DEQ-CFW_00087807

Mr 4
Sept.11, 2003
MEMORANDUM:
TO: Mike Benson, DAQ, Raleigh Central Office
FROM: Tom McKinney, DAQ, Fayetteville Regional Office
SUBJECT: Regional Comments on Draft Initial Title V Permit
Dupont Fayetteville Works
Bladen County, (0900009)
Current Permit: 03735R22
Regional Comments on Draft Initial Title V Permit:
Page 3: Currently boiler PS-1 is only permitted to fired No. 6 fuel oil. However, there is no
problem with adding No. 2 fuel oil as requested by Dupont.
Page 10: For section 2.1(B)(2)(a), I agree that BS-A, BS-B1, BS-B2, and BS-D are not a concern
for visible emissions monitoring.
Page 10: For source BS-C, Mike Johnson said that DAQ has not observed visible emissions
from this bagfilter. That is true. However, I assume that the concern is the possibility of a
problem with a bag. I am comfortable with whatever is consistent with other Title V permits
Page 13: For section 2. 1 (C)(2)(a), I agree that these sources are not a concern for visible
emissions monitoring.
Page 14: For section 2. 1 (C)(4)(b), Mike Johnson's suggested changes for monitoring and
recordkeeping are appropriate.
Page 14: For section 2. 1 (C)(5)(b), Mike Johnson's suggested changes for monitoring and
recordkeeping are appropriate.
Page 18: For section 2. 1 (D)(4)(b), Mike Johnson's suggested changes for monitoring and
recordkeeping are appropriate.
Page 18: For APFO section 2.1(E), this is a new process and I do not have any compliance
experience with it. Monthly visible emissions monitoring seem reasonable.
Page 19: For wastewater treatment area scrubber in section 2.1(F), I agree that this is not a
DEQ-CFW 00087807

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� Dupont Fayetteville Works
Sept. 11, 2003
concern for visible emissions monitoring.
Page 20: For section 2.2 list of toxic air pollutant limits there are many errors in this table. The
errors should be corrected and reviewed carefully before sending to public notice.
Page 26: 1 do not have a problem with Mike Johnson's request for changes to the 2D .0958
recordkeeping requirements.
Page 26: For section 2.3 Other Requirements, these control device requirements should be
moved to (or refer to) the applicable regulatory and source location in the permit. They should
t be isolated in section 2.3. Each of these control devices is addressed below.
Page 26: For the condenser BCD -A, these requirements should be moved to (or refer to) the 2D
.1806 requirement in section 2.1(B)(3). Note sure about Mike Johnson's request to delete the
inspection, maintenance, monitoring, and recordkeeping requirements. Odor is a concern for this
ounce. Should be consistent with condenser requirements for odorous sources in other Title V
permits.
Page 26: For the scrubbers BCD-B 1 and BCD-B2, these requirements should be moved to (or
refer to) the 2D .1806 requirement in section 2.1(B)(3).
All, Page 27: For the Butacite scrubber BCD -DI, these requirements should be in the MACT
`` requirements in section 2.1(B)(4).
4x1ge
27 For the Nafion scrubbers, these requirements should be moved to (or refer to) the
ics 2D .1100 in section 2.2 and the PSD avoidance requirements in section 2.1(D). The
regulations table in section 2.1C) should include 2D .1100.
Pa 8: For the APFO scrubber, these requirements should be moved to (or refer to) the toxics
.1100 requirement in section 2.2. The regulations table in section 2.1(E) for APFO should
clude 2D .1100.
Review Engineer: Date:
Permit Coordinator: Date:
DAQ Supervisor: Date:
cc: DAQ Central Files
FRO Files