Dear Secretary Regan and Assistant Secretary Holman:

Downstream residents have been overexposed to DuPont/Chemours’ PFAS chemical waste for decades.

We believe DuPont/Chemours used our drinking water supply to cut costs and increase their profits—these actions placed nearly 300,000 residents downstream from their Fayetteville facility in harm's way transferring external costs onto innocent and unassuming North Carolinians.

These PFAS chemicals are associated with multiple serious health effects including suppression of the immune system, developmental disorders, thyroid disease, and cancer.

The financial burden of these chemicals often goes undiscussed. A single cancer treatment can cost a patient nearly $1 million. A study by the Nordic Council found that inaction on these forever chemicals will lead to billions of euros in healthcare costs annually--meaning just the healthcare costs alone of doing nothing will far exceed the cost of taking preventative measures now. A similar analysis has not been performed in the United States.

We believe DuPont/Chemours knew their PFAS chemical waste could cause harm and willfully chose to not invest in preventive manufacturing precautions.

Chemours is a Fortune 500 company with over $5.5 billion in annual sales. In 2019, they returned $486 million to their shareholders through stock buybacks and dividends. Ultimately, they continue to increase shareholder value at the expense of North Carolinians.

In 2019, Chemours legally established a threshold for providing immediate relief to well owners who had 70 ppt for total PFAS, or 10 ppt per individual PFAS, in their drinking water. This “70/10 threshold” for immediate relief was only extended to well owners in Bladen and Cumberland counties and, sadly, excluded the 300,000 impacted residents downstream who have been suffering from similar, if not greater, drinking water contamination on a regular basis. We believe Chemours knew the true extent of their historical contamination into our river but failed to fully disclose this information at the time the consent order was signed.

On average, downstream residents drank over 70 ppt of total PFAS and 10 ppt of Schedule C PFAS for the majority of 2019 and we continue to drink DuPont/Chemours’ PFAS chemical waste for most of 2020. This has been well documented by regular testing of tap water provided by Cape Fear Public Utilities and Brunswick County Public Utilities.

Because DuPont/Chemours historically never provided test standards to accurately quantify how much PFAS impacted communities were being exposed to, the true nature of our contamination crisis keeps rising as new test standards are produced.

Per the 2019 consent order, Chemours was legally required to identify all PFAS generated from their manufacturing processes and general operations.

A non-targeted analysis from Chemours, released in June 2020, revealed we were likely exposed to an additional 271 “unknown” PFAS chemicals. Based on our understanding, 250 of those forever chemicals are currently being diverted into tanker trucks and driven to Deer Park, TX for deep well injection until NC DEQ approves Chemours’ new discharge permit.

The remaining 21 PFAS chemicals are likely still leaking into the Cape Fear River--per the non-targeted analysis report. It is reasonable to assume we are currently being exposed to these additional 21 “unknown” PFAS chemicals on top of the already high levels of PFAS our utilities continue to report in their regular samples.

Brunswick, New Hanover and Pender County impacted residents are still drinking some of the highest levels of PFAS in tap water per a recent nationwide tap water study from the Environmental Working Group. Again, these levels do not include the newly disclosed "unknown" PFAS.

A recent news article published in Discover magazine​ is sounding the alarm regarding endocrine disrupting chemicals, like PFAS, increasing our risk of having more severe Covid-19. This troubling news should create an increased sense of urgency for NC DEQ to act on our behalf.

NC DEQ is currently receiving public comments regarding amending paragraph 12 of the consent order which addresses remediation measures for continued PFAS releases into our river.

This amendment is a good step forward, however, it does not address providing immediate relief to the 300,000 impacted residents still chronically exposed to untold amounts of DuPont/Chemours’ toxic PFAS chemical waste by simply using on our own faucets.

The amended consent order seeks to provide permanent pollution control measures by spring of 2023—2.5 years from now.

It's our understanding, interim pollution measures will not be available for at least eight more months and none of these remediation efforts address sediment contamination all along the river which would likely still provide background levels of PFAS into the drinking water of impacted communities already harmed by decades of overexposure.

Brunswick County Public Utilities and Cape Fear Public Utility Authority are both working to upgrade their treatment processes to address this environmental crime. These upgrades are costing ratepayers millions of dollars and will not be fully operational for another 2-3 years.

This inequity and harm must stop now.

We are demanding that NC DEQ require Chemours to immediately establish a PFAS Community Relief Fund specifically for impacted communities who rely on the Cape Fear River as their primary source of drinking water.

Chemours must pay into this revolving fund to cover the cost of vouchers for downstream impacted residents who seek to install under sink reverse osmosis filters. These vouchers should cover the cost of filtration purchase and installation, as well as, yearly filter replacements until all permanent solutions at the Chemours Fayetteville facility are fully operational and adequate testing confirms their success.

In light of the discovery of the additional 271 unknown PFAS chemicals, NC DEQ should not approve Chemours’ process wastewater discharge permit application until:

1. A PFAS Community Relief Fund is established.

2. Chemours creates test standards to enable independent scientists to accurately quantify the levels of all these unknown PFAS..

3. The identity of every new compound is known.

4. Chemours can accurately quantify the levels of these unknown PFAS.

Thank you for your time and attention to this important topic.