DEQ-CFW_00088509

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
`�---- December 22, 1998
t
JAMES B. HUNT JR.
:. GOVERNOR Mr. Mike Johnson, Environmental Coordinator
E. I. DuPont Company - Fayetteville Works
PO Drawer Z
Fayetteville, North Carolina 28302-1770
WAYNE MCDEVITT
SECRETARY
SUBJECT: Receipt of Air Permit Application, APP 0900009.98B
E. I. DuPont - Fayetteville Works, Air Permit No. 03735R18
Duart, Bladen County, North Carolina
ALAN W. KLIMEK, P.E.
DIRECTOR Dear Mr. Johnson:
Your air permit revision request was received by this Division on December 21,
1998.
The amount of processing fee required is: $ 781
The amount of fee monies received was: $ 781
:m The application revision did contain all the required elements and has been
PP �
accepted for processing. Your revision request (APP 0900009.98B) will be considered
complete as of the receipt date unless you are informed otherwise by this office within 45
' days after the receipt date.
Should you have any questions regarding this matter, please contact Yongcheng
- Chen, Environmental Engineer, at [phone], ext. 308, in the Fayetteville Regional
Office.
Sincerely,
v
Steven F. Vozzo
Regional Air Quality Supervisor '
Fayetteville Regional Office
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SV/YCY/ma c ;
cc: DAQ Central Files w ,'
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FAYETTEVILLE REGIONAL OFFICE
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NC 28301-5043
a PHONE [phone] FAX [phone] WWW.ENR.STATE.Nc.us/ENR/
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% REGYC LEO/10`Yo POST -CONSUMER PAPER
i
DEQ-CFW 00088509

DIVISION OF AIR QUALITY
FAYETTEVILLE REGIONAL OFFICE
November 12, 1998
MEMORANDUM
TO: Mike Brandon /
THROUGH: Steven Vozzo
FROM: Ken Babb %
NOV i s use
AIR PERMITS SECTION
SUBJECT: Recommendations and Comments on Air Permit Application
DuPont, Inc. Current Air Permit No. 3735R17
Duart, North Carolina, Bladen County Cntyprem No. 09-00009
APP Nos.: APP 0900009.97B and 0900009.98A
Source Fee: modification
1. Purpose of Application:
This is an existing facility on State Road 87 South in Duart, Bladen County, North
Carolina that produces butacite and several specialty resins, gases, and supported films.
Application is to add another reactor to the butacite reactor line, add a control device to
the emissions to the rotagravure printer, and to renew the permit. Because the facility has
an outstanding Title V application, the renewal review will incorporate many changes
necessary for a Title V permit. I have attached a separate renewal review. The control
device is being added to comply with the printing and publishing MACT, although the
EPA has not yet approved this type of control device to meet the MACT. The facility's
test data shows that it should be acceptable to the EPA, however.
2. Application Chronology:
April 4, 1998 - Application for butacite reactor received by DAQ.
May 19, 1998 - Add info request sent to DuPont. ca v
June 2. 1998 - Control device application received and consolidated with butac
mod.
Sent. 14. 1998 -
Sept. 21, 1998 -
Sept. 25. 1998 -
Oct. 1, 1998 -
Oct. 21. 1998 -
Oct. 25. 1998 -
Nov. 1. 1998 -
Nov. 5. 1998 -
Phone conversation w/ M.
Phone conversation w/ M.
Phone conversation w/ M.
Phone conversation w/ M.
Phone conversation w/ M.
Phone conversation w/ M.
Phone conversation w/ M.
Johnson concerning PSD status. --,
Johnson concerning PSD status and &Mr
Johnson concerning PSD status.
Johnson concerning I&M.
Johnson concerning PSD status and I&M.
Johnson concerning PSD status.
Johnson concerning PSD status.
Meeting w/M. Johnson concerning PSD status and I&M.
3. Attainment Status:
Bladen County is in attainment.
DEQ-CFW 00088510

Dupont - Fayetteville Works
Page 2
4. PSD Applicability:
This is a major PSD source. The baseline date has been triggered in Bladen County for
SO2 and TSP. Several PSD questions need to be answered before the facility receives its
TV permit. The operation at the plant that exceeds the thresholds is the steam generation.
The original boiler (ID No. PS-1) had emissions of 500 tpy of SO2 since before the PSD
program. The first question concerns stipulation three of the current permit:
In no case shall the total heat input into the boilers (ID Nos. PS-1 and PS-2)
exceed a maximum of 139.4 million Btu per hour.
This stipulation was added with permit 3735R4, when the facility's three permits were
consolidated to one permit. It was also at this point that the second boiler at the facility
(ID No. PS-2) was no longer described in the permit as temporary. It is my belief that
the stipulation was originally put into the permit to function as a PSD avoidance
stipulation. The logic would have been that the original boiler has a maximum heat input
of 139.4 mm Btu/hr and therefore the stipulation would limit emissions to the then
current levels. The problem with this situation is that PSD evaluates emissions changes
on an actual to potential basis. Because actual use has never exceeded about 50% of the
original capacity, this stipulation would actually allow the new boiler to emit 500 tpy of
"additional" SO2. Because of the complexity of this question and the age of the problem,
we have decided to let resolution of this question wait until the issuance of the Title V
permit.
The second question concerns whether or not the entire operation at this site is really one
facility for PSD purposes. In the Title V application, three SIC codes from two different
two -digit groups are used to describe the operations at the facility (SIC codes 31 and 28).
This may mean that for PSD purposes the plant is not one facility. More than 50 percent
of the steam generated is used by the butacite operation, therefore the boilers and their
PSD major status would be assigned to the butacite (SIC 31). Other operations in a
different two digit SIC code may be PSD minor. The vinyl ethers gas production (which
leads to the products in the SIC 28 category) could be operated at a different site and all
of its production sent to market. The particular vinyl ethers (EVE and PSEPVE) used-i
the production of the Nafion films (SIC 31) could receive their intermediate vinyl ethe(s;
in cylinders from an off -site source. Vinyl ethers used for Nafion film production ye A
only 11 percent of vinyl ether production. The different vinyl ethers are produce
separately on the same equipment in campaigns. After one campaign, to make EVE far.:;
example, the production equipment is shut down, cleaned, and then adjusted so that the
yield of the next product is maximized. The vinyl ether gases are stored until eitlQ
shipped off site or used on site. Each product line (off -site vinyl ether and Nafion film)s
profitable enough to justify its operation separately. It is RCO's current position that if;=
the facility chose to be two sites, then all of the Nafion operations (both the majority th-al
is SIC code 28 and the minority that is SIC code 31) would be considered one site and the
steam plant and Butacite operation would be a different site. The facility is currently
considering the pros and cons of one or two site status and has not yet reached a decision.
5. Compliance Status:
At the time of last inspection by Ken Babb (06/18/98), the facility appeared to be in
compliance with the applicable requirements.
DEQ-CFW 00088511

Dupont - Fayetteville Works
Page 3
6. Facility -Wide Air Toxics:
This facility has previously modeled for all TAPS for a worst case situation at the facility.
No exceedances of those modeled limits are expected because of these modifications.
7. Stipulation review:
The facility's existing control devices require I&M stipulations. These are presented as
part of the attached renewal review.
8. Regional Concerns, Comments, and Recommendations:
FRO recommends issuance of this permit provided the changes recommended in the
renewal review are incorporated. FRO requests the opportunity to review this permit
prior to issuance.
Recommend issuance of permit? Yes
Review Engineer(s): `
Permit Coordinator: ��.¢�►�t, G"L
AQ Supervisor:
cc: AQ Central Files (yellow copy)
FRO Copy
G:\DATA\DAQ\BLADEN\00009\980914.AI6
Date: 1
Date: I Ll t
Date: 1 t -1(. -1 k
DEQ-CFW 00088512

DIVISION OF AIR QUALITY
AIR PERMIT REVIEW
E. I. DuPont -Fayetteville works Duart Bladen'County
CONTACT PHONE APPLICABILITY: NSPS NESHAP TAX OTHER
Michael Johnson 910 678 1155 x
APPLICATION FOR: Existing P/N
Renewal 3735R17
APPL. NO. REVIEWER SIGNATURE DATE
0900009.97B Ken Babb
RECOMMENDATION AND COMMENT FEE CLASS
Issuance of permit 3735R18 Title V
1. Purpose of Application:
This is an existing facility on State Road 87 South in Duart, Bladen County, North
Carolina that produces butacite and several specialty resins, gases, and supported films.
Application seeks to renew the permit. Because the facility has an outstanding Title V
permit application, some changes to numbering and insignificant activities will be made
with this permit. Also, the permitted control equipment have never had I&M stips placed
in the permit, so they will be added now.
Permit Contact for this Application:
The permit contact for this application is Mr. Michael Johnson, Environmental
Coordinator [phone]. The permit will be issued to Mr. Michael E. Mayberry,
Plant Manager.
2. Application Chronology:
09/05/1997 Renewal request received at FRO
10/01/1997 Add info requested on recordkeeping procedures and facility setup
03/17/1998 Partial inspection to verify method and type of recordkeeping
06/02/1998 Final modification application received
07/07/1998 Add info requested on control device I&M specs
07/22/1998 Some I&M specs received
08/06/1998 More I&M specs received
11/05/1998 Final I&M spec received
3. New Equipment/Change in Emission and Regulatory Review:
0
r'(1
c-)
i
a) None of the existing control devices at the facility have I&M specifications given
in the current permit. Therefore those stips have been added with this renewal. In
determining the proper values for these specifications the assumption has been
G:\DATA\DAQ\BLADEN\00009\980914.AI6
DEQ-CFW 00088513

made that because the facility has an exemplary compliance record, the values
currently in use likely are appropriate. The attached list of stipulations
incorporates these values. More extensive recordkeeping will be required of
DuPont to meet these requirements, for example monitoring of the water flow rate
to the butacite flake reactors' scrubbers.
b) Changes to the equipment list
i) Left Insig-138 [BS-3 and 7] (previous permit item 2(d)) on the permitted
items list. The point of this extruder process is to remove water from the
butacite. The removal is accomplished by pulling a strong vacumn on the
butacite using a staged series of steam jets followed by condensers. A
condenser is necessary after each steam jet so that the next jet can produce
a vacumn pull. The company argues that therefore only the last condenser
of the series should be considered a control device. By this point there
exists an uncontrolled potential of only 1093 pounds per year, therefore
this operation would be eligible for a 2Q .0102 exemption. The question
then is whether or not the earlier condensers are purely process devices or
are control devices. If all condensers are considered to be control devices,
this operation could have potential emissions in excess of 100 tpy.
Because of the difficulty in analyzing these cases, recommend leaving this
source on the regular equipment list, but not developing any I&M
stipulations at this time.
ii) removed FPX resin process (previous permit list item 3(e)). They have
removed this operation from the site.
iii) listed NCD-Hdrl and NCD-Hdr2 [NCD-1 and NCD-7] as one item.
Facility had previously requested that either or both units can be used to
control the main nafion process. It made that clearer to list as a single
equipment item.
iv) removed spray booth filter from listing of control devices. Spray booth
filters are generally considered an intrinsic part of spray booth and are not
considered control devices.
v) removed scrubber ID No. NCD-8 (previous permit item 3(g)). This unit
has never vented to the atmosphere at the Fayetteville Works facility. It
has vented to one of the NCD-Hdr's. It controls only a small stream whose
introduction uncontrolled into the NCD-Hdr stream would not
significantly affect the NCD-Hdr's ability to control the stream. Mike
Johnson believed that when the facility was first operated in Delaware,',,"
before being broken down and transported to NC, that this line may had
vented to the atmosphere and so merited its own control device. Cam.. ,
Regardless, this control device has now been shut down and will A? lon4er
be operated at this facility. --�
vi) changed NCD-G from a packed tower gas absorber to a venturi sccabbgr,
and moved the equipment to the insignificant activities list. Both e `''
venturi and the packed tower do currently exist in the caustic loop for tl�e
Nafion resins process. DuPont realised that the venturi was the true
control device during their research for developing I&M stips for this
permit. Regardless, this system primary purpose is to vent remaining
floride gases so that the vats can be open and product removed at the end
G:\DATA\DAQ\BLADEN\00009\980914.AI6
DEQ-CFW 00088514

DuPont - Fayetteville works
Page 6
of a batch. That the casutic in the Venturi does act to neutralize the floride
gases is but a nice side benefit according to DuPont and therefore the
venturi is acting as a process device and not a control device. Further,
even if the system is considered as a control device, potential HF
emissions are only 4321bs/yr. Therefore it is an insignificant source. And
should be placed there with this permit. In addition, the facility has
indicated that it is likely that this source will be removed in the near
future.
vii) removed cyclone BCD-C 1 installed on Butacite Flake Dryer. This cyclone
is followed by bagfilter BCD-C2. The cyclone functions primarily as a
product recovery unit (process unit), not as a control device.
4. PSD, NESHAPS, Non -Attainment and NSPS:
See modification review for PSD. The printing and publishing MACT will affect the
butacite tinting operation and is the motivation for installing the control device. Bladen
County is in attainment and has been triggered for both particulate and SO2. There are no
NSPS sources at the facility.
5. Air Toxics:
This facility has previously modeled for all TAPS for a worst case situation at the facility.
No exceedances of those modeled limits are expected from these modifications.
6. Facility Compliance Status:
At the time of last inspection by Ken Babb (06/18/98), the facility appeared to be in
compliance with the applicable requirements.
7. Facility Emissions Review:
Facility -wide emissions are shown on the facility's 1996 AQEI printout (attached). The
potential emissions have been updated and should be reliable. The 1997 emission
inventory has not yet been incorporated into AQEI. However, there are no large changes
in emission rates.
8. Stipulation Review:
The following list of stipulations will be included in Section A. Specific Conditions and
Limitations of Air Permit No. 03735R18. Stipulations have been added for I&M for all
control devices, for 2D .0503 for the boilers, and the standard NESHAP situation. The,,
2D .0518 stip has been modified to reflect the use of non-photochemically reactive ;
solvents. Reference to 2H .0610 has also been removed, because all toxics have been
modeled for, and so are covered under 2D .1100. A complete I&M stip has not bpgn
developed for NCD-6 (suggested stip 6) because currently little monitoring takes rplace
and because the process it controls will soon be modified so that the control device 1wift
not be needed. I recommend that this item be checked again at Title issuance tojgrW
that its use has been discontinued.'
1. Ml, Applicable Regulations: 2D .0503, .0515, .0516, .0518, .0521, .0522, .0535"
.1100, .1110, and 2Q .0507. =+
2. M3a, Allowable particulate emission rates per 2D .0515.
3. M3b, Allowable particulate emission rates per 2D .0503.
G:\DATA\DAQ\BLADEN\00009\980914.AI6
DEQ-CFW 00088515

4. M6, Reduce fugitive emissions.
5. M9, Sulfur dioxide limitation per 2D .0516.
6. M13, VE - 40% opacity limitation per 2D .0521.
7. M12, VE - 20% opacity 'limitation per 2D .0521.
8. M 14, Odor per 2D .0522
9. 1vt25, Tonics
10. M41a, HaS filter I&M
11. M41b, Condenser I&M
12. M41 d, Chas scrubber I&M
13. M41 i, Cyclone I&M
14. M24, P5D avoidance
15. M21c, MACT compliance
16. M37, Notification requirement, excess emission/malfunction reporting.
17, M59, TV Notification
9. Discussion and CommenU:
I recommend issuance of permit number 03735R18,
Review Engineer: �XI 664—
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Permit Coordinator: . A
Z
AQ Supervisor;
cc: RCO Central Has
FRO F11cs
0s1DATAOAQ1BLADEN1400091980914,A16
Date: l -A
Date: f ll
Date: 12--,3-1 CrcY3.-,)
T/T'd 0EE'ON
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DEQ-CFW 00088516

Permit No. 3735R17
Page 1
11/12/98
ID numbers in plain type indicate TV app id #'s, ID numbers in italics indicate last permit id#'s
BUTACITE®
1. FABRIC FILTER REQUIREMENTS - Particulate emissions from the Butacite® flake
dryer (ID No. BS-C [BS-8]) shall be controlled by the pulse jet fabric filter (6858 square feet
of filter area, ID No. BCD-C2[BCD-8B]).
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that maximum control
efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the manufacturer. The recording and record
keeping schedule is given below.
An annual internal inspection shall be conducted on the fabric filter by the Permittee
to ensure structural integrity such that optimum control efficiency is achieved. The
results of this inspection, and any maintenance performed on the fabric filter, shall
be recorded in a logbook which is described below and which will be kept on site and
made available to the Division of Air Quality upon request.
(b) Monitoring Requirements
The fabric filter shall be operated at a differential pressure not to exceed eighteen
(18) inches of water pressure. The differential pressure shall be continuously
measured and recorded electronically.
(c) Recordkeeping and Reporting Requirements
�a
A fabric filter logbook shall be kept on site and made available to Division of Air;
Quality personnel upon request. An electronic record is acceptable. Any variance'
from manufacturer's recommendations or from those given in the permit (1gen ;- i
different) shall be investigated with corrections made and date of actions recoyed,
in the logbook. The logbook shall also contain the following: --J ;-
3
r;7
records of any maintenance performed on the fabric filter system, Ca
(ii) the results of the VE tests (where applicable), -4
(iii) the pressure drop across the bags, and
DEQ-CFW 00088517

Permit No. 3735R17
Page 2
(iv) results of inspections including a broken bag record (where applicable).
2. CONDENSER REQUIREMENTS - Butryaldehyde emissions from the butryaldehyde
storage tank (ID No. BS-A [BS-11) shall be controlled by the condenser (ID No. BCD -A
[BCD-]]).
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that maximum control
efficiency is maintained, the Permittee shall perform periodic inspections and
maintenance as recommended by the manufacturer including those given below.
(i) annually inspect and maintain the structural integrity of the condenser and its
associated piping, including inspection for leakage of coolant and, if the
system is under positive gauge pressure, leakage of the contaminated gas
stream, and
(ii) maintain records of inspections and any measures taken to repair leaks or
other possible sites of fugitive emissions.
The Permittee shall report the results of such inspections according to the record
keeping and reporting requirements given below.
(b) Monitoring Requirements
The condenser shall be equipped with a pressure drop monitor to indicate the flow i'
rate of the ethylene glycol cooling system (nominal flow rate 8,900 pounds per hour)..J
The monitor shall be equipped with a low pressure drop alarm. The low alarm tall'-`-'�
be set at 5 pounds per square inch gauge. The ethylene glycol brine discharge pmnt
shall have a device to continuously measure the temperature to ensure that it does%ot
exceed 32 OF. The device (e.g., thermocouple) shall be installed in an accessiwe
location and shall be maintained by the Permittee such that it is in proper worlglg
order at all times.
(c) Record Keeping and Reporting Requirements
A condenser logbook shall be kept on site and made available to Division of Air
Quality personnel upon request. Any variance from manufacturer's recommendations
shall be investigated with corrections made and date of actions recorded in the
logbook. The I & M program as well as any sounding of the low pressure drop alarm
shall also be recorded.
DEQ-CFW 00088518

Permit No. 3735R 17
Page 3
3. PACKED TOWER GAS ABSORBER REQUIREMENTS - Gaseous emissions from the
Butacite® chemical reactor line (ID No. BS-B [BS-21) shall be controlled by two (2)
packed column scrubbers (ID Nos. BCD-B1 and BCD-B2 [BCD-2A and BCD-2B]) with
saddle type packing and a water scrubbing medium.
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that optimum control
efficiency is maintained, the Permittee shall establish an inspection and maintenance
schedule/checklist based on manufacturer's recommendations. As a minimum, the
inspection and maintenance program will include inspection of spray nozzles,
packing material, and the cleaning/calibration of all associated instrumentation.
The Permittee shall record the results of inspections according to the schedule of
record keeping and reporting given below.
(b) Monitoring Requirements
The Permittee shall ensure the proper performance of the scrubbers by monitoring the
following operational parameters:
(i) liquid flow rate (minimum of 8 gallons per minute), and
(ii) differential pressure across the scrubber (maximum of 7.5 inches of water
pressure), with a high differential pressure alarm.
(c) Record Keeping and Reporting Requirements
An absorber logbook which shall be kept on site and made available to Division of
Air Quality personnel upon request. Any variance from manufacturer's .
recommendations shall be investigated with corrections made and date of act;ns ".
recorded in the absorber logbook. The I & M program, as well as the liquid flowate x
and differential pressure across the scrubber, shall be recorded.
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DEQ-CFW 00088519

Permit No. 3735R17
Page 4
NAFION®
4. PACKED TOWER GAS ABSORBER REQUIREMENTS - Gaseous emissions from the
Nafion® process units (ID Nos. NS - A through NS - F [HFPO-NS-1, PPVE-NS-2,
PMVE/PEVE-NS-3, PSEPVE-NS-4, EVE-NS-S, RSU-NS-6, liquid waste stabilization NS-7,
MMF-NS-8, PEVEIPMVE-NS-1 S and PPVE-AOS-1]) shall be controlled by either of two (2)
counter -current baffle -plate type tower waste gas scrubbers (ID Nos. NCD-HdrI and NCD-
Hdr2 [NCD-1 and NCD-71) with nine inch spacing and a caustic scrubbing medium using
potassium hydroxide additives.
(a) Inspection and Maintenance Requirements
To comply with the provisions of this Permit and ensure that optimum control
efficiency is maintained, the Permittee shall establish an inspection and maintenance
schedule/checklist based on manufacturer's recommendations. As a minimum, the
inspection and maintenance program will include inspection of spray nozzles,
packing material, chemical feed system, and the cleaning/calibration of all associated
instrumentation.
The Permittee shall record the results of inspections according to the schedule of
record keeping and reporting given below.
(b) Monitoring Requirements
The Permittee shall ensure the proper performance of the scrubbers by monitoring the
following operational parameters:
(i) injection liquid flow rate [Testing shall be performed to determine the,
minimum flow rate and the results submitted by the Permittee to the Divisioj#
by December 1, 1999],
ca >
Fri :a
(ii) pressure drop across the scrubber (The scrubber shall be equipped with Tligk
pressure drop alarm. [Testing shall be performed to determine the maxifkurf;
pressure drop and the results submitted by the Permittee to the Divisim by
CO
December 1, 1999] ), and
(iii) pH of recirculation tank scrubbing solution (minimum of 8 with a setpoint ofi
12).
DEQ-CFW 00088520

Permit No. 3735R 17
Page 5
(c) Record Keeping and Reporting Requirements
An absorber logbook which shall be kept on site and made available to Division of
Air Quality personnel upon request. An electronic record is acceptable . Any
variance from manufacturer's recommendations shall be investigated with corrections
made and date of actions recorded in the absorber logbook. The I & M program as
well as the injection liquid flowrate, pH of the scrubber solution, and the pressure
drop across the scrubber alarm soundings shall be recorded.
Modified equipment list
Two (2) No. 6 fuel oil -fired boilers (one with 139.4 and one with 88.4 million Btu
per hour maximum permitted heat input, ID Nos. PS-1 and PS-2, respectively),
2. Butacite® processes consisting of the following:
(a) One (1) Butacite® tinting oven (ID No. BS-D [BS-6]),
(b) One (1) brine -cooled condenser (ID No. BCD -A [BCD-]]), installed on a
butyraldehyde storage tank (ID No. BS-A [BS-1]),
(c) Two (2) packed column scrubbers (8 gallons per minute water injection rate
each, ID Nos. BCD-B 1 and BCD-B2 [BCD-2A and BCD-2B]) with mist
eliminators (0.79 square feet of filter area each) installed one each on two
vents from the Butacite® chemical reactor line (ID No. BS-B [BS-21),
(d) One (1) bagfilter (6,858 square feet of filter area, ID No. BCD-Cl [BCD tP-i
8B]) installed on the flake dryer vent (ID No. BS-C [BS-8]). "'
,y
3. Nafion® processes consisting of the following:
21 r
(a) One (1) perfluorinated resin membrane treatment process (Nafion® process,
CO
ID No. NS-H [NS-11 ]) vented to the atmosphere (Nafion® Vent 0),
(b) Two (2) baffle plate -type tower waste gas scrubbers (72 gallons per minute
liquid injection rates, Vent #land Vent #7, ID Nos. NCD-Hdrl and NCD-
Hdr2 [NCD-1 and NCD-7]) installed on perfluorinated chemical
manufacturing processes (ID Nos. NS-A through NS-F [HFPO-NS-1, PPVE-
NS-2, PMVE/PEVE-NS-3, PSEPVE-NS-4, EVE-NS-5, RSU-NS-6, liquid
waste stabilization NS-7, MMF-NS-8, PEVEIPMVE-NS-15 and PPVE-AOS-
DEQ-CFW 00088521

Permit No. 3735R17
Page 6
(c) One (1) plate -type spray tower caustic scrubber (60 gallons per minute liquid
injection rate, ID No. NCD-G [NCD-2]) installed on the XR/CR resins
processes, ID No. NS-G [NS-9 and NS-10]) (Nafion® Vent #2), both
processes utilizing the same basic equipment, but not simultaneously,
(d) One (1) filter -type spray booth utilized in a membrane coating process (ID
No. NS-I [NS-121) utilizing non-photochemically reactive or exempt
materials,
(e) One (1) E-Fluids production process (Nafion® process, ID No. NS-K) vented
to the atmosphere (Nafion® Emission Point-Kl),
4. One (1) impingement type wet scrubber (70 gallons per minute total dilute potassium
hydroxide injection rate, ID No. WTCD-3) with mist eliminator filter (56.7 square
feet of filter area) installed on two indirect steam -heated, rotary wastewater treatment
sludge dryers (399 pounds per hour maximum permitted drying capacity each, ID
Nos. WT-1 and WT-2),
5. Nafion® Semiworks facility consisting of the following:
(a) One (1) polymerization operation exhaust (SW-1) and
(b) One (1) laboratory hood (SW-2).
6. Nafion® Semiworks 3 (ID No. NS-J3) facility consisting of laboratory and bench
scale production equipment, or idle process equipment.
DEQ-CFW 00088522

Permit No. 3735R17
Page 7
ATTACHMENT to Permit No. 3735R17, November 12, 1998
Activities Exempted from Permitting Under 15A NCAC 2Q .0102(b)(2)
Source Date of Exemption Source of TAPS? Source of Title V
Application Regulation Pollutants?
One (1) venturi 5 Nov 98
scrubber (3 gallons per
minute caustic liquid
injection rate, Vent
#100, ID No. NCD-8)
installed on the
PEVE/PMVE process
reactor No. ABR-2)
2Q .0102(b)(2)(E) Yes
Yes
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15 A NCAC 2D .1100 or 2H .0610.
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