DEQ-CFW_00067503

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Chemours-
The Chemours Company 910-483-46810
Fluoroproducts chemours.com
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
RECEIVED
JUL 13 2016
CERTIFIED MAIL ARTICLE NUMBER 7002 0860 0006 9104 7927 DEQ-FAYETTEVILLE REGIONAL OFFICE
RETURN RECEIPT REQUESTED
July 8, 2016
Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301-5095
SUBJECT: Title V Air Quality Permit — Deviation and Excess Emissions
Chemours Company — Fayetteville Works
Bladen County, North Carolina
Air Permit No. 03735T42
Facility ID: 06/09-0900009
Dear Mr. Vozzo:
Pursuant to Section 3(I.A)(2)(a) and Section 3(I.A.)(3)(a) of the subject Title V permit, this
letter is the required notification of excess emissions and a state -enforceable -only permit
deviation of an emissions limitation for methylene chloride specified in Section 2.2(B)(1) of
the subject permit, which is the rule regulating North Carolina toxic air pollutant emissions
per 15A NCAC 2D .1100. That rule sets a facility -wide emission limit of 24.85 pounds of
methylene chloride per hour.
Methylene chloride (dichloromethane) is used as the heat -transfer liquid ("brine")
throughout the site's FPS/IXM Process Area, On June 29, 2016, a relief valve in the brine
system opened due to a pressure spike, but failed to reseat, which resulted in a release of
methylene chloride into the FPS Vinyl Ethers South manufacturing area's exhaust stack.
This release from the brine system resulted in 3,900 pounds of methylene chloride being loss
from the Brine Storage Tank. Approximately 4,200 pounds of liquid methylene chloride
was recovered from the Vinyl Ethers South area. Therefore it is obvious that only a small
quantity of methylene chloride was actually lost to the atmosphere.
DEQ-CFW 00067503

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Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
July 8, 2016
Page 2 of 3
The SAFER Real -Time air dispersion computer model was used to estimate the
volatilization rate from a quiescent pool of methylene chloride of a size comparable to the
bottom of the Vinyl Ethers South stack. The model predicted an evaporation rate of 371b/hr,
which would be overstated since the model assumed the methylene chloride to be at the 90OF
actual temperature that day versus the liquid's initial temperature of -33°F. However the
model also did not take into account the large updraft of air through the stack, which would
have likely increased the volatilization rate.
It is therefore assumed that the emission of methylene chloride during the 5-hour period
from the beginning of the release to the completion of the removal of liquid methylene
chloride from the area was 37 lb/hr, which exceeded the Section 2.2(B)(1) limit of 24.85
lb/hr methylene chloride.
As required by 15A NCAC 02D .0535(f)(1), the NC-DAQ Fayetteville Regional Office was
notified on June 29, 2016, of the methylene chloride release and permit deviation via a
telephone call to Mr. Gregory Reeves. At the time of that call, it was not understood that
the excess emissions would exceed four (4) hours in duration.
As required by 15A NCAC 02D .0535(f)(3), this letter is the written report to NC-DAQ and
each specified rule requirement is addressed below.
02D .0535(f)(3)(A): Name and location of the facility
Chemours Company — Fayetteville Works; 22828 NC Highway 87 W, Fayetteville, NC
02D .0535(f)(3)(B): Identification or description of the processes and control devices
involved in the malfunction or breakdown
Methylene chloride heat -transfer liquid system in the site's FPS/IXM Process Area.
02D .0535(f)(3)(C): The cause and nature of the event
The Vinyl Ethers South brine system's relief valve has a reseating pressure that is less
than the normal operating pressure of the brine system in that area. As such, when the
relief valve properly opened due to a pressure spike in the brine system, the valve was
unable to reseat. This resulted in a continuous flow of methylene chloride from the
relief valve until the release was discovered and a circulation pump was stopped, which
allowed the valve to immediately reseat and stop the release.
02D .0535(f)(3)(D): Time and duration of the violation
The methylene chloride release began at approximately 10:00 a.m. on July 29, 2016,
and was discovered and stopped at approximately 11:00 a.m. The removal of liquid
methylene chloride from the area was completed at approximately 3:00 p.m. on July 29,
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Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
July 8, 2016
Page 3 of 3
2016. Therefore the duration of the emission of methylene chloride to the atmosphere
was approximately five (5) hours.
02D .0535(f)(3)(E): Estimated quantity of pollutant emitted
Based on a predicted volatilization rate by an air dispersion computer model, it is
estimated that 37 lb/hr of methylene chloride was emitted to the atmosphere during the
5-hour duration of the incident. To account for additional volatilization that might have
occurred as the incoming methylene chloride traveled countercurrent to the stack's
updraft of forced air, the first hour is being conservatively assumed to be five times (5X)
the predicted volatilization rate or 185 pounds. The total conservative estimated
quantity of emissions would then be 333 pounds of methylene chloride.
02D .0535(f)(3)(F): Steps taken to control the emissions and to prevent recurrences
The Vinyl Ethers South brine system's relief valve is being replaced by one with a
reseating pressure that is greater than the normal operating pressure of the brine system.
In addition, all other relief valves in the brine system will be reviewed and replaced if
any are found whose reseating pressure is less than the normal operating pressure.
02D .0535(f)(3)(G): Any other pertinent information requested by the Director
If additional information is needed, please contact Michael Johnson at [phone].
To comply with the requirement of Section 3(D) of the subject permit, the required
photocopy of this letter is enclosed.
By my signature below, I certify that I believe the information contained in this letter is true,
accurate, and complete.
Sincerely,
Ellis H. McGaughy
Plant Manager
DEQ-CFW 00067505