DEQ-CFW_00067864

Kelvington, Jenny
From: Kelvington, Jenny
Sent: Monday, November 04, 2013 9:07 AM
To: 'Michael. [e-mail]'
Cc: Reeves, Gregory W
Subject: RE: DuPont Title V Permit No. 03735T37 -- Significant Modification Application
Burning fuel oil with a sulfur content of 0.5 wt% will exceed the 0.06 lb S02/mmBtu avoidance
qualification. To avoid NSPS, the temporary boiler would need to fire fuel oil with a sulfur
content less than 0.06 wt%. Do you still want the NSPS avoidance condition or only the MACT
avoidance condition which only limits the number of consecutive days on site?
Jenny Kelvington, Environmental Engineer III NC DENR, Division of Air Quality Permit Section
1641 Mail Service Center, Raleigh, NC 27699-1641
Phone/Fax: [phone]
www.ncair.org
[e-mail]
Green Square Office Complex at 217 West Jones Street, Raleigh, NC.
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--Original Message -----
From: [e-mail][mailto:[e-mail]]
Sent: Monday, November 04, 2013 8:56 AM
To: Kelvington, Jenny
Cc: Reeves, Gregory W
Subject: RE: DuPont Title V Permit No. 03735T37 -- Significant Modification Application
Jenny:
I have reviewed the draft permit, and my only request is a quantitative replacement of the
phrase "low sulfur fuels" in the Section 2.1(F) table in the row for "Sulfur Dioxide and
Visible Emissions" that reads:
"On site less than 180 days per consecutive twelve month period and use of low sulfur
fuels"
The term "low sulfur fuel" seems to be open to interpretation.
Since the regulatory citation of this entry is 2D.0524 "New Source Performance Standards" as
promulgated in 40 CFR Part 60, and since the temporary boiler is subject specifically to NSPS
Subpart Dc where the sulfur content in fuel oil is limited to no "greater than 0.5 weight
percent sulfur" per 40 CFR 60.42c(d), it would seem appropriate and more descriptive to
replace the above requirement with the following:
"On site less than 180 days per consecutive twelve month period and use fuels containing
no greater than 0.5 weight percent sulfur".
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DEQ-CFW 00067864