DEQ-CFW_00071504

F- WA FORM AA
f-
NCDENR ADMINISTRATIVE APPLICATION (General Information)
REVISED 5/8/13 NCDENR/Division of Air Quality -Application for Air Permit to Construct/Operate FAA
GENERAL INFORMATION
Legal Corporate/Owner Name: I E. I. du Pont de Nemours and Company, Inc.
Site Name: FDuPont Company - Fayetteville Works APR 2 /
Site Address (911 Address) Line 1: 22828 NC Highway 87 West
Site Address Line 2:
City: Fayetteville State: IN.C. Zip Code: 28306-7332 — 1 County: Biaden
CONTACT INFORMATION
Permit/ Technical Contact: IMichael E. Johnson I Facility/Inspection Contact: IMichael E. Johnson
Name/Title: Environmental Manager Name/Title: Environmental Manager
Mailing Address Line 1: 122828 NC Highway 87 West Mailing Address Line 1: 22828 NC Highway 87 West
Mailing Address Line 2: 1 Mailing Address Line 2:
City: Fayetteville State: NC Zip Code: 28306-7332 City: Fayetteville State:INC Zip Code: 28306-7332
Ph. No. (area code) [phone] J Fax No. (area code) [phone] Ph. No. (area code) [phone] Fax No. (area code) [phone]
Lail Address: [e-mail] Email Address: [e-mail]
Responsible Official/Authorized Contact.'I Ellis H. McGaughy j Invoice Contact: (Michael E. Johnson
Name/Title: 1piant Manager Name/Title: Environmental Manager
Mailing Address Line 1: 122828 NC Highway 87 West Mailing Address Line 1: 122828 NC Highway 87 West
Mailing Address Line 2: 1 Mailing Address Line 2:
City: IFayetteville State: NC Zip Code: 28306-7332 7 City: I Fayetteville State: NC Zip Code: 28306-7332
Ph. No. (area code) [phone] Fax No. (area code) [phone] Ph. No. (area code) [phone] Fax No. (area code) [phone]
Email Address: [e-mail] Email Address: [e-mail]
APPLICATION IS BEING MADE FOR
❑ Renewal (non -Title V) ® Renewal Title V ❑ Name Change ❑ Ownership Change ❑ Administrative Amendment
FACILITY CURRENT CLASSIFICATION (Check Only One)
❑ Small ❑ Synthetic Minor I ® Title V
FACILITY (Plant Site) INFORMATION
Describe nature of (plant site) operation(s):
Manufacturer of chemicals, plastic resins, plastic sheeting, and plastic film.
Primary SIC/NAICS Code: 1326113 Current/Previous Air Permit No. 103735T38 Expiration Date: 101-31-2015 J
Facility Coordinates: Latitude: 134.843934 —1 Longitude:-78.836834 1 Facility ID No. 10900009 —1
Does this application contain confidential data? YES NO_ "`If yes, please contact the DAQ Regional Office prior to submitting Us application.— (See Instructions)
PERSON OR FIRM THAT PREPARED APPLICATION
Person Name: (Michael E. Johnson Firm Name:
Mailing Address Line 1: 22828 NC Highway 87 West Mailing Address Line 2: 1
City: Fayetteville I State: NC Zip Code:I County:
Ph. No. ( area code) [phone] � Fax No. (area code) [phone] Email Address:
SIGNATURE OF RESPONSIBLE OFFICIAL/AUTHORIZED CONTACT
Name (typed): Ellis H. McGaughy Title: giant Manager
X Signature (Blue Ink):
Date:
Additional Sheets As Necessary Pagel of 2
DEQ-CFW 00071504

FORM AA (continued, page 2 of 2)
ADMINISTRATIVE APPLICATION
RFMAM s/s/la Application for Air Permit to Construct/Operate
AA
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 an air permit since the last permit was issued.
Is your facility subiect to 40 CFR Part 68 "Prevention of Accidental Releases"- Section 112 ( 0 of the Clean Air Act? ❑ Yes ❑ No
If yes, have You already submitted a Risk Management Plan (RMP) to EPA? ❑ Yes ❑ No Date Submitted
Did you attach a current emissions inventory? ❑ Yes ❑ 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 I DuPont Company - Fayetteville Works (Company Name)
hereby formally requests renewal of Air Permit No. 103735T38 (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 2Q .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 describe
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 There have been no
modifications 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):
Date:
New Facility Name:
Former Facility Name:
Signature of Former (Seller) Responsible Official/Authorized Contact:
Name (typed or print):
Title:
X Signature (Blue Ink):
Date: I
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 00071505

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 A2
EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted
EMISSION SOURCE
ID NO.
EMISSION SOURCE
DESCRIPTION
CONTROL DEVICE
ID NO.
CONTROL DEVICE
DESCRIPTION
{Eq pment
To Be�A"Db,Eb By Th+s Apica ion N
w .Pre ions
y eem-_ ed, or Rep a Ili •)
Exlstmg PermittedEquipment Tole;MODIFIED
ByThIsA
,` Itcation . ,
.,,� �,,.,���d�•-;�3�f� �Equipment�T�o�'�Be�D,.�ELE�T.tEDByTlisAppl�cat�on�
'
'I12/r A'PPL�IC4BILTY INFORIVIION'�-�
i
A3
#.„l3 z eaa +r ga __AT . + `
Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases" - Section 112(r) of the Federal Clean Air Yes No ❑
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 ❑x No ❑ Specify required RMP submittal date: June 30, 1999
If submitted, RMP submittal date: June 8, 1999 RMP resubmitted on Feb. 1, 2011
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 00071506

FORM E5
TITLE V COMPLIANCE CERTIFICATION (Required)
Revised 01/01/07 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate E5
In accordance with the provisions of Title 15A NCAC 2Q .0520 and .0515(b)(4),
the responsible company official of,
SITE NAME:
DuPont Company - Fayetteville Works
SITE ADDRESS:
22828 NC Highway 87 West
CITY, NC:
Fayetteville, NC 28306-7332
COUNTY:
Bladen
PERMIT NUMBER:
03735T38
CERTIFIES THAT (Check the appropriate statement):
❑x The facility is in compliance with all applicable requirements
❑ 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.
Date: Zrl -/�; ZD l �4
Signature of r5sponsi
I (REQUIRED, USE BLUE INK)
Ellis H. McGaughy, Plant Manager
Name, Title of- responsible company official (Type or print)
h Additional Sheets As Necessary
DEQ-CFW 00071507

NCDENR
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 1 of 8
FORM E6
For CAM -affected emission units, the applicant must submit additional information in the form of a CAM Plan as required under 40 CFR 64.
For information about the CAM rule and this form, please refer to 40 CFR 64 and 15A NCAC 2D .0614.
Additional information (including guidance documents) may be found at http:l/www.epa.gov/ttn/emc/cam.html and http://dag.state,nc.us/enf/cam/
SOURCE INFORMATION
1. Facility Name: DUPONT COMPANY — FAYETTEVILLE WORKS
2. Permit No.: 03735T38
3. Date Form Prepared: APRIL 4, 2014
BASIS OF CAM SUBMITTAL
4. Mark the appropriate box below as to why this CAM Plan is being submitted as part of this application:
® Renewal Application: ALL Emission Units (Pollutant Specific Emission Units (PSEUs) considered separately with respect to EACH regulated air
pollutant) for which a CAM Plan has NOT yet been approved needs to be addressed in this CAM Plan submittal.
See Renewal Procedures per 15A NCAC 2Q .0513.
❑ Initial Application (Submitted after 4120/98): Only large PSEUs (PSEUs with potential post control device emissions of an applicable regulated air
pollutant that are equal to or greater than major source threshold levels) need to be addressed in this CAM Plan submittal.
See Initial Application Procedures per 15A NCAC 2Q .0505(1).
❑ Significant Modification to Large PSEUs: Only large PSEUs (PSEUs with potential post control device emissions of an applicable regulated air
pollutant that are equal to or greater than major source threshold levels) being modified after 4/20/98 need to be addressed in this CAM Plan submittal.
For large PSEUs with an approved CAM Plan, only address the appropriate monitoring requirements affected by the significant modification.
See Significant Modification Procedures per 15A NCAC 2Q .0516.
CAM APPLICABILITY DETERMINATION
5. To determine applicability, a PSEU must meet ALL of the following criteria (If not, then the remainder of this form need not be completed):
A. The PSEU is located at a major source.
B. The PSEU is subject to an emission limitation or standard for the applicable regulated air pollutant that is NOT exempt;
List of EXEMPT Emission Limitations or Standards below OR as provided in 15A NCAC 2D .0614(b)(1):
• NSPS (40 CFR Part 60) or NESHAP (40 CFR Parts 61 and 63) proposed after 11/15/1990.
• Stratospheric ozone protection requirements.
• Acid Rain program requirements.
• Emission limitations or standards for which a Title V permit specifies a continuous compliance determination method, as defined in the
CAM rule (40 CFR 64.1), Continuous Compliance Determination Method.
• An emission cap that meets the requirements specified in 40 CFR 70.4(b)(12).
If the PSEU is subject to both, Exempt and Not Exempt emission standards for the same pollutant, then the facility is required to determine the
CAM applicability for Not Exempt emission standards.
C. The PSEU uses an add -on control device to achieve compliance with an emission limitation or standard;
D. The PSEU has potential pre -control device emissions of the applicable regulated air pollutant that are equal to or greater than major source
threshold levels; and
E. The PSEU is NOT an exempt backup utility power emissions unit that is municipally owned and appropriately documented as provided in 15A
NCAC 2D .0614(b)(2).
DEQ-CFW 00071508

A ILF"A
NCDENR
TJ
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 2 of 8
FORM E6
BACKGROUND DATA AND INFORMATION
6. Complete the following table for ALL PSEUs that need to be addressed in this CAM Plan submittal. This section is to be used to provide
background data and information for each in order to supplement the submittal requirements specified in 40 CFR 64.4.
If additional space is needed, please attach and label as appropriate.
PSEU
Designation
PSEU
Description
Pollutant
Control Device
a Emission
Limitation OR
Standard
b Monitoring Requirement
BS-C
BUTACITE® FLAKE
DRYER
PARTICULATE
MATTER
CYCLONE
(ID No. BCD-C1)
AND
FABRIC FILTER
(ID No. BCD-C2)
NOT TO EXCEED
E = 4.10 x P 067
PER
15A NCAC 2D .0515
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
BS-C
BUTACITE® FLAKE
DRYER
MISSILE
EMISSIONS
CYCLONE
(ID No. BCD-Cl)
AND
FABRIC FILTER
ID No. BCD-C2
NOT TO EXCEED
20 PERCPER OPACITY
15A NCAC 2D .0521
A MONTHLY VISUAL
OBSERVATION OF THE EMISSION
POINT OF THE FABRIC FILTER
FOR ANY VISIBLE EMISSIONS
ABOVE NORMAL
a Indicate the emission limitation or standard for any applicable requirement that constitutes an emission limitation, emission standard, or standard of
performance. Examples of emission limitations or standards may include a permitted emission limitation, applicable regulations, work practices, process
or control device parameters, or other forms of specific design, equipment, operational or maintenance requirements.
b Indicate the monitoring requirements for the control device that are required by an applicable regulation or permit condition.
DEQ-CFW 00071509

Compliance Assurance Monitoring (CAM) Plan
Aye
North Carolina Department of Environment and FORM E6
NCDE14R Natural Resources / Division of Air Quality (DAQ)
Page 3 of 8
a CAM MONITORING APPROACH CRITERIA
7. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section
may be copied as needed for each PSEU. This section is to be used to provide monitoring data and information for EACH indicator selected
for EACH PSEU in order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being
selected for a PSEU or if additional space is needed, attach and label with the appropriate PSEU designation, pollutant, and indicator Nos.
6a. PSEU Designation: BS•C
6b. Pollutant:
6c. b Indicator No.1:
6d. b Indicator No. 2:
7a. General Criteria
PARTICULATE
MONTHLY VISUAL INSPECTION OF
Describe the monitoring approach used to
MATTER
DUCTWORK
measure the indicators.
.Establish the appropriate indicator range or
IF POWDER Is FOUND OUTSIDE of THE
the procedures for establishing the indicator
range which provides a reasonable
DUCTWORK, IT WOULD BE A DUCTWORK
assurance of compliance
-.--._..__...._..__...___-.....-.-_............___-_-------..__._.....__.......__._.__......__.__._
.............._........_____.._..._.....-._.......... _...
FAILURE
............ _-..._._..__... ............. -.-....._._.....___.._................
d Provide Quality Improvement Plan (QIP)
TWO OR MORE DUCTWORK FAILURES IN
Threshold levels:
A 12-MONTH PERIOD
7b. Performance Criteria
EACH MONTHLY VISUAL INSPECTION
Provide the Specification for Obtaining
Representative Data (Such as detector
WOULD QUALIFY AS REPRESENTATIVE
location and installation specificationsj:
................... _..... ... _... ................... _......... _....
DATA
.......... _.............. _.._..... ....... .__._...._._... _............ - _._......
_.-_ ....._--._.........._....._.........---........._..---.-___..,_----
Provide Verification Procedures, including
manufacturer's recommendations to confirm
NOT APPLICABLE
the Operational Status of the monitoring:
......._....... __.... ---- _......... .....
._.-_-_-..___._.... __........... _..... __...__._.�.
Provide Quality Assurance and Quality
Control (QAIQC) Practices that are
adequate to ensure the continuing validity of
NOT APPLICABLE
the data, considering manufacturer's
recommendations:
__.._.__......._......._....._._......._...._......................... ._..... _..... ........ _....... _.............. ._.._...........
......... _.-....-..................... ........... _..... ....
........... __............ ..._......... __.................... -_ .. _.......... _. _...
_...
e Provide the Monitoring Frequency:
MONTHLY
Provide the Data Collection Procedures that
RESULTS OF THE MONTHLY VISUAL
will be used:
INSPECTIONS ARE DOCUMENTED
_._..............................._-.........
Provide the Data Averaging Period for the
.
.-.._...................—_--........_..._.........
._....
---.__............_..._.... ..... ._......_-..-.. _-----•--- _ _
...._....._..__.....__...__..._..._... ...
.
purpose of determining whether an
NOTAPPLICABLE
excursion or exceedance has occurred:
a If a Continuous Emission Monitoring System (CEMS), Continuous Opacity Monitoring System (COMS), or Predictive Emission Monitoring System (PEMS)
is used, then this section need not be completed ONLY for the CEMS, COMS, or PEMS, EXCEPT that the Special Criteria Information of 40 CFR 64.3(d)
must be provided. Special Criteria Information may be provided on a separate sheet.
b Describe all indicators to be monitored which satisfy 40 CFR 64.3(a). Indicators of emission control performance for the control device and associated
capture system may include measured or predicted emissions (including visible emissions or opacity), process and control device operating parameters
that affect control device (and capture system) efficiency or emission rates, or recorded findings of inspection and maintenance activities.
Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly different operating conditions,
expressed as a function of process variables, expressed as maintaining the applicable indicator in a particular operational status or designated condition,
or established as interdependent between more than one indicator. In addition, unless specifically stated otherwise by an applicable requirement, the
owner or operator shall monitor the indicators to detect any bypass of the control device (or capture system) to the atmosphere.
d The QIP threshold is based on the number of excursions identified in a reporting period. (Example: If the historical monitoring data for a facility indicates
that the indicator range was exceeded 10 times in a 6-month period, the threshold could be established at no more than 10 excursions outside the
indicator range during a 6-month reporting period.) The threshold levels also could be established based on the duration of excursions as a percentage of
operating time.
e At a minimum, the owner of a large PSEUs must collect four or more data values equally spaced over each hour and average the values. All other PSEUs
must collect data at least once per 24-hour period or possibly more to provide reasonable assurance of compliance over the anticipated range of
operating conditions.
DEQ-CFW 00071510

NCDENR'
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 4 of 8
FORM E6
RATIONALE AND JUSTIFICATION
8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may
be copied as needed. Use this section to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet
the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional space
is needed, attach additional sheets and label with the appropriate PSEU designation, pollutant, and indicator Nos.
8a. PSEU Designation: BS-C
8b. Pollutant: PARTICULATE MATTER
9. INDICATORS and the MONITORING APPROACH: Provide the rationale and justification for the selection of the indicators and the monitoring approach
used to measure the indicators. Also provide any data supporting the rationale and justification. Explain the reasons for any differences between the
verification of operational status or the quality assurance and control practices proposed and the manufacturer's recommendations. (If additional space
is needed, attach and label with the appropriate PSEU designation and pollutant):
THE PARTICULATE MATTER IS CONTROLLED VIA A CYCLONE SEPARATOR FOLLOWED BY A FABRIC FILTER BAGHOUSE. THE DUST LADEN AIR IS CONVEYED THROUGH
DUCTWORK. IF POWDER IS FOUND OUTSIDE OF THE DUCTWORK, IT WOULD BE AN INDICATION OF A DUCTWORK FAILURE AND A POSSIBLE EMISSION OF PARTICULATE
MATTER, THE MONTHLY VISUAL INSPECTION OF THE DUCTWORK FOR LEAKS WOULD MINIMIZE THE POSSIBILITY OF THE INCIDENCE OF PARTICULATE MATTER
EMISSION.
10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges. The rationale and justification shall indicate how
EACH indicator range was selected by either a Compliance or Performance Test, a Test Plan and Schedule, or by Engineering Assessments.
Depending on which method is being used for each indicator range, include the specific information required below for that specific indicator range. (If
additional space is needed, attach and label with the appropriate PSEU designation and pollutant):
• COMPLIANCE or PERFORMANCE TEST (Indicator ranges determined from control device operating parameter data obtained during a
compliance or performance test conducted under regulatory specified conditions or under conditions representative of maximum potential
emissions under anticipated operating conditions. Such data may be supplemented by engineering assessments and manufacturer's
recommendations). The rationale and justification shall include a summary of the compliance or performance test results that was used to
determine the indicator range and documentation indicating that no changes have taken place that could result in a significant change in the control
system performance or the selected indicator ranges since the compliance or performance test was conducted and approved by DAQ.
• TEST PLAN AND SCHEDULE (Indicator ranges will be determined from a proposed implementation plan and schedule for installing, testing, and
performing any other appropriate activities prior to use of the monitoring). The rationale and justification shall include the proposed
implementation plan and schedule that will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan, but in no
case shall the schedule for completing installation and beginning operation of the monitoring exceed 180 days after approval.
• ENGINEERING ASSESSMENTS (Indicator ranges or the procedures for establishing indicator ranges are determined from engineering
assessments and other data, such as manufacturer's design criteria and historical monitoring data, because factors specific to the type of
monitoring, control device, or PSEU make compliance or performance testing unnecessary). The rationale and justification shall include
documentation demonstrating that compliance testing is not required to establish the indicator range.
RATIONALE AND JUSTIFICATION:
THE RATIONALE AND JUSTIFICATION FOR THE SELECTION OF THE INDICATOR RANGES OF THE MONTHLY VISUAL INSPECTION WAS VIA AN ENGINEERING ASSESSMENT.
THE BASIS FOR THE ASSESSMENT INCLUDES THE FACT THAT THE DUCTWORK HAS NOT HAD A LEAK IN AT LEAST THE PAST FIVE (5) YEARS.
Mail Completed Application to:
Division of Air Quality (DAQ), Permitting Section
1641 Mail Service Center
Raleigh, North Carolina 27699-1641
DEQ-CFW 00071511

e��
NCDENR
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 5 of 8
FORM E6
a CAM MONITORING APPROACH CRITERIA
8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section
may be copied as needed for each PSEU. This section is to be used to provide monitoring data and information for EACH indicator selected
for EACH PSEU in order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being
selected for a PSEU or if additional space is needed, attach and label with the appropriate PSEU designation, pollutant, and indicator Nos.
6a. PSEU Designation: BS-C
6b. Pollutant:
6c. b Indicator No.1:
6d. b Indicator No. 2:
7a. General Criteria
PARTICULATE
ANNUAL INTERNAL INSPECTION OF
Describe the monitoring approach used to
MATTER
THE BAGFILTER'S STRUCTURAL
measure the indicators.
INTEGRITY
_ __ _..._.._._......._._.__.
_..._.._._...__.._._......_.....__.__.._......-...-__......._..___._.........__......-__......_._......_........__......_._.___..._.....__............_._......
c Establish the appropriate indicator range or
___.__.........
.-_.._............__._........__._.. _--...... _ __ —� __........._.___._
ANY PROBLEMS FOUND AS A RESULT OF
..............__..._......-.._._-
the, procedures for establishing the indicator
THE BAGFILTER'S INTERNAL INSPECTION
range which provides a reasonable
ARE CORRECTED PRIOR TO RETURNING
assurance of compliance
THE BAGFILTER TO SERVICE.
_ ...__._....__........_..._._....._.. _....._
...._......_........_....__....__........__..............__._......._.__....._._...__......................._.._........._..._.........._....._.._..._...........................__._.........._._....._......_._......_......_...........__._.._..._.__..___.__._._..._-....
_..-_..__..__.._._....._..._........
d Provide Quality Improvement Plan (QIP)
FAILURE TO CORRECT ANY PROBLEMS
Threshold levels:
FOUND DURING THE INSPECTION
7b. Performance Criteria
EACH ANNUAL INTERNAL INSPECTION
Provide the Specification for Obtaining
Representative Data (Such as detector
WOULD QUALIFY AS REPRESENTATIVE
location and installation_specifcafionsl: _
............... .._......... _..... _ ... ..............
DATA
..... ...... _.......... -_-__......._._.._.............. .._........ _......... _._.._..................... _..._..
—_.......... ... ................ ...... _.............
Provide Verification Procedures, including
manufacturer's recommendations to confirm
NOT APPLICABLE
_ the Operational Status of the monitoring_ _
_.__....._..............._......__...___.__.._........._..__
.._-......_....._...__—_--___._.._._....._..__._._............._..__.______......_....__
________.__.__.._..._...___._.__..._..............._ ... ........ ...._... ._........... _
Provide Quality Assurance and Quality
Control (QA/QC) Practices that are
adequate to ensure the continuing validity of
NOT APPLICABLE
the data, considering manufacturer's
recommendations:
...._....._......_..................._._...... _.._....I......___.__...... _...... _......... _... ...................... _.......... _._.
................. _-....... _...... .__... ._................. ... ._..........
.-__..................... __..._ _...... ............ .
e Provide the Monitoring Frequency:
ANNUAL
Provide the Data Collection Procedures that
RESULTS OF THE ANNUAL INTERNAL
will be used:
INSPECTION ARE DOCUMENTED
_.__...._............._..._.............._-..___..........._.._._.....___......_...____.._._.__......._.._...__._.___
Provide the Data Averaging Period for the
_........_........._..._____......__..............______....._._......._
.-___.._....__._._............_....__.__......._._.........._..__...__._...._._........_..-._.__..........___.__..____......____..__....._..........._-....._......__.._
purpose of determining whether an
NOT APPLICABLE
excursion or exceedance has occurred:
a If a Continuous Emission Monitoring System (CEMS), Continuous Opacity Monitoring System (COMS), or Predictive Emission Monitoring System (PEMS)
is used, then this section need not be completed ONLY for the CEMS, COMS, or PEMS, EXCEPT that the Special Criteria Information of 40 CFR 64.3(d)
must be provided. Special Criteria Information may be provided on a separate sheet.
b Describe all indicators to be monitored which satisfy 40 CFR 64.3(a). Indicators of emission control performance for the control device and associated
capture system may include measured or predicted emissions (including visible emissions or opacity), process and control device operating parameters
that affect control device (and capture system) efficiency or emission rates, or recorded findings of inspection and maintenance activities.
Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly different operating conditions,
expressed as a function of process variables, expressed as maintaining the applicable indicator in a particular operational status or designated condition,
or established as interdependent between more than one indicator. In addition, unless specifically stated otherwise by an applicable requirement, the
owner or operator shall monitor the indicators to detect any bypass of the control device (or capture system) to the atmosphere.
d The QIP threshold is based on the number of excursions identified in a reporting period. (Example: If the historical monitoring data for a facility indicates
that the indicator range was exceeded 10 times in a 6-month period, the threshold could be established at no more than 10 excursions outside the
indicator range during a 6-month reporting period.) The threshold levels also could be established based on the duration of excursions as a percentage of
operating time.
e At a minimum, the owner of a large PSEUs must collect four or more data values equally spaced over each hour and average the values. All other PSEUs
must collect data at least once per 24-hour period or possibly more to provide reasonable assurance of compliance over the anticipated range of
operating conditions.
DEQ-CFW 00071512

A��
NCDENR
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 6 of 8
FORM E6
RATIONALE AND JUSTIFICATION
8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may
be copied as needed. Use this section to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet
the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional space
is needed, attach additional sheets and label with the appropriate PSEU designation, pollutant, and indicator Nos.
8a. PSEU Designation: BS-C
8b. Pollutant: PARTICULATE MATTER
9. INDICATORS and the MONITORING APPROACH: Provide the rationale and justification for the selection of the indicators and the monitoring approach
used to measure the indicators. Also provide any data supporting the rationale and justification. Explain the reasons for any differences between the
verification of operational status or the quality assurance and control practices proposed and the manufacturer's recommendations. (If additional space
is needed, attach and label with the appropriate PSEU designation and pollutant):
THE PARTICULATE MATTER IS CONTROLLED VIA A HIGH EFFICIECY CYCLONE SEPARATOR FOLLOWED BY A FABRIC BAGFILTER HOUSE. THE FABRIC BAGFILTER'S
PERFORMANCE DEPENDS ON THE INTERNAL INTEGRITY OF THE BAGFILTER HOUSE AND ITS COMPONENTS. THE ANNUAL INTERNAL INSPECTION OF THE BAGFILTER
HOUSE ENSURES THE PROPER OPERATION OF THE BAGFILTERS AND MINIMIZES THE POSSIBILITY OF THE INCIDENCE OF PARTICULATE MATTER EMISSIONS.
10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges. The rationale and justification shall indicate how
EACH indicator range was selected by either a Compliance or Performance Test, a Test Plan and Schedule, or by Engineering Assessments.
Depending on which method is being used for each indicator range, include the specific information required below for that specific indicator range. (If
additional space is needed, attach and label with the appropriate PSEU designation and pollutant):
• COMPLIANCE or PERFORMANCE TEST (Indicator ranges determined from control device operating parameter data obtained during a
compliance or performance test conducted under regulatory specified conditions or under conditions representative of maximum potential
emissions under anticipated operating conditions. Such data may be supplemented by engineering assessments and manufacturer's
recommendations). The rationale and justification shall include a summary of the compliance or performance test results that was used to
determine the indicator range and documentation indicating that no changes have taken place that could result in a significant change in the control
system performance or the selected indicator ranges since the compliance or performance test was conducted and approved by DAQ.
• TEST PLAN AND SCHEDULE (Indicator ranges will be determined from a proposed implementation plan and schedule for installing, testing, and
performing any other appropriate activities prior to use of the monitoring). The rationale and justification shall include the proposed
implementation plan and schedule that will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan, but in no
case shall the schedule for completing installation and beginning operation of the monitoring exceed 180 days after approval.
• ENGINEERING ASSESSMENTS (Indicator ranges or the procedures for establishing indicator ranges are determined from engineering
assessments and other data, such as manufacturer's design criteria and historical monitoring data, because factors specific to the type of
monitoring, control device, or PSEU make compliance or performance testing unnecessary). The rationale and justification shall include
documentation demonstrating that compliance testing is not required to establish the indicator range.
RATIONALE AND .JUSTIFICATION:
THE RATIONALE AND JUSTIFICATION FOR THE SELECTION OF THE INDICATOR RANGES OF THE ANNUAL INTERNAL INSPECTION OF THE FABRIC BAGFILTER HOUSE WAS
VIA AN ENGINEERING ASSESSMENT. THE BASIS FOR THE ASSESSMENT INCLUDES THE FACT THAT THE FABRIC. BAGFILTER HOUSE HAS HAD ONE (1) TORN OR
OTHERWISE COMPROMISED FILTER BAG DURING THE PAST FIVE (5) YEARS.
Mail Completed Application to:
Division of Air Quality (DAQ), Permitting Section
1641 Mail Service Center
Raleigh, North Carolina 27699-1641
DEQ-CFW 00071513

Compliance Assurance Monitoring (CAM) Plan
A±fflA-. North Carolina Department of Environment and FORM E6
NCDENR � Natural Resources /Division of Air Quality (DAQ)
Page 7 of 8
a CAM MONITORING APPROACH CRITERIA
9. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section
may be copied as needed for each PSEU. This section is to be used to provide monitoring data and information for EACH indicator selected
for EACH PSEU in order to meet the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being
selected for a PSEU or if additional space is needed, attach and label with the appropriate PSEU designation, pollutant, and indicator Nos.
6a. PSEU Designation: BS-C
6b. Pollutant:
6c. b Indicator No.1:
6d. b Indicator No. 2:
7a. General Criteria
MONTHLY VISUAL OBSERVATION OF THE
Describe the monitoring approach used to
VISIBLE EMISSIONS
EMISSION POINT OF THE FABRIC
measure the Indicators.
FILTER FOR ANY VISIBLE EMISSIONS
ABOVE NORMAL
Establish the appropriate indicator range or
the procedures for establishing the indicator
NORMAL HAS BEEN ESTABLISHED AS NO
range which provides a reasonable
OBSERVED VISIBLE EMISSIONS
assurance of compliance
_ _......._. _...__..........._.___._.._.__ .._.._._........_....... _._..._............._....._.._........._..._..........__._
......._........ ............ _..........................................__........
.... ................ .__...._............. ___.._..__.._._................ __......._..._........._.._.._......._...._
............. __........... ........ .... ....... ...... _._................. _.............. _.._.__..
d Provide Quality Improvement Plan (QIP)
TWO OR MORE OBSERVATIONS ABOVE
Threshold levels:
NORMAL DURING A 12-MONTH PERIOD
7b. Performance Criteria
EACH MONTHLY VISUAL OBSERVATION
Provide the Specification for Obtaining
WOULD QUALIFY AS REPRESENTATIVE
Representative Data (Such as detector
_ location and installation.specifications�:_____....._.__.____.._____.._.._..._.__...._.....___...._._____
DATA
--- _...._.............___.__._..._.......__..........._ .__......_.__.._
_...________._.__.___..... _................ _................. _....... ._... _........ _.
Provide Verification Procedures, including
manufacturer's recommendations to confirm
NOT APPLICABLE
_ the OpeStatus of the monitoring
_
..........__.._.rational
_.. _..__._...__._..... _ .....
_............ _....... _.... _._.._........... _.__......._._.._..... _..... __............ _.......... __..
Provide Quality Assurance and Quality
Control (QAIQC) Practices that are
adequate to ensure the continuing validity of
NOT APPLICABLE
the data, considering manufacturer's
recommendations:
.._......_......_ ..............._.__......_. _.....__..._.._............................._...._.....__.__..._..._..._........__............_.__..._.__..._.__..._....._...__.........._......_........_...
__...._..._..._.............__....._._._...._ _.._.
e Provide the Monitoring Frequency:
MONTHLY
Provide the Data Collection Procedures that
RESULTS OF THE MONTHLY VISUAL
will be used:
OBSERVATIONS ARE DOCUMENTED
_..............__..._._..._____._._.._...._._..._._........_._........__...__............__._...._... _._____._..._...__..___._..._.._._._..
Provide the Data Averaging Period for the
......... __._._...........
............. ___._.._.__........_..._... ...... ___.......... ___......... _._............... __.._...
_..__...___..__........ ........ ___........... _.._,.................. ___
purpose of determining whether an
NOT APPLICABLE
excursion or exceedance has occurred:
e If a Continuous Emission Monitoring System (CEMS), Continuous Opacity Monitoring System (COMS), or Predictive Emission Monitoring System (PEMS)
is used, then this section need not be completed ONLY for the CEMS, COMS, or PEMS, EXCEPT that the Special Criteria Information of 40 CFR 64.3(d)
must be provided. Special Criteria Information may be provided on a separate sheet.
b Describe all indicators to be monitored which satisfy 40 CFR 64.3(a). Indicators of emission control performance for the control device and associated
capture system may include measured or predicted emissions (including visible emissions or opacity), process and control device operating parameters
that affect control device (and capture system) efficiency or emission rates, or recorded findings of inspection and maintenance activities.
Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly different operating conditions,
expressed as a function of process variables, expressed as maintaining the applicable indicator in a particular operational status or designated condition,
or established as interdependent between more than one indicator. In addition, unless specifically stated otherwise by an applicable requirement, the
owner or operator shall monitor the indicators to detect any bypass of the control device (or capture system) to the atmosphere.
d The QIP threshold is based on the number of excursions identified in a reporting period. (Example: If the historical monitoring data for a facility indicates
that the indicator range was exceeded 10 times in a 6-month period, the threshold could be established at no more than 10 excursions outside the
indicator range during a 6-month reporting period.) The threshold levels also could be established based on the duration of excursions as a percentage of
operating time.
e At a minimum, the owner of a large PSEUs must collect four or more data values equally spaced over each hour and average the values. All other PSEUs
must collect data at least once per 24-hour period or possibly more to provide reasonable assurance of compliance over the anticipated range of
operating conditions.
DEQ-CFW 00071514

Ala
NCDENR
Compliance Assurance Monitoring (CAM) Plan
North Carolina Department of Environment and
Natural Resources / Division of Air Quality (DAQ)
Page 8 of 8
FORM E6
RATIONALE AND JUSTIFICATION
8. Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAM Plan submittal. This section may
be copied as needed. Use this section to provide monitoring data and information for EACH indicator selected for EACH PSEU in order to meet
the monitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additional space
is needed, attach additional sheets and label with the appropriate PSEU designation, pollutant, and indicator Nos.
8a. PSEU Designation: BS=C
8b. Pollutant: VISIBLE EMISSIONS
9. INDICATORS and the MONITORING APPROACH: Provide the rationale and justification for the selection of the indicators and the monitoring approach
used to measure the indicators. Also provide any data supporting the rationale and justification. Explain the reasons for any differences between the
verification of operational status or the quality assurance and control practices proposed and the manufacturer's recommendations. (If additional space
is needed, attach and label with the appropriate PSEU designation and pollutant):
THE VISIBLE EMISSIONS ARE CONTROLLED VIA A CYCLONE SEPARATOR FOLLOWED BY A FABRIC FILTER BAGHOUSE, THE EXHAUSTED AIR FROM THE FABRIC FILTER
BAGHOUSE IS DISCHARGED THROUGH THE BUTACITE® BAGHOUSE STACK. ANY OBSERVED VISIBLE EMISSIONS WOULD INDICATE A MECHANICAL FAILURE OF ONE
OR MORE OF THE FABRIC BAGFILTERS. THE MONTHLY VISUAL OBSERVATION OF THE VISIBLE EMISSIONS FROM THE BAGHOUSE STACK ENSURES THE FABRIC FILTER
BAGHOUSE IS OPERATING PROPERLY.
10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges. The rationale and justification shall indicate how
EACH indicator range was selected by either a Compliance or Performance Test, a Test Plan and Schedule, or by Engineering Assessments.
Depending on which method is being used for each indicator range, include the specific information required below for that specific indicator range. (If
additional space is needed, attach and label with the appropriate PSEU designation and pollutant):
• COMPLIANCE or PERFORMANCE TEST (Indicator ranges determined from control device operating parameter data obtained during a
compliance or performance test conducted under regulatory specified conditions or under conditions representative of maximum potential
emissions under anticipated operating conditions. Such data may be supplemented by engineering assessments and manufacturer's
recommendations). The rationale and justification shall include a summary of the compliance or performance test results that was used to
determine the indicator range and documentation indicating that no changes have taken place that could result in a significant change in the control
system performance or the selected indicator ranges since the compliance or performance test was conducted and approved by DAQ.
• TEST PLAN AND SCHEDULE (Indicator ranges will be determined from a proposed implementation plan and schedule for installing, testing, and
performing any other appropriate activities prior to use of the monitoring). The rationale and justification shall include the proposed
implementation plan and schedule that will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan, but in no
case shall the schedule for completing installation and beginning operation of the monitoring exceed 180 days after approval.
• ENGINEERING ASSESSMENTS (Indicator ranges or the procedures for establishing indicator ranges are determined from engineering
assessments and other data, such as manufacturer's design criteria and historical monitoring data, because factors specific to the type of
monitoring, control device, or PSEU make compliance or performance testing unnecessary). The rationale and justification shall include
documentation demonstrating that compliance testing is not required to establish the indicator range.
RATIONALE AND JUSTIFICATION:
THE RATIONALE AND JUSTIFICATION FOR THE SELECTION OF THE INDICATOR RANGES OF THE MONTHLY VISUAL OBSERVATION WAS VIA AN ENGINEERING
ASSESSMENT. THE BASIS FOR THE ASSESSMENT INCLUDES THE FACT THAT NO VISIBLE EMISSIONS FROM THE BAGHOUSE STACK HAVE BEEN OBSERVED IN AT LEAST
THE PAST FIVE (5) YEARS.
Mail Completed Application to:
Division of Air Quality (DAQ), Permitting Section
1641 Mail Service Center
Raleigh, North Carolina 27699-1641
DEQ-CFW 00071515

CAM Plan
Page 1 of 5
DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T38
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:
§64.2(a)(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 paragraph (b)(1) of this section;
§64.2(a)(2): The unit uses a control device to achieve compliance with any such emission
limitation or standard; and
§64.2(a)(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. For purposes of this paragraph,
"potential pre -control device emissions" shall have the same meaning as "potential to emit,"
as defined in §64.1, except that emission reductions achieved by the applicable control
device shall not be taken into account.
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:
§64.2(b)(1)(i): Emission limitations or standards proposed by the Administrator after
November 15, 1990 pursuant to section 111 (NSPS) or 112 (NESHAP) of the Act.
§64.2(b)(1)(ii): Stratospheric ozone protection requirements under title VI of the Act.
§64.2(b)(1)(iii): Acid Rain Program requirements pursuant to sections 404, 405, 406,
407(a), 407(b), or 410 of the Act.
§64.2(b)(1)(iv): 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.
§64.2(b)(1)(v): An emissions cap that meets the requirements specified in §70.4(b)(12) or
§71.6(a)(13)(iii) of this chapter.
§64.2(b)(1)(vi): Emission limitations or standards for which a part 70 or 71 permit specifies
a continuous compliance determination method, as defined in §64.1.
Updated April 4, 2014
DEQ-CFW 00071516

CAM Plan
Page 2 of 5
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).
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 §64.2(a)(1).
2. Four Butacite® flake reactors (ID Nos. BS-B1.1 through BS-B1.4) controlled by a
packed -bed scrubber (ID No. BCD-Bl)
The Butacite® flake reactors (ID Nos. BS-B1.1 through BS-B1.4) 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-131.1 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 §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-B2.1 through BS-B2.4) 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-132.1 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 -§ 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
Updated April 4, 2014
DEQ-CFW 00071517

CAM Plan
Page 3 of 5
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.
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-E1) 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 §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 §64.2(a)(1).
8. 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
Updated April 4, 2014
DEQ-CFW 00071518

CAM Plan
Page 4 of 5
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 §64.2(b)(1)(i).
9. 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 §64.2(b)(1)(i).
10. 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 §64.2(a)(1).
11. 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 §64.2(a)(1).
12. 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 §64.2(a)(1).
13. One MMF process (ID No. NS-F) controlled by one baffle -plate scrubber (ID No.
NCD-Hdrl or NCD-Hdr2)
Updated April 4, 2014
DEQ-CFW 00071519

CAM Plan
Page 5 of 5
The MMF process (ID 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 §64.2(a)(1).
14. 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 §64.2(b)(1)(i).
15. 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 §64.2(a)(1).
16. Polymer Processing Aid Process (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 PPA 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 §64.2(a)(1).
17. 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 §64.2(a)(1).
Updated April 4, 2014
DEQ-CFW 00071520

DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T38
Maximum Achievable Control Technology (MACT) Review
The DuPont Company — Fayetteville Works is currently subject to the following three (3)
Maximum Achievable Control Technology (MACT) standards:
40 CFR Part 63 Subpart FFFF — National Emission Standards for Hazardous Air
Pollutants for Miscellaneous Organic Chemical Manufacturing
The following sources are subject to the National Emission Standards for Hazardous Air
Pollutants for Miscellaneous Organic Chemical Manufacturing:
Emission Source ED Number
Emission Source Description
BS-B 1.1 through BS-B 1.4
Butacite polyvinyl butyral flake reactors (4 units)
BS-132.1 through BS-B2.4
Butacite polyvinyl butyral flake reactors (4 units)
BS-C
Butacite® polyvinyl butyral flake dryer
BS-F
Butacite® PVA Unloading System and Storage Silos
BS-G
Butacite® PVA Dissolver Tank System
NS-A
NafonR Hexfluoropropylene epoxide process (HFPO)
NS-B
NafionR Vinyl Ethers North process
NS-C
NaflonR Vinyl Ethers South process
NS-G
NaflonR Resins process
40 CFR Part 63 Subpart ZZZZ — National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines
The following sources are subject to the National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines:
Engine or Generator ID Number Engine or Generator Description
U-RICE-01 Emergency electrical generator (181 HP, 135 KW)
U-RICE-02 Emergency fire water pump (370 HP, 276 KW)
This was the last MACT standard that was applicable to the facility. The compliance date for
this MACT standard was October 19, 2013.
DEQ-CFW 00071521

MACT Review
Page 2 of 2
15A NCAC 2D .1109 — Case -by -Case MACT for Hazardous Air Pollutants for Industrial,
Commercial, and Institutional Boilers and Process Heaters at Major Sources
The following sources are subject to the Case -by -Case MACT for Hazardous Air Pollutants for
Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources
Emission Source ID Number
Emission Source Description
PS -A
Natural gas/No. 2 fuel oil -fired boiler (139.4 million Btu
per hour maximum heat input)
PS-B
Natural gas/No. 2 fuel oil -fired boiler (88.4 million Btu
per hour maximum heat input)
PS-C
Natural gas/No. 2 fuel oil -fired boiler (97 million Btu per
hour maximum heat input) equipped with a low-NOx
burner
BS-F
Butacite PVA Unloading System and Storage Silos
BS-G
Butacite® PVA Dissolver Tank System
NS-A
Nafion® Hexfluoropropylene epoxide process (HFPO)
NS-B
Nafion® Vinyl Ethers North process
NS-C
Nafion® Vinyl Ethers South process
NS-G
Nafion® Resins process
DEQ-CFW 00071522

DuPont Company — Fayetteville Works
Title V Air Permit No. 03735T38
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.1100.
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 00071523