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HomeMy WebLinkAboutNC0003573_Appendix G - DEQ Email Communication & GWTP Engineering Report_20210921Geosyntec ° consultants Geosyntec Consultants of NC, P.C. NC License No.: C-3500 and C-295 GES GFOSemee4, UC, 60ttthr1r end Mile rigs En®neere Appendix G DEQ E-mail Communication Engineering Report —Treatment of Groundwater and Upgradient Seeps Water TR0795 Aug-2021 Subject: RE: Re: Seeps and GW NPDES Permit Application (Outfall 004) From: Fields, Dianne L <DIANNE.L.FIELDS@chemours.com> Sent: Thursday, August 12, 2021 11:21 AM To: Grzyb, Julie; Chernikov, Sergei Cc: Garon, Kevin P; Ruiter, J. B; Compton, Christel E Subject: Re: Seeps and GW NPDES Permit Application (Outfall 004) Julie and Sergei, I am writing to provide you minor update on the flows specified in our Chemours Fayetteville Works NPDES Permit Application for the Groundwater Treatment System (submitted as Outfall 004 on June 13, 2021). In the application, the total average flow on Form 2D was 1.756 mgd (1,219 gallons per minute). We are maintaining a treatment system flow rate design of 1,500 gallons per minutes but have refined the anticipated flowrate of extracted black creek aquifer groundwater from a total of 800 gallons per minute to 830 gallons per minute as shown in the table below. We are therefore requesting that NCDEQ provide a permit based on this new flowrate. Water Source Approximate Flow Rate Seeps A and B Baseflow° 161 gpm Seeps A and B Stormflow* 108 gpm Groundwater from Surficial Aquifer° 150 gpm Groundwater from Black Creek Aquifer 830 gpm Total Flow 1,249 gpm * Seeps stonnflow represents maximum increase over baseflow averaged over 24-hour period. 0 Seeps baseflow and Shallow Groundwater may include some double counting. Seeps baseflow represents the 95th percentile instantaneous flow from each of Seeps A and B at location representative of the remedy capture location. If you need amended documents, please let us know. Respectfully, 1 Dianne Dianne L Fields Sr. Environmental Consultant 910-678-1384 office 919-628-8055 mobile The Chemours Company Fayetteville Works Plant 22828 NC Hwy 87 West Fayetteville, NC 28306 Chemours- < style="> This communication is for use by the intended recipient and contains information that may be privileged, confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact information for direct marketing purposes or for transfers of data to third parties. https://www.chemours.com/en/email-disclaimer 2 Geosyntecl> consultants Geosyntec Consultants of NC, P.C. NC License No.: C-3500 and C-295 ENGINEERING REPORT - TREATMENT OF GROUNDWATER AND UPGRADIENT SEEPS WATER Prepared for The Chemours Company FC, LLC 1007 Market Street PO Box 2047 Wilmington, DE 19899 Prepared by Geosyntec Consultants of NC, P.C. 2501 Blue Ridge Road, Suite 430 Raleigh, NC 27607 Geosyntec Project Number TR0795 June 2021 Geosyntec consultants TR0795 Ccosyn CV115 Imix%of NI:. RC. NC 1.i.111.0N: C-35flO onJ C-293 June 2021 Geosyntec consultants Ct symcc[:uuenlhm ix% of NI:. RC. NC I-irr i No C-35flO onJ C-293 TABLE OF CONTENTS 1. INTRODUCTION AND BACKGROUND 5 1.1 Site History and Overview 5 1.2 Process Overview 6 2. DESIGN BASIS 8 2.1 Aquifer Location 8 2.2 Influent Water Quality 10 2.3 Groundwater and Seeps Outfall 13 2.4 Influent Untreated Water Quality — Comparison to Water Quality Criterial3 2.5 Pilot Studies 15 2.6 Pumping & Conveyance Design 15 3. PROPOSED TREATMENT DESIGN 16 3.1 Overall Narrative 16 3.2 Individual Unit Operations 19 3.2.1 Metals Oxidation 19 3.2.2 Filtration 19 3.2.3 Granular Activated Carbon Adsorption 19 3.2.4 Solids Handling and Dewatering 20 3.3 Operability and Maintenance Considerations 20 3.4 Process Monitoring 21 4. SUMMARY 21 5. REFERENCES 21 TR0795 ii June 2021 Geosyntec consultants Ct symcc[:uuenlhm ix% of NI:. RC. NC I-irr i No C-35flO onJ C-293 LIST OF TABLES Table 1: Hydraulic Loading of Representative Groundwater and Seep Sources Table 2: Representative Well and Seep Locations and Estimated Flowrates Table 3: Influent Design Basis for the Groundwater Treatment System LIST OF FIGURES Figure 1: Remedy Alignment and Proposed Groundwater Treatment System Location Figure 2: Groundwater Flow Direction and Seep Locations Figure 3: Comparison of Carbon Isotherms for Heptachlor Epoxide, Two PAHs, and HFPO- DA Figure 4: Conceptual Process Flow Diagram of Primary Treatment Train and Solids Recovery Process LIST OF APPENDICES Appendix A: Analytical Data for Groundwater & Seep Sources for the Engineering Design TR0795 iii June 2021 Geosyntec consultants Ct symcc[:uuenlhm ix% of NI:. RC. NC I-irr i No C-35flO onJ C-293 ACRONYMS AND ABBREVIATIONS BCA Black Creek Aquifer CO Consent Order GAC granular activated carbon GPM gallons per minute GWTS groundwater treatment system HDPE high density polyethylene HFPO-DA hexafluoropropylene oxide-dimer acid HRT hydraulic retention time mg/L milligrams per liter MTZ mass transfer zone NCDEQ North Carolina Department of Environmental Quality ND Non -detect NPDES National Pollutant Discharge Elimination System PAH polycyclic aromatic hydrocarbons PFAS per- and polyfluoroalkyl substances PFMOAA perfluoro- 1 -methoxyacetic acid PMPA perfluoro-2-methoxypropanoic acid STD standard TSS total suspended solids ug/L micrograms per liter TR0795 iv June 2021 Geosyntec ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 1. INTRODUCTION AND BACKGROUND This Engineering Report was prepared by Geosyntec Consultants of NC, P.C. (Geosyntec) for the Chemours Company FC, LLC (Chemours) to provide a description of the future treatment works to be installed for the collection and treatment of groundwater and surface water from locations along the proposed groundwater remedy alignment at the Chemours Fayetteville Works, North Carolina site (the Site). The groundwater remedy includes a barrier wall, water extraction network, and treatment system (Groundwater Treatment System or GWTS) is a requirement of the Addendum to the Consent Order paragraph 12 (CO Addendum) amongst Chemours, the North Carolina Department of Environmental Quality (NCDEQ), and Cape Fear River Watch entered by the court on October 12, 2020. The goal of the GWTS is to achieve a removal efficiency of 99%, as measured by indicator parameters hexafluoropropylene oxide-dimer acid (HFPO-DA), perfluoro-2- methoxypropanoic acid (PMPA), and perfluoro-1-methoxyacetic acid (PFMOAA). The remedy is to commence operation by March 15, 2023 per paragraph 3(b) of the Addendum to the CO. To meet this requirement, Chemours intends to complete construction of the GWTS by April 1, 2022. Chemours will need to pump and treat the water collected by the remedy to protect the barrier wall's structural integrity. The GWTS therefore needs to be operational prior to the remedy's construction in June 2022. This document provides the conceptual design and engineering assumptions for the GWTS, in accordance with the National Pollutant Discharge Elimination System (NPDES) permit application requirements. The permit application requires that Chemours identify effluent characteristics of those parameters identified in the EPA Application Form 2D New Manufacturing, Commercial, Mining, and Silvicultural Operations That Have Not Yet Commenced Discharge of Process Wastewater (EPA Form 2D). 1.1 Site History and Overview The Site is located on NC Highway 87, 15 miles southeast of the City of Fayetteville, and south of the Bladen-Cumberland County line. The Site encompasses 2,177 acres of relatively flat undeveloped open land and sloping woodland bounded on the east by the Cape Fear River, on the west by NC Highway 87, and on the north and south by farmland. The ground on which the Site is situated slopes East towards the Cape Fear River. The proposed treatment facility is to be located on the southeastern portion of the Site just north of the William O. Huske Lock & Dam. E.I. du Pont de Nemours and Company (DuPont) purchased the property in parcels from several families in 1970. The Site's first manufacturing area was constructed in the early TR0795 5 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 1970s. Currently, the Site manufactures plastic sheeting, fluorochemicals, and intermediates for plastics manufacturing. A former manufacturing area, which was sold in 1992, produced nylon strapping and elastomeric tape. DuPont sold its Butacite® and SentryGlas® manufacturing units to Kuraray America, Inc. in June 2014; these are now a tenant operation. In July 2015, DuPont separated its specialty chemicals business into a new publicly traded company named The Chemours Company FC, LLC. With this separation, Chemours became the owner of the entire 2,177 acres of the Fayetteville Works along with the Fluoromonomers, Nafion® membranes, and Polymer Processing Aid (PPA) manufacturing units. The polyvinyl fluoride (PVF) resin manufacturing unit remained with DuPont as a tenant operation. In addition to the manufacturing operations, Chemours operates two natural gas -fired boilers and a biological wastewater treatment plant for the treatment of DuPont and Kuraray process wastewater and sanitary wastewaters from DuPont, Kuraray, and Chemours. 1.2 Process Overview Groundwater at the Site currently flows east towards the Cape Fear River. The extraction and conveyance portion of the treatment design proposes to capture the groundwater flow via the installation of a network of groundwater extraction wells and to capture the baseflow of seeps originating upgradient of the remedy and flows during rainfalls up to 0.5 inches in depth. The extracted groundwater and seeps water will then be collected and conveyed to be treated by the GWTS which is proposed to be located in the southeast corner of the Site. The proposed location is shown in Figure 1. TR0795 6 June 2021 Geosyntee ° consultants Proposed new GWTS location Legend S Extraction well - Planned groundwater remedy route GrusymccCmisidimi<x ofNf.. RC. NC 1-i,oi Nu: C-35flO onJ C-295 Figure 1: Remedy Alignment and Proposed Groundwater Treatment System Location The GWTS will be comprised of a series of chemical and physical separation steps. Chemical oxidation and pH adjustment will first be employed to precipitate metals, such as iron, to prevent downstream contamination or fouling of the granulated activated carbon (GAC) media. The precipitated metals and other particles above an appropriate control threshold will be removed via ultrafiltration membranes or some other suitable separation technology. The filtered effluent will then be treated for per- and polyfluoroalkyl substances (PFAS) by GAC adsorption. The reject from the filtration and GAC systems will undergo dewatering through a thickening tank and filter press or centrifugation, from which the sludge cake will be disposed of offsite and the press water will be recycled to the influent of the thickening tanks. Periodic backwashing will extend membrane and carbon media life, and the carbon will be removed and replaced based on breakthrough monitoring of several three -vessel carbon trains in a lead -middle -lag arrangement. Associated design elements such as pumps, piping, electrical, instrumentation and control for interlocks, mechanical and civil/structural elements will be finalized during the detailed design phase. This design concept may be optimized based on ongoing benchtop studies and data acquisition. TR0795 7 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 2. DESIGN BASIS 2.1 Aquifer Location The ground on which the Site is situated slopes east from the facility towards the Cape Fear River. The main groundwater aquifers therefore also flow towards the Cape Fear River. Furthermore, there are four seeps that also contribute surface water flow to the Cape Fear River, as identified in Figure 2. TR0795 8 June 2021 Geosyntee ° consultants TR0795 GrosymccCousidiw its. ofNC. RC. NC Li,011 Nu: C-3500 ol1J C-295 Proposed groundwater remedy alignment Seep Nearby tributary to river General direction of groundwater flow Site boundary Figure 2. Groundwater Flow Direction and Seep Locations 9 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 The groundwater originates from two main aquifers, known as the Black Creek Aquifer (BCA) and the Surficial Aquifer. These two zones are separated by the Black Creek Confining Unit along most of the length of the proposed groundwater remedy alignment, and the BCA is underlain by the Upper Cape Fear Confining unit, which is a layer of competent clay. The groundwater daylights near the Cape Fear riverbank as various seeps. There are four seeps (Seeps A through D), although only two of these are major hydraulic contributors (A and B) which will require collection for treatment. The estimated hydraulic loading in gallons per minute (gpm) from the two aquifers and four seeps, post remedy construction, is shown in Table 1. Table 1: Hydraulic Loading of Representative Groundwater and Seep Sources Water Source Approximate Flow Rate 0 Seeps Baseflow 161 gpm * Seeps Stormflow 108 gpm ° Groundwater from Surficial Aquifer 150 gpm Groundwater from Black Creek Aquifer 800 gpm Total Flow 1,219 gpm * Seeps stormflow represents maximum increase over baseflow averaged over 24-hour period. 0 Seeps baseflow and Shallow Groundwater may include some double counting. Seeps baseflow represents the 95th percentile instantaneous flow from each of Seeps A and B at location representative of the remedy capture location. Actual flows may vary from these model results due to variability in rainfall. The largest rainfall effect is expected to be seen in the seeps stormflow parameter in Table 1; the cited 108 gpm value is the 24-hour average flow for a 0.5 inch storm event. The seeps' baseflow quantity is also a conservative estimate (i.e. high -end). For this reason, the extraction system and the GWTS will be designed to handle reasonable expected flow variations and the GWTS currently has a planned capacity safety factor such that a maximum design flow of 1,500 gpm has been selected. 2.2 Influent Water Quality The source water to the GWTS will be the extracted groundwater and captured seep water. The groundwater will be extracted from a series of approximately 60 extraction wells installed along the length of the proposed groundwater remedy alignment. Water will also be captured from seeps originating upgradient of the barrier wall (Seeps A and B). Since the GWTS has not yet been installed, the influent water quality presented in this report is from representative wells in the associated aquifers and the seeps. The TR0795 10 June 2021 Geosyntec ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 currently available non-PFAS analytical data from the individual untreated groundwater and seep sources, or their closest analogs, has been collected and is summarized in the memorandum Chemours Fayetteville Works — Groundwater and Seeps Water Quality Assessment (Geosyntec, 2021). Relevant analytical data for the engineering design, including the PFAS data, is provided in Appendix A. Groundwater sampling was completed at four representative groundwater wells and three seep locations. The seep locations are shown relative to the site in Figure 2. The groundwater wells are analogs for the various groundwater sources to be collected by the new extraction network along the groundwater remedy alignment, as described in Table 2. Two of the seep locations (Seep A at Wall Point and Seep B at Wall Point) are analogs for the seep baseflow and surface runoff that will be intercepted by the groundwater remedy. The samples collected at the location Seep A minor tributary are not analogs of seep water as the location was artificially disturbed prior to sample collection to introduce sediment into the sample. The results from Seep A minor tributary were, however, included in the engineering design as a safety factor. Table 2: Representative Well and Seep Locations and Estimated Flowrates Representative Water Location Tag Flowrate (gpd) Flowrate (gpm) Proportion /0) Black Creek Aquifer at North EW-1 668,794 464 47% Black Creek Aquifer at South EW-3 428,198 297 30% Surficial Aquifer at North PIW-5S 104,760 73 7% Surficial Aquifer at South PIW-10S 75,773 53 5% Seep A minor tributary* SEEPA-TR-N 31,522 22 2% Seep A at Wall Point SEEP -A -WALL 50,501 35 4% Seep B at Wall Point SEEP-B-WALL 67,133 47 5% * Samples were artificially disturbed at SEEP-A-TR-N prior to collection to introduce turbidity. The dataset used for the GWTS design is inclusive of untreated water data collected during sampling events from 2019 and 2020 and a series of 11 sampling events that occurred during March and April 2021. PFAS compounds were specifically sampled for on March 3, March 26 and April 28, 2021. Appendix A provides a detailed overview of the average, maximum, and minimum concentrations of all untreated water parameters sampled for treatment design. The water collected at these wells (EW-1, EW-3, PIW-5S and PIW-10S) and two seep locations (SEEP -A -WALL and SEEP-B-WALL) is assumed to be representative of the total groundwater and seep flow that will be extracted and treated by the GWTS. TR0795 11 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 In addition to PFAS analyses, a variety of supporting analytes such as total suspended solids (TSS), and metals (such as aluminum and iron) were sampled as they were considered key parameters of concern that would inform the pre-treatment system upstream of the PFAS removal stage. Flow -weighted composite concentrations for each parameter were developed for each of the groundwater and surface water groupings, as a design aid for the development of the influent design basis. The average, minimum and maximum mass loading of each untreated water parameter and Table 3+ compound was estimated using the average, minimum, and maximum concentrations from the analytical data and the flow rates in Table 1. Thus, the flow -weighted, mass -based composition for the untreated water groundwater sources was estimated by summing the mass loadings from PIW-5S, PIW-10S, EW-1, and EW-3. The flow -weighted average composition for the seeps was estimated by summing the mass loadings from SEEP -A -WALL, SEEP-B- WALL, and SEEP-A-TRN. The projected concentrations in the combined influent to the GWTS were estimated from the flow -weighted concentrations groundwater and surface water groupings. Upon construction completion of the groundwater remedy, it is estimated that the total dry - weather groundwater and surface water flows will be 950 gpm and 161 gpm, respectively. The groundwater and surface water groupings were combined by flow -weighting the average, minimum, and maximum concentrations using these estimated post -construction flows. The design of the GWTS is based on the contaminant profile in Table 3. Table 3: Influent Design Basis for the Groundwater Treatment System Constituent Units Projected Concentrations Influent Design Basis Avg. Min. Max. Min. Max. HFPO Dimer Acid ug/L 12.2 8.22 18.9 4.11 28.3 PFMOAA ug/L 64.3 17.5 192 8.73 288 PMPA ug/L 13.2 8.38 22.5 4.19 33.8 Total table 3+ (20 compounds) ug/L 139 54.9 352 27.4 528 Aluminum, total mg/L 1.52 1.16 2.20 0.58 3.30 Bromide mg/L ND ND ND ND ND Calcium, total mg/L 4.07 3.74 4.55 1.87 6.82 Carbonate Alkalinity mg/L ND ND ND ND ND Chloride, total' mg/L 8.30 4.85 11.6 2.42 17.4 Fluoride, total mg/L 0.11 0.11 0.11 0.06 0.17 Hardness mg/L ND ND ND ND ND TR0795 12 June 2021 Geosyntec ° consultants Grusymcc Cuusidimrx% ofNC. RC. NC 1-i,o111.0 No: C-3500 mt.' C-295 Constituent Units Projected Concentrations Influent Design Basis Avg. Min. Max. Min. Max. Iron, total mg/L 4.86 2.28 8.56 1.14 12.8 Magnesium, total mg/L 2.37 2.27 2.53 1.13 3.80 Manganese, total mg/L 0.08 0.06 0.15 0.03 0.23 pH Std units 6.61 6.50 6.80 6.5 8.5 Phosphate mg/L ND ND ND ND ND Sulfate (as SO4) mg/L 24.7 13.3 33.9 6.66 50.9 Total Dissolved Solids mg/L 78.5 66.8 93.3 33.4 140 Total Organic Carbon mg/L 1.11 0.57 2.01 0.29 3.01 TSS2 mg/L 59.2 38.4 120 19.2 180 SEEP -A -WALL and SEEP-B-WALL each had one observation above 30,000 milligrams per liter (mg/L) chloride. Data has been excluded and can be considered an outlier for the basis of design. 2 Potentially 250 mg/L during peak storm events (see below). This also does not include the total suspended solids (TSS) contribution from solids generated during pretreatment. 2.3 Groundwater and Seeps Outfall The treated groundwater and seeps water will be discharged to the Chemours Fayetteville Site Outfall 002 discharge line to the Cape Fear River. The average flow rate from the Outfall 002 is 18.025 million gallons per day. The water quality assessment accounted for the combination of loads from Outfalls 004 and 002. In addition, the water quality assessment accounted for the mixing zone analysis that was conducted for Outfall 002 that documented a river dilution of 8:1 (Geosyntec, 2019). 2.4 Influent Untreated Water Quality - Comparison to Water Quality Criteria The groundwater and seep data for non-PFAS compounds were compared to North Carolina's surface water quality criteria. This screening -level exercise was conservative as no treatment was assumed. Results are documented in a memorandum - Chemours Fayetteville Works - Groundwater and Seeps Water Quality Assessment (Geosyntec, 2021). After flow -weighting the groundwater and seeps' concentrations, incorporating the load from Outfall 002, and applying an 8:1 dilution from the Outfall 002 mixing zone, heptachlor epoxide and polycyclic aromatic hydrocarbons (PAHs) warrant consideration as additional pollutants targeted for removal by the GWTS. Heptachlor epoxide was only detected in one well (PIW-5S) and one seep (SEEP -A - WALL) at low levels. The PAH compounds were only detected at low levels in one (PIW- TR0795 13 June 2021 Geosyntec ° eonsuirants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 5S) of the six untreated groundwater and seep sources. As detailed in the Groundwater and Seeps Water Quality Assessment (Geosyntec, 2021), Chemours will be resampling these locations to confirm the presence of these compounds. However, if these compounds are occasionally present in the influent to the GWTS it is unlikely that they will pass -through the GWTS. Heptachlor epoxide is extremely well adsorbed by activated carbon due to its size, double bonds, and the presence of chlorine atoms in the structure. PAHs tend to have strong sorptive interactions with carbon due to their hydrophobic nature and size. Activated carbon itself is composed largely of graphene plates, and this molecular similarity strengthens the binding energies via t-7c dispersive forces. A thorough review of the use of activated carbon (as well as other adsorbents) for removal of PAHs from water can be found in Chemosphere 148 (2016), 336-353. A number of other literature sources are also available that include adsorption equibria (i.e. isotherms), kinetics, and the combined effects in traditional packed bed adsorbers which give rise to dynamic capacities for various PAHs on activated carbons. Loading mg/g TR0795 Sorption of Various Organic Compounds on Activated Carbon - Weptech Ior epoxide - Ben zo k} fl u ora nth en - Benno; b jfl uo ra nthe the HFPO-OA 100 - 10 - 1 a.nnm C_0t n. I Concentration, ni /L 14 10 inn June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oliso Nu: C-35flO onJ C-295 Figure 3: Comparison of Carbon Isotherms for Heptachlor Epoxide, two PHAs, and HFPO-DA. Data from "Carbon Adsorption Isotherms for Toxic Organics" (EPA- 600/8-80-023, April 1980). The PFAS compounds this system is designed to treat adsorb to carbon more weakly than PAHs, as shown in Figure 3. Additionally, they are present in the water at concentrations roughly two orders of magnitude higher than the PAHs (and roughly four orders of magnitude higher than the heptachlor epoxide) that may be present in the intake water. As this treatment system will be run to prevent breakthrough of the three indicator PFAS, it is expected that heptachlor epoxide and the PAHs will be readily sorbed by the GAC and therefore are not expected to cause or contribute to exceedances of water quality criteria in the Cape Fear River if present in the wastewater. 2.5 Pilot Studies Pilot studies have been completed by vendors to verify the effectiveness of their proposed pretreatment methods and confirm performance of their selected carbon media to remove the required constituents and loadings from representative feed water. Tests were performed using bulk water collected from the sources in Table 2, which was proportionally blended based on collected flow contribution. The vendors were also furnished influent water quality data for each source. These pilot studies are being used to inform the efficacy of proposed full-scale treatment design, including pretreatment dosing chemistry and residuals characterization (for solids separation and solids -handling designs). 2.6 Pumping & Conveyance Design Groundwater modeling remedy development presently indicates a total of approximately 50 new BCA and extraction wells and 10 surficial aquifer extraction wells will be required to intercept groundwater. The combined maximum total flow rate produced from these wells is expected to be approximately 950 gpm. Each well pump is expected to extract approximately 5 to 30 gpm and will be sized to have additional flow capacity for contingency. The extraction wells are currently planned as high -density polyethylene (HDPE) construction below finished grade, whereas the wellhead will be of polyvinyl chloride construction. Each wellhead will then tee into their corresponding conveyance line (i.e., North or South Force mains), constructed of HDPE. Approximately two thirds of the required extraction wells will convey groundwater through the North Force main while the remaining third is conveyed via the South Force main. The conveyance lines will be sized to TR0795 15 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 accommodate the total collected flow of the extraction with added contingency to allow for increased extraction rates if required. Extracted groundwater will be conveyed to a surge tank prior to being treated by the GWTS. The seep flow will be impounded at or near seep capture locations (impoundment storage) to provide equalization storage during rainfall events and remove readily settleable/suspended solids prior to being conveyed to a break tank and treated by the GWTS. The total maximum dry weather flow to the GWTS after the groundwater remedy is fully operational, including seep flow, is estimated to be 1,111 gpm. Total flow over a 24-hour period with rainfall is estimated to average 1,219 gpm (see Table 1). The design flow rate for the GWTS was selected to be 1,500 gpm to allow for increased groundwater extraction from the extraction wells and potential uncertainty in post -installation flow behavior from the seeps. At the break tank, the influents from the extracted groundwater and the seeps will be combined. The effluent of the tank will then be drawn on demand by the GWTS. The impoundment storage will be dredged periodically, and solids characterized and disposed of at an appropriately designated facility. 3. PROPOSED TREATMENT DESIGN 3.1 Overall Narrative Based on turnkey vendor proposals currently under consideration, the GWTS is assumed to be comprised of the following series of treatment units: 1. Metals oxidation; 2. Ultrafiltration (UF) or similar solids separation technology; 3. Granular Activated Carbon (GAC) adsorption; 4. Solids Handling & Dewatering; and 5. Ancillary processes for backwashing and residuals handling. The influent oxidation system will be designed to help ensure complete oxidation of reduced iron species (or other dissolved metals), by means of pH adjustment and possible addition of inorganic coagulant and/or flocculant. Following oxidation, flow will proceed to the solids separation unit in which particle sizes above an appropriate control threshold will be removed. The filtrate will then be pumped to the GAC adsorption process, which will remove the PFAS and other contaminants from the water. Influent flow to the carbon beds may be pH adjusted to improve treatment performance. The GAC effluent will undergo further pH adjustment back to near -neutral conditions and then be discharged to the Cape Fear River via the pipe that conveys existing flows from Outfall 002 to the river. TR0795 16 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 The solids separation unit reject, solids separation unit cleaning, and GAC backwash water will collect in one or more thickener tanks. The thickened solids will be dewatered using a filter press or centrifuge. Sludge cake will be transferred into hoppers that will be trucked off -site for disposal at a permitted waste disposal facility. The dewatering filtrate will be returned to the head of the plant and blended with the influent downstream of the oxidation tanks. A backwash water tank will store a limited volume of treated water to supply GAC backwash, polymer dilution, and other process water requirements. A GAC backwash waste tank will collect backwash water and bleed it back into the treatment process downstream of the oxidation tanks. Process design considerations for each unit operation are further described in Section 3.2. Based on vendor experience, Chemours' current operational experience at Outfall 003 elsewhere at the facility, and outcomes of past treatability pilot studies, it is anticipated that a treatment design consisting of these elements will successfully address treatment requirements. In addition, Chemours is currently performing treatability studies based on anticipated wastewater characteristics of the groundwater and seeps. A conceptual process flow diagram (PFD) of the GWTS and the associated sludge handling system is shown in Figure 4. TR0795 17 June 2021 TR0795 Geosyntec consultants Georynt“Canud1onts ofNC, P.C. NC L.IctiM, Nu; 4.. end G-295 Feed a ■ Frac tank Frac tank Caustic Chlorine Coagulant Anionic polymer Decant Anionic polymer OF Vessel OF Vessel. OF Vessel iJF I _ Vessel jl�* OF Vessel Cone Bottom Tank H2SO4 pH to 3-5 Frac tank Frac tank CIP Caustic St35 12' diameter vessels GAG GAG GAC GAC GAC GAG GAG GAG GAG Caustic pH to 6-9 OF Reject Sludge T Cone Bottom Tank Decant Frac tan Filtrate Cationic polymer Filter Press Solids ■ Soilds roll -off Frac tank 4 To Outfall Frac tank To GAC BiW, Rinse, Sluice GAC — Backwash Out GAC System Solids handling Pre- and post- treatment Figure 4: Conceptual Process Flow Diagram of Primary Treatment Train and Solids Recovery Process System 18 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-3500 mt.' C-295 3.2 Individual Unit Operations 3.2.1 Metals Oxidation One or more influent oxidation retention tanks will be selected to allow for a hydraulic retention time (HRT) of 30 minutes at the design flow of 1,500 gpm. The HRT has been selected to achieve the optimal pH range of 6.5 to 7.5 and allow for the oxidation and coagulation of ferrous iron (Fe2+) to the less soluble ferric iron (Fe3+). Multiple tanks may be configured in a duty, active -standby configuration, with the capability to take one or more tanks offline for maintenance and still process the total plant flow of 1,500 gpm. Upstream of the tanks, chemical augmentation via an inorganic coagulant, sodium hydroxide, and sodium hypochlorite will be performed to adjust the pH, limit biofouling, and promote metals coagulation in the retention tanks. pH adjustment chemicals (sodium hydroxide and sulfuric acid) will be added to reach the target pH based on feedback from one or more pH probes. 3.2.2 Filtration Effluent from the oxidation process is pumped to the solids separation operation, via two or more pumps in duty -standby configuration. Ultrafiltration membranes or a similar solids separation process will be used to remove fine solids and turbidity down an appropriate control threshold upstream of the GAC beds to prevent fouling and extend runtimes between carbon backwashes or media replacement. The currently proposed OF system will be comprised of parallel banks of submerged membranes, provided as a prefabricated system, including the vessels, influent, effluent and backwash manifolds, automatic open/close valves, and any other ancillary equipment required. The filtered effluent from the solids separation process will be directed to a pH adjustment tank where sulfuric acid can be dosed to lower the pH to approximately 3.5 prior to being transferred to the GAC system. This pH adjustment is expected to improve GAC performance and extend service life. The reject and backwash from the solids separation process will routed to the sludge handling system to be dewatered prior to disposal. 3.2.3 Granular Activated Carbon Adsorption PFAS removal will be accomplished using GAC adsorption. Filtered effluent will be pumped from the pH adjustment tank to the GAC system and will enter three GAC adsorption trains, each designed to treat one third of the design flow (500 gpm). Each vessel will be configured as a down -flow process where water enters the top of the adsorber and exits through the bottom. In this configuration, adsorption of contaminants TR0795 19 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 (i.e., PFAS) will begin in the upper portion of the GAC bed. The mass transfer zone (MTZ) will move from the top of the bed downwards as each portion of the bed becomes saturated with the contaminants. Eventually, breakthrough will occur wherein the effluent of the tower contains the contaminant. Multiple carbon adsorbers will be arranged in series to capture the breakthrough. A three -column, lead/middle/lag, configuration per train is proposed for the GWTS. It is assumed that complete saturation of the lead column will occur prior to the initiation of a carbon changeout. During routine operation the lead column will act as the primary contaminant remover. The MTZ will travel from the top of the bed to the bottom until breakthrough of a contaminant of concern occurs. The spent GAC in the lead column will then be replaced with new GAC and the previous lead column will be placed in the lag column position. The expired GAC will be shipped offsite for disposal and if appropriate, regeneration of the carbon. The previous middle column will then become the lead column and the previous lag/third position column will become the second position column. It is expected that this operating the system in this manner will result in significant operations and maintenance savings without compromising removal efficiencies. Preliminary sizing for this application indicates that a series of 12-foot diameter vessels that can hold 20,000 pounds of carbon each will provide for the required hydraulic loading rate and Empty Bed Contact Time for PFAS removal. Effluent from the GAC trains will be transferred to a storage tank, where caustic will be dosed to the effluent upstream of the tank to adjust the pH back to neutral prior to discharge. This tank is sized to provide an appropriate retention time for the pH adjustment step. The used backwash water will be collected and transferred to the thickening process for dewatering and disposal. 3.2.4 Solids Handling and Dewatering The thickened sludge from the bottom of the thickening operation will be pumped to a filter press or similar technology for dewatering. The supernatant decanted from the top of the sludge thickening operation will be recycled to the influent of the initial chemical oxidation step for reprocessing. 3.3 Operability and Maintenance Considerations Process equipment has been selected from established vendors who maintain available inventory of critical spare parts, and the turnkey service provider should also have access to spares inventory based on duplication of unit operations in their commercial fleet. The TR0795 20 June 2021 Geosyntec ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 modular nature of the process train means that it is readily expanded or modified to adjust to future changes in process conditions or treatment requirements. 3.4 Process Monitoring The treatment process will be instrumented to monitor process performance consistent with industry best practices. Process data will be recorded in a remotely accessible database with an extended storage capacity and uninterruptible power supply. Regulatory compliance will be maintained by means of routine sampling and analytical testing of the untreated influent and treated water discharge points. Once a week, the influent to each train and the effluent of each vessel will be sampled and tested at the Site internal laboratory. Percent breakthrough is calculated for each PFAS indicator species. First PMPA, and then PFMOAA, breakthrough values are used to determine when a bed replacement is triggered. Generally once breakthrough begins to be observed in the middle vessel, the lead vessel's media is changed out. The former lead vessel, filled with new media, then becomes the lag vessel, former lag becomes the middle vessel, and former middle vessel becomes the new lead vessel. 4. SUMMARY In summary, the groundwater and seep flow associated with the proposed groundwater remedy will be collected and treated (by physical/chemical precipitation, filtration and carbon adsorption). It is anticipated that the environmental impacts associated with the groundwater and seep water will be significantly diminished and the treated water will exhibit a significant reduction in PFAS target compounds, total suspended solids and dissolved metals. PAHs, and heptachlor epoxide will also be treated if present. This will reduce the impact of these pollutants in the Cape Fear River. 5. REFERENCES Geosyntec, 2019. Mixing Zone Report, Addendum, Chemours Fayetteville Works Outfall 002. October 2019. Geosyntec, 2021. Memorandum to Chemours. Chemours Fayetteville Works — Groundwater and Seeps Water Quality Assessment. June 10, 2021. TR0795 21 June 2021 Geosyntee ° consultants GrusymccCmisidimi<x ofNC. RC. NC 1-i,oi Nu: C-35flO onJ C-295 APPENDIX A Analytical Data for Groundwater & Seep Sources for the Engineering Design TR0795 June 2021 June 2021 Table Al: EW-1 Table 3+ Compound Summary Location: EW-1 Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 9 9 ND ND ND ND ND Hfpo Dimer Acid 6 0 3.30 1.60 6.90 5.30 1.94 Hydro -EVE Acid 9 8 0.05 0.05 0.05 0.00 ND Hydrolyzed PSDA 9 3 0.48 0.02 1.60 1.58 0.69 Hydro -PS Acid 10 9 0.03 0.03 0.03 0.00 ND NVHOS 8 0 0.26 0.11 0.59 0.48 0.20 PEPA 10 0 0.48 0.06 1.70 1.65 0.61 PES 9 8 0.01 0.01 0.01 0.00 ND PFECA B 9 9 ND ND ND ND ND PFECA-G 10 10 ND ND ND ND ND PFMOAA 10 0 34.20 13.00 74.00 61.00 24.13 PFO2HxA 10 0 10.64 2.90 32.00 29.10 10.08 PFO3OA 10 0 1.16 0.10 4.20 4.10 1.53 PFO4DA 10 8 1.04 0.08 2.00 1.92 1.36 PFO5DA 10 10 ND ND ND ND ND PMPA 10 0 2.79 1.10 7.50 6.40 2.27 PS Acid 10 10 ND ND ND ND ND R-EVE 9 3 0.13 0.04 0.35 0.32 0.13 R-PSDA 9 3 0.17 0.04 0.47 0.43 0.17 R-PSDCA 9 9 ND ND ND ND ND Table A2: EW-1 Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 3 1 0.06 0.04 0.09 0.05 0.04 Bromide 12 12 ND ND ND ND ND Calcium 3 0 2.70 2.60 2.80 0.20 0.10 Carbonate Alkalinity 0 0 -- -- -- -- -- Chloride 12 0 7.19 6.30 10.00 3.70 1.00 Fluoride 3 3 ND ND ND ND ND Hardness 0 0 -- -- -- -- -- Iron 24 0 1.73 1.40 2.10 0.70 0.23 Magnesium 3 0 1.37 1.30 1.50 0.20 0.12 Manganese 23 0 0.02 0.02 0.03 0.01 0.00 pH 2 0 6.90 -- -- -- 0.14 Phosphate 1 1 ND ND ND ND ND Sulfate 12 0 15.08 14.00 17.00 3.00 1.00 Total Dissolved Solids 3 0 64.00 51.00 78.00 27.00 13.53 Total Organic Carbon 12 12 ND ND ND ND ND Total Suspended Solids 3 0 8.80 5.90 13.00 7.10 3.72 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table A3: EW-3 Table 3+ Compound Summary Location: EW-3 Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 15 12 0.097 0.095 0.1 0.005 0.002645751 Hfpo Dimer Acid 10 0 13.03 9.30 16.00 6.70 2.15 Hydro -EVE Acid 15 0 0.75 0.42 1.10 0.68 0.20 Hydrolyzed PSDA 15 0 4.25 1.50 6.50 5.00 1.85 Hydro -PS Acid 15 0 0.51 0.16 0.98 0.82 0.36 NVHOS 13 0 1.52 0.43 4.80 4.37 1.36 PEPA 15 0 2.85 1.80 4.90 3.10 0.77 PES 15 11 0.00 0.00 0.01 0.00 0.00 PFECA B 15 15 ND ND ND ND ND PFECA-G 15 15 ND ND ND ND ND PFMOAA 15 0 132.13 27.00 470.00 443.00 129.07 PFO2HxA 15 0 32.53 14.00 91.00 77.00 20.87 PFO3OA 15 0 14.77 5.20 43.00 37.80 11.94 PFO4DA 15 0 6.76 1.20 20.00 18.80 6.66 PFOSDA 15 6 0.91 0.01 2.40 2.39 0.77 PMPA 15 0 8.41 5.70 12.00 6.30 1.78 PS Acid 15 8 0.42 0.23 0.56 0.33 0.12 R-EVE 15 2 0.73 0.17 1.20 1.03 0.33 R-PSDA 15 0 1.21 0.65 1.70 1.05 0.33 R-PSDCA 15 3 0.04 0.01 0.10 0.09 0.03 Table A4: EW-3 Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 3 0 0.75 0.41 1.40 0.99 0.56 Bromide 22 22 ND ND ND ND ND Calcium 3 0 8.43 7.70 9.30 1.60 0.81 Carbonate Alkalinity 0 0 -- -- -- -- -- Chloride 22 0 12.42 3.00 16.00 13.00 2.67 Fluoride 4 3 0.32 0.32 0.32 -- -- Hardness 0 0 -- -- -- -- -- Iron 44 0 9.37 2.60 14.00 11.40 3.10 Magnesium 3 0 5.10 4.80 5.40 0.60 0.30 Manganese 43 0 0.20 0.16 0.25 0.09 0.02 PH 3 0 6.83 -- -- -- 0.29 Phosphate 1 1 ND ND ND ND ND Sulfate 22 0 59.95 14.00 72.00 58.00 12.44 Total Dissolved Solids 4 1 123.33 120.00 130.00 10.00 5.77 Total Organic Carbon 22 16 0.74 0.50 0.98 0.48 0.20 Total Suspended Solids 4 0 31.08 3.30 87.00 83.70 37.92 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table A5: PIW-10S Table 3+ Compound Summary Location: PIW-10S Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 7 7 ND ND ND ND ND Hfpo Dimer Acid 6 0 3.23 2.80 3.90 1.10 0.45 Hydro -EVE Acid 7 1 0.01 0.01 0.01 0.00 0.00 Hydrolyzed PSDA 7 7 ND ND ND ND ND Hydro -PS Acid 7 0 0.11 0.09 0.15 0.06 0.02 NVHOS 6 1 0.03 0.02 0.04 0.01 0.01 PEPA 7 0 1.69 1.50 2.10 0.60 0.23 PES 7 7 ND ND ND ND ND PFECA B 7 7 ND ND ND ND ND PFECA-G 7 7 ND ND ND ND ND PFMOAA 7 0 2.99 1.50 4.70 3.20 1.14 PFO2HxA 7 0 3.70 2.40 5.40 3.00 1.03 PFO3OA 7 0 0.70 0.45 0.99 0.54 0.20 PFO4DA 7 0 0.26 0.16 0.37 0.21 0.08 PFOSDA 7 2 0.02 0.01 0.03 0.02 0.01 PMPA 7 0 4.91 4.00 5.70 1.70 0.71 PS Acid 7 7 ND ND ND ND ND R-EVE 7 0 0.15 0.09 0.20 0.11 0.04 R-PSDA 7 0 0.31 0.19 0.42 0.23 0.10 R-PSDCA 7 7 ND ND ND ND ND Table A6: PIW-10S Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 4 0 0.84 0.62 1.20 0.58 0.28 Bromide 12 12 ND ND ND ND ND Calcium 4 0 0.44 0.43 0.46 0.03 0.02 Carbonate Alkalinity 0 0 -- -- -- -- -- Chloride 12 0 4.13 3.10 5.50 2.40 0.66 Fluoride 3 3 ND ND ND ND ND Hardness 0 0 -- -- -- -- -- Iron 24 13 0.52 0.04 2.60 2.56 0.78 Magnesium 4 0 0.60 0.58 0.61 0.03 0.01 Manganese 24 0 0.01 0.01 0.01 0.00 0.00 pH 3 0 6.77 -- -- -- 0.25 Phosphate 0 0 -- 0.00 0.00 -- -- Sulfate 12 0 9.94 9.00 11.00 2.00 0.67 Total Dissolved Solids 3 0 30.67 27.00 33.00 6.00 3.21 Total Organic Carbon 12 3 0.85 0.67 1.10 0.43 0.15 Total Suspended Solids 3 0 9.63 3.90 19.00 15.10 8.18 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table A7: PIW-5S Table 3+ Compound Summary Location: PIW-5S Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 6 0 0.986666667 0.57 1.8 1.23 0.478567306 Hfpo Dimer Acid 5 0 33.80 25.00 41.00 16.00 5.97 Hydro -EVE Acid 6 0 1.55 0.82 2.00 1.18 0.40 Hydrolyzed PSDA 6 0 15.67 5.00 28.00 23.00 8.26 Hydro -PS Acid 6 0 1.25 0.58 1.40 0.82 0.33 NVHOS 5 0 0.70 0.65 0.77 0.12 0.04 PEPA 6 0 26.00 17.00 44.00 27.00 10.16 PES 6 6 ND ND ND ND ND PFECA B 6 6 ND ND ND ND ND PFECA-G 6 6 ND ND ND ND ND PFMOAA 6 0 38.00 31.00 61.00 30.00 11.42 PFO2HxA 6 0 31.17 27.00 38.00 11.00 4.07 PFO3OA 6 0 8.58 7.50 10.00 2.50 0.97 PFO4DA 6 0 7.05 4.70 8.70 4.00 1.34 PFOSDA 6 0 5.23 1.90 6.60 4.70 1.76 PMPA 6 0 60.67 39.00 100.00 61.00 23.53 PS Acid 6 0 2.32 1.30 4.30 3.00 1.13 R-EVE 6 0 2.42 1.90 3.00 1.10 0.42 R-PSDA 6 0 3.70 2.90 4.70 1.80 0.63 R-PSDCA 6 0 0.05 0.04 0.07 0.03 0.01 Table A8: PIW-5S Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 2 0 0.91 0.86 0.96 0.10 0.07 Bromide 11 11 ND ND ND ND ND Calcium 2 0 1.95 1.90 2.00 0.10 0.07 Carbonate Alkalinity 0 0 -- -- -- -- -- Chloride 11 0 5.80 5.40 6.30 0.90 0.28 Fluoride 2 2 ND ND ND ND ND Hardness 0 0 -- -- -- -- -- Iron 22 0 0.79 0.04 12.00 11.96 2.52 Magnesium 2 0 0.82 0.79 0.84 0.05 0.04 Manganese 22 0 0.02 0.02 0.03 0.01 0.00 pH 2 0 6.75 -- -- -- 0.35 Phosphate 0 0 -- 0.00 0.00 -- -- Sulfate 11 0 22.36 20.00 24.00 4.00 1.63 Total Dissolved Solids 2 0 51.00 46.00 56.00 10.00 7.07 Total Organic Carbon 11 1 0.90 0.52 1.10 0.58 0.20 Total Suspended Solids 2 0 2.45 2.00 2.90 0.90 0.64 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table A9: SEEPA-TR-N Table 3+ Compound Summary Location: SEEPA-TR-N Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 7 7 ND ND ND ND ND Hfpo Dimer Acid 4 0 12.85 8.40 19.00 10.60 4.51 Hydro -EVE Acid 7 2 0.08 0.06 0.10 0.04 0.02 Hydrolyzed PSDA 7 4 0.05 0.03 0.08 0.05 0.03 Hydro -PS Acid 7 2 0.28 0.24 0.33 0.09 0.04 NVHOS 6 2 0.09 0.07 0.12 0.05 0.03 PEPA 7 2 4.52 2.90 6.80 3.90 1.68 PES 7 7 ND ND ND ND ND PFECA B 7 7 ND ND ND ND ND PFECA-G 7 7 ND ND ND ND ND PFMOAA 7 2 6.20 5.00 7.90 2.90 1.16 PFO2HxA 7 2 12.54 9.70 16.00 6.30 2.49 PFO3OA 7 2 2.12 1.70 2.80 1.10 0.43 PFO4DA 7 2 1.44 1.20 1.80 0.60 0.25 PFO5DA 7 2 0.35 0.32 0.38 0.06 0.02 PMPA 7 2 13.02 9.10 17.00 7.90 3.36 PS Acid 7 7 ND ND ND ND ND R-EVE 7 2 0.50 0.26 0.89 0.63 0.26 R-PSDA 7 2 0.96 0.48 1.60 1.12 0.47 R-PSDCA 7 4 0.01 0.00 0.01 0.00 0.00 Table A10: SEEPA-TR-N Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 2 0 14.14 0.27 28.00 27.73 19.61 Bromide 11 10 0.27 0.27 0.27 -- -- Calcium 2 0 1.30 1.00 1.60 0.60 0.42 Carbonate Alkalinity 0 0 -- -- -- -- -- Chloride 11 0 4.16 3.50 5.40 1.90 0.54 Fluoride 2 2 ND ND ND ND ND Hardness 0 0 -- -- -- -- -- Iron 22 0 13.90 0.74 44.00 43.26 14.73 Magnesium 2 0 1.46 0.82 2.10 1.28 0.91 Manganese 22 0 0.17 0.05 0.55 0.50 0.12 pH 2 0 6.75 -- -- -- 0.35 Phosphate 0 0 -- 0.00 0.00 -- -- Sulfate 11 0 10.73 10.00 12.00 2.00 0.79 Total Dissolved Solids 2 0 106.00 42.00 170.00 128.00 90.51 Total Organic Carbon 11 0 12.88 5.30 24.00 18.70 5.74 Total Suspended Solids 2 0 1100.00 1100.00 1100.00 -- 0.00 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table All: SEEPA-WALL Table 3+ Compound Summary Location: SEEPA-WALL Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 24 0 1.219166667 0.14 9.1 8.96 1.728462289 Hfpo Dimer Acid 11 0 28.36 19.00 41.00 22.00 5.94 Hydro -EVE Acid 24 0 1.60 0.14 3.50 3.36 0.72 Hydrolyzed PSDA 24 0 24.05 3.30 72.00 68.70 16.10 Hydro -PS Acid 29 3 1.35 0.01 3.50 3.49 0.57 NVHOS 23 0 1.03 0.23 1.70 1.47 0.44 PEPA 28 0 11.75 6.90 22.00 15.10 4.75 PES 24 24 ND ND ND ND ND PFECA B 24 24 ND ND ND ND ND PFECA-G 29 29 ND ND ND ND ND PFMOAA 29 0 70.93 15.00 130.00 115.00 41.13 PFO2HxA 29 0 35.38 18.00 55.00 37.00 11.30 PFO3OA 29 0 11.44 4.40 18.00 13.60 4.16 PFO4DA 29 0 6.91 1.40 11.00 9.60 2.28 PFO5DA 29 1 4.47 0.25 7.10 6.85 1.54 PMPA 28 0 27.25 17.00 46.00 29.00 7.94 PS Acid 29 2 4.56 0.02 31.00 30.98 5.92 R-EVE 24 0 1.36 0.80 3.60 2.80 0.53 R-PSDA 24 0 2.47 0.32 8.30 7.98 1.42 R-PSDCA 24 5 0.06 0.02 0.12 0.10 0.02 Table Al2: SEEPA-WALL Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 7 0 3.48 0.11 14.00 13.89 4.93 Bromide 12 12 ND ND ND ND ND Calcium 7 0 3.14 1.31 6.40 5.09 2.24 Carbonate Alkalinity 5 5 ND -- -- -- ND Chloride 18 0 5.56 4.00 12.20 8.20 2.07 Fluoride 3 2 0.41 0.41 0.41 -- -- Hardness 0 0 -- -- -- -- -- Iron 27 0 1.63 0.07 21.40 21.33 4.10 Magnesium 7 0 0.89 0.51 1.50 0.99 0.36 Manganese 27 0 0.05 0.02 0.42 0.40 0.08 pH 3 0 6.77 -- -- -- 0.25 Phosphate 5 4 1.00 1.00 1.00 -- -- Sulfate 16 0 14.88 8.60 30.30 21.70 5.96 Total Dissolved Solids 7 0 62.64 39.50 113.00 73.50 26.15 Total Organic Carbon 16 0 2.98 0.58 10.40 9.82 2.31 Total Suspended Solids 9 0 124.26 4.70 712.00 707.30 223.19 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C. June 2021 Table A13: SEEPB-WALL Table 3+ Compound Summary Location: SEEPB-WALL Table 3+ Compounds # of Results # of Non -Detects Average (ug/L) Min (ug/L) Max (ug/L) Range (ug/L) Std Dev (ug/L) EVE Acid 29 0 8.624137931 1.4 46 44.6 11.3600382 Hfpo Dimer Acid 17 0 37.47 25.00 85.00 60.00 18.93 Hydro -EVE Acid 29 0 3.30 0.85 11.00 10.15 2.77 Hydrolyzed PSDA 29 0 43.93 21.00 120.00 99.00 22.31 Hydro -PS Acid 33 2 1.63 0.49 4.70 4.21 1.32 NVHOS 28 0 3.57 1.80 8.50 6.70 1.88 PEPA 31 0 22.13 12.00 50.00 38.00 11.69 PES 29 25 0.07 0.01 0.21 0.20 0.10 PFECA B 29 27 0.11 0.05 0.17 0.12 0.09 PFECA-G 33 31 0.11 0.00 0.21 0.21 0.15 PFMOAA 33 0 118.08 4.80 200.00 195.20 80.31 PFO2HxA 33 0 34.76 11.00 50.00 39.00 13.64 PFO3OA 33 0 7.20 2.50 12.00 9.50 2.80 PFO4DA 33 0 1.95 0.79 7.70 6.91 1.20 PFO5DA 33 5 0.72 0.13 1.90 1.77 0.62 PMPA 31 0 47.19 32.00 87.00 55.00 17.18 PS Acid 33 1 7.56 0.04 31.00 30.96 8.97 R-EVE 29 0 4.38 2.00 13.00 11.00 3.45 R-PSDA 29 0 5.81 2.50 16.00 13.50 3.64 R-PSDCA 29 2 0.11 0.05 0.38 0.33 0.10 Table A14: SEEPB-WALL Treatment Parameter Summary Treatment Parameter # of Results # of Non -Detects Average (mg/L) Min (mg/L) Max (mg/L) Range (mg/L) Std Dev (mg/L) Aluminum 6 0 0.80 0.39 1.45 1.06 0.46 Bromide 12 12 ND ND ND ND ND Calcium 6 0 0.96 0.69 1.58 0.89 0.32 Carbonate Alkalinity 4 4 ND -- -- -- ND Chloride 20 0 7.67 5.00 16.20 11.20 2.97 Fluoride 3 3 ND ND ND ND ND Hardness 0 0 -- -- -- -- -- Iron 26 0 0.85 0.37 3.75 3.38 0.68 Magnesium 6 0 0.82 0.67 1.31 0.64 0.25 Manganese 26 0 0.03 0.02 0.41 0.40 0.08 pH 3 0 6.67 -- -- -- 0.29 Phosphate 4 4 ND ND ND ND ND Sulfate 15 0 10.70 7.00 24.40 17.40 4.70 Total Dissolved Solids 6 0 46.33 26.00 74.00 48.00 15.64 Total Organic Carbon 15 0 3.92 2.60 5.50 2.90 0.87 Total Suspended Solids 10 0 93.60 11.00 300.00 289.00 113.50 *pH expressed in standard units Legend: ug/L = micrograms per liter mg/L = milligrams per liter Min = minimum Max = maximum Range = difference between max and min Std Dev = standard deviation Engineering Report - Groundwater and Seeps Treatment System Prepared by: Geosyntec Consultants of NC, P.C.