DEQ-CFW_00088594

0
JV
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
November 4, 1998
Mr. Douglas Neeley, Chief
Air & Radiation Technology Branch
Air, Pesticides and Toxics Management Division
U.S. EPA Region IV
61 Forsyth Street SW
Atlanta, Georgia 30303
Subject: Alternate Control for NESHAP Compliance
Dupont Company, Fayetteville Works
Fayetteville, Bladen County, North Carolina
Dear Mr. Neeley:
The above referenced company is proposing to use a wet horizontal scrubber in lieu
of an incinerator or carbon adsorption system to achieve compliance with the 95
percent control limit required by National Emission Standards for the Printing and
Publishing Industry (40 CFR 63, Subpart KK). A request for approval was
submitted to Mr. Douglas Neely of your office on September 9, 1998 which was
forwarded by Mr. Lee Page to David Salman of at RTP for review and
concurrence.
In our telephone conversations with Mr. Salman, he indicated that the standard does
not intend to restrict control options to incineration or carbon adsorption. The
DAQ will, therefore, approve the proposed scrubber installation with appropriate
performance testing, parametric monitoring, recordkeeping, and reporting
requirements through issuance of a construction and operating permit (15A NCAC
2Q .0300) and subsequently through the issuance of the Title V operating permit
(15A NCAC 2Q .0500).
:7
Performance testing will be conducted for total enclosure and scrubber performance""
%
C-)
in accordance with EPA approved methodology and reference methods. Pararrjigric
3
monitoring will be required in lieu of continuous emissions monitoring becaus6a
parallels the requirements for incinerator controls. Recordkeeping, and reporting
will also parallel those for the use of parametric monitoring for incinerator use.to
c a
—i
PERMITS SECTION
P.O. BOX 29580, RALEIGH NC 27626-0580 / 2728 CAPITAL 9LV D., RALEIGH NC 27604
PHONE [phone] FAX [phone] ;1; .ehnr.Stat6.nc.US/EHNR
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oq POST -CONSUMER PAPER
DEQ-CFW 00088594

T. . V
Mr. Douglas Neeley
Page 2
Please feel free to contact Mr. Michael Brandon, P.E. at 919-715-6243 if you have any questions
regarding this letter.
cere ,
Donald R. van der Vaart, P.E.
Supervisor, Permits Section
c: Lee Page, EPA Region IV
David Salman, EPA - RTP
Michael Johnson, Dupont - Fayetteville
;10
rd�
.a
C—:
".0 C
CO U)
4'3
DEQ-CFW 00088595