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HomeMy WebLinkAboutAQ_F_0900009_20130228_CMPL_CmpltRpt Complaint Investigation Report County: Bladen Region: FRO NC Dept. of Environment&Natural Resources Suspect: DuPont Company-Fayetteville Works 09 Division of Air Quality Facility ID# 143 0 0 Record# 14308 Regional Investigator: Reeves, Gregory Suspect: DuPont Company-Fayetteville Works Regional Co-investigator: Suspect Contact: Ellis H. McGaughy Non-DAQ Investigator: Physical Location: 22828 NC Highway 87 West- Fayetteville Date Complaint Received: 02/28/2013 Mailing Address: 22828 NC Highway 87 West Received By: Reeves, Gregory City/State/Zip: Fayetteville NC 28306 Date assigned: 02/28/2013 Telephone: (910)678-1546 Alternate Telephone: Investigation date: 02/28/2013 Complainant: Gregory Reeves Follow-up date: Complainant Address: 225 Green Street Suite 714 Report submit date: City/State/Zip: Fayetteville NC 28301 Telephone(H): Complaint type: OTHER Telephone(W): (910)433-3373 Complaint description: Release of unknown Call Back Required? No Response Requested quantity of methylene chloride(dichloromethane) from coolant line Referral to DAQ: EPA Situation Dangerous: Violation documented: Occurring Now: DFR Permit: Signature: qz-(:4 Report Date: 011 YZ40a Comments/Directions: 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 Highway 87 just before the Cumberland/Bladen County line. Summary of investigation: On 02/28/13 at 09:39 AM, Greg Reeves of FRO received a telephone call from Mike Johnson at DuPont. Mr. Johnson reported that early the morning of 02/28/13 the facility had a small release of methylene chloride (dichloromethane)from a process coolant line, resulting in a release of less than 100 lbs of methylene chloride. Mr. Johnson stated that the release had been reported to the NRC. Upon investigation,the leak was caused by a pinhole in a 3/8"diameter tubing line carrying methylene chloride for a heat tracing line. The leak was isolated, the line drained, and repairs made. It was estimated that the release was less than 100 Ibs of material. The reportable quantity for methylene chloride is 1,000 Ibs, so the leak was below the reportable threshold. DuPont corporate policy is to report the leak within the 15 minute reporting requirement since the amount of material released will probably not be apparent at the time of reporting. The facility will have a meeting on Monday 03/04/13 to discuss the investigation and will send DAQ a follow-up communication on results of the investigation. FOLLOW-UP 03/04/13: Greg Reeves received an email from Mike Johnson at DuPont. The investigation determined that approximately 30 pounds of methylene chloride was released through the pinhole leak in a 3/8"diameter tubing over a 4.5 hour period. This equates to an average leak rate of 6.7 lb/hr,versus the Title V permit emission limit of 24.85 lb/hr. No additional action is required. The investigation was done from the Fayetteville Regional Office, and there was no site visit. Investigation completed 03/04/13 /GWR Reeves, Gregory W From: Michael.E.Johnson@dupont.com Sent: Monday, March 04, 2013 1:47 PM To: Reeves, Gregory W Subject: DuPont- Fayetteville Works : Methylene Chloride Release (02-28-2013) Greg: This is the requested follow-up notice regarding the release of methylene chloride that was reported on February 28, 2013. The methylene chloride was released from a pinhole in a piece of 3/8-inch copper tubing inside the Vinyl Ethers North Tower. The air in this tower is continuously vented through a duct leading to the Nafion® Division Stack Blower. An in- line gas chromatograph inside the vent duct measured the methylene chloride concentration, and using this concentration and the volumetric flow rate through the duct, it has been estimated that approximately 30 pounds of methylene chloride was release during a 4.5 hour period. This averages to 6.7 Ib/hr of methylene chloride versus the Title V Air Permit limit of 24.85lb/hr. We also used "AFT Fathom" which is a Incompressible Pipe Flow Analysis&System Modeling Software to estimate the leak rate. Methylene chloride was the specified chemical in this model. The model assumed a 0.0157-inch diameter hole in the tubing, which is roughly twice the area of the actual irregularly shaped hole. The model also assumed a driving force pressure of 500 kPa, which is the discharge pressure of the circulation pump and would be substantially greater than the actual pressure at the site of the leak. With these very conservative assumptions,the "AFT Fathom" software estimated a 20.22 Ib/hr methylene chloride leak rate versus the Title V Air Permit limit of 24.85 lb/hr. Therefore we are confident that the February 28, 2013, methylene chloride release was well below the Title V Air Permit limit of 24.85 lb/hr. Michael E.Johnson Environmental Manager DuPont Company—Fayetteville Works This communication is for use by the intended recipient and contains information that may be Privileged, confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously designated as "E-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. 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