AQ_F_0900009_20140217_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY DuPont Company-Fayetteville Works
NC Facility ID 0900009
Inspection Report County/FIPS:Bladen/017
Date: 02/18/2014
Facility Data Permit Data
DuPont Company-Fayetteville Works Permit 03735/T38
22828 NC Highway 87 West Issued 12/16/2013
Fayetteville,NC 28306 Expires 1/31/2015
Lat: 34d 50.6000m Long:78d 50.2930m Classification Title V
SIC: 3081 /Unsupported Plastics Film And Sheet Permit Status Active
NAICS: 326113/Unlaminated Plastics Fihn and Sheet(except Packaging) Current Permit Application(s)None
Manufacturing
Program Applicability
Contact Data
SIP/Title V/112r
Facility Contact Authorized Contact Technical Contact MACT Part 63: Subpart FFFF,Subpart ZZZZ
Michael Johnson Ellis McGaughy Michael Johnson NSPS: Subpart Dc
Environmental Manager Plant Manager Environmental Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/17/2014
Inspector's Name Gregory Reeves
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: OZ/g/2�1� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2012 7.95 1.23 63.76 260.86 29.24 7.95 37401.00
2011 11.60 2.74 73.06 271.17 31.42 11.31 35028.00
2010 13.29 2.04 43.89 296.10 13.12 9.25 34976.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 2 of 15
1. , DIRECTIONS TO SITE: DuPont Company-Fayetteville Works is located on NC Highway 87 in Bladen County.
From FRO,take Highway 87 south. The entrance to the facility is approximately 18 miles from FRO on the left side
of I-ghway 87 just before the Cumberland/Bladen County line.
2. SAFETY CONSIDERATIONS:The usual FRO safety gear is required(hardhat,safety glasses,safety shoes,
hearing protection). Entry into several areas of the plant requires specialized safety gear. In the Nafion®reactor
area,personnel are not allowed to enter unless the process is not operating due to the safety hazards of the chemical
reaction process.
3. FACILITY DESCRIPTION: DuPont Company-Fayetteville Works is a chemical manufacturing facility located
in Bladen County. The facility employs approximately 500 employees and 250 full-time contractors on a 24 hr,7
day per week basis. DuPont Fayetteville consists of six individual manufacturing plants,a boiler house and a waste
treatment operation. Several processes have PSD avoidance conditions. The facility has two permanent boilers
onsite,one permanent boiler which is permitted but not yet constructed,and one permitted temporary boiler.
4. INSPECTION SUMMARY: On February 17,2013,I,Greg Reeves,of the Fayetteville Regional Office,met with
Mike Johnson,Environmental Manager, for a full compliance inspection. Mr.Johnson reviewed the FacFinder
sheet and did not note any errors in the contact information. Facility records were reviewed for emissions,control
device inspections,and visible emissions from the emission sources. There are extensive electronic records
available for the facility operations available on the local computer area network. Mr. Johnson confirmed that there
have been no changes in emission sources since the previous inspection/permit modification and that the emissions
sources listed on the permit had not changed. Mr.Johnson led a tour of individual plants and provided the required
records. PSD records and most all other records are accessible on the Intranet in Mr. Johnson's office. For the
operating areas, flow rates and pressure drops in scrubbers are available in the control rooms of the respective areas.
The two PVF facilities were shut down during the inspection for major maintenance operations. Two boilers(PS-A
and PS-B)were operating, firing natural gas. The third permitted boiler(PS-C)is not yet constructed and Mr.
Johnson stated that the modification would not happen in the near future. The permitted temporary boiler(PSC-
Temp)is not currently on site,although it was on site for a 3-month period from November 2012 through January
2013. The Vinyl Ethers North product container decontamination process(ID No.NS-O),and the Vinyl Ethers
South product container decontamination process(ID No.NS-P)were not operating during the inspection. All other
processes were in operation during the inspection. I observed zero visible emissions from each of the operating
source emission points.
j 5. PERMITTED EMISSION SOURCES: At the time of the inspection,DuPont Company—Fayetteville Works was
operating under Permit No.037351738 which includes the following emission sources:
m1Sry9201tlddtod SAW ce 17tescrtptartoptl{tEI I1tt e " Cgntrolevtce T?escnttJon
, o y rc . to PS-A Natural Gas/No.2 fuel oil/No. 6 fuel oil- N/A N/A
(2D.1109 fired boiler(139.4 million Btu per hour
Case-by-case maximum heat input)
_ MACT) OPERATING
PS-B Natural Gas/No.2 fuel oil No.6 fuel oil- N/A N/A
(21).1109 fired boiler(88.4 million Btu per hour
Case-by-case maximum heat input)
MACT OPERATING
PS-C Natural Gas/No.2 fuel oil-fired boiler N/A N/A
NSPS Dc (97 million Btu per hour maximum heat
(2D.1109 input)equipped with a low-NOx burner
Case-by-case NOT YET CONSTRUCTED
MACT)

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 3 of 15
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gv„nlit'�0r`ID,.,)V,Ot i, ::.,<i� ...S...rt ..... .{ s.....:.:.::.. .:a .a,. :H)! . 4�
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PS-Temp Natural Gas/No.2 fuel oil-fired boiler N/A N/A
NSPS Dc (greater than 30.0 and less than 100.0
(2D.1109 million Btu per hour maximum heat
Case-by-case input)
MACT) NOT ON SITE AT THIS TIME.
BS-A Butyraldehyde storage tank BCD-A Brine-cooled condenser
OPERATING
-BS-Bl.l Butacite polyvinyl butyral flake reactors BCD-B1 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons per minute water
BS-BL4 OPERATING injection rate averaged over a 3-hour
MACT FFFFperiod)(state-enforceable,only)
BS-132.1 Butacite polyvinyl butyral flake reactors BCD-132 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons per minute water
BS-B2.4 OPERATING injection rate averaged over a 3-hour
MACT FFFF period)(state-enforceable,only)
BS-C Butacitew polyvinyl butyral flake dryer BCD-Cl Cyclone separator
MACT FFFF OPERATING BCD-C2 Fabric filter(6,858 square feet of filter
area)
BS-El Butacite Line No.3 Sheeting Extrusion BCD-El Water-Cooled Condenser(voluntary
Process,including four(4)extruders use only)
OPERATING
BS-E2 Butacite Line No.4 Sheeting Extrusion BCD-E2 Water-Cooled Condenser(voluntary
Process,including four(4)extruders use only)
OPERATING
BS-E3 Butacite Line No.3 Back-End N/A N/A
Processes, including a quencher,
dryer/relaxer,and wind-up area
OPERATING
BS-E4 Butacitew Line No.4 Back-End N/A N/A
Processes,including a quencher,
dryer/relaxer,and wind-up area
OPERATING
BS-F Butacite PVA Unloading System and N/A N/A
MACT FFFF Storage Silos
OPERATING
BS-G Butacite PVA Dissolver Tank System N/A N/A
MACT FFFF OPERATING
NS-A Nafloe Hexfluoropropylene epoxide NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF process(HFPO) kilogram/hour liquid injection rate
NOT OPERATING -or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-B Nation Vinyl Ethers North process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 4 of 15
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NS-C Nafion Vinyl Ethers South process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-D Naflono RSU Process NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-E Naflono Liquid waste stabilization NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-F Nafion MMF process NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-G Naflono Resins process NCD-G Venturi vacuum jet caustic scrubber
MACT FFFF OPERATING
NS-H Nalioe membrane process N/A N/A
OPERATING
NS-I Nafioe membrane coating N/A N/A
OPERATING
NS-J Naflono semiworks N/A N/A
OPERATING
NS-K Nafion E-2 Process N/A N/A
OPERATING
NS-L Nation'TFE/HC1 separation unit NCD-Hdrl Baffle-plate scrubber(7,000
OPERATING kilogram/hour liquid injection rate
-or- averaged over a 3-hour period)
NCD-Hdr2 Baffle-plate scrubber(7,000
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-M Nation'TFE/CO2 separation process N/A N/A
OPERATING
NS-N HFPO product container decontamination N/A N/A
process
NOT OPERATING

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 5 of 15
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' UF4'.4Cri v r :. i ..F,.. -(. IIS LVO. :::F .
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NS-O Vinyl Ethers North product container N/A N/A
decontamination process
NOT OPERATING
NS-P Vinyl Ethers South product container N/A N/A
decontamination process
NOT OPERATING
SW-1 Semiworks polymerization operation N/A N/A
OPERATING
SW-2 Semiworks laboratory hood N/A N/A
OPERATING
AS-A Polymer Processing Aid Process ACD-Al Wet scrubber(30 gallons per minute
OPERATING water injection rate averaged over a 3-
hour period)(state-enforceable only)
ACD-A3 Wet scrubber installed on the building
exhaust vent(voluntary use only)
WTS-A Extended aeration biological wastewater N/A N/A
treatment facility
OPERATING
WTS-B, Two(2)Indirect steam-heated,rotary WTCD-1 Impingement-type wet scrubber with
WTS-C sludge dryers mist eliminator(state-enforceable only)
OPERATING
SGS-A SentryGlas Process N/A N/A
OPERATING
FS-B Polyvinyl Fluoride Process No. 1 N/A N/A
NOT OPERATING:
FS-C Polyvinyl Fluoride Process No.2 N/A N/A
NOT OPERATING
6. APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each of the various
manufacturing processes as listed on the current air permit.
•Powerhouse(Boilers PS-A,PS-B,and PS-C)•
The facility is permitted to operate one Natural Gas/No.2 fuel oil-fired boiler(139.4 mmBtu/hr maximum heat
input,PS-A),one Natural Gas/No.2 fuel oil-fired boiler(88.4 mmBtu/hr maximum heat input,PS-B), and one
Natural Gas/No.2 fuel oil-fired boiler with low-NOx burner(97 mmBtu/hr maximum heat input,PS-C). The third
boiler(PS-C)has not yet been constructed. According to Mr.Johnson,the construction project will not begin
anytime soon. Both of the boilers are currently combusting natural gas. The#6 fuel oil storage tank has been
removed from service,and the permit was recently modified to remove#6 fuel oil as a permitted fuel for boilers PS-
A and PS-B. The larger boiler(PS-A)has a steam capacity of 113,000 pounds of steam per hour(139.4 mmBtu
maximum heat input)and was manufactured in 1969. The smaller boiler(PS-B)was manufactured in 1982 with a
steam capacity of 72,000 pounds per hour(88.4 mmBtu/hr maximum heat input). They are both pre-NSPS boilers;
however,Boiler PS-2 does have a PSD avoidance condition for PM,PM-10,NO.,and SO2. Boiler PS-C will be
subject to NSPS Subpart De when constructed. All three of the boilers are now subject to the 2D .1109 Case-by-
case MACT condition, in lieu of the NESHAP Subpart DDDDD Boiler MALT. Therefore,they are not currently
subject to any of the requirements of the Boiler MACT. Due to debottlenecking of the boilers by the PVF facility,
DuPont now has a facility-wide PSD SOz emissions limitation.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 6 of 15
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from boilers PS-1 and PS-2 shall not exceed 0.26671bs/mmBtu. Particulate emissions
from PS-C shall not exceed 0.2268 lbs/mmBtu.
APPEARS IN COMPLL4NCE-The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu and for No.
2 fuel oil is 0.024 lbs/mmBtu. As long as the facility only combusts these fuels,they should not exceed the
emission limits. The facility is currently combusting natural gas. The last#2 fuel oil was combusted in March
2013 and July 2013 during boiler tune-ups(total of 5,635 gallons of#2 fuel oil combusted). The#2 fuel ail
used is extremely low sulfur content(< 15 ppm sulfur by weight.)
15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—The sulfur
dioxide emissions from boilers PS-A and PS-B shall not exceed 23 pounds per million Btu heat input.
APPEARS IN COMPLL4NCE-The AP-42 emissions factor for Natural Gas is 0.001 lbs/mmBtu and for No.
2 fuel oil(with 0.5%sulfur content by weight)is 0.507 lbs/mmBm. All No. 2 fuel oil is extremely low sulfur
fuel oil(< 15 ppm sulfur content by weight.)The facility should never exceed the SO2 emission limit while
combusting either natural gas or#2 fuel oil.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from Boiler PS-A shall
not exceed 40%opacity. Visible emissions from PS-B,and PS-Temp shall not exceed 20%opacity. No
monitoring/recordkeeping/reporting is required.
APPEARS IN COMPLIANCE—The boilers are currently combusting natural gas and I observed 0%opacity
from the boiler stack.
15A NCAC 2D.0524 NEW SOURCE PERFORMANCE STANDARDS—SUBPART Be(for PS-C only)—
The sulfur content of fuel combusted in the new boiler(PS-C)shall not exceed 0.5%by weight and visible
emissions are limited to 20%opacity. Initial notifications are required at construction and startup. The facility
must conduct Method 9 testing after boiler start-up. The Permittee shall maintain records of fuel usage and fuel
certifications. A semi-annual summary report must be submitted. NSPS Construction and startup notifications
are required.
APPEARS INCOMPLIANCE-Boiler PS-C is not yet under construction,and there are no current plans to
install this unit.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS(PS-B only)—Emissions from Boiler PS-B shall not exceed the following: 40 TPY NO.,and
40 TPY SO,. The Permittee shall keep monthly records of fuel usage,fuel sulfur content, and maintain fuel
certifications. Semiannual reporting is also required for monthly emissions(14 month period), fuel usage,and
sulfur content. The Permittee must also list all deviations from the requirements in the report.
APPEARS IN COMPLJANCE—All reports show that the facility is well below these emissions limits. The
highest 12-month total NOx emissions during 2013 were 10.2 tons and SOZ emissions were 0.1 tons. The last
semi-annual report was received at FRO on 01/27/14.
15A NCAC 2D.1109 CASE-BY-CASE MACT—This stipulation includes requirements for boilers PS-A,PS-
B,and PS-C that were instituted as a result of the vacating of the Boiler MALT. Requirements include an
annual inspection of each boiler and a tune-up of each boiler each calendar year. Records of inspections and
tune-ups are required. Semi-annual reporting is required, starting January 30,2014.
APPEARS INCOMPLLANCE-Inspection and tune-up of PS-A was conducted on 09/07/13, and ofPS-B on
11/15/13. The semi-annual report was received on 01/27/14.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 7 of 15
*Butacite®Process Area(all sources labeled with BS-and BCD-)*
The Butacitew manufacturing operation includes: (1)the butyraldehyde storage tank,with emissions and potential
odors from the butyraldehyde controlled by a brine-cooled(ethylene glycol)condenser. (2)eight(8)Butacite flake
reactors, controlled by packed-bed column scrubbers,and(3)a Butacite flake dryer,controlled by a cyclone
separator and fabric filter. The operation also contains two Butacite Sheeting Extrusion Processes,two Back-End
Processes,a Polyvinyl Alcohol(PVA)Unloading System including Storage Silos,and A PVA dissolver tank. The
operation produces flexible glass laminate for use in car windshields. Portions of the Butacite area are subject to the
NESHAP MON requirements.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the Butacite process shall not exceed E=4.10*P0 6'. The Permittee shall
maintain production records. The Permittee shall perform a monthly visual inspection on cyclone BCD-CI and
bagfilter BCD-C2 and an annual internal inspection on bagfilter BCD-C2. A logbook detailing these
inspections must also be kept up to date. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—The flaking process is controlled by a cyclone and a bagfilter to reduce
particulate matter emissions. Visual inspections of the cyclone and bagfilter are performed on a monthly basis
and an annual inspection of the bagfilter is performed as well. The facility has detailed records of the amount of
production for any given time period. The most recent annual internal inspection of the bagfilter was on
09/04/13. The most recent external inspection of the cyclone and bagfilter was 01/03/14. The last semi-annual
report was received on 01/27/14.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the flake dryer BS-C
shall not exceed 20%opacity. The Permittee shall record a monthly visible emissions evaluation(normal or
above normal)and maintain a logbook showing the results of each evaluation. A summary semi-annual report
is required.
APPEARS INCOMPLIANCE—During the inspection,I observed 0%VE from the source stack. VE
evaluations are performed once during every shift despite the monthly requirement. The last formally
documented monthly VE evaluation was performed on 01/27/14. The last summary semi-annual report was
received on 01/27/14.
15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS(State-Enforceable
Only)—The Butacite®process shall not operate without odor control equipment(Condenser BCD-A, Scrubber
BCD-B 1,and Scrubber BCD-B2.) An objectionable odor shall not be detected from these sources. Liquid flow
rate for BCD-B 1 and BCD-B2 shall be at least 8 gallons per minute and the differential pressure shall be a
maximum of 30 inches of water pressure averaged over a three-hour period. The Permittee shall perform
periodic inspections and maintenance of BCD-A,BCD-B 1,and BCD-B2 as recommended by the manufacturer.
As a minimum,the inspection and maintenance program shall include inspection of spray nozzles,packing
material,chemical feed system(if so equipped),and the cleaning/calibration of all associated instrumentation.
APPEARS IN COMPLIANCE—Odorous emissions from the butyraldehyde storage tank BS-A are controlled
by a condenser BCD-A. Odorous emissions from the flake reactor lines BS-B 1 and BS-B2 are controlled by
packed-bed scrubbers BCD-BI and BCD-B2. External inspections are performed every three years for the
condenser BCD-A and annually for the two scrubbers BCD-B 1 and BCD-B2. The most recent triennial
external inspection of BCD-A was on 06/12/13.The liquid flow rates to BCD-Bl and BCD-B2 were 10.0 gpm
each during the inspection. The differential pressures across the scrubbers BCD-BI and BCD-B2 were 3.28"
H2O and 1.35"H2O,respectively. The most recent annual internal inspections of BCD-B 1 and BCD-B2 were
performed on 07/24/13 and 07/20/13,respectively. No odors were noted during the inspection.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 8 of15
40 CFR Part 60 Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing(MON).
For each affected MPCU with a Group 2 Process Vent,the Permittee shall retain a record of the day each batch
was completed,a record of whether each batch operated was considered a standard batch,the estimated
uncontrolled and controlled emissions for each batch that is considered to be a non-standard batch, and records
of the daily 365-day rolling summations of emissions,or alternative records that correlate to the emissions.The
Permittee shall also retain the following records:MPCU identification and description,stream identification
code,concentration of compounds, and stream flow rate(in L/min).
APPEARS IN COMPLIANCE—All completed batches are considered standard batches. Non-standard or off-
spec batches are recycled back to the feed for the process, and are reprocessed. Records of the daily 365-day
rolling summations of methanol emissions are readily available electronically. The emissions are calculated
based on material balances and flow rates/concentrations on a monthly basis.All the required records for each
affected MPCU with a Group 2 are available at the site on computer. A flow diagram with equipment
numbers,flowrates, and concentrations is available on computer.
*Nafion Process Area(all sources labeled with NS-and NCD-)*
The Nation'operation produces a variety of relatively uncommon monomer and polymer chemicals. Some of the
monomers are shipped offsite,while others are used onsite in the production of various polymers. The polymers are
shipped offsite or used onsite to produce Nafion membrane material. A principal use of the membrane is in the
electrolysis cells for production of chlorine and sodium hydroxide at chloro-alkali plants. The two waste gas
scrubbers located at the Nafion®process area are used to control the emissions of various pollutants including
hydrogen fluoride and other acid fluorides. The Nafion®process at this facility manufactures plastic materials
classified under SIC code 2821,and are therefore existing affected sources under the NESHAP"MON". The
Nafion®process is subject to the Miscellaneous Organic NESHAP, Subpart FFFF.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the Nafion®process shall not exceed E=4.10*Po-". The Permittee shall
maintain production records. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—Production records are available at each manufacturing facility. The last
semi-annual summary report was received at FRO on 01/27/13.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the membrane
coating process NS-I shall not exceed 20%opacity. No monitoring,recordkeeping,or reporting required.
APPEARS INCOMPLIANCE—During the inspection,I observed 0%VE.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The Nation process shall not operate without odor control equipment.
APPEARS IN COMPLLANCE—Odorous emissions from the Nafion process are controlled by two baffle-
plate scrubbers NCD-Hdrl and NCD-Hdr2. The control devices also have monitoring parameters that are
continually recorded and interlocked into the system. All the facility's monitoring parameters are recorded and
viewable in an Aspen program. No noticeable odor was detected away from the facility,and no odor
complaints have been received.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 9 of 15
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—VOC emissions from the Vinyl Ethers North process,NS-B,shall not exceed 68.9 TPY
VOC. The Permittee shall keep monthly records of VOC emissions. Semi-annual reporting is required.
APPEARS IN COMPLIANCE-VOC emissions are calculated using stack test results,material balances,and
flow rates/concentrations on a monthly basis. These records are submitted to Mike Johnson within 30 days of
the following month. Current records show a maximum 12-month running total of 26.5 TPY of VOCs during
2013,and a calendar year 2013 total emission of 26.5 tons.. The last semi-annual report was received at FRO
on 01/27/13.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-G shall not exceed the following: 40 TPY VOC. The
Permittee shall keep monthly records of VOC emissions. Semi-annual summary report is required.
APPEARS INCOMPLIANCE—The highest 12-month VOC emissions during 2013 were 18.7 tons per 12-
month period, and the calendar year 2013 total emission was 15.7 tons. The last semi-annual summary report
was received at FRO on 01/27/13.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the resin process NS-A shall not exceed the following: 85.3 TPY VOC. The
Permittee shall keep monthly records of VOC emissions. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—The highest 12-month VOC emissions during 2013 were 36.4 tons per 12-
month period, and the 2013 calendar year emissions were 36.4 tons. The last semi-annual summary report was
received at FRO on 01/27/13.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the HFPO Product Container Decontamination Process(NS-N) shall not
exceed the following: 40 TPY VOC. The Permittee shall keep monthly records of VOC emissions. The
Permittee shall also maintain records of dates each container is decontaminated and total mass of VOC removed
from each container. Semi-annual summary reporting is required.
APPEARS IN COMPLIANCE—The highest 12-month VOC emissions during 2013 were 7.3 tons per year,
and the 2013 calendar year emissions were 7.3 tons. Currently the facility is loading product on top of the _
_ material that remains in the cylinders,instead of purging them first. This has reduced emissions significantly;
however,every product and/or all containers can't be handled this way due to customer requirements. The last
semi-annual report was received at FRO on 01/27/13.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 10 of 15
40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The Nation'process
must comply with all provisions of this MALT. The MON requires 99%control efficiency for some Group 1
sources;however,DuPont determined that their sources are not subject to the stricter requirements of a control
device. The Permittee shall monitor and inspect all the valves,pumps,compressors, agitators,and connectors
for leaks using the instrument monitoring methods described in 40 CFR 63.1023(b)-(c). All equipment affected
by the leak requirements shall be identified. The Permittee shall create and retain a record of the monitoring
schedule for each process unit. If a leak is identified,it shall be repaired as provided in the repair provisions of
this section. After a leak has been repaired,the valve shall be monitored at least once within the first 3 months
after its repair. This requirement is in addition to the monitoring required to satisfy the definition of repaired
and first attempt at repair. The required periodic monitoring may be used if it satisfies the timing requirement
of this condition. The Permittee shall repair each leak detected as soon as practical,but not later than 15
calendar days after it is detected. The facility operates two process heat exchangers that are subject to the
MON. To monitor for presence of a leak in a heat exchanger system,requires that three samples of both the
cooling water entrance to and exit from the heat exchanger be monitored for the presence of hazardous air
pollutants monthly for the first six months of operation and quarterly thereafter. Semi-annual summary
reporting is required.
APPEARS IN COMPLIANCE—The scrubbers currently controlling the Nation"process(NCD-HdrI and
Hdr2)meet the control efficiency requirement. The scrubbers were tested at 99.6%efficiency in August 2003.
Initial notification was received on 2 March 2004. However,no controls are required for this facility based on
HAP content,THE values,and other various parameters. The facility has an extensive LDAR program,and
inspects all the valves,pumps, compressors,agitators,and connectors for leaks on a monthly basis.Records are
available at the site. Each affected unit has a physical tag for equipment identification. Three samples of both
the cooling entrance and exit are taken at the heat exchangers to analyze for leaks on a monthly basis. The
facility also submits a semi-annual report for MACT Subpart FFFF. There were no deviations from the
emission limits,operating limits,or work practice standards during 2013. The last semi-annual summary
report was received at FRO on 01/27/13. A more extensive MACT FFFF report is submitted to EPA and FRO
also,which includes several items not required in the Title V permit,but are required by the MACT. The
facility has a"zero leak"policy. If a leak is discovered,it is fixed ASAP,even if the process must be shut
down. No delay of repair scenarios are permitted by the facility's LDAR policy.
*Polymer Processing Aid(PPA)Process(all sources labeled with AS-and ACD-)+
The polymer processing aid process,formerly the ammonium perfluorooctanoate(APFO)process,began operation in
December of 2002. Formerly,the Polymer Processing Aid reaction process uses perfluorooctanoate(brought in by
truck in its iodide/salt form)reacted with sodium hydroxide(stored in totes)to form the acid fluoride. The acid
fluoride is then reacted with ammonia to produce the ammonium salt. Fuming sulfuric acid(oleum)is received by
truck and used as a solvent in the process. Currently,APFO and the associated perfluorooctanoic acid(PFOA),also
known as C8,are not regulated as toxic or hazardous air pollutants. However,the EPA is currently reviewing the
chemical with the possibility of its designation in the future as a regulated pollutant. Due to historical pollution and
health effects concerns and recent controversy regarding the DuPont facility in West Virginia,and the recent activities
by the U.S.EPA to develop and review toxicity data for this chemical,the DAQ file includes several documents and
articles related to APFO,PFOA, or C8. The APFO process is subject to the 112(r)chemical accident prevention
program for oleum. DuPont has made a decision to eliminate APFO by 2015. The PPA process at the Fayetteville
Works has been modified, and no longer produces AFPO. A more environmentally friendly polymer is currently
being produced in the existing reactor as a replacement for APFO.
15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The Polymer Processing Aid Process facility shall not operate without implementing a management
plan or without odor control equipment.
APPEARS INCOMPLIANCE—The APFO process is controlled by scrubbers. No odors were
noticeable during the inspection.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 11 of 15
15A NCAC 2D.I100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—Emissions
from the APFO facility shall be controlled by a wet scrubber. The liquid flow rate in the packed bed section
shall be at least 30 gallons per minute and the differential pressure across the bed shall be a maximum of 12
inches of water. An alarm is required for the pressure monitoring. Records of all inspections shall be kept in a
logbook.
APPEARS IN COMPLIANCE—The scrubber is interlocked so that the system will shut down,almost
instantaneously,if the parameters are exceeded. The facility will go,into shutdown mode if the two hour
average is less than 30 gpm or pressure is 5 inches of water. The system is set up such that upon startup after an
extended shutdown,the scrubber must be operated for two hours to establish the minimum 2-hour average prior
to allowing the startup of the remaining equipment. The polymer processing aid chemical is a surfactant;
therefore,the dP increases occasionally due to `suds' in the scrubber. The liquid flowrate during the inspection
was 38.2 gpm,and the pressure drop across the scrubber bed was 0.1"H2O. The last internal inspection of the
scrubber was performed on 08/13/2012. Inspections are on a two-year interval.
*Wastewater Treatment Area(all sources labeled with WTS-and WTCD-)*
For the wastewater treatment operations,the Title V permit specifies two rotary sludge dryers controlled by an
impingement-type wet scrubber with mist eliminator. The Miscellaneous Organic NESHAP(MON)will also
address emissions from wastewater. With respect to quantity of emissions,methanol is the most significant air
pollutant from the wastewater treatment operation.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The wastewater
treatment facility shall not operate without a management plan or odor control equipment. An objectionable
odor shall not be detected from these sources. The sludge dryers shall be controlled by a caustic injection
scrubber. An I&M logbook is also required for the scrubber.
APPEARS IN COMPLIANCE—Odorous emissions from the sludge dryers are controlled by a scrubber
utilizing potassium hydroxide solution. Inspections of this scrubber are on a 5-year cycle. Wastewater
treatment odors were not noted at boundary lines. The sludge dryers are located inside a building. The facility
keeps maintenance records for the scrubber in their electronic maintenance program. The most recent 5-year
inspection was 11/0l/11.
*Temporary Boiler(PS-Temp)*
This boiler is permitted for Natural Gas/No.2 fuel oil and is brought on-site on an `as needed'basis. There is
currently no temporary boiler on site. The temporary boiler was last on site during the period 11/19/12 through
01/09/13 and utilized natural gas for fuel.
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from the temporary boiler shall not exceed 0.24261bs/mmBm.
APPEARS I7VCOMPLL4NCE—The AP-42 emissions factor for Natural Gas is 0.0071bs/mmBm and for No.
2 fuel oil is 0.0241bs/mmBTU. This boiler was not on site during this inspection.
15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—Sulfur
Dioxide emissions from the temporary boiler shall not exceed 2.3 lb/mmBtu heat input.
APPEARS IN COMPLLANCE—The AP-42 emission factor for Natural Gas is 0.001 lb/mmBtu and for No.2
fuel oil burning extremely low sulfur content oil(<15 ppm Sulfur by weight)is 0.002 lb/mmBtu. Therefore,
the source will not exceed the limits while combusting either of these permitted fuels.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 12 of 15
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS-Visible emissions shall be no more than 20%
opacity.
APPEARS INCOMPLL4NCE—The source was not on site during the inspection. While combusting either
natural gas or 42 fuel oil,it is expected that there will be no visible emissions from this source(VE=0%
opacity).
15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.0524 NEW SOURCE PERFORMANCE
STANDARDS(NSPS Subpart De)—In order to avoid the applicability of NSPS Subpart Dc,the temporary
boiler shall combust natural gas or distillate oil with potential Sulfur Dioxide emissions rate no greater than
0.060 lb/mmBtu,be capable of being moved from one location to another,and remain onsite for no longer than
180 consecutive days as defined in 40 CFR 60.41 c(temporary boiler). Notification is required if the 180 days
will be exceeded. Recordkeeping and semi-annual summary report are required.
APPEARS INCOMPLIANCE—The temporary boiler was capable of being moved from one location to
another. It remained on site for 51 days from 11/19/12 through 01/09/13. No notification was required. While
onsite the boiler combusted only natural gas. The latest semi-annual report was received on 01/27/14.
15A NCAC 2Q.0317 AVOIDANCE OF 15A NCAC 2D.1109 CASE-BY-CASE MACT FOR BOILERS
AND PROCESS HEATERS AND OF 40 CFR 63 SUBPART DDDDD MACT FOR BOILERS AND
PROCESS HEATERS—The temporary boiler shall remain onsite for no longer than 180 consecutive days.
APPEARS IN COMPLLANCE—The boiler was onsite for only 51 days from 11/19/12 through 01/09/13.
*SentrvGlaso Process (SGS-A)*
The SentryGlas plant began in 2005 and manufactures rigid plastic glass laminate. This product is
similar to the Butacite product;however,this material is much stronger, even explosion proof. The facility has a
crushing system used to crush the pelletized raw material. Crushed material is sent to a silo,which is controlled by a
baghouse that vents indoors. The entire process takes place in a clean room to avoid contamination by lint,dirt,etc.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the SentryGlas®
manufacturing facility shall not exceed 20%opacity. No monitoring,recordkeeping, or reporting required.
APPEARS IN COMPLIANCE—During the inspection,I observed 0%VE.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The SentryGlas®manufacturing facility shall not operate without implementing a management plan or
without odor control equipment.
APPEARS IN COMPLIANCE—No odors were noted surrounding this facility.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 13 of 15
*Polyvinyl Fluoride(PVF)Polymer Manufacturing Facilities (FS-B&FS-Q*
The facility#1 (FS-B)started operation in the latter portion of September 2007. The facility#2 began operation in
June 2010. Vinyl fluoride reacts in a continuous reactor to form crude polyvinyl fluoride(PVF). The PVF is
separated,sent through a batch filter press,then through a tubular drier. The final product is PVF solid powder. The
PVF produced at this facility is used for photovoltaic panels and aircraft interiors. There are no emission controls on
these two processes.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate emissions from the PVF facility shall not exceed 4.1 *P"'. The Permittee shall maintain
production records of the process rates in tons per hour. Semi-annual summary reporting is required.
APPEARS IN COMPLIANCE—The process control system records process rates. During the inspection,both
plant were shut down for maintenance. The last semi-annual summary report was received at FRO on
01/27/14.
15A NCAC 2D.0521 CONTROL OF VISIBLE EMISSIONS—Visible emissions from the PVF facility shall
not exceed 20%opacity. Once each month,the Permittee shall observe the emission points for any visible
emissions above normal. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—During the inspection both these plants were shut down for maintenance. The
baghouse exhaust point is paired with an exhaust from the steam tank. The emissions are observed daily and
logged on the operator log. A formal VE observation is made each month. The last monthly documented VE
observation was performed on 02/03/14 for both FS-B and FS-C. The last semi-annual summary report was
received at FRO on 01/27/14.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS(State Enforceable
Only)—The PVF facility shall not operate without implementing management practices or installing and
operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
APPEARSIN COMPLLANCE—During the inspection,I did not detect any objectionable odors.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the two PVF facilities(FS-B&FS-C)shall not exceed 40 TPY VOC. The
Permittee shall keep monthly records of VOC emissions calculated by methods in permit. Semi-annual
reporting is also required for monthly emissions(17 month period).
APPEARS INCOMPLL4NCE—The highest 12-month VOC emissions for the facility during 2013 was 22.8
tons VOC. The facility modified the permit to allow for measurement of VOC concentration in the exhaust by
using a densitometer during 2011. This has shown fewer emissions than the previous estimation method. The
12-month rolling total emissions have been dropping since this change was made. The latest 12-month rolling
total for calendar year 2013 was 22.8 tons VOC. The latest semi-annual report was received on 01/27/14.
*Multiple Emission Source(s)Specific Limitations and Conditions*
*Boilers*
15A NCAC 2Q.0317_PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the boilers(PS-A,PS-B,PS-C, and PS-Temp)shall not exceed the
following: 702.5 tons of SOZ per consecutive 12-month period. Records must be maintained for the
_ quantities of fuels used monthly. Fuel supplier certification must be maintained for fuel oil shipments.
Semi-annual reporting is required.

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
Page 14 of 15
APPEARS IN COMPLIANCE—The 12-month rolling total SO2 emissions from the 4 boilers is 0.2 tons as
of May 2013. Current fuel is natural gas. Only 5,635 gallons of ultra-low sulfur#2 fuel oil was used in
2013 during boiler tune-up and testing. Fuel oil certifications are available in the company records on site.
#2 fuel oil used is ultra-low sulfur content(< 15 ppm sulfur by weight.) The last semi-annual report was
received on 01/27/14.
*Facility-Wide* _
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permittee shall maintain records of production rates,throughputs,material usage,excess emissions,and
control equipment failures. A quarterly summary report is required
APPEARS IN COMPLIANCE—Production rates,material usages,emissions,and equipment failure
records are available on the company electronic data system. TAP reports are submitted quarterly and
show emissions well below the 2D .I100 limits. The last quarterly report was received at FRO on
01/27/14.
15A NCAC 2D.I 100 CONTROL OF TOXIC AIR POLLUTANTS(State Enforceable Only)—The
Permittee shall emit less than the limits listed in the permit for HF from high dispersion stacks and from all
other sources. The Permittee shall also report in a quarterly report,all TPER exceedances,the maximum 1-
hour emission rate and the maximum 24-hour emissions rate. The liquid flow rate in the Nation scrubbers
(NCD-Hdr-1 and NCD-Hdr-2)shall be a minimum 7,000 kg/hr. The Permittee shall maintain a logbook of
all inspection and maintenance activities on the applicable scrubber.
APPEARS IN COMPLIANCE—The liquid flow rates during the inspection were 11,645 kg/hr for Hdr-1
and 17,571 kg/hr for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber and is
interlocked to shut the systems down at 7,000 kg/hr and to alarm at 9,000 kg/hr. The electronic I&M
logbook appeared to be complete. TAP reports are submitted quarterly and show emissions well below the
2D .1100 limits. Hdr-1 and Hdr-2 are inspected every 4 years. The last inspection of Hdr-1 was performed
on 05/23/1.1 and the last inspection of Hdr-2 was performed on 08/25/11. The last quarterly report was
received at FRO on 01/27/14.
15A NCAC 2D.0541 CONTROL OF EMISSIONS FROM ABRASIVE BLASTING—Abrasive
blasting shall take place inside a building unless the item exceeds eight feet in length or is permanently
situated at an outside location. Fugitive emissions shall not migrate beyond the property boundaries.
APPEARS IN COMPLIANCE—The facility now has an abrasive blasting building in which the sand
blasting occurs. Outside blasting of tanks and equipment is accomplished using shrouds to contain the
blasting materials.
40 CFR Part 68 CHEMICAL ACCIDENT PREVENTION AND Clean Air Act,Section 112(r): The
Nafloe process is subject to 112(r)for sulfur trioxide,tetrafluoroethylene,and hydrogen chloride. The
Polymer Processing Aid Process(APFO)is subject to 112(r)for oleum.
APPEARS INCOMPLIANCE- The facility submitted the written Risk Management Plan to the U.S.
EPA in June 1999. In addition,the facility is subject to the OSHA Process Safety Management(PSM)
Standard. The latest update of the RMP was submitted by the facility to EPA on 02/01/11. A full 112(r)
compliance inspection was conducted by Greg Reeves and Mike Reid on 01/23/12. The facility was
deemed to be in apparent compliance during that inspection. The facility has the following processes
subject to 112(r):

DuPont Company—Fayetteville Works
Compliance Inspection Report
02/17/2014
- Page 15 of 15
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TFE Process 1 TFE(Tetrafluoroeth lene) 22,000
APFO Process 3 Oleum 50,000
PVF Process 1 Vinyl Fluoride 130,000
Nafion®Process 3 Sulfur Trioxide 33,000
Note that the APFO Process has been modified, and will no longer use Oleum. The facility is in the
process of cleaning out the oeum from process lines, vessels, and storage tanks,and will submit an update
to the RMP to EPA when this is completed in order to remove the APFO as a covered process from the
RMP.
COMPLIANCE CERTIFICATION [15A NCAC 2Q.0509(n)]: The facility is required to submit an
annual compliance certification to DAQ and EPA by March 1 of each year for the previous calendar year.
APPEARS IN COMPLIANCE—The 2013 compliance certification was received at FRO on 02/18/14.
7. COMPLIANCE HISTORY:
06/20/13 The facility was inspected by Greg Reeves and was found to be in apparent compliance.
01/23/12 A full 112(r)compliance inspection was conducted by Greg Reeves and Mike Reid. The facility was
deemed to be in apparent compliance during this inspection.
08/09/06 The facility was inspected 7 times during the period 2006 through 2010 by Christy Richardson,Robert
through Kennedy,Tien Nguyen, Maureen Matroni-Rakes, and Greg Reeves. The facility appeared to be in
05/19/11 compliance during each of these inspections.
01/06/09 The facility was issued a NOV/NRE for operating three sources(container decontamination processes)
without an air permit. The facility was fined and submitted their enforcement payment and an air
permit application to include these sources on the permit.
11/2007 The facility was issued a Notice of Violation(NOV)for failure to submit the Title V operating permit
application(Part 2)in a timely manner.
08/2007 The facility was issued a Compliance Additional Information(CAI)letter in concerning the permit
applicability of a paint operation and shot blast operation as well as abnormal visible emissions from
the boilers noted during two recent site visits.
8. CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 02/17/14
inspection,DuPont Company—Fayetteville Works APPEARS IN COMPLIANCE with the requirements outlined
in their current air permit,03735T38.
GWR
cc: FRO Facility Files