AQ_F_0900009_20200311_ST_RvwMemo (9)

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 Dimer Acid Conducted on March 25-26, 2019 at Vinyl
Ethers North (VEN) Carbon Bed and Division Waste Gas Stack by Weston Solutions, Inc.
Tracking No. 2019-203ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
This test was conducted on the carbon bed adsorber and the Division Waste Gas Stack as a follow-up
test to test 2019-070ST. A previously unidentified source of HFPO Dimer Acid was discovered as the
result of the previous test and was routed to the inlet of the scrubber. This test was being conducted to
demonstrate the removal efficiency of the carbon bed and to determine if reconfiguring source flow had
reduced emissions at the stack.
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 60,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.
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
The reported HFPO test results reflect corrected emission rates accounting for dilution and spike
recovery values.
Vinyl Ethers North Area Test Results
Inlet and outlet emissions from the VEN carbon bed adsorber were measured on March 25-26, 2019 to
determine the removal efficiency of HFPO Dimer Acid from the process and room air emissions. Each
test run was 90 minutes in length. The process was operating normally and was producing PPVE.
Table 1. Summary of Stack Test Results for VEN Carbon Bed and DWG Stack on March 25-26,.2019
HFPO Dimer Acid Emission Rate
Run Number DWG.Stack Inlet Outlet % Removal
(lb/hr) (lb/hr) (lb/hr) Efficiency
1 8.20E-03 6.16E-01 6.23E-03 99.0
2 5.16E-03 4.95E-02 2.97E-03 94.0
3 1.08E-02 8.98E-02 6.89E-03 92.3
Average 8.05E-03 2.52E-01 5.36E-03 95.1
Summary and Conclusions
As can be seen in the table above,the stack gas emissions have decreased significantly from the
previous tests, indicating that the rerouting of previously unidentified sources of HFPO Dimer Acid have
reduced the emission rate and brough it more in-line with the emissions from the outlet of the carbon
bed. However,the stack values are still greater than the outlet of the carbon bed indicating that there
may be at least one other source of HFPO Dimer Acid reaching the stack and not passing through the
controls.
NC DAQ staff members were on site during each day that source testing occurred. 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: Central Files—Bladen County
iBEAM Documents-0900009