DEQ-CFW_00088624

DuPont Fluoroproducts
P. 0. Drawer Z
Fayetteville, NC 28302-1770
QWO
DuPont Fluoroproducts
kff-PERMITS SECTj0`11,ne 1, 1998
Mr. Michael Brandon, P.E.
NC -Department of Environment and Natural Resources
Division of Air Quality - Permitting Section
P.O. Box 29580
Raleigh, NC 27626-0580
RE: Air Permit Application No. 0900009.98A
Professional Engineering Certification
Dear Mr. Brandon:
This letter is in regard to your correspondence dated May 19, 1998, which stated a
professional engineering certification is required for the air permit application to install an
additional Butacite® Flake Reactor. You cited the "P.E. certification rule" which requires such a
certification for any control device that has been replaced, modified, or has changed the amount
or type of emission sources which it controls.
I do not believe a professional engineering certification should be required in this particular
situation. The Butacite® process currently consists of seven Flake Reactors, of which four of the
reactors vent to a packed column water scrubber (BCD-2A in the current air permit, BCD-B 1 in
the Title V application), which I will call "System A", and three of the reactors vent to another
packed column water scrubber (BCD-213 in the current air permit, BCD-132 in the Title V
application) which I will call "System B". The water scrubbers have the identical scrubbing
section, but the bottom section of BCD-213 is slightly more than a foot longer than BCD-2A.
The referenced application is to allow for an additional reactor to be added to "System B",
making a total of four reactors which would match the configuration of "System A".
If the emissions from "System A" are adequately controlled by water scrubber BCD-2A,
than it is intuitively logical that emissions from "System B" plus the additional reactor, which
would be identical in amount and type to the emissions from "System A", would be adequately
controlled by water scrubber BCD-213, an identical scrubber to BCD-2A. 71
Please contact me at [phone] to let me know if you concur with this reasoning,
Sincerely,-----=—�
CID
Michael E. Johnson
E I. du Pont de Nemours and Company
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DEQ-CFW 00088624