AQ_F_0900009_20110519_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY DuPont Company-Fayetteville Works
NC Facility ID 0900009
coon Re ort County/FIPS Bladen/017
Inspe p
Date:.05/19/2011
Facility Data Compliance Data
DuPont Company-an Fayetteville Works Inspection Date 05/19/2011
Y
22828 NC Highway 87 West Inspector's Name Gregory Reeves
Fa etteville,NC 28302 Operating Status Operating
Y
Lat:34d 50.6000m Long:78d 50.2930m Compliance Code Compliance inspection
SIC: 3081 /Unsupported Plastics Film And Sheet Action Code FCE
NAILS: 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/T36
Pe ,
Issued. 12/12/2010.
Michael Johnson Ellis McGaughy Michael Johnson Expires 1/31/2015
Environmental ManagerPlant Manager Environmental Manager p -
Classification Title V
[phone] [phone] [phone] Permit Status Active
Inspector's Signature: Comments:
Date of Signature:
1. MACT/GACT REVIEW:The Butacite®Polyvinyl Butyral Process and the Nafion®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
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 19,2011,I,Greg Reeves,of the Fayetteville Regional Office,met with
Mike Johnson,Environmental Manager,for a full compliance inspection. We reviewed daily records of the
completed batches and monthly records of total emissions from each affected MCPU.Mr.Johnson confirmed that
there have been no changes in emission sources since the previous inspection/permit modification and that the

DuPont Company -- Fayetteville Works
Compliance Inspection
05/19/2011
Page 2 of 14
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.
In the operating areas,inspection records are available on the computer in the plant SAP records. The recently
permitted second PVF facility has been completed and is in operation. The newly permitted boiler is not yet under
construction and Mr.Johnson stated that the modification would not happen in the near future.
We also discussed the recently submitted permit modification,requesting a change in the calculation of VOC
emissions from the Polyvinyl Fluoride process maintenance headers. This application was submitted to help the
facility avoid the 40 ton/yr PSD increment and subsequent PSD permitting.
6. PERMITTED EMISSION.SOURCES: At the time of the inspection,DuPont Company—Fayetteville Works was
operating under Permit No.03735T36 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
(2D.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 Dc (greater than 30.0 and less than 100.0
(21).1109 million Btu per hour maximum heat
Case-by-case input)
MACT)
BS-A But raldeh de storage tank BCD-A Brine-cooled condenser
Y Y g
BS-B 1.1 Butacite°polyvinyl butyral flake reactors BCD-B 1 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons.per minute water
BS-B 1.4 injection rate averaged over a 3-hour
MACT FFFFperiod) (state-enforceable,only)
BS-B2.1 Butacite°polyvinyl butyral flake reactors BCD-B2 Packed-bed column scrubber with mist
through (4 units) eliminator(8 gallons per minute water
BS-B2.4 injection rate averaged over a 3-hour
MACT FFFF eriod) (state-enforceable,only)
BS-C Butacite°polyvinyl butyral flake dryer BCD-Cl Cyclone separator
MACT FFFF BCD-C2 Fabric filter(6,858 square feet of filter
area)
BS-El Butacite't 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 use only)
BS-E3 Butacite't Line No.3 Back-End N/A NIA
Processes,including a quencher,
dryer/relaxer, and wind-up area

DuPont Company - Fayetteville Works
Compliance Inspection
05/19/2011
Page. 3 of 14
Emission Emission Source Description Control.Device Control Device Description
Source ID No. ID No.
BS-E4 Butaciteo Line No.4 Back-End N/A N/A
Processes,including a quencher,
dryer/relaxer., and wind-up area
BS-F Butaciteo' PVA Unloading System and NIA N/A
MALT FFFF Storage Silos
BS-G Butaciteo 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(BFPO) 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-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
Ji averaged over a 3-hourperiod)
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-hourperiod)
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)
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-hourperiod)
NS-G Nafion®Resins process NCD-G Venturi vacuum jet caustic scrubber
NIACT FFFF

DuPont Company - Fayetteville Works
Compliance Inspection
05/19/2011
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Emission Emission Source Description Control Device Control Device Description
Source ID No. ID No.
NS-H Nafion@ membrane process NIA NIA
NS-I Nafion@ membrane coating N/A NIA
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 NIA 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-A l 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 Sentr Glas0 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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Compliance Inspection
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7. APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each various manufacturing
process 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. 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,NOX,and S02. 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 MALT initially when it is
promulgated. Due to debottlenecking of the boilers by the PVF facility,DuPont now has a facility-wide PSD S02
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.
IN COMPLIANCE-The AP-42 emissions factor for Natural Gas is 0.007 lbs/mmBtu,for No.2 fuel oil is
0.024 lbs/mmB tu,and for No. 6 fuel oil is 0.16 lbs/mmBtu.
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.
IN COMPLIANCE—The AP-42 emissions factor for Natural Gas is 0.001 lbs/mmBtu,for No.2 fuel oil is
0.507 lbs/mmBtu,and for No.6 fuel oil is 2.20 lbs/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.
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 01/11/11.

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Compliance Inspection
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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.
IN COMPLIANCE Boiler PS-C is not yet under construction.
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.
IN COMPLIANCE—All reports show that the facility is well below these emissions limits. The current 12-
month total NOx emissions are 6.8 tons and S02 emissions are 0.1 tons. Since no No. b 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 01/11/11.
15A NCAC 2D.1.109 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
emission limitations of 0.45 lbs/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 30,2-014.
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 and_rotogravure printing
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.IO*P°,67. The permittee shall
maintain production records. The Permittee shall perform a monthly visual and annual internal inspection on
ba,ghouses BCD-Cl and BCD-C2. A logbook detailing these inspections must also be kept up to date.
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 10105110. The most recent external
inspection of the cyclone and bagfilter was 04/10/11.

DuPont Company - Fayetteville Works
Compliance Inspection
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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.
IN COMPLIANCE—During the inspection,I observed 0%VE. VE evaluations are performed once during
every shift despite the monthly requirement. The last summary semi-annual report was_received on 01/11/11 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-B1 and BCD-B2 shall beat 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..
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 l and BS-B2 are controlled by packed-
bed scrubbers BCD-B 1 and BCD-B2. The most recent annual internal inspection of BCD-A was on 07/27/10.
The differential pressure is maintained below 2 inches of water. Alarms automatically sound if the limits are
exceeded. No odor was noted during the inspection.. The liquid flow rates to BCD-B 1 and BCD-B2 were 10
gprn each during the inspection. The most recent annual internal inspections of BCD-B 1 and BCD-B2 were
performed on 07/27/10.
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).
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 indicate an emission rate of 3,617 lbs per year.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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Compliance Inspection
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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 Nafion®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*P0,67. The Permittee shall
maintain production records. A semi-annual summary report is required.
IN COMPLIANCE—Production records are available at each manufacturing facility. The last semi-annual
summary report was received at FRO on 01/11/11.
.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.
IN 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.
IN COMPLIANCE--Odorous emissions from the Nafion process are controlled by two baffle-plate scrubbers
NCD-Hdr 1 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.
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.
IN COMPLIANCE—The liquid flow rate during the inspection for.Hdr-1 was 12,575 kg/hr and for Hdr-2 was
17,506 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 24.11 TPY of VOCs.
The last semi-annual report was received at FRO on 01/11/11.
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.
IN COMPLIANCE—The current VOC emissions are 31.19 tons per 12-month period. The last semi-annual
summary report was received at FRO on 01/11/11.

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Compliance Inspection
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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.
IN COMPLIANCE—The current VOC emissions are 24.49 tons per 12-month period. The last semi-annual
summary report was received at FRO on 01/11/11.
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. Semii-annual summary reporting is required.
IN COMPLIANCE—The current VOC emissions are 21.81 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 is reducing
emissions tremendously;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 01/11/11.
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. The compliance date was 10
November 2006,but was extended by EPA to May 10,2008. Semi-annual summary reporting is required.
IN COMPLIANCE—The scrubbers currently controlling the Nafion process(NCD-Hdrl 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. No controls are required,however,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 MALT 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 01/11/11. Amore 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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Compliance Inspection
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Polymer Processing Aid Process(all sources labeled with AS-and ACD-)
The poly p rocessing aid process,formerly the ammonium perfluorooctanoate(APFO.)process,began operation in
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
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. By 2010, the facility is planning to manufacture 50%APFO and 50%PFOA at this manufacturing facility.
DuPont has made a decision to eliminate APFO by 2015.
15A NCAC 2D.1806 CONTR.OLAND PROHIBITION OF ODOROUS EMISSIONS—The Polymer
Processing Aid Process facility shall not operatevithout implementing a management plan or without odor
control equipment.
IN COMPLIANCE—The APFO process is controlled by scrubbers. During the inspection,this
process was not operating. The facility was shut down for annual inspections.
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.
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 process was shut down for annual inspections,but the scrubber was still in
operation. The liquid flowrate during the inspection was 38 gpm, and the pressure drop across the scrubber bed
was 0.2"H2O. The last internal inspection of the scrubber was performed on 05/20/2010. The scrubber will be
inspected during this shutdown,probably on 05/20/11.
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.

DuPont Company - Fayetteville Works
Compliance Inspection
05/19/2011
Page 11 of 14
*Wastewater Treatment Area(all sources labeled with WTS-and WTCD-I*
For the wastewater treatment operations,the Title V permit specifies two rotary sludge dryers controlled by an
impingement-type wet scrubber with mist eliminator('2.9 gallons per minute dilute potassium hydroxide solution).
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.
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 inspection was 12/15/10.
*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.
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.
15A NCAC 2D.0524 NEW SOURCE PERFORMANCE STANDARDS(Subpart De)—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.
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 2010.
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).
IN COMPLIANCE—The boiler was not on site during 2010.
15A NCAC 2D.11.09 CASE-BY-CASE MACT—This stipulation includes requirements for boiler-PS-Temp
that were instituted as a result of the vacating of the Boiler MALT. The compliance requirement for the boiler
under this regulation is a tune-up of the boiler each per calendar year. No reporting is required.
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.

DuPont Company - Fayetteville Works
Compliance Inspection
05/19/2011
Page 12 of 14
SentryGlas@ Plus Manufacturing Facility (SGS-A)
The SentyGlasa 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.
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.
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. Vinyf 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 *P0-67. The Permittee shall maintain
production records of the process rates in tons per hour. Semi-annual summary reporting is required.
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-01/11/11.
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.
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 01/11/11.
15A NCAC 2D.1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—The PVF facility
shall not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE—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 the following: 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).
IN COMPLIANCE—The 11-month emissions for the facility are 32.43 tons VOC. The facility has submitted a
permit application to allow for a different method for determining the VOC emissions from this process. The
new method involves the use of a densitometer to determine the concentration of vinyl fluoride in the emission
stream.

DuPont Company - Fayetteville Works
Compliance Inspection
05/19./2011
Page 1.3 of 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 S02 per consecutive 12-month period.
IN COMPLIANCE—The 12-month rolling total S02 emissions from the 4 boilers is 4 tons as of April
2011.
Facility-Wide*
15A NCAC 2D .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
IN COMPLIANCE—TAP reports are submitted quarterly and show emissions well below the 2D .1100
limits. The last quarterly report was received at FRO on 04/28/11.
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.
IN COMPLIANCE—The liquid flow rates during the inspection were 17,506 kg/hr for Hdr-1 and 12,575
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 .1100 limits. Hdr-1 and Hdr-2 are inspected every 4 years. The last inspection of Hdr-1 was performed
on 06/18/10 and the last inspection of Hdr-2 was performed on 09/24/10. The last quarterly report was.
received at FRO on 04/28/11.
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.
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.
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.

DuPont Company - Fayetteville Works
Compliance Inspection
05/19/2.011
Page 14 of 14
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 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 addition 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 Tien Nguyen,Maureen Matroni-Rakes,
and Greg Reeves on 05/27/10. The facility appeared to be in compliance during this inspection.
The facility was inspected 5 times during the period 2006 through 2009 by Christy.Richardson and Robert Kennedy.
The facility appeared to be in compliance during each of these inspections.
9. CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 05/19/2011
inspection,DuPont Company--Fayetteville Works appeared to be operating in compliance with the requirements
outlined in their current air permit,03735T36.
I will add the diesel-fired fire pump and small emergency generator to the pink sheet for inclusion on the next permit
revision.
GWR
cc: FRO Facility Files(blue)