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AQ_F_0900009_20211003_CMPL_CompRpt '� p9opa0q t01Z41Z'0L1 (,, The Chemours Company Chemours" Fayetteville Works 22828 NC Highway 87 W Fayetteville,NC 28306 RECEIVEL OCT 18 2021 DEQ-FAYETTEVIL LE REGION-JAL OF'Y. CERTIFIED MAIL ARTICLE NUMBER 7017 1450 0002 3902 3662 RETURN RECEIPT REQUESTED October 15, 2021 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 for Thermal Oxidizer—3Q 2021 Air Permit No. 03735T48 Facility ID No. 0900009 Ms. Carter, Attached is the quarterly summary report for the period from July 1, 2021 to September 30, 2021 for the Chemours Fayetteville Works Thermal Oxidizer per Section 2.1 B.1 l.n pursuant to Air Quality Permit No. 03735T48. Enclosed you will find the required photocopies of this report. If you have any questions,please feel free to contact me at(910) 678-1213. Sincerely, Christel Compton Program Manager Attachment Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3 d Quarter 2021 Air Permit No. 03 73 5T48 Page 1 of 8 Thermal Oxidizer and 4-Stage Scrubber System Quarterly Report (per Air Quality Permit No. 03735T48, Condition 2.1 Air Quality Permit No. 03735T48, Condition 2.1 B.11: "15A NCAC 02Q .0519(a)(7) and Consent Order" Pursuant to Section 2.1 B.11.n. of the subject Title V permit, the permittee shall submit a quarterly summary report that includes monitoring and recordkeeping activities specified in Section 2.1 B.II.f. through B.11.n. The summary report shall include the information recorded as required in Section 2.1 B.11 f. through B.11.n. For clarity, this report has been broken down into subsections for each monitoring and recordkeeping requirement contained in Sections 2.1 B.II.f. through 2.1 B.11.n. Section 2.1 B.11.f. Emissions of all PFAS, including GenX compounds,from the following emissions sources (ID Nos. NSA,NS-B,NS-C,NS D-1,NS-E,NS-F,NS-G-1,NS-K,NS-M,NS-N,NS-O, and NS-P) shall be controlled by a Thermal Oxidizer and 4-Stage Scrubber System (ID Nos. NCD-QI and NCD-Q2). The Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's recommendations, the inspection and maintenance requirement shall include: Section 2.1 B.11.f.is Hourly visual or positive detection by flame scanner checks of the Thermal Oxidizer flame and burner while in operation and annual inspections of the burner assemblies, blowers,fans, dampers, refractory lining, oxidizer shell,fuel lines, and ductwork. The DCS/CMS provides continuous monitoring of the flame and burner by using two separate infrared flame scanners. The data historian application(IP21) collects real-time process data from the DCS to provide control and supervision of the process. The flame can also be detected visually by a view port. The following table includes a summary of periods when the flame was not detected within the Thermal Oxidizer combustion chamber: Summary of Periods When a Flame Was Not Detected Date Duration Reason 7/11/21 6 minutes Combustion chamber high pressure caused the flame out. 7/31/21 13 minutes Natural Gas flow transmitter displayed negative readings and stopped flows. 8/1/21 11 minutes Induced Draft Fan faulted/tripped off. Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3r1 Quarter 2021 Air Permit No. 03735T48 Page 2 of 8 8/12/21 85 minutes Moisture in wiring caused automatic valve malfunction. 8/19/21 36 minutes Instrument air pressure low causing combustion controls to interlock off. 8/20/21 2 minutes Maintenance work inadvertently affected flame. 9/3/21 106 minutes Scheduled maintenance to replace transmitter. 9/7/21 9 minutes Induced Draft Fan breaker tripped due to overheating from ambient high temperature inside ECR. Total flameout duration for the quarter= 4.47 hours Scheduled Thermal Oxidizer Shutdowns During This Quarter Date Duration Reason 9/3/21 106 minutes Scheduled maintenance to replace transmitter. The Thermal Oxidizer is capable of a hot restart if the combustion chamber is within a temperature range. This was the case in all the above instances, with the exception of 09/03/21 maintenance. At no time were the processes allowed to vent to the atmosphere without being controlled by the Thermal Oxidizer and 4-Stage Scrubber System and includes the time during the above conditions. All flows were held in the accumulator tanks until the flame could be reestablished and target temperature achieved. Annual inspections of the burner assemblies, blowers, fans, dampers, refractory lining, oxidizer shell, fuel lines, and ductwork were completed in October 2020 during the annual TAR shutdown. Inspection and maintenance records are maintained onsite and are available upon request. Section 2.1 B.11 f ii: Annual inspection of scrubber spray nozzles to detect clogging or corrosion damage of nozzles and perform maintenance and repair when necessary to ensure proper operation of the scrubber. Annual inspection of the scrubber spray nozzles was completed in October 2020 during the annual TAR shutdown. There were no issues noted during the inspection of the scrubber spray nozzles. During this quarter, there were no issues noted with the scrubber spray nozzles. Inspection and maintenance records are maintained onsite and are available upon request. Section 2.1 B.11 f.iii: Annual inspection of scrubber packing material to ensure proper packing depth and to check for clogging. The annual inspection of the scrubber packing material was completed during the annual shutdown in October 2020. There were no issues noted during the inspection of the scrubber packing Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021 Air Permit No. 03 73 5T48 Page 3 of 8 material. During this quarter, there were no issues noted with the scrubber packing material. Inspection and maintenance records are maintained onsite and are available upon request. Section 2.1 B.11.fiv: Annual inspection, cleaning, and calibration of all associated instrumentation. Annual inspections, cleaning, and calibration of associated instrumentation was completed in October 2020 during the annual TAR shutdown. Inspection and maintenance records are maintained onsite and are available upon request. Section 2.1 B.11 f v: In addition to annual inspections, the Permittee shall also conduct the inspections required in paragraphs i. thru iv., above, whenever the Thermal Oxidizer and 4- Stage Scrubber System are nonoperational for a minimum of 72 hours. System Total Nonoperational Reason/Cause Hours during this Quarter Thermal Oxidizer 4.47 hours Refer to summary table of periods when a flame was not detected. Section 2.1 B.11.f.i 4-Stage Scrubber 0 N/A The Thermal Oxidizer and 4-Stage Scrubber System were not nonoperational for more than 72 consecutive hours during this quarter. Section 2.1 B.11. The Permittee shall develop, and submit to NC DAQ for approval, a site-specific monitoring plan that addresses design, data collection, and quality assurance/quality control elements for operating each CMS installed according to Section 2.1 B.11.h. and B.11 . The monitoring plan shall address the following: Section 2.1 B.11-g.is Initial and any subsequent calibration of the CMS. Section 2.1 B.11.g.ii: Determination and adjustment of the calibration drift of the CMS. Section 2.1 B.11.g.iii: Preventive maintenance of the CMS, including spare parts inventory. Section 2.1 B.Il.g.iv: Data recording, calculations, and reporting. Section 2.1 B.11.g.v: Accuracy audit procedures, including sampling and analysis methods. Section 2.1 B.11.g.vi: Program of corrective action for a malfunctioning CMS. Section 2.1 B.11.g.vii: Ongoing operation and maintenance procedures. Section 2.1 B.11.g.viii: Ongoing data quality assurance procedures. Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3r1 Quarter 2021 Air Permit No. 03735T48 Page 4 of 8 A detailed site-specific monitoring plan for the Thermal Oxidizer and 4-Stage Scrubber System was submitted to NC DAQ on November 27, 2019. It provides details on calibration, preventive maintenance, spare parts, data recording and calculations, accuracy, corrective action for malfunctioning CMS, ongoing operation and maintenance, and data quality assurance procedures. A copy of the site-specific monitoring plan is maintained onsite and available upon request. Section 2.1 B.11.h The Permittee shall install, calibrate, maintain, and operate a CMS for the Thermal Oxidizer. The CMS shall include a continuous recorder capable of taking measurement at least once every 15 minutes. The Permittee shall operate the CMS according to the approved site-specific monitoring plan specified in Section 2.1 B.Il.g., above, to ensure the following operational parameters are maintained. The Site has a DCS, capable of taking readings at least every 15 minutes. The DCS system is maintained and operated according to the approved site-specific monitoring plan. Section 2.1 B.11.h.is A minimum combustion chamber temperature of 1800 degrees Fahrenheit (3-hour rolling average). For this quarter, the lowest 3-hour rolling average combustion chamber temperature (while the Thermal Oxidizer was in operation)was 1,992 degrees Fahrenheit(OF). During this quarter,while the emissions sources were in operation, there were no instances where the 3-hour rolling average combustion chamber temperature dropped below the minimum 1,800 OF. Section 2.1 B.11.h.ii: A maximum Thermal Oxidizer inlet gas feed rate of 2,200 pounds per hour (3-hours rolling average). For this quarter, the maximum 3-hour rolling average inlet gas feed rate (combined total) was 1,0491bs/hour. Section 2.1 B.11.h.iii: Failure to operate the temperature monitor or inlet feed gas monitoring device identified, above, for at least 97 percent of the total operational time per quarterly reporting period shall constitute noncompliance with the emission limits in Section 2.1 B.Ha. The DCS was operational 100% of the time during the quarter when the Thermal Oxidizer was operational. The DCS communicated and recorded the combustion chamber temperature and inlet feed gas flow rate data for 100% of the operational time. Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021 Air Permit No. 03735T48 Page 5 of 8 Section 2.1 B.11.i The Permittee shall install, calibrate, maintain, and operate the CMS for the 4-Stage Scrubber System. The CMS shall include a continuous recorder capable of taking a measurement at least once every 15 minutes. The Permittee shall operate the CMS according to the approved site- specific monitoring plan specified in Section 2.1 B.11.g., to ensure the following operational parameters are maintained. The Site has a DCS, capable of taking readings at least every 15 minutes. The CMS was operated according to the approved site-specific monitoring plan during the quarter. A copy of the site- specific monitoring plan is maintained onsite and available upon request. Section 2.1 B.H.i.is The scrubber liquor flow shall be a minimum of 40 gallons per minute for the fourth caustic scrubber stage. During this quarter, at no time were there instances when the scrubber liquor flow rate for the 4th Stage dropped below 40 GPM while the emission sources were in operation. The lowest flow rate recorded during this quarter was 75 GPM. Records of scrubber liquor flow rate are maintained onsite and available upon request. Section 2.1 B.H.i.ii: A minimum scrubber liquor pH, no less than 7.1 (3-hour rolling average) for the fourth scrubber stage. For this quarter,the lowest 3-hour rolling average scrubber liquor pH(during the time the scrubber was in operation)was 7.39. Records of the scrubber liquor pH are maintained onsite and available upon request. Section 2.1 B.H.i.iii: Failure to operate the scrubber liquor flow meter or pH meter, identified in i. and ii.,for at least 97 percent of the total operational time per quarterly reporting period shall constitute noncompliance with the emission limits in Section 2.1 B.H.a. The DCS was operational 100% of the time during the quarter when the system was operational, as were the scrubber liquor flow and pH meters. The DCS communicated and recorded the scrubber liquor flow rate and the pH reading for 100% of the operational time, while the emission sources were in operation. Section 2.1 B.H.J. Except as specified in Section 2.1 B.H.k., the Permittee shall operate the Thermal Oxidizer and 4-Stage Scrubber System at all times when the emission sources (ID Nos. NSA, NS-B, NS-C, NS-D-1,NS-E, NS-F,NS-G-1,NS-K,NS-M, NS-N,NS-O, and NS-P) are operating. Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021 Air Permit No. 03735T48 Page 6 of 8 During this quarter, the Thermal Oxidizer and 4-Stage Scrubber System was in operation at all times when the emissions sources were in operation. Records are maintained onsite and available upon request. Section 2.1 B.H.k. Prior to operation of the Thermal Oxidizer and 4-Stage Scrubber System, the Permittee shall develop, and submit to NCDAQ for approval, a detailed shutdown and malfunction plan for the Thermal Oxidizer and 4-stage Scrubber System that contains specific procedures for initiating the shutdown of process emission sources during periods of control device shutdown and malfunction, and a program of corrective action for malfunctioning processes, and control systems used to comply with the limits in Section 2.1 B.II.a. The Permittee shall keep a copy of the approved plan onsite. A Shutdown and Malfunction Plan for the Thermal Oxidizer and 4-Stage Scrubber System was submitted to NC DAQ on December 18, 2019,which included a Proactive Maintenance Plan. The maintenance plan includes predictive maintenance, preventive maintenance, functional checks, corrective maintenance, and annual inspections to ensure the reliability of the Thermal Oxidizer and 4-Stage Scrubber System. A copy of the Shutdown and Malfunction Plan is maintained onsite and available upon request. Section 2.1 B.Il.k.i: To ensure that the control devices are well maintained to minimize malfunctions, the plan shall include a maintenance schedule for the Thermal Oxidizer and 4- Stage Scrubber System that is consistent with, but not limited to the manufacturer's instructions and recommendations for routine and long-term maintenance, as specified in Section 2.1 B.11.h. and B.Il.i. A Shutdown and Malfunction Plan was submitted to NC DAQ on December 18,2019 that includes a Proactive Maintenance Plan,which is the maintenance schedule for the Thermal Oxidizer and 4- Stage Scrubber System. The Proactive Maintenance Plan includes predictive maintenance, preventive maintenance, functional checks, corrective maintenance, and annual inspections to ensure the reliability of the Thermal Oxidizer and 4-Stage Scrubber system. A copy of the Shutdown and Malfunction Plan is maintained onsite and available upon request. Section 2.1 B.11.k.ii: An inspection schedule for each CMS installed on the Thermal Oxidizer and 4-Stage Scrubber System to ensure, at least once in each 24-hour period, that each CMS is properly functioning. The CMS is comprised of a DCS and IP21 and have various systems backup and other redundancies built into it to ensure, at least once in each 24-hour period,the proper functioning of the system. The IP21 application has a series of queries that monitor aspects of the application and data provided by the DCS and will send email alerts to the various support teams to investigate Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)—3rd Quarter 2021 Air Permit No. 03735T48 Page 7 of 8 and correct any potential malfunctions. The inspection schedule for the DCS is specified in the Shutdown and Malfunction Plan and is maintained onsite and available upon request. Section 2.1 B.Il.k.iii: At no time shall the emissions from the emissions sources (ID Nos. NS- A, NS-B, NS-C, NS-D-1, NS-E, NS-F, NS-G-1, NS-K, NS-M, NS-N, NS-O, and NS-P) be allowed to vent to the atmosphere without being controlled in the Thermal Oxidizer and 4-Stage Scrubber System. During the reporting quarter, the emissions from the emission sources did not vent to the atmosphere without being controlled by the Thermal Oxidizer and 4-Stage Scrubber System. Section 2.1 B.11.1. The Permittee shall record the following information monthly in a logbook (written or electronic) that shall be maintained onsite and made available to NC DAQ upon request. Section 2.1 B.11.l.i.: Records of the continuous and 3-hour rolling average operating parameters specified in Section 2.1 B.11.h. and B.11.i.,for the Thermal Oxidizer and 4-Stage Scrubber System. The IP21 data historian application has the capability to store 5 years of process data that includes 3-hour rolling averages. Process data records are maintained onsite and available upon request. Section 2.1 B.11.l.ii.: If the emission sources are not operating, a record of this fact along with the corresponding date and time. Process operating times for the emissions sources are submitted to NC DAQ every 2 weeks. Detailed records are maintained onsite and available upon request. Section 2.1 B.11.l.iii.: Records of all inspections and maintenance conducted for the Thermal Oxidizer and 4-Stage Scrubber System, as specified in Section 2.1 B.Ilf. Annual inspections and maintenance were completed in October 2020 during the annual TAR shutdown. Records of inspections and maintenance conducted are maintained onsite and available upon request. Section 2.1 B.H.l.iv.: Records associated with the site-specific monitoring plan specified in Section 2.1 B.11.g. Records associated with the site-specific monitoring plan are maintained onsite and available upon request. Chemours Company—Fayetteville Works Quarterly Report (per 2.1 B.11)— 3rd Quarter 2021 Air Permit No. 03735T48 Page 8 of 8 Section 2.1 B.H.m. The Permittee shall retain all results of performance testing conducted in accordance with Section 2.1 B.H.b. and B.H.c., including development of the operating parameters, as specified in Section 2.1 B.H.h. and B.H.L. and the calculation of the Thermal Oxidizer and 4-Stage Scrubber System control efficiency with respect to the control of all PFAS, including GenX compounds, and emissions from the emission sources (ID Nos. NSA, NS-B, NS-C, NS-D-1, NS-E, NS-F, NS-G-1,NS K, NS-M,NS-N,NS-O, and NS-P). Records of results from performance testing conducted on the Thermal Oxidizer and 4-Stage Scrubber System have been submitted to the State and copies are maintained onsite and available upon request. Chemours has submitted stack testing reports for each performance test, along with supporting documentation that includes operational parameters for the Thermal Oxidizer and 4-Stage Scrubber System and for the emissions sources during the testing periods. The most recent stack testing results report was submitted to NC DAQ on March 31, 2021 that demonstrated a control efficiency that exceeded 99.99%. Section 2.1 B.11.n. The Permittee shall submit a quarterly summary report of monitoring and recordkeeping activities specified in Section 2.1 B.11 f through B.11.n. All instances of deviations from the requirements of this permit must be clearly identified. During this quarter, there were no instances of deviations from the requirements of Section 2.1 B.l IS through 2.I.B.l l.n of the air permit. �