DEQ-CFW_00074946

West Virgitda Dept of Em*omnv td Protection
Division o f Air Quafity
Fact Sheet
For Proposed Minor Moth cation Permitting Action Chafer 45CSR3 0 and
Title V of the Cfean.Air Act
This Fact Sheet serves to address the changes specific to this Minor Modification, and shall be considered
a supplement to the Fact Sheet corresponding with the Title V operating permit issued on December 1,
2010.
Permit Number: R30-10700001-2010
Applications Received: MM01: April 30, 2012
MM02: August 22, 2012
MM03: November 1, 2012
MM04: November 13, 2012
Plant Identification Number: 03-54-10700001
Permittee: E. I. du Pont de Nemours and Company
Facility Name: Washington Works
Business Unit: Fluoropolymers (Part 2 of 14)
Mailing Address: P.O. Box 1217, Washington, WV 26181-1217
Permit Action Number: MMO1, MM02, MM03, and MM04 Revised: Proposed
Physical Location: Washington, Wood County, West Virginia
UTM Coordinates: 442.3767 km Easting • 4,346.8331 km Northing • Zone 17
Directions: Route 68 west from Parkersburg to intersection of Route 892. Continue
west on Route 892 with the plant being on the north side about one mile
from the intersection of Routes 68 and 892.
Facility Description
Within the Fluoropolymers Business Unit, there are the following Fluoroproduct production areas: C1P, C2, C3,
T1-T4 and T7, T5, and T6. Each area produces a product or family of products by varying operating conditions and
small adjustments to raw material ratios or material feed rates. The following is a general description of the
operations in each of the Fluoroproduct production areas within the Fluoropolymers Business Unit.
DEQ-CFW 00074946

Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 2 of 9
E. I. du Pont de Nemours and Company • Fluoronolvmers (Part 2 of 14)
C1P Area
Within the "C1P" area of DuPont Washington Works is a process capable of producing a variety of products in
dispersion, flake and cube form. These products are made from fluoromonomers produced at the Washington Works
Facility along with monomers from outside sources. The main product from this process is TEFLON® PFA.
C2 Area
The C2 Area manufactures fluoropolymer resins by precharging fluoromonomers into reactors along with
demineralized water. Aqueous solutions of catalyst salts are then pumped into the reactors to initiate
polymerization. Additional fluoromonomers are fed into the reactors as the reaction proceeds. Unreacted
fluoromonomers are vented to recycling facilities at the end of the reaction. The remaining fluoropolymer and water
slurry is pumped to agglomerators that mechanically separate the fluoropolymer from the water. Alternatively, the
reactor output may be sent to facilities which concentrate the dispersion to higher solids and package the dispersion
for sale. From the agglomerators, the polymer is conveyed to devices where water and other low boiling compounds
are removed prior to extrusion. The polymer is then converted to pellets via an extrusion process. The pellets are
hot air sparged to remove additional traces of miscellaneous volatile fluorocarbons, elutriated to remove traces of
polymer fines and packaged for distribution
C3 Area
The C3 area manufactures various molecular weight Telomers, which are short, straight chain carbon -fluorine
compounds. Telomer products are most commonly made up of the short chain compounds with four to fourteen
carbons. There are several recipes, one of which is selected to make a desired product. All recipes perform similarly
in that:
• Lower molecular weight (MW) Telomers are added to a reactor.
• Monomer and other raw materials are added and reacted to form more lower MW Telomers and to convert
lower MW Telomers to higher MW Telomers.
• At the end of reaction, the reaction mass is transferred to distillation which is used to separate the different
MW Telomers. Lower MW Telomers are put into hold tanks for re -use in the reactor. Higher MW
Telomers remain in the distillation pot and become Telomer product.
• The Telomer product is filtered and transferred to product storage tanks.
• The finished Telomer product is loaded into tank trailers for shipment.
T1-T4, and T7 Areas
The T1-T4, and T7 areas produce final products fluoromonomers tetrafluoroethylene (TFE) and
hexafluoropropylene (HFP); an intermediate, perfluorocyclobutane; and byproducts hydrogen chloride (HCI,
aqueous) and calcium fluoride (CaF2, solid). The production facility is divided into the following sections: Tl-TFE
Synthesis, T2-TFE Refining, T3-HFP Synthesis, T4-HFP Refining, and T7-Utilities.
Fluorocarbons are reacted by pyrolysis in the T1 area and the products are separated to form crude TFE and
recovered byproducts. TFE is refined in the T2 area. In -process materials and intermediates are reacted by
pyrolysis in the T3 area to form crude HFP that is then refined in the T4 area. The T7 area is comprised of several
utilities, including: refrigeration and cold brine supply; the unit vacuum systems for maintenance clearing of
equipment; waste acid neutralization; and the thermal converter. The thermal converter combusts fluorine -
containing byproduct gases from the Tl-T4 process areas and from polymerization operations in the C1P, C2, C3,
and T6 areas; and from two different non -hazardous fluorine -containing liquid streams to produce aqueous hydrogen
fluoride (HF) which is reacted with slaked lime (calcium oxide or CaO) to form CaF2.
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074947

Title V Fact Sheet R30-10700001-2012 (MMOI, MM02, MM03, and MM04) Page 3 of 9
E. I du Pont de Nemours and Company • Fluoronolvmers (Part 2 of 14)
T5 Area
The T5 area produces fluoropolymer resin. The basic processes used are polymerization, drying, and modification.
The resin is produced by water based emulsion polymerization in one of two reactor units. Water, monomer
(primarily tetrafluoroethylene), process aids, and other minor ingredients are introduced to the reactor. The reaction
starts under elevated pressure, but proceeds to an endpoint at sub -ambient pressure. The resin is removed as slurry
and is stored in one of several tanks pending further treatment and drying. The polymer slurry is processed and
dried. The wet polymer passes through one of two dryers. Emissions from either dryer pass through cyclone
separators to recover particulate matter. Both cyclone systems employ a water spray to improve effectiveness. The
material recovered from the cyclones is returned to the process. Dried resin is transferred to a pack -out room where
it is drummed using automated equipment. Air from the pack -out room is exhausted though a scrubber. The
recovered material from the packout exhaust is not recycled to the process.
T6 Area
The Teflon® T6 area produces TFE based homopolymers in four agitated batch reactors. The reaction takes place in
an aqueous medium, and a milk white raw polymer dispersion in water is produced. A portion of the raw dispersion
production is dried and sold as powder, and a portion is processed and sold as a finished aqueous dispersion.
Copolymer dispersion products are also made. A batch is started by adding water and other ingredients to the
reactor. Polymerization takes place in the aqueous phase at high temperature and pressure. At the end of each
batch, most of the unreacted material is recycled for reuse or sent to the thermal converter. Some products are made
by partially concentrating the reactor output in a water/solids separation vessel where some of the water is removed.
For product sold as fine powder, the material is dried at high temperature with subsequent removal of impurities.
The dried product is cooled and packaged.
The following minor modifications incorporate the changes to the following NSR Permit Revisions:
MMO1—R13-1953H
MM02 — R13-0815G
MM03 — R13-2365E
MM04 — R13-1353E
Emissions Summary
As a result of this modification, the facility will have the following change in emissions:
R13-1953H
Regulated Pollutant
Emissions Change
lb/hr
tpy
PM10
-1.50
-0.49
VOC
2.11
1.75
Hydrogen Flouride (HF)
-0.53
-1.10
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074948

4
Title V Fact Sheet R30-10700001-2012 (MMOI, MM02, MM03, and MM04) Page 4 of 9
E. I. du Pont de Nemours and Company • Fluoronolvmers (Part 2 of 14)
R13-0815G
Regulated Pollutant
Emissions Change
lb/hr
tpy
PMI0
400
0.20
VOC
-3,280
-1.64
ODC
2,620
1.35
Acetonitrile
-36
-0.018
Toluene
-6
-0.003
R13-2365E
Regulated Pollutant
Emissions Change
lb/hr
tpy
PM
-0.01
-0.05
PMI0
-0.01
-0.03
HF
-0.29
-1.26
VOC
0.31
1.35
R13-1353E
Regulated Pollutant
Emissions Change
lb/hr
tpy
ODC
1.4
0.28
VOC
-42.9
7.33
Hydrogen Fluoride (HF)
-0.02
1 -0.044
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074949

P
Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 5 of 9
E. I du Pont de Nemours and Company • Fluoronolvmers (Part 2 of 14)
Overall
Regulated Pollutant
Emissions Change
lb/hr
tpy
PM
-0.01
-0.05
PMI0
398.5
-0.32
VOC
- 3,320
-5.87
ODC
2,621
1.63
Hydrogen Fluoride (HF)
-0.84
-2.40
Acetonitrile
-36
-0.018
Toluene
-6
-0.003
Title V Program Applicability Basis
With the proposed changes associated with this modification, this facility maintains the potential to emit
over 100 tons per year of criteria pollutants, over 10 tons per year of an individual HAP, and over 25 tons
per year aggregate HAPs. Therefore, DuPont Washington Works is required to have an operating permit
pursuant to Title V of the Federal Clean Air Act as amended and 45CSR30.
Legal and Factual Basis for Permit Conditions
The State and Federally -enforceable conditions of the Title V Operating Permits are based upon the
requirements of the State of West Virginia Operating Permit Rule 45CSR30 for the purposes of Title V of
the Federal Clean Air Act and the underlying applicable requirements in other state and federal rules.
The modification to this facility has been found to be subject to the following applicable rules:
Federal and State: 45CSR13 Permits for construction, modification,
relocation, etc.
45CSR30 Operating permit requirement.
State Only: N/A
Each State and Federally -enforceable condition of the Title V Operating Permit references the specific relevant
requirements of 45CSR30 or the applicable requirement upon which it is based. Any condition of the Title V permit
that is enforceable by the State but is not Federally -enforceable is identified in the Title V permit as such.
The Secretary's authority to require standards under 40 C.F.R. Part 60 (NSPS), 40 C.F.R. Part 61 (NESHAPs), and
40 C.F.R. Part 63 (NESHAPs MACT) is provided in West Virginia Code §§ 22-5-1 et seq., 45CSR16, 45CSR34 and
45CSR30.
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074950

Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 6 of 9
E. I. du Pont de Nemours and Company • Fluormolymers (Part 2 of 14)
Active Permits/Consent Orders
Permit or
Consent Order Number
Date of
Issuance
Permit Determinations or Amendments That
Affect the Permit (if any)
R13-1953H
8/31/2012
R13-0815G
10/11/2012
R13-2365E
4/4/2013
R13-1353E
2/21/2013
Conditions from this facility's Rule 13 permit(s) governing construction -related specifications and timing
requirements will not be included in the Title V Operating Permit but will remain independently enforceable under
the applicable Rule 13 permit(s). All other conditions from this facility's Rule 13 permit(s) governing the source's
operation and compliance have been incorporated into this Title V permit in accordance with the "General
Requirement Comparison Table B," which may be downloaded from DAQ's website.
Determinations and Justifications
Changes made to the Title V Permit as part of this minor modification are summarized below:
Changes to C2 Area resulting from:
1. R13-1953H Changes
A) Section 1.0 - removal of the following equipment that is on the Insignificant List: C213J,
C2EE, C2KY, C2KZ; and addition of C2DH.
B) 1. Removed equipment that is no longer in service.
2. Updated significant figures to DAQ rounding policy.
3. Updated emissions in Conditions 5.1.1 through 5.1.3 due to inclusion of anew
Dimer Acid/Salt compound that will be used in the C2 process area as a phased
in replacement for APFO. The change will result in:
a. New or increased VOC emissions related to the new compound and its
degradation product El.
b. Addition of acetonitrile emissions as an impurity in the new compound
from emission points C2DTE and C2EFE. These emissions are
included in the revised VOC emissions in Condition 5.1.2.
C. Increase in emissions from C2EQ to reflect additional screen pack
changes.
d. Revised emission calculations to reflect operating scenarios using
100% APFO or 100% new compound. Since the use of both
compounds will occur over a multi -year phase in period, permit limis
were established to cover both scenarios.
e. Addition of VOC emissions from emission point C2DTE due to El.
4. C2DJ will no longer be a backup process tank for C2DK and will be receiving
decant waters from C2EG. Since no regulated pollutants will be emitted from
C2DJ in this service, control device C2DJC and emission point C2DJE were
removed.
5. Updated Condition 5.1.4 to "total HAPs" for all emission points and identified
them in the footnote.
C) Condition 5.1.7 - Added "the current revision of prior to "permit R13-1823".
D) Conditions 5.1.8, 5.1.9, 5.2.1, 5.2.2, 5.2.3, and 5.2.4 - removed references to equipment
that is no longer in service
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074951

Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 7 of 9
E I du Pont de Nemours and Company • Fluoropolvmers (Part 2 of 14)
E) Section 5.2.1 - corrected reference from 5.1.1 to 5.1.8.
F) Appendix B, Attachment A - (1) changed parameter language from "C2EJE" to "System
#V and "C2EFE" to "System #2"; (2) Deleted parameters for C2DI and C2EB that were
removed from service; (3) Added monitoring as indicated below.
Additions to Monthly Record Keeping, Attachment A
Equipment ID Monthly Monitoring Parameter
Facility # of completed GenX batches
C2DA # of completed dispersion batches
C213A # of GenX dispersion batches
C2DW Max pph held for one hour during the month
C2EH Max pph held for one hour during the month
C2DT, C2DW, C2EH Max pph rate of all TDD for one hour during the month
G) Appendix B, Attachment B - deleted emission points C2DBE, C2DJE, C2DME,
C2EBE1, C2EBE2, C2KAE, C2KIE, and C2KNE that have been removed from service.
H) Appendix B, Attachment C - (1) deleted emission points C2DBE, C2DJE, C2DME,
C2EBE1/C2EBE2, C2KAE, C2KIE from VOC Emissions and added C2DTE; (2) deleted
emission points C2DBE, C2DJE, C213ME, C2EBE1/C2EBE2, and C2KIE from PM10
emissions; (3) deleted C2DBE, C2DME, C2EBE1/C2EBE2, C2KAE, C2KIE, and
C2KNE from HF emissions; (4) and combined Toluene & Total HAP emissions section
into "total HAPs".
I) Appendix B, Attachment D - deleted scrubber C2DBC.
Changes to T6 Area resulting from:
2. R13-0815G Changes
Changes to the Emissions Unit Table in Section 1.0 and Condition 9.1.5 have been made because
of the following:
A) Inclusion of the new compound (Dimer Acid/Salt (CAS # 13252-13-6 and CAS # 62037-
80-3)) that will be used in the T6 process area as a phased in replacement for APFO. The
compound may also be referred to as FRD903, FRD902 or FRD905.
B) Revised calculations to reflect changes in emissions related to the new compound and its
degradation product El (also a VOC).
C) Revised calculations for acetonitrile emissions as an impurity in the new compound in
addition to reducing the impurity value in another raw material.
D) Increase in ODC emissions from various units as a result of new assumptions.
E) Revised emission calculations to reflect operating scenarios using 100% APFO or 100%
new compound. The use of both compounds will occur over a multi -year phase in
period. Therefore permit limits need to be established to cover both scenarios.
F) Addition of VOC emissions from emission points T6IZCE, T6IEE, T6IFE, and T6IVE
due to El.
G) Changing service of T6PG and T6PH to remove potential production of certain product
types no longer planned.
H) Removed permitted emergency vents from the Emission Units Table and emission limits
in Condition 9.1.5 for T6IBE2, T6ICE2, T61DE2, and T6IUE2.
Changes to CIP Area resulting from:
3. R13-2365E Changes
A) Inclusion of the new compound (Dimer Acid/Salt (CAS# 13252-13-6 and CAS 462037-
80-3)) that will be used in the Cl-P process area as a phased in replacement for APFO.
The compound may also be referred to as FRD903, FRD902 or FRD905.
B) Revised calculations to reflect changes in emissions related to the new compound and its
degradation product El (CAS 43330-15-2 also a VOC). The affected emission limits are
given in Condition 4.1.1.
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074952

Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 8 of 9
E. I. du Pont de Nemours and Company • Fluoropolvmers (Part 2 of 14)
C) Removed CIGYE and CIGY from the Emission Units Table in Section 1.0 and
Conditions 4.1.1 and 4.1.2 because these emission units were removed from service.
D) Removed emission point CICHE and its associated scrubber C1CHC from the Permit
because the emission units were removed from service; and added emission point CINPE
and its associated scrubber CINPC.
E) Eliminated parametric monitoring requirements for C1FSC1 from Condition 4.2.2.
Source C1FSC1 is a baghouse used to separate entrained product from the air stream.
Any material that would exit this device due to a failure would enter the downstream
recovery/control device C1FSC2 which has process interlock settings based on high
pressure (Table 4.2.2.a). The monitoring for C1FSC1 is not needed to insure proper
emission control from downstream equipment discharging through C1FSE. Further
parametric monitoring has been added to this Condition for C1FSC2 and CITSC3.
F) Condition 4.3.1 has been revised to eliminate the initial compliance test and add a
requirement to test within 90 days of the date the production rate exceeds 120% of the
rate demonstrated from the previous compliance test.
G) Removed C1GYE from the Rule 21 list given in Appendix E.
H) Appendix A, Attachment A - removed CIGY and CICH from monthly records; added
parameters for CIFQ, CIGK, and CIFV; and (3) corrected the equipment descriptions for
CIFS and CIFV.
1) Appendix A, Attachments B & C - (1) removed CIGYE, area emissions from CIGY, and
CICHE from Attachments B & C; (2) removed CIGY from the monthly and annual
emissions for emission points C1FQE, C1FWE, and C1GXE; and (3) added CINPE in
Attachment B and Attachment C for VOC emissions.
Changes to T5 Area resulting from:
4. R13-1353E Changes
A) Removal of Ovens TSHQ and TSHR from Condition 8.1.1.
B) Revision of emission limits in Condition 8.1.1. This is due to the following:
1. Inclusion of the new compound (Dimer Acid/Salt (CAS # 13252-13-6 and CAS #
62037-80-3)) that will be used in the T5 process area as a phased in replacement for
APFO. The compound may also be referred to as FRD 903/902 or FRD905.
2. Revised calculations to reflect changes in:
a. emissions related to the new compound and its degradation product E1 (also a
VOC);
b. changes in aborted batch numbers;
c. flexibility to manufacture products with different recipes in TSHC and TSHD;
d. revised approach to calculations for TSHC and TSHD; and
e. acetonitrile emissions as an impurity in the new compound in addition to
reducing the impurity value in another raw material. These emissions are
included in the revised VOC emissions of Condition 8.1.1.
3. Revised emission calculations reflecting operating scenarios using 100% APFO or
100% new compound. The use of both compounds will occur over a multi -year phase
in period. Therefore permit limits need to be established to cover both scenarios.
4. Addition of VOC emissions from emission point TSHIE due to El.
C) Revised operation for venting residual gases after reactions in TSHC and TSHD to vents
TSHCE and TSHDE instead of "Area" emission point. Because this mode of operation
has not yet been tested and proven the current TSHC/TSHD Area VOC limit was retained
in Condition 8.1.1 to allow for either operating scenario.
Non -Applicability Determinations
1. Greenhouse Gas Tailoring Rule
This modification did not trigger a PSD permit. As such, there are no applicable GHG permitting
requirements.
Request for Variances or Alternatives
None
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074953

Title V Fact Sheet R30-10700001-2012 (MM01, MM02, MM03, and MM04) Page 9 of 9
E. I du Pont de Nemours and Comnanv • Fluoronolvmers (Part 2 of 14)
Insignificant Activities
Insignificant emission unit(s) and activities are identified in the Title V application.
Comment Period
Beginning Date: N/A
Ending Date: N/A
All written comments should be addressed to the following individual and office:
Mike Egnor
Title V Permit Writer
West Virginia Department of Environmental Protection
Division of Air Quality
601 57' Street SE
Charleston, WV 25304
Procedure for Requesting Public Hearing
During the public comment period, any interested person may submit written comments on the draft permit
and may request a public hearing, if no public hearing has already been scheduled. A request for public
hearing shall be in writing and shall state the nature of the issues proposed to be raised in the hearing. The
Secretary shall grant such a request for a hearing if he/she concludes that a public hearing is appropriate.
Any public hearing shall be held in the general area in which the facility is located.
Point of Contact
Mike Egnor
West Virginia Department of Environmental Protection
Division of Air Quality
601 57' Street SE
Charleston, WV 25304
Phone: [phone] ext. 1208 • Fax: [phone]
Response to Comments (Statement of Basis)
(Choose) Not applicable.
OR
Describe response to comments that are received and/or document any changes to the final permit from the
draft/proposed permit.
West Virginia Department of Environmental Protection • Division of Air Quality
DEQ-CFW 00074954