 8 and 55 miles from the Facility would provide more information about the
spatial distribution of PFAS in surface waters of the Cape Fear River. Additional collection times
would provide more details about the temporal fluctuations of PFAS in surface waters of the
Cape Fear River.
Section 6: Intake Characterization; (pp 32-34 in Appendix F)
Intake of PFAS was expressed in milligrams of PFAS per kilogram of body weight per day as an
average daily intake (ADI). Equations used to calculate intake were based on U.S. EPA guidance
documents that provide intake rates. The following surface water ADIs were included in
Appendix F:
• Facility-adjacent and near-downstream EUs for recreationalists = 7.3 x 10-8 to 3.1 x 10-6
mg/kg/day.
• Bladen and Kings Bluffs EUs for recreationalists = 1.1 x 10-7 to 2.1 x 10-6 mg/kg/day
• Bladen Bluffs EUs for residents, HFPO-DA only = 1.2 x 10-5 to 1.8 x 10-5 mg/kg/day
• Kings Bluffs EUs for residents, HFPO-DA only = 6.4 x 10-7 to 9.2 x 10-7 mg/kg/day
• Kings Bluffs EUs for residents, Table 3+ PFAS = 3.5 x 10-6 to 5.0 x 10-6 mg/kg/day
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Components not considered/gaps in the assessment/additional studies: ADI calculations used in
the SLEA do not consider biological half-life and body burden. The biological half-life is how
much time it takes to reduce the concentration of a chemical in the body by one-half and body
burden is how much of a chemical is in the body at any given time (Baynes et al., 2012). Failure
to include half-life and body burden inherently flaws ADI calculations because it assumes
complete elimination of a chemical from the body between exposures. PFAS such as PFOA and
PFOS have biological half-lives of years, leading to increased body burdens over time with
repeated exposures. Therefore, ADI calculations without a factor that includes biological half-
life tend to underestimate intake. While the half-life of HPDO-DA and other Table 3+ PFAS are
unknown, an assumption of complete elimination is flawed without empirical data on half-life.
Components not considered/gaps in the assessment/additional studies: Dermal intakes were
not calculated due to the lack of dermal toxicity criteria (i.e., an RfD for dermal toxicity)
developed at the state or federal level. There are a few studies of adverse health outcomes
arising from dermal exposure to, for example, PFOA (Shane et al., 2020). Such values could have
been used as a basis for comparing dermal intakes.
Section 7: Provisional Hazard Characterization (pp 35-38 in Appendix F)
Much of this section contained background definitions of toxicological values (section 7.1).
Section 7.2 contained the basic methods used by Geosyntec Consultants to characterize the
potential hazards of HFPO-DA and Table 3+ PFAS. The basic comparison was the ratio of the ADI
to the RfD, often referred to as the “hazard quotient.” Recall that the RfD was derived by NC
DHHS in 2017 and was a draft oral RfD (1 x 10-4 mg/kg/day) for HFPO-DA. If the ADI exceeded
the RfD (hazard quotient > 1), intake was greater than a level that is considered acceptable. If
the ADI was less than the RfD (hazard quotient < 1), intake was less than a level that is
considered acceptable. It also is important to recall that the RfD is not a clearly defined value
separating high risk from low risk levels.
All of the hazard quotients that Geosyntec Consultants calculated for groups of people
consuming surface waters were less than one.
Components not considered/gaps in the assessment/additional studies: As stated previously,
ADI calculations without a factor that includes biological half-life tend to underestimate intake
and dermal intakes were not calculated.
Section 8: Uncertainty Assessment (pp 39-48 in Appendix F)
This section of Appendix F described uncertainties that may have had an impact on the SLEA.
Uncertainties included environmental sampling results, assumptions regarding receptor
behavior, and the quantitative representation of chemical toxicity. Geosyntec Consultants
indicated that where there was “significant uncertainty,” they tried to provide additional
conservatism, which would tend to provide additional protections. A few areas of this section
are highlighted here.
Review of
“APPENDIX F: Offsite Human Health Screening Level Exposure Assessment (SLEA) of Table 3+ PFAS”
Jamie C. DeWitt February 18, 2020
6
With respect to sources of uncertainty associated with surface water EPCs, Geosyntec
Consultants highlighted the “transient nature of surface water” as the primary source of
uncertainty. Each sample collected reflected only the levels of PFAS in surface water at that
particular time and may not reflect that levels of PFAS may differ across time. While (described
in Section 5) surface water samples were collected at nine discrete times that included months
in spring, summer, fall, and winter and also appeared to have included weather events such as
Hurricane Florence, these events may not have fully captured average/median levels of PFAS in
surface water.
There also may have been inconsistencies in what PFAS were measured across the different
surface water samples. In some samples, only HFPO-DA was measured whereas in others, all
nine Table 3+ PFAS were measured. Therefore, some PFAS (i.e., Table 3+ PFAS) could be
underestimated in surface water samples.
Dermal exposures from soil, well water, and surface water were not evaluated due to the lack
of dermal toxicity criteria developed at the state or federal level.
Another major area of significant uncertainty was associated with the hazard characterization.
One focus on this section was on discrepancies between the NC DHHS RfD and one derived by
authors of a manuscript published in 2019 (Thompson et al., 2019).
Components not considered/gaps in the assessment/additional studies: Pages 47-48 of this
section contain erroneous assumptions.
1. “Longer-duration animal studies are more relevant to most human exposure and
generally given preference when used to develop toxic potency estimates for humans.”
While this is a preference, it is not a rule or requirement. The database for HFPO-DA
contains several sub-chronic studies and only one chronic study. Therefore, the
database for sub-chronic studies is richer than for chronic studies, thus supporting the
derivation of a RfD from a sub-chronic study.
2. “…the liver lesions in mice are consistent with PPARa activation and, hence, the
observed effects are not relevant to humans.” The NC DHHS oral RfD was derived from
the observation of liver single cell necrosis (cell death) in mice. This particular endpoint,
necrosis, is not thought to be a PPARa-mediated key event for liver tumors in rodents
(Corton et al., 2018) and therefore is relevant to humans.
3.
Additionally, the oral RfD calculated by the NC DHHS is supported by the draft sub-chronic oral
RfD calculated by the U.S. EPA for HFPO-DA (2 x 10-4 mg/kg/day), which also was based on liver
single cell necrosis (EPA, 2018b). Therefore, including a discussion of a higher alternative oral
RfD derived by Thompson et al. (2019) without including a discussion of the U.S. EPA sub-
chronic oral RfD for HFPO-DA is misleading. This section should be removed, or a discussion of
the U.S. EPA sub-chronic oral RfD for HFPO-DA should be included.
Review of
“APPENDIX F: Offsite Human Health Screening Level Exposure Assessment (SLEA) of Table 3+ PFAS”
Jamie C. DeWitt February 18, 2020
7
References Cited
Baynes RE, Dix KJ, Riviere JE. 2012. Distribution and pharmacokinetics models. In: Pesticide
Biotransformation and Distribution (ed: E. Hodgson). Elsevier Inc. San Diego, CA, USA.
Corton JC, Peters JM, Klaunig JE. 2018. The PPARa-dependent rodent liver tumor response is
not relevant to humans: addressing misconceptions. Archives of Toxicology. 92:83-119.
NC DHHS. 2017. Questions and answers regarding North Carolina Department of Health and
Human Services Updated Risk Assessment for GenX (perfluoro-2-propoxypropanoic acid).
https://epi.dph.ncdhhs.gov/oee/pfas/NC%20DHHS%20Health%20Goal%20Q&A.pdf.
Shane HL, Baur R, Lukomska E, Weatherly L, Anderson SE. 2020. Immunotoxicity and allergenic
potential induced by topical application of perfluorooctanoic acid (PFOS) in a murine model.
Food and Chemical Toxicology. 137:111141.
Thompson CM, Fitch SE, Ring C, Rish W, Cullen JM, Haws LC. 2019. Development of an oral
reference dose for the perfluorinated compound GenX. Journal of Applied Toxicology. 39:1267-
1282.
US EPA. 1993. Reference dose (RfD): Description and use in health risk assessments.
Background Document 1A. https://www.epa.gov/iris/reference-dose-rfd-description-and-use-
health-risk-assessments.
U.S. EPA. 2018a. Method 537.1. Determination of selected per- and polyfluorinated alkyl
substances in drinking water by solid phase extraction and liquid chromatography/tandem
mass spectrometry. EPA Document #: EPA/600/R-18/352.
U.S. EPA. 2018b. Human health toxicity values for hexafluoropropylene oxide (HFPO) dimer acid
and its ammonium salt (CASRN 13252-13-6) and CASRN 62037-80-3). Also known as “GenX
Chemicals.” EPA Document #: 823-P-18-001.
From:RANDI DIKEMAN
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Friday, April 3, 2020 9:42:47 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility,
the Cape Fear River, and downstream communities ahead of its bottom line
—which its proposed plan fails to do.
Chemours—not families nearby and downstream communities already
burdened by exposure and health risks—should pay the costs to clean up
its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not
clean up the problem and will leave our communities, drinking water, and
the Cape Fear River at risk.
--
Randi Dikeman
102 Woodland Place
Littleton, N.C. 27850
252-702-8235 cell
From:Susan LosCalzo
To:SVC_DENR.publiccomments
Subject:[External] Chrmours plan
Date:Friday, April 3, 2020 7:44:18 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
This plan does not c!ean up the mess it made at the expense of our environment and the safety of the people nearby.
Make them do it right
Thank you,
Kathy Nance
990 Piney Knob Rd.,
Rutherfordton, NC 28139
From:Kim Porter
To:SVC_DENR.publiccomments
Subject:[External] Make Chemours Clean Up Its Pollution
Date:Thursday, April 2, 2020 9:08:55 PM
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attachment to report.spam@nc.gov
To Whom it May Concern:
My family has lived in Wilmington, NC for decades and been impacted by
Chemours history of unmitigated pollution and it must stop. Chemours' plan is
inadequate and fails to manage its decades of pollution, as required by the consent
order.
In its plan, Chemours plans to leave highly contaminated groundwater onsite and do
little to stop pollution from flowing offsite. Chemours has polluted 45,000 acres of
groundwater with toxic chemicals and poisoned the public and water supplies for
decades, yet now it proposes to avoid doing what’s needed to protect people and our
communities. It can not be allowed to get away with this.
We demand that Chemours clean up its pollution and put the health of North
Carolinians, the Cape Fear River, and downstream communities ahead of its bottom
line—which its proposed plan fails to do.
DEQ must ensure that Chemours—not families nearby and downstream communities
already burdened by exposure and health risks—pays the costs to clean up its
pollution.
Chemours has 45,000 acres of polluted, leaking groundwater, and its plan
is insufficient and will not clean up the problem and will leave our communities,
drinking water, and the Cape Fear River at risk.
Sincerely,
Kim Porter
828-712-4601
From:Susan Willets
To:SVC_DENR.publiccomments
Subject:[External] Clean Up Cape Fear
Date:Thursday, April 2, 2020 8:52:56 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Those responsible for polluting our ground water must be held accountable. Our citizen and wild life should be of
paramount importance to our legislators.
Sent from my iPhone
From:Doris Vannoy
To:SVC_DENR.publiccomments
Subject:[External] Chemours pollution
Date:Thursday, April 2, 2020 6:43:54 PM
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attachment to report.spam@nc.gov
Clean all of it up NOW, and require the company to pay for it. Also, immediately stop any
ongoing pollution by the company. They have poisoned people for years!!!!!!
Sent from my Verizon, Samsung Galaxy smartphoneGet Outlook for Android [aka.ms]
From:Yndiana Montes
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Thursday, April 2, 2020 1:13:23 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
"When you're poor and your family is at risk, is it possible to afford a Reverse Osmosis system,
costing between $200-300. The poor have to drink tap water and will do so for the rest of their
lives if the cases against Chemour are not won. The impact of drinking this contaminated water
will be cumulative over a period of time, resulting in a higher morbidity and mortality for those
exposed.
Some populations that have lived close to a hog farm, poultry facility or a polluted waterway have
migrated to more populated cities and towns like Raleigh, Charlotte, Winston Salem or
Wilmington. Most likely they have already been exposed to the cesspools from hog farms, coal
ashes Duke Energy and now GenX.
Considering this, we have to think what makes one population more vulnerable than others. In the
case of GenX, the environmental harm it produces might disproportionally affect certain
populations differently than others. For example, in Bladen, Cumberland, and New Hannover
Counties being impacted by GenX in the Cape Fear River. Now with this pandemic, the less
fortunate without reverse osmosis filtering are condemned to drinking this contaminated water and
it's long term consequences to the body.
Is it possible to petition the makers of R/O filtering systems to lower prices and participate in
helping out fellow man to at least have relatively clean drinking water.
Yndiana Montes
SoloCaribe INChttps://www.linkedin.com/in/yndianamontes/ [linkedin.com]
Cell: (910) 4706622Office (910) 8598040
From:Morris-McLawhorn, Bridgette R
To:SVC_DENR.publiccomments
Subject:Public comments received
Date:Thursday, April 2, 2020 10:35:05 AM
Attachments:2020 03 31 public comment on proposed GW corrective action plan 2.pdf
2020 03 31 public comment on proposed GW corrective action plan.pdf
Good morning,
Please find attached two more public comments received on the proposed GW corrective action
plan.
Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &Chief Deputy Secretary John Nicholson
North Carolina Department of Environmental Quality (919) 707-8643 office(984) 328-2303 mobile
bmorris@ncdenr.gov 217 West Jones Street1601 Mail Service Center
Raleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Jean Zhuang
To:SVC_DENR.publiccomments; Holman, Sheila
Cc:"Dana Sargent"; Kemp Burdette; Lane, Bill F; Benzoni, Francisco; Abraczinskas, Michael; Scott, Michael;
linda.culpepper@ncdenr.gov; Shelton, Dave; "Long, Brian D"; "JFSavarese@WLRK.com"; Gross, Joel M.
(Joel.Gross@arnoldporter.com); Geoff Gisler; Kelly Moser
Subject:[External] Cape Fear River Watch Comments on Chemours" Corrective Action Plan
Date:Thursday, April 2, 2020 10:34:46 AM
Attachments:2020-04-02- CFRW Comments on Chemours_ CAP w Attach. 1-3.PDF
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
Dear Ms. Holman:
The Southern Environmental Law Center offers the attached comments on Chemours’ CorrectiveAction Plan for the Fayetteville Works Facility. These comments are submitted on behalf of CapeFear River Watch.
Regards,Jean Zhuang
Staff Attorney | Southern Environmental Law Center [southernenvironment.org]601 West Rosemary Street, Suite 220 | Chapel Hill, NC 27516-2356T: 919-967-1450 | F: 919-929-9421 | Email: jzhuang@selcnc.org
This electronic message and any attached files are confidential and are intended solely for the use ofthe addressee(s) named above. This communication may contain material protected by attorney-client, work product or other privileges.
1
April 2, 2020
VIA E-MAIL
Sheila Holman
North Carolina Department of Environmental Quality
1601 Mail Service Center
Raleigh, N.C. 27699-1601
publiccomments@ncdenr.gov
Re: Cape Fear River Watch Comments on Chemours’ Corrective Action Plan
Dear Ms. Holman:
On behalf of Cape Fear River Watch, please accept these comments on Chemours’
Corrective Action Plan (“plan”) for the Fayetteville Works Facility. On December 31, 2019,
Chemours submitted an 1800-page document that is intended to provide for the “restoration of
groundwater quality” in accordance with state law. Although titled “Corrective Action Plan,”
Chemours’ document fails to provide any action or plan to correct the unprecedented
contamination the company has caused in violation of the 2019 Consent Order and state law.1
Rather than commit to clean up its historic contamination, Chemours seeks to do what it
and DuPont have done for decades—escape responsibility for the harm caused by its chemicals.
For years, DuPont and Chemours have known that the Washington Works Facility in West
Virginia contaminated the air, groundwater, river, and drinking water near the facility. And yet
neither DuPont nor Chemours did anything to prevent the same contamination at the Fayetteville
Works Facility. Now, having been caught contaminating more than 70 square miles, hundreds of
drinking water wells, and the river that provides water for more than 300,000 North Carolinians,
Chemours makes an astonishing argument—that it should be excused from the clear
requirements of the state’s groundwater rules because the harm it has caused is too vast.
Although the Cape Fear Public Utility Authority and Brunswick County have invested hundreds
of millions of dollars to clean up Chemours’ contamination, the company’s plan asserts that it
should be allowed to wait and further study its extensive contamination before taking action.
While communities, schools, and churches near and far depend on bottled water because
Chemours’ pollution continues to taint their taps, the company asks for more time to allow it to
escape responsibility.
DEQ must hold Chemours accountable. The company has now made it clear that it does
not intend to uphold its commitments under the Consent Order or the requirements for corrective
action under the state rules. DEQ must exercise its full authority under the Consent Order to
1 The Chemours Company FC, LLC, Corrective Action Plan – Chemours Fayetteville Works (Dec. 2019) (“CAP”).
2
seek penalties for Chemours’ violations of the order, reject Chemours’ proposed Corrective
Action Plan, and require the company to meet the groundwater rules’ requirement to eliminate its
contamination.
I. Chemours must be held responsible.
Chemours’ rejection of responsibility for its pollution begins with its cover letter. The
company states that any remaining problems should be DuPont’s problem.2 DEQ cannot allow
Chemours to shirk its obligations. The Consent Order and state law do not free Chemours from
its responsibility to clean up its pollution simply because DuPont formerly owned and operated
the facility. If Chemours wishes to seek compensation from DuPont, as it has begun to in the
Delaware Chancery Court, it is free to do so. Communities living near and downstream of
Chemours’ facility must not bear the burden of unresolved disputes between the two companies.3
II. State law and the Consent Order require Chemours to clean up its site.
Throughout Chemours’ Corrective Action Plan, the company uses uncertainty or a lack
of information to justify a failure to act. Because per- and polyfluoroalkyl substances (“PFAS”)
have not been studied enough, the company argues, it is not certain that there will be harms to
human health and the environment; therefore, more protective cleanup should not be required.
Chemours is wrong.
The Consent Order and state law are designed to ensure the maximum cleanup is
completed, even in the face of uncertainty. The Consent Order requires maximum reductions in
PFAS loading to surface waters to be implemented as soon as possible. In the long-term, the
Consent Order incorporates North Carolina’s stringent groundwater cleanup requirements, which
mandate the cleanup of pollutants to the lowest levels that are measurable by a laboratory, or as
close to those levels as are technologically and economically feasible. As a backstop, the
Consent Order requires that PFAS loading to the Cape Fear River, and each stream that flows
into it, be reduced by 75 percent at a minimum. State water quality standards, which are
incorporated into the state groundwater rules, prohibit discharges of PFAS unless the company
can demonstrate they are safe. In failing to apply these standards, Chemours ignores its
commitments under the Consent Order and those under state law, rendering their Corrective
Action Plan non-compliant.
A. State law requires that Chemours clean up its pollution to groundwater
standards, or as close as is economically and technologically feasible.
State law mandates the comprehensive cleanup of contaminated groundwater. First,
when groundwater contamination has been discovered, the entity responsible must act
immediately—even before investigating the scope of the contamination and before developing a
corrective action plan. It must “take action upon discovery to terminate and control the
2 Letter from Brian D. Long, Chemours, to Sheila Holman, N.C. Department of Environmental Quality (“DEQ”),
“Corrective Action Plan – Chemours Fayetteville Works,” Dec. 31, 2019, *1. 3 This is particularly true here, where the facility simply changed signs—continuing to employ the same persons
responsible for the practices leading to the unprecedented contamination.
3
discharge,” and “mitigate any hazards resulting from exposure to the pollutants.”4 The entity
responsible must abate, contain, and control the migration of the contaminants; remove, treat,
control primary pollution sources; and remove, treat, and control secondary pollution sources
that continue to pollute groundwater, including contaminated soils.5
Then, the entity responsible must assess the contamination,6 and develop a corrective
action plan that includes: “[s]pecific plans, including engineering details where applicable, for
restoring groundwater quality;” “a schedule for the implementation and operation of the
proposed plan;” and “a monitoring plan for evaluating the effectiveness of the proposed
corrective action and the movement of the contaminant plume.”7
The state groundwater rules require that “[w]here groundwater quality has been degraded,
the goal of any required corrective action shall be restoration to the level of the standards, or as
closely thereto as is economically and technologically feasible as determined by the Department
in accordance with this Rule.”8 Pollutants “which are not naturally occurring and for which no
standard is specified,” like PFAS, “shall not be permitted in concentrations at or above the
practical quantitation limit,”9 or the “lowest concentration of a given material that can be reliably
achieved among laboratories within specified limits of precision and accuracy by a given
analytical method during routine laboratory analysis.”10 The rules also require that corrective
action plans “be implemented using a remedial technology demonstrated to provide the most
effective means, taking into consideration geological and hydrogeological conditions at the
contaminated site, for restoration of groundwater quality to the level of standards.”11
State law thus requires that Chemours begin to contain and control its PFAS groundwater
pollution immediately after discovering it; remove, treat, and control all of the sources that
contribute to its groundwater pollution, including contaminated soil; and then clean up its
groundwater pollution to the lowest concentration level that is measurable by laboratories, or as
close to that level as possible—and that the company’s corrective action plan reflect these
actions and goals.
4 15A N.C. Admin. Code 2L .0106(b).
5 15A N.C. Admin. Code 2L .0106(f). 6 15A N.C. Admin. Code 2L .0106(c), (g). 7 15A N.C. Admin. Code 2L .0106(h). Due to the inadequacy of Chemours’ submission, Cape Fear River Watch
has not commented on the company’s proposed monitoring plan. Cape Fear River Watch reserves the right to
comment on a future monitoring plan submitted as part of a corrective action plan that complies with the Consent
Order and state groundwater rules. Just as Chemours’ Corrective Action Plan is wholly inadequate, so too is its
monitoring plan. 8 15A N.C. Admin. Code 2L .0106(a) (emphasis added). 9 15A N.C. Admin. Code 02L .0202(c). 10 15A N.C. Admin. Code 02L .0102(15).
11 15A N.C. Admin. Code 02L .0106(j) (emphasis added).
4
B. The Consent Order requires that Chemours achieve maximum reductions
from groundwater to rivers and streams within two years, and that
Chemours reduce PFAS loading to all rivers and streams by at least 75
percent.
The Consent Order requires that Chemours clean up and control its contaminated
groundwater in two stages. Paragraph 12 provides for more immediate implementation of
groundwater control measures at the site, whereas paragraph 16 requires the company to conduct
long-term cleanup, incorporating the stringent requirements of state law.
Under paragraph 12 of the Consent Order, Chemours must:
submit to DEQ and Cape Fear River Watch a plan demonstrating the maximum
reductions in PFAS loading from the Facility (including loading from
contaminated stormwater, non-process wastewater, and groundwater) to surface
waters, including Old Outfall 002, that are economically and technologically
feasible, and can be achieved within a two-year period (“PFAS reduction
targets”). The plan shall be supported by interim benchmarks to ensure
continuous progress in reduction of PFAS loading. If significantly greater
reductions can be achieved in a longer implementation period, Chemours may
propose, in addition, an implementation period of up to five years supported by
interim benchmarks to ensure continuous progress in reduction of PFAS
loading.12
Under this provision, Chemours was required to submit a plan by August 2019 that demonstrated
maximum reductions in PFAS loading from groundwater to surface waters that are feasible, and
that could be achieved within two years.
In addition to the short-term implementation of controls required under Consent Order
paragraph 12, paragraph 16 requires the company to submit a “complete Corrective Action Plan
that complies with the requirements of the 2L Rules.”13 These rules require that the company
clean up its PFAS groundwater pollution to almost undetectable levels (i.e., the “practical
quantitation limit”).
As a backstop to the rules, paragraph 16 of the Consent Order mandates that “[a]t
minimum, the Corrective Action Plan must require Chemours to reduce the PFAS loading to
surface water (Old Outfall 002, Willis Creek, Georgia Branch, and the Cape Fear River), for the
PFAS for which test methods and lab standards have been developed, by at least 75% from
baseline.”14 So that those reductions can be measured, the Consent Order requires that
Chemours install groundwater monitoring wells along each surface water near the facility (Old
Outfall 002, Willis Creek, Georgia Branch, and the Cape Fear River).15
12 Consent Order, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580, 14-15 (N.C. Super. 2019)
(“Consent Order”). 13 Consent Order at 21. 14 Id. at 22 (emphasis added).
15 Id. at 22.
5
Taken together, the goal of the Corrective Action Plan, as dictated by paragraph 16 of the
Consent Order, is Chemours’ cleanup of all PFAS to as close to the practical quantitation limits
as is economically and technologically feasible; and, at a minimum, reduction of PFAS loading
to Old Outfall 002, to Willis Creek, to Georgia Branch, and to the Cape Fear River by 75 percent
for all PFAS.
Despite these requirements, Chemours sent DEQ and Cape Fear River Watch a letter on
October 7, 2019, admitting that its August 2019 submission required by paragraph 12 of the
Consent Order did not address on-site groundwater, as required.16 Chemours’ letter stated that
“addressing on-site groundwater will be a major focus of the Corrective Action Plan due in
December” and proposed to “merge the paragraph 12 and 16 requirements.”17 The company
went on to promise that it would address groundwater loading to the Cape Fear River and other
surface waters in its Corrective Action Plan:
Under this approach, Chemours would be obligated to propose in the Corrective
Action Plan those feasible measures that would achieve maximum reductions in
loadings to surface waters from on-site groundwater in two and five year periods.
This would include consideration of measures that could impact not just loadings
from on-site groundwater to the Cape Fear River, but to other surface waters as
well.18
As discussed below, Chemours did not do any of this in its Corrective Action Plan.
III. Chemours applied the wrong standard and ignored its obligations under
state law and the Consent Order.
Chemours’ Corrective Action Plan could hardly do less to meet the clear state law and
Consent Order mandates set out above. Instead, the company brazenly attempts to rewrite the
law and the Consent Order in order to propose so-called “actions”—actions that cost the
company little, and that will leave 45,000 acres of toxic groundwater sitting beneath people’s
homes, and spilling into the Cape Fear River and streams for the foreseeable future.
A. The Corrective Action Plan will not meet groundwater standards and
Chemours does not qualify for an exemption.
Instead of developing a Corrective Action Plan that complies with state groundwater
laws, or the Consent Order, Chemours argues that DEQ should instead exempt Chemours from
the requirements of state groundwater standards. Chemours argues that it should be released
16 Letter from Joel M. Gross to Francisco Benzoni and Geoff Gisler, “Chemours’ PFAS Loading Reduction Plan,”
Oct. 7, 2019, included as Attachment 1. DEQ and Cape Fear River Watch have demanded compliance from the
company. Letter from Francisco Benzoni and Geoff Gisler to Joel Gross, “Chemours’ PFAS Loading Reduction
Plan,” Sept. 26, 2019, included as Attachment 2; Letter from Francisco Benzoni and Geoff Gisler to Joel Gross,
“PFAS Loading Reduction Plan,” Oct. 23, 2019, included as Attachment 3. 17 Letter from Joel M. Gross to Francisco Benzoni and Geoff Gisler, “Chemours’ PFAS Loading Reduction Plan,”
2-3, Oct. 7, 2019. Note that Cape Fear River Watch and DEQ did not agree to merge the Paragraph 12 and 16
requirements as Chemours proposed.
18 Id. at 3.
6
from state standards because of the historic extent of its contamination, and that it would be too
costly to clean it up in compliance with the law. Putting Chemours’ attempts to avoid
responsibility aside, the company does not qualify for any exemption, its Corrective Action Plan
does not meet the required standards, and DEQ must reject the company’s plan.
1. Chemours does not qualify for an exemption from state
groundwater standards.
Chemours asks DEQ to exempt the company from the state’s groundwater rules under
15A N.C. Admin. Code 2L .0106(k). For that narrow exemption to apply, however, DEQ must
find, based on Chemours’ demonstration, that all of the following elements are true:
Chemours must have already removed or controlled “all sources of contamination
and free product”19—including “buried waste, waste stockpiles, or surficial
accumulations of free products;” 20 as well as all “secondary pollution sources that
would be potential continuing sources of pollutants to the groundwaters, such as
contaminated soils and non-aqueous phase liquids.”21
“[T]he time and direction of contaminant travel can be predicted with reasonable
certainty.”22
“[C]ontaminants have not and will not migrate onto adjacent properties, or that: (A)
such properties are served by an existing public water supply system dependent on
surface waters or hydraulically isolated groundwater; or (B) the owners of such
properties have consented in writing to the request.”23
Groundwater standards “will be met at a location no closer than one year time of
travel upgradient of an existing or foreseeable receptor, based on travel time and the
natural attenuation capacity of subsurface materials or on a physical barrier to
groundwater migration that exists or will be installed by the person making the
request.”24
Because “the contaminant plume is expected to intercept surface waters,” the
groundwater discharge cannot “possess contaminant concentrations that would result
in violations of standards for surface waters contained in 15A NCAC 02B .0200.”25
Public notice of the request has been provided.26
19 15A N.C. Admin. Code 2L .0106(k) (emphasis added).
20 15A N.C. Admin. Code 2L .0106(f)(3). 21 15A N.C. Admin. Code 2L .0106(f)(4).
22 15A N.C. Admin. Code 2L .0106(k)(2). 23 15A N.C. Admin. Code 2L .0106(k)(3). 24 15A N.C. Admin. Code 2L .0106(k)(4). 25 15A N.C. Admin. Code 2L .0106(k)(5).
26 15A N.C. Admin. Code 2L .0106(k)(6).
7
The proposed corrective action plan would be consistent with all other environmental
laws.27
Chemours has not shown, and cannot show, that all of these circumstances exist.
Chemours has not come close to removing or controlling all sources of groundwater
contamination.28 Chemours’ facility has released PFAS into the air, water, and soil for over four
decades. As a result, there are numerous sources of contamination that continue to leach PFAS
into the groundwater below. For instance, there are PFAS in soils caused by the deposition of
Chemours’ air emissions—contamination that remains in soil on-site and off-site.29
Areas at the site have also been polluted by the company’s highly toxic process
wastewater and other media.30 For decades, PFAS-contaminated wastewater and stormwater
traveled throughout the facility.31 PFAS clung to soils and sludge, leaked continuously into
groundwater, and flushed throughout the site when it rained.32 The company did nothing to
contain that contamination.
Polluted solid waste and sludge from the facility’s wastewater treatment plant and from
sedimentation basins were dumped in unlined pits and lagoons around the site.33 Because
Chemours has not fully excavated that waste, PFAS will continue to leach into groundwater.34
In fact, Chemours outright refuses to conduct such remediation in its plan, stating that although
“2L requires removal or control of secondary sources to groundwater such as contaminated
soils,” it would not remove those sources because “soil remediation would have reduced
benefit.”35
Sampling at the facility required under paragraph 11 of the Consent Order confirms
continuing sources of contamination to groundwater. One sampling location had PFAS
27 15A N.C. Admin. Code 2L .0106(k)(7).
28 15A N.C. Admin. Code 2L .0106(k)(1). 29 CAP at 19 (describing the “[i]nfiltrating rainfall [that] has transported these PFAS downward to groundwater.”).
30 CAP at 23-24. This has also been documented by all of Chemours’ submissions since its pollution was uncovered
in 2017. 31 See Attachment 3 of The Chemours Company FC, LLC, Cape Fear River PFAS Loading Reduction Plan, 24, 26
(Aug. 2019).
32 Id. 33 Phase III Resource Conservation and Recovery Act Facility Investigation Report for DuPont Fayetteville Works,
Appendix D, SWMU 9, 16 (2014). Given that the historical waste was produced long before Chemours began
capturing its PFAS process wastewater, it is likely that the waste contains high concentrations of PFAS and is a
continuing source of contamination to groundwater. 34 Note that there is also a rainwater retention basin north of the PPA Manufacturing area that is a known source of
PFAS into groundwater that Chemours has not yet investigated. Phase III Resource Conservation and Recovery Act
Facility Investigation Report for DuPont Fayetteville Works, Appendix D, SWMU 7 (2014) (“Evidence of a release
was identified in the vicinity of the former rain water retention basin north of the PFOA manufacturing facility and a
second, similar release occurred on June 23, 2011 from the PPA stack in this same area. PFOA has been identified in
shallow groundwater as a result of air deposition in the immediate vicinity of the PFOA manufacturing area being
carried via runoff and infiltrating into the subsurface.” PFOA is a type of PFAS.).
35 CAP at 55 (emphasis added).
8
concentrations of 48,000 parts per trillion (“ppt”),36 potentially caused by a leaking terracotta
pipe which Chemours says will not be remedied for another year.37 Stormwater in its Nafion
Manufacturing area has been measured at concentrations up to 66,000 ppt;38 yet Chemours does
not currently have a plan in place to control its stormwater. The wastewater treatment plant
discharge has been measured at 36,000 ppt.39 Many channels around the facility that receive
wastewater treatment plant discharge and flow from the contaminated Nafion Manufacturing
area are unlined or leaking, allowing PFAS to seep into the groundwater below.40 The
company’s own analysis demonstrates that Chemours has not removed or controlled all sources
of contamination to groundwater, and does not meet the first and crucial requirement of 15A
N.C. Admin. Code 2L .0106(k).
Chemours cannot predict the time and direction of contaminant travel with reasonable
certainty.41 Chemours relies on “retardation factors” to predict contaminant travel, yet has only
produced such information for five PFAS.42 The company’s own fate and transport study only
addresses 24 PFAS.43 The company’s analysis thus only covers a fraction of the pollutants in
Chemours’ groundwater. The company has identified an additional 22 PFAS from non-targeted
sampling that are not addressed in its fate and transport study,44 and Chemours has admitted that
there are over 150 PFAS that could be present at the facility.45 Even for those covered by the
company’s study, Chemours acknowledges that it cannot predict their fate with any certainty.46
Chemours cannot demonstrate that its “contaminants have not and will not migrate
onto adjacent properties.”47 Chemours’ PFAS have migrated onto nearby properties. They
have been found in over 1,900 wells that provide drinking water to surrounding residents,48 and
Chemours cannot ensure that its PFAS-contaminated groundwater will not continue to migrate
further onto other properties.49 The company also cannot demonstrate that “such properties are
36 The Chemours Company FC, LLC, PFAS Characterization Quarterly Report, Figure 3B (Jan. 2020) (“Chemours
Jan. 2020 Characterization Report”).
37 CAP at 18-19. 38 Chemours Jan. 2020 Characterization Report at Figure 3B. 39 Id. 40 See Attachment 3 of The Chemours Company FC, LLC, Cape Fear River PFAS Loading Reduction Plan,
(Aug. 2019). 41 15A N.C. Admin. Code 2L .0106(k)(2).
42 CAP at 27, 58-59. 43 The Chemours Company FC, LLC., Site Associated PFAS Fate and Transport Study Chemours Fayetteville
Works, 3 (June 2019) (“Fate and Transport Study”). 44 Fate and Transport Study at 3.
45 The Chemours Company FC, LLC., Chemours Fayetteville Works NPDES Permit Application Update,
Attachment F-4, “List of PFAS Compounds” (July 2019). (“This list represents the known PFAS compounds that
could be present at Chemours – Fayetteville Works and therefore potentially detected in the effluent from the
facility.”). 46 Fate and Transport Study at 15 (“Site [a]ssociated PFAS have limited publicly available, peer-reviewed literature
describing their fate and transport.”).
47 15A N.C. Admin. Code 2L .0106(k)(3). 48 The Chemours Company FC, LLC., Consent Order Progress Report for Fourth Quarter 2019, *1.
49 DEQ guidance requires that a map “be provided that shows the current plume boundary as well as adjacent
properties and those down gradient properties where the plume is expected to migrate. Any supply wells on those
properties must be located on the map. An indication of which properties are predicted to be impacted and the
technical basis for this determination must also be provided. In addition, a map must be provided that shows the
predicted maximum extent of the contamination plume.” DEQ – Division of Water Resources, Guidelines for the
9
served by an existing public water supply system dependent on surface waters or hydraulically
isolated groundwater;” or that “the owners of such properties have consented in writing to the
request.”50 Hundreds of affected properties are not served by existing public water supplies,51
and the property owners have not consented in writing to Chemours’ pollution being on their
property.
Chemours cannot show that groundwater standards will be met upgradient of existing
or foreseeable receptors. 15A N.C. Admin. Code 2L .0106(k)(4) requires that groundwater
standards will “be met at a location no closer than one year time of travel upgradient of an
existing or foreseeable receptor, based on travel time and the natural attenuation capacity of
subsurface materials or on a physical barrier to groundwater migration that exists or will be
installed by the person making the request.”52 Groundwater upgradient of anyone who might be
exposed to the company’s contamination, and other potential receptors,53 will not meet practical
quantitation limits for PFAS—Chemours admits as much.54 Chemours has also not shown that
there is any physical barrier to groundwater migration, nor has the company proposed to install a
physical barrier to prevent that migration.
Chemours cannot demonstrate that its PFAS groundwater discharge will not cause
violations of standards in surface waters.55 Applicable surface water standards include the
North Carolina Toxics Substances Standard, which requires that: “[T]he concentration of toxic
substances […] in surface waters shall not render waters injurious to […] public health, or impair
the waters for any designated uses,”56 as well as the Class C water quality standard: 15A N.C.
Admin. Code 02B .0211(12), which requires that wastes “shall not render waters injurious to
public health, secondary recreation, or to aquatic life and wildlife, […] or impair the waters for
any designated uses.” To meet these standards, Chemours must demonstrate that it is not
harmful to public health to continue to expose the public to the PFAS that it has subjected
hundreds of thousands of people for decades. The company has not even considered such a
study. Lack of information cannot be a basis to excuse Chemours from taking responsibility for
its actions; it must instead be a bar to demonstrating compliance with applicable water quality
standards. Therefore, Chemours cannot demonstrate compliance with the either the North
Investigation and Remediation of Soil and Groundwater Contamination, 27 (2017). Chemours has not satisfied these
requirements. 50 15A N.C. Admin. Code 2L .0106(k)(3). 51 Chemours has not finished installing filters, or providing alternative drinking supplies for everyone with a
contaminated well. It has not even finished sampling wells. So the company cannot claim that properties are
effectively served by an uncontaminated drinking water supply. DEQ guidance states that “[s]uitable water supplies
must meet the regulatory definition of a public water supply and be approved by the DWR Public Water Supply
Section,” and that documentation must be provided. Id. 52 15A N.C. Admin. Code 2L .0106(k)(4). 53 DEQ guidance interprets “receptors” broadly to include “utility lines, public and domestic water supply wells,
surface waters, and regions of groundwater that have been identified for planned resource development by state or
local governments.” Id. at 27-28. In addition, DEQ guidance requires that “[a]ll existing and foreseeable receptors”
“be identified on the base map.” Id. at 27. 54 Chemours unilaterally concludes, without providing evidence, that meeting practical quantitation limits would not
be feasible, and argues for “alternate cleanup standards.” See CAP at 51-60. 55 15A N.C. Admin. Code 2L .0106(k)(5).
56 15A N.C. Admin. Code 02B .0208.
10
Carolina Toxic Substances Standard or the Class C water quality standard, 15A N.C. Admin.
Code 02B .0211(12).
Because Chemours fails to satisfy the requirements for 15A N.C. Admin. Code 2L
.0106(k)’s exemption to the groundwater rules, the company must clean up its groundwater to
practical quantitation limits, or as close as is technologically and economically feasible.
2. The Corrective Action Plan does not attempt to, and will not, meet
groundwater standards.
Chemours admits that the Corrective Action Plan will not clean up groundwater to
practical quantitation limits—the applicable standard for PFAS. The company also does not
propose remediation that comes as close to practical quantitation limits is technologically and
economically feasible, as state law requires.
Instead, Chemours unilaterally decides that achieving practical quantitation limits is
infeasible without providing any evidence.57 That omission alone is sufficient reason to reject
the plan. Feasibility under state law is determined by DEQ, not by Chemours.58 Therefore,
Chemours must provide DEQ with sufficient supporting documentation so that the agency can
make the determination as to what actions are economically and technologically feasible. It has
not.
Even if Chemours were able to prove to DEQ’s satisfaction that achieving practical
quantitation limits is not economically feasible or technologically feasible, state law requires that
Chemours come as close as possible to that standard—and that its Corrective Action Plan reflects
that goal.59 The plan, however, does not even consider methods to meet this mandatory standard.
The only action Chemours proposes to take to clean up its on-site groundwater is to pump water
from a handful of existing wells at a rate of 14 gallons per minute, after admitting that pumping
at such a low rate would not meaningfully reduce the contamination.60
Despite admitting that the “most effective means” to stop groundwater from flowing into
surface water is to install a barrier wall,61 the company argues that the technology is not available
57 Chemours makes broad sweeping statements about how it could not possibly meet groundwater standards without
providing any evidence or supporting documentation for those statements. For instance, the company states that any
remedy which “could help make progress towards PQLs over this area would cost in the billions to tens of billions
of dollars.” CAP at 56. It claims that a pump and treat system “with the goal of restoring groundwater to PQLs
would cost an economically infeasible amount of over a billion dollars and would almost certainly not achieve PQLs
and not achieve any additional benefit in loading reductions to the Cape Fear River greater than those already
proposed in this CAP.” CAP at 57. It adds that “[E]x situ treatment will become asymptotic and not achieve
cleanup goals.” CAP at 57. None of these broad, conclusory statements are supported by evidence. 58 State law requires that Chemours restore all contaminated groundwater to the level of standards, “or as closely
thereto as is economically and technologically feasible as determined by the Department.” 15A N.C. Admin. Code
2L .0106(a) (emphasis added).
59 15A N.C. Admin. Code 2L .0106(a). 60 The Chemours Company FC, LLC, Memorandum, “Response to Cape Fear River Watch Comments Dated
December 19, 2019,” Jan. 31, 2020, at 11. (Chemours states that pumping at 70 gallons per minute would not
“meaningfully reduce loadings to the Cape Fear River.”).
61 CAP at xvii.
11
to remedy the problem. The company’s long-term goal—to wait-and-see what “remedial
approaches” become available—is unacceptable.62 First, the law is clear: it requires that the
company come as close to practical quantitation limits as is feasible. Second, state groundwater
rules contemplate the development of new technology, but they do not allow a polluter to delay
cleanup. The rules state that if DEQ determines that a new technology is available at some point
in the future “that would remediate the contaminated groundwater to the standards…,” DEQ
“may require the responsible party to evaluate the economic and technological feasibility of
implementing the new technology in an active groundwater corrective action plan.”63 Chemours
must act now. If new technology is developed, DEQ may determine whether or not that
technology would be effective and require Chemours to evaluate it. Finally, effective technology
exists. The company admits that there is an effective way to prevent groundwater from leaving
the site, but is simply reluctant to pay for it.64
Similarly, the company argues that DEQ should wait-and-see what groundwater cleanup
standards are developed in the future, rather than developing a plan that attempts to achieve
practical quantitation limits.65 State groundwater rules specifically provide for situations in
which the groundwater cleanup standards have not been provided, and prioritize maximum
cleanup in the face of uncertainty.66 To wait for groundwater standards to be developed before
implementing a Corrective Action Plan that comes as close as possible to achieving practical
quantitation limits would be rewriting the law and excuse historic levels of groundwater
contamination.
3. DEQ must reject Chemours’ false and self-motivated claims that
its pollution will not harm communities and the environment.
Chemours argues that its toxic PFAS contamination is not harming people or the
environment, and therefore “hypothetical remedies” that would clean up its pollution “are not
considered necessary.”67 At the outset, this is not the applicable standard, as discussed above.
Moreover, the company’s exposure assessments are fundamentally flawed. In arguing that its
groundwater does not need to be cleaned up, Chemours relies only on existing human health data
for GenX—one out of dozens of PFAS released by the facility.68 Chemours’ ecological
62 CAP at 54; see also CAP at 51. 63 15A N.C. Admin. Code 2L .0106(o). 64 CAP at xvii. (“It is not presently possible to conclude with confidence whether this alternative is economically
feasible”).
65 CAP at 51. 66 15A N.C. Admin. Code 02L .0202(c); 15A N.C. Admin. Code 02L .0102(15).
67 CAP at 56. Chemours impermissibly uses this as a cleanup goal. It states that its cleanup goal for off-site
groundwater is to “maintain human exposures to HFPO-DA below the North Carolina Department of Health and
Human Services (NCDHHS) reference dose (achieved per HH-SLEA results and replacement drinking water
actions).” CAP at 54.
68 CAP, Appendix F – Offsite Human Health Screening Level Exposure Assessment (SLEA) of Table 3+ PFAS, at
35 (“The hazard characterization is limited to an assessment of HFPO-DA based on the current availability of
toxicity criteria.”). Because Chemours’ assessment is limited to GenX, or HFPO-DA, its conclusions regarding harm
to human health must be limited to GenX. See id. at 50 (“[B]ased on the provisional hazard characterization, HFPO-
DA does not pose a human health hazard…Under current conditions, no human health hazards from HFPO-DA were
identified for consumptive use of untreated surface water from the Bladen and Kings Bluffs public supply intake
points…In summary, the SLEA demonstrates that current concentrations of HDPO-DA in the environment in the
12
assessment is similarly unsupported by data.69 In addition to Table 3+ PFAS and GenX,
Chemours has identified an additional 22 PFAS from non-targeted sampling that are not
addressed in the assessment,70 and Chemours has admitted that there over 150 PFAS that could
be present at the facility.71
Furthermore, recent retesting of 2014 and 2015 samples downstream of Chemours
facility revealed that people have been drinking water with PFAS concentrations that are far
higher than previously suspected, including high levels of PFAS other than GenX, such as
PFMOAA, PFO2HxA and PFO3OA. A 2014 sample below Chemours’ outfall had PFAS
concentrations of about 990,000 ppt.72 Another sample near the drinking water intake for people
in Wilmington and Brunswick County had PFAS concentrations of 130,000 ppt.73 Detlef
Knappe, the N.C. State University scientist conducting the sampling, stated that these high
concentrations are the “current best estimate of what people in the Wilmington area were
drinking for […] 37 years.”74 Focused only on GenX, Chemours’ assessment, therefore, barely
begins to cover the breadth of its PFAS pollution, and the devastating impact it has had, and will
continue to have, on people nearby and downstream.75
Despite knowing that it has exposed hundreds of thousands of people to dozens of other
PFAS at high levels, Chemours justifies its failure to fully evaluate other PFAS—and to clean up
its groundwater—on a lack of information. The company states that “the lack of toxicity
information for other Table 3+ PFAS also introduces uncertainty to the [Human Health
Screening Level Exposure Assessment] but data are not available to evaluate the potential effect,
if any, on the conclusions hazard characterization.”76
For years, Chemours profited due to the public and the agency’s lack of knowledge about these
chemicals. By relying on a human health assessment that is supported by insufficient data in
order to claim that no one will be harmed, Chemours again attempts to profit over the lack of
information about PFAS. Chemours again attempts to put the burden of uncertainty on
communities that have already suffered for decades from the company’s actions.
Fortunately, the law places the risk of uncertainty on Chemours. There is a reason that
unnatural, poorly studied chemicals are not permitted in groundwater. State law could not be
clearer on how to deal with uncertainty regarding a chemical’s toxicity: if there is no standard,
vicinity of the Facility are unlikely to pose a hazard to human health, even in the absence of groundwater
treatment.”).
69 CAP at 42. (“[T]his analysis was unable to assess hazards to exposed receptors for Table 3+ PFAS other than
HFPO-DA”).
70 Fate and Transport Study at 3. 71 The Chemours Company FC, LLC, Chemours Fayetteville Works NPDES Permit Application Update,
Attachment F-4, “List of PFAS Compounds” (July 2019). 72 Adam Wagner, NC State-led study shows Cape Fear River had ‘incredibly high’ levels of chemicals, THE
NEWS&OBSERVER, Oct. 10, 2019, available at https://www.newsobserver.com/article235963052.html (last visited
Feb. 25, 2020).
73 Id. 74 Id. 75 For the same reason, the “Potential Future Risk-Based Remediation” proposed by Chemours in the company’s
plan is also inappropriate in this situation. See CAP at 60.
76 CAP at 40.
13
the chemical must be removed. DEQ’s decision here is not difficult. Chemours has decided to
submit a corrective action plan that does not attempt to comply with the law. The company’s
plan must be rejected.
B. Chemours’ plan does not comply with the Consent Order and DEQ should
impose penalties.
As discussed in Section II(B) of these comments, Chemours has violated the groundwater
remediation requirements under paragraph 12 of the Consent Order since August 26, 2019.
Chemours’ Corrective Action Plan also violates paragraph 16 of the Consent Order. Paragraph
16 of the Consent Order requires, at a minimum, a 75 percent reduction in PFAS loading to each
surface water near the plant: Old Outfall 002, Willis Creek, Georgia Branch Creek, and the Cape
Fear River.77 So that those reductions can be measured, the Consent Order requires that
Chemours install groundwater monitoring wells along each surface water near the facility (Old
Outfall 002, Willis Creek, Georgia Branch, and the Cape Fear River).78
In addition to the base failures of the company’s plan, Chemours attempts to unilaterally
rewrite the Consent Order by limiting its cleanup goal is to reduce PFAS loading only to the
Cape Fear River by 75 percent—thereby ignoring groundwater flow to all other surface waters.79
This is a blatant violation of the Consent Order. DEQ must reject the Corrective Action Plan,
require full compliance with the Order, and impose penalties on the company.
IV. State law demands action.
DEQ must discard Chemours’ plan and require maximum cleanup of the company’s
groundwater. In evaluating the company’s Corrective Action Plan, state law requires that DEQ
consider “the extent of any violations, the extent of any threat to human health or safety, the
extent of damage or potential adverse impact to the environment, technology available to
accomplish restoration, the potential for degradation of the contaminants in the environment, the
time and costs estimated to achieve groundwater quality restoration, and the public and economic
benefits to be derived from groundwater quality restoration.”80 Each of these factors warrants
DEQ’s rejection of Chemours’ current plan, and mandates that Chemours do more.
Chemours’ violations are extensive. As stated in DEQ’s complaint against Chemours,
filed in the Bladen County Superior Court, Chemours has committed extensive violations.81 The
company knew that it was dumping PFAS into surface waters, including drinking water supplies;
it repeatedly misled DEQ about its manufacturing processes, discharges, and the harmfulness of
GenX; it violated state groundwater rules; and it violated its National Pollutant Discharge
Elimination System permit and state water quality laws, and discharged without a permit.82
77 Consent Order at 22
78 Id. at 21-22. 79 CAP at 51. (“The Cape Fear River receives discharge from Old Outfall 002, Willis Creek and Georgia Branch
Creek, onsite seeps and onsite groundwater. Therefore, reducing Cape Fear River PFAS mass loading by at least
75% was established as the cleanup goal.”). 80 15A N.C. Admin. Code 2L .0106(i). 81 Amended Complaint, N.C. Dept. of Environmental Quality v. Chemours, 17 CVS 580 (N.C. Super. 2018).
82 Id.
14
Chemours’ pollution has caused extensive damage, and continues to threaten human
health and public safety. Chemours’ violations are especially concerning because DEQ, the
Environmental Protection Agency, other agencies, and other states acknowledge the serious
threats to human health and safety posed by PFAS contamination. Two of the most commonly
studied PFAS—perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonate (“PFOS”)—
have been found to cause developmental effects to fetuses and infants, kidney and testicular
cancer, liver malfunction, hypothyroidism, high cholesterol, ulcerative colitis, lower birth weight
and size, obesity, decreased immune response to vaccines, reduced hormone levels, and delayed
puberty.83 EPA established a lifetime health advisory of 70 ppt for the combined concentrations
of PFOA and PFOS in drinking water.84
Since then, in June 2018, the Agency for Toxic Substances and Disease Registry released
an updated Draft Toxicological Profile for PFOA, PFOS, and other PFAS—suggesting that many
of the chemicals are much more harmful than previously thought. For instance, the minimum
risk levels, or the amount of a chemical a person can eat, drink, or breathe each day without a
detectable risk to health, was determined to be only 11 ppt for PFOA, and 7 ppt for PFOS.85
Epidemiological studies show that many of these same health outcomes result from exposure to
other PFAS.86 Given these harms, states like Michigan, New York, New Hampshire, New
Jersey, and Vermont have acknowledged the dangers of these compounds and have either
proposed or finalized drinking water standards for various PFAS at 20 ppt and lower.87
Communities downstream of Chemours’ facility are still receiving drinking water with
PFAS concentrations much higher than these health-based values. As recently as October 2019,
total PFAS concentrations at the Cape Fear Public Utility Authority’s raw and finished water
reached nearly 400 ppt.88 Sampling results in December 2019 were still around 100 ppt.89
83 Arlene Blum et al., The Madrid Statement on Poly- and Perfluoroalkyl Substances (PFASs), 123 ENVTL. HEALTH
PERSPECTIVES 5, A 107 (2015); U.S. EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories, 2. 84 EPA, Fact Sheet: PFOA & PFOS Drinking Water Health Advisories at 2. 85 Cape Fear Public Utility Authority (CFPUA), CFPUA Statement on Recently Released DHHS Report (June 21,
2018); see also ATSDR, Toxicological Profile for Perfluoroalkyls, Draft for Public Comment (June 2018) (“Draft
2018 Toxicological Profile for Perfluoroalkyls”).
86 Draft 2018 Toxicological Profile for Perfluoroalkyls at 5-6, 25-26. 87 Press Release, Mich. Dep’t of Env’t, Great Lakes, and Energy, Michigan moves forward on PFAS in drinking
water rules (June 27, 2019), available at https://www.michigan.gov/egle/0,9429,7-135-3308_3323-500772--
,00.html (last visited Feb. 24, 2020); New York to set limits for industrial chemicals in water, AP, July 8, 2019,
available at https://apnews.com/63bffd42efaf49d08d114ea4443491f0 (last visited Feb. 24, 2020); Annie Ropeik,
N.H. Approves Unprecedented Limits for PFAS Chemicals in Drinking Water, NHPR, July 18, 2019, available at
https://apnews.com/63bffd42efaf49d08d114ea4443491f0 (last visited Feb. 24, 2020); Press Release, Vt. Agency of
Nat. Res., Agency Of Natural Resources Initiates Rulemaking Process To Adopt Maximum Contaminant Level For
PFAS Compounds, available at https://anr.vermont.gov/content/agency-natural-resources-initiates-rulemaking-
process-adopt-maximum-contaminant-level-pfas (last visited Feb. 24, 2020); James M. O’Neill, NJ proposes strict
new drinking water standards for cancer-linked chemicals, NORTH JERSEY RECORD, Apr. 1, 2019, available at
https://www.northjersey.com/story/news/environment/2019/04/01/nj-sets-stringent-drinking-water-standard-cancer-
linked-chemicals-pfoa-pfos-pfas/3334281002/ (last visited Feb. 24, 2020); Interstate Tech. Regulatory Council,
PFAS Fact Sheets, Section 4 Tables (Aug. 2019). 88 Cape Fear Public Utility Authority, Emerging Contaminants, available at https://www.cfpua.org/761/Emerging-
Compounds (last visited Feb. 24, 2020).
89 Id.
15
If Chemours does not clean up its groundwater and prevent it from continuously leaking into
rivers and streams, these communities will continue to suffer.
Chemours’ pollution also threatens the environment. PFAS have been shown to cause
damaging effects in fish,90 amphibians,91 mollusks,92 and other aquatic invertebrates93—resulting
in developmental and reproductive impacts, behavioral changes, adverse effects to livers,
disruption to endocrine systems, and weakened immune systems.94 Moreover, PFAS are
extremely resistant to breaking down in the environment, can travel long distances, and bio-
accumulate in organisms.95
Technology is available to remove PFAS pollution. Future threats and harms caused by
Chemours pollution can be eliminated because, as the company stated in its Corrective Action
Plan, the technology exists to prevent the company’s pollution from entering surface waters and
harming downstream communities and aquatic ecosystems.96 And the technology might even
exist to control off-site groundwater.97
90 Huang, et al., Toxicity, uptake kinetics and behavior assessment in zebrafish embryos following exposure to
perfluorooctanesulphonicacid (PFOS), 98 AQUATIC TOXICOLOGY 139–147 (2010); Jantzen, et al., PFOS, PFNA,
and PFOA sub-lethal exposure to embryonic zebrafish have different toxicity profiles in terms of morphometrics,
behavior and gene expression, 175 AQUATIC TOXICOLOGY 160–170 (2016); Hagenaars, et al., Structure–activity
relationship assessment of four perfluorinated chemicals using a prolonged zebrafish early life stage test, 82
CHEMOSPHERE 764–772 (2011); Du, et al., Chronic effects of water-borne PFOS exposure on growth, survival and
hepatotoxicity in zebrafish: A partial life-cycle test, 74 CHEMOSPHERE 723–729 (2009); Rotondo, et al.,
Environmental doses of perfluorooctanoic acid change the expression of genes in target tissues of common carp, 37
ENVIRON. TOXICOLOGY & CHEM. 942–948 (2018); Liu, et al., The thyroid-disrupting effects of long-term
perfluorononanoate exposure on zebrafish (Danio rerio), 20 ECOTOXICOLOGY 47–55 (2011); Chen, et al.,
Multigenerational Disruption of the Thyroid Endocrine System in Marine Medaka after a Life-Cycle Exposure to
Perfluorobutanesulfonate, 52 ENVIRON. SCI. & TECH. 4432–4439 (2018); Chen, et al., Perfluorobutanesulfonate
Exposure Causes Durable and Transgenerational Dysbiosis of Gut Microbiota in Marine Medaka, 5 ENVIRON. SCI.
& TECH. LETTERS 731–738 (2018); Chen, et al., Accumulation of perfluorobutane sulfonate (PFBS) and impairment
of visual function in the eyes of marine medaka after a life-cycle exposure, 201 AQUATIC TOXICOLOGY 1–10 (2018). 91 Ankley, et al., Partial Life-Cycle Toxicity And Bioconcentration Modeling of Perfluorooctanesulfonate in the
Northern Leopard Frog (Rana Pipiens), 23 ENVIRON. TOXICOLOGY & CHEM. 2745 (2004); Cheng, et al., Thyroid
disruption effects of environmental level perfluorooctane sulfonates (PFOS) in Xenopus laevis, 20 ECOTOXICOLOGY
2069–2078 (2011); Lou, et al., Effects of perfluorooctanesulfonate and perfluorobutanesulfonate on the growth and
sexual development of Xenopus laevis, 22 ECOTOXICOLOGY 1133–1144 (2013).
92 Liu, et al., Oxidative toxicity of perfluorinated chemicals in green mussel and bioaccumulation factor dependent
quantitative structure-activity relationship, 33 ENVIRON. TOXICOLOGY & CHEM. 2323–2332 (2014); Liu, et al.,
Immunotoxicity in green mussels under perfluoroalkyl substance (PFAS) exposure: Reversible response and
response model development, 37 ENVIRON. TOXICOLOGY & CHEM. 1138–1145 (2018).
93 Ji, et al., Oxicity of Perfluorooctane Sulfonic Acid and Perfluorooctanoic Acid on Freshwater Macroinvertebrates
(Daphnia Magna and Moina Macrocopa) and Fish (Oryzias Latipes), 27 ENVIRON. TOXICOLOGY & CHEM. 2159
(2008); Houde, et al, Endocrine-disruption potential of perfluoroethylcyclohexane sulfonate (PFECHS) in
chronically exposed Daphnia magna, 218 ENVIRON. POLLUTION 950–956 (2016); Liang, et al., Effects of
Perfluorooctane sulfonate on immobilization, heartbeat, reproductive and biochemical performance of Daphnia
magna, 168 Chemosphere 1613–1618 (2017); MacDonald, et al., Toxicity Of Perfluorooctane Sulfonic Acid and
Perfluorooctanoic Acid to Chironomus Tentans, 23 ENVIRON. TOXICOLOGY & CHEM. 2116 (2004). 94 See supra notes 92-95.
95 Draft 2018 Toxicological Profile for Perfluoroalkyls at 2, 534; see also EPA, Technical Fact Sheet -
Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA), 1, 3 (Nov. 2017). 96 CAP at xvii. 97 The Chemours Company FC, LLC, Cape Fear River PFAS Loading Reduction Plan – Supplemental Information
Report, 53-55 (Nov. 2019).
16
PFAS do not degrade. Chemours’ failure to apply available technology in its plan is
critical because, as the company admits, PFAS do not degrade.98
Chemours’ complaints about cost pale in comparison to the harm caused by the
company’s pollution. Chemours’ intentional dumping of toxic PFAS into the air, water, and soil
has devastated southeastern North Carolina. Municipalities are spending hundreds of millions of
dollars on clean drinking water.99 Multiple generations of families have gotten sick.100 People
who have been unknowingly drinking tainted water for decades are terrified and enraged every
day. Residents who have newly moved into the area are shattered when they discover the
contaminated water beneath their homes.101 It is crucial that Chemours be held responsible for
the harm that it has caused to these people and to the environment, and that DEQ requires
Chemours to eliminate the harms it has caused.
Even if the cleanup costs billions of dollars—as Chemours claims without support—
Chemours has, for decades, profited from its PFAS chemicals and from its unchecked pollution.
Chemours is a multi-billion-dollar company. Just last year, the company had $5.5 billion in net
sale.102 The local communities and municipalities that are already suffering from the company’s
intentional contamination should not be the ones left to shoulder the burden. DEQ must now
require the company to incur the costs to clean up that pollution.
The public, local communities, and municipalities will benefit tremendously from an
effective cleanup. If DEQ holds Chemours to its commitments under the Consent Order and
state law, there will be tremendous public and economic benefits from the resulting groundwater
cleanup—both tangible and intangible. For instance, families may be able to rest knowing that
the water they drink, and the rivers they swim and fish in, are no longer laced with Chemours’
toxic chemicals. Homeowners might be able to sell their homes for a reasonable price. Drinking
water utilities may not have to incur the heavy cost of upgrades. The local economy may benefit
without the stigma of Chemours’ PFAS pollution. By holding Chemours accountable, DEQ will
make it less likely that other corporations will be so reckless with their industrial pollution.
98 CAP at 58. 99 Makenzie Holland, Cleaner water could cost Brunswick, CFPUA water customers, STARNEWS ONLINE, Apr. 11,
2019, available at https://www.starnewsonline.com/news/20180411/cleaner-water-could-cost-brunswick-cfpua-
water-customers (last visited Feb. 24, 2020); Paul Woolverton, Cumberland County to spend $10.5M to send water
to GenX contaminated Gray’s Creek, THE FAYETTEVILLE OBSERVER, Jan. 6, 2020, available at
https://www.fayobserver.com/news/20200106/cumberland-county-to-spend-105m-to-send-water-to-genx-
contaminated-grayrsquos-creek (last visited Feb. 24, 2020); Greg Barnes, Local governments, residents having to
foot bill for industrial contamination, NORTH CAROLINA HEALTH NEWS, Jan. 7, 2020, available at
https://www.northcarolinahealthnews.org/2020/01/07/local-governments-residents-having-to-foot-bill-for-industrial-
contamination/ (last visited Feb. 24, 2020). 100 Sharon Lerner, New Teflon Toxin Found in North Carolina Drinking Water, THE INTERCEPT, June 17, 2017,
available at, https://theintercept.com/2017/06/17/new-teflon-toxin-found-in-north-carolina-drinking-water/ (last
visited Feb. 24, 2020). 101 Greg Barnes, People are buying houses unaware of ‘forever chemicals’ in their well water, NORTH CAROLINA
HEATH NEWS, Jan. 6, 2020, available at https://www.northcarolinahealthnews.org/2020/01/06/people-are-buying-
houses-unaware-of-forever-chemicals-in-their-well-water/ (last visited Feb. 24, 2020). 102 Press Release, The Chemours Company Reports Fourth Quarter and Full Year 2019 Results, Feb. 13, 2020,
available at https://investors.chemours.com/news-releases/news-releases-details/2020/The-Chemours-Company-
Reports-Fourth-Quarter-and-Full-Year-2019-Results/ (last visited Mar. 11, 2020).
17
Based on a thorough analysis of all relevant factors under 15A N.C. Admin. Code 2L
.0106(k), therefore, state law mandates that DEQ require maximum cleanup and control of the
company’s groundwater pollution.
V. Conclusion
With this proposed Corrective Action Plan, Chemours continues to put the cost of its
contamination on everyone else: on families downstream, on well owners, on utilities trying to
provide clean drinking water, on DuPont. DEQ must not allow it.
DEQ cannot allow Chemours’ blatant disregard for the law and for the well-being of
those living in southeastern North Carolina to continue. DEQ must exercise its full authority
under the Consent Order to seek penalties for Chemours’ violations of paragraphs 12 and 16,
reject Chemours’ proposed plan, and require that the company clean up its PFAS pollution.
Thank you for considering these comments. Please contact me at ggisler@selcnc.org or
919-967-1450 if you have any questions regarding this letter.
Sincerely,
Geoffrey R. Gisler
Senior Attorney
Jean Zhuang
Staff Attorney
Kelly Moser
Senior Attorney
Cc (via email):
Dana Sargent, CFRW
Kemp Burdette, CFRW
Bill Lane, DEQ
Francisco Benzoni, NCDOJ
18
Michael Abraczinskas, DAQ
Michael Scott, DWM
Linda Culpepper, DWR
David Shelton, Chemours
Brian Long, Chemours
John Savarese, Wachtell, Lipton
Joel Gross, Arnold & Porter
ATTACHMENT 1
ATTACHMENT 2
ATTACHMENT 3
From:wilddaisydeb@aol.com
To:SVC_DENR.publiccomments
Subject:[External] Groundwater Corrective Action plan
Date:Wednesday, April 1, 2020 8:24:28 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
From:
Debra Stewart (property owner)
Jason Stewart (occupant)
2494 Factory Lane
St. Pauls, NC 28384
Wilddaisydeb@aol.com
To: Department of Environmental Quality
Secretary Michael Regan
RE: Written Non-Concurrence to the proposed Groundwater Corrective Action
Plan 1601 Mail Service CenterRaleigh, N.C. 27699-1601
publiccomments@ncdenr.gov
Subject: Public Comment to the proposed Groundwater Corrective Action Plan
1. I am one of the “affected parties: per 15A NCAC 02L .0202(c) and § 143-215.2A. (Relief for
contaminated private drinking water wells). I DO NOT CONCUR with the Corrective Action
Plan (CAP) as written. I am providing my non-concurrence IAW15A NCAC 02L .0106(k) (3)
and provide my written notification to the Secretary of DEQ and Governor of the State of
North Carolina. I demand equal treatment under the laws of North Carolina and demand
Secretary Regan force Chemours and/or Dupont to provide a Permanent Solutions for all
wells found to be contaminated in exceedance of NC Groundwater Standards listed in 15A
NCAC 02L .0202. It is the belief that § 143-215.2A, which was enacted in June 2018 and
became a State Statute can still be used to force Chemoursand/or Dupont to run water at
their expense. Paragraph 34 utilized the verbiage Session Law 2018-5 Sec 13.1(c) when it
was signed and enacted in February 2019 over 8 months after § 143-215.2A had been
enacted as a State Law. Referring to it as Session Law 2018-5 Sec 13.1 (c) thus makes the
limitations that DEQ attempted to place on the use of § 143-215.2A invalid. Since the
enactment of the Consent Order Chemourshas been in violation in all testing of wells as they
are not testing for all chemicals agreed upon in Attachment C as both PFMOPrA (Perfluoro-
3- methoxypropanoic acid) & PFMOBA (Perfluoro-4- methoxybutanoic acid) are not tested
for. GEL Labs can test for these two compounds as they are tested for during NC DEQ testing
of wells.
2. As an adjacent property owner IAW the requirements of 15A NCAC 02L .0106(k)(3) I DO
NOT consent to the proposed Corrective Action Plan. It is required by the provisions of 15A
NCAC 02L .0106(k)(3) to gain approval of the property owners for the Corrective Action Plan
that was submitted for the Chemours i.e. the Fayetteville Works Facility (GeosyntecProject
Number TR0795). To date not one property owner that has been requested to provide
consent. Unless Chemoursand/or Dupont provides equal solutions for all “affected parties”
i.e. anybody with a Well that has been found to have any PFAS contamination from the
Fayetteville Works Facility (not limited to Attachment C of the consent order) in the means
of a Whole Home Solution be it Granular Activated Carbon Systems or Public
Water. I nonconcur with the Corrective Action Plan. Chemours & Dupont cannot be
permitted to contaminate our groundwater wells, soil and vegetation without being
required to remediate what they have damaged or a Permanent whole home water
solution. Cost to remediate or Public water should be the only feasible solution regardless
of costs i.e. the $75K DEQ imposed limit.
3. 15A NCAC 02L .0106(k)(3) is very clear and it states:
15A NCAC 02L .0106(k)(3) Any person required to implement an approved corrective action
plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the Secretary
approve such a plan without requiring groundwater remediation to the standards. A request
submitted to the Secretary under this Paragraph shall include a description of site-specific
conditions, including information on the availability of public water supplies for the affected
area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph. The person making the request shall demonstrate:
(1) that all sources of contamination and free product have been removed or controlled
pursuant to Paragraph (f) of this Rule;
(2) that the time and direction of contaminant travel can be predicted with reasonable
certainty;
(3) that contaminants have not and will not migrate onto adjacent properties, or that:
(A) such properties are served by an existing public water supply system dependent on
surface waters or hydraulically isolated groundwater; or
(B) the owners of such properties have consented in writing to the request;
4. There is still contamination in our trees specifically pine type trees and our soil
that Chemours has no intention of remediating. This will continue to have pass through
contamination caused by rainfall passing thru the vegetation. As such (1) will not be achieved
and neither will (2) above. Contaminants have migrated off of the Fayetteville Works Facility
to the adjacent properties as far as 11 miles from the center of the facility covering an area
in excess of 125 square miles and growing. All properties could be provided public water
supply IAW 15A NCAC 02L .0106 (k) at far less in cost that the cost to remediate an area over
125 square miles. Of whole home water filtration could be provided to all homes with
detection of PFAS in exceedance of the NC Ground Water Quality Standards. Chemours can
make the choice to fund billion to tens of billions of dollars of cleanup or millions for
providing permanent whole home solutions. I do not consent IAW (3)(B)
until Chemours provides that resolution voluntarily or forced by the State.
5. Per 15A NCAC 02L .0106(b) Any person conducting or controlling an activity that results in
the discharge of a waste or hazardous substance or oil to the groundwaters of the State, or
in proximity thereto, shall take action upon discovery to terminate and control the discharge,
mitigate any hazards resulting from exposure to the pollutants and notify the Department, as
defined in 15A NCAC 02C .0102, of the discharge. Chemours and Dupont violated 15A NCAC
02L .0106 (d) Any person conducting or controlling an activity that is conducted under the
authority of a permit initially issued by the
Department on or after December 30, 1983 pursuant to G.S. 143-215.1 or G.S. 130A-294 and
that results in an increase in concentration of a substance in excess of the standards. This was
known by NC DEQ as far back as December 2016 when Chemours delivered the Corrective
Measures Study to DEQ. So for three years Chemours failed to address a Corrective Action
Plan, and has only done so to meet a requirement of a Consent Order.
5. IAW 15A NCAC 02L .0106 (k) Any person required to implement an approved corrective
action plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the
Secretary approve such a plan without requiring groundwater remediation to the standards. A
request submitted to the Secretary under this Paragraph shall include a description of site-
specific conditions, including information on the availability of public water supplies for the
affected area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph.
6. The manner in which the consent order lists § 143-215.2A an State Law that was enacted in
June of 2018 prior to the Enactment of the Consent Order in February of 2019. Session Law
2018-5 Sec 13.1 (c) is irrelevant as it had been enacted as a State Law prior upon ratification in
June of 2018. So it should not have been referred to as Session Law 2018-5, but as the State
Statute and since listed incorrectly in Paragraph 34 of the Consent Order is invalid and the
Secretary of DEQ can still force the polluters to pay for permanent whole solution be that
Whole Home Granular Activated Carbon or the running of Public water Systems to all homes
found with a well in violation of the NC Ground Water Standards.
7. 15A NCAC 02L .0106 (a) Where groundwater quality has been degraded, the goal of any
required corrective action shall be restoration to the level of the standards, or as closely
thereto as is
economically and technologically feasible as determined by the Department in accordance
with this
Rule. If Chemours and/or Dupont cannot remediate all wells they have contaminated
in violation of the
15A NCAC 02L .0202 standards. For corrective action under 2L rules when no groundwater
standard exists, groundwater must, to the extent technologically and economically feasible, be
restored to practical quantitation limits (PQLs) except as otherwise provided in the rules. At
present, restoring groundwater to PQLs onsite or offsite is technologically and economically
infeasible. The size of the area encompasses thousands of private land parcels and any
remedial construction activities using currently available remedial technologies (excavation
and groundwater extraction) would be very disruptive to the local community and this
disruption would continue for a lengthy period of time. Any remedy which in principle could
help make progress towards PQLs over this large area would cost in the billions to tens of
billions of dollars.
8. I as one of the “affected parties” are demanding that NC DEQ protect our rights and
force Chemours and/or Dupont the polluters to either remediate the damages to our
Groundwater Wells or provide permanent whole home solutions i.e. Whole Home Granular
Activated Carbon or Public Water connections with a defined period of the polluter paying for
the water bills. The same solution provided for the Coal Ash “Affected Parties”.
9. Areas of Corrective Action Plan that indicate why Chemoursand/or Dupont should be forced
to provide Whole Home Filtration or Public Water for all those with wells that indicate
exceedance of the NC Groundwater Standards 15A NCAC 02L .0202(c). When referring to the
costs associated with providing the above remediation it must be taken into account
that Chemours is gaining a cost savings of $5,000,000 per month in cost savings for the
elimination of shipping the Waste Water to Texas. It must also be taken into account the
processing of the Waste from the Netherlands in determining the feasibility of providing
public water or Whole Home Solutions to all “affected parties”. Affected Party is any property
found with a groundwater well in exceedance of the NC Ground Water Standards established
by the NC Environmental
Page xiv
Comply with 2L Rules (CO paragraph 16), including following the policy for the intention of the
2L Rules
“to maintain and preserve the quality of the groundwaters, prevent and abate pollution and
contamination of the water of the state, protect public health, and permit management of
the groundwaters for their best usage by the citizens of North Carolina” (15A NCAC 02L
.0103)1; and comply with other requirements of the CO.
Response to Page xiv
Chemours is not in compliance with the Consent Order as they are not testing for all of the
Chemicals listed on Attachment C. The two compounds that are not tested for
are PFMOPrA(Perfluoro-3- methoxypropanoic acid) & PFMOBA (Perfluoro-
4- methoxybutanoic acid). This should be a complaint that all address to Michael Scott and
Michael Regan @ NC DEQ. Prior to approval of a Corrective Action Plan NC DEQ should ensure
that the Consent Order is actually enforced and that a permanent remediation solution or
permanent whole home water solutions are provided.
Page xvi
Because the results of the HH-SLEA and Ecological SLEA indicate that exposures to HFPO-DA in
offsite environmental media do not pose a hazard to human health or the environment, site-
specific, risk-based cleanup goals were not developed; rather, cleanup goals are based on CO
and 2L rules. ****
For corrective action under 2L rules when no groundwater standard exists, groundwater must,
to the extent technologically and economically feasible, be restored to practical quantitation
limits (PQLs) except as otherwise provided in the rules. At present, restoring groundwater to
PQLs onsite or offsite is technologically and economically infeasible.
For offsite groundwater receptors, provide public water connections or whole building
filtration units or reverse osmosis units to qualifying surrounding residents (CO paragraphs 19
and 20);
Response: to Chemours CAP Page xvi
Most all wells tested have multiple Chemicals in the wells. Some as many as 9- 16 yet in
documents like this Corrective Action Plan you will see Chemours discussion relate to only
HFPO-DA. In the Ground Water Quality Standard of the State of North Carolina under 15A
NCAC 02L .0202(b)(2) Where two or more substances exist in combination, the Director shall
consider the effects of chemical interactions as determined by the Division of Public Health
and may establish maximum concentrations at values less than those established in
accordance with Paragraphs (c), (h), or (i) of this Rule. In the absence of information to the
contrary, in accordance with Paragraph (d) of this Rule, the carcinogenic risks associated with
carcinogens present shall be considered additive and the toxic effects associated with non-
carcinogens present shall also be considered additive.
I as an “affected party”: per 15A NCAC 02L .0202(c) and § 143-215.2A (Relief for
contaminated private drinking water wells) demand that the Secretary of DEQ and
Governor of the State of North Carolina force Chemours and/or Dupontto provide a
Permanent Solution for all wells found to be contaminated in exceedance of the NC
Groundwater Standards as the remedy for our contaminated wells based on the admission
that Chemours has no plan for remediation of our contaminated properties. Secretary
Regan needs to follow NC Groundwater Quality Standards as well as enforce the Consent
Order. Failure to do so is a failure to perform the duties of office.
This property has the RO system installed per Chemours. My son Jason tells that the water
still smells horrible and he does not believe that the RO is removing all of the contaminants.
He does not trust this system and does not drink this water or use it for cooking. Also
Chemours only installed it in the kitchen giving some lame excuse for not installing it in the
bathroom. They were notified to return and install it in the bathroom but never returned to
complete the job. We request whole home solution with GAC filtration or county water run to
this property.
Page 1 of 5
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From:wilddaisydeb@aol.com
To:SVC_DENR.publiccomments
Subject:[External]
Date:Wednesday, April 1, 2020 8:15:38 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to report.spam@nc.gov
From:
Debra Stewart (property owner)
Jason Stewart (occupant)
2494 Factory Lane
St. Pauls, NC 28384
Wilddaisydeb@aol.com
To: Department of Environmental Quality
Secretary Michael Regan
RE: Written Non-Concurrence to the proposed Groundwater Corrective Action
Plan 1601 Mail Service Center
Raleigh, N.C. 27699-1601
publiccomments@ncdenr.gov
Subject: Public Comment to the proposed Groundwater Corrective Action Plan
1. I am one of the “affected parties: per 15A NCAC 02L .0202(c) and § 143-215.2A. (Relief for
contaminated private drinking water wells). I DO NOT CONCUR with the Corrective Action
Plan (CAP) as written. I am providing my non-concurrence IAW15A NCAC 02L .0106(k) (3)
and provide my written notification to the Secretary of DEQ and Governor of the State of
North Carolina. I demand equal treatment under the laws of North Carolina and demand
Secretary Regan force Chemours and/or Dupont to provide a Permanent Solutions for all
wells found to be contaminated in exceedance of NC Groundwater Standards listed in 15A
NCAC 02L .0202. It is the belief that § 143-215.2A, which was enacted in June 2018 and
became a State Statute can still be used to force Chemoursand/or Dupont to run water at
their expense. Paragraph 34 utilized the verbiage Session Law 2018-5 Sec 13.1(c) when it
was signed and enacted in February 2019 over 8 months after § 143-215.2A had been
enacted as a State Law. Referring to it as Session Law 2018-5 Sec 13.1 (c) thus makes the
limitations that DEQ attempted to place on the use of § 143-215.2A invalid. Since the
enactment of the Consent Order Chemourshas been in violation in all testing of wells as they
are not testing for all chemicals agreed upon in Attachment C as both PFMOPrA (Perfluoro-
3- methoxypropanoic acid) & PFMOBA (Perfluoro-4- methoxybutanoic acid) are not tested
for. GEL Labs can test for these two compounds as they are tested for during NC DEQ testing
of wells.
2. As an adjacent property owner IAW the requirements of 15A NCAC 02L .0106(k)(3) I DO
NOT consent to the proposed Corrective Action Plan. It is required by the provisions of 15A
NCAC 02L .0106(k)(3) to gain approval of the property owners for the Corrective Action Plan
that was submitted for the Chemours i.e. the Fayetteville Works Facility (GeosyntecProject
Number TR0795). To date not one property owner that has been requested to provide
consent. Unless Chemoursand/or Dupont provides equal solutions for all “affected parties”
i.e. anybody with a Well that has been found to have any PFAS contamination from the
Fayetteville Works Facility (not limited to Attachment C of the consent order) in the means
of a Whole Home Solution be it Granular Activated Carbon Systems or Public
Water. I nonconcur with the Corrective Action Plan. Chemours & Dupont cannot be
permitted to contaminate our groundwater wells, soil and vegetation without being
required to remediate what they have damaged or a Permanent whole home water
solution. Cost to remediate or Public water should be the only feasible solution regardless
of costs i.e. the $75K DEQ imposed limit.
3. 15A NCAC 02L .0106(k)(3) is very clear and it states:
15A NCAC 02L .0106(k)(3) Any person required to implement an approved corrective action
plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the Secretary
approve such a plan without requiring groundwater remediation to the standards. A request
submitted to the Secretary under this Paragraph shall include a description of site-specific
conditions, including information on the availability of public water supplies for the affected
area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph. The person making the request shall demonstrate:
(1) that all sources of contamination and free product have been removed or controlled
pursuant to Paragraph (f) of this Rule;
(2) that the time and direction of contaminant travel can be predicted with reasonable
certainty;
(3) that contaminants have not and will not migrate onto adjacent properties, or that:
(A) such properties are served by an existing public water supply system dependent on
surface waters or hydraulically isolated groundwater; or
(B) the owners of such properties have consented in writing to the request;
4. There is still contamination in our trees specifically pine type trees and our soil
that Chemours has no intention of remediating. This will continue to have pass through
contamination caused by rainfall passing thru the vegetation. As such (1) will not be achieved
and neither will (2) above. Contaminants have migrated off of the Fayetteville Works Facility
to the adjacent properties as far as 11 miles from the center of the facility covering an area
in excess of 125 square miles and growing. All properties could be provided public water
supply IAW 15A NCAC 02L .0106 (k) at far less in cost that the cost to remediate an area over
125 square miles. Of whole home water filtration could be provided to all homes with
detection of PFAS in exceedance of the NC Ground Water Quality Standards. Chemours can
make the choice to fund billion to tens of billions of dollars of cleanup or millions for
providing permanent whole home solutions. I do not consent IAW (3)(B)
until Chemours provides that resolution voluntarily or forced by the State.
5. Per 15A NCAC 02L .0106(b) Any person conducting or controlling an activity that results in
the discharge of a waste or hazardous substance or oil to the groundwaters of the State, or
in proximity thereto, shall take action upon discovery to terminate and control the discharge,
mitigate any hazards resulting from exposure to the pollutants and notify the Department, as
defined in 15A NCAC 02C .0102, of the discharge. Chemours and Dupont violated 15A NCAC
02L .0106 (d) Any person conducting or controlling an activity that is conducted under the
authority of a permit initially issued by the
Department on or after December 30, 1983 pursuant to G.S. 143-215.1 or G.S. 130A-294 and
that results in an increase in concentration of a substance in excess of the standards. This was
known by NC DEQ as far back as December 2016 when Chemours delivered the Corrective
Measures Study to DEQ. So for three years Chemours failed to address a Corrective Action
Plan, and has only done so to meet a requirement of a Consent Order.
5. IAW 15A NCAC 02L .0106 (k) Any person required to implement an approved corrective
action plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the
Secretary approve such a plan without requiring groundwater remediation to the standards. A
request submitted to the Secretary under this Paragraph shall include a description of site-
specific conditions, including information on the availability of public water supplies for the
affected area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph.
6. The manner in which the consent order lists § 143-215.2A an State Law that was enacted in
June of 2018 prior to the Enactment of the Consent Order in February of 2019. Session Law
2018-5 Sec 13.1 (c) is irrelevant as it had been enacted as a State Law prior upon ratification in
June of 2018. So it should not have been referred to as Session Law 2018-5, but as the State
Statute and since listed incorrectly in Paragraph 34 of the Consent Order is invalid and the
Secretary of DEQ can still force the polluters to pay for permanent whole solution be that
Whole Home Granular Activated Carbon or the running of Public water Systems to all homes
found with a well in violation of the NC Ground Water Standards.
7. 15A NCAC 02L .0106 (a) Where groundwater quality has been degraded, the goal of any
required corrective action shall be restoration to the level of the standards, or as closely
thereto as is
economically and technologically feasible as determined by the Department in accordance
with this
Rule. If Chemours and/or Dupont cannot remediate all wells they have contaminated inviolation of the
15A NCAC 02L .0202 standards. For corrective action under 2L rules when no groundwater
standard exists, groundwater must, to the extent technologically and economically feasible, be
restored to practical quantitation limits (PQLs) except as otherwise provided in the rules. At
present, restoring groundwater to PQLs onsite or offsite is technologically and economically
infeasible. The size of the area encompasses thousands of private land parcels and any
remedial construction activities using currently available remedial technologies (excavation
and groundwater extraction) would be very disruptive to the local community and this
disruption would continue for a lengthy period of time. Any remedy which in principle could
help make progress towards PQLs over this large area would cost in the billions to tens of
billions of dollars.
8. I as one of the “affected parties” are demanding that NC DEQ protect our rights and
force Chemours and/or Dupont the polluters to either remediate the damages to our
Groundwater Wells or provide permanent whole home solutions i.e. Whole Home Granular
Activated Carbon or Public Water connections with a defined period of the polluter paying for
the water bills. The same solution provided for the Coal Ash “Affected Parties”.
9. Areas of Corrective Action Plan that indicate why Chemoursand/or Dupont should be forced
to provide Whole Home Filtration or Public Water for all those with wells that indicate
exceedance of the NC Groundwater Standards 15A NCAC 02L .0202(c). When referring to the
costs associated with providing the above remediation it must be taken into account
that Chemours is gaining a cost savings of $5,000,000 per month in cost savings for the
elimination of shipping the Waste Water to Texas. It must also be taken into account the
processing of the Waste from the Netherlands in determining the feasibility of providing
public water or Whole Home Solutions to all “affected parties”. Affected Party is any property
found with a groundwater well in exceedance of the NC Ground Water Standards established
by the NC Environmental
Page xiv
Comply with 2L Rules (CO paragraph 16), including following the policy for the intention of the
2L Rules
“to maintain and preserve the quality of the groundwaters, prevent and abate pollution and
contamination of the water of the state, protect public health, and permit management of
the groundwaters for their best usage by the citizens of North Carolina” (15A NCAC 02L
.0103)1; and comply with other requirements of the CO.
Response to Page xiv
Chemours is not in compliance with the Consent Order as they are not testing for all of the
Chemicals listed on Attachment C. The two compounds that are not tested for
are PFMOPrA(Perfluoro-3- methoxypropanoic acid) & PFMOBA (Perfluoro-
4- methoxybutanoic acid). This should be a complaint that all address to Michael Scott and
Michael Regan @ NC DEQ. Prior to approval of a Corrective Action Plan NC DEQ should ensure
that the Consent Order is actually enforced and that a permanent remediation solution or
permanent whole home water solutions are provided.
Page xvi
Because the results of the HH-SLEA and Ecological SLEA indicate that exposures to HFPO-DA in
offsite environmental media do not pose a hazard to human health or the environment, site-
specific, risk-based cleanup goals were not developed; rather, cleanup goals are based on CO
and 2L rules. ****
For corrective action under 2L rules when no groundwater standard exists, groundwater must,
to the extent technologically and economically feasible, be restored to practical quantitation
limits (PQLs) except as otherwise provided in the rules. At present, restoring groundwater to
PQLs onsite or offsite is technologically and economically infeasible.
For offsite groundwater receptors, provide public water connections or whole building
filtration units or reverse osmosis units to qualifying surrounding residents (CO paragraphs 19
and 20);
Response: to Chemours CAP Page xvi
Most all wells tested have multiple Chemicals in the wells. Some as many as 9- 16 yet in
documents like this Corrective Action Plan you will see Chemours discussion relate to only
HFPO-DA. In the Ground Water Quality Standard of the State of North Carolina under 15A
NCAC 02L .0202(b)(2) Where two or more substances exist in combination, the Director shall
consider the effects of chemical interactions as determined by the Division of Public Health
and may establish maximum concentrations at values less than those established in
accordance with Paragraphs (c), (h), or (i) of this Rule. In the absence of information to the
contrary, in accordance with Paragraph (d) of this Rule, the carcinogenic risks associated with
carcinogens present shall be considered additive and the toxic effects associated with non-
carcinogens present shall also be considered additive.
I as an “affected party”: per 15A NCAC 02L .0202(c) and § 143-215.2A (Relief for
contaminated private drinking water wells) demand that the Secretary of DEQ and
Governor of the State of North Carolina force Chemours and/or Dupontto provide a
Permanent Solution for all wells found to be contaminated in exceedance of the NC
Groundwater Standards as the remedy for our contaminated wells based on the admission
that Chemours has no plan for remediation of our contaminated properties. Secretary
Regan needs to follow NC Groundwater Quality Standards as well as enforce the Consent
Order. Failure to do so is a failure to perform the duties of office.
This property has the RO system installed per Chemours. My son Jason tells that the water
still smells horrible and he does not believe that the RO is removing all of the contaminants.
He does not trust this system and does not drink this water or use it for cooking. Also
Chemours only installed it in the kitchen giving some lame excuse for not installing it in the
bathroom. They were notified to return and install it in the bathroom but never returned to
complete the job. We request whole home solution with GAC filtration or county water run to
this property.
Page 1 of 5
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From:wilddaisydeb@aol.com
To:SVC_DENR.publiccomments
Subject:[External] Comments on Corrective Action
Date:Wednesday, April 1, 2020 8:05:31 PM
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From:
Debra Stewart
Homeowner and Resident
2462 Factory Lane
St. Pauls, NC 28383
wilddaisydeb@aol.com
To: Department of Environmental Quality
Secretary Michael Regan
RE: Written Non-Concurrence to the proposed Groundwater Corrective Action
Plan 1601 Mail Service Center
Raleigh, N.C. 27699-1601
publiccomments@ncdenr.gov
Subject: Public Comment to the proposed Groundwater Corrective Action Plan
1. I am one of the “affected parties: per 15A NCAC 02L .0202(c) and § 143-215.2A. (Relief for
contaminated private drinking water wells). I DO NOT CONCUR with the Corrective Action
Plan (CAP) as written. I am providing my non-concurrence IAW15A NCAC 02L .0106(k) (3)
and provide my written notification to the Secretary of DEQ and Governor of the State of
North Carolina. I demand equal treatment under the laws of North Carolina and demand
Secretary Regan force Chemours and/or Dupont to provide a Permanent Solutions for all
wells found to be contaminated in exceedance of NC Groundwater Standards listed in 15A
NCAC 02L .0202. It is the belief that § 143-215.2A, which was enacted in June 2018 and
became a State Statute can still be used to force Chemoursand/or Dupont to run water at
their expense. Paragraph 34 utilized the verbiage Session Law 2018-5 Sec 13.1(c) when it
was signed and enacted in February 2019 over 8 months after § 143-215.2A had been
enacted as a State Law. Referring to it as Session Law 2018-5 Sec 13.1 (c) thus makes the
limitations that DEQ attempted to place on the use of § 143-215.2A invalid. Since the
enactment of the Consent Order Chemourshas been in violation in all testing of wells as they
are not testing for all chemicals agreed upon in Attachment C as both PFMOPrA (Perfluoro-
3- methoxypropanoic acid) & PFMOBA (Perfluoro-4- methoxybutanoic acid) are not tested
for. GEL Labs can test for these two compounds as they are tested for during NC DEQ testing
of wells.
2. As an adjacent property owner IAW the requirements of 15A NCAC 02L .0106(k)(3) I DO
NOT consent to the proposed Corrective Action Plan. It is required by the provisions of 15A
NCAC 02L .0106(k)(3) to gain approval of the property owners for the Corrective Action Plan
that was submitted for the Chemours i.e. the Fayetteville Works Facility (GeosyntecProject
Number TR0795). To date not one property owner that has been requested to provide
consent. Unless Chemoursand/or Dupont provides equal solutions for all “affected parties”
i.e. anybody with a Well that has been found to have any PFAS contamination from the
Fayetteville Works Facility (not limited to Attachment C of the consent order) in the means
of a Whole Home Solution be it Granular Activated Carbon Systems or Public
Water. I nonconcur with the Corrective Action Plan. Chemours & Dupont cannot be
permitted to contaminate our groundwater wells, soil and vegetation without being
required to remediate what they have damaged or a Permanent whole home water
solution. Cost to remediate or Public water should be the only feasible solution regardless
of costs i.e. the $75K DEQ imposed limit.
3. 15A NCAC 02L .0106(k)(3) is very clear and it states:
15A NCAC 02L .0106(k)(3) Any person required to implement an approved corrective action
plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the Secretary
approve such a plan without requiring groundwater remediation to the standards. A request
submitted to the Secretary under this Paragraph shall include a description of site-specific
conditions, including information on the availability of public water supplies for the affected
area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph. The person making the request shall demonstrate:
(1) that all sources of contamination and free product have been removed or controlled
pursuant to Paragraph (f) of this Rule;
(2) that the time and direction of contaminant travel can be predicted with reasonable
certainty;
(3) that contaminants have not and will not migrate onto adjacent properties, or that:
(A) such properties are served by an existing public water supply system dependent on
surface waters or hydraulically isolated groundwater; or
(B) the owners of such properties have consented in writing to the request;
4. There is still contamination in our trees specifically pine type trees and our soil
that Chemours has no intention of remediating. This will continue to have pass through
contamination caused by rainfall passing thru the vegetation. As such (1) will not be achieved
and neither will (2) above. Contaminants have migrated off of the Fayetteville Works Facility
to the adjacent properties as far as 11 miles from the center of the facility covering an area
in excess of 125 square miles and growing. All properties could be provided public water
supply IAW 15A NCAC 02L .0106 (k) at far less in cost that the cost to remediate an area over
125 square miles. Of whole home water filtration could be provided to all homes with
detection of PFAS in exceedance of the NC Ground Water Quality Standards. Chemours can
make the choice to fund billion to tens of billions of dollars of cleanup or millions for
providing permanent whole home solutions. I do not consent IAW (3)(B)
until Chemours provides that resolution voluntarily or forced by the State.
5. Per 15A NCAC 02L .0106(b) Any person conducting or controlling an activity that results in
the discharge of a waste or hazardous substance or oil to the groundwaters of the State, or
in proximity thereto, shall take action upon discovery to terminate and control the discharge,
mitigate any hazards resulting from exposure to the pollutants and notify the Department, as
defined in 15A NCAC 02C .0102, of the discharge. Chemours and Dupont violated 15A NCAC
02L .0106 (d) Any person conducting or controlling an activity that is conducted under the
authority of a permit initially issued by the
Department on or after December 30, 1983 pursuant to G.S. 143-215.1 or G.S. 130A-294 and
that results in an increase in concentration of a substance in excess of the standards. This was
known by NC DEQ as far back as December 2016 when Chemours delivered the Corrective
Measures Study to DEQ. So for three years Chemours failed to address a Corrective Action
Plan, and has only done so to meet a requirement of a Consent Order.
5. IAW 15A NCAC 02L .0106 (k) Any person required to implement an approved corrective
action plan for a site subject to Paragraphs (c) or (e) of this Rule may request that the
Secretary approve such a plan without requiring groundwater remediation to the standards. A
request submitted to the Secretary under this Paragraph shall include a description of site-
specific conditions, including information on the availability of public water supplies for the
affected area; the technical basis for the request; and any other information requested by the
Secretary to evaluate the request in accordance with Subparagraphs (1) through (7) of this
Paragraph.
6. The manner in which the consent order lists § 143-215.2A an State Law that was enacted in
June of 2018 prior to the Enactment of the Consent Order in February of 2019. Session Law
2018-5 Sec 13.1 (c) is irrelevant as it had been enacted as a State Law prior upon ratification in
June of 2018. So it should not have been referred to as Session Law 2018-5, but as the State
Statute and since listed incorrectly in Paragraph 34 of the Consent Order is invalid and the
Secretary of DEQ can still force the polluters to pay for permanent whole solution be that
Whole Home Granular Activated Carbon or the running of Public water Systems to all homes
found with a well in violation of the NC Ground Water Standards.
7. 15A NCAC 02L .0106 (a) Where groundwater quality has been degraded, the goal of any
required corrective action shall be restoration to the level of the standards, or as closely
thereto as is
economically and technologically feasible as determined by the Department in accordance
with this
Rule. If Chemours and/or Dupont cannot remediate all wells they have contaminated inviolation of the
15A NCAC 02L .0202 standards. For corrective action under 2L rules when no groundwater
standard exists, groundwater must, to the extent technologically and economically feasible, be
restored to practical quantitation limits (PQLs) except as otherwise provided in the rules. At
present, restoring groundwater to PQLs onsite or offsite is technologically and economically
infeasible. The size of the area encompasses thousands of private land parcels and any
remedial construction activities using currently available remedial technologies (excavation
and groundwater extraction) would be very disruptive to the local community and this
disruption would continue for a lengthy period of time. Any remedy which in principle could
help make progress towards PQLs over this large area would cost in the billions to tens of
billions of dollars.
8. I as one of the “affected parties” are demanding that NC DEQ protect our rights and
force Chemours and/or Dupont the polluters to either remediate the damages to our
Groundwater Wells or provide permanent whole home solutions i.e. Whole Home Granular
Activated Carbon or Public Water connections with a defined period of the polluter paying for
the water bills. The same solution provided for the Coal Ash “Affected Parties”.
9. Areas of Corrective Action Plan that indicate why Chemoursand/or Dupont should be forced
to provide Whole Home Filtration or Public Water for all those with wells that indicate
exceedance of the NC Groundwater Standards 15A NCAC 02L .0202(c). When referring to the
costs associated with providing the above remediation it must be taken into account
that Chemours is gaining a cost savings of $5,000,000 per month in cost savings for the
elimination of shipping the Waste Water to Texas. It must also be taken into account the
processing of the Waste from the Netherlands in determining the feasibility of providing
public water or Whole Home Solutions to all “affected parties”. Affected Party is any property
found with a groundwater well in exceedance of the NC Ground Water Standards established
by the NC Environmental
Page xiv
Comply with 2L Rules (CO paragraph 16), including following the policy for the intention of the
2L Rules
“to maintain and preserve the quality of the groundwaters, prevent and abate pollution and
contamination of the water of the state, protect public health, and permit management of
the groundwaters for their best usage by the citizens of North Carolina” (15A NCAC 02L
.0103)1; and comply with other requirements of the CO.
Response to Page xiv
Chemours is not in compliance with the Consent Order as they are not testing for all of the
Chemicals listed on Attachment C. The two compounds that are not tested for
are PFMOPrA(Perfluoro-3- methoxypropanoic acid) & PFMOBA (Perfluoro-
4- methoxybutanoic acid). This should be a complaint that all address to Michael Scott and
Michael Regan @ NC DEQ. Prior to approval of a Corrective Action Plan NC DEQ should ensure
that the Consent Order is actually enforced and that a permanent remediation solution or
permanent whole home water solutions are provided.
Page xvi
Because the results of the HH-SLEA and Ecological SLEA indicate that exposures to HFPO-DA in
offsite environmental media do not pose a hazard to human health or the environment, site-
specific, risk-based cleanup goals were not developed; rather, cleanup goals are based on CO
and 2L rules. ****
For corrective action under 2L rules when no groundwater standard exists, groundwater must,
to the extent technologically and economically feasible, be restored to practical quantitation
limits (PQLs) except as otherwise provided in the rules. At present, restoring groundwater to
PQLs onsite or offsite is technologically and economically infeasible.
For offsite groundwater receptors, provide public water connections or whole building
filtration units or reverse osmosis units to qualifying surrounding residents (CO paragraphs 19
and 20);
Response: to Chemours CAP Page xvi
Most all wells tested have multiple Chemicals in the wells. Some as many as 9- 16 yet in
documents like this Corrective Action Plan you will see Chemours discussion relate to only
HFPO-DA. In the Ground Water Quality Standard of the State of North Carolina under 15A
NCAC 02L .0202(b)(2) Where two or more substances exist in combination, the Director shall
consider the effects of chemical interactions as determined by the Division of Public Health
and may establish maximum concentrations at values less than those established in
accordance with Paragraphs (c), (h), or (i) of this Rule. In the absence of information to the
contrary, in accordance with Paragraph (d) of this Rule, the carcinogenic risks associated with
carcinogens present shall be considered additive and the toxic effects associated with non-
carcinogens present shall also be considered additive.
I as an “affected party”: per 15A NCAC 02L .0202(c) and § 143-215.2A (Relief for
contaminated private drinking water wells) demand that the Secretary of DEQ and
Governor of the State of North Carolina force Chemours and/or Dupontto provide a
Permanent Solution for all wells found to be contaminated in exceedance of the NC
Groundwater Standards as the remedy for our contaminated wells based on the admission
that Chemours has no plan for remediation of our contaminated properties. Secretary
Regan needs to follow NC Groundwater Quality Standards as well as enforce the Consent
Order. Failure to do so is a failure to perform the duties of office.
We deserve whole home solutions that can only be achieved by GAC water filtration or
county water being run to every home in the Grays Creek community. We eat, drink, bathe,
breathe these chemicals from DuPont Chemours with exposure 24/7 since 1980. Our clothing
is impregnated with these chemicals as we have no choice but to wash our clothing with this
water, we sleep in bed linen impregnated with these chemicals. Please protect us and clean up
our water. Hold these companies accountable for polluting our homes, land, air, water, and
wildlife areas.
Page 1 of 5
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From:bethgrandel@gmail.com
To:SVC_DENR.publiccomments
Subject:[External] GenX
Date:Tuesday, March 31, 2020 9:44:37 PM
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attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility,
the Cape Fear River, and downstream communities ahead of its bottom line
—which its proposed plan fails to do.
DEQ must ensure that Chemours—not families nearby and downstream
communities already burdened by exposure and health risks—pays the
costs to clean up its pollution.
Let DEQ know that, with 45,000 acres of polluted, leaking groundwater,
Chemours’ plan will not clean up the problem and will leave our
communities, drinking water, and the Cape Fear River at risk.
Sent from my iPhone
From:Mike McKay
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Monday, March 30, 2020 1:26:53 PM
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attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility, the Cape
Fear River, and downstream communities ahead of its bottom line—which its
proposed plan fails to do.
Chemours—not families nearby and downstream communities already burdened by
exposure and health risks—pays the costs to clean up its pollution.
45,000 acres of polluted, leaking groundwater, Chemours’ plan will not clean up the
problem and will leave our communities, drinking water, and the Cape Fear River atrisk.
Respectfully,
Michael McKay
Sent from my iPad
From:Barbara Bakowycz
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Sunday, March 29, 2020 2:24:41 AM
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attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility,
the Cape Fear River, and downstream communities ahead of its bottom line
—which its proposed plan fails to do.
DEQ must ensure that Chemours—not families nearby and downstream
communities already burdened by exposure and health risks—pays the
costs to clean up its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not
clean up the problem and will leave our communities, drinking water, and
the Cape Fear River at risk.
I’m a registered nurse in my 60’s. In the midst of the Covid-19 pandemic I continue to makeweekly trips refilling gallons of RO filtered water. As are many others. Allowing Chemours toremain unaccountable and not paying for their complicit actions is beyond egregious.
What say you DEQ?
J. Barbara Bakowycz RN
Sent from my iPad
From:Brian Habenicht
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 28, 2020 8:09:09 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Brian Habenicht
52 Westwood Pl
Asheville, NC 28806-4224
From:Laura Carrpenter
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 27, 2020 2:54:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Laura Carrpenter
8609 Beeswood Dr
Charlotte, NC 28277-5695
From:Morris-McLawhorn, Bridgette R
To:SVC_DENR.publiccomments
Subject:Public comments received
Date:Thursday, March 26, 2020 1:11:52 PM
Attachments:2020 03 26 public comment on proposed GW corrective action plan 2.pdf
2020 03 26 public comment on proposed GW corrective action plan.pdf
Good afternoon,
Please find attached two public comments received on the proposed GW corrective action plan.
Thanks,
Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &Chief Deputy Secretary John Nicholson
North Carolina Department of Environmental Quality (919) 707-8643 office(984) 328-2303 mobile
bmorris@ncdenr.gov 217 West Jones Street1601 Mail Service Center
Raleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Diana Ells
To:SVC_DENR.publiccomments
Subject:[External] Clean up our water
Date:Thursday, March 26, 2020 9:06:28 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
We have recently made a decision to move to Wilmington and are currently building a home there. Iy concerns me
greatly that I was not informed about the polluted water in the Cape Fear river caused by companies. I beg that the
companies are held accountable and made to clean this up. I have children and grandchildren that will be spending a
lot of time with us and I want them to stay healthy.
Diana Ells
Sent from my iPhone
From:Sarah Bartel
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Wednesday, March 25, 2020 5:09:59 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Sarah Bartel
11519 Essex Fells Dr
Charlotte, NC 28277
From:Ricardo Velazquez
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Monday, March 23, 2020 8:51:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Ricardo Velazquez
5008 Barbee Rd
Durham, NC 27713
From:Wendy Gilbert
To:SVC_DENR.publiccomments
Subject:[External] Stop chemours
Date:Saturday, March 21, 2020 10:16:15 PM
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attachment to report.spam@nc.gov
Let DEQ know that Chemours must
put the health of North Carolinians
living near the facility, the Cape
Fear River, and downstream
communities ahead of its bottom
line—which its proposed plan fails
to do.
DEQ must ensure that Chemours—
not families nearby and
downstream communities already
burdened by exposure and health
risks—pays the costs to clean up
its pollution.
Let DEQ know that, with 45,000
acres of polluted, leaking
groundwater, Chemours’ plan will
not clean up the problem and will
leave our communities, drinking
water, and the Cape Fear River at
risk.
~Wendy(919) 888-3553
From:Hannah McDermott
To:SVC_DENR.publiccomments
Subject:[External]
Date:Friday, March 20, 2020 3:48:50 PM
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attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility, the Cape Fear
River, and downstream communities ahead of its bottom line—which its proposed plan fails todo.
DEQ must ensure that Chemours—not families nearby and downstream communities alreadyburdened by exposure and health risks—pays the costs to clean up its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not clean up theproblem and will leave our communities, drinking water, and the Cape Fear River at risk
This is unacceptable and awful. Please don't allow them to do this.
Thank you,
Hannah McDermott
From:williamtravitz16@gmail.com
To:SVC_DENR.publiccomments
Subject:[External] Care about the people who can"t use their water.. Shame on you.
Date:Thursday, March 19, 2020 2:08:09 PM
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attachment to report.spam@nc.gov
It is past time to clean up your pollution and stop concentrating on profit. You are responsible for
this illegal pollution and it is past time stop illegal dumping & clean up your mess. Legally you are
obliged to do so. Do we have to take legal action?
Residents dealing with pollution……..Bill & Dorothy Travitz.
Sent from Mail [go.microsoft.com] for Windows 10
From:Linda Cavanaugh
To:SVC_DENR.publiccomments
Subject:[External] Clean up N.C. rivers.
Date:Thursday, March 19, 2020 12:26:39 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Chemours must take responsibility for and clean up our drinking water which comes from the Cape Fear river. I
don’t want to die from cancer because of your lax ability to keep dangerous chemicals out of our source of life—
clean water!! Get busy.
Sent from my iPhone
From:Myrlie Barrier
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 19, 2020 8:27:06 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Myrlie Barrier
173 Harris St
Rutherfordton, NC 28139-3001
From:Morris-McLawhorn, Bridgette R
To:SVC_DENR.publiccomments
Subject:comments received
Date:Wednesday, March 18, 2020 1:00:01 PM
Attachments:2020 03 18 public comment on proposed GW corrective action plan.pdf
Good morning,
Please find attached comments received on the proposed GW corrective action plan.
Thanks, Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &
Chief Deputy Secretary John NicholsonNorth Carolina Department of Environmental Quality (919) 707-8643 office
(984) 328-2303 mobilebmorris@ncdenr.gov 217 West Jones Street
1601 Mail Service CenterRaleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Subject:Comment received on Corrective Action Plan
Date:Tuesday, March 17, 2020 11:53:46 AM
Attachments:02282020-public comment on CAP recieved.pdf
Thanks,
Sharon
From:Polly Harris
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 17, 2020 10:48:07 AM
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Dear Department of Environmental Quality,
In the time of crisis safe water is essential. I'm writing to urge the NC Department of Environmental Quality to make
Chemours halt the discharge of all PFAS into the Cape Fear River. The river is a drinking source for downstream
communities. Residents in the river basin have been exposed to high concentrations of PFAS for decades. There is
no safe level for continued exposure and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Polly Harris
118 W Trinity Ave
Durham, NC 27701-1915
From:Morris-McLawhorn, Bridgette R
To:SVC_DENR.publiccomments
Subject:Comments received
Date:Tuesday, March 17, 2020 9:57:27 AM
Attachments:2020 03 17 public comment on proposed GW corrective action plan 2.pdf
2020 03 17 public comment on proposed GW corrective action plan.pdf
Good morning,
Please find 2 proposed GW corrective action plan comments received via mail.
Thanks, Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &
Chief Deputy Secretary John NicholsonNorth Carolina Department of Environmental Quality (919) 707-8643 office
(984) 328-2303 mobilebmorris@ncdenr.gov 217 West Jones Street
1601 Mail Service CenterRaleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Savor for the Soul
To:SVC_DENR.publiccomments
Subject:[External] Chemours Cape Fear Cleanup
Date:Monday, March 16, 2020 9:33:47 PM
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With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not
clean up the problem and will leave our communities, drinking water, and
the Cape Fear River at risk.
Chemours must put the health of North Carolinians living near the facility,
the Cape Fear River, and downstream communities ahead of its bottom line
—which its proposed plan fails to do.
From:Amy Popp
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 15, 2020 3:40:02 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Amy Popp
6905 Pinnacle Ridge Rd
Raleigh, NC 27603-9126
From:Joe Fleming
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 15, 2020 3:06:58 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Joe Fleming
1939 Gray Meadow Dr
Apex, NC 27502-9513
From:Rose Shulman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 14, 2020 5:18:06 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Rose Shulman
346 piney grove church rd
traphill, NC 28685
From:Esther Murphy
To:SVC_DENR.publiccomments
Subject:[External] Government is to protect us.
Date:Saturday, March 14, 2020 1:17:36 PM
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I am native North Carolinian. My family has suffered tremendous health assaults from
industrial poisoning. By age 58 I am sole survivor of my nuclear family. Three generations all died of cancer.
We have suffered tremendous loss in our pets and wildlife due to environmental poisoning.Our trees and native plants are not reproducing.
I have suffered the pain of chronic kidney and bladder conditions since childhood. I was
reluctant to purchase purified bottled water, all while paying mandatory water utility bills fortoxic water.
When I observed entire neighborhoods and towns getting sick at the same time, I made testson water. I stored tap water when all was well, then served it to my family when people
became ill. We remained healthy during times of "toxic" flush in water lines.
I have purchased purified bottled water, from known sources, usually outside of NorthCarolina, for 34 years. Until 2018 I used tap water for cooking, bathing and making
coffee, then my new Medical Doctor told me to stop consuming all local tap water. I havemany friends who don't even brush their teeth in this tap water. Many are wealthy enough to
purchase reverse osmosis water purifiers.
I think it is the most horrible dereliction in our history, that governmental puppets wouldchoose private, corporate greed over life and health.
Dupont / Chemours lied to North Carolina. They must be held accountable.
Esther Murphy
Wilmington, NC
From:Diane Arbour
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, March 14, 2020 10:45:13 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Chemours has made their profits at the expense of local citizens. It is time they pay back, although they can never
repair some of the damage done.
Diane Arbour
3409 6th Street Dr NW
Hickory, NC 28601-9092
From:Kenneth McKenzie
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 14, 2020 10:39:26 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities and an extremely important
wetland system for our state. Residents in the river basin have been exposed to high concentrations of PFAS for
decades. There is no safe level for continued exposure and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Kenneth McKenzie
1705 Athens Dr
Raleigh, NC 27606-2553
From:Nancy Fonvielle
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 13, 2020 9:57:15 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Nancy Fonvielle
6101 Sweetgum Hollow
Wilmington, NC 28409
From:Audrey Napier
To:SVC_DENR.publiccomments
Subject:[External] Genx
Date:Thursday, March 12, 2020 7:09:33 PM
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There needs to be a extension of 60 days.
Also there should be 3 more meetings in all cities affected!! There are many more coming up
positive also the fact Chemours is about 3 months behind checking water!
Audrey Napier
From:Walt Dietrich
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 12, 2020 11:48:06 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River. The law and Chemours effort to cleanup
must be sooner than later.
Also, any costs should not be passed to the taxpayer but to those who use their products and the consumers of their
products.
Walt Dietrich
429 Summerlea Dr
Fayetteville, NC 28311-1171
From:James Hoots
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 12, 2020 9:27:05 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
James Hoots
3455 Mountain View Rd
Germanton, NC 27019-8245
From:David Gardener
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Wednesday, March 11, 2020 8:12:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
David Gardener
110 Hidden Rock Ct
Cary, NC 27513
From:Ileana Clavijo
To:SVC_DENR.publiccomments
Subject:[External] Contamination of water
Date:Wednesday, March 11, 2020 5:34:12 PM
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Chemours contaminated our waters and they are responsible for all cleaning. I am tired of seeing industries getting
away with pollution. I live in Wilmington and I no longer drink the tap water.
Sent from my iPhone
From:Alanna Alanna Humphrey
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Wednesday, March 11, 2020 11:36:12 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Alanna Alanna Humphrey
302 Coston Rd
Richlands, NC 28574-7142
From:Ray Owens
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Wednesday, March 11, 2020 5:42:05 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Ray Owens
531 Manning Dr
Charlotte, NC 28209-3439
From:mauricio carvajal
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Tuesday, March 10, 2020 10:42:26 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
mauricio carvajal
El Viento Norte
Santiago, NC 92915
From:Susan Gail Auten
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 10, 2020 6:19:08 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Susan Gail Auten
3105 Sansbury Lane
Leland, NC 28451
From:Rachel Johnson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 10, 2020 4:18:35 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
We citizens are watching.
Rachel Johnson
202 Parkmont Dr
Greensboro, NC 27408
From:Bonney Brown
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Tuesday, March 10, 2020 3:15:35 PM
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Dear Department of Environmental Quality,
I was going to purchase a home in the Cape Fear river basin until I heard about this horrific siruation. Please, please
make them fix it completely. I 'm disappointed to see that Chemours continues to put its bottom line above the
health and safety of North Carolinians living near and downstream of their facility in the Fayetteville area. The
proposed plan put forward by Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Bonney Brown
210 W Barnes St
Nags Head, NC 27959-9647
From:Catherine Starkweather
To:SVC_DENR.publiccomments
Subject:[External] Re: Please require a full Chemours’ clean-up
Date:Tuesday, March 10, 2020 3:12:13 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Catherine Starkweather
110 Jennings Ln
Durham, NC 27713-2313
From:Gillian Scott
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Tuesday, March 10, 2020 1:22:58 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Gillian Scott
2224 Walnut Ridge Ct
Raleigh, NC 27610-6544
From:Patrick McLean
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 10, 2020 12:33:38 PM
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Dear Department of Environmental Quality,
Insufficient oversight of Chemours has resulted in unsafe living conditions for those near and downstream of their
facility in the Fayetteville area.
The proposed plan put forward by Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure.
Patrick McLean
PO Box 358
Montreat, NC 28757-0358
From:John Kalina
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 9, 2020 6:33:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
John Kalina
3624 Morris Farm Drive, Unit 2D
Greensboro, NC 27409
From:Mara Ruiz
To:SVC_DENR.publiccomments; SVC_DENR.publiccomments; SVC_DENR.publiccomments;SVC_DENR.publiccomments; SVC_DENR.publiccomments
Subject:[External] Chemours should pay for clean up, and should properly compensate the affected families
Date:Monday, March 9, 2020 6:21:45 PM
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attachment to report.spam@nc.gov
Dear Sirs,
When I started to write this letter, I was doing it in solidarity with all the
people affected by the Chemours contamination spill, now we count
ourselves among their victims.
It is time that big corporations be made accountable for their safety
failures. Especially if those failures result into people seeing the value of
their properties fall; family members getting sick; the loss of their
livelihoods; or even the loss of lives.
Making money should not be the only role of corporations, but being a
conscientious neighbor and a job provider.
Olga Jones
From:Darlene Parlett
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 9, 2020 3:33:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Darlene Parlett
1107 Millheim Court
Wilmington, NC 28411
From:Gail Sikes
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Monday, March 9, 2020 3:06:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Gail Sikes
313 E Church St
Rose Hill, NC 28458-1427
From:Jo Flynn
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Monday, March 9, 2020 2:48:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River.
DuPont has a history of not being held accountable for their toxic messes.We know the dangers from these
chemicals and the company's denials are unacceptable.
The river is a drinking source for downstream communities. Residents in the river basin have been exposed to high
concentrations of PFAS for decades. There is no safe level for continued exposure and Chemours must cutoff their
pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jo Flynn
210 NE 66th St
Oak Island, NC 28465-4631
From:Lydia Hardwick
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 9, 2020 2:21:05 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
The fact that Chemours continues to dump pollution into the water system shows they have no concern for public
health. We can no longer feel safe to drink the water or use the water for cooking in our own homes and have to
purchase bottled water.
Lydia Hardwick
4329 Ludi Mae Court
Charlotte, NC 28227
From:Marc Lewis
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 9, 2020 12:30:51 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Marc Lewis
9615 Hollyburgh Ter
Charlotte, NC 28215-7609
From:Donald Baker
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 9, 2020 12:21:04 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution. These types of chemicals are banned in Europe in 2030.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Donald Baker
6095 Shore Park Dr
Leland, NC 28451
From:Terrell Shortsleeve
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 9, 2020 12:18:52 PM
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Dear Department of Environmental Quality,
Chemours’ proposed plan leaves highly contaminated groundwater in place and will not stop pollution from
draining continuously into the Cape Fear River. The proposed plan is irresponsible and puts their profits ahead of
the safety of our drinking water.
Require Chemours to clean up their mess! In 2020 no one should have to worry about drinking clean water. Yet,
here in North Carolina, it is a CONSTANT problem.
Terrell Shortsleeve
6367 Havencrest Drive
Ocean Isle Beach, NC 28469
From:JTNL Jacobs
To:SVC_DENR.publiccomments
Subject:[External] Chemours Ground Water Plan
Date:Monday, March 9, 2020 11:43:27 AM
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attachment to report.spam@nc.gov
We live on the Cape Fear River in Castle Hayne, NC. The following
issues are of grave concern to me and my family:
1.) Chemours has polluted 45,000 acres of groundwater with toxic
chemicals and poisoned the public and water supplies for decades, yet now
it proposes to avoid paying what’s needed to protect people and our
communities.
2.) Chemours’ plan would leave highly contaminated groundwater at the site
and do little to stop pollution from leaking into people’s wells and into rivers
and streams.
3.) The DEQ is expected to ensure that Chemours—not families nearby and
downstream communities—pays the costs to clean up its pollution.
4.) Please ensure that Chemours will, going forward, put the health of North
Carolinians living near the facility, the Cape Fear River, and downstream
communities ahead of its bottom line. This proposed plan does not appear
to do enough to ensure the future.
Cordially,
Tom and Nancy Jacobs
3634 Rosewood Landing Drive
Castle Hayne, NC 28429
Sent from my iPad
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Subject:FW: public comment
Date:Monday, March 9, 2020 11:37:46 AM
Attachments:2020 03 01 public comment on proposed GW corrective action plan.pdf
From: Morris-McLawhorn, Bridgette R
Sent: Monday, March 2, 2020 1:14 PM
To: Holman, Sheila <sheila.holman@ncdenr.gov>; Lane, Bill F <Bill.Lane@ncdenr.gov>; Martin,
Sharon L. <sharon.martin@ncdenr.gov>; Lance, Kathleen C <kathleen.lance@ncdenr.gov>
Subject: public comment
Hello,
Please find attached a public comment we received in the mail today on the proposed groundwater
corrective action plan. Please note that only page 1 of 4 was in the envelope.
Thanks, Bridgette Morris-Mclawhorn
Executive Assistant to Secretary Michael Regan &Chief Deputy Secretary John NicholsonNorth Carolina Department of Environmental Quality (919) 707-8643 office(984) 328-2303 mobilebmorris@ncdenr.gov
217 West Jones Street1601 Mail Service CenterRaleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Subject:FW: public comments received
Date:Monday, March 9, 2020 11:37:35 AM
Attachments:2020 03 04 public comment on proposed GW corrective action plan (2).pdf
2020 03 04 public comment on proposed GW corrective action plan.pdf
From: Morris-McLawhorn, Bridgette R
Sent: Wednesday, March 4, 2020 5:39 PM
To: Holman, Sheila <sheila.holman@ncdenr.gov>; Lane, Bill F <Bill.Lane@ncdenr.gov>; Martin,
Sharon L. <sharon.martin@ncdenr.gov>; Lance, Kathleen C <kathleen.lance@ncdenr.gov>
Subject: public comments received
Hi,
Please find attached two more public comments on the proposed GW Corrective Action Plan. Please
let me know if there are others I should be sending these to.
Thanks,
Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &
Chief Deputy Secretary John NicholsonNorth Carolina Department of Environmental Quality (919) 707-8643 office(984) 328-2303 mobilebmorris@ncdenr.gov 217 West Jones Street
1601 Mail Service CenterRaleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Subject:FW: Public comments received
Date:Monday, March 9, 2020 11:37:30 AM
Attachments:2020 03 06 public comment on proposed GW corrective action plan 1.pdf
2020 03 06 public comment on proposed GW corrective action plan 2.pdf
2020 03 06 public comment on proposed GW corrective action plan 3.pdf
2020 03 06 public comment on proposed GW corrective action plan 4.pdf
2020 03 06 public comment on proposed GW corrective action plan 5.pdf
From: Morris-McLawhorn, Bridgette R
Sent: Friday, March 6, 2020 2:08 PM
To: Holman, Sheila <sheila.holman@ncdenr.gov>; Lane, Bill F <Bill.Lane@ncdenr.gov>; Martin,
Sharon L. <sharon.martin@ncdenr.gov>; Lance, Kathleen C <kathleen.lance@ncdenr.gov>
Subject: Public comments received
Good afternoon,
Please find attached 5 more public comments received via mail today on the proposed GW
Corrective Action Plan.
Thanks,
Bridgette Morris-MclawhornExecutive Assistant to Secretary Michael Regan &
Chief Deputy Secretary John NicholsonNorth Carolina Department of Environmental Quality (919) 707-8643 office(984) 328-2303 mobilebmorris@ncdenr.gov 217 West Jones Street
1601 Mail Service CenterRaleigh, NC 27699
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From:Martin, Sharon L.
To:SVC_DENR.publiccomments
Cc:Peterson, Kyle R
Subject:FW: [External] PFAS comments -Chemours CAP
Date:Monday, March 9, 2020 9:42:22 AM
Attachments:PFAS letter March2020.pdfimage001.png
From: Peterson, Kyle R
Sent: Monday, March 9, 2020 9:41 AM
To: Martin, Sharon L. <sharon.martin@ncdenr.gov>
Subject: FW: [External] PFAS comments
FYI – not sure if you have a holding place for these
Kyle Peterson
Assistant General Counsel
N.C. Dept. of Environmental Quality
Mailing Address: 1601 Mail Service Center, Raleigh, NC 27699-1601
Phone: (919) 707-8531
From: Scott, Michael
Sent: Friday, March 6, 2020 4:36 PM
To: Holman, Sheila <sheila.holman@ncdenr.gov>; Peterson, Kyle R <kyle.peterson@ncdenr.gov>
Subject: FW: [External] PFAS comments
Making sure this goes into the public comments on the CAP for Chemours.
From: Scott, Michael
Sent: Wednesday, March 4, 2020 11:44 AM
To: Woosley, Julie <julie.woosley@ncdenr.gov>; Mccarty, Bud <bud.mccarty@ncdenr.gov>; Ghiold,
Joe <joe.ghiold@ncdenr.gov>
Subject: Fwd: [External] PFAS comments
Fyi.
---------- Forwarded message ----------
From: David Paul Genereux <dpgenere@ncsu.edu>Date: Mar 4, 2020 10:49 AM
Subject: [External] PFAS commentsTo: "Scott, Michael" <michael.scott@ncdenr.gov>,"Smith, Danny"
<danny.smith@ncdenr.gov>Cc: "Wilson, Nat" <nat.wilson@ncdenr.gov>
CAUTION: External email. Do not click links or open attachments unless you verify. Send allsuspicious email as an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Michael, Danny,
I've attached a letter with a few comments/suggestions related to theCorrective Action Plan (CAP) offered by Chemours, focusing on "off-site"aspects of groundwater contamination outside the Fayetteville Worksproperty. Best regards,
Dave
--~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~David Genereux, Ph.D.
Professor, Dept. of Marine, Earth, & Atmospheric SciencesJordan Hall, Room 5135North Carolina State UniversityRaleigh, NC 27695-8208 USA
phone: 919-515-6017e-mail: genereux@ncsu.edu~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
1
Marine, Earth, and Atmospheric Sciences
5135 Jordan Hall
North Carolina State University
Raleigh, NC 27695-8208
919-515-6017
genereux@ncsu.edu
March 4, 2020
Mr. Michael Scott, Director, Division of Waste Management
Mr. Danny Smith, Director, Division of Water Resources North Carolina Department of Environmental Quality 217 West Jones Street Raleigh, NC 27603
Dear Mr. Smith and Mr. Scott: I'm writing with a few comments related to the Corrective Action Plan (CAP) offered by Chemours for the PFAS problem at and around their facility in Bladen County, NC. My comments here focus
on "off-site" aspects of groundwater contamination, outside the Fayetteville Works property.
Pilot Program for Deeper Private Water Supply Wells From the DEQ web site, I understand that the Revised Consent Order requires that Chemours provide permanent drinking water supplies (in the form of either a public waterline connection or
whole building filtration system) for those with drinking water wells having GenX above 140 parts
per trillion, and provide under-sink reverse osmosis (RO) drinking water systems for well owners with combined concentrations of certain PFAS above 70 parts per trillion or concentrations of certain individual PFAS above 10 parts per trillion.
While granular activated carbon (GAC) filters and RO systems can be effective at removal of PFAS
from water, it seems possible that some wells drawing in PFAS-contaminated groundwater may continue to do so for many years, perhaps decades, requiring a very long-term commitment to careful maintenance of such in-home filtration systems for the protection of human health. Also, at a February 26, 2020 public forum with researchers and Chemours area residents at Fayetteville
State University, there was mention of issues with microbial growth in GAC systems, and of routing
of PFAS-concentrated "rejectate" (waste water) from RO systems into septic systems (and thus back into the ground). As an alternative to in-home treatment systems, I suggest that DEQ consider requiring Chemours to
fund a pilot program that involves drilling deeper private or shared community water supply wells
that reach beneath contaminated groundwater, to provide clean groundwater to homes that currently have wells contaminated with PFAS. Such wells could be drilled into the Upper Cape Fear Aquifer, or, with caution, clean deeper parts of the Black Creek Aquifer in some areas (some parts of this aquifer do have PFAS contamination), or perhaps other suitable subsurface formations.
2
I think a useful pilot program would utilize only high-quality professional drillers, and have
oversight from groundwater experts at DEQ and NC universities. No bridging of confining units with gravel packs would be allowed; where a borehole runs through a confining unit, grout would be required in and above the annual space, to ensure this space does not become a conduit for inter-aquifer movement of PFAS. I imagine a pilot program could begin with 10 or so carefully drilled
and installed wells. If it is successful in supplying residents with good quality groundwater that is
essentially PFAS free or extremely low in PFAS, the program could be expanded at Chemours expense. At the February 2020 symposium I mentioned above, one area resident said she had asked
Chemours to provide a deeper well, and her request was refused. A second resident said she had
obtained quotes for a deeper water supply well, with estimates in the range of $15k. If such wells are successful, they could represent an essentially permanent solution for residents with shallower contaminated wells, possibly without the decades-long complication of in-home treatment. I can't confirm the resident's estimate of $15k; if each well cost twice that much (which seems unlikely),
even 100 wells would cost only $3 million, a relatively small sum for Chemours in the context of
the overall PFAS problem and the solutions they are pursuing. The proposed program could be seen as meeting Chemours' objective to "Provide replacement drinking water" (page 54 of the CAP). According to page 76 of the CAP, "Chemours is working
with NCDEQ to identify locations where public water is available and can be provided
to private residents for less than $75,000 per affected party". Deeper wells may be cost-competitive relative to new connections to existing public water supplies. Watershed-Scale Monitoring of PFAS Export My understanding is that the CAP does not involve mitigation of stream export of PFAS into the
Cape Fear River from tributary watersheds near Chemours (Georgia Branch, Willis Creek, and un-named tributaries on the east side of the river, all significantly contaminated with PFAS). It seems possible there could be some monitoring of PFAS in some streams, but the language in the CAP is not very clear on this, and even if streams are included in the "baseline monitoring" (page 86 of the
CAP), it seems that it may be for only one year.
One of the most important practical questions concerning the "off-site" groundwater contamination is, assuming the source (mainly air emissions) has been nearly eliminated, how long will it take for the PFAS contamination to flush out of the groundwater system by groundwater discharge into
streams? The answer is not well known but it may be decades. In my opinion, considering the
large scale of the contamination, it's in the best interest of the state and local residents to have an integrated large-scale measure of the rate of PFAS loss from the groundwater system, rather than rely only on point measurements at a limited number of wells. Stream export can provide such a measure.
I suggest that long-term stream discharge monitoring stations be established on Georgia Branch, Willis Creek, and at least one tributary on the east side of the Cape Fear River, and that these stations be used to collect continuous records of stream discharge (as at USGS gauging stations) and frequent measurements of PFAS in the stream water. Design, construction, and operation of the
stations would be through experts at DEQ, USGS, and NC universities, at Chemours expense.
3
Each station would provide integrated watershed-scale data on the rate of PFAS export from the
watershed (a good metric for the rate of PFAS discharge from groundwater), and the rate of change of PFAS export over time. This watershed-scale assessment of the resource would complement the information from point measurements at individual wells and provide what is likely the best indication of the overall rate of progress in recovery of the water quality in the affected groundwater
systems.
Chemours is claiming enormous reductions in PFAS emissions to air in the last year or two, and if that is true and the clock has truly started on PFAS flushing from the groundwater, now is the perfect time to begin the suggested monitoring.
Collection of RO Rejectate If the anecdotal information I've heard about RO system rejectate being routed to on-site septic systems is true, then I would suggest that there is a better way. I understand that the primary goal of an in-home RO system is to provide clean water with little or no PFAS to the residents, and it's not
intended as an aquifer remediation project. On the other hand, if a relatively small but concentrated
PFAS waste stream exists and can be easily captured (as with RO systems), it would seem disappointing to release it back into the aquifer, especially given the impact of this problem on residents and the state of NC, and the ready availability and proximity of a responsible party with means. A more desirable solution would seem to be Chemours-funded collection of all RO system
rejectate, followed by responsible destruction of the waste through thermal oxidation or at least safe
disposal through deep well injection.
Very Truly,
David Genereux, PhD Professor Department of Marine, Earth, and Atmospheric Sciences NC State University
From:Christopher Voigt
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Monday, March 9, 2020 9:39:09 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Christopher Voigt
1314 Rothes Rd
Cary, NC 27511-5023
From:Matthew McCoy
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Monday, March 9, 2020 8:39:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Matthew McCoy
5800 Perennial Ln
Wilmington, NC 28403-3585
From:Alicia Willard
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 9, 2020 2:27:06 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Alicia Willard
1554 Danny Bell Rd
Asheboro, NC 27205-2026
From:Connie Raper
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 9, 2020 1:48:11 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Connie Raper
2614 Woodmont Dr
Durham, NC 27705
From:Lynn Elliott
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 9, 2020 1:48:06 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Lynn Elliott
2614 Woodmont Dr
Durham, NC 27705
From:Gloria Kanoy
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 8, 2020 10:54:06 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Gloria Kanoy
2000 Whitmore Circle
Chapel Hill, NC 27516
From:Julie Beckwith
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 10:21:08 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Julie Beckwith
3745 Swarthmore Rd
Durham, NC 27707
From:Cindy Elmore
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 8, 2020 8:42:09 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Cindy Elmore
758 Winterfield Dr
Winterville, NC 28590-8484
From:Mary Baldwin
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 7:03:15 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mary Baldwin
6516 Red Cedar Rd
Wilmington, NC 28411-4730
From:Eva Duggins
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 8, 2020 6:06:17 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Eva Duggins
2212 NC Highway 731 W
Mount Gilead, NC 27306-8624
From:Carole Newsome
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 5:57:59 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Carole Newsome
7211 Emerald Dr
Emerald Isle, NC 28594-3010
From:Janice Stevenson
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 8, 2020 5:33:07 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Janice Stevenson
21 Von Ruck Terrace
Asheville, NC 28801
From:Paula Curry
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 8, 2020 3:39:07 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Paula Curry
504 N Main Ave
Maiden, NC 28650-1124
From:Michael Blake
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 3:12:06 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Michael Blake
2024 Klein Rd
Wilmington, NC 28405-2718
From:mary frazer
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 8, 2020 1:19:34 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
mary frazer
1716 Evergreen Ave
Raleigh, NC 27603-3078
From:Beverly McIllwain
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 12:12:49 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Beverly McIllwain
5413 Breakwater Dr
Granite Falls, NC 28630-8807
From:Jonathan Brown
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 8, 2020 11:24:07 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Jonathan Brown
7218 Chaddsley Dr
Huntersville, NC 28078-2277
From:Helena Guiles
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 9:42:50 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Helena Guiles
3722 Park Rd Unit Q
Charlotte, NC 28209-2162
From:Naomi Johnson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 8, 2020 3:21:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Naomi Johnson
225 Warrior Woods Rd
Carthage, NC 28327-8991
From:Zack Heinkel
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 7, 2020 10:54:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Zack Heinkel
115 Ferris Wheel Ct
Cary, NC 27513-3618
From:Patricia Rister
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 8:51:04 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Patricia Rister
323 Winding Woods Way
Beaufort, NC 28516-7411
From:Chelsea Brooks
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, March 7, 2020 8:42:09 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Chelsea Brooks
1107 Nonya St
Pleasant Garden, NC 27313
From:Connie Raper
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 7:39:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Connie Raper
2614 Woodmont Dr
Durham, NC 27705-2760
From:Janet Kuykendall
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 7, 2020 5:13:01 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Janet Kuykendall
973 Mauney Cove Rd.
Waynesville, NC 28786
From:Roger Chellew
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 7, 2020 4:42:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Roger Chellew
63 Brazil Nut Ln
Smithfield, NC 27577-8783
From:Ann Mccray
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 1:45:06 PM
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Dear Department of Environmental Quality,
For all of us, there comes a day when we realize we could have done more, better, selflessly and been rewarded
beyond measure psychologically for being our best selves. Sounds like a sappy sentimental self-help thought except
that it's not.
When the world was created, North Carolina was blessed with abundant resources and limitless natural beauty. I'm
not an NC native bragging. I was born and bred elsewhere, but I've moved back to North Carolina three times
because these attributes call me. Now, after nearly 17 years in Wilmington, my heart sinks for the wide wonderful
Cape Fear River, a needless victim to human greed and ecological indifference.
The River is tainted, dismally so, by people who seem to know the cost of everything but the value of nothing. And,
yet, maybe even that worn phrase falls short in appraising this dire situation because a priceless natural resource has
been squandered.
People of conscience in a position to remedy this disaster for the greater good must rise to the occasion of a
thorough, permanent solution to the pollution, or we will all suffer even more. Are you such a person? Such a
committee? Such a department?
No half-measures will do now in rectifying the River. You know that. We all know that. The only redemption is in
doing the right thing, regardless of the monetary cost. Money was never meant to be a value; it's a means to support
and improve life. Please consider this and hold those responsible accountable in full measure for all damages.
May your vision and commitment to North Carolina be as wide and beautiful as the River itself.
Most sincerely,
Ann Parks McCray
Ann Mccray
1712 Signature Pl
Wilmington, NC 28405-4130
From:Margaret Norris
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, March 7, 2020 12:21:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Margaret Norris
51 Carrisbrooke Ln
Winston Salem, NC 27104
From:marilyn shane
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 11:36:12 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
marilyn shane
1412 Milton St
Spring Lake, NC 28390-2512
From:jeff bohan
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 7, 2020 11:36:09 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
jeff bohan
900 Teague Rd
Winston Salem, NC 27107-6933
From:Kevin Watson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 10:18:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Kevin Watson
3 West Raleigh Rd
Asheville, NC 28803-1144
From:Kathleen Laub
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, March 7, 2020 7:00:07 AM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Kathleen Laub
908 Warren St
Clinton, NC 28328
From:Ellen Watson
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, March 7, 2020 3:09:07 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Ellen Watson
248 PO
Bethania, NC 27010
From:Julie Nye
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, March 7, 2020 12:06:06 AM
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Dear Department of Environmental Quality,
The proposed plan put forward by Chemours is inadequate and leaves communities at risk. Please make Chemours
clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear, and stop burdening
families with continued exposure and health risks.
Chemours must be held fully accountable for the costs associated with the cleanup of their own pollution and
damages.
Julie Nye
407 River Trace Dr
Rougemont, NC 27572-6500
From:Charles Allen
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 11:09:06 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Charles Allen
1592 S Oak Dr
Shelby, NC 28150-3207
From:amity pelfrey
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 11:09:05 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
amity pelfrey
5907 Applewood Lane
Raleigh, NC 27609
From:Mary Combs
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 10:42:22 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mary Combs
1602 Airport Rd
Marion, NC 28752-3882
From:Viv Graves
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 10:36:07 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Viv Graves
1163 John Sandling Rd
Franklinton, NC 27525-8907
From:Timothy Throndson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 7:42:54 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Timothy Throndson
7437 Capstone Drive
Raleigh, NC 27615
From:Liz Davis
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 6:21:04 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution. Chemours has been well aware of what their pollution is doing but they want
to continue polluting because it's cheaper and they can benefit financially.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Liz Davis
586 Salola Ln
Brevard, NC 28712-8489
From:Christopher Randall
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 6:18:19 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Christopher Randall
203 E. Sunset Blvd.
Cove City, NC 28523
From:Sandra Koritz
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 6:12:17 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Sandra Koritz
4 Cactus Ct Unit B
Greensboro, NC 27410-9738
From:Donna Killette
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 5:27:27 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Donna Killette
13472 NC Highway 48
Littleton, NC 27850-8987
From:Jeff Kulp
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 5:03:06 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jeff Kulp
5417 Oldtowne Rd
Raleigh, NC 27612-6111
From:William Lasley
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 4:51:05 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
William Lasley
1800 N. Elm St., Apt. F-3
Greensboro, NC 27408
From:Diane Nelson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 4:21:57 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Diane Nelson
244 Sweet Bay Pl
Carrboro, NC 27510
From:Deborah Finn
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 3:45:52 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Deborah Finn
750 Weaver Dairy Rd
Chapel Hill, NC 27514-1438
From:Alex East
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 2:54:15 PM
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Dear Department of Environmental Quality,
Dear Department of Environmental Quality (DEQ),
I work in PFAS chemical exposure research, and although my comment is not a reflection of my employer, agency,
or affiliates, it is my personal recommendation that you take full measures to stop Chemours from polluting Cape
Fear River, and demand a full cleanup of the operation.
I am embarrassed that a Hollywood celebrity has toured this state advocating for basic human rights legislation,
asking only that our communities are not poisoned by the externality of a multinational billion-dollar company. We
ask that you take full punitive action against Chemours who have polluted our state's drinking water.
Children are at especially at risk group in relation to PFAS - and water is a common route pathway. Please uphold
our existing state legislation and hold this company accountable for polluting our great state, citizens, and
ecosystems.
Thank you for your services to our state and communities.
Best Regards,
Alexander East
Alex East
207 Marvista Ct
Cary, NC 27518
From:Rebecca Ann Helgesen
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 2:39:59 PM
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Dear Department of Environmental Quality,
How can anyone possibly justify NOT requiring a total clean-up of this poisoned groundwater and soil by those who
poisoned it? It's as bad as letting a murderer off the hook because he or she can make you lots of money. And any
rationale for allowing a partial, ineffective clean-up is foundationally nonsensical.
Only full-home filtration systems can protect people, and most people can't afford them or are dependent on
landlords/owners to provide them, transferring the burden of protecting public health to citizens and owners, rather
than Chemours, which caused the problem.
As you know, PFAS in the soil exposes people through other pathways than drinking water, including fruits and
vegetables grown in local gardens.
I'm very concerned, and urge DEQ to require Chemours to do a full cleanup of soil and groundwater contamination.
It is Chemours' responsibility to clean up. Their partial proposal completely disregards public health now and for
future generations. Your job is to protect the public health, and I urge you to do that by rejecting Chemours'
indifferent proposal and requiring a full cleanup.
Rebecca Ann Helgesen
902 Shellbrook Court, Apt 3
Raleigh, NC 27609
From:Karen Santucci
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 2:30:17 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Karen Santucci
4951 Lombardy Ln
Winston Salem, NC 27103-5213
From:Arthur Bluethenthal
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 2:15:16 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Arthur Bluethenthal
5 Stevendale Ct
Greensboro, NC 27410-3700
From:Shirley May Cleveland
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 2:02:39 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Shirley May Cleveland
109 Whitehaven Ln.
Cary, NC 27519
From:Joy Fowler
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 1:58:50 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Be responsible. Clean up after yourselves! Water is life!
Joy Fowler
214 Hurdle Mills Road
Cedar Grove, NC 27231
From:Rob Allyn
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 12:40:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Rob Allyn
59 Luther Cove Rd
Candler, NC 28715
From:Joseph Allen
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 12:34:35 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Joseph Allen
200 Charlotte Ct
Clayton, NC 27520-7082
From:Kirsten Hall
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 12:30:14 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River. Whenever I hear a call to deregulate
businesses to spur economic growth I instantly point to the irresponsible actions of Chemours and Duke Energy.
This pollution has become a cautionary tale, but if there are no real consequences then takeaway for other businesses
will be that irresponsibility will be rewarded.
Kirsten Hall
214APoplar St
Chapel Hill, NC 27516
From:Debbie Kenyon
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 12:21:20 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Debbie Kenyon
509 Gablefield Ln
Apex, NC 27502-1361
From:Judith Porter
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 11:38:10 AM
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Dear Department of Environmental Quality,
I urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS into the Cape
Fear River. The river is a drinking source for downstream communities. Residents in the river basin have been
exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and Chemours
must cutoff their pollution.
Please demand that Chemours pursue a full cleanup of its contamination and halt the release of PFAS-laden
groundwater into the Cape Fear River.
Judith Porter
927 Mulberry Mill Rd
North Wilkesboro, NC 28659-7706
From:Elaine Molnar
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 11:11:17 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Elaine Molnar
4106 Brookfield Way
Southport, NC 28461
From:Bonnie Westbrook
To:SVC_DENR.publiccomments
Subject:[External] Comments regarding Chemours and GenX
Date:Friday, March 6, 2020 11:03:48 AM
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Dear Department of Environmental Quality,
I'm very concerned about our water quality and the effects it could have on my and my family’s health. So I’m very
disappointed to see that Chemours continues to put its bottom line above the health and safety of North Carolinians
living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by Chemours is
not adequate and leaves communities at risk. Your department needs to hold them truly accountable and also
impose stiff fines to keep them and other companies from polluting in the future! Please use the fines to fund more
studies into the effects of various PFAS so that specific levels allowed can be determined for more compounds.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear
River, and stop burdening residents (and even tourists) with continued exposure and health risks. The company
needs to be held fully accountable for all costs associated with cleaning up their own pollution, as well as damages.
Since the Federal Government and the EPA are doing whatever the President and lobbyists want to weaken all
environmental protections, we need to be able to count on our state government to step up and do more. Thank you
for your hard work to protect us from polluters.
Bonnie Westbrook
3795 Ridge Crest Dr
Southport, NC 28461-8177
From:Yvonne` Sherman
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 11:01:40 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Yvonne` Sherman
1400 Olde Cedar Court
Davidson, NC 28036
From:John Miller
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 10:53:30 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
John Miller
72 N Market St Apt 68
Asheville, NC 28801-2920
From:Pauline Crawshaw
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 10:24:25 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
These chemicals are harmful to all residents from birth to senior citizens. Doing just a part of a cleanup will not help
the communities in the area. All of the chemicals must be removed from the ground and water ways in the area.
Filters will never be able to do a complete job.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Pauline Crawshaw
3306 S Heritage Dr
Hendersonville, NC 28791-3555
From:Susan Hannah
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 9:12:21 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Susan Hannah
476 Caldwell Dr SE
Concord, NC 28025-3602
From:Lois Hoot
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 9:03:09 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Lois Hoot
405 Alderson Rd
Washington, NC 27889-3101
From:Bunny Simoneau
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 8:51:52 AM
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Dear Department of Environmental Quality,
I am fed up with corporate profits being prioritized over public health. If a corporation proves that it cannot operate
without poisoning people, it needs to fail. I'm writing to urge the NC Department of Environmental Quality to make
Chemours halt the discharge of all PFAS into the Cape Fear River. The river is a drinking source for downstream
communities. Residents in the river basin have been exposed to high concentrations of PFAS for decades. There is
no safe level for continued exposure and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Bunny Simoneau
10112 Lafoy Dr
Huntersville, NC 28078-4659
From:Susan Broadhead
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 8:51:51 AM
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Dear Department of Environmental Quality,
The Cape Fear River is an important resource for the people who live in its environs. It belongs to the public, and
should be kept safe and unpolluted, which means effectively cleaning up contamination.It is the responsibility of
those who polluted it to
do this job.
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Susan Broadhead
48 Full Circle Trl
Black Mountain, NC 28711-6075
From:Mark Shapiro
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 8:48:27 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mark Shapiro
1021 W Markham Ave
Durham, NC 27701-1528
From:Cora Brazell
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 8:18:16 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Cora Brazell
5005 Oleander Dr
Wilmington, NC 28403-7016
From:Stan Bozarth
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, March 6, 2020 7:36:20 AM
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Dear Department of Environmental Quality,
The PFAS in our drinking water is the result of Chemours' negligence and abdication of responsibility. We're being
poisoned and they simply keep finding ways to keep operating and pollute our water and our health. I urge DEQ to
require Chemours to do a full cleanup of soil and groundwater contamination and to pay for whatever filtration
system is required by water utilities to provide safe, clean drinking water. PFAS in the soil can expose community
members through other pathways than drinking water, including fruits and vegetables grown in local gardens. The
community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup and to pay any and all damages due to their neglect.
Stan Bozarth
1310 Legacy Ln
Wilmington, NC 28411
From:Rebecca Showalter
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 7:24:21 AM
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Dear Department of Environmental Quality,
As a 25 year North Carolinian, I have always trusted that the water that my family drinks is safe, and that my
government would keep it safe. I'll be honest that I am losing faith that this will continue to be true. Chemours
betrayed us; now, the question is whether they will be held accountable by you, our representatives.
I'm so disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Rebecca Showalter
921 Walkertown Dr
Raleigh, NC 27614
From:David Collins
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, March 6, 2020 7:24:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
David Collins
3912 Carolina Beach Rd
Wilmington, NC 28412-7361
From:Betty Horan
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 6:06:11 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Betty Horan
40178 Leslie Ln
Avon, NC 27915
From:Theresa Waldspurger
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 5:30:15 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Theresa Waldspurger
PO Box 271, 680 W King St
Boone, NC 28607
From:Keith Bates
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, March 6, 2020 12:33:10 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Keith Bates
212 Thomas Trail
Reidsville, NC 27320
From:Tamara Imperiale
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, March 6, 2020 12:12:17 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Tamara Imperiale
103 Shore Lake Dr Apt H
Greensboro, NC 27455-1461
From:Pat Momich
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 10:42:27 PM
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Dear Department of Environmental Quality,
We learn to clean up our own messes as small children. Now Chemours needs to clean up its mess. It's irresponsible
to put profit above the health and safety of North Carolinians living near and downstream of their facility in the
Fayetteville area. The proposed plan put forward by Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Pat Momich
7839 Nc 208 Hwy
Marshall, NC 28753-7536
From:Alan Linn
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 10:36:11 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
So with all that being said, my question to you (DEQ), is why are you dragging your feet in getting this clean-up
started?
Do you not care about the health and welfare of the citizens living in these areas, just because you don't live there,
but what would you do if these companies would start building more of their plants down the street from your
homes?
I'll bet you wouldn't waste any time in getting the ball rolling in stopping those builds. Am I right ??
Alan Linn
2115 Derby St
Hickory, NC 28602
From:Joanne Nikides
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 10:06:44 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
This is an outrage.
Joanne Nikides
5106A Murphy School Rd
Durham, NC 27705-8037
From:Donald Baker
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 9:39:55 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution. Europe has already banned these chemicals so why is the United States so far
behind in protecting humans???
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Donald Baker
6095 Shore Park Dr
Leland, NC 28451-6701
From:Deborah Byerly
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 9:37:14 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Deborah Byerly
PO Box 114
Lewisville, NC 27023-0114
From:Brenda Delima
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 9:21:43 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Polluted water affects so much more than just humans, it also affects the animal and plants it comes into contact
with as well. In turn, these things harm whatever they come into contact with as well, such as wildlife eating a
contaminated animal or plant.
Chemours, YOU made this mess, YOU need to clean it up. STOP polluting our water!
Brenda Delima
105 Barnbridge Ct
Cary, NC 27519-6667
From:Joan Beard
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 8:45:33 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Joan Beard
510 Hickory Leaf Ct
Lumberton, NC 28358-2336
From:Steven Tracy
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 8:39:41 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Steven Tracy
1118 Heatherloch Dr
Gastonia, NC 28054-6442
From:pam hall
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 8:18:55 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
pam hall
131 Woodland Dr Apt 105
Elkin, NC 28621-2469
From:Sheila Jones
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 8:18:17 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Sheila Jones
6719 Mintwood Ct
Wilmington, NC 28405-7752
From:James Bengel
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 8:10:36 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
James Bengel
20 Canterbury Ct
Wendell, NC 27591
From:Linda Hartford
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 7:42:38 PM
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Dear Department of Environmental Quality,
In kindergarten, I learned that when I made a mess I should clean it up. The CEOs of Chemours should be held just
as responsible as kindergartners.
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Linda Hartford
1403 Ashewood Cir
Asheboro, NC 27203-3688
From:J S
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 7:39:27 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
J S
14535 Harmonious St
Charlotte, NC 28278
From:Jack Mahrt
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 7:24:37 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jack Mahrt
6705 April Mist Trl
Huntersville, NC 28078-2313
From:Jeffrey Snow
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 7:15:28 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jeffrey Snow
3108 Hunters Bluff Dr
Raleigh, NC 27606-9623
From:Cynthia Radabaugh
To:SVC_DENR.publiccomments
Subject:[External] Water is the Source of Life
Date:Thursday, March 5, 2020 7:12:10 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Cynthia Radabaugh
9259 Bonnie Briar Cir
Charlotte, NC 28277
From:Tiffany Ehnes
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 7:00:04 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tiffany Ehnes
429 Rainbow Rd
Advance, NC 27006-6710
From:Mara Ruiz
To:SVC_DENR.publiccomments; SVC_DENR.publiccomments; SVC_DENR.publiccomments;SVC_DENR.publiccomments; SVC_DENR.publiccomments
Subject:[External] Chemours should pay for clean up, and should properly compensate the affected families
Date:Thursday, March 5, 2020 6:44:24 PM
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attachment to report.spam@nc.gov
When I started to write this letter, I was doing it in solidarity with all the
people affected by the Chemours contamination spill, now we count
ourselves among their victims.
It is time that big corporations be made accountable for their safety
failures. Especially if those failures result into people seeing the value of
their properties fall; family members getting sick; the loss of their
livelihoods; or even the loss of lives.
Making money should not play the only role of corporations, but being
and conscientious neighbor and job provider.
Olga Jones
From:Catherine Carter
To:SVC_DENR.publiccomments
Subject:[External] Chemours and GenX
Date:Thursday, March 5, 2020 6:42:30 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Catherine Carter
241 Oak Forest Drive
Cullowhee, NC 28723
From:Brinkley Hutchings
To:SVC_DENR.publiccomments
Subject:[External] Ensure Chemours Pays for Cleanup
Date:Thursday, March 5, 2020 6:10:40 PM
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attachment to report.spam@nc.gov
Hello,
I would like to submit a public comment about Chemours. Please ensure the health of
North Carolinians by holding Chemours to the strictest environmental standards and
making them pay for the cost of cleaning up their pollution. The health of North
Carolina residents must be protected.
Thank you,
Brinkley Hutchings
-- Brinkley HutchingsLeadership Coach [brinkleyhutchings.com]
Founder/Director of Nature Connect NC [natureconnectnc.org] and Nature Connect Alabama [natureconnectalabama.org]
251-747-7846
From:Frank Lorch
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 5:54:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Frank Lorch
1522 Lynway Dr
Charlotte, NC 28203-6044
From:Sue-Ann Rush
To:SVC_DENR.publiccomments
Subject:[External] Chemours Bad Deal for clean up.
Date:Thursday, March 5, 2020 5:30:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Sue-Ann Rush
1060 Stonebridge Ln
Leland, NC 28451-4109
From:Patrick Stroud
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 5:24:08 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Patrick Stroud
4394 Privet Dr
Kernersville, NC 27284-6731
From:Michelle Wells
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 5:21:15 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Michelle Wells
113 Modena Dr
Cary, NC 27513
From:Lynn Wood
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 5:12:52 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Lynn Wood
Palm Harbor Drive
Murphy, NC 28906
From:Carol Keeser
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 5:12:52 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Carol Keeser
1976 Tiger Eye Court
Winston Salem, NC 27127-8008
From:Tony Farino
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 5:12:06 PM
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Dear Department of Environmental Quality,
Let’s put it this way, take a glass of water from that river and you drink it. If you cannot, then you know better and
they must stop polluting.
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination.
Further, PFAS in the soil can expose community members through other pathways than drinking water, including
fruits and vegetables grown in local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tony Farino
6813 Stillmeadow Dr
Charlotte, NC 28277-9136
From:Gary Andrew
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 5:06:53 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Would you want to drink
water sourced from this river? Many residents can not afford to purchase bottled water. And residents in the river
basin have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure
and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Gary Andrew
319 N Downing St
Davidson, NC 28036-0269
From:Barbara Thornton
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 5:00:27 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Barbara Thornton
7111 Union Grove Church Rd
Chapel Hill, NC 27516-5267
From:Diane Thomas
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ plan is not sufficient
Date:Thursday, March 5, 2020 5:00:14 PM
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Dear Department of Environmental Quality,
Please require Chemours to do a full and complete cleanup of soil and groundwater contamination. Even residents
who have had filtration systems installed are not fully protected from contaminated groundwater if they do not have
full-home filtration systems. Further, PFAS in the soil can expose community members through other pathways than
drinking water, including fruits and vegetables grown in local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Diane Thomas
110 Pinecrest Rd
Durham, NC 27705-5813
From:Luke Williams
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 4:51:33 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Luke Williams
223 Rouen Ct
Wilmington, NC 28412
From:Mary Alden Hanson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 4:45:37 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Mary Alden Hanson
7412 Rocky Ridge Rd.
WAKE FOREST, NC 27587
From:Clarice Reber
To:SVC_DENR.publiccomments
Subject:[External] Chemours" Corrective Action Plan
Date:Thursday, March 5, 2020 4:41:15 PM
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To Whom It May Concern at the Department of Environmental Quality:
I am writing to oppose Chemour’s proposed groundwater corrective action plan. It does not do
enough to protect our health or environment. Chemours has polluted thousands of acres ofgroundwater with toxic chemicals and poisoned public and private water supplies. Their
proposed groundwater corrective plan leaves highly contaminated groundwater at the site anddoes little to prevent that bad water from entering private wells and the river which supplies
most of Wilmington’s drinking water leaving thousands and thousands of NC citizens at riskfor polluted drinking water. Already, my grandchildren must carry bottled water to school. NC
must move swiftly to reduce the risk of water poisoning with PFAS/GENX pollution.
Furthermore, we the citizens of NC should not pay the clean up bill. My families’ water billsare going up in order to clean PFAS including GENX from our drinking water already in order
to improve our water treatment plants. These chemical are in the Cape Fear River. Chemoursmade the profit from bad practices, their shareholders should take the financial hit, not NC
citizens.
DEQ’s mission is to "provide science-based environmental stewardship for the health andprosperity of All North Carolinians.” Please emphasize both the health and prosperity portion
of your mission. Require Chemours to remove contaminated groundwater at their site at theircost.
Thank you.
Clarice Reber claricereber@gmail.com
7919 Blue Heron Dr W, #305Wilmington, NC 28411
From:Bonnie Harvell
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 4:03:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Bonnie Harvell
553 Oak Hammock Dr
Harkers Island, NC 28531-9692
From:Cindy Taylor
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 4:00:04 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Cindy Taylor
1315 Beechgrove Ln
Chapel Hill, NC 27516-5398
From:Brenda Tenerelli
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 3:57:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Brenda Tenerelli
30 Roberts Rd.
Weaverville, NC 28787
From:Ellen Rothenberg
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 3:54:04 PM
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Dear Department of Environmental Quality,
Please, please require Chemours to stop, desist and clean up our water! I can’t believe they’re still able to do what
they’re doing and leave the cleanup to us! If folks can afford it, they’re being forced to pay for specialized filters and
the rest are being forced to put themselves into harms way because they can’t afford to spend $$ to clean our already
expensive coastal water. I’m writing to urge the NC Department of Environmental Quality to make Chemours halt
the discharge of all PFAS into the Cape Fear River. The river is a drinking source for downstream communities.
Residents in the river basin have been exposed to high concentrations of PFAS for decades. There is no safe level
for continued exposure and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Ellen Rothenberg
43 Goldsboro St
Ocean Isle Beach, NC 28469-7645
From:Linda Peterson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 3:30:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Linda Peterson
404 Woodlark Ct
Indian Trail, NC 28079
From:Carole Newsome
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 3:24:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Carole Newsome
7211 Emerald Dr
Emerald Isle, NC 28594-3010
From:Marie Michl
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 3:07:35 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Marie Michl
108 Whispering Pines Dr
Rocky Mount, NC 27804
From:Robert Baker
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 3:00:52 PM
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Dear Department of Environmental Quality,
They should all be in jail. They poisoned hundreds of thousands!!! I'm very concerned about PFAS in drinking
water and urge DEQ to require Chemours to do a full cleanup of soil and groundwater contamination. Even
residents who have had filtration systems installed are not fully protected from contaminated groundwater if they do
not have full-home filtration systems. Further, PFAS in the soil can expose community members through other
pathways than drinking water, including fruits and vegetables grown in local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Robert Baker
PO Box 1093
Wilmington, NC 28402-1093
From:Stephen Blake
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 2:51:51 PM
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Dear Department of Environmental Quality,
The NC Department of Environmental Quality must make Chemours halt the discharge of all PFAS into the Cape
Fear River. The river is a drinking water source for downstream communities and local residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Corporate polluters are not above the law. Please protect our drinking water by demanding that Chemours pursue a
full cleanup of its contamination, including halting the release of PFAS-laden groundwater into the Cape Fear River.
Stephen Blake
2114 Hollyrood St
Winston Salem, NC 27127-2928
From:Mary Goodkind
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 2:51:51 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Mary Goodkind
23 Ridgefield Pl
Asheville, NC 28803-3019
From:Mark Andersen
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 2:39:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mark Andersen
18404 John Connor Rd.
Cornelius, NC 28031
From:Ken House
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 2:36:06 PM
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Dear Department of Environmental Quality,
We need to protect our waterways to maintain drinking water quality and to protect our vital coastal ecosystem. We
have identified a problem area, and we should work together to find a permanent solution.
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Ken House
412 Parkview Crescent
Chapel Hill, NC 27516
From:Scott Jordan
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 2:33:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Scott Jordan
264 Wildwood Rd
Rutherfordton, NC 28139
From:Catherine Thompson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 2:24:05 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages. I
Catherine Thompson
140 Mount Airy Rd
Southport, NC 28461
From:Kim Adams
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 2:21:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Kim Adams
516 Melrose Avenue Ext
Tryon, NC 28782-3374
From:Katherine Crothers
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 2:21:05 PM
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Dear Department of Environmental Quality,
Dear Sir or Ma’am,
As a mother and grandmother living in the Thyroid Cancer Hotspot of 28117....
Please keep our NC water, air and soil safe.
We may lose the value of our home but our young people are getting sick.
On your watch.
The federal government isn’t doing that so it falls to NC to make policies that at a minimum reflect the golden rule
in the living conditions it leaves to its residents.
I am a teacher by profession. If someone makes a mess- it is the moral and polite thing for whoever made the mess
to clean it up.
Why regulations and safegaurds were not in place to prevent someone from making this mess...I fail to understand.
The problem is now here and it needs to be owned and fixed.
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Katherine Crothers
273 Castles Gate Dr
Mooresville, NC 28117-4407
From:Tom Baldwin
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 2:15:08 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Tom Baldwin
697 Dobbins Rd
Ellenboro, NC 28040-9394
From:Kimberly West
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 2:03:49 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Kimberly West
1912 Washington St
Wilmington, NC 28401-6714
From:Celeste Rogers
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 2:00:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Celeste Rogers
1807 Baywater Ct SE
Bolivia, NC 28422-8085
From:Carol Barre
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:54:05 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities including my city. Residents
in the river basin have been exposed to high concentrations of PFAS for decades. There is no safe level for
continued exposure and Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Carol Barre
1009 Robert E Lee Dr
Wilmington, NC 28412-7141
From:Phyllis Holmes
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:54:04 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Phyllis Holmes
3 Windrow Dr
Asheville, NC 28805-1281
From:Chas Griffin
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:51:51 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Chas Griffin
1275 Seven Lakes N.
Seven Lakes, NC 27376
From:Lorna Lineberry
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:51:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Lorna Lineberry
6265 Hunt Rd
Pleasant Garden, NC 27313
From:william carothers
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:45:51 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
william carothers
40 Inverrary Rd
Pinehurst, NC 28374
From:Barbara Smith
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:39:53 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
My best friend lives in the Fayetteville area and so do a lot of our heroic soldiers which reside at Fort Bragg.
Barbara Smith
220 Kinsale Dr
Chapel Hill, NC 27517-3433
From:George Bartholomew
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:39:51 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
George Bartholomew
680 W King St
Boone, NC 28607-3564
From:Jennifer Hodgkinson
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:39:09 PM
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Dear Department of Environmental Quality,
You call this a plan?! You are in charge of maintaining environmental quality. Do your job!!
Go back a work a plan that actually keeps us safe. Teflon should be banned. People used regular pans before, they
will do it again after being educated to the harm it causes.
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jennifer Hodgkinson
602 Windcrest Rd
Durham, NC 27713
From:Gary Nuccio
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:36:50 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
I’m sure you are aware of the recent information that has been released to the public domain regarding the forever
chemicals now polluting the water supplies that we all come in contact with daily. It just so happens that DuPont is
the leading contributor to the presence of polyflouroakyls (PFAS) in our water. It is a must that you take your
responsibilities to keep our water supplies safe and healthy seriously. You are the guardians who need to stop the
systematic abuse of our water supplies. Water is the living creation that makes this existence we are a part of
possible. Without her, we do not exist. Give water the eminent respect it deserves and let DuPont know it needs to
clean up it’s act at it’s own expense. Thank you for your service. g
Gary Nuccio
1225 High Lonesome Rd
Bryson City, NC 28713-0317
From:Jim Mitchem
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:36:04 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jim Mitchem
154 Old Spring Rd
Belmont, NC 28012-9707
From:John Little
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:33:49 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
John Little
4201 Windsor Pl.
Raleigh, NC 27609
From:Carolyn Beckner
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:33:49 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Carolyn Beckner
5116 Verde Vista Cir
Asheville, NC 28805
From:Cindy Hazeltine
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:27:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Cindy Hazeltine
7614 Dunbar Dr SW
Sunset Beach, NC 28468-4616
From:John Weast
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:24:54 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
John Weast
200 Peachtree Mtn Est Rd
Murphy, NC 28906-8647
From:Erin Ehrhardt
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:24:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Erin Ehrhardt
3413 US 21 Hwy
Hamptonville, NC 27020-7309
From:Warren Bobbitt
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:24:04 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Warren Bobbitt
2004 Galena Chase Dr
Indian Trail, NC 28079-6599
From:Melinda Lewis
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:21:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Melinda Lewis
3208 Hubbard Road
Charlotte, NC 28269
From:Rica xxxx
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:09:08 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
You poison your children and everyone else’s unless, of course, you drink bottled water or know that your well is
good.
Rica xxxx
Xxxx
Whiteville, NC 28472
From:Dennis Letman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:09:07 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Dennis Letman
1515 Park Summit Blvd
Apex, NC 27523-4370
From:Velter Lima
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:09:05 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Velter Lima
4004 Old Fairground Rd
Angier, NC 27501-6941
From:Kathleen Mcquaid
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 1:09:05 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Kathleen Mcquaid
802 Brooklyn St
Raleigh, NC 27605-1421
From:Joan Mahery
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 1:09:04 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Joan Mahery
527 Rose Hill Rd
Asheville, NC 28803-8544
From:David Stratton
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 1:03:05 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
David Stratton
4907 Rembert Dr
Raleigh, NC 27612-6239
From:Stephanie Scaramelli
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:57:50 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Stephanie Scaramelli
383 Bellwood Dr
Henderson, NC 27536-4805
From:James Currier
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:54:52 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
James Currier
404 Longwood Terrance
Roxboro, NC 27573
From:Frederick Boyce
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:54:06 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
The natural environment is not a subset of the economy. Sawing off the branch one is standing on is not good
economic policy, or any other kind for that matter.
Frederick Boyce
756 Tuttles Grove Rd.
Beaufort, NC 28516
From:Bonne Zotos
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:54:05 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Bonne Zotos
2223 Whiterock Ct
Sherrills Ford, NC 28673
From:Burt Melton
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:48:13 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Burt Melton
7035 Marching Duck Dr
Charlotte, NC 28210-2200
From:Timothy Benbow
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:48:12 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Timothy Benbow
2736 Cedar Falls Rd
Franklinville, NC 27248
From:Wanda Williams
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:48:10 PM
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Dear Department of Environmental Quality,
I live in Brunswick County which according to https://urldefense.com/v3/__https://www.ewg.org/research/national-
pfas-testing/__;!!HYmSToo!L8i1iz5os86EtbMtVOa5DyHjL5J5wAMNhkGzXsd4cs7zj6urQgmEyICJ-
zhNs99VVHSsmYI$ is the number one area in the USA for PFA contaminated water.
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Wanda Williams
PO BOX 10762
Southport, NC 28461
From:Jason Cashwell
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan - Thank you DEQ
Date:Thursday, March 5, 2020 12:48:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Jason Cashwell
314 Fairfield Ln
Cary, NC 27511-5408
From:Bill Bush
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:48:08 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I RESLIZE THE STATE HAS BUSINESS FRIENDLY POLICY, BUT THST DOES NOT EXTEND TO THIS
BUSINESS OF POISONING PEOPLE AND DOING SUPERFICIAL "PRETEND, GOOD ENOUGH GOR
GOVERNMENT WORK" YO SORTA SLIGHTLY CLEAN IT UP . STAND FOR THE PEOPLE!!!!
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Bill Bush
8040 Park Springs Rd
Ruffin, NC 27326-8975
From:Sandra Dishman
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:48:07 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Sandra Dishman
1883 Prince Edward Dr
Elon, NC 27244-9172
From:Ricardo Arevalo
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:45:10 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.How is it possible this plan is even
considered, this is a PR campaign, give a break.
Ricardo Arevalo
6403 Rockshire Dr
Charlotte, NC 28227-8033
From:Henry Torrey
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:45:07 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Henry Torrey
2029 Aurora Ln
Franklinton, NC 27525
From:Laura Boggess
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:42:53 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Laura Boggess
501 Bailey St
Mars Hill, NC 28754-6209
From:Beth Livingston
To:SVC_DENR.publiccomments
Subject:[External] They Owe a LOT More to the People They Have Harmed
Date:Thursday, March 5, 2020 12:42:53 PM
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Dear Department of Environmental Quality,
I'm flabbergasted to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is far from adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Beth Livingston
1105 Trails End Rd
Durham, NC 27712
From:Bob Mcelroy
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:42:52 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Bob Mcelroy
151 Mimosa Blvd
Atlantic Beach, NC 28512-6525
From:Claudia Kaplan
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:42:52 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Claudia Kaplan
4911 Victoria Drive
Durham, NC 27713
From:William Garrard
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:42:51 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
William Garrard
472 22nd Ave NE
Hickory, NC 28601-1520
From:Fran Lynch
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:36:51 PM
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Dear Department of Environmental Quality,
The notion that a corporation can game the system by polluting the water, a life necessity, needed by their
customers/fellow Americans in an effort to boost their profits is not only immoral but bad business! Killing your
customers is not a successful business strategy. PFAS in our drinking water can not be ignored and the DEQ must
require Chemours to do a full cleanup of soil and groundwater contamination. Even residents who have had
filtration systems installed are not fully protected from contaminated groundwater if they do not have full-home
filtration systems. Further, PFAS in the soil can expose community members to this danger through fruits and
vegetables grown in local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. It is imperative that DEQ
do its duty to protect their fellow citizens and reject Chemours' self-serving proposal and require a full cleanup.
Fran Lynch
10412 Fairbrook Ter
Raleigh, NC 27617-1849
From:Mary Adams-Ali
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:36:16 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
We the people are tired of companies polluting our water, ground and air. They must be held accountable for
cleanup and never allowed to continue their practice. They make millions from their products and should be forced
to develop ways to eliminate their pollution.
Mary Adams-Ali
703 S Hayne St
Monroe, NC 28112-6013
From:Heather Visingard
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:36:04 PM
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Dear Department of Environmental Quality,
This is very simple. Organizations, corporations and indivuduals need to take responsibility for their actions.
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Heather Visingard
1407 Castle Ct
Lenoir, NC 28645-8362
From:Camille Harris-Wallace
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:33:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Camille Harris-Wallace
3701 W Gate City Blvd
Greensboro, NC 27407-4627
From:george kalinchak
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:33:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
george kalinchak
357 Argonne Rd
Southport, NC 28461-7828
From:Victoria Oliver
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:33:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Victoria Oliver
725 Messer Rd
Murphy, NC 28906
From:Gabrielle Barry
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:27:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Gabrielle Barry
3764 Selwyn Cir
Southport, NC 28461-7505
From:Marilyn Zuckerman
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:27:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Some of my family live in Wilmington and they can no longer drink tap water or use it for cooking. That is
unacceptable. Please clean up the mess.
Marilyn Zuckerman
1010 Sturdivant Dr
Cary, NC 27511-4723
From:Mbark Montasser
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:21:54 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mbark Montasser
3109 Frinks Street
Raleigh, NC 27610
From:Jon Pitt
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:15:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jon Pitt
2011 Ford Gates Dr
Garner, NC 27529-3765
From:Sharon Daugherty
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:15:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River. The company should be closed down for
the permanent damage they have done to the environment. Disgusting.
Sharon Daugherty
4312 Bramlet Pl
Greensboro, NC 27407
From:Robert Austin
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:15:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Robert Austin
135 Williston Creek Road
Williston, NC 28579-9582
From:William Yingst
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:15:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
William Yingst
1042 Putting Ln
Carolina Shores, NC 28467-2247
From:Beth Ann Mellinger
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:12:13 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Beth Ann Mellinger
105 Florence Dr
Pinehurst, NC 28374-8207
From:Andrew Meulendyk
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:12:12 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Andrew Meulendyk
7714 Whipple Trl
Greensboro, NC 27455
From:Shaun Jones
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:12:05 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Shaun Jones
2315 Bayview St
Gastonia, NC 28054-3817
From:Tracy Gregory
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:12:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tracy Gregory
125 Church St.
Fuquay-Varina, NC 27526
From:Lisa West
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:09:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Lisa West
227 W Lookout Rd
Nags Head, NC 27959-9451
From:Peter Finlay
To:SVC_DENR.publiccomments
Subject:[External] Chemours" groundwater plan
Date:Thursday, March 5, 2020 12:09:00 PM
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Dear DEQ,
Chemour should be confiscated as a public trust and all responsible management should be putin the field digging up the mess they created. All profits should be put to cleaning up the mess
and the full board would be replaced till the water cleanup is done. Salaries would be cut onall knowledgable management to subsistence living as they are now indentured to the clean up
till completed. This would be a clear sign to other firms that the land is not theirs but is onloan from the public and must be returned clean and free from toxins. Their familys must live
with in the polluted areas.Sick of this stuff, spent my life near the Hudson river and couldn't swim in it 50 years ago
because of PCBs. How can this gross negligence go on with all the laws we have. The ownersand management are like out of a sick movie. Please be the good guys and make them pay.
The other thing is trading in their stock is frozen, no one is allowed to dump the stock and nobankruptcy.
Peter Finlay
Willmington NC
From:Leonard Mole
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:06:50 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Leonard Mole
1406 Laughridge Dr
Cary, NC 27511-5240
From:Diane Wallace
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:06:49 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
FROM DIANE WALLACE FORSYTH COUNTY NC Resident: Let's try to keep the Cape Fear River area as
clean as possible for everyone's benefit.
Diane Wallace
2503 NC Highway 66 S
Kernersville, NC 27284-4311
From:Debra Donnelly
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:03:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Debra Donnelly
246 Garrett Cove Rd
Leicester, NC 28748-5436
From:deb brady
To:SVC_DENR.publiccomments
Subject:[External] Chemours and GenX
Date:Thursday, March 5, 2020 12:03:05 PM
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Dear Department of Environmental Quality,
It's unacceptable that Chemours continues to put its bottom line above the health and safety of North Carolinians
living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by Chemours is
not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
deb brady
6500 NC highway 61
gibsonville, NC 27249
From:Joan Pearson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:00:52 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Joan Pearson
23 Banjo Way
Asheville, NC 28804-8707
From:Fred Coppotelli
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:00:52 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Fred Coppotelli
383 Seldon Emerson Rd.
Cedar Mountain, NC 28718
From:Thurman Grove
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 12:00:51 PM
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Dear Department of Environmental Quality,
The proposed plan put forward by Chemours is not adequate and leaves communities at risk. Please make Chemours
clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear, and stop burdening
families with continued exposure and health risks. The company should be held fully accountable for the costs
associated with the cleanup of their own pollution and damages.
Thurman Grove
3320 White Oak Rd
Raleigh, NC 27609-7619
From:Linda Gorby
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:00:50 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup. It is DEQ’s responsibility to standup for the health and
safety of the people, animals and the Earth .... protect all, it is your responsibility!
Linda Gorby
9620 Kestral Ridge Dr
Charlotte, NC 28269-6213
From:Steven Gordon
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:00:10 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Steven Gordon
349 Savannah Garden Drive
Carthage, NC 28327
From:Mary Mullin
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:00:08 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Mary Mullin
3410 - D Northline Avenue Unit D
Greensboro, NC 27410
From:Ed Flowers
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 12:00:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Ed Flowers
750 Weaver Dairy Rd
Chapel Hill, NC 27514
From:Hassane Alsibai
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 12:00:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Hassane Alsibai
2015 Ernesto Lane
Raleigh, NC 27603
From:Chris Moses
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:57:50 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Chris Moses
125 Sprunt St
Chapel Hill, NC 27517-7810
From:George Czerw
To:SVC_DENR.publiccomments
Subject:[External] The Proposed Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:57:50 AM
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Dear Department of Environmental Quality,
As an environmentally concerned citizen of this state, I'm writing to state that I am quite disappointed to see that
Chemours continues to put its bottom line above the health and safety of North Carolinians living near and
downstream of their facility in the Fayetteville area. They have illegally polluted the Cape Fear River with their
toxic chemicals for decades and I believe that the cleanup proposal which Chemours has submitted is woefully
inadequate and leaves our communities at risk.
Please take action to ensure that Chemours totally cleans up their pollution, blocks all PFAS in the groundwater
from discharging into the Cape Fear River, and stops burdening our families with continued exposure and health
risks.
I demand that this company be held fully accountable for the costs associated with both the cleanup of their own
pollution and for any and all collateral damages which they have caused.
Thank-you for your consideration.
George Czerw
703 Alyssum Ave
Caswell Beach, NC 28465
From:Sally Buchanan
To:SVC_DENR.publiccomments
Subject:[External] Chemors
Date:Thursday, March 5, 2020 11:57:21 AM
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Chemors has poisoned our river water and ground water. The counties are paying
millions of dollars to try to provide safe drinking water for the citizens. Chemors
should be responsible for cleaning up their mess. They should be required to assume
all the costs to return the river and ground waters to the level before they polluted the
environment. And their actions should be required in the immediate future...not
dragged out over a lifetime.
Sally Buchanan
904 Caswell Beach Road
Caswell Beach, NC 28465
From:Anne Cassebaum
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:57:09 AM
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Dear Department of Environmental Quality,
Chemours needs to come up with a complete plan to stop their discharge of PFAS into the Cape Fear River and not
stop with a partial plan. I'm writing to urge the NC Department of Environmental Quality to make Chemours halt
the discharge of all PFAS into the Cape Fear River.
The river is a drinking source for downstream communities. Please keep this fact foremost in your mind. The river
is also a source of fish and water for our coastal fisheries.
There is no safe level for continued exposure and Chemours must cutoff their pollution.
Isn't it your job to protect our drinking water? Why wouldn't you demand that Chemours pursue a full cleanup,
including halting the release of PFAS-laden groundwater into the Cape Fear River?
Anne Cassebaum
3469 Amick Rd
Elon, NC 27244-8111
From:Todd Yennior
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:57:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Todd Yennior
1325 Forest Wood Dr
Lewisville, NC 27023
From:Paul Collins Jr
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:57:06 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Paul Collins Jr
2224 Western Park Ln
Hillsborough, NC 27278-9395
From:Shari Broyles
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:57:05 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Shari Broyles
131 Riverfield Dr
Statesville, NC 28625-8781
From:Melinda Alpaugh
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:57:04 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Melinda Alpaugh
51 Darlington Dr
Broadway, NC 27505-9558
From:Jessie Cannon
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:54:15 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jessie Cannon
3333 Alleghany Dr
Raleigh, NC 27609-6903
From:Michael Gyurica
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:54:13 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Michael Gyurica
4609 Briargrove Ct
Greensboro, NC 27410
From:Gail Sikes
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:54:13 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Gail Sikes
313 E Church St
Rose Hill, NC 28458-1427
From:Christopher Chromey
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:54:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Christopher Chromey
12 Sheppard Dr
Asheville, NC 28806
From:Fred Starling
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:51:09 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Fred Starling
3246 Sunnydale Dr
Fayetteville, NC 28312-7936
From:Donald Rumph
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:51:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
One of the things we learn as children is that when you make a mess, you clean the mess up. Why should that not
apply to companies and corporations as well?
Donald Rumph
3238 Quail Pointe Dr
Greenville, NC 27858-7335
From:Harold Bowker
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:51:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup. It will take yrs to understand the full medical impacts so
lets error on the side of protecting our communities.
Harold Bowker
392 Beacon Ln
Sneads Ferry, NC 28460-6506
From:Elizabeth Mitchell
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:51:05 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Elizabeth Mitchell
328 W Morgan St Ste A
Raleigh, NC 27601
From:Dennis Hill
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:48:11 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Dennis Hill
131O Nantz Ave
Mount Holly, NC 28120-2342
From:Nancy Davis
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:48:11 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Nancy Davis
5201 Roundstone Way Apt 103
Charlotte, NC 28216-2298
From:Luvi Valino
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:45:15 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Luvi Valino
3615 Sunchase Dr
Fayetteville, NC 28306-8092
From:Grace Hepler
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:45:12 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Grace Hepler
1879 Harper Rd
Clemmons, NC 27012-8621
From:Fred Lampe
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:45:11 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Fred Lampe
1710 Michaux Rd
Chapel Hill, NC 27514-7636
From:Sreekanth Belpu
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:45:10 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Sreekanth Belpu
2112 Bluff Oak Dr
Cary, NC 27519-0104
From:Garold Carlisle
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:45:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Garold Carlisle
321 S Kerr Ave Unit 111
Wilmington, NC 28403-1450
From:Heide Coppotelli
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:42:49 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Heide Coppotelli
383 Seldon Emerson Rd
Cedar Mountain, NC 28718-9017
From:Cheryl Jednak
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:42:49 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Cheryl Jednak
209 Ginseng Ln
Hendersonville, NC 28791-1322
From:Gayle Adcock
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:42:14 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Gayle Adcock
503 Manor Ridge Dr
Carrboro, NC 27510
From:Anar Mirkar
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:42:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Anar Mirkar
1305 Spring Song Ln
Knightdale, NC 27545-9105
From:Leona Whichard
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:42:07 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Leona Whichard
344 Cedar Club Circle
Chapel Hill, NC 27517
From:William Coxe
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:42:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
William Coxe
908 Pelican Dr
New Bern, NC 28560
From:Susan Holt
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:39:14 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Susan Holt
350 Morningstar Lake Rd
Forest City, NC 28043-8186
From:Pat Vescio
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:39:13 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Your consideration will be appreciated.
Pat Vescio
312 Arvo Ln
Cary, NC 27513
From:Heather MacIntosh
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:39:10 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Heather MacIntosh
5000 Prentice Pl
Charlotte, NC 28210-2920
From:Steven Snyder
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:39:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Steven Snyder
911 W 2nd St
Roanoke Rapids, NC 27870-1620
From:Carol Colhard
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:39:07 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Carol Colhard
8295 Ellijay Rd
Franklin, NC 28734-3805
From:Kim Kent
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:39:04 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Kim Kent
382 Captain Beam Blvd
Hampstead, NC 28443-7425
From:Jessica Small
To:SVC_DENR.publiccomments
Cc:postmanrick29@aol.com
Subject:[External] Public Comment to the proposed Groundwater Corrective Action Plan
Date:Thursday, March 5, 2020 11:38:55 AM
Attachments:Rebuttal to Corrective Action Plan.pdf
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Secretary Michael Regan,
Attached you will find our public comment against the proposed Groundwater
Corrective Action Plan. Should you need any other clarification, please let us know.
Thank you,
Richard and Jessica Small
3640 Thrower Road
Hope Mills, NC 28348
From:Megan Justice
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:36:18 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Megan Justice
3 Winterberry Way
Chapel Hill, NC 27516-9471
From:Denise Sicotte
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:36:16 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Denise Sicotte
6927 Conservatory Ln
Charlotte, NC 28210-3497
From:Cindy Castevens
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:36:15 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Cindy Castevens
648 Irving St.
Winston-Salem, NC 27103
From:Mark Peters
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:36:15 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear
River, and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Mark Peters
5 Carter Crest Ln
Fletcher, NC 28732
From:Douglas Evans
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:36:11 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Douglas Evans
105 Summerwalk Ct
Cary, NC 27518-9146
From:Kathy Haigh
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:36:11 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Kathy Haigh
4226 Masonboro Loop Rd
Wilmington, NC 28409-3560
From:Lena Cogdill
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:36:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Lena Cogdill
600 Floyd Street
Fairmont, NC 28340
From:Krissa Johnson-Sotomayor
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:36:05 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
No one should be above the law or the safety of our water supply, a fundamental right and necessity to life.
Please do the right thing as is embedded in your Department name and mission ENVIRONMENTAL QUALITY.
Water is not quality if it is contaminated.
Krissa Johnson-Sotomayor
106 Spring Needle Ct
Cary, NC 27513-3500
From:Jacqueline Emerson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:36:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jacqueline Emerson
3512 New Potato Dr
Kannapolis, NC 28083-7600
From:Chuck Dockery
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:51 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Chuck Dockery
1088 Romie Snow Rd
Dobson, NC 27017
From:Kay Bedingfield
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:33:51 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Kay Bedingfield
8 Stadleridge Dr Apt C, Apt C
Greensboro, NC 27410
From:Martha Smith
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:50 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Martha Smith
510 W harnett St
Dunn, NC 28334
From:Janis Ramquist
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:17 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Janis Ramquist
2208 Oxford Hills Dr
Raleigh, NC 27608-1671
From:James Zito
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:33:17 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
James Zito
2073 Shelmore Way
Leland, NC 28451-9630
From:Victoria White
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:33:10 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Victoria White
Kestrel Dr
Shallotte, NC 28470
From:Catherine Lavau
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:10 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Catherine Lavau
605 Shady Lawn Rd
Chapel Hill, NC 27514-2005
From:Michelle Allen
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:33:09 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Michelle Allen
4474 Mill Village Rd
Raleigh, NC 27612-3764
From:Keith Allen
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Keith Allen
PO Box 11
Cedar Grove, NC 27231-0011
From:Shirley Brutko
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:07 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Shirley Brutko
PO Box 968
Kings Mountain, NC 28086-0968
From:Burwell Ware
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:33:06 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Burwell Ware
126 Kingston Dr
Chapel Hill, NC 27514-1630
From:BRITTNY CALLENDER
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:30:12 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
BRITTNY CALLENDER
2159 Wolf Ln
Kinston, NC 28501-9702
From:Tara Wilhelmson
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, March 5, 2020 11:30:09 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tara Wilhelmson
1533 Ellis Rd
Durham, NC 27703-6368
From:Glenn Goss
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:30:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Glenn Goss
7117 Laurel Point Dr
Gibsonville, NC 27249-8515
From:Douglas Meacham
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:30:07 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Douglas Meacham
7203 Saint Crispins Way
Summerfield, NC 27358-9371
From:Heidi McInnis
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 11:30:05 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Heidi McInnis
PO BOX 2478
Wilmington, NC 28402
From:John Replogle
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, March 5, 2020 11:27:51 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
John Replogle
445 Drummond Dr
Raleigh, NC 27609-7033
From:Eugenia Isbell
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Thursday, March 5, 2020 11:16:12 AM
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I am confused. So it's O.K. if corporations pollute our drinking water without responsibility
and no consequences? When is there going to be accountability for this negligence byChemours? When is the NC Dept. of Environment going to take action to protect it's citizen's
rather than the corporations? Respectfully,
Eugenia Isbell
From:Brianna Nisly
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, March 5, 2020 8:54:06 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Brianna Nisly
1639 Allens Ln
Wilmington, NC 28403-3690
From:John Lipscomb
To:SVC_DENR.publiccomments
Subject:[External] Please stop Chemours evil deeds!
Date:Thursday, March 5, 2020 12:11:07 AM
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Chemours must put the health of NorthCarolinians living near the facility, the CapeFear River, and downstream communitiesahead of its bottom line—which its proposedplan fails to do.
DEQ must ensure that Chemours—notfamilies nearby and downstreamcommunities already burdened by exposureand health risks—pays the costs to clean upits pollution.
Let DEQ know that, with 45,000 acres ofpolluted, leaking groundwater, Chemours’plan will not clean up the problem and willleave our communities, drinking water, andthe Cape Fear River at risk.
From:Charles Bailey
To:SVC_DENR.publiccomments
Subject:[External] Chemours Pollution Cleanup
Date:Wednesday, March 4, 2020 11:27:20 PM
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The polluting of the Cape Fear river by Chemours is totally unacceptable. It is unconscionable and
immoral for Chemours management to put their company profits ahead of the health and safety of
all of us who live downstream from them.
Chemours, not the public must be made to pay for the cost of the cleanup of it’s pollution. The plan
put forth by the company is inadequate and will leave all of our communities at risk.
Charles Bailey
Southport, NC
Sent from Mail [go.microsoft.com] for Windows 10
From:Sharyn Curtis
To:SVC_DENR.publiccomments
Subject:[External] Chemours water cleanup
Date:Wednesday, March 4, 2020 8:24:02 PM
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We first read about the Chemours GenX contamination years ago. We assumed that
Brunswick County had done something about it. It's time for major lawsuits by now!
From:Shannon Ryan
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Wednesday, March 4, 2020 6:42:05 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Shannon Ryan
15046 Deshler Ct
Charlotte, NC 28273-6950
From:Glenda Lang
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Wednesday, March 4, 2020 5:48:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Glenda Lang
PO Box 1236
Rutherfordton, NC 28139
From:Chris Micolucci
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Wednesday, March 4, 2020 4:43:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Chris Micolucci
20811 Island Forest Dr
Cornelius, NC 28031-7099
From:Joan Ryder
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Wednesday, March 4, 2020 2:48:55 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Joan Ryder
5156 Exton Park Loop
Castle Hayne, NC 28429-7401
From:Sandra Brown
To:SVC_DENR.publiccomments
Subject:[External] Chemours water pollution
Date:Wednesday, March 4, 2020 2:12:02 PM
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As a long time resident of Wilmington NC, I feel it is imperative that Chemours is held responsible for the long
pollution of the Cape Fear River and surrounding waters and forced to clean up the damage at their expense. It is a
disgrace that they have put profits over our health, not to mention wildlife. The release of these toxins must stop
and they need to be monitored closely to make sure they abide by the rules!!!!
Sent from my iPhone
From:Christine Ellis
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan - not corrective enough!
Date:Wednesday, March 4, 2020 2:06:07 PM
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Dear Department of Environmental Quality,
PFAs in drinking water is a huge concern to Winyah Rivers Alliance and our Lumber Riverkeeper and Waccamaw
Riverkeeper Programs. As community advocates working to protect clean water and healthy communities in the
Lumber River Basin, we are concerned for the health of the local community nearby Chemours and also surrounding
communities that are impacted.
Based on the information we've read, there does not seem to be a good grasp of possible groundwater issues across
watershed boundaries. As you know, the aquifer in question are not confined to the Cape Fear River watershed. We
are aware of reports of potential contamination in the Lumber River watershed too.
In order to properly protect our residents, we urge DEQ to require Chemours to do a full cleanup of soil and
groundwater contamination. Residents should not have to rely on full-home filtrations systems to protect themselves
and their loved ones, and foot the bill too!
Plus, PFAS in the soil can expose residents to harm through pathways other than drinking water, such as consuming
fruits and vegetables grown in local gardens.
It is Chemours' responsibility to cleanup its mess. The current plan is not stringent enough to protect the health of
nearby communities. Therefore we urge DEQ to reject Chemours' plan and require a full cleanup of its pollution.
Christine Ellis
106 Main Street
Pembroke, NC 28372
From:Amber Williams
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Wednesday, March 4, 2020 9:15:50 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Amber Williams
1938 Middle Rd
Eastover, NC 28312-9705
From:Sandy DeOliveira
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Tuesday, March 3, 2020 9:27:52 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Sandy DeOliveira
1916 Wilmore Dr
Charlotte, NC 28203-4621
From:Martha Spencer
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Tuesday, March 3, 2020 9:21:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Martha Spencer
988 Henry Mountain Rd
Brevard, NC 28712-6762
From:Robert Voelker
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Tuesday, March 3, 2020 7:33:16 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Robert Voelker
330 Crowell Lane
Salisbury, NC 28146
From:Pattie Mazzola
To:SVC_DENR.publiccomments
Subject:[External] gray matter
Date:Tuesday, March 3, 2020 6:09:58 PM
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I live right across the street from Snow's Cut Park and the intercoastal waterway, also known
as the Cape Fear River. I love a nice walk with my dog on the River and he loves it too. Oneday in partiche waves were coming on the beach and broken by the gray sticky looking stuff
that went up and down the beach as far as the eye could see. Well that was a tootal bummer. Idid not know at the timemwhat it was...I sent a picture to the news. I never heard back, they
probably were not sure what it is either. But I know now what it was. How horrible to seesuch a sight on a afternoon walk!! Chenours to blame they need to clean up their mess !!!
From:Jon Hoehn
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 3, 2020 5:06:11 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jon Hoehn
3117 Enterprise Dr Apt G2
Wilmington, NC 28405-6472
From:Linda Voelker
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Tuesday, March 3, 2020 4:36:40 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Linda Voelker
330 Crowell Ln
Salisbury, NC 28146-8856
From:Jeff Hall
To:SVC_DENR.publiccomments
Subject:[External] Chemours must pay for us to have clean water
Date:Tuesday, March 3, 2020 4:35:38 PM
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Chemours must pay for us to have clean water.
That requires that they fully fund 100% reverse osmosis filtration of the drinking water of every
home in the affected area that draws from the polluted river. Period. Nothing less is acceptable.
Even if the price tag is in the 100’s of millions. We pay our water bill every month and then go to the
store and buy pure water to drink. This is unacceptable. Get it fixed, or get out of the way of others
who will get it fixed.
Very sincerely,
Jeff Hall
Wilmington, NC 28411
From:Eileen McCorry
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Tuesday, March 3, 2020 3:48:16 PM
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Dear Department of Environmental Quality,
As a child I learned that if you make a mess, you clean it up thoroughly and completely. Companies should be
required to do the same thing, particularly if the mess they make adversely affects health and safety.
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Eileen McCorry
4103 Fearrington Post
Pittsboro, NC 27312-5049
From:connie Raper
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Tuesday, March 3, 2020 2:48:14 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
connie Raper
2614 Woodmont Dr
Durham, NC 27705-2760
From:Helen Brockett
To:SVC_DENR.publiccomments
Subject:[External] Proposed Groundwater Corrective Action Plan
Date:Tuesday, March 3, 2020 9:08:34 AM
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Secretary Michael Regan,
We are affected well owners in the Gray’s Creek Community of Cumberland County and live
about a mile away from the DuPont/Chemours Plant.
We DO NOT CONCER with the corrective action plan as written. We think you shouldconsider the fact that DuPont/Chemours has contaminated our well and hold them accountable
by offering a permanent solution for not only our well, but for all suffering from the samecontamination.
Thank you for your consideration.
Dave & Helen Brockett
6998 Point East DrFayetteville, NC 28306
910-303-2179
From:Linda Tyndall
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Tuesday, March 3, 2020 8:24:05 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Linda Tyndall
393 Owen Dr
Lumberton, NC 28358-8028
From:Barbara Gerlach
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Tuesday, March 3, 2020 8:18:57 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Barbara Gerlach
2737 Rosedale Ave
Raleigh, NC 27607-7121
From:Linda R. Nall
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 2, 2020 10:39:53 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Linda R. Nall
409 Ox Creek Rd
Weaverville, NC 28787
From:Raven Vergara
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 2, 2020 9:57:58 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Raven Vergara
11306 Wescott Hill Dr
Huntersville, NC 28078-0620
From:Lidia Lucaciu
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Monday, March 2, 2020 5:27:53 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Lidia Lucaciu
2446 27th Avenue Cir NE
Hickory, NC 28601-7238
From:Mellissa Blankenship
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Monday, March 2, 2020 4:00:12 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Mellissa Blankenship
P O Box 916
Oak Island, NC 28465
From:Joan Ryder
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 2, 2020 2:57:51 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Joan Ryder
5156 exton park loop
Castle hayne, NC 28429
From:Glenn Rape
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 2, 2020 2:18:51 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Glenn Rape
2921 Aprilia Ln
Monroe, NC 28112-8502
From:Fred Ehrgott
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 2, 2020 1:42:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Fred Ehrgott
7164 Bonaventure St SW
Ocean Isle Beach, NC 28469-5441
From:Lawson Thompson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Monday, March 2, 2020 11:33:09 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Lawson Thompson
1045 Anchors Bend Way
Wilmington, NC 28411-8009
From:steve roberts
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Monday, March 2, 2020 11:32:37 AM
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Hold Chemours responsible for the costs it has foisted on the taxpayers. Furthermore, PFASwarning should be in every restaurant or place of public consumption of water, paid for by the
profit-making C hemours. Public Health risk to the max!
Steve RobertsWilmington NC 28401
Sent from Yahoo Mail for iPad
From:Rebecca J. Holyfield
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Monday, March 2, 2020 11:00:09 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Rebecca J. Holyfield
658 Precinct Road
Pilot Mountain, NC 27041
From:Marilyn Bollinger
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Monday, March 2, 2020 9:09:18 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Marilyn Bollinger
26 Forestdale Dr
Asheville, NC 28803-1850
From:Mary Anne McAlonan
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Monday, March 2, 2020 8:03:48 AM
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I moved to Leland, NC one year ago. Since moving here I have read and investigated what
Chemours has been allowed to get away with in their facility upriver.
I am astounded that DEQ is allowing them to not only pollute our rivers, but also get away
with paying a minimal amount to correct their actions!!!
I continue to advise friends and family from NY to fully understand the situation downriver
before they commit to moving to this community.
I would like to hear back from someone at DEQ that you register my utmost concerns and I
would like to know your plan to have Chemours pay the FULL amount to clean our rivers.
Mary Anne McAlonan
Leland, NC
From:pia51451
To:SVC_DENR.publiccomments
Subject:[External] Chemours pollution
Date:Monday, March 2, 2020 7:47:04 AM
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It is terrible that Chemours is allowed to continue poisoning the people who live in southeast
North. Carolina. Clean water should be a right, not something that only rich people can affordto buy every week. Please make Chemours clean up their mess and our waters. Do not let
them ignore the damage they have done. It will continue to pollute. Thank you.Pat Walsh
2385 Sugargrove Trail, Leland, NC 28461
Sent from my Verizon, Samsung Galaxy smartphone
From:Linda Tatsapaugh
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Monday, March 2, 2020 6:48:06 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Linda Tatsapaugh
48 Beech Glen Dr.
Black Mountain, NC 28711
From:Susan Dameron
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 11:27:09 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Susan Dameron
1245 N Hill Dr
Lincolnton, NC 28092-9656
From:Maria Salgado
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 8:51:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Maria Salgado
2123 Fountain Ridge Rd
Chapel Hill, NC 27517-7925
From:Becky Sims
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 7:15:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Becky Sims
4171 Old Julian Rd
Julian, NC 27283
From:Kathy Lesko
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Sunday, March 1, 2020 7:01:49 PM
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As a resident of Leland NC, I am mot happy with Chemours clean-up plan. The children in
my county can't drink from fountains at their school, I pay a water bill every month forpolluted water and have to buy gallons of spring water every week to drink and cook with.
This is completely unacceptable!
Chemours must put the health of North Carolinians living near the facility, the
Cape Fear River, and downstream communities ahead of its bottom line—which
its proposed plan fails to do.
The DEQ must ensure that Chemours—not families nearby and downstream
communities already burdened by exposure and health risks—pays the costs to
clean up its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not clean
up the problem and will leave our communities, drinking water, and the Cape Fear
River at risk.
It is time foe DEQ and the state of NC to do something about it ... nationwide attentionhas been brought to this issue do the right thing for the people of NC.
Kathleen Lesko
1103 Spring Glen CT
Leland, NC 28451
From:MH Freeman
To:SVC_DENR.publiccomments
Subject:[External] Chemours MUST clean up!!!
Date:Sunday, March 1, 2020 6:22:18 PM
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It is imperative that Chemours clean up and take definitive action against the spread. Their plan fails to adequately
address what has already been done to harm the environment and inhabitants. All inhabitants. We must require
them to address damage already done as well as preventing future damage. Nothing less is adequate, let alone
satisfactory.
MH Freeman
Sent from my iPhone
From:Michele
To:SVC_DENR.publiccomments
Subject:[External] Chemours clean up
Date:Sunday, March 1, 2020 3:52:30 PM
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I find it incomprehensible to think that Chemours would not be mandated
to clean up the mess they have made of our water systems, private and
public. The DEQ MUST stand behind the citizenry and demand thatChemours be held to account for the destruction they have created and
clean up the mess they have made. The citizens of NC should not be held
to pay for a single penny of this effort that they had no part in creating.
Stand for and with the people and against corporate polluters.
Michele Kanatous
Leland, NC
From:Deborah Oliver
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 1, 2020 3:45:10 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Clean up our environment for your employees, their families, your family and our future!
Deborah Oliver
122 High Oak Ct
Pinnacle, NC 27043-9006
From:Wayne Berg
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 3:33:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Wayne Berg
1028 Back Stretch Blvd
Indian Trail, NC 28079-5753
From:David Tubergen
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 3:21:53 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
David Tubergen
PO BOX 2971
Morganton, NC 28680-2971
From:Diana Hales
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 3:18:54 PM
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Dear Department of Environmental Quality,
As an elected official that is asked to protect citizens drinking water, I'm urge DEQ to require Chemours to do a full
cleanup of soil and groundwater contamination. Even residents who have had filtration systems installed are not
fully protected from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in
the soil can expose community members through other pathways than drinking water, including fruits and
vegetables grown in local gardens. In Chatham we have numerous sludge fields and that is also a possible source of
PFAS from metropolitan wastewater treatment.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Diana Hales
528 Will Be Ln
Siler City, NC 27344-8396
From:Ricky King
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 3:00:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Ricky King
1304 Cozart St Unit 504
Durham, NC 27704-6225
From:Lauren Krouse
To:SVC_DENR.publiccomments
Subject:[External] Public comment in regards to Chemours" groundwater plan
Date:Sunday, March 1, 2020 2:16:11 PM
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Hi there,
I am writing to express my concern in regards to Chemours' groundwater plan. Their proposal would
leave contaminated groundwater and toxic chemicals at the site and fail in any way to make amends for
the harm they have caused to locals and our beautiful Cape Fear River environment over decades. We
deserve to be paid for all of the damages and complications that Chemours has knowingly and purposely
caused our community. To ask that the site is cleaned up in full without cost to the public is the least that
we should ask of this corrupt company.
My dear friend recently lost her newborn baby to a birth defect likely connected to the poisoned water she
unknowingly drank, bathed in, and washed her food in for years here in Wilmington (she and her family
have since relocated). My black lab Forrest developed a rare, incurable skin condition that costs me over
$100 per month to treat -- after swimming in the Cape Fear River weekly for a year. My veterinarian, a
long-time Wilmingtonian, has been practicing in the area for decades and had to complete multiple tests,
including an expensive skin biopsy, and search through a veterinary textbook to figure out what was
causing the oozing ulcers that suddenly appeared all over his face and paws, much like those that have
appeared on cows and fish affected by these toxins.
This is, of course, not to mention the amount of money we have spent on gallons of water over the past
however many years it has been now. This is, of course, not to mention the harm that has been caused to
people who cannot afford to regularly purchase bottled water, and the harm done to those, like me, who
cannot afford expensive filters for their shower heads and faucets and so risk further damage by
continuing to expose themselves to this water in order to clean themselves on a daily basis. This is, of
course, not to mention all of the unknowns numerous Cape Fear residents face as they must wonder:
What may come of how my body and my children's bodies and my loved one's bodies have been
poisoned?
I am disgusted by Chemours' behavior and I know that we are all disgusted by it. To describe what they
have done to our community as "wrong" would be an understatement. What they have done to us is
nothing short of violence against humanity and nature. It should be treated as such in a court of law. The
effects that they have caused have yet to be measured in full. From what we know already, though, they
have knowingly and purposely committed an unforgivable crime. What's even more sickening is that they
have done this to other communities before, and they will continue to do this to other communities after
this.
I am thankful to finally be leaving this area as I enter the years in which I will attempt to start a family of
my own. I'm sad but not surprised that the lack of speedy progress on this has forced me to leave in the
name of my own health, knowing that so many others do not have the privilege to relocate. I hope that my
fertility and the health of my children will not be affected. If it is, however, I will know who to blame and
who to call.
Sincerely,
Lauren Krouse
Lauren Krouse
910.623.8527
laurenkrouse.com
From:Victoria Conn
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 2:06:09 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Victoria Conn
210 W Crawford St
Mebane, NC 27302-2418
From:Ann Green
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Sunday, March 1, 2020 1:51:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Ann Green
740 Three Mile Knob Rd
Pisgah Forest, NC 28768-9060
From:Julia Young
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 1:33:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Julia Young
457 Meadow Branch Rd
Pittsboro, NC 27312-7056
From:John Gerwin
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 12:18:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
John Gerwin
1008 Ravenwood Dr
Raleigh, NC 27606-1638
From:Faith Dixon
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 12:09:53 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Faith Dixon
9 Lena Ln
Asheville, NC 28806-8802
From:lmole1941
To:SVC_DENR.publiccomments
Subject:[External] Chemour"s GenX clean-up plan
Date:Sunday, March 1, 2020 11:12:07 AM
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TOTALLY INADEQUATE!!
Leonard Mole
Cary, NC
Sent from my Samsung Galaxy smartphone.
From:Gregg Hudson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 11:09:10 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Gregg Hudson
296 Oscar Hill Rd
Newport, NC 28570-3712
From:BILLIE BELL
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 10:33:08 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
BILLIE BELL
1200 N 20th St
Morehead City, NC 28557-4410
From:Debby Hanks
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Sunday, March 1, 2020 8:30:09 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Debby Hanks
1703 Farm Lake Dr
Holly Springs, NC 27540-8805
From:James Emery
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Sunday, March 1, 2020 7:00:06 AM
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Dear Department of Environmental Quality,
As citizens of North Carolina, the Department of Environmental Quality is the only recourse we have to hold
industry accountable to their pollution that destroys our state's natural resources and harms the health of our citizens.
The plan submitted by Chemours demonstrates that the company continues to put its bottom line above the health
and safety of North Carolinians living near and downstream of their facility in the Fayetteville area. The proposed
plan put forward by Chemours is not adequate and leaves communities at risk.
Please protect NC citizens by: 1) making Chemours clean up their pollution, 2) block PFAS in groundwater from
discharging into the Cape Fear, and 3) stop burdening families with continued exposure and health risks.
Also, as a taxpayer I should not have to bear the financial burden for their bad business practices and negative
externalities. The company should be held fully accountable for the costs associated with the cleanup of their own
pollution and damages.
James Emery
106 Mary St
Carrboro, NC 27510-1232
From:A Lawson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 11:51:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
A Lawson
2231 E 7th St
Charlotte, NC 28204
From:Mercedes Garrett
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 10:18:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Mercedes Garrett
608 Pine Ridge Dr
Greensboro, NC 27406-6508
From:Victoria Shockley
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 10:15:08 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Victoria Shockley
1005 Dowling Ct
Leland, NC 28451
From:Steve Roberts
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, February 29, 2020 8:33:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Steve Roberts
202 S 3rd St Apt 10
Wilmington, NC 28401-4548
From:Kaaren Stoner
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 8:30:05 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Kaaren Stoner
2225 Coleman Mountain Rd
Waynesville, NC 28785-8424
From:Judith Zwick
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 4:15:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Judith Zwick
3931 Appleton Way
Wilmington, NC 28412
From:Susan Howell
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 4:09:54 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Susan Howell
513 Plymouth Dr
Greenville, NC 27858-0005
From:Farshid Bondar
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 3:18:06 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Farshid Bondar
128 Castlewood Dr
Cary, NC 27511-5510
From:Anja Collette
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 12:21:58 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Anja Collette
1283 Greens Creek Rd
Sylva, NC 28779-7678
From:Robert Collins, Ph.D.
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, February 29, 2020 11:18:15 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Robert Collins, Ph.D.
2135 Chambwood Dr
Charlotte, NC 28205-3617
From:m5050ed@yahoo.com
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Saturday, February 29, 2020 11:11:10 AM
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Chemours must be held accountable and forced to clean up what they have polluted. They
must be made to stop polluting rivers, streams, creeks and local ground water effecting wellsused for drinking water!
Elissa Doty
4914 Connell DriveRaleigh, NC 27612
Sent from Yahoo Mail on Android
From:K Elliott
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 11:00:17 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
K Elliott
PO BOX 4
Macon, NC 27551
From:Scott Woodson
To:SVC_DENR.publiccomments
Subject:[External]
Date:Saturday, February 29, 2020 10:42:15 AM
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Enough is Enough. Clean up chemours or move out of north carolina.
From:JANEY MCMILLEN
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 10:27:14 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
JANEY MCMILLEN
806 Knollwood Dr
Apex, NC 27502-1526
From:Jennifer Barbara
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 10:24:11 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jennifer Barbara
609 Appomatox Drive
Marvin, NC 28173
From:Rebecca Barnatt
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 10:15:52 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Rebecca Barnatt
128 Bauman Ct
Graham, NC 27253-8459
From:Samuel Brewer
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Saturday, February 29, 2020 9:48:26 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Samuel Brewer
1203 Kilmory Dr
Cary, NC 27511-5094
From:Aaron Keating
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 9:36:22 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Aaron Keating
2133 Goodman Lake Rd
Morganton, NC 28655-7075
From:Shauna Glaspie
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 9:28:03 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Shauna Glaspie
17 Redstone Ct
Durham, NC 27703-6315
From:Virginia Holman
To:SVC_DENR.publiccomments
Subject:[External] Chemours clean up
Date:Saturday, February 29, 2020 9:21:09 AM
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attachment to report.spam@nc.gov
Dear NC DEQ,
It is time for you, the guardians of NC Environmental Quality, to stand up for the rights of the
people of North Carolina, who also happen to be your loved ones, neighbors, children,caretakers, food preparers, doctors, nurses, lawyers, etc., and demand that Chemours put
human health first. Its proposed plan for cleanup does not do this. If you do not pressChemours for this action and achieve it, it will be a message to the people of this state that
DEQ puts corporate profits above the state, its communities, the health of its families, itsfuture economic reputation, and basic human worth. That would be a shameful statement.
DEQ must make Chemours clean up its own mess—and pay for it. This cost is not the state’s
burden, which is to say it is not the burden of its people. It belongs to Chemours.
The Cape Fear River is at risk from over 45,000 acres of polluted leaking groundwater thatthreatens our communities and our drinking water.
Do the right thing and stand up for the people of our fine state.
Sincerely,
Virginia Holman
From:Patricia Burns
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 8:39:49 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Patricia Burns
1015 W Abberley Ln
Apex, NC 27502-8106
From:Mark Shipman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Saturday, February 29, 2020 7:57:51 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Mark Shipman
4700 Powder Mill Rd
Chapel Hill, NC 27514-9589
From:Celeste Roberson Smith
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Saturday, February 29, 2020 7:33:54 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Celeste Roberson Smith
211 S 2nd St
Wilmington, NC 28401-4403
From:Tanya Heinze
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 11:51:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Tanya Heinze
3919 Old Vineyard Rd
Winston Salem, NC 27104-4733
From:Timothy Leighton
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 11:33:06 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Timothy Leighton
13115 Indigo Run Ct
Charlotte, NC 28278-0210
From:Janis Bradish
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 9:33:54 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Janis Bradish
7th St
Carolina Beach, NC 28428
From:Vickie Penninger
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 9:09:57 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Vickie Penninger
711 Kimbrough St
Raleigh, NC 27608-2723
From:Rob Rowe
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 8:48:51 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Rob Rowe
105 Spivey Ct
Cary, NC 27513
From:Linda Schroeder
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 8:33:11 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Linda Schroeder
210 Trafalgar Ln
Raleigh, NC 27513
From:Andrea Li
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 8:03:58 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Andrea Li
278 Old Hwy 86 n
yanceyville, NC 27379
From:Tim Stevenson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 8:03:49 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Tim Stevenson
2615 Oak Ridge Rd
Oak Ridge, NC 27310
From:Lawrence Turk, RN
To:SVC_DENR.publiccomments
Subject:[External] Chemours and GenX Comments
Date:Friday, February 28, 2020 7:39:13 PM
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Dear Department of Environmental Quality,
Stop poisoning us.
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Lawrence Turk, RN
PO BOX 203
Hendersonville, NC 28793-0203
From:Kristen Rudy
To:SVC_DENR.publiccomments
Subject:[External] CLEAN WATER
Date:Friday, February 28, 2020 5:59:45 PM
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Dear DEQ:
Chemours must put the health of North Carolinians living near the facility, the Cape Fear River, and downstream
communities ahead of its bottom line—which its proposed plan fails to do.
Please ensure that Chemours—not families nearby and downstream communities already burdened by exposure and
health risks—pays the costs to clean up its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not clean up the problem and will leave
our communities, drinking water, and the Cape Fear River at risk.
Please help give us a stable source for clean drinking water. We deserve clean drinking water as a basic human right.
Thank you,
Kristen Rudy
From:Ted Frazer
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 5:57:12 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Ted Frazer
6 Drakesway Ct
Durham, NC 27713
From:Stephen Carroll
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 5:27:06 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Stephen Carroll
1017 Garden Club Way
Leland, NC 28451-9599
From:Hugh McCammon
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 5:06:09 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Hugh McCammon
1644 Lackey Dr
Hickory, NC 28602-9039
From:Raymond Lee
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 5:00:49 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Raymond Lee
160 Chatham Road
Asheville, NC 28804
From:Rachel Wendel
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 4:54:15 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Rachel Wendel
920 Open Field Dr
Garner, NC 27529-7043
From:Terry Faulkner
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 4:40:18 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Terry Faulkner
160 Chatham Rd
Asheville, NC 28804
From:Toni Taylor
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 4:37:42 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Toni Taylor
164 Jacktown Rd
Marion, NC 28752-9260
From:Stephanie Benson
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 4:18:11 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Stephanie Benson
6808 Palomino Ridge Ct
Summerfield, NC 27358-9506
From:Hart Palmer
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:58:17 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Hart Palmer
4919 Silver Fox Ln
Efland, NC 27243-9508
From:John Freeze
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 3:51:54 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
John Freeze
648 Chaney Road
Asheboro, NC 27205
From:Vickie Mullins
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:42:05 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Vickie Mullins
5905 Turnbull Rd
Fayetteville, NC 28312-7547
From:Joan Wells
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 3:21:25 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Joan Wells
1514 St Andrews Dr
Mebane, NC 27302
From:Betty Tennant
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:21:21 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Betty Tennant
641 kings trail
Sunset Beach, NC 28468
From:Nancy Granfortuna
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:12:18 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Nancy Granfortuna
6502 Lismore Dr
Browns Summit, NC 27214
From:erin dougherty
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 3:12:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
erin dougherty
307 Wake Dr
Salisbury, NC 28144-7790
From:David Robertson
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 3:10:48 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
David Robertson
4012 6th St NW
Hickory, NC 28601-8042
From:Lisa Loeffel
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:00:11 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Lisa Loeffel
7824 Mayfaire Crest Ln Apt 104
Raleigh, NC 27615-4875
From:Arielle Schechter
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 2:57:10 PM
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Dear Department of Environmental Quality,
PLEASE, make Chemours clean up the massive soil and groundwater contamination it has caused around its
facility!!!
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Arielle Schechter
440 Bayberry Dr
Chapel Hill, NC 27517-9122
From:Adi S
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 2:48:10 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Adi S
129 Aurora Dr
Asheville, NC 28805-1798
From:Janine Tokarczyk
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 2:48:10 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Janine Tokarczyk
109 N Oakland Dr
Mebane, NC 27302-3301
From:al Bynum
To:SVC_DENR.publiccomments
Subject:[External] Chemours must be accountable
Date:Friday, February 28, 2020 2:34:27 PM
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It is unconscionable for Chemours to be excused from putting the health of
North Carolinians living near the facility, the Cape Fear River, and
downstream communities ahead of its bottom line—which the proposed
plan fails to do.
You must ensure that Chemours—not families nearby and downstream
communities already burdened by exposure and health risks—pays the
costs to clean up its pollution.
With 45,000 acres of polluted, leaking groundwater, Chemours’ plan will not
clean up the problem and will leave our communities, drinking water, and
the Cape Fear River at risk.
From:David Curtis
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 2:18:57 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
David Curtis
10 Southwicke Ct
Arden, NC 28704-9433
From:Jeffryn Stephens
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 2:09:15 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Jeffryn Stephens
1114 Burch Ave
Durham, NC 27701-2819
From:Dellla Mol
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 1:54:15 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Dellla Mol
503 Charleston Pl
Fayetteville, NC 28303-5229
From:Robert Wallen
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 1:24:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Robert Wallen
302 Jeb Stuart Dr
Wilmington, NC 28412-6608
From:Melissa Beaver
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 1:15:23 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Melissa Beaver
3825 Cherry Grove Drive
Hickory, NC 28602-9785
From:liz gallagher
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 1:15:12 PM
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Dear Department of Environmental Quality,
My children when to college there and played sports drinking a ton of water for 7 years!! I sincerely hope that they
do not suffer horrible diseases because of this. You have a responsibility to make this right and SHOW AN
EXAMPLE Of what AN ETHICAL COMPANY DOES so that others follow. BE THE LEADER!
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
liz gallagher
8309 Clear Brook Drive
Raleigh, NC 27615
From:Dan Caryll
To:SVC_DENR.publiccomments
Subject:[External]
Date:Friday, February 28, 2020 12:48:43 PM
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DEQ, Please insure that Chemours pay the cost to clean up their pollution and not burden the
communities for this. Sincerely Daniel Caryll
From:Tracy Huley
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 12:16:00 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tracy Huley
204 Pollock St
Beaufort, NC 28516-2245
From:Lane Peeler
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 11:48:32 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Lane Peeler
48188 Wesley Chapel Road
Misenheimer, NC 28109
From:Timothy Birthisel
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan on PFA"s, PFOA"s and related pollutants
Date:Friday, February 28, 2020 11:48:22 AM
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Dear Department of Environmental Quality,
I have been unfavorably impressed with much of NC's environmental policies, that run parallel to our federal
government's negligent standards and practices. Those who advise neglect of nature stand on the wrong side of
history, and this issue is a great case in point: the current proposal before NCDEQ's doesn't make the cut.
The persistence and chronic toxicity issues posed by DuPont's chemistry, the failed attempt to hide behind the shill
Nemours, plus the negligent regulatory vacuum from USEPA, represent a doomed business platform. The investor
markets are apparently wiser than our governments, as the declining market values of these companies and their
bearish outlook attests, even against the background of a historic bull market. Our state government should take
note, and realize those responsible for protecting people and nature are as culpable as the primary perpetrators, by
standing by in inaction against environmental crime.
The community needs a complete cleanup of this mess, and it is DuPont's and Chemours' responsibility to provide it.
Failure to ensure our environmental quality will bury the people who allow it to join the extractive corporate
"citizens" in the trash can of history. Hiding behind a flawed 'letter of law' will not disguise their failures in the
coming years.
Timothy Birthisel
19 Sourwood Ln
Asheville, NC 28805
From:Sylvan Copelof
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 11:18:20 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Sylvan Copelof
100 Park Ave
Brevard, NC 28712-3536
From:Paula Stober
To:SVC_DENR.publiccomments
Subject:[External] Chemours cleanup
Date:Friday, February 28, 2020 11:16:15 AM
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You must require Chemours to be responsible for the cleanup of the water they polluted. It is only
right to do so
Paula Stober
Greensboro, NC
Sent from Mail for Windows 10
From:Barbara Barcomb
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 11:06:07 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Barbara Barcomb
311 Virginia Street SW
Lenoir, NC 28645
From:Lynn Garwood
To:SVC_DENR.publiccomments
Subject:[External] DEQ- please make Chemours clean up our water/ Brunswick county
Date:Friday, February 28, 2020 10:41:00 AM
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DEQ-
I am a life long citizen of NC and love our state including the coast, outer banks, crystal coast. Consequently I just
bought a house on Oak Island- Brunswick county.
I cannot believe what I have learned about Chemours making our water supply dangerous- this is awful! Please hold
them accountable for cleaning up the water they polluted/ damaged.
Brunswick county is building new facilities treat our water- Chemours should pay for it.
I’ve owned houses throughout the state and on Oak Island my county bill is 75$ whether I use water/sewer or not-
half of which is water approximately 37$. I cannot imagine the cost to taxpayers if we have to pay to clean up
Chemours mess.
Please hold them accountable and allow us the citizens of BC to continue to love our coast/ enjoy our water.
Thank you
Thank you
S Lynn Garwood
336-225-1889
From:Alice Stack
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 10:36:17 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Alice Stack
5721 Fox Chase Dr
Winston Salem, NC 27105-3085
From:Elizabeth Whitt
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 10:18:53 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Elizabeth Whitt
1116 Scaleybark Rd Apt 116B
Charlotte, NC 28209-4509
From:Sherri White-Williamson
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 10:09:06 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Sherri White-Williamson
528 McKoy St
Clinton, NC 28328-2517
From:Ginny Nolan
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 9:42:56 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Ginny Nolan
3204 S Memorial Ave
Nags Head, NC 27959-9362
From:Judy Husketh
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 9:36:58 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Judy Husketh
1630 Allens Ln
Wilmington, NC 28403-3672
From:Anne Brashear
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 9:09:52 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Anne Brashear
1606 Ferrell Rd
Chapel Hill, NC 27517-2315
From:Deborah Hankins
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 9:03:14 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Deborah Hankins
206 Heritage Park Drive
Wilmington, NC 28401
From:Helen Gray
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 9:00:21 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Helen Gray
1020 W Peace St Apt U8
Raleigh, NC 27605-1430
From:Tacye Lang
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 8:45:17 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Tacye Lang
6406 Rosny Rd
Raleigh, NC 27613-3111
From:Julie Gros
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 8:45:15 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Julie Gros
63 Macon Ave
Asheville, NC 28801-1522
From:Frances Kelly
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 8:42:56 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Frances Kelly
1965 Riverside Dr
Asheville, NC 28804-2051
From:Stephen Weissman
To:SVC_DENR.publiccomments
Subject:[External] Chemours cleanup
Date:Friday, February 28, 2020 8:40:49 AM
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Dear Sirs/Mesdames
This is a public comment about the proposed plan to clean up Chemours water pollution. Ithink that the plan does not guarantee that the company, not citizens, pay for the costs of
cleanup. Furthermore, the proposed plan does not contain provisions for the cleanup ofgroundwater, which is important for drinking water supplies and for the cleanliness of the
Cape Fear River.
Thank you for recording these comments. Stephen Weissman
Buncombe County, NC
From:Jacquelyn Hough
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 8:39:56 AM
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Dear Department of Environmental Quality,
Please - once and for all - make Chemours halt the discharge of all PFAS into the Cape Fear River and clean up the
mess they've already made! The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. THERE IS NO SAFE LEVEL.
Act now to protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination,
including halting the release of PFAS-laden groundwater into the Cape Fear River.
Jacquelyn Hough
305 Andrews Rd
Red Springs, NC 28377
From:Tom Riggins
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Friday, February 28, 2020 8:18:45 AM
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This company is responsible for polluting our waterways and I believe they should
pay to help clean them.
--
Regards , Tom Riggins
From:Doug Morris
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 8:03:13 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Doug Morris
324 Tern Ct
Kill Devil Hills, NC 27948-9217
From:DD
To:SVC_DENR.publiccomments
Subject:[External] Chemour
Date:Friday, February 28, 2020 7:49:32 AM
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The DEQ must force Chemour to clean up it’s contribution to toxic groundwater in North Carolina. Clean toxic free
water should be a citizens right that overpowers corporate greed.
A concerned North Carolinian.
Sent from my iPad
From:Bridget J Dunford
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 7:45:11 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Bridget J Dunford
525 Patton Valley Dr
Nebo, NC 28761-7710
From:Mike Stimpson
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 7:39:10 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Mike Stimpson
7312 Finn Hall Ave
Charlotte, NC 28216-9602
From:Anne RICHARDSON
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 7:19:01 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Anne RICHARDSON
10000 Amazona Dr
Huntersville, NC 28078-8406
From:Julia Hartman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 7:19:00 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Julia Hartman
70 Dalmatian Trl
Alexander, NC 28701-9210
From:Cheryl Jenkins
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 7:07:05 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Cheryl Jenkins
5802 Anne Dr
Wilmington, NC 28403
From:Raymond Occhipinti
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 6:57:53 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Raymond Occhipinti
265 Brooklyn Rd
Asheville, NC 28803
From:Anne Pistacchio
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 6:52:51 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Anne Pistacchio
1813 Bodwin Ln
Apex, NC 27502-6522
From:cheryl hustvedt
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 6:48:06 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
cheryl hustvedt
2710 Stuart Dr
Durham, NC 27707
From:Marie Coler
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 6:45:05 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Marie Coler
651 Par Dr
Jacksonville, NC 28540-9366
From:J. Robin Hall
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 6:24:15 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
J. Robin Hall
539 Bayshore Drive SE
Bolivia, NC 28422
From:Melissa Maynard
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 6:21:15 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Melissa Maynard
925 Brintonial Way
Winston Salem, NC 27104
From:Mary Pelosi Ejlali
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 6:15:07 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Mary Pelosi Ejlali
12329 Old Falls of Neuse Rd
Wake Forest, NC 27587-9215
From:Bill Snuggs
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 6:00:52 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Bill Snuggs
3626 Sunchase Dr
Fayetteville, NC 28306-8092
From:Chanda Farley
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 5:57:07 AM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Chanda Farley
117 Ford St
Canton, NC 28716
From:Cary James
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 5:54:07 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Cary James
4348 Frying Pan Rd SE
Southport, NC 28461-6303
From:ISABEL CERVERA
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 4:54:50 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
ISABEL CERVERA
2118 s main st
Salisbury Rowan County, NC 28147
From:gilchristab1@yahoo.com
To:SVC_DENR.publiccomments
Subject:[External] Demand Chemours to clean up our water!!!
Date:Friday, February 28, 2020 4:52:27 AM
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Please make Chemours be accountable for destroying our precious water and make them fix
what they have caused! It’s the right thing to do! Please make our water clean and healthy forplants, animals and HUMANS!
Ann Gilchrist - concerned citizen
45,000 acres of polluted, leaking groundwater, Chemours’ plan will not
clean up the problem and will leave our communities, drinking water, and
the Cape Fear River at risk.
Chemours must put the health of North Carolinians living near the facility,
the Cape Fear River, and downstream communities ahead of its bottom line
—which its proposed plan fails to do.
Chemours—not families nearby and downstream communities already
burdened by exposure and health risks—pays the costs to clean up its
pollution.
From:Abbygale Huffman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 3:09:54 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Abbygale Huffman
2506 22nd St NE
Hickory, NC 28601-7928
From:Andreas Batz
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 3:03:17 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Andreas Batz
1007 Manchester Dr
Cary, NC 27511-4808
From:Camryn Pate
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Friday, February 28, 2020 1:36:14 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Camryn Pate
2567 Hunter Rd
Clinton, NC 28328-5929
From:Ann Arader
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Friday, February 28, 2020 1:06:20 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River.
American companies need to respect our laws! - If they do not...they need to be charged the cost of having their
pollution professionally cleaned up, and the state needs to VERIFY that the cleanup is sufficient, or heavy fines
should occur.
PLEASE protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination,
including halting the release of PFAS-laden groundwater into the Cape Fear River.
THANK YOU!
Ann Arader
101 NE 26th st
Oak Island, NC 28465
From:Charles Cantrell
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 12:42:07 AM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Charles Cantrell
186 Brittany Place Dr Apt B
Hendersonville, NC 28792-7176
From:Barbara Benson
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Friday, February 28, 2020 12:27:08 AM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Barbara Benson
104 Deerfield Ct
Cedar Point, NC 28584-8047
From:Sheila Gasquet
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Friday, February 28, 2020 12:09:09 AM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Sheila Gasquet
613 Red Cross St
Wilmington, NC 28401-3556
From:Barb Benson
To:SVC_DENR.publiccomments
Subject:[External] Chemours must clean up its GenX pollution as it is required to do under state law and a consent order
with the state and Cape Fear River Watch.
Date:Thursday, February 27, 2020 11:46:37 PM
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attachment to report.spam@nc.gov
Chemours must put the health of North Carolinians living near the facility, the
Cape Fear River, and downstream communities ahead of its bottom line—which its
proposed plan fails to do.
DEQ must ensure that Chemours—not families nearby and downstream
communities already burdened by exposure and health risks—pays the costs to
clean up its pollution.
Let DEQ know that, with 45,000 acres of polluted, leaking groundwater,
Chemours’ plan will not clean up the problem and will leave our communities,
drinking water, and the Cape Fear River at risk.
Thank you,
Barbara Benson
This email has been checked for viruses by Avast antivirus software.
www.avast.com
From:Michael Harris
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 11:36:07 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Michael Harris
1431 Waterlily Lane
Charlotte, NC 28262
From:Frances McHugh
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 11:12:08 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Frances McHugh
6501 Red Bay Ct
Wilmington, NC 28405-7761
From:Ronald Artz
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 10:57:20 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Ronald Artz
314 Westview St
Kannapolis, NC 28081-2453
From:Marie Montemurro
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 10:24:06 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Marie Montemurro
8708 Lincolnshire Ln
Wilmington, NC 28411
From:Frank Stroupe
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 10:21:14 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Frank Stroupe
329 Raintree Dr
Matthews, NC 28104-7319
From:Tracy Feldman
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 10:18:08 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Tracy Feldman
5306 Pelham Rd
Durham, NC 27713-2532
From:Paul Fallon
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 10:09:28 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Paul Fallon
1712 Old Fort Rd
Greenville, NC 27834-9374
From:Jane Ann Hughes
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 9:54:21 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jane Ann Hughes
7760 Netherlands Dr
Raleigh, NC 27606
From:Karen Kaser-Odor
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 9:54:19 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Karen Kaser-Odor
278 Fryling Ave SW # 26
Concord, NC 28025-5776
From:Elaine Herring
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 9:48:15 PM
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Dear Department of Environmental Quality,
It so important fir the polluters to clean up the mess they have made and it shouldn’t be put upon the backs of
citizens and tax payers to clean these massive pollutants. The companies have reaped the benefits of their negligence
and wish to shift the burden.....this can’t keep happening in our neighborhoods or our state!!!
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Elaine Herring
60 Byrum Rd
Gates, NC 27937
From:Bill Staton, MBA, CFA
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 9:42:18 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Bill Staton, MBA, CFA
2431 Hartmill Ct
Charlotte, NC 28226-6463
From:Jessica Dennis
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 9:27:24 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Jessica Dennis
291 Confederate Dr.
Seagrove, NC 27371
From:Frank Moore
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 9:25:35 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Frank Moore
3301 Carolina Lily St
Cary, NC 27519-6710
From:Brayton Willis
To:SVC_DENR.publiccomments
Subject:[External] Chemours public comment
Date:Thursday, February 27, 2020 9:22:52 PM
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We who live and work here in Lower Cape Fear River region have a very serious problem going on right now with
Chemours et al contamination in our Cape Fear River water supply. The contamination is so bad that our utilities
have had to design, construct and will have to operate and maintain extremely expensive water treatment facilities to
rid these contaminates from our precious drinking water. This is blatant environmental injustice at the expense of
those that are less fortunate.... those that live at or below the federal poverty line. . . those that cannot stand the
stresses of undue, unwarranted financial burdens. This is beyond criminal. We should absolutely not have to pay to
clean up the pollution caused by our neighbors upstream of us. This is the tragic legacy of the failures of our NPDES
program, criminal polluters and inept politicians who rewrite our clean water laws to suit their lobbyist’s profit
margins.
Brayton Willis
Acting Chairman, Environmental and Climate Justice Committee
Brunswick County Branch NAACP
From:Dianne Miller
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 9:06:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Dianne Miller
910 Woodbrook Pl NE
Concord, NC 28025
From:Adam Matar
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 9:03:07 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Adam Matar
183 Brucemont Cir
Asheville, NC 28806-3442
From:Elton Glenn
To:SVC_DENR.publiccomments
Subject:[External] Clean water
Date:Thursday, February 27, 2020 9:00:59 PM
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We all cherish clean water free from any cancer causing substances, therefore I as a resident of the Cape Fear
Watershed demand that you do everything in your power to clean up any and all cancerous materials in the Cape
Fear Watershed with out charging we citizens for the clean up, since you created the problem.
Sent from my iPhone
From:Susan Chandler
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 8:57:19 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Susan Chandler
217 Longwood Drive
Chapel Hill, NC 27514
From:Iris Carman
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:57:17 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Iris Carman
327 Lakewood Dr
Wilkesboro, NC 28697-8459
From:Cheryl Vecellio
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:55:02 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Cheryl Vecellio
103 Deerlake Dr
Asheville, NC 28803
From:Tiffany Horton
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:48:20 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Tiffany Horton
1014 Davidson Ave NE
Leland, NC 28451-8310
From:Angela Vieth
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 8:48:10 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Angela Vieth
3009 Bexley Ave
Durham, NC 27707-2843
From:M Woolley
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 8:43:03 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
M Woolley
22 College St
Asheville, NC 28801-2803
From:Carol Ann Minor
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:43:02 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
I personally know of a family where both the father and mother have different forms cancer because of pollution and
poisons in their drinking water over many years!
Carol Ann Minor
10372 Singletree Ln
Davidson, NC 28036-7751
From:FRED MARTINIV
To:SVC_DENR.publiccomments
Subject:[External] Comments on Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:39:25 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
FRED MARTINIV
1016 W 1st St
Charlotte, NC 28202-1031
From:Joseph Fudge
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 8:39:20 PM
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Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
I also believe that Chemours should pay for a water treatment plant to process the polluted water which we rely on
since the plant that we currently have cannot properly process the water.
Joseph Fudge
3826 Lemon Drop Ln
Leland, NC 28451-4802
From:Barbara Dornbush
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 8:39:15 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Barbara Dornbush
41 Fox Falls Lane
Highlands, NC 28741
From:Julie Shoemaker
To:SVC_DENR.publiccomments
Subject:[External] Comments for Chemours and GenX
Date:Thursday, February 27, 2020 8:33:53 PM
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Dear Department of Environmental Quality,
I'm writing to urge the NC Department of Environmental Quality to make Chemours halt the discharge of all PFAS
into the Cape Fear River. The river is a drinking source for downstream communities. Residents in the river basin
have been exposed to high concentrations of PFAS for decades. There is no safe level for continued exposure and
Chemours must cutoff their pollution.
Please protect our drinking water by demanding that Chemours pursue a full cleanup of its contamination, including
halting the release of PFAS-laden groundwater into the Cape Fear River.
Julie Shoemaker
1569 Folly Rd
Hendersonville, NC 28739-2544
From:Brace Boone
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:33:53 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Further, PFAS in the soil can
expose community members through other pathways than drinking water, including fruits and vegetables grown in
local gardens.
The community needs a complete cleanup, and it is Chemours' responsibility to provide it. I urge DEQ to reject
Chemours' self-serving proposal and require a full cleanup.
Brace Boone
408 Elm St
Raleigh, NC 27604-1932
From:Doug Wingeier
To:SVC_DENR.publiccomments
Subject:[External] Chemours Corrective Action Plan
Date:Thursday, February 27, 2020 8:31:09 PM
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an attachment to report.spam@nc.gov<mailto:report.spam@nc.gov>
Dear Department of Environmental Quality,
I'm disappointed to see that Chemours continues to put its bottom line above the health and safety of North
Carolinians living near and downstream of their facility in the Fayetteville area. The proposed plan put forward by
Chemours is not adequate and leaves communities at risk.
Please make Chemours clean up their pollution, block PFAS in groundwater from discharging into the Cape Fear,
and stop burdening families with continued exposure and health risks. The company should be held fully
accountable for the costs associated with the cleanup of their own pollution and damages.
Doug Wingeier
266 Merrimon Avenue
Asheville, NC 28801
From:Sally Ferrell
To:SVC_DENR.publiccomments
Subject:[External] Chemours
Date:Thursday, February 27, 2020 8:26:37 PM
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attachment to report.spam@nc.gov
Feb 27 2020
Chemours must clean up its GenX pollution as it is required to do under statelaw and a consent order with the state and Cape Fear River Watch.
Chemours must pay the costs to clean up its pollution —not families nearby
and downstream communities already burdened by exposure and health risks.
Thank you
Sally Ferrell
647 Boone Gap Rd
Boomer NC 28606
From:Mark Vaughan
To:SVC_DENR.publiccomments
Subject:[External] Re: Chemours’ inadequate plan
Date:Thursday, February 27, 2020 8:16:07 PM
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Dear Department of Environmental Quality,
I'm very concerned about PFAS in drinking water and urge DEQ to require Chemours to do a full cleanup of soil
and groundwater contamination. Even residents who have had filtration systems installed are not fully protected
from contaminated groundwater if they do not have full-home filtration systems. Fu