DEQ-CFW_00086961

NCDEN;R
North Carolina Department :of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Govemor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
August 13,.2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Ms. Karen Wrigley
Plant Manager
DuPont Company — Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306 7332
SUBJECT: Compliance Additional Information - Permit Applicability of Painting and Shot Blasting
Operations & Visible Emissions from Boiler (11) No. PS-2)
DuPont Company— Fayetteville Works, Air Permit No. 03735T30
Fayetteville, NC, Bladen County 06/09-00009
Dear Ms. Wrigley:
On August 9, 2006, Christy Richardson and Markus Elliott, Fayetteville Regional Office (FRO), performed an
annual compliance inspection of DuPont Company — Fayetteville Works located in Bladen County, North Carolina.
During the inspection, several unpermitted paint booths, and shot blast booths were observed at your facility. After
further research, these small booths used for maintenance activities were determined to be insignificant sources.
These sources were to be added to the insignificant activities list during the next air permit modification. On July 18,
2007, this Office received a permit modification for the addition of an APFO scrubber and TFE/CO2 separation
process. As part of this process, Ms. Richardson contacted Mr. Mike Johnson, Environmental Manager, to obtain the
number of paint booths and shot blast booths located throughout the facility. During further investigation by Mr.
Johnson, it was determined that your facility has three small paint booths and four small sand blast units as well as a
large paint and sand blast operation for Nafion® product cylinders. Since further investigation of these two
operations was wan -anted, Mr. Robert Kennedy, of this Office, went to the facility on August 9, 2007 to observe the
operations. Additionally during the site visit, Mr. Kennedy noticed excess visible emissions coming from boiler (ID
No. PS-2) while combusting No. 2 fuel oil. Following the site visit, this Office has three compliance concerns
regarding permit applicability of these units, regulatory requirements of these units, and opacity from boiler (ID No.
PS-2). These three compliance concerns are described in more detail in the following paragraphs.
NCGS 143-215.108 G°Control of Sources of Air Pollution; Permits Required"
At this time, it is unclear if the large paint and shot blast operations for Nafion® product cylinders need to be
permitted. Please evaluate these operations and submit your findings to this Office so that a permit applicability
determination can be made. In your response, please provide throughput information, paint usage, shot blast media
usage, and any limiting factors for calculating potential emissions.
Fayetteville Regional Office — Division of Air Quality One 1;
225 Green Street, Suite 714, Fayetteville, North Carolina 28301.5043 NorthCarohna
Phone: [phone].\ Fax: [phone] \ Internet: hftp:#www.ncalr.org f,
An Equal opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00086961

Compliance Additional Information — DuPont Company -Fayetteville Works
August 13, 2007
15A NCAC 2D .0541, "Control of Emissions from Abrasive Blasting"
It appears, from the site visit, that the cylinder sand blast operation takes place outdoors. Regulation 15A NCAC 2D
.0541, "Control of Emissions from Abrasive Blasting," which was adopted in July 2000, states that abrasive blasting
must take place in a building (structure with four wails and a roof) unless the object is larger than 8 feet in any
dimension, is located at its fixed location, or takes place at a farm or residence. Since none of these exemptions
appear to apply to the Nafion@ product cylinder shot blast operation, the process must take place inside a building.
Please also note that Stipulation 15A NCAC 2D .0521, "Control of Visible Emissions," applies to this operation and
all applicable regulations still apply even if the process is determined to. be an insignificant activity: Please provide a
response to this Office as to how your facility plans to ensure compliance of the aforementioned regulations at the
cylinder shot blast operation.
15A NCAC 2D .0521, "Control of Visible Emissions"
During the site visit, Mr. Kennedy observed high opacity readings from boiler (ID No. PS-2) while combusting No. 2
fuel oil. Visible emissions appeared to exceed 60% opacity during certain intervals. After discussion with a
powerhouse employee, it was determined that the oxygen sensor was not operating properly. During an annual
inspection performed on September 29, 2005, Ms. Richardson and I observed a similar scenario in which boiler (ID
No. PS-1) appeared to be puffing intervals of high opacity due to problems with the air damper. Since this scenario
has been observed by our Office during two recent inspections, it is a cause for concern. Please provide as a
response, the circumstances causing the high opacity readings, which occurred on August 9, 2007, and how your
facility plans to avoid instances 'like this in the future. Additionally, please address how your staff is documenting
these situations when they are observed during the course of a workday.
Please submit your written response to this Office by August 29, 2007 as to actions taken to ensure that all the above
compliance concerns are addressed and any additional information or description of any mitigating circumstances in
reference to the compliance concerns. The Fayetteville' Regional Office, Division of Air Quality appreciates your
prompt attention to this matter. If you have any questions regarding this matter, please call Christy Richardson,
Environmental Engineer, or Robert Hayden, Compliance Coordinator, at [phone].
Sincerely,
U1.
/ o
Steven F. Vozzo
Regional Air Quality Supervisor
cc: DAQ Central Files
FRO County Files
DEQ-CFW 00086962