2019.12.03_CCO.p8.A_Long to Abraczinskas re 82% Facility-Wide Reduction of GenX Compounds Emissions

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

December 3, 2019

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

Re: 82% Facility-Wide Reduction of GenX Compounds Emissions Pursuant to
Consent Order Paragraph 8.a

Dear Mr. Abraczinskas,

This submittal is intended to satisfy Paragraph 8.a of the Consent Order, which requires
Chemours to submit a final report by December 5, 2019 documenting that Facility-wide air
emissions of GenX Compounds from October 6, 2018 through October 5, 2019 have been
reduced by at least 82% from 2017 Total Reported Emissions.

Please find in Table 1 on the following page a summary of the GenX Compounds
emissions for the period from October 6, 2018 through October 5, 2019. This table demonstrates
that Chemours has met the Consent Order’s 82% requirement for plant-wide interim reductions
of GenX Compounds emissions from 2017 Total Reported Emissions. These emissions were
calculated pursuant to Paragraph 8.b and 8.d of the Consent Order, which require that Chemours
submit monthly emissions reports for GenX Compounds and include fugitive, maintenance,
malfunction and accidental emissions. Please refer to the November 2019 monthly emissions
report spreadsheet for the calculations for the GenX Compounds emissions presented in Table 1
(the emissions presented in Table 1 are the same as in the November 2019 monthly emissions
report).1 Because the monthly emissions report spreadsheet contains confidential business
information of Chemours and has already been submitted to DAQ, we are not resubmitting it
here.

If you have any questions, please contact me at [e-mail].

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works

1 The monthly emissions report spreadsheet also provides the emissions test data, control device data, and
production data underlying the calculations, as well as notes on the calculation methodologies.

2
Table 1. Inventory of Emissions of GenX Compounds Pursuant to Consent Order
Paragraph 8.a

Month
GenX
Compound
Emissions
(lbs)
October 6-31, 2018 0.1
November 2018 58.1
December 2018 69.7
January 2019 10.9
February 2019 31.7
March 2019 46.7
April 2019 9.7
May 2019 10.3
June 2019 11.9
July 2019 3.1
August 2019 4.3
September 2019 3.0
October 1-5, 2019 0.5
Total GenX Compound Emissions
(12-Month Period from October 6, 2018
through October 5, 2019)
260.1

2017 Baseline Emissions 2,302.7
Percent Reduction 88.71%

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