AQ_F_0900009_20210212_ST_RvwMemo

Division of Air Quality
February 12, 2021
MEMORANDUM
To: Heather Carter, Fayetteville Regional Supervisor
From: Gary L.Saunders,Stationary Source Compliance Branch �s
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 December 9, 2020
at Vinyl Ethers North (VEN) Carbon Bed by Ramboil (formerly O'Brien& Gere, Inc.)
Tracking No. 2020-316ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
The VEN carbon bed adsorber was sampled on December 9, 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 far 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 December 9, 2020 to
determine the removal efficiency of HFPO Dimer Acid from the process room air emissions. Each test
run was nominally 90 minutes in length. The process was operating normally and was producing PPVE.
The concentration levels at the outlet are quite low. A review of the analytical data indicates that there
may be slight contamination issues in the Run 2 Inlet Train data and the Run 3 Outlet Train as the
breakthrough XAD-2 resin showed a higher value than the impinger catch. However, the total analytical
capture was included in the calculations.
Table 1. Summary of Stack Test Results for VEN Carbon Bed and DWG Stack on December 9,2020
HFPQ Dimer Acid Emission Rate
Run Number DWG Stack Inlet Outlet % Removal
(lb/hr) (lb/hr) (lb/hr) Efficiency
1 Not Sampled 1 92E-02 6.25-05 99.67
2 Not Sampled 3 50-02 5.17-05 99.86
3 Not Sampled .2.65E-02 2.82E-04 98.99
Average Not Sampled 2.79E-02 1.32E-04 99.53
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
]BEAM Documents-0900009