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Home My WebLink AboutDEQ-CFW_00087478DEQ-CFW 00087478 0 2.0 BUTACITE@ OPERATIONS • Butacite® is a registered DuPont trademark for polyvinyl butyral sheeting. The Butacite® plant consists of two main areas: (1) Flake reactors and associated drying operations to produce polyvinyl butyral resin (PVB) flake and (2) Finishing operations where the PVB flake is formed into Butacite® sheeting. Both the PVB flake and Butacite® sheeting are shipped off -site as product. The Butacitee sheeting, which is used in the manufacturing of laminated safety glass for automotive and architectural applications, is either clear or with a gradient tinted band, and is packaged in rolls. Figure 2-1 is a process flow diagram that presents the overall Butaciteg process. All emission units, control devices, and emission points are shown on the diagram, and insignificant emission units are also indicated. It should be pointed out that as part of the Title V permitting effort a new nomenclature has been developed for emission unit, control device, and emission point identification numbers. As can be seen from Figure 2-1, PVB is produced by reacting polyvinyl alcohol (PVA) with butyraldehyde (BA). A plasticizer is then added to the PVB resin to enhance its strength and elasticity. In addition, small quantities of other materials can also be added to the PVB resin to stabilize physical properties. As part of the Title V permitting effort, all Butacite® emission units were identified and a regulatory applicability analysis was performed. A summary of these findings are included in the following tables: Table 2-1 Summary of Butacite® Emission Units Table 2-2 Summary of Applicable Requirements Table 2-3 Summary of Compliance Monitoring Table 2-4 Summary of the Old Versus New Identification Numbers for the Butacite® Process Three general comments regarding the Butacite® area are as follows: 1. Presently the Butacite® extruder operations are permitted emission sources; however, as part of the Title V permitting effort, it has been concluded that these units should be exempt from permitting because they have low potential uncontrolled emissions (under 5 tons). The end of this section includes the North Carolina E-2 Application Form listing insignificant activities in the Butacite® area, and following this form, calculations documenting that the extruder operation emissions are insignificant are presented. g: \projectMayett\butnaf DEQ-CFW 00087479 • • 2. The tinting operation in the Butacite® process is subject to the recently promulgated MACT Standard (40 CFR Part 63 Subpart KK) for Printing and Publishing operations. Compliance with the standard is required by May 1999. At this time, DuPont has not yet determined how they will achieve compliance with the standard. There are several possible options including changing to a new ink solvent (which could possibly be water or perhaps a "non -HAP" solvent) or installation of a control device. Once a decision is made, DuPont will contact North Carolina Division of Environmental Health and Natural Resources (NCDEHNR) and submit appropriate permit application forms as necessary. 3. All of the Butacite® emission units were included in a facility -wide North Carolina air toxics modeling demonstration (see Section 5 for additional detail) that was done in 1995. gAprojects\fayett\butnaf a _�P_ DEQ-CFW 00087480 0 4654BUTA.DWG 10-11-95 1-1 RHR/KH Cu" N F I DENT I A J ERM—Southeast, Inc. BUTACITE N PROCESS FIGURE CHARLOTTE, NORTH CAROLINA DUPONT — FAYETTEVILLE WORKS 2-1 ERM DUART, NORTH CAROLINA N L TABLE 2-1 SUMMARY OF BUTACITEO EMISSION UNITS Emissit�n i7nit',I�escr pt�an Emissran Unti '< Ili To Devi.: ON Gontrot:�ev�ce bescri httn )ErmrssionPoint :: ,i : Butyraldehyde Storage Tank BS-A BCD -A Condenser BEP-A Flake Reactors BS-B BCD-B1 BCD-B2 Scrubber 1 Scrubber 2 BEP-B1lB2 Flake Dryer BS-C BCD-Cl BCD-C2 Cyclone Separator Bag Filter BEP-C Butaciite® Tinting BS-D -- -- BEP-D PVA Unloading Insig-B1 -- -- __ PVA 'ranks Insig-B2 -- -- __ Rework Vacuum System Insig-B3 -- -- __ Conservation Vent Insig-B4 -- -- __ Sheeting Quench Tanks Insig-B5 Butaciite® Fugitive Emissions Insig-B6 -- -- -- Plasticizer Storage Tanks Insig-B7 -- -- -- ButaciiteO Extruders Insig-B8 See Note 1 See Note 1 -- Note: 1. A detailed emissions analysis of the Butacite0 extruder process was recently performed and it showed that potential emissions upstream of the final 0 condensers are less than 5 tons per year. Therefore, the Butacite@ extruder process is exempt by size. p C� m I 0 0 0 00 14 gAprojectsWayetAbutnaf 00 N • tP 0 0 n J i 0 0 0 00 00 w TABLE 2-2 SUMMARY OF APPLICABLE REQUIREMENTS FOR BUTACITEO FACILITY' utyra dehyde Storage Tank BS-A VOC emissions controlled > 90% 15A NCAC 2D.0518(b) Flake Reactors BS-B There are no applicable requirements N/A Flake Dryer BS-C PM emissions < 9.76 Ib/hr 15A NCAC 213.0515 Opacity < 20% 15A NCAC 2D.0521(d) Butacite@ Tinting BS-D Photochemically reactive VOC emissions 15A NCAC 2D.0518(d) < 40 lbs/day or controlled by 85% See Note 3. 40 CFR Part 63 Subpart KK Notes: 1. All of the Butacite® emission units are subject to the facility -wide North Carolina air toxics emission limits. 2. Solvents used in the Butacite® Tinting are not photochemically reactive. 3. The Butacite® Tinting operation will be subject to the recently promulgated printing and publishing MACT Standard (40 CFR Part 63 Subpart KK). The compliance date for this standard is May 1999. DuPont is presently considering options for compliance, and will inform NCDEHNR once a decision is made. gAprojectsWayeMbutnaf N j' 0 9 0 TABLE 2-3 SUMMARY OF COMPLIANCE MONITORING FOR BUTACITEO FACILITYI Emission Unit pescription .: Applicable itequirement C'ompliAtice Ntonitbnrrg Butyraldehyde Storage Tank VOC emissions controlled > 90% Maintain written procedure to vent butyraldehyde storage (BS-A) tank back to railcar when unloading railcar; Track brine supply temperature to the tank condenser weekly. Flake: Dryer PM emissions < 9.76 lb/hr Compliance is presumed based on past compliance history of (BS-C) Opacity < 20% the source and the fact that potential emissions are only 7% of allowable. Any malfunction or upset will be reported pursuant to 15A NCAC 2D.0535. Butacite® Tinting Photochemically reactive VOC emissions No monitoring is necessary because only non -reactive (BS-D) < 40 lbs/day or controlled by 85% solvents are used; 40 CFR Part 63 Subpart KK Compliance options for the MACT Standard are currently being considered. NCDEHNR will be contacted once a decision is made. Note 1. Emissions from each of the Butaciteg emission units will be tracked and reported as part of the annual emissions inventory report. g:\prqjects\fayett\butnaf 0 r' 6 m I 0 0 0 w w ch TABLE 2-4 SUMMARY OF THE OLD VERSUS NEW IDENTIFICATION NUMBERS FOR THE BUTACITEO PROCESS Emission Untt Descd. ;';! t>ri hlo Old Source; ID hlo. on rolDevire'Descrption >< New Control �e�:fice TI7►.' f1[d Canrol :: Uev�ce,�1i Butyraldehyde Storage Tank BS-A BS-1 Brine -Cooled Condenser BCD -A BCD-1 Flake Reactors BS-B BS-2 Packed column scrubber ............................................................................................................... Packed column scrubber BCD-B1 BCD-B2 BCD-2A BCD-2B Flake Dryer BS-C BS-8 Cyclone Separator Bag Filter BCD-Cl ................................................................. BCD-C2 BCD-8A BCD- 8B Butacite@ Tinting BS-D BS-6 PVA Unloading Insig-B1 PVA Tanks Insig-B2 Rework Vacuum System Insig-B3 Conservation Vent Insig-B4 Sheeting Quench Tanks Insig-B5 Butacite® Fugitive Emissions Insig-B6 Plasticizer Storage Tanks Insig-B7 Butacite® Extruders Insig-B8 BS-3 BS-7 Vacuum Jet Final Condenser 1 .............................. .. . Vacuum Jet Final Condenser 2 Exempt Exempt BCD-3 B65-7 Note: 1. Before control emissions from the Butacite® extruder process are less than 5 tons per year. Therefore, this unit is exempt and the final condensers do not need to be permitted. g Aproj ectsWayet6butnaf FILENAME: NONCONF\BUT-B10 R-1 SECTION B EMISSION SOURCE (FIXED ROOF STORAGE TANK) r L REVISED 04/15/94' AIR QUALITY SECTION MISSION SOURCE DESCRIPTION: Butyraldehyde Storage Tank EMISSION SOURCE ID NO: BS-A ONTROL DEVICE ID NO(S): BCD -A EMISSION POINT ID NO(S) BEP-A INDICATE WHETHER THIS SOURCE 1S SUBJECT ( ) NSPS ( ) NESHAP REGULATIONS. ALTERNATIVE OPERATING SCENARIO (AOS) NO: DESCRIPTION OF STORAGE TANK: 68, 000 gallon bu tyral dehyde storage tank equipped with a 40 square foot brine -cooled condenser. OPERATING SCHEDULE (ACTUAL) OPERATION DATE: 1969 HRS/DAY: 24 DAYS/WK: 7 WEEKS/YR: 52 SEASONAL VARIATION(%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-.DEC: 25 LIQUID STORED: Butyraldehyde TRUE VAPOR PRESSURE (PSIA): 1, 77 DAILY AVG. LIQUID SURFACE TEMP. (R): 563 VAPOR MOLECULAR WEIGHT (LB/LB MOLE): 72.12 AVERAGE STORAGE TEMP (F): 71 CAPACITY GALLONS: 68, 000 TONS: 232 DIMENSIONS (FEET) HEIGHT: 25 DIAMETER: 22 TANK ROOF HEIGHT (FT): 24 TANK LIQUID HEIGHT (FT): Avg. 11 1 TANK SHELL HEIGHT (FT): 25 TANK ROOF/SHELL COLOR: Diffuse Aluminum MAXIMUM FILLS PER DAY: 1 or 2 MX. AFILLING RATE (GPM): CONFID MAX. DURATION OF FILL (HR/FILL) Approx. 3 AX. THROUGHPUT PER YEAR (GAL): CONFID MAX. TURNOVERS PER YEAR: CONFID ESCRIBE ALL MAINTENANCE PROCEDURES: DESCRIBE ANY MONITORING OR WARNING DEVICES (SUCH AS LEAK AND FUME DETECTION INSTRUMENTATION): Tank is equipped with a high level and pressure alarm system. Tank and unloading area are equipped with a butraldehyde leak detection system. INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., hours of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE MONITORED AND WITH WHAT FREQUENCY. See Form D3 -2 OMMENTS: when being loaded the tank is vented back to the railcar (i.e. vapor recovery system). Z-B DEQ-CFW 00087486 • • • CONRDENTIAL ' FIGURE ' ERM—Southeast, Inc. BUTYRALDEHYDE STORAGE TANK CHARLOTTE, NORTH CAROUNA DUPONT- FAYETTEVILLE WORKS BS—A ERM DUART, NORTH CAROLINA 2:q DEQ-CFW 00087487 FILEMANE: BUT-C9.DBF R-2 SECTION C F19 CONTROL DEVICE (CONDENSER) REVISED: 04/15/94 AIR QUALITY SECTION CONTROL DEVICE ID NO: BCD -A CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): BS-A dEbIMISSION POINT ID NO(S): BEP-A POSITION IN SERIES OF CONTROLS NO. 1 OF 1 UNITS MANUFACTURER: American Heat Reclaiming Corp. MODELNO: TYPE 1-V 7745 ALTERNATIVE OPERATING SCENARIO (AOS) NO: DESCRIBE CONTROL SYSTEM: 40 square foot brine -cooled stainless steel condenser installed on vent from 68,000 gallon butyraldehyde storage tank. Conservation vent/flame arrestor is installed in vent. POLLUTANT(S) COLLECTED: VOC CORRESPONDING EFFICIENCY: 70 EFFICIENCY DETERMINATION CODE: 2 BEFORE CONTROL CONCENTRATION (PPMV): 0.283 lb/hr AFTER CONTROL CONCENTRATION (PPMV): 0. 085 lb/hr EMISSION STREAM FLOW RATE (CFM): See below INLET EMISSION STREAM TEMPERATURE fl: Ambient MOISTURE CONTENT OF EMISSION STREAM (%): Negligible TEMPERATURE OF CONDENSATION (F): 27 - 32 COOLANT USED: Brine TEMPERATURE OF INLET COOLANT (F): 27 - 32 COOLANT FLOW RATE (LB/HR): 8, 900 REFRIGERATION CAPACITY (TONS): Approx. 600 CONDENSER SURFACE AREA (FT^2): 40 SPECIFIC HEAT OF POLLUTANT COLLECTED (BTU/LB-MOL-F): 36.5 AT OF VAPORIZATION OF COLLECTED POLLUTANT (BTU/LB-MOL): ESCRIBE MAINTENANCE PROCEDURES: DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: Condenser system is equipped with a low flow alarm. SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See process flowchart ----------------------------------------------------------------------------------------------------- Note 1: Condenser controls breathing loss emissions. The flow rate associated with breathing losses is a function of temperature change and when there is positive flow rate, it will be very low. There are no working losses from the tank because it is vented directly back to the railcar when being loaded. to 2: Tem..perature of the inlet brine ranges from 27 to 32 degrees Fahrenheit. Control efficiency been calculated based on a worst -case brine temperature of 320F (see attached calculations on D6 Form) . DEQ-CFW 00087488 FILENAME: BUT-D3-I.DBF R-1 SECTION D D3-1 SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) 0 Nee note in instructions concerning state air toxics regulations) REVISED: 04115/94 AIR QUALITY SECTION EMISSION SOURCE DESCRIPTION: Butyraldehyde Storage Tank EMISSION SOURCE 10 NO.: BS-A IS THIS SOURCE A FUGITIVE SOURCE? I 1 YES ( X 1 NO ALTERNATIVE OPERATING SCENARIO (ADS) NO: EMISSION RATE IN EMISSION RATE IN LBSIHR LBSIYR EMISSION FACTOR POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL voc 2 0.086 0.086 751 751 COMMENTS: Emissions are strictly from breathing losses which are calculated by EPA -developed TA1VKS2 software. The losses are a function of outside temperature change and are constant (as predicted by TANKS2). z- DEQ-CFW 00087489 FILENAME: BUT-D3-2.D13F R-2 SECTION D D3 2 SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS) REVISED: 04115/94 AIR QUALITY SECTION ISSION SOURCE DESCRIPTION: Butyraldehyde Storage Tank MISSION SOURCE ID NO: BS-A ALTERNATIVE OPERATING SCENARIO (ADS) NO: REGULATED POLLUTANT EMISSION AND OPERATING LIMITS APPLICABLE REQUIREMENT VOC Control Emissions by at Least 90% 15A NCAC 2D.0518(b) COMMENTS: -1I DEQ-CFW 00087490 FILENAME: BUT-D3-3.DBF R-1 SECTION D D3-3 SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES) REVISED: 04/15/94 AIR QUALITY SECTION EMISSION SOURCE DESCRIPTION: Butyraldehyde Storage Tank EMISSION SOURCE ID NO: BS-A REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION ACTIVITIES (LBS/YEAR) (LBS/YEAR) ACTIVITIES (ENTER CODES) (ENTER CODES) See Below COMMENTS: DuPont maintains on -going efforts to minimize emissions. Breathing losses from the tank are controlled by a condenser and working losses are controlled through vapor recovery. 2- �3 DEQ-CFW 00087491 SECTION D -FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: BS-A Emission Source Desc. Butyraldehyde Storage Tank A. Emission Estimation Approach: Emissions from this unit are based on EPA Publication AP-42 (using EPA -developed Tanks 2.0 software). Actual working losses are zero because when being loaded, the tank is vented back to the railcar. Breathing losses are calculated from the ambient temperature changes in the tank, and are controlled by an 70% efficient brine cooled condenser. Thus, control on working losses is 100% and control on breathing losses is 70%, and as shown by the calculations below, this gives an overall control efficiency of approximately 92-94%. Actual Emission Calculations BA (Breathing Losses) To Condenser 2482 Ibs/yr Uncontrolled Working Losses' (Actual 94) 7438 Ibs/yr Uncontrolled Working Losses' (Potential) 9905 Ibs/yr Total Uncontrolled Emissions2 (Actual 94) 9920 Ibs/yr Total Uncontrolled Emissions2 (Potential) 12387 Ibs/yr • Vapor Pressure @ 71.37°F (21.87°C) 1.844 psi Vapor Pressure @ 320F (0°C) 0.558 psi Condenser efficiency4 70% or greater BA Emissions From Condensers (Annual) 751 Ibs/year BA Emissions From Condensers (Hourly Average) 0.086 Ibs/hour Actual Working Loss Emissions 0 Ibs/year Overall Control Efficiencys (Based on Actual 94 Emissions) 92% or greater Overall Control Efficiency (Based on Potential Emissions) 94% or greater BS-AALS, nonconf Page 1 of 2 G- �q DEQ-CFW 00087492 • SECTION D -FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION • Emission Unit ID: BS-A Emission Source Desc. Butyraldehyde Storage Tank Note: 1. Actual 1994 uncontrolled working losses based on CONFIDENTIAL number of turnovers. Potential uncontrolled working losses based on CONFIDENTIAL number of turnovers. 2. Total uncontrolled emissions equal breathing losses plus working losses. 3. Vapor pressure calculated using Antoine Equation log p*(T°C) = A - [B / (T°c + C)] where p* = Vapor pressure A = 6.3854 B = 913.590 C = 185.480 4. Condenser control efficiency is calculated: 1 - (Vapor pressure @ 32 / Vapor pressure @ 71.4) This is based on the assumption that the condenser exit temperature will be at 320F (because of the low flow associated with breathing losses the gas will be completely chilled to the coolant temperature in the condenser and 320F is the upper value of the condenser temperature; 71.37°F is the average surface temperature in the BA storage tank - See Tanks 2.0 Output). 5. Emissions from condenser calculated as: Uncontrolled BA to condenser x (1 - control efficiency) Hourly emissions calculated by dividing annual emissions by 8,760. 6. Overall Control Efficiency = 1 - [(Annual Breathing Losses from Condenser + Actual Working Loss Emissions) / Total Uncontrolled Emissions) BS-A.XLS, nonconf h _ � 5 Page 2 of 2 DEQ-CFW 00087493 • • TANKS2 OUTPUT IS CONFIDENTIAL SEE D6 FORM FOR A SUMMARY OF EMISSIONS I-\Lp DEQ-CFW 00087494 • • SECTION D - FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: Emission Unit Description: B. Regulatory Information: BS-A Butyraldehyde Storage Tank This emission unit is subject to the following regulation: 15A NCAC 2D .0518(b) requires a vapor recovery system that maintains 90% or greater control of organic emissions. C. Control Device Information: There are no working losses when the tank is being loaded because vapor displaced from the tank is routed back to the tank car being unloaded. Breathing losses are controlled by a condenser. Overall control efficiency is calculated as 92% or greater. D. Compliance Information: 15A NCAC 2D .0518(b) - Whenever BA is loaded into the tank, the operator will fill in a checklist indicating that the vapor recovery system has been connected. The brine supply temperature to the condenser will be recorded weekly, and the condenser will be periodically inspected per standard operating procedures to insure proper operation. gAprojects\fayett\d6al l DEQ-CFW 00087495 FILENAME:BUT-E4.DBF R-1 SECTION E E4 COMPLIANCE PLAN (METHOD OF COMPLIANCE) REVISED 04/15194 AIR QUALITY SECTION iSSION SOURCE ID NO. BS-A REGULATED POLLUTANT VOC APPLICABLE REGULATION 15A NCAC 2D. 0518 (b) ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A MONITORING REQUIREMENTS IS ENHANCED MONITORING APPLICABLE? ( ► YES (X ► NO IS ENHANCED MONITORING PROTOCOL ATTACHED? ( I YES (X 1 NO MONITORING DEVICE TYPE: MONITORING LOCATION: OTHER MONITORING METHODS (DESCRIBE IN DETAIL): Maintain written procedure to vent butyraldehyde storage tank back to the railcar (vapor recovery system) when unloading; Track brine supply temperature GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourlyaverage): Maintain log to be completed each time that a railcar is unloaded to verify vapor recovery system is hooked up. Record brine supply temperature weekly. TEST METHODS ERENCE TEST METHOD DESCRIPTION: NIA REFERENCE TEST METHOD CITATION: RECORDKEEPING REQUIREMENTS DATA (PARAMETER) BEING RECORDED: Vapor recovery system checklist; brine supply temperature FREQUENCY OF RECORDKEEPING (HOW OFTEN IS DATA RECORDED): when tank is loaded vapor recovery system checklist will be completed; brine supply temperature will be checked weekly. REPORTING REQUIREMENTS GENERALLY DESCRIBE WHAT IS REPORTED: Checklist completion and brine supply temperature QUENCY: j I MONTHLY I )QUARTERLY j X I ONCE EVERY 6 MONTHS ( ► ONCE PER YEAR I 1 OTHER (DESCRIBE): �-19 DEQ-CFW 00087496 FILENAME: N01VC01VF\BUT-B1.D13F R-1 SECTION B EMISSION SOURCE (GENERAL) 61 REVISED: D4115194 AIR QUALITY SECTION MISSION SOURCE DESCRIPTION: Butaci to Flake Reactors EMISSION SOURCE ID NO: Bs-B CONTROL DEVICE ID NO(S): BCD-Bl, BCD-B2 EMISSION POINT ID NO(S): BEP-B1, BEP-B2 INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS ALTERNATIVE OPERATING SCENARIO (ADS) NO: 0 DESCRIBE PROCESS: Reactors for the reaction of butyraldehyde and polyvinyl alcohol to form polyvinyl butyral resin. Installed with 2 packed column water scrubbers used to cleanse process vents of any residual organic compounds. OPERATION DATE: 1969, 1990 SEASONAL VARIATION JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25 MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS MAX. DESIGN CAPACITY (UNITIHR) REQUESTED CAPACITY LIMITATION (UNITIHR) TYPE UNITS MATERIALS ENTERING PROCESS - BATCH OPERATION MAX. DESIGN CAPACITY (UNITIBATCH) REQUESTED CAPACITY LIMITATION (UNITIBATCH) TYPE UNITS Butyraldehyde (BA) LB CONFIDENTIAL Polyvinyl Alcohol (PVA) LB CONFIDENTIAL - I T_ MAXIMUM DESIGN CAPACITY (BATCHESIYR): CONFIDENTIAL - MAXIMUM DESIGN CAPACITY (BATCHESIHR): CONFIDENTIAL FUEL USED: TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR): MAX. CAPACITY HOURLY FUEL USE: MAX. CAPACITY YEARLY FUEL USE: DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS: INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS le.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE MONITORED AND WITH WHAT FREDUENCY. MENTS: DEQ-CFW 00087497 • • • 0 N F I D E N T � A L t 1 FIGURE ERM—Southeast, Inc. BUTACITEU CONDENSATION REACTORS CHARLOTTE. NORTH CAROUNA B S - B ERM DUPONT- FAYETTEVILLE WORKS g DUART, NORTH CAROLINA ti �-.20 DEQ-CFW 00087498 FILENAME: BUT-C7.DBF R-1 SECTION C F 7] CONTROL DEVICE (GASEOUS ABSORBER) REVISED: 04/15/94 AIR QUALITY SECTION NTROL DEVICE ID NO: BCD-Bl CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): BS-B ISSION POINT ID NO(S): BEP-B1 POSITION IN SERIES OF CONTROLS NO. 1 OF 1 UNITS MANUFACTURER: Ceilcote MODEL NO: SPT-05 ALTERNATIVE OPERATING SCENARIO (AOS) NO: DESCRIBE CONTROL SYSTEM: Packed column water scrubber - Modified Ceilcote model SPT-05 stainless steel. POLLUTANT(S) COLLECTED: vOC CORRESPONDING EFFICIENCY: >95 % % % % EFFICIENCY DETERMINATION CODE: 3 BEFORE CONTROL EMISSION CONTROL RATE(LB/HR): 75.6 AFTER CONTROL EMISSION RATE (LB/HR): 3.79 PRESSURE DROP (IN. H2O) MIN. 2 MAX WARNING ALARM? YES NO Xxy INLET TEMPERATURE (F) MIN. 80 MAX 120 OUTLET TEMPERATURE (F) MIN. 50 MAX 100 INLET AIR FLOW RATE (ACFM): 0-50 TOTAL GAS PRESSURE (PSIG): ambient GAS DEW POINT (F): GAS VELOCITY (FT/SEC): varies PE OF SYSTEM: Packed Column JA CKED COLUMN TYPE OF PACKING: saddles COLUMN LENGTH (FT): 16.92 COLUMN DIAMETER (FT): 1. 0 PLATE COLUMN PLATE SPACING (IN): COLUMN LENGTH (FT): COLUMN DIAMETER (FT): ADDITIVE LIQUID SCRUBBING MEDIUM:: water PERCENT RECIRCULATED: 0 TOTAL LIQUID INJECTION RATE (GAUMIN): 10 MAKE UP RATE (GAUMIN): 10 FOR ADDITIVE (GAUMIN): DESCRIBE MAINTENANCE PROCEDURES: DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: Low flow monitor. SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See process flowchart. ------------------------------------------------------------------------------------------------ ent: Efficiency is based on testing performed at a DuPont sister facility (see attached pages). DEQ-CFW 00087499 • • • Scrubber Emissions Air Sample Results CONFIDENTIAL a-a.z DEQ-CFW 00087500 FILENAME: BUT-C7.DBF R-2 SECTION C C7 CONTROL DEVICE (GASEOUS ABSORBER) RF\llRFll• (1d/1519d AIR QUALITY SECTION NTROL DEVICE ID NO: 13CD-B2 CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): BS-B ISSION POINT ID NO(S): BEP-B2 POSITION IN SERIES OF CONTROLS NO. 1 OF 1 UNITS MANUFACTURER: Fluor -Daniel MODEL NO: ALTERNATIVE OPERATING SCENARIO (AOS) NO: DESCRIBE CONTROL SYSTEM: Packed column water scrubber. POLLUTANT(S) COLLECTED: VOC CORRESPONDING EFFICIENCY: >95 % % % % EFFICIENCY DETERMINATION CODE: 3 BEFORE CONTROL EMISSION CONTROL RATE(LB/HR): 101.1 AFTER CONTROL EMISSION RATE (LB/HR): 5.05 PRESSURE DROP (IN. H2O) MIN. 2 MAX WARNING ALARM? YES NO XXx INLET TEMPERATURE (F) MIN. 80 MAX 120 OUTLET TEMPERATURE (F) MIN. 50 MAX 100 INLET AIR FLOW RATE (ACFM): 0-50 TAL GAS PRESSURE (PSIG): ambient GAS DEW POINT (F): GAS VELOCITY (FT/SEC): varies PE OF SYSTEM: Packed Column JA CKED COLUMN TYPE OF PACKING: saddles COLUMN LENGTH (FT): 18. 04 COLUMN DIAMETER (FT): 1. 0 PLATE COLUMN PLATE SPACING (IN): COLUMN LENGTH (FT): COLUMN DIAMETER (FT): ADDITIVE LIQUID SCRUBBING MEDIUM:: water PERCENT RECIRCULATED: 0 TOTAL LIQUID INJECTION RATE (GAUMIN): 10 MAKEUP RATE (GAUMIN): 10 FOR ADDITIVE (GAUMIN): DESCRIBE MAINTENANCE PROCEDURES: DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: Low flow moni tor. SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See process flowchart. --------------------------------------------------------------------------------------------------- ildr, ell t: Efficiency is based on testing pexfox led at a DuPont sister facility (see attached pages). a-a3 DEQ-CFW 00087501 • Scrubber Emissions Air Sample Results CONFIDENTIAL • • DEQ-CFW 00087502 FILENAME: BUT-D3-l.DBF R-2 SECTION D SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) D3-1 0 REVISED: 04115194 Fl- L {•see note in instructions concerning state air toxics regulations► AIR QUALITY SECTION EMISSION SOURCE DESCRIPTION: Butacite Flake Reactors EMISSION SOURCE ID NO.: BS-B IS THIS SOURCE A FUGITIVE SOURCE? ( I YES ( g ► NO ALTERNATIVE OPERATING SCENARIO (ADS) NO: I M EMISSION RATE IN EMISSION RATE IN LBSIHR LBSIYR EMISSION FACTOR POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL VOc 2 8.85 1.24 77,526 6,974 Methanol 2 COMMENTS: Methanol emissions are not quantified here because there is no specific regulation that limits methanol emissions. Actual emissions are based on 1994 operation. DEQ-CFW 00087503 FILENAME: BUT-D3-2.DBF R-3 SECTION D D3.2 SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS) EVISED: 04115/94 AIR QUALITY SECTION IN MISSION SOURCE DESCRIPTION: Butaci to Flake Reactors EMISSION SOURCE ID NO: BS-B ALTERNATIVE OPERATING SCENARIO (ADS) NO: REGULATED APPLICABLE POLLUTANT EMISSION AND OPERATING LIMITS REQUIREMENT See Comment COMMENTS: There are no applicable requirements for the Butacite Reactors. 2 2-LP DEQ-CFW 00087504 FILENAME: BtTI'-D3 -3 . DBF R-2 SECTION D SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES) . REVISED:04/15/94 1] • AIR QUALITY SECTION D33 I EMISSION SOURCE DESCRIPTION: Bu taci to Flake Reactors I EMISSION SOURCE ID NO: BS-B REGULATED ONGOING SOURCE POLLUTANT REDUCTION ACTIVITIES (ENTER CODES) See Below QTY. EMITTED BEFORE REDUCTION (LBSNEAR) QTY. EMITTED AFTER REDUCTION (LBSNEAR) PLANNED SOURCE REDUCTION ACTIVITIES (ENTER CODES) COMMENTS: DuPont maintains on -going efforts to minimize emissions. Emissions from this process are controlled by scrubbers. z- Z7 DEQ-CFW 00087505 C. 0 • SECTION D - FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: Emission Source Desc. BS-B Butaciteo Flake Reactors A. Emission Estimation Approach: Emissions from the flake reactors include unreacted butyraldehyde and residual methanol in the PVA. (PVA contains a maximum of approximately CONFIDENTIAL% methanol). Emissions are calculated on a per batch basis. Butyraldehyde vented per batch is calculated based on the nitrogen sparging rate and the concentration of butyraldehyde in the vapor space. For methanol, it is assumed that it is all vented. Emission Calculations Butyraldehyde per batch Sparge time = CONFIDENTIAL min N2 flow during sparging = CONFIDENTIAL cfm Simulation model data = CONFIDENTIAL mole fraction BA in N2 during sparging N2 density (lb / cu. ft.) = PM/RT=(14.7psia*28lb/lb-mole)/10.73psia-cu.ft./(Ib-mole-degR*520degR) = 0.0738 Ibs N2 to scrubber (Ibs N2) = CONFIDENTIAL cfm * 0.0738 lb N2/cu.ft.N2 * CONFIDENTIAL min = 132.8 lbs. BA in N2 purge (Ibs BA/lbs N2) = CONFIDENTIAL mole BA/mole N2 * 72 Ibs BA/mole BA * mole N2/18 Ibs N2 = CONFIDENTIAL Ibs BA to scrubber (Ibs BA/batch) = 132.8 Ibs N2 * CONFIDENTIAL Ibs BA/Ibs N2 = CONFIDENTIAL Methanol per batch Each batch contains potentially CONFIDENTIAL Ibs PVA that is CONFIDENTIAL% methanol. This corresponds to a potential of CONFIDENTIAL Ibs methanol per batch. BS-BALS, nonoonf Page 1 of 2 DEQ-CFW 00087506 • SECTION D - FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: BS-B Emission Source Desc, Butaciteo Flake Reactors VOC Emissions Total VOC to scrubbers is CONFIDENTIAL Ibs (CONFIDENTIAL Ibs BA + CONFIDENTIAL Ibs methanol) per batch. 1994 Maximum batches per hour = CONFIDENTIAL batches/hr Potential batches per hour = CONFIDENTIAL batches/hr 1994 Annual Batches = CONFIDENTIAL batches/yr Potential batches per year = CONFIDENTIAL batches/yr Act'I Hourly Uncontrolled VOC Emi = 124 Ibs/hr Pot'I Hourly Uncontrolled VOC Emi = 177 Ibs/yr Actual 94 Uncontrolled Annual Emi = 697,362 Ibs/yr Potential Uncontrolled Annual Emis = 1,550,520 Ibs/yr Actual Control Efficiency = 99% Worst Case Control Efficiency = 95% Actual 94 Hourly Emissions = 1.24 Ibs/hr Potential Hourly Emissions = 8.85 Ibs/hr Actual 94 Annual Emissions = 6,974 Ibs/yr Potential Annual Emissions = 77,526 lbs/yr Notes; 1. Actual emissions are based on actual control efficiency. 2. Potential emissions are based on maximum rates at worst -case control efficiency. Page 2 of 2 BS-B.XLS, nonwnf DEQ-CFW 00087507 • • • SECTION D - FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: Emission Unit Description: B. Regulatory Information: BS-B Butacite® Reactors There are no applicable requirements for the Butacite® Reactors. C. Control Device Information: This emission unit is equipped with two packed -column water scrubbers to control emissions. These scrubbers will be periodically inspected per standard operating procedures to ensure proper operation. D. Compliance Information• There are no applicable regulations to comply with. However, emissions for the Butacite® reactors will continue to be tracked and reported as part of the required annual emissions inventory. g Aprojects\fayett\d6a1I M DEQ-CFW 00087508 FILENAME: N01VC0NF\BUT-B1.DBF R-2 REVISED: 04115194 SECTION B EMISSION SOURCE (GENERAL) AIR QUALITY SECTION WISSION SOURCE DESCRIPTION: Bu taci to Flake dryer EMISSION SOURCE 10 NO: BS-C CONTROL DEVICE ID NO(S): BCD-Cl, BCD -C2 EMISSION POINT ID NO(S): BEP-C INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS ALTERNATIVE OPERATING SCENARIO (ADS) NO: DESCRIBE PROCESS: Water saturated flake is fed to a flake dryer where it is dried to low levels of moisture using steam heated air. OPERATION DATE: 1969 SEASONAL VARIATION(%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25 MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS MAX. DESIGN CAPACITY (UNITIHR) REQUESTED CAPACITY LIMITATION (UNITIHR) TYPE UNITS Polyvinyl butyral LB CONFIDENTIAL Water LB CONFIDENTIAL MATERIALS ENTERING PROCESS - BATCH OPERATION MAX. DESIGN CAPACITY (UNITIBATCH) REQUESTED CAPACITY LIMITATION (UNITIBATCH) TYPE UNITS MAXIMUM DESIGN CAPACITY (BATCHESIYR): MAXIMUM DESIGN CAPACITY (BATCHESIHR): FUEL USED: TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR): MAX. CAPACITY HOURLY FUEL USE: MAX. CAPACITY YEARLY FUEL USE: DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS: INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE MONITORED AND WITH WHAT FREQUENCY. SEE FORM D3 -2 kIMENTS: 7 DEQ-CFW 00087509 • • • CONFIDENTIAL FIGURE ERM—Southeast, Inc. BUTACITE(D FLAKE DRYER nCHARLOTTE, NORTH CAROLINA B S - C ERM DUPONT — FAYETTEVILLE WORKS r DUART, NORTH CAROLINA .�-3z DEQ-CFW 00087510 * FILENAME:BUT-05.DBF R-1 • • r. n- nAMCMA SECTION C CONTROL DEVICE (MECHANICAL) AIR QUALITY SECTION H CONTROL DEVICE ID NO: BCD -CI CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): BS-C EMISSION POINT ID NO(S): BEP-C POSITION IN SERIES OF CONTROLS NO. 1 OF 2 UNITS MANUFACTURER: Mitternight Boiler Works ALTERNATIVE OPERATING SCENARIO (AOS) NO: DESCRIBE CONTROL SYSTEM: Cyclone separator exits the flake dryer. The cyclone has diameter of 116 inches. It is rated at MODEL NO: Cyclone Separator, DuPont design to remove flake particles from the hot air that an overall height of 464 inches and a barrel 90% efficiency. POLLUTANT(S) COLLECTED: CORRESPONDING EFFICIENCY: EFFICIENCY DETERMINATION CODE: BEFORE CONTROL EMISSION RATE (LB/HR): AFTER CONTROL EMISSION RATE (LB/HR): PM 9O % 4 667 66.7 PRESSURE DROP (IN H2O) MIN MAX WARNING ALARM? YES NO INLET TEMPERATURE (F) MIN 12.5 MAX OUTLET TEMPERATURE (F) MIN 125 MAX INLET AIR FLOW RATE (ACFM): 4 0, 000 PARTICLE DENSITY (LB/FT3): SETTLING CHAMBER LENGTH(INCHES): INLET VELOCITY (FTisEC):58. 5 CYCLONE ( ) CIRCULAR ( ) SQUARE MULTICYCLONE NO. TUBES: WIDTH (INCHES): DIMENSIONS (INCHES) IF WET SPRAY UTILIZED DIAMETER OF TUBES: HEIGHT (INCHES): 4 64 H: Dd: LIQUID USED: HOPPER ASPIRATION SYSTEM? ( ) YES { ) NO VELOCITY (FT/SEC):3 6.4 W: Lb: FLOW RATE (GPM): NO. TRAYS: De: La MAKE UP RATE (GPM): LOUVERS? NO. BAFFLES: D: 116 S: DESCRIBE MAINTENANCE PROCEDURES: ( ) YES ( ) NO DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See Process Fl owshee t . -------------------------------------------------------- Comment: Cyclone efficiency is based on original design criteria. 90* control is typical Lor cyclones. -4-53 DEQ-CFW 00087511 A 14 FILENAME: FAY-C2.DBF R-1 - ,, . REVISED:04115194 SECTION C CONTROL DEVICE (FABRIC FILTER) AIR QUALITY SECTION F2 NTROL DEVICE ID NO: BCD-C2 CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): BS-C EMISSION POINT ID NO(S): BEP-C POSITION IN SERIES OF CONTROLS NO. 2 OF 2 UNITS MANUFACTURER: Flex Kleen MODELNO: Bag Filter 100 WPWC540ARRIII ALTERNATIVE OPERATING SCENARIO (ADS) NO: DESCRIBE CONTROL SYSTEM: Bagfilter controls emissions of fine particles that exit the cyclone separator. The bagfilter is 12' x 30' x 30' and contains 540 bags that are"10' long. It is rated at 99% efficiency. POLLUTANT(S) COLLECTED: PM 99 % % % % CORRESPONDING EFFICIENCY: 4 EFFICIENCY DETERMINATION CODE: 66.7 BEFORE CONTROL EMISSION RATE (LBIHR): 0.67 AFTER CONTROL EMISSION RATE (LBIHR): PRESSURE DROP (IN H20) MIN 0 MAX 11 WARNING ALARM? YES ]x NO INLET TEMPERATURE (F) MIN 125 MAX OUTLET TEMPERATURE (F) MIN 2.25 MAX INLET AIR FLOW RATE (ACFM): 4 0, 000 AIR TO CLOTH RATIO: 5. 9811 FILTER SURFACE AREA (FT" 2): 6858 FILTER MAX. OPERATING TEMP. IF): TER MATERIAL: 16 OZ. POLYESTER DESCRIBE CLEANING PROCEDURES: TIME BETWEEN CLEANING: PULSE 15 MECHANICAL REVERSE FLOW SIMPLE BAG COLLAPSE CLEANING TIME: BAGS EVERY 20 SEC SONIC g AIR PULSE RINGED BAG COLLAPSE IlOTHER: DESCRIBE MAINTENANCE PROCEDURES: DESCRIBE MOISTURE BLINDING, CHEMICAL RESISTIVITY, ANDIOR SPECIAL OPERATING CONDITIONS: DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC: Low air flow alarm. High pressure differential alarm. SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See Process Flowchart. gfilter efficiency is based on original design criteria of 99% control (or better) which is a typical control efficiency for bagfilters. -2- 3 DEQ-CFW 00087512 FILENAME: BUT-D3-I.DBF R-5 SECTION D SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) 0 (•see note in instructions canceming state arc taxics regulations) �. ,��o. AIR nlm my SECTION D3•i EMISSION SOURCE DESCRIPTION: Butaci to Flake Dryer EMISSION SOURCE 10 NO.: BS-C IS THIS SOURCE A FUGITIVE SOURCE? ( I YES I X ) NO ALTERNATIVE OPERATING SCENARIO (ADS) NO: EMISSION RATE IN EMISSION RATE IN LBSIHR LBSIYR EMISSION FACTOR POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL PM and PM-10 2 0.67 0.50 5,843 4,380 COMMENTS: 2-35 DEQ-CFW 00087513 FILENAME: BUT-D3-2.DBF R-1 SECTION D D3.2 SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS) EVISEO: 04115194 AIR OUALITY SECTION EMISSION SOURCE AIR OUALITY SECTION DESCRIPTION: Butaci to Flake Dryer EMISSION SOURCE ID NO: BS-C ALTERNATIVE OPERATING SCENARIO (ADS) NO: REGULATED APPLICABLE POLLUTANT EMISSION AND OPERATING LIMITS REQUIREMENT PM PM less than 9.76 lb/hr 15A NCAC 2D.0515 OPACITY opacity less than 40$ 15A NCAC 2D.0521(d) COMMENTS: The opacity standard reads as follows, "visible emissions shall not be more than 40-t opacity when averaged over a six -minute period except that six -minutes periods averaging not more than 90* opacity may occur not more than once in any hour nor more than four times in any 24-hour period". 2-3LD DEQ-CFW 00087514 DEQ-CFW 00087514 FILENAME: BUT-D3 -3 . DBF R-3 SECTION D D3-3 SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES) REVISED:04/15/94 MW E AIR QUALITY SECTION EMISSION SOURCE DESCRIPTION: Butaci to Flake Dryer EMISSION SOURCE ID NO: BS-C QTY. EMITTED AFTER REDUCTION (LBSNEAR) PLANNED SOURCE REDUCTION ACTIVITIES (ENTER CODES) REGULATED POLLUTANT ONGOING SOURCE REDUCTION ACTIVITIES (ENTER CODES) QTY. EMITTED BEFORE REDUCTION (LBSNEAR) PM See Comment COMMENTS: DuPont maintains on -going efforts to minimize emissions. Emissions from this process are controlled by a cyclone and bagfilter in series. Z-3 7 DEQ-CFW 00087515 SECTION D - FORM D6 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION Emission Unit ID: BS-C Emission Source Desc. Flake Dryer A. Emission Estimation Approach: Particulate emissions are calculated based on a mass balance approach. The cyclone separator has a 90% control efficiency and the bag filter has a 99% control efficiency. Emission Calculations Particulates Actual PM to cyclone separator = 500 Ib/hr Potential PM to cyclone separator = 667 Ib/hr Cyclone separator efficiency = 90% ctual PM from separator to bag filter = 50 Ib/hr otential PM from separator to bag filter = 66.7 Ib/hr Sag filter efficiency = 99% Actual PM emissions from bag filter = 0.5 Ib/hr Potential PM emissions from bag filter = 0.67 Ib/hr Actual emissions = 0.5 Ib/hr * 8760 hr/yr = 4380 Ib/yr Potential emissions = 0.667 Ib/hr * 8760 hr/yr = 5843 Ib/yr • BS-CALS Page 1 of 1 a-38 DEQ-CFW 00087516