2020.01.21_CCO.p8.B_Long to Abraczinskas re 92% Facility-Wide Reduction of GenX Compounds Emissions

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

January 21, 2020

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

Re: 92% Facility-Wide Reduction of GenX Compounds Emissions Pursuant to
Consent Order Paragraph 8.b

Dear Mr. Abraczinskas,

This submittal is intended to satisfy Paragraph 8.b of the Consent Order, which requires
Chemours to submit a final report documenting that Facility-wide air emissions of GenX
Compounds from December 31, 2018 through December 30, 2019 have been reduced by at least
92% from 2017 Total Reported Emissions.

Please find in Table 1 attached a summary of the GenX Compounds emissions for the
period from December 31, 2018 through December 30, 2019. This table demonstrates that
Chemours has met the Consent Order’s 92% 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.

The spreadsheet file with the calculations underlying the GenX Compounds emissions
presented in Table 1 was prepared by our consultant, ERM NC, Inc. (“ERM”). The spreadsheet
file also provides the emissions test data, control device data, and production data underlying the
calculations, as well as notes on the calculation methodologies. Because the spreadsheet file
contains confidential business information of Chemours, 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.
The emissions presented in Table 1 and in ERM’s spreadsheet file have been updated
from the last monthly emissions report, submitted on December 20, 2019. The emissions figures
here incorporate the results from emissions testing at the Division stack on November 22 and
December 4, 2019 and at the E2 stack on December 4 and 5, 2019. The Division stack testing
was performed to refine test methods that will be used for testing the thermal oxidizer, and the
E2 stack testing was performed during the first E2 product campaign of 2019, pursuant to
Paragraph 8.b.i of the Consent Order. The emissions test reports from the Division and E2 stack
testing, prepared by Weston Solutions, Inc., are enclosed.

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The emissions presented in Table 1 and in ERM’s spreadsheet file also incorporate the
results from emissions testing at Vinyl Ethers South (VES) on November 20 and 21, 2019. The
report from that testing was submitted with the last monthly emissions report on December 20,
2019. As noted in that submission, that testing at VES was conducted during periods of isotainer
venting, following redirection of the vent line from the Vinyl Ethers North scrubber to the VES
scrubber during the October plant turnaround, and the emissions measured were higher than
those measured during previous testing events at VES. ERM has conservatively incorporated the
November VES testing results into the emissions calculations, resulting in higher emissions for
November and December than in prior months as presented in Table 1 (but still meeting the 92%
reduction requirement). The isotainer vent line that was venting during the November VES
testing was routed to the thermal oxidizer, which became fully operational on December 27,
2019.

Finally, please note that the emissions presented in Table 1 and in ERM’s spreadsheet file
do not incorporate the anticipated reductions associated with the thermal oxidizer for the time
between its becoming operational on December 27, 2019 through the end of the reporting period
here of December 30, 2019, as stack testing results for the thermal oxidizer are not yet available.
Pursuant to the Consent Order, within 90 days of installation, Chemours and the Division of Air
Quality will conduct testing to confirm that the thermal oxidizer is destroying 99.99% of all
PFAS air emissions routed to it.

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

Sincerely,

Brian D. Long
Plant Manager
Chemours – Fayetteville Works

Attachment
Table 1. Inventory of Emissions of GenX Compounds Pursuant to Consent Order Paragraph
8.b

Enclosures
IXM Manufacturing Process E2 Stack Emissions Test Report, Test Dates: 4-5 December
2019
Fluoromonomers Manufacturing Process Division Stack Emissions Test Report, Test Dates:
22 November and 4 December 2019

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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

4

Attachment -

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

Chemours Company - Fayetteville Works Jan-20
Air Permit No. 03735T46
Month Notes Status
GenX Compound
Emissions
(lbs)
December 31, 2018 1 Actual 0.3
January 2019 Actual 10.9
February 2019 Actual 31.7
March 2019 Actual 46.7
April 2019 Actual 9.7
May 2019 Actual 10.3
June 2019 Actual 11.9
July 2019 Actual 3.1
August 2019 Actual 4.3
September 2019 Actual 3.0
October 2019 Actual 0.7
November 2019 Actual 17.0
December 1-30, 2019 2 Actual 34.2
183.7
2,302.7
92.02%
Notes:
1) Contains emissions from December 31, 2018 only
2) Contains emissions from December 1, 2019 - December 30, 2019
Assumptions:
4) Unless otherwise noted, emissions are calculated using average stack test data from
relevant stack testing.
Table 1
Inventory of Emissions of GenX Compounds
(Per Consent Order, Paragraph 8b)
January-20
3) [For March only] Emission rate for when the ABR only was operating was
determined by subtracting the 230 kg/hr ABR on and ABR off runs from the February
2019 stack testing. Stack testing following the permeator tie-in (March 2019) was not
utilized for determining ABR only emissions since those specific conditions were not
tested independently. Therefore, emissions rates after the permeator was tied in to the
scrubber were calculated using the following control efficiencies: 99.1% for Division
Scrubber (obtained from acid fluoride testing conducted by Entec Services in 2013), 45%
for Secondary Scrubber (most conservative efficiency from the Dec 2018 stack testing),
and 95.1% for Carbon Bed (from March 2019 stack testing).
1) Emission rates for PPVE campaign runs determined using the following for the
Feb/March campaign: 52.4% operating time ABR is on, 2.7% burnout, and 44.9% ABR
is off. And the following for Dec 20-30, 2018 PPVE Campaign: 38.2% operating time
ABR is on, 2.1% burnout, and 59.7% ABR is off.
2) Carbon bed became operational on VE-South process and equipment emissions on
June 29, 2019. Emissions from July stack testing data were utilized for the period after
installation and prior to the October TAR or after the October TAR when PPVE was not
being produced in VE-North. Emissions from November stack testing data were utilized
for the periods after the October TAR, when PPVE was being produced in VE-North.
Dimer iso loading vent line was redirected to VE-South scrubber (from VE-North
scrubber) during the October TAR.
Total GenX Compound Emissions
(12-Month Period from December 31, 2018
through December 30, 2019)
2017 Baseline Emissions
Percent Reduction