2019.03.27_CCO.p14_ToxicityStudyWorkPlanCoverLetter

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

March 27, 2019
Sheila Holman
Assistant Secretary for the Environment
1601 Mail Service Center
Raleigh, NC 27699-1601
[e-mail]

Re: Work Plan for Toxicity Studies Pursuant to Consent Order Paragraph 14
Dear Ms. Holman,
Paragraph 14 of the Consent Order states: “Within thirty (30) days of entry of this
Consent Order, Chemours shall submit a plan and proposed schedule for review and approval by
DEQ for funding and facilitating the conducting of an initial set of toxicity studies by a qualified
third party approved by DEQ relating to both toxicity assays informative to human health and
aquatic life sufficient to aid in development of surface water and groundwater regulatory
standards for up to five PFAS as determined by DEQ. The plan shall provide for the studies and
parameters identified in Attachment B as well as technologically feasible dosing parameters to
be agreed upon by Chemours and DEQ.”

Chemours previously submitted a request for approval of the proposed third parties to
conduct the toxicity tests and hereby submits its proposed work plan for the toxicity assays for
the chemical substances identified in Attachment B. This work plan includes the test guidelines
and protocols for each toxicity study, as well as the proposed dosing parameters and schedule of
work.

Chemours looks forward to continuing to discuss the implementation of these toxicity
studies under Paragraph 14 of the Consent Order so that the necessary work can proceed in a
timely manner. If you have any questions or need further information, please let me know.

Sincerely,
Brian D. Long
Plant Manager
Chemours – Fayetteville Works

2
Enclosure

Cc:
William F. Lane, DEQ
Francisco Benzoni, NC DOJ
Michael Abraczinskas, DAQ
Michael Scott, DWM
Linda Culpepper, DWR
David C. Shelton, Chemours
John F. Savarese, WLRK
Kemp Burdette, CFRW
Geoff Gisler, SELC