AQ_F_0900009_20201201_ST_RvwMemo (4)

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. 03735T48
Performance Testing for HFPO Dimer Acid Conducted on September 3, 2020
at Vinyl Ethers North (VEN) Carbon Bed by Ramboll (formerly O'Brien &Gere, Inc.)
Tracking No. 2020-309ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VEN carbon bed adsorber was sampled on September 3, 2020. The carbon bed adsorber was
returned to service for controlling fugitive emissions from "room air" at the VEN production area after
the thermal oxidizer became operational. 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. HFPO Dimer Acid was extracted from the resin traps. This summary of results only
addresses the results provided by Test America for Chemours. No split sample analysis is included in this
review. 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 North Area Test Results
Inlet and outlet emissions from the VEN carbon bed adsorber were measured on September 3, 2020 to
determine the removal efficiency of HFPO Dimer Acid from the process and room air emissions. Each
test run was nominally 90 minutes in length. The process was operating normally and was producing
PPVE. As noted in Table 1,the Run 1 removal efficiency was negative. Although not mentioned the test
results discussion, a review of the analytical data also indicated that there was possible contamination
of the XAD-2 breakthrough resin trap. The quantity of HFPO Dimer Acid found in the resin trap results
was approximately an order of magnitude greater than the analytical results for the composite of the
impingers indicating either glassware and/or resin contamination. Normally,the analytical results for
second XAD-2 resin trap are either less than or approximately equal to the quantity captured in the
condensate impingers.
Table 1. Summary of Stack Test Results for VEN Carbon Bed and DWG Stack on September 3, 2020
HFPO Dimer Acid Emission Rate
Run Number DWG Stack Inlet Outlet % Removal
(lb/hr) (lb/hr) (lb/hr) Efficiency
1 Not Sampled 1.57E-03 2.11E-03 NA*
2 Not Sampled 1.37E-02 3.75E-03 72.63
3 Not Sampled 6.47E-03 2,27E-03 64.91
Average Not Sampled 7.42E-03 2.71E-03 63.48
*Outlet emission rate was greater than the inlet producing a negative efficiency
Summary and Conclusions
NC DAQ personnel were not on-site to observe this test due to COVID-19 considerations. 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 with the exceptions noted above.
Cc: Central Files—Bladen County
IBEAM Documents-0900009