2019.02.06_CCO.p7_Long to Abraczinskas re Submission

The Chemours Company
Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306

February 6, 2019
Michael Abraczinskas
Director, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
[e-mail]

Re: Submission Pursuant to Proposed Consent Order Paragraph 7
Dear Mr. Abraczinskas,
As you are aware, pursuant to the requirements of Paragraph 7 of the proposed Consent
Order, in late 2018 Chemours completed installation of two major projects to substantially
reduce emissions of GenX Compounds from the Vinyl Ethers North (“VEN”) facility at
Fayetteville Works: the Second Phase Scrubber, and the VEN Carbon Adsorber Project.
Although the proposed Consent Order has not yet been entered by the Court, Chemours has
continued to proceed on the schedule set forth in the proposed Consent Order with respect to the
requirements in Paragraph 7 and to provide notice as set forth in the proposed Consent Order.

Paragraph 7.a states: “On or before February 6, 2019, Chemours shall submit a report to
DAQ demonstrating that the Second Phase Scrubber operates with a minimum control efficiency
of 72% for GenX Compounds.” Paragraph 7.b.iii, in turn, states: “Within ninety (90) days of
installation [installation was completed December 26, 2018], Chemours shall submit a report to
DAQ demonstrating that the Vinyl Ethers North Carbon Adsorber Unit operates with a minimum
control efficiency of 93% for GenX Compounds.”

Pursuant to these provisions, Chemours is hereby submitting to the Division of Air
Quality (“DAQ”) the enclosed report from Weston Solutions, Inc. (“Weston”) entitled
“Fluoromonomers Manufacturing Process Scrubber Efficiency Test Report, Test Dates: 6 and 7
December 2018” (“December 2018 Scrubber Report”), as well as draft results from Weston for
carbon inlet, carbon outlet, and stack testing conducted on January 16 and 17, 2019 (“Draft
January 2019 Carbon Results”). Chemours received the Draft January 2019 Carbon Results just
yesterday and will submit the final report to DAQ within the next week.

Draft January 2019 Carbon Results

I am pleased to report that the Draft January 2019 Carbon Results show an average
93.9% control efficiency of the VEN Carbon Adsorber Unit for GenX Compounds, in
compliance with the proposed Consent Order’s 93% requirement. These results, which were
measured during a PSEPVE product campaign, also show an average 95.5% reduction of stack
emissions of GenX Compounds as compared to baseline PSEPVE stack testing conducted in
March 2018 (thus showing the combined emission reduction benefits of the VEN Carbon
Adsorber Unit and Second Phase Scrubber). Additionally, the average emissions measured at

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the Carbon Adsorber Unit inlet during the January testing were 80% lower than the stack
emissions measured during the March 2018 baseline PSEPVE testing. Because the emissions
entering the Carbon Adsorber Unit inlet are predominantly comprised of process emissions
exiting the Second Phase Scrubber (there is a very small additional contribution to the carbon
inlet from indoor air), this 80% reduction serves as an approximation of the control efficiency of
the Second Phase Scrubber.

Furthermore, since installation, the VEN Carbon Adsorber Unit has had substantially less
unit downtime (as necessary for safety and maintenance) than we predicted when we calculated
that we could meet the 92% facility-wide emissions reduction of GenX Compounds for 2019 in
the proposed Consent Order. Specifically, we calculated that we could meet a 92% facility-wide
emissions reduction with a prediction of 25% downtime of the VEN Carbon Adsorber Unit.
Since the VEN Carbon Adsorber Unit was installed in December, actual downtime has been
below 3%, meaning that emissions are being controlled even further.

December 2018 Scrubber Report

With regard to the testing of the Second Phase Scrubber in December 2018, we
encountered significant technical challenges with the testing. The stack testing team was not
able to capture all of the emissions entering the scrubber inlet, due to technical challenges that
we have previously discussed with DAQ. These challenges have included the fact that the air
flow involved is not isokinetic and the challenges in finding an appropriate sampling port. As a
result, the emissions measured at the inlet, which was before either scrubber, were actually lower
than those measured at the outlet, which means that we cannot calculate a control efficiency by
comparing these measurements. We are continuing to study and refine the methods for testing at
the scrubber inlet, so that we can collect more reliable data there.

While the optimal way to measure control efficiency is to compare the emissions
measured at the scrubber inlet with those measured at the scrubber outlet on the same testing run,
and we cannot do that with the December testing, we can roughly estimate control efficiency by
comparing outlet results from different stack testing events. But this is an imprecise method,
because of significant variability between testing events. Within a product campaign, there are
several operating conditions that may impact emissions, and the relative variation in emissions is
magnified when the levels measured are very small, as they are here. This was seen in the results
of the three runs of the scrubber outlet testing done in December, which showed substantial
variability.

In December, the testing was done during a PPVE campaign. If we compare the outlet
results from the December testing to the PPVE outlet results from the testing we conducted back
in January 2018, one of the runs showed over a 72% reduction but the other two showed less,
with a 45% reduction when we compare the average across the testing runs. So, to summarize,
the results from the Second Phase Scrubber testing done in December are inconclusive, and there
were significant technical challenges.

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Later this month, we will be conducting a number of stack tests during a PPVE campaign
at VEN, including during varying operating scenarios. And beyond that, we are planning a
robust testing program where we conduct more runs and further assess the impacts of differing
operating scenarios, so that we can have a more complete data set for more precisely evaluating
the efficiency of the Second Phase Scrubber.

We have no reason to believe that the Second Phase Scrubber is not working as we
expected. The January testing further demonstrates the substantial combined emission reduction
benefits of the VEN Carbon Adsorber Unit and Second Phase Scrubber, and provides an
approximation of 80% control efficiency of the Second Phase Scrubber. The rainfall data we
have been collecting and sharing with you also demonstrates the effectiveness of our interim
emission control technologies, as GenX concentrations have dropped substantially since we
implemented our interim technologies starting last May.

***

If you have any questions, please contact me.

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Enclosures:
Fluoromonomers Manufacturing Process Scrubber Efficiency Test Report, Test Dates: 6 and
7 December 2018 (“December 2018 Scrubber Report”)
Draft Carbon Inlet, Carbon Outlet, and Stack Test Results, Test Dates: 16 and 17 January
2019 (“Draft January 2019 Carbon Results”)

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Cc:
Sheila Holman, DEQ
William F. Lane, DEQ
Francisco Benzoni, NC DOJ
Michael Scott, DWM
Linda Culpepper, DWR
David C. Shelton, Chemours
John F. Savarese, WLRK
Kemp Burdette, CFRW
Geoff Gisler, SELC