DEQ-CFW_00068357

STM VOM
FAYErrMLLE R.O.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor
August 4, 2008
Ms. Karen B. Wrigley
Plant Manager
E.I. du Pont de Nemours & Co., LLC
DBA, DuPont Company — Fayetteville Works
22828 NC Highway 87 West
Duart Township, North Carolina 28306-7332
Dear Ms. Wrigley
SUBJECT: Air Quality Permit No. 03735T33
Facility ID: 0900009
E.I. du Pont de Nemours & Co., LLC
DBA, DuPont Company — Fayetteville Works
Duart Township
Bladen County
Fee Class: Title V
William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
In accordance with your completed Air Quality Permit Application for a "I" -Part" significant modification
of a Title V permit pursuant to 15A NCAC 2Q .0501(c)(2) received April 8, 2008, we are forwarding herewith
Air Quality Permit No. 03735T33 to E.I. du Pont de Nemours & Co., LLC, Duart Township, Bladen County,
North Carolina authorizing the construction and operation of the emission source(s) and associated air pollution
control device(s) specified herein. Additionally, any emissions activities determined from your Air Quality Permit
Application as being insignificant per 15A North Carolina Administrative Code 2Q .0503 have been listed for
informational purposes. Please note the requirements for the annual compliance certification are contained in
General Condition P in Section 3. The current owner is responsible for submitting a compliance
certification for the entire year regardless of who owned the facility during the year.
The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 2Q
.0504 for the air emission source(s) (ID No. FS-C) on or before 12 months after commencing operation.
As the designated responsible official it is your responsibility to review, understand, and abide by all
of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition of
the attached permit reviews, understands, and abides by the condition(s) of the attached permit that are
applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you, you
have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identiflying
Permitting Section One
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 NorthCarolina
2728 Capital Blvd., Raleigh, North Carolina 27604 a?
Phone: [phone] / FAX [phone] / Internet: www.ncair.org �/ �/atumll
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00068357

Ms. Karen B. Wrigley
August 4, 2008
Page 2
the specific issues to be contested. This hearing request must be in the form of a written petition, conforming to
NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of Administrative Hearings,
6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division of Air Quality, Permitting
Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Please note that
this permit will be satyed in its entirety upon receipt of the request for a hearing Unless a request for a hearing
is made pursuant to NCGS 15013-23, this Air Quality Permit shall be final and binding 30 days after issuance.
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
15013-22. This request must be submitted in writing to the Director and must identify the specific provisions or
issues for which the modification is sought. Please note that this Air Quality Permit will become final and binding
regardless of a request for informal modification unless a request for a hearing is also made under NCGS 15013-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction. Failure to do so is a violation of GS 143-215.108 and may subject the Permittee to civil or
criminal penalties as described in GS 143-215.114A and 143-215.114B.
This Air Quality Permit shall be effective from August 4, 2008 until January 31, 2009, is nontransferable
to future owners and operators, and shall be subject to the i d limitations as specified therein. Should
you have any questions concerning this matter, please ntact Ms. Fern P terson, P.E. at [phone].
Van der Vaart, Ph.D., P.E.
Enclosure
cc: V Fayetteville Regional Office
Central Files
DEQ-CFW 00068358

ATTACHMENT I:
C---7 of rha""ac to Pravinnc Permit (Nn 01719TTI)
Pa e s
Section
Description of Change(s)
N/A
Insignificant
Add "Abrasive blasting building" (ID No. I-10) to the insignificant activity
Activity List
list.
Global
Global
[Testing Requirement Citations] Change all references to 15A NCAC 2D
.0501 c to 15A NCAC 2D .2601 to be consistent with a recent rule change.
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
5
Sec. 1, Table
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add table footnotes with procedural/Perinit Shield information related to
the modification.
6
Sec. 2.1. A., Table
Add reference to PSD Avoidance Condition for SO2, which is located in
Section 2.2. A. 1. of the draft ern -lit.
7
Sec. 2. L A.3.d.ii.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ Protocol.
11
Sec. 2.1. B.2.c.ii.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ protocol.
20
Sec. 2.1. G., Table
Add reference to PSD Avoidance Condition for 5O2, which is located in
Section 2.2. A. 1. of the draft pertrift.
23-26
Sec. 2.1. I.
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add clarification language to existing visible emission monitoring
language to be consistent with current DAQ protocol (Section 2.1. 1.2.c. ii)
- Add PSD avoidance condition for VOC Section 2.1. I.
26-27
Section 2.2. A.
Add PSD avoidance condition limiting SO2 emissions from the existing
boilers to no greater than 702.5
32-33
Sec. 2.2. B.3.
Add 15A NCAC 2D .0541 — "Control of Emissions from Abrasive Blasting".
This rule is state -enforceable only.
34-42
General Conditions
Update General Conditions with the most current version (v2.20), including
changes to General Condition JJ (Testing), new General Condition MM
(Fugitive Dust and new General Condition NN Modification Procedures).
DEQ-CFW 00068359

ATTACHMENT H:
Just mncant activities rursuani w zm.u:)uji a
Emission Source
Emission Source Description
I-1
Polyvinyl fluoride vacuuming system for housekeeping purposes
I-2
Waste DMSO Storage Tank
I-3
Fugitive Emissions of Methylene Chloride
I-4
Chlorination of Riverwater to control mussel growth in equipment
I-5
Sitewide Laboratory Emissions
I-6
Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension
I-7
Paint shop
I-8
Self-contained abrasive blasting cabinets
I-9
Paint spray booths
I-10
Abrasive blasting building
I-Bl
PVA Unloading System and Storage Silos
I-B2
PVA Dissolver Tank System
I-B7
Plasticizer storage tank
1. Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement or that
the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement.
2. When applicable, emissions from stationary source activities identified above shall be included in determining
compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100 "Control of Toxic Air
Pollutants" or 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit".
DEQ-CFW 00068360

State of North Carolina, 0
Department of Environment,
and Natural Resources
Division of Air Quality
' PIPFA
NCDENR
AIR OUALITY PERMIT
Permit No.
Replaces Permit No.
Effective Date
Expiration Date
03735T33
03735T32
August 4, 2008
January 31, 2009
Until such time as this permit expires or is modified or revoked, the below named Permittee is permitted to construct and
operate the emission source(s) and associated air pollution control device(s) specified herein, in accordance with the terms,
conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B of Chapter 143,
General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes (15A NCAC),
Subchapters 2D and 2Q, and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission source(s)
or air pollution control device(s) without having first submitted a complete Air Quality Permit Application to the permitting
authority and received an Air Quality Permit, except as provided in this permit.
Permittee: E.I. du Pont de Nemours & Co., LLC
DBA, DuPont Company — Fayetteville Works
Facility ID: 0900009
Facility Site Location: 22828 NC Highway 87 W
City, County, State, Zip: Duart Township, Bladen County, NC, 28306-7332
Mailing Address: 22828 NC Highway 87 W
City, State, Zip: Fayetteville, NC, 28306-7332
Application Number: 0900009.08A
Complete Application Date: April 8, 2008
Primary SIC Code: 2821, 3081, 3083
Division of Air Quality, Fayetteville Regional Office
Regional Office Address: 225 Green Street, Suite 714
Fayetteville, NC 28301
issued this the V day of August, 2008
,$. der Vaart, Ph.D., P.E., Chief, Air Permits Section
By Authority of the Environmental Management Commission
DEQ-CFW 00068361

SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1- Emission Source(s) Specific Limitations and Conditions (Including specific
requirements, testing, monitoring, recordkeeping, and reporting requirements)
2.2- Multiple Emission Source(s) Specific Limitations and Conditions (Including
specific requirements, testing, monitoring, recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT
List of Acronyms
DEQ-CFW 00068362

1 0 0
Permit 03735T33
Page 3
The Division of Air Quality (DAQ), the United States Environmental Protection Agency (EPA), and citizens as defined under the
Federal Clean Air Act have the authority to enforce the terms, conditions, and limitations contained in this permit unless otherwise
specified.
Under Title 15A NCAC 2Q, the operation of emission source(s) and associated air pollution control device(s) and appurtenances
listed in this permit is based on plans, specifications, operating parameters, and other information as submitted in the Air Quality
Permit Application.
SECTION I - PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE(S) AND APPURTENANCES
71,o F:,lln...;»R+nPrm7ttA/i Pmia.cinn cnnme., and nssnciated air nollution control devices:
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
PS-1
No, 2/No. 6 fuel oil -fired boiler (139.4
N/A
N/A
million Btu per hour maximum heat
in ut
PS-2
No. 2/No. 6 fuel oil -fired boiler (88.4
N/A
N/A
million Btu per hour maximum heat
in ut
PS -Temp
No. 2 fuel oil -fired boiler (greater than
N/A
N/A
NSPS De
30.0 and less than 100.0 million Btu per
hour maximum heat input)
BS-A
Butyraldehyde storage tank
BCD -A
Brine -cooled condenser
BS-B 1.1
Butacite polyvinyl butyral flake reactors
BCD-B 1
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B 1.4
injection rate averaged over a 3-hour
period) state -enforceable only)
BS-B2.1
Butacite polyvinyl butyral flake reactors
BCD-B2
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B2.4
injection rate averaged over a 3-hour
eriod) (state -enforceable only)
BS-C
Butacite polyvinyl butyral flake dryer
BCD-Cl
Cyclone separator
BCD-C2
Fabric filter (6,859 square feet of filter
area
BS-El
Butacite @ Line No. 3 Sheeting Extrusion
BCD -El
Water -Cooled Condenser (voluntary
Process including four 4 extruders
use only)
BS-E2
Butacite Line No. 4 Sheeting Extrusion
BCD-E2
Water -Cooled Condenser (voluntary
Process includin four 4 extruders
use only)
BS-E3
Butacite Line No. 3 Back -End
N/A
N/A
Processes, including a quencher,
dryer/rela and wind-up area
BS-E4
Butacite0 Line No. 4 Back -End
N/A
N/A
Processes, including a quencher,
d er/relaxer and wind-up area
BS-D
Butacite Polyvinyl butyral sheeting
BCD-D1
Multi -stage horizontal spray scrubber (6
MACT KK
rotogravure printing operation
gallons per minute of water flow to each
nozzle averaged over a 3-hourperiod)
DEQ-CFW 00068363

Permit 03735T33
Page 4
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
NS-A
Nafion® Hexfluoropropylene epoxide
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
process (HFPO)
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-B
Nafion® Vinyl Ethers North process
NCD-Rdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-C
Nafion® Vinyl Ethers South process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-D
Nafion® RSU Process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
avera ed over a 3-hourperiod)
NS-E
Nafion® Liquid waste stabilization
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
avera ed over a 3-hourperiod)
NS-F
Nafion® MMF process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
avera ed over a 3-hour eriod
NS-G
Nafion® Resins process
NCD-G
Venturi vacuum jet caustic scrubber
MACT FFFF
NS-H
Nafion® membrane process
N/A
N/A
MACT FFFF
NS-I
Nafion® membrane coating
N/A
N/A
MACT FFFF
NS-J
Nafion® semiworks
N/A
N/A
MACT FFFF
DEQ-CFW 00068364

Permit 03735T33
Page 5
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
NS-K
Nafion® E-2 Process
N/A
N/A
MACT FFFF
NS-L
Nafion® TFE/HCl separation unit
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-M
Nafion® TFE/CO2 separation process
N/A
N/A
SW-1
Semiworks polymerization operation
N/A
N/A
SW-2
Semiworks laboratory hood
N/A
N/A
FS-A
Fluoroproducts polymer manufacturing
FCD-Al
Wet scrubber (3 gallons per minute
development facility
water injection rate averaged over a 3-
hour period) (nominal injection rate)
Fabric filter (125 square feet of filter
FCD-A2
area
AS -A
APFO Manufacturing Facility
ACD-Al
Wet scrubber (30 gallons per minute
water injection rate averaged over a 3-
hour period) (state -enforceable only)
Wet scrubber installed on the building
ACD-A3
exhaust vent(voluntary use only)
WTS-A
Extended aeration biological wastewater
N/A
N/A
treatment facility
WTS-B,
Two (2) Indirect steam -heated, rotary
WTCD-1
Impingement -type wet scrubber with
WTS-C
slud e drvers
mist eliminator state -enforceable only)
SGS-A
SentryGlas Plus Manufacturing
N/A
N/A
FS-B
Polyvinyl Fluoride Manufacturing
N/A
N/A
Facility No.1
FS-C'
Polyvinyl Fluoride Manufacturing
N/A
N/A
Facility No.2
' This emission source (ID No. FS-C) is listed as a 15A NCAC 2Q .0501(c)(2) modification. The Permittee shall file a Title V Air Quality
Permit Application on or before 12 months after commencing operation in accordance with General Condition NN.L The permit shield
described in General Condition R does not apply and compliance certification as described in General Condition P is not required.
DEQ-CFW 00068365

Permit 03735T33 •
Page 6
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 -Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s) and appurtenances listed below are subject to the
following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting
requirements as specified herein:
A. No. 2/No. 6 fuel oil -fired boiler (ID No. PS-1), 139.4 million Btu per hour maximum heat input,
and
No. 2/No. 6 fuel oil -fired boiler (ID No. PS-2), 88.4 million Btu per hour maximum heat input.
The followinR table rovides a summary of limits and standards for the emission sources described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
0.2667 pounds particulate per million Btu heat input, each
15A NCAC 2D .0503
Sulfur dioxide
2.3 pounds S02 per million Btu heat input, each
15A NCAC 2D .0516
Visible emissions
Affected Source: PS-1, only
15A NCAC 2D .0521(c)
40% visible opacity emissions
Affected Source: PS-2, only
15A NCAC 2D .0521(d)
20% visible opacity emissions
PM, PM-10, NO., and
Affected Source: PS-2, only
15A NCAC 2Q .0317
SOZ
Particulate matter <25 tons per year.
(PSD Avoidance)
Particulate matter under 10 micron <15 tons per year.
Nitrogen oxide <40 tons per year.
Sulfur dioxide <40 tons per year.
Sulfur dioxide
Affected Sources: PS-1, PS-2, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
(PSD Avoidance)
See Section 2.2. A.1. of this permit
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2/No. 6 fuel oil, that are discharged from this source into
the atmosphere shall not exceed 0.2667 pounds per million Btu heat input.
lestin [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
this test are above the limit given in Section 2.1 A. La. above, the Permittee shall be deemed in noncompliance with
15A NCAC 2D .0503.
Monitoring/Recordkeeping/Re or inu [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 or No. 6 fuel oil
in these sources.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. Sulfur
dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included when
determining compliance with this standard.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
DEQ-CFW 00068366

Permit 03735T33 •
Page 7
Condition JJ found in Section 3. If the results of this test are above the limit given in Section 2.1 B. La. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeering [15A NCAC 2Q .0508(f) and 15A NCAC 2D .0501(c)(4)(A)]
c. No monitoringlrecordkeeping is required for sulfur dioxide emissions from No. 2 fuel oil burned in these sources.
d. The maximum sulfur content of any No. 6 fuel oil received and burned in the boiler shall not exceed 2.1 percent by
weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the fuel
oil exceeds this limit.
To assure compliance, the Permittee shall monitor the sulfur content of the No. 6 fuel oil by using fuel oil supplier
certification per shipment received. The results of the fuel oil supplier certifications shall be recorded in a logbook
(written or electronic format) on a quarterly basis and include the following information:
i. The name of the fuel oil supplier;
ii. The maximum sulfur content of the fuel oil received during the quarter;
iii. The method used to determine the maximum sulfur content of the fuel oil; and
iv. A certified statement signed by the responsible official that the records of fuel oil supplier certification submitted
represent all of the No. 6 fuel oil fired during the period.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the oil is not
monitored and recorded.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on or before January
30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boiler (ID No. PS-1) shall not be more than 40 percent opacity when averaged over a six -
minute period. However, six -minute averaging periods may exceed 40 percent not more than once in any hour and
not more than four times in any 24-hour period. In no event shall the six -minute average exceed 90 percent opacity.
b. Visible emissions from the boiler (ID No. PS-2) shall not be more than 20 percent opacity when averaged over a six -
minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any hour and
not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent opacity.
Testing [15A NCAC 2D .2601]
c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 A.3.a. or .b above, the Permittee shall
be deemed in noncompliance with 15A NCAC 21) .0521.
Monitoring [15A NCAC 2Q .0508(f)]
d. To assure compliance, each day that an affected source fires No. 6 fuel oil, the Permittee shall observe the emission
point of the affected source for any visible emissions above normal. The daily observation must be made for each
day of the calendar year period to ensure compliance with this requirement. The Permittee shall be allowed three (3)
days of absent observations per semi-annual period. If visible emissions from this source are observed to be above
normal, the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 A.3.a. or b. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
DEQ-CFW 00068367

Permit 03735T33 •
Page 8
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
R ce� ordkeeping [15A NCAC 2Q .0508(f)]
The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Monitoring/Recordkee,ping[ Rg on rtin_g [15A NCAC 2Q .0508(f)]
f No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in these
sources.
Reporting [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the affected
boiler (ID No. PS-2 only) shall discharge into the atmosphere less than the following, per consecutive 12-month
period.
Pollutant
Emission Limitation
tons per ear
Particulate Matter
25
Particulate Matter under 10 microns
15
Nitrogen Oxide
40
Sulfur Dioxide
40
T stin [15A NCAC 2Q .2601]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test are above the limit given in Section 2.1 AA.a., the Permittee shall be deemed in noncompliance.
with 15A NCAC 2D .0530.
Monitoring/Reeordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly accounting records of the amount of fuel used and the sulfur content, including
certification of the fuel, in a logbook (written or in electronic format). The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the sulfur content of the fuel is not monitored.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
DEQ-CFW 00068368

Permit 03735T33 •
Page 9
between January and June. The report shall contain the following:
i. The monthly particulate matter, particulate matter below 10 microns, nitrogen oxide, and sulfur dioxide
emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over
the previous 17 months;
ii. The monthly quantities of No. 2/No. 6 fuel oil consumed for the previous 17 months;
iii. The average sulfur content for the fuel oil; and,
iv. All instances of deviations from the requirements of this permit must be clearly identified.
B. Butacite® Process Area consisiting of one butyraldehyde storage tank (ID No. BS-A)
controlled by a brine cooled condenser (ID No. BCD -A),
Four Butacite® flake reactors (ID Nos. BS-B1.1 through BS-BIA) controlled by a packed -
bed scrubber (ID No. BCD-Bl),
Four Butacite® flake reactors (ID Nos. BS-B2.1 through BS-B2.4) controlled by a packed -
bed scrubber (ID No. BCD-B2),
One Butacite® flake dryer (ID No. BS-C) controlled by a cyclone (ID No. BCD-Cl) and
fabric filter (ID No. BCD-C2) and,
Butacite Line No. 3 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-El)
controlled by a water-cooled condenser (ID No. BCD -El) (voluntary use only)
Butacite Line No. 4 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-E2)
controlled by a water-cooled condenser (ID No. BCD-E2) (voluntary use only)
Butacite Line No. 3 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area t1D No. BS-E3)
Butacite Line No. 4 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area (ID No. BS-E4)
One polyvinyl butyral sheeting rotogravure printing operation (ID No. BS-D) controlled by
one multi -stage horizontal spray scrubber (ID No. BCD -DI).
_ r_n ___.:___._t_t_ � .: a,... ,. ,.07:.,.. «.7 ,.t..«.7.,.�.7� F ,-tl.e a a/c\ AncrrihA(1 ahnvo•
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Source: BS-C, only
15A NCAC 2D .0515
for process rates less than 30 tons per hour -
E = 4. 10 x P 0.67
Where:
E = allowable emission rate in pounds per hour, and
P = the process weight rate in tons per hour
Visible emissions
Affected Source: BS-C, only
15A NCAC 2D .0521
ZO% visible opacitygpacity emissions
Odors
State -enforceable only
15A NCAC 21).1806
Odorous emissions must be controlled.
Organic HAP
Affected Source: BS-D, only
15A NCAC 2D .1111
National Emission Standards for Hazardous Air
(40 CFR 63, Subpart KK)
Pollutants Printing and Publishing Industry
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. BS-C) shall not exceed an allowable emission rate
as calculated by the following equation:
DEQ-CFW 00068369

Permit 03735T33 •
Page 10
E=4.10xPo.6�
Where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 B. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [ 15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the Butacite flaker dryer (ID No. BS-C) shall be controlled by the bagfilter (ID
No. BCD-C2) and cyclone separator (ID No. BCD-Cl). To assure compliance, the Permittee shall perform
inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and
maintenance recommendations, or if there is no manufacturer's inspection and maintenance recommendations, as a
minimum, the inspection and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii. An annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and bagfilters are not
inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on -site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bagfilters; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 days of a written
request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or.before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. BS-C) shall not be more than 20 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 B.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
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Page 11
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. If visible emissions from this source are observed to be above normal,
the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 B.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
R ce ordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -.site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
STATE-ENFORCRART E ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
b. CONDENSER REQUIREMENTS - Odorous emissions from the butyraldehyde storage tank (ID No. BS-A) shall
be controlled by a condenser (ID No. BCD -A). To comply with the provisions of this Permit and ensure that
maximum control efficiency is maintained, the Permittee shall perform periodic inspections and maintenance as
recommended by the manufacturer. The results of the inspections and maintenance shall be recorded in a logbook
(either written or electronic).
c. SCRUBBER REQUIREMENTS - Gaseous emissions from the Butacite flake reactor line (ID Nos. BS-B1.1
through BS-B1.4) shall be controlled by packed column scrubber (ID No. BCD-111). Gaseous emissions from the
Butacite flake reactor line (ID Nos. BS-B2.1 through BS-B2.4) shall be controlled by packed column scrubber (ID
No. BCD-B2).
d. INSPECTION AND MAINTANENCE REQUIREMENTS - To comply with the provisions of this Permit and
ensure that maximum control efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the manufacturer. As a minimum, the inspection and maintenance program shall
include inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the
cleaning/calibration of all associated instrumentation.
e. MONITORING REQUIREMENTS - The Permittee shall ensure the proper performance of the Flake Reactor
Line's packed column scrubbers (ID Nos. BCD-B1 and BCD-B2) by monitoring the following operational
DEQ-CFW 00068371

Permit 03735T33
Page 12
parameters:
i. Liquid flow rate (minimum of 8 gallons per minute averaged over a 3-hour period), and
ii. Differential pressure across the scrubber (maximum of 30 inches of water pressure averaged over a 3-hour
period), with a high differential pressure alarm.
RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (written or electronic records) that shall be kept on site and made available to Division of Air Quality
personnel upon request. Any variance from the manufacturer's recommendations or the permit monitoring
requirements, or the failure of the air pollution control equipment to operate in a normal and usual manner, shall be
investigated with corrections made and dates of action recorded in the log book. The inspection and maintenance
activities, as well as required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate,
shall be recorded.
4. 15A NCAC 2D .1111: MAXIMUM AVAILABLE CONTROL TECHNOLOGY (40 CFR 63, Subpart KK:
Printing and Publishing Industry)
For the polyvinyl butyral (Butacite ) sheeting rotogravure printing operation (ID No. BS-D), the Permittee shall comply
with all applicable provisions, including the notification, testing, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111 as promulgated in 40 CFR 63, Subpart KK,
including Subpart A "General Provisions" except as follows:
"Oxidizer" referenced in 40 CFR Part 63.820 through 63.831 shall refer to scrubber (ID No. BCD -DI) and shall require
the operation and maintenance of devices to monitor water flow rate and air flow rate (used in dispersion of water in the
scrubber) for the scrubber (ID No. BCD -DI) in lieu of a temperature monitoring device for an oxidizer.
Control Requirements [15A NCAC 2Q .0508(f)]
a. Emissions from the polyvinyl butyral sheeting rotogravure printing operation shall be controlled using a permanent
total enclosure for the process area and a multi -stage horizontal spray scrubber (ID No. BCD-Dl) that achieves an
overall organic HAP control efficiency of at least 95 percent.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
b. The Permittee shall ensure the proper performance of the scrubber (ID No. BCD -DI) by monitoring the following
operational parameters:
i. Water flow rate to each nozzle (minimum of 6 gallons per minute, averaged over a three-hour period).
ii. Air flow rate to each nozzle (minimum of 63 standard cubic feet per minute, averaged over a three-hour period).
iii. General area exhaust fan exit velocity (minimum of 3,950 feet per minute, averaged over a three-hour period).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the required monitoring is not
conducted or if the monitored parameter exceeds the minimum value.
Rec�rdkeeping/Repor in¢ [15A NCAC 2Q .0508(f)]
The Permittee shall comply with all applicable record keeping and reporting requirements specified in 40 CFR Parts
63.829 and 63.830, and in 40 CFR Part 63 Subpart A - General Provisions, including the following reporting
requirements:
i. As specified in 40 CFR Part 63.6(e)(3)(iv), if an action taken by the Permittee during a startup, shutdown, or
malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified
in the affected source's startup, shutdown, and malfunction plan, the Permittee shall record the actions taken for
that event and shall report such actions within 2 working days after commencing actions inconsistent with the
plan, followed by a letter within 7 working days after the end of the event, in accordance with 40 CFR Part
63.10(d)(5).
ii. The Permittee shall submit to the Regional Supervisor, DAQ, a semi-annual summary report as specified in 40
CFR Part 63.830, by January 30 of each calendar year for the preceding six-month period between July and
December, and by July 30 of each calendar year for the preceding six-month period between January and June.
iii. If the actions taken by the Permittee during start-up, shutdown, or malfunction (SSM) are not completely
DEQ-CFW 00068372

Permit 03735T33
Page 13
•
consistent with the procedures specified in the SSM plan, then the Permittee shall submit an SSM report, as
specified in 40 CFR 63.830, to the Regional Supervisor, DAQ. However, separate SSM reports are not required
if the information is included in the semi-annual summary report specified above in Section 2.1. BA.c.i.
C. Nafion° Process Area consisting of one hexfluoropropylene epoxide process (ID No. NS-A)
controlled by one baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2),
Two vinyl ethers processes (ID Nos. NS-B and NS-C) EACH controlled by one of two available
baffle -plate scrubbers (ID No. NCD-Hdrl or NCD-Hdr2),
One RSU process (ID No. NS-D) controlled by one baffle -plate scrubber (ID No. NCD-Hdr1 or
NCD-Hdr2),
One liquid waste stabilization process (ID No. NS-E) controlled by one baffle -plate scrubber
(ID No. NCD-Hdr1 or NCD-Hdr2),
One MMF process (ID No. NS-F) controlled by one baffle -plate scrubber" (ID No. NCD-Hdrl
or NCD-Hdr2),
One resins fluorination process (ID No. NS-G) controlled by a venturi vacuum jet scrubber (ID
No. NCD-G),
One Nafion membrane process (ID No. NS-H),
One Nafion® membrane coating process (ID No. NS-I),
Three Nafion semiworks processes (ID Nos. SW -I, SW-2, and NS-J),
One E-2 Process (ID No. NS-K),
One TFE/HCl separation unit (ID No. NS-L) controlled by one baffle -plate scrubber (ID No.
NCD-Hdrl or NCD-Hdr2), and
One uncontrolled TFE/COZ separation unit (ID No. NS-M)
—_- c_it a..1-1-.. ..A_ ..rl;_;+� A F r41,A nnrra(cl'IPc riJIPd nhnvp.
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Sources: ID No. NS-I, only
15A NCAC 213.0515
For process rates less than 30 tons per hour -
E = 4.10 P0.67
where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons per hour
Visible emissions
Affected Sources: ID No. NS-I, only
15A NCAC 2D .0521
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
Toxic air pollutants
State -enforceable only
15A NCAC 2D .1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2. B.1. and B.2.
Volatile organic
Affected Sources: ID No. NS-B, only
15A NCAC 2Q .0317
compounds
VOC emissions <68.9 tons per consecutive 12-month
(PSD Avoidance)
period
Affected Sources: ID No. NS-G, only
VOC emissions <40 tons per consecutive 12-month
period
Affected Sources: ID No. NS-A, only
VOC emissions <85.3 tons per consecutive 12-month
eriod
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Page 14
Regulated Pollutant
Limits/Standards
Applicable Regulation
Hazardous air
Affected Sources: All, excluding ID No. NS-L and
15A NCAC 2D. 1111
pollutants
NS-M
(40 CFR 63, Subpart FFFF)
Miscellaneous Organic NESHAP MON
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. NS-I) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xP""
Where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 C. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour, as specified by the
formulas contained above (or the formulas contained in 15A NCAC 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515 if the production records are not maintained or the types of materials and finishes are not
monitored.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. NS-I) shall not be more than 20 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 C.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Moni oring/Recordkee,ping/Re on rting, [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
,STATF,-F,NFORCF,ABIX ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
DEQ-CFW 00068374

Permit 03735T33 •
Page 15
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the Vinyl Ethers North process (ID No. NS-B) shall discharge into
the atmosphere less than 68.9 tons of VOCs per consecutive 12-month period.
Monitnring/Recordkee in [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
Monitoring [15A NCAC 2Q .0508(f)]
d. The Permittee shall ensure the proper performance of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-1 and NCD-Hdr-2) by monitoring the following operational parameters:
i. Injection liquid flow rate (minimum of 7,000 kilograms per hour, averaged over a three-hour period).
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The Permittee shall record the results of inspections in a scrubber logbook (written or electronic records), which shall
be kept on site and made available to Division of Air Quality personnel upon request. Any variance from the
manufacturer's recommendations or the permit monitoring requirements, or the failure of the air pollution control
equipment to operate in a normal and usual manner, shall be investigated with corrections made and dates of action
recorded in the log book. The inspection and maintenance activities, as well as required monitoring for scrubbing
liquid flow rates, and scrubber pressure drops, if appropriate, shall be recorded. .
Bl:pilrLing [15A NCAC 2Q .0508(f)]
The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
5. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the resins process (ID No. NS-G) shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic
format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed
this limit.
DEQ-CFW 00068375

•
Permit 03735T33
Page 16
Reporting [I 5A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
6. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the HFPO process (ID No. NS-A) shall discharge into the
atmosphere less than 85.3 tons of VOCs per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
7. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT),
40 CFR 63, Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing (MON)
a. The Permittee shall comply with all applicable provisions contained in Environmental Management Commission
Standard 15A NCAC 2D .1111, "Maximum Achievable Control Technology" (MACT) as promulgated in 40 CFR Part
63, Subpart FFFF by May 10, 2008, or as provided in the rule. [40 CFR 63.2445(b)]
b. The Permittee shall submit a Notification of Compliance Status to the Fayetteville Regional in accordance with 40
CFR 63.2520(d) by October 7, 2008, or as provided in the rule.
DEQ-CFW 00068376

Permit 03735T33 •
Page 17
D. Fluoroproducts polymer manufacturing development facility (ID No. FS-A) controlled by a
wet scrubber (ID No. FCD-Al) and fabric filter (ID No. FCD-A2)
The following tnhle nrnviries a mmmnry of limit- and standards for the emission source(s) described" above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
For process rates less than 30 tons per hour
15A NCAC 2D .0515
E = 4.10 P0.67
Where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons er hour
Visible emissions
20% visible opacity emissions
15A NCAC 21) .0521
Odors
State -enforceable only
15A NCAC 21) .1806
Odorous emissions must be controlled
Volatile organic
Less than 40 tons per consecutive 12-month period
15A NCAC 2Q .0317
compounds
I (PSD Avoidance
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. FS-A) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xPo.67
Where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 D. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 21) .0515.
MonitoringlR . ordk enin [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the Fluoroproducts polymer manufacturing facility (ID No. FS-A) shall be
controlled by the bagfilter (ID No. FCD-A2). To assure compliance, the Permittee shall perform inspections and
maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance
recommendations, or if there is no manufacturer's inspection and maintenance recommendations, as a minimum, the
inspection and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii. An annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and bagfilters are not
inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on -site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bagfilters; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 21) .0515 if these records are not maintained.
DEQ-CFW 00068377

Permit 03735T33
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•
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 days of a written
request by the DAQ.
£ The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID Nos. FS-A) shall not be more than 20 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 E. La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Mon[15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATE. ENFORCEABLE ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the fluoroproducts polymer manufacturing development facility (ID
No. FS-A) shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Moni oring/Recordkeening [15A NCAC 2Q .0508(f)]
b. Calculations of VOC emissions per month shall be made within 30 days of the end of each month. The Permittee
shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the
VOC emissions are not monitored and recorded.
c. The total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the VOC emissions exceed this limit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions for the previous 17 months. The emissions shall be calculated for each of the 12-
month periods over the previous 17 months.
DEQ-CFW 00068378

Permit 03735T33 S
Page 19
E. APFO manufacturing facility (ID No. AS -A) controlled by a wet scrubber (ID No. ACD-Al)
and a building exhaust vent wet scrubber (ID No. ACD-A3) (voluntary use only)
The followino table provides a sununary of limits and standards for the emission sources described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
15A NCAC 2D .1806
odorous emissions must be controlled
Toxic air pollutants
State -enforceable only
15A NCAC 2D. 1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2.A and B.
STATF,-F.NFORCF,ABLF, ONLY
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
STATE -ENFORCEABLE ONT,V
2. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. SCRUBBER REQUIREMENTS - Gaseous and mist emissions from the APFO process area shall be controlled by
a wet scrubber (ID No. ACD-Al). The Permittee shall ensure the proper performance of the scrubber by monitoring
the following operational parameters:
i. Liquid flow rate through the packed bed section (minimum of 30 gallons per minute averaged over a 3-hour
period), and
ii. Differential pressure across the packed bed section of the scrubber (maximum of 12 inches of water pressure
averaged over a 3-hour period), with a high differential pressure alarm.
b. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (written or electronic records), which shall be kept on site and made available to Division of Air Quality
personnel upon request. Any variance from the manufacturer's recommendations or the permit monitoring
requirements, or the failure of the air pollution control equipment to operate in a normal and usual manner, shall be
investigated with corrections made and dates of action recorded in the log book. The inspection and maintenance
activities, as well as required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate,
shall be recorded.
F. Wastewater Treatment Area consisting of an extended aeration biological wastewater
treatment facility (ID No. WTS-A) and two indirect steam -heated rotary sludge dryers
(ID Nos. WTS-B and WTS-C) controlled by a wet scrubber with mist eliminator (ID No.
WTCD-1)
ThP fnllnmino tnhlP nmuirlec n znmmnry of limits and standards fnr the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
odorous emissions must be controlled
15A NCAC 2D .1806
STATE, ENFORCEABLE ONLY
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
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Permit 03735T33
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b. SCRUBBER REQUIREMENTS - Odorous emissions from the wastewater treatment sludge dryers (ID Nos.
WTS-B and WTS-C) shall be controlled by an impingement -type scrubber with caustic injection (ID No.
WTCD-1).
c. INSPECTION AND MAINTANENCE REQUIREMENTS - To comply with the provisions of this Permit and
ensure that maximum control efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the manufacturer. As a minimum, the inspection and maintenance program shall
include inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the
cleaning/calibration of all associated instrumentation.
d. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (written or electronic records) that shall be kept on site and made available to Division of Air Quality
personnel upon request. Any variance from the manufacturer's recommendations or the permit monitoring
requirements, or the failure of the air pollution control equipment to operate in a normal and usual manner, shall be
investigated with corrections made and dates of action recorded in the log book. The inspection and maintenance
activities, as well as required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate,
shall be recorded.
G. Temporary Boiler (ID' No. PS -Temp), No. 2 fuel oil -fired (greater than 30.0 and less than
100.0 million Btu per hour maximum heat input)
mL_ r_n.....:_t,... .;A ..fh,,,;r� —Act�nr3 Ar fnrthaemiccinn Qnnrnp.kl rleccrihed Anve-
ow
Regulated Pollutant
Limits/Standards
Applicable Regulations
Particulate Matter
0.2426 pounds of particulate per million Btu
15A NCAC 2D .0503(c)
Sulfur Dioxide
0.5 percent sulfur content fuel
15A NCAC 2D .0524
NSPS 40 CFR 60 Sub art DO
Visible Emissions
20 percent opacity
15A NCAC 2D .0524
NSPS 40 CFR 60 Sub art DO
Sulfur Dioxide
Less than 40 tons per consecutive twelve-month period.
15A NCAC 2Q .0317
PSD Avoidance
Sulfur Dioxide
Affected Sources: PS-1, PS-2, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
(PSD Avoidance)
See Section 2.2. A.1. of this permit
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter discharged into the atmosphere from the combustion of fuel oil at the temporary
boiler (ID No. PS -Temp) shall not exceed 0.2426 pounds per million Btu heat input.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
this test are above the limit given in Section 2.1 G. La. above, the Permittee shall be deemed in noncompliance with
15A NCAC 2D .0503.
Monitoring/R .ocg_rdkeeping/Re or inu [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 fuel oil in this
source for this regulation.
2. 15A NCAC 2D .0524: NSPS 40 CFR PART 60 SUBPART Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and
DEQ-CFW 00068380

Permit 03735T33
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•
monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524
"New Source Performance Standards (NSPS) as promulgated in 40 CFR Part 60 Subpart Dc, including Subpart A
"General Provisions."
Emission Limitations [15A NCAC 2D .0524]
b. The maximum sulfur content of any fuel oil received and burned in the boiler (ID No. PS -Temp) shall not exceed
0.5 percent by weight.
c. Visible emissions shall not exceed 20 percent opacity (6 minute average) except for one six -minute period per hour
but not more than 27 percent opacity when firing fuel oil.
Testing [15A NCAC 2D .0524)
d. Within 60 days of installing any temporary boiler, the Permittee shall conduct a Method 9 test (6-minute average of
24 observations) to determine the opacity of stack emissions in accordance with 40 CFR 60.8, 40 CFR 60.45c(a)(8),
and General Condition JJ found in Section 3 of this permit. If the Permittee fails to conduct the opacity observation
or if the results of the test are above the applicable limit, the Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0524.
Mon itoring/Recordkeeping [15A NCAC 2Q .0508(f)]
e. The Permittee shall retain a record of the quantity of No. 2 fuel oil fired at the affected boiler each calendar month.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if this record is not created and
retained. [49 CFR 60.48c(g)l
f. The Permittee shall retain a copy of the fuel supplier certification for any No. 2 fuel oil fired at the affected boiler.
The fuel supplier certification shall include the following information:
i. The name of the oil supplier;
ii. The sulfur content of the oil (in % by weight); and,
iii. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil
in 40 CFR 60.41 c.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur content of the oil exceeds
the limit provided in Section 2.1 G.2.b. of this permit or if fuel supplier certifications are not retained as described
above. [40 CFR 60.46c(d), 40 CFR 60.48c(oj
Notifications and Re r inu [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit the following written notifications to the Regional:
i. An initial notification of the date of actual initial startup of the boiler within 15 days of such date [40 CFR
60.7(a)(1)];
ii. An opacity observation notification indicate the anticipated date that the Permittee will be conducting the
Method 9 opacity observation, as required in Section 2.1 G.2.d. of this permit, at least 30 days prior to such date
[40 CFR 60.7(a)(6), 40 CFR 60.8(d)]; and,
iii. Performance test results with the results of the Method 9 opacity observation, as required in Section 2.1 G.2.d.
of this permit, shall be submitted within 30 days of the test.
h. Semiannual Report. In addition to any other reporting required by 40 CFR 60.48c or notification requirements to
the EPA, the Permittee is required to provide a semiannual summary report, acceptable to the Regional Air Quality
Supervisor, of the sulfur content of the distillate fuel oil fired, by January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-month period
between January and June. The summary report shall include the following information:
i. Fuel supplier certification(s) for distillate fuel oil, as provided in Section 2.1 G.2.d. of this permit;
ii. A certified statement signed by the owner or operator that the records of fuel supplier certification(s) submitted
represents all of the fuel fired at the affected boiler during the semiannual period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068381

Permit 03735T33
Page 22
3. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the temporary
boiler (ID No. PS -Temp) shall discharge into the atmosphere less 40 tons of sulfur dioxide per consecutive twelve-
month period.
Testing [15A NCAC 2D .26011
b. If emissions testing is required, the testing shall be performed in accordance with 15A General Condition JJ. If the
results of this test are above the limits given in Section 2.1 G.3.a. (ID No. PS -Temp) above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkee in¢ [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in 1,000 gal) of No. 2 fuel oil fired at the boiler; and,
ii. The fuel oil supplier certification for any fuel oil fired at the boiler, including the sulfur content of the oil (in
percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the fuel usage and No. 2
fuel oil sulfur content are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling S02 emissions from the temporary boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (written or electronic format),
according to the following formulas:
i. Calculate S02 emissions from the previous calendar month using the following equation:
ES02=142*S*Qfo2
Where, Es02 = S02 emissions (in lbs) during the previous calendar month,
S = Sulfur content in the No. 2 fuel oil (in percent by weight), and
Qfo2 = Quantity of No. 2 fuel oil fired at the temporary boiler during the
previous calendar month (in 1,000 gal)
ii. Sum the S02 emissions from the boiler for the previous 12-month period to determine the 12-month rolling
emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.1 G.3.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly S02 emissions from the boiler for the previous 17 months;
ii. The total S02 emissions from the boiler for each 12-month period ending during the six month reporting period;
and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068382

Permit 03735T33 to
Page 23
9
H. SentryGlas® Plus Manufacturing (ID No. SGS-A)
The followinv table nrnvides n summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Visible emissions
20% visible opacity emissions
15A NCAC 2D .0521
Odors
State -enforceable only
Odorous emissions must be controlled
15A NCAC 2D .1806
1. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from this source (ID No. SGS-A) shall not be more than 20 percent opacity when averaged over a
six:minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any hour
and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testin [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 H. La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Re on rting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATE-F.NFORCF,ABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
I. Polyvinyl Fluoride Polymer Manufacturing Facility No. 1 (ID No. FS-B)
Polyvinyl Fluoride Polymer Manufacturing Facility No. 2 (ID No. FS-C)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Source: Product Collection Systems
15A NCAC 2D .0515
(Vents FEP-B4 & FEP-C4)
for process rates less than 30 tons per hour -
E = 4.10 P0.67
Where:
E = allowable emission rate in, pounds per hour, and
P = process weight rate in tons per hour
Visible emissions
Affected Source: Product Collection Systems
15A NCAC 213.0521
(Vents FEP-B4 & FEP-C4)
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
Volatile organic
Less than 40 tons per consecutive 12-month period
15A NCAC 2Q .0317
compounds
I
(PSD Avoidance
DEQ-CFW 00068383

Permit 03735T33 •
Page 24
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the Product Collection Systems at the polyvinyl fluoride manufacturing facilities
(Vent Nos. FEP-B4 & FEP-C4) shall not exceed an allowable emission rate as calculated by the following equation:
E=4.10xP""
Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 I.l.a. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkee in [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour, as specified by the
formulas contained above (or the formulas contained in 15A NCAC 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515 if the production records are not maintained.
Reporting [I5A NCAC 2Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the Product Collection Systems at the polyvinyl fluoride manufacturing facilities (Vent Nos.
FEP-B4 & FEP-C4) shall not be more than 20 percent opacity when averaged over a six -minute period. However,
six -minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in
any 24-hour period. In no event shall the six -minute average exceed 87 percent opacity.
Testing [15A NCAC 2D .26011
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 I.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. The Permittee shall establish "normal' for the PVF Manufacturing
Facility No. 2 (ID No. FS-C, Vent No. FEP-C4) within 30 days of initial start-up. If visible emissions from this
source are observed to be above normal, the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with I5A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 I.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
DEQ-CFW 00068384

Permit 03735T33
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0
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
STATF,-FNFORCEARTY ONT.Y
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the Polyvinyl Fluoride (PVF) Manufacturing Facility No. 1 and No.
2 (ID Nos. FS-B and FL-C) shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-
month period.
Testing [15ANCAC 2D .26011
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 IA.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordheepi� [15A NCAC 2Q .0508(f)]
To demonstrate compliance with the limit provided in Section 2.1 I.4.a., each calendar month the Permittee shall
create and retain production records and estimate associated VOC emissions, as follows:
i. Record the vent flow rates from the Analytical Equipment (QFEP_B1 and QFENCI) at the two affected facilities
(Vent Nos. FEP-131 and FEP-C1 respectively) during the previous calendar month (in lb/month);
n. Calculated the VOC emissions (EFEP-Bcl) from the Analytical Equipment at two affected facilities during the
previous calendar month (in lb/month) using the following equation:
EFEP-BC1 — T..FEP-Bl + QFEP-Cl
iii. Record the vent flow rates from the Maintenance Headers (QFEP-B2 and QFEP.C2) at the two affected facilities
(Vent Nos. FEP-132 and FEP-C2 respectively) during the previous calendar month (in lb/month);
iv. Calculate the VOC emissions (EFEP-13C2) from the Maintenance Header at two affected facilities during the
previous calendar month (in lb/month) using the following equation: l
EFEP-BC2 � 0.5\QFEP-B2 + QFEP-C2 /
v. At least once each hour, record the pressure (PFEP-133 and PFEP_C3) in the Low Pressure Slurry Separators at the two
DEQ-CFW 00068385

Permit 03735T33
Page 26
affected facilities (Vent Nos. FEP-B3 and FEP-C3 respectively) during the previous calendar month (in psig);
vi. At least once each hour, record the vinyl fluoride flow rates (QFEP_B3 and QFEP-C3) to the PVF Reactors at the two
affected facilities (Vent Nos. FEP-133 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
vii. Using an emissions model based on vapor pressure equilibrium data and vinyl fluoride flow rates to the PVF
Reactors, determine the hourly VOC emissions (EFEP_B3 and EFEF_C3) from the Flash Tank vents at the two
affected facilities (Vent Nos. FEP-B3 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
viii. Calculate the sum of the hourly VOC emissions (EFEP-BC3) from the Flash Tanks at the two affected facilities
during the previous calendar month (in lb/month) using the following equation:
EFEP-60 = E (EFEP-B3 )+ Yj (EFEP-C3 )
ix. Calculate the VOC emissions (E) from the two affected facilities during the previous calendar month (in
lb/month) using the following equation:
E = EFEP-BC1 + EFEP-BC2 + EFEP-BC3
x. Calculate the 12-month rolling VOC emissions from the two affected facilities by summing the monthly VOC
emissions (E), as calculated in x. above, for the previous consecutive 12-months.
The first required monthly compliance demonstration, as described in i. through x. above, shall be required during
the calendar month fal owi u initial start-up of PVF Manufacturing Facility No. 2 (ID No. FS-C). Required records
shall be maintained in a logbook (written or electronic format) on -site and made available to an authorized
representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in x. above
exceeds the limit in Section 2.1 I.4.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions from two affected polyvinyl fluoride manufacturing operations for the previous 17
calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. BOILERS:
No. 2/No. 6 fuel oil -fired boiler (ID No. PS-1), 139.4 million Btu per hour maximum heat input;
No. 2/No. 6 fuel oil -fired boiler (ID No. PS-2), 88.4 million Btu per hour maximum beat input;
and,
Temporary Boiler (ID No. PS -Temp), No. 2 fuel oil -fired (greater than 30.0 and less than 100.0
million Btu per hour maximum heat input).
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the affected boilers (ID Nos. PS-1, PS-2, and PS -Temp) shall
discharge into the atmosphere less than 702.5 tons of S02 per consecutive 12-month period.
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:7
T s inu [15A NCAC 2D .2601]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.2 A.l .a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Mon itoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in 1,000 gal) of No. 2 and No. 6 fuel oil fired at the affected boilers; and;
ii. The fuel oil supplier certification for any fuel oil fired at the affected boilers, including the sulfur content of the
oil (in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the fuel usage and fuel oil
sulfur contents are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling S02 emissions from the affected boilers within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (written or electronic format),
according to the following formulas:
i. Calculate S02 emissions from the previous calendar month using the following equation:
ESo2=157*Sfo6 * Qfo6 + 142* Sf,2 *Qfo2
Where, Eg02 =
S02 emissions (in lbs) during the previous calendar month;
S M =
Sulfur content in the No. 6 fuel oil (in percent by weight);
Qfo6 =
Quantity of No. 6 fuel oil fired at the temporary boiler during the previous
calendar month (in 1,000 gal);
S fo2 =
Sulfur content in the No. 2 fuel oil (in percent by weight); and,
Qfo2 =
Quantity of No. 2 fuel oil fired at the temporary boiler during the previous
calendar month (in 1,000 gal).
ii. Sum the S02 emissions from the affected boilers for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.2 A. La. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly S02 emissions from two affected boilers for the previous 17 calendar months;
ii. The 12-month rolling S02 emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
B. FACILITY -WIDE
STATF,-ENFORCRABLE, ONL
1. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic compliance
demonstration, the following permit limit shall not be exceeded:
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Toxic Air Pollutant
Facility -Wide Emission Limit
Acetaldehyde
394.62 lb/hr
Acetic Acid
54.081b/hr
Acrolein
1.17 lb/hr
Acrylonitrile
240.06 lb/hr
Ammonia
39.46 lb/hr
Ammonium Chromate
0.54 lb/day
Ammonium Dichromate
0.54 lb/day
Aniline
14.62 lb/hr
Arsenic and Inorganic Arsenic Compounds
0.37 lb/yr
Aziridine
5.261b/day
Benzene
192.05 lb/yr
Benzidine and Salts
0.02 lb/yr
Benzo(a)pyrene
52.81 lb/yr
Benzyle Chloride
7.31 lb/yr
Beryllium
6.561b/yr
Beryllium Chloride
6.56 lb/yr
Beryllium Fluoride
6.56 lb/yr
Beryllium Nitrate
6.561b/yr
Bis-Chloromethyl Ether
0.59 lb/yr
Bromine
2.92 lb/hr
1,3-Butadiene
272.07 lb/yr
Cadmium
8.81b/yr
Cadmium Acetate
8.81b/yr
Cadmium Bromide
8.8 lb/yr
Calcium Chromate
0.13 lb/yr
Carbon Disulfide
163.11 lb/day
Carbon Tetrachloride
10,723 lb/yr
Chlorine
13.15 lb/hr
32.88III
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•
Toxic Air Pollutant
Facility -Wide Emission Limit
Chlorobenzene
1,929.23 lb/day
Chloroform
6,882 lb/yr
Chloroprene
51.15 lb/hr
385.85 lb/da
Chromic Acid
0.54 lb/day
Chromium (VI)
0.13 lb/yr
Cresol
32.15 lb/hr
p-Dichlorobenzene
964.62 lb/hr
Dichlorodifluoromethane
217,476.92 lb/day
Dichlorofluoromethane
438.46 lb/day
Di(2-ethylhexyle)phthalate
26.31 lb/day
Dimethyl Sulfate
2.63 lb/day
1,4-Dioxane
491.081b/day
Epichlorohydrin
132, 8321b/yr
Ethyl Acetate
2,046.15 lb/hr
Ethylenediamine
36.54 lb/hr
263.08 lb/day
Ethylene Dibromide
640.2 lb/yr
Ethylene Dichloride
6,081 lb/yr
Ethylene Glycol Monoethyl Ether
27.771b/hr
105.23 lb/day
Ethylene Oxide
43.21 lb/yr
Ethyl Mercaptan
1.46 lb/hr
Fluorides
3.65 lb/hr
14.03 lb/day
Formaldehyde
2.191b/hr
Hexachlorocyclopentadiene
0.15 lb/hr
0.53 lb/day
Hexachlorodibenzo-p-dioxin
0.12 lb/yr
n-Hexane
964.62 lb/day
Hexane Isomers
5,261.541b/hr
Hydazine
0.53 lb/day
Hydrogen Chloride
10.23 .lb/hr
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Toxic Air Pollutant
Facility -Wide Emission Limit
Hydrogen Cyanide
16.08 lb/hr
122.77 lb/day
Hydrogen Sulfide
30.69 lb/hr
Maleic Anhydride
1.461b/hr
10.52 lb/day
Manganese & Compounds
27.18 lb/day
Manganese Cyclopentadienyl Tricarbonyl
0.53 lb/day
Manganese Tetroxide
5.44 lb/day
Mercury, Alkyl
0.05 lb/day
Mercury, Aryl & Inorganic
0.53 lb/hr
Mercury, vapor
0.53 lb/hr
Methyl Chloroform
3,580.77 lb/hr
10 523.08 lb/day
Methylene Chloride
24.85 lb/hr
38,409 lb/
Methyl Ethyl Ketone
1,293.46 lb/hr
3.244.62 lb/day
Methyl Isobutyl Ketone
438.46 lb/hr
2.244.92 lb/day
Methyl Mercaptan
0.73 lb/hr
Nickel Carbonyl
0.53 lb/day
Nickel Metal
5.26 lb/day
Nickel, Soluble Compounds as Nickel
5.261b/day
Nickel Subsulfide
3.36 lb/yr
Nitric Acid
14.621b/hr
Nitrobenzene
7.31 lb/hr
52.62 lb/day
n-Nitrosodimethlamine
80.021b/yr
Pentachlorophenol
0.37 lb/hr
2.63 lb/day
Perchloroethylene
304,073 lb/yr
Phenol
13.88 lb/hr
Phosgene
2.19 lb/day
Phosphine
1.90 lb/hr
Polycholinated Biphenyls
132.83 lb/yr
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•
Toxic Air Pollutant
Facility -Wide Emission Limit
Potassium Chromate
0.541b/day
Potassium Dichromate
0.54 lb/day
Sodium Chromate
0.541b/day
Sodium Dichromate
0.54 lb/day
Strontium Chromate
0.13 lb/yr
Styrene
154.921b/hr
Sulfuric Acid
1.46 lb/hr
10.521b/da
Tetrachlorodibenzo-p-dioxin
0.00481b/yr
1, 1, 1,2-Tetrachloro-2,2-Difluoroethane
45,6001b/day
1,1,2,2,-Tetrachloro-1,2-Difluoroethane
45,600 lb/day
1, 1, 1,2-Tetrachloroethane
10,082 lb/yr
Toluene
818.461b/hr
4 121.541b/day
Toluene-2,4-diisocyanate
0.22 lb/hr
0.44 lb/day
Trichloroethylene
94,423 1b/yr
Trichlorofluoromethane
491,076.92 lb/day
1,1,2-Trichloro-1,2,2-Trifluoroethane
13,8851b/hr
Vinyl Chloride
608.1 lb/yr
Vinylidene Chloride
105.23 lb/day
Xylene
950 lb/hr
2 367.691b/da
Zinc Chromate
0.13 lb/yr
Reeordkeeping
b. For compliance purposes, the Permittee shall maintain records of production rates, throughput, material usage,
periods of excess emissions, failure of air pollution control equipment to operate in a normal and usual manner,
and other process operational information, that allows for evaluation for compliance with the toxic air pollutant
limits. These records shall be retained for a minimum of three years from the date of recording, and access to
these records shall be provided to the Division of Air Quality staff upon request.
Re on rtinn�
c. For compliance purposes, within thirty (30) days after each calendar year quarter the following shall be reported
to the Regional Supervisor, Division of Air Quality:
i. Any and all exceedences of applicable toxic air pollutant emission limits during the previous calendar year
quarter.
ii. The maximum pounds per 1-hour emission rate at anytime during the previous calendar year quarter for all
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applicable toxic air pollutants that have a listed pounds per hour emission rate.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants that have a listed pounds per day emission rate.
iv. The yearly emission rate for the 12-month period ending with the previous calendar year quarter for all
applicable toxic air pollutants that have a listed pounds per year emission rate.
STATE -ENFORCEABLE ONLY
2. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic compliance
A.tr the followin ermit limit shall not be exceeded:
mons a t'
on i
Emission Source
Toxic Air Pollutant
Emission Limit
High dispersion stacks
Hydrogen Fluoride
7.28 lb/hr
(ID Nos. NEP-Hdr-1, NEP-
52.45 lb/day
Hdr-2, AEP-Al, and FEP-
Al
All other sources
Hydrogen Fluoride
2.7 lb/hr
19.4 lb/day
Monitoring
b. The Permttee shall ensure the proper performance of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-I and NCD-Hdr-2) by monitoring the Injection liquid flow rate (minimum of 7,000 kilograms per
hour, averaged over a three-hour period).
Recordkeening
c. The Permittee shall record the results of inspections of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-1 and NCD-Hdr-2) in a scrubber logbook (written or electronic records) that shall be kept on site
and made available to Division of Air Quality personnel upon request. Any variance from the manufacturer's
recommendations or the permit monitoring requirements, or the failure of the air pollution control equipment to
operate in a normal and usual manner, shall be investigated with corrections made and dates of action recorded
in the log book. The inspection and maintenance activities, as well as required monitoring for scrubbing liquid
flow rates, and scrubber pressure drops, if appropriate, shall be recorded.
d. The Permittee shall maintain records of production rates, throughput, material usage, periods of excess
emissions, failure of air pollution control equipment to operate in a normal and usual manner, and other process
operational information, that allows for evaluation for compliance with the toxic air pollutant limits. These
records shall be retained for a minimum of three years from the date of recording, and access to these records
shall be provided to the Division of Air Quality staff upon request.
Reporting e. For compliance purposes, within thirty (30) days after each calendar year quarter the following shall be reported
to the Regional Supervisor, Division of Air Quality:
i. Any and all exceedences of applicable toxic air pollutant emission limits during the previous calendar year
quarter.
ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year quarter for all
applicable toxic air pollutants that have a listed pounds per hour emission rate.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants which have a listed pounds per day emission rate.
STATE -ENFORCEABLE ONLY
3. 15A NCAC 2D .0541: CONTROL OF EMISSIONS FROM ABRASIVE BLASTING
a. The Permittee shall ensure that any abrasive blasting operation conducted outside a building or conducted
indoors and vented to the atmosphere is performed in accordance with the requirements set forth in 15A NCAC
2D .0521, Control of Visible Emissions. Any visible emissions reading for abrasive blasting performed outside
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a building shall be taken at a spot approximately one meter above the point of abrasive blasting with a viewing
distance of approximately five meters.
b. All abrasive blasting operations shall be conducted within a building, except as provided in i. or ii. below. The
following abrasive blasting operations need not be conducted within a building:
i. Abrasive blasting of an item that exceeds eight feet in any dimension; or,
ii. Abrasive blasting of a surface situated at its permanent location or not further away from its permanent
location than is necessary to allow the surface to be blasted.
c. Any abrasive blasting operation conducted outside a building, as provided in Section 2.2. B.3. b.i. or ii. above,
shall take appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting
operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being
conducted. Appropriate measures include the following:
i. Addition of a suppressant to the abrasive blasting material;
ii. Wet abrasive blasting;
iii. Hydroblasting;
iv. Vacuum blasting;
v. Shrouded blasting; or
vi. Shrouded hydroblasting.
4. 40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK MANAGEMENT
PROGRAMS UNDER THE CLEAN AIR ACT, SECTION 112(r)" - The Permittee shall comply with all
applicable requirements in accordance with 40 CFR Part 68 including submitting a Risk Management plan to EPA
pursuant to 40 CFR Part 68.150 prior to June 21, 1999 or as specified in 40 CFR Part 68.10.
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SECTION 3 - GENERAL CONDITIONS (v2.22.1)
This section describes terms and conditions applicable to this Title V facility.
A. C�enerai Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)]
1. Terms not otherwise defined in this pernut shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or criminal penalties. Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3. This permit is not a waiver of or approval of any other Department pennits that may be required for other aspects of the
facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal or plant
life, or property caused by the construction or operation of this permitted facility, or from penalties therefore, nor does it
allow the Permittee to cause pollution in contravention of state laws or rules, unless specifically authorized by an order
from the North Carolina Environmental Management Commission.
5. Except as identified as state -only requirements in this permit, all terms and conditions contained herein shall be
enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the appropriate and valid
permits issued by the DAQ, unless the source is exempted by rule. The DAQ may issue a permit only after it receives
reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements.
A permitted installation may only be operated, maintained, constructed, expanded, or modified in a manner that is
consistent with the terms of this permit.
Permit Availability [15A NCAC 2Q .0507(k) and .0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit term one
complete copy of the. application -and any information submitted in support of the application package. The permit and
application shall be made available to an authorized representative of Department of Environment and Natural Resources
upon request.
C. Severability Clause [15A NCAC 2Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid, the
provisions in this permit are severable so that all requirements contained in the permit, except those held to be invalid, shall
remain valid and must be complied with.
Submissions issions [15A NCAC 2Q .0507(e) and 2Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, notifications, request
for renewal, and any other information required by this pen -nit shall be submitted to the appropriate Regional Office. Refer to
the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems (CEMS) reports,
continuous opacity monitoring systems (COMS) reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM
certification reports, and NOx budget CEM certification reports, one copy shall be sent to the appropriate Regional Office
and one copy shall be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
E. Dn g o Comply [15A NCAC 2Q .0508(i)(2)]
The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit.
Noncompliance with any permit condition except conditions identified as state -only requirements constitutes a violation of
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the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement action, for permit
termination, revocation and reissuance, or modification, or for denial of a permit renewal application.
F. Circumvention - STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of
its associated air pollution control device(s) and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 2Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 2Q
.0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q .0505]
The Pernttee shall submit an application for an ownership change in accordance with 15A NCAC 2Q.0524 and 2Q
.0505.
3. Minor Permit Modifications [15A NCAC 2Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q .0515.
4. Significant Permit Modifications [15A NCAC 2Q .05161'
The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 2Q .0516.
5. Reopening for Cause [15A NCAC 2Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q .0517.
H. Changes Not Requiring Permit Modifications
1. Section 502(b)(10) Changes [15A NCAC 2Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition. Such changes do
not include changes that would violate applicable requirements or contravene federally enforceable permit terms
and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification
requirements.
b. The Permittee may make Section 502(b)(10) changes without having the permit revised if:
i. • The changes are not a modification under Title I of the Federal Clean Air Act;
ii. The changes do not cause the allowable emissions under the permit to be exceeded;
iii. The Permittee notifies the Director and EPA with written notification at least seven days before the change is
made; and
iv. The Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. A description of the change;
ii. The date on which the change will occur;
iii. Any change in emissions; and
iv. Any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10) changes shall be made in the permit -the next time that the permit is revised or renewed,
whichever comes first.
2. Off Permit Changes [15A NCAC 2Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if
a. The change affects only insignificant activities and the activities remain insignificant after the change; or
b. The change is not covered under any applicable requirement.
3. Emissions Trading [15A NCAC 2Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently adopted maximum
achievable control technology standards, emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 2Q .0523(c).
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I.A. hr r ing Requirements for Excess Emissions and Permit Deviations
[15A NCAC 2D .0535(f) and 2Q .0508(f)(2)]
"Excess Emissions" - means an emission rate that exceeds any applicable emission limitation or standard allowed by any rule
in Sections .0500, .0900, .1200, or .1400 of Subchapter 2D; or by a permit condition; or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q .0700. (Note: Definitions of excess emissions under 2D .I I10 and 2D
.1111 shall apply where defined by rule)
"Deviations" - for the purposes of this condition, any action or condition not in accordance with the terms and conditions of
this permit including those attributable to upset conditions as well as excess emissions as defined above lasting less than four
hours.
Excess Emission
1. If a source is required to report excess emissions under NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D
.1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of excess emissions, reporting
shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .1111), or these rules
do NOT define "excess emissions," the Permittee shall report excess emissions in accordance with 15A NCAC 2D .0535
as follows:
a. Pursuant to 15A NCAC 2D .0535, if excess emissions last for more than four hours resulting from a malfunction, a
breakdown of process or control equipment, or any other abnormal condition, the owner or operator shall:
i. Notify the Regional Supervisor or Director of any such occurrence by 9:00 a.rrL Eastern Time of the Division's
next business day of becoming aware of the occurrence and provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration; and
• estimated rate of emissions;
ii. Notify the Regional Supervisor or Director immediately when corrective measures have been accomplished;
and
iii. Submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC 2D
.0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 2Q .0508(f)(2), the Permittee shall report deviations from permit requirements (terms and
conditions) as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered under 15A
NCAC 2D .0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of such
deviation and any corrective actions or preventative actions taken. The responsible official shall certify all
deviations from permit requirements.
I.B. Other Reg'C' uir ments under 15A NCAC 2D 0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535, including 15A NCAC
2D .0535(c) as follows:
1. Any excess emissions that do not occur during start-up and shut -down shall be considered a violation of the appropriate
rule unless the owner or operator of the sources demonstrates to the Director, that the excess emissions are a result of a
malfunction. The Director shall consider, along with any other pertinent information, the criteria contained in 15A
NCAC 2D .0535(c)(1) through (7).
2. 15A NCAC 2D .0535(g). Excess emissions during start-up and shut -down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
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facility, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the facility to exceed a technology -based emission limitation under the permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by
improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology -based
emission limitations if the conditions specified in 3. below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or
other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s) of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the permit; and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency, steps
taken to mitigate emissions, and corrective actions taken.
4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of
proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal [15A NCAC 2Q .0508(e) and 2Q .0513(b)]
This permit is issued for a fixed term of five year$ for facilities subject to Title IV requirements and for a term not to exceed
five years in the case of all other facilities. This permit shall expire at the end of its term. Permit expiration terminates the
facility's right to operate unless a complete renewal application is submitted at least nine months before the date of permit
expiration. If the Permittee or applicant has complied with 15A NCAC 2Q .0512(b)(1), this permit shall not expire until the
renewal permit has been issued or denied. All terms and conditions of this permit shall remain in effect until the renewal
permit has been issued or denied.
L. Ned to Halt or Reduce Activity Not a Defense [15A NCAC 2Q .0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information (,submittal of information) [15A NCAC 2Q .0508(i)(9)]
1. The Permittee shall furnish to the DAQ, in a timely mariner, any reasonable information that the Director may request in
writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to
determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies are requested
by the Director. For information claimed to be confidential, the Permittee may furnish such records directly to the EPA
upon request along with a claim of confidentiality.
N. Dn y to Supp] m n [15A NCAC 2Q .0507(f)]
The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the
permit application, shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee shall
also provide additional information as necessary to address any requirement that becomes applicable to the facility after the
date a complete permit application was submitted but prior to the release of the draft permit.
O. Retention of Records [15A NCAC 2Q .0508(f) and 2Q .0508 (1)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five
years from the date of the monitoring sample, measurement, report, or application. Supporting information includes all
calibration and maintenance records and all original strip -chart recordings for continuous monitoring information, and copies
of all reports required by the permit. These records shall be maintained in a form suitable and readily available for
expeditious inspection and review. Any records required by the conditions of this permit shall be kept on site and made
DEQ-CFW 00068397

Permit 03735T33
Page 38
available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 2Q .0508(n)]
The Pernrittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61 Forsyth
Street, Atlanta, GA 30303) postmarked on or before March 1 a compliance certification (for the preceding calendar year) by
a responsible official with all federally -enforceable terms and conditions in the permit, including emissions limitations,
standards, or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the
entire year regardless of who owned the facility during the year. The compliance certification
shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal Clean Air
Act. The compliance certification shall specify:
1. The identification of each term or condition of the permit that is the basis of the certification;
2. The compliance status (with the terms and conditions of the permit for the period covered by the certification);
3. Whether compliance was continuous or intermittent; and
4. The method(s) used for determining the compliance status of the source during the certification period.
Q, Certification by Responsihle Official [15A NCAC 2Q .05201
A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after reasonable
inquiry, the statements and information in the document are true, accurate, and complete.
R. Permit Shield for Appli .abl _ R n uireements [ 15A NCAC 2Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the permit as of the date of permit
issuance.
2. A permit shield shall not alter or affect:
a. The power of the Commission, Secretary of the Department, or Governor under NCGS 143-215.3(a)(12), or EPA
under Section 303 of the Federal Clean Air Act;
b. The liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective
date of the permit or at the time of permit issuance;
c. The applicable requirements under Title IV; or
d. The ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or pen -nit revision made
under 15A NCAC 2Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515.
Termination Modificationand Revocation of the Permit [15A NCAC 2Q .0519]
The Director may terminate, modify, or revoke and reissue this permit if.
l . the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or
5. the Director finds that termination, modification, or revocation and reissuance of the permit is necessary to carry out the
purpose ofNCGS Chapter 143, Article 21B.
T. Iyg_nifi an Activities [15A NCAC 2Q .0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any
applicable requirement. The Permittee shall have available at the facility at all times and made available to an authorized
representative upon request, documentation, including calculations, if necessary, to demonstrate that an emission source or
activity is insignificant.
DEQ-CFW 00068398

Permit 03735T33 •
Page 39
U. Property Righfc [15A NCAC 2Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and F.ntrev [15A NCAC 2Q .0508(1) and NCGS 143-215.3(a)(2)]
l . Upon presentation of credentials and other documents as may be required by law, the Permittee shall allow the DAQ, or
an authorized representative, to perform the following:
a. Enter the Pennittee's premises where the permitted facility is located or emissions -related activity is conducted, or
where records are kept under the conditions of the permit;
b. Have access to and copy, at reasonable times, any records that are required to be kept under the conditions of the
permit;
c. Inspect at reasonable times and using reasonable safety practices any source, equipment (including monitoring and
air pollution control equipment), practices, or operations regulated or required under the permit; and
d. Sample or monitor substances or parameters, using reasonable safety practices, for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under Section
114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment [15A NCAC 2Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200.
2. Payment of fees maybe by check or money order made payable to the N.C. Department of Environment and Natural
Resources. Annual permit fee payments shall refer to the permit number.
3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate action to terminate
the permit under 15A NCAC 2Q .0519.
X. Ann jal FmMion Inventory_ Requirements [15A NCAC 2Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q
.0207(a) from each emission source within the facility during the previous calendar year. The report shall be in or on such
form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the
facility.
Y. Confidential information [15A NCAC 2Q .0107 and 2Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107, the Permittee
may also submit a copy of all such information and claim directly to the EPA upon request. All requests for confidentiality
must be in accordance with 15A NCAC 2Q ,0107.
Z. Construction and Operation Permits [15A NCAC 2Q .0100 and .0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or emission
source which is not exempted from having a permit prior to the beginning of construction or modification, in accordance with
all applicable provisions of 15A NCAC 2Q .0100 and .0300.
AA. Standard Annlication Form and Required Information [15A NCAC 2Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 2Q .0505
and -.0507.
BB. Financial Re..sponsibili X and Compliance History [15A NCAC 2Q .0507(d)(3)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
DEQ-CFW 00068399

Permit03735T33 •
Page 40
CC. Refr igerant Reiluirements (Stratospheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which use Class I or II
ozone -depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR
Part 82 Subpart A Appendices A and B; the Permittee shall service, repair, and maintain such equipment according to
the work practices, personnel certification requirements, and certified recycling and recovery equipment specified in 40
CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or II substance into the. environment during the
repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports shall be
submitted to the EPA or its designee as required.
leases - Section 11
DD. If the Permittee is required torevention of Accidental developand register a Risk M Management PlanBwi)th EPA pursuant to Section 112(r) of the
q pg
Clean Air Act, then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
EE. Prevention of Accidental Releases General Duty Clause Section i i 2(r)(i 1 -
FEDERALLY -ENFORCEABLE ONLY
Although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of
a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental
release of such substance and to minimize the consequences of any release.
FF. Title iV Allowances [15A NCAC 2Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee, but the Permittee may not use allowances
as a defense to noncompliance with any other applicable requirement. The Permittee's emissions may not exceed any
allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG. Air Pollution Rmergesy Episode [15A NCAC 2D .03001
Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be required to operate in
accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of an approved plan, with
the appropriate requirements specified in 15A NCAC 2D .0300.
HH. Registration of Air Pollution Sources [15A NCAC 2D .0200]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is required to
register a source of air pollution, this registration and required information will be in accordance with 15A NCAC 2D
.0202(b).
II. Ambient, Air Qu.916ty Standards [15A NCAC 2D .0501(e)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any source of
air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality
standards in 15A NCAC 2D .0400 to be exceeded at any point beyond the premises on which the source is located. When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of the
ambient air quality standards or are required to create an offset, the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 2Q .0508(i)(16)]
If emissions testing is required by this permit or the DAQ or if the Permittee submits emissions testing to the DAQ in support
of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A
NCAC 2D .2600 and follow the procedures outlined below:
1. The Permittee shall submit a completed Protocol Submittal Form to the DAQ Regional Supervisor at least 45 days prior
to the scheduled test date. A copy of the Protocol Submittal Form may be obtained from the Regional Supervisor.
2. The Permittee shall notify the Regional Supervisor of the specific test dates at least 15 days prior to testing in order to
afford the DAQ the opportunity to have an observer on -site during the sampling program
3. During all sampling periods, the Permittee shall operate the emission source(s) under maximum normal operating
DEQ-CFW 00068400

Permit 03735T33
Page 41
•
conditions or alternative operating conditions as deemed appropriate by the Regional Supervisor or his delegate.
4. The Permittee shall submit two copies of the test report to the DAQ. The test report shall contain at a minimum the
following information:
a. A description of the training and air testing experience of the person directing the test;
b. A certification of the test results by sampling team leader and facility representative;
c. A summary of emissions results and text detailing the objectives of the testing program, the applicable state and
federal regulations, and conclusions about the testing and compliance status of the emission source(s);
d. A detailed description of the tested emission source(s) and sampling location(s) process flow diagrams, engineering
drawings, and sampling location schematics should be included as necessary;
e. All field, analytical, and calibration data necessary to verify that the testing was performed as specified in the
applicable test methods;
f. Example calculations for at least one test run using equations in the applicable test methods and all test results
including intermediate parameter calculations; and
g. Documentation of facility operating conditions during all testing periods and an explanation relating these operating
conditions to maximum normal operation. If necessary, provide historical process data to verify maximum normal
operation.
5. The testing requirement(s) shall be considered satisfied only upon written approval of the test results by the DAQ.
6. The DAQ will review emission test results with respect exclusively to the specified testing objectives as proposed by the
Permittee and approved by the DAQ.
KK. Reopening for Cause [15A NCAC 2Q .0517]
1. A pemut shall be reopened and revised under the following circumstances:
a. Additional applicable requirements become applicable to a facility with remaining permit term of three or more
years;
b. Additional requirements (including excess emission requirements) become applicable to a source covered by Title
IV;
c. The Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards or other terms or conditions of the permit; or
d. The Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is
promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit term
unless the term of the permit was extended pursuant to 15A NCAC 2Q .0513(c).
3. Except for the state -enforceable only portion of the permit, the procedures set out in 15A NCAC 2Q .0507, .0521, or
.0522 shall be followed to reissue the permit. If the State -enforceable only portion of the permit is reopened, the
procedures in 15A NCAC 2Q .0300 shall be followed.. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened, except in
cases of imminent threat to public health or safety the notification period may be less than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the EPA that a
permit needs to be terminated, modified, or revoked and reissued, the Director shall send to the EPA a proposed
determination of termination, modification, or revocation and reissuance, as appropriate.
LL. Reporting Renuirements for Non -Operating F,quipment [15A NCAC 2Q .0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from and
placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the
permit shall be implemented within the monitoring period.
MM. Fugitive Dtist Control Requirement [15A NCAC 2D .0540] - STATE ENFORCEABLE ONLY
As required by 15A NCAC 2D .0540 'Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or
allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property
boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property
DEQ-CFW 00068401

Permit 03735T33 0
Page 42
boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may
be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter from process operations that does not pass through a process stack or vent
and that is generated within plant property boundaries from activities such as: unloading and loading areas, process areas
stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads).
NN.1. For modifications made pursuant to 15A NCAC 2Q .0501(c)(2), the Permittee shall file a Title V Air Quality Permit
Application for the air emission source(s) and associated air pollution control device(s) on or before 12 months after
commencing operation.
2. For modifications made pursuant to 15A NCAC 2Q .0501(d)(2), the Permittee shall not begin operation of the air
emission source(s) and associated air pollution control device(s) until a Title V Air Quality Permit Application is filed
and a construction and operation permit following the procedures of Section .0500 (except for Rule .0504 of this
Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 2Q .0523(a)(1)(C), the Permittee shall
notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth St., Atlanta, GA 30303) in writing at least seven
days before the change is made. The written notification shall include:
a. A description of the change at the facility;
b. The date on which the change will occur;
c. Any change in emissions; and
d. Any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit renewal, the
Permittee shall submit a page "ES" of the application forms signed by the responsible official verifying that the
application for the 502(b)(10) change/modification, is true, accurate, and complete. Further note that modifications
made pursuant to 502(b)(10) do not relieve the Permittee from satisfying pre -construction requirements.
DEQ-CFW 00068402

+Permit 03735T33 •
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ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
CAA Clean Air Act
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
SIC Standard Industrial Classification
SIP State Implementation Plan
SOz Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound
DEQ-CFW 00068403

0
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: August 4, 2008
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
Karen Wrigley
Plant Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
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 - Inspectio
Permit Applicability (this application only)
SIP: 2D .0515, 2D .0521
NSPS: N/A
NESHAP: N/A
PSD: N/A
PSD Avoidance: VOC, SO2
NC Toxics: N/A
112(r): N/A
Other: 2D .1806 (odors), 2D .0541 (abrasive
blasting)
Application Data
Application Number: 0900009.08A
Date Received: 04/08/2008
Application Type: Modification
Application Schedule: TV-Sign-501(c)(2)
Existing Permit Data
Existing Permit Number: 03735/T32
Existing Permit Issue Date: 01/24/2008
Existing Permit Expiration Date: 01/31/2009
Review Engineer: Fern Paterson Comments / Recommendations:
Issue: 03735/T33
Rev ineer%s- nature: Date: Permit Issue Date: 08/04/08
Permit Expiration Date: 01/31/2009
L4 lzooVn>
I. Purpose of Application
The North Carolina Division of Air Quality (DAQ) received Application No. 0900009.08A from E.I. du Pont de
Nemours & Co., LLC (DuPont) on April 8, 2008. The application is for the following permit modifications:
(1) Construct and operate Polyvinyl Fluoride (PVF) Manufacturing No. 2 (ID No. FS-C).
(2) Add an abrasive blasting building (ID No. I-10) to the insignificant activity list in Attachment II of the permit.
DuPont is adding a building to enclose shot blast operations to clean product cylinders that are less than 8 feet
in length.
Pursuant to 15A NCAC 2Q .0317, DuPont will accept a PSD avoidance condition to limit VOC emissions from the
new PVF manufacturing operation (ID No. FS-C) and the existing PVF manufacturing operation (ID No. FS-B),
which commenced operation in September 2007. In addition, operation of the two PVF manufacturing operations
will result in an increased steam demand at the existing boilers of approximately 16,000 pounds of steam per hour,
which equates to about 19.7 million Btu per hour. DuPont will accept a PSD avoidance condition to limit SO2
emissions from the boilers to no greater than 702.5 tons per consecutive 12-month period. t
t Johnson, Michael E. (DuPont Co., Fayetteville, NC). Letter to: Fern A. Paterson (NC DENR— DAQ, Raleigh, NC). 2008 Jul 24.
DEQ-CFW 00068404

0
Because avoidance conditions are required to avoid PSD permitting, the modification requires a significant
modification of the air quality permit pursuant to 15A NCAC 2Q .0516(b)(3). DuPont has requested a 2-Part
permitting procedure pursuant to 15A NCAC 2Q .0501(c)(2). DuPont submitted both the "Part I" and "Part 11"
application for the proposed PVF manufacturing operations simultaneously. The "Part 2" application, assigned
Application No. 0900009.08B, was received by NC DAQ on April 8, 2008. DuPont has also submitted an
application for a Title V permit renewal, which was received on April 17, 2008.
H. Permit Modifications/Changes
The following table describes the modifications to the current
De
Pa e s Section scription of Chant(
N/A
Insignificant
Activity List
Global
Global
1
Permit Cover Page
5
Sec. 1, Table
6
Sec. 2.1. A. Table
7
Sec. 2.1. A.3.d.ii.
11
Sec. 2.1. B.2.c.ii.
20
Sec. 2.1. G., Table
23-26
Sec. 2.1.I.
26-27
Section 2.2. A.
32-33
Sec. 2.2. B.3.
34-42
General Conditions
Add "Abrasive blasting building" (ID No. I-10) to the insignificant activity
list.
[Testing Requirement Citations] Change all references to 15A NCAC 2D
.050l(c) to 15A NCAC 2D .2601 to be consistent with a recent rule change
Amend permit revision numbers and issuance/effective dates.
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add table footnotes with procedural/Permit Shield information related to
the modification. -
Add reference to PSD Avoidance Condition for S02i which is located in
Section 2.2. A.1. of the draft permit.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ protocol.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ protocol.
Add reference to PSD Avoidance Condition for S02, which is located in
Section 2.2. A. 1. of the draft permit.
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add clarification language to existing visible emission monitoring
language to be consistent with current DAQ protocol (Section 2.1. I.2.c.ii)
- Add PSD avoidance condition for VOC (Section 2.1. I.)
Add PSD avoidance condition limiting S02 emissions from the existing
boilers to no greater than 702.5 tpy.
Add 15A NCAC 2D .0541 — "Control of Emissions from Abrasive
Blastine". This rule is state -enforceable only.
Update General Conditions with the most current version (v2.20), including
changes to General Condition JJ (Testing), new General Condition MM
(Fugitive Dust), and new General Condition NN (Modification Procedures).
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On April 16, 2008, Ms. Christy Richardson and Mr.
Tien Nguyen (FRO) conducted a site inspection of the facility. At this time, the facility appeared to be operating in
compliance with all applicable requirements as provided in the air quality permit.
In November 2007, the facility was issued a Notice of Violation (NOV) for failure to submit a Part II significant
modification application in a timely manner. Note that the required application was submitted and received by NC
DAQ on October 11, 2007, and a revised permit was issued on January 24, 2008.
DEQ-CFW 00068405

IV. Regulatory Review
A. Polyvinyl Fluoride Manufacturing Facility No. 1 (ID No. FS-B)
Polyvinyl Fluoride Manufacturing Facility No. 2 (ID No. FS-C)
1. Description of Process/Modification
DuPont has an existing polyvinyl fluoride polymer (PVF) manufacturing operation (ID No. FS-B) that
was originally permitted on June 23, 2006 and commenced operation in September 2007. With this
application, DuPont is seeking authorization to construct and operate a second PVF manufacturing
process (ID No. FS-C).
The Fayetteville Works facility manufactures PVF in a solid powder form. PVF films are used in the
production of photovoltaic modules. In this process, PVF is formed from vinyl fluoride (VF) in a
continuous reactor. VF is a gas at atmospheric conditions, and is stored in a pressurized tank with a
polymerization inhibitor. VF is fed to the continuous reactor, first passing through a feed vessel in
which the inhibitor is removed and a small quantity of a modifier is added to improve product quality.
In the continuous reactor, a polymerization initiator is added to the VF and a crude PVF product is
formed. From the continuous reactor, the crude PVF passes through a series of separation equipment,
including separators, a filter press, and a steam -heated dryer.
Operation of the two PVF manufacturing operations will result in an increased steam demand at the
existing boilers of approximately 16,000 pounds of steam per hour, which equates to about 19.7
million Btu per hour.
PVF product is collected in a PVF Collection System, or baghouse.
A block flow diagram of the PVF manufacturing process is provided below.
Figure A 1-1 • Block Flow Diagram of Proposed PVF Manufacturing Process
VF with
Pressurized VF
Storage Tank IFEP-Cl
Modifier
VF Feed
Inhibitor System
Initiator Continuous Separator
Reactor System
FEP-C2
Maintenance Header
Fugitives Air Collected Around
Process Eauinment
FEP-C3
Flash Tank
FEP-C4
PVF Isolation PVF Collection
Tank System (baghouse)
PVF Product
DEQ-CFW 00068406

0
As shown above, there are four point sources of emissions from the proposed PVF process:
FEP-CI: VOC emissions from the VF feed system (non -HAP, non -TAP)
FEP-C2: VOC emissions from the maintenance header that draws air from around the process
equipment (non -HAP, non -TAP)
FEP-C3: VOC emissions from the Flash Tank, following the separator system (non -HAP, non -TAP)
FEP-C4: PM/PM-10/PM-2.5 emissions from the product collection system (non -HAP, non -TAP)
2. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
This regulation limits allowable particulate matter emissions from any stack, vent, or outlet of any
industrial process for which no other emissions control standards apply based on the process weight
rate. The PVF product collection system (Vent No. FEP-C4) is a potential source of PM emission
with a maximum product throughput of less than 30 tons per hour.
For process weights less than or equal to 60,000 pounds per hour (30 tons per hour), allowable PM
emissions are limited as follows:
E = 4.10*P^(0.67)
where: E = allowable PM emission rate in pounds per hour, and
P = process weight in tons per hour
Potential particulate matter emissions associated with the PVF manufacturing process are less than
15% of the allowable emission rate on a lb/hr-bases, and less than 2 tons per year on an annual basis.Z
To demonstrate compliance with this standard, DuPont shall retain records on -site that are sufficient to
determine the process rate "P" in tons per hour.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
This regulation limits allowable visible emissions from any industrial process where a visible emission
can reasonably be expected to occur to no more than 20 percent opacity when averaged over a 6-
minute period, except that 6-minute periods averaging more than 87 percent opacity may occur not
more than once in any hour not more than four times in any 24-hour period. The PVF product
collection system (Vent No. FEP-C4) is a potential source of particulate matter with associated
opacity.
Monitoring. The permit will require monthly visible emissions observations of the affected exhaust
point, to check for visible emissions above "normal". The Permittee shall be required to establish what
constitutes "normal" emissions within 30 days of initial startup.
4. 15A NCAC 2D 1806• Control and Prohibition of Odorous Emissions (State -Enforceable On
This standard forbids the Permittee from operating the PVF manufacturing operations without
implementing management practices or installing and operating odor control equipment sufficient to
prevent odorous emissions from the facility from causing or contributing to objectionable odors
beyond the facility's boundary. No new requirements have been added to the draft permit to
demonstrate compliance with 15A NCAC 2D .1806.
5. 15A NCAC 20.0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION
DuPont is located in Bladen County, which is a designated attainment/unclassified area for all
pollutants regulated by the New Source Review (NSR) permitting program. Therefore, emissions
increases associated with proposed construction activities must be evaluated to determine whether the
Prevention of Significant Deterioration (PSD) program applies as provided in 15A NCAC 2D .0530.
2 DuPont has requested that emissions calculations, including emission factors, chemical names, and potential production rates, be protected as
Business Confidential information.
DEQ-CFW 00068407

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•
DuPont, which is a chemical processing plant with a 100-tpy major source threshold, is an existing
major source under the PSD program.
To determine whether the proposed project is a major modification pursuant to the PSD permitting
program, potential emissions associated with PVF Manufacturing Facility No. 2 (ID No. FS-C) are
combined with PVF Manufacturing Facility No. 1 (ID No. FS-B), which commenced operation in
September 2007. As shown in the following table, VOC and SO2 emissions increases associated with
the two projects could potentially exceed 40 tpy:
Tahle A.5-1. Summary of Potential Emissions Increases*
Potential Emissions Increases Emissions t
PM"*
SO2
NOx
CO
VOC
PVF Manufacturing Facility No. 1
1.7
N/A
N/A
N/A
>20
(ID No. FS-B)
PVF Manufacturing Facility No. 2
1.7
N/A
N/A
N/A
>20
(ID No. FS-C)***
"Debottleneck" of Boilers
****
11.2
189.7
31.6
2.9
0.2
(ID Nos. PS-1 & PS-2)
TOTALS
14.6
189.7
31.6
2.9
>40.2
>PSD Significant Emission Rate?
I No
Yes
No
No
Yes
DuPont has requested that potential production rates be protected as Business Confidential information. To maintain
confidentiality of the potential production rates at the facility, exact potential emissions estimates are not provided in this table.
PM estimates include both PM-2.5 and PM-10.
Potential emissions estimates are from Application No. 0900009.06B, which requests authorization to construct and operate PVF
Manufacturing Facility No. 1 (ID No. FS-B) (Permit No. 03735T29).
."" Both PVF manufacturing lines use steam from the existing boilers. Total steam demand for the two PVF manufacturing lines is
approximately 19.7 mmBtu/hr heat. Debottlenecking emissions are estimated based on No. 6 fuel oil firing, 2.1% sulfur by
weight, and 8,760 hr/year.
PSD Avoidance for VOC Emissions
To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an enforceable 40
tpy VOC emission limitation on the two PVF manufacturing facilities pursuant to 15A NCAC 2Q
.0317. At each PVF manufacturing line, VOC emissions may occur at three individual point sources,
as follows:
- Analytical Equipment Vents (FEP-Bl and FEP-CI). VOC emissions from these points will be
monitored by a mass flow meter (in lbs). The measured flow rate is assumed to be 100% vinyl
fluoride.
- Maintenance Header Vents (FEP-B2 and FEP-C2). Emissions from these vents occur during
process/equipment maintenance activities, when the process is purged with nitrogen gas. The
purge stream, including both nitrogen and vinyl fluoride, is vented to the maintenance vent heaters
and then to the stack. VOC emissions from these points will be monitored by a mass now meter
at the stack. The measured flow rate is assumed to be 50% vinyl fluoride.
- Flash Tank Vents (FEP-B3 and FEP-C3). Unreacted vinyl fluoride that is NOT recovered in
the separator system is vented to the atmosphere from the flash tank vents. VOC emissions from
these vents will be monitored using DuPont's proprietary TMODS chemical process model,
including chemical equilibrium data, with vinyl fluoride flow rates to the reactors and pressures a
the separator system. Each hour, the Permittee shall monitor and record vinyl fluoride flow rate
and separator system pressure at each PVF manufacturing line. Once per calendar month, the
Permittee shall use the hourly process data in the TMOD model to determine monthly VOC
emission rate.
PSD Avoidance for SO, Emissions
To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an enforceable 702.5
tpy SO2 emission limitation on the three existing boilers. The requested PSD avoidance limit is
derived by adding 40 tpy, the significant emission rate for SO2, to the baseline actual emissions of SO2
determined from Calendar Years 2000-2001. DuPont used a 10-year look -back period to determine
baseline actual emissions due to numerous instances of extended periods of non -operation and
DEQ-CFW 00068408

•
•
unscheduled maintenance periods at the main boiler (ID No. PS-1) during the previous five years.
Derivation of the PSD avoidance limit is provided below:
SOZ emissions from existing boilers — CY2000: 688.0 tpy
SO, emissions from existing boilers — CY 2001: 637.1 tpv
Baseline Actual Emissions: 662.5 tpy
+ Significant Emission Rate: + 40.0 tpv
Allowable SOZ Emission Rate: 702.5 tpy
To demonstrate compliance with the SOz emission limitation, each calendar month DuPont shall
monitor and record the monthly fuel combustion at the affected boilers, including sulfur content of fuel
oils, and calculate the associated SOZ emissions (in lb/month and tons/12-month period).
A Note on Fluorides
40 CFR 51.166(b)(49) defines a "regulated NSR pollutant" as,
(i) Any pollutant for which a national ambient air quality standard has been
promulgated and any pollutant identified under this paragraph (b)(49)(i) as a
constituent or precursor to such pollutant ...
(ii) Any pollutant that is subject to any standard promulgated under section 111 of the
Act;
(iii) Any Class I or II substance subject to a standard promulgated under or established
by title VI of the Act;
(iv) Any pollutant that otherwise is subject to regulation under the Act; except that any
or all hazardous air pollutants either listed in section 112 of the Act or added to the
list pursuant to section 112(b)(2) of the Act, which have not been delisted pursuant
to section 112(b)(3) of the Act, are not regulated NSR pollutants unless the listed
hazardous air pollutant is also regulated as a constituent or precursor of a general
pollutant listed under section 108 of the Act.
Inorganic fluorides, as detected using U.S. EPA Methods 13A and/or 13B, are subject to promulgated
standards under Section 111 of the Act (i.e. NSPS Standards), and are therefore regulated NSR
pollutants pursuant to (ii) above. Hydrogen fluoride (HF) is a regulated hazardous air pollutant (HAP),
and therefore exempt from the definition of regulated NSR pollutants pursuant to (iv) above.
Organic HAP, including polyvinyl fluorides, do not have an associated NAAQS (except as VOC), are
not regulated by a NSPS, and are not subject to a standard promulgated under or established by Title
VI of the Act. Therefore, organic fluorides that are not detected using U.S. EPA Methods 13A and/or
13B and not regulated NSR pollutants (except as VOC).
B. Abrasive Blasting Building (ID No. I-10) — State -Enforceable Only
DuPont is completing construction of an enclosed building to house periodic abrasive blasting operations
and comply with the requirements of 15A NCAC 2D .0541(c). PM emissions from the abrasive blasting
operations will be less than 2 tons per year based on historical use of blasting abrasive at the facility and
calculation methodology provided in Section 13.2.6 of U.S. EPA's AP-42.
This abrasive blasting operation is an insignificant activity because of size or production rate pursuant to
15A NCAC 2Q .0503(8) (ID No. I-10)
NOTE: Because DuPont has multiple small abrasive blasting operations located on -site, the Fayetteville
Regional Office (FRO) has requested that 15A NCAC 2D .0541, "Control of Emissions from Abrasive
Blasting" be included in the permit. In response to the FRO request, 15A NCAC 2D .0541 has been
included as a "facility -wide" requirement in Section 2.2.C, of the draft permit.
DEQ-CFW 00068409

•
V. Permit History:
The following list provides a very brief summary of permit revisions for this facility:
Permit No. Issuance Date
Description of Revision
03735T23 July 2003
Initial Title V Permit
03735T24 January 2004
Administrative amendment to the permit related to the permit effective
date.
03735T25 February 2004
Modification to add a temporary No. 2 fuel oil -fired boiler (ID No. PS -
Temp).
03735T26 May 2004
Administrative amendment to the permit related to modify permit
organization, thereby improving permit clarity.
03735T27 December 2004
Modification to add a SentryGlasO Plus manufacturing process (ID No.
SGS-A), change the description of the existing wastewater treatment plant,
and revise various monitoring requirements for existing scrubbers.
03735T28 January 2006
Administrative amendment to the change the required annual compliance
certification due date from January 30 to March 1.
03735T29 June 2006
Modification to add a polyvinyl fluoride polymer manufacturing facility
(ID No. FS-B),and an insignificant polyvinyl fluoride vacuuming system
for housekeeping purposes (ID No. I-1).
03735T30 September 2006
Replace an existing internal scrubber at the hexfluoropropylene epoxide
(HFPO) process (ID No. NS-A) in the Nafion® Process Area
(debottlenecking).
03735T31 October 2007
Modification to authorize (1) the installation of a wet scrubber (ID No.
ACD-A3) on the building exhaust vent at the ammonium perfluoro-
octanoate (APFO) manufacturing facility (ID No. AS -A) and (2) add a
tetrafluoroethylene (TFE) / carbon dioxide (CO2) separation process (ID
No. NS-M).
03735T32 January 2008
"Part 2" Significant modification for the temporary rental boiler (ID No.
PS-Temp),and the hexafluoropropylene oxide (HFPO) manufacturing
facility (ID No. NS-A). Also authorize changes at the existing Butacite0
Extruder Lines (ID Nos. BS-El and BS-E2).
VI. Draft/Proposed Permit Review Summary
• Ms. Christie Richardson (FRO) provided initial comments on the permit application, which were received in
the Raleigh Central Office (RCO) on April 23, 2008. Ms. Richardson requested that 15A NCAC 2D .0521
language in the permit be updated to be consistent with current DAQ protocol, that General Condition MM
("Fugitive Dust") be added to the permit to be consistent with current DAQ protocol, and that 15A NCAC 2D
.0541 ("Control of Emissions from Abrasive Blasting") be added to the permit due to the number of
insignificant shot blast operations existing at the facility. Ms. Richardson was provided a copy of the draft
permit for review on Friday, July 25, 2008. On July 28, 2008, Ms. Richardson commented on several
typographical type errors, and requested that a discussion of applicability of the PSD regulations to organic
fluorides be added to the Permit Review.
• Mr. Michael Johnson (DuPont) was provided a draft permit for review on Friday, July 25, 2008, On Friday,
August 1, 2008, Mr. Johnson provided comments on the monitoring language for the VOC PSD avoidance
condition for the PVF manufacturing facilities, including information about monitoring methodology at each
affected vent. The draft permit was modified to be consistent with recommended language provided by Mr.
Johnson.
• Public notice is NOT required for this application.
• U.S. EPA review is NOT required for this application,
DEQ-CFW 00068410

VII.Other Regulatory Considerations
• The application fee of $867.00 was received on April 8, 2008.
• The Reduction and Recycling Form was received on April 8, 2008.
• A Professional Engineers Seal is NOT required for this application.
• A zoning consistency determination was received by the DAQ on April 8, 2008.
VIH. Recommendations
The permit modification application for E.I. du Pont de Nemours & Co., LLC, located in Duart Township, Bladen
County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and
requirements. NC DAQ has determined that this facility appears to be complying with all applicable requirements.
Issue Permit No. 03735T33
DEQ-CFW 00068411

Comprehensive Application Report for 0900009.08A 08/04/2008
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
General Information:
Permit/Latest Revision: 03735/ T33
Application Dates
Permit code:
TV-Sign-501(c)(2)
Received
Completeness Due Clock Start Calculated Issue Due
Application type:
Modification
04/08/200805
/23/2008 04/08/2008 09/03/2008
Engineer/Rev. location:
Fern Paterson/RCO
Fee Information
Regional Contact:
Christy Richardson
Initial amount:
Date receivedmount Due Add. Amt Rcv'd: Date Rcv'd:
Facility location:
Fayetteville Regional Office
$867.00
04/08/2008
Facility classification:
Title V
Fund type:
Deposit Slip #: Location rec'd: Location deposited:
Clock is ON
Application is COMPLETE
2333
Status is :
Issued
Contact Information
Type
Name
Address
Cijy State ZIP
Telephone
Technical/Permit
Michael E Johnson, Environmental Manager
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
[phone]
Authorized
Karen B Wrigley, Plant Manager
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
[phone]
Acceptance Criteria
Received?
Acceptance Criteria Description
Yes
Application fee
Yes
Appropriate number of apps submitted
Yes
Zoning Addressed
Yes
Source recycling/reduction form
Yes
Authorized signature
N/A
PE Seal
0
m
p
C�
n
I
0
0
0
rn
ao
Completeness Criteria
Received? Complete Item Description
•
L

Application Events
Event
TV - Acknowledgment/Complete
Technical additional information request
Draft permit to region
Draft permit to applicant
Draft permit to 1 st line supervisor
Permit issued
Comprehensive Application Report for 0900009.08A
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Start Due Complete
04/08/2008 04/18/2008 04/10/2008
05/07/2008 06/25/2008 06/25/2008
07/25/2008 08/01/2008
07/25/2008 08/01/2008 08/01/2008
07/25/2008 07/25/2008
08/04/2008 08/04/2008
08/04/2008
Comments Staff
kathy_hash
S02 PSD Avoidance Condition (enfhO tMsolvhnson)
fapaterson
fapaterson
fapaterson
kmhash
•
•
2