AQ_F_0900009_20210826_CMPL_NOV-NRE

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GOY COOPER a
Governor �{�
ELIZABETH S.BISER a nM r
Secretary
MICHAELABRACZINSKAS NORTH CAROLINA
Director Environmental:Quality
26 August 2021
CERTIFIED MAIL
RETURN RECIEPT REQUESTED
Ms. Dawn Hughes, Plant Manager
Chemours Company- Fayetteville Works
22828 NC Highway 87 West
Fayetteville,NC 28306-7332
Subject: Notice of Violation/Notice of Recommendation for Enforcement
Chemours Company- Fayetteville Works, Air Permit No. 03735T48
Fayetteville, Bladen County,NC 06/0900009 Fee Class: Title V
Dear Ms. Hughes:
Pursuant to the Consent Order entered on 25 February 2019 in Bladen County Superior
Court,the Chemours Company - Fayetteville Works (Chemours) was required by 31 December
2019 to reduce facility-wide annual air emissions of GenX Compounds by at least 99% from
2017 Total Reported Emissions. The Consent Order further provided that this requirement, or a
more stringent one, would be incorporated into an Air Quality permit issued by the Division of
Air Quality (DAQ).
As contemplated by the Consent Order, Chemours' current air quality permit,No.
03735T48, contains Specific Limitation and Condition 2.2.D.1,which provides, in part:
[T]he Permittee shall reduce facility-wide annual emissions (includingfugitive,
maintenance, ma�/unction, or accidental emissions) of GenX Compounds to less than
23.027 pounds per year, which constitutes a 99 percent reduction from the 2017 Total
Reported Emissions of 2,302.7 pounds per year.
Permittee shall demonstrate compliance with the GenX Compounds emission limit of
23.027 pounds per year by calculating annual emissions each calendar month for the
previous 12 months.
In addition, General Condition 3.17 provides
The facility shall be properly operated and maintained at all times in a manner that will
effect an overall reduction in air pollution. Unless otherwise specified by this permit, no
emission source may be operated without the concurrent operation of its associated air
pollution control device(s) and appurtenances.
��- North Carolina Department of Environmental Quality I Division of Air Quality
Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301
o +nM'pB1+1 m+�aa� 910.433.3300T 191OA85.7467F

Ms. Dawn Hughes
26 August 2021
Page 2 of 3
On 28 April 2021, Chemours submitted a"Title V Plant-Wide 1Q21 Continuous
Compliance Report,"which summarized facility-wide GenX emissions through March 2021.
Upon review of this report, DAQ determined that the methodology employed by Chemours to
calculate its annual GenX emissions was not appropriate. Therefore, on 29 June 2021, DAQ sent
Chemours a letter directing the facility to change the GenX emissions estimation methodology
and directing the facility to recalculate and resubmit GenX emission estimates for the period
beginning January 2020. On 15 July 2021, DAQ received the recalculated emissions report from
Chemours. The report documented facility-wide emissions of GenX for each month and for each
12-month period beginning in January 2020 through June 2021.
The data provided in the recalculated emissions report documents that Chemours
exceeded the permitted facility-wide annual GenX Compounds emissions limit of 23.027 pounds
per year for the 12-month periods ending in March, April, May, and June 2021. Chemours'
failure to reduce facility-wide annual emissions of GenX Compounds to less than 23.027
pounds per year constitutes an ongoing violation of Specific Limitation and Condition
2.2.D.1.
In addition, DAQ's investigation has revealed that the cause of recently documented
increases in GenX emissions from the Vinyl Ethers North indoor fugitive emissions processes
(ID No. NS-13-2) included improper operation and maintenance of Carbon Adsorber 11)No.
NCD-Q3 and appurtenances. Chemours' failure to properly operate and maintain Carbon
Adsorber ID No. NCD-Q3 constitutes violation of General Condition 3.F.
As stated in the "subject" above, this letter represents not only a Notice of Violation, but
puts you on notice that the DAQ Fayetteville Regional Office is preparing an enforcement report
addressing the above-cited violations. The above violations and any future violation of an air
quality rule are subject to the assessment of civil penalties as per North Carolina General Statute
143-215.114A. This General Statute provides that civil penalties of up to twenty-five thousand
dollars ($25,000) per day may be assessed for a violation of any classification, standard, or
limitation established pursuant to General Statute 143-215.107, "Air Quality Standards and
Classifications."
Please submit a written response to this office by 10 September 2021. In your
response, please include the following:
• A detailed timeline of the events leading to the excess emissions from Carbon
Adsorber ID No.NCD-Q3 which resulted in violations noted above;
• All corrective actions Chemours has taken or plans to take to address and prevent
further excess emissions;
• A detailed plan of action and timeline to return the Fayetteville Works facility to
compliance with all permit requirements; and
• Any additional information regarding the cited violations for the DAQ Director's
consideration prior to civil penalty assessment.

Ms. Dawn Hughes
26 August 2021
Page 3 of 3
After the above date, the DAQ Fayetteville Regional Office will submit the enforcement
report to the DAQ Director, including recommendations for the assessment of appropriate civil
penalties.
We appreciate your immediate attention to these environmental concerns. If you have any
questions regarding your permit or the violations cited above,please contact Evangelyn
Lowery-Jacobs, Environmental Engineer, or Greg Reeves, Acting Compliance Coordinator, at
[phone].
Sincerely,Q
Aeµ �1
Heather S. Carter
Fayetteville Regional Supervisor
Division of Air Quality, NC DEQ
HSC/elj
cc: Christel Compton,Chemours(e-copy)
FRO Facility Files
FRO Enforcement Files