DEQ-CFW_00086923

FORM D1
FACILITY -WIDE EMISSIONS SUMMARY
REVISED 12/01/01 NCDENR/Dtvlsion of Air Qualltv - Application for Air Permit to Construct/Operate D1
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EXPECTED ACTUAL EMISSIONS
POTENTIAL EMISSIONS
POTENTIAL EMISSIONS
(AFTER CONTROLS /
(BEFORE CONTROLS /
(AFTER CONTROLS /
LIMITATIONS)
LIMITATIONS)
LIMITATIONS
AIR POLLUTANT EMITTED
tons/
tons/
tons/yr
Unchanged (site Is
Unchanged (site Is
PARTICULATE MATTER (PM)
^ 50
Major Source)
Major Source)
Unchanged (site Is
Unchanged (site isMajor
PARTICULATE MATTER < 10 MICRONS (PM,o)
-'50
Source)
Major Source)
Unchanged (site is
Unchanged (site Is
PARTICULATE MATTER < 2.5 MICRONS (PM)
^-50
Major Source)
Major Source)
Unchanged (site Is
Unchanged (site is
SULFUR DIOXIDE (S02)
—600
Major Source)
Major Source)
Unchanged (site is
Unchanged (site is
NITROGEN OXIDES (NOx)
�100
Major Source)
Major Source)
Unchanged (site is
Unchanged (site is
CARBON MONOXIDE (CO)
—15
Major Source)
Major Source)
VOLATILE ORGANIC COMPOUNDS (VOC)
^-215
Major Source
Major Source
LEAD
OTHER
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EXPECTED ACTUAL EMISSIONS
POTENTIAL EMISSIONS
POTENTIAL EMISSIONS
(AFTER CONTROLS /
(BEFORE CONTROLS /
(AFTER CONTROLS !
LIMITATIONS)
LIMITATIONS)
LIMITATIONS
HAZARDOUS AIR POLLUTANT EMITTED CAS NO.
tons!yr
tons/ r
tons/yr
Total HAPs
>25 (site Is Major Source)
>25 (site is Major
>25 (site is Major
Source)
Source)
x = m t�triy,
d :C C i tT i8
__ SStOAt ;t�0 - 'Tito 1=A1PA,
-'Y tt�
- f.. 3:
INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS i LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (i'PER) IN
15A NCAC 2Q .0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY.
Modeling Required ?
TOXIC AIR POLLUTANT EMITTED
CAS NO.
Ib/hr
lb/day
lb/year
Yes
No
TAP emissions will be not increase as
a result of this modification. Current
limits In the Title V Air Permit will be
X
unchanged.
COMMENTS:
As indicated above, the site is a major source for criteria pollutants and HAPs. The wet scrubber (ACD-A3) will
not change any of the current classifications. VOC and PM are the only criteria pollutants emitted from this
process. The APFO Manufacturing Facility currently emits both HAPs and TAPS, but the new wet scrubber (ACD-
A3) will not result in an increase of those air pollutants.
DEQ-CFW 00086923

FORM D
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED: 12/01/01 NCDENR/Division of Air Quality -Application for Air Permit to Construct/Operate D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION, CONTROL, AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A
SPECIFIC EMISSIONS SOURCE (EMISSION INFORMATION) (FORM B) - SHOW CALCULATIONS USED, INCLUDING EMISSION FACTORS, MATERIAL BALANCES,
AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE CALCULATION OF POTENTIAL
BEFORE AND, WHERE APPLICABLE, AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT
MATERIAL BALANCE CALCULATIONS.
B
SPECIFIC EMISSION SOURCE (REGULATORY INFORMATION)(FORM E2 -TITLE V ONLY) - PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO
INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS (e.g. FOR TESTING AND/OR MONITORING REQUIREMENTS)
FOR COMPLYING WITH APPLICABLE REGULATIONS, PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER
OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS (PREVENTION OF SIGNIFICANT DETERIORATION (PSD),
NEW SOURCE PERFORMANCE STANDARDS (NSPS), NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS), TITLE V), INCLUDING
EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED TO DOCUMENT
COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM "A" ABOVE, DATES OF MANUFACTURE, CONTROL EQUIPMENT, ETC. TO
SUPPORT THESE CALCULATIONS.
C
CONTROL DEVICE ANALYSIS (FORM C) - PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL EFFICIENCIES LISTED ON
SECTION C FORMS, OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM "A" ABOVE. INCLUDE PERTINENT OPERATING PARAMETERS (e.g.
OPERATING CONDITIONS, MANUFACTURING RECOMMENDATIONS, AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION) CRITICAL TO ENSURING PROPER
PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS
EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND
MAINTENANCE TO BE PERFORMED.
D
PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS - (FORM E3 -TITLE V ONLY) - SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS,
OPERATIONAL, OR OTHER DATA TO DEMONSTRATE COMPLIANCE. REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM "B" WHERE
APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE APPLICABLE
REGULATIONS.
E
PROFESSIONAL ENGINEERING SEAL - PURSUANT TO 15A NCAC 20.0112 "APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).
/ attest that this application for
has been reviewed by me and is accurate, complete and consistent with the information supplied
in the engineering plans, calculations, and all other supporting documentation to the best of my knowledge. I further attest that to the best of my
knowledge the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal
package may have been developed by other professionals, inclusion of these materials under my seal signifies that I have reviewed this material
and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B, any
person who knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor which
may include a line not to exceed $10, 000 as well as civil penalties up to $25,000 per violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME:
DATE:
COMPANY:
ADDRESS:
TELEPHONE:
SIGNATURE:
PAGES CERTIFIED:
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary -- See Attached Calculation Sheet
DEQ-CFW 00086924

FORM D
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
The purpose for installing and operating the wet scrubber (ACD-A3) is to reduce the emissions
of perfluorooctanoic acid (APFO) or its salt ammonium perfluorooctanoate (APFO). Neither
of these compounds are regulated air pollutants except for their generic classification as a
volatile organic compound (VOC) or as particulate matter (PM). Taking the worst case
scenario for the applicability of the New Source Review regulations, the criteria polutant with
the smallest significant emission rate would be particulate matter less than 10 micron (PM-10).
The significant emission rate for PM-10 is 15 tons per year.
Stack testing of the APFO Manufacturing Facility has shown that the potential emission of
APFO is approximately sixty (60) pounds per year or 0.03 tons per year. Obviously the
potential emission rate of 0.03 ton/year is well less than the NSR significant emission rate of
15 ton/year for PM-10. As such, there is no applicable regulation requiring any additional
emission control for this source.
While there is no applicable regulation requiring the operation of the wet scrubber (ACD-A3),
DuPont has elected to voluntarily install and operate this control device so as to reduce the
current emission rate of APFO and/or PFOA.
Because of the above and to expedite the processing of this application by the Division of Air
Quality, this application is assuming that the new wet scrubber (ACD-A3) will have a capture
and control efficiency of 0%. Accordingly, the information provided in Form C8 on the
operating parameters of the scrubber shows worst -case ranges and conditions.
DEQ-CFW 00086925