2018.12.20_CCO.p9_Long to Abraczinskas re Submission of Test Methods and Lab Standardss for PFAS in Facility Air Emissions

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

December 20, 2018
Michael Abraczinskas
Director, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
[e-mail]

Re: Submission of Test Methods and Lab Standards for PFAS in Facility Air
Emissions Pursuant to Proposed Consent Order Paragraph 9
Dear Mr. Abraczinskas,
Pursuant to the requirements of paragraph 9 of the proposed Consent Order,
Chemours is hereby providing the Division of Air Quality (“DAQ”) with all of the
presently known analytical test methods and lab standards for PFAS compounds in air
emissions from the Fayetteville Works. Although the proposed Consent Order has not
yet been entered by the Court, Chemours is continuing to proceed on the schedule set
forth in the proposed Consent Order with respect to these requirements. We are also
providing notice as set forth in the proposed Consent Order.

Historically, we have identified specific PFAS compounds in our facility’s air
emissions based on process, engineering, and chemistry knowledge. And, as you are
aware, each year, in our Annual Emission Inventory report to DAQ, we have provided
our estimated emissions calculations for all of these specific PFAS compounds on a
compound-by-compound basis.

This year, newly developed analytical test methods and lab standards allowed us
to quantify the actual amounts of three specific PFAS compounds in our facility’s air
emissions—namely, HFPO Dimer Acid (CAS No. 13252-13-6), HFPO Monomer (CAS
No. 428-59-1), and E1 (CAS No. 3330-15-2). As you know, we reported to DAQ on the
emissions of these compounds measured during the several stack testing events
conducted at our facility in 2018.

The enclosed documents, as detailed on the following page, provide the sample
extraction protocol, preparation method, and analytical methods for HFPO Dimer Acid,
HFPO Monomer, and E1, used to enable the measurement of these compounds in the
samples collected during stack testing. The lab standards for these compounds were
purchased from external vendors and are available online.1

1 See http://synquestlabs.com/product/id/17276.html (2-MTP),
http://synquestlabs.com/product/id/52427.html (HFPO Monomer),
2

Finally, I would like to highlight that Chemours is also currently in the process of
performing innovative non-targeted analysis on retained extracted stack sampling
solutions in order to identify and potentially quantify additional PFAS compounds in air
emissions from the Fayetteville Works. We are proceeding with this non-targeted
analysis notwithstanding that the thermal oxidizer being installed at our facility in 2019 is
expected to destroy 99.99% of the emissions of PFAS compounds routed to it. Once
complete, we will share the results of our non-targeted analysis with DAQ.

If you have any questions, please contact me.

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Enclosures
“Extraction of Perfluorooctanoic Acid (PFOA) and Perfluorooctanoic Sulfonate
(PFOS) and other Perfluorinated Hydrocarbons (PFCs) in Water and Soil”
(“Extraction Protocol.pdf”)
“Extraction of 2,3,3,3-tetrafluoro-2-(1,1,2,2,3,3,3-heptafluoropropoxy)propanoic acid
(HFPO-DA) in Method 0010 Sampling Trains and Surface Wipe Samples” (“HFPO
Dimer Acid Preparation Method.pdf”)
“Analysis of Perfluorooctanoic Acid (PFOA) and other Perfluorinated Hydrocarbons
(PFCs) and Perfluorinated Hydrocarbon Sulfonates (PFSs) in Water and Soil by
LC/MS/MS” (“HFPO Dimer Acid LCMSMS Method.pdf”)
“Determination of Volatile Organics by GC/MS Based on Method 8260B” (“GC
Method for E1 and 2-MTP (HFPO Monomer).pdf”)

http://synquestlabs.com/product/id/19306.html (E1), and http://synquestlabs.com/product/id/18551.html
(HFPO Dimer Acid). Note that 2-MTP is the compound formed and analyzed for when HFPO Monomer is
sampled in methanol.
3

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