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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. gAprojectAfayetAd6al l �-gyp 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 r' 6 n �o 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