DEQ-CFW_00065714

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Facility Name: DuPont - Fayetteville Wog
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 1. Registration Information
Facility Name: DuPont - Fayetteville Works
Parent Company #1 Name: E.I. DuPont de Nemours & Company, Inc.
Parent Company #2 Name:
Submission Type: Re -submission
Subsequent RMP Submission Reason: Process no longer covered (source has other
processes that remain covered) (40 CFR
68.190(b)(7))
Description
Receipt Date:
18-Aug-2014
Postmark Date:
18-Aug-2014
Next Due Date:
18-Aug-2019
Completeness Check Date:
18-Aug-2014
Complete RMP:
Yes
De -Registration / Closed Reason:
De -Registration / Closed Reason Other Text:
De -Registered / Closed Date:
De -Registered / Closed Effective Date:
Certification Received:
Yes
s-
EPA Facility Identifier: 1000 0002 8178
Other EPA Systems Facility ID: NCD047368642
Facility Registry System ID: 1100 0055 9609
• 3-
Facility DUNS: 47368642
Parent Company #1 DUNS: 1315704
Parent Company #2 DUNS:
Street 1:
22828 NC Highway 87 W
Street 2:
City:
Fayetteville
State:
NORTH CAROLINA
ZI P:
28306
ZI P4:
7332
County:
BLADEN
Latitude (decimal): 34.845000
Longitude (decimal):-078.811667
Lat/Long Method: Interpolation - Digital map source (TIGER)
Lat/Long Description: Process Unit Area Centroid
Horizontal Accuracy Measure: 100
DEQ-CFW 00065714

Facility Name: DuPont - Fayetteville Oks
EPA Facilitv Identifier: 1000 0002 8178
Plan
Number: 1000043005
Horizontal Reference Datum Name:
Source Map Scale Number:
Owner or Operator
Operator Name:
Operator Phone:
Mailing Address
Operator Street 1:
Operator Street 2:
Operator City:
Operator State:
Operator ZIP:
Operator ZIP4:
Operator Foreign State or Province:
Operator Foreign ZIP:
Operator Foreign Country:
North American Datum of 1983
E.I. DuPont de Nemours & Company, 1
[phone]
22828 NC Highway 87 W
Fayetteville
NORTH CAROLINA
28306
7332
Name and title of person or position responsible for Part 68 (RMP) Implementation
RMP Name of Person:
RMP Title of Person or Position: Site Manager
RMP E-mail Address:
Emergency Contact
Emergency Contact Name:
Emergency Contact Title:
Emergency Contact Phone:
Emergency Contact 24-Hour Phone:
Emergency Contact Ext. or PIN:
Emergency Contact E-mail Address:
Other Points of Contact
Facility or Parent Company E-mail Address:
Facility Public Contact Phone:
Facility or Parent Company WWW Homepage
Address:
Local Emergency Planning Committee
LEPC:
Full Time Equivalent Employees
Joel C. Blake
Safety and Security Manager
[phone]
[phone]
[e-mail]
www.dupont.com
Bladen County LEPC
Number of Full Time Employees (FTE) on Site: 320
FTE Claimed as CBI:
Covered
DEQ-CFW 00065715

Facility Name: DuPont - Fayetteville Woo •
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
EPCRA 302 : Yes
CAA Title V: Yes
Air Operating Permit ID: 03735
OSHA Star or Merit Ranking:
Last Safety Inspection
Last Safety Inspection (By an External Agency)
Date:
Last Safety Inspection Performed By an External
Agency:
Did this RMP involve predictive filing?:
Preparer Name:
Preparer Phone:
Preparer Street 1:
Preparer Street 2:
Preparer City:
Preparer State:
Preparer ZIP:
Preparer ZIP4:
Preparer Foreign State:
Preparer Foreign Country:
Preparer Foreign ZIP:
CBI Claimed:
Substantiation Provided:
Unsanitized RMP Provided:
Reportable Accidents
23-Apr-2014
OSHA
Reportable Accidents: See Section 6. Accident History below to determine
if there were any accidents reported for this RMP.
Process ID:
Description:
Process Chemical ID:
Program Level:
Chemical Name:
CAS Number:
Quantity (lbs):
CBI Claimed:
Glammnhla/Tnxir•
1000053025
Nafion Manufacturing
1000064347
Program Level 3 process
Sulfur trioxide
7446-11-9
59400
Tnxir.
DEQ-CFW 00065716

Facility Name: DuPont - Fayetteville Os • t
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Process ID:
Description:
Process Chemical ID:
Program Level:
Chemical Name:
CAS Number:
Quantity (lbs):
CBI Claimed:
Flammable/Toxic:
Process ID:
Description:
Process Chemical ID:
Program Level:
Chemical Name:
CAS Number:
Quantity (lbs):
CBI Claimed:
Flammable/Toxic:
Process NAICS
1000053026
TFE Process
1000064348
Program Level 1 process
Tetrafluoroethylene [Ethene, tetrafluoro-]
116-14-3
61000
1000053028
Polyvinyl Fluoride Manufa
1000064350
Program Level 1 process
Vinyl fluoride [Ethene, fluoro-]
75-02-5
202000
Flammable
Process ID:
1000053025
Process NAICS ID:
1000053784
Program Level:
Program Level 3 process
NAICS Code:
32519
NAICS Description:
Other Basic Organic Chemical Manufacturing
Process ID:
1000053026
Process NAICS ID:
1000053785
Program Level:
Program Level 1 process
NAICS Code:
32519
NAICS Description:
Other Basic Organic Chemical Manufacturing
Process ID:
1000053028
Process NAICS ID:
1000053787
Program Level:
Program Level 1 process
NAICS Code:
32619
NAICS Description:
Other Plastics Product Manufacturing
DEQ-CFW 00065717

Facility Name: DuPont - Fayetteville Woo
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 2. Toxics: Worst Case
Toxic Worst ID: 1000046358
Percent Weight:
Physical State:
Model Used:
Release Duration (mins):
Wind Speed (m/sec):
Atmospheric Stability Class:
Topography:
Dikes:
Enclosures:
Berms:
Drains:
Sumps:
Other Type:
100.0
Liquid
EPA's RMP*Comp(TM)
7070
1.5
F
Rural
Yes
Yes
A trained Emergency Response Team is staffed 24
hrs/day, 365 days/year. Response equipment
includes a foam application system to help mitigate
a release.
DEQ-CFW 00065718

Facility Name: DuPont - Fayetteville Os •
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 3. Toxics: Alternative Release
Toxic Auer ID: 1000045899
Percent Weight:
Physical State:
Model Used:
Wind Speed (m/sec):
Atmospheric Stability Class:
Topography:
Passive Mitigation Considered
Dikes:
Enclosures:
Berms:
Drains:
Sumps:
Other Type:
Active Mitigation Considered
Sprinkler System:
Deluge System:
Water Curtain:
Neutralization:
Excess Flow Valve:
Flares:
Scrubbers:
Emergency Shutdown:
Other Type:
100.0
Liquid
EPA's RMP*Comp(TM)
3.0
D
Rural
Yes
A trained Emergency Response Team is staffed 24
hrs/day, 365 days/year. Response equipment
includes a foam application system to help mitigate
the release.
DEQ-CFW 00065719

Facility Name: DuPont - Fayetteville W0
EPA Facility Identifier• 1000 0002 8178 Plan Sequence Number: 1000043005
Section 4. Flammables: Worst Case
Flammable Worst ID: 1000031453
Model Used: EPA's RMP*Comp(TM)
Endpoint used: 1 PSI
Passive Mitigation Considered
Blast Walls:
Other Type:
Model Used:
Endpoint used:
Passive Mitigation Considered
Blast Walls:
Other Type:
TFE is stored as a non-flammable mixture of
TFE/CO2 in tube trailers each containing 12,200
Ibs/trailer. TFE is scrubbed to remove the CO2 as
needed. Bulk quantities of pure TFE are not stored.
EPNs RMP*Comp(TM)
1 PSI
VF is stored in separate storage tanks and tankers
on the site. This is the largest storage vessel.
DEQ-CFW 00065720

Facility Name: DuPont - Fayetteville OS 0
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 5. Flammables: Alternative Release
No records found.
DEQ-CFW 00065721

Facility Name: DuPont - Fayetteville W*
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 6. Accident History
No records found.
DEQ-CFW 00065722

Facility Name: DuPont - Fayetteville Os • ,
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 7. Program Level 3
Description
This prevention program applies to SO3 and SO3 Storage.
Program Level 3 Prevention Program Chemicals
Prevention Program Chemical ID:
1000053659
Chemical Name:
Sulfur trioxide
Flammable/Toxic:
Toxic
CAS Number:
7446-11-9
Process ID:
1000053025
Description:
Nafion Manufacturing
Prevention Program Level 3 ID:
1000044617
NAICS Code:
32519
Safety Information
Safety Review Date (The date on which the safety 02-Jun-2014
information was last reviewed or revised):
Process Hazard Analysis (PHA
PHA Completion Date (Date of last PHA or PHA 02-Nov-2012
update):
The Technique Used
What If:
Yes
Checklist:
Yes
What If/Checklist:
Yes
HAZOP:
Failure Mode and Effects Analysis:
Fault Tree Analysis:
Other Technique Used:
PHA Change Completion Date (The expected or
12-Nov-2013
actual date of completion of all changes resulting
from last PHA or PHA update):
Hazards Identified
Toxic Release: Yes
Fire:
Explosion:
Runaway Reaction:
Polymerization:
Overpressurization:
Corrosion: Yes
Overfilling:
Contamination:
Equipment Failure: Yes
DEQ-CFW 00065723

Facility Name: DuPont - Fayetteville W* .
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Earthquake:
Floods (Flood Plain):
Tornado:
Hurricanes:
Other Major Hazard Identified:
Vents:
Relief Valves:
Yes
Check Valves:
Yes
Scrubbers:
Yes
Flares:
Manual Shutoffs:
Yes
Automatic Shutoffs:
Yes
Interlocks:
Yes
Alarms and Procedures:
Yes
Keyed Bypass:
Emergency Air Supply:
Emergency Power:
Backup Pump:
Grounding Equipment:
Inhibitor Addition:
Rupture Disks:
Yes
Excess Flow Device:
Quench System:
Purge System:
None:
Other Process Control in Use:
Mitigation Systems in Use
Sprinkler System:
Dikes:
Fire Walls:
Blast Walls:
Deluge System:
Water Curtain:
Enclosure:
Neutralization:
None:
Other Mitigation System in Use:
Monitoring/Detection Systems in Use
Process Area Detectors:
Perimeter Monitors:
None:
Other Monitoring/Detection System in Use:
Yes
There is a containment sump adjacent to the tank
and the site Emergency Response Team maintains
foam for mitigation of a release. The ERT is staffed
24 hrs/day, 365 days/year.
Yes
Employees are present at all times while a tanker is
being unoaded. The area is staffed 24 hrs/day, 365
days/year and leak patrols are routinely made.
Changes Since Last PHA Update
DEQ-CFW 00065724

Facility Name: DuPont - Fayetteville os • `
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Reduction in Chemical Inventory:
Increase in Chemical Inventory:
Change Process Parameters:
Installation of Process Controls:
Installation of Process Detection Systems:
Installation of Perimeter Monitoring Systems:
Installation of Mitigation Systems:
None Recommended:
None:
Other Changes Since Last PHA or PHA Update:
Review of Operatinq Procedures
1�
Yes
Operating Procedures Revision Date (The date of 13-May-2014
the most recent review or revision of operating
procedures):
Training Revision Date (The date of the most recent 13-May-2014
review or revision of training programs):
The Type of Training Provided
Classroom: Yes
On the Job: Yes
Other Training: Computer Based Training
The Type of Competency Testing Used
Written Tests:
Yes
Oral Tests:
Yes
Demonstration:
Yes
Observation:
Yes
Other Type of Competency Testing Used:
Maintenance
Maintenance Procedures Revision Date (The date of 31-Jul-2014
the most recent review or revision of maintenance
procedures):
Equipment Inspection Date (The date of the most 04-Aug-2014
recent equipment inspection or test):
Equipment Tested (Equipment most recently Internal Inspection of Storage Tank
inspected or tested):
Management of Change
Change Management Date (The date of the most 13-Aug-2014
recent change that triggered management of change
procedures):
DEQ-CFW 00065725

Facility Name: DuPont - Fayetteville Woo 0
EPA Facility Identifier 1000 0002 8178 Plan Sequence Number: 1000043005
Change Management Revision Date (The date of 01-Jul-2014
the most recent review or revision of management of
change procedures):
Pre -Startup Review Date (The date of the most 14-Aug-2014
recent pre -startup review):
Compliance Audit Date (The date of the most recent 14-Nov-2013
compliance audit):
Compliance Audit Change Completion Date 14-Dec-2014
(Expected or actual date of completion of all
changes resulting from the compliance audit):
Incident Investigation Date (The date of the most
recent incident investigation (if any)):
Incident Investigation Change Date (The expected
or actual date of completion of all changes resulting
from the investigation):
Employee Participation Plans
Participation Plan Revision Date (The date of the 21-Mar-2013
most recent review or revision of employee
participation plans):
Hot Work permit Review Date (The date of the most 17-Jul-2014
recent review or revision of hot work permit
procedures):
• 's
Contractor Safety Procedures Review Date (The 27-Aug-2012
date of the most recent review or revision of
contractor safety procedures):
Contractor Safety Performance Evaluation Date 14-Nov-2013
(The date of the most recent review or revision of
contractor safety performance):
CBI Claimed:
DEQ-CFW 00065726

Facility Name: DuPont - Fayetteville Os • '
EPA Facility Identifier: 1000 0002 8178 Plan Sequence Number: 1000043005
Section 8. Program Level 2
No records found.
DEQ-CFW 00065727

Facility Name: DuPont - Fayetteville W* 0
EPA Facility Identifier 1000 0002 8178 Plan Sequence Number: 1000043005
Section 9. Emergency Response
Written Emergency ResponsePlan
Community Plan (Is facility included in written Yes
community emergency response plan?):
Facility Plan (Does facility have its own written Yes
emergency response plan?):
Response Actions (Does ER plan include specific Yes
actions to be taken in response to accidental
releases of regulated substance(s)?): .
Public Information (Does ER plan include Yes
procedures for informing the public and local
agencies responding to accidental release?):
Healthcare (Does facility's ER plan include Yes
information on emergency health care?):
Emergency Response
Review Date (Date of most recent review or update 08-Jul-2014
of facility's ER plan):
Training Date (Date of most recent review or update 31-Jul-2014
of facility's employees):
mom=A*--
Agency Name (Name of local agency with which the Bladen County LEPC
facility ER plan or response activities are
coordinated):
Agency Phone Number (Phone number of local [phone]
agency with which the facility ER plan or response
activities are coordinated):
OSHA Regulations at 29 CFR 1910.38:
Yes
OSHA Regulations at 29 CFR 1910.120:
Yes
Clean Water Regulations at 40 CFR 112:
Yes
RCRA Regulations at CFR 264, 265, and 279.52:
Yes
OPA 90 Regulations at 40 CFR 112, 33 CFR 154,
Yes
49 CFR 194, or 30 CFR 254:
State EPCRA Rules or Laws:
Yes
Other (Specify):
DEQ-CFW 00065728

Facility Name: DuPont - Fayetteville
EPA Facility Identifier: 1000 0002 81
0
Plan Sequence Number: 1000043005
Executive Summary
ACCIDENT RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
At the DuPont Fayetteville Works, we are committed to operating and maintaining our processes in a safe and responsible manner.
We use a combination of accident release prevention programs and emergency response planning programs to help insure the
safety of our employees, the public and the environment. We adhere to the DuPont Corporate philosophy of the commitment is
zero. This means that we constantly strive for zero process safety incidents, zero environmental incidents and zero injuries. Our
site safety, operating and emergency response procedures are available to all site employees thorough hard copies and/or
electronic copies on computers throughout the plant.
FACILITY DESCRIPTION '
The DuPont Fayetteville Works consists of approximately 2200 acres located on the Bladen - Cumberland county line, adjacent to
N.C. highway 87, approximately 15 miles southeast of Fayetteville, N.C. -Approximately 400 acres are currently used for
manufacturing, with the remainder set -aside for future manufacturing needs.
The Nafion process at Fayetteville is a Prevention Program 3 processes due to regulated toxic chemicals with off -site impact
potential. The Nafion process produces chemical intermediates using Sulfur Trioxide.
The TFE and Polyvinyl Fluoride processes are Prevention Program 1 processes since the regulated chemicals are flammables with
no off -site impact. TFE is used to produces a membrane used in fuel cells and the Chloralkali industry. In the production of those
products, the regulated substance Tetrafluoroethylene is used.
Polyvinyl Fluoride is the polymer used in TEDLAR. It is a film product with multiple applications. The polymer is produced at
Fayetteville Works and shipped to other DuPont sites for final processing. The regulated substance Vinyl Fluoride is used in the
Polyvinyl Fluoride manufacturing process.
ACCIDENT RELEASE PREVENTION PROGRAM
The DuPont Fayetteville Works is in compliance with the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Our Process
Safety Management system includes a documented process technology system detailing the hazards of the materials, equipment
design basis and the process design basis. Periodic Process Hazards Analyses are conducted to review the entire process to
insure safe operation and compliance with design guidelines. Materials of construction are strictly controlled to insure the
mechanical integrity of the systems. Extensive operating and safety instrumentation include alarms, interlocks and gas detectors
that allow the operators to continuously monitor and control the process conditions. Process safety critical equipment and
instruments are identified and routinely tested or inspected to insure proper operation and mechanical integrity. A work order and
permit system is used to control maintenance work. Maintenance and operations personnel are trained and qualified via a rigorous
training program. Operating and maintenance procedures are documented and available to personnel either via hard copy or
electronic copies on computers located throughout the operating areas.
FIVE YEAR ACCIDENT HISTORY
There have been no on site injuries and no off site injuries, evacuations, sheltering in place, property damage or environmental
damage due the accidental release of RMP regulated substances from the DuPont Fayetteville Works in the past 5 years.
EMERGENCY RESPONSE PROGRAM
The site has an emergency response team staffed 24 hrs/day, 365 days/year that is trained to respond to fire, medical or hazmat
emergencies. Our emergency response program provides planning and training to effectively protect our employees, the public and
the environment during emergency situations. The emergency response procedures are in place and updated periodically. All
employees are trained for their role in an emergency situation. The plant conducts emergency response drills, with critiques held
after the drills and actual events. The plant is actively involved with the Bladen County LEPC.
IMPROVING SAFETY
We constantly strive to evaluate and improve the safety of our processes. Every person on the site has a responsibility to improve
the safety of our operations. As part of our Process Hazards Analysis process, teams consisting of operators, mechanics, technical
engineers and management thoroughly examine and evaluate our manufacturing operations on a periodic frequency to identify risk
reduction opportunities. Audits, both first party and second party, are conducted using site based personnel and non -site personnel
to evaluate compliance with safety, environmental, occupational health and process safety management requirements and
DEQ-CFW 00065729