DEQ-CFW_00071473

Sands, Heather
From: JOHNSON, MICHAEL E <[e-mail]>
Sent: Friday, January 15, 2016 8:35 AM
To: Sands, Heather
Subject: RE: Quick question regarding your comments on the preliminary draft
Good morning Heather.
The short answer to your question is "Yes; these sources are no longer in use."
Here is the long answer:
The NS-J (Semiworks No. 3) was a short-lived Nafion® membrane -related process that was actually located in
what is now the Kuraray SentryGlasO Manufacturing Building. It produced treated membrane for a few years
in the late 1990's or early 2000's, and then we ceased that activity. It was really a glorified laboratory set-up,
and in today's permitting process it would have been an insignificant activity.
Until a few years ago, our tetrafluoroethylene ("TFE") raw material was shipped to this site as a blend of TFE
and anhydrous HCI. TFE is an extremely flammable gas, and by mixing it with the HCl gas it became non-
flammable, and hence safer to transport on the highway, from the standpoint of flammability not toxicity. The
NS-L (TFE/HCI separation unit) was the process that separated the TFE from the HCI. Then beginning some
number of years ago, we began receiving the TFE as a mixture with CO2 to make it non-flammable without the
toxicity concerns of the anhydrous HCI. That is when we constructed and began operating NS-M (TFE/CO2
separation unit) that separates the TFE from the CO2. As a result, the NS-L (TFE/HCI separation unit) unit
has been completely disassembled and removed.
ACD-A3 (building exhaust vent wet scrubber) was a "voluntary use only" wet scrubber that was installed
inside the PPA Process Building with the intent to further reduce the low emissions (about 50 lb/yr) of the
product that process produced. In April 2013, the PPA Process ceased producing that particular product, hence
the purpose of the wet scrubber disappeared. Also, that scrubber had tremendous operational problems,
therefore since the scrubber was "voluntary use only" it has not operated for the past couple years.
Let me know if you need any other information.
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
DEQ-CFW 00071473

From: Sands, Heather[mailto:[e-mail]]
Sent: Thursday, January 14, 2016 5:41 PM
To: JOHNSON, MICHAEL E <[e-mail]>
Subject: Quick question regarding your comments on the preliminary draft
Mike,
In your comments on the preliminary draft (August 31 email), you deleted NS-J (semiworks), NS-L (separation unit), and
ACD-A3 (building exhaust vent wet scrubber). Can you provide a brief explanation about why they are being removed.
Are these pieces of equipment no longer in use at your facility?
Once I get this cleared up, I think I am ready to send you the draft for review prior to sending this to notice.
Thanks!
Heather
Heather Sands
Environmental Engineer
Division of Air Quality
Department of Environmental Quality
919 707 8725 office
heather. sands(a)ncdenr.gov
217 West Jones Street
1641 Mail Service Center
Raleigh, NC 27699-1641
'NothingCompares---,,
Fc.
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DEQ-CFW 00071474

Sands, Heather
From: JOHNSON, MICHAEL E <[e-mail]>
Sent: Tuesday, January 12, 20161:08 PM
To: Sands, Heather
Cc: McGaughy, Ellis H; Cuilla, Mark
Subject: Title V Permit No. 03735T41 - Amended Section 2.1(C)(6)(c)(iii)
Attachments: Permit T41 - Amended HFPO.docx
Hi Heather.
I hope this request is not too late to be included with the permit renewal.
We wish to make a very, very small change to a section of the Title V Permit.
The HFPO Process is intending to make a modification that would allow a solid waste stream to be ultimately
converted into a raw material. The new equipment, the Solvent Reclamation Converters, will include a new
HFPO Process vent (Esxc) that is controlled by the existing wet scrubbers (ID No. NCD-Hdrl or NCD-Hdr2).
Section 2. 1 (C)(6)(c)(iii) specifies how the various process emissions are determined and used to calculate the
process VOC emissions (EP). This sentence and its associated equation needs to be modified to account for the
new process vent (EsRC) emissions.
I have attached a Word document with the addition shown in bolded blue. I also changed the equation
following this sentence to include EsRc but I am not clever enough to know how to change the color of the
equation's text nor how to make it bold.
I have cc'd our responsible official, Ellis McGaughy, on this email to convey his concurrence with this change.
Please let me know if you will be able to make this change to the renewal permit.
Thanks so much!
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
Chemours
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
DEQ-CFW 00071475

notified that any use, copying or distribution of this e-mail, in whoele or im part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitwte a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute .a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data totthird parties.
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DEQ-CFW 00071476

6. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the BFPO process (ID No. NS-A) shall
discharge into the atmosphere less than 85.3 tons of VOCs per consecutive 12-month period.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with
General Condition JJ. If the results of this test indicate annual emission rates in exceedance of
the limit given in Section 2.1 C.6.a above, the Permittee shall be deemed in noncompliance with
15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
To demonstrate compliance with the limit provided in Section 2.1 C.6.a, within 30 days of the
end of each calendar month the Permittee shall create and retain production records and estimate
associated VOC emissions for the previous calendar month, as follows:
i. Record the total raw material HFP consumed (MHFP) in the affected facility during the
previous calendar month;
ii. Record the average vent flow rate and composition from the AF column (Qnc) and Stripper
columns (Qsc) during the previous calendar month;
in. Using a combination of ratios of vent rates (Qnc and Qsc) to HFP consumption (MHFP) from
the process flowsheet and actual vent data, determine the process VOC emissions (EP) from
the AF column (Enc), stripper column (Esc), solvent recycle tank (EsRT), solvent reclamation
converters (EsRcl, and routine decontamination of HFP unloading system (EDc) through the
baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2).
E p = EAC + Esc + ESRT + ESRC + EDC
iv. Calculate the VOC emissions through the baffle -plate scrubber (ID No. NCD-Hdrl or NCD-
Hdr2) from maintenance activity (EM) based on vessel volumes and vapor density for each
occurrence of this activity during the previous calendar month.
v. Calculate the VOC emissions from fugitive emissions (EF) using accepted practices during
the previous calendar month.
vi. Record VOC emissions from any accidental releases (En) during the previous calendar
month.
vii. Calculate the VOC emissions (E) from the affected facility during the previous calendar
month (in lb/month) using the following equation:
E=Ep+EM+EF+EA
viii. Calculate the 12-month rolling VOC emissions from the affected facility by summing the
monthly VOC emissions (E), as calculated in 2.1 C.6.c.vii above, for the previous
consecutive 12-months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The Permittee shall be deemed in
noncompliance with 15A NCAC 21) .0530 if the above records are not created and retained, or if
the 12-month rolling VOC emission rate calculated in viii., above, exceeds the limit in Section
2.1 C.6.a of this permit.
DEQ-CFW 00071477

Sands, Heather
From:
JOHNSON, MICHAEL E <[e-mail]>
Sent:
Monday, January 11, 20161:26 PM
To:
Sands, Heather
Cc:
McGaughy, Ellis H; Cuilla, Mark
Subject:
RE: Toxics Limits, Section 2.2 B
Hi Heather.
If it does not cause you any trouble, I would like to leave the current TAP limits as they are... with the notable
exception of the typos you found for acrylonitrile and trichlorofluoromethane.
Thanks!
Mike
Michael E. Johnson, PE
Environmental Manager
Chemours Company — Fayetteville Works
[phone]
OC Chemours-
The Chemours Company FC, LLC
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
From: Sands, Heather [mailto:[e-mail]]
Sent: Monday, December 28, 2015 7:06 PM
To: JOHNSON, MICHAEL E <[e-mail]>
Cc: McGaughy, Ellis H <[e-mail]>; Cuilla, Mark <[e-mail]>
Subject: RE: Toxics Limits, Section 2.2 B
Mike,
I am continuing to work through your renewal and I'm not 100 percent sure that we came to an agreement on how you
would like us to proceed with regards to your toxics limits. I can't recall whether we discussed this over the phone or
not. I did send an email documenting our phone call on July 171h, indicating that you wanted to leave your toxics limits as
they are. But this email from August 13th makes me think that we may have decided to proceed with potentially revising
your toxics limits.
If we leave the toxics alone, I have noticed a couple of typos in the table. Other than the ones that are just editorial,
there are two I'd like you to be aware of:
1. The allowable emissions for acrylonitrile are 240 Ib/hr in the table. They should be 240 Ib/yr. This agrees with
the 1995 application and appears to have happened when the initial title V was issued.
2. The allowable emissions for trichlorofluoromethane are 491,077 lb/day. However, the AAL for that TAP is an
hourly standard. I think the emissions should be 8,185 Ib/hr (based on the 1995 application).
DEQ-CFW 00071478

Quick status update: the Boiler MACT went final last month and was issued on 11/20. I'm awaiting our permit shell
language so I can drop that in. Otherwise, I think I've addressed all of your comments. Those will be in the review.
Hope you had a great holiday!
Heather
Heather Sands
Environmental Engineer
Division of Air Quality
Department of Environmental Quality
919 707 8725 office
heather. sand s(o)ncdenr.aov
217 West Jones Street
1641 Mail Service Center
Raleigh, NC 27699-1641
FM_
!'--^ Nothing Compares -�-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Sands, Heather
Sent: Thursday, August 13, 2015 11:12 AM
To:'Johnson, Michael E'<[e-mail]>
Cc: '[e-mail]'<[e-mail]>; Cuilla, Mark ([e-mail])
<[e-mail]>
Subject: RE: Toxics Limits, Section 2.2 B
Mike,
Attached is the spreadsheet I prepared to analyze the toxics. This shows the four TAPs that are above the TPER. As I
discussed in the email below, other than perhaps getting agreement on which stack data applies to your current permit
(I think the ID numbers are not 100% transferable, but I may be able to decode it), we will do the modeling.
Let me know if you have any questions and whether you'd like us to proceed with reevaluating the toxics.
Thanks!
Heather
Htathersawds, Environmental Engineer
Permitting Section
NC DENR, Division of Air Quality
1641 Mail Service Center, Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
[e-mail]
DEQ-CFW 00071479

E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Sands, Heather
Sent: Wednesday, July 15, 2015 1:48 PM
To:'Johnson, Michael E' <MICHAEL.E.JOHNSON chemours.com>
Cc: 'Ellis. [e-mail]' <[e-mail]>; Cuilla, Mark ([e-mail])
<[e-mail]>
Subject: Toxics Limits, Section 2.2 B
Mike,
I am looking at the toxics limits in Section 2.2 of the permit and wanted to let you know that our toxics rules have
changed. Therefore:
1. You are eligible to remove, from the toxics limits, those sources that are no longer on your permit.
2. You are also eligible to remove, from those limits, the sources that are subject to MACT/GACT, including
combustion sources, pending an unacceptable risk review.
3. Finally, you maybe able to remove the toxics limit from your permit all together.
The steps for going through all of this are:
1. We will use your emission inventory data and conduct a modeling analysis to demonstrate that there is no
unacceptable risk from all sources at your facility. (NOTE: if the current analysis we have is more than five years
old, we may need you to verify that none of the stack parameters and flow rates have changed.)
2. We will use this same inventory data for the nonexempt source (i.e., those not subject to MACT/GACT, etc.) we
will determine whether or not your facility wide emissions exceed the toxic air pollutant permitted emission
rates.
3. Depending upon the first two, and your approval, we may be able to remove or at least revise the toxics limits.
Please confirm that you are in agreement with this process and would like for us to proceed (please respond to all on
this email). It is an option to leave the limits in the permit as they exist, so please let us know if you would rather just
leave them alone. As always, please contact me if you have any questions or comments.
Thanks!
Heather
Heather Bawds, Environmental Engineer
Permitting Section
NC DENR, Division of Air Quality
1641 Mail Service Center, Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
[e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
DEQ-CFW 00071480

the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
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4
DEQ-CFW 00071481

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 Ghemours-
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)
I
DEQ-CFW 00071482

• earn efficiency credits from implementation of energy conservation measures 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
1-leather.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
[e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records
Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
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F
DEQ-CFW 00071483

Sands, Heather
From: Johnson, Michael E <[e-mail]>
Sent: Wednesday, July 15, 2015 12:30 PM
To: Sands, Heather
Cc: McGaughy, Ellis H
Subject: Title V Air Permit 03735T39 : Boiler Fuels vs. MACT Requirements
Heather.
Regarding the subject Title V renewal permit, please proceed with permitting our main boiler (ID No. PS -A) as
a unit designed to burn gas 1 subcategory and permitting our backup boiler (ID No. PS-B) as a unit designed to
light liquid subcategory.
I have cc'd Ellis McGaughy, the Responsible Official for this facility, on this 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
This communication is for use by the intended recipient and contains information that may be Privileged,
confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally
notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify
the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously
designated as "E-Contract Intended. This e-mail does not constitute a contract offer, a contract amendment, or
an acceptance of a contract offer. This e-mail does not constitute a consent to the use of sender's contact
information for direct marketing purposes or for transfers of data to third parties.
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DEQ-CFW 00071484