DEQ-CFW_00087628

k __ ,
• SECTION D -FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-J1, J2, and J3
Emission Unit Description: Nafion® Semiworks 1, 2, and 3
A. Emissions Estimation Approach:
Potential emissions from Semiworks 1, 2, and 3 are estimated as a total of 88,000 pounds per
year based on potential emissions of 15.0 tpy VOC for the Semiworks 1 and 2, and 29.0 tpy
VOC for the Semiworks 3. Actual annual emissions are based on 1994 operations (which do not
include Semiworks 3), and are estimated as 4.64 tons per year (See Addendum A). Because of
the laboratory and testing nature of the Semiworks operations, a wide variety of the HAPs can
potentially be emitted from these processes, and it is not possible to quantify actual or potential
hourly emissions.
B. Regulatory Information:
There are no federally enforceable regulations that apply to the Nafion Semiworks 1, 2, and 3.
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 the Semiworks operations.
D Compliance Information:
As stated above, there are no specific federal requirements applicable to this emission unit.
However, emissions from the Nafion® Semiworks will continue to be tracked and reported as
part of the required annual emissions inventory.
gAprojectMayetAd6a 1
3 A5
DEQ-CFW 00087628

FILENAME: NONCONF\NAF-B1.DBF R-9
nmimp. rwiguQd
SECTION B
EMISSION SOURCE (GENERAL)
AIR QUALITY SECTION
F1
SION SOURCE DESCRIPTION: E-2 Process
EMISSION SOURCE ID N0: NS-K
CONTROL DEVICE ID NO(S):
CONTROL
EMISSION POINT ID NO(S): NEP-Ki thru K21
WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: Production of E-2 solvent by reaction of acid fluoride with potassium hydroxide (KOH) .
(Includes associated reaction 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)
UNITS
TYPE
TERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
UNITS
TYPE
Potassium Hydroxide (KOH) Soln.
lb
CONFIDENTIAL
HFPO Dimer
lb
CONFIDENTIAL
HFPO Trimer
1b
CONFIDENTIAL
HFPO Tetramer
lb
CONFIDENTIAL
MAXIMUM DESIGN CAPACITY (BATCHESIYR): 973
MAXIMUM DESIGN CAPACITY (BATCHESIHR): 9 hours/batch
FUEL USED: NIA
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR): NIA
MAX. CAPACITY HOURLY FUEL USE: NIA
MAX. CAPACITY YEARLY FUEL USE: NIA
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS: Nuclear level device; pressure transmitter; thermocouple;
jacketed vessel for heating and cooling; rupture disk and relief valve.
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. No state of federally enforceable limits are triggered by
this source.
MENTS:
-�L
DEQ-CFW 00087629

•
0
luo—J7.UAb I L- I L-11D I= 1 KHK/JU
CONRDENTIAL
maERM—Southeast, Inc. E-2 PROCESS FIGURE
CHARLOTTE, NORTH CAROUNA DUPONT — FAYETTEVILLE WORKS NS—K
ERM DUART, NORTH CAROLINA

FILENAME: NAF-D3-I.DBF R-4 SECTION D
D3-1
- I SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
0 (`see note in instructions concerning state air toxics regulations)
RLVLCFn• nanF/4d AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: E-2 Process
EMISSION SOURCE ID NO.: NS-K IS THIS SOURCE A FUGITIVE SOURCE? ( I YES ( X ) NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
LBSIHR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
2
1.140
1.007
10,021
8,847
F--
COMMENTS: voc emissions are taken directly from the E-2 process permit application (submitted in
1995). Emissions include both fugitive and point source emissions. See the D6 Form and Addendum A
for more detail.
.3 - be
DEQ-CFW 00087631

FILENAME: 1VAF-D3-2.DBF R-4 SECTION D D3 2
_ SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
,ggEVISED: 04115194 AIR QUALITY SECTION
ISSION SOURCE DESCRIPTION: E- 2 PROCESS
EMISSION SOURCE ID NO: NS-K ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED APPLICABLE
POLLUTANT EMISSION AND OPERATING LIMITS REQUIREMENT
COMMENTS: There are no federally enforceable applicable requirements associated with the E2 Process.
1
DEQ-CFW 00087632

FILENAME: NAF-D3-3.DBF R-11 SECTION D D3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
EVISED: 04/15/94 AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: E-2 Process
EMISSION SOURCE ID NO: NS-K E i
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-
DEQ-CFW 00087633

SECTION D - FORM D6
10 ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-K
Emission Unit Description: E2 Process
A Emissions Estimation Appr� oath:
Actual and potential emissions from the E2 process are defined by the E2 permit application that
was submitted November 1995. Emission calculations from this application are attached in
Addendum A. As part of the application, potential VOC emissions (both point source and
fugitive) were defined as 5 tons per year. Actual emissions are estimated as 4.4 tons VOC.
Potential hourly emissions are not quantified because they depend upon several interrelated
parameters
B. Regulatory Information:
There are no federally enforceable regulations that apply to the E2 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:
There are no control devices associated with the E2 process.
D. Compliance Information:
As stated above, there are no specific federal requirements applicable to this emission unit.
However, emissions from the E2 process will continue to be tracked and reported as part of the
required annual emissions inventory.
gAprojects\fayett\d6a11 3-' ,
DEQ-CFW 00087634

FILENAME: NAF-B1.DBF R-16 SECTION 6
EMISSION SOURCE (GENERAL) [BI]
REVISED: 04/15/94 AIR QUALITY SECTION
SSION SOURCE DESCRIPTION: Nafion Refrigerant System
EMISSION SOURCE ID NO: NS-RefFug
ROL DEVICE ID NO(S): N/A
EMISSION POINT ID NO(S): Fugi tive
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: The Nafion refrigerent system is used throughout the Nafion area processes. The
refrigerent used is methylene chloride. The system is closed loop; however, because of fugitive
emissions it is periodically necessary to add methylene chloride to the system.
OPERATION DATE:
SEASONAL VARIATION fV 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
Not Applicable
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.
4MENTS:
DEQ-CFW 00087635

FILENAME: NAF-D3-l.DBF R-12 SECTION D
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION) D3-1
('see note in instructions concerning state air toxics regulations)
OISED: 04115194 AIR QUALITY SECTION
4
EMISSION SOURCE DESCRIPTION: Nafion Refrigerant System
EMISSION SOURCE ID NO.: NS-RefFug IS THIS SOURCE A FUGITIVE SOURCE? I X ) YES ( 1 NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
Methylene Chloride
See Below
See Below
38,409
18,867
COMMENTS: Actual emissions are based on 1995 operation. Potential emissions are defined by the
facility -wide air toxics emission limit for methylene chloride.
J G
DEQ-CFW 00087636

FILENAME: NAF-D3-2.DBF R-12 SECTION D D3 2
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04►15194 AIR QUALITY SECTION
SINSOURCE DESCRIPTION: Nafion Refrigerant System
OISSION
SOURCE ID N0: NS-RefFug
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
Methylene Chloride
COMMENTS: There are no federally enforceable applicable requirements associated with the Nafion
refrigerant system, although facility -wide emissions of methylene chloride are limited to 38,409
pounds per year as a result of air toxics modeling (See Section 5 of the application).
3-G q
DEQ-CFW 00087637

FILENAME: NAF-D3-3.DBF R-12 SECTION D D3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
REVISED: 04/15/94 AIR QUALITY SECTION
MiSS10N SOURCE DESCRIPTION: Nafion Refrigerant System
EMISSION SOURCE ID NO: NS-RefFug 0 1
REGULATED ONGOING SOURCE QTY. EMITTED CITY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
A11
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3-q6
DEQ-CFW 00087638

•
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-RefFug
Emission Unit Description: Nafion® Refrigeration System Fugitive Emissions
A. Emissions Estimation Approach:
Actual fugitive methylene chloride emissions from the Nafion® refrigeration system in 1995
were 9.4 tons. Note that methylene chloride is a HAP, but is not considered a VOC because it
has negligible photochemical reactivity (see NCAC 2D .0901 #28). Hours of operation in 1995
were 8,760. Actual hourly emissions from the process are estimated as actual annual emissions
divided by hours of operation or 9.4 tons * 2,000 / 8,760 which equals 2.14 lbs/hour. Potential
hourly emissions are not quantified because they depend upon several interrelated parameters.
Potential annual emissions from this process are defined by the facility -wide air toxics modeling
limit of 38,409 pounds per year.
B. Regulatory Information•
There are no federally enforceable regulations that apply to this 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:
There are no control devices associated with this process.
D. Compliance Information:
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the Nafion® refrigerant system will continue to be tracked and
reported as part of the required annual emissions inventory.
gAprojects\fayett\d6al l
3- 9 (-,
DEQ-CFW 00087639

FILENAME: NAF-C7.DBF R-3 SECTION C
CONTROL DEVICE (GASEOUS ABSORBER)
H
REVISED: 04/15/94 AIR QUALITY SECTION
NTROL DEVICE ID NO: NCD-Hdrl/Hdr2
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): NS-A thru F
SSION POINT ID NO(S): NEP-Hdrl/Hdr2
tMAN
POSITION IN SERIES OF CONTROLS
NO. 1 OF 1 UNITS
UFACTURER: SGL Industries MODELNO: DuPont Engineering Desing
ERNATIVE OPERATING SCENARIO (AOS) NO:
DESCRIBE CONTROL SYSTEM: Both NCD-Hdrl and NCD-Hdr2 are 2.2 square foot cross section baffle plate
towers 20 feet high with counter -current contact of vent gases with caustic solution.
POLLUTANT(S) COLLECTED:
HF
VOC
CORRESPONDING EFFICIENCY:
99.6 %
Note 1 ova
EFFICIENCY DETERMINATION CODE:
3,1
BEFORE CONTROL EMISSION CONTROL RATE(LB/HR):
<562
AFTER CONTROL EMISSION RATE (LB/HR):
<2.25
PRESSURE DROP (IN. H2O) MIN. 0 MAX 8 WARNING ALARM? YES Xg NO
INLET TEMPERATURE (F) MIN. Amb. MAX OUTLET TEMPERATURE (F) MIN. 40 MAX 50
INLET AIR FLOW RATE (ACFM): l0o
TOTAL GAS PRESSURE (PSIG): 0.5 GAS DEW POINT (F): N/A GAS VELOCITY (FT/SEC): 1.75
OF SYSTEM:ED
kPE
COLUMN
TYPE OF PACKING:
COLUMN LENGTH (FT):
COLUMN DIAMETER (FT):
E COLUMN
PLATE SPACING (IN): 9
COLUMN LENGTH (FT): 25
COLUMN DIAMETER (FT): 1. 67
ADDITIVE LIQUID SCRUBBING MEDIUM:: Caustic
PERCENT RECIRCULATED: 100
TOTAL LIQUID INJECTION RATE (GAUMIN): 72
MAKE UP RATE (GAUMIN): FOR ADDITIVE (GAUMIN):
DESCRIBE MAINTENANCE PROCEDURES: Periodic instrument calibration.
DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC.: Monitor column pressures and effluent liquid pH.
SHOW BY DIAGRAM THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S): See process diagram.
Note 1: The purpose of the waste gas scrubbers is to control emissions of acid fluorides (which
vert to HF after being emitted). An incidental benefit is the reduction of VOC emissions. On the
11-
rage, overall reduction of VOC emissions is estimated as 85%.
Note 2: After control, HF emissions have been set to the allowable level of 2.25 pounds or less.
Given the 99.6* measured control efficiency this corresponds to before control emissions of <562
lbs/hr.
L7
DEQ-CFW 00087640

W
1
CA
0
r'
6
n
�o
0
0
co
14
%o0+xua.uwt; 1 Z-1 o—aa AM 1 -1 TIWK
NCD—Hdr1
BARRICADE EVACUATION AIR
CAUSTIC
NCD—Hdr1
BARRICADE EVACUATION AIR
WASTE
NCD— I -Id r 1 WASTE
SCRUBBER 1 NCD — H d r2 SCRUBS R 2
TO WASTEWATER
TREATMENT
NOTE: PRESENTLY HFPO IS THE ONLY PROCESS THAT IS HARD —PIPED TO BOTH OF THE WASTE GAS SCRUBBERS
ALTHOUGH FUTURE PLANS ARE FOR THE WASTE GAS SCRUBBER HEADERS TO BE INTERCONNECTED.
HFPO
(NS-A)
NO 1 RSU LIQUID WASTE MMF
VINYL (NS-D) STABILIZATION (NS-F)
ETHERS (NS-E)
(NS-B)
NO. 2
VINYL ETHERS .
(NS-C)
CAUSTIC
TO WASTEWATER
TREATMENT
ERM—Southeast, Inc. WASTE GAS SCRUBBER SYSTEM FIGURE
I w CHARLOTTE, NORTH CAROUNA NAFION®
NS—
ERM DUART, NORTH CAROLINA HEADER

FILENAME:g, \forms \dup-faye \naf rl SECTION E
TITLE V INSIGNIFICANT ACTIVITIES SUMMARY
rE2]
Ad
REVISED: 04115194 AIR QUALITY SECTION
INSIGNIFICANT ACTIVITIES PER TITLE 15A NCAC 2Q.0507(b)
DESCRIPTION OF EMISSION SOURCE
UNITS
BASIS FOR EXEMPTION
(REF 15A NCAC 20.0507(b))
1-No. 1 Vinyl Ethers Reactor Purge System
tons
15A NCAC 2Q.0102(b)(2)(E)(i)
t No. 2 Vinyl Ethers Reactor Purge System
tons
15A NCAC 2Q.0102(b)(2)(E)(i)
3.MMF Sodium Methoxide Charge System
tons
15A NCAC 2Q. 0102 (b) (2) (E) (i)
4.
5.
7.
8.
REQUEST FOR INSIGNIFICANT ACTIVITIES PER
TITLE 15A NCAC 210508(aa)
DESCRIPTION OF EMISSION SOURCE
UNITS
BASIS FOR EXEMPTION
(SEE INSTRUCTIONS)
1.
2.
,3-'t�
DEQ-CFW 00087642

11/04/96 13:26 NAFION CUSTOMER SERVICE LAB. 002
DuPont Automotive
P,D. Drawer t
Fayetteville, NC 2W2
DuPont Automotive
August 31, 1995
Ms. Cynthia A. Savoy
NC DEHNR - Division of Environmental Management
Fayetteville Regional Office . Air Quality Section
Wachovia Bldg, - Suite 714
Fayetteville, NC 28301
RE: Air Permit No. 3735RIS
MMF Process - Sodium Methoxide Conveyance
Insignificant Activity Determination
Dear Ms. Savoy:
This letter is a request for the following process change to be determined as an insignificant
activity, and therefore exempted ttom permitting requirements finder 2Q.0102.
Currently the'M.MF process charges sodium methoxide (NaOCH3) by carrying four 50-lb
bags of the NaOCH3 to a second floor charge hopper, and manually dumping the material
into the hopper for subsequent use in the process.
The requested change would pneumatically convey the NaOCH3 via a Dense -Phase Nitrogen
Conveyance System from the ground floor directly to the MTP Reactor. The displaced
nitrogen will be exhausted through a bag-Sler to the atmosphere.
Without the control device (bag -filter), total potential emissions of TSP and PMto would be
469 lb/year NaOCH3. With the bag -filter, total potential emissions of TSP and PMto would
be less than 2 lb/year NaOCH3. See attached engineering calculations.
Therefore, this proposed process change should be exempted from permitting requirements
by 2Q.0102(b)(2)(E)(i).
If you have any questions regarding this request, please me at [phone],
cc: Mr. Richard Lasater, NC DE-HNR DEM, Raleigh
Michael E. Johnson
Environmental Coordinator
E. I. du Pam do Nunmw s and COMPeny 3 - \0 D
® Prwnd an Re-Wod P400f
Cc 4991 nuu KAI
DEQ-CFW 00087643

11/{�4/7b 115: dY NHr 1 UN UUb I UMt--K StKV 1 UL LH". 0015
is
^ A
/ C �fi �S >� Sl eiy,s
Air Permit No. 373SR15
N" Process - Sodium Methoxide Conveyance
Insignificant Activity Determination
AIR EMISSION DETERMINATION
Potential Emissions (TSP/PMlo) of N40CH3 without Air Pollution Control Device:
Maximum NaOCH3 usage: 93,8301b/yr
Per vendor information: 0.005 lb NaOCH3 in vapor space per lb of conveyed NaOCH3
Potential Emissions without Air Pollution Control Device:
(Q 005 Ib NaOCH3 ettaissions (9 30 lb Na0 1
lb NaOCHI conveyed j t yr
469 lb/yr NaOC143 emissions
Potential Emissions (TSP/PMW of NaOCH3 with Air Pollution Control Device:
Per vendor information., Bag-1~iltor efficiency for particles above 3 µm is 99.75%
Per NaOCH3 supplier: Average particle size = 70 µm and powder is "dust free".
Assume amount of NaOCH3 which is < 3 µm is negligible,
Potential Emissions with Air Pollution Control Device:
_ (469 lb/yr NaOCH) emissions) (1- 0.9975)
= 1.17 lb/yr NaOCH3 emissions
3-\O\
DEQ-CFW 00087644