DEQ-CFW_00068002

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Qualit
Beverly Eaves Perdue Sheila C. Holman Dee Freeman
Governor Director Secretary
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September 4, 2012 '1 1
Mr. Michael E. Johnson
Environmental Manager
DuPont Fluoroproducts —Fayetteville Works Plant
22828 NC Highway 87 West
Fayetteville, North Carolina 28306-7332
SUBJECT: Applicability Determination No. 2061
Facility ID: 0900009, Permit No. 03735T37
E.I. du Pont de Nemours and Company
DBA, DuPont Company — Fayetteville Works
Duart Township, Bladen County
Fee Class: Title V
Dear Mr. Johnson:
DENR
} AyETTEVILLE REGIONAL OFFICE
The North Carolina Division of Air Quality (NC DAQ) received your letter dated August 10, 2012
requesting a determination as to whether a permit modification application is required for a process change to
the existing Nafion® Vinyl Ethers North (VEN) process (ID No. NS-B) at the Dupont Company — Fayetteville
Works. The VEN process produces a vinyl ether product and an undesirable byproduct, carbon dioxide (CO2),
in its reactor. Currently, CO2 is removed from the product by a process scrubber where it is converted to
potassium carbonate. During separation, a small amount vinyl ether product is lost in the scrubber effluent
and is sent to the site wastewater treatment plant. The proposed change replaces the process scrubber with a
compressor/permeator system for product and CO2 separation. The new system will discharge directly to the
atmosphere at a potential emission rate of 17 lb CO2/hr (512 tons/year (tpy) CO2) and 0.35 lbs vinyl ether/hr
(1.54 tpy VOCs). Actual increases from the proposed modification are expected to be 64 tpy CO and 0.44
tpy VOCs.
Because the vinyl ether/CO2 separation system will not emit any particulate matter, air toxics, HAPs,
or visible emissions, it will only be subject to two existing permit requirements as part of the VEN process
(ID No. NS-B). The system must comply with a PSD avoidance limitation and a state -enforceable odors
standard.
15A NCAC 200317: Avoidance Condition for 15A NCAC 2D .0530: Prevention of Simificant Deterioration
In order to avoid PSD applicability, the permit limits emissions from the VEN process (ID No. NS-B) to less
than 68.9 tons of VOCs per consecutive 12-month period and requires VOC emissions to be calculated
monthly and reported semiannually. The installation of the new vinyl ether/CO2 separation system will not
change this condition or, affect the facility's ability to comply.
Permitting Section One 1
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 NofthCarohna
217 West Jones Street, Raleigh, North Carolina 27603
Phone: [phone] / Fax: [phone] / Internet: www.ncair.org Natumily
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00068002

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Air 1811
Dr. Donald R. van der Vaart
NCDENR — Division of Air Quality
Permitting Section
1641 Mail Service Center
Raleigh, NC 27699-1641
SUBJECT: Permit Modification Applicability Determination
Vinyl Ethers North Process (ID No. NS-B)
Title V Air Permit No. 03735T37
Facility ID: 0900009
Dear Dr. van der Vaart:
•
DuPont Fluoroproducts
Fayetteville Works Plant
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
August 10, 2012
ftE
RE ,
C '. P IZO1r
DENR
Fq TiEV1LLE REGIONAL OFFICE
This letter is a request for the Division of Air Quality ("DAQ") to make a determination of
applicability as to whether a permit modification application is required for a process change to
the existing Vinyl Ethers North Process (ID No. NS-B) at the DuPont Company — Fayetteville
Works.
The Vinyl Ethers North Process currently operates under a PSD avoidance limitation that limits
the discharge of volatile organic compounds ("VOC") into the atmosphere to less than 68.9 tons
per consecutive 12-month period.
EXISTING PROCESS EMISSIONS: Currently the Vinyl Ethers North Process produces the
desired vinyl ether product and carbon dioxide ("CO2") in its reactor. The CO2 would be
detrimental to the downstream unit operations and must be separated from the vinyl ether
product. This is currently accomplished by passing the process stream through a caustic process
scrubber that converts the gaseous CO2 into dissolved potassium carbonate in the scrubber
effluent. The potassium carbonate and approximately 0.15 kg of the vinyl ether per hour exit the
process scrubber and are transferred to the site's NPDES permitted wastewater treatment plant.
PROPOSED PROCESS EMISSIONS: The proposed project would replace the caustic
process scrubber with a compressor / permeator system in which the CO2 would be separated
from the vinyl ether product in the permeator. The permeator would be vented directly to the
atmosphere, with an potential emission rate of 53 kg CO2 per hour or 464.3 metric tons CO2 per
year, and 0.16 kg vinyl ether per hour or 1.54 tons VOC per year . Actual emissions from the
proposed modification are 58 metric tons CO2 per year and. 0.44 tons VOC per year.
E.I. du Pont de Nemours and Company
DEQ-CFW 00068003

Dr. Donald R. van der Vaaf
NCDENR — DAQ
August 10, 2012
0 Page 2 of 2
The Vinyl Ethers North Process currently emits less than 30 tons VOC per consecutive 12-month
period versus the PSD avoidance limitation of 68.9 tons VOC per consecutive 12-month period.
Therefore the proposed process change's small potential increase of 1.54 tons VOC per year
would be inconsequential.
The proposed process change's potential emission rate of 464.3 metric tons CO2 per year is well
less than the 75,000 metric ton CO2 per year significant emission rate under the PSD regulations.
Therefore it would appear that the proposed process change would not result in any substantive
change to the subject Title V Air Permit.
DuPont appreciates DAQ's consideration of the proposed change to the Vinyl Ethers North
Process and the determination as to whether this process change will necessitate the submission
of a permit modification application.
As required by the general conditions of the subject Title V air permit, two copies of this letter
are being sent to the NCDENR DAQ Fayetteville Regional Office.
If you have any questions regarding this letter, or if you need additional information, please call
me at [phone].
Sincerely.
Michael E. Johnson
Environmental Manager
cc: Mr. Steven F. Vozzo, NCDENR — DAQ FRO
Ms. Jenny Kelvington, NCDENR — DAQ Central Office
DEQ-CFW 00068004

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Dr. Donald R. van der Vaart
NCDENR — Division of Air Quality
Permitting Section
1641 Mail Serv.ce Center
Raleigh, NC 27699-1641
SUBJECT: Permit Modification Applicability Determination
Vinyl Ethers North Process (11) No. NS-B)
Title V Air Permit No. 03735T37
Facility ID: 0900009
Dear Dr. van der Vaart,
DuPont Fluoroproducts 4110,
Fayetteville Works
22828 NC Highway 87 Wrsst^
Fayetteville, NC 28306-7332 $�
August 10, 2012
rl . Y_..
S"r'
DEW
�ETTtVLLE REGIONAL OFFICE
This letter is a request for the Division of Air Quality ("DAQ") to make a determination of
applicability as to whether a permit modification application is required for a process change to
the existing Vinyl Ethers North Process (ID No. NS-B) at the DuPont Company — Fayetteville
Works.
The Vinyl Ethers North Process currently operates under a PSD avoidance limitation that limits
the discharge of volatile organic compounds ("VOC") into the atmosphere to less than 68.9 tons
per consecutive 12-month period.
EXISTING PROCESS EMISSIONS: Currently the Vinyl Ethers North Process produces the
desired vinyl ether product and carbon dioxide ("CO2") in its reactor. The CO2 would be
detrimental to the downstream unit operations and must be separated from the vinyl ether
product. This is currently accomplished by passing the process stream through a caustic process
scrubber that converts the gaseous CO2 into dissolved potassium carbonate in the scrubber
effluent. The potassium carbonate and approximately 0.15 kg of the vinyl ether per hour exit the
process scrubber and are transferred to the site's NPDES permitted wastewater treatment plant.
PROPOSED PROCESS EMISSIONS: The proposed project would replace the caustic
process scrubber with a compressor / permeator system in which the CO2 would be separated
from the vinyl ether product in the permeator. The permeator would be vented directly to the
atmosphere, with an potential emission rate of 53 kg CO2 per hour or 464.3 metric tons CO2 per
year, and 0.16 kg vinyl ether per hour or 1.54 tons VOC per year . Actual emissions from the
proposed modification are 58 metric tons CO2 per year and 0.44 tons VOC per year.
E.I. du Pont de Nemours and Company
DEQ-CFW 00068005

Dr. Donald R. van der VaaP • Page 2 of 2
NCDENR — DAQ
August 10, 2012
The Vinyl Ethers North Process currently emits less than 30 tons VOC per consecutive 12-month
period versus the PSD avoidance limitation of 68.9 tons VOC per consecutive 12-month period.
Therefore the proposed process change's small potential increase of 1.54 tons VOC per year
would be inconsequential.
The proposed process change's potential emission rate of 464.3 metric tons CO2 per year is well
less than the 75,000 metric ton CO2 per year significant emission rate under the PSD regulations.
Therefore it would appear that the proposed process change would not result in any substantive
change to the subject Title V Air Permit.
DuPont appreciates DAQ's consideration of the proposed change to the Vinyl Ethers North
Process and the determination as to whether this process change will necessitate the submission
of a permit modification application.
As required by the general conditions of the subject Title V air permit, two copies of this letter
are being sent to the NCDENR DAQ Fayetteville Regional Office.
If you have any questions regarding this letter, or if you need additional information, please call
me at [phone].
Sincerely
Michael E. Johnson
Environmental Manager
cc: Mr. Steven F. Vozzo, NCDENR — DAQ FRO
Ms. Jenny Kelvington, NCDENR — DAQ Central Office
DEQ-CFW 00068006

CENTRAL OFFICE PERMIT TRACKING SLIP I� 0 `�
+ F tli plicat'on Ib. 67 0 0 0 0-1
Facility Name:
gounty/Regii 04,LVngi.1:
Send Regional Office Copy of Application: ❑ Yes q�N0
PART I -ACCEPTANCE ECKLIST
Acknowledgement Letter: 0 Already Sent ❑ Please S d
Initial Event(s): 0 TV-Ack./Complete ❑ State ck. Letter due
❑ TV-Ack./Incomplete add info ❑ S e App. not accepted — add info request
Fee Information: Acceptance Check List:
Amount Due: PSD or NSR/NAA $13,488 Yes No NA
PSD and NSR/NAA $26,235 Appropriate Number of Apps Submitted (minimum of 2) 0 0 0
TV Greenfield $8,910 Application Fee Submitted 0 0 ❑
TV $867 Zoning Addressed 0 0 ❑
Ownership Change $62 Authorized Signature 0 0 ❑
Renewal/Name Change — NA PE Seal 0 0 0
Initial Amount Received: Application Contains Toxics Modification(s) 0 0 0
Additional Amount Due:
PART I - IBEAM UPDATES PART III - COMPLETENESS CHECKLIST
Application Type: Permit Application Schedule:
❑ Additional Permit ❑ ppeal ❑ Director Administrative Amendment ❑ Required Application Forms Submitted and Completed
❑ Administrative Amendment Expedited State ❑ State ❑ Supporting Materials & Calculations Received
❑ Appeal ❑ PSD 0 PE Seal (If 15A NCAC 2Q .0112)
❑ Greenfield Facility ❑ Modeling Protocol Acceptance
❑ Last GACT/Toxics ❑ Confirmation of Pollutants Modeled
❑ Last MACT/Toxics ❑ TV — State Only ❑ TV — 502(b)(10) ❑ E5 Form (Significant Modifications)
❑ Modification ❑ TV — Expedited ❑ TV — Minor
❑ Name Change ❑ TV — Greenfield ❑ TV — Renewal
❑ New Permit ❑ TV — Reopen for Cause ❑ TV — Significant (2Q.0501 (c)(2))
❑ Ownership Chan ❑ TV — Administrative ❑ TV — Significant
❑ Renewal ❑ TV — Ownership Change ❑ TV — V Time
❑ Renewal w odification
n PART IV - GENERAL COMMENTS
PART V - SUPERVISOR REVIEW CHECKLIST
TVEE Updated (by Engineer): TVEE Verified: Supervisor:
PART VI - CLOSEOUT INFORMATION �y
Regulations Applicable to This Application (indicate all new regulations): Permit Class Information
0 NESHAPS/MACT 0 PSD/NSR ❑ Toxics/Combustion Sources After 7/10/10 Before After
0 NESHAPS/GACT ❑ PSD/NSR Avoidance ❑ SIP Regulations (list all new): ❑ Small ❑ Title V
0 NSPS 0 Existing Source RACT/LAER ❑ Syn Minor
❑ 2D .1100 ❑ New Source RACT/LAER 0 Title V
❑ 2Q .0711 ❑ PACT Avoidance ❑ Proh Small
❑ General
0 2Q .0705 Last MACT/Toxics ❑ RACT/LAER Added Fee ❑ Transportation
(Let Connie Horne know)
HAP Major Status (after) ❑ Major ❑ Minor ❑ Not Determined
PSD or NSR Status (after) ❑ Major ❑ Minor
Miscellaneous ❑ Multiple Permits at Facility ❑ Multi -Site Permit [I Recycled
Oil Condition
Dates Issue Effective
IBEAM Closed Out By:
Permit Number:
❑ Public Notice Published ❑ Public Notice Affidavit (if not noticed via DAQ Website)
Document Manager Updated by Engineer: Date:
Tracking Slip v38 - mjc
Expiration
Revision Number:
''. E E I V E
UENR
Y7TEViLLE REGIONAL OFFICE
DEQ-CFW 00068007