DEQ-CFW_00067927

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NORTH CAROLINA DIVISION OF
AIR QUALITY
Regional Office P&O Review
P&O Review Date: 11/22/2013
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
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: 06/20/2013
Compliance Code: 3 / Compliance -
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
P & O REVIEW
MINOR MODIFICATION
& 502(b)(10) CHANGES
Application Data
Application Number: 0900009.1313
Date Received: 05/13/2011
Application Type: Modification
Application Schedule: TV -Minor
Existing Permit Data
Existing Permit Number: 03735/T37
Existing Permit Issue Dater 08/17/2011
Existing Permit Expiration Date: 01/31/2015
Review Engineer: Mike Gordon Comments / Recommendations:
Regional Office Review Engineer: Gregory Reeves
Review E In 's Signature: Date: P & O Review Date: 11/22/2013
1117-I(A0 l3
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 modification to
their existing Title V air permit. The modifications consist of the following:
• The company requests that #6 fuel oil be removed as a permitted fuel for the facility's two
primary boilers (ID Nos. PS -A and PS-B).
• The company requests that the current permit requirements for testing of the boilers while firing
#6 fuel oil under the 2D .1109 "Case -by -Case MACT" be removed, since #6 fuel oil is being
removed as a permitted fuel.
DEQ-CFW 00067927

Du*Company — Fayetteville Works
Permit T37 Regional P&O Review .13D
Page 2 of 4
The company requests that any operations/monitoring/recordkeeping/reporting requirements that
were incorporated into the permit due to the combustion of #6 fuel oil be removed from the
permit.
• The company requests that a 2Q .0317 avoidance condition be inserted into the permit to avoid
applicability of the 2D .1109 "Case -by -Case MACT" condition and the 2D .I I I I NES14AP
Subpart DDDDD MACT conditions for the Temporary Boiler (ID No. PS -Temp). By limiting
the boiler to being on site for less than 180 days, the boiler is considered a "temporary boiler" and
avoids applicability of these regulations.
The company has added a new insignificant activity in the PVF plant #2. The current permit lists
a single Polyvinyl Fluoride vacuuming system (ID No. I-01B) located in the #1 PVF plant. There
are actually two of these systems, one in each of the PVF process plants. These processes qualify
as insignificant activities. The current insignificant vacuuming system in PVF plant #1 (ID No. I-
01) is proposed to be re -numbered as I-01A. The added second system in PVF plant #2 is
proposed to be numbered 1-01 B.
The company requests that two recent 502(b)(10) notification changes be incorporated into the
permit. These are:
✓ Change the filter area of control device ID No. BCD-C2 from 6,858 square feet to 6,245
square feet.
✓ Removal aqueous scrubber system for CO2 emissions and installation of CO2 gas
permeator system for the Vinyl Ethers North process (ID No. NS-B) to reduce
wastewater discharge from this process.
The facility is HAP major for methanol emissions. Limitations on NO, and SO2 emissions from
boiler operations and VOC emissions from Nafiori and Polyvinyl Fluoride operations avoid PSD
review. The facility has requested the removal of the current PSD avoidance condition for SO2
emissions which was the result of firing #6 fuel oil in the boilers. That avoidance condition is no
longer required, as the potential SO2 emissions are now below the PSD threshold limits with the
removal of the #6 fuel oil combustion.
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 —
11/14/13 FRO received the Air Permit Modification Application. The application package
included a description of the modifications and the appropriate application forms. A
separate application package was sent directly to the RCO Permits Section, including
a check in the amount of $889 for the applicable permit fees.
DEQ-CFW 00067928

ari. ti
Dule Company — Fayetteville Works
Permit T37 Regional P&O Review .13D
Page 3 of 4
4. Changes in Equipment, Emissions, and Regulations
• The company is requesting a modification to their existing Title V permit to remove #6 fuel oil as
a permitted fuel for the facility's two primary boilers (ID Nos. PS -A and PS-B). The facility's #6
fuel oil storage tank has been removed from service, and the facility has no plans to combust #6
fuel oil in the future.
• The company requests that the PSD Avoidance condition for SO2 emissions from the Temporary
Boiler (ID No. PS -Temp) be removed from the permit. This condition was placed in the permit
due to the potential emissions of SO2 while combusting #6 fuel oil. Since #6 fuel oil is being
removed as a permitted fuel, this is no longer necessary.
• The company requests that any operations/monitoring/recordkeeping/reporting requirements that
were incorporated into the permit due to the combustion of #6 fuel oil be removed from the
permit.
• The company requests that the current permit requirements for testing of the boilers while firing
#6 fuel oil under the 2D .1109 "Case -by -Case MACT" be removed, since #6 fuel oil is being
removed as a permitted fuel.
• The company requests that a 2Q .0317 avoidance condition be inserted into the permit to avoid
applicability of the 2D .1109 "Case -by -Case MACT" condition and the 2D .1111 NESHAP
Subpart DDDDD MACT conditions for the Temporary Boiler (ID No. PS -Temp). By limiting
the boiler to being on site for less than 180 days, the boiler avoids applicability of these
regulations.
NOTE: 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.
• The company is also requesting the addition of a second Polyvinyl Fluoride vacuuming system
for the #2 PVF plant. This system is considered an insignificant activity. The current permit lists
a similar system in the #1 PVF plant as insignificant activity ID No. I-01. The facility is
requesting re -numbering of this # 1 system to be ID No. 1-01A, with the new #2 system to be
designated as ID No. 1-01B.
• The company requests that the two recent 502(b)(10) notification changes be incorporated into
the permit. These are:
✓ Change in the filter area of control device ID No. BCD-C2 from 6,858 square feet to
6,245 square feet.
✓ Remove aqueous scrubber system for CO2 emissions and insert gas permeator system for
the Vinyl Ethers North process (ID No. NS-B) to reduce wastewater discharge from this
process. (This is a process change, not a control device change.)
DEQ-CFW 00067929

DuPtCompany — Fayetteville Works
Permit T37 Regional P&O Review AD
Page 4 of 4
5. Facility Compliance History
06/20/13 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 three (3) times by Tien Nguyen, Maureen Matroni-Rakes, and
through Greg Reeves. The facility was found to be in apparent compliance during each of these
05/23/12 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 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 a -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 Cas-
by-Case MACT requirements and the NESHAP Subpart DDDD requirements.
Review Engineer Date /! 09 yo C
rl-
Permit Coordinator Date
DAQ Supervisor _ Date
/GWR
c: FRO Files
DEQ-CFW 00067930