DEQ-CFW_00085600

---------- L -------------------------------------
Division of Air Quality
Fayetteville Regional Office
8 November 2006
Memorandum
To: Mike Aldridge
From : Steven Vozzo
SUBJECT: Request for Central Office Review of APFO Stack Testing at Dupont
DuPont Company — Fayetteville Works, Air. Permit No. 03735T28
Duart Township, North Carolina, Bladen County 06/09-00009
As you recall, DENR and several Divisions (DWQ, DAQ, DWM) have been involved with the
environmental concerns with ammonium perfluorooctanoate (APFO) from Dupont's APFO
Manufacturing Facility. DENR had several meetings with Dupont about this pollutant and the
processes at the Bladen County plant. Dupont told us that they had agreed to perform detailed
sources tests to gain a better calculation of the emissions from this process. This pollutant has also
been a high profile concern for EPA. EPA's Dick Dubose and other Region IV folks had contacted
FRO DAQ and requested NC DAQ to carefully review the source testing per our standard testing
procedures. A protocol form was submitted by Dupont and forwarded to Shannon Vogel in your
group. On 24 March 2006, David Hughes completed a protocol review for the APFO testing. A
conditional approval was given for the proposed methodology— the big concern was that this method
is not certified for this particular pollutant.
The original plan was for two test dates to address two types of production - March 27 & 28 -
Purification Campaign (24 hour sampling), and April 3 & 4 - Virgin Campaign (30 hour
sampling). The March 27-28 testing was witnessed by Steven Vozzo (FRO) and David Hughes
(RCO) and the April 3-4 testing was witnessed by Christy Richardson (FRO).
Subsequently, Dupont tested again on 21 and 22 July 2006. DAQ was not aware of this testing
and thus did not witness. Dupont has stated they used the same protocol. On 1 November 2006
we received the source test reports for these three time periods. We are requesting that you
review these tests as soon as possible. We will forward this review document to both Dupont
and EPA Region IV.
Should you have any questions regarding this matter, please contact Christy Richardson,
Environmental Engineer, or Mitchell Revels, Environmental Chemist at [phone], in the
Fayetteville Regional Office.
\sfv
cc: -- DAQ Central Files ❑ FRO Files
DEQ-CFW 00085600

NCDENR
North Carolina Department of Environment and Natural f es®urces
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B, Keith Overcash, P.E., Director
8 November 2006
Mr. Barry Hudson, Plant Manager
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306
SUBJECT: Regional Office Receipt of Stack Test Results
DuPont Company — Fayetteville Works, Air. Permit No. 03 73 5T27
Duart Township, North Carolina, Bladen County O6 K27—O0=1-09
Dear Mr. Hudson:
This Division on 1 November 2006 received your stationary source test for ammonium
perfluorooctanoate (APFO) from your APFO Manufacturing Facility at DuPont Company —
Fayetteville Works. It is our understanding that this test was performed to gain a better calculation
of the emissions from this process. This test was conducted on 27-28 March 2006 and 2-4 April
2006. Additional testing was also conducted in July 2006. We have received the source test reports
for all three test periods. On this date we are forwarding a copy to the Raleigh Central Office
Stationary Source Compliance Group for the Division's review. The Central Office will notify us as
to whether your test was conducted properly. This Regional Office as to the final determination will
then notify you.
Should you have any questions regarding this matter, please contact Christy Richardson,
Environmental Engineer, or Mitchell Revels, Environmental Chemist at [phone], in the
Fayetteville Regional Office.
Sincerely,
Steven F. Vozzo
Regional Air Quality Supervisor
Fayetteville Regional Office
SFV\mr
cc: Shannon Vogel, RCO-Stationary Source Compliance (w/2"d copy of report & tracking form 2006-06-1 ST)
C- DAQ Central Files
D. FRO Files
Fayetteville Regional Office — Division of Air Quality
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043
Main Phone: [phone] \ DAQ Fax: [phone] \ Internet: http://www.ncair,org
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00085601

Test Report Transmittal Form - from Region to SSCB
1118/2006
Facility Name: DuPont Company - Fayetteville Works
PermitNo.: 03735 Revision No.: T28
Tracking No.: 2006-061 ST
Test Report Received in Region: 11/01/2006
Test Report Sent to SSCB: 11/08/2006
Test Start Date: 03/27/2006
Test Observer: Christy Richardson
County: Bladen
Facility ID: 0900009
Region: FRO
DEQ-CFW 00085602

A
NCDENR
Nort� Carolina Department of Environment and Natural Resources
Dilillsion of Air QLialltY Will G, Ross, Jr, kSecrertary
Michael F. Easley; Govemor
March 24, 2006
Mike Johnson
Bnvirori-mental Coordinator
DuPont Fayettevilleworks
22828 NC 87 Highway W
F Vt fflz, NC 28306 ayc+ eyl
for onlIXI-P til-UOTO OCt-i
arOtC (APF 0) ly 0-,4 U-,-
Subject: Test: Protocol 1 ff
Arnm
on a AFFO Manufacturing Facility
DuPont Company -7Fayetteville Works in Duart Township, Bladen County, NC
Air Permit No. 03735T28 Facility ID 03/09/00009
Proposed Test Date, March 27, 28 and April 3, 4 2006
Dear Mr.: Johnson:
The protocol submittal form (PSF) prepared by Integrity Air INIonitoring, Inc, has been reviewed
for the A=onium perfluorooctanoatc (APFO) emissions tastin&
abprpyd by this office as outlined beloa,
specific air pollutant.
Based on the information provided, APFO is currently unregulated as a specif testing is
APFO --gulated in a general sense, as particulate matter. The purpose of the proposed
to quanti�'y the specific quantities of AFFO emitted from the process. The proposed test
methodology utilizes existing EPA methods, but makes both modifications and analytical additions
I I ;
to these methods in order to measure APED. While these changes appear reasonable, (here is no
specific, information provided that assures DAQ that these methods will provide "compliance
quality' results, However, given that the results will not be used for any compliance purposes, the
methods are conditionally approved for the specific purpose provided.
s1lb by DAO� If the results
Any bfthl�r use of the results from this testing 1—� _sect to review
i -i --- At— "no-cl +nn'hn;rn1 -r*vif-ur and/tar validation of
Thv source to be tested consists of a APFO manufactming facility (ID No, AS -A) controlled by a
wet scrubber (ID No. ACD-Al) and a condenser (ID No. ACD-A?-). Integrity has proposed a
modified version of EPA Method 5 in order to improve the collection of APFO and enim-ice . its
detactability. The modification and justification are presented in the table below-.
1 &41 Mail Struics .�FPter, Raleigh, Nor0l Cardins 2,7659-1641
.1128 rjpild Slid., Rdlei h, North Carding 27504
phont 9940-1334728 / PAX 919-733-1812 1 Internet wxw,acQrkrg
An Equal OppodunitOAffirryiafiye Ackii E ni&Yer - 33 % qfacycle(y1o% PasA Consurnar Paper
IM'd t.,- , 9T 900,7 t7Z -141
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DEQ-CFW-00085603

Mike Johnsor,
March 24, 2006
Page 2 of 2
F-,Obe/box temperature set at no more than 10' stack gas temperature is ambient.
F above stack temperature. 4
Replace plair distilled water with ASTM TrPhis C 5 combination will provide the best solution
I Reasw,,- ::iade water in the Jimping'-27s. for absorbingthe surfactant.
Five (5) impinger train configuration The modification is intended to improve the
collection of APFO by providing an additional
absorption zone. The impingers will be loaded
as fol]QW5:
I
9 Impingers 1,2, oral 3 filled with 100-Tnl
each of
distilled water solution.
Irnping,= 4 i6 ompry
1pingcr 5 contains desi-want
Sample recovery will be performed with water
Sample recovery to remain consistent with the sample collection
reagent. All samples will be properly labeled
and submitted to an offsite lab for analysis.
Re,w,ewof this protocol does not exernpt the testa in any way, from the minimum requirements of
the applicable methods. The testing should be conducted in strict accordance with the
requirements of EPA Methods I through 4. The modified version of BPA Method 3 should be
conducted as provide in the FSF.and outlined in the above table.
Integrity has proposed to use; 2.9.0" for the stack gas dry molecular weight, According to Method 2
Section 8.6 'Tor processes Omitting essentially air, an analysis'need not be conducted; Use a dry
molecular weight of 29ff'- this is acceptable.
Any other modifications to the applicable 'Lest methods remain subject to approval by the Division
all relevant process/operating data is included and summarized in the
of Air Quality. Please insure 0
test report. if you have any questions, please &el free to contact me at
Ravi d.B-Hug—Yhes(@,ncmaiU or [phone].
David B, Hughes
Environmental Engineer
C c: Jarnes A. Lewis, Integrity Air Monitoring, Inc.
SSC13 File through MichaQ1 Aldridge
Christy Richardson Fayetteville Regional Office
IBEAM Documents 900009 (03/27/06)
Central Files — Blad'q, County
Tracking No. 2006-0,61 ST
20'd SZ:9T 90U� VZ JPW ZT8T22Z6T6: x7j, Airiuno diu
DEQ-CFW-00085604