HomeMy WebLinkAbout2019.02.06_CCO.p7.Fluoromonomers Manufacturing Process Scrubber Efficiency Test ReportIASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019
FLUOROMONOMERS
MANUFACTURING PROCESS
SCRUBBER EFFICIENCY TEST REPORT
TEST DATES: 6 AND 7 DECEMBER 2018
THE CHEMOURS COMPANY
FAYETTEVILLE, NORTH CAROLINA
Prepared for:
THE CHEMOURS COMPANY
22828 NC Hwy 87 W
Fayetteville, North Carolina 28306
Prepared by:
WESTON SOLUTIONS, INC.
1400 Weston Way
P.O. Box 2653
West Chester, Pennsylvania 19380
6 February 2019
W.O. No. 15418.002.008
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 i
TABLE OF CONTENTS
Section Page
1. INTRODUCTION..............................................................................................................1
1.1 FACILITY AND BACKGROUND INFORMATION ...........................................1
1.2 TEST OBJECTIVES ...............................................................................................1
1.3 TEST PROGRAM OVERVIEW .............................................................................1
2. SUMMARY OF TEST RESULTS ...................................................................................4
3. PROCESS DESCRIPTIONS ............................................................................................5
3.1 FLUOROMONOMERS ..........................................................................................5
3.2 PROCESS OPERATIONS AND PARAMETERS .................................................5
4. DESCRIPTION OF TEST LOCATIONS .......................................................................6
4.1 DIVISION SCRUBBER INLET .............................................................................6
4.2 DIVISION STACK (DIVISION SCRUBBER OUTLET) ......................................6
4.3 VINYL ETHERS NORTH CARBON BED OUTLET ...........................................6
5. SAMPLING AND ANALYTICAL METHODS ...........................................................10
5.1 STACK GAS SAMPLING PROCEDURES .........................................................10
5.1.1 Pre-Test Determinations .........................................................................10
5.2 STACK PARAMETERS .......................................................................................10
5.2.1 EPA Method 0010...................................................................................10
5.2.2 EPA Method 0010 Sample Recovery .....................................................13
5.2.3 EPA Method 0010 Sample Analysis.......................................................14
5.3 DIVISION SCRUBBER INLET ...........................................................................16
5.3.1 Modified EPA Method 0010 ...................................................................16
5.3.2 Modified EPA Method 0010 Sample Recovery .....................................18
5.3.3 Modified EPA Method 0010 Sample Analysis .......................................19
5.4 GAS COMPOSITION ...........................................................................................21
6. DETAILED TEST RESULTS AND DISCUSSION .....................................................24
TABLE OF CONTENTS (CONTINUED)
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 ii
APPENDIX A PROCESS OPERATIONS DATA
APPENDIX B RAW AND REDUCED TEST DATA
APPENDIX C LABORATORY ANALYTICAL REPORT
APPENDIX D SAMPLE CALCULATIONS
APPENDIX E EQUIPMENT CALIBRATION RECORDS
APPENDIX F LIST OF PROJECT PARTICIPANTS
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 iii
LIST OF FIGURES
Title Page
Figure 4-1 Division Scrubber Inlet Schematic............................................................................... 7
Figure 4-2 Division Stack Test Port and Traverse Point Location ................................................ 8
Figure 4-3 VE North Process Carbon Bed Outlet Schematic ........................................................ 9
Figure 5-1 EPA Method 0010 Sampling Train ............................................................................. 11
Figure 5-2 HFPO Dimer Acid Sample Recovery Procedures for Method 0010 ......................... 15
Figure 5-3 Modified EPA Method 0010 Sampling Train ............................................................ 17
Figure 5-4 HFPO Dimer Acid Sample Recovery Procedures for Modified Method 0010 ......... 20
Figure 5-5 WESTON Sampling System ...................................................................................... 22
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 iv
LIST OF TABLES
Title Page
Table 1-1 Sampling Plan for Division Scrubber Testing ................................................................ 3
Table 2-1 Summary of HFPO Dimer Acid Scrubber Test Results ................................................. 4
Table 6-1 Summary of HFPO Dimer Acid Test Data and Test Results Division Scrubber Inlet –
Runs 2, 3, and 4..................................................................................................................... 26
Table 6-2 Summary of HFPO Dimer Acid Test Data and Test Results Carbon Bed Outlet – Runs
2, 3, and 4 .............................................................................................................................. 28
Table 6-3 Summary of HFPO Dimer Acid Test Data and Test Results Division Stack – Runs 2,
3 and 4 ................................................................................................................................... 30
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 1
1. INTRODUCTION
1.1 FACILITY AND BACKGROUND INFORMATION
The Chemours Fayetteville Works (Chemours) is located in Bladen County, North Carolina,
approximately 10 miles south of the city of Fayetteville. Chemours operating areas on the site
include the Fluoromonomers, IXM and Polymers Processing Aid (PPA) manufacturing areas,
Wastewater Treatment, and Powerhouse.
Chemours contracted Weston Solutions, Inc. (WESTON) to perform HFPO Dimer Acid
Fluoride, captured as HFPO Dimer Acid, emission testing on the Division Scrubber at the
facility. Testing was performed on 6 and 7 December 2018 and generally followed the “Emission
Test Protocol” reviewed and approved by the North Carolina Department of Environmental
Quality (NCDEQ). This report provides the results from the emission test program.
A single test run was previously performed on 14 November 2018. The VE North process was
not operating at typical conditions and no further testing was performed during that mobilization.
That test run (run number 1) was considered not representative and is not included in this report.
The subsequent three test run series was therefore labeled test runs 2, 3 and 4.
1.2 TEST OBJECTIVES
The specific objectives for this test program were as follows:
Measure the emissions concentrations and mass emissions rates of HFPO Dimer Acid
Fluoride from the Division waste gas scrubber inlet and outlet which are located in the
Fluoromonomers process area.
Calculate the scrubber removal efficiency for HFPO Dimer Acid.
Monitor and record process and emissions control data in conjunction with the test
program.
Provide representative emissions data.
1.3 TEST PROGRAM OVERVIEW
During the emissions test program, the concentrations and mass emissions rates of HFPO Dimer
Acid were measured at three locations.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 2
Table 1-1 provides a summary of the test locations and the parameters that were measured along
with the sampling/analytical procedures that were followed.
Section 2 provides a summary of test results. A description of the processes is provided in
Section 3. Section 4 provides a description of the test locations. The sampling and analytical
procedures are provided in Section 5. Detailed test results and discussion are provided in
Section 6.
Appendix C includes the summary reports for the laboratory analytical results. The full
laboratory data packages are provided in electronic format and on CD with each hard copy.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 3
Table 1-1
Sampling Plan for Division Scrubber Testing
Sampling Point & Location Division Scrubber
Number of Tests: 9 (3 Scrubber inlet, 3 Carbon Bed outlet, 3 Division stack)
Parameters To Be Tested: HFPO Dimer
Acid
(HFPO-DA)
Volumetric
Flow Rate and
Gas Velocity
Carbon
Dioxide
Oxygen Water Content
Sampling or Monitoring Method EPA M-0010 EPA M1, M2,
M3A, and M4
in conjunction
with M-0010
tests
EPA M3/3A EPA M4 in
conjunction
with M-0010
tests
Sample Extraction/ Analysis Method(s): LC/MS/MS NA6 NA NA
Sample Size ≥ 1.5m3 NA NA NA NA
Total Number of Samples Collected1 9 9 9 9 9
Reagent Blanks (Solvents, Resins)1 1 set 0 0 0 0
Field Blank Trains1 1 per source 0 0 0 0
Proof Blanks1 1 per train 0 0 0 0
Trip Blanks1,2 1 set 0 0 0
Lab Blanks 1 per fraction3 0 0 0 0
Laboratory or Batch Control Spike Samples
(LCS) 1 per fraction3 0 0 0 0
Laboratory or Batch Control Spike Sample
Duplicate (LCSD) 1 per fraction3 0 0 0 0
Media Blanks 1 set4 0 0 0 0
Isotope Dilution Internal Standard Spikes Each sample 0 0 0 0
Total No. of Samples 135 9 9 9 9
Key:
1 Sample collected in field.
2 Trip blanks include one XAD-2 resin module and one methanol sample per sample shipment.
3 Lab blank and LCS/LCSD includes one set per analytical fraction (front half, back half and condensate).
4 One set of media blank archived at laboratory at media preparation.
5 Actual number of samples collected in field.
6 Not applicable.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 4
2. SUMMARY OF TEST RESULTS
A total of three test runs were performed on the Division scrubber inlet and outlet (stack).
Table 2-1 provides a summary of the HFPO Dimer Acid emissions test results and scrubber
removal efficiencies. Detailed test results summaries are provided in Section 6.
It is important to note that emphasis is being placed on the characterization of the emissions
based on the stack test results. Research conducted in developing the protocol for stack testing
HFPO Dimer Acid Fluoride, HFPO Dimer Acid Ammonium Salt and HFPO Dimer Acid
realized that the resulting testing, including collection of the air samples and extraction of the
various fraction of the sampling train, would result in all three compounds being expressed as
simply the HFPO Dimer Acid. However, it should be understood that the total HFPO Dimer
Acid results provided on Table 2-1 and in this report include a percentage of each of the three
compounds.
Table 2-1
Summary of HFPO Dimer Acid Scrubber Test Results
Inlet Outlet(1) Removal
Efficiency
g/sec lb/hr g/sec lb/hr %
Division Waste Gas Scrubber
R2 3.59E-2 2.85E-1 3.43E-2 2.72E-1 4.4
R3 6.17E-3 4.90E-2 9.66E-3 7.67E-2 NC
R4 6.11E-3 4.85E-2 1.75E-2 1.39E-1 NC
Average 1.60E-2 1.27E-1 2.05E-2 1.63E-1 NC
(1) The scrubber outlet mass rates are derived from the HFPO Dimer Acid (Adjusted Emissions) calculated by
subtracting the measured Carbon Bed outlet mass rates from the measured Division Stack mass rates.
NC = Not calculated
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 5
3. PROCESS DESCRIPTIONS
The Fluoromonomers area is included in the scope of this test program.
3.1 FLUOROMONOMERS
These facilities produce a family of fluorocarbon compounds used to produce Chemours
products such as Nafion®, Krytox®, and Viton®, as well as sales to outside customers.
Process emissions are vented to the Division waste gas scrubber.
3.2 PROCESS OPERATIONS AND PARAMETERS
The following table is a summary of the operation and products from the specific areas tested.
Source Operation/Product Batch or Continuous
Division PPVE Semi-continuous – Condensation is a continuous
Agitated Bed Reactor, Refining (ether column) is
batch
During the test program, the following parameters were monitored by Chemours and are
included in Appendix A.
Fluoromonomers Process
o VEN Precurser Rate
o VEN Condensation Rate
o VEN ABR Rate
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 6
4. DESCRIPTION OF TEST LOCATIONS
4.1 DIVISION SCRUBBER INLET
The Division scrubber inlet consists of a nominal 3-inch ID vertical pipe equipped with a single
¼-inch OD sample port. Due to the small size of the inlet pipe and sample port, non-isokinetic
sampling was performed at a single point inside the pipe. Gas flow rates were recorded by a
CHEMOURS mass flow meter mounted on the inlet piping. See Figure 4-1.
4.2 DIVISION STACK (DIVISION SCRUBBER OUTLET)
The Division Scrubber outlet emissions were measured at the Division stack and were
determined by subtracting the emissions measured from the Carbon Bed exit (which also
exhausts to the Division stack) from the total emissions measured at the Division stack.
Two 6-inch ID test ports were installed on the 36-inch ID fiberglass stack as shown below. The
four vents that enter the top of the stack and the one vent ~11 feet below are catch pots which,
under normal process operations, do not discharge to the stack. They are used to vent process gas
to the stack in the event of a process upset and are not considered a flow contributor or a
disturbance.
Per EPA Method 1, a total of 12 traverse points (six per axis) were used for M-0010 isokinetic
sampling. Figure 4-2 provides a schematic of the test ports and traverse point locations.
4.3 VINYL ETHERS NORTH CARBON BED OUTLET
The fiberglass reinforced plastic (FRP) duct at the outlet of the Division carbon bed is 34-inch
ID. The test ports are located as shown below. Based on EPA Method 1, a total of 24 traverse
points (12 per port) were required for HFPO Dimer Acid sampling at the test location. Figure 4-3
provides a schematic of the test port and traverse port locations.
Location Distance from Flow Disturbance
Downstream (B) Upstream (A)
Carbon Bed Outlet 58 inches > 1.7 duct diameters 57 inches > 1.5 duct diameters
Division Stack 30 feet > 10 duct diameters 9 feet > 3 diameters
~ 3 "
FIGURE 4-1
DIVISION SCRUBBER INLET SCHEMATIC
IASDATA\CHEMOURS\15418.002.008\FIGURE 4-1 DIVISION SCRUBBER INLET
7
DRAWING NOT TO SCALE
~ 6 "
TO SCRUBBER
MICRO
MOTION
FLOW
SENSOR
SAMPLE PORT
36 "
TRAVERSE
POINT
NUMBER
DISTANCE FROM
INSIDE NEAR
WALL (INCHES)
1
2
3
4
5
6
FIGURE 4-2
DIVISION STACK TEST PORT
AND TRAVERSE POINT LOCATIONS
IASDATA\CHEMOURS\15418.002.008\FIGURE 4-2 DIVISION STACK8
~ 9 '
BUILDING
EXHAUST
ID FAN
DISCHARGE
CATCH POT
~
~
~
~~~~~
CATCH POT VENTS
DRAWING NOT TO SCALE
~ 30 '
~ 128 "
1 5/8
5 3/8
10 7/8
26
31 5/8
33 3/8
34 "TRAVERSE
POINT
NUMBER
DISTANCE FROM
INSIDE NEAR
WALL (INCHES)
1
2
3
4
5
6
7
8
9
10
11
12
FIGURE 4-3
VE NORTH PROCESS CARBON BED OUTLET SCHEMATIC
IASDATA\CHEMOURS\15418.002.008\FIGURE 4-3 VE NORTH PROCESS SCHEMATIC9
ID
FAN
CARBON BED
3/4
2 1/4
4
6
8 1/2
12 1/8
21 5/8
25 1/2
28
30
31 3/4
33 1/4
DRAWING NOT TO SCALE
57 "
58 "
INLET OUTLET
CEMENT BLOCK WALL
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 10
5.SAMPLING AND ANALYTICAL METHODS
5.1 STACK GAS SAMPLING PROCEDURES
The purpose of this section is to describe the stack gas emissions sampling trains and to provide
details of the stack sampling and analytical procedures utilized during the emissions test
program.
5.1.1 Pre-Test Determinations
Preliminary test data were obtained at each test location. Stack geometry measurements were
measured and recorded, and traverse point distances verified. A preliminary velocity traverse
was performed utilizing a calibrated S-type pitot tube and an inclined manometer to determine
velocity profiles. Flue gas temperatures were observed with a calibrated direct readout panel
meter equipped with a chromel-alumel thermocouple. Preliminary water vapor content was
estimated by wet bulb/dry bulb temperature measurements.
A check for the presence or absence of cyclonic flow had previously been conducted at each test
location. The cyclonic flow checks were negative (< 20°) verifying that the test locations were
acceptable for testing.
Preliminary test data was used for nozzle sizing and sampling rate determinations for isokinetic
sampling procedures.
Calibration of probe nozzles, pitot tubes, metering systems, and temperature measurement
devices was performed as specified in Section 5 of EPA Method 5 test procedures.
5.2 STACK PARAMETERS
5.2.1 EPA Method 0010
The sampling train utilized to perform the HFPO Dimer Acid sampling at the outlet locations
was an EPA Method 0010 train (see Figure 5-1). The Method 0010 consisted of a borosilicate
nozzle that attached directly to a heated borosilicate probe. In order to minimize possible thermal
degradation of the HFPO Dimer Acid, the probe and particulate filter were heated above stack
temperature to minimize water vapor condensation before the filter. The probe was
VENTWALLICE WATER RECIRCULATION PUMPCONDENSATE TRAPIMPINGERSICE BATHVACUUM LINEMAINVALVETEMPERATURESENSORSBY-PASS VALVEAIR-TIGHT PUMPDRY GAS METERORIFICEMANOMETERCHECKVALVETEMPERATURESENSORHEATED AREAFILTER HOLDERORIFICESILICA GELCONDENSERXAD-2 SORBENTMODULES ONE AND TWOTEMPERATURESENSORTEMPERATURESENSORVACUUMGAUGEIASDATA\CHEMOURS\15418.002.008\FIGURE 5-1 METHOD 0010FIGURE 5-1EPA METHOD 0010 SAMPLING TRAINHEATED PROBE/BUTTON HOOKNOZZLEREVERSE TYPEPITOT TUBE11 NOTE: THE CONDENSER MAY BE POSITIONED HORIZONTALLY. THE XAD-2 SORBENT MODULE WILL ALWAYS BE IN A VERTICAL POSITION..RIGID BOROSILICATE TUBINGOR FLEXIBLE SAMPLE LINEICE WATERRECIRCULATIONCONDENSATE TRAPIMPINGER
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 12
connected directly to a heated borosilicate filter holder containing a solvent extracted glass fiber
filter.
A section of borosilicate glass [or flexible polyethylene tubing (Division stack and carbon bed
outlet only)] connected the filter holder exit to a Grahm (spiral) type ice water-cooled condenser,
an ice water-jacketed sorbent module containing approximately 40 grams of XAD-2 resin. The
XAD-2 resin tube was equipped with an inlet temperature sensor. The XAD-2 resin trap was
followed by a condensate knockout impinger and a series of two impingers that contained 100-
ml of high purity distilled water. The train also included a second XAD-2 resin trap behind the
impinger section to evaluate possible sampling train breakthrough. Each XAD-2 resin trap was
connected to a 1-L condensate knockout trap. The final impinger contained 300 grams of dry
pre-weighed silica gel. All impingers and the condensate traps were maintained in an ice bath.
Ice water was continuously circulated in the condenser and both XAD-2 modules to maintain
method-required temperature. A control console with a leakless vacuum pump, a calibrated
orifice, and dual inclined manometers was connected to the final impinger via an umbilical cord
to complete the sample train.
HFPO Dimer Acid Fluoride (CAS No. 2062-98-8) that is present in the stack gas is expected to
be captured in the sampling train along with HFPO Dimer Acid (CAS No. 13252-13-6). HFPO
Dimer Acid Fluoride undergoes hydrolysis instantaneously in water in the sampling train and
during the sample recovery step and will be converted to HFPO Dimer Acid such that the
amount of HFPO Dimer Acid emissions represents a combination of both HFPO Dimer Acid
Fluoride and HFPO Dimer Acid.
During sampling, gas stream velocities were measured by attaching a calibrated S-type pitot tube
into the gas stream adjacent to the sampling nozzle. The velocity pressure differential was
observed immediately after positioning the nozzle at each traverse point, and the sampling rate
adjusted to maintain isokineticity ± 10. Flue gas temperature was monitored at each point with a
calibrated panel meter and thermocouple. Isokinetic test data was recorded at each traverse point
during all test periods, as appropriate. Leak checks were performed on the sampling apparatus
according to reference method instructions, prior to and following each run, component change
(if required) or during midpoint port changes.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 13
5.2.2 EPA Method 0010 Sample Recovery
At the conclusion of each test, the sampling train was dismantled, the openings sealed, and the
components transported to the field laboratory trailer for recovery.
A consistent procedure was employed for sample recovery:
1. The two XAD-2 covered (to minimize light degradation) sorbent modules (1 and 2) were
sealed and labeled.
2. The glass fiber filter(s) were removed from the holder with tweezers and placed in a
polyethylene container along with any loose particulate and filter fragments.
3. The particulate adhering to the internal surfaces of the nozzle, probe and front half of the
filter holder were rinsed with a solution of methanol and ammonium hydroxide into a
polyethylene container while brushing a minimum of three times until no visible
particulate remains. Particulate adhering to the brush was rinsed with methanol/
ammonium hydroxide into the same container. The container was sealed.
4. The volume of liquid collected in the first condensate trap was measured, the value
recorded, and the contents poured into a polyethylene container.
5. All train components between the filter exit and the first condensate trap were rinsed with
methanol/ammonium hydroxide. The solvent rinse was placed in a separate polyethylene
container and sealed.
6. The volume of liquid in impingers one and two, and the second condensate trap, were
measured, the values recorded, and the sample was placed in the same container as Step 4
above and sealed.
7. The two impingers, condensate trap, and connectors were rinsed with methanol/
ammonium hydroxide. The solvent sample was placed in a separate polyethylene
container and sealed.
8. The silica gel in the final impinger was weighed and the weight gain value recorded.
9. Site (reagent) blank samples of the methanol/ammonium hydroxide, XAD resin, filter
and distilled water were retained for analysis.
Each container was labeled to clearly identify its contents. The height of the fluid level was
marked on the container of each liquid sample to provide a reference point for a leakage check
during transport. All samples were maintained cool.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 14
During each test campaign, a Method 0010 blank train was set up near the test location, leak-
checked and recovered along with the respective sample train. Following sample recovery, all
samples were transported to TestAmerica Laboratories, Inc. (TestAmerica) for sample extraction
and analysis.
See Figure 5-2 for a schematic of the Method 0010 sample recovery process.
5.2.3 EPA Method 0010 – Sample Analysis
Method 0010 sampling trains resulted in four separate analytical fractions for HFPO Dimer Acid
analysis according to SW-846 Method 3542:
Front-Half Composite—comprised of the particulate filter, and the probe, nozzle, and
front-half of the filter holder solvent rinses;
Back-half Composite—comprised of the first XAD-2 resin material and the back-half of
the filter holder with connecting glassware solvent rinses;
Condensate Composite—comprised of the aqueous condensates and the contents of
impingers one and two with solvent rinses;
Breakthrough XAD-2 Resin Tube—comprised of the resin tube behind the series of
impingers.
The second XAD-2 resin material was analyzed separately to evaluate any possible sampling
train HFPO-DA breakthrough.
The front- and back-half composites and the second XAD-2 resin material were placed in
polypropylene wide-mouth bottles and tumbled with methanol containing 5% NH4OH for 18
hours. Portions of the extracts were processed analytically for the HFPO dimer acid by liquid
chromatography and duel mass spectroscopy (HPLC/MS/MS). The condensate composite was
concentrated onto a solid phase extraction (SPE) cartridge followed by desorption from the
cartridge using methanol. Portions of those extracts were also processed analytically by
HPLC/MS/MS.
IASDATA\CHEMOURS\15418.002.008\FIGURE 5-2 EPA 0010FIGURE 5-2HFPO DIMER ACID SAMPLE RECOVERY PROCEDURES FOR METHOD 0010NOZZLE, PROBE ANDFRONT-HALF FILTER HOLDERSAMPLE FRACTION 2FILTERSAMPLE FRACTION 1BACK-HALF FILTER HOLDER CONNECTORS, FLEXIBLE LINE CONDENSER SAMPLE FRACTION 5XAD-2 MODULE ONESAMPLE FRACTION 3REMOVE FROM IMPINGER TRAINWASH WITH NANOGRADE METHANOL/AMMONIUM HYDROXIDESEAL IN LABELED POLYETHYLENE BOTTLE. COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLWASH WHILE BRUSHING WITH NANOGRADE METHANOL/ AMMONIUM HYDROXIDESEAL ENDS WITH GLASS CAPS, COVER, LABEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AT AND KEEP COOLTRANSFER WASHINGS TO POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLSEAL WASHINGS IN LABELED POLYETHYLENE BOTTLE. MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLFIRST AND SECOND CONDENSATE TRAPS AND IMPINGER NOS. 1 AND 2SAMPLE FRACTION 4IMPINGER NO. 4 (SILICA GEL)WEIGH AND RECORDMEASURE VOLUME OF LIQUID AND RECORDTRANSFER WASHINGS TO POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOL15 WEIGH AND RECORDRETAIN FOR REGENERATIONFIRST AND SECOND CONDENSATE TRAPS AND IMPINGER NOS. 1 AND 2SAMPLE FRACTION 6WASH WITH NANOGRADE METHANOL/AMMONIUM HYDROXIDETRANSFER WASHINGS TO POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLXAD-2 MODULE TWOSAMPLE FRACTION 7REMOVE FROM IMPINGER TRAINSEAL ENDS WITH GLASS CAPS, COVER, LABEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AT AND KEEP COOL
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 16
Samples were spiked with isotope dilution internal standard (IDA) at the commencement of their
preparation to provide accurate assessments of the analytical recoveries. Final data was
corrected for IDA standard recoveries.
TestAmerica developed detailed procedures for the sample extraction and analysis for HFPO
Dimer Acid. These procedures were incorporated into the test protocol.
5.3 DIVISION SCRUBBER INLET
The purpose of this section is to describe the Division scrubber inlet sampling train and to
provide details of the sampling and analytical procedures utilized during the emissions test
program.
Due to the anticipated elevated levels of HFPO Dimer Acid at the scrubber inlet, the previously
used EPA Method 0010 train was modified. In addition, the small diameter scrubber inlet vent
and associated vent access were not conducive to isokinetic sampling. As a result, the EPA
Method 0010 HFPO Dimer Acid sample train was modified for non-isokinetic low volume
sampling.
5.3.1 Modified EPA Method 0010
The sampling train utilized to perform the HFPO Dimer Acid sampling at the Division scrubber
inlet was a modified EPA Method 0010 train (see Figure 5-3). The modified Method 0010 train
consisted of an unheated section of tubing (SS, Teflon® or plastic) to be used as the sample
probe.
The section of tubing connected directly to a series of three Teflon® impingers, each containing
400 ml of KOH solution and then connected to an ice water-jacketed sorbent module containing
approximately 40 grams of XAD-2 resin. The XAD-2 resin tube was equipped with an inlet
temperature sensor. The XAD-2 resin trap was followed by a condensate knockout impinger and
a series of two impingers containing 100 mls of high-purity distilled water. The train included a
VENTWALLICE WATER RECIRCULATION PUMPCONDENSATE TRAPIMPINGERSICE BATHVACUUM LINEMAINVALVETEMPERATURESENSORSBY-PASS VALVEAIR-TIGHT PUMPDRY GAS METERORIFICEMANOMETERCHECKVALVETEMPERATURESENSORORIFICESILICA GELXAD-2 SORBENTMODULES ONE AND TWOTEMPERATURESENSORVACUUMGAUGEIASDATA\CHEMOURS\15418.002.008\FIGURE 5-3 MODIFIED METHOD 0010FIGURE 5-3MODIFIED EPA METHOD 0010 SAMPLING TRAINWASTE GAS SCRUBBER INLET17 NOTE:THE XAD-2 SORBENT MODULE WILL ALWAYS BE IN A VERTICAL POSITION.CONDENSATE TRAPIMPINGERDRAWING NOT TO SCALETEFLON IMPINGERSFLEXIBLE SAMPLE TUBING
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 18
second XAD-2 resin trap behind the impinger section to evaluate possible sampling train
breakthrough. Each XAD-2 resin trap was connected to a condensate knockout trap. The final
impinger contained 300 grams of dry pre-weighed silica gel. All impingers and the condensate
traps were maintained in an ice bath. Ice water was continuously circulated in the XAD-2
module to maintain method-required temperature. A control console with a leakless vacuum
pump, a calibrated orifice, and dual inclined manometers was connected to the final impinger via
an umbilical cord to complete the sample train.
Leak checks were performed on the sampling apparatus according to reference method
instructions, prior to and following each run, component change (if required).
5.3.2 Modified EPA Method 0010 Sample Recovery
At the conclusion of each test, the sampling train was dismantled, the openings sealed, and the
components transported to the field laboratory trailer for recovery.
A consistent procedure was employed for sample recovery:
1. The two XAD-2 covered (to minimize light degradation) sorbent modules (1 and 2) were
sealed and labeled.
2. Any particulate adhering to the internal surfaces of the front tubing section (probe) to the
initial Teflon® impinger was rinsed with distilled water into a polyethylene container.
The container was sealed.
3. The volume of each Teflon® impinger was measured. The contents of the first two
Teflon® impingers were combined and the impingers and connectors rinsed with distilled
water. This sample and rinse were combined with the sample collected in Step 2 above
and the container was sealed.
4. The third Teflon® impinger contents and associated distilled water rinse were sealed in a
separate container.
5. The volume of liquid collected in the first condensate trap was measured, the value
recorded, and the contents poured into a polyethylene container.
6. All train components starting with the first Teflon® impinger to the first condensate trap
were rinsed with methanol/ammonium hydroxide. The solvent rinse was placed in the
same container as Step 4 above and sealed.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 19
7. The volume of liquid in impingers one and two, and the second condensate trap, was
measured, the values recorded, and the sample was placed in the same container as Step 5
above and sealed.
8. The two impingers, condensate traps, and connectors were rinsed with methanol/
ammonium hydroxide. The sample was placed in the same container as Step 6 above and
sealed.
9. The silica gel in the final impinger was weighed and the weight gain value recorded.
10. Site (reagent) blank samples of the KOH, methanol/ammonium hydroxide, XAD resin,
and distilled water were retained for analysis.
Each container was labeled to clearly identify its contents. All samples were maintained cool.
See Figure 5-4 for a schematic of the M0010 sample recovery process.
5.3.3 Modified EPA Method 0010 – Sample Analysis
The modified Method 0010 sampling train described above resulted in six separate analytical
fractions for HFPO Dimer Acid analysis according to SW-846 Method 3542:
Initial two Teflon® Impingers – comprised of the contents of impingers one and two and
the probe and impinger rinses;
Final Teflon® Impinger – comprised of the impinger three contents and the rinses;
Back-half Composite—comprised of the first XAD-2 resin material;
Condensate Composite—comprised of the aqueous condensates and the contents of
impingers one and two;
The solvent rinses for the condensate traps and impingers;
Breakthrough XAD-2 Resin Tube—comprised of the resin tube behind the series of
impingers.
The second XAD-2 resin material was analyzed separately to evaluate any possible sampling
train HFPO-DA breakthrough.
IASDATA\CHEMOURS\15418.002.008\FIGURE 5-4 MODIFIED EPA 0010FIGURE 5-4HFPO DIMER ACID SAMPLE RECOVERY PROCEDURES FOR MODIFIED METHOD 0010WASTE GAS SCRUBBER INLET PROBE AND FRONT-HALF RINSESAMPLE FRACTION 1XAD-2 MODULE ONESAMPLE FRACTION 4REMOVE FROM IMPINGER TRAINWASH WITH NANOGRADE METHANOL/ AMMONIUM HYDROXIDERECORD MOISTURE WEIGHT GAINSEAL ENDS WITH GLASS CAPS, COVER, LABEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AT AND KEEP COOLSEAL WASHINGS IN LABELED POLYETHYLENE BOTTLE. MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLFIRST AND SECOND CONDENSATE TRAPS AND IMPINGER NOS. 1 AND 2SAMPLE FRACTION 5FINAL IMPINGER(SILICA GEL)MEASURE VOLUME OF LIQUID AND RECORDTRANSFER TO POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOL20 WEIGH AND RECORDRETAIN FOR REGENERATIONFIRST AND SECOND CONDENSATE TRAPS AND IMPINGER NOS. 1 AND 2SAMPLE FRACTION 6WASH WITH NANOGRADE METHANOL/AMMONIUM HYDROXIDETRANSFER WASHINGS TO POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AND KEEP COOLXAD-2 MODULE TWOSAMPLE FRACTION 7REMOVE FROM IMPINGER TRAINSEAL ENDS WITH GLASS CAPS, COVER, LABEL, COMPLETE CUSTODY FORM, SECURE SAMPLE AT AND KEEP COOLFIRST AND SECOND TEFLON IMPINGERSSAMPLE FRACTION 2MEASURE VOLUME OF LIQUID AND RECORDWASH WITH METHANOL/AMMONIUM HYDROXIDETRANSFER WASHINGS TO A POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL.COMPLETE CUSTODY FORM.SECURE SAMPLE AND KEEP COOL.THIRD TEFLON IMPINGERSSAMPLE FRACTION 3MEASURE VOLUME OF LIQUID AND RECORDWASH WITH METHANOL/AMMONIUM HYDROXIDETRANSFER WASHINGS TO A POLYETHYLENE BOTTLE; LABEL, SEAL AND MARK LIQUID LEVEL.COMPLETE CUSTODY FORM.SECURE SAMPLE AND KEEP COOL.COMBINE WITH FRACTION 2
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 21
The individual sample composites and the second XAD-2 resin material were placed in
polypropylene wide-mouth bottles and tumbled with methanol containing 5% NH4OH for 18
hours. Portions of the extracts were processed analytically for the HFPO dimer acid by liquid
chromatography and duel mass spectroscopy (HPLC/MS/MS). The condensate composite was
concentrated onto a solid phase extraction (SPE) cartridge followed by desorption from the
cartridge using methanol. Portions of the final extracts were processed analytically by
HPLC/MS/MS.
Samples were spiked with isotope dilution internal standard (IDIS) at the commencement of their
preparation to provide accurate assessments of the analytical recoveries. Final data was corrected
for isotope dilution standard recoveries.
5.4 GAS COMPOSITION
The WESTON mobile laboratory equipped with instrumental analyzers was used to measure
carbon dioxide (CO2) and oxygen (O2) concentrations. A diagram of the WESTON sampling
system is presented in Figure 5-5.
The sample was collected at the exhaust of the Method 0010 sampling system. At the end of the
line, a tee permitted the introduction of calibration gas. The sample was drawn through a heated
Teflon® sample line to the sample conditioner. The output from the sampling system was
recorded electronically, and one-minute averages were recorded and displayed on a data logger.
Each analyzer was set up and calibrated internally by introduction of calibration gas standards
directly to the analyzer from a calibration manifold. The calibration manifold is designed with an
atmospheric vent to release excess calibration gas and maintained the calibration at ambient
pressure. The direct calibration sequence consisted of alternate injections of zero and mid-range
gases with appropriate adjustments until the desired responses were obtained. The high-range
standards were then introduced in sequence without further adjustment.
HEATEDSAMPLEPROBESTACK WALLHEATED FILTERHOLDER OR METHOD0010 SAMPLE TRAINHEATED SAMPLE LINESAMPLECONDITIONINGSYSTEMMOISTUREREMOVALVENTCO2O2GASANALYZERSACQUISTIONINTERFACEANALOGSIGNALLINECOMPUTER FOR DATAACQUISITION ANDREDUCTIONSAMPLEPUMPCALIBRATIONGASES= ON / OFF VALVECALIBRATION BIAS LINEFIGURE 5-5WESTON SAMPLING SYSTEMIASDATA\CHEMOURS\15418.002.008\FIGURE 5-5 WESTON SAMPLING SYSTEM22
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 23
The sample line integrity was verified by performing a bias test before and after each test period.
The sampling system bias test consisted of introducing the zero gas and one up-range calibration
standard in excess to the valve at the probe end when the system was sampling normally. The
excess calibration gas flowed out through the probe to maintain ambient sampling system
pressure. Calibration gas supply was regulated to maintain constant sampling rate and pressure.
Instrument bias check response was compared to internal calibration responses to insure sample
line integrity and to calculate a bias correction factor after each run using the ratio of the
measured concentration of the bias gas certified by the calibration gas supplier.
The oxygen and carbon dioxide content of each stack gas was measured according to EPA
Method 3A procedures which incorporate the latest updates of EPA Method 7E. A Servomex
Model 4900 analyzer (or equivalent) was used to measure oxygen content. A Servomex Model
4900 analyzer (or equivalent) was used to measure carbon dioxide content of the stack gas. Both
analyzers were calibrated with EPA Protocol gases prior to the start of the test program and
performance was verified by sample bias checks before and after each test run.
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 24
6. DETAILED TEST RESULTS AND DISCUSSION
Preliminary testing of inlet samples to the scrubbers and the associated analytical results required
significant sample dilution to bring the HFPO Dimer Acid concentration within instrument
calibration, therefore, sample times and sample volumes were reduced for the formal test
program. This was approved by the North Carolina Department of Environmental Quality
(NCDEQ).
Each test was a minimum of 90 minutes in duration. A total of three test runs were performed at
each location.
Tables 6-1 through 6-3 provide detailed test data and test results for the Scrubber inlet, the
Carbon Bed outlet and the Division stack, respectively.
The Method 3A sampling on all sources indicated that the O2 and CO2 concentrations were at
ambient air levels (20.9% O2, 0% CO2), therefore, 20.9% O2 and 0% CO2 values were used in all
calculations.
The Division stack includes emissions from the Carbon Bed outlet. These emissions have been
subtracted from the Division stack results.
The waste gas scrubber inlet location presents many sampling and analytical challenges. The
vertical duct is nominal 3 inch ID with a ¼-inch ID sample port. Due to the small size, isokinetic
sampling cannot be performed. This may have resulted in a bias of unknown value. In addition,
gas volumetric flow rates are not measured using standard EPA Method 2 equipment. However,
volumetric flow is measured by the Chemours flow meter. The flow meter is calibrated to the
mole weight of nitrogen which cannot be verified by actual gas composition sampling, and
therefore may also lead to an additional bias. The gas stream is also known to contain elevated
concentrations of HF, and this required additional sampling train modifications to mitigate the
effects of HF on the pH of the impinger solutions by adding KOH impingers to the first portion
of the sample train. Although this modification appeared to help control the pH, a method
validation study for this sampling and analytical approach has not been performed. Additional
concerns for sampling at this location include the process variability and how that may affect
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019 25
sample parameters, the inability to confirm laminar verses cyclonic flow, and the accurate
collection of particulates, if present, all add to the potential bias of the test results. In
conclusion, the waste gas scrubber inlet sample location and associated test results are outside
approved sampling procedures, and the above deviations from approved procedures have been
and continue to result in variable data sets and should not be used for regulatory compliance
purposes.
All three test runs performed at the VE North Carbon Bed Outlet were below the acceptance
criteria for isokinetic sampling (90 to 110%). This was due to the dry gas meter calibration factor
used at that sample location shifting prior to the performance of the tests. The post-test
calibration check revealed that the calibration factor was off by approximately 10%. The post-
test calibration acceptance criteria is 5%. Please note that this could potentially result in an over
estimate of larger diameter particulate captured on the sample train filter. However, the sample
location is after the Carbon Bed, therefore, larger size particulate was not expected. In addition,
the results have been reported using the post-test calibration factor for each test run which results
in a more conservative (lower) calculation of removal efficiency.
TEST DATA
Test run number 2 3 4
Location VEN Scrubber Inlet VEN Scrubber Inlet VEN Scrubber Inlet
Test date 12/06/18 12/06/18 12/07/18
Test time period 0906-1141 1356-1547 0842-1038
SAMPLING DATA
Duration, minutes 96 96 96
Average dry gas meter press. in. H2O 1.81 2.00 2.00
Average dry gas meter temp. deg. F 46.35 50.75 52.40
Average absolute meter temp. deg. R 506.4 510.8 512.4
Sample vol. at meter cond., dcl 96.123 96.115 96.072
Meter box calibration, Y 1.0088 1.0088 1.0088
Barometric pressure, in. Hg 30.38 30.38 30.38
Sample volume, dscl (1)103.077 102.228 101.854
Sample volume, dscf (1)3.63972 3.610 3.597
VOLUMETRIC FLOW RATE
Avg. gas stream volumetric flow, kg/hr (from Chemours)111.0 111.0 108.0
Avg. gas stream density, g/liter (from Chemours)1.204 1.204 1.204
Avg. gas stream volumetric flow, liters/hr 92192.7 92192.7 89701.0
Avg. gas stream volumetric flow, dscf/min.54.265 54.265 52.798
(1) Standard conditions = 68 deg. F. (20 deg. C.) and 29.92 inches Hg (760mm Hg).
TABLE 6-1
CHEMOURS-FAYETTEVILLE, NC
INPUTS FOR HFPO DIMER ACID CALCULATIONS
VE NORTH SCRUBBER INLET
2/6/201910:29 AM 26 120618 VEN scrubber inlet
2/6/201910:44 AM 27 120618 VEN scrubber inlet.xlsx
TABLE 6-1 (cont.)
CHEMOURS - FAYETTEVILLE, NC
SUMMARY OF HFPO DIMER ACID TEST DATA AND TEST RESULTS
TEST DATA
Run number 2 3 4
Location VEN Scrubber Inlet VEN Scrubber Inlet VEN Scrubber Inlet
Date 12/06/18 12/06/18 12/07/18
Time period 0906-1141 1356-1547 0842-1038
LABORATORY REPORT DATA, ug.
HFPO Dimer Acid 144464 24629 24980.4
EMISSION RESULTS, ug/dscm.
HFPO Dimer Acid 1.40E+06 2.41E+05 2.45E+05
EMISSION RESULTS, lb/dscf.
HFPO Dimer Acid 8.75E-05 1.50E-05 1.53E-05
EMISSION RESULTS, lb/hr.
HFPO Dimer Acid 2.85E-01 4.90E-02 4.85E-02
EMISSION RESULTS, g/sec.
HFPO Dimer Acid 3.59E-02 6.17E-03 6.11E-03
TABLE 6-2
CHEMOURS - FAYETTEVILLE, NC
SUMMARY OF HFPO DIMER ACID TEST DATA AND TEST RESULTS
VE NORTH CARBON BED OUTLET
Test Data
Run number 2 3 4
Location VEN-CBed Outlet VEN-CBed Outlet VEN-CBed Outlet
Date 12/06/18 12/06/18 12/07/18
Time period 0906-1141 1356-1547 0842-1038
SAMPLING DATA:
Sampling duration, min. 96.0 96.0 96.0
Nozzle diameter, in. 0.215 0.215 0.215
Cross sectional nozzle area, sq.ft. 0.000252 0.000252 0.000252
Barometric pressure, in. Hg 30.38 30.38 30.38
Avg. orifice press. diff., in H2O 1.62 1.58 1.59
Avg. dry gas meter temp., deg F 39.8 51.5 47.0
Avg. abs. dry gas meter temp., deg. R 500 511 507
Total liquid collected by train, ml 17.7 16.5 19.1
Std. vol. of H2O vapor coll., cu.ft. 0.8 0.8 0.9
Dry gas meter calibration factor 1.1203 1.0679 1.0873
Sample vol. at meter cond., dcf 50.751 53.181 52.139
Sample vol. at std. cond., dscf (1)61.203 59.734 60.149
Percent of isokinetic sampling 90.7 90.3 90.2
GAS STREAM COMPOSITION DATA:
CO2, % by volume, dry basis 0.0 0.0 0.0
O2, % by volume, dry basis 20.9 20.9 20.9
N2, % by volume, dry basis 79.1 79.1 79.1
Molecular wt. of dry gas, lb/lb mole 28.84 28.84 28.84
H20 vapor in gas stream, prop. by vol. 0.013 0.013 0.015
Mole fraction of dry gas 0.987 0.987 0.985
Molecular wt. of wet gas, lb/lb mole 28.69 28.70 28.68
GAS STREAM VELOCITY AND VOLUMETRIC FLOW DATA:
Static pressure, in. H2O 3.50 3.50 3.50
Absolute pressure, in. Hg 30.64 30.64 30.64
Avg. temperature, deg. F 69 77 74
Avg. absolute temperature, deg.R 529 537 534
Pitot tube coefficient 0.84 0.84 0.84
Total number of traverse points 24 24 24
Avg. gas stream velocity, ft./sec. 46.1 45.9 46.0
Stack/duct cross sectional area, sq.ft. 6.31 6.31 6.31
Avg. gas stream volumetric flow, wacf/min. 17456 17359 17419
Avg. gas stream volumetric flow, dscf/min. 17578 17238 17368
(1) Standard conditions = 68 deg. F. (20 deg. C.) and 29.92 in Hg (760 mm Hg)
2/6/2019 10:41 AM
28
120618 VEN CBed OUTw new gamma
VE NORTH CARBON BED OUTLET
TEST DATA
Run number 2 3 4
Location
VEN-CBed
Outlet
VEN-CBed
Outlet
VEN-CBed
Outlet
Date 12/06/18 12/06/18 12/07/18
Time period 0906-1141 1356-1547 0842-1038
LABORATORY REPORT DATA, ug.
HFPO Dimer Acid 56.55 47.54 49.94
EMISSION RESULTS, ug/dscm.
HFPO Dimer Acid 32.62 28.10 29.32
EMISSION RESULTS, lb/dscf.
HFPO Dimer Acid 2.04E-09 1.75E-09 1.83E-09
EMISSION RESULTS, lb/hr.
HFPO Dimer Acid 2.15E-03 1.81E-03 1.91E-03
EMISSION RESULTS, g/sec.
HFPO Dimer Acid 2.70E-04 2.28E-04 2.40E-04
TABLE 6-2 (cont.)
CHEMOURS - FAYETTEVILLE, NC
SUMMARY OF HFPO DIMER ACID TEST DATA AND TEST RESULTS
2/6/2019 10:42 AM
29
120618 VEN CBed OUTw new gamma
TABLE 6-3
CHEMOURS - FAYETTEVILLE, NC
SUMMARY OF HFPO DIMER ACID TEST DATA AND TEST RESULTS
VE-NORTH DIVISION STACK
Test Data
Run number 2 3 4
Location Divison-Stack Divison-Stack Divison-Stack
Date 12/06/18 12/06/18 12/07/18
Time period 0906-1141 1356-1547 0842-1038
SAMPLING DATA:
Sampling duration, min. 96.0 96.0 96.0
Nozzle diameter, in. 0.160 0.160 0.160
Cross sectional nozzle area, sq.ft. 0.000140 0.000140 0.000140
Barometric pressure, in. Hg 30.38 30.23 30.25
Avg. orifice press. diff., in H2O 1.27 1.25 1.17
Avg. dry gas meter temp., deg F 57.5 58.0 55.6
Avg. abs. dry gas meter temp., deg. R 517 518 516
Total liquid collected by train, ml 9.4 10.1 9.3
Std. vol. of H2O vapor coll., cu.ft. 0.4 0.5 0.4
Dry gas meter calibration factor 1.0150 1.0150 1.0150
Sample vol. at meter cond., dcf 59.384 59.402 57.068
Sample vol. at std. cond., dscf (1)62.615 62.257 60.120
Percent of isokinetic sampling 104.6 102.4 100.5
GAS STREAM COMPOSITION DATA:
CO2, % by volume, dry basis 0.0 0.0 0.0
O2, % by volume, dry basis 20.9 20.9 20.9
N2, % by volume, dry basis 79.1 79.1 79.1
Molecular wt. of dry gas, lb/lb mole 28.84 28.84 28.84
H20 vapor in gas stream, prop. by vol. 0.007 0.008 0.007
Mole fraction of dry gas 0.993 0.992 0.993
Molecular wt. of wet gas, lb/lb mole 28.76 28.75 28.76
GAS STREAM VELOCITY AND VOLUMETRIC FLOW DATA:
Static pressure, in. H2O -0.70 -0.70 -0.70
Absolute pressure, in. Hg 30.33 30.18 30.20
Avg. temperature, deg. F 64 70 67
Avg. absolute temperature, deg.R 524 530 527
Pitot tube coefficient 0.84 0.84 0.84
Total number of traverse points 12 12 12
Avg. gas stream velocity, ft./sec. 73.3 75.9 74.2
Stack/duct cross sectional area, sq.ft. 7.07 7.07 7.07
Avg. gas stream volumetric flow, wacf/min. 31113 32188 31472
Avg. gas stream volumetric flow, dscf/min. 31567 32060 31565
(1) Standard conditions = 68 deg. F. (20 deg. C.) and 29.92 in Hg (760 mm Hg)
2/6/2019 10:39 AM
30
120618 Division
TEST DATA
Run number 2 3 4
Location Divison-Stack Divison-Stack Divison-Stack
Date 12/06/18 12/06/18 12/07/18
Time period 0906-1141 1356-1547 0842-1038
LABORATORY REPORT DATA, ug.
HFPO Dimer Acid 4117.81 1152.46 2026.97
EMISSION RESULTS, ug/dscm.
HFPO Dimer Acid 2321.9 653.6 1190.4
EMISSION RESULTS, lb/dscf.
HFPO Dimer Acid 1.45E-07 4.08E-08 7.43E-08
EMISSION RESULTS, lb/hr.
HFPO Dimer Acid 2.75E-01 7.85E-02 1.41E-01
HFPO Dimer Acid (From Carbon Bed Exit) 2.15E-03 1.81E-03 1.91E-03
HFPO Dimer Acid (Adjusted Emissions) 2.72E-01 7.67E-02 1.39E-01
HFPO Dimer Acid (Scrubber Inlet) 2.85E-01 4.90E-02 4.85E-02
EMISSION RESULTS, g/sec.
HFPO Dimer Acid 3.46E-02 9.88E-03 1.77E-02
HFPO Dimer Acid (From Carbon Bed Exit) 2.70E-04 2.28E-04 2.40E-04
HFPO Dimer Acid (Adjusted Emissions) 3.43E-02 9.66E-03 1.75E-02
Scrubber Removal Efficiency, % 4.4 NC NC
TABLE 6-3 (cont.)
CHEMOURS - FAYETTEVILLE, NC
SUMMARY OF HFPO DIMER ACID TEST DATA AND TEST RESULTS
VE-NORTH DIVISION STACK
2/6/2019 10:40 AM
31
120618 Division
32
Date
Time
Stack Testing
HFPO
VEN Product
VEN Precursor
VEN Condensation (HFPO)
VEN ABR
VEN Refining
Stripper Column Vent
Division WGS Recirculation Flow
Division WGS Inlet Flow
Secondary Scrubber KOH feed
Date
Time
Stack Testing
HFPO
VEN Product
VEN Precursor
VEN Condensation (HFPO)
VEN ABR
VEN Refining
Stripper Column Vent
Division WGS Recirculation Flow
Division WGS Inlet Flow
Secondary Scrubber KOH feed
800
800
12/6/2018
12/7/2018
1400 1500 1600
0906-1141 (Run 2)1356-1547 (Run3)
900 1000 1100 1200 1300
Burnout
900 1000 1100
0842-1038 (Run 4)
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019
APPENDIX F
LIST OF PROJECT PARTICIPANTS
113
IASDATA\CHEMOURS\15418.002.008\SCRUBBER EFFICIENCY TEST REPORT-LW 2/6/2019
The following WESTON employees participated in this project.
Paul Meeter Senior Project Manager
Wes Fritz Team Member
Chris Hartsky Team Member
Austin Squires Team Member
Steve Dryden Team Member
Matt Winkeler Team Member
Kris Ansley Team Member
Jacob Little Team Member
114