DEQ-CFW_00065593

NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit issue Date: 09/15/2015
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 W
Fayetteville, NC 28306
SIC: 2821 / Plastics Materials And Resins
NAICS: 325211 / Plastics Material and Resin Manufacturing
Facility Classification: Before: N/A After: Small
Fee Classification: Before: N/A After: Small
Contact Data
Facility Contact
D. Faye Godwin
SHE Competency
Consultant
[phone]
22654 NC Hwy 87 W
Fayetteville, NC 28306
Authorized Contact
Donald Stockhausen
Plant Manager
[phone]
22654 NC Hwy 87 W
Fayetteville, NC 28306
Technical Contact
D. Faye Godwin
SHE Competency
Consultant
[phone]
22654 NC Hwy 87 W
Fayetteville, NC 28306
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900092
Inspector's Name:
Date of Last Inspection:
Compliance Code:
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
NEW PERMIT
EXISTING FACILITY
Application Data
Application Number: 0900092.15A
Date Received: 08/06/2015
Application Type: New Permit
Application Schedule: State
Existing Permit Data
Existing Permit Number: N/A
Existing Permit Issue Date: N/A
Existing Permit Expiration Date: N/A
Review Engineer: Joshua L. Harris Comments / Recommendations:
Issue 10458R00
Review Engineer's Signature: Date: Permit Issue Date: 09/15/2015
Permit Expiration Date: 08/31/2023
1. Purpose of Application
DuPont Company — Fayetteville Works is an existing facility in Fayetteville, Bladen County that has
legally separated from Chemours FC, LLC (0900009), a spinoff company. The two facilities are
currently operating under the same Title V permit, 03735 T40, and occupy adjacent properties.
DuPont is requesting a new permit as an existing facility, and will retain operational control of the
two polyvinyl fluoride (PVF) processes. Chemours will retain the existing Title V permit, and
control of all other emission sources.
The facility did make a request for confidentiality. FRO sent the facility a letter acknowledging this
request.
The facility is classified as Small.
The application included the required $50.00 fee.
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• DuP• Company — Fayetteville Works
Permit R00 Review
Page 2
There are no facility Pink Sheet items.
The facility contact is D. Faye Godwin, SHE Competency Consultant, (910-213-1383).
2. Facility Description
DuPont produces bulk polyvinyl fluoride (PVF) that is used to make protective films for a myriad of
industrial uses including solar and wind energy, transportation, and circuit board manufacturing.
Vinyl fluoride (VF) is received and run through a separation process to remove stabilizers which are
added during transport and storage. The VF, along with modifiers and inorganic salts, are fed through
a continuous reactor where it polymerizes to form crude PVF.
The PVF is then isolated in a separator system followed by a filter press, a heated -air dryer, and
finished product packaging. Chemours provides steam to DuPont for the heated -air dryer, so there
are no combustion sources involved. The final product is a powdered solid which is packaged in bulk
bags. Any PVF powder that is spilled during the process is picked up using the house vacuum system.
Particulates are captured using a two -stage fabric filter, and disposed of in a landfill.
The facility operates 24 hours per day, 7 days per week, 50 weeks per year.
3. Zoning
A zoning consistency determination is not required.
4. Application Chronology
08/06/15 FRO received the application packet, including the $50.00 processing fee. There was a
request to keep any information confidential. The application appeared to be complete
for processing.
08/06/15 FRO sent the facility a letter acknowledging receipt of the permit application.
08/27/15 FRO sent the facility a letter acknowledging the request for confidentiality.
5. NSPS, NESHAP, PSD, 112(r), Attainment Status & Greenhouse Gases (GHG)
• NSPS — There are no current NSPS Regulations that are applicable to this facility.
• NESHAP — There are no current NESHAP Regulations that are applicable to this facility.
• PSD — The facility's potential emissions do not exceed PSD permitting thresholds.
• 112(r) — The facility stores approximately 202,000 lb of vinyl fluoride, which exceeds the 10,000
lb threshold. The facility is required to maintain a written Risk Management Plan (RMP). The
RMP was submitted on 07/30/2015. A 2D .2100 stipulation has been included in the permit.
• GHG — There are no GHG emissions at this facility.
• Attainment status — Bladen County is in attainment.
DEQ-CFW 00065594

• DuPIRCompany — Fayetteville Works
Permit R00 Review
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6. Permitted Emission Sources and Controls
The facility's permitted emission sources and control devices are as follows:
PVF-A Polyvinyl Fluoride Manufacturing
Process No. 1
PVF-B Polyvinyl Fluoride Manufacturing
Process No. 2
PVF-Vac-A I PVF-A House Vacuum System
PVF-Vac-B I PVF-B House Vacuum System
N/A
N/A
Fabric filter
CD -Vac -Ai
(524 square feet of filter area)
in series with
in series with
CD-Vac-A2
Fabric filter
(46 square feet of filter area)
Fabric filter
CD-Vac-B 1
(524 square feet of filter area)
in series with
in series with
CD-Vac-132
Fabric filter
(46 square feet of filter area)
The facility's Insignificant/Exempt Activities are as follows:
IES-Lab
PVF Facility Quality Control 2Q .0102 (c)(1)(C)(i) Yes Yes
Laboratory
7. Emissions Review
Pollutant
CY 2t114 Emissions
(tons)
Potential After Controls
/ Limitations
tons! r
63.86
Potential Before Controls
/ Limitations
tons/ r)
95.04
PM (TSP)
1.47
PM10
1.47
63.86
95.04
PM2.5
1.47
63.86
95.04
VOC
26.5
68.04
68.04
GHG (COze)
Short Tons
0
0
0
Actual emissions for the facility were taken from the appropriate portions of the 2014 annual
emissions inventory submitted by Chemours.
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• DuPont Company — Fayetteville Works
Permit R00 Review
Page 4
The particulate emission potentials for the two PVF processes are based on emission factors provided
by the vendor of the equipment, and VOC potentials are based on leak detection sampling and mass
balances for each process. VOC emissions include a worst case scenario for monthly maintenance.
Particulate emission potentials before controls for the house vacuum systems were arrived at by an
estimation of the mass of material collected from the first stage filter during operations. Using the
mass estimation and the filter efficiencies for various particle sizes as provided by the manufacturer,
the uncontrolled particulate loading was back calculated, then increased by a factor of three to arrive
at the reported potential to emit. Though a sample was analyzed to determine the particle size
distribution of the product, the facility assumes a worst case scenario that all particulate emitted is
PM2.s.
8. Air Toxics
Formaldehyde is emitted during the drying process due to some thermal decomposition of the
product. DuPont constructed a small test unit to determine the rate of decomposition and
formaldehyde emission. During that testing, it was noted that formaldehyde emissions were equal to
0.02 lb/hr, which is less than the 2Q .0711 TEPR for vertical, unobstructed stacks. Therefore, no
modeling is required. A 2Q .0711 stipulation will be included in the permit.
Emission
Averaging
Rate at
Modeling
Pollutant
Period
Maximum
TPER
Required?
Throughput
Formaldehyde
lb/hr
0.02
0.16
No
9. Compliance History
03/10/15 The latest compliance inspection was conducted by Greg Reeves. The facility was found
to be operating in apparent compliance.
03/05/15 Mike Thomas, Greg Reeves, and Mike Reid conducted a full 112(r) inspection, and
found the facility to be operating in apparent compliance.
02/17/14 Greg Reeves conducted three compliance inspections, and found the PVF processes to be
Through operating in apparent compliance each time.
05/23/12
O1/23/12 Greg Reeves and Mike Reid conducted a full 112(r) inspection, and found the facility to
be operating in apparent compliance.
05/19/11 Greg Reeves and Tien Nguyen conducted a total of two compliance inspections. The
And facility was found to be operating in apparent compliance each time.
05/27/10
DEQ-CFW 00065596

• DuP•Company — Fayetteville Works
Permit R00 Review
Page 5
10. Stipulation Review
itegulaticn
Affected Sources
Emission Limits or Requirements
Permit Renewal and Emission Inventory Requirement
15A NCAC 2D .0202
Facility -wide
15A NCAC 2D .0515
PVF-A
PVF-B
E = 4.10 * (P) 0 67 for P <= 30 tons/hr, or
E = 55 * (P) ° "- 40 for P >30 tons/hr
15A NCAC 2D .0521
Facility -wide
VE < 20%
15A NCAC 2D .0535
Facility -wide
Excess Emissions Notification Requirement
15A NCAC 2D .0540
Facility -wide
Control fugitive dust emissions
15A NCAC 2D .0611
Fabric Filters
Fabric Filter Requirements
Annual Internal Inspection
Periodic I&M per manufacturer recommendations
Recordkeeping
15A NCAC 2D .0958
Facility -wide
VOC Work Practices
15A NCAC 2D .1806
Facility -wide
No objectionable odors
15A NCAC 2D .2100
Facility -wide
Facility is required to maintain a written
Risk Management Plan (RMP)
15A NCAC 2Q .0711
Facility -wide
Emissions shall not exceed listed TEPRs without first
demonstrating compliance with 15A NCAC 213.1100
11. Changes to Permit Writer
• Highlighted headers, adjusted column widths and borders for improved clarity and appearance.
• Added the words "in series with" to the Control System ID column of the emission source table.
• Changed 2D .0611 condition from "... internal inspection of each bagfilter system" to "...
internal inspection of each filter system".
• Removed unused columns in the 2Q .0711 TPERs table.
12. Comments and Recommendations
• Recommend issuing permit no. 10458 R00 to DuPont Company — Fayetteville Works (0900092).
Review Engineer:
F
Permit Coordinator
AQ Supervisor:
Date:
Date:.
Date:
DEQ-CFW 00065597