Consent Order Progress Report For
Third Quarter 2021

Submissions to the State of North Carolina and Cape Fear River Watch
The following table identifies submissions made by Chemours pursuant to the Consent Order andAddendum (COA) for the period of July 1, 2021 through the end of the third quarter on September
30, 2021.1
COSection

111112 – COA 1b12 – COA 2a12 – COA 2a12 – COA 2a12 – COA 3b12 – COA 4c
28

Title

PFAS Non-Targeted Analysis andMethods Interim Report #3
Characterization of PFAS in Process and
Non-Process Wastewater andStormwater – Ongoing Sampling - 2021
Quarters 1 and 2 Semi-Annual Report
Cape Fear River PFAS Mass Loading
Assessment Report – Second Quarter
2021
Interim Seep Remediation Operation andMaintenance Report #3
Seep A Effectiveness Demonstration
ReportInterim Seep Remediation Operation and
Maintenance Report #4
Groundwater and Seeps Remedy 60%
Design Submittal
Stormwater Treatment System Capture
and Removal Efficiency Report
Consent Order Quarterly Progress Report

Submitted
Date

07/30/2021
09/29/2021

09/30/2021
07/30/2021
08/26/2021
09/30/2021
08/13/2021
09/30/2021
07/29/2021

1 Consent Order submissions by Chemours from lodging of the Proposed Consent Order in November
2018 through March 31, 2019 were presented in the 2019 1st quarter report, April 1, 2019 throughJune 30, 2019 in the 2019 2nd quarter report, July 1, 2019 through September 30, 2019 in the 2019
3rd quarter report, October 1, 2019 through December 31, 2019 in the 2019 4th quarter report,
January 1, 2020 through March 31, 2020 in the 2020 1st quarter report, April 1, 2020 through June30, 2020 in the 2020 2nd quarter report, July 1, 2020 through September 30, 2020, in the 2020 3rdquarter report, October 1, 2020 through December 31, 2020 in the 2020 4th quarter report, January
1, 2021 through March 31, 2021 in the 2021 1st quarter report, and April 1, 2021 through June 30,
2021 in the 2021 2nd quarter report.

Consent Order Progress Report For
Third Quarter 2021

2021 Third Quarter Residential Summary

Item
Total Number of Residences
SampledResidences Exceeding GAC
Criteria (GenX >= 140 ng/L)
Residences Exceeding RO
Criteria (∑PFAS >= 70 ng/L)
Residences Exceeding RO
Criteria (PFAS >= 10 ng/L)
Residences Drinking Water Well
Detections (Results < 10 ng/L)
Residences Drinking Water Well
Non-DetectionsCumberland
County(East ofRiver)

Cumberland
County(West ofRiver)

BladenCounty(East ofRiver)

BladenCounty(West ofRiver)

RobesonCountySampson
County

Total

372

110

148177528000100151

175240791604632110222

78

31220

6119

83

164121107

Consent Order Progress Report For
Third Quarter 2021

Replacement Drinking Water Actions(Replacement drinking water actions from November 20182 ‐ September 30, 2021)

2 The date the proposed Consent Order was lodged.

Consent Order Progress Report For
Third Quarter 2021

Consent Order Progress Details
This section summarizes the activities that have been undertaken by Chemours pursuant to theConsent Order Compliance Measures and Addendum for the period from July 1, 2021 through the endof the third quarter of 2021 (September 30, 2021). On August 13, 2020, Chemours signed theAddendum to Consent Order Paragraph 12, and the Addendum was entered by the Bladen County
Superior Court on October 12, 2020.

Section 7 Control Technology Improvements
The thermal oxidizer (see photo at right)
continues to control process emissions at anaverage PFAS destruction efficiency exceeding
99.99%.

Section 10 No Discharge of Process
Wastewater from Chemours’
Manufacturing Areas
Chemours does not discharge its processwastewater and instead collects and ships its
process wastewater offsite for disposal orrecycles treated water internally within several
manufacturing processes.

Section 11 Characterization of PFAS in
Process and Non‐Process Wastewater and Stormwater at the Facility
During the third quarter of 2021, two sampling events were conducted, one during August 17 – August23, 2021 (the August 2021 event) and the other during September 21 ‐ 24, 2021 (the September 2021
event). Samples were collected from 26 locations during the August 2021 event and from 27 locations
during the September 2021 event.
Results from three sampling events collected during January – June 2021 were reported in the firstsemi‐annual report of paragraph 11(d), ongoing sampling, which Chemours submitted on September
29, 2021. Findings from the first semi‐annual period were consistent with previous reporting under theparagraph 11 sampling program.

Section 12 Accelerated Reduction of PFAS Contamination in the Cape Fear River andDownstream Water Intakes, and Addendum to Consent Order Paragraph 12During the third quarter of 2021, Chemours continued operation of the treatment system for the Old
Outfall (Outfall 003) pursuant to Consent Order Paragraph 12(e) and a NPDES permit issued by NCDEQ.
As noted above, the Addendum to Consent Order Paragraph 12 was signed in the third quarter of 2020and entered by the Court during the fourth quarter of 2020. Chemours’ Addendum implementation
activities during the third quarter of 2021 included:

Consent Order Progress Report For
Third Quarter 2021
Consent Order Addendum Paragraph 1
On September 30, 2021, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear
River PFAS Mass Loading Assessment – Second Quarter 2021 Report pursuant to Consent Order
Addendum Paragraph 1(b). The report describes sampling activities and mass loading results for theCape Fear River and PFAS loading pathways from the second quarter of 2021. This submission was also
pursuant to quarterly reporting of mass loading sampling outlined in the Corrective Action Plan
(Paragraph 16). In each of July, August and September 2021, Chemours conducted monthly massloading sampling required by Consent Order Addendum Paragraph 1.
Consent Order Addendum Paragraph 2During the third quarter of 2021, Chemours operated and maintained the four flow‐through cells, i.e.,
the interim remediation systems, at Seeps A‐D. On July 30 and September 30, 2021, Chemours
submitted the Interim Seep Remediation Operation and Maintenance Reports #3 and #4, respectively.
The Operation and Maintenance reports describe the operations and maintenance activities at theflow‐through cells over the bimonthly reporting periods of May/June and July/August, respectively.
Additionally, on August 26, 2021, Chemours submitted the Interim Seep Remediation Seep A
Effectiveness Demonstration Report. This report provided a record of construction completion anddemonstration of interim effectiveness for the Seep A system.
Consent Order Addendum Paragraph 3
As required by the Addendum, the Black Creek Aquifer interim measure system to extract groundwaterfrom the seven existing Black Creek Aquifer monitoring wells (BCA‐01, BCA‐02, PW‐11, PW‐14, PW‐15R,
PIW‐9D, and PIW‐10DR) continued to operate in the third quarter as designed. During the third quarterof 2021 (July, August, and September), the system extracted 438,375 gallons of water for a total of
1,250,900 gallons since startup on November 30, 2020 through the last reading taken in September on
the 27th. During the last two weeks of September, electric submersible pumps were removed andreplaced with piston pumps at the four deeper extraction wells (BCA‐01, BCA‐02, PW‐14, and PW‐15R).
The new pumps are expected to provide reliable service in these wells. Otherwise, the wells havecontinued to operate as designed with only minor, routine shutdowns for maintenance or equipment
issues.
On August 13, 2021, Chemours submitted to NCDEQ the 60 percent design submittal package pursuant
to Consent Order Addendum Paragraph 3(b). This design report provides the 60 percent design of thegroundwater interception remedy, the ex‐situ capture remedy and the groundwater treatment plant.
This submittal package included a cover report, summarizing the remedy design, and had sevenappended reports (Appendix A through Appendix G) detailing the design basis and 60 percent designsof the individual remedy components.
On September 15, 2021, Chemours received a conditonal approval and comments from NCDEQ on the60% design submittal and PDI report. During the second half of September, Chemours was preparing
responses to NCDEQ’s comments for submittal in early October 2021.
Consent Order Addendum Paragraph 4
Operation of the stormwater treatment system began on June 30, 2021. Consistent with theStormwater Sampling Plan, Chemours conducted three sampling events in July 2021, four sampling
events in August 2021, and two sampling events in September 2021 to evaluate the treatment system’seffectiveness in removing indicator parameters HFPO‐DA, PFMOAA, and PMPA. Results from the July

Consent Order Progress Report For
Third Quarter 2021
2021 and August 2021 sampling events indicated the treatment system removed all three indicatorparameters to greater than 99%; September 2021 results are pending. The treatment system also
appears to have consistently captured stormwater runoff from precipitation events of up to the 1‐inch,
24‐hour design storm.
Pursuant to CO Addendum paragraph 4(c), Chemours submitted a report to NCDEQ on September 30,
2021 summarizing the stormwater treatment system capture and removal efficiency during the July –August 2021 evaluation period.

Section 14 Toxicity Studies
Updated protocols for the aquatic toxicology studies were submitted to NCDEQ on August 19 and
September 21, 2021. A meeting was scheduled (and held) with NCDEQ on October 14, 2021 to address
remaining open questions and comments.

Section 16 Groundwater Remediation
On September 30, 2021, Chemours submitted to NCDEQ and Cape Fear River Watch the Cape Fear
River PFAS Mass Loading Assessment – Second Quarter 2021 Report pursuant to Consent Order
Addendum Paragraph 1(b). This submission was also pursuant to quarterly reporting of mass loading
sampling outlined in the Corrective Action Plan (Paragraph 16). On‐going groundwater remediation
activities are being conducted pursuant to Consent Order Addendum Paragraph 3 and are describedearlier in this document under that paragraph. Pursuant to Corrective Action Plan monitoring
recommendations, annual groundwater sampling for Table 3+ PFAS and EPA Method 537 perfluoroalkyl
carboxylic acids (PFCAs) was conducted during the third quarter of 2021.

Sections 19 and 20 Provision of Public Water Supplies, Whole Building Filtration
Systems, and Reverse Osmosis Drinking Water Systems
As shown in the summary tables above, Chemours continues to make significant progress in
implementing the Consent Order requirements of Paragraphs 19 and 20. Since resuming ROinstallations in June 2020, following the COVID‐19 postponement period, the pace of RO acceptance
rates and installations has been on the rise. O&M activities for installed GAC systems continuesuninterrupted. Bottled water services continue uninterrupted for 2,491 homes. In September 2021,
Chemours entered into an agreement with Bladen County to fund public water system upgrades andconnections associated with providing permanent replacement drinking water supplies under theConsent Order.

Section 21 Private Well Testing
To date, 12,203 residences have been identified within the current study area, of which 7,380 havebeen sampled and 2,847 residences have received at least one initial sample offer letter. Results ofsampling that occurred throughout the third quarter of 2021 (528 residences) are presented at thebeginning of this progress report. Current Step‐out and Infill distance intervals range from 2.5 miles to17.5 miles from the Site.
Chemours continues to follow the private well cold calling protocol (i.e., to confirm residences,
tenant/owner name and phone number, addresses, not connected to public water, and residents’
willingness to have a sample collected from their drinking water well).

Consent Order Progress Report For
Third Quarter 2021

Section 22 Provision of Sampling Results
Chemours provided (and continues to provide) sampling results to NCDEQ and residents as required
under the Consent Order. Chemours has provided sampling results to NCDEQ by sending a courtesy
email notification and by uploading sampling results to the state Equis database. Chemours has also
provided final lab reports to NCDEQ. Chemours has provided sampling results to residents by including
preliminary results with water filtration system initial offer letters and sending the final lab reports toresidents within the following 30 days. Chemours has also provided non‐detect sampling results toresidents.

Section 23 Interim Replacement of Private Drinking Water Supplies
All residences eligible to receive the interim replacement drinking water supplies have received thesupplies (i.e., bottled water or voucher card for bottled water). As of September 30, 2021, there are2,491 residences receiving bottled water services.

Section 24 Drinking Water Compliance PlanAs discussed above, the off‐site replacement drinking water program continues. The Drinking Water
Compliance Plan is currently under review and some of the protocols are being revised based ondiscussions with NCDEQ in recent weeks. The revised Drinking Water Compliance Plan will be
submitted to NCDEQ in the coming weeks. The following revised procedures are currently
implemented based on approval by NCDEQ: Point‐of‐Use (POU) Granular Activated Carbon (GAC) filtration systems for commercial
establishments that were eligible for RO systems, pursuant to NCDEQ’s approval letter dated
January 5, 2021.
 Chemours connected six homes in Cumberland County to public water as part of a pilot programand a report was submitted to NCDEQ on June 25, 2021 and approved by NCDEQ on September
22, 2021. The program will now expand to include additional residences for public water
connection in the study area.
 Starting in the second quarter of 2020, the GAC OM&M sampling has been revised to include
quarterly sampling in between the lead and lag carbon vessel and one annual raw water sample.

Section 26 Total Organic Fluorine
Please see Appendix A for the quarterly progress report from Dr. Susan D. Richardson.

Section 28 ReportingChemours submitted the Consent Order second quarter 2021 progress report on July 29, 2021.

Sections 29 and 30 Public Information
Chemours has continued to post its Consent Order submissions at
https://www.chemours.com/Fayetteville‐Works/en‐us/c3‐dimer‐acid/compliance‐testing/.

Appendix A8th Progress Report
Development of a Total Organic Fluorine (TOF) Method for the Analysis ofProcessed Wastewater Streams and Air from Fayetteville Works (NC)
Susan D. Richardson, Alexandria L. Forster, University of South Carolina
October, 2021
Since the last progress report in July, focus has been on finalizing the Adsorbable Organic Fluorine (AOF)
method and further optimization of the Extractable Organic Fluorine (EOF) method.
1. Adsorbable Organic Fluorine (AOF)
The focus since July for the AOF method has been on wrapping up method parameter optimization andmoving towards using the optimized method to calculate percent recoveries for individual PFAS
standards and a mix of PFAS standards in ultra‐pure water and river water. To help improve inorganic
fluoride background levels, a carbon pre‐rinse step was tested before loading the sample onto thecarbons to understand if an anionic solution used before loading the sample would lower the adsorption
ability of inorganic fluoride to the carbons. After testing this step, experiments were aimed at using theoptimized method to test for percent recoveries for all 39 PFAS standards in ultra‐pure water. Percent
recoveries ranged from 64‐112% with smaller chain PFAS compounds having a lower percent recovery
as expected. A PFAS standard mix was also spiked into river water collected in Columbia, South Carolina
to test for percent recovery in a more realistic matrix. Percent recovery for the PFAS standard mix using
the optimized method was 87%.
Focus in further experiments will be to quantify percent recovery of the 39 PFAS standards individuallyin river water. Sample storage time has also been tested for one and two weeks after collecting samples,and experiments will be repeated at the one‐month interval. An LOQ and LOD was also calculated forthis method, but further optimization is being done to help lower these values.
2. Extractable Organic Fluorine (EOF)
Method parameter optimization experiments have been continued for the EOF method since the lastprogress report. These experiments have included the optimization of the conditioning, equilibration,
sample load, wash, drying, and elution step for composition, volume, and pH. Pre‐soaking the cartridges
before eluting has also been tested at varies times.
Focus in further experiments will be on the continuation of optimizing the EOF method parameters andmoving into using the optimized method for percent recoveries of all 39 PFAS standards individually andin a mix in ultra‐pure water and river water just as mentioned above in the AOF method for comparison.
Sample storage will also be tested over several time intervals as above, and LOQ and LOD values will also
be calculated.