DEQ-CFW_00068354

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NORTH CAROLINA DIVISION OF
AIR QUALITY
Permit Issue Date:
Regional P&O Review
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
NAILS: 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
Karen Wrigley
Plant Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Regional Engineer: Christy Richardson
Engineer's Signature: Date:
Facility Description
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: Christy Richardson
Date of Last Inspection: 04/16/2008
Compliance Code: 3 / In Compliance - Inspecti
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
Application Data
Application Number: 0900009.08D
Date Received: 12/09/2008
Application Type: Modification
Application Schedule: TV-Sign-501(c)(2)
Existing Permit Data
Existing Permit Number: 03735/T33
Existing Permit Issue Date: 08/04/2008
Existing Permit Expiration Date: 01/31/2009
Comments / Recommendations:
Issue 03735/T34
Permit Issue Date:
Permit Expiration Date:
Dupont Company - Fayetteville Works (0900009) is a chemical manufacturing facility located in Bladen
County. The Plant consists of six individual manufacturing processes: Butaciteg Process Area, Nafion®
Process Area, Fluoroproducts Polymer Manufacturing Development Facility (PMDF/Teflon),
Ammonium Perfluorooctanate (APFO) Manufacturing Facility, SentryGlas® Plus Manufacturing Facility
and two Polyvinyl Fluoride Polymer Manufacturing Facilities. The facility is subject to NESHAP
Subpart KK, Printing and Publishing Industry, and Subpart FFFF, Miscellaneous Organic NESHAP. The
facility has two permanent boilers as well as one temporary boiler, which is transient and comes on and
off site as needed.
Purpose
DuPont Company — Fayetteville Works has submitted the Part 1 and Part 2 permit applications for the
addition of a new natural gas / No. 2 fuel oil -fired boiler, HFPO product cylinder decontamination
process, Vinyl Ethers North production cylinder decontamination process, and Vinyl Ethers South
production cylinder decontamination process. The application also requests to add natural gas as a fuel
DEQ-CFW 00068354

option to the two currently permitted boilers and one permitted temporary boiler. The application also
requests some typographical corrections and / or clarifications, which will be described in more detail
below. This P&O serves as the regional comments for both the Part 1 (0900009.08D) and Part 2
(0900009.08E) applications.
Permit Modification Issues
The following is a detailed description of each of the proposed changes detailed in the application
narrative provided by DuPont — Fayetteville Works (Items 1-8):
(1) Addition of a Natural Gas / No. 2 Fuel Oil -Fired Boiler (ID No. PS-C). DuPont is requesting to
add a natural gas / No. 2 fuel oil -fired boiler with low-NOx burner (97 mmBTU/hr max heat
input). The boiler will be subject to NSPS Subpart Dc, 2D .0503, 2D .0516, and 2D .0521.
Emissions are below PSD thresholds since the facility will utilize a low-NOx burner.
(2) Addition of HFPO Product Cylinder Decontamination Process (ID No. NS-N). The facility
discovered an existing, unpermitted source in which the facility purges all `left -over' product
from the tankers and 1-ton cylinders. Potential to emit is 100 TPY; therefore, the facility has
requested a PSD avoidance limit of 40 TPY of VOC. The facility made a modification to this
process in 2006, unless the net change in potential exceeded 40 tons, not sure that this would
trigger PSD avoidance.
(3) Addition of Vince Ethers North Product Cylinder Decontamination Process (ID No. NS-O). The
facility discovered an existing, unpermitted source in which the facility purges all `left -over'
product from the tankers and 1-ton cylinders. Potential to emit 20.6 TPY; therefore, emissions
are below PSD thresholds.
(4) Addition of Vinyl Ethers South Product Cylinder Decontamination Process (ID No. NS-P). The
facility discovered an existing, unpermitted source in which the facility purges all `left -over'
product from the tankers and 1-ton cylinders. Potential to emit 10.7 TPY; therefore, emissions
are below PSD thresholds
(5) Rename SentryGlas (ID No. SGS-A). All references to SentryGlas® Plus should be changed to
SentryGlas® in the permit.
(6) Add natural gas as a fuel source to all boilers (ID Nos. PS-1, PS-2, and PS -Temp). The facility
has requested to add natural gas as a fuel source to all boilers. It does not appear that this will
trigger any PSD implication since there is no increase in emissions for NOx and no increase in
CO emissions over the threshold limits.
(7) Add Painting as description in the Abrasive Blasting Building (ID No. I-10) description.
(8) Typographical error. Make correction to ID no.
Facility Compliance Status
The facility was last inspected by Christy Richardson and Tien Nguyen on April 16, 2008 and appeared to
be operating in compliance with all requirements outlined in their current air permit. On January 6, 2009,
the facility was issued a Notice of Recmmendation for Enforcement (NRE) for operating the
decontamination sources listed above (ID Nos. NS-N, NS-O, and NS-P) without an air permit. In
November 2007, the facilitywas issued a Notice of Violation (NOV) for failure to submit operating
permit application (Part 2) in a timely manner. The facility was issued a compliance addition information
(CAI) letter in August 2007 concerning the permit applicability of a paint operation and shot blast
operation as well as abnormal visible emissions from the boilers noted during two recent site visits.
DEQ-CFW 00068355

Emissions Inventory Review
The largest criteria pollutant emissions as reported on the CY 2007 AQEI were volatile organic
compounds at 342 tons and sulfur dioxide at 443 tons. The vast majority of the VOC and SO2 emissions
were a result of combustion of fuel oil in the boilers and Nafion manufacturing process.
The largest HAP/TAP emissions as reported on the CY 2006 AQEI were methanol at 23 tons, acetonitrile
at 5 tons, hydrogen fluoride at 1.7 tons, and methylene chloride at 1.7 tons.
Additional Items
There are no additional issues listed on the FRO Facility Tracking Form (pink sheet) in the facility folder.
Recommendation
FRO recommends that RCO issue the revised air permit (03735T34 & T35) to DuPont Company —
Fayetteville Works. If DuPont — Fayetteville Works submits any revisions to this application, FRO
requests a copy of the submittal for additional review. Also, FRO would like to review the draft permit
and draft review prior to being issued to the company or for public review.
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Regional Engineer. C VA CL-�I Date: �f I
Permit Coordinator: Date: a /
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AQ Supervisor: l / Date:
FRO Files
RCO Files
DEQ-CFW 00068356