AQ_F_0900009_20201130_ST_RvwMemo (11)

Division of Air Quality
November 30,2020
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 January 6-7, 2020
at Vinyl Ethers North (VEN) Carbon Bed and Division Waste Gas Stack by Weston
Solutions, Inc.
Tracking No. 2020-290ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VEN carbon bed adsorber and Division Waste Gas Stack were sampled on January 6-7, 2020 after
the carbon bed adsorber was returned to service for controlling fugitive emissions from "room air" at
the VEN production area. Testing was conducted to determine removal efficiency and emission rates
from the VEN fugitive emissions and controls.
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 Dime rAcid test results reflect corrected emission rates accounting ford i I ution and
spike recovery values.
Vinyl Ethers North Area Test Results
Inlet and outlet emissions from the VEN carbon bed adsorber were measured on January 6-7,2020 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 I. Summary of Stack Test Results for VEN Carbon Bed and DWG Stack on January 6-7,2020
HFOP Dimer Acid Emission Rate
Run Number DWG Stack Inlet Outlet % Removal
(lb/hr) (lb/hr) (lb/hr) Efficiency
1 1.45E-03 3.82E-01 5.20E-04 99.86
2 9.82E-04 4.48E-01 6.30E-04 99.86
3 9.07E-04 5.15E-01 6.70E-04 99.87
Average 1.11E-03 4.48E-01 6.07E-04 99.86
Summary and Conclusions
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