AQ_F_0900009_20210203_CMPL_InspRpt

NORTH CAROLINA DIVISION OF FChemours
7Regional Office
AIR QUALITY -Fayetteville Works
0009
Inspection Report n/017
Date: 02/24/2021
Facility Data Permit Data
Chemours Company-Fayetteville Works Permit 03735/T48
22828 NC Highway 87 West Issued 5/13/2020
Fayetteville,NC 28306 Expires 3/31/2021
Lat: 34d 50.6700m Long: 78d 49.8750m Class/Status Title V
SIC: 2869/Industrial Organic Chemicals,nec Permit Status Active
NAICS: 32512/Industrial Gas Manufacturing Current Permit Application(s)TV-Sign-501(b)(2)
Part II,TV-Significant,TV-Renewal,TV-
Contact Data 502(b)(10)
Facility Contact Authorized Contact Technical Contact Program Applicability
Christel Compton Dawn Hughes Christel Compton SIP/Title V/112r
Program Manager Plant Manager Program Manager MACT Part 63: Subpart DDDDD, Subpart FFFF,
[phone] [phone] [phone] Subpart ZZZZ
NSPS: Subpart De, Subpart 1II1
Compliance Data
Comments:
Inspection Date 02/03/2021
Inspector's Name Evangelyn Lowery-Jacobs
Inspector's Signature: Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: d2Jyt/?vtj Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 1.73 0.2100 62.47 281.28 28.97 1.0000 30536.60
2018 1.68 0.2100 65.87 299.95 29.83 0.9400 35869.00
2017 3.97 0.2000 61.63 239.09 33.86 3.97 34586.00
*Highest HAP Emitted(in pounds)
Five Year Violation Year Violation Histoo
Date Letter Tvvc Rule Violated Violation Resolution Date
04/17/2020 NOV 2D .0515 Particulates from Miscellaneous Industrial 04/29/2020
Processes

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 2 of 15
Performed Stack Tests since last FCE:
Date Test Results Test Method(s) Source(s)Tested
01/28/2021 Pending
09/02/2020 Pending
09/01/2020 Pending
06/25/2020 Pending
06/24/2020 Pending
16121/2020 Pending
06/03/2020 Pending
02/29/2020 Compliance NS-A,NS-B,NS-C,NS-D-1,NS-
G-1,NS-G-2,NS-H,NS-I,NS-
L.14A,NS-M,NS-N,NS-O,NS-P
02/19/2020 Pending
11/21/2019 Pending
09/26/2019 Pending
03/01/2019 Pending
I. DIRECTIONS TO SITE: Chemours Company-Fayetteville Works is located off of NC Highway 87 in Bladen
County. From FRO,head south on Green Street toward Maiden Lane. At the traffic circle,take the 2nd exit onto
Gillespie Street for approximately 1 mile. Turn right onto the ramp to Elizabethtown and merge onto Highway 87
south. Travel approximately 15 miles and turn left onto County Line Road,which is the entrance to the facility.
Follow the signs to check in at the security gate.
Yt
II. SAFETY CONSIDERATIONS: The usual FRO safety gear is required(hardhat, safety glasses, safety shoes,
hearing protection). Entry into several areas of the plant requires specialized safety gear. In the HFPO reactor and
MMF process areas,personnel are not allowed to enter unless the process is not operating due to the possibility of
explosion hazards of the chemical reaction process.
III. FACILITY DESCRIPTION: Chemours Company-Fayetteville Works is a chemical manufacturing facility
located in Bladen County. The facility was formerly owned by DuPont. The facility employs approximately 500
employees and 250 full-time contractors on a 24 In,7 day per week basis. The facility consists of four individual
manufacturing plants,a boiler house and a waste treatment operation. Several processes have PSD avoidance
conditions. The facility has two permanent boilers onsite,one permanent boiler which is permitted but not yet
constructed,and one permitted temporary boiler.
IV. INSPECTION SUMMARY: On Wednesday,February 3,2021,I,Evangelyn Lowery-Jacobs,of the DAQ
Fayetteville Regional Office,conducted a compliance inspection with Christel Compton,Program Manager. Due to
the COV D-19 pandemic,the compliance inspection was scheduled prior to the visit to discuss logistics and any
PPE requirements. The inspection was conducted in 2 parts: an online Microsoft Teams records review,
immediately followed by an onsite visit for an outdoor facility tour including visible emissions observations. Ms.
Compton reviewed the FacFinder sheet and noted that all information is correct.
Facility records were reviewed for emissions calculations and control device inspections. We discussed the
changes in permitted emission sources since the previous inspection/permit modification and reviewed all of the
new emissions sources listed on the permit. There are extensive electronic records for the facility operations
available on the local computer area network. Ms. Compton was able to display PSD data and other facility
processing and operational records via computer for review. For the operating areas,screenshots of flow rates and
pressure drops in scrubbers were provided by technicians available in the control rooms of the respective areas.
Boilers(PS-A and PS-B)were operating,firing natural gas. The third permitted boiler(PS-C)is not yet constructed.
The permitted temporary boiler(PSC-Temp)is not currently on site and was not on site during 2020. The Lime
Processing System(ID Nos.NS-RI and NS-R2)was not operating during the inspection. All other processes were
in operation during the inspection. I observed zero visible emissions from each of the operating source emission
points.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 3 of 15
V. PERMITTED EMISSION SOURCES: At the time of the inspection,Chemours Company—Fayetteville Works
was operating under Permit No.03735T48 which includes the following emission sources:
EmissiunSpurae
ID hidx "« misstog p96 rte llpscripYiou a ce t1� Control De ice Deso vpttigl
PS-A Natural Gas/No.2 fuel oil-fired boiler
Case-by-case (139.4 million Btu per hour maximum heat input) N/A N/A
MACT equipped with an oxygen trim system
MACT DDDDD OPERATING
PS-B Natural Gas/No.2 fuel oil-fired boiler
Case-by-case (88.4 million Btu per hour maximum heat input) N/A N/A
MACT equipped with an oxygen trim system
MACT DDDDD OPERATING
PS-C Natural Gas/No.2 fuel oil-fired boiler
NSPS De (97 million Btu per hour maximum heat input)
Case-by-case equipped with a low-NOx burner and N/A N/A
MACT an oxygen trim system
MACT DDDDD NOT YET CONSTRUCTED
Natural Gas/No.2 fuel oil-fired boiler
PS-Temp (less than 100.0 million Btu per hour N/A N/A
maximum heat input)
NOT ON SITE AT THIS TIME
NS-A Hexfluoropropylene epoxide(HFPO)process
MACT FFFF F OPERATING POS
NS-B Vinyl Ethers North process POS Baffle-plate scrubber(7,000
NCD-Hdrl kilo am/hour liquid injection rate
MACT FFFF OPERATING �' q j
NS-C V nyl Ethers South process averaged over a 3-hour period)
MACT FFFF OPERATING
RSU ProcessRA(except S03 System) Baffle-plate scrubber(7,000
coon
NS D-1 y ) or kilogram hour liquid injection rate
OPERATING NCD-Hdr2 averaged over a 3-hour period)
NS-E FPS Liquid waste stabilization
OPERATING AOS
Thermal Oxidizer(10 million Btu
AOS per hour,natural gas-fired)
NCD-QI 4-Stage Scrubber: Countercurrent
MF process _ Packed Bed Stages 1,2, and 3;
NS-F M
OPERATING -and Caustic Stage 4 with minimum
NCD-Q2 scrubber liquor flow of 40 gallons
per minute and minimum pH of 7.1
NS-G-2 IXM Resins Process Fluorinator NCD-G2 Caustic scrubber
MACT FFFF F
RSU Process S03 System: Wet scrubber with mist eliminator
NS D-2 S03 Storage Tank,Vaporizer, S03 Truck NCD-D (minimum liquid injection rate of
Unloading,Reservoir Tank 0.5 gallons per minute)
NS-H M membrane process N/A i N/A
OPERATING I

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 4 of 15
pt�s l�o S4n Emtssian Source
Descri ton, D`fi�vcicoen,tIDro l '
CautrolDevice,DoMptionk
NS-I IXM membrane coating I N/A N/A
OPERATING
SW-1 Semiworks polymerization operation
OPERATING
Semiworks laboratory hood SCD-SW l Carbon Adsorber
SW-2 OPERATING
NS G-1 DCM Resins Process(except Fluorinator)
MACT FFFF OPERATING
NS-K E 2 Process
OPERATING
TFE/CO2 separation process
(NOTE: Although NS-M is routed through one of
NS-M two baffle plate scrubbers,NCD-Hdrl and NCD-
Hdr2,the non-acid fluoride emissions from this
source are not removed in the scrubber.)
OPERATING
HYPO product container decontamination process POS POS
(NOTE:Although NS-N is routed through one of N/A N/A
NS-N two baffle plate scrubbers,NCD-Hdrl and NCD-
Hdr2,the non-acid fluoride emissions from this AOS AOS
source are not removed in the scrubber. NCD-QI Thermal Oxidizer(10 million Btu
OPERATING per hour,natural gas-fired)
Vinyl Ethers North product container -and-
decontamination process NCD-Q2 4-Stage Scrubber:Countercurrent
(NOTE:Although NS-O is routed through one of Packed Bed Stages 1,2,and 3;
NS-O two baffle plate scrubbers,NCD-Hdrl and NCD- Caustic Stage 4 with minimum
Hdr2,the non-acid fluoride emissions from this scrubber liquor flow of 40 gallons
source are not removed in the scrubber.) per minute and minimum pH of 7.1
OPERATING
Vinyl Ethers South product container
decontamination process
(NOTE:Although NS-P is routed through one of
NS-P two baffle plate scrubbers,NCD-Hdrl and NCD-
Hdr2,the non-acid fluoride emissions from this
source are not removed in the scrubber.)
OPERATING
VE-North Indoor Fugitives NCD-Q3 a e
NS-B-2 Carbon Adsorber
OPERATING
VE-South Indoor Fugitives
NS C2 NCD-Q4 Carbon Adsorber
OPERATING
ACD-Al Wet scrubber(30 gallons per minute
water injection rate averaged over a
AS-A Polymer Processing Aid Process 3-hour period)
OPERATING State-enforceable only
-and-
ACD-A2 Carbon Adsorber

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 5 of 15
SS40n" 011l'�''. i� h r. , z �.• ^..�..COLtI'dI
am iss Source Dos �tion autr 17)evib Descrtptitra
'� 4
Extended aeration biological was
tewater
WTS-A treatment facility N/A N/A
OPERATING
WTS B Two(2)Indirect steam-heated Wet scrubber with mist eliminator
WTS-C to
sludge dryers WTCD-1 State-enforceable only
I OPERATING
NS-RI Lime Silo NCD Rl Pulse Jet Baghouse
NOT OPERATING (300 square feet of filter area)
Lime Slaker Wet Particulate Scrubber
NS-R2 TNCD-R2 (minimum liquid in
rate of
NOT OPERATING 0.84 gallons per minute)
VI. APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each of the various
manufacturing processes as listed on the current air permit.
6• Powerhouse(Boilers PS-A,PS-B,and PS-C)
The facility is permitted to operate one Natural Gas/No.2 fuel oil-fired boiler(139.4 mmBtu/hr maximum heat
input,PS-A),one Natural Gas/No.2 fuel oil-fired boiler(88.4 mmBtu/hr maximum heat input,PS-B),and one
Natural Gas/No.2 fuel oil-fired boiler with low-NOx burner(97 mtnBtu/hr maximum heat input,PS-C). The
third boiler(PS-C)has not yet been constructed. According to Ms. Compton,this boiler will not be constructed
anytime soon,as there is no current need for additional steam capacity. Both of the existing boilers are
currently combusting natural gas. The larger boiler(PS-A)has a steam capacity of 113,000 pounds of steam
per hour(139.4 mmBtu maximum heat input)and was manufactured in 1969. The smaller boiler(PS-B)was
manufactured in 1982 with a steam capacity of 72,000 pounds per hour(88.4 mmBtu/hr maximum heat input).
They are both pre-NSPS boilers;however,Boiler PS-B has a PSD avoidance condition for NO.and 5O2.
Boiler PS-C will be subject to NSPS Subpart Dc when constructed. Chemours has a facility-wide PSD SO2
emissions limitation of 702.5 tons per consecutive 12-month period.
A. 15A NCAC 02D.0503 PARTICULATES FROM FUEL BURNING DMIRECT HEAT.
EXCHANGERS—Particulate emissions from boilers PS-A and PS-B shall not exceed 0.26671bs/mmBtu.
Particulate emissions from PS-C shall not exceed 0.2268 lbs/mmBtu.
No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.0071bs/mmBtu and for
No.2 fuel oil is 0.024 lbs/mmBtu. As long as the facility only combusts these fuels,they should not
exceed the emission limits. The facility is currently combusting natural gas. The last#2 fuel oil was
combusted in January 2018 during a short natural gas curtailment(28,350 gallons of No.2 fuel oil
combusted). The#2 fuel oil used is ultra-low sulfur content(< 15 ppm sulfur by weight.)
B. 15A NCAC 02D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—The
sulfur dioxide emissions from boilers PS-A and PS-B shall not exceed 2.3 pounds per million Btu heat
input while firing natural gas or No.2 fuel oil, and the sulfur dioxide emissions from boiler PS-C shall not
exceed 2.3 pounds per million Btu heat input while firing natural gas only.
No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.001 lbs/mmBtu and for
No.2 fuel oil(with 0.5%sulfur content by weight)is 0.507 lbs/mmBtu. All No.2 fuel oil is ultra-low
sulfur fuel oil(< 15 ppm sulfur content by weight.)The facility should never exceed the SO2 emission limit
while combusting either natural gas or#2 fuel oil. Ms. Compton produced a bill of lading for the last fuel
oil shipment which indicated the sulfur content to be< 15 ppm.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 6 of 15
C. 15A NCAC 02D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from Boiler PS-A
shall not exceed 40%opacity. Visible emissions from PS-B and PS-C shall not exceed 20%opacity. No
monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The boilers were combusting natural gas and I observed 0%opacity from
the boiler stack during the inspection. Boiler PS-C has not yet been constructed.
D. 15A NCAC 02D.0524 NEW SOURCE PERFORMANCE STANDARDS—SUBPART Be(for PS-C
only)—The sulfur content of fuel combusted in the new boiler(PS-C)shall not exceed 0.5%by weight and
visible emissions are limited to 20%opacity. Written notifications are required for construction
commencement and startup within 30 days after these events. The facility must conduct Method 9 testing
after boiler start-up if using No.2 fuel oil. The facility must maintain records of fuel usage and fuel oil
certifications. Records of startup, shutdown,and malfunctions must also be maintained. A semi-annual
summary report is required.
APPEARS IN COMPLIANCE—Boiler PS-C has not yet commenced construction,and there are no
current plans to install this unit. Therefore,none of the above requirements have been triggered. The last
semi-annual report was received at FRO on 01/27/2021 and appeared complete.
E. 15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS(PS-B only)—Emissions from Boiler PS-B shall not exceed the following: 40 TPY NOx,
and 40 TPY S02. The Permittee shall keep monthly records of fuel usage, fuel sulfur content,and maintain
fuel certifications. A semi-annual report is required, listing monthly emissions(17-month period),fuel
usage,and sulfur content. The Permittee must also list all deviations from the requirements in the report.
APPEARS IN COMPLIANCE—All records show that the facility is well below these emissions limits.
The highest 12-month total NOx emissions during 2020 were 6.6 tons and S02 emissions were 0.0 tons.
The last semi-annual report was received at FRO on 01/27/2021,which noted no deviations.
F. 15A NCAC 02D.1109 CASE-BY-CASE MACT—This condition includes requirements for boilers PS-A,
PS-B,and PS-C that were instituted as a result of the vacating of the Boiler MACT. Requirements include
an annual inspection and tune-up of each boiler each calendar year. Records of inspections and tune-ups
are required. A semi-annual report is required, starting January 30,2014.
APPEARS IN COMPLIANCE—The facility complied with this standard until May 19,2019 and is no
longer applicable. The condition was superseded by the requirements of NESHAP Subpart DDDDD
beginning as of May 20,2019.
G. 15A NCAC 02D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY—Requires that the
Permittee comply with the requirements of NESHAP Subpart DDDDD beginning as of May 20,2019 for
the boilers PS-A,PS-B,and PS-C. Includes the requirement for a one-time energy assessment,which must
be conducted prior to May 20,2019. Initial tune-ups for existing boilers PS-A and PS-B must be
conducted no later than May 20,2019 and subsequently every 5 years. An initial startup notification is
required for boiler PS-C not later than 15 days after actual startup. Compliance reports submitted every 5
years.
APPEARS IN COMPLIANCE—The one-time energy assessment was completed 02/11 -02/13/2019. The
initial tune-ups for boilers PS-A and PS-B were conducted on 02/12/2019 and 10/25/2018,respectively.
Boiler PS-C has not yet been constructed.

Chemours Company-Fayetteville Works
Compliance Inspection Report
Page 7 of 15
y FPS/IXM Process Area
The operation produces a variety of relatively uncommon monomer and polymer chemicals. Some of the
monomers are shipped offsite,while others are used onsite in the production of various polymers. The
polymers are shipped offsite or used onsite to produce Nafion®membrane material. A principal'use of this
membrane is in the electrolysis cells for production of chlorine and sodium hydroxide at chloro-alkali plants.
The two waste gas scrubbers located at the FPS/IXM process area are used to control the emissions of various
pollutants including hydrogen fluoride and other acid fluorides. The HFPO,Vinyl Ethers North and South, and
the IXM Resins processes(ID Nos.NS-A,NS-B,NS-C,and NS-G)are subject to the Miscellaneous Organic
NESHAP, Subpart FFFF and are classified as existing sources under this regulation.
H. 15A NCAC 02D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
Particulate matter emissions from the membrane coating process NS-I shall not exceed E=4.10*P067. The
Permittee shall maintain production records. A semi-annual summary report is required.
APPEARS IN COMPLIANCE-The initial permit application indicated that compliance would be
achieved based on the process description as permitted. No changes to the process have been made since
that application, and therefore compliance is indicated Production records were made available by Ms.
Compton for each manufacturingfacility. The last semi-annual summary report was received at FRO on
0112712021 and appeared complete.
I. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES -
Emissions of sulfur dioxide from the Thermal Oxidizer(ID No.NCD-Ql)shall not exceed 2.3 pounds per
million Btu heat input.No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE-The AP-42 emissionsfactorfor Natural Gas is 0.0011bs/mmBtu. The
facility should never exceed the S02 emission limit while combusting natural gas in the thermal oxidizer.
J. 15A NCAC 02D.0521 CONTROL OF VISIBLE EMISSIONS-Visible emissions from the membrane
coating process(ID No.NS-I),the S03 System(ID No.NS-D-2),and the outlet of the 4-Stage Scrubber
(ID No.NCD-Q2)shall not exceed 20%opacity. No monitoring,recordkeeping, or reporting is required.
APPEARS IN COMPLIANCE-I observed no visible emissions from any of the sources during this
inspection.
K. 15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS-VOC emissions from the Vinyl Ethers North process,NS-B,shall not exceed 68.9 TPY
VOC. The Permittee shall keep monthly records of VOC emissions. A semi-annual report is required.
APPEARS IN COMPLIANCE- VOC emissions are calculated using stack test results, material balances,
and flow rates/concentrations on a monthly basis. These records are submitted to Ms. Compton within 30
days of the end of the previous month. Records indicate that the highest 12-month VOC emissions during
2020 were 4.84 tons which was lower than previously recorded due to installation of the thermal oxidizer.
The last semi-annual report was received at FRO on 0112712021 and appeared complete.
L. 15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS-Emissions from the resin process NS-G-1 and NS-G-2 shall not exceed 40 TPY VOC.
The Permittee shall keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS IN COMPLIANCE-Records indicate that the highest 12-month VOC emissions during 2020
were ll.51 tons. The last semi-annual summary report was received at FRO on 0112712021 and appeared
complete.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 8 of 15
M. 15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-A shall not exceed 85.3 TPY VOC. The Permittee
shall keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2020
were 18.44 tons. The last semi-annual summary report was received at FRO on 0112712021 and appeared
complete.
N. 15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the HFPO Product Container Decontamination Process(NS-N)shall not
exceed 40 TPY VOC. The Permittee shall keep monthly records of VOC emissions. The Permittee shall
also maintain records of dates each container is decontaminated and total mass of VOC removed from each
container. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Records indicate that the highest 12-month VOC emissions during 2018
were 3.05 tons. The last semi-annual report was received at FRO on 0112712021 and appeared complete.
O. 15A NCAC 02D.0530(u)USE OF PROJECTED ACTUAL EMISSIONS TO AVOID
APPLICABILITY OF REQUIREMENTS OF PSD—Requires the facility to maintain records of annual
VOC emissions from the IXM Membrane Coating Process(ID No.NS-I)for 10 years following the startup
of the modified process. An annual report is required within 60 days after the end of the calendar year. If
the projected actual emissions of 67.27 tons per year,as stated in the permit application,are exceeded,an
explanation as to why the actual rates exceeded the projection must be included in the annual report.
APPEARSIN COMPLIANCE—The IXMMembrane Coatingprocess modification started operation on
May 1, 2017. The Actual VOC emissions in 2018 were 40.4 tons. The startup notification was received at
FRO on 05108/17. The latest annual report was received at FRO on 0112 712 02 1 and appeared complete.
P. 15A NCAC 02D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY(MACT)40 CFR
Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The BFPO,Vinyl Ethers
North and South,and the IXM Resins processes(ID Nos.NS-A,NS-B,NS-13-2,NS-C,NS-C-2,NS-G-1,
and NS-G-2)must comply with all provisions of this MACT. The MON requires 99%control efficiency
for some Group 1 sources;however, Chemours determined that their sources are not subject to the stricter
requirements of a control device. The Permittee shall monitor and inspect all the valves,pumps,
compressors,agitators,and connectors for leaks using the instrument monitoring methods described in 40
CFR 63.1023(b)-(c). All equipment affected by the leak requirements shall be identified. The Permittee
shall create and retain a record of the monitoring schedule for each process unit. If a leak is identified,it
shall be repaired as provided in the repair provisions of this section. After a leak has been repaired,the
valve shall be monitored at least once within the first 3 months after its repair. This requirement is in
addition to the monitoring required to satisfy the defmition of repaired and first attempt at repair. The
required periodic monitoring may be used if it satisfies the timing requirement of this condition. The
Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days after it is
detected. The facility operates two process heat exchangers that are subject to the MON. Monitoring for
presence of a leak in a heat exchanger system requires that three samples of both the cooling water entrance
to and exit from the heat exchanger be monitored for the presence of hazardous air pollutants monthly for
the first six months of operation and quarterly thereafter. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—The scrubbers currently controlling the HFPO, Vinyl Ethers North and
South, and the IXM Resins processes(ID Nos.NS-A,NS-B,NS-B-2,NS-C,NS-C-2,NS-G-1, and NS-G-2)
meet the control efficiency requirement. The scrubbers were tested at 99.6%efficiency in August 2003
(further data indicates that the efficiency was only 99.1%). Initial notification was received on 2 March
2004. However, no controls are required for this facility based on HAP content, THE values, and other
various parameters. The facility has an extensive LDAR program, and inspects all the valves,pumps,
compressors, agitators, and connectors for leaks on a monthly basis. Records are available at the site.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 9 of 15
Each affected unit has a physical tag for equipment identification. Three samples of both the cooling
entrance and exit are taken at the heat exchangers to analyze for leaks on a monthly basis. The facility
also submits a semi-annual report for MACT Subpart FFFF There were no deviations from the emission
limits, operating limits, or work practice standards during 2020. The last semi-annual summary report
was received at FRO on 0112712021. Amore.extensive MACT FFFF report is submitted to EPA and FRO
also, which includes several items not required in the Title V permit but are required by the MALT. The
facility has a "zero leak"policy. If a leak is discovered, it is fixed ASAP, even if the process must be shut
down. No delay ofrepair scenarios are normally permitted by the facility's LDAR policy, but they are
allowed under the MA CT regulation. According to the facility records, no delays of repair occurred in any
of the facility processes during 2020.
Q. 15A NCAC 02Q.0519(a)(7)and CONSENT ORDER(State Enforceable Only)—The permittee shall
reduce emissions of all PFAS,including GenX Compounds, from the following sources:HFPO Process,
Vinyl Ethers North Process,Vinyl Ethers South Process,RSU Process,FPS Liquid Waste Stabilization
Process,MMF Process,E-2 Process,TFE/CO2 Separation Process,HFPO Product Container
Decontamination Process,VEN Product Decontamination Process,and VES Product Container
Decontamination Process(ID Nos. NS-A,NS-B,NS-C,NS-D-I,NS-E,NS-F,NS-G-I,NS-K,NS-M,NS-
N,NS-O,and NS-P)by the following:
• Install and begin normal operation of a Thermal Oxidizer in series with a 4-Stage Scrubber System(ID
Nos.NCD-QI and NCD-Q2).
• The Thermal Oxidizer and 4-Stage Scrubber System shall reduce emissions of all PFAS,including
GenX Compounds,by at least 99.99 percent.
The Permittee shall perform inspections and maintenance as recommended by the manufacturer. Develop,
and submit to DAQ for approval,a site-specific monitoring plan. Install, calibrate,maintain,and operate
CMS for the Thermal Oxidizer with a minimum combustion chamber temperature of 1800 degrees
Fahrenheit(3-hour rolling average)and maximum Thermal Oxidizer inlet gas feed rate 2,200 pounds per
hour(3-hour rolling average). Install,calibrate,maintain,and operate CMS for the 4-Stage Scrubber
System with the scrubber liquor flow shall be a minimum of 40 gallons per minute and a minimum
scrubber liquor pH,no less than 7.1 (3-hour rolling average). Quarterly reporting of monitoring and
recordkeeping activities.
APPEARS IN COMPLL4NCE- The following inspections were conducted for the thermal oxidizer and
scrubber system: Thermal Oxidizer on 1011512020; Scrubber Tank on 10/1512020; and Liquid Mist
Separator on 1012112020. The minimum combustion chamber temperature was 2017°F with a set point of
2012°F. The oxidizer inlet gas feed rate was 275 Ibs/hr. The scrubber liquid f ow was maintained at 86
gpm with a pH of 8.1. The operating parameters were well within the requirements of the current permit
during the inspection. The latest annual report was received at FRO on 0112712021 and appeared
complete.
+e Polymer Processing Aid(PPA)Process(all sources labeled with AS-and ACD-)
The polymer processing aid process,formerly the ammonium perfluorooctanoate(APFO)process,began
operation in December of 2002. Formerly,the Polymer Processing Aid reaction process used perfluorooctanoic
acid(PFOA-brought in by truck in its iodide/salt form)reacted with sodium hydroxide(stored in totes)to form
the acid fluoride. The acid fluoride was then reacted with ammonia to produce the ammonium salt. Fuming
sulfuric acid(oleum)is received by truck and used as a solvent in the process. Currently,APFO and the
associated(PFOA),also known as C8,are not regulated as toxic or hazardous air pollutants. However,the EPA
has been reviewing the chemical with the possibility of its designation in the future as a regulated pollutant. Due
to historical pollution and health effects concerns and recent controversy regarding the DuPont facility in West
Virginia,and the recent activities by the U.S.EPA to develop and review toxicity data for this chemical,the DAQ
file includes several documents and articles related to APFO,PFOA,or C8. The APFO process was subject to the
112(r)chemical accident prevention program for oleum. DuPont made a decision to eliminate APFO by 2015,
and therefore the PPA process at the Fayetteville Works was modified,and no longer produces APFO and is no
longer subject to 112(r)written risk management plan requirements. The replacement for APFO is HFPO Dimer

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 10 of 15
Acid,which is currently also under scrutiny.
R. 15A NCAC 02D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—
Emissions from the PPA facility shall be controlled by a wet scrubber. The liquid flow rate in the packed
bed section shall be a minimum of 30 gallons per minute and the differential pressure across the bed shall
be a maximum of 12 inches of water,based on three-hour averages. An alarm is required for the pressure
monitoring. Records of all inspections shall be kept in a logbook. No reporting is required.
APPEARS IN COMPLIANCE—The scrubber is interlocked so that the system will shut down, almost
instantaneously, if the parameters are exceeded The facility will go into shutdown mode if the three-hour
average is less than 30 gpm or pressure is 5 inches of water. The system is setup such that upon startup
after an extended shutdown, the scrubber must be operated for three hours to establish the minimum 3-hour
average prior to allowing the startup of the remaining equipment. The polymer processing aid chemical is
a surfactant; therefore, the AP increases occasionally due to 'suds'in the scrubber. The liquid flowrate
during the inspection was 38 gpm, and the pressure drop across the scrubber bed was-0.66"H2O. The
last internal inspection of the scrubber was performed on 1011912019.
6• Wastewater Treatment Area(all sources labeled with WTS-and WTCD-)
For the wastewater treatment operations,the Title V permit specifies two rotary sludge dryers controlled by an
impingement-type wet scrubber with mist eliminator. The Miscellaneous Organic NESHAP(MON)also
addresses emissions from wastewater. With respect to quantity of emissions,methanol is the most significant
air pollutant from the wastewater treatment operation.
S. 15A NCAC 02D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The
wastewater treatment facility shall not operate without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the property boundary. The sludge dryers shall be
controlled by a caustic injection scrubber. An I&M logbook is also required for the scrubber. No reporting
is required.
APPEARS IN COMPLIANCE—Odorous emissions from the sludge dryers are controlled by a scrubber
utilizing potassium hydroxide solution. Wastewater treatment odors were not noted at boundary lines. The
sludge dryers are located inside a building. The facility keeps maintenance records for the scrubber in
their electronic maintenance program. The most recent inspection of this scrubber was conducted on
0910912019. Ms. Compton stated that no odor complaints have been received by the facility. FRO has not
received any odor complaints relating to this facility.
•L Temporary Boiler(PS-Temp)
This boiler is permitted to combust Natural Gas/No.2 fuel oil and is brought on-site on an`as needed'basis.
There is currently no temporary boiler on site. The temporary boiler was last on site during the period 11/19/12
through 01/09/13 and utilized natural gas for fuel.
T. 15A NCAC 02D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS—Particulate emissions from the temporary boiler shall not exceed 0.2426 lbs/mmBtu.
No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.0071bs/mmBtu and for
No. 2 fuel oil is 0.0241bs/mmBTU The boiler was not on site during this inspection.
U. 15A NCAC 02D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—Sulfur
Dioxide emissions from the temporary boiler shall not exceed 2.3 lbhnmBtu heat input. No
monitoring/recordkeeping/reporting is required. The boiler was not on site during this inspection.
APPEARS IN COMPLIANCE—The AP-42 emission factor for Natural Gas is 0.00 1 lb/mmBtu and for

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 11 of 15
No. 2 fuel oil burning ultra-low sulfur content oil(< 15 ppm Sulfur by weight) is 0.002 lb/mmBtu.
Therefore, the source will not exceed the limits while combusting either of these permitted fuels. The boiler
was not on site during this inspection.
V. 15A NCAC 02D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions shall be no more
than 20%opacity. No monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The source was not on site during the inspection. While combusting
either natural gas or ff2 fuel oil, it is expected that there will be no visible emissions from this source(VE _
0%opacity).
W. 15A NCAC 02Q.0317 AVOIDANCE OF 15A NCAC 02D.0530 PREVENTION OF SIGNIFICANT
DETERIORATION—The temporary boiler PS-Temp shall discharge into the atmosphere less than 40
tons of S02 per consecutive 12-month period. Monthly records of fuel usage are required. Monthly
calculation of S02 emissions and rolling 12-month S02 emissions are required. A semi-annual report is
required.
APPEARS INCOMPLIANCE—The boiler was not onsite during this inspection. The last semi-annual
report was received at FRO on 0112712021 and appeared complete.
X. 15A NCAC 02Q.0317 AVOIDANCE OF 15A NCAC 02D.1109 CASE-BY-CASE MACT FOR
BOILERS AND PROCESS HEATERS AND OF 40 CFR 63 SUBPART DDDDD MACT FOR
BOILERS AND PROCESS HEATERS—The temporary boiler shall remain onsite for no longer than
180 consecutive days. If it is onsite for more than 180 consecutive days,the facility must notify the
regional office within 10 days of exceeding the 180-day period. A startup notification is required within 15
days after startup of the boiler.
APPEARS IN COMPLIANCE—The boiler was not onsite during 2020..No notifications have been
required.
•J Lime Silo and Slaker(all sources labeled with NS-and NCD-)
Lime processing system to process the weak hydrofluoric acid collected from the underflow of the scrubber
system. Aqueous 18 percent,by weight,HF acid from the Thermal Oxidizer/Scrubber system is introduced to a
Crystallizer with a lime slurry,where calcium fluoride(CaF2)crystals are formed.The CaF2 is dried in the filter
press and the solids are loaded into trucks for offske disposal. The facility receives pebble or hydrated calcium
oxide(CaO),or lime,which is stored in a lime silo prior to being mixed into a wet,calcium hydroxide lime
slurry in the Lime Slaker which is then fed to the Crystallizer.
Y. 15A NCAC 02D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the membrane coating process NS-Rl and NS-R2 shall not exceed
E=4.10*P0 6'. Install,operate,and maintain a wet scrubbing liquid flowmeter on each scrubber. Daily
records for daily scrubbing liquid flow rates(greater than 0.84 gallons per minute)are required.
Particulate matter emissions from the Lime Silo(ID Nos.NS-RI)shall be controlled by the bagfilter(ID
Nos.NSD-RI). Records are required for monthly visual and annual internal inspections. A semi-annual
summary report is required.
APPEARS IN COMPLIANCE—The initial permit application indicated that compliance would be
achieved based on the process description as permitted. No changes to the process have been made since
that application, and therefore compliance is indicated The scrubber system was not operating during the
inspection; however, the scrubbing liquid f ow rate was 1.7 gpm during the most recent date of operation
on 0113112021, Inspection records were provided by Ms. Compton for review during the onsite visit. The
last semi-annual summary report was received at FRO on 0 112 712 02 1 and appeared complete.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 12 of 15
Z. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS—Visible emissions from the Lime Silo
and Lime Slaker(ID Nos.NS-Rl and NS-R2)shall not be more than 20 percent opacity when averaged
over a six-minute period. Weekly observations for any visible emissions above normal and maintained in a
logbook. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—I observed 0%opacity from the Lime Silo and Lime Slaker during the
inspection. The last semi-annual summary report was received at FRO on 0112712021 and appeared
complete.
➢ Multiple Emission Source(s)Specific Limitations and Conditions
•- Boilers
AA.15A NCAC 02Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the boilers(PS-A,PS-B,PS-C,and PS-Temp)shall not exceed 702.5
tons of S02 per consecutive 12-month period. Records must be maintained for the quantities of fuels used
monthly. Fuel supplier certification must be maintained for fuel oil shipments. A semi-annual report is
required.
APPEARS IN COMPLIANCE—The highest 12-month rolling total S02 emissions during the past 15
months from the 4 boilers was 0.2 tons. Current fuel is natural gas. Fuel oil certifications are available in
the company records on site. #2 fuel oil used is ultra-low suer content(< 15 ppm sulfur by weight.)
Some No. 2 fuel oil was combusted in January 2018(28,350 gallons) during a short natural gas
curtailment. The last semi-annual report was received at FRO on 0112712021 and appeared complete.
C• Facility-Wide
BB.15A NCAC 02D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permittee shall maintain records of production rates,throughputs,material usage,excess emissions,and
control equipment failures. A quarterly summary report is required.
APPEARS IN COMPLIANCE—Production rates, material usages, emissions, and equipmentfailure
records are available on the company electronic data system. TAP reports are submitted quarterly and
show emissions well below the 2D.1100 limits. The last quarterly report was received at FRO on
0 112 712 02 1 and appeared complete.
CC.15A NCAC 02D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permittee shall emit less than the limits listed in the permit for HF from high dispersion stacks and from all
other sources. The Permittee shall also report quarterly all TPER exceedances,the maximum I-hour
emission rate and the maximum 24-hour emissions rate. The liquid flow rate in the Baffle Plate-Type
Scrubbers(NCD-Hdr-1 and NCD-Hdr-2)shall be a minimum 7,000 kg/hr each. Ensure the proper
performance of the Thermal Oxidizer and 4-Stage Scrubber System(ID Nos.NCD-QI and NCD-Q2)by
complying with the requirements specified in Consent Order. The Permittee shall maintain a logbook of all
inspection and maintenance activities on the applicable scrubber. A quarterly report is required.
APPEARS IN COMPLIANCE—The Baffle Plate-Type Scrubbers(NCD-Hdr-I and NCD-Hdr-2)are no
longer operational as ofstartup of the thermal oxidizer on 1213112019. The following inspections were
conducted for the thermal oxidizer and scrubber system: Thermal Oxidizer on 1011512020;Scrubber Tank
on 1011512020; and Liquid Mist Separator on 1012112020. The last quarterly report was received at FRO
on 0112712021 and appeared complete.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 13 of 15
DD.40 CFR Part 68 CHEMICAL ACCIDENT PREVENTION AND CLEAN AIR ACT<SECTION
112(r): The S03 process is subject to 112(r)for sulfur trioxide. The TFE process is subject to 112(r)for
Tetrafluoroethylene.
APPEARS IN COMPLIANCE—The facility submitted the written Risk Management Plan to the U.S. EPA
in June 1999. The facility was issued a facility identifier number 1000 0022 9647. In addition, the facility
is subject to the OSHA Process Safety Management(PSM)Standard. The latest update of the RMP was
submitted by the facility to EPA on 0712412019. The last full 112(r) compliance inspection was conducted
by Greg Reeves DAQ on 06121117. The facility appeared to be in compliance during that inspection.
The facility has the following processes subject to 112(r):
TFE Process 1 TFE(Tetrafluoroethylene) 591400
S03 Process 3 Sulfur Trioxide 61,000
EE.15A NCAC 02D.0541 CONTROL OF EMISSIONS FROM ABRASIVE BLASTING—Abrasive
blasting shall take place inside a building unless the item exceeds eight feet in length or is permanently
situated at an outside location. Fugitive emissions shall not migrate beyond the property boundaries.
APPEARS INCOMPLIANCE—The facility has an abrasive blasting building in which the sand blasting
occurs. Outside blasting of tanks and equipment is accomplished using shrouds to contain the blasting
materials.
FF. 15A NCAC 02D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The facility
shall not operate without implementing management practices or installing and operating odor control
equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
APPEARS IN COMPLIANCE—No objectionable odors were detected during the inspection. Ms.
Compton stated that no odor complaints have been received by the facility. No odor complaints have been
received by FRO regarding this facility.
•A Permit Application Submittal Requirement
GG. 15A NCAC 02Q.0504 OPTION FOR OBTAINING CONSTRUCTION AND OPERATION
PERMIT—The facility is required to submit an amended Title V permit application within 1 year from the
date of beginning normal operation of the Thermal Oxidizer(ID No.NCD-Ql),the 4-Stage Caustic
Scrubber(ID No.NCD-Q2),the Lime Silo(ID No.NS-RI),or the Lime Slaker(ID No.NS-R2). The
facility is also required to submit a notification of startup of this process within 30 days after the beginning
of normal operation.
APPEARS IN COMPLIANCE—The Startup date for TO and Caustic Scrubber was 12/31/2019. Startup
date for Lime Silo and Lime Slaker was 01/06/2020. Startup notification was received at FRO on
0112 712 02 0. The required permit application was submitted on 1111112020.

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 14 of 15
Facility-Wide
HH. 15A NCAC 02Q.0519(a)(7)and CONSENT ORDER(State Enforceable Only)—The permittee shall
reduce facility-wide annual emissions(including fugitive,maintenance,malfunction,or accidental
emissions)of GenX Compounds'to less than 23.027 pounds per year,which constitutes a 99 percent
reduction from the 2017 Total Reported Emissions of 2,302.7 pounds per year. Calculate annual emissions
monthly for previous 12 months. Install,operate, and maintain a Thermal Oxidizer and 4-Stage Scrubber
System(ID Nos.NCD-Ql and NCD-Q2). Performance testing required. Records of production data and
hours of operation;annual GenX Compound emissions; Carbon Adsorbers(ID Nos.ACD-A2,NCD-Q3,
NCD-Q4,and SCD-SW 1)inspection and maintenance;process shutdowns;inspections and calibrations of
monitoring equipment. Quarterly summary report required of monitoring and recordkeeping activities.
APPEARS IN COMPLIANCE—The annual GenX Compound emissions were 14.551 lbs/yr for 2020. The
following inspections were conducted for the Carbon Adsorbers(ID Nos.ACD-A2, NCD-Q3): 51712020,
1012212020, and NCD-Q4 is scheduled for maintenance in March 2021. Carbon Adsorber SCD-SWI has
not yet been installed. Performance testing is conducted as scheduled including submittal ofrequired test
_emission reports. The latest annual report was received at FRO on 0 112 712 02 1 and appeared complete.
➢ Permit Shield for Nonapplicable Requirements
II. Temporary Boiler(ID No.PS-TEMP)—This permit condition states that the boiler(ID No.PS-
TEMP)has been declared a temporary boiler,as is thus not subject to NESHAP Subpart DDDDD.
The facility must keep records documenting that the boiler meets the criteria of a temporary boiler.
The facility must also submit a startup notification within 15 days of startup of the boiler.
APPEARS IN COMPLIANCE—The boiler has not been brought onsite yet, so no notification or records
have been required
JJ. GENERAL CONDITION"I"REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND
PERMIT DEVIATIONS—Requires the facility to report incidents of excess emissions or deviations from
permit conditions.
APPEARS IN COMPLIANCE—Ms. Compton stated that no excess emission events occurred during
2020. There were no deviations from permit conditions occurred during 2020; therefore, no reporting was
required
KK. GENERAL CONDITION"K"PERMIT RENEWAL—If the permit renewal application is received at
least 6 months prior to the expiration of the permit,then the permit shall not expire until the renewal permit
has been issued or denied.
APPEARS IN COMPLLANCE—The renewal application was received more than 6 months prior to the
permit expiration date. This application was received 0910812020 and is currently in process.
LL. GENERAL CONDITION"P"COMPLIANCE CERTIFICATION [15A NCAC 2Q.0509(n)]: The
facility is required to submit an annual compliance certification to DAQ and EPA by March 1 of each year
for the previous calendar year.
APPEARS IN COMPLIANCE—The 2019 compliance certification was received at FRO on 0310112020.
The 2020 certification is due no later than 0310112021.
'"GenX Compounds"means HFPO Dimer Acid,also known as C3 Dimer Acid(CAS No. 13252-13-6);HFPO Dimer Acid Fluoride,also known
as C3 Dimer Acid Fluoride(CAS No.2062-98-8);and HFPO Dimer Acid Ammonium Salt,also known as C3 Dimer Acid Ammonium Salt
(CAS No.62037-80-3).

Chemours Company—Fayetteville Works
Compliance Inspection Report
Page 15 of 15
MM.GENERAL CONDITION 11X"ANNUAL EMISSION INVENTORY REQUIREMENTS—The
facility must submit an annual emission inventory by June 30 of each year.
APPEARS IN COMPLIANCE—The 2019 emission inventory was received at FRO on 0613012020 and
appeared complete.
NN. GENERAL CONDITION"MM"FUGITIVE DUST CONTROL REQUIREMENT—The facility
shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the property boundary.
APPEARS IN COMPLIANCE—I did not observe any dust accumulations nor observe any excess visible
emissions beyond the property boundary. Ms. Compton stated that no dust complaints have been received
by the facility. There have been no dust complaints received at FRO.
VII. NON-COMPLIANCE HISTORY SINCE 2010:
04/16/2026 NOV issued for failure to maintain minimum liquid flow rate for the Wet Particulate Scrubber
(1D No.NCD-R2): 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes
VIH. CONCLUSIONS AND RECOMMENDATIONS:
Based on the observations made during the 02/03/2021 inspection,Chemours Company—Fayetteville Works
APPEARS IN COMPLIANCE with the requirements outlined in their current air permit,03735T48.
M. PINK SHEET ITEMS:
Permit Engineer should evaluate removal of 15A NCAC 02D.1109 CASE-BY-CASE MACT during next permit
revision. The facility complied with this standard until May 19,2019 and is no longer applicable. The condition
was superseded by the requirements of NESHAP Subpart DDDDD beginning as of May 20,2019.
/elj