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HomeMy WebLinkAboutAQ_F_0900009_20150310_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: 03/13/2015 Facility Data Permit Data Chemours Company-Fayetteville Works Permit 03735/T39 22828 NC Highway 87 West Issued 2/2/2015 Fayetteville,NC 28306 Expires 1/31/2020 Lat: 34d 50.6000m Long: 78d 50.2930m Classification Title V SIC: 3081 /Unsupported Plastics Film And Sheet Permit Status Active NAICS: 326113/Unlaminated Plastics Film and Sheet(except Packaging) Current Permit Application(s)TV-Minor, TV- Manufacturing Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V/112r Michael Johnson Ellis McGaughy Michael Johnson MACT Part 63: Subpart Boiler-112j, Subpart Environmental Manager Plant Manager Environmental Manager FFFF, Subpart ZZZZ NSPS: Subpart Dc (910)678-1155 (910)678-1224 (910)678-1155 Compliance Data Comments: Inspection Date 03/10/2015 Inspector's Name Gregory Reeves Inspector's Signature: C� Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: ®311311"11— On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2013 9.47 0:2100 80.13 312.90 30.45 9.47 39856.00 2012 7.95 1.23 63.76 260.86 29.24 7.95 37401.00 2011 11.60 2.74 73.06 271.17 31.42 11.31 35028.00 *Highest HAP Emitted(in pounds) 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 Chemours Company—Fayetteville Works Compliance Inspection Report Page 2 of 15 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 Nafion®reactor area,personnel are not allowed to enter unless the process is not operating due to the safety 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 March 10,2013,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 changes in the email addresses for the facility contacts, and also noted that the SIC/NAICS codes as listed in IBEAM were incorrect. The changes have been made to the IBEAM database,and the email address change for the invoice contact has been sent to the FRO and RCO fees coordinators. Facility records were reviewed for emissions, control device inspections, and visible emissions from the emission sources. There are extensive electronic records available 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 Intranet 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 2014. 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. 5. PERMITTED EMISSION SOURCES: At the time of the inspection,Chemours Company—Fayetteville Works was operating under Permit No. 0373 5T3 9 which includes the following emission sources: emission' ', Emi@sion'SoureeDescription �C'omt�olpeyice coatpo�AevlrxDeseetptton ;. $0'arC@ TD No. . IANo. PS-A Natural Gas/No.2 fuel oil/No. 6 fuel oil- N/A N/A (21).1109 fired boiler(139.4 million Btu per hour Case-by-case maximum heat input) MACT OPERATING PS-B Natural Gas/No.2 fuel oil No.6 fuel oil- N/A N/A (21).1109 fired boiler(88.4 million Btu per hour Case-by-case maximum heat input) MACT) OPERATING PS-C Natural Gas/No.2 fuel oil-fired boiler N/A N/A NSPS De (97 million Btu per hour maximum heat (2D.1109 input)equipped with a low-NOx burner Case-by-case NOT YET CONSTRUCTED MACT) Chemours Company—Fayetteville Works Compliance Inspection Report Page 3 of 15 EhtsstanmissionSourceDescription ControlDeviee 'Co Description: Source D)No. ID Not PS-Temp Natural Gas/No. 2 fuel oil-fired boiler N/A N/A NSPS Be (greater than 30.0 and less than 100.0 (2D.1109 million Btu per hour maximum heat Case-by-case input) MACT) NOT ON SITE AT THIS TIME BS=A Butyraldehyde storage tank BCD-A Brine-cooled condenser NO LONGER OWNED BY CHEMOURS BS-Bl.l Butacite®polyvinyl butyral flake reactors BCD-131 Packed-bed column scrubber with mist through (4 units) eliminator(8 gallons per minute water BS-BL4 NO LONGER OWNED BY injection rate averaged over a 3-hour MACT FFFF CHEMOURS period)(state-enforceable,only) BS-132.1 Butacite®polyvinyl butyral flake reactors BCD-132 Packed-bed column scrubber with mist through (4 units) eliminator(8 gallons per minute water BS-132.4 NO LONGER OWNED BY injection rate averaged over a 3-hour MACT FFFF CHEMOURSperiod)(state-enforceable, only) BS-C Butacite®polyvinyl butyral flake dryer BCD-Cl Cyclone separator MACT FFFF NO LONGER OWNED BY BCD-C2 Fabric filter(6,858 square feet of filter CHEMOURS area) BS-El Butacite®Line No.3 Sheeting Extrusion BCD-El Water-Cooled Condenser(voluntary Process,including four(4)extruders use only) NO LONGER OWNED BY CHEMOURS BS-E2 Butacite®Line No.4 Sheeting Extrusion BCD-E2 Water-Cooled Condenser(voluntary Process, including four(4)extruders use only) NO LONGER OWNED BY CHEMOURS BS-E3 Butacite®Line No.3Back-End N/A N/A Processes,including a quencher, dryer/relaxer,and wind-up area NO LONGER OWNED BY CHEMOURS BS-E4 Butacite®Line No.4 Back-End N/A N/A Processes,including a quencher, dryer/relaxer,and wind-up area NO LONGER OWNED BY CHEMOURS BS-F Butacite®PVA Unloading System and N/A N/A MACT FFFF Storage Silos NO LONGER OWNED BY CHEMOURS BS-G Butacite®PVA Dissolver Tank System N/A N/A MACT FFFF NO LONGER OWNED BY CHEMOURS NS-A Naflon®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 kilogram/hour liquid injection rate averaged over a 3-hourperiod) Chemours Company—Fayetteville Works Compliance Inspection Report Page 4 of 15 imssron .:i emission Source Descripti9n CoiioolDevice :' Cootrol Device De iption 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 -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-D Nafion®RSU Process NCD-Hdrl Baffle-plate scrubber(7,000 NOT 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-E Nafion®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 Battle-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 vacuumjet caustic scrubber MACT FFFF NOT OPERATING NS-H Nafion®membrane process N/A N/A OPERATING 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/HCI 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) Chemours Company—Fayetteville Works Compliance Inspection Report Page 5 of 15 EaY�ssipn Elhis#ion SourceDescriptign. C64tkolDeviee. Control 1)6ice Description SotS'rce ID No. ID lYG 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-0 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-Al 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 SGS-A SentryGlas®Process N/A N/A NO LONGER OWNED BY CHEMOURS FS-B Polyvinyl Fluoride Process No. 1 N/A N/A OPERATING FS-C Polyvinyl Fluoride Process No. 2 N/A N/A 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 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 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#6 fuel oil storage tank has been removed from service,and the permit was recently modified to remove#6 fuel oil as a permitted fuel for boilers PS- A and PS-B. 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-2 does have a PSD avoidance condition for PM,PM-10,NO.,and S02. Boiler PS-C will be subject to NSPS Subpart De 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 MACT. Therefore,they are not currently subject to any of the requirements of the Boiler MACT. Due to debottlenecking of the boilers by the PVF facility, DuPont now has a facility-wide PSD S02 emissions limitation. Chemours Company—Fayetteville Works Compliance Inspection Report Page 6 of 15 15A NCAC 2D .0503.PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—Particulate emissions from boilers PS-1 and PS-2 shall not exceed 0.2667 lbs/mmBtu. Particulate emissions from PS-C shall not exceed 0.2268 lbs/mmBtu. APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.0071bs/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 42 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 dioxide emissions from boilers PS-A and PS-B shall not exceed 2.3 pounds per million Btu heat input. 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 porn sulfur content by weight.)The facility should never exceed the S02 emission limit while combusting either natural gas or 42 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 COMPLIANCE—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. The Permittee shall maintain records of fuel usage and fuel certifications. A semi-annual summary report must be submitted. NSPS Construction and startup notifications are required. APPEARS IN COMPLIANCE—Boiler PS-C is not yet under construction, and there are no current plans to install this unit. 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. Semiannual reporting is also required for 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 S02 emissions were 0.0 tons. The last semi-annual report was received at FRO on 01/20/15. 15A NCAC 2D.1109 CASE-BY-CASE MACT—This stipulation 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 of each boiler and a tune-up of each boiler each calendar year. Records of inspections and tune-ups are required. Semi-annual reporting is required,starting January 30,2014. APPEARS INCOMPLIANCE—Inspection of PS-A was conducted on 10/01/14,and of PS-B on 03/18/14. Boiler tune-ups were conducted on 09/27/14 for PS-1 and on 03/27/14 for PS-B. The semi-annual report was received on 01/20/15. Chemours Company—Fayetteville Works Compliance Inspection Report Page 7 of 15 *Butacite®Process Area(all sources labeled with BS-and BCDA* The Butacite®manufacturing operation includes: (1)the butyraldehyde storage tank,with emissions and potential odors from the butyraldehyde controlled by a brine-cooled(ethylene glycol)condenser. (2)eight(8)Butacite®flake reactors, controlled by packed-bed column scrubbers, and(3)a Butacite®flake dryer,controlled by a cyclone separator and fabric filter. The operation also contains two Butacite®Sheeting Extrusion Processes,two Back-End Processes,a Polyvinyl Alcohol(PVA)Unloading System including Storage Silos,and A PVA dissolver tank. The operation produces flexible glass laminate for use in car windshields. Portions of the Butacite area are subject to the NESHAP MON requirements. 15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES— Particulate matter emissions from the Butacite®process shall not exceed E=4.10*P067. The Permittee shall maintain production records. The Permittee shall perform a monthly visual inspection on cyclone BCD-CI and bagfilter BCD-C2 and an annual internal inspection on bagfilter BCD-C2. A logbook detailing these inspections must also be kept up to date. A semi-annual summary report is required. NO LONGER APPLICABLE—THESEASSETS WERE SOLD TO KURARAY(FACILITYID 0900091)IN 2014. 15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the flake dryer BS-C shall not exceed 20%opacity. The Permittee shall record a monthly visible emissions evaluation(normal or above normal)and maintain a logbook showing the results of each evaluation. A summary semi-annual report is required. NO LONGER APPLICABLE—THESE ASSETS WERE SOLD TO KURARAY(FACILITYID 0900091)IN 2014. 15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS(State-Enforceable Only)—The Butacite®process shall not operate without odor control equipment(Condenser BCD-A, Scrubber BCD-B 1,and Scrubber BCD-B2.) An objectionable odor shall not be detected from these sources. Liquid flow rate for BCD-B 1 and BCD-B2 shall be at least 8 gallons per minute and the differential pressure shall be a maximum of 30 inches of water pressure averaged over a three-hour period. The Permittee shall perform periodic inspections and maintenance of BCD-A,BCD-B 1,and BCD-B2 as recommended by the manufacturer. As a minimum,the inspection and maintenance program shall include inspection of spray nozzles,packing material,chemical feed system(if so equipped),and the cleaning/calibration of all associated instrumentation. NO LONGER APPLICABLE— THESE ASSETS WERE SOLD TO KURARAY(FACILITYID 0900091)IN 2014. 40 CFR Part 60 Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing(MON). For each affected MPCU with a Group 2 Process Vent,the Permittee shall retain a record of the day each batch was completed, a record of whether each batch operated was considered a standard batch,the estimated uncontrolled and controlled emissions for each batch that is considered to be a non-standard batch, and records of the daily 365-day rolling summations of emissions,or alternative records that correlate to the emissions. The Permittee shall also retain the following records: MPCU identification and description,stream identification code,concentration of compounds,and stream flow rate(in L/min). NO LONGER APPLICABLE—THESE ASSETS WERE SOLD TO KURARAY(FACILITYID 0900091)IN 2014. Chemours Company—Fayetteville Works Compliance Inspection Report Page 8 of 15 *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=4.109 "'. The Permittee shall maintain production records. A semi-annual summary report is required. APPEARS IN COMPLIANCE—Production records are available at each manufacturing facility. The last semi-annual summary report was received at FRO on 01/20/15. 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 required. APPEARS IN COMPLIANCE—During the inspection,I observed 0%VE. 15A NCAC 2D.1806 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-HdrI 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 no odor complaints have been received. 15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS—VOC emissions from the Vinyl Ethers North process,NS-E,shall not exceed 68.9 TPY VOC. The Permittee shall keep monthly records of VOC emissions. Semi-annual reporting 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 2014 were 41.92 tons. The last semi-annual report was received at FRO on 01/20/15. 15A NCAC 2Q.0317PREVENTION 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. Semi-annual summary report is required. APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2014 were 17.52 tons. The last semi-annual summary report was received at FRO on 01/20/15. 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 IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2014 were 48.70 tons. The last semi-annual summary report was received at FRO on 01/20/15. Chemours Company—Fayetteville Works Compliance Inspection Report Page 9 of 15 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 from each container. Semi-annual summary reporting is required. APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2014 were 8.29 tons. The last semi-annual report was received at FRO on 01/20/15. 40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The Nafion®process must comply with all provisions of this MACT. 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 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. Semi-annual summary reporting is required. APPEARS INCOMPLIANCE—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 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 2014. The last semi-annual summary report was received at FRO on 01/20/15. 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 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 is currently 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. Chemours Company—Fayetteville Works Compliance Inspection Report Page 10 of 15 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 IN COMPLIANCE—The APFO process is controlled by scrubbers. No odors were noticeable during the inspection. 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. 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 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 38.02 gpm,and the pressure drop across the scrubber bed was 0.12"H2O. The last internal inspection of the scrubber was performed in September 2014. Inspections are on a two-year interval. *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. 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. 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. APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBm and for No. 2 fuel oil is 0.0241bs/mmBTU. This boiler was not on site during this inspection. Chemours Company—Fayetteville Works Compliance Inspection Report Page 11 of 15 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. 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 0.002 lb/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. APPEARS IN COMPLIANCE—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 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 2014. The latest semi-annual report was received on 01/20/15. 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 INCOMPLL4NCE—The boiler was note onsite during 2014. *SentrvGlaO Process(SGS-A)* The SentryGlas®plant began operation in 2005 and manufactures rigid plastic glass laminate. This product is similar to the Butacite®product;however,this material is much stronger,even explosion proof. The facility has a crushing system used to crush the pelletized raw material. Crushed material is sent to a silo,which is controlled by a baghouse that vents indoors. The entire process takes place in a clean room to avoid contamination by lint, dirt, etc. 15A NCAC 213.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the SentryGlaso manufacturing facility shall not exceed 20%opacity. No monitoring,recordkeeping,or reporting required. NO LONGER APPLICABLE—THESE ASSETS WERE SOLD TO XURARAY(FACILITYID 0900091)IN 2014. 15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable Only)—The SentryGlaso manufacturing facility shall not operate without implementing a management plan or without odor control equipment. NO LONGER APPLICABLE— THESE ASSETS WERE SOLD TO%URARAY(FA CILITYID 0900091)IN 2014. Chemours Company—Fayetteville Works Compliance Inspection Report Page 12 of 15 *Polyvinyl Fluoride(PVF)Polymer Manufacturing Facilities(FS-B&FS-C)* The facility#1(FS-B)started operation in latter portion of September 2007. The facility#2 began operation in June 2010. Vinyl fluoride reacts in a continuous reactor to form crude polyvinyl fluoride(PVF). The PVF is separated,sent through a batch filter press,then through a tubular drier. The final product is PVF solid powder. The PVF produced at this facility is used for photovoltaic panels and aircraft interiors. There are no emission controls on these two processes. 15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES— Particulate emissions from the PVF facility shall not exceed 4.1 *PO 67. The Permittee shall maintain production records of the process rates in tons per hour. Semi-annual summary reporting is required. APPEARS IN COMPLIANCE—The process control system records process rates. During the inspection,both plants were operating. The last semi-annual summary report was received at FRO on 01/20/15. 15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the PVF facility shall not exceed 20%opacity. Once each month,the Permittee shall observe the emission points for any visible emissions above normal. A semi-annual summary report is required. APPEARS INCOMPLLANCE—The baghouse exhaust point is paired with an exhaust from the steam tank. The emissions are observed daily and logged on the operator log. A formal VE observation is made each month. The last monthly documented VE observation was performed on 03/09/15 for FS-B and on 03/02/15 for FS-C. The last semi-annual summary report was received at FRO on 01/20/15. 15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable Only)—The PVF 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. APPEARS IN COMPLIANCE—During the inspection,I did not detect any objectionable odors. 15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS—Emissions from the two PVF facilities(FS-B&FS-C)shall not exceed 40 TPY VOC. The Permittee shall keep monthly records of VOC emissions calculated by methods in permit. Semi-annual reporting is also required for monthly emissions(17 month period). APPEARS INCOMPLIANCE—The highest 12-month VOC emissions for the facility during 2014 was 28.40 tons VOC. The latest semi-annual report was received on 01/20/15. *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 the following: 702.5 tons of SO2 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. Semi-annual reporting is required. APPEARS IN COMPLIANCE—The highest 12-month rolling total S02 emissions during 2014 from the 4 boilers was 0.0 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- annual report was received on 01/20/15. Chemours Company—Fayetteville Works Compliance Inspection Report Page 13 of 15 *Facility-Wide 15A NCAC 2D.I100 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 APPEARS IN COMPLIANCE—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 .1100 limits. The last quarterly report was received at FRO on 01/20/15. 15A NCAC 2D.I 100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The Permittee shall emit less than the limits listed in the permit for BF 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-1 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. APPEARS IN COMPLL4NCE—The liquid flow rates during the inspection were 18,309 kg/hr for Hdr-1 and 12,600 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-I 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 01/20/15. 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 COMPLIANCE—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. Chemours Company—Fayetteville Works Compliance Inspection Report Page 14 of 15 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 COMPLLANCE- 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) Standard. The latest update of the RMP was submitted by the facility to EPA on 08/18/14. A full 112(r) compliance inspection was conducted by Greg Reeves and Mike Reid on 01/23/12. The facility was deemed to be in apparent compliance during that inspection. The facility was being inspected for compliance with the I I2(r)program on 03/10/15 by Mike Reid of RCO and Mike Thomas of FRO, separate from this facility air permit compliance inspection. The facility has the following processes subject to 112(r): z s� z P�pramvel � CQer�ed t��L 3 " ens 3 TFE Process 1 TFE(Tetrafluoroethylene) 22,000 PVF Process 1 Vinyl Fluoride 130,000 Nation®Process 3 Sulfur Trioxide 33,000 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. APPEARS IN COMPLLANCE—The 2013 compliance certification was received at FRO on 01/23/15. Chemours Company—Fayetteville Works Compliance Inspection Report Page 15 of 15 7. COMPLIANCE HISTORY: 02/17/14 Greg Reeves inspected the facility and found the facility to be in apparent compliance. 06/20/13 Greg Reeves inspected the facility and found the facility to be in apparent compliance. 01/23/12 A full 112(r)compliance inspection was conducted by Greg Reeves and Mike Reid. The facility was deemed to be in apparent compliance during this inspection. 08/09/06 The facility was inspected 7 times during the period 2006 through 2010 by Christy Richardson,Robert through Kennedy,Tien Nguyen,Maureen Matroni-Rakes, and Greg Reeves. The facility appeared to be in 05/19/11 compliance during each of these inspections. 01/06/09 The facility was issued a NOV/NRE for operating three sources(container decontamination processes) without an air permit. The facility was fined and submitted their enforcement payment and an air permit application to include these sources on the permit. 11/2007 The facility was issued a Notice of Violation(NOV)for failure to submit the Title V operating permit application(Part 2)in a timely manner. 08/2007 The facility was issued a Compliance Additional Information(CAI)letter in concerning the permit applicability of a paint operation and shot blast operation as well as abnormal visible emissions from the boilers noted during two recent site visits. 8. CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 02/17/14 inspection, Chemours Company—Fayetteville Works APPEARS IN COMPLIANCE with the requirements outlined in their current air permit,03735T39. PINK SHEET: N/A GWR cc: FRO Facility Files