AQ_F_0900009_20120523_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: 05/25/2012
Facility Data Compliance Data
DuPont Company-Fayetteville Works Inspection Date 05/23/2012
22828 NC Highway 87 West Inspector's Name Gregory Reeves
Fayetteville,NC 28306 Operating Status Operating
Lat: 34d 50.6000m Long: 78d 50.2930m Compliance Code Compliance- inspection
SIC: 3081 /Unsupported Plastics Film And Sheet Action Code FCE
NAICS: 326113 /Unlaminated Plastics Film and Sheet(except Packaging) On-Site Inspection Result Compliance
Manufacturing
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 03735/T37
Michael Johnson Ellis McGaughy Michael Johnson Issued 8/17/2011
Environmental Manager Plant Manager Environmental Manager Expires 1/31/2015
[phone] [phone] [phone] Classification Title V
Permit Status Active
Inspector's Signature: Comments:
Date of Signature: d5f 5 f��1� q A
1. MACT/GACT REVIEW: The Butacite©Polyvinyl Butyral Process and the Nafiong processes are subject to
NESHAP Subpart FFFF"Miscellaneous Organic Chemical Manufacturing". Butacite®process wastewater is
classified as Group 2 because the concentration of methanol in the wastewater falls well below the Group 1
threshold of 30,000 ppmw. There is an emergency generator that is subject to NESHAP Subpart ZZZZ. In addition,
there is a 370 HP diesel-fired fire pump located at the facility(manufacturing date prior to 2001). This unit is also
subject to NESHAP Subpart ZZZZ.
2. 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 Highway 87 just before the Cumberland/Bladen County line.
3. SAFETY CONSIDERATIONS: The usual FRO safety gear is required(hardhat, safety glasses, safety shoes,
hearing protection). Entry into several areas of the plant require 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.
4. 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,as well as one permitted temporary boiler.
5. INSPECTION SUMMARY: On May 23,2012, 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 noted that the zip code for the facility is incorrect. The correct zip code is 28306. I will correct that in the
IBEAM Facilities Module. We reviewed daily records of the completed batches and monthly records of total

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Compliance Inspection
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emissions from each affected MCPU. There are extensive electronic records available for the facility operations.
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 now. For the operating areas, inspection records are available on the computer in
the plant SAP records for most of the inspection items. The two PVF facilities have been operating at reduced
capacity recently due to the economy,as has the Butacite©facility. The PPA facility(formerly APFO facility) is in
the process of converting from the production of APFO to a new product that will replace it. The newly permitted
boiler(PS-C)is not yet under construction 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.
6. PERMITTED EMISSION SOURCES: At the time of the inspection,DuPont Company—Fayetteville Works was
operating under Permit No. 03735T37 which includes the following emission sources:
Emission Emission Source Description Control Device Control Device Description
Source ID No. ID No.
PS-A Natural Gas/No. 2 fuel oil/No. 6 fuel oil- N/A N/A
(21).1109 fired boiler(139.4 million Btu per hour
Case-by-case maximum heat input)
MACT
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
PS-C Natural Gas/No.2 fuel oil-fired boiler N/A N/A
NSPS Dc (97 million Btu per hour maximum heat
(21).1109 input)equipped with a low-NOx burner
Case-by-case
MACT)
PS-Temp Natural Gas/No.2 fuel oil-fired boiler N/A N/A
NSPS De (greater than 30.0 and less than 100.0
(213.1109 million Btu per hour maximum heat
Case-by-case input)
MACT
BS-A Butyraldehyde storage tank BCD-A Brine-cooled condenser
BS-131.1 Butacite polyvinyl butyral flake reactors BCD-131 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons per minute water
BS-131.4 injection rate averaged over a 3-hour
MACT FFFFperiod)(state-enforceable,only)
BS-132.1 Butaciteo polyvinyl butyral flake reactors BCD-132 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons per minute water
BS-132.4 injection rate averaged over a 3-hour
MACT FFFFperiod)(state-enforceable,only)
BS-C Butaciteo polyvinyl butyral flake dryer BCD-CI Cyclone separator
MACT FFFF 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)
BS-E2 Butacite Line No.4 Sheeting Extrusion BCD-E2 Water-Cooled Condenser(voluntary
Process, including four(4)extruders I use only)

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Emission Emission Source Description Control Device Control Device Description
Source ID No. ID No.
BS-E3 Butacite Line No. 3 Back-End N/A N/A
Processes, including a quencher,
dryer/relaxer,and wind-up area
BS-E4 Butacitew Line No.4 Back-End N/A N/A
Processes, including a quencher,
dryer/relaxer,and wind-up area
BS-F Butacite PVA Unloading System and N/A N/A
MACT FFFF Storage Silos
BS-G Butacitew PVA Dissolver Tank System N/A N/A
MACT FFFF
NS-A Nafion&Hexfluoropropylene epoxide NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF process(HFPO) 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-B Nafion©Vinyl Ethers North process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF 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-C Nafion&Vinyl Ethers South process NCD-Hdrl Baffle-plate scrubber(7,000
MACT FFFF 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 Nafion®RSU Process NCD-Hdrl Baffle-plate scrubber(7,000
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-E Nafion&Liquid waste stabilization NCD-Hdrl Baffle-plate scrubber(7,000
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)

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Compliance Inspection
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Emission Emission Source Description Control Device Control Device Description
Source ID No. ID No.
NS-F Nafion®MMF process NCD-Hdrl Baffle-plate scrubber(7,000
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 Nafion®Resins process NCD-G Venturi vacuum jet caustic scrubber
MACT FFFF
NS-H Nafion©membrane process N/A N/A
NS-I Nafion©membrane coating N/A N/A
NS-J Nafion©semiworks N/A N/A
NS-K Nafion©E-2 Process N/A N/A
NS-L Nafion®TFE/HCl separation unit NCD-Hdrl Baffle-plate scrubber(7,000
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-M Nafion©TFE/CO2 separation process N/A N/A
NS-N HFPO product container decontamination N/A N/A
process
NS-O Vinyl Ethers North product container N/A N/A
decontamination process
NS-P Vinyl Ethers South product container N/A N/A
decontamination process
SW-1 Semiworks polymerization operation N/A N/A
SW-2 Semiworks laboratory hood N/A N/A
AS-A Polymer Processing Aid Process ACD-Al Wet scrubber(30 gallons per minute
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
WTS-B, Two(2) Indirect steam-heated,rotary WTCD-1 Impingement-type wet scrubber with
WTS-C sludge dryers mist eliminator(state-enforceable only)
SGS-A SentryGlas Process N/A N/A
FS-B Polyvinyl Fluoride Process No. 1 N/A N/A
FS-C Polyvinyl Fluoride Process No. 2 N/A N/A

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7. APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each of the various
manufacturing processes as listed on the current air permit.
*Powerhouse(PS-A,PS-B,and PS-C)*
The facility is permitted to operate one Natural Gas/No. 2/No. 6 fuel oil-fired boiler(139.4 mmBtu/hr maximum
heat input, PS-A),one Natural Gas/No. 2/No. 6 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. The boilers are currently combusting natural gas. The#6 fuel oil storage tank has been
removed from service, and the facility has no plans to combust#6 fuel oil. The facility may request that this
capability be removed from the permit in the future. The larger boiler(PS-A)has a steam capacity of 113,000
pounds of steam per hour and was manufactured in 1969. The smaller boiler(PS-B)was manufactured in 1982 with
a steam capacity of 72,000 pounds per hour. 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 Dc when
constructed. All three of the boilers are now subject to the 2D .1109 Case-by-case MACT condition, in lieu of the
vacated Boiler MACT(NESHAP Subpart 5D). Therefore,they will not be subject to the Boiler MACT initially
when it is promulgated. Due to debottlenecking of the boilers by the PVF facility, DuPont now has a facility-wide
PSD SOZ emissions limitation.
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from boilers PS-1 and PS-2 shall not exceed 0.2667 lbs/mmBtu. Particulate emissions
from PS-C shall not exceed 0.2268 lbs/mmBtu.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu, for No.2
fuel oil is 0.024 Ibs/mmBtu,and for No. 6 fuel oil is 0.16 lbs/mmBtu. The facility is currently combusting
natural gas. The last#6 fuel oil was combusted in March 2008. The last#2 fuel oil was combusted in June
2011.
15A NCAC 2D.0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—The sulfur
dioxide emissions from boilers PS-A and PS-B shall not exceed 2.3 pounds per million Btu heat input. The
sulfur content of No. 6 fuel oil shall not exceed 2.1%sulfur by weight. The Permittee shall maintain fuel
certifications for all No. 6 fuel oil shipments.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.001 Ibs/mmBtu, for No.2
fuel oil is 0.507 lbs/mmBtu,and for No. 6 fuel oil is 2.20 Ibs/mmBtu. As long as the No. 6 fuel does not exceed
the fuel sulfur limit,the regulatory limit will not be exceeded during normal operation. The facility has not
combusted No. 6 fuel oil since March 2008 and has no plans to combust it again. The No.6 fuel oil tank has
been emptied and cleaned out and is currently marked on the tank as being out of service. All No. 2 fuel oil is
below 0.5%sulfur by weight and most of the No.2 fuel was ultra-low sulfur fuel oil(15 ppm).
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. The
permittee shall record a daily visible emissions evaluation(normal or above normal)when combusting No. 6
fuel oil and maintain a logbook showing the results of each evaluation. These results from monitoring must be
submitted to DAQ in a semi-annual report.
APPEARS IN COMPLIANCE—The boilers are currently combusting natural gas and I observed 0%opacity
from the boiler stack. The facility is not required to conduct daily VE observations unless they are combusting
No. 6 fuel oil. The last semi-annual summary report was received at FRO on 01/23/12.

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15A NCAC 2D.0524 NEW SOURCE PERFORMANCE STANDARDS—SUBPART Dc—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 as well. NSPS Construction and startup notifications are
required.
APPEARS IN COMPLIANCE—Boiler PS-C is not yet under construction,and there are no current plans to
build this unit.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from Boiler PS-B shall not exceed the following: 40 TPY NOX,and 40 TPY S02.
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 define all deviations in the report.
APPEARS IN COMPLIANCE—All reports show that the facility is well below these emissions limits. The
highest 12-month total NOx emissions during 2011 were 8.0 tons and SO2 emissions were 0.1 tons. Since no
No. 6 fuel oil has been combusted, I did not review the fuel certifications during the inspection. The last semi-
annual report was received at FRO on 01/23/12.
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 MACT. Requirements include
emission limitations of 0.45 Ibs/mmBtu Filterable PM,2.0E-05 lbs/mmBtu Mercury(Hg), and 28 ppmvd
Carbon Monoxide(CO). Stack testing is required within 180 days of the initial compliance date of December
12,2013. Periodic fuel analysis may be used to show compliance with the Hg standard. A tune-up of each
boiler is required per calendar year. A Notification of Compliance Status is required to be submitted within 60
days following the completion of the final performance test or compliance demonstration. Semi-annual
reporting is required,starting January 30,2014.
APPEARS IN COMPLIANCE—The initial compliance date for this regulation is December 12,2013.
Therefore,no action is needed as yet.
*Butacite®Process Area(all sources labeled with BS-and BCD-)*
The Butacite®manufacturing operation includes: (1)a polyvinyl butyral sheeting operation. The operation
produces flexible glass laminate for car windshields. (2)the butyraldehyde storage tank,with emissions and
potential odors from the butyraldehyde controlled by a brine-cooled(ethylene glycol)condenser. (3)the Butacite
flake reactors,controlled by packed-bed column scrubbers,and(4)a butacite flake dryer,controlled by a cyclone
separator and fabric filter. At this time one of the Butacite lines is not operating. Portions of the Butacite area are
subject to the MON requirements.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate matter emissions from the Butacite process shall not exceed E=4.10*P067. The permittee shall
maintain production records. The Permittee shall perform a monthly visual and annual internal inspection on
baghouses BCD-Cl and BCD-C2. A logbook detailing these inspections must also be kept up to date.
APPEARS IN COMPLIANCE—The flaking process is controlled by bagfilters to reduce particulate matter
emissions. Visual inspections on these bagfilters are performed on a daily basis and annual inspections are
performed as well. Each facility can detail the amount of production for any given time period to meet the
requirement of production records. The most recent annual internal inspections were on 10/28/11. The most
recent external inspection of the cyclone and bagfilter was 04/03/12.

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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 IN COMPLIANCE—During the inspection, I observed 0%VE. VE evaluations are performed
once during every shift despite the monthly requirement. The last formal monthly VE evaluation was
performed on 04/03/12. The last summary semi-annual report was received on 01/23/12 at FRO.
15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS—The Butacite
process shall not operate without odor control equipment. 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 less than 30 inches of water over a three-hour period. The Permittee shall perform
periodic inspections and maintenance of 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-B1 and BS-B2 are controlled by
packed-bed scrubbers BCD-B 1 and BCD-B2. External inspections are performed every two years. The most
recent biennial external inspection of BCD-A was on 09/01/10. No odor was noted during the inspection. The
liquid flow rates to BCD-B 1 and BCD-132 were 10.0 gpm each during the inspection. The differential pressures
across the scrubbers BCD-B I and BCD-B2 were 7" H2O and 6"H2O, respectively. The most recent annual
internal inspections of BCD-B1 and BCD-B2 were performed on 07/03/11 and 07/05/11,respectively.
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.

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*Nafion®Process Area (all sources labeled with NS-and NCD-)*
The Nafion©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 NafionOO membrane material. A principal use of the membrane is in the
electrolysis cells for production of chlorine and sodium hydroxide at chlor-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 acid fluorides. The Nafion©process at this facility manufactures plastic materials classified
under SIC code 2821,and are therefore existing affected sources under the"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*P067. 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 01/23/12.
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.
APPEASRSIN COMPLIANCE—During the inspection, I observed 0%VE.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The Nafion
process shall not operate without odor control equipment.
APPEARS IN COMPLIANCE—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.
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 baffle-plate tower scrubbers must maintain a liquid flow rate of at least 7,000 kilograms per hour.
The Permittee shall keep monthly records of VOC emissions. Semi-annual reporting is required.
APPEARS IN COMPLIANCE—The liquid flow rate during the inspection for Hdr-1 was 12,100 kg/hr and for
Hdr-2 was 17,500 kg/hr. The scrubber utilizes a potassium hydroxide solution in the scrubber and is
interlocked to shut the system down at 7,000 kg/hr and to alarm at 9,000 kg/hr. 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 of 25.86
TPY of VOCs. The last semi-annual report was received at FRO on 01/23/12.
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 IN COMPLIANCE—The highest 12-month VOC emissions during 2011 were 32.64 tons per 12-
month period. The last semi-annual summary report was received at FRO on 01/23/12.

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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 2011 were 26.43 tons per 12-
month period. The last semi-annual summary report was received at FRO on 01/23/12.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the HFPO container decontamination unit(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 2011 were 23.18 tons per year.
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 01/23/12.
40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP(MON)—The Nafion®process
must comply with all provisions of this MACT. 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 Nafion process(NCD-Hdr 1 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 this calendar year. The last semi-annual
summary report was received at FRO on 01/23/12. 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.

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I Page 10 of 14
*Polymer Processing Aid Process(all sources labeled with AS-and ACD-)*
The polymer processing aid process,formerly the ammonium perfluorooctanoate(APFO)process,began operation in
a December of 2002. 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
'j reacted with ammonia to produce the ammonium salt. Fuming sulfuric acid(oleum) is received by truck and used as a
j solvent in the process. Currently,APFO and the associated perfluorooctanoic acid(PFOA),also known as C8, are not
p 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,and is currently producing some of the replacement
polymer in the existing reactor for APFO. Expectation is that APFO will be phased out at this facility by sometime in
2013.
15A NCAC 2D.1806 CONTROLAND PROHIBITION OF ODOROUS EMISSIONS—The Polymer
Processing Aid Process facility shall not operate without implementing a management plan or without odor
control equipment.
APPEARS IN COMPLIANCE—The APFO process is controlled by scrubbers. No odors were
noticeable during the inspection.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS—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. 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. APFO is a surfactant;therefore,the DP increases
occasionally due to `suds' in the scrubber. The liquid flowrate during the inspection was 38.9 gpm, and the
pressure drop across the scrubber bed was 0.1"H2O. The last internal inspection of the scrubber was performed
on 05/19/2011.
Results of the stack tests in March 2006 and April 2006 show that approximately 62 lbs of PFOA is emitted
from this facility per year. To further reduce these emissions,the facility added a HEPA filter to control PFOA
(a particulate)from the building exhaust. The building exhaust appears to be the source of most(80-90%)of
these emissions.

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Page 11 of 14
*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. 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 annual inspection was 11/04/11.
*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. In the near future,a temporary boiler will be brought on site during the
shutdown of boiler BS-A for maintenance.
15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—
Particulate emissions from the temporary boiler shall not exceed 0,2426 lbs/mmBtu.
APPEARS IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu and for No.
2 fuel oil is 0.024 lbs/mmBTU. This boiler was not on site during 2011.
15A NCAC 2D.0524 NEW SOURCE PERFORMANCE STANDARDS(Subpart Dc)—The sulfur content
of all received fuel oil shall not exceed 0.5%sulfur by weight. The Permittee shall maintain fuel certifications
and monthly amounts of fuel burned. The facility must provide notification when the unit is brought on-site and
operational. The facility must also conduct Method 9 testing and submit associated protocol,etc after startup.
APPEARS IN COMPLIANCE—Fuel certs indicate fuel oil has been less than 0.5%sulfur by weight;actually
most is 15 ppm sulfur. However,this boiler was not on site during 2011.
15A NCAC 2Q.0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS—Emissions from the temporary boiler PS-Temp shall not exceed the following: 40 TPY S02.
The Permittee shall keep monthly records of the amount of fuel combusted. Semi-annual reporting is also
required for monthly combustion and all deviations(17 month period).
APPEARS IN COMPLIANCE—The boiler was not on site during 2011.
15A NCAC 2D.1109 CASE-BY-CASE MACT—This stipulation includes requirements for boiler PS-Temp
that were instituted as a result of the vacating of the Boiler MACT. The compliance requirement for the boiler
under this regulation is a tune-up of the boiler each per calendar year. No reporting is required.
APPEARS IN COMPLIANCE—The initial compliance date for this regulation is December 12,2013.
Therefore, no action is needed as yet. In addition,the boiler is not yet on site.

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*S_entryGlas®Plus Manufacturing Facility (SGS-A)*
The SentyGlas©plant began operation 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—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.
*Polyvinyl Fluoride(PVF)Polymer Manufacturing Facility (FS-B&FS-C)*
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.
15A NCAC 2D.0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES—
Particulate emissions from the PVF facility shall not exceed 4.1 * P°'67. 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,and we did not notice any
emission of particulates. The last semi-annual summary report was received at FRO on 01/23/12.
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 point of the baghouse for
any visible emissions above normal. A semi-annual summary report is required.
APPEARS IN COMPLIANCE—During the inspected I observed 0%VE. The baghouse exhaust point is
paired with an exhaust from the steam tank. The emissions are observed daily. The last semi-annual summary
report was received at FRO on 01/23/12.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—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.
APPEARS IN COMPLIANCE—During the inspection, I did not detect any objectionable odors.

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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 IN COMPLIANCE—The highest 12-month VOC emissions for the facility during 2011 were 36.99
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 through April 2012 was slightly more than 24 tons VOC.
*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 natural gas,#2 and#6 fuel oil used monthly. Fuel supplier certification must be maintained
for fuel oil shipments. Semi-annual reporting is required.
APPEARS IN COMPLIANCE—The 12-month rolling total SOZ emissions from the 4 boilers is 4 tons as
of April 2011. Current fuel is natural gas. No#6 fuel oil was used during 2011. 250,000 gallons of#2 fuel
oil was used in 2011. 581 mmcf of natural gas was combusted during 2011. Fuel oil certifications are
available in the company records on site. #2 fuel oil sulfur content was an average of 0.137%by weight.
The last semi-annual report was received on 01/23/12 at FRO.
* Facility-Wide*
15A NCAC 213.1100 CONTROL OF TOXIC AIR POLLUTANTS—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 .1100 limits. The last quarterly report was received at FRO on
04/26/12.
15A NCAC 2D.1100 CONTROL OF TOXIC AIR POLLUTANTS—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 Nafion scrubbers shall be at 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 12,100 kg/hr for Hdr-1
and 17,500 kg/hr for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber. The
electronic I&M logbook appeared to be complete. TAP reports are submitted quarterly and show emissions
well below the 2D .1 100 limits. Hdr-I and Hdr-2 are inspected every 4 years. The last inspection of Hdr-I
was performed on 05/23/11 and the last inspection of Hdr-2 was performed on 11/04/10. The last
quarterly report was received at FRO on 04/26/12.

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Page 14 of 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.
A APPEARS IN COMPLIANCE—The facility now has an abrasive blasting building in which the sand
blasting occurs.
40 CFR Part 68 CHEMICAL ACCIDENT PREVENTION AND Clean Air Act,Section 112(r): The
Nafion 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 IN COMPLIANCE- The facility submitted the initial Risk Management Plan to the U.S. EPA
in June 1999. In addition,the facility is subject to the OSHA Process Safety Management Standard. The
latest update of the RMP was submitted by the facility to EPA on 08/29/07. 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.
COMPLIANCE CERTIFICATION [15A NCAC 2Q.0509(n)]: The facility is required to submit an
annual compliance certification to DAQ and EPA by March I of each year for the previous calendar year.
APPEARS IN COMPLIANCE—The 2011 compliance certification was received at FRO on 01/30/12.
8. COMPLIANCE HISTORY: On 6 January 2009,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. In November 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. The facility was issued a Compliance Additional Information(CAI) letter in August 2007 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.
The most recent facility air quality compliance inspection was conducted by Greg Reeves on 05/19/11. The facility
was deemed to be in apparent compliance during this inspection.
A full 112(r)compliance inspection was conducted on 01/23/12 by Greg Reeves and Mike Reid. The facility was
deemed to be in apparent compliance during this inspection.
The facility was inspected 6 times during the period 2006 through 2010 by Christy Richardson, Robert Kennedy,
Tien Nguyen, Maureen Matroni-Rakes,and Greg Reeves. The facility appeared to be in compliance during each of
these inspections.
9. CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 05/23/2012
inspection,DuPont Company—Fayetteville Works APPEARS IN COMPLIANCE with the requirements outlined
in their current air permit, 03735T37.
GWR
cc: FRO Facility Files(yellow)