DEQ-CFW_00085934

I'rn 't
auPANT DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
December 4, 2008
Mr. William Willets
NCDENR — Division of Air Quality
Permits Section
1641 Mail Service Center
Raleigh, NC 27699-1641
SUBJECT: Title V Air Permit Modification
Air Quality Permit No. 03735T32
DuPont Company — Fayetteville Works
Facility ID: 03/09/00009
Dear Mr. Willets:
The DuPont Company — Fayetteville Works ("DuPont") is requesting a modification of the
subject Title V air permit for the various changes enumerated below.
DuPont is opting to obtain a construction and operation permit pursuant to 15A NCAC 2Q.0504,
and as such is submitting both the Part 1 application and fee and the Part 2 application and fee
with this single submission.
To expedite the permit modification process, enclosed are two application copies and the
required confidential information for the Part 1 application, and two application copies and the
required confidential information for the Part 2 application. A check for $1734 to cover the cost
of both application fees ($867 each) for these two applications has already been received by the
Division of Air Quality Permitting Section.
As required by the subject permit, the original and two copies of an application and the required
confidential information for the Part 1 permit application, and the original and two copies of an
application and the required confidential information for the Part 2 permit application have been
sent to the attention of Mr. Steven Vozzo at the Division of Air Quality's regional office in
Fayetteville.
E.I. du Pont de Nemours and Company
DEQ-CFW 00085934

Mr. William Willets
NCDENR , Division of Air Quality
December 4, 2008
Page 2 of 5
This application is for the following ten (10) permit modifications:
I, to establish as a new emission source a natural gas -fired or No. 2 oil -fired boiler, 97 million
BTU per hour maximum heat input (Emission Source ID No. PS-C); ✓✓
2. to establish as a new emission source the HFPO product cylinder decontamination process
(Emission Source ID No. NS-N); ✓
to establish as a new emission source the Vinyl Ethers North product cylinder
decontamination process (Emission Source ID No. NS-O); _
4. to establish as a new emission source the Vinyl Ethers South product cylinder
_ decontamination process (Emission Source ID No. NS-P); ✓
'S! to change the identification of the current SentryGlas® Plus Manufacturing Facility to the
SentryGlas® Manufacturing Facility (Emission Source ID No. SGS-A);
j to modify the description of the/No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-1) to include
! natural gas as a fuel source;
i
g1to modify the description of the No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-2) to include
natural gas as a fuel source;
to modify the description of the No. 2 fuel oil -fired temporary boiler (ID No. PS -Temp) to
it
include natural gas as a fuel source; ✓
to modify the insignificant activity description of the Abrasive Blasting Building (Emission
Source ID No. I-10) to include periodic painting of equipment; and
�correct a typographical error in Part 2.1(I)(4)(a) in which the Emission Source ID
Number for the Poly-v l Fluoride (PVF),.Mafa nuct4ring Facility No. 2 is shown
.._—
incorrectly asX�No. FL-C versus the corre t ID No. FS-C. J
You will find all of the confidential information for this application in a separate envelope.
Pursuant to North Carolina General Statutes §132-1.2, §143-215.3C(a), and §143-215.65,
DuPont requests that access to the information which is contained in the confidential information
package, which would divulge information regarding methods or processes entitled to protection
as trade secrets and confidential business information, be restricted exclusively to Division of Air
Quality personnel.
Natural gas -fired or No. 2 oil -Bred boiler, 97 million BTU per hour maximum heat input
(Emission Source ID No. PS-C)
DuPont is requesting a construction and operating permit to install a new package boiler. The
boiler will rated for 97 million BTU per hour and will be fired with either natural gas or No. 2
fuel oil. This boiler will increase the reliability of steam supply for the site.
DEQ-CFW 00085935

Mr. William Willets
NCDENR Division of Air Quality
December 4, 2008
Page 3 of 5
Because of the boiler's design capacity will be less than 100 million BTU per hour, it is
classified as a small boiler and will be subject to the New Source Performance Standard
("NSPS") codified in 40 CFR 60 Subpart De. The subject boiler will comply with all the
requirements specified in the NSPS Subpart Dc.
The boiler will include low-NOx burner t t will control the emissions of nitrogen oxides by at
least 35%. This 97 mi i'11'on BTTJ pef-dour boiler with the low-NOx burner will not have a
potential to emit any of the new source review ("NSR") pollutants at or above the significant
emission rates listed in 40 CFR 51.166(b)(23)(i).
The sulfur dioxide emissions from this boiler will be included in the facility -wide PSD avoidance
limit of 702.5 tons S02 per year specified in Section 2.2(A)(1) of the subject permit, which
applies to all combustion sources at this site. This limit is also found in the table in Section
2.1(A) of the permit.
fHFPO Product Cylinder Decontamination Process (Emission Source ID No. NS-N)
DuPont is requesting the HFPO Product Cylinder Decontamination Process be added to the
subject Title V air permit. This is an existing, unpermitted activity in which product containers
(one -ton cylinders and ISO tank containers) that are returned from customers are decontaminated
by venting residual product (a volatile organic compound or "VOC") to the atmosphere.
Actual emissions for this emission source for 2008 is estimated to be 37.1 tons VOC.
The potential to emit for this emission source is estimated to be 100.3 tons VOC per year. This
emission rate is greater than the 40 tons VOC per year significant emission rates listed in
40 CFR 51.166(b)(23)(i).
Therefore, pursuant to 15A NCAC 2Q .0317, in order to avoid the applicability of 15A NCAC
2D .0530, DuPont is requesting that a PSD avoidance limit of 40 tons VOC per consecutive
12-month period be established for this source.
JVinyl Ethers North Product Cylinder Decontamination Process (Emission Source ID No.
NS-O)
DuPont is requesting the Vinyl Ethers North Product Cylinder Decontamination Process be
added to the subject Title V air permit. This is an existing, unpermitted activity in which product
containers (one -ton cylinders and ISO tank containers) that are returned from customers are
decontaminated by venting residual products (VOCs) to the atmosphere.
The potential to emit for this decontamination process is estimated to be 20.6 tons VOC per year.
This emission rate is less than the 40 tons VOC per year significant em 'ssion rate listed in
40 CFR 51.166(b)(23)(i).
DEQ-CFW 00085936

Mr. William Willets
NCDENR , Division of Air Quality
December 4, 2008
Page 4 of 5
Vinyl Ethers South Product Cylinder Decontamination Process (Emission Source ID No.
NS-P)
DuPont is requesting the Vinyl Ethers South Product Cylinder Decontamination Process be
added to the subject Title V air permit. This is an existing, unpermitted activity in which product
containers (one -ton cylinders and ISO tank containers) that are returned from customers are
decontaminated by venting residual products (VOCs) to the atmosphere.
The potential to emit for this decontamination process is estimated to be 10.7 tons VOC per year.
This emission rate is less than the 40 tons VOC per year significant emission rate listed in
40 CFR 51.166(b)(23)(i).
SentryGlas® Manufacturing Facility (Emission Source ID No. SGS-A);
DuPont is requesting the current SentryGlas® Plus Manufacturing Facility be renamed the
SentryGlas® Manufacturing Facility in the various sections of the subject Title V air permit.
The DuPont Company has recently announced the brand name change from SentryGlas® Plus to
SentryGlas® and as such all references t6 this product is being transitioned to merely
Natural gas -fired or No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-1)
DuPont is requesting the description of the No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-1) to
include natural gas as a fuel source. The site is pursuing a project to bring a natural gas supply
pipe to the DuPont facility. This change would allow the facility to burn natural gas in this
boiler, as well as the current No. 2 or No. 6 fuel oils.
Natural gas -fired or No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-2)
DuPont is requesting the description of the No. 2 / No. 6 fuel oil -fired boiler (ID No. PS-2) to
include natural gas as a fuel source. The site is pursuing a project to bring a natural gas supply
pipe to the DuPont facility. This change would allow the facility to burn natural gas in this
boiler, as well as the current No. 2 or No. 6 fuel oils.
Natural gas -fired or No. 2 fuel oil -fired boiler (ID No. PS -Temp)
DuPont is requesting the description of the No. 2 fuel oil -fired boiler (ID No. PS -Temp) to
include natural gas as a fuel source. The site is pursuing a project to bring a natural gas supply
pipe to the DuPont facility. This change would allow the facility to burn natural gas in this
boiler, as well as the current No. 2 fuel oil.
Abrasive Blasting and Painting Building (ID No. I-10)
DEQ-CFW 00085937

Mr. William Willets
NCDENR --r Division of Air Quality
December 4, 2008
Page 5 of 5
DuPont is completing the construction of an enclosed building to perform periodic abrasive
blasting operations to comply with the requirements of 15A NCAC 2D.0541(c). This source was
recently added to the subject permit as an insignificant activity.
DuPont requests the insignificant activity description of the Abrasive Blasting Building
(Emission Source ID No. I-10) be modified to include periodic painting of equipment. Any
painting that would occur in the building would be part of the total painting insignificant activity
described in Paint Shop (ID No. 1-7) that has a potential to emit of 1.56 tons VOC per year.
Polyvinyl Fluoride (PVF) Manufacturing Facility No. 2 (ID No. FS-C)
DuPont is requesting the correction of a typographical error in Part 2.1(I)(4)(a) in which the
emission source ID Number for the Polyvinyl Fluoride (PVF) Manufacturing Facility No. 2 is
shown incorrectly as ID No. FL-C versus the correct ID No. FS-C.
Summary
DuPont is submitting this modification application under the rules set forth in 15A NCAC
2Q.0501(c)(2) meaning the Part 1 permit application should result in a construction and
operation permit per NCAC 2Q.0504, and the Part 2 permit application should have the review
process that includes the required public notification and EPA review.
If you should have any questions additional or need additional information, please feel free to
contact me at [phone].
Environmental Manager
Enclosures
DEQ-CFW 00085938