DEQ-CFW_00087794

Inspection by THM on 09/30/02
1) Plant Location:
Dupont Company - Fayetteville Works (09/00009) is located on NC highway 87 in Bladen
County, North Carolina. From Fayetteville, take highway 87 south. The facility is
approximately 18 miles from FRO on the left side of Highway 87 near the Cumberland/Bladen
County line.
2a) Plant Description:
Dupont Company - Fayetteville Works is a chemical manufacturing facility located in Bladen
County. The facility has a Butacite manufacturing operation that includes a polyvinyl butyral
sheeting rotogravure printing operation. The printing operation is subject to MACT Subpart KK
requirements and controlled by a permanent total enclosure for the printing operation room
exhaust and a multi -stage horizontal spray scrubber to control emissions of dimethylformamide
(DMF)•
The Nafion operation produces a variety of relatively uncommon monomer and polymer
chemicals. Some of the monomers are shipped offsite, while others are used onsite in the
production of various polymers. The polymers are shipped offsite or used onsite to produce
membrane material. The two waste gas scrubbers located at Nafion are used to control the
emissions of various pollutants including hydrogen fluoride and acid fluorides.
The facility also has a fluoroproducts polymer manufacturing development facility, a semiworks
area, and a wastewater treatment system. There are two No. 6 fuel oil -fired boilers (139.4 and
88.4 million Btu per hour maximum heat input).
The new ammonium perfluorooctanoate (APFO) process has been under construction and is
nearing completion. The APFO reaction process will involve perfluorooctanoate (brought in by
truck in its iodide/salt form) reacted with sodium hydroxide (stored in totes) to form the acid
fluoride. The acid fluoride will then be reacted with ammonia to produce the ammonium salt.
Fuming sulfuric acid (oleum) will be received by truck and used as a solvent in the process.
The facility currently operates under air permit no. 03735R22, with an expiration date of
November 30, 2003. The facility authorized contact is Barry L. Hudson, Plant Manager.
2b) Current Permitted Sources:
UTH=s
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Ia. one No. 6 fuel oil -fired boiler (139.4 mmBtu per hour heat input, ID No. PS-1),
lb. one No. 2/No. 6 fuel oil -fired boiler (88.4 mmBtu per hour heat input, ID No. PS-2),
BUTAcrrE PROCESS AREA
2 one brine -cooled condenser (ID No. BCD -A), installed on a butyraldehyde storage tank
(ID No. BS-A),
3. one polyvinyl butyral flake reactor line (ID No. BS-B) consisting of eight flake reactors,
each with a process condenser, as follows:
a. one packed bed column scrubber with mist eliminator (8 gallon per minute water
injection rate; ID No. BCD-B1) installed on four polyvinyl butyral flake reactors,
b. one packed bed column scrubber with mist eliminator (8 gallon per minute water
injection rate; ID No. BCD-B2) installed on four polyvinyl butyral flake reactors,
NESHAP:
4. one multi -stage horizontal spray scrubber (12,500 cubic feet per minute with air assisted
water spray; ID No. BCD -DI) installed on a polyvinyl butyral sheeting rotogravure printing
operation (ID No. BS-D) consisting of the following:
a. a total enclosure for the rotogravure printing operation room exhaust,
b. local hood exhausts,
c. press hood exhausts, and
d. one dryer (tint oven) exhaust.
5. two -two stage steam ejector vacuum systems, each with after stage surface condensers,
installed one each on the Butacite extruders (ID Nos. INSIG-B8),
6. one fabric filter (6,858 square feet of filter area, ID No. BCD-Cl) installed on the vent of
the product recovery cyclone on the flake dryer (ID No. BS-C),
NAnoN PROCESS AREA
7. one perfluorinated resin membrane treatment process (Nafion process, ID No. NS-H)
vented to the atmosphere, Nafion Vent #3,
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8. two baffle plate -type tower waste gas scrubbers ,Vent #1 and #7, (each 72 gallons per
minute liquid injection rate; ID Nos. NCD-Hdrl and NCD-Hdr2) installed on the
perfluorinated chemical manufacturing processes (ID Nos. NS-A through NS-F),
[One or both scrubbers may be used to control emissions.]
9. one venturi vacuum jet installed on the MUCR resin process, Nafion Vent #2, (ID No.
NS-G).
[Both processes (XR and CR) use the same equipment, but not simultaneously.]
10. one membrane coating process (ID No. NS-i) conducted in a filter -type spray booth
utilizing non-photochemically reactive or exempt solvents,
11. one E-Fluids production process (ID No. NS-K) vented to the atmosphere,
SEW WORM
12. one polymerization operation exhaust (SW-1),
13. one laboratory hood (SW-2), and
14. the Nafion semiworks 3 (ID No. NS-J3) facility consisting of.
laboratory and bench
scale production
equipment, or idle
process equipment.
FtuoROPRODum PRouss AREA
15. one Fluoroproducts Polymer Manufacturing Development Facility (ID No. FS-A)
consisting of :
a. one (1) venturi scrubber (ID No. FCD-Al) installed on the upstream of the vent
blower venting to the stack (ID No. FEP-A1), and
b. one (1) fabric filter (130 square feet of filter area, ID No. FCD-A2) installed on the
downstream of the vent blower venting to the atmosphere (ID No. FEP-A2),
APFO PRocEss AREA
16. one APFO manufacturing facility (ID No. AS -A) consisting of the following:
a. one (1) gaseous wet scrubber (ID No. ACD-A1) installed on the upstream of the vent
blower venting to the process stack (ID No. AEP-Al), and
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b. one (1) condenser (ID No. ACD-A2) installed on the downstream vent of the
foreshots receiver and venting to the gaseous wet scrubber (ID No. FEP-A2),
WASTEWATER TREATMENT AREA
17. one impingement type wet scrubber with mist eliminator (70 gallons per minute total
dilute potassium hydroxide injection rate, ID No. W7CD-3) installed on two indirect
steam -heated, rotary wastewater treatment sludge dryers (399 pounds per hour maximum
permitted drying capacity each, ID Nos. WT-I and WT-2),
Current Specific Permit Stipulations and Limitations:
A.1. Listing of applicable requirements.
A.2. Limit on particulates from the boilers per 2D .0503.
A:3. Limit on particulates per 2D .0515.
AA Limit on sulfur dioxide emissions per 2D .0516.
A.S. Misc. VOC emissions per 2D .0518.
A.6. Visible emissions less than 20 % opacity.
A.7. Visible emissions less than 40 % opacity.
A.B. Control and prohibition of odorous emissions.
A.9. Toxic air pollutant limits per 2D .1100.
A.10. MACT Subpart KK (Part 63 NESHAP) requirements for Butacite.
A.11 PSD avoidance for VOCs from the modified Nafion vinyl ether process.
A.12 PSD avoidance for VOCs from the XR/CR resins process.
A.13 PSD avoidance for VOCs from the fluoroproducts process.
A.14. PSD avoidance for boiler PS-2.
A.15. PSD avoidance for boiler PS -TEMP.
A.16. NSPS for boiler PS -TEMP.
A.17. Bagfilter I&M and record keeping requirements.
A.18. Condenser i&M and record keeping requirements.
A.19. Scrubber i&M and record keeping requirements.
A.20. Requirements for accident release prevention.
A.21. Requirement to update Title V application per 2Q .0507.
A.22. Excess emissions reporting and malfunctions.
3) Pre -Inspection Conference:
On September 30, 2002, Tom McKinney and Sally McKinney of DAQ met with Mr. Joe Blake
EHS Supt., at Dupont - Fayetteville Works.
a) The facility has been submitting the required permit reports in a timely
manner.
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b) The new ammonium perfluorooctanoate (APFO) process has been under
construction and is nearing completion.
4) Nafion Process Area:
The Nafion operation produces a variety of relatively uncommon monomer and polymers
chemicals. Some of the monomers are shipped offsite, while others are used onsite in the
production of various polymers. The polymers are shipped offsite or used onsite to produce
membrane material. A principal use of the membrane is in the production of chlorine and
sodium hydroxide at chlor-alkali plants throughout the world. The Nafion products are not
common materials and tend to have a very high economic value. The primary concern for air
emissions from Nafion are hydrogen fluoride and the various acid fluorides.
The facility has two baffle plate -type tower scrubbers (ID Nos. NCD-Hdr-1 and NCD-Hdr-2) for
controlling emissions from the Nafion chemical processes. The facility has submitted parameters
for monitoring to ensure a 99.6 percent control efficiency for the waste gas scrubbers. They are
the injection liquid flow rate (minimum of 16,500 kilograms per hour, averaged over a three-hour
period) and the pH of the recirculated scrubbing solution (minimum pH of 11.0 SU, averaged
over a three-hour period). The software system allows for these measured values to be saved and
displayed. Random dates during the past 6 months were chosen for viewing the monitoring data
for liquid flow rate and pH of the scrubbing solution. The scrubbers appear to be in compliance
with the permit requirements.
5) Butacite Process Area:
The polyvinyl butyral sheeting rotogravure printing operation is subject to MACT Subpart KK -
Printing and Publishing for emissions of dimethylformamide (DMF). The DMF emissions are
controlled using a permanent total enclosure (testing was conducted per EPA Method 24) for the
process area and a multi -stage horizontal spray scrubber (ID No. BCD -DI).
The following monitoring requirements apply (based on Method 18 source testing):
i. Water flow rate to each nozzle (minimum of 6 gallons per minute,
averaged over a three-hour period).
ii. Air flow rate to each nozzle (minimum of 58 standard cubic feet per
minute, averaged over a three-hour period).
iii. General area exhaust fan exit velocity (minimum of 3,950 feet per minute,
averaged over a three-hour period).
A software system is used by facility personnel to monitor and record the performance of the
DMF scrubber. There are alarm settings for each of the monitoring parameters.
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• The facility maintains a copy of the start-up, shutdown, and malfunction (SSM) plan. The
Butacite process and the DMF scrubber are interlocked to prevent operating without the scrubber.
This change was made last year to prevent an occurrence like the event on January 6, 2000,
when they started up the Butacite operation without the scrubber operating.
The facility has been submitting in a timely manner the Subpart KK semi-annual summary report
as specified in 40 CFR Part 63.830, by January 30th and by July 30th of each calendar year.
These reports have also included reporting for actions taken when the start-up, shutdown, or
malfunction are not completely consistent with the procedures specified in the SSM plan.
Subpart KK does not require separate SSM reports if the information is included in the semi-
annual summary report. The inspection and maintenance program for the scrubber includes an
annual internal inspection. They inspect more frequently if the monitor alarms indicate problems
with the unit. The scrubber uses demineralized water to help keep the scrubber nozzles clean.
6) Utility Boilers:
The facility is permitted to operate one No. 6 fuel oil -fired boiler (139.4 million Btu per hour
maximum heat input, ID Nos. PS-1) and one No. 2/No. 6 fuel oil -fired boiler (88.4 million Btu
per hour maximum heat input, ID Nos. PS-2). These two boilers share the same stack. The
larger boiler has a steam capacity of 113,000 pounds of steam per hour and was manufactured in
1969. The smaller boiler was manufactured in 1982 with a steam capacity of 72,000 pounds per
hour. The boilers were observed to be in compliance with 2D .0521. Note that the temporary
boiler (from April 2002) is no longer at the site.
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7) APFO Process:
The new ammonium perfluorooctanoate (APFO) process has been under construction and
is nearing completion. The APFO reaction process will involve perfluorooctanoate
(brought in by truck in its iodide/salt form) reacted with sodium hydroxide (stored in
totes) to form the acid fluoride. The acid fluoride will then be reacted with ammonia to
produce the ammonium salt. Fuming sulfuric acid (oleum) will be received by truck and
used as a solvent in the process. The primary purpose of the scrubber in APFO will be
the process emissions from oleum and for emergency releases of oleum. The scrubbing
liquid will be water or an alkaline solution. The condenser will be installed on the
foreshots receiver. Any emissions from the condenser will be routed to the scrubber.
The APFO process will be subject to the 112(r) chemical accident prevention program for
oleum. Note that ammonium perfluorooctanoate is. not a listed NC toxic air pollutant and
not an EPA hazardous air pollutant.
8) Chemical Accident Prevention and 112(r):
The 112(r) chemical accident prevention program was discussed only briefly during this
inspection. The Nafion process is subject to 112(r) for sulfur trioxide, tetrafluoroethylene, and
hydrogen chloride. The facility submitted the RMP to the U.S. EPA in June 1999. The new
APFO process will be subject to 112r for oleum.
9) Compliance Statement:
The facility appeared to be in compliance with all applicable air quality requirements at the time
of the inspection.
DEQ-CFW 00087800