DEQ-CFW_00068512

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NORTH CAROLINA DIVISION OF
AIR QUALITY
Inspection Report
Date: 05/19/2009
Facility Data
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
Lat: 34d 50.6000m Long: 78d 50.2930m
SIC : 3081 / Unsupported Plastics Film And Sheet
NAILS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Contact Data
Facility Contact I Authorized Contact I Technical Contact
Michael Johnson Karen Wrigley Michael Johnson
Environmental Manager Plant Manager Environmental Manager
[phone] [phone] [phone]
Inspector's Signature: Comments:
c V
Date of SignatureU
511912-VO-1 �A
Fayetteville Regional Office
DuPont Company - Fayettille Works
NC Facility ID 09000097
County/FIPS: Bladen/017
Compliance Data
Inspection Date 05/12/2009
Inspector's Name Christy Richardson
Operating Status Operating
Compliance Code Compliance - inspection
Action Code FCE
On -Site Inspection Result Compliance
Permit Data
Permit 03735 / T34
Issued 1/15/2009
Expires 1/31/2009
Classification Title V
Permit Status Active
1) DIRECTIONS TO SITE: Dupont Company -Fayetteville Works is located on NC Highway 87 in Bladen County.
From Fayetteville, take Highway 87 south. The entrance to the facility is approximately 18 miles from FRO on the left
side of Highway 87 just before the Cumberland/Bladen County line.
2) FACILITY DESCRIPTION: Dupont Company - Fayetteville Works is a chemical manufacturing facility located in
Bladen County. The facility employs approximately 500 employees and 100 contractors on a 24X7 basis. Production
and employees have decreased drastically at the DuPont Fayetteville facility since the previous inspection. Most
contractors are now employed only half time. DuPont Fayetteville consists of six individual manufacturing plants, a
boiler house and a waste treatment operation. The facility is subject to NESHAP Subpart KK, Printing and Publishing
Industry, as well as Subpart FFFF, Miscellaneous Organic NESHAP. Several processes also have PSD avoidance
conditions. The facility has two permanent boilers onsite, one permanent boiler which is permitted but not yet
constructed, as well as one temporary boiler.
3) PRE -INSPECTION SUMMARY: On May 12, 2009, I, Christy Richardson, met with Mike Johnson, Environmental
Manager for a full compliance inspection. During the pre -inspection conference, we discussed the status / operation
mode of all manufacturing plants and recently permitted equipment. We also discussed the requirements for MON
compliance in great detail. Mr. Johnson confirmed that there have been no changes in emission sources since the
previous inspection / permit modification and that the emissions sources listed on the permit had not changed. Mr.
Johnson, along with Technical Engineers from various manufacturing facilities, led a tour of individual plants and
provided the required records. PSD records and most all other records are accessible on the Intranet in Mr. Johnson's
office now. The recently permitted second PVF facility is under construction but is not planned to be operational until
2010. The newly permitted boiler is not yet under construction and Mr. Johnson stated that the modification would not
happen in the near future.
DEQ-CFW 00068512

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4) PERMITTED EMISSION SOURCES: At the time of the inspection, DuPont Company — Fayetteville Works was
operating under Permit No. 03735T34 which includes the following emission sources:
Emission Source
Emission Source Description
Control
Control Device Description
ID No,
Device ID No.
PS-1
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired
N/A
N/A
boiler (139.4 million Btu per hour maximum heat
input)
PS-2 2
Natural Gas/No. 2 fuel oil /No. 6 fuel oil -fired
N/A
N/A
boiler (88.4 million Btu per hour maximum heat
input)
PS-C
Natural Gas/No. 2 fuel oil -fired boiler (97 million
N/A
N/A
NSPS Dc
Btu per hour maximum heat input) equipped with
a low-NOx burner
PS -Temp
Natural Gas/No. 2 fuel oil -fired boiler (greater
N/A
N/A
NSPS Dc
than 3 0. 0 and less than 100.0 million Btu per hour
maximum heat input)
BS-A
Butyraldehyde storage tank
BCD -A
Brine -cooled condenser
BS-B1.1 through
Butaciteo polyvinyl butyral flake reactors (4
BCD-Bl
Packed -bed column scrubber with mist
BS-B1.4
units)
eliminator (8 gallons per minute water
injection rate averaged over a 3-hour period)
state -enforceable, only)
BS-B2.1 through
Butacite polyvinyl butyral flake reactors (4
BCD-B2
Packed -bed column scrubber with mist
BS-B2.4
units)
eliminator (8 gallons per minute water
injection rate averaged over a 3-hour period)
state -enforceable, only)
BS-C
Butacite polyvinyl butyral flake dryer
BCD-Cl
Cyclone separator
BCD-C2
Fabric filter 6,858 square feet of filter area
BS-El
Butacite Line No. 3 Sheering Extrusion Process,
BCD -El
Water -Cooled Condenser (voluntary use
includin four 4 extruders
only)
BS-E2
Butacite Line No. 4 Sheeting Extrusion Process,
BCD-E2
Water -Cooled Condenser (voluntary use
including four 4 extruders
only)
BS-E3
Butacite Line No. 3 Back -End Processes,
N/A
N/A
including a quencher, dryer/relaxer, and wind-up
area
BS-E4
Butacite Line No. 4 Back -End Processes,
N/A
N/A
including a quencher, dryer/relaxer, and wind-up
area
BS-D
Butacite Polyvinyl butyral sheeting rotogravure
BCD-D1
Multi -stage horizontal spray scrubber (6
MACT KK
printing operation
gallons per minute of water flow to each
nozzle, averaged over a 3-hourperiod)
NS-A
Nafion® Hexfluoropropylene epoxide process
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
(HFPO)
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period
NS-B
Nafion@ Vinyl Ethers North process
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
DEQ-CFW 00068513

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Emission Source
Emission Source Description
Control
Control Device Description
ID No.
Device ID No.
NS-C
Nafion® Vinyl Ethers South process
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
NS-D
Nafiong RSU Process
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
NS-E
Nafion@ Liquid waste stabilization
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
NS-F
Nafion® MMF process
NCD-Hdrl
Baffle -plate scrubber (7,000 kilogram/hour
MACT FFFF
liquid injection rate averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
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
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 averaged over a 3-hour
-or-
period)
NCD-Hdr2
Baffle -plate scrubber (7,000 kilogram/hour
liquid injection rate averaged over a 3-hour
period)
NS-M
Nafion® TFE/CO2 separation process
N/A
N/A
NS-N
HFPO product container decontamination
N/A
N/A
process
NS-02
Vinyl Ethers North product container
N/A
N/A
decontamination process
NS-P
Vinyl Ethers South product container
N/A
N/A
decontamination process
SW-1
Semiworks polymerization operation
NIA
N/A
SW-2
Semiworks laboratory hood
N/A
N/A
DEQ-CFW 00068514

Emission Source
Emission Source Description
Control
Control Device Description
ID No.
Device ID No.
FS-A
Fluoroproducts polymer manufacturing
FCD-Al
Wet scrubber (3 gallons per minute water
development facility
injection rate averaged over a 3-hour period)
(nominal injection rate)
Fabric filter (125 square feet of filter area)
FCD-A2
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 sludge
WTCD-1
Impingement -type wet scrubber with mist
WTS-C
dryers
eliminator (state -enforceable only)
SGS-A
entryGIas Manufacturing
N/A
N/A
FS-B
Polyvinyl Fluoride Manufacturing Facility No. 1
N/A
N/A
FS-C
Polyvinyl Fluoride Manufact Facility No. 2
N/A
N/A
5) APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each various manufacturing
process as listed on the current air permit.
* Powerhouse (PS-1 and PS-2)*
The facility is permitted to operate one Natural Gas/No. 2/No. 6 fuel oil -fired boiler (139.4 mmBtu/hr maximum heat
input, PS-1), one Natural Gas/No. 2/No. 6 fuel oil -fired boiler (88.4 mmBtu/hr maximum heat input, PS-2), and one
Natural Gas/No. 2 fuel oil -fired boiler with low-NOx burner (97 mmBtu/hr maximum heat input, PS-C). The third
boiler (PS-C) was recently permitted and is not yet under construction. According to Mr. Johnson, the construction
project will not begin anytime soon. Also, during the last revision, the boilers were permitted to combust natural gas.
The facility currently does not have access to natural gas but are proposing to run natural gas lines to the facility in the
future. The two onsite boilers share the same stack. The stack was damaged recently and has been reduced in height
drastically to 50 feet. The larger boiler has a steam capacity of 113,000 pounds of steam per hour and was
manufactured in 1969. The smaller boiler was manufactured in 1982 with a steam capacity of 72,000 pounds per hour.
They are both pre-NSPS boilers; however, Boiler PS-2 does have a PSD avoidance condition for PM, PM-10, NO,,
and SO2. The software used at the boiler house allows the operator to track criteria pollutant emissions for the PSD
avoidance requirement for the smaller boiler. The new boiler (PS-C) is subject to NSPS Dc. Due to debottlenecking
of the boilers by the PVF facility, DuPont now has a facility -wide PSD S02 emissions limitation.
15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
—Particulate emissions from boilers PS-1 and PS-2 shall not exceed 0.26671bs/mmBtu. Particulate emissions
from PS-C shall not exceed 0.2268 lbs/mmBtu.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.024 lbs/mmBtu and 0.161bs/mmBtu for
No. 6 fuel oil.
15A NCAC 2D .0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES — The sulfur
dioxide emissions from each boiler shall not exceed 2.3 pounds per million Btu heat input. The sulfur content of
No. 6 fuel oil shall not exceed 2.1 % sulfur by weight. The Permittee shall maintain fuel certs for all No. 6 fuel oil
shipments.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.5071bs/mmBtu and 2.20 lbs/mmBtu for
No. 6 fuel oil. As long as the No. 6 fuel does not exceed the fuel sulfur limit, the regulatory limit will not be
exceeded during normal operation. Fuel certs were reviewed during the inspection and total fuel usage as well as
average sulfur content are given to Mike Johnson after each month. Highest sulfur content of the No. 6 fuel oil
was 2.01% by weight. The facility has not combusted No. 6 fuel oil since March 2008 and has no plans to
combust it again. The No. 6 fuel oil tank has been emptied and cleaned out. All No. 2 fuel oil is below 0.5%
sulfur by weight and most of the No.2 fuel was ultra -low sulfur fuel oil (15 ppm).
DEQ-CFW 00068515

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from Boiler PS-1shall not
exceed 40% opacity. Visible emissions from PS-2, and PS -Temp shall not exceed 20% opacity. The pernuttee
shall record a daily visible emissions evaluation (normal or above normal) when combusting No. 6 fuel oil and
maintain a logbook showing the results of each evaluation. These results from monitoring must be submitted to
DAQ in a semi-annual report.
IN COMPLIANCE — The boiler was combusting No. 2 fuel oil during the inspection and I observed 0% opacity
from the boiler stack. The facility stopped taking daily VE observations in the end of April 2008 since the facility
does not plan to burn No. 6 fuel oil. Prior to this date, the facility was taking daily observations regardless of the
type of fuel being combusted.
15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS — SUBPART Dc — The sulfur
content of fuel combusted in the new boiler (PS-C) shall not exceed 0.5% by weight and visible emissions are
limited to 20% opacity. Initial notifications are required at construction and startup. The facility must conduct
Method 9 testing after boiler start-up. The Permittee shall maintain records of fuel usage and fuel certifications.
A semi-annual summary report must be submitted as well.
IN COMPLLANCE — Boilers (PS-Q is not yet under construction.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from Boiler PS-2 shall not exceed the following: 25 TPY PM, 15 TPY PM-10, 40
TPY NOx, and 40 TPY S02. The Permittee shall keep monthly records of fuel usage, fuel sulfur content, and
maintain fuel certifications. Semiannual reporting is also required for monthly emissions (14 month period), fuel
usage, and sulfur content. The Permittee must also define all deviations in the report.
IN COMPLIANCE —All reports show that the facility well below these emissions limits. The current electronic
record listed NOx at 21 tons, S02 at 3 tons, PM at 3.5 tons, and PM10 at 1 ton. Fuel certifications were reviewed
during the inspection.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from ALL boilers shall not exceed the following: 702.5 TPY S02. The Permittee
shall keep monthly records of fuel usage and fuel sulfur content. The Permittee shall also record monthly S02
emissions. Semiannual reporting is also required for monthly emissions (14 month period), fuel usage, and sulfur
content. The Permittee must also define all deviations in the report.
IN COMPLIANCE — Currently, the 12-month running total is 1 ton per year since the facility is now combusting
only No. 2 fuel oil. The fuel oil also is ultra -low sulfur (15 ppm). Fuel certifications were reviewed during the
inspection.
* Butacite® Process Area (all sources labeled with BS- and BCD -I*
The Butacite® manufacturing operation includes a polyvinyl butyral sheeting and rotogravure printing operation. The
operation produces flexible glass laminate for car windshields. The printing (tinting) operation is subject to MACT
Subpart KK, Printing and Publishing, requirements and controlled by a permanent total enclosure (testing conducted
per EPA Method 24) for the printing operation room exhaust and a multi -stage horizontal spray scrubber (testing
conducted per EPA Method 18) to control emissions of dimethylformamide (DMF). The tinting operation has been
permanently shut down and will be removed from the permit during renewal. The butacite process area includes the
butyraldehyde storage tank, with emissions and potential odors from the butyraldehyde controlled by a brine -cooled
(ethylene glycol) condenser. The process also includes the Butacite flake reactors, controlled by packed -bed column
scrubbers, and a Butacite flake dryer, controlled by a cyclone separator and fabric filter. At this time one of the
Butacite lines is not operating and the remaining Butacite line is operating at 50% of capacity. Portions of the Butacite
area are subject to the MON requirements.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
—Particulate matter emissions from the Butacite process shall not exceed E=4.10*P°'67. The permittee shall
maintain production records. The Permittee shall perform a monthly visual and annual internal inspection on
baghouses BCD-Cl and BCD-C2. A logbook detailing these inspections must also be kept up to date.
DEQ-CFW 00068516

IN COMPLIANCE — The flaking process is controlled by bagfilters to reduce particulate matter emissions.
Visual inspections on these bagfilters are performed on a daily basis and annual inspections are performed as well.
Each facility can detail the amount of production for any given time period to meet the requirement of production
records. The most recent annual internal inspections were on 19 September 2009.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the flake dryer BS-C
shall not exceed 20% opacity. The Permittee shall record a monthly visible emissions evaluation (normal or
above normal) and maintain a logbook showing the results of each evaluation.
IN COMPLIANCE — During the inspection, I observed 0% VE. VE evaluations are performed daily (actually
once during every shift) despite the monthly requirement.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The Butacite
process shall not operate without odor control equipment. An objectionable odor shall not be detected from these
sources. Liquid flow rate for BCD-B 1 and BCD-B2 shall be at least 8 gallons per minute and the differential
pressure shall be less than 30 inches of water over a three-hour period.
IN COMPLIANCE — Odorous emissions from the butyraldehyde storage tank BS-A are controlled by a
condenser BCD -A. Odorous emissions from the flake reactor lines BS-B1 and BS-B2 are controlled by
packed -bed scrubbers BCD-B 1 and BCD-B2. The liquid flow rate was 10 gpm on records observed on the day of
the inspection. The differential pressure was generally below 2 inches of water. Alarms automatically sound if
the limits are exceeded. An odor was detected inside the Butacite building but no odor was noted outside the
facility.
40 CFR Part 60 Subpart KK: NATIONAL EMISSIONS STANDARDS FOR PRINTING AND
PUBLISHING INDUSTRY — The printing operation BS-D must have scrubber control with an overall organic
HAP control efficiency of at least 95 percent. The water flow rate in the scrubber must be greater than 6 gallons
per minute. The airflow rate must be greater than 63 standard cubic feet per minute and the fan exit velocity must
be greater than 3,950 feet per minute over a three-hour period. If startup, shutdown, maintenance procedures
differ from the SSMP, DAQ must be notified.
IN COMPLIANCE — The tinting operation was completely shut down and cleaned out on 30 December 2009.
On 31 December 2009, the scrubber was taken offline and a record of the shutdown was placed in file. The
facility has requested to have the unit removed from the permit during the renewal. The equipment is still located
on site but `abandoned in place.'
* Nafion® Process Area (all sources labeled with NS- and NCD-)*
The Nafion operation produces a variety of relatively uncommon monomer and polymer chemicals. Some of the
monomers are shipped offsite, while others are used onsite in the production of various polymers. The polymers are
shipped offsite or used onsite to produce Nafion® membrane material. A principal use of the membrane is in the
extraction / production of chlorine and sodium hydroxide at chlor-alkali plants. The two waste gas scrubbers located
at Nafion are used to control the emissions of various pollutants including hydrogen fluoride and acid fluorides.
During a last permit modification, the facility requested to add three existing sources to the permit: HFPO, Vinyl
Ethers North, and Vinyl Ethers South container decontamination processes. The facility received an enforcement for
operating these sources without an air permit. The Nafion process is subject to the Miscellaneous Organic NESHAP.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
—Particulate matter emissions from the Nafion process shall not exceed E=4.10*P°'67. The Permittee shall
maintain production records.
IN COMPLIANCE — Production records are available at each manufacturing facility.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the membrane coating
process NS-I shall not exceed 20% opacity. No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — During the inspection, I observed 0% VE,
DEQ-CFW 00068517

15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The Nafion process
shall not operate without odor control equipment.
IN COMPLIANCE — Odorous emissions from the Nafion process are controlled by two baffle -plate scrubbers
NCD-Hdrl and NCD-Hdr2. ' The control devices also have monitoring parameters that are continually recorded
and interlocked into the system. All the facility's monitoring parameters are recorded and viewable in an Aspen
program. A slight odor was detected close to the storage tanks, but, no noticeable odor was detected away from
the facility.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — VOC emissions from the Vinyl Ethers North process, NS-B, shall not exceed 68.9 TPY VOC.
The baffle -plate tower scrubbers must maintain a liquid flow rate of at least 7,000 kilograms per hour. The
Permittee shall keep monthly records of VOC emissions.
IN COMPLIANCE — The liquid flow rate set point is still set to exceed 12,000 kg/hr for Hdr-1 and 17,500 kg/hr
for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber and is interlocked to shut the
system down at 7,000 kg/hr and to alarm at 9,000 kg/hr. All reports show that the facility is not close to
exceeding these emissions limits. Records indicate a couple of instances when the flow was less than 7,000 kg/hr;
however, the facility had documentation that the unit was down. The facility also has backup historians in case
the primary historian malfunctions. VOC emissions are calculated using stack test results, material balances, and
flow rates / concentrations on a monthly basis. These records are submitted to Mike Johnson within 30 days of the
following month. Current records show a maximum of 50.3 TPY of VOCs.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the resin process NS-G shall not exceed the following: 40 TPY VOC. The
Permittee shall keep monthly records of VOC emissions.
IN COMPLIANCE — The current emissions are 25-31 tons per 12-month period.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the resin process NS-A shall not exceed the following: 85.3 TPY VOC. The
Permittee shall keep monthly records of VOC emissions.
IN COMPLIANCE — The current emissions 26.5-56.8 tons per 12-month period
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the HFPO container decontamination unit (NS-N) shall not exceed the
following: 40 TPY VOC. The Permittee shall keep monthly records of VOC emissions. The Permittee shall also
maintain records of dates each container is decontaminated and total mass of VOC removed from each container.
IN COMPLIANCE — The current emissions 0.4 tons per month. Currently the facility is loading product on the
material that remains in the cylinders, instead of purging them first. This is reducing emissions tremendously;
however, every product and/or all containers can't be handled this way.
40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP (MON) — The Nafion process
must comply with all provisions of this MACT. The MON requires 99% control efficiency for some Group 1
sources; however, DuPont determined that their sources are not subject to the stricter requirements of a control
device. The compliance date was 10 November 2006, but was extended by EPA to May 10, 2008.
IN COMPLIANCE — The scrubbers currently controlling the Naflon process (NCD-Hdrl and Hdr2) meet the
control efficiency requirement. The scrubbers were tested at 99.6% efficiency in August 2003. Initial notification
was received on 2 March 2004. No controls are required, however, for this facility based on HAP content, THE
values, and other various parameters. The facility does conduct LDAR monitoring.
DEQ-CFW 00068518

* Fluoro roducts Polymer Manufacturine Development Facility MDF/Teflon all sources labeled with FS-
and FCD-)*
The Fluoroproducts PMDF operation is a continuous process designed to produce fluoropolymer resins. The process
includes a wet scrubber and a fabric filter (125 ftz filter area). The final product is an extruded plastic pellet used to
make Teflon products. The emissions from the process include acid fluorides and hydrogen fluoride.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
—Particulate matter emissions from the PMDF shall not exceed E=4.10*P0'67. The Permittee shall maintain
production records. The Permittee shall perform a monthly visual and annual internal inspection on baghouse
FCD-A2. A logbook detailing these inspections must also be kept up to date. The facility must report
semi-annually a summary report of monitoring and recordkeeping activities.
IN COMPLIANCE — The PMDF is controlled by bagfilters to reduce particulate matter emissions. Visual
inspections on these bagfilters are performed on a monthly basis and annual inspections are performed once a
year.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the PMDF shall not
exceed 20% opacity. No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — During the inspection, I observed 0% VE.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The PMDF shall
not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE — The scrubber is only used during purge for maintenance activities and is used to control
acid fluorides. During the inspection, I did not observe any odor.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the PMDF shall not exceed the following:. 40 TPY VOC. The Permittee shall
keep monthly records of VOC emissions. Semi-annual reporting is also required for monthly emissions (17
month period).
IN COMPLIANCE — All reports show that the facility is well below these emissions limits. The current
emissions are approximately 22-30 TPY.
* Ammonium Perfluorooctanate (APFO) Manufacturing Facility (all sources labeled with AS- and ACD-)*
The ammonium perfluorooctanoate (APFO) process began operation in December of 2002. The APFO reaction process
uses perfluorooctanoate (brought in by truck in its iodide/salt form) reacted with sodium hydroxide (stored in totes) to
form the acid fluoride. The acid fluoride is then reacted with ammonia to produce the ammonium salt. Fuming sulfuric
acid (oleum) is received by truck and used as a solvent in the process. Currently, APFO and the associated
perfluorooctanoic acid (PFOA), also known as C8, are not regulated as toxic or hazardous air pollutants. However, the
EPA is currently reviewing the chemical with the possibility of its designation in the future as a regulated pollutant.
However, due to historical pollution and health effects concerns and recent controversy regarding the Dupont facility in
West Virginia, and the recent activities by the U.S. EPA to develop and review toxicity data for this chemical, the DAQ
file includes several documents and articles related to APFO, PFOA, or C8. The APFO process is subject to the 112(r)
chemical accident prevention program for oleum. By 2010, the facility is planning to manufacture 50% APFO and 50%
of the new product at this manufacturing facility. DuPont made a decision to eliminate APFO by 2015.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The APFO facility
shall not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE — The APFO process is controlled by scrubbers. During the inspection, I did not
detect an odor near the facility.
15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS — Emissions from the APFO facility shall
be controlled by a wet scrubber. The liquid flow rate in the packed bed section shall be at least 30 gallons per
minute and the differential pressure across the bed shall be a maximum of 12 inches of water. An alarm is
required for the pressure monitoring. All inspections shall be kept in a logbook.
DEQ-CFW 00068519

IN COMPLIANCE — The scrubber is interlocked so that the system will shut down, almost instantaneously, if
the parameters are exceeded. The facility will go into shutdown mode if the two hour average is less than 30 gpm
or pressure is 5 inches of water. APFO is a surfactant; therefore, the DP increases occasionally due to `suds' in the
scrubber.
Results of the stack tests in March 2006 and April 2006 show that approximately 62 lbs of PFOA is emitted from
this facility per year. To further reduce these emissions, the facility added a HEPA filter to control PFOA (a
particulate) from the building exhaust. The building exhaust appears to be the source of most (80-90%) of these
emissions.
* Wastewater Treatment Area (all sources labeled with WTS- and WTCD-)*
For the wastewater treatment operations, the Title V permit specifies two rotary sludge dryers controlled by an
impingement -type wet scrubber with mist eliminator (29 gallons per minute dilute potassium hydroxide solution).
The Miscellaneous Organic NESHAP (MON) will also address emissions from wastewater. With respect to quantity
of emissions, methanol is the most significant air pollutant from the wastewater treatment operation.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The wastewater
treatment facility shall not operate without management plan or odor control equipment. An objectionable odor
shall not be detected from these sources. The sludge dryers shall be controlled by a caustic injection scrubber. An
I&M logbook is also required for the scrubber.
IN COMPLIANCE — Odorous emissions from the sludge dryers are controlled by a scrubber utilizing potassium
hydroxide solution. Wastewater treatment odors were not noted at boundary lines. The sludge dryers are located
inside a building. The facility keeps maintenance records for the scrubber in their electronic maintenance
program. The most recent inspection was 29 November 2008.
* Temporary Boiler (PS -Temp)*
This boiler is permitted for Natural Gas/No. 2 fuel oil and is brought on -site on an `as needed' basis. The boiler was on
site from March 2008 through February 2009.
15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
—Particulate emissions from the temporary boiler shall not exceed 0.24261bs/mmBtu.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.024 lbs/mmBTU.
15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS (Subpart De) — The sulfur content
of all received fuel oil shall not exceed 0.5% sulfur by weight. The Permittee shall maintain fuel certifications and
monthly amounts of fuel burned. The facility must provide notification when the unit is brought on -site and
operational. The facility must also conduct Method 9 testing and submit associated protocol, etc.
IN COMPLIANCE — Fuel certs indicate fuel oil is less than 0.5% sulfur by weight; actually most is 15 ppm
sulfur.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the temporary boiler PS -Temp shall not exceed the following: 40 TPY SO2.
The Permittee shall keep monthly records of the amount of fuel combusted. Semi-annual reporting is also
required for monthly combustion and all deviations (17 month period).
IN COMPLIANCE — Emissions were approximately 0.5 tons per year.
DEQ-CFW 00068520

* SentryGlas® Plus Manufacturing Facility (SGS-A)*
The SentyGlas plant began operation in 2005 and manufactures rigid plastic glass laminate. This product is similar to
the Butacite product; however, this material is much stronger, even explosion proof. The facility has a crushing
system used to crush the pelletized raw material. Crushed material is sent to a silo, which is controlled by a baghouse
that vents indoors. The entire process takes place in a clean room to avoid contamination by lint, dirt, etc.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the SentryGlas
manufacturing facility shall not exceed 20% opacity, No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — During the inspection, we observed 0% VE.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The SentryGlas
manufacturing facility shall not operate without implementing a management plan or without odor control
equipment.
IN COMPLIANCE —No odors were noted surrounding this facility.
* Polyvinyl Fluoride (PVF) Polymer Manufacturing Facility (FS-B & FS-C)*
This facility started operation in the latter portion of September 2007. The facility began construction on the second
facility (FS-C); however, it is not expected to be operational until 2010. Vinyl fluoride reacts in a continuous reactor
to form crude polyvinyl fluoride (PVF). The PVF is separated, sent through a batch filter press then a tubular drier.
The final product is PVF solid powder. The PVF produced at this facility is used for photovoltaic panels and aircraft
interiors.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES —
Particulate emissions from the PVF facility shall not exceed 4.1 * P°'67. The Pernttee shall maintain production
records of the process rates in tons per hour.
IN COMPLIANCE — The process control system records process rates, and we did not notice any emission of
particulates.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the PVF facility shall
not exceed 20% opacity. Once each month, the Permittee shall observe the emission release point of the baghouse
for any visible emissions above normal.
IN COMPLIANCE — During the inspected we observed 0% VE. The baghouse exhaust point is paired with an
exhaust from the steam tank. .
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The PVF facility
shall not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE — During the inspection, no odor was detected.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the two PVF facilities (FS-B & FS-C) shall not exceed the following: 40 TPY
VOC. The Permittee shall keep monthly records of VOC emissions calculated by methods in permit.
Semi-annual reporting is also required for monthly emissions (17 month period).
IN COMPLIANCE — The facility is not required to maintain this data yet since the second facility has not yet in
operation. The potential for each individual facility is less than 40 tons per year.
* Facility -Wide Tonics Limits*
15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS — The Permittee shall maintain records of
production rates, throughputs, material usage, excess emissions, and control equipment failures.
IN COMPLIANCE —TAP reports are submitted quarterly and show emissions well below the 2D .1100 limits.
DEQ-CFW 00068521

15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS — The Permittee shall emit less than the
limits listed in the permit for BF from high dispersion stacks and from all other sources. The Permittee shall also
report in a quarterly report, all TPER exceedances, the maximum 1-hour emission rate and the maximum 24-hour
emissions rate. The liquid flow rate in the Naflon scrubbers shall be at minimum 7,000 kg/hr. The Permittee shall
maintain a logbook of all inspection and maintenance activities on the applicable scrubber.
IN COMPLIANCE — The liquid flow rate set point is still set to exceed 12,000 kg/hr for Hdr-1 and 17,500 kg/hr
for Hdr-2. The scrubber utilizes a potassium hydroxide solution in the scrubber. The electronic I&M logbook
appeared to be complete. TAP reports are submitted quarterly and show emissions well below the 2D .1100
limits.
15A NCAC 2D .0541 CONTROL OF EMISSIONS FROM ABRASIVE BLASTING — Abrasive blasting
shall take place inside a building unless the item exceeds eight feet in length or is permanently situated at an
outside location. Fugitive emissions shall not migrate beyond the property boundaries.
IN COMPLIANCE — The facility now has an abrasive blasting building in which the sand blasting occurs.
6) CHEMICAL ACCIDENT PREVENTION AND 112(r): The Nafion process is subject to 112(r) for sulfur trioxide,
tetrafluoroethylene, and hydrogen chloride. The APFO process is subject to-1 12(r) for oleum. The facility submitted
the initial Risk Management Plan to the U.S. EPA in June 1999. In addition, the facility is subject to the OSHA
Process Safety Management Standard.
7) COMPLIANCE HISTORY: On 6 January 2009, the facility was issued a NOV/NRE for operating three sources
(container decontamination processes) without an air permit. The facility has been fined and has submitted their
payment. In November 2007, the facility was issued a Notice of Violation (NOV) for failure to submit operating
permit application (Part 2) in a timely manner. The facility was issued a compliance addition information (CAI) letter
in August 2007 concerning the permit applicability of a paint operation and shot blast operation as well as abnormal
visible emissions from the boilers noted during two recent site visits.
8) CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 12 May 2009
inspection, DuPont Company — Fayetteville Works appeared to be operating in compliance with the requirements
outlined in their current air permit, 03735T34.
CTR
cc:
RCO Central Files (yellow)
FRO Facility Files (blue)
Inspector (original)
DEQ-CFW 00068522