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ROY COOPER A
Governor
ELIZABETH S.BISER
Secretary *�f QUAM W
MICHAELABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
December 16, 2022
Ms. Dawn Hughes
Plant Manager
Chemours Company-Fayetteville Works
22828 NC Highway 87 West
Fayetteville,NC 28306
SUBJECT: Receipt of Permit Application
Modification of Permit No. 03735T48
Application No. 0900009.2213
Chemours Company-Fayetteville Works
Facility ID: 0900009,Fayetteville,Bladen County
Dear Ms. Hughes:
The subject permit application(0900009.22B)for Chemours Company-Fayetteville Works
(Chemours)located in Fayetteville,Bladen County,North Carolina was accepted by the Division of Air
Quality(DAQ)on November 3,2022.
Chemours is requesting authorization to modify the Vinyl Ethers North(VEN)and Vinyl Ethers
South(VES)plants and the IXM Membrane Process Area(ID Nos.NS-B,NS-C, and NS-H,respectively).
The proposed modification will be referred to as the Proposed Project throughout this letter.
DAQ has reviewed the subject application in accordance with 15A NCAC 02Q .0504 and 15A
NCAC 02Q .0312(a) and determined the application is incomplete. The items listed below must be
addressed:
Fugitive Emissions of Methylene Chloride
Chemours calculated potential fugitive emissions of methylene chloride(MeCI)(ID No. I-03)by
increasing the 2021 emissions by 20%. This percentage was selected assuming emissions would
increase proportionally to the additional equipment/components that will be added as a result of the
Proposed Project. This methodology is appropriate,but the use of 2021 data may underestimate
emissions of MeCI.As shown in the table below,the 2021 fugitive emissions of McCl represent the
lowest emissions in the last five years.
Compound Emissions as Reported in EI in lb/ r
2017 2018 2019 2020 2021
MeCI 6,933 4,046 1,800 8,057 1,159
Note: McCl emissions ID No.I-03 are not controlled by the thermal oxidizer ID No.NCD- 1 .
Please explain why 2021 emissions are appropriate as a basis for potential emissions from this
source. If necessary,please provide updated potential emissions from the Proposed Project including
revised fugitive MeCI emissions.
D North Carolina Department of Environmental Quality I Division of Air Quality
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217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
NORTH CAROLINA _
Depart—m ofsn.imnmanai Quall /`� 919.707.8400

Ms. Hughes
December 16,2022
Page 2
Baseline Actual Emissions
A project is considered a major modification under Prevention of Significant Deterioration(PSD)if
there is a physical change in or a change in the method of operation of a major stationary source that
would result in both a significant emissions increase and a significant net emissions increase.
Chemours provided a PSD applicability analysis to determine if any regulated compounds would be
subject to PSD review. Emission increases were calculated by comparing baseline actual emissions
(BAE)to potential to emit(PTE) for the Proposed Project. Chemours selected calendar years 2018
and 2019 as the period for BAE, and the average emissions for these two years were used for the
BAE.
• Thermal oxidizer(ID No.NCD-Q1), lime silo(ID No.NS-Rl), and lime slaker(ID No.NS-R2)
—Because the thermal oxidizer,the lime silo,and lime slaker were not operating in 2018 and
2019, Chemours used 2021 emissions for the BAE for these sources. This approach is not
acceptable. For a new emission unit,which is defined in 40 CFR 51.166(b)(7)(i)"as any
emissions unit that is(or will be)newly constructed and that has existed for less than 2 years
from the date such emissions unit first operated,"BAE are set to zero in accordance with 40 CFR
Part 51.166(b)(47)(iii). If these emission sources have been operating more than two years such
that they are no longer considered new emission units,the BAE would still be set to zero because
they were not operating during the baseline period(i.e.,calendar years 2018 and 2019).
• Emissions from boilers(ID Nos. PS-A and PS-B)—The boilers at Chemours are used to produce
steam for the Kuraray America, Inc.—Fayetteville facility(FID 0900091)and the DuPont
Company-Fayetteville Works(FID 0900092),in addition to the Chemours site. The BAE were
based on emissions for the operation of both boilers(ID Nos. PS-A and PS-B)in calendar years
2018 and 2019 and accounted for steam production for all three facilities.
Post project emissions from the boilers were based on the highest steam production(kg/h) for
Chemours only during 2021 and 2022. This value was then increased by 50% (a conservative
increase according to Chemours), and annual natural gas usage was determined from this value.
The natural gas usage was used to estimate emissions from the boilers. Chemours indicated
operation of only one boiler was necessary and selected the largest boiler(ID No. PS-A)because
of the higher associated emission factors.
As noted above,the BAE for the boiler included emissions from steam produced in support of
Kuraray America,Inc.—Fayetteville facility,DuPont Company-Fayetteville Works, and
Chemours. Please provide justification for including the emissions from steam production
supporting these facilities in the BAE, as boiler emissions from the Proposed Project were based
only on steam production for Chemours.
Please provided a revised PSD applicability determination that includes the appropriate BAE for the
thermal oxidizer(ID No.NCD-Q1),the lime silo(ID No.NS-RI),the lime slaker(ID No.NS-R2),
and the boiler(ID No. PS-A).
Emissions of Fluorinated Organic Compounds
Chemours compared emissions of Fluorinated Organic Compounds(FOC) from the Proposed Project
with 2021 emissions to demonstrate that the Proposed Project did not result in an increase in FOC.
The FOC emissions used for this comparison represent proposed emissions,not potential emissions,
from the modified processes. Potential emissions of FOC from the Proposed Project were also
provided in the permit application and were based on 2021 emissions, adjusted for maximum
production volume and hours of operation. The methodology for determining proposed emissions

Ms. Hughes
December 16,2022
Page 3
was not well documented in the permit application. Please provide a detailed explanation of how the
proposed emissions of FOC were determined.
As part of the application review,DAQ compared the potential emissions of FOC to the proposed
emissions.Potential emissions of FOC were larger for all emissions sources included as part of the
Proposed Project with the exception of the VEN plant(ID No.NS-B).As shown in the table below,
created by DAQ,the total potential emissions of FOC(4,143.9 lb/yr) from the VEN plant are larger
than the total proposed emissions(3,285.7 lb/yr). However,the proposed emissions for several
specific FOC are larger than the potential emissions. Specific FOC with larger proposed emissions
are shaded in the table below.
Fluorinated VEN(NS-B)-Proposed(Actual Hours) VE-North(NS-B) Difference
Organic Indoor Outdoor Total Post-Mod Potential Between Potential
Compound Name CAS No. Compounds Emissions Emissions Process Equipment Equipment and Proposed
(FOC) (lb/yr) Emissions Emissions (Ib/yr) (lb/yr) Emissions
(Ib/yr) (lb/yr) (lb/yr)
HFPO 428-59-1 FOC 4.8 656.69 0 661.49 839.23 177.74
HFP 116-15-4 FOC 2.1 31.12 89 122.22 105.32 -16.9
COF2 353-50-4 FOC 0 0 0 0 0 0
PAF 354-34-7 FOC 0 0 0 0 0 0
PMCP 379-16-8 FOC 0 0 0 0 0 0
A/F Solvent n=4 TFF 21703-48-0 FOC 0 0 0 0 0 0
A/F Solvent n=1 TAF 21703-43-5 FOC 0 0 0 0 0 0
A/F Solvent n=2 TAF 21703-45-7 FOC 0 0 0 0 0 0
A/F Solvent n=3 TAF 21703-47-9 FOC 0 0 0 0 0 0
A/F Solvent n=4 TAF 21703-49-1 FOC 0 0 0 0 0 0
Other A/F Compounds NA FOC 0 0 0 0 0 0
PPF 422-61-7 FOC 3.16 22.3 0 25.46 39.01 13.55
DA 4089-58-1 FOC 0.01 45.2 0 45.21 37.56 -7.65
MA 4089-57-0 FOC 0 2.01 0 2.01 1.67 -0.34
TA 4628-44-8 FOC 0 1.65 0 1.65 1.37 -0.28
RSU 677-67-8 FOC 0 0.82 0 0.82 0.68 -0.14
MAE 69116-72-9 FOC 0 6.31 0 6.31 1.6 -4.71
MMF 69116-71-8 FOC 0 3.76 0 3.76 0.96 -2.8
DAE 69116-73-0 FOC 0 9.75 0 9.75 2.48 -7.27
TAE 69116-67-2 FOC 0 0.43 0 0.43 0.11 -0.32
HFPO Trimer 2641-34-1 FOC 0 7.71 0 7.71 10.87 3.16
EVE 63863-43-4 FOC 0 7.38 219.45 226.83 57.65 -169.18
PPVE 1623-05-8 FOC 0.33 326.04 847.56 1173.93 2,105.22 931.29
PSEPVE 16090-14-5 FOC 0 27.59 736.94 764.53 635.16 -129.37
hydro-EVE 660857-95-4 FOC 0 0.43 9.75 10.18 2.59 -7.59
iso-EVE 73122-14-2 FOC 0 0.78 14.63 15.41 3.92 11.49
C4 360-89-4 FOC 0.49 28.99 178.25 207.73 298.27 90.54
C5 376-87-4 FOC 0.01 0 0 0.01 0.01 0
TFE 116-14-3 FOC 0.22 0 0 0.22 0.22 0
H dro-PSEPVE 75549-02-9 FOC 0 0 0 0 0 0
lso-PSEPVE 34805-58-8 FOC 0 0 0 0 0 0
PMPF 2927-83-5 FOC 0 0 0 0 0 0
PEPF 1682-78-6 FOC 0 0 0 0 0 0
PMVE 1187-93-5 FOC 0 0 0 0 0 0
PEVE 10493-43-3 FOC 0 0 0 0 0 0
MD 2479-75-6 FOC 0 0 0 0 0 0
H droPEVE 360796-50-5 FOC 0 0 0 0 0 0
E-1 3330-15-2 FOC 0 0 0 0 0 0
E-2 3330-14-1 FOC 0 0 0 0 0 0
E-3 3330-16-3 FOC 0 0 0 0 0 0
F-113 76-13-1 FOC 0 0 0 0 0 0
SU 697-18-7 FOC 0 0 0 0 0 0
Initiator 56347-79-6 FOC 0 0 0 0 0 0
Fluoroform* 75-46-7 FOC 0 0 0 0 0 0
Total FOC 11.12 1178.96 2095.58 3285.66 4143.9 858.24

Ms. Hughes
December 16,2022
Page 4
This result leaves DAQ with no confidence in the FOC estimates for the VEN plant as an error may
exist in either the determination of potential emissions,the proposed emissions,or both. Please
reevaluate the potential and proposed scenarios from the VEN plant, and other emission sources as
necessary,and provide revised emissions data.
It should be noted that GenX does not appear in the table of FOC emissions. Chemours provided a
separate table in the permit application specifically for GenX emissions,which remain below the
emission limit of 23.027 pounds per year after the Proposed Project.Please include GenX emissions
in the table of FOC emissions from the project for completeness.
Impact of Emissions on Water Resources
DAQ continues to evaluate Chemours current FOC emissions from the facility as a whole and their
impact on the environment. This evaluation is informed by DAQ's prior confirmation of a causal
link between FOC emissions from Chemours and widespread degradation of groundwater quality,
DAQ's analysis of deposition data nearby the facility, and an expanding area of groundwater and
surface water quality impacts,including in downstream communities.With regard to the Proposed
Project,and Chemours' representation of FOC emission increases for some specific compounds,
DAQ does not have sufficient information to ensure protection of the State's water resources.DAQ
requests that Chemours provide information sufficient to demonstrate that emissions from the project
will not cause further degradation of the State's water resources in violation of applicable laws and
regulations, including but not limited to a full fate and transport modeling analysis.
Please address the above requested information within thirty(30)days of receipt of this letter.
Processing of this application will be stopped until DAQ receives the requested information.
Please note this letter does not preclude DAQ from requesting additional information at a later date if
such information is necessary to properly evaluate the source, its air pollution abatement equipment, or the
facility.
If you have any questions or concerns with respect to this additional information letter,please
contact Betty Gatano,P.E.,of my staff at(919) 707-8736.
Sincerely yours,
6U"—�
Mark J. Cuilla,EIT, CPM,Chief,Permitting Section
Division of Air Quality,NCDEQ
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