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HomeMy WebLinkAboutDEQ-CFW_00087170TITLE V AIR PERMIT APPLICATION REVIEW Revised July 7, 2003 APPLICANT: SITE LOCATION: COUNTY: E.I. Dupont de Nemours & Co., LLC Fayetteville Bladen DBA, Dupont - Fayetteville Works TECHNICAL CONTACT: PHONE: RESPONSIBLE OFFICIAL: TITLE: Michael Johnson 910-678-1155 Barry Hudson Plant Manager REVIEW ENGINEER: SIGNATURE: DATE: Michael Benson May 12, 2004 REGIONAL CONTACT: REGIONAL OFFICE: SIC CODE: Tom Mckinney Fayetteville 2821, 3081, 3083 APPLICATION NUMBER: EXISTING PERMIT NUMBER: NEW PERMIT NUMBER: 03735T25 03735T26 1. Purpose of Application: The purpose of this application is to make an administrative amendment to the originally issued initial Title V p er m it. T hi s p er m it c 0 nt ai n e d DEQ-CFW 00087170 a S ec ti 0 n 2. 3 fo r m is ce 11 e n e 0 us sc ru b b er re 9 ui re m e nt s as so ci at e d w it h v ar io us e 9 DEQ-CFW 00087171 } l ui P m e nt ac ro ss th e PI a nt T h e P er m itt ee c 0 nt ac to d D A Q b Y P h 0 n e a n d re 9 u es to d DEQ-CFW 00087172 4 % th at th es e re 9 ui re In e nt s b e In 0 v e d to th ei r re sp ec ti v e su bs ec ti 0 ns in s ec ti 0 n 2. 2. T h e DEQ-CFW 00087173 c h a n g es ar e li st e d 0 n th e to bl e b el 0 w 2. Facility Description: E.I. du Pont de Nemours & Co., LLC produces polyvinyl butyral sheeting used in the automotive industry andspecialized membranes used in the chemical industry as well as some fluoroproducts. The facility currently has two oil -fired boilers, a Butacite® production process, a Nafion® production process, a fluoroproducts polymer manufacturing development facility, and a wastewater treatment facility. The facility is considered major for Title V purposes because S02, NOx and VOC exceed major thresholds. The facility also exceeds 10/25 TPY for HAP emissions. DEQ-CFW 00087174 3. Application Chronology: April 5.2004 - Permittee contacted Dr. Don van der Vaart in regards to making an adminstrative amendment. May 24, 2004 - Draft permit sent to Tom McKinney, FRO. 4. Changes to the Current Permit: Changes to the permit are summarized below: Page No. Section Changes cover N/A Dates, Permit No. Table of contents N/A Removed Section 2.3. 11 2.1.B.3. Added condensor and scrubber requirements (b. - f.). 15-16 2.1.C.6 - 8. Added MACT and scrubber requirements. 18 2.113.4. Added scrubber requirements (e. - g.). 19 2.1.E.2. Added scrubber requirements (a. and b.). 19 2.1.F.1. Added condensor and scrubber requirements (b. - d.). 28 2.2.13.2 - 4. Added scrubber requirements. DEQ-CFW 00087175 5. New Equipment/Change in Emissions and Regulatory Review: There were no changes in equipment or applicable regulations as a result of this modification. 6. NSPS, NESHAPS, PSD, MACT and Attainment Status: Bladen County has been triggered for PSD increment tracking for PM10 and S02. This modification does not affect PSD increment tracking. The facility also has equipment subject to MACT Subpart KK and FFFF. The facility will be subject to MACT DDDDD in the future. A stipulation indicating that the facility shall comply with MACT Subpart FFFF was included in this permit. 7. CAM Issues: The facility is not subject to CAM at this time. 8. 112(r) Issues: This facility is subject to 112(r). 9. Facility -wide Air Toxics: The facility is subject to 2D .1100 and has completed maximum emission rate modeling for all TAPs. These limits are in the current permit as facility -wide limit. 10. Monitoring Recordkeeping/Reporting: This application did not change the facility's monitoring and recordkeeping requirements. However, the way the monitoring and recordkeeping requirements are organized was changed. In Permit No.03735T25, condensor and scrubber requirements were contained in Section 2.3. These requirements were moved to each respective subsection as listed above. The facility is required to perform periodic maintanence as recommended by the manufacture, as well as monitoring and recording key operating parameters of the control equipment. These parameters shall be recorded in a logbook. DEQ-CFW 00087176 11. Emissions Summary: Facility -wide criteria emissions are summarized from the most recent application for modification. Emissions have not changed as a result of this administrative amendment. Pollutant Actual Emissions (after controls, TPY) Potential Emissions (before controls, TPY) Potential Emissions (after controls) PM 82.86 419.51 124.04 PM10 41.81 134.87 56.31 PM2.5 238 241.16 90.31 S02 674.97 1530.19 1489.29 NOx 104.91 308.57 271.31 CO 13.84 49.67 49.67 VOC 167.34 2092.41 444.73 Lead 0.00 0.00 0.00 In addition, the facility has methanol emissions of 24.18, the largest HAP, and is also above the 10l25 TPY threshold for Title V. 12. Compliance Status: The DAQ has reviewed the compliance status of this facility. On its latest inspection, September 19, 2003, the facility appeared to be operating in compliance with all requirements. There have been no violations in at least five years. 13. Conclusions, Comments, and Recommendations: FRO recommends issuance of Permit No. 03735T26. Issue Permit No. 03735T26. DEQ-CFW 00087177