HomeMy WebLinkAboutDEQ-CFW_00087577FILENAMft NAFy;-M-2.DBF R-9 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04115194 AIR OUALITY SECTION
D3.2
SSION SOURCE DESCRIPTION: RSU Process
EMISSION SOURCE ID NO: NS-D ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
COMMENTS: There are no federally enforceable applicable requirements associated with the RSU process.
DEQ-CFW 00087577
FILENAME: NAF-D3 -3 . DBF R-2 SECTION D D3�3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
04l15/�J4 lilR LttiAl-11 i ACV f 1VIY
SOURCE DESCRIPTION: RSU Process
EMISSION SOURCE ID NO: NS-D
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
-3q
DEQ-CFW 00087578
Is
SECTION D -FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-D
Emission Unit Description: RSU Process
Actual VOC emissions from the RSU process in 1994 were 1.58 tons (See Addendum A for
emissions calculations). The potential VOC's per year can be estimated by multiplying the
actual VOC's in lbs/hr by the number of hours per year:
(3.29 lbs VOC/hr) x (8,760 hours/year) x (1 tons/2,0001bs) = 14.4 tons VOC/year
The actual hourly VOC emissions from the RSU process are estimated to by modeling of the
process. Potential hourly emissions are not quantified because they depend upon many
interrelated process parameters. HAP's which may be emitted from the RSU process include
trace amounts of hydrogen fluoride (HF). Trace amounts of sulfur dioxide (S02) can also be
emitted.
B. Rggulatoa Information:
There are no federally enforceable regulations that apply to the RSU process.
Emissions of North Carolina toxic air pollutants (TAPS) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device Information:
Point source emissions from this process unit can be controlled by either of the waste gas
scrubbers. The waste gas scrubbers control acid fluoride emissions. The waste gas scrubbers are
periodically inspected per standard operating procedures to insure proper operation.
D. Compliance Information:
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the RSU process will continue to be tracked and reported as part of the
required annual emissions inventory.
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DEQ-CFW 00087579
FILENAME: NONCONF\NAF-BI.DBF R-11 SECTION B
Y B1
EMISSION SOURCE (GENERAL)
4
RFVISFn-- 04115194
AIR QUALITY SECTION
ISSION SOURCE DESCRIPTION: Liquid Waste Stabilization
EMISSION SOURCE ID NO: Ns-E
NTROL DEVICE ID NO(S): NCD-Hdrl or NCD-Hdr2
EMISSION POINT ID NO(S): NEP-Hdri or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO
ALTERNATIVE OPERATING SCENARIO (AOS) NO:
DESCRIBE PROCESS: Collection, stabilization,
OPERATION DATE: 1979
SEASONAL VARIATION ffl JAN•MAR: 25
NSPS OR NESHAPS REGULATIONS
and temporary storage of liquid waste fluorocarbons.
APR-JUN: 25 JUL•SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNIT►HR)
UNITS
TYPE
Waste Fluorocarbons
lb
CONFIDENTIAL
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY(UNITIBATCH)
REQUESTED CAPACITY
LIMITATION_(UNITIBATCH)
UNITS
TYPE
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
MENTS:
3 - L\
DEQ-CFW 00087580
3- a �)-
DEQ-CFW 00087581
FILENAME: INAF-D3� I.DBF R-2 SECTION 0
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) 03.1
4
0ISED: 04115194
('see note in instructions concerning state air toxics regulations)
AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Liquid Waste Stabilization
EMISSION SOURCE 10 NO.: NS-E IS THIS SOURCE A FUGITIVE SOURCE? ( ! YES ( ! NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
LBSIHR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
See Comment
0.47
4,095
3,740
Hydrogen Fluoride*
COMMENTS: Emissions include both point source and fugitive emissions. Potential hourly emissions vary
depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the Liquid Waste Stabilization process. Emissions are
ed on the 1995 emissions inventory. See the D6 Form and Addendum A for additional detail.
te: Emission of BAPS are not quantified because there are no federally enforceable applicable
uirements.
l
3
DEQ-CFW 00087582
FILENAME; NAF-Dj-2.DBF R-2 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04115194 AIR QUALITY SECTION
D3.2
SSIONSOURCEDESCRIPTION: Liquid Waste Stabilization
MISSION SOURCE ID NO: NS-E
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
COMMENTS: There are no federally enforceable applicable requirements for the liquid waste
stabilization process.
3-u�1
DEQ-CFW 00087583
FILENAME: 1VAF-D3-3.DBF R-9 SECTION D �3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
REVISED: 04/15/94 AIR QUALITY SECTION
ANKMISSION SOURCE DESCRIPTION: Liquid Waste Stabilization
EMISSION SOURCE ID NO: NS-E
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3- k15
DEQ-CFW 00087584
0
•
•
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-E
Emission Unit Description: Liquid Waste Stabilization
K16711M,i iI t)_ T Oe 1_ Ip.
Actual VOC emissions from Liquid Waste Stabilization in 1995 were 1.87 tons (See
Addendum A) during 8,000 hours of operation. Potential VOC are estimated as 8,760 / 8000
1.87 tons which equals 2.05 tons per year. Actual hourly VOC emissions from the Liquid Waste
Stabilization process are estimated as actual annual emissions divided by hours of operation or
1.87 tons * 2,000 / 8,000 which equals 0.467 lbs/hour. Potential hourly emissions are not
quantified because they depend upon several interrelated parameters. HAPs which may be
emitted from the Liquid Waste Stabilization process include trace amounts of hydrogen fluoride.
B. Regulatory Information:
There are no federally enforceable regulations that apply to the Liquid Waste Stabilization
process.
Emissions of North Carolina toxic air pollutants (TAPS) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
Point source emissions from this process unit can be controlled by either of the waste gas
scrubbers. The waste gas scrubbers control acid fluoride emissions. The waste gas scrubbers are
periodically inspected per standard operating procedures to insure proper operation.
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the Liquid Waste Stabilization process will continue to be tracked and
reported as part of the required annual emissions inventory.
gAprojects\fayett\d6a11
3—L1Lo
DEQ-CFW 00087585
FILENAME N0NCO1JF\.NAF-B1. DBF R-12 SECTION B
EMISSION SOURCE (GENERAL) B1
WISED: 04115194
AIR QUALITY SECTION
SSION SOURCE DESCRIPTION: MMF Process
EMISSION SOURCE ID NO: NS-F
CONTROL DEVICE ID NO(S): NCD-F, NCD-Hdr1 or NCD-Hdr2
EMISSION POINT ID NO(S►: NEp-Hdr1 or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS'OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: Production of methyl malom t by reaction of tetrafluoroethylene (TFE) and
dimethylcarbonate (DMC). (Includes associate*action and purification steps)
OPERATION DATE:
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
TERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNiT►BATCH)
UNITS
TYPE
Dimethyl carbonate
lb
CONFIDENTIAL
Sodium Methoxide
lb
CONFIDENTIAL
Tetrafluoroethylene
lb
CONFIDENTIAL
Sulfuric Acid
1b
CONFIDENTIAL
MAXIMUM DESIGN CAPACITY (BATGHESIYR): 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 (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
MENTS:
3-17
DEQ-CFW 00087586
0 0 a
0
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0
0
00
00
IZ-12-95 1-1
ERM—Southeast, Inc.
CHARLOTTE, NORTH CAROLINA
ERM
CONFIDENTIAL
MMF PROCESS
DUPONT — FAYETTEVILLE WORKS
DUART, NORTH CAROLINA
FIGURE
NS—F
FILENAME: NAF-C7.DBF R-2 SECTION C
CONTROL DEVICE (GASEOUS ABSORBER)
H
REVISED: 04/15/94 AIR QUALITY SECTION
NTROL DEVICE ID NO: NCD-F
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): NS-F
ISSION POINT ID NO(S): NEp-F
POSITION IN SERIES OF CONTROLS
NO. 1 OF 1 UNITS
MANUFACTURER: DuPont Fabricated MODEL NO:
ALTERNATIVE OPERATING SCENARIO (AOS) NO:
DESCRIBE CONTROL SYSTEM: 925 lb/hr of an approximate 10* KOH solution is circulated continuously
through the packed column. A pH measurement is used to determine when additional KOH is required.
POLLUTANT(S) COLLECTED:
HF
H2SO4
CORRESPONDING EFFICIENCY:
> 80 %
> 80 %
%
%
EFFICIENCY DETERMINATION CODE:
4 (est.)
4 (est. )
BEFORE CONTROL EMISSION CONTROL RATE(LB/HR):
0.023
0.0027
AFTER CONTROL EMISSION RATE (LB/HR):
0.005
0.0005
PRESSURE DROP (IN. H2O) MIN, 0 MAX 7.6 WARNING ALARM? YES XX NO
INLET TEMPERATURE (F) MIN. 70 MAX 104 OUTLET TEMPERATURE (F) MIN. 70 MAX 104
INLET AIR FLOW RATE (ACFM):
TOTAL GAS PRESSURE (PSIG): 0.45 GAS DEW POINT (F): GAS VELOCITY (FTISEC):
PE OF SYSTEM: Caustic Scrubber
CKED COLUMN
TYPE OF PACKING: poly Pall Rings
COLUMN LENGTH (FT): 8
COLUMN DIAMETER (FT): 0. 67
TE COLUMN
7AD
PLATE SPACING (IN):
COLUMN LENGTH (FT):
COLUMN DIAMETER (FT):
DITIVE LIQUID SCRUBBING MEDIUM:: 10$ KOH
PERCENT RECIRCULATED: 100*
TOTAL LIQUID INJECTION RATE (GALIMIN): 2.3 --]MAKEUP
RATE (GAL/MIN): negl FOR ADDITIVE (GAL/MIN):
DESCRIBE MAINTENANCE PROCEDURES: Routine maintenance is performed on the scrubber only when the MMF
Process is not operating.
DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: The pH of the KOH solution is monitored
continuously.
SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S):
13A
DEQ-CFW 00087588
FILENAME: NAF-D3-I.DBF R-3 SECTION D D3.1
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
('see note in instructions concerning state air toxics regulations)
OISED: 04/15194 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: MMF Process
EMISSION SOURCE ID NO.: NS-F IS THIS SOURCE AFUGITIVE SOURCE? ) YES ( 1 NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
1,2
See Comment
7.42
65,000
21,000
Hydrogen Fluoride*
Methanol*
COMMENTS: Emissions include both point source and fugitive emissions. Potential hourly emissions vary
depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the MF process. Emissions are based on the 1994
emissions inventory. See the D6 Form and Addendum A for additional detail.
ote: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements.
3 —S0
DEQ-CFW 00087589
FILENAME: kAF-D3J2.DBF R - 3 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
04115184
SOURCE DESCRIPTION: MMF Process
Ain UUMLII I QL10I IWIN
EMISSION SOURCE ID NO: NS-F I ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
COMMENTS: There are no federally enforceable applicable regulations for the MMF process.
D3.2
f6-v
DEQ-CFW 00087590
F-
L
4
FILENAME: NAF-D3-3.DBF R-1
SECTION D
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
EVISED: 04/15/94
AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: MMF Process
EMISSION SOURCE ID NO: NS-F
REGULATED
POLLUTANT
ONGOING SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
QTY. EMITTED
BEFORE REDUCTION
(LBSNEAR)
QTY. EMITTED
AFTER REDUCTION
(LBSNEAR)
PLANNED SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
All
Ilk
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3-5 2
DEQ-CFW 00087591
•
•
•
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-F
Emission Unit Description: M11f Process
A. Emissions Estimation Approach:
Emissions from the MMF process include point source emissions and fugitive emissions. All
point source emissions can be routed to the MMF caustic scrubber and then onto one of the
overall waste gas scrubbers. The only federally regulated pollutant emitted from the MMF
process is VOC. Actual VOC emissions in 1994 were 10.5 tons (See Addendum A). Hours of
operation in 1994 were 2,832. Therefore, potential VOC are estimated as 8,760 hr/yr / 2,832 hr
times 10.5 tons which gives 32.5 tons per year. Actual hourly VOC emissions from the MMF
process are estimated as actual annual emissions divided by hours of operation or 10.5 tons *
2,000 / 2,832 which equals 7.42 lbs/hour. Potential hourly emissions are not quantified because
they depend upon several interrelated parameters. HAPs which may be emitted from the MMF
process include hydrogen fluoride and methanol.
B. Regulatory Information:
There are no federally enforceable applicable regulation to the MMF process.
Emissions of North Carolina toxic air pollutants (TAPS) from the entire facility are limited and
TAP emissions from this unit count towards the overall limit (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device Information:
Point source emissions from this process unit can initially be controlled in the MMF caustic
scrubber and then will be controlled by either of the overall Nafion® waste gas scrubbers. All of
these scrubbers control acid fluoride emissions and are periodically inspected per standard
operating procedures to insure proper operation.
This process is also equipped with a sodium methoxide conveying system. However,
uncontrolled potential emissions from the conveying system are less than 0.25 tons per year, and
therefore, it is considered insignificant.
D. Compliance Information:
VOC emissions from this emission unit are tracked by entering process data into spreadsheets
developed to calculate emissions..
gAprojects\fayett\d6a11
3-s3
DEQ-CFW 00087592
FILENAME: NAF-A5.DBF r2 SECTION A A5
` " EMISSION SOURCEICONTROL OEVICE ALTERNATIVE -OPERATING SCENARIOS
REVISED: 04115184 AIR QUALITY SECTION
SOURCEIDNO: NS-G
DEVICE ID NO: NCD-G
PRIMARY OPERATING SCENARIO (DESCRIBE): AOS-1
XR Resin Process - Reaction of PSEPVE, TFE, and F2 and associated separation operations to produce XR
resin.
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO. AOS-2
CR Resin Process Reaction of EVE and TFE and associated separation operations to produce CR resin.
DESCRIBE ALTERNATIVE OPERATING SCENARIO (AOS) NO.
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO.
COMMENTS: Neither the XR or CR resin processes are the "primary" mode of operation, and therefore,
they have been identified as AOS-Land AOS-2, respectively.
DEQ-CFW 00087593
4
FILENAME: NONCONF\NAP-BI.DBF R-6 SECTION B
EMISSION SOURCE (GENERAL)
FB 11
REVISED: 04n5/94 AIR BUALITY SECTION
ON SOURCE DESCRIPTION: Resins Process
CONTROL
EMISSION SOURCE ID NO: NS-G
DEVICE ID NO(S): NCD-G
EMISSION POINT 10 NO(S): NEP-G
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS)NO: AOS-1
DESCRIBE PROCESS: Production of XR resin (includes associated reaction and purification steps)
OPERATION DATE: 1980
SEASONAL VARIATIONt%j 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
PSEPVE
lb
CONFIDENTIAL
Tetrafluoroethylene (TFE)
lb
CONFIDENTIAL
MATERIALS ENTERING PROCESS • BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
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.
MENTS: PSEPVE - Perfluorinated Sulfonyl Vinyl Ether
Note: A trace amount of fluorine is also used in this process.
DEQ-CFW 00087594
FILENAME: NONC0P7F\NAF-B1.DBF R-7 SECTION B
EMISSION SOURCE (GENERAL) B1
REVISED:04115194 AIR QUALITY SECTION
ISSION SOURCE DESCRIPTION: Resins Process
EMISSION SOURCE ID NO: NS-G
CONTROL DEVICE ID NO(S): NCD-G
EMISSION POINT ID NO(S): NEP-G
INDICATE WHETHER THIS SOURCE IS SUBJECT TO
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-2
DESCRIBE PROCESS: Production of CR resin
OPERATION DATE: 1982
SEASONAL VARIATION(%1 JAN•MAR: 25
NSPS OR NESHAPS REGULATIONS
(includes associated reaction and purification steps)
APR•JUN: 25 JUL•SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS. CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Ester Vinyl Ether (EVE)
lb
CONFIDENTIAL
Tetrafluoroethylene (TFE)
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.
MENTS:
3-5 i.o
DEQ-CFW 00087595
4054XRGK.UWG 12-12-95 1-1
ERM—Southeast, Inc.
CHARLOTTE, NORTH CAROLINA
ERM
Co'N''FIDENTIAL
RESINS PROCESS
DUPONT — FAYETTEVILLE WORKS
DUART, NORTH CAROLINA
FIGURE
NS—G
FILENAME: NAF-C7.DBF R-1 SECTION C R
CONTROL DEVICE (GASEOUS ABSORBER)
REVISED: 04/15/94 AIR QUALITY SECTION
CONTROL DEVICE ID NO: NCD-G
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): NS-G
ISSION POINT ID NO(S): NEP-G
POSITION IN SERIES OF CONTROLS
NO.1 OFl UNITS
MANUFACTURER: DuPont MODEL NO:DuPont Engineering Design
ALTERNATIVE OPERATING SCENARIO (AOS) NO: AOS-1
DESCRIBE CONTROL SYSTEM: 1.23 sq. ft. cross section sieve plate caustic scrubber with counter -current
contact of gases from XR resin fluorinator with KOH.
POLLUTANT(S) COLLECTED:
F2 & HF
CORRESPONDING EFFICIENCY:
95$ %
%
%
%
.EFFICIENCY DETERMINATION CODE:
1
BEFORE CONTROL EMISSION CONTROL RATE(LB/HR):
.036
AFTER CONTROL EMISSION RATE (LB/HR):
.0018
PRESSURE DROP (IN. H2O) MIN. MAX 2.0 WARNING ALARM? YES NO
INLET TEMPERATURE (F) MIN. MAX OUTLET TEMPERATURE (F) MIN. Arab MAX Amb
INLET AIR FLOW RATE (ACFM): 0.1
TOTAL GAS PRESSURE (PSIG): GAS DEW POINT (F): Saturated GAS VELOCITY (FT/SEC):. 001
TYPE OF SYSTEM: Sieve Plate Tower
KED COLUMN
TYPE OF PACKING:
COLUMN LENGTH (FT): 12
COLUMN DIAMETER (FT):
PLATE COLUMN
PLATE SPACING (IN):
COLUMN LENGTH (FT):
COLUMN DIAMETER (FT):
ADDITIVE LIQUID SCRUBBING MEDIUM:: KOH
PERCENT RECIRCULATED: Approximately 100*
TOTAL LIQUID INJECTION RATE (GAL/MIN): 50
MAKE UP RATE (GAL/MIN):. Ol FOR ADDITIVE (GAL/MIN):
DESCRIBE MAINTENANCE PROCEDURES:
DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.:
SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S):
3-s8
DEQ-CFW 00087597
FILENAME: NAF-D3-I.DBF R-.5 SECTION 0
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION D3-1
1
('see note in instructions concerning state air toxics regulations)
QVISED: O4115194 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Resins Process
EMISSION SOURCE ID NO.: NS-G IS THIS SOURCE A FUGITIVE SOURCE? ( ! YES ( ) NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
LBSIHR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
1,2
See Comment
9.93
80,000
33,400
Hydrogen Fluoride*
Fluorine*
COMMENTS: Emissions include both point source and fugitive emissions. Potential hourly emissions vary
depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the Resins process. Emissions are based on the 1994
issions inventory. See the D6 Form and Addendum A for additional detail.
Note: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements.
3-51�
DEQ-CFW 00087598
FILENAMEi NAP-D3-2.DBF R-5 SECTION O 03.2
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04115/94 AIR QUALITY SECTION
SIGN SOURCE DESCRIPTION: Resins Process
EMISSION SOURCE ID NO: NS-G
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
VOC
Emissions from Resins process < 40 tpy
Avoid. 15A NCAC 2D.0530
COMMENTS: VOC emission cap taken to avoid applicability of 2D.0530.
DEQ-CFW 00087599
FILENAME: NAF-D3 -3 . DBF R-3 SECTION D
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
U4/101y4 AIR wu/41L.11 / orV I IVIY
SOURCE DESCRIPTION: Resins Process
EMISSION SOURCE ID NO: NS-G
REGULATED ONGOING SOURCE QTY, EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBS/YEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
A11
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3- LQ 1
DEQ-CFW 00087600
•SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
:7
Emission Unit ID: NS-G
Emission Unit Description: Resins Process
Operating Scenarios: Both (AOS 1 and 2)
A. Emissions Estimation Approach:
Actual VOC emissions from the Resin Process in 1994 were 16.7 tons (See Addendum A).
Hours of operation in 1994 were 3,362. Potential VOC emissions are estimated defined by the
PSD avoidance limit of 40 tons per year. Actual hourly VOC emissions from the Resins process
are estimated as actual annual emissions divided by hours of operation or 16.7 tons * 2,000 /
3,362 which equals 9.93 lbs/hour. Potential hourly emissions are not quantified because they
depend upon several interrelated parameters. HAPs which may be emitted from the Resins
process include trace amounts of hydrogen fluoride. Also, trace amounts of fluorine can be
emitted from the process.
B. Regulatory Information:
The only federal permit condition that applies to this emissions unit is a VOC emissions cap
taken to avoid applicability of NCAC 2D.0530 - Prevention of Significant Deterioration (PSD).
The PSD avoidance limit is 40 tons per year for the Resins Process.
Emissions of North Carolina toxic air pollutants (TAPs) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device information:
The XR Resin process has a fluorination step and residual FZ and HF are controlled in a caustic
scrubber. The caustic scrubber is periodically inspected per standard operating procedures to
insure proper operation.
D. Compliance Information:
VOC emissions from the Resins Process will be determined monthly by tracking process data
and using engineering calculation. Emissions will be recorded as a rolling 12-month VOC total,
and will be reported quarterly.
gAprojects\fayett\d6a11
3-t-pa
DEQ-CFW 00087601
FILENAME: SECTION E
NAF—E4.DBF R-5
FE4]
COMPLIANCE PLAN (METHOD OF COMPLIANCE)
REVISED 04115194
AIR QUALITY SECTION
4!!!
E ID NO. NS—G REGULATED POLLUTANT VOC
APPLICABLE REGULATION 15A NCAC 2D.0530
ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A
MONITORING REQUIREMENTS
IS ENHANCED MONITORING APPLICABLE? ( ) YES (X ) NO
IS ENHANCED MONITORING PROTOCOL ATTACHED? ( ► YES IX ) NO
MONITORING DEVICE TYPE: N/A
MONITORING LOCATION: N/A
OTHER MONITORING METHODS (DESCRIBE IN DETAIL): Engineering calculations based on process flow sheet emission
information.
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
hourly average): VOC emissions are determined monthly.
TEST METHODS
REFERENCE TEST METHOD DESCRIPTION: N/A
REFERENCE TEST METHOD CITATION: N/A
RECORDKEEPING REQUIREMENTS
DATA (PARAMETER) BEING RECORDED: process throughput.
FREQUENCY OF RECORDKEEPING (HOW OFTEN IS DATA RECORDED): Data is recorded on the Resins process data sheets on at
least a monthly basis. VOC emissions are recorded monthly in the Resins Area Emissions
Log.
REPORTING REQUIREMENTS
GENERALLY DESCRIBE WHAT IS REPORTED: VOC emissions from the Resins process are reported on a rolling
12-month average basis.
FREQUENCY: 1 1 MONTHLY ( X ► QUARTERLY ( ) ONCE EVERY 6 MONTHS
( ) ONCE PER YEAR ( ) OTHER (DESCRIBE):
DEQ-CFW 00087602
FILENAME: NAF-BI.DBF R-5 SECTION B
EMISSION SOURCE (GENERAL) B1
REVISED: 04115194
AIR QUALITY SECTION
SION SOURCE DESCRIPTION: Nafion Membrane Process
EMISSION SOURCE 10NO- NS-H
CONTROL DEVICE 10 NO(S): N/A
EMISSION POINT ID NO(S): NEp-HI , NEP-H2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: ,F,xtrusion, lamination, and chemical treatment of fluoropolymer resin
membrane.
OPERATION DATE: 1980
SfASONALVARIATION 1%) JAN-MAR:25 APR•JUN:25 JUL-SEP:25
to produce Nafion
OCT•DEC:25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Fluoropolymer (XR and CR) resin
1b
CONFIDENTIAL
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
UNITS
TYPE
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 Forms D3 -2 and E-4 .
MENTS:
3- L
DEQ-CFW 00087603
3-cos
DEQ-CFW 00087604
f
L
r
L
FILENAME: NAF-W-1.DBF R - 6 SECTION 0
- SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) D3-1
REVISED: 04115194
('see note in instructions concerning state au toxics regulations)
AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Nafion Membrane Process
EMISSION SOURCE ID NO.: NS-H IS THIS SOURCE A FUGITIVE SOURCE? ( 1 YES I X ) NO
ALTERNATIVE -OPERATING SCENARIO (ADS) NO: -M
EMISSION RATE IN EMISSION RATE IN
LBS►HR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
VOC
2
See Comment
3.75
32,850
6,720
Hydrogen Fluoride*
COMMENTS: Emissions include both point source and fugitive emissions. Potential hourly emissions vary
depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the Nafion Membrane process. Emissions are based on the
1534 emissions inventory. See the D6 Form and Addendum A for additional detail.
*Mote: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements.
DEQ-CFW 00087605
FWKN : NAP-D3-2.DBF x-6 SECTION D D3-2
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
MIRW J W15/94 AIR QUALITY SECTION
ONCE DESCRIPTION: Nafion Membrane Process
7 10 NO: NS-H ALTERNATIVE OPERATING SCENARIO IAOS► NO:
REGULATED APPLICABLE
POLLUTANT EMISSION AND OPERATING LIMITS REQUIREMENT
COMMENTS: There are no applicable requirements to the Nafion Membrane Process.
7
_ Ull
DEQ-CFW 00087606
FILENAME: 1VAF-D3-3.DBF R-4 SECTION D
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
REVISED: 04/15/94 AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: Nafion Membrane Process
EMISSION SOURCE ID NO: NS-H
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
DEQ-CFW 00087607
SECTION D -FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-H
Emission Unit Description: Nafion® Membrane Process
o� m 1 i r v KT, jA_ UIT_ 4 e 91 1
Actual VOC emissions from the Nafion(D membrane process in 1994 were 3.36 tons. Hours of
operation in 1994 were 1,791. Actual hourly VOC emissions from the process are estimated as
actual annual emissions divided by hours of operation or 3.36 tons * 2,000 f 1,791 which equals
3.75 lbs/hour. Potential annual emissions are estimated as 3.75 * 8,760 which equals 32,850 lbs.
Potential hourly emissions are not quantified because they depend upon several interrelated
parameters. HAPs which may be emitted from the NafionlD membrane process include trace
amounts of hydrogen fluoride.
B. Re lgu story Information•
There are no federally enforceable regulations that apply to this process.
40 Emissions of North Carolina toxic air pollutants (TAPs) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device Information•
There are no control devices associated with this process.
n_ _ Compliance Information:
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the Nafion® membrane process will continue to be tracked and
reported as part of the required annual emissions inventory.
gAprojecks\fayett\d6a11
3- L-P �
DEQ-CFW 00087608
FILENAME: N0NC01yF\1VAF-B7.DBF R-1 SECTION B B7
EMISSION SOURCE (COATINGIPAINTING)
REVISED: 05124194
AIR QUALITY SECTION
SSION SOURCE DESCRIPTION: Nafion Membrane Coating
EMISSION SOURCE ID NO: NS-I
CONTROL DEVICE ID NO(S):
EMISSION POINT ID NOIS1: lop -I
INDICATE WHETHER THIS SOURCE IS SUBJECT TO I I NSPS OR I ) NESHAP REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: Nafion membrane coating in booth equipped with internal fire retardant paint arrestor
pads.
OPERATING SCHEDULE (ACTUAL) OPERATION DATE: 1984
HRSIDAY: 24
DAYSIWK: 7
WKSIYR: 52
SEASONAL VARIATION (%)
JAN•MAR: 25
APR•JUN: 25
JUL•SEP: 25
OCT-DEC: 25
WHAT IS BEING COATED?
TYPE OF COATING OPERATION: Spray
CONTINUOUS COATING
TYPE FEED SYSTEM:
MAXIMUM NO. ITEMS COATEDIHOUR:
MAXIMUM SPEED (FTIMIN)
FOR BATCH OPERATION
MAX. NO. ITEMS COATEDIBATCH:
BATCH TIME AT MAX. (MINUTES):
NUMBER OF STATIONS OR BOOTHS: NUMBER OF SPRAY GUNS:
TRANSFER EFF:
CAPTURE EFF:
STATION
COATING(S) APPLIED AT THIS STATION (LIST ID)
NO.
BUNS
ACTUAL USAGE
MAXIMUM DESIGN CAPACITY
GALIHR
GALIYR
GALIHR
GALIYR
1
V0000
CONFID
CONFID
CONFID
CONFID
NO. OF BAKE OVENS: METHOD OF HEATING: ( I STEAM ( I DIRECT FIRED
( 1 ELECTRIC ( 1OTHER:
FUEL USED: TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAXIMUM ANNUAL FUEL USE:
MAXIMUM HOURLY FUEL USE:
ACTUAL ANNUAL FUEL USE:
ACTUAL HOURLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST POINTS:
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.
COMMENTS: Arrestor pads are replaced on an as needed basis (approximately once per month).
'Ip
DEQ-CFW 00087609
3' `1 \
DEQ-CFW 00087610
1
1
FILENAME: NAF-D1.DBF R-1 SECTION D
PRODUCT ANALYSIS WORKSHEET (VOC EMISSIONS) F1
REVISED: 05/24/94 AIR QUALITY SECTION ATTACH TO APPROPRIATE 'B'FORM
RODUCTNAME: Generic Coating
PRODUCT NO: Generic 1
COATING ID NO: V0000
MANUFACTURER: N/A
SUPPLIER: N/A
LIST EMISSION SOURCE ID AO(S) WHERE PRODUCT IS USED: Ns-1
DESCRIPTION OF USE. Nafion Coating operations
PRODUCT DENSITY (LBIGAU: 6 - 10
VOLATILE DENSITY 1N PRODUCT (LBIGAQ: 6 - 9.5
LB. VOC►GAL. SOLID APPLIED: SUPPLIED TO APPLICATOR:
SOLIDS
VOLATILES
% BY WEIGHT
> 0.5
<99.5
% BY VOLUME
> 0.5
<99.5
KG. VOC/LITER SOLID
APPLIED:
SUPPLIED TO APPLICATOR:
WATER
<99.5
<99.5
PRODUCTBREAKDOWNOf CONSTITUENTS /ATTACII MATERIAL SAfmDATA SHEETS/
VOC
CONSTITUENTS
CAS
NO.
OF VOLATILES
IN PRODUCT
OF VOLATILES
IN PRODUCT
REACTIVITY
(CIRCLE ONE)
Reactive VOC 1
N/A
N/A
<5
R
R2
R3
NR E
Reactive VOC 2
N/A
N/A
<8
R1
R
R3
NR E
Reactive VOC 3
N/A
N/A
<20
R1
R1
R2
R2
R
R3
NR E
NR E
other VOC
N/A
N/A
<OR=100
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
R1
R2
R3
NR E
TOTAL 100%
COMMENTS: This is a generic nonreactive VOC coating. All
peration are nonreactive.
TOTAL 100% R1 R2 R3 R1,R2,R3
TOTAL TOTAL TOTAL TOTAL
<5 <8 <20 <20
REACTIVE ( I NONREACTIVE ( (XX )
coatings used in the Nafion Membrance Coating
DEQ-CFW 00087611
FILENAME: NAF-D3-I.DBF R-8 SECTION D
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
('see note in instructions concerning state air toxics regulations)
WED. 04115194 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Nafion Membrane Coating
EMISSION SOURCE 40 NO.: NS-I IS THIS SOURCE A fUGITIVE SOURCE? t I YES ( X ) NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
2
28.4
14.2
52,000
26,000
PM
2
0.32
0.16
600
300
Methanol*
COMMENTS: Emissions include both point source and fugitive emissions. Emissions are based on the 1995
emissions inventory. See the D6 Form and Addendum A for additional detail.
ote: Emission of HAPs are not quantified because there are no federally enforceable applicable
quirements.
3- 93
DEQ-CFW 00087612
FILENAME: NAF-DI-2.DBF R-7 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04/15/94 AIR QUALITY SECTION
D3.2
III&ISSION SOURCE DESCRIPTION: Nafion Membrane Coating Process
EMISSION SOURCE ID NO: NS-I
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
PM
Emissions less than 1.05 lb/hr
15A NCAC 2D.0515
Opacity (PM)
Opacity less than 204-
15A NCAC 2D.0521
COMMENTS:
Or rig
DEQ-CFW 00087613
FILENAME•: 1gAF-D3-3.DBF R-5
SECTION D
D3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
Aj%kREVISED: 04/15/94
AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: Nafion Membrane Coating
EMISSION SOURCE ID NO: NS-I
REGULATED
POLLUTANT
ONGOING SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
QTY. EMITTED
BEFORE REDUCTION
(LBSNEAR)
QTY. EMITTED
AFTER REDUCTION
(LBSNEAR)
PLANNED SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
A11
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3''Ls
DEQ-CFW 00087614
.SECTION D -FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-I
Emission Unit Description: NafionS Membrane Coating Process
A. Emissions Estimation Approach:
Actual VOC emissions from the Nafion® membrane coating process in 1995 were 12.97 tons
(See Addendum A). Hours of operation in 1995 were 1,825. Future potential emissions are not
expected to be significantly different than actual historical emissions. Based on engineering
judgment worst -case potential annual emissions are estimated as twice actual 1995 emissions or
26 tons/year. Actual hourly VOC emissions from the Nafion(& Coating process are estimated as
actual annual emissions divided by hours of operation or 12.97 tons * 2,000 / 1,825 which equals
14.2 lbs/hour. Potential hourly emissions are estimated as 2 times actual emissions or 28.4 lb/hr.
HAPs which may be emitted from the Nafiong membrane process include methanol. This
process also has minor amounts of particulate matter emissions, associated with the solids in the
coatings. 1995 particulate emissions were 0.15 tons. Potential particulate emissions are
estimated as 0.15 tons. Thus, actual PM emissions are calculated as 300 / 1,825 or 0.169 lb/hr.
Potential emissions are estimated to be twice the actual emissions.
0 B. u4 latory Information:
•
Emissions of particulate matter from this process are regulated by 15A NCAC 2D.0515 -
Particulates from Miscellaneous Industrial Processes. This standard gives a PM emission
limit based on maximum product throughput. Allowable PM emissions are calculated by the
equation: E = 4.1 * P0,67 where E is the allowable emission rate in pounds per hour and P is the
maximum process throughput in tons/hr. For the membrane coating process, maximum
throughput is approximately 260 lb/hr (this includes the membrane and coating material) which
equals 0.13 tons. Thus allowable PM emissions are 1.05 lb/hr.
This emission unit is also subject to 15A NCAC 2D.0521- Control of Visible Emissions. This
standard limits opacity to 20% or less except that 6-minute periods of opacity less than 87% are
allowed once in any hour and four times in any 24-hour period.
Only non-photochemically reactive solvents are used in the coating process.
Emissions of North Carolina toxic air pollutants (TAPs) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
gAprojectsWayet6d6all 3 • I L�
DEQ-CFW 00087615
•
E
SECTION D - FORM D6 (continued)
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-I
Emission Unit Description: Nafion(& Membrane Coating Process
C. Control Device Information:
There are no control devices associated with this process. The coating spray booth is equipped
with a filter but the filter is an integral part of the spray booth and not considered a control device
(see NCAC 2Q.0102(b)(2)(D)).
D. Compliance Information:
Potential PM emissions are approximately 41 % of allowable emissions per 2D.0515, and
therefore, compliance is presumed. Emissions from the Nafion® membrane coating process will
continue to be tracked and reported as part of the required annual emissions inventory.
gAprojects\fayett\d6al l
3-7`)
DEQ-CFW 00087616
FILENAME:NAF—E4.DBF R-4 SECTION E
4 ` , t COMPLIANCE PLAN (METHOD OF COMPLIANCE)
E4
REVISED 04115194 AIR QUALITY SECTION
SIONSOURCE ID NO. NS—I
REGULATED POLLUTANT PM and Opacity
t
APPUCABLEREGULATION Z5A NCAC 2D.0515 & 15A NCAC 2D.0521
RNATIVE OPERATING SCENARIO (ADS) N0: N/A
MONITORING REQUIREMENTS
IS ENHANCED MONITORING APPLICABLE?
( ) YES (g ) NO
IS ENHANCED MONITORING PROTOCOL ATTACHED?
( ) YES (g ) NO
MONITORING DEVICE TYPE: Visual examination
for opacity.
MONITORING LOCATION: Near emission point.
OTHER MONITORING METHODS (DESCRIBE IN DETAIU: potential PM emissions are 410 of allowable emissions, and
compliance is presumed based on
compliance history of the source. Any malfunction or upset
will be reported pursuant to 15A
NCAC 2D.0535.
GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes, i minute instantaneous readings taken to produce an
hourly average): Opacity monitoring will
be performed if there are any indications of opacity
problems.
TEST METHODS
FERENCE TEST METHOD DESCRIPTION: N/A
REFERENCE TEST METHOD CITATION:
RECORDKEEPING REQUIREMENTS
DATA (PARAMETERI BEING RECORDED: Recordkeeping will be performed if there is a malfunction or upset
pursuant to 15A NCAC 2D.0535.
FREQUENCY OF RECORDKEEPING IHOW OFTEN IS DATA RECORDED):
As necessary, upon detection of a problem.
REPORTING REQUIREMENTS
GENERALLY DESCRIBE WHAT IS REPORTED: Any malfunction or upset will be reported pursuant to 15A NCAC
2D.0535.
EQUENCY: ( ! MONTHLY
( 1 QUARTERLY ( g 1 ONCE EVERY 6 MONTHS
( I ONCE PER YEAR
( ► OTHER (DESCRIBE):
DEQ-CFW 00087617
FILENAME: NA -Bj . DBF R - 6 SECTION B B 1
EMISSION SOURCE (GENERAL)
REVISED: 04115194
AIR QUALITY SECTION
AIMSSION SOURCE DESCRIPTION: Nafion Semiworks 1, 2, and 3
EMISSION SOURCE ID NO: NS-J
CONTROL DEVICE ID NO(S): N/A
EMISSION POINT ID NO(S): NEp-J2 , NEp-J2, NEp-J3
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: Laboratory and bench -scale production equipment used primarily for testing and R & D
purposes. Semiworks 3 also includes short-term plant scale testing.
OPERATIONDATE: See Below
SEASONAL YAMATIONF%l 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
Variable
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.
MENTS: Semiworks 1 and 2 were put into operation in 1993. Semiworks 3 is scheduled for operation
2996. Materials entering the process cannot be specifically defined because laboratory/testing
operations inherently use a wide variety of materials.
DEQ-CFW 00087618
r
•
0
N
(.-ON/ 0 N F I D E N T I A L
ERM—Southeast, Inc.
CHARLOTTE. NORTH CAROUNA
ERM
NAFION SEMIWORKS #1 AND #2
DUPONT - FAYETTEVILLE WORKS
DUART, NORTH CAROLINA
FIGURE
NS-J1/
-qo
DEQ-CFW 00087619
3-li
DEQ-CFW 00087620
FILENAME: NAF-D3-I.DBF R-7 SECTION 0
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
QEVISED: 04115/94
4
('see note in instructions concerning state air toxks regulations)
AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Nafi on Semiworks 1, 2, and 3
EMISSION SOURCE ID NO.: NS-J IS THIS SOURCE A FUGITIVE SOURCE? ( I YES ( X ) NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
2
See Comment
See Comment
88,000
9,280
Wide variety of H"s*
COMMENTS: Actual annual emissions are based on 1994 operation, but do not include Semiworks 3 which is
not yet operational. Actual and potential hourly emissions are not quantified because of the
"laboratory" nature of the Semiworks operations. See the D6 Form and Addendum A for additional
etail.
*Note: Due to the nature of the Semiworks operations, a wide variety of HAPs can be used in
relatively small amounts. Emission of HAPs are not quantified because there are no federally
enforceable applicable requirements.
DEQ-CFW 00087621
FILENAME: NAF-D3-2.DBF R-7 SECTION D
a SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
D3.2
REVISED: 04115►94 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: Nafion Semiworks 1, 2, and 3
ION SOURCE ID NO: NS-J
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
COMMENTS: There are no federally enforceable applicable requirements associated with the Semiworks
operations.
-M3
DEQ-CFW 00087622
.a
FILENAME: NAF-D3 -3 . DBF R-10 SECTION D
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
EVISED: 04/15/94 AIR QUALITY SECTION
ME MISSION SOURCE DESCRIPTION: Nafion Semiworks
EMISSION SOURCE ID NO: NS-J
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3-IN
DEQ-CFW 00087623