DEQ-CFW_00068470

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FORM AA
ADMINISTRATIVE APPLICATION (General Information)
REVISED 8/31/03 NCDENR/Division of Air Quality - Application for Air Permit to' Construct/Operate
GENERAL INFORMATION
Legal Corporate/Owner Name: E.I. du Pont de Nemours & Company
Site Name: DuPont Company - Fayetteville Works
Site Address (911 Address) Line 1: 22828 NC Highway 87 W
Site Address Line 2:
City: Fayetteville State: North Carolina Zip Code: 28306-7332 County: Bladen
CONTACT INFORMATION
Permit / Technical Contact:
Facility / Inspection Contact:
Name/Title: Michael E. Johnson /Enviro. Manager
Name/Title: Michael E. Johnson / Enviro. Manager
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 2:
Mailing Address Line 2:
city: Fayetteville State: NC Zip Code: 28306-7332
City: Fayetteville State: NC Zip Code: 28306-7332
Ph. No. [phone] Fax No. [phone]
Ph. No. [phone] Fax No. [phone]
Email Address: [e-mail]
Email Address: [e-mail]
Responsible Official/Authorized Contact:
Invoice Contact:
Name / Title: Karen B. Wrigley / Plant Manager
Name/Title: Michael E. Johnson / Enviro. Manager
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 2:
Mailing Address Line 2:
city: Fayetteville State: NC Zip Code: 28306-7332
City: Fayetteville State: NC Zip Code: 28306-7332
Ph. No. [phone] Fax No. [phone]
Ph. No. [phone] Fax No. [phone]
Email Address: [e-mail]
Email Address: [e-mail]
APPLICATION IS BEING MADE FOR
Renewal (Non -Title v) �X Renewal Title V 0 Name Change 0 Ownership Change Administrative Amendment
FACILITY CURRENT CLASSIFICATION (Check Only One)
® Small ® Synthetic Minor ❑X Title V
FACILITY (Plant Site) INFORMATION
Describe nature of (plant site) operation(s):
Manufacturer of chemicals, resins, plastic sheeting, and plastic film.
Primary SIC/NAICS Code: 326113 Current/Previous Air Permit No. 03735T32 Expiration Date: 01/31/2009
Facility Coordinates: Latitude: 34 deg 50' 30" N Longitude: 78 deg 50' 00" W Facility ID No. 0900009
Does this application contain confidential data? Yes ❑X No (see instructions)
PERSON OR FIRM THAT PREPARED APPLICATION
Person Name: Michael E. Johnson Firm Name:
Mailing Address Line 1: 22828 NC Highway 87 W Mailing Address Line 2:
city: Fayetteville State: N.C. Zip Code: 28306-7332 County: Bladen
Ph. No. [phone] Fax No. [phone] Email Address: [e-mail]
SIGNATURE OF RESPONSIBLE OFFICIAL / AUTHORIZED CONTACT
Name (typed): Karen B. Wrigley Title: Plant Manager
x Signature (Blue Ink): Date: gllco108
Attach Additional Sheets as Necessary Page 1 of 2
DEQ-CFW 00068470

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FORM AA (continued, page 2 of 2)
ADMINISTRATIVE APPLICATION
REVISED 8/31/03 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate
SECTION AA1 - APPLICATION FOR NON -TITLE V PERMIT RENEWAL
(Company name) hereby formally requests renewal of Air Permit No.
There have been no modifications to the originally permitted facility or the operations therein that would require and air permit since the last permit was issued.
Is your facility subject to 40 CFR part 68 "Prevention of Accidental Releases" - Section 112(r) of the Clean Air Act?11 Yes No
If yes, have you already submitted a Risk management Plan (RMP) to EPA? 11 Yes 11 No Date submitted
Did you attach a current emission inventory? 0Yes 11 No If no, was it submitted via AERO or by mail (date mailed)
SECTION AA2 - APPLICATION FOR TITLE V PERMIT RENEWAL
In accordance with the provisions of Title 15A 2Q .0513 the responsible official of DuPont Company - Fayetteville Works (Company Name)
hereby formally requests renewal of Air Permit No. 03735T32 (Air Permit No.) and further certifies that:
(1) the current air quality permit identifies and describes all emissions units at the above subject facility, except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 20 .0500,
(2) the current air quality permit cites all applicable requirements and provides the method or methods for determining compliance with the applicable
requirements,
(3) the facility is currently in compliance, and shall continue to comply, with all applicable requirements. (Note: As provided under 15A NCAC 2Q. 0512
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit.),
(4) for applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis,
(5) the facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64,
The responsible official (signature on page 1) certifies under the penalty of law that all information and statements provided above, based on
information and belief formed after reasonable inquiry, are true, accurate, and complete.
SECTION AA3 - APPLICATION FOR NAME CHANGE
New Facility Name:
Former Facility Name:
An official facility name change is requested as described above for the air quality permit mentioned on page 1 of this form. Complete the other
sections if there has been modifications to the originally permitted facility that would require an air quality permit since the last permit was issued
and if there has been an ownership change associated with this name change.
SECTION AA4 - APPLICATION FOR AN OWNERSHIP CHANGE
By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described
below. The transfer of permit responsibility, coverage and liability shall be effective (immediately or insert date). The legal
ownership of the facility described on page 1 of this form has been or will be transferred on (date). There have been no
been on modification to the originally permitted facility that would require an air quality permit since the last permit was issued.
Signature of New (Buyer) Responsible Official/Authorized Contact (as typed on page 1):
x Signature (Blue Ink):
NOTE: It shall be the responsibility of the new owner to submit an annual compliance
certification pursuant to the terms and conditions of the air permit for the entire calendar yeas
regardless of who owned the facility during the year. The new owner should obtain
Date: compliance information from the former owner prior to the transfer of ownership.
New Facility Name:
Former Facility Name:
Signature of Former (Seller) Responsible Official/Authorized Contact:
Name (typed or print):
Title:
x Signature (Blue Ink):
Date:
Former Legal Corporate/Owner Name:
In lieu of the seller's signature on this form, a letter may be submitted with the seller's signature indicating the ownership change.
SECTION AA5 - APPLICATION FOR AN ADMINISTRATIVE AMENDMENT
Describe the requested administrative amendment here (attach additional documents as necessary):
Attach Additional Sheets as Necessary Page 2 of 2
DEQ-CFW 00068471

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FORMs A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION - A2
112r APPLICABILITY INFORMATION - A3
REVISED 04/10/07 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate
I A2
EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted,
Replaced, Deleted
EMISSION SOURCE
ID NO.
EMISSION SOURCE
DESCRIPTION
CONTROL DEVICE
ID NO.
CONTROL DEVICE
DESCRIPTION
l�pp:To F►,�?Y�I�I�it�S� klGi�ily
U�p�rtnt)ed, Q Repl�mt)
Itx)sting PermittedQuipxn�nt Tp $e MQQIFI�D By.This Application
- �qulpl> of To p,EIL D Tht Al�pl)c tipn
11 (r) APPL( /#BO.ITY INFQ 1 1 JON"
A3
Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases" - Section 112(r) of the Federal Clean Yes 0 No ❑
Air Act?
If No, please specify in detail how your facility avoided applicability:
If your facility is Subject to 112(r), please complete the following:
A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150?
Yes No ❑ Specify required RMP submittal date: June 30, 1999
If submitted, RMP submittal date: June 8, 1999 RMP resubmitted on June 3, 2004
B. Are you using administrative controls to subject your facility to a lesser 112(r) program standard?
Yes ❑ No 0 If yes, please specify:
Attach Additional Sheets As Necessary
DEQ-CFW 00068472

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FORM E5
TITLE V COMPLIANCE CERTIFICATION (Required)
Revised 01/01/07 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate
In accordance with the provisions of Title 15A NCAC 2Q .0520 and .0515(b)(4),
the responsible company official of.
SITE NAME: DuPont Fayetteville Works
SITE ADDRESS: 22828 NC Highway 87 W
CITY, NC: Fayetteville, NC 28306
COUNTY: Bladen
PERMIT NUMBER: 03735T32
CERTIFIES THAT (Check the appropriate statement):
❑X The facility is in compliance with all applicable requirements
E5
❑ In accordance with the provisions of Title 15A NCAC 2Q .0515(b)(4) the responsible
company official certififies that the proposed minor modification meets the criteria for using
the procedures set out in 2Q .0515 and requests that these procedures be used to process
the permit application.
❑ The facility is not currently in compliance with all applicable requirements
If this box is checked, you must also complete form E4 "Emission Source Compliance Schedule"
The undersigned certifies under the penalty of law, that all information and statements provided
in the application, based on information and belief formed after reasonable inquiry, are true,
accurate, and complete.
K)
Karen B. Wrigley, Plant Manager
Name, Title of responsible company official (Type or print)
Date: 1-1i(D - Ug'
Attach Additional Sheets As Necessary
DEQ-CFW 00068473

DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T32
Compliance Assurance Monitoring (CAM) Plan
This compliance assurance monitoring (CAM) plan satisfies the 40 CFR 64.5(a)(3) requirement
of submitting said plan at the time of the Title V air permit renewal.
Under the general applicability of 40 CFR 64.2(a), the CAM requirements apply to any
pollutant -specific emissions unit at a major source that is required to obtain a part 70 if the unit
satisfies all of the following criteria:
(1) The unit is subject to an emission limitation or standard for the applicable regulated air
pollutant (or a surrogate thereof), other than an emission limitation or standard that is
exempt under 40 CFR 64.2(b)(1);
(2) The unit uses a control device to achieve compliance with any such emission limitation or
standard; and
(3) The unit has potential pre -control device emissions of the applicable regulated air
pollutant that are equal to or greater than 100 percent of the amount, in tons per year,
required for a source to be classified as a major source.
Pursuant to the 40 CFR 64.2(b)(1) exemptions, the CAM requirements do not apply to pollutant -
specific emissions units that are subject to any of the following emission limitations or standards:
(1) Emission limitations or standards proposed by the Administrator after November 15, 1990
pursuant to section 111 (NSPS) or 112 (NESHAP) of the Act.
(2) Stratospheric ozone protection requirements under title VI of the Act.
(3) Acid Rain Program requirements pursuant to sections 404, 405, 406, 407(a), 407(b), or
410 of the Act.
(4) Emission limitations or standards or other applicable requirements that apply solely under
an emissions trading program approved or promulgated by the Administrator under the
Act that allows for trading emissions within a source or between sources.
(5) An emissions cap that meets the requirements specified in §70.4(b)(12) or
§71.6(a)(13)(iii) of this chapter.
(6) Emission limitations or standards for which a part 70 specifies a continuous compliance
determination method, as defined in §64.1.
This CAM Plan is organized in a manner that each pollutant -specific emissions unit at the
DuPont Company — Fayetteville Works that has a control device is discussed, even if that unit is
exempted under 40 CFR 64.2(b)(1).
DEQ-CFW 00068474

CAM Plan 0 0 Page 2 of 6
1. Butacite® Process Area consisting of one butyraldehyde storage tank (ID No. BS-A)
controlled by a brine cooled condenser (ID No. BCD -A)
The butyraldehyde storage tank (ID No. BS-A) is not subject to an emission limitation or
standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
2. Four Butacite® flake reactors (ID Nos. BS-Bl.l through BS-BIA) controlled by a
packed -bed scrubber (ID No. BCD-B1)
The Butacite® flake reactors (ID Nos. BS-B1.1 through BS-131.4) are subject to an
emission limitation or standard for regulated hazardous air pollutants in the form of
methanol.
However, the Butacite® flake reactors (ID Nos. BS-B1.1 through BS-B1.4) are subject to
the Part 63 Subpart FFFF NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
3. Four Butacite® flake reactors (ID Nos. BS-B2.1 through BS-B2.4) controlled by a
packed -bed scrubber (ID No. BCD-B2)
The Butacite® flake reactors (ID Nos. BS-132.1 through BS-132.4) are subject to an
emission limitation or standard for regulated hazardous air pollutants in the form of
methanol.
However, the Butacite® flake reactors (ID Nos. BS-B2.1 through BS-B2.4) are subject to
the Part 63 Subpart FFFF NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
4. One Butacite® flake dryer (ID No. BS-C) controlled by a cyclone (ID No. BCD-Cl)
and fabric filter (ID No. BCD-C2)
The Butacite® flake dryer (ID No. BS-C) is subject to an emission limitation or standard
for regulated particulate matter per 15A NCAC 2D .0515 and is limited to the particulate
matter emission rate of the equation found in 15A NCAC 2D .0515(a).
To ensure compliance with this requirement, once a month DuPont personnel make a visual
observation of the emission point of the fabric filter (ID No. BCD-C2) for any visible
emissions above normal. Since the effective date of the Title V permit, no visible
emissions of any quantity have ever been observed. In addition, DuPont personnel perform
inspections and maintenance as recommended by the manufacturer. As a minimum, the
inspection and maintenance requirement include a monthly visual inspection of the system
ductwork and material collection unit for leaks and an annual internal inspection of the
bagfilter's structural integrity.
DEQ-CFW 00068475

CAM Plan 0 Page 3 of 6
5. One Butacite® flake dryer (ID No. BS-C) controlled by a cyclone (ID No. BCD-Cl)
and fabric filter (ID No. BCD-C2)
The Butacite® flake dryer (ID No. BS-C) is subject to an emission limitation or standard
for regulated visible emissions per 15A NCAC 2D .0521 and visible emissions are limited
to not exceed 20 percent opacity when averaged over a six -minute period as found in 15A
NCAC 2D .0521(d).
To ensure compliance with this requirement, once a month DuPont personnel make a visual
observation of the emission point of the fabric filter (ID No. BCD-C2) for any visible
emissions above normal. Since the effective date of the Title V permit, no visible
emissions of any quantity have ever been observed. In addition, DuPont personnel perform
inspections and maintenance as recommended by the manufacturer. As a minimum, the
inspection and maintenance requirement include a monthly visual inspection of the system
ductwork and material collection unit for leaks and an annual internal inspection of the
bagfilter's structural integrity.
6. 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)
The Butacite® Line No. 3 Sheeting Extrusion Process (ID No. BS-El) is not subject to an
emission limitation or standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
7. 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)
The Butacite® Line No. 4 Sheeting Extrusion Process (ID No. BS-E2) is not subject to an
emission limitation or standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
8. One polyvinyl butyral sheeting rotogravure printing operation (ID No. BS-D)
controlled by one multi -stage horizontal spray scrubber (ID No. BCD-Dl)
The Butacite® polyvinyl butyral sheeting rotogravure printing operation (ID No. BS-D) is
subject to an emission limitation or standard for regulated hazardous air pollutants in the
form of dimethyl formamide.
However, the polyvinyl butyral sheeting rotogravure printing operation (ID No. BS-D) is
subject to the Part 63 Subpart KK NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
DEQ-CFW 00068476

CAM Plan 0 0 Page 4 of 6
9. 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)
The hexfluoropropylene epoxide process (ID No. NS-A) is subject to an emission limitation
or standard for regulated volatile organic compounds to comply with 15A NCAC 2Q. 0317
which is the avoidance conditions for 15A NCAC 2D. 0530, Prevention Of Significant
Deterioration.
However, the hexfluoropropylene epoxide process (ID No. NS-A) is subject to the Part 63
Subpart FFFF NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
10. One vinyl ethers process (ID No. NS-B) controlled by one of two available baffle -plate
scrubbers (ID No. NCD-Hdrl or NCD-Hdr2)
The vinyl ethers process (ID No. NS-B) is subject to an emission limitation or standard for
regulated volatile organic compounds to comply with 15A NCAC 2Q. 0317 which is the
avoidance conditions for 15A NCAC 2D. 0530, Prevention Of Significant Deterioration.
However, the vinyl ethers process (ID No. NS-B) is subject to the Part 63 Subpart FFFF
NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
11. One vinyl ethers process (ID No. NS-C) controlled by one of two available baffle -plate
scrubbers (ID No. NCD-Hdrl or NCD-Hdr2)
The vinyl ethers process (ID No. NS-C) is not subject to an emission limitation or standard
for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
12. One RSU process (ID No. NS-D) controlled by one baffle -plate scrubber (ID No. NCD-
Hdrl or NCD-Hdr2)
The RSU process (ID No. NS-D) is not subject to an emission limitation or standard for any
applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
13. One liquid waste stabilization process (ID No. NS-E) controlled by one baffle -plate
scrubber (ID No. NCD-Hdrl or NCD-Hdr2)
The liquid waste stabilization process (ID No. NS-E) is not subject to an emission
limitation or standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
DEQ-CFW 00068477

CAM Plan 0 0 Page 5 of 6
14. One MMF process (ID No. NS-F) controlled by one baffle -plate scrubber (ID No.
NCD-Hdrl or NCD-Hdr2)
The MMF process (1D No. NS-F) is not subject to an emission limitation or standard for
any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
15. One resins fluorination process (ID No. NS-G) controlled by a venturi vacuum jet
scrubber (ID No. NCD-G),
The resins fluorination process (ID No. NS-G) is subject to an emission limitation or
standard for regulated volatile organic compounds to comply with 15A NCAC 2Q. 0317
which is the avoidance conditions for 15A NCAC 2D. 0530, Prevention Of Significant
Deterioration.
However, the resins fluorination process (ID No. NS-G) is subject to the Part 63 Subpart
FFFF NESHAP regulations.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(b)(1)(i).
16. One TFE/HCI separation unit (ID No. NS-L) controlled by one baffle -plate scrubber
(ID No. NCD-Hdrl or NCD-Hdr2)
The TFE/HCl separation unit (ID No. NS-L) is not subject to an emission limitation or
standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
17. Fluoroproducts polymer manufacturing development facility (ID No. FS-A) controlled
by a wet scrubber (ID No. FCD-AI) and fabric filter (ID No. FCD-A2)
The Fluoroproducts polymer manufacturing development facility (ID No. FS-A) is subject
to an emission limitation or standard for regulated particulate matter per 15A NCAC 2D
.0515 and is limited to the particulate matter emission rate of the equation found in 15A
NCAC 2D .0515(a).
To ensure compliance with this requirement, DuPont personnel perform inspections and
maintenance of the fabric filter (ID No. FCD-A2) as recommended by the manufacturer.
As a minimum, the inspection and maintenance requirement include a monthly visual
inspection of the system ductwork and material collection unit for leaks and an annual
internal inspection of the bagfilter's structural integrity.
DEQ-CFW 00068478

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18. 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 Fluoroproducts polymer manufacturing development facility (ID No. FS-A) is subject
to an emission limitation or standard for regulated visible emissions per 15A NCAC 2D
.0521 and visible emissions are limited to not exceed 20 percent opacity when averaged
over a six -minute period as found in 15A NCAC 2D .0521(d).
To ensure compliance with this requirement, DuPont personnel perform inspections and
maintenance of the fabric filter (ID No. FCD-A2) as recommended by the manufacturer.
As a minimum, the inspection and maintenance requirement include a monthly visual
inspection of the system ductwork and material collection unit for leaks and an annual
internal inspection of the bagfilter's structural integrity.
19. 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 Fluoroproducts polymer manufacturing development facility (ID No. FS-A) is subject
to an emission limitation or standard for regulated volatile organic compounds to comply
with 15A NCAC 2Q. 0317 which is the avoidance conditions for 15A NCAC 2D. 0530,
Prevention Of Significant Deterioration.
However, the Fluoroproducts polymer manufacturing development facility's (ID No. FS-A)
two listed control devices are not used to achieve compliance with any such emission
limitation or standard. In the determination of VOC emissions, the water scrubber is
assumed to have no control efficiency for VOCs.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(2).
20. 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 APFO manufacturing facility (ID No. AS -A) is not subject to an emission limitation or
standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
21. 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)
The Wastewater Treatment Area (ID No. WTS-A) is not subject to an emission limitation
or standard for any applicable regulated air pollutant.
Therefore, the CAM requirements do not apply to this unit per 40 CFR 64.2(a)(1).
DEQ-CFW 00068479

0
DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T32
Maximum Achievable Control Technology (MALT) Review
The DuPont Company — Fayetteville Works is currently subject to two Maximum Achievable
Control Technology (MACT) standards, excluding the MACTs for combustion sources.
40 CFR Part 63 Subpart KK — Printing and Publishing NESHAP
Per 40 CFR 63.826(a) the compliance date for an owner or operator of an existing affected
source subject to the provisions of the Subpart KK MACT standard was May 30, 1999.
The Butacite® manufacturing facility produces polyvinyl butyral interlayer sheeting for the
automobile windshield industry. Some of the interlayer includes a tinted band across the top that
reduces the sun's brightness. This tinted band is applied to the interlayer using a rotogravure
press. This process is subject to the product rotogravure printing standard of 40 CFR 63.825.
To comply with the Subpart KK MACT standard requirements, a wet scrubber was installed
which controls the dimethyl formamide (a HAP) emissions. Stack testing demonstrated that the
wet scrubber had an overall organic HAP control efficiency of at least 95 percent as required by
this MACT standard.
The Title V air permit includes operational parametric limitations for the minimum water flow
rate and minimum air flow rate in each of the scrubber's nozzles, and a minimum exhaust fan
exit velocity for the Tinting Process area.
40 CFR Part 63 Subpart FFFF — Miscellaneous Organic NESHAP
Per 40 CFR 63.2445(b) the compliance date for an owner or operator of an existing affected
source subject to the provisions of the Subpart KK MACT standard is May 10, 2008.
The Butacite® manufacturing facility produces polyvinyl butyral that is either finished as
interlayer sheeting or as resin. It is known that the raw material for this process, polyvinyl
alcohol (PVA), contains a small concentration of methanol (a HAP), some of which ultimately
becomes an air emission. This process meets the definition of a miscellaneous organic chemical
manufacturing process per 40 CFR 63.2550 and as such would be subject to the Subpart FFFF
MACT standard.
The standards for batch process vents per Part 63.2460 specify that no HAP control is required
for Group 2 batch process vents, which are defined as batch process vents in a process for which
the collective uncontrolled organic HAP emissions from all of the batch process vents are less
than 10,000 pounds per year at an existing source.
DEQ-CFW 00068480

MACT Review 0 Page 2 of 2
As stated in the Precompliance Report that was submitted to N.C. Division of Air Quality on
November 8, 2005, initial emission testing indicates that the uncontrolled emissions of methanol
from the polyvinyl butyral process would be less than 10,000 pounds per year if the PVA
consumption is limited to 50,860,000 pounds per year.
DuPont is preparing to perform stack testing using the required EPA methodology to quantify the
potential uncontrolled emissions of methanol and to determine the existing ButaciteO polyvinyl
butyral water scrubber's control efficiency for methanol. The result of this formal testing will
undoubtedly change the PVA consumption quantity discussed in the preceding paragraph. The
stack testing protocol will be submitted to N.C. Division of Air Quality within the next 30 days.
The ButaciteO manufacturing process does not have any ancillary equipment that is subject to
the Subpart FFFF leak detection and repair (LDAR) requirements.
The NafionO manufacturing area produces the NafionO films, polyfluorocarbon resins, and
numerous fluoromonomers. Many of these units meet the definition of miscellaneous organic
chemical manufacturing processes per 40 CFR 63.2550 and as such would be subject to the
Subpart FFFF MACT standard.
The NafionO manufacturing area operates two gaseous absorbers or wet scrubbers (Title V
Permit ID Nos. NCD-Hdr-1 and NCD-Hdr-2). Essentially all vents controlled by these scrubbers
are subject to the hydrogen halide provisions of the Subpart FFFF MACT standard. However, in
July and August 2003, formal stack testing using EPA methodology was performed on the two
scrubbers. This testing proved that both of the scrubbers exceeded the 98% control efficiency for
halide HAPs as required by the Subpart FFFF MACT standard.
The NafionO manufacturing process does have ancillary equipment that is subject to the Subpart
FFFF leak detection and repair (LDAR) requirements. The required monitoring of that
equipment will be begin prior to compliance date of the Subpart FFFF MACT standard.
DEQ-CFW 00068481

DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T32
Facility -Wide Toxic Air Pollutant (TAP) Review
The DuPont Company — Fayetteville Works is compliant with the requirements of 15A NCAC
2Q.0705 and 15A NCAC 2D.I 100.
In October 1995, a facility -wide North Carolina Air Toxics modeling demonstration was
submitted to the North Carolina Division of Air Quality. As a result of that modeling
demonstration, facility -wide limits were established for virtually all of the toxic air pollutants
listed in 15A NCAC 2D.1104.
An update to the facility -wide air toxics modeling demonstration was submitted to the Division
of Air Quality on August 30, 2001 as part of the air permit application for the APFO
Manufacturing Facility. Since that submittal, no new sources have been constructed at this site
that emit N.C. toxic air pollutants.
In both the 1995 and 2001 modeling demonstration, the approach taken was to define a "worst -
case" unit impact as the highest ambient concentration in micrograms (µg) per cubic meter that is
associated with an emission rate of one (1) pound per hour from a non-existent or "pseudo"
emission point. This worst -case unit impact from the pseudo emission point would be higher
than any of the existing emission points' unit impacts, as determined using the EPA SCREEN3
model.
Once this worst -case unit impact was established, then the emission rate for each of the N.C.
toxic air pollutants was determined which would result in the acceptable ambient level (AAL) air
concentration for the specific TAP at the site's property boundary. These individual emission
rates were then added to the site's air permit.
In practice, since each actual emission point has a modeled unit impact that is lower than the
pseudo source, then as long as the facility -wide emission of a specific TAP is less than the
quantity listed in the air permit, then the concentration of that specific TAP will be lower than
the AAL for that specific TAP.
The DuPont site complies with the permitted TAP limits by determining the emission rate for
each TAP on a quarterly basis and reporting that emission rate to N.C. Division of Air Quality in
a quarterly report.
DEQ-CFW 00068482