DEQ-CFW_00067995

Reeves, Gregory W
From: Michael E Johnson [[e-mail]]
Sent: Monday, January 07, 2013 10:48 AM
To: Kelvington, Jenny
Cc: Reeves, Gregory W
Subject: DuPont - Fayetteville Works Permit No. 03735T37
Jenny:
I think I found an error in our Title V Air Permit, but because of its trivial impact, I
believe it could be corrected the next time the permit is open for modification or renewal.
Section F of the permit is for those occasions when we have a rental boiler (a.k.a. temporary
boiler) on site. Section 2.1(F)(3) is the PSD avoidance condition that limits the boiler
emissions to less than 40 tons S02 per 12-month period. The description of the temporary
boiler correctly lists the fuel sources as either No. 2 fuel oil or natural gas. However in
Section 2.1(F)(3) only No. 2 fuel oil is addressed. The equation for calculating the S02
emissions does not address the S02 emitted from the burning of natural gas.
For comparison, the PSD avoidance conditions found in Section 2.1(A)(5)(e) and Section
2.2(A)(1)(d) both have natural gas with an emission factor of
0.6 lb. S02 per mmscf of gas.
We had the rental boiler on site in November and December 2012, and the total emissions from
the boiler was a mere 20 pounds of S02 versus the permitted limit of 80,000 pounds of S02.
I discovered the apparent error while preparing our Title V semiannual compliance report for
the second half of 2012. I will include the temporary boiler's S02 emission from the burning
of natural gas on this report even though it is not explicitly required by the permit.
Mike
Michael E. Johnson
Environmental Manager
DuPont Company
Fayetteville Works
[phone]
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DEQ-CFW 00067995