DEQ-CFW_00067798

NORTH CAROLINA DIVISION OF
AIR QUALITY
Regional Office P&O Review
P&O Review Date: 05/20/2014
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306
SIC: 3091 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
Technical Contact
Michael Johnson
Ellis McGaughy
Michael Johnson
Environmental Manager
Plant Manager
Environmental Manager
[phone]
[phone]
[phone]
22828 NC Highway 87
22828 NC Highway 87
22828 NC Highway 87
West
West
West
Fayetteville, NC
Fayetteville, NC 28306
Fayetteville, NC
28306+7332
28306+7332
__ _:_ TYIATC/VV AD.
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Gregory Reeves
Date of Last Inspection: 02/17/2014
Compliance Code: 3 / Compliance - inspection
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
P & O REVIEW
RENEWAL
ADDENDUM
Application Data
Application Number: 0900009.14A
Date Received: 04/23/2014
Application Type: Renewal
Application Schedule: TV -Renewal
Existing Permit Data
Existing Permit Number: 03735/T38
Existing Permit Issue Date: 12/16/2013
Existing Permit Expiration Date: 01/31/2015
CY
S02
NOX
vOC
CO
PM10
Total HAP
Largest HAP
2012
1.23
63.76
260.86
29.24
7.95
28.44
18.70
[Methanol (methyl alcohol)]
2011
2.74
73.06
271.17
31.42
11.31
29.39
17.51
[Methanol (methyl alcohol)]
2010
2.04
43.89
296.10
13.12
9.25
37.52
17.49
[Methanol (methyl alcohol)]
2009
0.9800
37.00
225.44
11.54
7.20
23.40
15.19
[Methanol (methyl alcohol)]
2008
118.63
53.95
312.50
15.13
13.13
30.08
18.64
[Methanol (methyl alcohol)]
Review Engineer: Heather Sands
Regional Office Review Engineer: Gregory Reeves
Review Engineers Signature: Date:
A00170 t 5/-
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P & O Review Date: 05/20/2014
DEQ-CFW 00067798

DuPo company — Fayetteville Works
Permit T39 P&O Review .14A Addendum
Page 2 of 3
1. Purpose of Application
DuPont Company — Fayetteville Works is an existing Title V facility located just south of the
Cumberland County line in Duart Township, Bladen County (although the plant mailing address is in
Fayetteville, Cumberland County). The facility has previously submitted an application for a renewal
of their existing Title V air permit with no modifications. This addendum is for the removal of a
"voluntary use only" control device in the Polymer Processing Aid facility.
The facility is HAP major for methanol emissions.
The application did not contain any confidential information.
The facility contact for the application is Michael Johnson, Environmental Manager (910-678-1155).
2. Zoning
A zoning consistency determination was not required for this application.
3. Application Chronology at FRO —
04/21/14 FRO received the original Air Permit Renewal Application. The application package
included the appropriate application forms, including a Compliance Assurance
Monitoring (CAM) Plan (Form E6), a MACT review, and a facility -wide toxics review.
No fees are required for a renewal of the permit.
05/08/14 FRO received the addendum to the permit renewal application
4. Changes in Equipment, Emissions, and Regulations
This addendum requests the removal from the permit of a small wet scrubber in the Polymer
Processing Aid facility at the site. The scrubber was initially installed to reduce the emissions of
perfluorooctanaoate (APFO) and perfluorooctanoic acid (PFOA) from this operation. The use and
production of these two chemicals has ceased, and therefore the scrubber no longer serves a useful
purpose. The permit currently lists this scrubber as "Voluntary Use Only." There are no periodic
monitoring, recordkeeping, or reporting requirements for this scrubber, and there are no operational
parameters required to be maintained. In addition, there are no state toxics emission limitations for
this scrubber.
5. Facility Compliance History
02/17/14 The most recent facility inspection was performed by Greg Reeves. The facility was
found to be in apparent compliance.
05/27/10 The facility was inspected four (4) times by Tien Nguyen, Maureen Matroni-Rakes, and
through Greg Reeves. The facility was found to be in apparent compliance during each of these
06/20/13 inspections.
01/23/12 Greg Reeves performed a full CAA Section 112(r) inspection. The facility was found to
be in apparent compliance.
DEQ-CFW 00067799

• Dupocompany — Fayetteville Works
Permit T39 P&O Review. 14A Addendum
Page 3 of 3
04/29/09 Enforcement for operating without a permit. Civil Penalty of $3,285 was assessed and
paid.
01/06/09 NOV/NRE Issued for operating without a permit. Several sources subject to permit
requirements were being operated without a permit. Subsequent Enforcement action
resulted on 04/29/09. This resulted from the facility self -reporting the violation by
submission of a permit application for the unpermitted sources.
6. FRO Recommendations, Conclusions, and Concerns.
• FRO has no objections to the removal of this scrubber from the operating air permit. It appears to
serve no current purpose in the DuPont operation, and in any case was deemed as "Voluntary Use
Only", so need not be operated at all.
• If DuPont submits any revisions to this application, including any significant response to
additional information requests, FRO requests a contemporaneous copy for additional review.
• FRO requests the opportunity to review the draft permit and permit review prior to issuance of the
permit. Additionally, as part of this review process, FRO requests copies of all correspondence
regarding this application, including e-mails and meeting notes.
• FRO requests that the company be required to send a startup notification to the Regional
Office, DAQ, within 15 days of startup of the temporary boiler (ID No. PS -Temp). In
addition, the company should keep records of the days of operation on site, so that an
inspector can verify that the boiler is on site for less than 180 days and thereby avoiding
applicability of the 2D .1109 Case=by-Case MACT requirements and the NESHAP Subpart
DDDD requirements.
Review Engineer
Permit Coordinator
DAQ Supervisor
/GWR
c: FRO Files
Date
Date
Date
DEQ-CFW 00067800