AQ_F_0900009_20180228_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Chemours Company-Fayetteville Works
NC Facility ID 0900009
Inspection Report County/FIPS:Bladen/017
Date: 03/01/2018
Facility Data Permit Data
Chemours Company-Fayetteville Works Permit 03735/T43
22828 NC Highway 87 West Issued 12/14/2016
Fayetteville,NC 28306 Expires 3/31/2021
Lat: 34d 50.6700m Long: 78d 49.8750m Classification Title V
SIC: 2869/Industrial Organic Chemicals,nec Permit Status Active
NAILS: 32512/Industrial Gas Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V/112r
7 MACT Part 63: Subpart Boiler-112j,Subpart
Michael Johnson Ellis McGaughy Michael Johnson FFFF, Subpart ZZZZ
Environmental Manager Plant Manager Environmental Manager NSPS: Subpart
[phone] [phone] [phone]
Dc
Compliance Data
- Comments:
Inspection Date 02/28/2018
Inspector's Name Gregory Reeves
Inspector's Signature: �� Operating Status Operating
Compliance Code Compliance-inspection
P P P
Action Code FCE
_ Date of Signature: On-Site Inspection Result Compliance
I "'
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 4.16 0.2100 65.19 237.76 36.45 4.16 36881.00
%. 2015 8.94 0.2030 55.45 290.39 42.10 8.94 34123.00
2014 8.60 1.95 76.26 332.17 38.10 8.60 39138.00
t *Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
{
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 2 of 12
1. DIRECTIONS TO SITE: Chemours Company-Fayetteville Works is located on NC Highway 87 in Bladen
County. From FRO,take Highway 87 south. The entrance to the facility is approximately 18 miles from FRO on
the left side of Highway 87 just before the Cumberland/Bladen County line.
2. SAFETY CONSIDERATIONS: The usual FRO safety gear is required(hardhat,safety glasses, safety shoes, i
hearing protection). Entry into several areas of the plant requires specialized safety gear. In the HFPO reactor and
MMF process areas,personnel are not allowed to enter unless the process is not operating due to the possibility of
explosion hazards of the chemical reaction process.
3. FACILITY DESCRIPTION: Chemours Company-Fayetteville Works is a chemical manufacturing facility
located in Bladen County. The facility was formerly named DuPont. The facility employs approximately 500
employees and 250 full-time contractors on a 24 hr,7 day per week basis. The facility consists of four individual
manufacturing plants,a boiler house and a waste treatment operation. Several processes have PSD avoidance I
conditions. The facility has two permanent boilers onsite, one permanent boiler which is permitted but not yet i
constructed,and one permitted temporary boiler.
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4. INSPECTION SUMMARY: On Wednesday,February 28,2018,I,Greg Reeves,of the DAQ Fayetteville
Regional Office,met with Christel Compton,Program Manager,and Mike Johnson,Environmental Manager,for a
full compliance inspection. Mr.Johnson reviewed the FacFinder sheet and noted that the facility contacts have j
changed. He provided updated information for the contacts. These changes have been noted in the IBEAM
Facilities database and updated invoice contact information has been emailed to the RCO Fees Coordinator.
Facility records were reviewed for emissions,control device inspections,and visible emissions from the emission
sources. There are extensive electronic records for the facility operations available on the local computer area
network. Mr.Johnson confirmed that there have been no changes in emission sources since the previous inspection
/permit modification and that the emissions sources listed on the permit had not changed. I had toured the facility
on Monday 02/26 and observed the emission sources during that tour. PSD records and most all other records are
accessible on the facility computer LAN in W.Johnson's office. For the operating areas,flow rates and pressure
drops in scrubbers are available in the control rooms of the respective areas. Two boilers(PS-A and PS-B)were
operating,firing natural gas. The third permitted boiler(PS-C)is not yet constructed and Mr.Johnson stated that the
installation of the third boiler would not happen in the near future. The permitted temporary boiler(PSC-Temp)is
not currently on site,and was not on site during 2017. The HFPO product container decontamination process(ID
No.NS-N),Vinyl Ethers North product container decontamination process(ID No.NS-O),and the Vinyl Ethers
South product container decontamination process(ID No.NS-P)were not operating during the inspection. All other
processes were in operation during the inspection. I had observed zero visible emissions from each of the operating
source emission points during my plant tour on 02/26/18. I did not tour the plant during the inspection visit on
02/28/18,but was able to observe most all of the emission source points during my entry into the facility.
5. PERMITTED EMISSION SOURCES: At the time of the inspection, Chemours Company—Fayetteville Works
was operating under Permit No.03735T43 which includes the following emission sources:
PS-A Natural Gas/No.2 fuel oil-fired boiler N/A N/A
Case-by-case (139.4 million Btu per hour maximum
MACT heat input)
OPERATING
PS-B Natural Gas/No.2 fuel oil-fired boiler N/A N/A
Case-by-case (88.4 million Btu per hour maximum heat
MACT input)
OPERATING

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 3 of 12
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PS-C Natural Gas/No.2 fuel oil-fired boiler N/A N/A
NSPS Dc (97 million Btu per hour maximum heat
Case-by-case input)equipped with a low-NOx burner
MACT NOT YET CONSTRUCTED
PS-Temp Natural Gas/No.2 fuel oil-fired boiler N/A N/A
(less than 100.0 million Btu per hour
maximum heat input)
NOT ON SITE AT THIS TIME
NS-A Hexfluoropropylene epoxide(HFPO) NCD-Hdr1 Baffle-plate scrubber(7,000
MACT FFFF process kilogram/hour liquid injection rate
OPERATING -or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-B Vinyl Ethers North process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
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NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-C Vinyl Ethers South process NCD-Hdr1 Baffle-plate scrubber(7,000
MACT FFFF OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-D RSU Process NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-E FPS Liquid waste stabilization NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-F MMF process NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-G IXM Resins process NCD-G Venturi vacuum jet caustic scrubber
MACT FFFF OPERATING

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Chemours Company—Fayetteville Works
Compliance Inspection Report '
Page 4 of 12
1113
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NS-H IXM membrane process N/A N/A
OPERATING
NS-I IXM membrane coating N/A N/A
OPERATING
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NS-K E-2 Process N/A N/A
OPERATING
NS-M TFE/CO2 separation process N/A N/A
OPERATING
NS-N HFPO product container decontamination N/A N/A
process
OPERATING
NS-O Vinyl Ethers North product container N/A N/A
decontamination process
OPERATING
NS-P Vinyl Ethers South product container N/A N/A
decontamination process
OPERATING
SW-1 Semiworks polymerization operation N/A N/A
OPERATING
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SW-2 Semiworks laboratory hood N/A N/A
OPERATING
AS-A Polymer Processing Aid Process ACD-Al Wet scrubber(30 gallons per minute
OPERATING water injection rate averaged over a 3-
hourperiod)State-enforceable only
WTS-A Extended aeration biological wastewater N/A N/A
treatment facility
OPERATING
WTS-B, Two(2)Indirect steam heated,rotary WTCD-1 Wet scrubber with mist eliminator
WTS-C sludge dryers State-enforceable only
OPERATING
6. APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each of the various
manufacturing processes as listed on the current air permit.
*Powerhouse(Boilers PS-A,PS-B,and PS-C)*
The facility is permitted to operate one Natural Gas/No.2 fuel oil-fired boiler(139.4 mmBtu/hr maximum heat (I
input,PS-A),one Natural Gas/No.2 fuel oil-fired boiler(88.4 mmBtu/hr maximum heat input,PS-B),and one
Natural Gas/No.2 fuel oil-fired boiler with low-NOx burner(97 mmBtu/hr maximum heat input,PS-C). The third k'
boiler(PS-C)has not yet been constructed. According to Mr.Johnson,this boiler will not be constructed anytime '
soon,as there is no current need for additional steam capacity. Both of the existing boilers are currently combusting
natural gas. The larger boiler(PS-A)has a steam capacity of 113,000 pounds of steam per hour(139.4 mmBtu
maximum heat input)and was manufactured in 1969. The smaller boiler(PS-B)was manufactured in 1982 with a
steam capacity of 72,000 pounds per hour(88.4 mmBtu/hr maximum heat input). They are both pre-NSPS boilers;
however,Boiler PS-B has a PSD avoidance condition for NO.and S02. Boiler PS-C will be subject to NSPS
Subpart Dc when constructed. All three of the boilers are now subject to the 213.1109 Case-by-case MACT
condition through May 2019,in lieu of the NESHAP Subpart DDDDD Boiler MALT. Therefore,they are not
currently subject to any of the requirements of the Boiler MALT. Boiler MACT requirements will become effective
in May 2019. Chemours has a facility-wide PSD S02 emissions limitation of 702.5 tons per consecutive 12-month
period.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 5 of 12
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from boilers PS-A and PS-B shall not exceed 0.26671bs/mmBtu. Particulate emissions
from PS-C shall not exceed 0.2268 lbs/mmBtu. No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu and for No.
2 fuel oil is 0.024 lbs/mmBtu. As long as the facility only combusts these fuels,they should not exceed the
emission limits. The facility is currently combusting natural gas. The last#2 fuel oil was combusted in
January 2017 during a short natural gas curtailment(28,350 gallons of No.2 fuel oil combusted). The#2 fuel
oil used is extremely low sulfur content(< 15 ppm sulfur by weight.)
15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—The sulfur
r dioxide emissions from boilers PS-A and PS-B shall not exceed 2.3 pounds per million Btu heat input while
firing natural gas or No.2 fuel oil,and the sulfur dioxide emissions from boiler PS-C shall not exceed 2.3
pounds per million Btu heat input while firing natural gas only. No monitoring/recordkeeping/reporting is
required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.001 lbs/mmBtu and for No.
2 fuel oil(with 0.5%sulfur content by weight)is 0.5071bs/mmBtu. All No.2 fuel oil is extremely low sulfur
fuel oil(< 15 ppm sulfur content by weight.)The facility should never exceed the S02 emission limit while
combusting either natural gas or#2 fuel oil. Mr.Johnson produced a bill of lading for the latest fuel oil
shipment which indicated the sulfur content to be< 15 ppm.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from Boiler PS-A shall
not exceed 40%opacity. Visible emissions from PS-B and PS-C shall not exceed 20%opacity. No
monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The boilers are currently combusting natural gas and I observed 0%opacity
from the boiler stack. Boiler PS-C has not yet been constructed.
15A NCAC 2D.0524 NEW SOURCE PERFORMANCE STANDARDS—SUBPART Dc(for PS-C only)—
The sulfur content of fuel combusted in the new boiler(PS-C)shall not exceed 0.5%by weight and visible
emissions are limited to 20%opacity. Written notifications are required for construction commencement and
startup within 30 days after these events. The facility must conduct Method 9 testing after boiler start-up if
6 using No.2 fuel oil. The facility must,maintain records of fuel usage and fuel oil certifications. Records of
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startup,shutdown,and malfunctions must also be maintained. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Boiler PS-C has not yet commenced construction,and there are no current
plans to install this unit. Therefore,none of the above requirements have been triggered. The last semi-annual
report was received at FRO on 01/30/18.
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15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS(PS-B only)—Emissions from Boiler PS-B shall not exceed the following: 40 TPY NO,and
40 TPY S02. The Permittee shall keep monthly records of fuel usage, fuel sulfur content, and maintain fuel
certifications. A semi-annual report is required,listing monthly emissions(17-month period),fuel usage,and
f sulfur content. The Permittee must also list all deviations from the requirements in the report.
i APPEARS IN COMPLIANCE—All records show that the facility is well below these emissions limits. The
highest 12-month total NOx emissions during 2016 were 3.6 tons and S02 emissions were 0.0 tons. The last
semi-annual report was received at FRO on 01/30/18,which noted no deviations.
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Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 6 of 12
15A NCAC 2D.1109 CASE-BY-CASE MACT—This condition includes requirements for boilers PS-A,PS-
B,and PS-C that were instituted as a result of the vacating of the Boiler MACT. Requirements include an
annual inspection and tune-up of each boiler each calendar year. Records of inspections and tune-ups are
required. A semi-annual report is required,starting January 30,2014.
APPEARS IN COMPLIANCE—The last inspection and tune-up of PS-A was conducted on 01/21/18,and the
last inspection and tune-up of PS-B was conducted on 08/07/17. The last semi-annual report was received on
01/30/18.
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15A NCAC 2D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY—Requires that the
Permittee comply with the requirements of NESHAP Subpart DDDDD beginning as of May 20,2019. Includes
the requirement for a one-time energy assessment,which must be conducted prior to May 20,2019.
APPEARS IN COMPLIANCE—These requirements are not yet applicable. The facility contacts were
reminded of the due date of the energy assessment.
*FPS/IXM Process Area*
The operation produces a variety of relatively uncommon monomer and polymer chemicals. Some of the monomers
are shipped offsite,while others are used onsite in the production of various polymers. The polymers are shipped
offsite or used onsite to produce Nafion®membrane material. A principal use of this membrane is in the electrolysis
cells for production of chlorine and sodium hydroxide at chloro-alkali plants. The two waste gas scrubbers located
at the FPS/IXM process area are used to control the emissions of various pollutants including hydrogen fluoride and
other acid fluorides. The HFPO,Vinyl Ethers North and South,and the IXM Resins processes(ID Nos.NS-A;NS-
B,NS-C,and NS-G)are subject to the Miscellaneous Organic NESHAP, Subpart FFFF and are classified as existing
sources under this regulation.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the membrane coating process NS-I shall not exceed E=4.10*P°.67. The
Permittee shall maintain production records. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—The initial permit application indicated that compliance would be achieved
based on the process description as permitted. No changes to the process have been made since that application,
and therefore compliance is indicated. Production records are available at each manufacturing facility. The
last semi-annual summary report was received at FRO on 01/30/18.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the membrane
coating process NS-I shall not exceed 20%opacity. No monitoring,recordkeeping,or reporting is required.
APPEARS IN COMPLIANCE—During my previous visit on 02/26,I observed 0%VE from all emission
points at the facility. I noted no visible emissions from any of the sources during this inspection.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—VOC emissions from the Vinyl Ethers North process,NS-B,shall not exceed 68.9 TPY
VOC. The Permittee shall keep monthly records of VOC emissions. A semi-annual report is required.
APPEARS IN COMPLIANCE—VOC emissions are calculated using stack test results,material balances,and
flow rates/concentrations on a monthly basis. These records are submitted to Mike Johnson within 30 days of
the end of the previous month. Records indicate that the highest 12-month VOC emissions during 2017 were
18.99 tons. The last semi-annual report was received at FRO on 01/30/18.
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Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 7 of 12
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-G shall not exceed 40 TPY VOC. The Permittee shall
keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2017 were
24.95 tons. The last semi-annual summary report was received at FRO on 01/30/18.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-A shall not exceed 85.3 TPY VOC. The Permittee shall
keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2017 were
45.79 tons. The last semi-annual summary report was received at FRO on 01/30/18.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the HFPO Product Container Decontamination Process(NS-N)shall not
exceed 40 TPY VOC. The Permittee shall keep monthly records of VOC emissions. The Permittee shall also
maintain records of dates each container is decontaminated and total mass of VOC removed from each
container. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2017 were
9.04 tons. The last semi-annual report was received at FRO on 01/30/18.
15A NCAC 2D.0530(u)USE OF PROJECTED ACTUAL EMISSIONS TO AVOID APPLICABILITY
OF REQUIREMENTS OF PSD—Requires the facility to maintain records of annual VOC emissions from the
IXM Membrane Coating Process(ID No.NS-I)for 10 years following the startup of the modified process. An
annual report is required within 60 days after the end of the calendar year. If the projected actual emissions of
67.27 tons per year,as stated in the permit application,are exceeded,an explanation as to why the actual rates
exceeded the projection must be included in the annual report.
APPEARS IN COMPLIANCE—The IXM Membrane Coating process modification started operation on May
1,2017. The Actual VOC emissions in 2017 were 29.01 tons. The startup notification was received at FRO on
05/08/17. Mr.Johnson indicated that the annual report had been mailed on 02/19/18.
15A NCAC 2D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(MACT)40 CFR Part
60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The HFPO,Vinyl Ethers North
and South,and the IXM Resins processes(ID Nos.NS-A,NS-B,NS-C,and NS-G)must comply with all
provisions of this MACT. The MON requires 99%control efficiency for some Group 1 sources;however,
Chemours determined that their sources are not subject to the stricter requirements of a control device. The
Permittee shall monitor and inspect all the valves,pumps,compressors,agitators,and connectors for leaks using
the instrument monitoring methods described in 40 CFR 63.1023(b)-(c). All equipment affected by the leak
requirements shall be identified. The Permittee shall create and retain a record of the monitoring schedule for
each process unit. If a leak is identified,it shall be repaired as provided in the repair provisions of this section.
After a leak has been repaired,the valve shall be monitored at least once within the first 3 months after its
repair. This requirement is in addition to the monitoring required to satisfy the definition of repaired and first
attempt at repair. The required periodic monitoring may be used if it satisfies the timing requirement of this
condition. The Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days
after it is detected. The facility operates two process heat exchangers that are subject to the MON. Monitoring
for presence of a leak in a heat exchanger system requires that three samples of both the cooling water entrance
to and exit from the heat exchanger be monitored for the presence of hazardous air pollutants monthly for the
first six months of operation and quarterly thereafter. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—The scrubbers currently controlling the HFPO,Vinyl Ethers North and South,
and the IXM Resins processes(ID Nos.NS-A,NS-B,NS-C,and NS-G)(NCD-Hdrl and Hdr2)meet the
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Chemours Company—Fayetteville Works !
Compliance Inspection Report
Page 8 of 12
control efficiency requirement. The scrubbers were tested at 99.6%efficiency in August 2003 (further data
indicates that the efficiency was only 99.1%). Initial notification was received on 2 March 2004. However,no
controls are required for this facility based on HAP content,THE values,and other various parameters. The
facility has an extensive LDAR program,and inspects all the valves,pumps,compressors,agitators,and
connectors for leaks on a monthly basis.Records are available at the site. Each affected unit has a physical tag
for equipment identification. Three samples of both the cooling entrance and exit are taken at the heat
exchangers to analyze for leaks on a monthly basis. The facility also submits a semi-annual report for MACT
Subpart FFFF. There were no deviations from the emission limits,operating limits,or work practice standards
during 2017. The last semi-annual summary report was received at FRO on 01/30/18. A more extensive
MACT FFFF report is submitted to EPA and FRO also,which includes several items not required in the Title V
permit,but are required by the MALT. The facility has a"zero leak"policy. If a leak is discovered,it is fixed
ASAP,even if the process must be shut down. No delay of repair scenarios are normally permitted by the j
facility's LDAR policy,but they are allowed under the MACT regulation. One delay of repair occurred in the
HFPO process in December 2017 when the process could not be shut down immediately. i
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*Polymer Processing Aid(PPA)Process(all sources labeled with AS-and ACD-)*
The polymer processing aid process,formerly the ammonium perfluorooctanoate(APFO)process,began operation in f
December of 2002. Formerly,the Polymer Processing Aid reaction process used perfluorooctanoate(PFOA-brought
in by truck in its iodide/salt form)reacted with sodium hydroxide(stored in totes)to form the acid fluoride. The acid f
fluoride was then reacted with ammonia to produce the ammonium salt. Fuming sulfuric acid(oleum)is received by
truck and used as a solvent in the process. Currently,APFO and the associated(PFOA),also known as C8,are not
regulated as toxic or hazardous air pollutants. However,the EPA has been reviewing the chemical with the possibility
of its designation in the future as a regulated pollutant. Due to historical pollution and health effects concerns and i
recent controversy regarding the DuPont facility in West Virginia,and the recent activities by the U.S.EPA to develop
and review toxicity data for this chemical,the DAQ file includes several documents and articles related to APFO,
PFOA,or C8. The APFO process was subject to the 112(r)chemical accident prevention program for oleum. DuPont
made a decision to eliminate APFO by 2015,and therefore the PPA process at the Fayetteville Works was modified,
and no longer produces APFO and is no longer subject to 112(r)written risk management plan requirements. The
replacement for APFO is HFPO Dimer Acid,which is currently also under scrutiny.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—Emissions j
from the PPA facility shall be controlled by a wet scrubber. The liquid flow rate in the packed bed section shall
be a minimum of 30 gallons per minute and the differential pressure across the bed shall be a maximum of 12
inches of water,based on three-hour averages. An alarm is required for the pressure monitoring. Records of all
inspections shall be kept in a logbook. No reporting is required.
APPEARS IN COMPLIANCE—The scrubber is interlocked so that the system will shut down,almost
instantaneously,if the parameters are exceeded. The facility will go into shutdown mode if the three-hour
average is less than 30 gpm or pressure is 5 inches of water. The system is set up such that upon startup after an
extended shutdown,the scrubber must be operated for three hours to establish the minimum 3-hour average
prior to allowing the startup of the remaining equipment. The polymer processing aid chemical is a surfactant;
therefore,the dP increases occasionally due to `suds' in the scrubber. The liquid flowrate during the inspection
was 38.1 gpm,and the pressure drop across the scrubber bed was 0.4"H2O. The last internal inspection of the
scrubber was performed on 03/01/16. Inspections are on a two-year interval.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 9 of 12
*Wastewater Treatment Area fall sources labeled with WTS-and WTCD-)*
For the wastewater treatment operations,the Title V permit specifies two rotary sludge dryers controlled by an
impingement-type wet scrubber with mist eliminator. The Miscellaneous Organic NESHAP(MON)also addresses
emissions from wastewater. With respect to quantity of emissions,methanol is the most significant air pollutant
from the wastewater treatment operation.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The wastewater
,I treatment facility shall not operate without implementing management practices or installing and operating odor
control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the property boundary. The sludge dryers shall be controlled by a caustic injection
scrubber. An I&M logbook is also required for the scrubber. No reporting is required.
APPEARS IN COMPLIANCE—Odorous emissions from the sludge dryers are controlled by a scrubber
utilizing potassium hydroxide solution. Inspections of this scrubber are on a 5-year cycle. Wastewater
treatment odors were not noted at boundary lines. The sludge dryers are located inside a building. The facility
keeps maintenance records for the scrubber in their electronic maintenance program. Mr.Johnson stated that no
odor complaints have been received by the facility. The most recent 5-year inspection was 06/29/16.
*Temporary Boiler(PS-Temp)*
This boiler is permitted to combust Natural Gas/No.2 fuel oil and is brought on-site on an`as needed' basis. There
is currently no temporary boiler on site. The temporary boiler was last on site during the period 11/19/12 through
01/09/13 and utilized natural gas for fuel
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from the temporary boiler shall not exceed 0.2426 lbs/mmBtu. No
monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu and for No.
2 fuel oil is 0.024 lbs/mmBTU. The boiler was not on site during this inspection.
15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—Sulfur
Dioxide emissions from the temporary boiler shall not exceed 2.3 lb/mmBtu heat input. No
monitoring/recordkeeping/reporting is required. The boiler was not on site during 2017.
{ APPEARS IN COMPLIANCE—The AP-42 emission factor for Natural Gas is 0.001 lb/mmBtu and for No.2
E fuel oil burning extremely low sulfur content oil(< 15 ppm Sulfur by weight)is 0.002 lb/mmBtu. Therefore,
i the source will not exceed the limits while combusting either of these permitted fuels. The boiler was not on
site during this inspection.
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15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions shall be no more than 20%
j opacity. No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The source was not on site during the inspection. While combusting either
`i natural gas or#2 fuel oil,it is expected that there will be no visible emissions from this source(VE=0%
I opacity).
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15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.0530 PREVENTION OF SIGNIFICANT
DETERIORATION—The temporary boiler PS-Temp shall discharge into the atmosphere less than 40 tons of
S02 per consecutive 12-month period. Monthly records of fuel usage are required. Monthly calculation of S02
emissions and rolling 12-month S02 emissions are required. A semi-annual report is required.
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APPEARS IN COMPLIANCE—The boiler was not onsite during 2016. The last semi-annual report was
received at FRO on 01/30/18.
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Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 10 of 12
15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.1109 CASE-BY-CASE MACT FOR BOILERS 1
AND PROCESS HEATERS AND OF 40 CFR 63 SUBPART DDDDD MACT FOR BOILERS AND
PROCESS HEATERS-The temporary boiler shall remain onsite for no longer than 180 consecutive days. If
it is onsite for more than 180 consecutive days,the facility must notify the regional office within 10 days of
exceeding the 180-day period. A startup notification is required within 15 days after startup of the boiler.
APPEARS IN COMPLIANCE—The boiler was not onsite during 2017. No notifications have been required.
*Multiple Emission Source(s)Specific Limitations and Conditions*
*Boilers*
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15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the boilers(PS-A,PS-B,PS-C,and PS-Temp)shall not exceed 702.5 j
tons of S02 per consecutive 12-month period. Records must be maintained for the quantities of fuels used
monthly. Fuel supplier certification must be maintained for fuel oil shipments. A semi-annual report is
required.
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APPEARS IN COMPLIANCE—The highest 12-month rolling total S02 emissions during the past 15
months from the 4 boilers was 3.2 tons. Current fuel is natural gas. Fuel oil certifications are available in
the company records on site. #2 fuel oil used is ultra-low sulfur content(< 15 ppm sulfur by weight.)
Some No.2 fuel oil was combusted in January 2018(28,350 gallons)during a short natural gas curtailment.
The last semi-annual report was received at FRO on 01/30/18.
*Facility-Wide*
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permittee shall maintain records of production rates,throughputs,material usage,excess emissions,and
control equipment failures. A quarterly summary report is required
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APPEARS IN COMPLIANCE—Production rates,material usages,emissions,and equipment failure g
records are available on the company electronic data system. TAP reports are submitted quarterly and
show emissions well below the 2D.1100 limits. The last quarterly report was received at FRO on
01/30/18.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS State Enforceable Only)—The
( Y)
Permittee shall emit less than the limits listed in the permit for HF from high dispersion stacks and from all
other sources. The Permittee shall also report quarterly all TPER exceedances,the maximum 1-hour
emission rate and the maximum 24-hour emissions rate. The liquid flow rate in the Baffle Plate-Type
Scrubbers(NCD-Hdr-1 and NCD-Hdr-2)shall be a minimum 7,000 kg/hr each. The Permittee shall k
maintain a logbook of all inspection and maintenance activities on the applicable scrubber. A quarterly
report is required.
APPEARS IN COMPLIANCE—The liquid flow rates during the inspection were 15,024 kg/hr for Hdr-1
and 18,497 kg/hr for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber and is
interlocked to shut the systems down when flowrate drops below 7,000 kg/hr and to alarm at 9,000 kg/hr.
The electronic I&M logbook appeared to be complete. TAP reports are submitted quarterly and show
emissions well below the 2D.1100 limits. Hdr-1 and Hdr-2 are inspected every 4 years. The last
inspection of Hdr-1 was performed on 05/26/15 and the last inspection of Hdr-2 was performed on
07/29/15. The last quarterly report was received at FRO on 01/30/18.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 11 of 12
40 CFR Part 68 CHEMICAL ACCIDENT PREVENTION AND Clean Air Act,Section 112(r): The
S03 process is subject to 112(r)for sulfur trioxide. The TFE process is subject to 112(r)for
Tetrafluoroethylene.
APPEARS IN COMPLIANCE- The facility submitted the written Risk Management Plan to the U.S.
EPA in June 1999. The facility was issued a facility identifier number 1000 0022 9647. In addition,the
facility is subject to the OSHA Process Safety Management(PSM)Standard. The latest update of the RMP
was submitted by the facility to EPA on 06/09/15. The last full 112(r)compliance inspection was
conducted by Greg Reeves DAQ on 06/21/17. The facility appeared to be in compliance during that
inspection.
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aThe facility has the following processes subject to 112(r):
TFE Process 1 TFE Tetrafluoroeth lene 59,400
i S03 Process 3 Sulfur Trioxide 61,000
15A NCAC 2D.0541 CONTROL OF EMISSIONS FROM ABRASIVE BLASTING—Abrasive
blasting shall take place inside a building unless the item exceeds eight feet in length or is permanently
situated at an outside location. Fugitive emissions shall not migrate beyond the property boundaries.
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APPEARS IN COMPLIANCE—The facility has an abrasive blasting building in which the sand blasting
occurs. Outside blasting of tanks and equipment is accomplished using shrouds to contain the blasting
materials.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The facility
shall not operate without implementing management practices or installing and operating odor control
equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
j APPEARS IN COMPLIANCE—No objectionable odors were detected during the inspection. Mr.
Johnson stated that no odor complaints have been received by the facility.
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15A NCAC 2Q.0504 OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT
—The facility is required to submit an amended Title V permit application within 1 year from the date of
beginning normal operation of the IXM Membrane Coating Process(ID No.NS71). The facility is also
required to submit a notification of startup of this process within 15 days after the beginning of normal
4 operation.
APPEARS IN COMPLIANCE—The process commenced operation on May 1,2017. Startup notification
was received at FRO on 05/08/17. The facility personnel are in process of assembling the permit
application now.
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PERMIT SHIELD FOR NONAPPLICABLE REQUIREMENTS—This permit condition states that the
boiler(ID No.PS-TEMP)has been declared a temporary boiler,as is thus not subject to NESHAP Subpart
DDDDD. The facility must keep records documenting that the boiler meets the criteria of a temporary
boiler. The facility must also submit a startup notification within 15 days of startup of the boiler.
APPEARS IN COMPLIANCE—The boiler has not been brought onsite as yet,so no notification or
records have been required.
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.Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 12 of 12
GENERAL CONDITION 3.I REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND
PERMIT DEVIATIONS—Requires the facility to report incidents of excess emissions or deviations from
permit conditions.
APPEARS IN COMPLIANCE—Mr.Johnson stated that no excess emission events occurred during 2017.
No deviations from permit conditions occurred during 2017. Therefore,no reporting was required.
GENERAL CONDITION 3.P COMPLIANCE CERTIFICATION[15A NCAC 2Q.0509(n)]: The
facility is required to submit an annual compliance certification to DAQ and EPA by March 1 of each year
for the previous calendar year.
APPEARS IN COMPLIANCE—The 2017 compliance certification was received at FRO on 03/01/18.
GENERAL CONDITION 3.X ANNUAL EMISSION INVENTORY REQUIREMENTS—The facility
must submit an annual emission inventory by June 30 of each year.
APPEARS IN COMPLIANCE—The 2016 emission inventory was received at FRO on 06/27/17
GENERAL CONDITION 3.MM FUGITIVE DUST CONTROL REQUIREMENT—The facility shall
not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary.
APPEARS IN COMPLIANCE—I did not observe any dust accumulations nor observe any excess visible
emissions beyond the property boundary. Mr.Johnson stated that no dust complaints have been received
by the facility.
7. NON-COMPLIANCE HISTORY SINCE 2010:
There have been no non-compliance instances at this facility since 2010.
8. CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 02/28/18
inspection,Chemours Company—Fayetteville Works APPEARS IN COMPLIANCE with the requirements
outlined in their current air permit,03735T43.
PINK SHEET: N/A
GWR
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