DEQ-CFW_00086901

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Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
DuPont Fluoroproducts
22820 NC Highway 87 W
FByetroville, NC 28306.7332.
August 28, 2007
SUBJECT: Compliance Additional Information — Permit Applicability of Painting and Shot
Blasting Operations & Visible Emissions from Boiler (ID No. PS-2)
DuPont Company - Fayetteville Works
North Carolina Air Permit No. 03735T30
Fayetteville, NC, Bladen County 06/09-00009
Dear Mr. Vozzo:
This is the requested response to your letter dated August 13, 2007. The three compliance
concerns stated in your letter are addressed individually below.
NCGS 143-215.108 "Control of Sources of Air Pollution: Permits Required"
The DuPont Company -- Fayetteville Works operates an abrasive blasting operation in which
metal parts are blasted prior to painting. The operation takes place in an open structure
consisting of a Quonset but without end walls. The abrasive blasting operation operates on an
as -needed basis.
The abrasive blasting operation consumed approximately sixty (60) tons of DuPontTM Starblast®
blasting abrasive in 2006. Per the AP-42 Section 13.2.6 particulate emission factors for abrasive
blasting of mild steel panels with a five mile per hour wind speed, total particulate natter
EL du Pont do Nemaure and Compony
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August 28, 2007
emissions would be 27 pounds per 1,000 pounds of abrasive. The choice of this low wind speed
is appropriate since the blasting operation is conducted inside a shelter.
Based on this emission factor and the amount of abrasive consumed, the total particulate matter
emitted in 2006 would have been 3,240 pounds or 1.62 tons. Since the abrasive blasting activity
level of 2006 is normal for this site, it can be assumed that the particulate matter emissions from
this source would be less than two (2) tons per year.
Since the anticipated particulate matter emissions from the abrasive blasting operation is less
than five (5) tons per year, this operation should be classified as an insignificant activity per 15A
NCAC 2Q .0503(8) and as such should be added the Title V permit's insignificant activities list
Thus site also operates a Paint Shop in which primarily one -ton cylinders are painted before
product from the fluoromonomers manufacturing area is loaded into them for off -site shipment.
The Paint Shop is a stand-alone building and operates on an as -needed basis.
In 2006, the Paint Shop consumed a total of 598 gallons of paint and thinner. The following is a
summary of the paint consumed, the VOC content of the paint, and the total VOC emissions
from the painting operation_
Name of Paint
2006
Consumption
(gallons)
VOC Content of
Paint
(lb.VOC / gallon)
Maximum VOC
Emissions
(lb. VOC)
DuPont Imron
63
2.8
176
DuPont Dulux
177
4.2
743
DuPont 25P
108
2.8
302
DuPont Primer
50
3.5
175
DuPont Thinner 200 8.3
GM --I Egg
2006 Total VOC Emissions froin Paint Shop (pounds)
1,660
3,057
2006 Total VOC Emissions from Paint Shop (tons)
1.53
The painting activity of the Paint Shop is directly proportional to the production volume of the
fluoromonomers business. The fluoromonomers' production volume for 2006 was similar to
previous years and it is expected that future years will also be similar to this 2006 level. Since
the painting activity seen in 2006 is extremely representative of the future, it is appropriate to
assume that the VOC emissions from this source will be approximately 1.5 tons per year.
Since the anticipated VOC emissions from the Paint Shop is less than five (5) tons per year, the
Paint Shop should be classified as an insignificant activity per 15A NCAC 2Q .0503(8) and as
such should be added the Title V permit's iosigruficant activities list.
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15A NCAC 2D .05,41, "Control of Emissions from Abrasive )Blasting"
The DuPont Company — Fayetteville Works' lluoromonomers manufacturing area uses one -ton
metal cylinders to store the various products produced in that area. When the cylinders were
returned from the customer, the old paint was removed via abrasive blasting, then the cylinders
were primed and repainted in the site's Paint Shop. The cylinders are roughly 80 inches long and
30 inches in diameter. Since the cylinders do not exceed eight feet in any dimension, they would
have to be abrasive blasted in a building per 2D.0541(b).
As the existing abrasive blasting structure does not meet the rule's definition of a building, all
blasting of these product cylinders was ceased following the visit by Mr. Robert Kennedy
(NCDENR DAQ FRO) on August 9, 2007. Since that time, DuPont has contracted for the off -
site abrasive blasting and printing of the product cylinders prior to their return to the Fayetteville
Works site.
This site continues to need to have the ability to perform abrasive blasting of metal parts such as
pipe. The Fayetteville Works Construction Area's personnel understand that only items that
exceed eight feet in at least one dimension are allowed to be abrasive blasted in the existing
structure. This site also understands that, per 2D .0521, the visible emissions from the abrasive
blasting operation cannot be more than twenty (20) percent opacity when averaged over a six -
minute period except for allowed exceedances specified in 2D.0521(d).
The site is investigating engineering solutions to deal with the visible emissions from the
abrasive blasting operation. This may include, but not be limited to, enclosing the existing
structure to create a building, moving the blasting operation to a new or existing building, or
installing dust control equipment to limit the exhaust of airborne particles. DuPont is aware of
the requirement that any control device that exhaust a on* r atmosphere would require a
permit modification. Conversely, pursuant to .0102(c) uipment that is not vented
to the outdoor atmosphere is exempted fro the permit requirements.
F_ t
15A NCAC 2D .05z1, "Control of Visible Emissions"
During Mr. Kennedy's visit on August 9, 2007, visible emissions from the site's back-up boiler
(1D No. PS-2) were observed to be higher than expected while burning No. 2 fuel oil. During
this time the back-up boiler, which normally emits no visible emissions, was experiencing
operational problems that resulted in the noted opacity. Area personnel found that operating the
boiler in manual control mode reduced or eliminated these visible emissions. At the time of
Mi. Kennedy's visit, area personnel were running the boiler in automatic control mode in an
attempt to determine the cause of the operational problem.
It was subsequently determined that the observed opacity was due to a malfunction of the
boiler's fuel nozzle in which a metal piece was found to be interrupting the fuel flow. This
nozzle was replaced and the visible emissions returned to the typically low opacity level. As a
result of this malfunction, the boiler operating procedures have been modified and now specify
as a troubleshooting step that the fuel nozzle be replaced should opacity levels become an issue.
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August 28, 2007
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You ask how the DuPont Company — Fayetteville Works' personnel are documenting situations
where the emissions from the back-up boiler (ID No. PS-2) results in higher opacity readings.
Pursuant to Section 2.l(A)(3)(f) of this site's Title V Permit, no monitoring, rccordkeeping or
reporting is required for visible emissions from the firing of No. 2 fuel oil in either the main
boiler (1 D No. PS-1) or the back-up boiler (ID No. PS-2). However, this site does continue to
perform the daily monitoring prescribed for the burning of No. 6 fael oil regardless of the type of
fuel being fired. Therefore, a visual observation is performed every day that one or more of the
boilers are operating to determine if the visible emissions are nonxtal. It was recorded that the
daily visible exruissions were normal when the operator made his observation at 0800 that
morning. This observation preceded the troubleshooting attempts that were occurring at the time
of Mr. Kennedy's visit.
If you have any questions regarding this letter, or if you need additional information, please call
me at 678-1155.
Enviroiunental Manager
cc: Ms. Christy T. Richardson, NCDENR Division of Air Quality, FRO
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