2019.07.23_CCO.p11.b_NCDWRResponseToApprovalWithReccomendations

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

July 23, 2019
Linda Culpepper
Director, Division of Water Resources
1611 Mail Service Center
Raleigh, NC 27699-1611
[e-mail]

Re: Consent Order Paragraph 11.b Sampling Plan -
Response to DEQ Approval Letter with Recommendations

Dear Ms. Culpepper,

Thank you for providing DEQ’s approval of Chemours’s wastewater and stormwater
sampling plan (the “Plan”) submitted pursuant to Consent Order paragraph 11.b. Your approval
letter dated June 19, 2019, and sent by email on June 24, 2019, stated that the “the plan [is]
acceptable provided the following recommendations are implemented.” Among other
recommendations, your letter stated that “the plan should evolve to include testing throughout
the site in order to determine and eliminate sources,” and “Chemours should continually adjust
or increase sampling locations until each significant source of PFAS compounds is identified and
corrective actions are taken to eliminate the source.”

Chemours agrees with DEQ’s recommendation that the Plan be viewed dynamically, with
adjustments being made, when appropriate, as more is learned from ongoing sampling,
evaluation and remediation. But the Consent Order does not contemplate the complete
elimination of every source of PFAS compounds at the site. Instead, as you know, paragraph
12.a of the Consent Order, for example, requires Chemours to submit “a plan demonstrating the
maximum reductions in PFAS loading from the Facility…that are economically and
technologically feasible, and can be achieved within a two-year period.” We will continue to
work closely with DEQ to report on our ongoing sampling and to modify the sampling plan as
appropriate. And we will submit source reduction plans in accordance with the requirements
established by the terms of the Consent Order.

If you have any questions or would like to discuss this matter further with us, we would
be glad to arrange a time to speak.

Sincerely,
Brian D. Long
Plant Manager, Chemours – Fayetteville Works
2

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