DEQ-CFW_00068537

4M.
scomm.
DENR
REGIONAL
Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
February 14, 2008
SUBJECT: Notification of Past Deviations
Refrigerant Requirements (Stratospheric Ozone and Climate Protection)
DuPont Company - Fayetteville Works
North Carolina Air Permit No. 03735T32
Fayetteville, NC, Bladen County 06/09-00009
Dear Mr. Vozzo:
This letter is a notification of the discovery of past deviations with the refrigerant requirements
of Part I Section 3(CC)(3) of the referenced Title V air permit.
The DuPont Company — Fayetteville Works has been active in installing an electronic historian
for the refrigerant recordkeeping requirements of 40 CFR 82 Subpart F. While entering past
information into this historian, it was discovered that there were six (6) instances between 2004
and 2006 where a required refrigerant leak repair was completed, but the results of the initial and
follow-up verification tests were not documented as specified in Part 82.166(n)(3).
As background, Part 82 Subpart F requires that industrial process refrigeration equipment
normally containing more than fifty (50) pounds of refrigerant must have leaks repaired if the
appliance is leaking at a rate such that the loss of refrigerant will exceed 35 percent of the total
charge during a 12-month period. It is the practice of this site that all leaks of refrigerant be
promptly repaired, regardless of whether the calculated leak rate requires the repair or not.
E.I. du Pont de Nemours and Company
DEQ-CFW 00068537

Mr. Steven F. Vozzo
NCDENR — DAQ
February 14, 2008
Page 2 of 2
The refrigeration technician who was involved with all six of those deviation affirms that it was
his standard work practice following a repair to first pull a full vacuum on the refrigeration
equipment's system as an initial verification of the repair. If the initial vacuum test passed, the
refrigerant was charged into the appliance, it was operated at normal operating characteristics
and conditions, and a follow-up verification test was performed using both a halon detector and
soap bubbles. However, he did fail to document the results of this verification testing at the time
of the repair.
The following are the dates and refrigeration machines involved in the deviations:
DATE
LOCATION
MANUF
MODEL#
SERIAL #
04/20/2004
Butacite Mfg Roof
York
IHICA60046A
NPPM15397
05/18/2004
Butacite Overhead Whse for
Larkin
CU-0760-HZ
AP88-90831-A2
cooler condenser (Unit #5)
10/09/2005
Nafion Lab Air Handler
Trane
SAHCC4040210
J93J72167
(Roof)
C47D 1 A01 EGRT
02/01/2006
Butacite Overhead Whse for
Larkin
CU-0760-HZ
AP88-90831-A3
cooler condenser (Unit #4)
02/13/2006
Butacite Overhead Whse for
Larkin
CU-0760-HZ
AP88-90831-Al
cooler condenser (Unit #6)
02/28/2006
Butacite Overhead Whse for
Heatcraft
CDH2O00D6
A95F00039
cooler condenser (Unit #8)
Based on guidance from the Division of Air Quality's Fayetteville Regional Office, DuPont will
not be submitting revised annual compliance certifications for these past deviations.
If you have any questions regarding this letter, or if you need additional information, please call
me at 678-1155.
Environmental Manager
cc: Ms. Christy T. Richardson, NCDENR Division of Air Quality, FRO
DEQ-CFW 00068538