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HomeMy WebLinkAboutAQ_F_0900009_20211003_CMPL_CompRpt '� p9opa0q
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(,, The Chemours Company
Chemours" Fayetteville Works
22828 NC Highway 87 W
Fayetteville,NC 28306
RECEIVEL
OCT 18 2021
DEQ-FAYETTEVIL LE REGION-JAL OF'Y.
CERTIFIED MAIL ARTICLE NUMBER 7017 1450 0002 3902 3662
RETURN RECEIPT REQUESTED
October 15, 2021
Heather Carter
NCDEQ—Division of Air Quality
225 Green Street—Suite 714
Fayetteville,NC 28301
SUBJECT: Chemours Company—Fayetteville Works
Title V Permit Quarterly Summary Report for Thermal Oxidizer—3Q 2021
Air Permit No. 03735T48
Facility ID No. 0900009
Ms. Carter,
Attached is the quarterly summary report for the period from July 1, 2021 to September 30, 2021
for the Chemours Fayetteville Works Thermal Oxidizer per Section 2.1 B.1 l.n pursuant to Air
Quality Permit No. 03735T48.
Enclosed you will find the required photocopies of this report.
If you have any questions,please feel free to contact me at(910) 678-1213.
Sincerely,
Christel Compton
Program Manager
Attachment
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3 d Quarter 2021
Air Permit No. 03 73 5T48 Page 1 of 8
Thermal Oxidizer and 4-Stage Scrubber System Quarterly Report
(per Air Quality Permit No. 03735T48, Condition 2.1
Air Quality Permit No. 03735T48, Condition 2.1 B.11: "15A NCAC 02Q .0519(a)(7) and
Consent Order"
Pursuant to Section 2.1 B.11.n. of the subject Title V permit, the permittee shall submit a quarterly
summary report that includes monitoring and recordkeeping activities specified in Section 2.1
B.II.f. through B.11.n. The summary report shall include the information recorded as required
in Section 2.1 B.11 f. through B.11.n. For clarity, this report has been broken down into
subsections for each monitoring and recordkeeping requirement contained in Sections 2.1 B.II.f.
through 2.1 B.11.n.
Section 2.1 B.11.f.
Emissions of all PFAS, including GenX compounds,from the following emissions sources (ID
Nos. NSA,NS-B,NS-C,NS D-1,NS-E,NS-F,NS-G-1,NS-K,NS-M,NS-N,NS-O, and NS-P)
shall be controlled by a Thermal Oxidizer and 4-Stage Scrubber System (ID Nos. NCD-QI and
NCD-Q2). The Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's recommendations, the inspection and
maintenance requirement shall include:
Section 2.1 B.11.f.is Hourly visual or positive detection by flame scanner checks of the Thermal
Oxidizer flame and burner while in operation and annual inspections of the burner assemblies,
blowers,fans, dampers, refractory lining, oxidizer shell,fuel lines, and ductwork.
The DCS/CMS provides continuous monitoring of the flame and burner by using two separate
infrared flame scanners. The data historian application(IP21) collects real-time process data from
the DCS to provide control and supervision of the process. The flame can also be detected visually
by a view port.
The following table includes a summary of periods when the flame was not detected within the
Thermal Oxidizer combustion chamber:
Summary of Periods When a Flame Was Not Detected
Date Duration Reason
7/11/21 6 minutes Combustion chamber high pressure caused the flame out.
7/31/21 13 minutes Natural Gas flow transmitter displayed negative readings and stopped
flows.
8/1/21 11 minutes Induced Draft Fan faulted/tripped off.
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3r1 Quarter 2021
Air Permit No. 03735T48 Page 2 of 8
8/12/21 85 minutes Moisture in wiring caused automatic valve malfunction.
8/19/21 36 minutes Instrument air pressure low causing combustion controls to interlock off.
8/20/21 2 minutes Maintenance work inadvertently affected flame.
9/3/21 106 minutes Scheduled maintenance to replace transmitter.
9/7/21 9 minutes Induced Draft Fan breaker tripped due to overheating from ambient high
temperature inside ECR.
Total flameout duration for the quarter= 4.47 hours
Scheduled Thermal Oxidizer Shutdowns During This Quarter
Date Duration Reason
9/3/21 106 minutes Scheduled maintenance to replace transmitter.
The Thermal Oxidizer is capable of a hot restart if the combustion chamber is within a temperature
range. This was the case in all the above instances, with the exception of 09/03/21 maintenance.
At no time were the processes allowed to vent to the atmosphere without being controlled by the
Thermal Oxidizer and 4-Stage Scrubber System and includes the time during the above conditions.
All flows were held in the accumulator tanks until the flame could be reestablished and target
temperature achieved.
Annual inspections of the burner assemblies, blowers, fans, dampers, refractory lining, oxidizer
shell, fuel lines, and ductwork were completed in October 2020 during the annual TAR shutdown.
Inspection and maintenance records are maintained onsite and are available upon request.
Section 2.1 B.11 f ii: Annual inspection of scrubber spray nozzles to detect clogging or
corrosion damage of nozzles and perform maintenance and repair when necessary to ensure
proper operation of the scrubber.
Annual inspection of the scrubber spray nozzles was completed in October 2020 during the annual
TAR shutdown. There were no issues noted during the inspection of the scrubber spray nozzles.
During this quarter, there were no issues noted with the scrubber spray nozzles. Inspection and
maintenance records are maintained onsite and are available upon request.
Section 2.1 B.11 f.iii: Annual inspection of scrubber packing material to ensure proper packing
depth and to check for clogging.
The annual inspection of the scrubber packing material was completed during the annual shutdown
in October 2020. There were no issues noted during the inspection of the scrubber packing
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021
Air Permit No. 03 73 5T48 Page 3 of 8
material. During this quarter, there were no issues noted with the scrubber packing material.
Inspection and maintenance records are maintained onsite and are available upon request.
Section 2.1 B.11.fiv: Annual inspection, cleaning, and calibration of all associated
instrumentation.
Annual inspections, cleaning, and calibration of associated instrumentation was completed in
October 2020 during the annual TAR shutdown. Inspection and maintenance records are
maintained onsite and are available upon request.
Section 2.1 B.11 f v: In addition to annual inspections, the Permittee shall also conduct the
inspections required in paragraphs i. thru iv., above, whenever the Thermal Oxidizer and 4-
Stage Scrubber System are nonoperational for a minimum of 72 hours.
System Total Nonoperational Reason/Cause
Hours during this Quarter
Thermal Oxidizer 4.47 hours Refer to summary table of periods when a flame was
not detected. Section 2.1 B.11.f.i
4-Stage Scrubber 0 N/A
The Thermal Oxidizer and 4-Stage Scrubber System were not nonoperational for more than 72
consecutive hours during this quarter.
Section 2.1 B.11.
The Permittee shall develop, and submit to NC DAQ for approval, a site-specific monitoring
plan that addresses design, data collection, and quality assurance/quality control elements for
operating each CMS installed according to Section 2.1 B.11.h. and B.11 . The monitoring plan
shall address the following:
Section 2.1 B.11-g.is Initial and any subsequent calibration of the CMS.
Section 2.1 B.11.g.ii: Determination and adjustment of the calibration drift of the CMS.
Section 2.1 B.11.g.iii: Preventive maintenance of the CMS, including spare parts inventory.
Section 2.1 B.Il.g.iv: Data recording, calculations, and reporting.
Section 2.1 B.11.g.v: Accuracy audit procedures, including sampling and analysis methods.
Section 2.1 B.11.g.vi: Program of corrective action for a malfunctioning CMS.
Section 2.1 B.11.g.vii: Ongoing operation and maintenance procedures.
Section 2.1 B.11.g.viii: Ongoing data quality assurance procedures.
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3r1 Quarter 2021
Air Permit No. 03735T48 Page 4 of 8
A detailed site-specific monitoring plan for the Thermal Oxidizer and 4-Stage Scrubber System
was submitted to NC DAQ on November 27, 2019. It provides details on calibration, preventive
maintenance, spare parts, data recording and calculations, accuracy, corrective action for
malfunctioning CMS, ongoing operation and maintenance, and data quality assurance procedures.
A copy of the site-specific monitoring plan is maintained onsite and available upon request.
Section 2.1 B.11.h
The Permittee shall install, calibrate, maintain, and operate a CMS for the Thermal Oxidizer.
The CMS shall include a continuous recorder capable of taking measurement at least once every
15 minutes. The Permittee shall operate the CMS according to the approved site-specific
monitoring plan specified in Section 2.1 B.Il.g., above, to ensure the following operational
parameters are maintained.
The Site has a DCS, capable of taking readings at least every 15 minutes. The DCS system is
maintained and operated according to the approved site-specific monitoring plan.
Section 2.1 B.11.h.is A minimum combustion chamber temperature of 1800 degrees Fahrenheit
(3-hour rolling average).
For this quarter, the lowest 3-hour rolling average combustion chamber temperature (while the
Thermal Oxidizer was in operation)was 1,992 degrees Fahrenheit(OF). During this quarter,while
the emissions sources were in operation, there were no instances where the 3-hour rolling average
combustion chamber temperature dropped below the minimum 1,800 OF.
Section 2.1 B.11.h.ii: A maximum Thermal Oxidizer inlet gas feed rate of 2,200 pounds per
hour (3-hours rolling average).
For this quarter, the maximum 3-hour rolling average inlet gas feed rate (combined total) was
1,0491bs/hour.
Section 2.1 B.11.h.iii: Failure to operate the temperature monitor or inlet feed gas monitoring
device identified, above, for at least 97 percent of the total operational time per quarterly
reporting period shall constitute noncompliance with the emission limits in Section 2.1 B.Ha.
The DCS was operational 100% of the time during the quarter when the Thermal Oxidizer was
operational. The DCS communicated and recorded the combustion chamber temperature and inlet
feed gas flow rate data for 100% of the operational time.
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021
Air Permit No. 03735T48 Page 5 of 8
Section 2.1 B.11.i
The Permittee shall install, calibrate, maintain, and operate the CMS for the 4-Stage Scrubber
System. The CMS shall include a continuous recorder capable of taking a measurement at least
once every 15 minutes. The Permittee shall operate the CMS according to the approved site-
specific monitoring plan specified in Section 2.1 B.11.g., to ensure the following operational
parameters are maintained.
The Site has a DCS, capable of taking readings at least every 15 minutes. The CMS was operated
according to the approved site-specific monitoring plan during the quarter. A copy of the site-
specific monitoring plan is maintained onsite and available upon request.
Section 2.1 B.H.i.is The scrubber liquor flow shall be a minimum of 40 gallons per minute for
the fourth caustic scrubber stage.
During this quarter, at no time were there instances when the scrubber liquor flow rate for the 4th
Stage dropped below 40 GPM while the emission sources were in operation. The lowest flow rate
recorded during this quarter was 75 GPM. Records of scrubber liquor flow rate are maintained
onsite and available upon request.
Section 2.1 B.H.i.ii: A minimum scrubber liquor pH, no less than 7.1 (3-hour rolling average)
for the fourth scrubber stage.
For this quarter,the lowest 3-hour rolling average scrubber liquor pH(during the time the scrubber
was in operation)was 7.39. Records of the scrubber liquor pH are maintained onsite and available
upon request.
Section 2.1 B.H.i.iii: Failure to operate the scrubber liquor flow meter or pH meter, identified
in i. and ii.,for at least 97 percent of the total operational time per quarterly reporting period
shall constitute noncompliance with the emission limits in Section 2.1 B.H.a.
The DCS was operational 100% of the time during the quarter when the system was operational,
as were the scrubber liquor flow and pH meters. The DCS communicated and recorded the
scrubber liquor flow rate and the pH reading for 100% of the operational time, while the emission
sources were in operation.
Section 2.1 B.H.J.
Except as specified in Section 2.1 B.H.k., the Permittee shall operate the Thermal Oxidizer and
4-Stage Scrubber System at all times when the emission sources (ID Nos. NSA, NS-B, NS-C,
NS-D-1,NS-E, NS-F,NS-G-1,NS-K,NS-M, NS-N,NS-O, and NS-P) are operating.
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021
Air Permit No. 03735T48 Page 6 of 8
During this quarter, the Thermal Oxidizer and 4-Stage Scrubber System was in operation at all
times when the emissions sources were in operation. Records are maintained onsite and available
upon request.
Section 2.1 B.H.k.
Prior to operation of the Thermal Oxidizer and 4-Stage Scrubber System, the Permittee shall
develop, and submit to NCDAQ for approval, a detailed shutdown and malfunction plan for the
Thermal Oxidizer and 4-stage Scrubber System that contains specific procedures for initiating
the shutdown of process emission sources during periods of control device shutdown and
malfunction, and a program of corrective action for malfunctioning processes, and control
systems used to comply with the limits in Section 2.1 B.II.a. The Permittee shall keep a copy of
the approved plan onsite.
A Shutdown and Malfunction Plan for the Thermal Oxidizer and 4-Stage Scrubber System was
submitted to NC DAQ on December 18, 2019,which included a Proactive Maintenance Plan. The
maintenance plan includes predictive maintenance, preventive maintenance, functional checks,
corrective maintenance, and annual inspections to ensure the reliability of the Thermal Oxidizer
and 4-Stage Scrubber System.
A copy of the Shutdown and Malfunction Plan is maintained onsite and available upon request.
Section 2.1 B.Il.k.i: To ensure that the control devices are well maintained to minimize
malfunctions, the plan shall include a maintenance schedule for the Thermal Oxidizer and 4-
Stage Scrubber System that is consistent with, but not limited to the manufacturer's instructions
and recommendations for routine and long-term maintenance, as specified in Section 2.1
B.11.h. and B.Il.i.
A Shutdown and Malfunction Plan was submitted to NC DAQ on December 18,2019 that includes
a Proactive Maintenance Plan,which is the maintenance schedule for the Thermal Oxidizer and 4-
Stage Scrubber System. The Proactive Maintenance Plan includes predictive maintenance,
preventive maintenance, functional checks, corrective maintenance, and annual inspections to
ensure the reliability of the Thermal Oxidizer and 4-Stage Scrubber system.
A copy of the Shutdown and Malfunction Plan is maintained onsite and available upon request.
Section 2.1 B.11.k.ii: An inspection schedule for each CMS installed on the Thermal Oxidizer
and 4-Stage Scrubber System to ensure, at least once in each 24-hour period, that each CMS is
properly functioning.
The CMS is comprised of a DCS and IP21 and have various systems backup and other
redundancies built into it to ensure, at least once in each 24-hour period,the proper functioning of
the system. The IP21 application has a series of queries that monitor aspects of the application
and data provided by the DCS and will send email alerts to the various support teams to investigate
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021
Air Permit No. 03735T48 Page 7 of 8
and correct any potential malfunctions. The inspection schedule for the DCS is specified in the
Shutdown and Malfunction Plan and is maintained onsite and available upon request.
Section 2.1 B.Il.k.iii: At no time shall the emissions from the emissions sources (ID Nos. NS-
A, NS-B, NS-C, NS-D-1, NS-E, NS-F, NS-G-1, NS-K, NS-M, NS-N, NS-O, and NS-P) be
allowed to vent to the atmosphere without being controlled in the Thermal Oxidizer and 4-Stage
Scrubber System.
During the reporting quarter, the emissions from the emission sources did not vent to the
atmosphere without being controlled by the Thermal Oxidizer and 4-Stage Scrubber System.
Section 2.1 B.11.1.
The Permittee shall record the following information monthly in a logbook (written or
electronic) that shall be maintained onsite and made available to NC DAQ upon request.
Section 2.1 B.11.l.i.: Records of the continuous and 3-hour rolling average operating
parameters specified in Section 2.1 B.11.h. and B.11.i.,for the Thermal Oxidizer and 4-Stage
Scrubber System.
The IP21 data historian application has the capability to store 5 years of process data that includes
3-hour rolling averages. Process data records are maintained onsite and available upon request.
Section 2.1 B.11.l.ii.: If the emission sources are not operating, a record of this fact along with
the corresponding date and time.
Process operating times for the emissions sources are submitted to NC DAQ every 2 weeks.
Detailed records are maintained onsite and available upon request.
Section 2.1 B.11.l.iii.: Records of all inspections and maintenance conducted for the Thermal
Oxidizer and 4-Stage Scrubber System, as specified in Section 2.1 B.Ilf.
Annual inspections and maintenance were completed in October 2020 during the annual TAR
shutdown.
Records of inspections and maintenance conducted are maintained onsite and available upon
request.
Section 2.1 B.H.l.iv.: Records associated with the site-specific monitoring plan specified in
Section 2.1 B.11.g.
Records associated with the site-specific monitoring plan are maintained onsite and available upon
request.
Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)— 3rd Quarter 2021
Air Permit No. 03735T48 Page 8 of 8
Section 2.1 B.H.m.
The Permittee shall retain all results of performance testing conducted in accordance with
Section 2.1 B.H.b. and B.H.c., including development of the operating parameters, as specified
in Section 2.1 B.H.h. and B.H.L. and the calculation of the Thermal Oxidizer and 4-Stage
Scrubber System control efficiency with respect to the control of all PFAS, including GenX
compounds, and emissions from the emission sources (ID Nos. NSA, NS-B, NS-C, NS-D-1,
NS-E, NS-F, NS-G-1,NS K, NS-M,NS-N,NS-O, and NS-P).
Records of results from performance testing conducted on the Thermal Oxidizer and 4-Stage
Scrubber System have been submitted to the State and copies are maintained onsite and available
upon request.
Chemours has submitted stack testing reports for each performance test, along with supporting
documentation that includes operational parameters for the Thermal Oxidizer and 4-Stage
Scrubber System and for the emissions sources during the testing periods. The most recent stack
testing results report was submitted to NC DAQ on March 31, 2021 that demonstrated a control
efficiency that exceeded 99.99%.
Section 2.1 B.11.n.
The Permittee shall submit a quarterly summary report of monitoring and recordkeeping
activities specified in Section 2.1 B.11 f through B.11.n.
All instances of deviations from the requirements of this permit must be clearly identified.
During this quarter, there were no instances of deviations from the requirements of Section 2.1
B.l IS through 2.I.B.l l.n of the air permit. �