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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