AQ_F_0900009_20140115_CMPL_InspRpt

MEMORANDUM
TO: File
FROM: Robert Hayden, DAQ FRO
DATE: 15 January 2014
SUBJECT: Dupont Fayetteville McCI Accident—31 Oct 13
The purpose of this memo is to document the closure of DAQ activities related to the subject.
See attached correspondence from the company,dated 11 Nov 14 and the associated DAQ FRO
Complaint Investigation Report for details.
The McCI release was caused by an accident whose specifics may never be known. There is typically no
loss(emissions) associated with routine processes, so stipulated requirements and limits in the Title V
permit(toxics emission limits) do not apply. McCI is not a 112r-listed chemical subject to the Accidental
Release Prevention under the Clean Air Act Title III, Part 68.
FRO believes that no further regulatory action is appropriate.

oU PANT DuPont Chemicals&Fluoroproducts
r ® Fayetteville Works Plant
RECEIVED 22828 NC Hwy 87
/6! Fayetteville,NC 211306 28306 7332
NOV t 3 2013
OENR-FAYETTE%ALLE REGIONAL OFFICE
CERTIFIED MAIL ARTICLE NUMBER 7007 0710 00051455 9218
RETURN RECEIPT REQUESTED
November 11, 2013
Mr. StevenF. Vozzo
NCDENR—Division of Air Quality
Fayetteville Regional Office
225 Green Street— Suite 714
Fayetteville,NC 28301
SUBJECT: Title V Air Quality Permit Deviation and Excess Emissions
DuPont Company—Fayetteville Works
Air Quality Permit No. 03735T37
Facility ID: 0909009,Fayetteville, Bladen County
Dear Mr. Vozzo:
Pursuant to Part I Section 3(l.A)(2)(a) and Section 3(I.A.)(3)(a) of the subject Title V
permit, this letter is the required notification of excess emissions and a state-enforceable-
only permit deviation of an emissions limitation for methylene chloride specified in Part I
Section 2.2(B)(1) of the subject permit, which is the rule regulating North Carolina toxic
air pollutant emissions per 15A NCAC 2D .1100. That limitation sets a facility-wide
emission limit of 24.85 pounds of methylene chloride per hour.
Methylene chloride is used as the heat-transfer liquid ("brine") throughout the site's
Nafion® Process Area. On October 31, 2013, a 3/8-inch copper tube fitting in the brine
system became detached, which resulted in the release of methylene chloride inside of the
Nafion®Polymers Process manufacturing building.
This release from the brine system resulted in 1,181 pounds of methylene chloride being
unaccognted-for and presumed to have been vented to the atmosphere through the Nafion®
Polym�xs Process stack(ID No.NEP-G)during a 1-hour period.
E.I.du Pont de Nemours and Company

Mr. Steven F. Vozzo Page 2 of 2
NCDENR—Division of Air Quality
November 11, 2013
The loss of 1,181 pounds of methylene chloride during a 1-hour period exceeds the Part I
Section 2.2(B)(1) limit of 24.85 lb/hr methylene chloride.
The cause of this deviation was due to a release of methylene chloride from a detached
copper tube fitting in the Nafion®Process Area's brine system.
The Nafion© Polymers Process is currently shutdown due to this incident. The brine
system's copper tube fitting will have been reattached prior to the start-up of that Nafion®
Polymers Process.
If you have any questions regarding this excess emission and permit deviation, or if you
need any additional information,please contact Michael Johnson at(910) 678-1155.
To comply with the requirement of Section 3(D) of the subject permit, the required
photocopy of this letter is enclosed.
By my signature below, I certify that I believe the information contained in this letter is
true, accurate, and complete.
Sincerely,
Ellis H. McGaughy
Plant Manager
t t