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ROY COOPER NORTH CAROLINA
Governor Environmental Quailty
MICHAEL S.REGAN
Secretory
MICHAEL ABRACZINSKAS
Director
January 27, 2020
Mr. Christel Compton
Environmental Manager
Chemours Company FC, LLC
22828 NC Highway 87 West
Fayetteville,North Carolina 28306
Subject: Chemours Company—Fayetteville Works
Fayetteville, Bladen County,North Carolina
Air Permit No.03735T46, Facility ID 0900009
Thermal Oxidizer/Four-Stage Scrubber Emissions Testing
Proposed Test Date: February 03-05, 2020
DAQ Tracking No. 2020-008ST
Dear Ms. Compton:
North Carolina Division of Air Quality(NCDAQ)has reviewed the protocol submitted by
Chemours on December 06, 2019 for the subject testing and deemed it acceptable. Chemours
has proposed testing of the inlet feeds to the thermal oxidizer and the outlet of the four-stage
scrubber system to determine emission rates and destruction removal efficiency(DRE) of certain
fluorinated compounds.
The purpose for this testing is to determine compliance with the emissions reductions of certain
per- and polyfluorinated alkyl substances(PFAS) as required by the February 26, 2019 Consent
Order and the associated Title V permit requirements. These reductions are to be determined, in
part, through simultaneous inlet and outlet emissions testing on the new emissions control system
consisting of the thermal oxidizer and four-stage scrubber. Two sampling methods will be used
during the testing. The first sampling method is a modified Method 18 chilled methanol midget-
impinger method. This sampling method is a proportional, non-isokinetic sampling method and
is used at both the inlet and the outlet sampling locations. This method will be used to quantify
several PFAS compounds that represent a significant proportion of the total mass of
perfluorinated chemicals potentially emitted by the various processes at the Fayetteville Works.
In addition, this method will also be used to quantify HFPO C3 dimer acid at the inlet side of the
thermal oxidizer. The second sampling method is a modified SW-846 Method 0010. This
RE Q
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707.8400

Ms. Christel Compton
January 27, 2020
Page 2
sampling method will be used at the outlet of the four-stage scrubber and will sample for C3-
HFPO dimer acid isokinetically. Both methods have been used previously to quantify emissions
of specific perfluorinated chemicals at the Chernours facility.
The proposed test methods are acceptable for the purpose of the sampling of the inlet and outlet
of the thermal oxidizer/four-stage scrubber. Approval of the protocol does not exempt the
tester from meeting other sampling requirements and QA/QC procedures not specifically
addressed in the protocol and otherwise incorporated by reference into the test method. Any
modifications to the test method that may deemed to be necessary during the performance testing
is subject to review and approval by the NCDAQ. All test data are subject to review of actual in-
field sampling procedures,process operations during testing, and QA/QC review of the
analytical methods. Any confidential business information(CBI) should be identified in the
report provided to NCDAQ. In the event that CBI is included in the report to NCDAQ, a
redacted or nonconfidential version of the report should also be provided to NCDAQ for public
availability. Note that emissions rate data may not be claimed as confidential or proprietary
business information.
If you have any questions,please feel free to contact me at [phone] or
gary.saunders@,ncdenr.gov.
Sincerely,
Gary L. Saunders, Supervisor
Stationary Source Compliance Branch
Division of Air Quality,NCDEQ
cc: Greg Reeves and Heather Carter, Fayetteville Regional Office
Central Files, Bladen County
IBEAM Documents-0900009