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DEQ-CFW_00072517
e Cou PONT FAYETTEVILLE WORKS APPLICATION TO MODIFY THE TITLE V AIR PERMIT (PERMIT NO.03735T32) TO CONSTRUCT AND OPERATE THE POLYVINYL FLUORIDE = MANUFACTURING FACILITY NO.2 y �l3 APRIL 2, 2008 DEQ-CFW 00072517 Zoning Consistency Determination Facility Name DuPont Company - Fayetteville Works Facility Street Address 22828 NC Highway 87 W Facility City Duart Township, Bladen County, North Carolina Description of Process Polyvinyl Fluoride Manufacturing Facility No. 2 SIC Code/NAICS 3081 / 326113 Facility Contact Michael E. Johnson Phone Number (910) 678-1155 Mailing Address 22828 NC Highway 87 W Mailing City, State Zip Fayetteville, NC 28306-7332 Based on the information given above: Q I have received a copy of the air permit application (draft or final) AND... Q The proposed operation IS consistent with applicable zoning and subdivision ordinances Agency Bladen County Planning Department Name of Designated Official Greg Elkins Title of Designated Official Planning Director Signature Date y-3 - 0 5? Please forward to the mailing address listed above and the air quality offices listed below: Attn: Major Source Review Branch Supervisor NCDENR - Division of Air Quality Permitting Section 1641 Mail Service Center Raleigh, NC 27699-1641 Mr. Steven F. Vozzo NCDENR - Division of Air Quality Fayetteville Regional Office 225 Green Street - Suite 714 Fayetteville, NC 28301 DEQ-CFW 00072518 FORM Al FACILITY (General Information) REVISED 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate Al El Local Zoning Consistency Determination (if required) 0 Facility Reduction & Recycling Survey Form (Form A4) IM Application Fee 0 Responsible Official/Authorized Contact Signature ❑x Appropriate Number of Copies of Application ❑ P.E. Seal (if required) Legal Corporate/OwnerName: E.I. du Pont de Nemours & Company Site Name: DuPont Company - Fayetteville Works Site Address (911 Address) Line 1: 22828 NC Highway 87 W Site Address Line 2: City: Fayetteville State: North Carolina Zip Code: 28306-7332 County: Bladen Permit/Technical Contact. Facility/Inspection Contact; Name/Title: Michael E. Johnson, Environmental Manager Name/Title: (Same as Permit/Technical Contact) Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 1: Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306 City: State: Zip Code: Phone No. 910.678.1155 Fax No. 910.678.1247 Phone No. ( ) Fax No. ( ) Email Address: michael.e.johnson@usa.dupont.com Email Address: Responsible Official/Authorized Contact. Invoice Contact. Name/Title: Karen B. Wrigley / Plant Manager Name/Title: (Same as Permit/Technical Contact) Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 1: Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306 City: State: Zip Code: Phone No. 910-678-1546 Fax No. 910-678-1247 Phone No. ( ) Fax No. ( ) Email Address: karen.b.wrigley@usa.du�pont.c(oomA Email Address: y N ❑ New (non -permitted) Facility/Greenfield Modification of Facility (permitted) ❑ Renewal With Modification ❑ Renewal (TV Only) ❑ General ❑ Small ❑ Prohibitory Small ❑ Synthetic Minor Title V (Must include Form(s) E) 3���� w � �_� �.�A�.�����>RE�nt- e� IN�a�,GtQ�ky•��:� �� . _� ..:�� s � � r. �: �k Describe nature of (plant site) operation(s): Chemical manufacturing facility. Primary SIC/NAILS Code: 3081, 3083, 2821, 2869 Current/Previous Air Permit No. 03735T32 Facility Coordinates: Latitude: 34 deg. 50 min. 30 sec. Longitude: -74 deg. 50 min. 10 sec. Does this application contain confidential data? ❑ No 0 Yes (See Instructions) r ° PERSQQ E R>I~tRh�l_THAT PR ---a e 4. PAI�t�© 1PP YMAK JO ` .; ;� > :. =�.a a 5+.. ',l Person Name: Michael E. Johnson Firm Name: Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306-7332 county: Bladen Phone No. 910-678-1155 Fax No. 910-678-1247 Email Address: Michael.E.Johnson@USA.dupont.com `"' XSIG[4TURE OF RESPQNS[BLE QFFtCYALI�U �EfIiZE C9CAC� Y Name (typed): Karen B. Wrigley Title: Plant Manager X Signature(Blue Ink): Date: Oq jo /0 Attach Additional Sheets As Necessary DEQ-CFW 00072519 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 EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted EMISSION SOURCE ID NO. EMISSION SOURCE DESCRIPTION CONTROL DEVIC CONTROL DEVICE ID NO. DESCRIPTION EEMi PAM R[t 10 �rI!►�� e�a R- NOW FS-C Polyvinyl Fluoride Manufacturing Facility No.2 None t�9=Pearltedqu�pitto:Dpgq TtttsPptr�alron a�pent Tad Be F�ELLTy�Tr$�pprat�o rP` 3 Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases"- Section 112(r) of the Federal Clean No 0 Air Act? Yes ❑ If No, please specify in detail how your facility avoided applicability: If your facility is Subject to 112(r), please complete the following: A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150? Yes No ❑ Specify required RMP submittal date: June 30, 1999 If submitted, RMP submittal date: June 8, 1999 RMP resubmitted on June 3, 2004 B. Are you using administrative controls to subject your facility to a lesser 112(r) program standard? Yes ❑ No IN] If yes, please specify: Attach Additional Shppts As_Npceccary DEQ-CFW 00072520 FORM A4 '.Sh 'Nid •"aY �.'. .II. iw1W' 3� ',i VL f •S•w •�v i'W':LfMY. fltw DATE: 04/02/2008 Does facility'have an environmental mangement system in place?( ) YES (X) NO If so, is facility ISO 14000 Certified?( ) YES ( ) NO Facility Name: DuPont Company -Fayetteville Works Permit Number: 03735T32 Facility ID: 0900009 County: Bladen Environmental Contact: Michael E. Johnson Mailing Address Line 1: 22828 NC Highway 87 W Phone No. (910) 678.1155 Fax No. (910) 678-1247 Mailing Address Line 2: Zip Code: 28306.7332 County: Bladen City: Fayetteville State: NC Email Address: michael.e.johnson@usa.dupont.com EMISSIONSAIR • • Any Air Emissions Source Reductions in the past year? ( ) YES (X) NO Enter Code for Date Reduction Quantity Emitted Quantity Emitted Has reduction actNity been Source Description and ID Air Pollutant Emission Reduction Option Implemented from prior annual from current annual discontinued? If so, when Addition detail about source Option (See Codes) (molyr) report to DAQ IIblyr) report to DAQ (Iblyr) was it discontinued? (molyr 'r�R4le�fs�`�, �� �+s �;r.y ''(+: '�r�� ' a �6..,:.: tii� ' i3C-0''(a �flBe g p ;�, ,,,x. �. ,.:: ,.,.. a� d4'�,a •v:v1,%� .tin ,. s,�,;�,'•'' b.. ? U. re ,b n i";r. d( 1 "�((�ir11 t�^7yyqqt f• ��;"�Jl. rH�ila'wt'f�tiL� Eki1a,"a� Comments: FACILITY WIDE REDUCTIONSAny Reductions or Recycling Activities in the past year? ( )YES (X) NO Enter Code for Pollutant or Recycled or Date Reduction Emitted Quantity Emitted Has reduction activhy been Source Description or Activity p y Reduced Materials Emission Reduction [-&Q-u-antity Option Implemented from prior annual from currant annual discontinued) N so, when Addition detail about source Option (See Codes) (mo/yr) report report was it discontinued? (molyr Vc':y' Pdl,'..A � 1r 1 i ;t > W J• t .:" "P �rter Oi%tis� atl0n nd , ' e ae v,�+le t 1 � � S ' a' �snp 4 1 .:. ;. N � f '- . tt P �r ��, � • ;� � ' - , I; �� ::..� -... ,YS., :...Y ; '� .,o •i:, w � "! :.,w .S; '�iie0�'e�I:EI�IS ,,::,'S 3 �, ,�..± y ,�y ✓:..:�'+ nf.,v. ,. a4, :� � ' �'( <h S f ' 3� ' i'. . s ri Y} �h. �' I b'��X,.Y ��. d"`,J ! .: ' s� y�y st' 'i�'t: h fv :. ; ', r� ; � + Ai"". ie' , s' �h," . �� n�/p � hyif �. ! a. �� .l;• 7�M� Yl! till .:5 �: � �r. . rn 1 � y.,,�I !v, rTi.i � i '"j'rEVWu Q�YJ ,H l p� ..� ': yaY^d 'n,�,?y t ,�(,',.,rr '1 �1" ':wct i" `ST,p, ,� �'f."� �•.�.. '. ( .�� �: r41 ai{� ...1 � .IY' A w14 �.1?Iti '. ��hnev,�.: ��. 19 w'if"�NWF';R' R'f, ) •11 � :: �'^' �'f:, „ e .Y�`4"w Pw r. r 4� M•"�k, r� � ;. n`� - .' YD�yQn v l fr �'d' S - .� 3 . :. ,...-. R "� �'l ,. �..'.1 � k : �. 4l' <,+'. �,p . . 5( L AV.. 1) l i jM M1 u w ,, b..,;;n ,dti.,f, +Y ... :Y^� .;: . A T,�f: .i}. �i ,4�17^�3" r �.. � '1� I tea? ,� :::. .L:,, 1"' .,' n. + �---- Comments: The requested information above shall be used for fulfillin the requirements of North Carolina General Statute 3-215.108(g). The permit holder shall submit tothe: D• projected1%source•• 1 • I I I aii •• shall •• 051 1 • permit and for each annual air quality permit fee payment. Source reduction9 defined as reducing the amount of any hazardous$Q anyotherw • the environment Cm 0. C (including fugitive emissions) prior to recycling, treatment, or disposal. If no has taken R activity place since the previous report, simply indicate so by checking the '81 no box in that section. Once completed, this form• be first are.I on the line ofsection each we for your benefit. �: Om """S°°— ch n ls^ For assistance with FORM A4, please contact the North Carolina DivisionAttaoftVoitWu IonShVrevenAsNetionssa Wnd Environmental Assistance at 1-800-763-0136 or nowaste(cbp2pays.org FORM B SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES) REVISED 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate f EMISSION SOURCE DESCRIPTION: polyvinyl Fluoride Manufacturing Facility N0.2 EMISSION SOURCE ID NO: FS-C CONTROL DEVICE ID NO(S): None OPERATING SCENARIO 1 OF 1 EMISSION POINT (STACK) ID NO(S) FEP-C1,C2,C3,104 DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM): Vinyl fluoride (VF) reacts in a continuous reactor to form crude polyvinyl fluoride (PVF). The PVF is then isolated in a separator system followed by a filter press and a dryer. The final product is a solid powder. TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM 131-139 ON THE FOLLOWING PAGES): ❑ Coal,wood,oil, gas, other burner (Form B1) '❑ Woodworking (Form B4) ❑ Manufact. of chemicals/coatings/inks (Form B7) ❑ Int.combustion engine/generator (Form B2) ❑ Coating/finishing/printing (Form 65) ❑ Incineration (Form B8) ❑ Liquid storage tanks (Form B3) ❑ Storage silos/bins (Form B6) IR Other (Form 69) START CONSTRUCTION DAT duly 08 1OPERATION DATE Aug 09 IDATE MANUFACTURED: July 2008 MANUFACTURER / MODEL NO.: n/a 1EXPECTED OP. SCHEDULE: 24 HR/DAY 7 DAY/WK 50 WK/YR IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?): NO NESHAP (SUBPART?): NO MACT (SUBPART?): No PERCENTAGE ANNUAL THROUGHPUT (%): JAN-MAR 25 APR-JUN 25 JUL-SEP 25 OCT-DEC 25 EXPECTED ANNUAL HOURS OF OPERATION: —8300 IVISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: —0 % OPACITY L s�cAr�ae�z�rM�s�ossr�r�1 �a�nrorissor..: Y . AIR POLLUTANT EMITTED SOURCE OF EMISSION FACTOR EXPECTED ACTUAL (AFTER CONTROLS/LIMITS) POTENTIAL EMISSIONS (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS) Ib/hr tons/ r Ib/hr tons/ r Ib/hr tons/ r PARTICULATE MATTER (PM) Vendor 0.3 1.1 0.4 1.7 0.4 1.7 PARTICULATE MATTER<10 MICRONS (PM10) Vendor 0.3 1.1 0.4 1.7 0.4 1.7 PARTICULATE MATTER<2.5 MICRONS (PM2.1) Vendor 0.3 1.1 0.4 1.7 0.4 1.7 SULFUR DIOXIDE (S02) 0 1 0 0 0 0 0 NITROGEN OXIDES (NOx) 0 0 0 0 0 0 CARBON MONOXIDE (CO) 0 0 0 0 0 0 VOLATILE ORGANIC COMPOUNDS (VOC) Model 4.7 16.3 6.1 26.8 6.1 26.8 LEAD 0 0 0 0 0 0 OTHER 1 0 1 0 0 0 0 0 HAZARDOUS AIR POLLUTANT AND CAS NUMBER SOURCE OF EMISSION FACTOR EXPECTED ACTUAL (AFTER CONTROLS/LIMITS) POTENTIAL EMISSIONS (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS) Ib/hr tons/ r Ib/hr tons/ r Ib/hr tons/ r None } �.X!4uT�Eiss�o�ir.tnr�.Ri4lroorrocr INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS TOXIC AIR POLLUTANT AND CAS NO. EF SOURCE Ib/hr Ibida Ib/ r None ttachments: (1) emissions calculations and supporting documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates) and describe how these are monitored and with what frequency: and (3) describe any monitoring devices, gauges, or test ports for this source. COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOURCE Attach Additional Sheets As Necessary DEQ-CFW 00072522 FORM 139 - Confidential EMISSION SOURCE (OTHER) REVISED: 12/01/01 NCDENR/Division of Air Qualitv - Aoolication for Air Permit to Construct/Ooerate B9 EMISSION SOURCE DESCRIPTION: Polyvinyl Fluoride Manufacturing Facility No. 2 EMISSION SOURCE ID NO: FS-C CONTROL DEVICE ID NO(S): None OPERATING SCENARIO: 1 OF 1 EMISSION POINT (STACK) ID NO(S; FEP-C1, C2, C3, C4 DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM): Vinyl fluoride (VF) reacts in a continuous reactor to form crude polyvinyl fluoride (PVF). The PVF is then isolated in a separator system followed by a filter press and a dryer. The final product is a solid powder. MAX. DESIGN CAPACITY UNIT/HR REQUESTED CAPACITY LIMITATION UNIT/HR TYPE UNITS Vinyl Fluoride lb. Confidential d-Linonene (inhibitor) lb. Confidential Propylene (modifier) lb. Confidential Water soluable salt (inhibitor) lb. Confidential V MAX. DESIGN CAPACITY UNIT/BATCH REQUESTED CAPACITY LIMITATION UNIT/BATCH TYPE UNITS MAXIMUM DESIGN BATCHES / HOUR): REQUESTED LIMITATION (BATCHES / HOUR): (BATCHES/YR): FUEL USED: Not applicable (NA) TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR): NA MAX. CAPACITY HOUF NA REQUESTED CAPACITY ANNUAL FUEL USE: NA COMMENTS: Process flow diagram attached as separate page. Attach Additional Sheets as Necessary DEQ-CFW 00072523 POLYVINYL FLUORIDE MANUFACTURING FACILITY NO.2 EMISSION SOURCE ID NO. FS-C PROCESS FLOWCHART INHIBITED VINYL FLUORIDE �► VINYL-A STORAGE TANK FLUORIDE IF MODIFIER FEED SYSTEM REMOVED INHIBITOR INITIATOR 10 FEP-C4 ANALYTICAL ---- EQUIPMENT CRUDE PVF REACTOR I PVF FEP-C3 PRODUCT COLLECTION PVF ISOLATION FLASH SYSTEM EQUIPMENT TANK -♦ FEP-Cl SEPARATOR SYSTEM PRODUCT FEP-C2 MAINTENANCE HEADER------------v E GITIVE---------- FROM PROCESS EQUIPMENT DEQ-CFW 00072524 FORM D1 FACILITY -WIDE EMISSIONS SUMMARY REVISED.12/01101 NCDENR/Division of Air Qualitv - AnDlication for Air Permit to Construct/Onerate D1 EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS / (BEFORE CONTROLS / (AFTER CONTROLS / LIMITATIONS) LIMITATIONS) LIMITATIONS AIR POLLUTANT EMITTED tons/ r tons/ r tons/ r PARTICULATE MATTER (PM) -50 Unchanged (site is Unchanged (site is Major Source) Major Source) PARTICULATE MATTER < 10 MICRONS (PM,,) —50 Unchanged (site is Unchanged (site is Major Source) Major Source) PARTICULATE MATTER < 2.5 MICRONS (PM2.5) —50 Unchanged (site is Unchanged (site is Major Source) Major Source) SULFUR DIOXIDE (S02) —600 Unchanged (site is Unchanged (site is Major Source) Major Source) NITROGEN OXIDES (NOx) —100 Unchanged (site is Unchanged (site is Major Source) Major Source) CARBON MONOXIDE (CO) -15 Unchanged (site is Unchanged (site is Major Source) Major Source) VOLATILE ORGANIC COMPOUNDS (VOC) —215 Major Source Major Source LEAD OTHER �I?tUT4.�sst�r4 ,RE 2 l EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS / (BEFORE CONTROLS / (AFTER CONTROLS / LIMITATIONS) LIMITATIONS) LIMITATIONS HAZARDOUS AIR POLLUTANT EMITTED CAS NO. tons/ r tons/ r tons/ r Total HAPs[>25 (site is Major Source) >25 (site is Major >25 (site is Major Source) Source) INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (TPER) IN 15A NCAC 2Q .0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY. Modeling Required ? TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day lb/year Yes No No TAPs will be emitted from this modification. X COMMENTS: As indicated above, the site is a major source for criteria pollutants and HAPs..The proposed operation of the Polyvinyl Fluoride Manufacturing Facility No. 2 (ID No. FS-C) will not change any of the current classifications. VOC is the only pollutant emitted from this process. The Polyvinyl Fluoride Manufacturing Facility No. 2 does not emit any HAPs or any TAPS. Attach Additional Sheets as Necessary DEQ-CFW 00072525 FORM D2 AIR POLLUTANT NETTING WORKSHEET Revised:12/01101 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D2 PURPOSE OF NETTING: ❑ AIR TOXICS ❑ PSD (100/250 tons per year) ❑ PSD SIGNIFICANT LEVELS AIR POLLUTANT: None CAS NO.: EMISSION SOURCE ID NOS.: y EMISSIONS - USE APPROPRIATE COLUMNS ONLY LBNEAR LB/DAY LB/HR MODIFICATION INCREASE - MINUS - - MINUS - - MINUS - - MINUS - MODIFICATION DECREASE = EQUALS = = EQUALS = = EQUALS = = EQUALS = NET CHANGE FROM MODIFICATION -. ,f G• �t +F -.SAif`v`b 3 - -' fy Y X .S, v' .31 :r�" 4,_ tg' ,ifi' :�. fU�faNA i, s3.', '� j "� ' ' s1F-'Tk�s.?�Siri.� ..�4`1Jj'-E$").=MfS 3'.a..3<S�a.�_z-1'r e 3 -z wr �s.'Tx.S.;,..'�'�`. .r s�W CREDITABLE INCREASE - MINUS - - MINUS - - MINUS - - MINUS - CREDITABLE DECREASE = EQUALS = = EQUALS = = EQUALS = = EQUALS = NET CREDITABLE CHANGE 3_ L_�s..<..ir'v 5�t.., •4Y.,.n. TOTAL FACILITY EMISSIONS TPER LEVELS (2Q .0711) CHECK HERE IF AN AIR DISPERSION MODELING ANALYSIS IS REQUIRED ❑ COMMENTS: The Polyvinyl Fluoride Manufacturing Facility No. 2 will have no emissions of Toxic Air Pollutants. The combined potential emissions of VOCs from the Polyvinyl Fluoride Manufacturing Facility No. 1 and the Polyvinyl Fluoride Manufacturing Facility No. 2 will be greater than the 40 ton per year significant level for PSD applicability. A PSD avoidance condition of 40 tons VOC per year is being requested for the combined VOC emissions from these two facilities. Attach Additional Sheets As Necessary DEQ-CFW 00072526 FORM D3 MODELING REQUEST FORMS (3 pages) REVISED: 02/20/03 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D3 If the applicant desires, the NCDAQ/AQAB will perform the initial modeling compliance demonstration using EPA approved screening and, if applicable and where possible, refined models. If the model results indicate the facility will be unable to demonstrate compliance with applicable Acceptable Ambient Level(s) the applicant will be notified and will be required to perform the compliance demonstration using established modeling protocol and modeling analysis requirements as defined in the North Carolina Administrative Code 15A NCAC 2D .1100 and 2Q .0700 and in the Guidelines for Evaluating the Impacts of Toxic Pollutants in North Carolina. To perform the dispersion modeling compliance demonstration, the AQAB will require the following data: Provide a brief description of the modification and/or addition necessitating the toxic modeling request: The Polyvinyl Fluoride Manufacturing Facility No. 2 will have no emissions of Toxic Air Pollutants. Therefore, modeling is neither needed nor requested. Subsequently, pages 2 and 3 of this form are not included in this application. �, xik�1i.In:iiSJO#..it74.L`SlY� ft3f F "L.'u�m-.N TOXIC AIR POLLUTANT (TAP) MAXIMUM TOXIC AIR POLLUTANT TAP EMISSIONS (After Controls) Emission Point ID Ibs/ ear Ibs/da Ibs/hr I Attach Additional Sheets As Necessary Page 1 of 3 DEQ-CFW 00072527 FORM D4 EXEMPT AND INSIGNIFICANT ACTIVITIES SUMMARY REVISED: 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D4 rs SIZE OR PRODUCTION BASIS FOR EXEMPTION OR DESCRIPTION OF EMISSION SOURCE RATE INSIGNIFICANT ACTIVITY Per AP-42 Section 13.2.6, particulate emission factors for abrasive blasting Less than 100 of mild steel panels with a five mile per tons abasive is hour wind speed, total particulate Abrasive blasting building used matter emissions would be 27 pounds per year per 1,000 pounds of abrasive. Based on this, 100 tons of abrasive would generate 5400 lb. or 2.7 ton PM. 2. 3. 4. 5. 6. 7. 8. Attach Additional Sheet As Necessary DEQ-CFW 00072528 FORM D TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION REVISED: 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D5 PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION, CONTROL, AND REGULATORY DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES: A. SPECIFIC EMISSIONS SOURCE (EMISSION INFORMATION) (FORM B) - SHOW CALCULATIONS USED, INCLUDING EMISSION FACTORS, MATERIAL BALANCES, AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE CALCULATION OF POTENTIAL BEFORE AND, WHERE APPLICABLE, AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS. B. SPECIFIC EMISSION SOURCE (REGULATORY INFORMATION)(FORM E2 - TITLE V ONLY) - PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS (e.g. FOR TESTING AND/OR MONITORING REQUIREMENTS) FOR COMPLYING WITH APPLICABLE REGULATIONS, PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF AN FEDERAL REGULATIONS (PREVENTION OF SIGNIFICANT DETERIORATION (PSD), NEW SOURCE PERFORMANCE STANDARDS (NSPS), NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS), TITLE V), INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM "A" ABOVE, DATES OF MANUFACTURE, CONTROL EQUIPMENT, ETC. TO SUPPORT THESE CALCULATIONS. C. CONTROL DEVICE ANALYSIS (FORM C) - PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL EFFICIENCIES LISTED ON SECTION C FORMS, OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM "A" ABOVE. INCLUDE PERTINENT OPERATING PARAMETERS (e.g. OPERATING CONDITIONS, MANUFACTURING RECOMMENDATIONS, AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION) CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED. D. PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS - (FORM E3 - TITLE V ONLY) - SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS, OPERATIONAL, OR OTHER DATA TO DEMONSTRATE COMPLIANCE. REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM "B" WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS. E. PROFESSIONAL ENGINEERING SEAL - PURSUANT TO 15A NCAC 2Q .0112 "APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL," A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY). 1, attest that this application for has been reviewed by me and is accurate, complete and consistent with the information supplied in the engineering plans, calculations, and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other professionals, inclusion of these materials under my seal signifies that I have reviewed this material and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per violation. (PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE NAME: DATE: COMPANY: ADDRESS: TELEPHONE: SIGNATURE: PAGES CERTIFIED: (IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT THAT IS BEING CERTIFIED BY THIS SEAL) Attach Additional Sheets As Necessary -- See Attached Calculation Sheet DEQ-CFW 00072529 FORM E1 TITLE V GENERAL INFORMATION REVISED: 12/01/01 Division of Air Quality - Application for Air Permit to Construct/Operate E1 Indicate here if your facility is subject to Title V by: EI Emissions ❑ Other If subject to Title V by other, check or specify: ❑ NSPS ❑ NESHAPS (MACT) ❑ TITLE IV Other, specify: If you are or will be subject to any maximum achievable control technology standards (MACT) issued pursuant to section 112(d) of the Clean Air Act, specify below: EMISSION SOURCE EMISSION SOURCE ID DESCRIPTION MACT BS-D Butacite Tinting "Printing MACT" (40 CFR Part 63 Subpart KK Throughout Facilitl Facility Wide "MON MACT" (40 CFR Part 63 Subpart FFFF) List any additional regulation which are requested to be included in the shield and provide a detailed explanation as to why the shield should be granted: REGULATION EMISSION SOURCE (Include ID) EXPLANATION Comments: Attach Additional Sheets As Necessary DEQ-CFW 00072530 FORM E2 EMISSION SOURCE APPLICABLE REGULATION LISTING REVISED 12/( Division of Air Qualitv - AnDlication for Air Permit to Construct/Onerate E2 EMISSION EMISSION OPERATING SCENARIO SOURCE SOURCE INDICATE PRIMARY (P) APPLICABLE ID NO. DESCRIPTION OR ALTERNATIVE (A) POLLUTANT REGULATION s _ Polyvinyl Fluoride FS-B Manufacturing NCAC 2Q.0317 - Avoidance FS-C Facilities No. 1 and p VOC conditions for 15A NCAC 2D.0530 No.2 Polyvinyl Fluoride FS-C Manufacturing p PM NCAC 2D.0515 -Particulate matter Facilities No.2 for vent FEP-C4 only Polyvinyl Fluoride FS-C Manufacturing P VE NCAC 2D.0521 - Visible emissions Facilities No.2 for vent FEP-C4 only Polyvinyl Fluoride FS-C Manufacturing P Odor NCAC 2D.1806 - Odor (State -Only Facilities No.2 Requirement) Attach Additional Sheets As Necessary DEQ-CFW 00072531 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate F E3 Regulated Pollutant VOC Emission Source ID NO. FS-B and FS-C Applicable Regulation NCAC 2Q.0317 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes rX-1 No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes ❑x No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): ,.*�� .. Data (Parameter) being recording: VOC emissions will be determined via engineering calculations Frequency of recordkeeping (How often is data recorded?): Monthly Generally describe what is being reported: Monthly VOC emissions will be determined monthly and will be reported to N.C. Division of Air Quality every six months. Frequency: ❑ MONTHLY ❑ QUARTERLY 0 EVERY 6 MONTHS ❑ OTHER (DESCRIBE): .1 6� " HMO;y�4S_.u, v. 3 AMA.-K't�.._ie� Y 1 Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW 00072532 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate 1 FA 1 Regulated Pollutant Particulate matter Emission Source ID NO. FS-C Applicable Regulation NCAC 2D.0515 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS WIRE x..v. a_. ... Y r,,.Jrtr-.sue' •� 3 ir`:eS: .#+%sz x"�A4-• .r� N 4e-3`a. a ... � & i -i t °':+ ".., .:a P i , c..-#fd`.,. :v,° ` ✓,=�!`3? '*Rx Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): .a f�,.Z'4"§..: ✓'�: _t' a`.Yi..%9. _..?`tirr�. .`_*�: .R,� _�?k fir. %Fisi#��l "aw yf � �6'X._O .. �a+V .k ai„ _.."�_y s�`. .;-., z'§.�i,... -.a .`rv'� 'fia; ,,�-w_ Data (Parameter) being recording: Production reocords will be maintained and will be available to a DAQ representative upon request. Frequency of recordkeeping (How often is data recorded?): Annual *" Generally describe what is being reported: Norte Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER (DESCRIBE): Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW 00072533 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate E3 Regulated Pollutant Visible emissions Emission Source ID NO. FS-B and FS-C Applicable Regulation NCAC 2D.0521 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGES TO EXPAND ON ANY OF THE BELOW COMMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes ❑X No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes 0 No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable -- This process does not produce visible emissions as demonstrated by the existing PVF Manufacturing Facility No. 1 that has has been in operation since Setember 2007. Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): BWi. Data (Parameter) being recording: Visible emissions will be determined via visual observation Frequency of recordkeeping (How often is data recorded?): Monthly Generally describe what is being reported: None Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER (DESCRIBE): Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW 00072534 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate E3 Regulated Pollutant Odor Emission Source ID NO. FS-C Applicable Regulation NCAC 2D.1806 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes M No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes ❑X No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe •In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): Data (Parameter) being recording: Not applicable Frequency of recordkeeping (How often is data recorded?): Generally describe what is being reported: Not applicable Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER (DESCRIBE): Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW 00072535 FORM E4 EMISSION SOURCE COMPLIANCE SCHEDULE Revised 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate ' E4 COMPLIANCE STATUS WITH RESPECT TO ALL APPLICABLE REQUIREMENTS Will each emission source at your facility be in compliance with all applicable requirements at the time of permit issuance and continue to comply with these requirements? 0 Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. Will your facility be in compliance with all applicable requirements taking effect during the term of the permit and meet such requirements on a timely basis? El Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. If this application is for a modification of existing emissions source(s), is each emission source currently in compliance with all applicable requirements? 21 Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. A. Emission Source Description (Include ID NO.) B. Identify applicable requirement for which compliance is not achieved: C. Narrative description of how compliance will be achieved with this applicable requirements: D. Detailed Schedule of Compliance: Step(s) E. Frequency for submittal of progress reports (6 month minimum): Not applicable F. Starting date of submittal of progress reports: Not applicable Date Expected Attach Additional Sheets As Necessary DEQ-CFW 00072536 r Revised 01/01/07 FORM E5 TITLE V COMPLIANCE CERTIFICATION (Required) NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate In accordance with the provisions of Title 15A NCAC 2Q .0520 and .0515(b)(4), the responsible company official of. SITE NAME: DuPont Fayetteville Works SITE ADDRESS: 22828 NC Highway 87 W CITY, NC: Fayetteville, NC 28306 COUNTY: Bladen PERMIT NUMBER: 03735T32 CERTIFIES THAT (Check the appropriate statement): Fx_1 The facility is in compliance with all applicable requirements E5 ❑ In accordance with the provisions of Title 15A NCAC 2Q .0515(b)(4) the responsible company official certififies that the proposed minor modification meets the criteria for using the procedures set out in 2Q .0515 and requests that these procedures be used to process the permit application. ❑ The facility is not currently in compliance with all applicable requirements If this box is checked, you must also complete form E4 "Emission Source Compliance Schedule" The undersigned certifies under the penalty of law, that all information and statements provided in the application, based on information and belief formed after reasonable inquiry, are true, accurate, and complete. K) Karen B. Wrigley, Plant Manager Name, Title of responsible company official (Type or print) Date: OWf Gajo8 Attach Additional Sheets As Necessary DEQ-CFW 00072537