AQ_F_0900009_20200520_CMPL_CmplDetLtr

ROY COOPER ° mO
Governor
MICHAEL S. REGAN
Secretary �. -
MICHAELA.ABRACZINSKAS NORTH CAROLINA
°""`°' Environmental Quality
20 May 2020
Brian Long, Plant Manager
Chemours Company—Fayetteville Works
22828 NC Highway 87 West
Fayetteville,NC 28306
SUBJECT: Enhanced Leak Detection and Repair (LDAR) Procedure Approval
Chemours Company—Fayetteville Works Permit No. 03735T47
Fayetteville, NC, Bladen County Facility ID: 0900009
Fee Class: Title V
Dear Mr. Long:
The North Carolina Division of Air Quality (DAQ) is in receipt of your submitted
updated proposed Enhanced Leak Detection and Repair(LDAR) Procedures for the Chemours
Company—Fayetteville Works facility. The submission was initially received by DAQ on 13
May 2019 and subsequently revised on 14 August 2019. The procedures were further revised
and the final update submitted to DAQ on 31 December 2019.
Chemours entered into a Consent Order (Order) with the Department of Environmental
Quality and the Cape Fear River Watch on 25 February 2019. Subsequent to that Order, DAQ
issued air quality permit 03735T44 on 24 March 2019, which incorporated certain requirements
from the Order.
Permit 03735T44 contains Specific Condition and Limitation 2.2.D.l.h"Inspections and
Monitoring—Enhanced Leak Detection and Repair Program"which requires that no later than
13 May 2019, Chemours develop and submit to DAQ for approval, an enhanced leak detection
and repair program, addressing pressure testing, enhanced audial, visual, and olfactory (AVO)
inspections, routine Method 21 instrument monitoring, enhanced area monitoring, replacement
or improvement program for valves and connectors, and maintenance and calibration of any
instrumentation and equipment used to implement the enhanced leak detection and repair
program.
DAQ staff have reviewed the submitted Enhanced LDAR Procedures and determined that
these procedures meet the requirements of the applicable permit condition. The DAQ is
approving the Enhanced LDAR Procedures as submitted on 31 December 2019.
C ^1n North Carolina Department of Environmental Quality I Division of Air Quality
�<J Fayetie 5900 T Regional
Office
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Enhanced LDAR Procedures Approval
20 May 2020
Page 2
If you have any questions concerning this approval or other issues regarding your permit,
please contact Gregory Reeves, Permits Coordinator, or me at 910-433-3300.
Sincerely, (1
Heather S. Carter
Regional Supervisor
Division of Air Quality, NC DEQ
HSC\gwr
cc: FRO Facility Files
Attachment: Environmental Procedures Enhanced LDAR for DAF and DA Emissions
�I ^� North Carolina Department of Envaonmental Quality Division of Air Quality
tt rayeville Regional Office 1 225 Green Su vet.Suite,7141 Fayetteville,North Carolina 28301
910.43333009 1910.485.7447E

ENVIRONMENTAL PROCEDURES
ENHANCED MAR FOR DAF & DA EMISSIONS
I. GENERAL DESCRIPTION
The intent of this procedure is to provide additional LDAR 'best practices'which
will assist in reducing emissions specific to DAF production and further enhance
our current LDAR monitoring programs
II. PURPOSE
To provide instructional guidance for Enhanced Pressure Testing, Enhanced AVO
Inspections, and additional instrument (TVA) monitoring for all equipment
containing 1% or greater DAF or DA.
III. SAFETY CONSIDERATIONS
A. Extra caution should be exercised when patrolling near equipment/lines
associated with DAF production.
B. Knowledge of all area safety equipment locations and status must be known in
order to provide a safe and immediate response in the unlikely event a leak is
detected.
C. When Chemours personnel are using the TVA instrument to monitor equipment
containing DAF or DA, care and good judgement must be exercised to prevent
damaging the TVA analyzer. It is recommended the TVA instrument only be used
after the repairs have been made to verify the repair was successful.
D. As per normal area operating procedures, ALL leaks are to be reported
immediately.
IV. ENHANCED AVO INSPECTIONS
A. Each area that is identified as having equipment/lines which contain 1% or
greater DAF or DA, must conduct a daily AVO inspection on that equipment
and provide a signed checksheet which will be submitted daily.
B. The AVO inspection sheet (aka: LDAR Inspection Record) should include a
list of all equipment to be inspected along with information such as the date,
time, name of the person conducting the inspection, and detailed
descriptions of the areas or equipment inspected. Inspection results,
including any leaks found and repair actions taken, would also be
documented and maintained.

V. ENHANCED PRESSURE TESTING
A. To reduce the potential of fugitive emissions from equipment containing 1% or
greater DAF or DA outdoors, a leak during enhanced pressure test is defined as a
change in pressure greater than 3.45 kpa (0.5 psi) during a 30-minute interval.
B. The following areas have been identified as needing to follow the enhanced
pressure testing guidelines:
1. VE North
2. VE South
3. PPA
4. Semi-works
Note: It is recommended that ALL areas review their leak checking
procedures to ensure that we are operating at a more efficient level to
reduce future equipment leaks.
C. Each time a leak check is to be performed on equipment containing 1% or greater
DAF or DA, use the PRESSURE TESTING CHECKSHEET (next page) to document
leak tests. Normal operating procedures are to be used for set point of pressure
testing. However, the rate of change in this procedure (3.45 kpa/30 min) supersedes
existing procedures unless the rate of change is already lower.

PRESSURE TESTING
Date:
AREA CAMPAIGN (if applicable)
EQUIPMENT
Normal Operating Pressure
START TIME PRESSURE
END TIME PRESSURE
TIME ELAPSED Change in Pressure
PASS OR LEAK
A Leak is detected if the rate of change in pressure is greater than 3.45 kPa (or 0.5 psig) in 30
minutes or if there is visible, audible, or olfactory evidence of fluid loss.
If a Leak is found document repairs made to equipment:
RETEST
START TIME PRESSURE
END TIME PRESSURE
TIME ELAPSED Change in Pressure
PASS OR LEAK
PRINT NAME SIGNATURE
DATE
*Attach additional sheets if necessary
If a process fails the retest or the second of two consecutive pressure tests, it shall be repaired as soon
as practicable, but not later than 30 calendar days after the second pressure test, provided the following
conditions are met. Delay of repair of equipment for which leaks have been detected is allowed if the
replacement equipment is not available providing the following conditions are met:
• Equipment supplies have been depleted and supplies had been sufficiently stocked before
the supplies were depleted.
• The repair is made no later than 10 calendar days after delivery of the replacement
equipment.
• Delay of Repair must be approved by Environmental Resource.

VI. ADDITIONAL INSTRUMENT MONITORING
A. Additional instrument (TVA) monitoring using EPA Method 21 will be expanded to
include all outdoor equipment/lines identified as containing 1% or greater DAF or
DA.
B. All outdoor equipment/lines identified as containing 1% or greater DAF or DA will
be tagged with a `round black' tag which will have a number that corresponds to a
specific location on the P&ID.
C. Routine quarterly instrument (TVA) monitoring of valves will be conducted by
TEAM Industrial Emissions Control Services. Routine annual instrument (TVA)
monitoring will be conducted by TEAM, INC for connectors. TEAM, INC will be
responsible for the calibration and maintenance of the TVA.
D. Fugitive emission calculations will use the date and time stamp on the LDAR
TEAM report for each component as the start of emissions and will reset the.date
and time when new measurement is made.
VII. LEAK REPAIR
A. The Enhanced LDAR monitoring will initiate replacement with low emission
technology based on the following criteria:
a. a leak will be defined as 100 ppm as measured by instrument monitoring
b. Manual Valves and Gaskets
(i) first leak, use normal means for repair on first attempt, ie tighten
flanges, packing, bonnet
(a) if pass then no further action
(b) if fail then replace with low-emission valve or certified re-built
or new gasket
(ii) maintain log of leakers and replace repeat leakers (rolling 12-
months). If a component is found to be leaking above 100 ppm twice
during a 12-month period, conduct a first repair attempt as per usual
procedures but even if a first repair attempt repairs the second leak,
replace with low-emission technology during the next shutdown.

c. Automated Valves
(i) first leak, use normal means for repair on first attempt, le tighten
flanges, packing, bonnet
(a) if pass then no further action;
(b) if fail then pull valve and rebuild with vendor's appropriate
low—emission technology in Chemours maintenance shop; if
still fails then order new low-emission control valve and
replace during next shutdown following receipt of the valve
(ii) maintain log of leakers and replace repeat leakers (rolling 12-
months). If a component is found to be leaking above 100
ppm twice during a 12-month period, conduct a first repair attempt
as per usual procedures but even if a first repair attempt repairs the
second leak, order new low-E automated valve and when received
replace during next shutdown