2019.01.30_CCO.p11.a_ProposedConsentOrder

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

January 30, 2019
Linda Culpepper
Interim Director, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
[e-mail]

Re: Submission Pursuant to Proposed Consent Order Paragraph 11.a
Dear Ms. Culpepper,
Paragraph 11.a of the proposed Consent Order states:

By January 31, 2019, Chemours shall (a) provide DWR
with all known analytical test methods and lab standards
for all PFAS in all process and non-process wastewater and
stormwater at the Facility, including but not limited to all
process and non-process wastewater and stormwater
discharged through Outfall 002, and (b) submit a plan and
schedule for conducting non-targeted analysis of all process
and non-process wastewater and stormwater streams to
identify any additional PFAS and developing test methods
and lab standards for such compounds. Chemours shall
commence implementation of such plan within thirty (30)
days of approval by DEQ.

Although the proposed Consent Order has not yet been entered by the Court,
Chemours is continuing to proceed on the schedule set forth in the proposed Consent
Order with respect to these requirements. We are also providing notice as set forth in the
proposed Consent Order.

With respect to the requirements set forth in paragraph 11.a(a) of the proposed
Consent Order, Chemours is hereby providing DWR with the enclosed documents
entitled “Polyfluorinated Alkyl Substances (PFAS) in Aqueous Samples by Method 537
Version 1.1 Modified Using LC/MS/MS” (“Modified Method 537”) and “Determination
of Table 3 Plus Compounds by LC/MS/MS” (“Table 3 Plus Method”).

The enclosed Modified Method 537 was prepared by the Eurofins third-party
laboratory, and it describes the analytical test method currently used for certain PFAS
compounds (as specified therein) based on US EPA’s September 2009 Method 537. The
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lab standards for each of the Modified Method 537 compounds are commercially
available and may be purchased online.

The enclosed Table 3 Plus Method, in turn, was prepared by Chemours, and it
describes the analytical test method currently used for certain additional PFAS
compounds (as specified therein). The Table 3 Plus Method is currently in draft form, as
Chemours continues to refine and optimize this method. Chemours has shared this
method and the associated lab standards for each compound with its external testing
laboratories. The lab standards are in the form of a 0.1% (by weight) solution in water
for each compound, and Chemours can ship these standards solutions to DEQ promptly
upon request.

The enclosed Modified Method 537 and Table 3 Plus Method comprise the two
current analytical test methods for currently known PFAS compounds in process and
non-process wastewater and stormwater at Fayetteville Works. As you are aware,
sampling at the facility has detected the presence of some, but not all, of the PFAS
compounds covered by these two methods.

With respect to the requirements set forth in paragraph 11.a(b) of the proposed
Consent Order, Chemours is hereby submitting to DWR for its approval the enclosed
“PFAS Non-Targeted Analysis and Methods Development Plan” for process and non-
process wastewater and stormwater streams at Fayetteville Works.

Please let me know if you have any questions. Pursuant to the proposed Consent
Order, we will await further action with respect to the non-targeted analysis plan until we
receive DWR’s approval.

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

Enclosures
Polyfluorinated Alkyl Substances (PFAS) in Aqueous Samples by Method 537
Version 1.1 Modified Using LC/MS/MS
Determination of Table 3 Plus Compounds by LC/MS/MS
PFAS Non-Targeted Analysis and Methods Development Plan

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