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Home My WebLink AboutAQ_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