AQ_F_0900009_20200309_ST_RvwMemo (11)

Division of Air Quality
March 9, 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 June 10-11,2019 at the
Polymer Processing Aid (PPA)Carbon Bed Adsorber by Weston Solutions, Inc.
Tracking No. 2019-208ST
Summary of GenX Test Program
Sources Tested
During June 10-11, 2019,emissions testing was conducted on the Polymer Processing Aid (PPA)area.
HFPO Dimer Acid Fluoride (HFPO DAF) produced in the VEN process is used to produce HFPO dimer acid
(also known as GenX). There area number of products that maybe produced at PPA depending upon
the raw materials and the final product needs. Process gases pass through the PPA scrubber which is a
pH controlled packed bed scrubber. Chemours has added a carbon bed adsorber following the scrubber
for additional control of GenX. Fugitive emissions from enclosed areas of the PPA process(i.e., room air)
are also vented through the PPA carbon bed adsorber though it does not pass through the scrubber
prior to the adsorber. Testing was conducted at the inlet to the carbon bed and at the stack to
determine the overall reduction efficiency to GenX emissions due to the addition of the carbon bed
adsorber.
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 NC 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.
PPA Area Test Results
GenX emissions testing of the PPA carbon bed inlet and the PPA Area Stack(for carbon bed outlet
results)was conducted on June 10-11, 2019. Three runs were conducted to characterize the emissions
reduction by the carbon bed during the vaporization process. The per run emission rate and average for
three runs is displayed in the table below. Inlet and outlet volumetric flow rates were within the normal
variation that we expect between independent measurements.
Table 1. PPA Carbon Bed Adsorber Test Results,June 10-11,2019
inlet Outlet Removal
Efficiency
g/sec Ib/hr g/sec lb/hr %
Run 1 2.81E-04 2.23E-03 1.36E-05 1.08E-04 95.2
Run 2 4.87E-04 3.87E-03 6.09E-06 4.84E-05 98.7
Run 3 2.15E-04 1.71E-03 1.73E-05 1.37E-04 92.0
Average 3.28E-04 2.60E-03 1.23E-05 9.78E-05 95.3
Summary and Conclusions
NC DAQ staff members were on site during each day that source testing occurred. 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