DEQ-CFW_00067805

NORTH CAROLINA DIVISION OF
AIR QUALITY
Regional Office P&O Review
P&O Review Date: 05/07/2014
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: 3081 / 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
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC
28306+7332
Authorized Contact
Ellis McGaughy
Plant Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC 28306
Technical Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC
28306+7332
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
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
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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 Engineer's Signature: Date:
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P & O Review Date: 05/07/2014
DEQ-CFW 00067805

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Ant Company — Fayetteville Works
Permit T39 P&O Review
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 submitted an application for a renewal of their
existing Title V air permit with no modifications.
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 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.
4. Changes in Equipment, Emissions, and Regulations
The company is requesting a renewal of their existing Title V permit with no modifications.
There have been no 502(b)(10) changes made since the previous permit revision.
Note that the company is in the process of selling the Butacite® and SentryGlas® process plants
at the facility to Kuraray, a Japanese company. After the sale of the plants, DuPont will submit
a permit application to remove these from their permit and Kuraray will submit an application
to permit the facilities.
DEQ-CFW 00067806

DuPtCompany — Fayetteville Works
Permit T39 P&O Review
Page 3 of 3
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.
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.
• 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 ;
7711
Date
DEQ-CFW 00067807