Consent Order Progress Report ThroughFirst Quarter 2019

Consent Order Submissions to the State of North Carolina and Cape Fear RiverWatch
The following table identifies Consent Order submissions by Chemours for theperiod following the lodging of the proposed Consent Order in November 2018
through the end of the first quarter of 2019.
COSection

Submitted Title
To

Submittal Date

7bii
7biii
8bi
8bi
8bi
8bi
8bi
8bi
8d
9
99
9
9
11a11a11a11b12c and 27
14
14
17
19
19
1919 and 20
19 and 20
19 and 20

NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDAQ
NCDWR
NCDWR
NCDWR
NCDWR
NCDEQ
NCDEQ
NCDEQ
NCDWM
NCDEQ
NCDEQ
NCDEQ
NCDEQ
NCDEQ
NCDEQ

12312018
02152019
02222019
02222019
02222019
03042019
03042019
03042019
03222019
12202018
12202018
12202018
12202018
12202018
01302019
01302019
01302019
12302018
01142019
03012019
03272019
12312018
03062019
03062019
03112019
03062019
03062019
01282019

2122

NCDEQ
NCDEQ

VEN Carbon Adsorber Project Completion Notification
Final Report VEN Carbon Adsorber Unit > 93% Efficiency
Final PPA Stack Test Report
Final Semi-Works Stack Test Report
Final VES Stack Test Report
Final Division Stack Test Report
Final Polymers Stack Test Report
Final Semi-Works Stack Test ReportMonthly Emissions Report
E1 and 2-MTP (HFPO Monomer) GC Method SOP
HFPO Dimer Acid LCMSMS Method SOP
HFPO Dimer Acid Preparation Method SOP
PFAS Extraction Protocol SOP
PFAS Test Methods Lab Standards Submittal
PFAS Non-Targeted Analysis and Methods Work Plan
Modified Method 537 PFAS Analytical and Test Methods
Table 3+ Compounds Analytical and Test Methods
PFAS Characterization Sampling Workplan
Geosyntec Approval Request
Request for Laboratory Approval
Toxicity Study Work Plan
Permanent Lining of North Sedimentation Pond Notification
GAC Approval Request Enclosure
GAC Approval Request Letter
Public Water Feasibility Analysis
RO Approval Request Enclosure
RO Approval Request Letter
Request for Approval of Drinking Water Letters toResidents
Request for Laboratory Approval and Funding Notification
Residential Sampling Results

OtherNCDEQ

Final Creeks and Seeps Work Plan12182018
Multiple andOngoing02272019

Consent Order Progress Report ThroughFirst Quarter 2019Replacement Drinking Water Actions Through First Quarter 2019

BottledWater

RO

Residences
Receiving

Additional
Residences
1Q19

RefusedVacantAlready
Connected
to Public
Water

600

407

1362Eligible(includinghouses thatshare awell)

Systems to
Install407

407
Already
Connected
to Public
Water

PublicWater
Readily
Available

PublicWater
Feasible

Systems toInstall183

21336132

InitialInterview
Conducted?

SignedAccessAgreement?

Total Sheds
DroppedCompleted

InitialSampling
Complete

GAC
ChangeOuts

5137372935

1SampleDeliveryGroup(SDG)
Emailed orUploaded% Within 7days ofFinal Data151

100%

Eligible

GAC

Drinking
Water
Data toState

Drinking
Water
Data toResidents

Samples

668% Within
Timeframe(7 or 30days)
Delivered orAttempted100%

Consent Order Progress Report ThroughFirst Quarter 2019

Consent Order Progress Details
This section summarizes the activities that have been undertaken by Chemours
pursuant to the Consent Order Compliance Measures for the period following thelodging of the proposed Consent Order in November 2018 through the end of thefirst quarter of 2019.

Paragraph 7 - Control Technology Improvements
Paragraph 7a - Second Phase Scrubber• Chemours completed installation of a packed bed scrubber ("Second PhaseScrubber") to control emissions from the Division Waste Gas Scrubber on
November 7, 2018.
Paragraph 7bi - Vinyl Ethers North Carbon Adsorber Project• On October 19, 2018, Chemours submitted to DAQ a process hazard
assessment pertaining to the Vinyl Ethers North Carbon Adsorber Project.
Paragraph 7bii - Vinyl Ethers North Carbon Adsorber Project• On December 26, 2018, Chemours completed construction of the Vinyl Ethers
North Carbon Adsorber Project.
• All emissions from the Second Phase Scrubber are controlled by the Vinyl
Ethers North Carbon Adsorber Unit subject to such unit downtime as may berequired by the process hazard assessment or as necessary for maintenanceof the unit. Chemours is using its best efforts consistent with safe operations
to minimize unit downtime and downtime has been minimal to date.
Paragraph 7biii - Vinyl Ethers North Carbon Adsorber Project• On February 15, 2019, Chemours submitted a report documenting a 93.9%
control efficiency for the Vinyl Ethers North Carbon Adsorber Unit.
Paragraph 7c - Thermal Oxidizer• A new Title V air permit (including for the thermal oxidizer) was issued byDAQ on March 14, 2019.
• Chemours construction activities continue on schedule for completion of
installation of the thermal oxidizer by December 31, 2019, with foundations
having been formed and poured at the facility and the construction of theequipment continuing offsite by the supplier for delivery and installation
later this year.

Paragraph 8 - GenX Emissions Reduction Milestones•

On March 22, 2019, Chemours submitted its first monthly emissions report
as required under the Consent Order, showing the details of emissions todate for the two annual reporting periods (one starting October 6, 2018 andone starting December 31, 2018) and how the facility plans to meet theConsent Order’s 82% and 92% requirements for plant-wide interim
reductions of air emissions of GenX Compounds.

Consent Order Progress Report ThroughFirst Quarter 2019
•Emissions testing of the first product campaigns in 2019 have been
conducted for all products except for EVE and IXM CR. The first campaigns
for these products will not occur until later in 2019, and will be tested then.
All emissions test reports have been submitted to DAQ within forty-five daysof completion of the emissions test, as required.

Paragraph 9 - Disclosure of PFAS Emissions•On December 20, 2018, Chemours provided DAQ with analytical test methods
and lab standards for PFAS compounds in air emissions from the FayettevilleWorks.

Paragraph 10 - No Discharge of Process Wastewater from Chemours'Manufacturing Area•

Chemours continues to not discharge its process wastewater and to ship allof its process wastewater offsite for disposal.

Paragraph 11 - Characterization of PFAS in Process and Non-Process Wastewaterand Stormwater at the Facility
Paragraph 11a - Test Methods and Lab Standards• On January 30, 2019, Chemours submitted analytical test methods and lab
standards for PFAS in process and non-process wastewater and stormwaterat the Facility as well as a plan and schedule for conducting non-targetedanalysis.
• Comments from NCDEQ and USEPA on the non-targeted analysis plan havebeen received and are being addressed.
• Chemours plans to submit a response to comments table alongside updated
TestAmerica and Eurofins Lancaster Table 3+ SOPs to facilitate discussion
and approval of the non-targeted analysis plan.
• Chemours plans to collect samples for non-targeted analysis during its firstsampling event pursuant to Consent Order paragraph 11c.
Paragraph 11b - Sampling Plan
• On December 30, 2018, Chemours submitted its sampling plan.
• Comments from NCDEQ, USEPA and Cape Fear River Watch on the sampling
plan have been received and are being addressed.
• Chemours plans to submit a response to comments table to facilitate
discussion and approval of the sampling plan. Chemours also plans to submit
a revised set of figures and tables for review.
Paragraph 11c - Initial Characterization• Chemours has conducted planning for its first round of initialcharacterization sampling, including the purchase of auto-samplers,coordination with analytical laboratories, and refining sample collection
methods.

Consent Order Progress Report ThroughFirst Quarter 2019•

A dry sampling event was scheduled for late April 2019 (it was conducted onApril 24, 2019) and the first stormwater sampling event will be conductedsoon.

Paragraph 11.1 - Characterization of PFAS Contamination in Downstream Raw
Water Intakes•

Chemours’ contractor Geosyntec is preparing a recommendation ofsuggested raw water samples to collect to perform the analysis required
under the Consent Order.

Paragraph 11.2 - Characterization of PFAS Contamination in River Sediment•Chemours’ contractor Geosyntec has identified task leads and prepared a
proposed scope of work to complete this effort.

Paragraph 12 - Accelerated Reduction of PFAS Contamination in the Cape Fear
River and Downstream Water Intakes
Paragraph 12a - Accelerated Reduction of PFAS Contamination in the Cape Fear Riverand Downstream Water Intakes• Chemours and its contractors Geosyntec and Parsons have reviewed existingdata (including from the seep and creek investigation), potential actions, andestimated reductions.
Paragraphs 12b and 12c - Accelerated Reduction of PFAS Contamination in the Cape
Fear River and Downstream Water Intakes• By the end of March 2019, Chemours and its contractors had prepared a draftmodeling scope of work document (the final document was submitted toDEQ and Cape Fear River Watch on April 11, 2019).
Paragraph 12e - Accelerated Reduction of PFAS Contamination in the Cape Fear Riverand Downstream Water Intakes• Chemours’ contractor Parsons prepared a work plan for sampling in Old
Outfall 002. The first sampling event was conducted on March 21, 2019.
• REGENESIS pilot study:o Trees have been removed to facilitate the installation of performanceverification monitoring wells and subsequent injections.
o A geophysical survey was completed to determine the presence ofutilities.
o A driller was contracted to install performance verification testing
monitoring points in April 2019.
o Injections are scheduled to begin in early May 2019.
• Chemours continues to work on the plan to be submitted within 90 days ofConsent Order entry as well as the pilot study for capture and treatment.

Consent Order Progress Report ThroughFirst Quarter 2019

Paragraph 13 - Facility Site Visit•The facility site visit with DEQ and Cape Fear River Watch occurred on January 3,2019.

Paragraph 14 - Toxicity Studies•In March 2019, Chemours submitted its request for laboratory approvals aswell as its toxicology workplan. Chemours is working to respond to DEQ’squestions about the laboratories.

Paragraph 16 - Groundwater Remediation•Chemours’ contractor Geosyntec has started to develop the Corrective Action
Plan, which will be submitted by the deadline of December 31, 2019.

Paragraph 17 - Lining of Nafion Ditch and Sedimentation Ponds•

These items have been completed, as stated in the Consent Order.

Paragraph 18 - On and Off-site Assessment•Chemours’ contractor Geosyntec has started to prepare the comprehensive
site assessment, which will be submitted by the deadline of September 30,
2019.

Paragraphs 19 and 20 - Provision of Public Water Supplies, Whole Building
Filtration Systems, and Reverse Osmosis Drinking Water Systems•••

On March 11, 2019, Chemours submitted its public water feasibility analysis.
On March 22, 2019, Chemours met with the Bladen County utilities
department to discuss the process for making public water connections.
On March 25, 2019, Chemours received DEQ’s approval for the Granular
Activated Carbon (GAC) whole building filtration system and the Reverse
Osmosis (RO) drinking water systems that Chemours plans to install.

Paragraph 21 - Private Well Testing•On December 18, 2018, Chemours submitted its request for laboratory
approval and notification of funding.

Paragraph 22 - Provision of Sampling Results••

Chemours provided (and continues to provide) sampling results to DEQ andresidences as required under the Consent Order.
Chemours’ contractor AECOM also prepared and transmitted level 4 lab
reports for the sampling results to DEQ (and continues to do so).

Consent Order Progress Report ThroughFirst Quarter 2019

Paragraph 23 - Interim Replacement of Private Drinking Water Supplies•

As of March 31, 2019, Chemours had provided bottled water to 600
residences. Of these, 407 residences were added to the bottled water
distribution program in the first quarter of 2019.

Paragraph 24 - Drinking Water Compliance Plan•

During the first quarter of 2019, Chemours drafted the Drinking Water
Compliance Plan (the Plan was submitted on April 26, 2019).

Paragraph 26 - Total Organic Fluorine•

During the first quarter of 2019, Chemours obtained and reviewed proposals
from third-parties to conduct this work (Chemours will soon submit for
approval a proposal from the scientist to be recommended to conduct thisstudy).

Paragraph 27 - Fate and Transport Study•

Chemours’s contractor Geosyntec performed a fate and transport literature
review and identified relevant literature papers to support development of
this study. The study will be submitted by the deadline of June 30, 2019.

Paragraphs 29 and 30 - Public Information•

Chemours has posted its Consent Order submissions at
https://www.chemours.com/Fayetteville-Works/en-us/c3-dimeracid/compliance-testing/index.html.