AQ_F_0900009_20201201_ST_RvwMemo

Division of Air Quality
December 1, 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 (GenX) Conducted on February 19-20, 2020 at
Vinyl Ethers South (VES) Carbon Bed by Weston Solutions, Inc.
Tracking No. 2020-291ST
Summary of HPPO Dimer Acid Test Program
Sources Tested
On February 19-20, 2020,emissions testing was conducted on the Vinyl Ethers South Carbon Adsorber
located at the Vinyl Ethers South (VES) process area.The VES carbon bed controls fugitive emissions
collected from the enclosed areas of VES (sometimes referred to as"room air"). Process emission gases
from various reaction vessels and unit operations in the VES process area are vented to the thermal
oxidizer which reduce emissions of GenX(HFPO Dimer Acid) and its precursors(HFPO Dimer Acid
Fluoride).These process emissions are not part of this testing. Although the VES can produce perfluoro
propyl vinyl ether(PPVE),the VES area is be used to produce perfluoro methyl vinyl ether(PMVE) and
perfluoro ethyl vinyl ether(PEVE). During the testing,the HFPO process was operating and the VES
process was producing PMVE and PEVE.
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 GenX test results reflect corrected emission rates accounting for dilution and spike
recovery values.
Vinyl Ethers South Test Results
GenX emissions testing of the VE5 carbon bed adsorber was conducted on February 19-20, 2020 while
VES was producing PMVE and PEVE. Each run was conducted under normal operating conditions.
Each sampling run was nominally 90 minutes in length. The sample analysis data indicated the sampling
train captured the HFP© Dimer Acid (GenX) before the second XAD-2 trap. The per run emission rate,
removal efficiency, and averages are displayed in the table below.
Table 1. Summary of Carbon Bed Test Results for VE5 on February 19-20,2020
HFPO Dimer Acid Emission Rate Efficiency
Run Number
Inlet(lb/hr) Outlet(lb/hr)
1 8.48E-04 1.21E-04 85.7
2 3.82E-04 1.18E-04 69.2
3 2.26E-04 1.12E-04 50.5
Average 4.85E-04 1.17E-04 62.7
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: Central Files—Bladen County
IBEAM Documents-0900009