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HomeMy WebLinkAboutDEQ-CFW_00073246NORTH CAROLINA DIVISION OF AIR QUALITY Air Permit Review Permit Issue Date: 10/02/2014 Facility Data Applicant (Facility's Name): DuPont Company - Fayetteville Works Facility Address: DuPont Company - Fayetteville Works 22828 NC Highway 87 West Fayetteville, NC 28306 SIC: 3081 / Unsupported Plastics Film And Sheet NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging) Manufacturing Facility Classification: Before: Title V After: Title V Fee Classification: Before: Title V After: Title V Contact Data Facility Contact Authorized Contact Technical Contact Michael Johnson Ellis McGaughy Michael Johnson Environmental Manager Plant Manager Environmental Manager (910) 678-1155 (910) 678-1224 (910) 678-1155 22828 NC Highway 87 22828 NC Highway 87 22828 NC Highway 87 West West West Fayetteville, NC Fayetteville, NC 28306 Fayetteville, NC 28306+7332 28306+7332 Total Actual emissions in TONS/YEAR: Region: Fayetteville Regional Office County: Bladen NC Facility ID: 0900009 Inspector's Name: Gregory Reeves Date of Last Inspection: 02/17/2014 Compliance Code: 3 / Compliance - Permit Applicability (this application only) SIP: NSPS: NESHAP: PSD: PSD Avoidance: NC Toxics: 112(r): Other: P&O REVIEW MODIFICATION ADD EMERG GENERATOR Application Data Application Number: 0900009.1413 Date Received: 09/16/2014 Application Type: Modification Application Schedule: TV -Minor Existing Permit Data Existing Permit Number: 03735/T38 Existing Permit Issue Date: 12/16/2013 Existing Permit Expiration Date: 01/31/2015 CY S02 NOX vOC CO PM10 Total HAP Largest HAP 2013 0.2100 80.13 312.90 30.45 9.47 33.71 19.93 [Methanol (methyl alcohol)] 2012 1.23 63.76 260.86 29.24 7.95 28.44 18.70 [Methanol (methyl alcohol)] 2011 2.74 73.06 271.17 31.42 11.31 29.39 17.51 [Methanol (methyl alcohol)] 2010 2.04 43.89 296.10 13.12 9.25 37.52 17.49 [Methanol (methyl alcohol)] 2009 0.9800 37.00 225.44 11.54 7.20 23.40 15.19 [Methanol (methyl alcohol)] Review Engineer: Heather Sands Comments / Recommendations: Regional Office Engineer: Gregory Reeves Regional Office Engineer's Signature: Date: P&O Review Date: 10/02/2014 DEQ-CFW 00073246 DuPont Company — Fayetteville Works Permit T39 P&O Review .14B 10/02/2014 Page 2 of 3 1. Purpose of Application: DuPont Company — Fayetteville Works is a chemical manufacturing facility located in Fayetteville, Bladen County. The facility produces specialty fluorocarbon materials. The facility has requested a modification of their air permit to add a new 147 KW diesel -fired emergency generator. The facility is classified as Title V due to emissions of VOC and HAP exceeding the Title V permitting thresholds. The facility is Title III HAP Major. The facility is an existing PSD Major Source for VOC, with actual VOC emissions exceeding 250 tons per year during calendar year 2013. The application did not contain any confidential information. The facility contact for the permit application is Mike Johnson, Environmental Manager (910- 678-1155). 2. Facility and Application Chronology: 09/16/14 FRO received a copy of the permit application. The permit application was also submitted directly to RCO, including a check in the amount of $904 for the applicable permit processing fees. 3. Changes in Equipment: There are no recent 502(b)(10) modifications to be incorporated into this permit action. The facility is proposing to purchase and install a new 147 KW diesel -fired emergency generator. No other modifications are requested. 4. NSPS, NESHAP, PSD, Attainment Status,112(r), and Greenhouse Gases (GHG): • NSPS — The new emergency engine will be subject to NSPS Subpart IIII "Compression Ignition Internal Combustion Engines." • NESHAP —The new emergency engine will be subject to NESHAP Subpart ZZZZ "Stationary Reciprocating Internal Combustion Engines." • PSD — The facility has emissions of VOC that exceed the PSD permitting threshold. The facility is included in the 28 source categories subject to 100 ton per year PSD thresholds for criteria pollutant emissions. • Attainment Status — Bladen County is in attainment for ozone and PM2.5 • 112(r) - The facility stores Tetrafludroethylene, Oleum, Vinyl Fluoride, and Sulfur Trioxide in four different chemical processes in amounts that exceed the threshold quantities. Therefore, the facility is required to maintain a written Risk Management Plan (RMP). The latest update to the facility's RMP was submitted to EPA on 02/01/2011. DEQ-CFW 00073247 DuPont Company — Fayetteville Works Permit T39 P&O Review .14B 10/02/2014 Page 3 of 3 • Greenhouse Gases (GHG) — According to the most recent facility -submitted emission inventory for 2013, the facility's actual GHG emissions, in CO2 equivalent (COze) is 112,315 metric tons (123,806 short tons), which exceeds the 100,000 short tons PSD permitting threshold. 5. Facility Compliance Status: 02/17/14 The most recent facility inspection was performed by Greg Reeves. The facility was found to be in apparent compliance. 05/27/10 The facility was inspected four (4) times by Tien Nguyen, Maureen Matroni-Rakes, and through Greg Reeves. The facility was found to be in apparent compliance during each of these 06/20/13 inspections. 01/23/12 Greg Reeves performed a full CAA Section 112(r) inspection. The facility was found to be in apparent compliance. 04/29/09 Enforcement for operating without a permit. Civil Penalty of $3,285 was assessed and paid. 01/06/09 NOV/NRE Issued for operating without a permit. Several sources subject to permit requirements were being operated without a permit. Subsequent Enforcement action resulted on 04/29/09. This resulted from the facility self -reporting the violation by submission of a permit application for the unpermitted sources. 6. Conclusions, Comments, and Recommendations: If DuPont Company — Fayetteville Works submits any revisions to this application, including any significant response to additional information requests, FRO requests a contemporaneous copy for additional review. FRO requests the opportunity to review the draft permit and permit review prior to issuance of the permit. Additionally, as part of this review process, FRO requests copies of all correspondence regarding this application, including a -mails and meeting notes. FRO recommends a review of the GHG emissions from the facility for possible inclusion of GHG requirements (if any) in the permit. Review Engineer: Permit Coordinator: DAQ Supervisor: \GWR cc: FRO Files Date: Date: Date: DEQ-CFW 00073248