DEQ-CFW_00065968

r I
TO: SHANNON VOGEL
Protocol Transmittal Form - from Region to SSCB
Facility Name: DuPont Company - Fayetteville Works
Tracking No.: 2013-127ST
Permit No.: 03735 Revision No.: T37 County: Bladen
Protocol Received in Region: 06/28/2013
Protocol Sent to SSCB: 07/16/2013
Proposed Test Date: 08/13/2013
Assigned Inspector: Gregory Reeves
Comments.
7/16/2013
Facility ID: 0900009
Region: FRO
DEQ-CFW 00065968

A
NCDENR
PROTOCOL SUBMITTAL FORM (Rev. 2010a)
DMSTON OF AIR QUALITY
PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultants, and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAQ Regional
Supervisor at least 45 days prior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary, attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available from the DAQ website (http://daq.state.nc.us/enVsourcetest/)
Specify Appropriate Regional Office: (check one)
❑ Asheville ® Fayetteville ❑ Mooresville ❑ Raleigh ❑ Washington ❑ Wilmington ❑ Winston-Salem
Facility Name: Dupont Fayetteville Works
Testing Company: Entec Services, Inc.
Facility ID No: 0900009
Facility Contact Person / mailing address & email:
Testing Company Contact Person / mailing address & email:
Ms. Dianne Fields
Mr. Keith Poole
DuPont Inc.
Entec Services, Inc.
22828 NC Hwy 87 West
301 Brookdale Street
Fayetteville, NC 28306
Kannapolis, NC 28083
Email Address: [e-mail]
Email Address: [e-mail]
Phone:[phone]
Fax:[phone]
Phone:[phone]
Fax:
Mobile No.:
I
Mobile No.: 704-796-7308
Air Permit Number & Revision: 03537T37
Permitted Source Name and ID No.: HFPO Process (ID No. NS-A);
Vinyl Ethers North Process (ID No. NS-B); RSU Process (ID No.
NS-D); Liquid Waste Stabilization (ID No. NS-E); MMF Process (ID
No. NS-F)
Permitted Maximum Process Rate:
Maximum Normal Operation Process Rate:
Target Process Rate for Testing:
ID No. NSA 85.3 TPY VOC
350 kg/hr
350 kg/hrT"'N� ,_ , r,
ID No. NS-B: 68.9 TPY VOC
liCCE� v ED
ID No. NS-D: not applicable
ID No. NS-E: not applicable
JUN 2 8 2013
ID No. NS-F: not applicable
1.1) What is the s ecific purpose for the proposed testing? (permit condition, NSPS, NESHAP, etc, seer ^widance doc)' �rt t,t
test 10 to determine the destruction efficiency of this wet scrulY+.R—FAYEfTEVI�L
requires an emissions every years
Is this an initial performance test? ❑ Yes or ®No
1.2) List all state and federal regulations that apply to the proposed testing (see guidance doc): 40 CFR 98.124(g)(2)(i)
1.3) Will the test results be used for other regulatory purposes (e.g.,=ission inventories, permit application, etc.) beyond that stated above?
® Yes or ❑ No If yes, explain. Emitted quantities of acid fluoride compounds, reported as hydrogen fluoride on the annual
emissions inventory, are based on the control efficiency of this wet scrubber.
1.4) How will production/process & control device data be documented during testing (list specific control equipment, process parameters,
instrumentation that will be used, frequency of data collection, collected by computer/manually, etc.)? TEST WILL NOT BE
ACCEPTED WITHOUT APPROPRIATE PRODUCTION/PROCESS & CONTROL DEVICE OPERATION DATA.
Data will be collected using computer historian IP21 and/or DCS backup historian on documented on frequency of every 5 minutes. The
following process tags will be used in IP21 to document production/process & control device data: VE-N: 22766FC production flow;
RSU: R05115FC production flow; HFPO H01361FG production flow; Division WGS recirculation flow W03360FC and/or W36100FC;
Division WGS inlet flow W03375FG; Division WGS outlet flow W0337617G.
DEQ-CFW 00065969

1.5) Provide a brief description of the source (including control equipment) and attach source or process flow diagram from source through
stack exit: Nafion® BFPO process, Vinyl Ethers North process, RSU process, MMf process, and liquid waste stabiliation, all controlled
by a baffle -plate scrubber (control device ID No. NCD-Hdrl).
1.6) Provide a brief description of the sampling location, attach schematic of sampling location, and indicate whether concurrent testing will
be conducted at other sampling locations (Approval of protocol without this data will not exempt you from Method 1 criteria):
The sample locations are the inlet to the WGS immediately downstream of inlet flow 3375FG and the exhuast of the WGS immediately
downstream of outlet flow 3376FG.
DEQ-CFW 00065970

PROTOCOL SUBMITTAL FORM (Rev. 2010a)
NCDENR DY RTON OF AIR OTTALITY PAGE 2 OF 2
2.1) Provide the following information for each test parameter.
Comments
Target
Proposed
Number of
Test Run
# of Sampling
Pollutant
Test Method
Test Runs
Duration
Points
Inlet and outlet Testing Very High
HF
Modified 26**
3
60 min
N/A
Concentration on Inlet.
2.2) Will all testing be conducted in strict accordance with the applicable test methods? If answer is no, attach
❑ Yes
®No
complete documentation of all modifications and/or deviations to the applicable test methods.
2.3) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites?
®Yes
❑ No
Attach supporting documentation.
2.4) Has cyclonic flow been documented at this source (EPA Method 1 Section 11.4)?
❑ Yes
® No
ABSENCE OF CYCLONIC FLOW MUST BE VERIFIED DURING CURRENT TESTING.
2.5) Will the oxygen concentration be determined by ❑ EPA Method 3 via Orsat or ❑ strict EPA Method 3A (specify)
❑ Yes
® No
If answer is no, see Question 2.2 above. (Fyrites are NOT allowed per 15A NCAC 2D .2606)
2.6) Do any of the proposed test methods require analysis of EPA audit samples? If yes, notify Regional Office
® Yes
❑ No
a minimum of 45 days prior to testing to allow for audit sample preparation and shipment.
2.7) Has all testing equipment been calibrated within the past year? If answer is no, explain.
® Yes
❑ No
2.8a) Have all calibration gases been certified by EPA Protocol 1 procedures? (Answer only as applicable)
❑ Yes
❑ No
2.8b) Is a dilution system (via EPA Method 205) proposed? (Answer only as applicable)
❑ Yes
❑ No
2.8c) Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule? DAO Regional Supervisor must be notified a minimum of 15 days prior to the actual test dates)
THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
Tuesday August 13, 2013
Additional Comments: Flows will be determined by instailea flow meters.
**Method 26 modified to inlet large teflon impingers due to high concentrations exspected.
Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
Dlgltally signed by W. Keith Poole
W. Keith Poole Inc.=T. hnlcPoole, o=Entec Services,
`Inc, ou=Technical Writer,
emaR-/ c DS
i43/
/ s—�✓
Date: 2001133.OG�261 57.04!001
Permitted Facility Representative Date
Testing Company Representative Date
W. Keith Poole i � v E' " ED
Name: Dianne Fields
Name:
Title: Nafion/Fluoromonomers Manufacturing
Title: Carolinas Operations° ger8 Zo13
Technical Sr Engineer
REGIONAL OFFICE
Company: DuPont Inc.
Company: Com an Entec Servjg' 1n[AYETTEVILLE
DEQ-CFW 00065971

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