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Home My WebLink AboutAQ_F_0900009_20210104_CMPL_CompRpt 09/01 o Z10$�ao z z. ✓ j The Chemours Company Chemours Fayetteville Works 22828 NC Highway 87 W Fayetteville,NC 28306 RECEIVED JAN 2 8 20-22 DEO-FAYE17EVILLE RMONAL OFFICE CERTIFIED MAIL ARTICLE NUMBER 7017 1450 0002 3902 3891 RETURN RECEIPT REQUESTED January 26, 2022 Heather Carter NCDEQ—Division of Air Quality 225 Green Street—Suite 714 Fayetteville,NC 28301 SUBJECT: Chemours Company—Fayetteville Works Title V Air Permit No. 03735T48 Facility ID No. 0900009 Quarterly Summary Report—Carbon Adsorbers—4th Quarter 2021 Ms. Carter, Attached is the quarterly summary report for the period from October 1, 2021 to December 31, 2021 for the Chemours Fayetteville Works submitted 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, i CZ4,j4 Christel Compton Program Manager Attachment a Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021 Air Permit No. 03735T48 Page 1 of 6 Carbon Adsorbers and Enhanced LDAR Program Quarterly Report (per Air Quality Permit No. 03735T48, Condition Section 2.2 D.1) Air Quality Permit No. 03735T48, 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 monitoring and recordkeeping requirement contained in Sections 2.2 D.1.k. and 2.2 D.1.1. Section 2.2 D.l.m.i The summary report shall include the information recorded as required in Section 2.2 D.1.k and 1. Section 2.2 D.I.k.i: Records of all production data and hours of operation collected during performance tests Chemours submitted production data with the emissions reports for each performance test conducted. Additional production data and hours of operation are maintained onsite and are available upon request. Section 2.2 D.I.k.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.I.a. The initial annual emissions report per 2.2.1).Li was submitted in February 2021. Quarterly 99% reduction reports were submitted under separate cover. 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: Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1) —4th Quarter 2021 Air Permit No. 03735T48 Page 2 of 6 Area No. of days Specific dates Comments not operating VE North 27 days (10/8-10/31) (11/1-11/3) Annual TAR site-wide shutdown PPA 31 days (10/1-10/2, 10/7-10/23) (11/6, Annual TAR site-wide 11/13, 11/18-11/20, 11/27) (12/11- shutdown; Scheduled 12/13, 12/18, 12/24, 12/25) downtime VE South 27 days (10/6-10/29) (11/6, 11/9, 11/10) Annual TAR site-wide shutdown; Unscheduled downtime—feedstock Semiworks 74 days (10/1-10/24, 10/29-10/31) (11/1, Scheduled down and 11/5-11/10, 11/12-11/14, 11/19- deinventoried. 11/28) (12/3-12/6, 12/10-12/31) Section 2.2 D.Lk.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.d. 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. In addition, annual inspections of the structural integrity of the carbon adsorber systems and the duct work and piping leading to the carbon adsorbers are required. In accordance with a letter issued by DAQ to Chemours on November 2, 2021, carbon bed replacement schedules for PPA and VE South were approved and are as follows: • Replace the carbon in the PPA Carbon Adsorber when operating times reach 2,950—3,050 operating hours. • Replace the carbon in the VE-South Indoor Fugitives Carbon Adsorber annually (once every 12 months). The following is a summary of Carbon Adsorber inspections and maintenance conducted this quarter. Note: any carbon changeouts will automatically include internal and external inspections as part of the changeout. VE North Carbon Unit Date Completed Inspections Internal/External inspection 10/26/21 Maintenance Carbon chan eout 10/26/21 Calibrate pressure transmitter 10/20/21 Repairs None this quarter n/a Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021 Air Permit No. 03735T48 Page 3 of 6 PPA Carbon Unit Date Completed Inspections Internal/External 12/14/21 Maintenance Carbon changeout 12/14/21 Repairs None this quarter n/a VE South Carbon Unit Date Completed Inspections Internal/External 10/20/21 Maintenance Carbon chan eout 10/20/21 Replaced belts on blower 10/12/21 Calibrated pressure transmitters 10/15/21 Repairs None this quarter n/a Semiworks Carbon Unit Date Completed Inspections None this quarter n/a Maintenance None this quarter n/a Repairs None this quarter n/a Section 2.2 D.I.k.v: Records of all instances of process shutdowns, including those triggered by the pressure differential alarms associated with the carbon adsorber systems. Records of all instances of process shutdowns that occurred during this quarter are shown below: Area No. of days Specific dates Comments not operating VE North 27 days (10/8-10/31) (11/1-11/3) Annual TAR site-wide shutdown PPA 31 days (10/1-10/2, 10/7-10/23) (11/6, Annual TAR site-wide 11/13, 11/18-11/20, 11/27) (12/11- shutdown; Scheduled 12/13, 12/18, 12/24, 12/25) downtime VE South 27 days (10/6-10/29) (11/6, 11/9, 11/10) Annual TAR site-wide shutdown; Unscheduled downtime—feedstock Semiworks 74 days (10/1-10/24, 10/29-10/31) (11/1, Batch process-scheduled 11/5-11/10, 11/12-11/14, 11/19- down and deinventoried. 11/28) (12/3-12/6, 12/10-12/31) During this quarter, there were no instances where a process shutdown was triggered by the pressure differential alarms associated with any of the carbon adsorber systems. Detailed process operating times are maintained onsite and available upon request. Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.1)—4th Quarter 2021 Air Permit No. 03735T48 Page 4 of 6 Section 2.2 D.I.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.IS.)—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 outlined in the site-specific monitoring plan. 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. (2.2 D.l.h.) - TEAM Industrial Services (Wilmington, NC office) is contracted to satisfy the monitoring requirements for fugitive emissions from process equipment. All monitoring records and calibration records for the monitoring equipment (TVA) are 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 the NC DAQ a copy of each emissions test report and compliance reports, including supporting documentation as specified in the Title V permit. The test reports and compliance reports are maintained onsite and available upon request. 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. Carbon Adsorber operational procedures are maintained onsite and available upon request. During this reporting quarter, there were no instances that 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 August 14, 2019 to Greg Reeves in the NC DAQ Fayetteville Regional Office. Section 2.2 D.1.l.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. 1 f Chemours Company—Fayetteville Works Quarterly Report (per 2.2 D.l)—4th Quarter 2021 Air Permit No. 03 73 5T48 Page 5 of 6 Pressure testing was completed as required and records are maintained onsite and are available upon request. During this reporting quarter, there were no instances of equipment found to be leaking during pressure testing, therefore, no repairs were required for 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. AVO inspections were completed as required and the records are maintained onsite and are available upon request. During this reporting quarter, the AVO inspections did not find evidence of any leaks. Section 2.2 D.I.l.iii.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. During this reporting quarter,Method 21 and enhanced area monitoring results identified no components with monitored results exceeding the lower leak definition. Section 2.2 D.I.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. A 12-month rolling log is used to record and track all readings above the lower leak definition to assist with the component replacement program. The following is a summary of the components recorded as exceeding the lower leak definition as defined by the permit: October 2021 —no components exceeding the lower leak definition. November 2021 —no components exceeding the lower leak definition. December 2021 —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. Chemours Company—Fayetteville Works Quarterly Report(per 2.2 D.1)—4th Quarter 2021 Air Permit No. 03735T48 Page 6 of 6 The 12-month rolling calculation for HFPO-DA emissions continued to be exceeded during the reporting period due to an increase in emissions identified in carbon adsorber testing on the VE- North unit in March 2021 and that was corrected in early April 2021.