DEQ-CFW_00067518

Sands, Heather
From: Johnson, Michael E <[e-mail]>
Sent: Wednesday, July 29, 2015 8:32 AM
To: Sands, Heather
Subject: RE: Few more boiler questions, etc.
Heather: See your attached email.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
it Chemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Sands, Heather[mailto:[e-mail]]
Sent: Tuesday, July 28, 2015 2:16 PM
To: Johnson, Michael E <[e-mail]>
Subject: Few more boiler questions, etc.
Hi Mike,
I am plugging through the renewal and have some more specific questions for the boiler MACT requirements. Hopefully,
these won't be too rough.
1. Do PS -A and/or PS-B have oxygen trim systems? Will PS-C have an oxygen trim system? These will impact the
frequency of the tuneups. YES... all boilers, present and future, have an oxygen trim system.
2. How do you want PS-C permitted? Right now it is also a natural gas/No. 2 fuel oil -fired unit. I know that you have
not built it. Are you still planning to and want to retain it on the permit? If so, do you want it as a unit designed
to burn gas 1 or a unit designed to burn light liquid fuel? YES... we want to retain the future 3rd boiler
(PS-C) on the permit. That boiler should be designated as a unit designed to burn gas 1, just like
the site's main boiler (PS -A).
3. With respect to PS-B and performance testing, you have some compliance options that I wanted to discuss with
you. These come from a presentation from EPA:
• comply with alternate TSM limit instead of PM limit.
• comply with alternate output -based limit instead of input -based limit.
• comply with alternate CO CEMS based limit instead of CO stack based limit.
• comply with mercury, HCI, or TSM limits by fuel analysis instead of by performance stack test.
• comply by emission averaging (§63.7522)
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DEQ-CFW 00067518

• earn efficiency credits froaplementation of energy conservation Aures to comply with output -based
limits (§63.7533)
I need to think about this offer, but the one that seemingly sounds the best is the fuel
analysis. That one sounds like we would not have to mess with the annual performance (stack)
testing, which would be great since we rarely burn fuel oil. Do you have more guidance
information on that option? If not I know it is in the regs, but I think it is merely a statement
instead of a detailed method.
I know these are pretty detailed, but I don't want to clutter up the permit by putting all the options in if you
know how you want to do this. For this one, it might be better if we walk through it a little.
Also, were you able to find any documentation on the modeling by any chance?
Please let me know about the boilers as soon as you can because I will need to have those answers to put the boiler
language in.
Thanks so much!
Heather
I tenther Sawds, Environmental Engineer
Permitting Section
NC DENR, Division of Air Quality
1641 Mail Service Center, Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
heather.sandsCa ncdenr.gov
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