DEQ-CFW_00068435

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NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue, Governor Division of Air Quality Dee Freeman, Secretary
Sheila C. Holman, Director
25 October 2010
Karen Wrigley, Plant Manager
Dupont Company -- Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
SUBJECT: Excess Emissions Event on 2 August 2010
Dupont Company — Fayetteville Works
Air Permit No. 03735R35
Facility ID No. 0900009
North Carolina, Bladen County
Dear Ms. Wrigley:
This office received your 19 October 2010 Title V Air Quality Permit Deviation and Excess
Emissions report regarding the events of 2 August 2010 at your facility in Bladen County, North
Carolina. The notification of this excess emissions incident is required by 15A NCAC 2D .0535, "Excess
Emissions Reporting and Malfunctions". Based on the information you submitted, this office has
determined that the excess emissions event reported meets the requirements of 15A NCAC 213.0535(c),
and will be considered by this Division a malfunction as defined in 15A NCAC 2D .0535(a)(2).
This office appreciates your attention to this environmental concern. If you have any questions
regarding this matter, please contact Greg Reeves, Environmental Engineer, or me at [phone].
Sincerely,
Steven F. Vozzo
Regional Air Quality Supervisor
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cc: • Sheila Holman, Director
DAQ Central Files
FRO County Files
Fayetteville Regional Office — Division of Air Quality
225 Green Street, Suite 714, Fayetteville, Noah Carolina 28301-5043
Main Phone: [phone] \ 0AQ Fax: [phone] \ Internet: http://www.ncalr.org
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DEQ-CFW 00068435

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NC DAQ Excess Emissions Form
Based on the information that the facility submits, the Division will determine if a
malfunction has occurred. This reporting requirement does not allow the operation of the
facility in excess of Environmental Management Commission Regulations. Continuing to
operate the facility in this manner is at the facility's own risk.
As required by 15A NCAC 2D .0535, "Excess Emissions Reporting and Malfunctions" (f), "The owner or operator of a
source of excess emissions which last for more than four hours and which results from a malfunction, a breakdown of
process or control equipment or any other abnormal conditions, shall: (1) notify the director or his designee of any such
occurrence by 9am of the next business day of becoming aware of the occurrence."
Title V facilities are required to report deviations within one business day and submit a written report within two business
days after the deviation pursuant to 15A NCAC 2Q .0508(f)(2).
Complete this Information :
(A) Name and location of the facility: "ANC "- �F G!/al 0 9aDoo9
(13) Equipment involved and the nature and cause of the excess emissions / malfunction / deviation:
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(C) The time/date the event was first observed: 020 Z/Zo! v
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(D) The expected duration: y`f iq CS
(E) An estimated rate of emissions (if known): 1�5_11, 33
(F) A written report* is required to be submitted to the Regional Supervisor. In accordance with 15A NCAC 2D
.0535(f)(3) the report is to include the following information:
(1) name and location of the facility,
(2) identification or description of the processes and control devices involved in the malfunction or breakdown,
(3) the cause and nature of the event,
(4) time and duration of the violation or the expected duration of the excess emission if the malfunction or breakdown
has not been fixed,
(5) estimated quantity of pollutant emitted,
(6) steps taken to control the emissions and to prevent recurrences and if the malfunction or breakdown has not been
fixed, steps planned to be taken, and
(7) any other pertinent infonnation requested by the director.
*If the company is Title V with a federal permit, the written report is required to be submitted within 2 business days.
All reports of deviations from permit requirements must be certified by the responsible official.
*For non -Title V facilities, the written report is required to be submitted within 15 days.
Version 1.1-10119104
DEQ-CFW 00068436

For DAQ use:
Name of Notifier: /y//K� �o f,�N� &7d
Telephone Number:
Received by: ap,152G p 6,s:t/cs
Date/Time Received:
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Comments:
Follow-up Written Notification Received: IOlZOl Zol0
and reviewed by:
Comments:
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Final review by Supervisor: Date : to 2S'
Decision: Malfunction approved for these circumsta ces: x Yes No
Comments : Ls el a rn0 L'1 C ) LZZU-) `g�r,n."p
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cc: Regional Facility File
Central Files, RCO
DEQ-CFW 00068437

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DuPont Fluoroproducts
22828 NC Highway 87 West
Fayetteville, NC 28306-7332
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October 19, 2010
Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
SUBJECT: Title V Air Quality Permit Deviation and Excess Emissions
DuPont Company — Fayetteville Works
Air Quality Permit No. 03735T35
Facility ID: 0900009, Fayetteville, Bladen County
Dear Mr. Vozzo:
Pursuant to Part I Section 3(I.A)(2)(a) and Section 3(I.A.)(3)(a) of the subject Title V
permit, this letter is the required notification of excess emissions and a state -enforceable -
only permit deviation of a limitation of methylene chloride emissions specified in Part I
Section 2.2(B)(1) of the subject permit, which is the rule regulating North Carolina toxic
air pollutant emissions per 15A NCAC 2D .1100. That limitation sets a facility -wide
emission limit of 24.851b. methylene chloride per hour.
In the site's Nafion® Process Area, methylene chloride is used as the heat -transfer liquid
("brine") throughout that area. On August 2, 2010, a copper tube in the brine system
developed a hole due to a crimp in that tube. This resulted in a loss of 1424 lb. of
methylene chloride during a 24-hour period. The drop of the brine storage tank's level was
the initial indication of a leak, and subsequent field investigation located the leak as being
from the failed tube. The leaking tube was immediately replaced, whic eel
additional losses of methylene chloride.", s r r
E.I. du Pont de Nemours and Company
EN
FAYMEYM REGIONAL OFFICE
DEQ-CFW 00068438

Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
October 19, 2010
Page 2 of 2
Following the August 2, 2010 incident, it was originally believed that the loss of
methylene chloride was less than the 1000 lb. CERCLA reportable quantity. During a
subsequent internal incident investigation, it was determined that the methylene chloride
release was in fact 1424 lb. As such, the required reporting of this release has been made
to the National Response Center, the N.C. Division of Emergency Management, and the
Local Emergency Planning Committees of both Cumberland and Bladen Counties.
The loss of 1424 lb. of methylene chloride during the 24-hour period equates to an
emission rate of 59.33 lb/hr, which is an exceedance of the 24.85 lb/hr methylene chloride
limit.
The cause of this deviation was due to an equipment malfunction of the Nafion® Process
Area's methylene chloride heat -transfer liquid ("brine") system.
If you have any questions regarding this excess emission and permit deviation, or if you
need any additional information, please contact Michael Johnson at [phone].
To comply with the requirement of Section 3(D) of the subject permit, the required
photocopy of this letter is enclosed.
By my signature below, I certify that I believe the information contained in this letter is
true, accurate, and complete.
Sincerely,
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Karen B. Wrigley
Plant Manager
DEQ-CFW 00068439