AQ_F_0900009_20200311_ST_RvwMemo

Division of Air Quality
March 11,2020
MEMORANDUM
To: Heather Carter, Fayetteville Regional Supervisor
From: Gary L. Saunders, Stationary Source Compliance Branch
Subject: The Chemours Company--Fayetteville Works
Fayetteville, Bladen County, North Carolina
Facility ID. No.0900009, Permit No. 03735T47
Performance Testing for HFPO Monomers and Dimer Acid Conducted November 22 and
December 4, 2019 at Vinyl Ethers North (VEN) Division Waste Gas Stack and
December 4-5, 2019 at the E2 Stack by Weston Solutions, Inc.
Tracking No. 2020-037ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VEN Division Waste Gas Stack was sampled using the Modified Method 0010 and Modified Method
18. A two-run test was conducted using Modified Method 0010. A three-run test was conducted using
the Modified Method 18 as a "proof-in-concept"test method for use when the thermal oxidizer
becomes operational. It is the method for use at the high concentrations that characterize the inlet of
the thermal oxidizer. The VEN process was producing PPVE during these tests.
The E2 process stack was sampled for HFPO Dimer Acid. This was the first test of this process stack.
Sampling was conducted using Modified Method 0010.
Sampling Method
Testing was conducted using a modified EPA Method 0010 found in the SW-846 compendium of Test
Methods for Evaluating Solid Waste: Physical/Chemical Methods. This sampling train is a variation of the
EPA Reference Method 5 found in 40 CFR 50,Appendix A. The Method 0010 train extracts a sample
isokinetically from the gas stream, passes the sample through a temperature-controlled filter,through a
temperature-controlled condenser and into a series of XAD-2 resin "traps" and impingers to capture and
collect the materials that passed through the filter. The test method is designed to capture certain
particulate and condensable materials for later recovery and analysis.
The Modified Method 18 uses mini-impingers filled with methanol for capture and reaction of certain
PFAS compounds for lab analysis. The mini-impingers are maintained at a low temperature in a
methanol dry ice bath.
After sample recovery,the samples were sent to Chemours' contractor,Test America's laboratory in
Denver, Colorado. GenX was extracted from the resin traps. The DAQ required split samples after

extraction to be submitted for independent analysis. This summary of results only addresses the results
provided by Test America for Chemours. Laboratory analysis and quantification was performed using a
liquid chromatography column and a dual mass spectrometer(LC/MS/MS)-
Test Results
As a proof in concept test,the results at VEN indicated that the test methods were suitable for use in
the upcoming thermal oxidizer testing. The results are displayed in the test report but are not reported
here.
The emissions from the E2 process stack are shown in the table below
Table 1. Summary of Stack Test Results for E2 Stack on December 4-5, 2019
HFPO Dimer Acid Emission Rate
Test Method Ruin Number
Ib/hr g/sec
1 8.80E-05 1.1E-05
2 1.06E-05 1.34E-06
Modified Method 0010
3 1.59E-05 200E-06
Average 3.82E--05 4.81E-06
Summary and Conclusions
NC DAQ staff members were on site during source testing. DAQ staff observed the source test teams,
the sample recovery and the process operations. Based upon the onsite observation of the testing and
review of the test report, NC DAQ concludes that the testing was conducted in accordance to the
modified testing protocol submitted by Chemours and that the analytical results appear representative
of the stack conditions and process operations during the testing.
Cc: CentralFiles—BladenCounty
IBEAM Documents-0900009