UPDATED PFASCHARACTERIZATION SAMPLING
PLAN
Process and Non-Process Wastewater andStormwaterPrepared 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

May 1, 2019

TABLE OF CONTENTS
1.

INTRODUCTION ................................................................................................ 1
1.1 Background.................................................................................................. 1
1.1.1 Water Usage at the Facility ............................................................. 2
1.1.2 Analytical Methods ......................................................................... 2
1.2

Scope and Rationale .................................................................................... 2

2.

DATA QUALITY OBJECTIVES ........................................................................ 3

3.

SAMPLING PLAN .............................................................................................. 4
3.1 Sampling Locations ..................................................................................... 4
3.2 Sampling Schedule ...................................................................................... 4
3.3 Sampling Protocol ....................................................................................... 4
3.3.1 General Field Protocol .................................................................... 4
3.3.2 Sample Collection Considerations .................................................. 4
3.3.3 Decontamination Protocol............................................................... 9
3.4
3.5

Sample Shipping, Chain of Custody, and Holding Times ........................... 9
Quality Assurance/ Quality Control .......................................................... 10
3.5.1 Field QA/QC ................................................................................. 10

3.6

Documentation........................................................................................... 11

4.

TEST METHODS AND LABORATORY STANDARDS ............................... 12
4.1 Analytical Methods.................................................................................... 12
4.2 Laboratory QA/QC .................................................................................... 12

5.

DATA VERIFICATION .................................................................................... 15

6.

REPORTING ...................................................................................................... 17

7.

REFERENCES ................................................................................................... 18

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LIST OF TABLES
Table 1: PFAS and Associated Methods
Table 2: Criteria for Achieving Data Quality Objectives
Table 3: Description of Sampling Locations
Table 4: Sampling Containers, Preservation, and Holding Times
Table 5: Quality Assurance/ Quality Control Samples
LIST OF FIGURES
Figure 1: Site Location
Figure 2: Sample Locations
Figure 3: Gantt Chart of Proposed Sampling Schedule
ACRONYMS AND ABBREVIATIONSCFRW – Cape Fear River Watch
DEQ – Department of Environmental Quality
DWR – Division of Water Resources
HFPO-DA – hexafluoropropylene oxide dimer acid
IXM – Ion Exchange Membrane
NCCW – non-contact cooling water
PFAS – per- and polyfluoroalkyl substances
PFCA – perfluorocarboxylic acids
PFSA – perfluorosulfonic acids
PPA – Polymer Processing Aid
SOP – standard operating procedure
USEPA – United States Environmental Protection Agency

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1.

INTRODUCTION

This sampling plan (the Sampling Plan) was prepared by Geosyntec Consultants of NC,
P.C. (Geosyntec) for the Chemours Company FC, LLC (Chemours) to provide a plan forsampling and analysis of process wastewater, non-process wastewater (including noncontact cooling water, [NCCW], sanitary water, and utility water) and stormwater at the
Chemours Fayetteville Works, North Carolina site (the Facility, Figure 1). This Sampling
Plan is intended to address requirements specified in Paragraph 11(b) in the executedConsent Order dated 25 February 2019 between Chemours and the North Carolina
Department of Environmental Quality (DEQ) with the Cape Fear River Watch (CFRW)
as intervenor. Other parts of the Consent Order will be addressed separately by Chemours
and Chemours contractors.
The purpose of this plan is to obtain more information on the concentrations and temporal
trends of per- and polyfluoroalkyl substances (“PFAS”) in the three water types identified
above. The Sampling Plan may be updated at a later date as analytical methods arefurther improved.
1.1

Background

PFAS may be present in: 1) rainwater/stormwater, 2) as dry deposition from stackemissions that washes off with overland flow during rainfall events, 3) in groundwaterthat has been impacted by infiltration of PFAS to the subsurface, 4) process wastewater,
and/or 5) NCCW. Evaluation of the data collected to date indicates that PFAS present in
the Cape Fear River are partially attributable to emissions from the Facility and partiallyattributable to other regional sources. Chemours has taken numerous actions to reducereleases of PFAS from the Facility, including the following partial list:•••

Off-Site disposal of all Chemours process wastewater to reduce discharges to theCape Fear River as quickly as possible;
Installation of air emissions abatement controls in May, October, and December
2018; andExtraction and off-Site disposal of groundwater with elevated PFAS
concentrations from the perched aquifer.

Chemours continues to work towards further reducing PFAS emissions to air anddischarges to water by designing and installing enhanced PFAS abatement systems.

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1.1.1

Water Usage at the Facility

The Facility is adjacent to the Cape Fear River and draws water from the Cape Fear Riverand returns over 95% of this water via Site Outfall 002 after being used primarily as
NCCW. Rainfall at the Facility that does not evaporate or infiltrate to groundwater runs
off through a series of storm drains and ditches. Figures 1 and 2 show the known drains
and ditches.
The Facility has four chemical production areas, shown in Figure 1 and listed below:
•
•
•
•
1.1.2

Chemours Monomers Ion Exchange Membrane (IXM) Area;
Chemours Polymer Processing Aid (PPA) Area;
Kuraray America northern and southern leased areas (Kuraray Area); andDow-DuPont leased area (DuPont Area).
Analytical Methods

Two analytical methods have been employed to analyze PFAS, which include all thecompounds listed in Attachment C of the executed Consent Order:••

EPA Method 537 Mod (laboratory-specific standard operating procedure [SOP])– perfluorocarboxylic acids (PFCAs), perfluorosulfonic acids (PFSAs) andothers;Table 3+ laboratory-specific SOP

PFAS to be analyzed by the two methods listed above will include all the PFAS listed in
Attachment C of the executed Consent Order in addition to other analytes reported bythese methods, as summarized in Table 1. Additional samples will be collected andarchived as part of this sampling program for analysis by potential future analyticalmethods developed as part of the executed Consent Order.
1.2

Scope and Rationale

This Sampling Plan addresses requirements in Paragraph 11(b) as listed in the executedConsent Order. Chemours will conduct bimonthly sampling events for one year for theInitial Characterization and provide quarterly reports and prepare a final Initial
Characterization Report within 18 months of NCDEQ approval of this Sampling Plan.

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Chemours will continue bimonthly sampling events and quarterly reports during theOngoing Sampling for a period of two years (i.e., 12 events and eight reports).
2.

DATA QUALITY OBJECTIVES

Data quality objectives are established here to provide data of known and sufficientquality to accomplish the following:•••

Characterize concentrations of PFAS in process wastewater, non-processwastewater, and stormwater at the Facility;
Assess PFAS concentration trends over time in process wastewater, non-processwastewater, and stormwater; andDocument intake water quality (i.e., water drawn from the Cape Fear River for
use at the facility before reaching any manufacturing areas) to differentiate thecomponents of PFAS originating at the Facility.

The criteria for achieving the data quality objectives are provided in Table 2.

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3.

SAMPLING PLAN

3.1

Sampling Locations

Up to thirty-two investigative samples will be collected during each of the Initial
Characterization events at locations shown on Figure 2 and listed in Table 3.
3.2

Sampling Schedule

The proposed sampling and reporting schedule is provided in a Gantt Chart (Figure 3).
3.3

Sampling Protocol

3.3.1

General Field Protocol

All equipment will be inspected by the field program on-Site supervisor and calibrated
daily prior to use in the field according to the manufacturer’s recommendations.
Calibration information will be recorded. Field parameters will be measured with a water
quality meter prior to sample collection and then recorded. Field parameters will include
the following:
•
•
•
•
•
•
•
•
3.3.2

pH;
Temperature (degrees Celsius; °C);
Specific conductance [SC] (micromhos, μmho);
Dissolved oxygen [DO] (milligrams per liter; mg/L);
Oxidation/Reduction Potential [ORP] (millivolts; mV);
Turbidity (nephelometric turbidity units, NTU);
Color; andOdor.
Sample Collection Considerations

Samples containing process wastewater, non-process wastewater, and stormwater will becollected as part of this Sampling Plan. Sample collection considerations common to all
sample types are outlined below and summarized in Table 4. Detailed sampling
procedures can be found in the PFAS Quality Assurance Project Plan (QAPP) (AECOM,2018).

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All sample locations that include or are intended to be exclusively stormwater (Locations
1-5, 7, 9-15, 20, 21A, and 21B) will be sampled contemporaneously during storm events.
All sample locations that are not intended to include stormwater (i.e., NCCW and processwastewater) that could potentially be biased by stormwater during a storm event (6A, 6B,
8, 18, 19A, 19B, 22, 23, 24A, 24B, and 24C) will be sampled on the next working day
following the storm event where there is no precipitation in the forecast. Locations 16,
17A, and 17B are sampled from closed systems that can be sampled without stormwaterbiasing the sample, so they will be sampled at any convenient time within a samplinground.
The sample bottles will be 250 milliliter (mL) high density polyethylene (HDPE) with awide-mouth screw-cap. For all samples, bottles will be pre-cleaned by the vendor tominimize the risk of unplanned sample contamination from the sample container (i.e.,
blank contamination).
Sample bottles will be filled and the caps will be securely fastened after sample collection.
For each sample, sufficient water will be collected to fill seven bottles (two for EPA
Method 537 Mod, one for Table 3+, and four bottles to be archive at 4oC for potential
future analyses). Each sample will be labelled with a unique sample identification
number, date, time and location of sampling, and the initials of the individual collecting
the sample. A field form will be used to record information regarding additional items
such as quality assurance/ quality control (QA/QC), sample identifications, color, odor,
turbidity, and other field parameters. Some samples will be collected as grab samples(i.e., instantaneous) and some samples will be collected as temporal composite samples.
Table 3 lists the sampling method for each sample location.
Grab Sample Considerations
Grab samples are appropriate where temporal variability over the course of one day is notexpected at the sampling location. These locations include NCCW samples and processwastewater samples. All grab samples except for 21A and 21B (the Sediment Basins) will
be collected by directly filling the HDPE bottle with sample. The method to collectsamples at 21A and 21B is described further below. Prior to grab sample collection, fieldparameters will be measured by filling a flow through cell, either directly using a dip rod
or via a peristaltic pump.

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Non-Contact Cooling Water
NCCW samples will be collected as grab samples from the NCCW discharge points
before these waters flow into the Site Drainage Network for Kuraray and Chemours
manufacturing areas (Locations 6A, 6B, 24A, 24B, and 24C). There are multiple NCCW
discharges from each of these areas to the Site Drainage Network, therefore multiple
individual grab samples will be collected within the reach of each location shown on
Figure 2. Individual grab samples will be poured into 250-mL HDPE bottles.
If these split locations are found to be similar to each other in compounds detected andconcentrations of compounds detected during the first sampling event, they may becomposited into single samples for analysis in subsequent sampling events. This will bedone by pouring individual grab samples into a stainless-steel pot then pouring thecomposited sample from the pot into HDPE bottles.
Process Wastewater
Process wastewater samples will be collected as grab samples from the Chemours
Monomers IXM Area, Chemours PPA Area, Kuraray and DuPont (Locations 16 to 19,
22, 23A and 23B). Some process wastewater locations will be collected as split samples(e.g., "A" and "B" samples) during the first sampling event. These split locations may becomposited into a single sample for analysis in subsequent sampling events if thecomposition of the split samples are similar to each other in compounds detected andconcentrations of detected compounds. Composting will be done in the same manner as
described for NCCW above.
Grab samples are appropriate for the Chemours process wastewater samples (Locations
16, 17A, and 17B) since these samples are collected from tanks that composite
wastewater over several days before being taken off site by tanker truck. Grab samples
are also appropriate for the DuPont process wastewater samples (Locations 19A and 19B)
since these samples accumulate in a tank at the DuPont facility before being released tothe sump at the wastewater treatment plant.
For the first sampling event, temporal variability of the Kuraray process wastewaterlocations (Locations 18 and 23A) will be assessed by collecting and analyzing 4 separate
grab samples at 4-hour intervals over the course of 12 hours. Data will be evaluated todetermine whether autosamplers are required for subsequent sampling events.

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One sample will be collected at Location 23B during the first sampling event. If analyticalresults indicate PFAS concentrations greater than historical ranges for PFAS intake water,then Location 23B will also be sampled in subsequent sampling events.
Sediment Basins
Combined stormwater and excess intake water samples will be collected as grab samples
from the south or north sediment basin, whichever is actively being used (Locations 21A
and 21B). These basins discharge to the Site Drainage Network when basin water levels
become higher than a riser pipe. Water near the effluent point (i.e. where the basin water
enters the riser pipe) will be captured from shore using a pole to reach to within 8 feet ofthe riser pipe, from the depth of the sediment basin equivalent to the height of the riser
pipe. This method will capture water that is representative of the effluent from thesediment basins and is safe for the field team to implement.
Wastewater Treatment Plant Combined Influent
Grab samples will be collected from the combined influent to the wastewater treatment
plant (WWTP, Location 22). WWTP influent consists of untreated Kuraray and DuPont
process wastewater and non-process wastewater (i.e., Facility sanitary and utility water).
Temporal Composite Sample Considerations
Temporal composite samples are appropriate where variability is expected to besignificant within a short time frame (e.g., one day). Temporal composite samples will becollected for locations containing stormwater including intake and outfall samples, since
stormwater can have highly variable dissolved and suspended constituents loads overshort time periods. Composite samples will be collected using a dedicated Teledyne
6712C autosampler equipped with a rain gauge or similar device. HDPE tubing, silicontubing, and an HDPE sample reservoir will be used during sample collection. HDPE
tubing will be placed at approximately the mid-depth of the water stream, held in placewith a weight or a float, and capped with a stainless-steel strainer to avoid clogging thetubing. Field parameters will be measured twice for temporal composite samples: once
during composite sampling (collected directly from the water stream), and once after
composite sampling (collected from the autosampler reservoir). The field parameters
recorded directly from the water stream will represent the instantaneous water quality for
one timepoint. The field parameters recorded from the autosampler reservoir will
represent the time integrated water quality for the entire composited sample.
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Temporal composite samples will be collected once every two months when there is a
70% or greater chance of a storm event predicted to last at least 4 hours and have at least
0.5" of rainfall, following an antecedent dry period lasting at least 72 hours. National
Oceanic and Atmospheric Administration (NOAA) weather data will be used to track
regional weather and identify storm events that meet these criteria. Local and sitemeteorological data suggests that there will be multiple storm events of this nature in each
two month period, however if there is a two month period with no storm events meetingthese criteria, some stormwater sampling locations may not contain any water, in whichcase they will not be sampled. Autosamplers will be switched on 1-2 hours ahead of thepredicted storm event, and they will start collecting aliquots once their dedicated rain
gages or similar device collect 0.1" of water. Water will be composited over either 4 or 8hours, depending on the predicted length of the storm event, and 10-12 aliquots will becomposited over the course of the storm event. These criteria may be updated at a later
date based on experiences and data from implementing these characterization events.
Following sample collection, the composited samples will be poured into 250 mL HDPE
bottles.
Since sorption and volatilization losses for PFAS are not well characterized, a grab
sample will be collected at one temporal composite location during each sampling event.
Detection and abundance of PFAS will be compared in the grab sample and the temporalcomposite sample to assess whether there were losses in the temporal composite sample.
Intake Sampling Point - Excess River Water Discharge Point
Intake water will be collected as a temporal composite sample at the point where Excess
River Water (Location 1) discharges into the Site Drainage Network. Excess intake wateris withdrawn from the Cape Fear River, but not used as process water or NCCW. It
represents the chemical composition of river water prior to use as process and non-processwater.
Outfall 002
Outfall 002 water will be collected as a temporal composite sample from the OpenChannel just before entering the pipe to the river (Location 20). Outfall 002 is wherestormwater, NCCW and treated, non-Chemours process wastewater combine prior todischarge to the Cape Fear River.

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Wastewater Treatment Plant Discharge
The discharge from the WWTP will be collected at Outfall 001 (Location 8) as acomposite sample.
3.3.3

Decontamination Protocol

Sample containers will be new and used only once for each sample and disposable
equipment (e.g., gloves, tubing, etc.) will not be reused, therefore; these items will not
require decontamination.
All non-dedicated or non-disposable sampling equipment (i.e., the autosampler reservoir
and the aluminum pole) will be decontaminated immediately before sample collection in
the following manner:•••

De-ionized water rinse;
Scrub with de-ionized water containing non-phosphate detergent (i.e.,
Alconox®); andDe-ionized water rinse.

If there is a delay between decontamination and sample collection, decontaminatedsampling equipment will be covered with PFAS-free plastic until it is ready for use.
3.4

Sample Shipping, Chain of Custody, and Holding Times

Upon sample collection, each containerized sample will be labelled and placed as soon
as possible into a heavy plastic bag inside an insulated sample cooler with ice. The cooler
will serve as a shipping container and will be provided by the laboratory along with theappropriate sample containers. Chemours will request that samples be analyzed by thelaboratory within the holding times specified in Table 4. The additional samples collected
at each location for potential future analyses will be stored under chain of custody (COC)
in a secured, refrigerated location on site.
Prior to shipment of the samples to the laboratory, a COC form will be completed by thefield sample custodian. Sample locations, sample identification numbers, description ofsamples, number of samples collected, and specific laboratory analyses to be performedon each sample will be recorded on the COC form. The COC will be signed by the field
personnel relinquishing the samples to the courier and will be signed by the laboratory

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upon receipt of the cooler. The cooler will be taped shut and signed across the lid of thecooler, and the laboratory personnel will confirm the signature is intact upon receipt.
3.5

Quality Assurance/ Quality Control

QA/QC activities will be performed in the field and in the laboratories to document thedata quality. Each are described in the subsections below and summarized in Table 5.
3.5.1

Field QA/QC

Field QA/QC samples will be collected and analyzed along with the investigative samples
to determine the potential bias and variability introduced in sample collection, storage,
handling and shipping. Criteria for achieving data quality objectives for field QA/QC
samples are summarized in Table 2. During the Initial Characterization period four typesof field QA/QC samples will be collected: equipment blanks, trip blanks, field blanks andfield duplicates.
Equipment Blanks
Equipment blanks (field rinsate blanks) are used to evaluate equipment and cleaning or
decontamination procedures. At the sample location, laboratory-supplied analyte-freewater will be poured over or through the clean, non-dedicated sampling equipment, andcollected in a sample container. The equipment blank samples will then be shipped,
stored and handled with the other samples and will be analyzed for the same parameters
as other samples collected using the same device. Equipment blanks will be collected ata frequency of one per day during Initial Characterization and Ongoing Sampling.
Trip Blanks
Trip blanks are used to assess whether samples might be inadvertently contaminatedduring shipment and handling. The trip blanks will consist of a series of new containers
filled with analyte-free water prepared by the laboratory analyzing the samples and willtravel to the Facility with the empty sample bottles and back from the Facility with theinvestigative samples. Trip blanks will not be opened in the field. Trip blanks will becollected at a frequency of one per day during Initial Characterization and Ongoing
Sampling.

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Field Blanks
Field blanks are used to assess whether field conditions pose a potential for bias orvariability in the results of analysis. The field blank will be collected by transferringlaboratory-supplied analyte-free water into a sample container without contacting anyother sampling equipment. Field blanks will be collected at a frequency of one per day
during Initial Characterization and Ongoing Sampling.
Field Duplicates
Duplicate samples are collected to assess the precision of the laboratory analysis throughcalculation of the relative percent difference (RPD) between duplicate samples. The
equation for calculating RPD is shown below:
𝑅𝑅𝑅𝑅𝑅𝑅(%) =|(𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 1 − 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑒𝑒 2)|
× 100%(𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 1 + 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 2)��2

RPDs less than or equal to 25% indicate acceptable precision at mid and high range
concentrations; RPDs less than or equal to 50% indicate acceptable precision within afactor of five of the reporting limit. Duplicates will be collected in the same manner as
investigative samples and the duplicate samples will be analyzed for the same parameters
as the co-located investigative sample. Duplicates will be numbered sequentially withinvestigative samples so they are not identifiable by the analytical laboratories (i.e.,“blind” duplicates). Field duplicate samples will be collected at a frequency of one
duplicate for every 20 investigative samples (i.e., two duplicates for every sampling
event).
3.6

Documentation

The project field team will keep a daily record of field activities during the execution offield work including sampling notes and observations, instrument calibration records,
measured field parameters, sample COC and shipping records. All field collected data
will be furnished to Chemours within 10 business days of the conclusion of the field
event.

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4.

TEST METHODS AND LABORATORY STANDARDS

4.1

Analytical Methods

Collected samples will be analyzed by the following three laboratory methods:••
4.2

EPA Method 537 Mod (Laboratory SOP); andTable 3+ Laboratory SOP.
Laboratory QA/QC

Laboratory QA/QC procedures will be employed to document the quality of the data
resulting from the analytical programs. Laboratory procedures will include method
blanks, matrix spikes (MS), laboratory replicate samples, laboratory control samples(LCS), isotope dilution analytes (IDA), and continuing calibration verification (CCV) toverify and document the precision and accuracy of the results of analysis. The laboratory
will prepare and analyze all samples according to their in-house Standard Operating
Procedures (SOPs) and laboratory Quality Assurance Plans (QAPs). Data quality
objectives for laboratory QA/QC samples are summarized in Table 2.
Method Blanks
Method blanks are used to evaluate laboratory contamination. Laboratory-supplied
analyte-free water will be analyzed for the same parameters as investigative samples.
Method blanks will be analyzed at a frequency of one per sample group up to 20
investigative samples at the laboratory. Method blanks with no detected target analytes
are considered acceptable. If target analytes are detected in the method blanks, associateddata for investigative samples will be B-qualified if the concentrations are less than 5times higher than the concentration detected in the method blank.
Matrix Spike
A matrix spike (MS) is a subsample of an investigative sample to which the laboratory
adds a spike containing target analytes at known concentrations prior to
extraction/analysis of the sample to assess the effect of sample matrix on the extraction
and analysis procedures. A matrix spike sample will be analyzed by the laboratory once
for each sample group (of the same matrix) or at a minimum of one in every 20 samples

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1-May-19analyzed. The percent recovery of the MS is calculated to document the accuracy of themethod for the matrix. Percent recovery is calculated as follows:% 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 = �

𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑜𝑜𝑜𝑜 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 − 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑜𝑜𝑜𝑜 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆
� × 100%
𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑜𝑜𝑜𝑜 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆

Percent recoveries within the range of 70% to 130% indicate acceptable accuracy. If thepercent recovery is greater than the range of acceptable accuracy, detected results will be
J-qualified. If the percent recovery is lower than the range of acceptable accuracy,
detected results will be J-qualified and non-detect results will be UJ-qualified. If thepercent recovery is less than 10%, results may be R-qualified, pending evaluation by thedata reviewer.
Laboratory Replicate Samples
Laboratory replicate samples are subsamples of the same investigative sample, split andanalyzed by the laboratory to assess the precision of the laboratory analysis throughcalculation of the RPD. Laboratory replicate samples will be analyzed at a frequency of
one per sample group, up to 20 investigative samples analyzed. RPDs less than or equal
to 25% indicate acceptable precision at mid and high range concentrations; RPDs lessthan or equal to 50% indicate acceptable precision within a factor of five of the reporting
limit. If the RPD is outside the acceptable precision range, associated results will be Jqualified.
Laboratory Control Samples (Second Source Standard)
LCS (otherwise known as second source standards) are samples prepared by thelaboratory with known concentrations of target analytes prepared from a source that isdifferent than the standards used to calibrate the instrument. The percent recovery of the
LCS is calculated to document the accuracy of the method. LCS samples will be analyzed
at a frequency of one per sample group. Percent recoveries within the range of 70% to130% indicate acceptable accuracy. If the percent recovery is greater than the range ofacceptable accuracy, detected results will be J-qualified. If the percent recovery is lower
than the range of acceptable accuracy, detected results will be J-qualified and non-detect
results will be UJ-qualified. If the percent recovery is less than 10%, results may be Rqualified, pending evaluation by the data reviewer.

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Isotope Dilution Analytes (IDA)
Isotope dilution analytes (IDA) consist of carbon-13 labeled analogs, oxygen-18 labeledanalogs, or deuterated analogs of the compounds of interest, and they are spiked into thesamples at the time of extraction. This technique allows for the correction for analyticalbias encountered when analyzing more chemically complex environmental samples. The
isotopically labeled compounds are chemically similar to the compounds of concern andare therefore affected by sample-related interferences to the same extent as thecompounds of concern. Compounds that do not have an identically labeled analog arequantitated by the IDA method using a closely related labeled analog. IDAs are added in
known amounts to all (100%) investigative and quality control samples where appropriate
IDAs are available. The percent recovery of the surrogate is calculated to document theaccuracy of the method. Recoveries in the range of 25% to 150% indicate acceptableaccuracy. If the percent recovery is outside the range of acceptable accuracy, detected
results will be J-qualified. If the percent recovery is lower than the range of acceptableaccuracy, detected results will be J-qualified and non-detect results will be UJ-qualified.
If the percent recovery is less than 10%, results may be R-qualified, pending evaluationby the data reviewer.
Continuing Calibration Verification
CCV samples are samples prepared with known concentrations of target analytes fromthe primary standards used to calibrate the instrument. They are analyzed periodically toverify the instrument calibration is still acceptable before analyses are performed oninvestigative samples. A percent difference (%D) is calculated to document thecontinuing calibration of the instrument. %D values less than or equal to 30% indicate
acceptable calibration. If the %D is outside the acceptable range, associated results
detected at or above 5 times the PQL will be J-qualified.

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5.

DATA VERIFICATION

The analytical laboratory performing the analysis will provide all analytical data to
Chemours’ data verification contractor, AECOM’s in-house Analytical Data Quality
Management (ADQM) group. The data package will be reviewed by ADQM forcompliance with the laboratory SOPs and usability. The laboratory will also deliver the
analytical data electronically for upload to the Chemours Locus EIM™ database.
All data will be reviewed using the Data Verification Module (DVM). The DVM is an
automated database algorithm developed by the ADQM group that includes a series ofdata quality checks, which are binary (yes/no) and do not require professional judgement.
Manual review is performed after the DVM process to address validation componentsthat are not readily automated. The data are evaluated against the following data usability
checks:
•
•
•
•
•
•
•
•
•

Field and laboratory blank contamination
USEPA hold time criteria
Missing quality control samples
MS recoveries to verify measurement precision
LCS recoveries verify measurement precision
Surrogate spike recoveries to verify measurement accuracy
RPD between field duplicate sample pairs to verify field duplicate precision
Completeness as a percentage of the planned samples actually collected andanalyzed
Sensitivity of the PQL compared to regulatory standards or screening levels

The DVM applies the following data evaluation qualifiers to analysis results, aswarranted:••••

TR0795

R - Unusable result. Analyte may or may not be present in the sample.
B – Not detected substantially above the level reported in the laboratory or fieldblanks.
J – Analyte present. Reported value may not be accurate or precise.
UJ – Not detected. Reporting limit may not be accurate or precise.

15

1-May-19

An individual DVM narrative report will be generated for each lot entered into the EIM™
database which will summarize any samples that are qualified, the specific reasons forthe qualification, and the potential bias in reported results.
The DVM review process described above will be performed on 100% of the data
generated for the sampling event. The DVM review process will be supplemented by amanual review of the instrument- related QC results for calibration standards, blanks, andrecoveries to elevate the overall review process to be consistent with Stage 2b of the EPA
Guidance for Labelling Externally Validated Laboratory Analytical Data for Superfund
Use (EPA-540-R-08-005, 2009).

TR0795

16

1-May-19

6.

REPORTING

Quarterly reports will be submitted for the Initial Characterization as specified in subpart11(c) of the executed Consent Order. In compliance with Subpart 11(d), Chemours willreport quarterly during the Ongoing Sampling period. Sampling will be performed every
two months beginning within 30 days of approval of this Sampling Plan. The sampling
and reporting schedule is summarized in Figure 3. Each quarterly report will include amap of sample locations, data tables of measured concentrations and data review
summary.

TR079517

1-May-19

7.

REFERENCES

AECOM, 2018. Poly and Perfluoroalkyl Substance Quality Assurance Project Plan for the
Chemours Corporate Remediation Group. August, 2018.
Chemours, 2017. Chemours Announces Voluntary Actions to Respond to North Carolina
Community. http://pages.chemours.com/FayettevilleStatement.html. Accessed March
18, 2018.
Chemours, 2018 – May 2018 abatement measures.

TR079518

1-May-19

TABLESGeosyntec Consultants

TABLE 1PFAS AND ASSOCIATED METHODS
Chemours Fayetteville Works, North Carolina
Analytical Method

Common Name

Chemical Name

HFPO-DA
Hexafluoropropylene oxide dimer acid
PEPA
Perfluoroethoxypropyl carboxylic acidPFECA-G
Perfluoro-4-isopropoxybutanoic acidPFMOAA
Perfluoro-2-methoxyaceticacid
PFO2HxA
Perfluoro(3,5-dioxahexanoic) acid
PFO3OA
Perfluoro(3,5,7-trioxaoctanoic) acidPFO4DA
Perfluoro(3,5,7,9-tetraoxadecanoic) acid
PMPA
Perfluoromethoxypropyl carboxylic acid
Hydro-EVE Acid
Perfluoroethoxsypropanoic acid
EVE Acid
Perflouroethoxypropionic acid
MMF
Difluoromalonic acid
MTP
Perfluoro-2-methoxypropanoic acid
Table 3+ Lab SOP
PPF Acid
Pentafluoropentionic acidPFECA B
Perfluoro-3,6-dioxaheptanoic acid
R-EVE
R-EVE
PFO5DA
Perfluoro-3,5,7,9,11-pentaoxadodecanoic acid
Byproduct 4
Byproduct 4
Byproduct 6
Byproduct 6
Byproduct 5
Byproduct 5
DFSA
Difluoro-sulfo-acetic acid
NVHOS
Perflouroethoxysulfonic acid
PES
Perfluoroethoxyethanesulfonic acid
PFESA-BP1
Byproduct 1
PFESA-BP2
Byproduct 2
PFBA
Perfluorobutanoic acid
PFDA
Perfluorodecanoic acid
PFDoA
Perfluorododecanoic acid
PFHpA
Perfluoroheptanoic acid
PFNA
Perfluorononanoic acid
PFOA
Perfluorooctanoic acid
PFPeA
Perfluorohexanoic acid
PFPeA
Perfluoropentanoic acid
PFTeA
Perfluorotetradecanoic acid
PFTriA
Perfluorotridecanoic acid
PFUnA
Perfluoroundecanoic acid
PFBS
Perfluorobutanesulfonic acid
PFDS
Perfluorodecanesulfonic acid
PFHpS
Perfluoroheptanesulfonic acid
PFHxS
Perfluorohexanesulfonic acid
Perfluorononanesulfonic acid
EPA Method 537 Mod PFNS
PFOS
Perfluorooctanesulfonic acid
PFPeS
Perfluoropentanesulfonic acid
10:6 FTS
10:2-fluorotelomersulfonic acid
4:2 FTS
4:2 fluorotelomersulfonic acid
6:2 FTS
6:2 fluorotelomersulfonic acid
8:2 FTS
8:2 fluorotelomersulfonic acid
NEtFOSAA
NEtFOSAA
NEtPFOSANEtPFOSANEtPFOSAE
NEtPFOSAE
NMeFOSAA
NMeFOSAA
NMePFOSA
NMePFOSA
NMePFOSAE
NMePFOSAE
PFDOS
Perfluorododecanesulfonic acid
PFODA
Perfluorohexadecanoic acid
PFODA
Perfluorooctadecanoic acid
PFOSA
Perfluorooctanesulfonamide
Notes:
PQLs are listed as of March 31, 2019.
EPA - Environmental Protection Agency
ng/L - nanograms per liter
PFAS - per- and polyfluoroalkyl substances
PQL - practical quantitation limit
SOP - Standard Operating Procedure

CASN
13252-13-6
267239-61-2
801212-59-9
674-13-539492-88-1
39492-89-2
39492-90-5
13140-29-9773804-62-9
69087-46-3
1514-85-893449-21-9
422-64-0
151772-58-6
N/A
39492-91-6
N/A
N/A
N/A
422-67-3
1132933-86-8
113507-82-7
29311-67-9749836-20-2
375-22-4
335-76-2
307-55-1
375-85-9
375-95-1
335-67-1
307-24-4
2706-90-3
376-06-7
72629-94-8
2058-94-8
375-73-5
335-77-3
375-92-8
355-46-4
68259-12-1
1763-23-1
2706-91-4
120226-60-0
757124-72-4
27619-97-2
39108-34-4
2991-50-6
4151-50-2
1691-99-2
2355-31-931506-32-8
24448-09-7
79780-39-5
67905-19-5
16517-11-6
754-91-6

Chemical FormulaC6HF11O3
C5HF9O3
C12H9F9O3S
C3HF5O3C4HF7O4C5HF9O5C6HF11O6
C4HF7O3
C8H2F14O4
C8HF13O4
C3H2F2O4
C4H4F4O3
C3HF5O2C5HF9O4
C8H2F12O5
C7HF13O7
C7H2F12O6S
C6H2F12O4S
C7H3F11O7S
C2H2F2O5S
C4H2F8O4S
C4HF9O4SC7HF13O5S
C7H2F14O5S
C4HF7O2C10HF19O2
C12HF23O2
C7HF13O2
C9HF17O2
C8HF15OC5HF9O2C5HF9O2C14HF27O2
C13HF25O2
C11HF21O2
C4HF9SO
C10HF21O3SC7HF15O3SC6HF13SO3
C9HF19O3S
C8HF17SO3
C5HF11O3S
C12H5F21O3
C6H5F9O3S
C8H5F13SO3
C10H5F17O3S
C12H8F17NO4S
C10H6F17NO2S
C12H10F17NO3S
C11H6F17NO4S
C9H4F17NO2S
C11H8F17NO3SC12HF25O3S
C16HF31O2
C18HF35O2
C8H2F17NO2S

PQL (ng/L)
Eurofins
TestAmerica
Lancaster
2.0
2.0
20
20
2.0
2.0
5.0
5.0
2.0
2.0
2.0
2.0
2.0
2.0
10
10
2.0
2.0
2.0
2.0
100
100
20
20
20
20
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
100
100
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
5.5
2.0
1.8
2.0
1.8
2.0
0.91
2.0
1.8
2.0
0.91
2.0
1.8
2.0
5.5
2.0
0.91
2.0
0.91
2.0
1.8
2.0
0.91
2.0
1.8
2.0
1.8
2.0
1.8
2.0
1.8
2.0
1.8
2.0
1.8
2.0
2.7
20
2.7
20
1.8
20
5.5
20
2.7
2.0
8.2
2.0
2.7
20
2.7
2.0
8.2
2.0
2.7
2.0
0.91
2.0
0.91
2.0
1.8
2.0
2.7

May 2019

TABLE 2
Geosyntec Consultants
CRITERIA FOR ACHIEVING DATA QUALITY OBJECTIVES
Chemours Fayetteville Works, North Carolina
Category

Data Quality Objective

Criteria

Field Duplicate RPD (%)

25*

Lab Replicate RPD (%)

25*

MS % Recovery

70-130

LCS % Recovery

70-130

Isotope Dilution Analyte %Recovery25-150Calibration

CCV % Difference70-130Completeness% Complete

90

Precision

Accuracy

Notes* RPD criteria is 25%, or 50% within a factor of five of the reporting limit.
Criteria may be replaced by statistical limits generated by the laboratory(ies).
CCV - continuing calibration verification
LCS - laboratory control sample
MS - matrix spike
RPD - relative percent difference

May 2019

Geosyntec Consultants

TABLE 3DESCRIPTION OF SAMPLING LOCATIONS
Chemours Fayetteville Works, North Carolina

Sample Category
SampleNumberSample Location Description

1

Discharge point of excess river water (i.e., water drawn fromthe Cape Fear River, but not used as process water or NCCW)
to characterize background levels of PFAS

2

Kuraray northern leased area stormwater discharge

3

Chemours PPA area stormwater discharge

4

Combined stormwater discharge from Kuraray northern leased
area and Chemours PPA area

5

Kuraray southern leased area stormwater

6A*

Kuraray southern leased area NCCW discharge - Vacuum
Condenser

Sampling
MethodIntake/OutfallTemporalComposite

IntakeProcess water

Non-processwastewater

TemporalComposite
TemporalComposite
TemporalComposite
TemporalComposite

Stormwater






Grab



6B*

Kuraray southern leased area NCCW discharge - Resins Area

Grab



7A

Combined stormwater and NCCW discharge from western
portion of the Facility

TemporalComposite





7B

Combined stormwater and NCCW discharge from western
portion of the Facility and treated discharge from WWTP

TemporalComposite**







8*

Outfall 001 - Wastewater Treatment Plant Discharge to open
channel flowing to Outfall 002. Contains treated non-Chemours
process wastewater and treated sanitary water.

TemporalComposite

9Chemours Monomers IXM NCCW and stormwater discharge
including stormwater from Vinyl Ethers South and Vinyl Ethers
North

TemporalComposite

10

Chemours Monomers IXM area stormwater discharge

11
12
13

Stormwater discharge from portion of grassy field to north ofdecommissioned Chemours Teflon area.
DuPont area southern drainage ditch stormwater discharge and
NCCW
DuPont area northern drainage ditch stormwater discharge and
NCCW

14

DuPont area southeast stormwater and NCCW discharge

15

Combined stormwater and NCCW discharge from eastern
portion of the Facility



TemporalComposite
TemporalComposite
TemporalComposite
TemporalComposite
TemporalComposite
TemporalComposite




Grab



Grab
Grab
Grab
Grab
Grab
TemporalComposite
Grab
Grab
Grab


























16

Chemours Monomers IXM Area combined process wastewater

17A
17B
18*
19A*
19B*

Chemours PPA Area waste acid stream into trailer
Chemours PPA Area waste rinse water trailer
Kuraray process wastewater
DuPont process wastewater, Plant 1
DuPont process wastewater, Plant 2

20

Outfall 002 pipe to Cape Fear River

21A
21B
22*

23B*
24A*

Sediment Basin South
Sediment Basin North
WWTP Combined Influent
Kuraray northern leased area combined process wastewater andnon-process wastewater
Kuraray laboratory process wastewater‡
Chemours Monomers IXM Vinyl Ethers South NCCW

24B*

Chemours Monomers IXM Line 3 and Line 4 Extruder NCCW

Grab



24C*

Chemours Monomers IXM Water Return Header NCCW

Grab



23A*



Outfall







Grab





Grab
Grab




Notes
Sample numbers refer to locations identified in Figure 2
Some locations will be collected as split locations (e.g., "A" and "B" samples) during the first sampling event. These split locations may be composited intoa single sample for analysis in subsequent sampling events if the composition of the split samples are similar to each other in compounds detected andconcentrations of detected compounds.
NCCW - non-contact cooling water
PPA - polymer processing aid
WWTP - Wastewater treatment plant* - Samples will be collected during dry weather only, on the next working day with dry weather following a storm event.
** - Location 7B will be a grab sample for the first sampling event due to time constraints associated with acquiring an autosampler. For subsequent events,
Location 7B will be a temporal composite sample.
‡ - Location 23B will be sampled during the first sampling event. If analytical results indicate PFAS concentrations greater than historical ranges for PFAS
intake water then this location will also be sampled in subsequent sampling events.

May 2019

TABLE 4
SAMPLING CONTAINERS, PRESERVATION, AND HOLDING TIMES
Chemours Fayetteville Works, North Carolina
Analytical Method

Container Type andNumber of Containers
VolumePreservation

Geosyntec Consultants

Holding Times
TestAmerica
Eurofins Lancaster14 days to extraction, 14 days to extraction,
40 days to analysis
28 days to analysis

EPA Method 537 Mod

250 mL HDPE

2

None

Table 3+ Lab SOP

250 mL HDPE

1

None

28 Days

14 days

Non-Targeted
Analysis(1)250 mL HDPE

4(1)

None

14 days to extraction,
40 days to analysis

14 days to extraction,
28 days to analysis

Archived for potential
future analyses

250 mL HDPE

4

None

14 days to extraction,
40 days to analysis

14 days to extraction,
28 days to analysis

Notes:HDPE - high density polyethylene
SOP - Standard Operating Procedure(1) - Simultaneous samples will be collected for non-targeted analysis at select locations during the first sampling event, and at Location 16(Monomers IXM process wastewater) during each sampling event for the first year. The field team implementing this plan should refer to the PFAS
Non-Targeted Analysis and Methods Development Plan (Chemours, January 2019) for details on sample locations.

May 2019

Geosyntec Consultants

TABLE 5QUALITY ASSURANCE/ QUALITY CONTROL SAMPLES
Chemours Fayetteville Works, North Carolina
Field

Lab
IsotopeContinuing
Dilution
Lab Control
Calibration
1
Analytes
Matrix Spike Lab Replicate
SampleVerification(per sample(per sample(per sample (every sample) (beginning ofgroup)
group)
group)
each group)

Analytical
MethodInvestigative
Samples1(per event)

Equipment
Blank(per day)Trip Blank(per day)Field Blank(per day)

Field
Duplicate(per 20
samples)

MethodBlank(per sample
group)EPA Method
537 Mod

32

1

1

1

1

1

1

1

1

32

1

Table 3+ Lab
SOP

32

1

1

1

1

1

1

1

1

N/A

1

Notes:
1 - Number of samples may be subject to change following Initial Characterization
N/A - none available at present
SOP - Standard Operating Procedure

May 2019

FIGURES³
Chemours
PPA Area

Chemours Monomers IXM Area
Kuraray America
Leased Areas

Chemours
Former Teflon
Production Area

Wastewater
Treatment
Plant
Dupont / Dow
Leased Area

Path: E:\TR0726\Saved Keep\TR0726_SiteLocationRaleigh.mxd; JK; 12/18/2018

Legend

750

375

0

750 Feet

Drainage Network
Site Boundary
Areas at Site
Chemours Monomers IXM Area
Chemours PPA Area
Dupont / Dow Leased Area
Chemours Former Teflon Production Area
Kuraray America Leased Area
Wastewater Treatment Plant
Notes:
Basemap Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Site Location
Chemours Fayetteville Works, North Carolina

FigureRaleigh

May 20191

LegendTemporal Composite Sample
Grab Sample

17 A

2 3

Sample Location Category
Outfall

17 B

Intake

4

C

Wood L

6B

Process wastewater

annel

Non-process wastewater

21 B

23A
23B

16

n
ine d Tre

21 A

1

24B
10
9

Stormwater

24C

Ditch Types
Wood Lined Trench

24A

Waste Water Treatment Plant Discharge

ch

6A

18

ater Chooling W

Cooling Water Channel

5Open Channel to Outfall 002
DuPont Area

19A
19B

7A

Notes:
Location 7B will be a grab sample for the first sampling event due
to time constraints associated with acquiring an autosampler. For
subsequent events, Location 7B will be a temporal composite
sample.

22

8

11

7B 15
13
12

Waste Water Treatment Plant Discharge

14
Area
DuPontO pen

l to Ou
C hannetfall 002

20
500

250

0

500 FeetSample Locations
Chemours Fayetteville Works, North Carolina

Consultants of NC, PC
NC License No.: C-3500
Raleigh
Projection: NAD 1983 StatePlane North Carolina FIPS 3200 Feet; Units in Foot US

May 2019

Figure2

Project Milestone/Deliverable
Approval of Sampling Plan
Initial Characterization (IC)IC Sampling EventsIC Quarterly Reports
Scope updates, regulatory approval
Initial Characterization Final Report
Ongoing Sampling (OS)OS Sampling Events
OS Quarterly Reports
Scope updates, regulatory approval
Ongoing Sampling Final Report

2022
2019
2020
2021
01 02 03 04 05 06 07 08 09 10 11 12 01 02 03 04 05 06 07 08 09 10 11 12 01 02 03 04 05 06 07 08 09 10 11 12 01 02 03 04 05 06 07 08


--

--



-



--

-


--

--

--



-



--

--

--

--

--

--

--

--

--

--

--










♦

-


--

--

--



-



Notes:-- Timespan for major tasks
 Anticipated approval of sampling plan
 Bimonthly sampling event. This schedule assumes that storm events will occur resulting in enough rain such that water is present at all sampling
locations in the stormwater drainage network for the proposed sampling events.
 Quarterly reports
 Scope updates and regulatory approval following Initial Characterization and Ongoing Sampling. The number of locations may be reduced
following Initial Characterization, and the frequency of sampling events may be reduced following Ongoing Sampling.
♦ Final reports

--

-


--

--

--



--

--



-





--

--

--



-



--

-


--

--

--

--

--






♦

Gantt Chart of Proposed Sampling Schedule
Chemours Fayetteville Works, North Carolina

FigureRaleigh

May 2019

3