AQ_F_0900009_20201130_ST_RvwMemo (10)

Division of Air Quality
November30, 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 June 23,2020
at Vinyl Ethers South (VES) Carbon Bed by O'Brien &Gere, Inc.
Tracking No. 2020-308ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VES carbon bed adsorber was sampled on June 25, 2020. The carbon bed adsorber was returned
service for controlling fugitive emissions from "room air" at the VES production area after the thermal
oxidizer became operational. Testing was conducted to determine removal efficiency and emission
rates from the VES 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 Dimer Acid test results reflect corrected emission rates accounting for dilution and
spike recovery values.

Vinyl Ethers South Area Test Results
Inlet and outlet emissions from the VES carbon bed adsorber were measured on June 23, 2020 to
determine the removal efficiency of HFPO Dimer Acid from the room air emissions. Each test run was
90 minutes in length. The process was operating normally and was producing PMVE and PEVE.
Table 1. Summary of Stack Test Results for VIES Carbon Bed on June 23, 2020
HFPO Dimer Acid Emission Rate
Run Number Inlet Outlet %Removal Efficiency
(lb/hr) (lb/hr)
1 2.44E-04 1.46E-04 40.16
2 4.86E-04 1.75E-04 63.99
3 3.26E-04 1.44E-04 55.83
Average 3.52E-04 1.55E-04 55.97
Summary and Conclusions
NC DAQ was not on-site to observe this test due to COVID-19 safety concerns. 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
!BEAM Documents-0900009