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HomeMy WebLinkAboutAQ_F_0900009_20180402_ST_ProtRvw ROY COOPER
r1o.
Governor
MICHAEL S. REGAN
Secretary
Air Quality MICHAEL A. ABRACZINSKAS
ENVIRONMENTAL QUALITY Director
April 2,2018
Mr. Christel Compton
Environmental Manager
Chemours Company FC,LLC
22828 NC Highway 87 West
Fayetteville,North Carolina 28306
Subject: Chemours Company—Fayetteville Works
Fayetteville,Bladen County,North Carolina
Air Permit No.03735T43,Facility ID 0900009
Fluoromonomers Manufacturing Processes HFPO Emissions Testing
Modified Method 18 Testing of Vinyl Ethers South(VES)and Vinyl Ethers North
Division Stack
Proposed Test Date: April 3,2018
DAQ Tracking No.2018-109ST
Dear Ms. Compton:
North Carolina Division of Air Quality(NCDAQ)has reviewed the protocol submitted by Chemours on
March 21, 2018 for the subject testing and deemed it acceptable. Chemours has proposed testing of two
major vent stacks at the facility identified as the Division Stack at Vinyl Ethers North(VEN)and the
Vinyl Ethers South(VES) Stack. Each of these stacks serve specific process areas within the facility.
Process gases from each area are vented through separate caustic scrubbers before being vented to the
associated process area stack. In addition,each stack also vents the enclosed process area"room air"to
exhaust fugitive emissions from equipment leaks(e.g.,leaks from valves,flanges and seals)in the
enclosed process area. These room air emissions do not pass through the associated process area
scrubber. Rather,they are vented for release to the associated stack via an induced draft fan.
The purpose for this testing is to determine the levels of certain fluorocarbon compounds emissions from
the combined scrubber vents and the process room air for each process area stack. The primary
compound identified for recovery and analysis from the sampling train during this sampling event is
hexafluoropropylene oxide(HFPO,CAS No. 428-59-1,boiling point of-28°C).
The proposed sampling methodology is a modified EPA Method 18 sampling train using midget
impingers to capture and react HFPO with methanol to form Methyl 2-methoxytetrafluoropropionate(2-
MTP, CAS No. 10186-63-7). The impingers will be kept at dry-ice temperatures during sampling to
capture the HFPO. After sampling is completed for each run,the train is gradually warmed to a slightly
elevated temperature(40°C)to complete the reaction to form 2-MTP. Analytical procedures from SW-
846 (Method 826013)will be used to quantify 2-MTP. There is a 1:1 stoichiometric ratio between the
quantity of HFPO reacted and the 2-MTP analyte.
State of North Carolina I Environmental Quality I Air Quality
217 W.Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699=1641
919 707 8400
Ms. Christel Compton
April 2,2018
Page 2
The proposed modifications to the original proposed test method have been reviewed and found
acceptable. The two modifications proposed are the use of six midget impingers rather than four as
initially proposed and the use of sodium carbonate as the solution buffer rather than ammonium
hydroxide. The probe wash and Impingers 1 and 2 will be composited as in the proposed protocol. Each
subsequent impinger will be treated and analyzed separately assist in the determination of capture and
breakthrough of HFPO. No bag collection will be used in this modified configuration.
The proposed test methods are acceptable for the initial sampling of the stacks for HFPO. Each run is
proposed to be an hour in length at a single point. Velocity traverses will be conducted at the beginning
of each test,between each test run and at the end of the last run to determine average gas velocity/volume
during each test run.
The test runs will be conducted during periods of normal maximum production emission based upon
process specific operations and process cycles as mutually arranged and agreed upon between Chemours
and NCDAQ. It is our understanding the VEN will be producing perfluoropropyl vinyl ether(PPVE)
while VES will be producing either perfluoromethyl vinyl ether(PMVE)or perfluoroethyl vinyl ether
(PEVE). Process operating parameters and control equipment operating parameters shall be monitored
and recorded during each test run. Approval of the protocol does not exempt the tester from meeting
other sampling requirements and QA/QC procedures not specifically addressed in the protocol and
otherwise incorporated by reference into the test method.
All test data are subject to review of actual in-field sampling procedures,process operations during
testing,and QA/QC review of the analytical methods. Any confidential business information(CBI)
should be identified in the report provided to NCDAQ. In the event that CBI is included in the report to
NCDAQ, a redacted or nonconfidential version of the report should also be provided to NCDAQ for
public availability. Note that emissions rate data may not be claimed as confidential or proprietary
business information.
If you have any questions,please feel free to contact me at(919)707-8413 or gary.saundersta'_,ncdenr.gov.
Sincerely,
Gary L. Saunders
Acting Supervisor
Stationary Source Compliance Branch
Division of Air Quality,NCDEQ
cc: Greg Reeves and Heather Carter,Fayetteville Regional Office
Central Files,Bladen County
IBEAM Documents-0900009
State of North Carolina I Environmental Quality I Air Quality
217 W.Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641