DEQ-CFW_00086870

NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: October 11, 2007
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
SIC: 3081 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Authorized Contact
Karen B. Wrigley
Plant Manager.
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Review Engineer: Fern Paterson
Review E •neer's Sign e, Date:
Technical Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Christy Richardson
Date of Last Inspection: 08/09/2006
Compliance Code: 3/In Compliance - Inspecrio
Permit Applicability (this application only)
SIP: N/A
NSPS: N/A
NESHAP: N/A
PSD: N/A
PSD Avoidance: N/A
NC Toxics: N/A
112(r): N/A
Other: Odors
Application Data
Application Number: 0900009.07A
Date Received: 07/18/2007
Application Type: Modification
Application Schedule: TV-502(b)(10)
Existing Permit Data
Existing Permit Number: 03735/T30
Existing Permit Issue Date: 09/22/2006
Existing Permit Expiration Date: 01/31/2009
Comments / Recommendations:
Issue: 03735/T31
Permit Issue Date: 10/11/2007
Permit Expiration Date: 01/31/2009
I. Purpose of Application
The North Carolina Division of Air Quality (DAQ) received Application No. 8000055.07A from E.I. du Pont de
Nemours & Co., LLC (DuPont) on July 18, 2007. The application seeks to authorize (1) the installation of a wet
scrubber (ID No. ACD-A3) on the building exhaust vent at the ammonium perfluorooctanoate (APFO)
manufacturing facility (ID No. AS -A) and (2) add a tetrafluoroethylene (TFE) / carbon dioxide (CO2) separation
process (ID No. NS-M). Discussions of these proposed installations are provided in greater detail in Section IV of
this permit review document.
In addition to the requested changes listed above, the following changes were made to the permit in response to
input from the Fayetteville Regional Office (FRO) and Mr. Mike Johnson (DuPont):
1. One outdoor abrasive blasting operation (for items exceeding 8 feet in any dimension) was added to the
insignificant activity list (ID No. I-6). Pursuant to a letter from DuPont to Mr. Steven Vozzo (FRO) dated
August 28, 2007, annual PM emissions from this source are less than 2 tons per year.
2. One painting operation was added to the insignificant activity list (ID No. I-7). Pursuant to a letter from
DuPont to Mr. Vozzo dated August 28, 2007, annual VOC emissions from this source are approximately 1.5
tons per year.
DEQ-CFW 00086870

DuPont, Bladen County
Review for Permit No. 03735T31
Page 2
3. An existing condenser (ID No. ACD-A2) was removed from the permit. This condenser caused operational
problems (i.e., plugging) and hasn't operated since 2002. There was no assumed control efficiency associated
with this condenser to demonstrate compliance with any applicable standard.
4. The description of the impingement -type wet scrubber with mist eliminator (ID No. WTCD-1) associated with
the wastewater treatment area was modified to remove the scrubbant injection rate. The scrubber is installed for
odor control purposes only, and this injection rate is not a regulatory requirement.
5. Monitoring language for the resins fluorination process (ID No. NS-G) PSD avoidance condition in Section 2.1.
C.5.b was modified, as shown below, to clarify intent:
■ Existing Language in Permit No. 03735T30:
"Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions shall
be determined by multiplying the total amount of each type of VOC-containing material consumed during
the month by the VOC content of the material. The Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0530 if the amounts of VOC containing materials or the VOC emissions are not monitored and
recorded."
■ Proposed Language in Draft Permit No. 03735T31:
"Calculations of VOC emissions per month shall be made at within 30 daa s of the end of each month. 449E
eensimied duringfs., menth b - fh, VOG , to .t of the „te 1l The Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0530 if the amounts of VOC containing materials or the VOC
emissions are not monitored and recorded. "
Note that VOC emissions from the resins fluorination process are not calculated using a mass balance.
Therefore the description of the emissions methodology provided in this condition is inaccurate.
6. Visible emission language pursuant to 15A NCAC 2D .0521 was updated throughout the permit to be consistent
with current DAQ protocol.
7. Add language to the description of various existing scrubbers to clarify enforceability of listed injection rates.
8. Additional detail was added to the existing Miscellaneous Organic NESHAP (MON) requirement in Section 2.1
C.7. of the permit.
9. Boiler MACT language was removed.
10. Several typographical errors were corrected.
These modifications will be processed as a 502(b)(10) permit change pursuant to 15A NCAC 2D .0523(a).
II. Permit Modifications/Changes
The following table describes the modifications to the current permit.
Old Page(s)
New Page(s)
Section
Description of Change(s)
N/A
N/A
Insignificant
— Revise table formatting to be consistent with current DAQ
Activity List
protocol.
— Add four new insignificant activities (ID Nos. I-6 through
1-9).
— Add footnotes to table with discussion of regulatory
applicability to insignificant activity. These footnotes are
consistent with current DAQ protocol.
1
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
DEQ-CFW 00086871

puPont, Bladen County
Review for Permit No. 03735T31
Page 3
Old Page(s)
New Page(s)
Section
Description of Change(s)
Pages 3-5
Pages 3-5
Section 1, Table
— Add labels to Nafion! sources indicating MACT FFFF
applicability.
— Add "state enforceable only" language to injection rates of
scrubbers (ID Nos. BCD-Bl and BCD-B2). These
scrubbers are only used to control odors.
— Add new TFE/CO2 separation process (ID No. NS-M).
— Add "nominal' indication at the end of the description of
the scrubber (ID No. FCD-Al). Currently, there are no
permit conditions requiring DuPont to achieve these
injection rates.
— Remove condenser (ID No. ACD-A2).
— Add "state enforceable only" language to injection rate of
wet scrubber (ID No. ACD-A9). This scrubber is only used
to control odors.
— Add wet scrubber (ID No. ACD-A3).
— Remove injection rate language from description of WWTP
scrubber (ID No. WTCD-1) and add "state enforceable
only" language. This scrubber is for odors only. Currently,
there are no permit conditions requiring DuPont to achieve
these injection rates, and DuPont has indicated that the
listed injection rate is not used as the set point for this
scrubber.
— Add footnote (5) with procedural information for this
permit modification.
Page 8
Page 8
Sec. 2.1. A.3.d.
Revise VE monitoring requirement to be consistent with
current DAQ protocol.
Page 11
Page 11
Sec. 2.1. B.2.c.
Revise VE monitoring requirement to be consistent with
current DAQ protocol.
Page 14
Page 14
Sec. 2.1. C., Table
Add reference to MON applicability to the summary table.
Page 17
Page 16
Sec. 2.1. C.S.b.
Revise monitoring language to be consistent with Sec. 2.1.
CA.b. and Sec. 2.1. C.6.b.
Page 18
Page 17
Sec. 2.1. C.7.
Update MON placeholder language to include the initial
compliance date and the due date of the Notification of
Compliance Status.
Page 20
Page 19
Sec. 2.1. E.,
Remove condenser (ID No. ACD-A2) and add new scrubber
Descri lion
D No. ACD-A3 to source description.
Page 24
N/A
Sec. 2.1.G.4
Remove Boiler MACT requirements in response to the recent
Former
vacatur of this rule.
Pages 25-26
Pages 24-25
Sec. 2.1. I.1. and 2.
Add clarification to 2D .0515 and 2D .0521 sections
indicating that these regulations only apply to Vent FEP-B4
(Product Collection System), which is the only potential PM
source at the facility. Other vents potentially vent steam and
Vinyl Fluoride, which is an odorless, colorless gas.
Page 25
Page 24
Sec. 2.1. I.l.c.
Remove requirement to keep a record of maintenance
(Former)
performed on bagfilters. There are no bagfilters associated
with the affected source D No. FS-B .
Page 26
Page 25
Sec. 2.1. I.2.c.
Revise VE monitoring requirement to be consistent with
current DAQ protocol.
Pages 32-41
Pages 31-39
Part I, General
Replace General Conditions with most current version
Conditions
(Version 2.19). Changes to Condition I.A.3 and multiple
re2latory citations in the condition heading.
DEQ-CFW 00086872

DuPont, Bladen County
Review for Permit No. 03735T31
Page 4
Old Page(s)New
Page(s)
Section
Description of Change(s)
Pages 43-46
Pages 41-44
Part II
Update Part II to include equipment associated with this
modification (ID Nos. NS-M and ACD-A3). Also, remove
Condition 1 related to ID No. BS-132. This source was
permitted years ago and is covered under the Title V permit
shield.
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On August 9, 2006, Ms. Christy Richardson and Mr.
Markus Elliot (FRO) conducted a site inspection of the facility and identfied several small paint booths and a shot
blast operation that were not listed on the permit. Per correspondence with Mr. Mike Johnson (DuPont) dated
August 8, 2007, it was determined that these unlisted sources are insignificant activities. FRO requests that these
insignificant activities be added at this time. No other issue of non-compliance were identified during the 2006
inspection.
Mr. Robert Kennedy (FRO) conducted a site inspection on September 7, 2007. The facility appeared to be in
compliance with all applicable requirements at that time. The facility has not been issued any Notices of Violation
(NOVs) during the previous five-year period.
IV. Detailed Description of Modification / Regulatory Review
A. Wet Scrubber (ID No. ACD-A3)
1. Description of Modification
DuPont manufactures APFO (a principle salt of PFOA) which is used in many household surface finishes (e.g.,
Teflon, flexible food packaging, water- and stain -resistant clothing, and fire -fighting foams. The generalized
chemical process for the manufacturing process is shown below:
Perfluorooctyl Iodide -- ) 0, PFOA — 2) 0, AFPO
(1) Oxidation of Perfluorooctyl Iodide to form Perfluorooctanoic Acid.t
(2) Neutralization of Perfluorooctanoic Acid with Sodium Hydroxide to the ammonium salt,
Ammonium Perfluorooctanoate and water.
There is an existing wet scrubber (11) No. ACD-Al) at the APFO manufacturing facility that is used to control
exhaust gases collected from the APFO reactor and associated purification equipment. However, some
APFO/PFOA exhaust is not captured and is eventually emitted to the atmosphere through the building exhaust
vent, which is currently uncontrolled. This permit application seeks authorization to install and operate a new
wet scrubber (ID No. ACD-A3) on the existing building exhaust vent.
PFOA and AFPO are regulated both as particulate emissions (PM/PM-10/PM-2.5) and as volatile organic
compounds (VOC). However, they are not regulated hazardous air pollutants (HAPs) or state -regulated toxic
air pollutants (TAP). The new wet scrubber will be vented through the same stack as the existing scrubber
(AEP-Al). The wet scrubber being proposed in this permit application is not required to comply with
any currently applicable air quality regulatory requirement 2
Stack testing of the existing operations has shown that the potential emissions of AFPO from the manufacturing
facility are approximately 60 pounds per year, or 0.03 tpy. The addition of the new wet scrubber will not result
in a potential increase of emissions from this facility.
1 Oxidizing agent is business confidential information.
Z DuPont did NOT include a Professional Engineer (P.E.) seal for the wet scrubber as part of this permit application. NC DAQ will not require
the P.E. seal because the control device is not required to comply with any regulatory requirement.
DEQ-CFW 00086873

,DuPont, Bladen County
Review for Permit No. 0373ST31
Page .5
2. Regulatory Review
The APFO manufacturing process (Section 2.1 E. of the draft permit) is only subject to state -enforceable
odors and toxics standards, as described below:
15A NCAC 2D 1806 "Control and Prohibition of Odorous Emissions" (State -Enforceable Only)
This standard forbids the Permittee from operating the APFO manufacturing facility without implementing
management practices or installing and operating odor control equipment sufficient to prevent odorous
emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary. The installation of the new wet scrubber is not expected to affect the odors from this operation.
No new requirements have been added to the draft permit to demonstrate compliance with 15A NCAC 2D
.1806.
15A NCAC 2D 1100 "Control of Toxic Air Pollutants" (State -Enforceable Only)
The APFO manufacturing operation has the potential to emit several regulated TAP emissions, including
hydrogen fluoride and sulfuric acid. These pollutants are collected from the reactor and process equipment
and routed to the existing wet scrubber (ID No. ACD-Al) for control. The existing permit includes
requirements for the proper operation of the existing control equipment to ensure compliance with the
facility -wide emission limits for these pollutants.
The emissions of these pollutants from the building exhaust vent are assumed to be negligible, and no
additional control of these pollutants is assumed to demonstrate compliance with the state -enforceable
toxics requirements. Therefore, no new requirements will be added to the draft permit to demonstrate
compliance with 15A NCAC 2D .1100.
NOTES:
■ APFO is not a regulated HAP. The AFPO manufacturing process is not regulated under the Hazardous
Organic NESHAP (HON) pursuant to 40 CFR 63, Subpart F, G, H, and I or to the Miscellaneous
Organic NESHAP (MON) pursuant to 40 CFR 63, Subpart FFFF. The new wet scrubber (ID No.
ACD-A3) is not subject to any NESHAP/MACT standards.
■ There are no New Source Performance Standards (NSPS) pursuant to 40 CFR Part 60 that are
potentially applicable to the AFPO manufacturing process or the new wet scrubber.
■ See Section V of this review document for a discussion of PSD/NSR applicability.
B. TFE / CO2 Separation Process (ID No. NS-M)
1. Description of Modification
DuPont is seeking authorization to install and operate a new, uncontrolled TFE/CO2 separation process (ID No.
NS-M). DuPont purchases TFE as a raw material for several of the fluoroproduct manufacturing processes,
including the Nafiono processes. The TFE-vendor adds a chemical compound (e.g., CO2 or HCI) to the TFE
prior to transport to reduce flammability.
In the proposed process, CO2 is separated from TFE by reacting it with sodium hydroxide (NaOH) to form
sodium carbonate (Na2CO3) in a steam -heated reactor. The reactants then proceed to separation equipment.
The carbonate salt leaves the process via wastewater and the liberated TFE leaves the process in the vapor phase
with inert nitrogen gas.
The proposed TFE/CO2 separation process will replace the existing process (ID No. NS-L) in which the
incoming THE is separated from anhydrous hydrogen chloride (HCI). One of the benefits of the new process is
the improved safety of transporting, handling, and storing CO2 in lieu of anhydrous HCI. Additionally,
emissions of TFE, which is a regulated VOC, will be reduced and the emissions of HCI, which is a state -
regulated TAP, will be eliminated.s
3 ID No. NS-L will be left on the permit to allow continued operation during construction/shakedown of the new process. DuPont has indicated
that they intend to remove ID No. NS-L administratively upon startup of the new process. However, there is no regulatory requirement (e.g.,
PSD netting) for them to do so.
DEQ-CFW 00086874

DuPont, Bladen County
Review for Permit No. 03735T31
Page 6
Potential TFENOC emissions from the proposed process are estimated to be less than 20 tpy. Actual
TFENOC emissions from the proposed process are estimated to be 7.13 tpy.
2. Regulatory Review
The new TFE/CO2 separation process will be included in the draft permit with other equipment associated
with the Nafion® processes (Section 2.1. C.). The TFE/CO2 separation process is only subject to the state -
enforceable odors standard, as described below:
15A NCAC 2D .1806, "Control and Prohibition of Odorous Emissions" (State -Enforceable Only)
This standard forbids the Permittee from operating the Nafion® processes without implementing
management practices or installing and operating odor control equipment sufficient to prevent odorous
emissions from the facility from causing or contributing to objectionable odors beyond the facility's
boundary. The installation of the new TFE / CO2 separation process is not expected to affect the odors
from this operation. No new requirements have been added to the draft permit to demonstrate compliance
with 15A NCAC 2D .1806.
NOTES:
■ The Nafion® membrane coating operation (1D No. NS-I) is subject to PM and VE standards pursuant
to 15A NCAC 2D .0515 and .0521, respectively. The new TFE/CO2 separation process is not a
potential source of PM or VE emissions and is not subject to these rules.
■ Several Nafion® processes, including the existing TFE/HCI separation process, are subject to state -
enforceable toxics requirements pursuant to 15A NCAC 2D .1100. The proposed TFE/CO2 separation
process is not a potential source of any regulated TAP and is not subject to this standard.
■ All Nafion® processes that are potential sources of organic HAP will be subject to the Miscellaneous
Organic NESHAP (40 CFR 63, Subpart FFFF) upon the initial compliance date (May 10, 2008) The
proposed TFE/CO2 separation process is not a potential source of any regulated HAP and is not subject
to this standard.
■ There are no New Source Performance Standards (NSPS) pursuant to 40 CFR Part 60 that are
potentially applicable to the TFE/CO2 separation process.
■ See Section V of this review document for a discussion of PSD/NSR applicability.
V. New Source Review/Prevention of Significant Deterioration
DuPont is located in Bladen County, which is a designated attainment/unclassified area for all pollutants regulated
by the New Source Review (NSR) permitting program. Therefore, emissions increases associated with proposed
construction activities must be evaluated to determine whether the Prevention of Significant Deterioration (PSD)
program applies as provided in 15A NCAC 21) .0530. DuPont, which is a chemical processing plant with a 100-tpy
major source threshold, is an existing major source under the PSD program
Pollutant <- =
PSD Significant Net
_
EmissionS Increase
PS b Revieyv -
-
Emissions Increase y
ired 2
PM-10
15
N/A
No
SO2
40
N/A
No
NOx
40
N/A
No
CO
100
N/A
No
VOC ozoneprecursor)
40
<20
No
Fluorides
3
N/A
No
Potential TFF/VOC emissions from ID No. NS-M are -estimated to be less than 20 tpy. No emissions reductions associated with the
subsequent shutdown of ID No. NS-L are accounted for in the above table. There are no potential emissions increases associated with
the proposed wet scrubber. While it is anticipated that the wet scrubber (ID No. ACD-A3) will reduce VOC and PM-10 emissions (i.e.,
PFOA and APFO), no emissions reductions are accounted for in the above table.
The proposed modifications will not require PSD permitting pursuant to 15A NCAC 2D .0530.
DEQ-CFW 00086875

,DuPont,, Bladen County
Review for Permit No. 03735T31
Page .7
VI. Title V Permit History:
The following list provides a very brief summary of Title V permit revisions for this facility:
Permit No. Issuance Date
Description of Revision
03735T23 July 2003
Initial Title V Permit
03735T24 January 2004
Administrative amendment to the permit related to the permit effective
date.
03735T25 February 2004
Modification to add a temporary No. 2 fuel oil -fired boiler (ID No. PS -
Temp).
03735T26 May 2004
Administrative amendment to the permit related to modify permit
organization, thereby improving permit clarity.
03735T27 December 2004
Modification to add a SentryGlas® Plus manufacturing process (ID No.
SGS-A), change the description of the existing wastewater treatment plant,
and revise various monitoring requirements for existing scrubbers.
03735T28 January 2006
Administrative amendment to the change the required annual compliance
certification due date from January 30 to March 1.
03735T29 June 2006
Modification to add a polyvinyl fluoride polymer manufacturing facility
(ID No. FS-B) and an insignificant polyvinyl fluoride vacuuming system
for housekeeping purposes (ID No. I-1).
03735T30 September 2006
Replace an existing internal scrubber at the hexfluoropropylene epoxide
(HFPO) process (ID No. NS-A) in the Nafion® Process Area
(debottlenecking).
VII.Other Regulatory Considerations
• The application fee of $867.00 was received on July 18, 2007.
• The Reduction and Recycling Form was received on July 18, 2007.
• A Professional Engineers Seal is NOT required for this application.
• A zoning consistency determination was received by the DAQ on July 18, 2007.
• Public notice is NOT required for this application.
VIII. Draft Permit Review Summary
Ms. Christy Richardson of the Fayetteville (FRO) was provided a draft permit for review on September 12, 2007.
The draft permit was also provided to Mr. Robert Kennedy (FRO) on September 19, 2007. Mr. Kennedy provided
comments via email on Monday, September 24, 2007, as detailed below:
Comment 1: Add "or" language to Section 1, Table to clarify the orientation of emissions control (ID Nos.
NCD-Hdrl vs NCD-Hdr2) at the various "Nafion" processes.
Response: Changes made per request.
• Comment 2: Correct inconsistencies in the ID Nos. used to refer to the Butacite Processes throughout the draft
permit.
Response: Changes made per request.
• Comment 3: Butacite Process - BS-C is the only source in Section 2.1.B. of the permit with particulate or VE
requirements.
Response: No changes made in response to this comment. ID No. BS-C is the only potential source of
particulate emissions in this section. The other emission sources in this section are potential VOC sources.
Comment 4: The permit requires that inspection records by maintained for the wet scrubber at the APFO
Manufacturing process, but does not specify a required inspection/maintenance schedule.
Response: No changes made in response to this comment. In this case, I do not believe that the original permit
engineer intended to specify a required inspection/maintenance schedule. Compliance with the standard is
demonstrated through monitoring of the liquid flow rate and differential pressure (Section 2.I.E.1.a.i. and ii.).
believe the engineer included the r ecordkeeping requirement so that .FF there were compliance issues 6.e., the
DEQ-CFW 00086876

DuPont, Bladen County
Review for Permit No. 03735T31
Page 8
pressure differential and/or the injection rate drops below the minimum allowable), the inspector/Regional
office would be able to review inspection/maintenance records. This could be valuable if the Permittee claimed
that the event was an unavoidable malfunction pursuant to 15A NCAC 2D .0535 (i. e., if the
inspection/maintenance records were lacking, DAQ would likely not accept the "malfunction" claim).
If, based on compliance history, FRO thinks an inspection/maintenance program needs to be specified, it should
be addressed during the permit renewal, or the next time the monitoring conditions for this unit are subject to
change due to a modification.
Comment 5: Add requirement to calculate the SO2 emissions to demonstrate compliance with the 40 tpy PSD
avoidance condition in Section 2.1 G. (Temporary Boiler).
Response: No changes made in response to this comment. I do not have the authority to make a substantive
change to this condition as part of this modification (which is unrelated to the temporary boiler). I proposed
that, upon receiving DuPont's "Part II" application shortly for ID No. NS-A (which is due within the month),
notify DuPont of our intention to update this monitoring condition to include a monthly SO2 calculation
requirement.
• Comment 6: Add time allowed for corrective actions in the event that "above normal" visible emissions are
detected at the at Polyvinyl Fluoride Polymer process.
Response: No changes made in response to this comment. In the original draft, I added the "as soon as
practicable" language, in accordance with comments in the P&O submitted by FRO, and in accordance with
current DAQ protocol. I have not made any further changes in response this comment.
• Comment 7: 2.2 Section B. Toxics - inspection records for scrubbers.
Response: No changes made in response to this comment. See Response to Comment No. 4.
The Permittee was provided a draft permit for review on September 12, 2007. Mr. Michael Johnson (DuPont)
provided comments to Ms. Paterson via email on September 18, 2007. Mr. Johnson requested numerous corrections
and clarifications. All of Mr. Johnson's concerns were addressed.
IX. Recommendations
The permit modification application for E.I. du Pont de Nemours & Co., LLC, located in Duart Township, Bladen
County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and
requirements. NC DAQ has determined that this facility is complying or will achieve compliance, as specified in
the permit, with all requirements that are applicable to the affected sources.
Issue Permit No. 03735T31
DEQ-CFW 00086877