AQ_F_0900009_20200311_ST_RvwMemo (10)

Division of Air Quality
March 11, 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 May 20, 2019 at
Vinyl Ethers South (VES) Stack by Weston Solutions, Inc.
Tracking No. 2019-206ST
Summary of HFPO Dimer Acid Test Program
Sources Tested
On May 20, 2019, emissions testing was conducted on the Vinyl Ethers Scrubber Stack located at the
Vinyl Ethers South (VES) process area.The VES Stack is a common stack through which emissions from
VES Scrubber are combined with fugitive emissions collected from the enclosed areas of VES (sometimes
referred to as "room air"). Gases from various reaction vessels and unit operations in the VES process
area are vented through the caustic scrubber which reduces emissions of GenX (HFPO Dimer Acid) and
its precursors(HFPO Dimer Acid Fluoride).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 VES scrubber was conducted on May 20, 2019 while VES was producing
PMVE and PEVE. Each run was conducted under normal operating conditions.
Each sampling run was 90 minutes in length. The emission rate is the combination of the process gases
through the scrubber and the room air emissions because of the current stack configuration. The
sample analysis data indicated the sampling train captured most of GenX before the second XAD-2 trap.
The per run emission rate and average is displayed in the table below.
Table 1. Summary of Stack Test Results for VES on May 20,2019
NFPO Dimer Acid Emission Rate
Test Method Run Number
lb/hr g/sec
1 3.79E-03 4.78E-04
Modified Method 0010 2 1.19E-03 1.50E-04
3 1.56E-03 1.96E-04
Average 2.18E-03 2.75E-04
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
!BEAM Documents-0900009