DEQ-CFW_00071536

DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
DuPont Fluoroproducts
S(:p 18 2014
Ak
VIA OVERNIGHT DELIVERY COURIER
September 12, 2014
Ms. Heather Sands
NCDENR — Division of Air Quality
Permits Section
1641 Mail Service Center
Raleigh, NC 27699-1641
SUBJECT: Title V Air Permit Modification
Air Quality Permit No. 03735T38
DuPont Company — Fayetteville Works
Facility ID: 03/09/00009
Ms. Sands:
Enclosed are two copies of an application and a check for the required application fee to
modify the DuPont Company — Fayetteville Works' ("DuPont") Title V Air Permit. The
requested modification is to install a stationary emergency generator that is driven by a diesel
reciprocating internal combustion engine ("RICE"). The engine is subject to the RICE
MACT of 40 CFR 63 Subpart ZZZZ.
As required by the subject permit, an original and two copies of an application have been sent
to the attention of Mr. Steven Vozzo at the Division of Air Quality's regional office in
Fayetteville.
This request is for a "Title V Minor Modification Prior to Permit Revision". In accordance
with 15A NCAC 2Q .0515, Title V permittees may make changes to their facility prior to
receiving a revised permit if the following four (4) conditions:
(1) The change is a "minor modification" under 15A NCAC 2Q .0515 and does not revise
any state -enforceable only portion of the permit.
E. I. du Pont de Nemours and Company
FL-4 Rev. 3/2000
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Ms. Heather Sands Page 2 of 6
NCDENR — Division of Air Quality
September 12, 2014
(2) The Permittee submits a complete Title V permit application.
(3) The Permittee has received an acknowledgment letter that the application is complete.
(4) The Permittee follows the proposed interim permit terms and conditions and any other
applicable requirements governing the change(s) until the DAQ takes final action on
the application.
For a complete Title V permit application, the Permittee must include the proposed interim
permit terms and conditions for the new source. The following are those interim terms and
conditions:
DuPont proposes the following interim permit terms and conditions associated with the
control of visible emissions as it applies to the new emergency generator, which ultimately
might be a modification of Section 2.1(C)(2) of the subject permit:
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected sources (ID No. NS-I and RICE-03) shall not
be more than 20 percent opacity when averaged over a six -minute period.
However, six -minute averaging periods may exceed 20 percent not more than once
in any hour and not more than four times in any 24-hour period. In no event shall
the six -minute average exceed 87 percent opacity.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with
General Condition JJ. If the results of this test are above the limit given in Section
2.1 C.2.a above, the Permittee shall be deemed in noncompliance with 15A NCAC
2D .0521.
Monitoring/Recordkeeping/Renorting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from these
sources.
DuPont proposes the following interim permit terms and conditions associated with the sulfur
dioxide emissions from combustion sources as it applies to the new emergency generator,
which ultimately might be added as Section 2.1(C)(9) of the subject permit:
9. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION
SOURCES
a. Emissions of sulfur dioxide from the combustion of diesel fuel in the affected RICE
(ID No. RICE-03) shall not exceed 2.3 pounds per million Btu heat input.
DEQ-CFW 00071537

Ms. Heather Sands
NCDENR — Division of Air Quality
September 12, 2014
Page 3 of 6
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with
General Condition JJ found in Section 3. If the results of this test are above the
limit given in Section 2.1 A.2.a above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeeping/Recordkeeping [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the
combustion of diesel fuel in this source.
DuPont proposes the following interim permit terms and conditions associated with the RICE
MACT as it applies to the new emergency generator, which ultimately might be added as
Section 2.1(C)(10) of the subject permit:
10. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(MALT), 40 CFR 63, Subpart ZZZZ: NESHAP for Stationary Reciprocating
Internal Combustion Engines (RICE)
a. The Permittee shall comply with all applicable provisions, including the
notification, testing, recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .1111,
"Maximum Achievable Control Technology" as promulgated in 40 CFR 63,
Subpart ZZZZ, including Subpart A, "General Provisions".
Operating Standards [15A NCAC 2Q .0508(f)]
b. The affected RICE may be operated for maintenance checks and readiness testing
for a maximum of 100 hours per calendar year. [40 CFR 63.6640(f)(2)]
c. To demonstrate compliance with the operating hours limitation, the affected RICE
must be equipped with a non-resettable hour meter.
d. There is no time limit on the use of an emergency stationary RICE in emergency
situations.
Work Practice Standards [15A NCAC 2Q .0508(f)]
e. The Permittee shall perform the following inspections and maintenance on the
affected RICE:
i. Change oil and filter every 500 hours of operation or annually, whichever
comes first;
ii. Inspect air cleaner every 1,000 hours of operation or annually, whichever
comes first, and replace as necessary; and,
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Ms. Heather Sands
NCDENR — Division of Air Quality
September 12, 2014
Page 4 of 6
iii. Inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the
affected RICE is not inspected and maintained as required above. [Table 2c to
Subpart = of Part 63]
f. The Permittee must comply with the following work practice:
i. Operating and maintaining the affected RICE according to the manufacturer's
emission -related operation and maintenance instructions; or
ii. Develop and follow a site -specific maintenance plan which must provide to the
extent practicable for the maintenance and operation of the engine in a manner
consistent with good air pollution control practice for minimizing emissions.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the
affected RICE is not operated and maintained as required above. [Table 6 to Subpart
ZZZZ of Part 63]
Recordkeeping [15A NCAC 2Q .0508(f)]
g. The results of the monitoring and any required inspection and maintenance shall be
maintained in a log (written or electronic format) on -site and made available to an
authorized representative upon request. The log shall record the following:
i. The hours recorded by the non-resettable hour meter that must be installed on
the affected RICE shall be recorded at least annually;
ii. The date of each recorded inspection or maintenance performed on the affected
RICE;
iii. The results of each inspection; and,
iv. The results of any maintenance performed on the affected RICE.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these
records are not maintained.
The proposed stationary emergency generator is driven by a John Deere diesel -fueled RICE
with a maximum engine power of 147 kW (197 HP) and a displacement of 1.12 liters per
cylinder. This RICE is subject to the New Source Performance Standard ("NSPS") for
Stationary Compression Ignition Internal Combustion Engines of 40 CFR 60 Subpart IIII.
The emission standards for an owner or operator of a stationary compression ignition ("Cl")
internal combustion emergency engine are found in § 60.4205. Per § 60.4205(b), owners and
operators of 2007 model year and later emergency stationary CI engines with a displacement
of less than 30 liters per cylinder that are not fire pump engines must comply with the
emission standards for new non -road CI engines in §60.4202, for all pollutants.
DEQ-CFW 00071539

Ms. Heather Sands
NCDENR — Division of Air Quality
September 12, 2014
Page 5 of 6
Per § 60.4202(a)(2), stationary Cl internal combustion engine manufacturers must certify their
2007 model year and later emergency stationary Cl engines with a maximum engine power
greater than or equal to 37 kW (50 HP) and less than or equal to 2,237 kW (3,000 HP) and a
displacement of less than 10 liters per cylinder that are not fire pump engines to the
certification emission standards for new non -road Cl engines for the same model year and
maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 for all pollutants beginning in
model year 2007.
Both the Kohler generator (Model 125REOZJG) and the John Deere PowerTechTM diesel
engine (Model 4045HF285) specification sheets state that the equipment meets the NSPS
Tier 3 emission standards requirement.
DuPont proposes the following interim permit terms and conditions associated with the New
Source Performance Standard as it applies to the new emergency generator, which ultimately
might be added as Section 2.1(C)(11) of the subject permit:
11. 15A NCAC 2D .0524: New Source Performance Standards (40 CFR 60, Subpart
IIII)
a. For the affected RICE (ID No. RICE-03), the Permittee shall comply with all
applicable provisions, including the notification, testing, recordkeeping, and
monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 02D .0524, "New Source Performance Standards" (NSPS) as
promulgated in 40 CFR 60, Subpart IIII, including Subpart A, "General
Provisions."
Emission Limitations
b. Combined emissions of nonmethane hydrocarbon (NMHC) and oxides of nitrogen
(NOx) from the combustion of diesel fuel that are discharged from the affected
RICE (ID No. RICE-03) into the atmosphere shall not exceed 4.0 g/kW-hr. [Table
I of 40 CFR 89.112(a)]
c. Emissions of carbon monoxide (CO) from the combustion of diesel fuel that are
discharged from the affected RICE (ID No. RICE-03) into the atmosphere shall
not exceed 3.5 g/kW-hr. [Table I of 40 CFR 89.112(a)]
d. Emissions of particulate matter (PM) from the combustion of diesel fuel that are
discharged from the affected RICE (ID No. RICE-03) into the atmosphere shall
not exceed 0.20 g/kW-hr. [Table 1 of 40 CFR 89.112(a)]
e. Constant -speed emergency engines with a maximum engine power greater than or
equal to 37 kW (50 HP) are exempt from the smoke emissions standard of the Part
60 Subpart IIII NSPS. [40 CFR 89.113(c)(3)]
DEQ-CFW 00071540

Ms. Heather Sands
NCDENR — Division of Air Quality
September 12, 2014
Page 6 of 6
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Testing [15A NCAC 2Q .0508(f)]
f. If emissions testing is required, the testing shall be performed in accordance with
General Condition JJ found in Section 3. If the results of this test are above the
limit given in Section 2.1 A.2.a above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0516.
Recordkeeping [15A NCAC 2Q .0508(f)]
g. The RICE manufacturer's Tier 3 certification shall be maintained (written or
electronic format) on -site and made available to an authorized representative upon
request.
Monitoring/Reporting [15A NCAC 2Q .0508(f)]
h. No monitoring/reporting is required for combustion of diesel fuel in this source.
If you should have any questions additional or need additional information regarding this
permit modification request, please contact me at [phone].
Environmental Manager
Enclosures
DEQ-CFW 00071541