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Home My WebLink AboutAQ_F_0900009_20200204_CMPL_CompRpt y f Ch� TM The Chemours Company 910-483-4681 mOu rs Fluoroproducts chemours.com 22828 NC Highway 87 W RECEIVED Fayetteville,NC 28306-7332 FEB - 3 2020 DEQ-FAYEITEVILLE REGIONAL OFFICE CERTIFIED MAIL ARTICLE NUMBER 7013 1710 0001 0250 9357 RETURN RECEIPT REQUESTED January 30, 2020 Heather Carter NCDEQ—Division of Air Quality 225 Green Street— Suite 714 Fayetteville,NC 28301 SUBJECT: Chemours Company—Fayetteville Works Title V Permit Quarterly Summary Report — 4th Quarter 2019 Air Permit No. 03 73 5T47 Facility ID No. 0900009 Ms. Carter, Attached is the quarterly summary report for the period from October 1, 2019 to December 30, 2019 for the Chemours Fayetteville Works submitted pursuant to Air Quality Permit No. 03735T47. Enclosed you will find the required photocopy of this report. If you have any questions, please feel free to contact me at (910) 678-1213. Sincerely, i Christel Compton Program Manager 4 tta�hment U.S. POSTAGE PAID FCM LG ENV FAYETTEVILLE, NC 283018301 7013 1�10 0001 lJITE75TVIC O AMJAN U9f 0 0 2 5 0 9 3 5 7 POSTAL SERVICE 2 1 020 $7.60 28301 R2304M113739-9 Chemours Company—Fayetteville Works Quarterly Report (per 2.2.D.1)—41h Quarter 2019 Air Permit No. 03735T47 Page 1 of 4 Quarterly Report (per Air Quality Permit No. 03735T47, Condition Section 2.2 D.1) Air Quality Permit No. 03735T47, Condition 2.2.D.1. 15A NCAC 02Q .0519(a)(7) and Consent Order" Pursuant to Section 2.2 D.1.m of the subject Title V permit, the permittee shall submit a quarterly summary report that includes monitoring and recordkeeping activities specified in Section 2.2 D.1. The summary report shall include the information recorded as required in Section 2.2 D.1.k and 1. For clarity, this report has been broken down into subsections for each inspection and recordkeeping requirement contained in Sections 2.2 D.1.k. and 2.2 D.I.I. Section 2.2 D.l.m.i The summary report shall include the information recorded as required in Section 2.2 D.Lk and 1. Section 2.2 D.Lk.i: Records of all production data and hours of operation collected during performance tests Chemours has submitted production data with the emissions reports for each performance test. Additional production data and hours of operation are maintained on site and submitted to DAQ every two weeks. Section 2.2 D.Lk.ii: Records of the calculations, and all supporting documentation, of annual GenX Compound emissions to demonstrate compliance with the emissions limitations specified in Section 2.2 D.1.a. Startup of the Thermal Oxidizer system (when waste gas feeds were first introduced) began on 27 December 2019. The Thermal Oxidizer system achieved `normal operation' on 31 December 2019. GenX Compound emissions reports meeting the requirements in Section 2.2.D.La., will be submitted to the agency as required in the 1st quarter report for 2020, which is due 30 April 2020. Section 2.2 D.I.k.iii: If the emission source is not operating, a record of this fact, along with the corresponding date and time. Records indicating periods when the emission sources were not operating are being maintained and available upon request. A summary list of dates the emission sources were not operating is as follows: VE North - 41 days (10/1 — 10/31, 11/1 — 11/4, 11/11, 11/14— 11/17, 11/28) PPA - 41 days (1015, 10/9, 10/11 — 10/26, 11/2, 11/9, 11/13 — 11/27, 11/3 0, 12/14, 12/25 — 12/28) Chemours Company—Fayetteville Works Quarterly Report (per 2.2.D.1)—4th Quarter 2019 Air Permit No. 03735T47 Page 2 of 4 Section 2.2 D.l.k.iv: Records of all inspections and maintenance conducted for the Carbon Adsorbers (ID Nos.ACD A2 and NCD-Q3) as specified in Section 2.2 D.1.d1 The Carbon Adsorber manufacturer does not provide any recommendations on a routine maintenance schedule, however, Chemours has developed a preventive maintenance plan for the Carbon Adsorbers. The following is a summary of Carbon Adsorber inspections and maintenance conducted this quarter: VE North Carbon Unit Date Completed Inspections Visual exterior/interior October 2019 TAR Maintenance Carbon replaced October 2019 TAR Replaced internal screen October 2019 TAR Replaced blower 11/17/19 Repairs n/a n/a PPA Carbon Unit Date Completed Inspections Visual exterior/interior 10/17/19 Maintenance Carbon replaced 10/17/19 Repairs n/a n/a Section 2.2 D.1.k.v: Records of all instances of process shutdowns, including those triggered by the pressure differential alarms associated with the carbon adsorber systems. As stated above, the processes were shut down on the following dates: VE North- 41 days (10/1 — 10/31, 11/1 — 11/4, 11/11, 11/14— 11/17, 11/28) Carbon changed: October 2019 PPA- 41 days (1015, 10/9, 10/11 — 10/26, 11/2, 11/9, 11/13 — 11/27, 11/3 0, 12/14, 12/25 — 12/28) Carbon changed: 10/17/19 During this quarter, there were no instances which occurred where a process shutdown was triggered by the pressure differential alarms associated with the carbon adsorber systems. Detailed process operating times are maintained onsite and available upon request. Note: PPA normal area operations are shutdown routinely every Friday evening and restarted Sunday evening. The only exceptions are if there is an increased demand for product. Section 2.2 D.L k.vi: Records of all inspections and calibration of monitoring equipment as required in Section 2.2 D.l f and D.1.h. (2.2 D.1.f.)—The continuous monitoring systems (aka: DCS) installed on the carbon adsorbers in VE North and PPA do not require calibration on any frequency. There is monthly preventive maintenance performed on the DCS system. The instrumentation connected to the DCS i (communicating with DCS) are calibrated based on their own preventive maintenance requirements. There are certain points in the DCS system, specific to alarms and interlocks, that IF Chemours Company—Fayetteville Works Quarterly Report (per 2.2.D.1)—41h Quarter 2019 Air Permit No. 03735T47 Page 3 of 4 are tested annually during the yearly site wide turn around (TAR) which is usually conducted during the 4th quarter. For 2019, the alarm and interlock tests were performed in the month of October, at which time, the DCS functionality and capability was verified against the calibrated field instruments associated with the carbon adsorbers. Inspection and calibration records for all equipment associated with the DCS system are maintained onsite and available upon request. The procedures and schedule for maintenance and servicing of the DCS system is maintained onsite and available upon request. (2.2 D.Lh.) - TEAM Industrial Services (Wilmington, NC office) is contracted to satisfy the monitoring requirements for fugitive emissions from processing equipment. Calibration records for the monitoring equipment (TVA) are also maintained onsite and available for review upon request. Section 2.2 D.1.l.i: A copy of each test report and compliance report submitted to NC DAQ to comply with Section 2.2 D.1, including all documentation supporting any compliance report. Chemours continues to submit to NC DAQ a copy of each emissions test report, including supporting documentation. Section 2.2 D.I.l.ii: The most recent copy of the approved Carbon Adsorber shutdown and malfunction plan required in Section 2.2 D.l.g. Records of instances where the differential pressure monitors required in Section 2.2 D.lf have resulted in process shutdowns. The most recent copy of the Carbon Adsorber shutdown and malfunction plan was submitted on 4/15/19. Carbon Adsorber operational procedures are maintained onsite and available for review upon request. During this quarter, there were no instances which occurred where a process shutdown was triggered by the pressure differential alarms associated with the Carbon Adsorber systems. Detailed process operating times are maintained onsite and available upon request. Section 2.2 D.I.l.iii: The most recent copy of the approved Enhanced Leak Detection and Repair Program required in Section 2.2 D.1.h. The most recent copy of the Enhanced Leak Detection and Repair(LDAR)program was submitted on 8/14/19 (to Greg Reeves). Section 2.2 D.I.I.iii.A: Pressure testing records, including, but not limited to, the date of inspection, results of the inspection/pressure testing, repairs made to any equipment found to be leaking during pressure testing, and follow-up pressure testing to verify successful repair. Pressure testing was completed as required and records are maintained in the Environmental Emissions Reduction Facilitator office and are available for review upon request. During this quarter, there were no instances of equipment found to be leaking during pressure testing and no repairs made to any equipment. Section 2.2 D.1.l.iii.B: AVO inspection records, including the completed checklist specified in Section 2.2 D.1.h.ii.0 and inspection results including any leaks found and repair actions taken. Chemours Company—Fayetteville Works Quarterly Report (per 2.2.D.1)—4th Quarter 2019 Air Permit No. 03735T47 Page 4 of 4 AVO inspections were completed as required and the records are maintained in the Environmental Emissions Reduction Facilitator's office and are available for review upon request. During this quarter, the AVO inspections did not find evidence of any leaks. Section 2.2 D.1.l.M.C. Method 21 and enhanced area monitoring results. Method 21 monitoring is conducted by TEAM Industrial Services for the Enhanced LDAR program. All monitoring reports and records of leaks found, repairs made, and re-monitoring results are maintained onsite and are available upon request. The Enhanced Emissions Monitoring Spreadsheet is a supplemental record used to review and track any readings below the `leaker' definition and is maintained by the Environmental Emissions Reduction Facilitator and available for review upon request. During this quarter, Method 21 and enhanced area monitoring results identified no components exceeding the lower leak definition. Section 2.2 D.1.l.iii.D: Replacement program for valves and connectors logs of leakers and repair attempts. The replacement program for components identified as `leakers' is detailed in the Enhanced LDAR Procedure. Reports with the monitoring results and any leakers detected, along with the details on repairs and re-monitoring results, are available upon request. Applicable Enhanced LDAR monitoring was completed as required. During this quarter, the following is a summary of the components recorded as exceeding the lower leak definition as defined by the permit: October 2019 - no components exceeding the lower leak definition. November 2019—no components exceeding the lower leak definition. December 2019—no components exceeding the lower leak definition. Section 2.2 D.Lm.ii The Permittee shall include in the summary report any excess emissions that have occurred �� during the reporting period. Excess emissions are defined as any calculated annual rolling average GenX Compound emissions rate, calculated as required in Section 2.2 D.La, above, that exceeds the emission limit in Section 2.2 D.I.a. Startup of the Thermal Oxidizer system(when waste gas feeds were first introduced) began on 27 December 2019. The Thermal Oxidizer system achieved `normal operation' on 31 December 2019. GenX Compound emissions reports meeting the requirements in Section 2.2.D.La., will be submitted to the agency as required in the 1 st quarter report for year 2020, which is due 30 April 2020.