PFAS CHARACTERIZATIONSAMPLING 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 TR0726

December 28, 2018

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 Procedures ................................................................................... 4
3.3.1 General Field Procedures ................................................................ 4
3.3.2 Sample Collection Procedures Common to All Locations ............. 4
3.3.3 Decontamination Procedures .......................................................... 7
3.4
3.5

Sample Shipping, Chain of Custody, and Holding Times ........................... 7
Quality Assurance/ Quality Control ............................................................ 7
3.5.1 Field QA/QC ................................................................................... 8

3.6

Documentation............................................................................................. 9

4.

TEST METHODS AND LABORATORY STANDARDS ............................... 10
4.1 Analytical Methods.................................................................................... 10
4.2 Laboratory QA/QC .................................................................................... 10

5.

DATA VERIFICATION .................................................................................... 13

6.

REPORTING ...................................................................................................... 15

7.

REFERENCES ................................................................................................... 16

TR0726ii

28-Dec-18

LIST OF TABLES
Table 1: Proposed Consent Order Attachment C PFAS and Associated Methods
Table 2: 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

TR0726iii

28-Dec-18

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 (i.e., non-contact
cooling water, [NCCW]) 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 in the proposed Consent Order dated 21
November 2018 between Chemours and the North Carolina Department ofEnvironmental Quality (DEQ) with the Cape Fear River Watch (CFRW) as intervenor.
Other parts of the Consent Order will be addressed separately by Chemours andChemours 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, and/or 4) processwastewater or NCCW. Evaluation of the data collected to date indicate that PFAS present
in the Cape Fear River are partially attributable to emissions from the Facility andpartially attributable to other regional sources. Chemours has taken numerous actions to
reduce releases of PFAS from the Facility, including the following partial list:•••

Off-Site disposal of all Chemours process wastewater containing
hexafluoropropylene oxide dimer acid (HFPO-DA) 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 and waterby designing and installing enhanced PFAS abatement systems.

TR0726

1

28-Dec-18

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 infiltrate to groundwater runs off through aseries 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

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

EPA Method 537 Mod (Laboratory-specific standard operating procedure [SOP])– perfluorocarboxylic acids (PFCAs), perfluorosulfonic acids (PFSAs) and others
EPA Method 8321A (USEPA, 1996) – HFPO-DA
Table 3 Lab Standard Operating Procedure (SOP; a method developed by
Chemours) - perfluoroalkyl ether carboxylic acids (PFECAs) and perfluoroalkyl
ether sulfonic acids (PFESAs). This SOP was developed by Chemours andmodified and implemented by the analytical laboratories.

PFAS to be analyzed by the three methods listed above will include all the PFAS listed
in Attachment C of the proposed Consent Order in addition to additional analytes reportedby these 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 proposed Consent Order.
1.2

Scope and Rationale

This Sampling Plan addresses requirements in Paragraph 11 as listed in the proposed
Consent 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.

TR07262

28-Dec-18

Chemours will continue bimonthly sampling events and quarterly reports during theOngoing Sampling for a period of two years (i.e., 12 events).
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 (a.k.a. NCCW), and stormwater at the Facility;
Assess PFAS concentration trends over time in process water, NCCW, andstormwater; andDocument intake water quality to elucidate the components of PFAS originating
at the facility from PFAS originating from other sources.

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

TR0726

3

28-Dec-18

3.

SAMPLING PLAN

3.1

Sampling Locations

Twenty 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 Procedures

3.3.1

General Field Procedures

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 Procedures Common to All Locations

Sample types to be collected as part of this Sampling Plan include storm water samples,
Cape Fear River water intake samples, outfall samples, NCCW samples, and processwastewater samples. Sample collection procedures common to all sample types are
outlined below and summarized for each sample type specified in Table 4.
The sample bottles will be 250 milliliter (mL) high density polyethylene (HDPE) with awide-mouth screw-cap. For all samples, bottles pre-cleaned by the vendor will be used
to minimize the risk of unplanned sample contamination from the sample container.
TR0726

4

28-Dec-18

Field parameters will be measured by filling a flow-through cell from the 250 mL HDPE
bottle. Following field parameter measurement, the sample bottle will be filled and thecap securely fastened after sample collection. For each sample type, sufficient water will
be collected to fill nine bottles (two for EPA Method 537 Mod, two for EPA Method
8321A, and one for Table 3) and 4 bottles to be archive for potential future analyses. Eachsample will be labelled with a unique sample identification number, date, time andlocation of sampling, the initials of the individual collecting the sample and 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 fieldparameters.
Some samples will be collected as grab samples (i.e., instantaneous) and some samples
will be collected as composite samples (e.g., temporal or spatial). Table 3 lists the
sampling method for each sampling location. Grab samples are appropriate where
temporal variability over the course of one day is not expected at the sampling location.
Composite samples are appropriate where variability is expected within a short timeframe (e.g., one day). Temporal composite samples will be collected for stormwater,
intake and outfall samples. Stormwater, which will contribute to intake and outfall
samples as well, can have highly variable dissolved and suspended constituents loads
over short time periods. Composite samples will be collected using a Hach SD900
composite sampler or similar with a composite sampler dedicated to each location. The
duration over which composite samples are collected will be selected to coincide with theduration of the storm event to the extent practical or to a maximum of 2 days. Spatial
composite grab samples will be collected for non-contact cooling water. The sampling
method may be modified if information acquired during the monitoring program indicatesan opportunity for improved sample quality (representativeness, reproducibility, and/or
reliability).
Stormwater Sampling
Stormwater samples will be collected at Locations 2-5, 7, 10-13 and 15. Locations 2, 3,
5, and 11 are stormwater only. Locations 4, 7, 10, 12, 13, and 15 are a combination ofstormwater and treated process and non-process water. Sampling of stormwater will bescheduled to coincide with storm events as defined in 40 C.F.R. 122.21(g)(7)(ii), provided
the storm event resulted in enough rain such that water is present at all sampling locationsin the stormwater drainage network, otherwise no sample will be collected at dry
locations.

TR0726

528-Dec-18

Cape Fear River Intake and Outfall Sampling
Intake Sampling Point - Excess River Water Discharge Point
Intake water will be collected as a composite sample at the point where Excess River
Water (Location 1) discharges into the Site Drainage Network. Excess river water iswithdrawn 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 composite sample from the Open Channel justbefore entering the pipe to the river (Location 20). Outfall 002 is where stormwater,
NCCW and treated, non-Chemours process wastewater combine prior to discharge to theCape Fear River.
Non-Contact Cooling Water
NCCW samples will be collected as spatial composite samples from the NCCW discharge
points before these waters flow into the Site Drainage Network for Kuraray, Chemoursand DuPont manufacturing areas (Locations 6, 9 and 14). 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 collected using 250-mL HDPE bottles and will
be composited in a decontaminated stainless-steel vessel producing one spatial composite
sample per location.
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).
The project team is working with Chemours, Kuraray and DuPont facility staff to identify
and access the appropriate sampling points for the combined process wastewater fromeach of these areas.
Wastewater Treatment Plant Discharge
The discharge from the wastewater treatment plan (WWTP) will be collected at Outfall
001 (Location 8) as a composite sample. WWTP discharge consists of treated Kuraray
and DuPont process wastewater and treated facility sanitary and utility water.
TR0726

628-Dec-18

3.3.3

Decontamination Procedures

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 stainless-steel
compositing vessel(s), flow-through cell, and aluminum rod) will be decontaminatedbetween sample locations in the following manner:
•
•
•
•
•
3.4

Tap water rinse;
Scrub with tap water containing non-phosphate detergent (i.e., Alconox®);
Tap water rinse;
De-ionized water rinse; andRinse three times with water to be sampled before sample collection.
Sample Shipping, Chain of Custody, and Holding Times

Upon sample collection, each containerized sample will be labelled and placed as soon
as possible into an insulated sample cooler with ice. The cooler will serve as a shipping
container and will be provided by the laboratory along with the appropriate sample
containers. Chemours will request that samples be analyzed by the laboratory within theholding times specified in Table 4. The additional samples collected at each location forpotential future analyses will be stored under chain of custody in a secured, refrigerated
location on site.
Prior to shipment of the samples to the laboratory, a chain of custody (COC) form will becompleted by the field sample custodian. Sample locations, sample identification
numbers, description of samples, number of samples collected, and specific laboratory
analyses to be performed on each sample will be recorded on the chain-of-custody form.
The COC will be signed by the field personnel relinquishing the samples to the courier
and will be signed by the laboratory upon receipt of the cooler. The cooler will be taped
shut and signed across the lid of the cooler, and the laboratory personnel will confirm thesignature 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 4.

TR0726

728-Dec-18

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. Data quality objectives for field QA/QC samples are summarizedin Table 3. During the Initial Characterization period four types of field QA/QC samples
will be collected: equipment blanks, trip blanks, field blanks and field duplicates.
Equipment Blanks
Equipment blanks (field rinsate blanks) are used to evaluate equipment 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 the Initial Characterization, then their frequency andthe need for other blanks will be re-evaluated for 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 only
be analyzed if there are detections above the practical quantitation limit (PQL) in theequipment blanks in the six sampling events of the Initial Characterization.
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 only be included if there are detections
above the PQL in the equipment blanks in the six sampling events of the Initial
Characterization.

TR0726

828-Dec-18

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 − 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 2)|
× 100%(𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 1 + 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 2)��2

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 with investigative 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., one duplicate 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.

TR0726

928-Dec-18

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);
EPA Method 8321A (USEPA, 1996); andTable 3 Lab 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 4.
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
analyzed. The percent recovery of the MS is calculated to document the accuracy of themethod for the matrix. Percent recovery is calculated as follows:
TR0726

1028-Dec-18

𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑜𝑜𝑜𝑜 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 − 𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴𝐴 𝑜𝑜𝑜𝑜 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆 𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵𝐵 𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆𝑆% 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 = �
� × 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. RPD values less than
20% indicate acceptable precision. If the RPD is outside the acceptable precision range,
associated results detected at or above 5 times the PQL will be J-qualified.
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.
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 analytical
TR0726

1128-Dec-18

bias 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.

TR0726

1228-Dec-18

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:••••

TR0726

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.

1328-Dec-18

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).

TR0726

14

28-Dec-18

6.

REPORTING

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

TR072615

28-Dec-18

7.

REFERENCES

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.

TR0726

16

28-Dec-18

TABLESGeosyntec Consultants

TABLE 1PROPOSED CONSENT ORDER ATTACHMENT C PFAS AND ASSOCIATED METHODS
Chemours Fayetteville Works, North Carolina

Analytical
MethodEPA Method
8321A

Common Name
HFPO-DA / PFPrOPrA/“GenX”
PFESA-BP1 / Nafion BP
PFESA-BP2 / Nafion BP

EPA Method 537
Mod2,3,3,3-Tetrafluoro-2 (1,1,2,2,3,3,3- heptafluoropropoxy)-propanoic acid)CASN
13252-13-6

Chemical FormulaC6HF11O3

PFO3OAPFO4DATAFN4 / PF05DA

66796-30-3; 29311-67-9
Nafion Byproduct 1
C7HF13O5S
749836-20-2
Nafion Byproduct 2
C7H2F14O5S
Hexanoic acid, 2,2,3,3,4,4,5,5,6,6‐decafluoro‐6‐(trifluoromethoxy)‐; Butanoic
174767-10-3; 801212-59-9 C7HF13O3
acid, 2,2,3,3,4,4‐hexafluoro‐4‐[1,2,2,2‐tetrafluoro‐1‐ (trifluoromethyl)ethoxy]‐674-13-5
Perfluoro-2-methoxyacetic acidC3HF5O3C4HF7O3
Perfluoro-2-methoxypropanoic acid
Perfluoro 3-methoxypropanoic acid 13140-29-9 377-73-1
39492-88-1
Perfluoro(3,5-dioxahexanoic) acidC4HF7O4
2,3,3,3-Tetrafluoro-2-(pentafluoroethoxy)
Perfluoro-4-methoxybutanoic acid 267239-61-2 863090-89-5 C5HF9O3
propanoic acid39492-89-2
Perfluoro(3,5,7-trioxaoctanoic) acidC5HF9O539492-90-5
Perfluoro(3,5,7,9-tetraoxadecanoic) acidC6HF11O6
39492-91-6
Perfluoro(3,5,7,9,11-pentadodecanoic) acidC7HF13O7

PFHpA

Perfluoroheptanoic acidPFECA-G
Table 3 Lab SOP

Attachment C PFAS
Chemical NamePFMOAAPMPAPFO2HXAPFMOPrAPEPAPFMOBA

375-85-9

C7HF13O2

Notes:PFAS - per- and polyfluoroalkyl substances
SOP - Standard Operating Procedure

December 2018

Geosyntec Consultants

TABLE 2DATA QUALITY OBJECTIVES
Chemours Fayetteville Works, North Carolina
Current PQL (ng/L)

Precision

Accuracy

Calibration

Completeness

CCV %Difference% Complete

MS %RecoveryLCS %Recovery

Isotope
Dilution
Analyte %Recovery20

70-13070-13025-15060-14090202070-13070-13025-15060-140

90

50

20

20

70-13070-13025-15060-140

90

96

50

20

20

70-13070-13025-15060-14090

PFMOAA

95

50

20

20

70-13070-13025-15060-140

90

PMPA

84

50

20

20

70-13070-13025-15060-14090

PFMOPrA

84

50

20

20

70-13070-13025-15060-14090

PFO2HXA

92

50

20

20

70-13070-13025-15060-140

90

PEPA

100

50

20

20

70-13070-13025-15060-14090

PFMOBA

100

50

20

20

70-13070-13025-15060-14090

PFO3OA

88

50

20

20

70-13070-13025-15060-14090

PFO4DA

97

50

20

20

70-13070-13025-15060-14090

TAFN4 / PF05DA

110

100

20

20

70-13070-13025-15060-140

90

PFHpA

1.7

0.88

20

20

76-14067-13725-15060-14090

PFAS

TestAmerica

Eurofins
LancasterField Duplicate Lab Replicate
RPD
RPD

HFPO-DA / PFPrOPrA /“GenX”

8.6

1.7

20

PFESA-BP1 / Nafion BP #1

120

50

PFESA-BP2 / Nafion BP #2

95

PFECA-G

Notes
Criteria may be replaced by statistical limits generated by the laboratory(ies).
CCV - continuing calibration verification
LCS - laboratory control sample
MS - matrix spike
ng/L - nanograms per liter
PFAS - per- and polyfluoroalkyl substances
PQL - practical quantitation limit
RPD - relative percent difference

December 2018

Geosyntec Consultants

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

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

Sample Location Description

Sampling
MethodDischarge point of excess river water (i.e., water
drawn from the Cape Fear River, but not used as Temporalprocess water or NCCW) to characterizeComposite
background levels of PFAS
Kuraray northern leased area stormwater
Temporaldischarge
Composite
TemporalChemours PPA area stormwater discharge
Composite
Combined stormwater discharge from Kuraray
Temporalnorthern leased area and Chemours PPA area
Composite
Temporal
Kuraray southern leased area stormwater
Composite
SpatialKuraray southern leased area NCCW discharge
Composite
Combined stormwater and NCCW discharge
Temporalfrom western portion of the Facility
Composite
Outfall 001 non-Chemours process wastewater
Temporaldischarge to open channel to Outfall 002
Composite
SpatialChemours Monomers IXM NCCW discharge
Composite
Chemours Monomers IXM area stormwater
Temporaldischarge and NCCW
Composite
Decommissioned Chemours Teflon area
Temporalstormwater discharge
Composite
DuPont area southern drainage ditch stormwater Temporaldischarge and NCCW
Composite
DuPont area northern drainage ditch stormwater Temporaldischarge and NCCW
Composite
SpatialDuPont NCCW discharge
Composite
Combined stormwater and NCCW discharge
Temporalfrom eastern portion of the Facility
Composite
Chemours Monomers IXM Area combinedGrabprocess wastewater
Chemours PPA Area combined process
Grab
Kuraray process wastewater sampling
Grab
DuPont process wastewater samplingGrab
TemporalOutfall 002 pipe to Cape Fear River
Composite

Intake/Outfall

Process water

Non-processwastewater(i.e., NCCW)

Stormwater

Intake



































Outfall

Notes
Sample numbers refer to locations identified in Figure 2
NCCW - non-contact cooling water
PPA - polymer processing aid

December 2018

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

EPA Method 8321A

250 mL HDPE

2

None

14 days to extraction,
40 days to analysis

14 days to extraction,
28 days to analysis

Table 3 Lab SOP

250 mL HDPE

1

None

28 Days

14 days

Notes:HDPE - high density polyethylene
SOP - Standard Operating Procedure

December 2018

Geosyntec Consultants

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

Lab

Analytical
MethodInvestigative
Samples1(per event)

Equipment
Blank(per day)Trip Blank

Field Blank

EPA Method
537 Mod

20

1

1

EPA Method
8321A

20

1

Table 3 Lab
SOP

20

1

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)

Field
Duplicate(per 20
samples)

MethodBlank(per sample
group)

1

1

1

1

1

1

20

1

1

1

1

1

1

1

1

20

1

1

1

1

1

1

1

1

N/A

1

2

2

Notes:
1 - Number of samples may be subject to change following Initial Characterization
2 - Field blanks and trip blanks may be added to the sampling events if there are detects above the PQL in the equipment blanks
N/A - none available at present
SOP - Standard Operating Procedure
PQL - practical quantitation limit

December 2018

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

Figure1Raleigh

December 2018

Legend
Ditch Types
Wood Lined Trench
Waste Water Treatment Plant Discharge

17
2

Cooling Water Channel
Open Channel to Outfall 002

3

DuPont Area Ditches

1

16

4
1

6

Intake Water at Excess
River Water Discharge

9 - Monomers IXM NCCW

Discharge Section andSampling Area

10

Sample Location

Outfall 002 Pipe to Cape Fear River

16: Chemours Monomers IXM Area
Combined Process Water Sampling- Kuraray NCCW Discharge
Section and Sampling Area

17: Chemours PPA Area Combined
Process Water Sampling

5
18

18: Kuraray Process
Wastewater Sampling
19: DuPont Process
Wastewater Sampling

14 - DuPont NCCW

NCCW - non-contact cooling water

Discharge Sectionand Sampling Area

7
8

15
12

13

19

11
20

Outfall 002 Pipe to Cape Fear River
500

250

0

500 FeetPrimary Ditches
Samplein SiteLocations
Drainage Network
Chemours Fayetteville Works, North Carolina

Figure2
Basemap Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Raleigh

December 2018

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


-

--

-


--

--

--



-



--

-


--

--

--

--

--

--

--

--





-

--

-

--

♦

-


--

--

--



-



--

-


--

--

--



-



--

-


--

--

--



-



--

--

--




--

--

--

--






♦

Notes:
This schedule is based on an assumption of 1 month for regulatory review and approval of the Sampling Plan, and will be modified accordingly if the approval date changes.
-- Timespan for major tasks
 Approval of sampling plan
Gantt Chart of Proposed Sampling Schedule Bimonthly sampling event. This schedule assumes that storm events, as defined in C.F.R. 122.21(g)(7)(ii), will occur resulting in enough rain such
Chemours Fayetteville Works, North Carolina
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
Figurefollowing Initial Characterization, and the frequency of sampling events may be reduced following Ongoing Sampling.
♦ Final reports
Raleigh

December 20183

Page 1 of 1