AQ_F_0900009_20160303_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: 03/04/2016
Facility Data Permit Data
Chemours Company-Fayetteville Works Permit 03735 /T41
22828 NC Highway 87 West Issued 11/24/2015
Fayetteville,NC 28306 Expires 1/31/2020
Lat: 34d 50.6000m Long: 78d 50.2930m Classification Title V
SIC: 2869/Industrial Organic Chemicals,nec Permit Status Active
NAILS: 32512/Industrial Gas Manufacturing Current Permit Application(s)TV-Minor, TV-
Renewal
Contact Data
Facility Contact Authorized Contact Technical Contact Program Applicability
Michael Johnson Ellis McGaughy Michael Johnson SIP/Title /112r
Environmental Manager Plant Manager Environmental Manager 1VI�`CT Partt 63: Subpart Boiler-112j, Subpart
[phone] [phone] [phone] NSPS: Subpart
Dc FFpart ZZZZ
Compliance Data
Comments:
Inspection Date 03/03/2016
Inspector's Name Gregory Reeves
Inspector's Signature: i j.� Operating Status Operating
a Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: fJJ� l�l U�6 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 *HAP
2014 0 1.95 76.26 332.17 38.10 8.60 39138.00
2013EJ7.95
7 0.2100 80.13 312.90 30.45 9.47 39856.00
2012 1.23 63.76 260.86 29.24 7.95 37401.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 2 of 11
1. DIRECTIONS TO SITE: Chemours Company-Fayetteville Works(formerly DuPont)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,
hearing protection). Entry into several areas of the plant requires specialized safety gear. In the Nation®reactor
and Nafion®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
conditions. The facility has two permanent boilers onsite,one permanent boiler which is permitted but not yet
constructed, and one permitted temporary boiler.
4. INSPECTION SUMMARY: On Thursday,March 3,2016,I,Greg Reeves,of the Fayetteville Regional Office,
met with Mike Johnson,Environmental Manager,for a full compliance inspection. Mr.Johnson reviewed the
FacFinder sheet and noted no changes for the facility contacts. 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. Mr.Johnson led a tour of individual plants and provided the required records. PSD
records and most all other records are accessible on the facility computer LAN in Mr.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 modification would not happen in the near future. The permitted
temporary boiler(PSC-Temp)is not currently on site,and was not on site during 2015. The Vinyl Ethers North
product container decontamination process(ID No.NS-0),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 observed zero visible emissions from each of the operating source emission points
during the inspection.
5. PERMITTED EMISSION SOURCES: At the time of the inspection, Chemours Company—Fayetteville Works
was operating under Permit No. 03735T41 which includes the following emission sources:
E hissioh Emiss on Source DwWri(ition Control I)evlee .Coufrol'Device Deser pt�on
Si oree ID N6 ID No. ...
PS-A Natural Gas/No.2 fuel oil/No. 6 fuel oil- N/A N/A
Case-by-case fired boiler(139.4 million Btu per hour
MACT maximum heat input)
OPERATING
PS-B Natural Gas/No.2 fuel oil No. 6 fuel oil- N/A N/A
Case-by-case fired boiler(88.4 million Btu per hour
MACT maximum heat input)
OPERATING
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

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 3 of 11
Etiiission Ess
mii1on Source'Desariptioti Contras Device. rol D Contevice Description
PS-Temp Natural Gas/No. 2 fuel oil-fired boiler N/A N/A
(greater than 30.0 and less than 100.0
million Btu per hour maximum heat
input)
NOT ON SITE AT TIIIS TIME
NS-A Nation Hexfluoropropylene epoxide NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF process(HFPO) kilogram/hour liquid injection rate
OPERATING -or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
J1 kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-B Nafion®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)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-C Nafion®Vinyl Ethers South process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF OPERATING kilogram/hour liquid injection rate
-m- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
j kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-D Nafion®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
j kilogram/hour liquid injection rate
avera ed over a 3-hourperiod)
NS-E Nafion®Liquid waste stabilization NCD-Hdrl Baffle-plate scrubber(7,000
i
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-hour period)
NS-F Nafion®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-hour period)
NS-G Nafion®Resins process NCD-G Venturi vacuum jet caustic scrubber
MACT FFFF OPERATING
NS-H Nafion®membrane process N/A N/A
OPERATING

I
ChemoursCompany—FayettevilleWorks
Compliance Inspection Report
Page 4 of 11
emission TmissiunSourceDgscri(ttiop ;Control Device Cbut0)P iceDgscritthou':
Suiuil+oe`ID No. ;. ! 'ID No;
NS-I Nafion®membrane coating N/A N/A
OPERATING
NS-J Nafion®semiworks N/A N/A
OPERATING
NS-K Nafion®E-2 Process N/A N/A
OPERATING
NS-L Nafion®TFE/HC1 separation unit NCD-Hdrl Baffle-plate scrubber(7,000
REMOVED FROM SERVICE 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-hour period)
NS-M Nafion®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
SW-2 Semiworks laboratory hood N/A N/A
OPERATING
AS-A Polymer Processing Aid Process ACD-AI Wet scrubber(30 gallons per minute
OPERATING water injection rate averaged over a 3-
hour period)(state-enforceable only)
ACD-A3 Wet scrubber installed on the building
exhaust vent(voluntary use only)
WTS-A Extended aeration biological wastewater N/A N/A
treatment facility
OPERATING
WTS-B, Two(2)Indirect steam-heated,rotary WTCD-1 Impingement-type wet scrubber with
WTS-C sludge dryers mist eliminator(state-enforceable only)
OPERATING

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 5 of 11
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
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 mniBtu/hr maximum heat input,PS-C). The third
boiler(PS-C)has not yet been constructed. According to Mr.Johnson,the construction project will not begin
anytime soon. Both of the 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 does have 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 2D .1109 Case-by-case MACT condition,in lieu of the NESHAP Subpart
DDDDD Boiler MALT. Therefore,they are not currently subject to any of the requirements of the Boiler MACT.
Boiler MACT requirements will become effective in 2019. Chemours has a facility-wide PSD S02 emissions
limitation of 702.5 tons per consecutive 12-month period.
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from boilers PS-A and PS-B shall not exceed 0.2667 lbs/mmBtu. Particulate emissions
from PS-C shall not exceed 0.2268 lbs/mmBtu. No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLLANCE—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 March
2013 and July 2013 during boiler tune-ups(total of 5,635 gallons of#2 fuel oil combusted)and in June 2015 for
a short test(109 gallons 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
dioxide emissions from boilers PS-A and PS-B shall not exceed 2.3 pounds per million Btu heat input. 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 0.507 lbs/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.
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-Temp shall not exceed 20%opacity. No
monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLLANCE—The boilers are currently combusting natural gas and I observed 0%opacity
from the boiler stacks.
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. Initial notifications are required at construction and startup. The facility
must conduct Method 9 testing after boiler start-up using No. 2 fuel oil. The Permittee shall maintain records of
fuel usage and fuel certifications. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Boiler PS-C is not yet under construction,and there are no current plans to
install this unit. The last semi-annual report was received at FRO on 01/19/16.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 6 of 11
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 SO2. 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(14 month period),fuel usage, and
sulfur content. The Permittee must also list all deviations from the requirements in the report.
APPEARS IN COMPLIANCE—All records show that the facility is well below these emissions limits. The
highest 12-month total NOx emissions during 2013 were 6.8 tons and SO2 emissions were 0.0 tons. The last
semi-annual report was received at FRO on O1/19/16.
15A NCAC 2D.1109 CASE-BY-CASE MACT—This stipulation includes requirements for boilers PS-A,PS- j
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—Inspection and tune-up of PS-A was conducted on 09/22/15 and 10/19/15,and
inspection and tune-up of PS-B was conducted on 03/13/15. The last semi-annual report was received on
O1/19/16.
i
*Nafion®Process Area(all sources labeled with NS-and NCD-)*
The Nafion®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 the 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 Nafion®process area are used to control the emissions of various pollutants including
hydrogen fluoride and other acid fluorides. The Nafion®process at this facility manufactures plastic materials
classified under SIC code 2821, and are therefore existing affected sources under the NESHAP"MON".The
Nafion®process is subject to the Miscellaneous Organic NESHAP, Subpart FFFF.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the Nafion®process shall not exceed E-4.10*P0 67. The Permittee shall
maintain production records. A semi-annual summary report is required.
APPEARS INCOMPLIANCE—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 01/19/16.
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 the inspection,I observed 0%VE from all emission points at the
facility.
15A NCAC 2D.1506 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The Nation process shall not operate without odor control equipment.
APPEARS IN COMPLIANCE—Odorous emissions from the Nafion®process are controlled by two baffle-
plate scrubbers NCD-Hdrl and NCD-Hdr2. The control devices also have monitoring parameters that are
continually recorded and interlocked into the system. All the facility's monitoring parameters are recorded and
viewable in an Aspen program. No noticeable odor was detected away from the facility,and Mr.Johnson
indicated that no odor complaints had been received.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 7 of 11
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 following month. Records indicate that the highest 12-month VOC emissions during 2015 were 49.56 tons.
The last semi-annual report was received at FRO on 01/19/16.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-G shall not exceed the following: 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 2015 were
17.52 tons. The last semi-annual summary report was received at FRO on 01/19/16.
I
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-A shall not exceed the following: 85.3 TPY VOC. The
Permittee shall keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS INCOMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2015 were
52.13 tons. The last semi-annual summary report was received at FRO on 01/19/16.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the HFPO Product Container Decontamination Process(NS-N)shall not
exceed the following: 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
i
from each container. A semi-annual summary report is required.
APPEARS INCOMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2015 were
9.64 tons. The last semi-annual report was received at FRO on 01/19/16.
40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The Nafion®process
must comply with all provisions of this MALT. The MON requires 99%control efficiency for some Group 1
sources;however,DuPont 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
Ili 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. To monitor 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
II is required.
APPEARS IN COMPLIANCE—The scrubbers currently controlling the Nafion®process(NCD-Hdrl and
Hdr2)meet the control efficiency requirement. The scrubbers were tested at 99.6%efficiency in August 2003.
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
i
I

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 8 of 11
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 2015. The last semi-annual summary
report was received at FRO on 01/19/16. Amore 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 MACT. 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 permitted by the facility's LDAR policy.
*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
December of 2002. Formerly,the Polymer Processing Aid reaction process used perfluorooctanoate(brought in by
truck in its iodide/salt form)reacted with sodium hydroxide(stored in totes)to form the acid fluoride. The acid
fluoride is 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 perfluorooctanoic acid(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 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 is subject to the 112(r)chemical accident prevention
program for oleum. DuPont has made a decision to eliminate APFO by 2015. The PPA process at the Fayetteville
Works has been modified, and no longer produces AFPO. A more environmentally friendly polymer is currently
being produced in the existing reactor as a replacement for APFO.
15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The Polymer Processing Aid Process facility shall not operate without implementing a management
plan or without odor control equipment.
APPEARS INCOMPLL4NCE—The APFO process is controlled by scrubbers. No odors were
noticeable during the inspection. Mr.Johnson stated that no odor complaints had been received.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—Emissions
from the APFO facility shall be controlled by a wet scrubber. The liquid flow rate in the packed bed section
shall be at least 30 gallons per minute and the differential pressure across the bed shall be a maximum of 12
inches of water. An alarm is required for the pressure monitoring. Records of all inspections shall be kept in a
logbook. No reporting is required.
APPEARS INCOMPLL4NCE—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 two 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 two hours to establish the minimum 2-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 37.9 gpm,and the pressure drop across the scrubber bed was 0.1"H2O. The last internal inspection of the
scrubber was performed on 10/12/14. Inspections are on a two-year interval.
I

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 9 of 11
*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)will also
address 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
treatment facility shall not operate without a management plan or odor control equipment. An objectionable
odor shall not be detected from these sources. 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 INCOMPLIANCE—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. The most recent 5-year
inspection was 11/01/11.
*Temporary Boiler(PS-Temp)*
This boiler is permitted for 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 INCOMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu and for No.
2 fuel oil is 0.0241bsflnmBTU. This 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.
APPEARS IN COMPLIANCE—The AP-42 emission factor for Natural Gas is 0.001 lb/mmBtu and for No.2
fuel oil burning extremely low sulfur content oil(<15 ppm Sulfur by weight)is 0.0021b/mmBtu. Therefore,
the source will not exceed the limits while combusting either of these permitted fuels.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions shall be no more than 20%
opacity. No monitoring/recordkeeping/reporting is required.
APPEARS INCOMPLIANCE—The source was not on site during the inspection. While combusting either
natural gas or#2 fuel oil,it is expected that there will be no visible emissions from this source(VE=0%
opacity).
15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.0524 NEW SOURCE PERFORMANCE
STANDARDS(NSPS Subpart Dc)—In order to avoid the applicability of NSPS Subpart Dc,the temporary
boiler shall combust natural gas or distillate oil with potential Sulfur Dioxide emissions rate no greater than
0.060 lb/mmBtu,be capable of being moved from one location to another,and remain onsite for no longer than
180 consecutive days as defined in 40 CFR 60.41c(temporary boiler). Notification is required if the 180 days
will be exceeded. Recordkeeping and a semi-annual summary report are required.
APPEARS IN COMPLIANCE—The temporary boiler was not on site during the inspection,and had not been
on site during 2015. The last semi-annual report was received at FRO on 01/19/16.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 10 of 11
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.
APPEARS IN COMPLIANCE—The boiler was note onsite during 2015. The last semi-annual report was
received at FRO on 01/19/2016.
15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.1109 CASE-BY-CASE MACT FOR BOILERS
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.
APPEARS 17V COMPLIANCE—The boiler was not onsite during 2015.
*Multiple Emission Source(s)Specific Limitations and Conditions*
*Boilers*
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
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.
APPEARS INCOMPLIANCE—The highest 12-month rolling total S02 emissions during 2014 from the 4
boilers was 0.2 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.) The last semi- j
annual report was received at FRO on 01/19/16.
*Facility-Wide*
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Pemrittee shall maintain records of production rates,throughputs,material usage,excess emissions,and
control equipment failures. A quarterly summary report is required
APPEARS INCOMPLIANCE—Production rates,material usages, emissions,and equipment failure
records are available on the company electronic data system. TAP reports are submitted quarterly and
show emissions well below the 2D .I100 limits. The last quarterly report was received at FRO on
01/19/16.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permince 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 Nafion®scrubbers
(NCD-Hdr-I and NCD-Hdr-2)shall be a minimum 7,000 kg/hr. The Permittee shall 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 14,661 kg/hr for Hdr-1
and 17,936 kg/hr for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber and is
interlocked to shut the systems down at 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 05/23/11 and the last inspection of Hdr-2 was performed on 08/25/11. The last quarterly report was
received at FRO on 01/19/16.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 11 of 11
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.
APPEARS IN COMPLL4NCE—The facility now 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.
40 CFR Part 68 CHEMICAL ACCIDENT PREVENTION AND Clean Air Act,Section 112(r): The
Nafion process is subject to 112(r)for sulfur trioxide. The TFE process is subject to 112(r)for
Tetrafluoroethylene. The PVF process is subject to 112(r)for Vinyl Fluoride.
APPEARS IN COMPLL4NCE- The facility submitted the written Risk Management Plan to the U.S.
EPA in June 1999. In addition,the facility is subject to the OSHA Process Safety Management(PSM)
I 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 Mike Thomas, Greg Reeves,and Mike Reid of DAQ and
Thomas Steelman of the Division of Emergency Management(DEM)on 03/05/15. The facility appeared
to be in compliance during that inspection. The facility has the following processes subject to 112(r):
TFE Process 1 TFE(Tetrafluoroethylene) 59,400
Nation®Process 3 Sulfur Trioxide 61,000
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.
i
APPEARS IN COMPLIANCE—The 2015 compliance certification was received at FRO on 02/18/16.
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 03/03/16
inspection,Chemours Company—Fayetteville Works APPEARS IN COMPLIANCE with the requirements
outlined in their current air permit,03735T41.
PINK SHEET: N/A
GWR