DEQ-CFW_00085512

DIVISION OF AIR QUALITY
December 11, 2006
MEMORANDUM
To: Steven Vozzo, Fayetteville Regional Office �(�
From: Shannon M. Vogel, Stationary Source Compliance Branch ,�1
Subject: E.I. du Pont de Nemours & CO. LLC
DuPont Company — Fayetteville Works
Duart, Bladen County, North Carolina
Facility ID 09/00009, Permit No. 03 73 5T28
Ammonium Perfluorooctanoate (APFO) Emissions Testing of the APFO Process
Performed on March 27 and 28, April 3 and 4, 2006 by Integrity Air Monitoring
And Performed July 21 and 22, 2006 by Ramcon Environmental
The Stationary Source Compliance Branch has reviewed the report for the March and April 2006 testing
by Integrity and the report for the July 2006 testing by Ramcon. DuPont and Integrity submitted a
protocol to perform a modified EPA Method 5 to test for ammonium perfluorooctanoate (APFO)
emissions. As discussed in the protocol review letter from David Hughes dated March 24, 2006, APFO is
not a regulated air pollutant and the proposed method has not been validated for compliance testing of this
pollutant. Integrity performed testing at the APFO process stack in March and April 2006 for two
operating conditions and Ramcon performed simultaneous testing at four sampling locations in July 2006.
Integrity and Ramcon performed modified EPA Method 5 testing for AFPO emissions. The sampling
was performed in accordance with modified EPA Method 5 sampling procedures. Although the
calculations seemed to have been performed correctly, the test results are not acceptable for compliance
or emissions estimations purposes due to the fact that the method is not a validated method for this
pollutant.
In addition to the fact that this method is not validated for APFO emissions, SSCB noted other
deficiencies in the sampling reports as discussed below. The laboratory did not specify in either report
the method used to analyze for APFO and PFOA. No sample custody sheets were included in the test
reports. The analytical results for the rinse water were reported by the laboratory in nanograms per liter,
but since rinse volumes were not reported, the APFO catch weights for the rinse sample fractions could
not be calculated. And finally, DuPont provided no technical data to support that this method accurately
quantifies the APFO emissions.
In conclusion, Integrity and Ramcom seemed to follow the proposed sampling plan, but due to the fact
that this method has not been validated for APFO emissions, the results are not acceptable for emissions
estimation purposes, for compliance demonstration or for any other regulatory purposes. If you have any
questions regarding the results of this review, please contact me at [phone] or
[e-mail].
cc: Central Files, Bladen County.
SSCB File through Michael Aldridge
IBEAM Documents — 09/00009 (March, April, July 2006)
Tracking No. 2006-061 ST and 2006-282ST
DEQ-CFW 00085512