DEQ-CFW_00085996

DuPont Fluoroproducts
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
August 6, 2008
Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
SUBJECT: Title V Air Quality Permit Deviations
Miscellaneous Organic Chemical Manufacturing NESHAP (MON)
Air Quality Permit No. 03735T33
Dear Mr. Vozzo:
Pursuant to Part I Section 3(I.A)(3) of the subject Title V permit, this letter is the required
notification of four (4) permit deviations of a requirement specified in Part I Section 2.1(C)(7)(a)
of the subject permit. That condition requires that this site comply with all applicable provisions
of the Miscellaneous Organic Chemical Manufacturing NESHAP ("MON") as promulgated in
40 CFR Part 63, Subpart FFFF. The effective date of the MON was May 10, 2008.
Pursuant to 40 CFR 63.2490, any heat exchanger subject to the MON must comply with the
work practice standards of 40 CFR 63.104. The DuPont Company — Fayetteville Works' HFPO
Process (ID No. NS-A) operates two (2) process heat exchangers that are subject to the MON.
To monitor for the presence of a leak in a heat exchanger system, §63.104(b)(5) requires that
three (3) samples of both the cooling water entrance and exit of the heat exchanger be monitored
for the presence of speciated hazardous air pollutants ("HAP") monthly for the first six months
of operation and quarterly thereafter.
To comply with the monthly heat exchanger monitoring requirement, three samples of both the
cooling water entrance and exit were taken at both of the above heat exchangers for the months
of May 2008 and June 2008. DuPont personnel believed that these samples satisfied the
requirement of monthly triplicate samples at each required monitoring location.
E.I. du Pont de Nemours and Company
DEQ-CFW 00085996

W. Steven F. Vozzo
NCDENR — Division of Air Quality
August 6, 2008
Page 2 of 2
When the commercial laboratory received the sets of triplicate samples, their belief was that each
set represented.a single sample for analysis of the specific HAP, a duplicate sample for QA/QC
purposes, and a spare sample container in case of breakage of the other two samples. As such,
the lab analyzed at most two of the samples from set each instead of the required three.
This error was discovered in July 2008 and DuPont personnel were able to sample and submit
the required three samples per monitoring point for that month.
Therefore, the two heat exchangers subject to this MON requirement did not have the required
number of samples analyzed for either May 2008 or June 2008. This results in the four permit
deviations.
The cause of these deviations was a misunderstanding between DuPont personnel submitting
triplicate samples and the commercial laboratory who interpreted them as being a single sample.
DuPont personnel will now submit nine (9) samples per monitoring point per month, and those
samples will be clearly labeled to identify them as the required triplicate samples. This will
eliminate the possibility of the recurrence of these deviations.
If you have any questions regarding this permit deviation, or if you need any additional
information, please contact Michael Johnson at [phone].
By my below signature, I certify that I believe the information contained in this letter is true,
accurate, and complete.
Sincerely,
Karen B. Wrigley
Plant Manager
DEQ-CFW 00085997