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Permit Modification Issues
The following is a detailed description of each of the proposed changes detailed in the application
narrative provided by DuPont - Fayetteville Works (Items 1-2) as well as those changes proposed at FRO
(Items 3-6):
(1) Addition of a wet scrubber on the APFO ManufacturingFacility acility building exhaust. The Permittee
has requested to install a wet scrubber (ID No. ACD-A3) to control emissions from the building
exhaust at the APFO manufacturing facility. Currently, the processes within the APFO
manufacturing building (i.e. the reactor and purification equipment) are being controlled by a
permitted wet scrubber (ID No. ACD-Al). Because of the controversy surrounding the
unregulated chemicals emitted from this facility, the Permittee is requesting to add a scrubber to
the building exhaust which is currently uncontrolled. Both the process equipment exhaust and
the building exhaust will exit the same (already existing) stack. The installation of the proposed
scrubber is not required for compliance purposes and the facility plans to claim no control
efficiency for this device; therefore, there should be no additional requirements added to the
permit, such as operational restriction or recordkeeping requirements, for the proposed control
device.
(2) Addition of a TFE/CO, Separation Process. The Permittee has requested that a TFE/CO2
separation process (ID No. NS-M) be added to the permit. Tetrafluoroethylene (TFE) is used a
raw material for several processes at the DuPont facility. Due to TFE flammability, TFE must be
transported as a mixture to make it non-flammable for transportation. Currently the TFE is
mixed with HCI, which has safety concerns of its own. The company plans to begin transporting
TFE as a mixture of COZ, which is much safer for transportation, handling, and storage than
anhydrous hydrogen chloride. The facility currently has a permitted TFE/HCl separation process
(ID No. NS-L) `w is pr x' 2� tons of Vi?� erni�sion� per year and 132-ibsz —
emissions per year. This p i-t fbe-r-epl-need by -the -proposed-TFE-/CO2-separafimrecessF -�
-whiclr is=expecte3 to emit 7 tons of VOCs per year and no HAPs or TAPS. The reduction in VOC
(TFE) emissions is contributed to the decrease in pressure of the new separation process.
Currently, a baffle plate scrubber (ID No. NCD-Hdr1) is used on the TFE/HCl separation process
to control HCl emissions. A control device will not be required for the new TFE/CO2 separation
unit since no toxic emissions will be emitted from this process. No additional re+quirements are
needed for this modification and the source is subject only to the (State -enforceable only) odor
regulation. Once the proposed separation process is constructed and fully operational, the facility
will request an administration amendment to remove the existing TFE/HCl separation process
(ID No. NS-L) from the permit.
'O Remove condenser (ID No. ACD-A2) from the ppermit. The condenser (ID No. ACD-A2) listed .
operation
j as a control device for the APFO manufacturing iaci�ty should be removed 1e-pew-it: -the
cori�ehser-hasn't operated since 2002, shortly after sfarCup-of �hi�unit: �'he-condnser_ causect-
arobleemsnsuch as plugging of the system. There is no control efficiency associated
with this�Qn
(4) Addition of small paint booths and shot blast operations to the list of insignificant activities.
During the last inspection, FRO noticed several small paint booths and shot blast operations
located throughout the facility. The units were very small and used only for maintenance
activities. Per correspondence with Mike Johnson on August 8, 2007, the facility has three of
these small paint booths and four of the small sand blast booths.
During this investigation, it was also determined that the facility has a larger paint operation and
an outside sand blast operation for 1 ton capacity product cylinders. On August 13, 2007, FRO
issued a Compliance Additional Information letter to DuPont requesting information on these
operations. DuPont - Fayetteville Works responded with the following information: the abrasive
blasting operation accounted for approximately 1.6 tons of particulate and the painting operation
accounted for 1.5 tons of VOC during CY 2006. Based on the nature and size of these
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operations, FRO requests that these two sources be added to the list of insignificant activities as
well. If the facility determines that a control device is required in order to maintain compliance
with the VE standard, the facility will submit an application as necessary.
(5) Use standard language for VE Monitoring requirements. The monitoring requirements for VE in
the current permit reads as follows:
If visible emissions from this source are observed to be above normal, the Permittee shall
either: (a) be deemed to be in noncompliance with 15A NCAC 2D .0521 or (b)
demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15,4 NCAC 2D . 0501(c)(8) is below the limit given in Section 2.1 B.2. a.
above. If the demonstration in (b) above cannot be made, the Permittee shall be deemed
to be in noncompliance with 15A NCAC 2D . 0521.
The permit language should be changed to reflect the standard language for VE monitoring. The
following language, which was taken from another TV permit, should replace the language in
DuPont's current air permit:
If visible emissions from this source are observed to be above normal, the Permittee shall
either: (i) take appropriate action to correct the above -normal emissions as soon as
practicable and within the monitoring period and record the action taken as provided in
the recordkeeping requirements below, or (ii) demonstrate that the percent opacity from
the emission points of the emission source in accordance with 15A NCAC 2D . 0501(c)(8)
is below the limit given in Section 2.1 E.2.a.above. If the above -normal emissions are not
corrected per (i) above or if the demonstration in (ii) above cannot be made, the
Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
!��) Spelling / Grammatical Errors. The permit currently has several misspellings throughout the
document (specifically, consecutive).
Facility Compliance Status
The facility was last inspected by Christy Richardson and Markus Elliott on August 9, 2006 and appeared
to be operating in compliance with all requirements outlined in their current air permit. During this
inspection, several maintenance spray paint booths and shot blasters were discovered. This review
requests that these items be added to the list of insignificant activities. There are no compliance issues
(NOV/NRE's) during the last five-year period. The facility was issued a compliance addition information
(CAI) letter in August 2007 concerning the permit applicability of a paint operation and shot blast
operation as well as abnormal visible emissions from the boilers noted during two recent site visits.
Emissions Inventory Review
The largest criteria pollutant emissions as reported on the CY 2006 AQEI were volatile organic
compounds at 256 tons and sulfur dioxide at 548 tons. The vast majority of the VOC and SO2 emissions
were a result of combustion of fuel oil in the boilers and Nafion manufacturing process.
The largest HAP/TAP emissions as reported on the CY 2004 AQEI were methanol at 42 tons, toluene at 2
tons, CFC-113 at <1 ton, acetonitrile at 6 tons, hydrogen fluoride at 1.5 tons, and methylene chloride at 8
tons.
Additional Items
There are no additional issues listed on the FRO Facility Tracking Form (pink sheet) in the facility folder.
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Recommendation
FRO recommends that RCO issue the revised air permit (03735T31) to DuPont Company — Fayetteville
Works. If DuPont — Fayetteville Works submits any revisions to this application, FRO requests a copy of
the submittal for additional review. Also, FRO would like to review the draft permit and draft review
prior to being issued to the company or for public review.
Regional Engineer: Date:
Permit Coordinator: Date:
AQ Supervisor: Date:
\CTR
c: FRO Files
RCO Files
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