2019.07.22_CCO.p8.D_ Long to Abraczinskas re Monthly Emissions Report

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

July 22, 2019
Michael Abraczinskas
Director, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
[e-mail]

Re: Monthly Emissions Report Pursuant to Consent Order Paragraph 8
Dear Mr. Abraczinskas,
Pursuant to Paragraph 8.d of the Consent Order, please find enclosed the July monthly
emissions report for GenX Compounds from Fayetteville Works, prepared with support from our
consultant, ERM NC, Inc. (“ERM”). The report shows the estimated GenX Compounds
emissions through June, the projected emissions for the rest of the year, and the assumptions that
underlie the estimates. Based on the identified assumptions, ERM’s calculations continue to
show that the facility will meet the Consent Order’s 82% and 92% requirements for plant-wide
interim reductions of emissions of GenX Compounds.

I am also pleased to report that in June, we completed installation and startup of a carbon
bed at Vinyl Ethers South (VES) for further control of process and indoor equipment emissions
from that facility. We performed emissions testing at VES last week (on July 16 and 17) and
will incorporate the final results from that testing, once received, into our future monthly
emissions reports.

As with the prior monthly emissions reports, the spreadsheet file with the calculations
underlying the enclosed report contains confidential business information of Chemours, so we
will send that spreadsheet file under separate cover directly to you, and the spreadsheet file will
not be further distributed or posted on Chemours’ website.

Finally, in response to questions we recently received from DAQ on the calculations
underlying the monthly emissions reports, I would like to clarify a few items:
• The calculations account for plant-wide process, indoor equipment, and outdoor
equipment (fugitive) emissions of GenX compounds.
• The final results from stack emissions testing and outdoor equipment monitoring
events conducted during the reporting periods are incorporated into the calculations.
• Process and indoor equipment emissions, which vent through stacks, are calculated
by multiplying the stack emissions rates measured during emissions testing by the
monthly hours of operation of the process that was running during the test. Emissions
equipment control efficiencies (e.g., scrubber efficiency, carbon bed efficiency) are
used to calculate emissions amounts only where a particular process or condition has
not been stack tested.

2
We would be glad to arrange a time with DAQ to explain the calculations further and
answer any additional questions you may have.

Sincerely,
Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Enclosures
July 2019 Monthly Emissions Report

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