DEQ-CFW_00066108

Miscellaneoporg anic Chemical Manufacturing NOHAP (MON)
Part 63 Subpart FFFF
Compliance Report
40 CFR 63.2520(e)
Reporting Period from May 10, 2008 through December 31, 2008
40 CFR 63.2520(e)(1) Company name and address:
DuPont Company — Fayetteville Works, 22828 NC Hwy 87 W, Fayetteville, NC 28306-7332.
40 CFR 63.2520(e)(2) Statement by a responsible official with that official's name, title, and
signature, certifying the accuracy of the content of the report.
See Attachment 1 for this certification statement.
40 CFR 63.2520(e)(3) Date of report and beginning and ending dates of the reporting period.
The date of this report is February 18, 2009. The reporting period of this report is from May
10, 2008 through December 31, 2008.
40 CFR 63.2520(e)(4) For each SSM during which excess emissions occur, the compliance
report must include records that the procedures specified in your startup, shutdown, and
malfunction plan (SSMP) were followed or documentation of actions taken that are not
consistent with the SSMP, and include a brief description of each malfunction.
There are no sources subject to the Subpart FFFF NESHAP for which a startup, shutdown,
and malfunction plan (SSMP) is required.
40 CFR 63.2520(e)(5) The compliance report must contain the information on deviations, as
defined in §63.2550, according to paragraphs (e)(5)(1), (ii), (iii), and (iv) of this section.
A deviation of a work practice standard is described below.
40 CFR 63.2520(e)(5)(i) If there are no deviations from any emission limit, operating limit or
work practice standard specified in this subpart, include a statement that there were no
deviations from the emission limits, operating limits, or work practice standards during the
reporting period.
This section is not applicable. A deviation of a work practice standard is described below.
40 CFR 63.2520(e)(5)(ii) For each deviation from an emission limit, operating limit, and work
practice standard that occurs at an affected source where you are not using a continuous
monitoring system (CMS) to comply with the emission limit or work practice standard in this
subpart, you must include the information in paragraphs (e)(5)(ii)(A) through (C) of this section.
This includes periods of SSM.
A deviation of a work practice standard occurred during the reporting period.
Page 1 of 4
DEQ-CFW 00066108

Miscellaneouporg anic Chemical Manufacturing NPHAP (MON)
Part 63 Subpart FFFF
Compliance Report
40 CFR 63.2520(e)
Reporting Period from May 10, 2008 through December 31, 2008
40 CFR 63.2520(e)(5)(ii)(A) The total operating time of the affected source during the reporting
period.
A deviation of a work practice standard occurred with two heat exchange systems used to cool
process equipment in an MCPU meeting the conditions of §63.2435. During the reporting
period, these heat exchange systems each operated 4,272 hours.
40 CFR 63.2520(e)(5)(ii)(B) Information on the number, duration, and cause of deviations
(including unknown cause, if applicable), as applicable, and the corrective action taken.
Pursuant to 40 CFR 63.2490, any heat exchanger subject to the MON must comply with the
work practice standards of 40 CFR 63.104. The DuPont Company — Fayetteville Works'
HFPO Process (ID No. NS-A) operates two (2) process heat exchangers that are subject to the
MON. To monitor for the presence of a leak in a heat exchanger system, §63.104(b)(5)
requires that three (3) samples of both the cooling water entrance to and exit from the heat
exchanger be monitored for the presence of speciated hazardous air pollutants ("HAP")
monthly for the first six months of operation and quarterly thereafter.
To comply with the monthly heat exchanger monitoring requirement, three samples of both
the cooling water entrance and exit were taken at both of the above heat exchangers for the
months of May 2008 and June 2008. DuPont personnel believed that these samples satisfied
the requirement of monthly triplicate samples at each required monitoring location.
However, when the commercial laboratory received the sets of triplicate samples, their belief
was that each set of three samples represented: (1) a single sample for analysis of the specific
HAP, (2) a duplicate sample for QA/QC purposes, and (3) a spare sample container in case of
breakage of the other two samples. As such, the lab analyzed one or two of the samples from
set each instead of the required three.
This error was discovered in July 2008 and DuPont personnel were able to sample and submit
the required three samples per monitoring point for that month. Therefore, the two heat
exchangers subject to this MON requirement did not have the required number of samples
analyzed for either May 2008 or June 2008. This resulted in four permit deviations.
The corrective action taken is that DuPont personnel now submit triplicate samples, triplicate
duplicates, and triplicate spare samples of each heat exchanger monitoring location for each
monitoring event.
40 CFR 63.2520(e)(5)(ii)(C) Operating logs of processes with batch vents from batch
operations for the day(s) during which the deviation occurred, except operating logs are not
required for deviations of the workpractice standards for equipment leaks.
This section is not applicable. This deviation involved work practice standards for equipment
leaks.
Page 2 of 4
DEQ-CFW 00066109

MiscellaneoPorg anic Chemical Manufacturing NRHAP (MON)
Part 63 Subpart FFFF
Compliance Report -
40 CFR 63.2520(e)
Reporting Period from May 10, 2008 through December 31, 2008
40 CFR 63.2520(e)(5)(iii) For each deviation from an emission limit or operating limit
occurring at an affected source where you are using a CMS to comply with an emission limit in
this subpart, you must include the information in paragraphs (e)(5)(iii)(A) through (i) of this
section. This includes periods of SSM.
This section is not applicable. This deviation did not involve a continuous monitoring system.
40 CFR 63.2520(e)(5)(iv) If you documented in your notification of compliance status report
that an MCPU has Group 2 batch process vents because the non -reactive HAP is the only HAP
and usage is less than 10,000 lblyr, the total uncontrolled organic HAP emissions from the batch
process vents in an MCPU will be less than 1, 000 lblyr for the anticipated number of standard
batches, or total uncontrolled hydrogen halide and halogen HAP emissions from all batch
process vents and continuous process vents in a process are less than 1, 000 lblyr, include the
records associated with each calculation required by §63.2525(e) that exceeds an applicable
HAP usage or emissions threshold. `
This section is not applicable. This deviation did not involve a continuous monitoring system.
40 CFR 63.2520(e)(6) If you use a CEMS, and there were no periods during which it was out -
of -control as specified in §63.8(c)(7), include a statement that there were no periods during
which the CEMS was out -of -control during the reporting period.
This section is not applicable. This site does not have a continuous emission monitoring
system.
40 CFR 63.2520(e)(7) Include each new operating scenario which has been operated since the
time period covered by the last compliance report and has not been submitted in the notification
of compliance status report or a previous compliance report. For each new operating scenario,
you must provide verification that the operating conditions for any associated control or
treatment device have not been exceeded and that any required calculations and engineering
analyses have been performed. For the purposes of this paragraph, a revised operating scenario
for an existing process is considered to be a new operating scenario.
This section is not applicable. This site does not have any new operating scenarios that have
been operating since the submittal of the notification of compliance status report.
40 CFR 63.2520(e)(8) Records of process units added to a PUG as specified in §63.2525(i)(4)
and records of primary product redeterminations as specified in §63.2525(i)(5).
This section is not applicable. This site does not have any process unit groups.
Page 3 of 4
DEQ-CFW 00066110

Miscellaneous Org anic Chemical Manufacturing N SHAP (MON)
Part 63 Subpart FFFF
Compliance Report
40 CFR 63.2520(e)
Reporting Period from May 10, 2008 through December 31, 2008
40 CFR 63.2520(e)(9) Applicable records and information for periodic reports as specified in
referenced subparts F, G, H, SS, UU, WW, and GGG of this part and subpart F of 40 CFR part
65.
The periodic report for Subpart UU as specified in 40 CFR 63.1039(b) is provided as
Attachment 2.
40 CFR 63.2520(e)(10) Notification ofprocess change.
This section is not applicable. Since the submittal of the notification of compliance status
report, this site has not made any process changes that are not within the scope of an existing
operating scenario.
Page 4 of 4
DEQ-CFW 00066111

• 0
ATTACHMENT 1
Miscellaneous Organic Chemical Manufacturing NESHAP (MON)
Part 63 Subpart FFFF
Compliance Report
40 CFR 63.2520(e)
Reporting Period from May 10, 2008 through December 31, 2008
Certification of Report Accuracy
As required by 40 CFR 63.2520(e)(2), this document is the statement by a responsible
official certifying the accuracy of the content of the subject MON compliance report.
By my signature below, I certify under penalty of law that I have personally examined
and am familiar with the information submitted in this document and all attachments
and that, based on my inquiry of those individuals immediately responsible for
obtaining the information, I believe that the information is accurate. I am aware that
there are significant penalties for submitting false information, including the possibility
of fine and imprisonment.
tvV� r
Karen B. Wrigley
Plant Manager
February 18, 2009
Date
DEQ-CFW 00066112

0
Miscellaneous Organic Chemical Manufacturing NVHAPg g (MON)
Part 63 Subpart FFFF
Compliance Report
ATTACHMENT 2
Subpart UU Periodic Report — 40 CFR 63.1039
40 CFR 63.1039(b) Periodic Reports. The owner or operator shall report the information
specified in paragraphs (b)(1) through (b)(8) of this section, as applicable, in the Periodic Report
specified in the referencing subpart.
The information required for the Subpart UU Periodic Report is provided below.
40 CFR 63.1039(b)(1) For the equipment specified in paragraphs (b)(1)(i) through (b)(1)(v) of
this section, report in a summary format by equipment type, the number of components for which
leaks were detected and for valves, pumps and connectors show the percent leakers, and the total
number of components monitored. Also include the number of leaking components that were not
repaired as required by §63.1024, and for valves and connectors, identify the number of
components that are determined by §63.1025(c)(3) to be nonrepairable.
DuPont has chosen to subdivide the applicable process unit or group of process units into four
subgroups, namely HFPO, Polymers, VE North, and VE South. See Attachments 3, 4, 5, and 6
for the required summary report of monitored components during the reporting period.
During the reporting period, there were no leaking components that were not repaired as required
by §63.1024. During the reporting period, there were no valves and connectors that were
determined by §63.1025(c)(3) to be nonrepairable.
40 CFR 63.1039(b)(2) Where any delay of repair is utilized pursuant to §63.1024(d), report that
delay of repair has occurred and report the number of instances of delay of repair.
During the reporting period, there was no delay of repairs.
40 CFR 63.1039(b)(3) If applicable, report the valve subgrouping information specified in
§63.1025(b)(4)(iv).
DuPont has chosen to subdivide the valves in the applicable process unit or group of process
units into four subgroups, namely HFPO, Polymers, VE North, and VE South. See Attachments
3, 4, 5, and 6 for the specified information.
40 CFR 63.1039(b)(4) For pressure relief devices in gas and vapor service pursuant to
§63.1030(b) and for compressors pursuant to §63.103](1) that are to be operated at a leak
detection instrument reading of less than 500 parts per million, report the results 'of all monitoring
to show compliance conducted within the semiannual reporting period.
All pressure relief device subject to the Subpart UU regulations are equipped with a rupture disk
upstream of the pressure relief device, and pursuant to 40 CFR 1030(e) are exempt from the
compliance standard and pressure relief requirements of 40 CFR 1030. The DuPont Company —
Fayetteville Works has no compressors subject to Subpart UU requirements.
Page 1 of 2
DEQ-CFW 00066113

Miscellaneous Or anic Chemical Manufacturing NESHAP (MON)
g g
Part 63 Subpart FFFF
Compliance Report
ATTACHMENT 2
Subpart UU Periodic Report — 40 CFR 63.1039
40 CFR 63.1039(b)(5) Report, if applicable, the initiation of a monthly monitoring program for
valves pursuant to §63.1025(b)(3)(i).
During the reporting period and following the initial monitoring event, less than 2 monitored
valves or 2 monitored percent of the monitored valves were found to be leaking. Therefore the
initiation of the monthly monitoring program for valves was not applicable.
40 CFR 63.1039(b)(6) Report, if applicable, the initiation of a quality improvement program for
pumps pursuant to §63.1035.
During the reporting period, less than 3 monitored pumps or 10 percent of the monitored pumps
were found to be leaking. Therefore the initiation of the quality improvement program for
pumps was not applicable.
40 CFR 63.1039(b)(7) Where the alternative means of emissions limitation for batch processes is
utilized, report the information listed in §63.1036(f).
This section is not applicable.
40 CFR 63.1039(b)(8) Report the information listed in paragraph (a) of this section for the Initial
Compliance Status Report for process units or affected facilities with later compliance dates.
Report any revisions to items reported in an earlier Initial Compliance Status Report if the method
of compliance has changed since the last report.
The DuPont Company — Fayetteville Works does not have any process units or affected facilities
that have later compliance dates with this NESHAP.
Page 2 of 2
DEQ-CFW 00066114

ATTACHMENT 3
Compliance Group:
HFPO
VALVES
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
PUMPS
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
COMPRESSORS
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
AGITATORS
APRIL
MAY
JUNE
JULY
AUGUST
SEPTEMBER
OCTOBER
This report produced using Orr LeakDAS
Periodic MoulToring Summary
Report:R807
Report Date: 2/6/2009 10:01:51AM
Report from: 04/01/2008 To 12/31/2008
Percent
Late
Non
Leaking
Inspected
Leaking
Repairs
Repairable
2
169
1.18
0
0
0
160
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
2
160
1.25
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
160
0.00
0
0
0
0
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
3
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
0
0
0.00
0
0
Page 1 of 8
DEQ-CFW 00066115

•
ATTACHMENT 3
Periodic Monte ring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
AGITATORS NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
CONNECTORS APRIL
2
517
0.39
0 0
MAY
0
2
0.00
0 0
JUNE
0
0
0.00
0 0
JULY
0
0
0.00
0 0
AUGUST
1
1
100.00
0 0
SEPTEMBER
0
1
0.00
0 0
OCTOBER
0
0
0.00
0 0
NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
This report produced using Orr LeakDAS Page 2 of 8
DEQ-CFW 00066116

ATTACHMENT 4
Compliance Group:
Periodic MoniToring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
POLYMERS
Percent
Late
Non
Leakin
Inspected
Leaking
Repairs
Repairable
VALVES
APRIL
0
65
0.00
0
0
MAY
0
65
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
65
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
65
0.00
0
0
DECEMBER
0
0
0.00
0
0
PUMPS
APRIL
0
2
0.00
0
0
MAY
1
2
50.00
1
0
JUNE
0
2
0.00
0
0
JULY
0
2
0.00
0
0
AUGUST
0
2
0.00
0
0
SEPTEMBER
0
2
0.00
0
0
OCTOBER
0
2
0.00
0
0
NOVEMBER
0
2
0.00
0
0
DECEMBER
0
2
0.00
0
0
COMPRESSORS
APRIL
0
0
0.00
0
0
MAY
0
0
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
0
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
0
0.00
0
0
DECEMBER
0
0
0.00
0
0
AGITATORS
APRIL
0
0
0.00
0
0
MAY
0
0
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
0
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
This report produced
using Orr LeakDAS
Page 3 of 8
DEQ-CFW 00066117

ATTACHMENT 4
Periodic Mon-Moring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
AGITATORS NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
CONNECTORS APRIL
2
341
0.59
0 0
MAY
0
0
0.00
0 0
JUNE
0
0
0.00
0 0
JULY
0
0
0.00
0 0
AUGUST
0
0
0.00
0 0
SEPTEMBER
0
0
0.00
0 0
OCTOBER
0
0
0.00
0 0
NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
This report produced using Orr LeakDAS
Page 4 of 8
DEQ-CFW 00066118

ATTACHMENT 5
Compliance Group:
Periodic MonMoring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
VE NORTH
Percent
Late
Non
Leakin
InaRected
Leakin
Repairs
Repairable
VALVES
APRIL
0
0
0.00
0
0
MAY
0
183
0.00
0
0
JUNE
0
183
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
183
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
183
0.00
0
0
DECEMBER
0
0
0.00
0
0
PUMPS
APRIL
0
0
0.00
0
0
MAY
0
5
0.00
0
0
DUNE
0
5
0.00
0
0
JULY
0
5
0.00
0
0
AUGUST
0
5
0.00
0
0
SEPTEMBER
0
5
0.00
0
0
OCTOBER
0
5
0.00
0
0
NOVEMBER
0
5
0.00
0
0
DECEMBER
0
5
0.00
0
0
COMPRESSORS
APRIL
0
0
0.00
0
0
MAY
0
0
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
0
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
0
0.00
0
0
DECEMBER
0
0
0.00
0
0
AGITATORS
APRIL
0
0
0.00
0
0
MAY
0
1
0.00
0
0
JUNE
0
1
0.00
0
0
JULY
0
1
0.00
0
0
AUGUST
0
1
0.00
0
0
SEPTEMBER
0
1
0.00
0
0
OCTOBER
0
1
0.00
0
0
This report produced
using Orr LeakDAS
Page 5 of 8
DEQ-CFW 00066119

ATTACHMENT 5
Periodic Mon—iforing Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
AGITATORS NOVEMBER
0
1
0.00
0 0
DECEMBER
0
1
0.00
0 0
CONNECTORS APRIL
0
598
0.00
0 0
MAY
0
0
0.00
0 0
JUNE
0
0
0.00
0 0
JULY
0
0
0.00
0 0
AUGUST
0
0
0.00
0 0
SEPTEMBER
0
0
0.00
0 0
OCTOBER
0
0
0.00
0 0
NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
This report produced using Orr LeakDAS Page 6 of 8
DEQ-CFW 00066120

ATTACHMENT 6
Compliance Group:
Periodic Monitoring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
VE SOUTH
Percent
Late
Non
Leakin
Insl2ected
Leaking
Repairs
Repairable
VALVES
APRIL
0
0
0.00
0
0
MAY
0
181
0.00
0
0
JUNE
0
181
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
181
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
181
0.00
0
0
DECEMBER
0
0
0.00
0
0
PUMPS
APRIL
0
0
0.00
0
0
MAY
0
6
0.00
0
0
JUNE
0
6
0.00
0
0
JULY
0
6
0.00
0
0
AUGUST
0
6
0.00
0
0
SEPTEMBER
0
6
0.00
0
0
OCTOBER
0
6
0.00
0
0
NOVEMBER
0
6
0.00
0
0
DECEMBER
0
6
0.00
0
0
COMPRESSORS
APRIL
0
0
0.00
0
0
MAY
0
0
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
0
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
NOVEMBER
0
0
0.00
0
0
DECEMBER
0
0
0.00
0
0
AGITATORS
APRIL
0
0
0.00
0
0
MAY
0
0
0.00
0
0
JUNE
0
0
0.00
0
0
JULY
0
0
0.00
0
0
AUGUST
0
0
0.00
0
0
SEPTEMBER
0
0
0.00
0
0
OCTOBER
0
0
0.00
0
0
This report produced
using Orr LeakDAS
Page 7 of 8
DEQ-CFW 00066121

ATTACHMENT 6
Periodic Monitoring Summary
Report: R807
Report Date: 2/6/2009 10:01:52AM
Report from: 04/01/2008 To 12/31/2008
AGITATORS NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
CONNECTORS APRIL
0
0
0.00
0 0
MAY
0
697
0.00
0 0
JUNE
0
0
0.00
0 0
JULY
0
0
0.00
0 0
AUGUST
0
0
0.00
0 0
SEPTEMBER
0
0
0.00
0 0
OCTOBER
0
0
0.00
0 0
NOVEMBER
0
0
0.00
0 0
DECEMBER
0
0
0.00
0 0
This report produced using Orr LeakDAS Page 8 of 8
DEQ-CFW 00066122