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HomeMy WebLinkAboutAQ_F_0900009_20210104_CMPL_CompRpt 09/01
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The Chemours Company
Chemours Fayetteville Works
22828 NC Highway 87 W
Fayetteville,NC 28306
RECEIVED
JAN 2 8 20-22
DEO-FAYE17EVILLE RMONAL OFFICE
CERTIFIED MAIL ARTICLE NUMBER 7017 1450 0002 3902 3891
RETURN RECEIPT REQUESTED
January 26, 2022
Heather Carter
NCDEQ—Division of Air Quality
225 Green Street—Suite 714
Fayetteville,NC 28301
SUBJECT: Chemours Company—Fayetteville Works
Title V Air Permit No. 03735T48
Facility ID No. 0900009
Quarterly Summary Report—Carbon Adsorbers—4th Quarter 2021
Ms. Carter,
Attached is the quarterly summary report for the period from October 1, 2021 to December 31,
2021 for the Chemours Fayetteville Works submitted 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,
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Christel Compton
Program Manager
Attachment
a
Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021
Air Permit No. 03735T48 Page 1 of 6
Carbon Adsorbers and Enhanced LDAR Program Quarterly Report
(per Air Quality Permit No. 03735T48, Condition Section 2.2 D.1)
Air Quality Permit No. 03735T48, Condition 2.2 D.1: "15A NCAC 02Q .0519(a)(7) and
Consent Order"
Pursuant to Section 2.2 D.1.m of the subject Title V permit, the permittee shall submit a quarterly
summary report that includes monitoring and recordkeeping activities specified in Section 2.2 D.1.
The summary report shall include the information recorded as required in Section 2.2 D.1.k and 1.
For clarity, this report has been broken down into subsections for each monitoring and
recordkeeping requirement contained in Sections 2.2 D.1.k. and 2.2 D.1.1.
Section 2.2 D.l.m.i
The summary report shall include the information recorded as required in Section 2.2 D.1.k
and 1.
Section 2.2 D.I.k.i: Records of all production data and hours of operation collected during
performance tests
Chemours submitted production data with the emissions reports for each performance test
conducted. Additional production data and hours of operation are maintained onsite and are
available upon request.
Section 2.2 D.I.k.ii: Records of the calculations, and all supporting documentation, of annual
GenX Compound emissions to demonstrate compliance with the emissions limitations specified
in Section 2.2 D.I.a.
The initial annual emissions report per 2.2.1).Li was submitted in February 2021. Quarterly 99%
reduction reports were submitted under separate cover.
Section 2.2 D.I.k.iii: If the emission source is not operating, a record of this fact, along with
the corresponding date and time.
Records indicating periods when the emission sources were not operating are being maintained
and available upon request. A summary list of dates the emission sources were not operating is as
follows:
Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1) —4th Quarter 2021
Air Permit No. 03735T48 Page 2 of 6
Area No. of days Specific dates Comments
not
operating
VE North 27 days (10/8-10/31) (11/1-11/3) Annual TAR site-wide
shutdown
PPA 31 days (10/1-10/2, 10/7-10/23) (11/6, Annual TAR site-wide
11/13, 11/18-11/20, 11/27) (12/11- shutdown; Scheduled
12/13, 12/18, 12/24, 12/25) downtime
VE South 27 days (10/6-10/29) (11/6, 11/9, 11/10) Annual TAR site-wide
shutdown; Unscheduled
downtime—feedstock
Semiworks 74 days (10/1-10/24, 10/29-10/31) (11/1, Scheduled down and
11/5-11/10, 11/12-11/14, 11/19- deinventoried.
11/28) (12/3-12/6, 12/10-12/31)
Section 2.2 D.Lk.iv: Records of all inspections and maintenance conducted for the Carbon
Adsorbers (ID Nos.ACD A2 and NCD-Q3) as specified in Section 2.2 D.1.d.
The Carbon Adsorber manufacturer does not provide any recommendations on a routine
maintenance schedule, however, Chemours has developed a preventive maintenance plan for the
Carbon Adsorbers. In addition, annual inspections of the structural integrity of the carbon
adsorber systems and the duct work and piping leading to the carbon adsorbers are required.
In accordance with a letter issued by DAQ to Chemours on November 2, 2021, carbon bed
replacement schedules for PPA and VE South were approved and are as follows:
• Replace the carbon in the PPA Carbon Adsorber when operating times reach 2,950—3,050
operating hours.
• Replace the carbon in the VE-South Indoor Fugitives Carbon Adsorber annually (once
every 12 months).
The following is a summary of Carbon Adsorber inspections and maintenance conducted this
quarter. Note: any carbon changeouts will automatically include internal and external inspections
as part of the changeout.
VE North Carbon Unit Date Completed
Inspections Internal/External inspection 10/26/21
Maintenance Carbon chan eout 10/26/21
Calibrate pressure transmitter 10/20/21
Repairs None this quarter n/a
Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021
Air Permit No. 03735T48 Page 3 of 6
PPA Carbon Unit Date Completed
Inspections Internal/External 12/14/21
Maintenance Carbon changeout 12/14/21
Repairs None this quarter n/a
VE South Carbon Unit Date Completed
Inspections Internal/External 10/20/21
Maintenance Carbon chan eout 10/20/21
Replaced belts on blower 10/12/21
Calibrated pressure transmitters 10/15/21
Repairs None this quarter n/a
Semiworks Carbon Unit Date Completed
Inspections None this quarter n/a
Maintenance None this quarter n/a
Repairs None this quarter n/a
Section 2.2 D.I.k.v: Records of all instances of process shutdowns, including those triggered
by the pressure differential alarms associated with the carbon adsorber systems.
Records of all instances of process shutdowns that occurred during this quarter are shown below:
Area No. of days Specific dates Comments
not
operating
VE North 27 days (10/8-10/31) (11/1-11/3) Annual TAR site-wide
shutdown
PPA 31 days (10/1-10/2, 10/7-10/23) (11/6, Annual TAR site-wide
11/13, 11/18-11/20, 11/27) (12/11- shutdown; Scheduled
12/13, 12/18, 12/24, 12/25) downtime
VE South 27 days (10/6-10/29) (11/6, 11/9, 11/10) Annual TAR site-wide
shutdown; Unscheduled
downtime—feedstock
Semiworks 74 days (10/1-10/24, 10/29-10/31) (11/1, Batch process-scheduled
11/5-11/10, 11/12-11/14, 11/19- down and deinventoried.
11/28) (12/3-12/6, 12/10-12/31)
During this quarter, there were no instances where a process shutdown was triggered by the
pressure differential alarms associated with any of the carbon adsorber systems. Detailed process
operating times are maintained onsite and available upon request.
Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021
Air Permit No. 03735T48 Page 4 of 6
Section 2.2 D.I.k.vi: Records of all inspections and calibration of monitoring equipment as
required in Section 2.2 D.l f and D.1.h.
(2.2 D.IS.)—Inspection and calibration records for all equipment associated with the DCS system
are maintained onsite and available upon request. The procedures and schedule for maintenance
and servicing of the DCS system is outlined in the site-specific monitoring plan. 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.
(2.2 D.l.h.) - TEAM Industrial Services (Wilmington, NC office) is contracted to satisfy the
monitoring requirements for fugitive emissions from process equipment. All monitoring records
and calibration records for the monitoring equipment (TVA) are maintained onsite and available
for review upon request.
Section 2.2 D.1.l.i: A copy of each test report and compliance report submitted to NC DAQ to
comply with Section 2.2 D.1, including all documentation supporting any compliance report.
Chemours continues to submit to the NC DAQ a copy of each emissions test report and compliance
reports, including supporting documentation as specified in the Title V permit. The test reports
and compliance reports are maintained onsite and available upon request.
Section 2.2 D.I.l.ii: The most recent copy of the approved Carbon Adsorber shutdown and
malfunction plan required in Section 2.2 D.l.g. Records of instances where the differential
pressure monitors required in Section 2.2 D.lf have resulted in process shutdowns.
Carbon Adsorber operational procedures are maintained onsite and available upon request. During
this reporting quarter, there were no instances that occurred where a process shutdown was
triggered by the pressure differential alarms associated with the Carbon Adsorber systems.
Detailed process operating times are maintained onsite and available upon request.
Section 2.2 D.I.l.iii: The most recent copy of the approved Enhanced Leak Detection and
Repair Program required in Section 2.2 D.1.h.
The most recent copy of the Enhanced Leak Detection and Repair(LDAR)program was submitted
on August 14, 2019 to Greg Reeves in the NC DAQ Fayetteville Regional Office.
Section 2.2 D.1.l.iii.A: Pressure testing records, including, but not limited to, the date of
inspection, results of the inspection/pressure testing, repairs made to any equipment found to
be leaking during pressure testing, and follow-up pressure testing to verify successful repair.
1 f
Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.l)—4th Quarter 2021
Air Permit No. 03 73 5T48 Page 5 of 6
Pressure testing was completed as required and records are maintained onsite and are available
upon request. During this reporting quarter, there were no instances of equipment found to be
leaking during pressure testing, therefore, no repairs were required for any equipment.
Section 2.2 D.1.l.iii.B: AVO inspection records, including the completed checklist specified in
Section 2.2 D.1.h.ii.0 and inspection results including any leaks found and repair actions
taken.
AVO inspections were completed as required and the records are maintained onsite and are
available upon request. During this reporting quarter, the AVO inspections did not find evidence
of any leaks.
Section 2.2 D.I.l.iii.C. Method 21 and enhanced area monitoring results.
Method 21 monitoring is conducted by TEAM Industrial Services for the Enhanced LDAR
program. All monitoring reports and records of leaks found, repairs made, and re-monitoring
results are maintained onsite and are available upon request. During this reporting quarter,Method
21 and enhanced area monitoring results identified no components with monitored results
exceeding the lower leak definition.
Section 2.2 D.I.l.iii.D: Replacement program for valves and connectors logs of leakers and
repair attempts.
The replacement program for components identified as `leakers' is detailed in the Enhanced LDAR
Procedure. A 12-month rolling log is used to record and track all readings above the lower leak
definition to assist with the component replacement program. The following is a summary of the
components recorded as exceeding the lower leak definition as defined by the permit:
October 2021 —no components exceeding the lower leak definition.
November 2021 —no components exceeding the lower leak definition.
December 2021 —no components exceeding the lower leak definition.
Section 2.2 D.Lm.ii
The Permittee shall include in the summary report any excess emissions that have occurred
during the reporting period Excess emissions are defined as any calculated annual rolling
average GenX Compound emissions rate, calculated as required in Section 2.2 D.La, above,
that exceeds the emission limit in Section 2.2 D.I.a.
Chemours Company—Fayetteville Works Quarterly Report(per 2.2 D.1)—4th Quarter 2021
Air Permit No. 03735T48 Page 6 of 6
The 12-month rolling calculation for HFPO-DA emissions continued to be exceeded during the
reporting period due to an increase in emissions identified in carbon adsorber testing on the VE-
North unit in March 2021 and that was corrected in early April 2021.