DEQ-CFW_00087793

le: Dupont
Subject: Re: Dupont
Date: Wed, 19 May 2004 09:26:10 -0400
From: Tom McKinney [e-mail]>
To: "Mike.Benson" <[e-mail]>
For permit T25 it says item C. is Nafion Process Area consisting of .. So in C. I woul
add the Miscellaneous Organic NESHAP and under that put the scrubber requirements for
Nafion. They need to use those scrubbers to comply with the NESHAP. I would also list
the Nafion scrubber requirements AGAIN under section 2.2 for the facility -wide toxics
limits of 2D .1100. (They need to use those scrubbers to meet BOTH the PSD avoidance AN
the facility -wide toxics limits.)
For Butacite of item B. I would put the scrubber requirements from section 2.3.
Otherwise, the things under item B. can remain unchanged.
"Mike.Benson" wrote:
> hi Tom,
> In looking at the permit for the Nafion process it has PSD avoidance
> for NS-B and NS-G only. Whereas the current Sec 2.3 requirement is
> for NS-A through F. I am thinking to put it under odors like the
> others,
> or create a separate subsection for scrubber requirements.
> Which would you prefer, or neither?
> Also on the Butacite line, this is Section B, the only NESHAP is for
> BS-D.
> Do you think I should reference 2D .1100 for the other sourcessincethe
> 2D .1100
> is facility -wide? I guess I would include that question for other
> listed sources not
> covered by the NESHAPS.
> Thanks,
> Mike
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Of 1 5/20/2004 7:23 AM
DEQ-CFW 00087793