DEQ-CFW_00068211

r
•
Aja
NCDENR
North Carolina Department of Environment and Natura
Division of Air Quality
Beverly Eaves Perdue
Governor
B. Keith Overcash, P.E.
Director
February 22, 2010
olieJC 02_Z©
Fa eeA -aU(IIe--
Resources
Ms.Xaren B_Wrigle-y---
Plant Manager
E.I. du Pont de Nemours and Company
DBA, DuPont Company - Fayetteville Works
- 2828-NC.High- Highway-8-7 West — - -- -- - -- -- - . -- -- - . - - - --- --- - - ---
Duart Township, North Carolina 28306-7332
Dear Ms. Wrigley
Dee Freeman
Secretary
SUBJECT: Air Quality Permit No. 03735T35
Facility ID: 0900009
E.I. du Pont de Nemours and Company MAR QQ�Q
DBA, DuPont Company - Fayetteville Works
Duart Township
Bladen County EASE i i,- . — Ji, FICE
Fee Class: Title V
In accordance with your completed Air Quality Permit Application for a Title V permit renewal received
on April 17, 2008, an application for a significant modification received April 8, 2008, and an application for a
significant modification received December 9, 2008, we are forwarding herewith Air Quality Permit No.
03735T35 to E.I. du Pont de Nemours and Company, Duart Township, Bladen County, North Carolina authorizing
the construction and operation of the emission source(s) and associated air pollution control device(s) specified
herein. Additionally, any emissions activities determined from your Air Quality Permit Application as being
insignificant per 15A North Carolina Administrative Code 2Q .0503 have been listed for informational purposes.
Please note the requirements for the annual compliance certification are contained in General Condition P in
Section 3. The current owner is responsible for submitting a compliance certification for the entire year
regardless of who owned the facility during the year.
As the designated responsible official it is your responsibility to review, understand, and abide by all
of the terms and conditions of the attached permit. It is also your responsibility to ensure that any person who
operates any emission source and associated air pollution control device subject to any term or condition of
the attached permit reviews, understands, and abides by the condition(s) of the attached permit that are
applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you, you
have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying
the specific issues to be contested. This hearing request must be in the form of a written petition, conforming to
Permitting Section One
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 NorthCarolina
2728 Capital Blvd., Raleigh, North Carolina 27604 �a�ur,�LL�
Phone: [phone] / FAX [phone] / Internet: www.ncair.org
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00068211

Ix
Ms. Karen B. Wrigley
February 22, 2010
Page 2
NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of Administrative Hearings,
6714 Mail Service Center, Raleigh, North Carolina 27699-6714 and the Division of Air Quality, Permitting
Section, 1641 Mail Service Center, Raleigh, North Carolina 27699-1641. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Please note that
this permit will be stayed in its entirety upon receipt of the request for a hearing. Unless a request for a
hearing is made pursuant to NCGS 15013-23, this Air Quality Permit shall be final and binding 30 days after
issuance.
You may request modification of your Air Quality Permit through informal means pursuant to NCGS
150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or
issues for which the modification is sought. Please note that this Air Quality Permit will become final and binding
regardless of a request for informal modification unless a request for a hearing is also made under NCGS 150B-23.
The—construction_of new air pollution emission sources and associated _airPollution _control_
device(s), or modifications to the emission source(s) and air pollution control device(s) described in this
permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction. Failure to do so is a violation of GS 143-215.108 and may subject the Permittee to civil or
criminal penalties as described in GS 143-215.114A and 143-215.114B.
This Air Quality Permit shall be effective from February 22, 2010 until January 31, 2015, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified
therein. Should you have any questions concerning t after, plea contact Ms. Fern Paterson, P.E. at (919)
715-6242.
Chief
Enclosure
cc: Gregg Worley, EPA Region 4
,/Fayetteville Regional Office
Central Files
R. van der Vaart, Ph.D., J.D., P.E.
DEQ-CFW 00068212

•
•
ATTACHMENT I:
Summary of Changes to Previous Permit (No. 03735T34)
Page(s)
Section
Description of Change(s)
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
Global
Global
Change boiler ID Nos., as follows:
• ID No. PS-1 PS -A
• ID No. PS-2 PS-B
3-5
Section 1, Table
• Add ID Nos. BS-F & BS-G, which were previously included on the insignificant
activity list (ID Nos. I-B1 & I-B2).
• Remove ID Nos. BS-D, which is not longer at the facility.
• Add MACT FFFF designations to all Butacite® sources.
! Remoye all oottnotes rQgard ngmodification procedures and Title V shield
applicability.
10-11
Section 2.1 A.S.
Revise PSD avoidance condition to include only NOx and SOZ and update monitoring
provisions to includes specific compliance demonstration methodology.
14-15
Section 2.1 BA._
•_ Remove MACT KK requirements. All affected printing operations (ID No. BS-D)
have been removed from the facility.
• Add MACT FFFF requirements.
17-18
Section 2.1 CA.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
18-19
Section 2.1 C.S.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
19-20
Section 2.1 C.6.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
20
Section 2.1 C.7.
(Formerly identified as 2.1 C.6, in error) Update PSD avoidance condition to include
specific compliance demonstration methodology.
20-27
Section 2.1 C.8
Add facility -specific MACT FFFF requirements to the permit.
N/A
Former Section
Remove ID No. FS-A, which no longer operating at the facility.
2.1.D
DEQ-CFW 00068213

ATTACHMENT H:
Insignificant Activities Pursuant to 15A NCAC 2Q .0503(8)
End, Source
ID No.
-
Emission Source Description _
I-01
Polyvinyl fluoride vacuuming system for housekeeping purposes
I-02
Waste DMSO Storage Tank
I-03
Fugitive Emissions of Methylene Chloride
1-04
Chlorination of Riverwater to control mussel growth in equipment
I-05
wde Laboratory Emissions,
I-06
Outdoor abrasive blasting operation for items exceeding 8 feet in any dimension
I-07
Paint shop
I-08
Self-contained abrasive blasting cabinets
I-09
Paint spray booths
I-10
Abrasive blasting and painting building
I-11
Plasticizer storage tank
I-12
Nafion® Dispersion Process
1. Because an.activity is insignificant 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 15A NCAC 2D .1100, "Control of Toxic Air
Pollutants", or 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit".
DEQ-CFW 00068214

•
•
State of North Carolina,
Department of Environment,
and Natural Resources
Division of Air Quality NCDENR
AIR QUALITY PERMIT
Permit No.
Replaces Permit No.
Effective Date
Expiration Date
03735T34
03735T35
February 22, 2010
January 31, 2015
Until such time as this permit expires or is modified or revoked, the below named Permittee is permitted to construct and
opera e the erriissiori sources an a� ssociated air pollution contra device(s)-ecified teir—inardatrce witlrthe terms
conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B of Chapter 143,
General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes (15A NCAC),
Subchapters 2D and 2Q, and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Pere -tee shall not construct, operate, or modify any emission source(s)
or air pollution control device(s) without having first submitted a complete Air Quality Permit Application to the permitting
authority and received an Air Quality Permit, except as provided in this permit.
Permittee: E.I. du Pont de Nemours & Co., LLC
DDA, DuPont Company — Fayetteville Works
Facility ID: 0900009
Facility Site Location: 22828 NC Highway 87 W
City, County, State, Zip: Duart Township, Bladen County, NC, 28306-7332
Mailing Address: 22828 NC Highway 87 W
City, State, Zip: Fayetteville, NC, 28306-7332
Application Number: 0900009.08B, 0900009.08C, and 900009.08E
Complete Application Date: April 8, 2008, April 17, 2008, and December 9, 2008
Primary SIC Code: 2821, 3081, 3083
Division of Air Quality, Fayetteville Regional Office
Regional Office Address: 225 Green Street, Suite 714
Fayetteville, NC 28301
issued this the 22y' day of February, 2010
er Vaart, Ph.D., J.D., P.E., Chief, Air Permits Section
By Ant ority of the Environmental Management Commission
DEQ-CFW 00068215

0 Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE (S) AND ASSOCIATED
AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1- Emission Source(s) Specific Limitations and Conditions (Including specific
requirements, testing, monitoring, recordkeeping, and reporting requirements)
2.2- Multiple Emission Source(s) Specific Limitations and Conditions (Including
specific requirements, testing, monitoring, recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENT _
List of Acronyms
DEQ-CFW 00068216

Permit 03735T35
Page 3
•
SECTION I - PERMITTED EMISSION SOURCE(S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICES) AND APPURTENANCES
The following table contains a suniniary of all permitted emission sources and associated air ollution control devices:
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
PS -A
Natural Gas/No. 2 fuel oil/No. 6 fuel oil-
N/A
N/A
fired boiler (139.4 million Btu per hour
maximum heat input)
PS-B
Natural Gas/No. 2 fuel oil /No. 6 fuel oil-
N/A
N/A
fired boiler (88.4 million Btu per hour
maximum heat input)
PS-C
Natural Gas/No. 2 fuel oil -fired boiler (97
N/A
N/A
NSPS Dc
million Btu per hour maximum heat
m u a ui e with a ow- x urner
PS -Temp
Natural Gas/No. 2 fuel oil -fired boiler
N/A
N/A
NSPS De
(greater than 30.0 and less than 100.0
million Btu per hour maximum heat
input)
BS-A
Butyraldehyde storage tank
BCD -A
Brine -cooled condenser
BS-B 1.1
Butacite polyvinyl butyral flake reactors
BCD-B 1
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B l A
injection rate averaged over a 3-hour
MACT FFFFperiod)
(state -enforceable, on! )
BS-B2.1
Butacite® polyvinyl butyral flake reactors
BCD-B2
Packed -bed column scrubber with mist
through
(4 units)
eliminator (8 gallons per minute water
BS-B2.4
injection rate averaged over a 3-hour
MALT FFFFperiod)
state -enforceable, only)
BS-C
Butacite polyvinyl butyral flake dryer
BCD-Cl
Cyclone separator
MACT FFFF
BCD-C2
Fabric filter (6,858 square feet of filter
area
BS-El
Butacite®Line No. 3 Sheeting Extrusion
BCD -El
Water -Cooled Condenser (voluntary
Process, including four (4) extruders
use only)
BS-E2
Butacite® Line No. 4 Sheeting Extrusion
BCD-E2
Water -Cooled Condenser (voluntary
Process, including four (4) extruders
use onl
BS-E3
Butacite Line No. 3 Back -End
N/A
N/A
Processes, including a quencher,
drye and wind-up area
BS-E4
Butacite® Line No. 4 Back -End
N/A
N/A
Processes, including a quencher,
dryer/relaxer, and wind-up area
BS-F
Butacite® PVA Unloading System and
N/A
N/A
MACT FFFF
Storage Silos
BS-G
Butacite PVA Dissolver Tank System
N/A
N/A
MACT FFFF
DEQ-CFW 00068217

Permit 03735T35
Page 4
•
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
NS-A
Nafion® Hexfluoropropylene epoxide
NCD-Hdrl
Baffle -plate scrubber (7,000
MALT FFFF
process (HFPO)
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-B
Nafion® Vinyl Ethers North process
NCD-Hdrl
Baffle -plate scrubber (7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hourperiod)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
-
1Vafio� y1 Ethers Sou process
BCD-IdrBattle-plate
scrubber(7,000
MACT FFFF
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-D
Nafion® RSU Process
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-E
Nafion® Liquid waste stabilization
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-F
Nafion® MMF process
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
NS-G
Nafion® Resins process
NCD-G
Venturi vacuum jet caustic scrubber
MACT FFFF
NS-H
Nafion® membrane process
N/A
N/A
NS-I
Nafion® membrane coating
N/A
N/A
NS-J
Nafion® semiworks
N/A
N/A
DEQ-CFW 00068218

Permit 03735T35
Page 5
•
Emission
Emission Source Description
Control Device
Control Device Description
Source ID No.
ID No.
NS-K
Nafion® E-2 Process
N/A
N/A
NS-L
Nafion® TFE/HCl separation unit
NCD-Hdrl
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
-or-
averaged over a 3-hour period)
NCD-Hdr2
Baffle -plate scrubber (7,000
kilogram/hour liquid injection rate
average over a 3-hourperiod)
NS-M
Nafion® TFE/COZ separation process
N/A
N/A
NS-N
HFPO product container decontamination
N/A
N/A
rocess
NS-O
Vinyl Ethers North product container
N/A
N/A
deconta-nat18n--rocess
NS-P
Vinyl Ethers South product container
N/A
N/A
decontamination process
SW-1
Semiworks polymerization operation
N/A
N/A
SW-2
Semiworks laboratory hood
N/A
N/A
AS -A
Polymer Processing Aid Process
ACD-Al
Wet scrubber (30 gallons per minute
water injection rate averaged over a 3-
hour period) (state -enforceable only)
ACD-A3
Wet scrubber installed on the building
exhaust vent (voluntary use only)
WTS-A
Extended aeration biological wastewater
N/A
N/A
treatment facility
WTS-B,
Two (2) Indirect steam -heated, rotary
WTCD-1
Impingement -type wet scrubber with
WTS-C
sludge dryers
mist eliminator state -enforceable only
SGS-A
Sen Glas® Process
N/A
N/A
FS-B
Polyvinyl Fluoride Process No. 1
N/A
N/A
FS-C
Polyvinyl Fluoride Process No. 2
NIA
N/A
DEQ-CFW 00068219

Permit 03735T35
Page 6
�J
SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS
2.1 -Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s) and associated air pollution control device(s) and appurtenances listed below are subject to the
following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting
requirements as specified herein:
A. Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS -A), 139.4 million Btu per hour
maximum heat input,
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-B), 88.4 million Btu per hour
movi at input,
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-Q equipped with a low-NOx burner, 97
million Btu per hour maximum heat input.
-'-Th4.4v ••••Zdtis-a�'u13jm�mits'a IIUAI UJ 1V1-Ll[G-e�Z�.�.S'f�n-.5'oijr{.'e G
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Sources: PS -A, PS-B
15A NCAC 2D .0503
0.2667 pounds particulate per million Btu heat input
Affected Sources: PS-C
0.2268 pounds particulate per million Btu heat in Tut
Sulfur dioxide
Affected Sources: PS -A, PS-B
15A NCAC 2D .0516
2.3 pounds SOZ per million Btu heat input, each
Sulfur dioxide
Affected Source: PS-C
15A NCAC 2D .0524
No. 2 fuel oil sulfur content shall not exceed 0.5% by weight.
(40 CFR 60, Subpart Dc)
Visible emissions
Affected Source: PS -A
15A NCAC 2D .0521(c)
40 percent opacity
Affected Source: PS-B
15A NCAC 2D .0521(d)
20 percent opacity
Visible emissions
Affected Source: PS-C
15A NCAC 2D .0524
20 percent opacity
(40 CFR 60, Subpart Dc)
Nitrogen oxides,
Affected Source: PS-B
15A NCAC 2Q .0317
Sulfur dioxide
Nitrogen oxide <40 tons per year.
(PSD Avoidance)
Sulfur dioxide <40 tons per year.
Sulfur dioxide
Affected Sources: PS -A, PS-B, PS-C, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
(PSD Avoidance)
See Section 2.2. A.1. of this permit
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil/No. 6 fuel oil that are discharged from the
affected boilers (ID Nos. PS -A and PS-B) into the atmosphere shall not exceed 0.2667 pounds per million Btu heat
input.
b. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from the affected boiler (ID
No. PS-C) into the atmosphere shall not exceed 0.2268 pounds per million Btu heat input.
Testing [15A NCAC 2D .2601 ]
c. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
this test are above the limits given in Section 2.1 A.l.a. and/or b. above, the Permittee shall be deemed in
noncompliance with 15A NCAC 2D .0503.
DEQ-CFW 00068220

Permit 03735T35
Page 7
•
Monitoring/Recordkeeping/Reporting [I 5A NCAC 2Q .0508(f)]
d. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 or No. 6 fuel oil
in these sources.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from the affected boilers (ID Nos. PS -A and PS-B) shall not exceed 2.3 pounds per
million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances
shall be included when determining compliance with this standard.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
on ition oun m ection t e resu is o t is test area ove e limmt given m Section 2.1 B.l,a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516.
Monitorin2/Recordkeeping [15A NCAC 2Q .0508(f) and 15A NCAC 2D .0501(c)(4)(A)]
--c-.—N�monitoring/recordkeeping-i required-for--sulfur-dioxide-enussiom-ftom-naturarga"r-Nv.2 fuel '
these sources.
d. The maximum sulfur content of any No. 6 fuel oil received and burned in the boiler shall not exceed 2.1 percent by
weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the fuel
oil exceeds this limit.
e. To assure compliance, the Permittee shall monitor the sulfur content of the No. 6 fuel oil by using fuel oil supplier
certification per shipment received. The results of the fuel oil supplier certifications shall be recorded in a logbook
(written or electronic format) on a quarterly basis and include the following information:
i. The name of the fuel oil supplier;
ii. The maximum sulfur content of the fuel oil received during the quarter;
iii. The method used to determine the maximum sulfur content of the fuel oil; and
iv. A certified statement signed by the responsible official that the records of fuel oil supplier certification submitted
represent all of the No. 6 fuel oil fired during the period.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the oil is not
monitored and recorded.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on or before January
30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected boiler (ID No. PS -A) shall not be more than 40 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 40 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 90 percent
opacity.
b. Visible emissions from the affected boiler (ID No. PS-B) shall not be more than 20 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
DEQ-CFW 00068221

Permit 03735T35
Page 8
•
Testing [ 15A NCAC 2D .2601 ]
c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 21) .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 A.3.a. or .b above, the Permittee shall
be deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
d. To assure compliance, each day that an affected source fires No. 6 fuel oil, the Permittee shall observe the emission
point of the affected source for any visible emissions above normal. The daily observation must be made for each
day of the calendar year period to ensure compliance with this requirement. The Permittee shall be allowed three (3)
days of absent observations per semi-annual period. If visible emissions from this source are observed to be above
normal, the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements beow, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 A.3.a. or b. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Perniinee shall be deemed to be in no.,icompliance with 15A
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
f. No monitoring/recordkeeping/reporting is required for visible emissions from the fining of natural gas or No. 2 fuel
oil in these sources.
Reporting [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
4. 15A NCAC 2D .0524: New Source Performance Standards (40 CFR 60, Subpart Dc)
a. For the affected boiler (ID No. PS-C), the Permittee shall comply with all applicable provisions, including the
notification, testing, recordkeeping, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 02D .0524, "New Source Performance Standards" (NSPS) as promulgated in 40 .
CFR 60, Subpart Dc, including Subpart A, "General Provisions."
Emission Limitations [15A NCAC 2D .0524]
b. The maximum sulfur content of any fuel oil received and fired in the affected boiler (ID No. PS-C) shall not exceed
0.5 percent by weight. [40 CFR 60.42c(d)]
c. Visible emissions from the affected boiler (ID No. PS-C) shall not be more than 20 percent opacity when averaged
over a six -minute period, except for one six -minute period per hour of not more than 27 percent opacity. [40 CFR
60.43c(c)]
DEQ-CFW 00068222

Permit 03735T35
Page 9
F__�
Testing [15A NCAC 2D .2601]
d. Within 60 days after achieving the maximum firing rate at the affected boiler (ID No. PS-C), but not later than 180
days after initial startup, the Permittee shall conduct a Method 9 test (6-minute average of 24 observations) to
determine the opacity of stack emissions in accordance with 40 CFR 60.45c(a)(8) and 40 CFR 60.8. All testing
notifications and reports shall be submitted in accordance with General Condition JJ of this permit. If the Permittee
fails to conduct the opacity observation or if the results of the test are above the applicable limit, the Permittee shall
be deemed in noncompliance with 15A NCAC 2D .0524. [40 CFR 60.45c(a)(8)J
Monitoring/Recordkeeping [15A NCAC 2Q .0508(t)]
e. The Permittee shall retain a record of the quantity of natural gas and No. 2 fuel oil fired at the affected boiler (ID No.
PS-C) each calendar month. The Permttee shall be deemed in noncompliance with 15A NCAC 2D .0524 if this
record is not created and retained. [49 CFR 60.48c(g)]
£ The Permittee shall retain a copy of the fuel supplier certification for any No. 2 fuel oil fired at the affected boiler
(ID No. PS-C). The fuel supplier certification shall include the following information:
i. The name of the oil supplier;
liee 'ulcer--
iii. A statement from the oil supplier that the oil complies with the specification under the defmition of distillate oil
in 40 CFR 60.41 c.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur content of the oil exceeds
the limit provided in Section 2.1.AA.b. of this permit or if fuel supplier certifications are not retained as described
above. [40 CFR 60.46c(e), 40 CFR 60.48c6q]
Initial Notification [15A NCAC 2Q .0508(f)]
g. The Permittee shall submit a construction notification of the date construction of the affected boiler (ID No. PS-C) is
commenced, postmarked no later than 30 days after such date. [40 CFR 60.7(a)(1)J
h. The Permittee shall submit an initial notification to the Regional Supervisor within 15 days of actual startup of the
affected boiler (ID No. PS-C). The notification shall include:
i. The actual date of initial startup; and,
ii. The design heat input capacity of the boiler and identification of fuels to be combusted in the boiler.
[40 CFR 60.48c(a), 40 CFR 60.7(a)(3)]
Reporting [15A NCAC 2Q .0508(f)]
The Permittee shall submit a semiannual summary report, acceptable to the Regional Air Quality Supervisor, of the
sulfur content of the distillate fuel oil fired, by January 30 of each calendar year for the preceding six-month period
between July and December and July 30 of each calendar year for the preceding six-month period between January
and June. The summary report shall include the following information:
i. Fuel supplier certification(s) for distillate fuel oil, as provided in Section 2.1.AA.e. of this permit;
I A certified statement signed by the owner or operator that the records of fuel supplier certification(s) submitted
represents all of the fuel fired at the affected boiler (ID No. PS-C) during the semiannual period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
DEQ-CFW 00068223

Perrnit 03735T35
Page 10
•
5. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the affected
boiler (ID No. PS-B only) shall discharge into the atmosphere less than the following, per consecutive 12-month
period.
Pollutant Emission Limitation
tons per ear
Nitrogen Oxide 40
Sulfur Dioxide 40
Testing [15A NCAC 2Q .2601)
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test are above the limit given in Section 2.1 A.5.a., the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0530.
MonitorinLY/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in mmscf) of natural gas fired at the affected boiler;
ii. The total quantity (in 1,000 gal) of No. 2 and No. 6 fuel oil fired at the affected boiler; and,
iii. The fuel oil supplier certification for any fuel oil fired at the affected boiler, including the sulfur content of the
fuel oil (in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the fuel usage and fuel oil
sulfur contents are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling NOx emissions from the affected boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (written or electronic format),
according to the following formulas:
i. Calculate NOx emissions from the previous calendar month using the following equation:
ENOx = 55 *Qfo6 +20*Qfo2 +100*Qng
Where, ENO, = NOx emissions (in lbs) during the previous calendar month;
Quantity of No. 6 fuel oil fired during the previous calendar month (in
1,000 gal);
Qro2 = Quantity of No. 2 fuel oil fired during the previous calendar month (in
1,000 gal); and,
Q„g = Quantity of natural gas fired during the previous calendar month (in
mmscf).
ii. Sum the NOx emissions from the affected boiler for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.1 A.5.a. of this permit.
e. The Permittee shall calculate monthly and 12-month rolling SO2 emissions from the affected boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (written or electronic format),
according to the following formulas:
i. Calculate SO2 emissions from the previous calendar month using the following equation:
DEQ-CFW 00068224

Permit 03735T35
Page 11
•
E S02 = 157 * Sfo6 *Qfo6 +142*Sfo2 *Qfo2 +0.6*Q,rg
Where, ES02 = SO2 emissions (in lbs) during the previous calendar month;
S fob = Sulfur content in the No. 6 fuel oil (in percent by weight); and,
S f02 = Sulfur content in the No. 2 fuel oil (in percent by weight).
ii. Sum the S02 emissions from the affected boiler for the previous 12-month period to determine the 12-month
rolling emission total.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
mo utori g_and—cordkeeping activ_itiea .postmarked on or before January 30 of each calendar year for the receding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly NOx and S02 emissions from the affected boiler for the previous 17 calendar months;
ii. The 12-month rolling NOx and S02 emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
B. Butacite® Process Area consisting of one butyraldehyde storage tank (ID No. BS-A)
controlled by a brine cooled condenser (ID No. BCD -A),
Four Butacite® flake reactors (ID Nos. BS-B1.1 through BS-B1.4) controlled by a packed -bed
scrubber (ID No. BCD-BI),
Four Butacite® flake reactors (ID Nos. BS-B2.1 through BS-B2.4) controlled by a packed -bed
scrubber (ID No. BCD-B2),
One Butacite® flake dryer (ID No. BS-C) controlled by a cyclone (ID No. BCD -CI) and fabric
filter (ID No. BCD-C2) and,
Butacite Line No. 3 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-El)
controlled by a water-cooled condenser (ID No. BCD-E1) (voluntary use only)
Butacite Line No. 4 Sheeting Extrusion Process, including four (4) extruders (ID No. BS-E2)
controlled by a water-cooled condenser (ID No. BCD-E2) (voluntary use only)
Butacite Line No. 3 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area (ID No. BS-E3)
Butacite® Line No. 4 Back -End Process, including a quencher, dryer/relaxer, and wind-up
area (ID No. BS-E4)
Butacite® PVA Unloading System and Storage Silos (ID No. BS-F)
Butacite® PVA Dissolver Tank System (ID No. BS-G) .
DEQ-CFW 00068225

Permit 03735T35
Page 12
•
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Source: BS-C, only
15A NCAC 2D .0515
for process rates less than 30 tons per hour -
E = 4. 10 X pO.67
Where:
E = allowable emission rate in pounds per hour, and
P = the process weight rate in tons per hour
Visible emissions
Affected Source: BS-C, only
15A NCAC 21) .0521
20% visible opacity emissions
Odors
State -enforceable only
Odorous arnissions must be Controlled
15A NCAC 2D .1806
Hazardous air
Recordkeeping requirements for each MCPU with
15A NCAC 2D .1111
pollutants
Group 2 batch process vents to demonstrate total HAP
(40 CFR 63, Subpart FFFF)
emissions less than 10,000 lbs/12-month.
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. BS-C) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xP0"'
Where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [ 15A NCAC 2D .2601 ]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 B.l .a. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 21) .0515.
Monitorine/Recordkeepin2 [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the Butacite® flake dryer (ID No. BS-C) shall be controlled by the bagfilter (ID
No. BCD-C2) and cyclone separator (ID No. BCD-Cl). To assure compliance, the Permittee shall perform
inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and
maintenance recommendations, or if there is no manufacturer's inspection and maintenance recommendations, as a
minimum, the inspection and maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii. An annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and bagfilters are not
inspected and maintained.
d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on -site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection;
iii. The results of any maintenance performed on the bagfilters; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained.
DEQ-CFW 00068226

Permit 03735T35
Page 13
2
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the bagfilters within 30 days of a written
request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. BS-C) shall not be more than 20 percent opacity when averaged
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
our an no more an our imes m a` ny 2�1- our peno n no event s a e six-rmnute average excee percent
opacity.
Testing [15A NCAC 2D .2601]
b—� ernisai�n�s testing is-required-4he-testingshall-be-pe-rfermed-in-aceordnnee with-13A-1C-AC--2D--2601-and-General
Condition JJ. If the results of this test are above the limit given in Section 2.1 13.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. If visible emissions from this source are observed to be above normal,
the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 13.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 21) .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
STATE -ENFORCEABLE ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
DEQ-CFW 00068227

Permit 03735T35
Page 14
b. CONDENSER REQUIREMENTS - Odorous emissions from the butyraldehyde storage tank (ID No. BS-A) shall
be controlled by a condenser (ID No. BCD -A). 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 results of the inspections and maintenance shall be recorded in a logbook
(either written or electronic).
SCRUBBER REQUIREMENTS - Gaseous emissions from the Butacite® flake reactor line (ID Nos. BS-B1.1
through BS-BIA) shall be controlled by packed column scrubber (ID No. BCD-B1). Gaseous emissions from the
Butacite flake reactor line (ID Nos. BS-B2.1 through BS-B2.4) shall be controlled by packed column scrubber (ID
No. BCD-B2).
d. INSPECTION AND MAINTANENCE 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. As a minimum, the inspection and maintenance program shall
include inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the
cleaning/calibration of all associated instrumentation.
e. MONITORING REQUIREMENTS - The Permittee shall ensure the proper performance of the Flake Reactor
Line's packed column scrubbers (ID Nos. BCD-B1 and BCD-B2) by monitoring the following operational
parameters:
i. Liquid flow rate (minimum of 8 gallons per minute averaged over a 3-hour period), and
ii. Differential pressure across the scrubber (maximum of 30 inches of water pressure averaged over a 3-hour
period), with a high differential pressure alarm.
f. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (written or electronic records) that shall be kept on site and made available to Division of Air Quality
personnel upon request. Any variance from the manufacturer's recommendations or the permit monitoring
requirements, or the failure of the air pollution control equipment to operate in a normal and usual manner, shall be
investigated with corrections made and dates of action recorded in the log book. The inspection and maintenance
activities, as well as required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate,
shall be recorded.
4. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT),
40 CFR 63, Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing (MON)
a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and
monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .1111,
"Maximum Achievable Control Technology" as promulgated in 40 CFR 63, Subpart FFFF, including Subpart A,
"General Provisions".
Recordkeepiniz [15A NCAC 2Q .0508(f)]
b. For each affected MPCU with a Group 2 Process Vent, including the Butacite PVA Unloading System and Storage
Silos (ID No. BS-F), the Butacite® PVA Dissolving System (ID Nos. BS-G), and the Butacite® Flake Reactor
System (ID Nos. BS-B1.1 through BS-B1.4 and BS-B2.1 through BS-B2.4), and the Butacite® Flake Dryer (ID
No. BS-C), the Permittee shall retain the following records:
i. A record of the day each batch was completed;
ii. A record of whether each batch operated was considered a standard batch;
iii. The estimated uncontrolled and controlled emissions for each batch that is considered to be a non-standard
batch; and,
iv. Records of the daily 365-day rolling summations of emissions, or alternative records that correlate to the
emissions (e.g., number of batches), calculated no less frequently than monthly.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
DEQ-CFW 00068228

Permit 03735T35
Page 15
•
retained, or if the total HAP emissions from either MCPU are 10,000 lbs or greater on a rolling 12-month basis. [40
CFR 63.2525(e)(4)]
c. For each affected Group 2 wastewater stream, the Permittee shall retain the following records:
i. MPCU identification and description;
ii. Stream identification code;
iii. Concentration of compounds listed in Table 8 and Table 9 of 40 CFR 63, Subpart FFFF (in ppmw), including
documentation of the methodology used to determine concentration; and,
iv. Stream flow rate (in L/min).
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
retained. [40 CFR 63.2585(a), 40 CFR 63.147(b)(8)]
C. Nafiono Process Area consisting of one hexfluoropropylene epoxide process (ID No. NS-A)
controlled by one baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2),
Two vinyl ethers processes (ID Nos. NS-B and NS-C) EACH controlled by one of two available
baffle-plate-s"ubb- er-s-(TD-No NCD=Rdr-l-or NCD=-H-1r2),
One RSU process (ID No. NS-D) controlled by one baffle -plate scrubber (ID No. NCD-Hdrl or
NCD-Hdr2),
One liquid waste stabilization process (ID No. NS-E) controlled by one baffle -plate scrubber
(ID No. NCD-Hdrl or NCD-Hdr2),
One MMF process (ID No. NS-F) controlled by one baffle -plate scrubber (I) No. NCD-Hdrl
or NCD-Hdr2),
One resins fluorination process (ID No. NS-G) controlled by a venturi vacuum jet scrubber (ID
No. NCD-G),
One Naflon® membrane process (ID No. NS-H),
One Naflon® membrane coating process (ID No. NS-I),
Three Naflon® semiworks processes (ID Nos. SW -I, SW-2, and NS-.n,
One E-2 Process (ID No. NS-K-),
One TFE/HCl separation unit (ID No. NS-L) controlled by one baffle -plate scrubber (ID No.
NCD-Hdrl or NCD-Hdr2), and
One uncontrolled TFE/CO2 separation unit (I) No. NS-M)
One HFPO product container decontamination process (ID No. NS-N)
One Vinyl Ethers North product container decontamination process (ID No. NS-O)
One Vinyl Ethers South product container decontamination process (ID No. NS-P)
T9,P fnllmvina tnhle nrnvirles n cnmmary of limits and ctandardc for the emission source(sl described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Sources: ID No. NS-I, only
15A NCAC 2D .0515
For process rates less than 30 tons per hour -
E = 4.10 pO.67
where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons per hour
Visible emissions
Affected Sources: ID No. NS-I, only
15A NCAC 2D .0521
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
DEQ-CFW 00068229

Permit 03735T35 Is
Page 16
�J
Regulated Pollutant
Limits/Standards
Applicable Regulation
Toxic air pollutants
State -enforceable only
15A NCAC 2D. 1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2 B.1. and 13.2.
Volatile organic
Affected Sources: ID No. NS-B, only
15A NCAC 2Q .0317
compounds
VOC emissions <68.9 tons per consecutive 12-month
(PSD Avoidance)
period
Affected Sources: ID No. NS-G, only
VOC emissions <40 tons per consecutive 12-month
period
Affected Sources: ID No. NS-A, only
period
Affected Sources: ID No. NS-N, only
VOC emissions <40 tons per consecutive 12-month
Hazardous air
Affected Sources: ID Nos. NS-A, NS-B, NS-C, and
15A NCAC 2D .1111
pollutants
NS-G
(40 CFR 63, Subpart FFFF)
LDAR, wastewater, and heat exchanger requirements..
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the affected source (ID No. NS-I) shall not exceed an allowable emission rate
as calculated by the following equation:
E=4.10xP""
Where: E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 C. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour, as specified by the
formulas contained above (or the formulas contained in 15A NCAC 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515 if the production records are not maintained or the types of materials and finishes are not
monitored.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the affected source (ID No. NS-I) shall not be more than 20 percent opacity when averaged
DEQ-CFW 00068230

Pemvt 03735T35
Page 17
over a six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testing [15A NCAC 21) .2601]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 C.2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 21) .0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
_ —ST-A- TE--ENFORCEABLE-ONLY - ---- --- - -- - -
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
- - - -- contributing -to obiec-tionahle-odors-beyond-the-faoihty's-boundary-
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the Vinyl Ethers North process (ID No. NS-B) shall discharge into
the atmosphere less than 68.9 tons of VOCs per consecutive 12-month period.
Testing [15A NCAC 2D .2601]
If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 CA.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 CA.a., within 30 days of the end of each calendar
month the Permittee shall create and retain production records and estimate associated VOC emissions for the
previous calendar month, as follows:
i. Using measured vent flow rates and assumed compositions, determine the process vent mass flow rates of non-
acid fluoride VOC (Q,,, ) and acid fluoride VOC (QAF) during the previous calendar month (in lb/month);
ii. Considering the 99.6% efficiency of the baffle -plate scrubber (ID No. NCD-Hdrl) to control acid fluoride
VOC, calculate the VOC emissions (Ev) from the process vents during the previous calendar month (in
lb/month) using the following equation:
EV = QnAF + 0.004(QAF
iii. Record the total solvents used (M) in the affected facility during the previous calendar month (in lb/month);
iv. Record the total solvent waste generation (W) for the affected facility during the previous calendar month (in
lb/month);
v. Calculate the solvent VOC emissions (Es) from the affected facility during the previous calendar month (in
lb/month) using the following equation:
ES = M - W
vi. Determine the VOC emissions from maintenance emissions (EM) during the previous calendar month.
vii. Calculate the VOC emissions from fugitive emissions (EF) using accepted practices during the previous calendar
month.
viii. Record VOC emissions from any accidental releases (EA) during the previous calendar month.
ix. Calculate the total process VOC emissions (E) using the following equation:
DEQ-CFW 00068231

Permit 03735T35
Page 18
•
E=EV +ES +EM +EF+EA
x. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC
emissions (E), as calculated in ix. above, for the previous consecutive 12-months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530
if the above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in x. above
exceeds the limit in Section 2.1 CA.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year or the a preceding six -Mont pit six-month
between January and June. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period; and,
—iii:—A-ll-instances-of-deviations-fi-omthe requirements--of-thispermit-must-be-ciearlyidentified: -- — -----
5. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the resins process (ID No. NS-G) shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Testing [ 15A NCAC 2D .2601 ]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.5.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
To demonstrate compliance with the limit provided in Section 2.1 C.5.a., within 30 days of the end of each calendar
month the Permittee shall create and retain production records and estimate associated VOC emissions for the
previous calendar month, as follows:
i. Record the total raw materials fed (M) to the affected facility during the previous calendar month (in kg/month);
ii. Record the total transformed materials collected (P) for the affected facility during the previous calendar month
(in kg/month);
iii. Record the total untransformed materials collected (W) for the affected facility during the previous calendar
month (in kg/month);
iv. Determine the VOC emissions from the filling of storage tanks (S) for the affected facility during the previous
calendar month;
v. Calculate the VOC emissions (E) from the affected facility during the previous calendar month (in lb/month)
using the following equation:
E=(M— P—W+S)*2.2
vi. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC
emissions (E), as calculated in iv. above, for the previous consecutive 12-months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530
if the above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in v. above
exceeds the limit in Section 2.1 C.5.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
DEQ-CFW 00068232

Permit 03735T35
Page 19
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
6. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the HFPO process (ID No. NS-A) shall discharge into the
atmosphere less than 85.3 tons of VOCs per consecutive 12-month period.
- T estme [1 5A NCAC 2D
.2 7i01 ]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 C.6.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeaing [15A NCAC 2Q .0508(f)]
To demonstrate compliance with the limit provided in Section 2.1 C.6.a., within 30 days of the end of each calendar
month the Permittee shall create and retain production records and estimate associated VOC emissions for the
previous calendar month, as follows:
i. Record the total raw material HFP consumed (MHFP) in the affected facility during the previous calendar month;
ii. Record the average vent flow rate and composition from the AF column (QAc) and Stripper columns (Qsc)
during the previous calendar month;
iii. Using a combination of ratios of vent rates (QAC and Qsc) to HFP consumption (MHFP) from the process
flowsheet and actual vent data, determine the process VOC emissions (EP) from the AF column (EAR), stripper
column (Esc), solvent recycle tank (EsRA and routine decontamination of HFP unloading system (EDC) through
the baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2).
EP - EAC + ESC + ESRT + EDC
iv. Calculate the VOC emissions through the baffle -plate scrubber (ID No. NCD-Hdrl or NCD-Hdr2) from
maintenance activity (EM) based on vessel volumes and vapor density for each occurrence of this activity during
the previous calendar month.
v. Calculate the VOC emissions from fugitive emissions (EF) using accepted practices during the previous calendar
month.
vi. Record VOC emissions from any accidental releases (EA) during the previous calendar month.
vii. Calculate the VOC emissions (E) from the affected facility during the previous calendar month (in lb/month)
using the following equation:
E . Ep + Em + EF + EA
viii. Calculate the 12-month rolling VOC emissions from the affected facility by summing the monthly VOC
emissions (E), as calculated in vii. above, for the previous consecutive 12-months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530
if the above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in viii.
above exceeds the limit in Section 2.1 C.6.a. of this permit.
Reporting [15A NCAC 2Q .0508(o]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
DEQ-CFW 00068233

Permit 03735T35
Page 20
r�
L-�
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
7. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the HFPO Product Container Decontamination Process (ID No. NS-
N) shall discharge into the atmosphere less than 40.0 tons of VOCs per consecutive 12-month period.
Monitorim/Recordkeeping [15A NCAC 2Q .0508(f)]
b. To demonstrate compliance with the limit provided in Section 2.1 C.7.a., within 30 days of the end of each calendar
month the Permittee shall create and retain records and estimate associated VOC emissions for the previous calendar
i. Create a record of each container received at the facility including:
(A) The date the container was decontaminated; and,
(B) The total mass of VOC released from the container (in lbs).
ri. Calculate-theAIOC—emissions frorrrthe preeess dari he�revi u-s-c-alendar-month-(ft"bhnonth)-by-su�ng----
the quantity of VOC released from each container decontaminated during the previous calendar month.
iii. Calculate the VOC emissions from the process during the previous consecutive 12-month period (in tons/12-
months) by summing the quantity of VOC released for the previous twelve (12) calendar months.
Required records shall be maintained in a logbook (written or electronic format) on -site and made available to an
authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530
if the above records are not created and retained, or if the 12-month rolling VOC emission rate calculated above
exceeds the limit in Section 2.1 C.7.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
c. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions from the affected facility for the previous 17 calendar months;
ii. The 12-month rolling VOC emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
8. 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MALT),
40 CFR 63, Subpart FFFF: NESHAP for Miscellaneous Organic Chemical Manufacturing (MON)
a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and
monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .1111,
"Maximum Achievable Control Technology" as promulgated in 40 CFR 63, Subpart FFFF, including Subpart A,
"General Provisions".
Operating Standards [15A NCAC 2Q .0508(f)]
b. Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to avoid unsafe
conditions. [40 CFR 63.2450(p)]
Equipment Identification & Special Designations [40 CFR 63.2480(a), 40 CFR 63.1022]
c. All equipment affected by these leak requirements shall be identified. Identification of the equipment does not
require physical tagging of the equipment. For example, the equipment may be identified on a plant site plan, in log
entries, by designation of process unit or affected facility boundaries by some form of weatherproof identification, or
by other appropriate methods. The following additional equipment identification requirements also apply:
i. Connectors need not be individually identified if all affected connectors in a designated area or length of pipe
are identified as a group, and the number of connectors subject is indicated.
DEQ-CFW 00068234

Permit 03735T35
Page 21
ii. Identify pressure relief devices equipped with upstream rupture disks, as described in 40 CFR 63.1030(e); and,
iii. The identity, either by list, location (area or group), or other method, of equipment in regulated material service
less than 300 hours per calendar year.
iv. Identify unsafe -to -monitor equipment, meeting the criteria provided in 40 CFR 63.1022(c)(1), an explanation
why the equipment is unsafe -to -monitor, and record the planned schedule for monitoring this equipment.
v. Identify difficult -to -monitor equipment, meeting the criteria provided in 40 CFR 63.1022(c)(2) , an explanation
why the equipment is difficult -to -monitor, and record the planned schedule for monitoring this equipment.
vi. Identify unsafe -to -repair equipment, meeting the criteria provided in 40 CFR 63.1022(d)(1) , an explanation why
the equipment is unsafe -to -repair.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if affected equipment is not identified
as required above. [40 CFR 63. 1038(b)]
d. If t e aci ity inc u es equipment esignate as:
i. Unsafe -to -monitor, create and implement a written plan that requires monitoring of the equipment as frequently
as practical during safe -to -monitor times, but not more frequently than the periodic monitoring schedule
otherwise applicable, and repair procedures that are consistent with the requirements of this permit.
' cu3t=ta-nianitor-, create-ancl ' 'ttenplan-tliat requilrrient-at per calendar calendar year and repair procedures that are consistent with the requirements of this permit.
The Permittee shall retain required written plans on -site, and make them available to NC DAQ for review upon
request. The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the required plans are not
created, implemented, and retained. [40 CFR 63. 1038(b)]
Equipment Leak Standards & Inspections [40 CFR 63.2480(a), 40 CFR 63, Subpart LTU]
Standards for Valves in Light Liquid, Gas and Vapor Service [40 CFR 63.1025]
e. The instrument reading that defines a leaking valve is 500 ppm or greater.
f. Instrument inspection. The Permittee shall monitor valves for leaks using the instrument monitoring methods
described in 40 CFR 63.1023(b)-(c) at the frequency specified below:
i. If at least the greater of 2 valves or 2% of the valves in a process unit leak, as calculated according to 40 CFR
63.1025(c), monitor each valve once per month.
ii. At process units with less than the greater of 2 leaking valves or 2% leaking valves, monitor each valve once
each calendar quarter, except as provided in iii., iv., or, v. below.
iii. At process units with less than 1 percent leaking valves, the Permittee may elect to monitor each valve once
every two quarters.
iv. At process units with less than 0.5 percent leaking valves, the Permittee may elect to monitor each valve once
every four quarters.
v. At process units with less than 0.25 percent leaking valves, the Permittee may elect to monitor each valve once
every 2 years.
The Permittee may choose to subdivide the valves in the applicable process units or groups of process units and
apply the provisions above to each subgroup. If the Permittee elects to subdivide the valves, it shall comply with the
provisions of 40 CFR 63.1025(b)(4). The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111
if it does not meet the requirements listed above.
g. The percentage of leaking valves, used to determine the required monitoring frequency above, shall be calculated
according to the procedures in 40 CFR 63.1025(c).
h. The Permittee shall create and retain a record of the monitoring schedule for each process unit. The Permittee shall
be deemed in non-compliance with 15A NCAC 2D .1111 if it does not keep this record. [40 CFR 63. 1025(b)(3)(vi),
40 CFR 63. 1038(c)(1)(i)]
i. If a leak is identified:
i. It shall be repaired as provided in the repair provisions of this section.
ii. After a leak has been repaired, the valve shall be monitored at least once within the first 3 months after its repair.
This requirement is in addition to the monitoring required to satisfy the definition of repaired and first attempt at
repair. The required periodic monitoring may be used if it satisfies the timing requirement of this condition. If a
DEQ-CFW 00068235

Permit 03735T35
Page 22
leak is detected by this follow-up monitoring, follow the provisions below to determine whether that valve must
be counted as a leaking valve:
(A) If the periodic monitoring was used to satisfy the follow-up monitoring requirement, then the valve shall be
counted as a leaking valve.
(B) If other monitoring is used satisfy the follow-up monitoring requirements, then the valve shall be counted as
a leaking valve unless it is repaired and shown by periodic monitoring not to be leaking.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the requirements
listed above.
j. Unsafe -to -monitor valves. Any valve that is designated unsafe -to -monitor is exempt from the monitoring and repair
requirements this section and the Permittee shall monitor the valve according to the written plan. The Permittee shall
be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet these requirements.
k. Difficult -to -monitor valves. Any valve that is designated as difficult -to -monitor is exempt from the monitoring
requirements of this section and the Permittee shall monitor the valve according to the written plan. lhePernuttee
shall be deemed in non-compliance with 15A NCAC 21) .1111 if it does not meet these requirements.
Standards for Pumps in Light Liquid Service [40 CFR 63.1026]
1. The Uilstiunient eadingthat diefines a lealk-un punip is 1,000 ppin or greater. Repair is not required unless an
instrument reading of 2,000 ppm or greater is detected.
m. Visual inspection. Each pump shall be checked by visual inspection each calendar week for indications of liquids
dripping from the pump seal. The visual inspection shall be consistent with the methods described in 40 CFR
63.1023(d). Document that the inspection was conducted and the date of the inspection. If are indications of liquids
dripping from the pump seal at the time of the weekly inspection, follow either of the following procedures:
i. Conduct instrument monitoring of the pump using the methods described in 40 CFR 63.1023(b)-(c). If the
instrument reading indicates a leak (1,000 ppm), it shall be repaired as provided in the repair provisions of this
section unless the reading is less than 2,000 ppm; or
ii. Eliminate the visual indications of liquids dripping.
The Permittee shall document each visual pump inspection. The Permittee shall be deemed in non-compliance with
15A NCAC 21) .1111 if it does not monitor and repair pumps as listed above. [40 CFR 63.1026(b)(4), 40 CFR
63.1038(c)(2)(i)]
n. Instrument inspection. The Permittee shall monitor affected pumps once per calendar month using the instrument
monitoring methods described in 40 CFR 63.1023(b)-(c). Leaks shall be repaired as provided in the repair
provisions of this section. The Permittee shall be deemed in non-compliance with 15A NCAC 21) .1111 if it does
not monitor and repair pumps as required above.
o. Unsafe -to -monitor pumps. Any pump that is designated as unsafe -to -monitor is exempt from the inspection
requirements provided above, and shall monitor and inspect the pump in accordance with the written plan. The
Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet these requirements.
Standards for Connectors in Gas and Vapor and Light Liquid Service [40 CFR 63.1027]
p. The instrument reading that defines a leaking connector is 500 ppm or greater.
q. Instrument inspection. The Permittee shall monitor connectors for leaks using the instrument monitoring methods
described in 40 CFR 63.1023(b)-(c). The required frequency of monitoring is based on the monitoring results from
the previous leak inspection, as provided below:
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then monitor within
12 months (1 year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but less than 0.5
percent, then monitor within 4 years. The Permittee may satisfy this requirement by monitoring at least 40
percent of the connectors within 2 years of the start of the monitoring period, provided all connectors have been
monitored by the end of the 4 year monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent, monitor at least 50 percent of the
connectors within 4 years of the start of the monitoring period and, based on the results of this inspection:
(A) If the percent leaking connectors detected is greater than or equal to 0.35 percent of the monitored
connectors, monitor all remaining connectors as soon as practical, but within the next 6 months. At the
DEQ-CFW 00068236

Permit 03735T35
Page 23
to
conclusion of monitoring, the new monitoring frequency shall be determined based on the percent leaking
connectors of the total monitored connectors.
(B) If the percent leaking connectors is less than 0.35 percent of the monitored connectors, monitor all
connectors that have not yet been monitored within 8 years of the start of the monitoring period.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not monitor and repair
connectors as listed above.
r. Create and retain a record of the monitoring schedule and the start date and end date of each monitoring period under
this section for each affected process unit. The Permittee shall be deemed in non-compliance with 15A NCAC 21)
.1111 if it does not keep these records. [40 CFR 63.1027(b)(3)(v), 40 CFR 63.1038(c)(2)(i)]
s. If a leak is identified:
i. It shall be repaired as provided in the repair provisions of this section.
ii. After a leak has been repaired, re -monitor the connector once within 90 days after repair to confirm that it is not
The Permittee shall be deemed in non-compliance with 15A NCAC 21) .1111 if leaks are not repaired as required
above.
t. Unsafe -to -monitor connectors. Any connector that is designated as unsafe -to -monitor is exempt from the monitoring
—and-repairrequ-irements this-seetion-and-the-Permlttee-s'��a�f, �onitor-he-eonnectorae ding - -The-
Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet these requirements.
Standards for Agitators in Gas and Vapor and Light Liquid Service [40 CFR 63.1028]
u. The instrument reading that defines a leaking agitator is 10,000 ppm or greater.
v. Visual inspection. Each agitator shall be checked by visual inspection each calendar week for indications of liquids
dripping from the agitator seal. The visual inspection shall be consistent with the methods described in 40 CFR
63.1023(d). Document that the inspection was conducted and the date of the inspection. If are indications of liquids
dripping from the agitator seal at the time of the weekly inspection, follow either of the following procedures:
i. Conduct instrument monitoring of the pump using the methods described in 40 CFR 63.1023(b)-(c). If the
instrument reading indicates a leak (10,000 ppm), it shall be repaired as provided in the repair provisions of this
section; or
ii. Eliminate the visual indications of liquids dripping.
The Permittee shall document each visual agitator inspection. The Permittee shall be deemed in non-compliance
with 15A NCAC 2D .1111 if it does not monitor and repair agitators as required above. [40 CFR 63.1028, 40 CFR
63.1038(c)(4)(i)]
w. Instrument inspection. The Permittee shall monitor affected agitator once per calendar month using the instrument
monitoring methods described in 40 CFR 63.1023(b)-(c). Leaks shall be repaired as provided in the repair
provisions of this section. The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not
monitor and repair agitators as required above.
Standards for Pressure Relief Valves [40 CFR 63.1030]
x. The instrument reading that defines a leaking pressure relief valve is 500 ppm or greater. This standard does not
apply during pressure releases as provided below. After each pressure release, the pressure relief device shall be
returned to a condition indicated by an instrument reading of less than 500 parts per million, as soon as practical, but
no later than 5 calendar days after each pressure release.
y. Instrument inspection. The pressure relief device shall be monitored no later than five calendar days after the
pressure release to confirm the condition indicated by an instrument reading of less than 500 parts per million above
background using the instrument monitoring methods described in 40 CFR 63.1023(b)-(c). Record the dates and
results of the monitoring including the background level measured and the maximum instrument reading measured.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not monitor and maintain
pressure relief valves as required above. [40 CFR 63.1038(c)(5)]
DEQ-CFW 00068237

Permit 03735T35
Page 24
I*
Equipment Leak Identification [40 CFR 63.2480(a)]
z. When a leak is detected using either sensory or instrument monitoring methods, a weatherproof and readily visible
identification shall be attached to the leaking equipment. The Permittee shall be deemed in non-compliance with
15A NCAC 2D .1111 if each detected leak is not identified as provided above. [40 CFR 63.1023(e)(1)]
aa. Leak identifications that are placed on leaking equipment may be removed as follows:
i. Leak identification on a valve in gas/vapor or light liquid service may be removed after it has been re -monitored
as required in this section, and no leak has been detected during that monitoring.
ii. Leak identification on a connector in gas/vapor or light liquid service may be removed after it has been re -
monitored as required in this section and no leak has been detected during that monitoring.
iii. Leak identification on other equipment may be removed after it is repaired.
[40 CFR 63.1024(c)]
Equipment Leak Repair [40 CFR 63.2480(a), 40 CFR 63, Subpart UU]
bb. The Permittee shall repair each leak detected as soon as practical, but not later than 15 calendar days after it is
detected, except where "Delay of Repair" or "Unsafe to Repair" provisions apply. A first attempt at repair shall be
made no latei than 5 calendit, days aftei the leak is deiected.
i. First attempt at repair for pumps includes, but is not limited to, tightening the packing gland nuts and/or ensuring
that the seal flush is operating at design pressure and temperature.
ii. First attempt at repair for valves includes, but is not limited to, tightening the bonnet bolts, and/or replacing the
bonnet bolts, and/or tightening the packing gland nuts, and/or injecting lubricant into the lubricated packing.
cc. Delay of repair. Delay of repair is allowed for any of the conditions listed below. The Permittee shall maintain a
record of the facts that explain any delay of repairs and, where appropriate, why the repair was technically infeasible
without a process unit shutdown.
i. Delay of repair is allowed if repair within 15 days after a leak is detected is technically infeasible without a
process unit or affected facility shutdown. Repair of this equipment shall occur as soon as practical, but no later
than the end of the next process unit or affected facility shutdown, except as provided in v. below.
ii. Delay of repair is allowed for equipment that is isolated from the process and that does not remain in regulated
material service.
iii. Delay of repair for valves, connectors, and agitators is also where:
(A) The Permittee determines that emissions of purged material resulting from immediate repair would be
greater than the fugitive emissions likely to result from delay of repair, and
(B) When repair procedures are effected, the purged material is collected and destroyed, collected and routed to
a fuel gas system or process, or recovered in a control device.
iv. Delay of repair for pumps is also allowed where:
(A) Repair requires replacing the existing seal design with a new system that the Permittee has determined
through a Quality Improvement Plan will provide better performance or:
(1) A dual mechanical seal system will be installed;
(2) A pump that meets the requirements of 40 CFR 63.1026(e)(2) will be installed; or
(3) A system that routes emissions to a process or a fuel gas system or a closed vent system and control
device will be installed; and
(B) Repair is completed as soon as practical, but not later than 6 months after the leak was detected.
v. Delay of repair beyond a process unit or affected facility shutdown will be allowed for a valve if valve assembly
replacement is necessary during the process unit or affected facility shutdown, and valve assembly supplies have
been depleted, and valve assembly supplies had been sufficiently stocked before the supplies were depleted.
Delay of repair beyond the second process unit or affected facility shutdown will not be allowed unless the third
process unit or affected facility shutdown occurs sooner than 6 months after the first process unit or affected
facility shutdown.
dd. Unsafe -to -repair connectors. Any connector that is identified as unsafe -to -repair is exempt from the leak repair
requirements of this permit.
DEQ-CFW 00068238

Permit 03735T35 46
Page 25
71
Equipment Leak Recordkeeping [40 CFR 63.2480(a), 40 CFR 63, Subpart UU]
ee. For each leak detected, the following information shall be recorded and maintained:
i. The date of first attempt to repair the leak.
ii. The date of successful repair of the leak.
iii. Maximum instrument reading measured by Method 21 of 40 CFR 60, Appendix A at the time the leak is
successfully repaired or determined to be non -repairable.
iv. 'Repair delayed" and the reason for the delay if a leak is not repaired within 15 calendar days after discovery of
the leak as specified below:
(A) The Permittee may develop a written procedure that identifies the conditions that justify a delay of repair.
In such cases, reasons for delay of repair may be documented by citing the relevant sections of the written
procedure.
e ay o repair was cause y ep e ion o s oc e pa s, ere mus e ocumen a ion a e spare pa s
were sufficiently stocked on -site before depletion and the reason for depletion.
v. Dates of process unit or affected facility shutdowns that occur while the equipment is unrepaired.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
—c-re-ated-and4eiained 444D-CC-R-63.-I-02W{e)o, 40 CFR 63.1024b%-��03&(bff-
ff. Create and retain the following general records:
i. General and specific equipment identification if the equipment is not physically tagged and the Permittee is
electing to identify the affected equipment through written documentation such as a log or other designation;
ii. Written plans for any equipment that is designated as unsafe- or difficult -to -monitor; and,
iii. A record of the identity and justification of any equipment that is designated as unsafe -to -repair.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
created and retained. [40 CFR 63. 1038(b)]
Heat Exchanger Requirements [15A NCAC 2Q .0508(f)]
gg. Prepare and implement a monitoring plan that documents the procedures that will be used to detect leaks of process
fluids into cooling water. The plan shall require monitoring of one or more surrogate indicators (e.g., pH,
conductivity, etc.) or monitoring of one or more process parameters or other conditions that indicate a leak. The plan
shall include the following:
i. A description of the parameter or condition to be monitored and an explanation of how the selected parameter or
condition will reliably indicate the presence of a leak;
ii. The parameter level(s) or conditions(s) that shall constitute a leak. This shall be documented by data or
calculations showing that the selected levels or conditions will reliably identify leaks. The monitoring must be
sufficiently sensitive to determine the range of parameter levels or conditions when the system is not leaking.
When the selected parameter level or condition is outside that range, a leak is indicated;
iii. The monitoring frequency which shall be no less frequent than monthly for the first 6 months and quarterly
thereafter to detect leaks;
iv. The records that will be maintained to document compliance with the requirements of this section.
If a substantial leak is identified by methods other than those described in the monitoring plan and the method(s)
specified in the plan could not detect the leak, revise the plan and document the basis for the changes no later than
180 days after discovery of the leak. Maintain a copy of the monitoring plan on -site. If the monitoring plan is
superseded, retain the most recent superseded plan at least until 5 years from the date of its creation. The Permittee
shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the above requirements. [40 CFR
63.2490, 40 CFR 63.104(c)]
hh. If a leak is detected in any heat exchanger system, it shall be repaired as soon as practical but not later than 45
calendar days after the Permittee receives results of monitoring tests indicating a leak, unless the Permittee
demonstrates that the results are due to a condition other than a leak. Once the leak has been repaired, the owner or
operator shall confirm that the heat exchange system has been repaired within 7 calendar days of the repair or startup,
whichever is later. The Permittee shall be deemed in non-compliance with 15A NCAC 2D .I 111 if it is not repaired
as required above, except where it applies the delay of repair provisions. [40 CFR 63.2490, 40 CFR 63.104(d)]
DEQ-CFW 00068239

Permit 03735T35
Page 26
•
ii. Delay of repair of heat exchange systems is allowed if the equipment is isolated from the process. Delay of repair is
also allowed if repair is technically infeasible without a shutdown and any one of the conditions listed in 40 CFR
63.104(e)(1)-(2) is met. [40 CFR 63.2490, 40 CFR 63.104(e)]
jj. For each affected heat exchanger system, the Permittee shall retain the following records:
i. Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not to be a leak, the
basis for that determination;
ii. Records of any leaks detected by procedures other than those provided in the written plan, including the date the
leak was discovered;
iii. The dates of efforts to repair leaks; and,
iv. The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
retained. [40 CFR 63.2490, 40 CFR 63.104(fl]
Additional Recordkeeping [15A NCAC 2Q .0508(f)]
kk. Create and retain the following records on each affected MCPU:
i. A description of the process and the type of process equipment used;
emissions episodes), wastewater points of
determination (PODS), and storage tanks;
iii. The applicable control requirements pursuant to 40 CFR 63, Subpart FFFF, including the level of required
control, and for vents, the level of control for each vent;
iv. The control device or treatment process used, as applicable, including a description of operating and/or testing
conditions for any associated control device;
v. The process vents, wastewater POD, transfer racks, and storage tanks (including those from other processes) that
are simultaneously routed to the control device or treatment process;
vi. The applicable monitoring requirements of this subpart and any parametric level that assures compliance for all
emissions routed to the control device or treatment process; and,
vii. Calculations and engineering analyses required to demonstrate compliance.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the above records are not retained.
11. Create and retain a record of each time a safety device is opened to avoid unsafe conditions. The Permittee shall be
deemed in non-compliance with 15A NCAC 2D .1111 if this record is not retained.
mm. For each affected Group 2 wastewater stream, the Permittee shall retain the following records:
i. MPCU identification and description;
ii. Stream identification code;
iii. Concentration of compounds listed in Table 8 and Table 9 of 40 CFR 63, Subpart FFFF (in ppmw), including
documentation of the methodology used to determine concentration; and,
iv. Stream flow rate (in L/min).
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the records listed above are not
retained. [40 CFR 63.2585(a), 40 CFR 63.147(b)(8)]
Process Changes [15A NCAC 2Q .0508(f)]
nn. If a Group 2 emission point becomes a Group 1 emission point, the Permittee must be in compliance with the Group
1 requirements beginning on the date the switch occurs. An initial compliance demonstration as specified in 40 CFR
63, Subpart FFFF must be conducted within 150 days after the switch occurs. The Permittee shall be deemed in non-
compliance with 15A NCAC 2D .1111 if it does not meet these requirements. [40 CFR 63.2445(d)]
Reporting [15A NCAC 2Q .0508(i)]
oo. The Permittee shall submit a semi-annual compliance report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before February 28 of each calendar year for the preceding
six-month period between July and December, and August 31 of each calendar year for the preceding six-month
period between January and June. The report shall contain the following:
i. Company name and address;
DEQ-CFW 00068240

Permit 03735T35
Page 27
•
ii. Statement by a responsible official with that official's name, title, and signature, certifying the accuracy of the
content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard specified in this
subpart, include a statement that there were no deviations from the emission limits, operating limits, or work
practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the following
information:
(A) The total operating time of the affected source during the reporting period; and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if applicable), as
applicable, and the corrective action taken.
vi. Identify each new operating scenario which has been operated since the time period covered by the last
comp lance report an as not een su mttte m t e previous comp lance report. or t e purposes o t is
paragraph, a revised operating scenario for an existing process is considered to be a new operating scenario;
vii. For the equipment listed below, report in a summary format by equipment type, the number of components for
which leaks were detected and for valves, pumps and connectors show the percent leakers, and the total number
f re . ed,—
and for valves and connectors, identify the number of components that are determined to be non -repairable as
described in 40 CFR 63.1025(c)(3).
(A) Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D) Agitators in gas and vapor service and in light liquid service.
viii. Where any delay of repair for leaks is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted within the
semiannual reporting period.
x. Report, if applicable, the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair, include the
following information:
(A) the presence of the leak and the date that the leak was detected
(B) whether or not the leak has been repaired
(C) the reason(s) for delay of repair
(D) If the leak is repaired, the owner or operator shall report the date the leak was successfully repaired.
(E) If the leak remains unrepaired, the expected date of repair.
D. Polymer Processing Aid Process (ID No. AS -A) controlled by a wet scrubber (ID No. ACD-Al)
and a building exhaust vent wet scrubber (ID No. ACD-A3) (voluntary use only)
The followinfa, table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
15A NCAC 2D .1806
ddorous emissions must be controlled
Toxic air pollutants
State -enforceable only
15A NCAC 2D .1100
Permit limits for toxic air pollutants shall not be
exceeded. See Section 2.2.A and B.
STATE -ENFORCEABLE ONLY
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
DEQ-CFW 00068241

Permit 03735T35
Page 28
E
contributing to objectionable odors beyond the facility's boundary.
STATE -ENFORCEABLE ONLY
2. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. SCRUBBER REQUIREMENTS - Gaseous and mist emissions from the APFO process area shall be controlled by
a wet scrubber (ID No. ACD-Al). The Permittee shall ensure the proper performance of the scrubber by monitoring
the following operational parameters:
i. Liquid flow rate through the packed bed section (minimum of 30 gallons per minute averaged over a 3-hour
period), and
ii. Differential pressure across the packed bed section of the scrubber (maximum of 12 inches of water pressure
averaged over a 3-hour period), with a high differential pressure alarm.
b. PING REQU11% MENTS - e Pertnittee shall record a results of inspections in a scrubber
logbook (written or electronic records), which shall be kept on site and made available to Division of Air Quality
personnel upon request. Any variance from the manufacturer's recommendations or the permit monitoring
requirements, or the failure of the air pollution control equipment to operate in a normal and usual manner, shall be
investigated with cor-reetions ado ra awto of a .r;., rd.ed i the 1., book -The e
activities, as well as required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate,
shall be recorded.
E. Wastewater Treatment Area consisting of an extended aeration biological wastewater
treatment facility (ID No. WTS-A) and two indirect steam -heated rotary sludge dryers
(ID Nos. WTS-B and WTS-C) controlled by a wet scrubber with mist eliminator (ID No.
WTCD-1)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
State -enforceable only
odorous emissions must be controlled
15A NCAC 2D .1806
STATE ENFORCEABLE ONLY
1. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
SCRUBBER REQUIREMENTS - Odorous emissions from the wastewater treatment sludge dryers (ID Nos.
WTS-B and WTS-C) shall be controlled by an impingement -type scrubber with caustic injection (ID No.
WTCD-1).
c. INSPECTION AND MAINTANENCE 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. As a minimum, the inspection and maintenance program shall
include inspection of spray nozzles, packing material, chemical feed system (if so equipped), and the
cleaning/calibration of all associated instrumentation.
d. RECORDKEEPING REQUIREMENTS - The Permittee shall record the results of inspections in a scrubber
logbook (written or electronic records) that shall be kept on site and made available to NC-DAQ personnel upon
request. Any variance from the manufacturer's recommendations or the permit monitoring requirements, or the
failure of the air pollution control equipment to operate in a normal and usual manner, shall be investigated with
corrections made and dates of action recorded in the log book. The inspection and maintenance activities, as well as
DEQ-CFW 00068242

Permit 03735T35 0
Page 29
required monitoring for scrubbing liquid flow rates, and scrubber pressure drops, if appropriate, shall be recorded.
F. Temporary Boiler (ID No. PS -Temp), Natural Gas/No. 2 fuel oil -fired (greater than 30.0 and
less than 100.0 million Btu per hour maximum heat input)
The followinQ table Provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulations
Particulate Matter
0.2426 pounds of particulate per million Btu
15A NCAC 2D .0503
Sulfur Dioxide
0.5 percent sulfur content fuel
15A NCAC 2D .0524
NSPS (40 CFR 60, Subpart Dc)
Visible Emissions
20 percent opacity
15A NCAC 2D .0524
NSPS (40 CFR 60, Subpart Dc
Sulfur Dioxide
Less than 40 tons per consecutive twelve-month period.
15A NCAC 2Q .0317
PSD Avoidance)
Sulfur Dioxide
Affected Sources: PS -A, PS-B, PS-C, and PS -Temp
15A NCAC 2Q .0317
Sulfur dioxide <702.5 tons per year.
See Section 2.2. A.1. of this permit
(PSD Avoidance)
Ll
1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS
a. Emissions of particulate matter discharged into the atmosphere from the combustion of No. 2 fuel oil at the
temporary boiler (ID No. PS -Temp) shall not exceed 0.2426 pounds per million Btu heat input.
Testing [15A NCAC 2D .2601]
b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the results of
this test are above the limit given in Section 2.1 F. La. above, the Permittee shall be deemed in noncompliance with
15A NCAC 2D .0503.
Monitorin2/Recordkeenin2/Reportin2 [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of No. 2 fuel oil in this
source for this regulation.
2. 15A NCAC 2D .0524: NSPS 40 CFR 60, Subpart Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and
monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524
"New Source Performance Standards (NSPS) as promulgated in 40 CFR 60, Subpart Dc, including Subpart A
"General Provisions."
Emission Limitations [15A NCAC 2D .0524]
b. The maximum sulfur content of any fuel oil received and burned in the boiler (ID No. PS -Temp) shall not exceed
0.5 percent by weight.
c. Visible emissions shall not exceed 20 percent opacity (6 minute average) except for one six -minute period per hour
but not more than 27 percent opacity when firing fuel oil.
Testin [15A NCAC 2D .0524]
d. Within 60 days of installing any temporary boiler, the Permittee shall conduct a Method 9 test (6-minute average of
24 observations) to determine the opacity of stack emissions in accordance with 40 CFR 60.8, 40 CFR 60.45c(a)(8),
and General Condition JJ found in Section 3 of this permit. If the Permittee fails to conduct the opacity observation
or if the results of the test are above the applicable limit, the Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0524.
DEQ-CFW 00068243

Permit 03735T35
Page 30
C;
Monitoring/Recordkeeping [ 15A NCAC 2Q .0508(f)]
The Permittee shall retain a record of the quantity of natural gas and No. 2 fuel oil fired at the affected boiler each
calendar month. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if this record is not
created and retained. [49 CFR 60.48c(g)]
The Permittee shall retain a copy of the fuel supplier certification for any No. 2 fuel oil fired at the affected boiler.
The fuel supplier certification shall include the following information:
i. The name of the oil supplier;
ii. The sulfur content of the oil (in % by weight); and,
iii. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil
in 40 CFR 60.41 c.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur content of the orl excee s
the limit provided in Section 2.1 F.2.b. of this permit or if fuel supplier certifications are not retained as described
above. [40 CFR 60.46c(d), 40 CFR 60.48c(f)J
Notifications and eporting-f 1 8(
g. The Permittee shall submit the following written notifications to the Regional:
i. An initial notification of the date of actual initial startup of the boiler within 15 days of such date [40 CFR
60.7(a)(1)];
ii. An opacity observation notification indicate the anticipated date that the Permittee will be conducting the
Method 9 opacity observation, as required in Section 2.1 F.2.d. of this permit, at least 30 days prior to such date
[40 CFR 60.7(a)(6), 40 CFR 60.8(d)]; and,
iii. Performance test results with the results of the Method 9 opacity observation, as required in Section 2.1 F.2.d. of
this permit, shall be submitted within 30 days of the test.
h. Semiannual Report. In addition to any other reporting required by 40 CFR 60.48c or notification requirements to
the EPA, the Permittee is required to provide a semiannual summary report, acceptable to the Regional Air Quality
Supervisor, of the sulfur content of the distillate fuel oil fired, by January 30 of each calendar year for the preceding
six-month period between July and December and July 30 of each calendar year for the preceding six-month period
between January and June. The summary report shall include the following information:
i. Fuel supplier certification(s) for distillate fuel oil, as provided in Section 2.1 F.2.d. of this permit;
ii. A certified statement signed by the owner or operator that the records of fuel supplier certification(s) submitted
represents all of the fuel fired at the affected boiler during the semiannual period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
3. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications, the temporary
boiler (ID No. PS -Temp) shall discharge into the atmosphere less 40 tons of sulfur dioxide per consecutive twelve-
month period.
Testing [ 15A NCAC 2D .2601 ]
b. If emissions testing is required, the testing shall be performed in accordance with 15A General Condition JJ. If the
results of this test are above the limits given in Section 2.1 F.3.a. (ID No. PS -Temp) above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in 1,000 gal) of No. 2 fuel oil fired at the boiler; and,
ii. The fuel oil supplier certification for any fuel oil fired at the boiler, including the sulfur content of the oil (in
percent by weight).
DEQ-CFW 00068244

Permit 03735T35
Page 31
0
The Permttee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the fuel usage and No. 2
fuel oil sulfur content are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling SO2 emissions from the temporary boiler within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (written or electronic format),
according to the following formulas:
i. Calculate SO2 emissions from the previous calendar month using the following equation:
ES02=142*S*Qfo2
Where, Es02 = S02 emissions (in lbs) during the previous calendar month,
= C„lfiontgnt in the No._i fuel of ( t by weighty and
-' .C�er6ell T'� s 7
Qfo2 = Quantity of No. 2 fuel oil fired at the temporary boiler during the
previous calendar month (in 1,000 gal)
ii Sum the SO, emissions from the boiler for the previous 12-month period to determine the 12-month rolling
emission total.
The Pernttee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.1 F.3.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly S02 emissions from the boiler for the previous 17 months;
ii. The total SO2 emissions from the boiler for each 12-month period ending during the six month reporting period;
and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
G. SentryGlas® Process (ID No. SGS-A)
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Visible emissions
20% visible opacity emissions
15A NCAC 2D .0521
Odors
State -enforceable only
Odorous emissions must be controlled
15A NCAC 2D. 1806
1. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from this source (ID No. SGS-A) shall not be more than 20 percent opacity when averaged over a
six -minute period. However, six -minute averaging periods may exceed 20 percent not more than once in any hour
and not more than four times in any 24-hour period. In no event shall the six -minute average exceed 87 percent
opacity.
Testing [ 15A NCAC 2D .2601 ]
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 G. La. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
DEQ-CFW 00068245

Permit 03735T35
Page 32
Monitoring/Recordkeening/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from this source.
STATE -ENFORCEABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
H. Polyvinyl Fluoride Process No. 1 (ID No. FS-B)
Polyvinyl Fluoride Process No. 2 (ID No. FS-Q
The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Affected Source: Product Collection Systems
15A NCAC 2D .0515
for process rates less than 30 tons per hour -
E = 4.10 pO.61
Where:
E = allowable emission rate in pounds per hour, and
P = process weight rate in tons per hour
Visible emissions
Affected Source: Product Collection Systems
15A NCAC 2D .0521
(Vents FEP-B4 & FEP-C4)
20% visible opacity emissions
Odors
State -enforceable only
15A NCAC 2D .1806
Odorous emissions must be controlled
Volatile organic
Less than 40 tons per consecutive 12-month period
15A NCAC 2Q .0317
compounds
(PSAvoidance)
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the Product Collection Systems at the polyvinyl fluoride processes (Vent Nos.
FEP-B4 & FEP-C4) shall not exceed an allowable emission rate as calculated by the following equation:
E=4.1OxP0.67
Where E = allowable emission rate in pounds per hour
P = process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 21) .2601]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If the results
of this test are above the limit given in Section 2.1 H. La. above, the Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour, as specified by the
formulas contained above (or the formulas contained in 15A NCAC 2D .0515) can be derived, and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance
with 15A NCAC 21) .0515 if the production records are not maintained.
DEQ-CFW 00068246

Permit 03735T35
Page 33
•
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations from the
requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the Product Collection Systems at the polyvinyl fluoride processes (Vent Nos. FEP-B4 &
FEP-C4) shall not be more than 20 percent opacity when averaged over a six -minute period. However,•six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-
hour period. In no event shall the six -minute average exceed 87 percent opacity.
es in
b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .2601 and General
Condition JJ. If the results of this test are above the limit given in Section 2.1 H.2.a. above, the Pernuttee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring [15A NCAC 2Q .0508(f)]
To assure compliance, once a month the Permittee shall observe the emission point of the affected source for any
visible emissions above normal. The monthly observation must be made for each month of the calendar year period
to ensure compliance with this requirement. If visible emissions from this source are observed to be above normal,
the Permittee shall either:
i. Take appropriate action to correct the above -normal emissions as soon as practicable and within the monitoring
period and record the action taken as provided in the recordkeeping requirements below, or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A
NCAC 2D .2601 (Method 9) for 12 minutes is below the limit given in Section 2.1 H.2.a. above.
If the above -normal emissions are not corrected per (i) above or if the demonstration in (ii) above cannot be made,
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on -site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to be in
noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of each calendar year for
the preceding six-month period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
STATE -ENFORCEABLE ONLY
3. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the above listed equipment without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or
contributing to objectionable odors beyond the facility's boundary.
DEQ-CFW 00068247

Permit 03735T35
Page 34
0
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the Polyvinyl Fluoride (PVF) Process No. 1 and No. 2 (ID Nos. FS-
B and FS-C) shall discharge into the atmosphere less than 40 tons of VOCs per consecutive 12-month period.
Testin [15A NCAC 2D .2601]
b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.1 HA.a. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitorin2/Recordkeeping [15A NCAC 2Q .0508(f)]
c. To demonstrate compliance with the limit provided in Section 2.1 HA.a., within 30 days of the end of each calendar
month the Pernuttee s a create an retain pro uctron recor s an estrmate associate -VOA ssrons or t e
previous calendar month, as follows:
i. Record the vent flow rates from the Analytical Equipment (QFEP_BI and QFEP_C1) at the two affected facilities
(Vent Nos. FEP-B 1 and FEP-C1 respectively) during the previous calendar month (in lb/month);
— ii.--Calcuiate-the-VOC emissions-(�Bclfrorn-tire-Analytical-Equipment-at-two-df€eeted-€aeilities-during tb
previous calendar month (in lb/month) using the following equation:
EFEP-BCI = QFEP-B1 + QFEP-CI
iii. Record the vent flow rates from the Maintenance Headers (QFEP-B2 and QFEP-C2) at the two affected facilities
(Vent Nos. FEP-B2 and FEP-C2 respectively) during the previous calendar month (in lb/month);
iv. Calculate the VOC emissions (EFEP.BC2) from the Maintenance Header at two affected facilities during the
previous calendar month (in lb/month) using the following equation:
EFEP-BC2 - 0.5\QFEP-B2 + QFEP-C2 /
v. At least once each hour, record the pressure (PFEP_s3 and PFEP.C3) in the Low Pressure Slurry Separators at the
two affected facilities (Vent Nos. FEP-B3 and FEP-C3 respectively) during the previous calendar month (in
psig);
vi. At least once each hour, record the vinyl fluoride flow rates (QFEP-B3 and QFEP-C3) to the PVF Reactors at the two
affected facilities (Vent Nos. FEP-B3 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
vii.. Using an emissions model based on vapor pressure equilibrium data and vinyl fluoride flow rates to the PVF
Reactors, determine the hourly VOC emissions (EFEP-133 and EFEP_cs) from the Flash Tank vents at the two
affected facilities (Vent Nos. FEP-133 and FEP-C3 respectively) during the previous calendar month (in lb/hour);
viii. Calculate the sum of the hourly VOC emissions (EFEP-BC3) from the Flash Tanks at the two affected facilities
during the previous calendar month (in lb/month) using the following equation:
EFEP-BC3 - I \EFEP-B3 / + Z (EFEP-C3 )
ix. Calculate the VOC emissions (E) from the two affected facilities during the previous calendar month (in
lb/month) using the following equation:
E = EFEP-BC] + EFEP-BC2 + EFEP-BC3
x. Calculate the 12-month rolling VOC emissions from the two affected facilities by summing the monthly VOC
emissions (E), as calculated in x. above, for the previous consecutive 12-months.
The first required monthly compliance demonstration, as described in i. through x. above, shall be required during
the calendar month followin the initial start-up of Polyvinyl Fluoride Process No. 2 (ID No. FS-C). Required
DEQ-CFW 00068248

Permit 03735T35
Page 35
L�
records shall be maintained in a logbook (written or electronic format) on -site and made available to an authorized
representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the
above records are not created and retained, or if the 12-month rolling VOC emission rate calculated in x. above
exceeds the limit in Section 2.1 HA.a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly VOC emissions from two affected polyvinyl fluoride processes for the previous 17 calendar
months;
ii. -Th—e T2 month ro mg emissions or eac r�mont perio en mg during t ie repo mg perio , an ,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions -
A. BOILERS:
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS -A), 139.4 million Btu per hour
maximum heat input;
Natural Gas No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-B), 88.4 million Btu per hour
maximum heat input;
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-C) equipped with a low-NOx burner, 97.0
million Btu per hour maximum heat input; and,
Temporary Boiler (ID No. PS -Temp), Natural Gas/No. 2 fuel oil -fired (greater than 30.0 and
less than 100.0 million Btu per hour maximum heat input).
1. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS
for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation, the affected boilers (ID Nos. PS -A, PS-B, PS-C, and PS -Temp)
shall discharge into the atmosphere less than 702.5 tons of SOz per consecutive 12-month period.
Testing [15A NCAC 2D .2601 ]
If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If
the results of this test indicate annual emission rates in exceedance of the limit given in Section 2.2 A. La. above, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
The Permittee shall keep monthly records of fuel usage in a logbook (written or in electronic format), as follows:
i. The total quantity (in mmscf) of natural gas fired at the affected boilers;
ii. The total quantity (in 1,000 gal) of No. 2 and No. 6 fuel oil fired at the affected boilers; and,
iii. The fuel oil supplier certification for any fuel oil fired at the affected boilers, including the sulfur content of the
oil (in percent by weight).
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the fuel usage and fuel oil
sulfur contents are not created and retained as required above.
d. The Permittee shall calculate monthly and 12-month rolling SOZ emissions from the affected boilers within 30 days
after the end of each calendar month. Calculations shall be recorded in a logbook (s=mitten or electronic format),
according to the following formulas:
DEQ-CFW 00068249

Pernut 03735T35 •
Page 36
r]
i. Calculate S02 emissions from the previous calendar month using the following equation:
ES02 = 157 * Sfo6 *Qfo6 +142*Sfo2 *Qfo2 +0.6*Q„g
Where, ES02 =
S02 emissions (in lbs) during the previous calendar month;
S fob =
Sulfur content in the No. 6 fuel oil (in percent by weight);
Qfo6 =
Quantity of No. 6 fuel oil fired during the previous calendar month (in
1,000 gal);
S fo2 =
Sulfur content in the No. 2 fuel oil (in percent by weight);
Qfo2 =
Quantity of No. 2 fuel oil fired during the previous calendar month (in
1,000 gal); and,
ng
Quantity ofnatural gas fired 6W calendar month (in
mmscf).
ii. Sum the S02 emissions from the affected boilers for the previous 12-month period to determine the 12-month
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if records of the monthly calculations
listed above are not retained or if the 12-month rolling emission totals are greater than the emission limit provided in
Section 2.2 A.l .a. of this permit.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of
monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding
six-month period between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report shall contain the following:
i. The monthly S02 emissions from the two affected boilers for the previous 17 calendar months;
ii. The 12-month rolling S02 emissions for each 12-month period ending during the reporting period; and,
iii. All instances of deviations from the requirements of this permit must be clearly identified.
B. FACILITY -WIDE
STATE -ENFORCEABLE ONLY
1. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 213.1100 and in accordance with the approved application for an air toxic compliance
demonstration, the following permit limit shall not be exceeded:
Toxic Air Pollutant
Facility -Wide Emission Limit
Acetaldehyde
394.62 lb/hr
Acetic Acid
54.081b/hr
Acrolein
1.17 lb/hr
Acrylonitrile
240.061b/hr
Ammonia
39.46 lb/hr
Ammonium Chromate
0.54 lb/day
Ammonium Dichromate
0.54 lb/day
DEQ-CFW 00068250

Permit 03735T35
Page 37
•
Toxic Air Pollutant
Facility -Wide Emission Limit
Aniline
14.62 lb/hr
Arsenic and Inorganic Arsenic Compounds
0.37 lb/yr
Aziridine
5.261b/day
Benzene
192.05 lb/yr
Benzidine and Salts
0.02 lb/yr
Benzo(a)pyrene
52.81 lb/yr
enzy e one
7. 1 yr
Beryllium
6.56 lb/yr
Beryllium Chloride
6.56 lb/yr
Beryllium Fluoride
6.561b/yr
Beryllium Nitrate
6.56 lb/yr
Bis-Chloromethyl Ether
0.591b/yr
Bromine
2.92 lb/hr
1,3-Butadiene
272.07 lb/yr
Cadmium
8.8 lb/yr
Cadmium Acetate
8.8 lb/yr
Cadmium Bromide
8.81b/yr
Calcium Chromate
0.13 lb/yr
Carbon Disulfide
163.11 lb/day
Carbon Tetrachloride
10,723 1b/yr
Chlorine
13.15 lb/hr
32.88 lb/day
Chlorobenzene
1,929.23 lb/day
Chloroform
6,8821b/yr
Chloroprene
51.15 lb/hr
385.85 lb/day
Chromic Acid
0.541b/day
Chromium (VI)
0.13 lb/yr
Cresol
32.15 lb/hr
p-Dichlorobenzene
964.62 lb/hr
DEQ-CFW 00068251

Permit 03735T35 •
Page 38
0
Toxic Air Pollutant
Facility -Wide Emission Limit
Dichlorodifluoromethane
217,476.92 lb/day
Dichlorofluoromethane
438.46 lb/day
Di(2-ethylhexyle)phthalate
26.31 lb/day
Dimethyl Sulfate
2.63 lb/day
1,4-Dioxane
491.08 lb/day
Epichlorohydrin
132,832 lb/yr
Ethylcetate
2,046.15lb/hr
Ethylenediamine
36.541b/hr
263.08 lb/day
Ethylene Dichloride
6,081 lb/yr
Ethylene Glycol Monoethyl Ether
27.771b/hr
105.23 lb/day
Ethylene Oxide
43.21 lb/yr
Ethyl Mercaptan
1.461b/hr
Fluorides
3.651b/hr
14.031b/da
Formaldehyde
2.191b/hr
Hexachlorocyclopentadiene
0.15 lb/hr
0.531b/day
Hexachlorodibenzo-p-dioxin
0.121b/yr
n-Hexane
964.62 lb/day
Hexane Isomers
5,261.54 lb/hr
Hydazine
0.531b/day
Hydrogen Chloride
10.23 lb/hr
Hydrogen Cyanide
16.08 lb/hr
122.77 lb/day
Hydrogen Sulfide
30.691b/hr
Maleic Anhydride
1.46 lb/hr
10.52 lb/day
Manganese & Compounds
27.181b/day
Manganese Cyclopentadienyl Tricarbonyl
0.53 lb/day
Manganese Tefroxide
5.441b/day
DEQ-CFW 00068252

Permit 03735T35
Page 39
•
Toxic Air Pollutant
Facility -Wide Emission Limit
Mercury, Alkyl
0.05 lb/day
Mercury, Aryl & Inorganic
0.53 lb/hr
Mercury, vapor
0.53 lb/hr
Methyl Chloroform
3,580.77 lb/hr
10,523.08 lb/day
Methylene Chloride
24.85 lb/hr
38,409 lb/yr
Methyl Ethyl Ketone
1,293.46 lb/hr
> Y
Methyl Isobutyl Ketone
438.46 lb/hr
2,244.92 lb/day
Methyl Mercaptan
0.73 lb/hr
Nickel Carbonyl
0.53 lb/day
Nickel Metal
5.26 lb/day
Nickel, Soluble Compounds as Nickel
5.26 lb/day
Nickel Subsulfide
3.36 lb/yr
Nitric Acid
14.62 lb/hr
Nitrobenzene
7.31 lb/hr
52.62 lb/day
n-Nitrosodimethlamine
80.021b/yr
Pentachlorophenol
0.37 lb/hr
2.63 lb/day
Perchloroethylene
304,073 lb/yr
Phenol
13.88 lb/hr
Phosgene
2.19 lb/day
Phosphine
1.901b/hr
Polycholinated Biphenyls
132.83 lb/yr
Potassium Chromate
0.54 lb/day
Potassium Dichromate
0.54 lb/day
Sodium Chromate
0.54 lb/day
Sodium Dichromate
0.54 lb/day
Strontium Chromate
0.13 lb/yr
Styrene
154.92 lb/hr
DEQ-CFW 00068253

Permit 03735T35 41
Page 40
Toxic Air Pollutant
Facility -Wide Emission Limit
Sulfuric Acid
1.46 lb/hr
10.521b/day
Tetrachlorodibenzo-p-dioxin
0.0048 lb/yr
1, 1, 1,2-Tetrachloro-2,2-Difluoroethane
45,600 lb/day
1,1,2,2,-Tetrachloro-1,2-Difluoroethane
45,600 lb/day
1, 1, 1,2-Tetrachloroethane
10,082 lb/yr
Toluene
818.46 lb/hr
54 lb/day
Toluene-2,4-diisocyanate
0.22 lb/hr
0.441b/day
Trichloroethylene
94,423 lb/yr
Trichlorofluoromethane
491,076.92 lb/day
1,1,2-Trichloro-1,2,2-Triuoroethane
13,885 lb/hr
Vinyl Chloride
608.1 lb/yr
Vinylidene Chloride
105.23 lb/day
Xylene
950 lb/hr
2,367.69 lb/day
Zinc Chromate
0.13 lb/yr
Recordkeeping
b. For compliance purposes, the Penn ittee shall maintain records of production rates, throughput, material usage,
periods of excess emissions, failure of air pollution control equipment to operate in a normal and usual manner,
and other process operational information, that allows for evaluation for compliance with the toxic air pollutant
limits. These records shall be retained for a minimum of three years from the date of recording, and access to
these records shall be provided to the Division of Air Quality staff upon request.
Reporting
For compliance purposes, within thirty (30) days after each calendar year quarter the following shall be reported
to the Regional Supervisor, Division of Air Quality:
i. Any and all exceedences of applicable toxic air pollutant emission limits during the previous calendar year
quarter.
ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per hour.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants that have a listed emission rate in pounds per day.
iv. The yearly emission rate for the 12-month period ending with the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per year.
STATE -ENFORCEABLE ONLY
2. 15A NCAC 2D .1100: TOXIC AIR POLLUTANT EMISSIONS LIMITATIONS AND REQUIREMENTS
a. Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic compliance
demonstration, the following permit limit shall not be exceeded:
DEQ-CFW 00068254

Permit 03735T35
Page 41
•
Emission Source
Toxic Air Pollutant
Emission Limit
High dispersion stacks
Hydrogen Fluoride
7.28 lb/hr
(ID Nos. NEP-Hdr-1, NEP-Hdr-
52.45 lb/day
2, AEP-Al, and FEP-Al
All other sources
Hydrogen Fluoride
2.7 lb/hr
19.4 lb/day
Monitoring
b. The Permittee shall ensure the proper performance of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-I and NCD-Hdr-2) by monitoring the injection liquid flow rate (minimum of 7,000 kilograms per
hour, averaged over a 3-hour period).
Recordkeeping
c. The Permittee shall record the results of inspections of the Nafion Baffle Plate -Type Tower Scrubbers (ID Nos.
NCD-Hdr-1 and NCD-Hdr-2) in a scrubber logbook (written or electronic records) that shall be kept on site
and made available to Division of Air Quality--ersonnel upon request. Any variance from the manufacturer's
recommendations or the permit monitoring requirements, or the failure of the air pollution control equipment to
operate in a normal and usual manner, shall be investigated with corrections made and dates of action recorded
in the log book. The inspection and maintenance activities, as well as required monitoring for scrubbing liquid
flow rates, and scrubber pressure drops, if appropriate, shall be recorded.
d. The Permittee shall maintain records of production rates, throughput, material usage, periods of excess
emissions, failure of air pollution control equipment to operate in a normal and usual manner, and other process
operational information, that allows for evaluation for compliance with the toxic air pollutant limits. These
records shall be retained for a minimum of three years from the date of recording, and access to these records
shall be provided to the Division of Air Quality staff upon request.
Reporting
e. For compliance purposes, within thirty (30) days after each calendar year quarter the following shall be reported
to the Regional Supervisor, Division of Air Quality:
i. Any and all exceedences of applicable TAP emission limits during the previous calendar year quarter.
ii. The maximum pounds per 1-hour emission rate at any time during the previous calendar year quarter for all
applicable toxic air pollutants that have a listed emission rate in pounds per hour.
iii. The maximum pounds per 24-hour emission rate at any time during the previous calendar year quarter for
all applicable toxic air pollutants which have a listed emission rate in pounds per day.
STATE -ENFORCEABLE ONLY
3. 15A NCAC 2D .0541: CONTROL OF EMISSIONS FROM ABRASIVE BLASTING
a. The Permittee shall ensure that any abrasive blasting operation conducted outside a building or conducted
indoors and vented to the atmosphere is performed in accordance with the requirements set forth in 15A NCAC
2D .0521, Control of Visible Emissions. Any visible emissions reading for abrasive blasting performed outside
a building shall be taken at a spot approximately one meter above the point of abrasive blasting with a viewing
distance of approximately five meters.
b. All abrasive blasting operations shall be conducted within a building, except as provided in i. or ii. below. The
following abrasive blasting operations need not be conducted within a building:
i. Abrasive blasting of an item that exceeds eight feet in any dimension; or,
ii. Abrasive blasting of a surface situated at its permanent location or not fiirther away from its permanent
location than is necessary to allow the surface to be blasted.
c. Any abrasive blasting operation conducted outside a building, as provided in Section 2.2. B.3. b.i. or ii. above,
shall take appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting
DEQ-CFW 00068255

Permit 03735T35
Page 42
•
operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being
conducted, Appropriate measures include the following:
i. Addition of a suppressant to the abrasive blasting material;
ii. Wet abrasive blasting;
iii. Hydroblasting;
iv. Vacuum blasting;
v. Shrouded blasting; or
vi. Shrouded hydroblasting.
4. 40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK MANAGEMENT
PROGRAMS UNDER THE CLEAN AIR ACT, SECTION 112(r)" - The Permittee shall comply with all
applicable requirements in accordance with 40 CFR Part 68 including submitting a Risk Management Plan to EPA
pursuant to 4U CER Part,68.150prior to June , or as speci ie in art . .
DEQ-CFW 00068256

Permit 03735T35
Page 43
SECTION 3 - GENERAL CONDITIONS (version 3.1) This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 2Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in 15A NCAC 2D
and 2Q.
2. The terms, conditions, requirements, limitations, and restrictions set forth in this permit are binding and enforceable
pursuant to NCGS 143-215.114A and 143-215.114B, including assessment of civil and/or criminal penalties. Any
unauthorized deviation from the conditions of this permit may constitute grounds for revocation and/or enforcement
action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other aspects of the
facility which are not addressed in this permit
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare, animal or plant
life, or property caused by the construction or operation of this permitted facility, or from penalties therefore, nor does it
allow the Permittee to cause pollution in contravention of state laws or rules, unless specifically authorized by an order
from the North Carolina Environmental Management Commission.
5. Except as identified as state -only requirements in this permit, all terms and conditions contained herein shall be
enforceable by the DAQ, the EPA, and citizens of the United States as defined in the Federal Clean Air Act.
6. Any stationary source of air pollution shall not be operated, maintained, or modified without the appropriate and valid
permits issued by the DAQ, unless the source is exempted by rule. The DAQ may issue a permit only after it receives
reasonable assurance that the installation will not cause air pollution in violation of any of the applicable requirements.
A permitted installation may only be operated, maintained, constructed, expanded, or modified in a manner that is
consistent with the terms of this permit.
B. Permit Availability [15A NCAC 2Q .0507(k) and .0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the permit term one
complete copy of the application and any information submitted in support of the application package. The permit and
application shall be made available to an authorized representative of Department of Environment and Natural Resources
upon request.
C. Severability Clause [15A NCAC 2Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be invalid, the
provisions in this pen -nit are severable so that all requirements contained in the permit, except those held to be invalid, shall
remain valid and must be complied with.
D. Submissions [15A NCAC 2Q .0507(e) and 2Q .0508(i)(16)]
Except as otherwise specified herein, two copies of all documents, reports, test data, monitoring data, notifications, request
for renewal, and any other information required by this permit shall be submitted to the appropriate Regional Office. Refer to
the Regional Office address on the cover page of this permit. For continuous emissions monitoring systems (CEMS) reports,
continuous opacity monitoring systems (COMS) reports, quality assurance (QA)/quality control (QC) reports, acid rain CEM
certification reports, and NOx budget CEM certification reports, one copy shall be sent to the appropriate Regional Office
and one copy shall be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
All submittals shall include the facility name and Facility ID number (refer to the cover page of this permit).
DEQ-CFW 00068257

Permit 03735T35 10
Page 44
•
E. Duty to Comply [15A NCAC 2Q .0508(i)(2)]
The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit.
Noncompliance with any permit condition except conditions identified as state -only requirements constitutes a violation of
the Federal Clean Air Act. Noncompliance with any permit condition is grounds for enforcement action, for permit
termination, revocation and reissuance, or modification, or for denial of a permit renewal application.
Circumvention - STATE ENFORCEABLE ONLY
The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air
pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of
its associated air pollution control device(s) and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 2Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A NCAC 2Q
.0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 2Q .0524 and 2Q .0505]
e ee s u
.0505.
3. Minor Permit Modifications [15A NCAC 2Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC 2Q .0515.
4. Simmificant Permit Modifications [ 15A NCAC 2Q .0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A NCAC 2Q .0516.
5. Reopening for Cause [15A NCAC 2Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 2Q .0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s) listed in Section 1 must
be reported to the Regional Supervisor, DAQ:
a. Changes in the information submitted in the application;
b. Changes that modify equipment or processes; or
c. Changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the perni t
conditions. In no case are any new or increased emissions allowed that will cause a violation of the emission limitations
specified herein.
2. Section 502(b)(10) Changes [15A NCAC 2Q .0523(a)]
a. "Section 502(b)(10) changes" means changes that contravene an express permit term or condition. Such changes do
not include changes that would violate applicable requirements or contravene federally enforceable permit terms
and conditions that are monitoring (including test methods), recordkeeping, reporting, or compliance certification
requirements.
b. The Permittee may make Section 502(b)(10) changes without having the permit revised if:
i. The changes are not a modification under Title I of the Federal Clean Air Act;
ii. The changes do not cause the allowable emissions under the permit to be exceeded;
iii. The Pemuttee notifies the Director and EPA with written notification at least seven days before the change is
made; and
iv. The Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. A description of the change;
ii. The date on which the change will occur;
iii. Any change in emissions; and
iv. Any permit term or condition that is no longer applicable as a result of the change.
DEQ-CFW 00068258

Permit 03735T35 is
Page 45
1�1
d. Section 502(b)(10) changes shall be made in the permit the next time that the permit is revised or renewed,
whichever comes first.
3. Off Permit Changes [15A NCAC 2Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if:
a. The change affects only insignificant activities and the activities remain insignificant after the change; or
b. The change is not covered under any applicable requirement.
4. Emissions Trading [15A NCAC 2Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 2D, including subsequently adopted maximum
achievable control technology standards, emissions trading shall be allowed without permit revision pursuant to 15A
NCAC 2Q .0523(c).
I.A. Reporting Requirements for Excess Emissions and Permit Deviations
[15A NCAC 2D .0535(f) and 2Q .0508(f)(2)]
"Excess Emissions" - means an emission rate that exceeds any applicable emission limitation or standard allowed by any rule
in Sections .0500, .0900, .1200, or .1400 of Subchapter 21); or by a permit condition; or that exceeds an emission limit
established in a permit issued under 15A NCAC 2Q .0700. (Note: Definitions of excess emissions under 2D. 1110 and 2D
"Deviations" - for the purposes of this condition, any action or condition not in accordance with the terms and conditions of
this permit including those attributable to upset conditions as well as excess emissions as defined above lasting less than four
hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D
.1110 or .1111), or the operating permit provides for periodic (e.g., quarterly) reporting of excess emissions, reporting
shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 2D .0524), NESHAPS (15A NCAC 2D .1110 or .I 111), or these rules
do NOT define "excess emissions," the Permittee shall report excess emissions in accordance with 15A NCAC 2D .0535
as follows:
a. Pursuant to 15A NCAC 2D .0535, if excess emissions last for more than four hours resulting from a malfunction, a
breakdown of process or control equipment, or any other abnormal condition, the owner or operator shall:
i. Notify the Regional Supervisor or Director of any such occurrence by 9:00 a.m. Eastern Time of the Division's
next business day of becoming aware of the occurrence and provide:
• Name and location of the facility;
• Nature and cause of the malfunction or breakdown;
• Time when the malfunction or breakdown is first observed;
• Expected duration; and
• Estimated rate of emissions;
ii. Notify the Regional Supervisor or Director immediately when corrective measures have been accomplished;
and
iii. Submit to the Regional Supervisor or Director within 15 days a written report as described in 15A NCAC 2D
.0535(f)(3).
Permit Deviations
3. Pursuant to 15A NCAC 2Q .0508(f)(2), the Permittee shall report deviations from permit requirements (terms and
conditions) as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not covered under 15A
NCAC 2D .0535 quarterly. A written report to the Regional Supervisor shall include the probable cause of such
deviation and any corrective actions or preventative actions taken. The responsible official shall certify all
deviations from permit requirements.
I.B. Other Requirements under 15A NCAC 2D .0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 2D .0535, including 15A NCAC
DEQ-CFW 00068259

Permit 03735T35
Page 46
0
2D .0535(c) as follows:
1. Any excess emissions that do not occur during start-up and shut -down shall be considered a violation of the appropriate
rule unless the owner or operator of the sources demonstrates to the Director, that the excess emissions are a result of a
malfunction. The Director shall consider, along with any other pertinent information, the criteria contained in 15A
NCAC 2D .0535(c)(1) through (7).
2. 15A NCAC 2D .0535(g). Excess emissions during start-up and shut -down shall be considered a violation of the
appropriate rule if the owner or operator cannot demonstrate that excess emissions are unavoidable.
J. Emergency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the
facility, including acts of God, which situation requires immediate corrective action to restore normal operation, and that
causes the facility to exceed a technology -based emission limitation under the permit, due to unavoidab e increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by
improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such technology -based
emission limitations if the conditions specified in 3. below ait; met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous operating logs or
other relevant evidence that include information as follows:
a. An emergency occurred and the Permittee can identify the cause(s) of the emergency;
b. The permitted facility was at the time being properly operated;
c. During the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that
exceeded the standards or other requirements in the permit; and
d. The Permittee submitted notice of the emergency to the DAQ within two working days of the time when emission
limitations were exceeded due to the emergency. This notice must contain a description of the emergency, steps
taken to mitigate emissions, and corrective actions taken.
4. In any enforcement proceeding, the Permittee seeking to establish the occurrence of an emergency has the burden of
proof
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement specified
elsewhere herein.
K. Permit Renewal [15A NCAC 2Q .0508(e) and 2Q .0513(b)]
This permit is issued for a fixed term of five years for facilities subject to Title IV requirements and for a term not to exceed
five years in the case of all other facilities. This permit shall expire at the end of its term. Permit expiration terminates the
facility's right to operate unless a complete renewal application is submitted at least nine months before the date of permit
expiration. If the Permittee or applicant has complied with 15A NCAC 2Q .0512(b)(1), this permit shall not expire until the
renewal permit has been issued or denied. All terms and conditions of this permit shall remain in effect until the renewal
permit has been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense [15A NCAC 2Q .0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information (submittal of information) [15A NCAC 2Q .0508(i)(9)]
1. The Permittee shall fiunish to the DAQ, in a timely manner, any reasonable information that the Director may request in
writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to
determine compliance with the permit.
2. The Pernttee shall furnish the DAQ copies of records required to be kept by the permit when such copies are requested
by the Director. For information claimed to be confidential, the Permittee may furnish such records directly to the EPA
upon request along with a claim of confidentiality.
DEQ-CFW 00068260

Permit 03735T35 •
Page 47
N. Duty to Supplement [15A NCAC 2Q .0507(f)]
The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the
permit application, shall promptly submit such supplementary facts or corrected information to the DAQ. The Permittee shall
also provide additional information as necessary to address any requirement that becomes applicable to the facility after the
date a complete permit application was submitted but prior to the release of the draft permit.
O. Retention of Records [15A NCAC 2Q .0508(f) and 2Q .0508 (1)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five
years from the date of the monitoring sample, measurement, report, or application. Supporting information includes all
calibration and maintenance records and all original strip -chart recordings for continuous monitoring information, and copies
of all reports required by the permit. These records shall be maintained in a form suitable and readily available for
expeditiousinspection and review. Any records required by the conditions of this permit shall be kept on site and made
available to DAQ personnel for inspection upon request.
P. Compliance Certification [15A NCAC 2Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA (Air and EPCRA Enforcement Branch, EPA, Region 4, 61 Forsyth
> 1
a responsible official with all federally -enforceable terms and conditions in the permit, including emissions limitations,
standards, or work practices. It shall be the responsibility of the current owner to submit a compliance certification for the
entire year regardless of who owned the facility during the year. The compliance certification shall comply with additional
requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal Clean Air Act. The compliance
certification shall specify:
1. The identification of each term or condition of the permit that is the basis of the certification;
2. The compliance status (with the terms and conditions of the permit for the period covered by the certification);
3. Whether compliance was continuous or intermittent; and
4. The method(s) used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 2Q .0520]
A responsible official shall certify the truth, accuracy, and completeness of any application form, report, or compliance
certification required by this permit. All certifications shall state that based on information and belief formed after reasonable
inquiry, the statements and information in the document are true, accurate, and complete.
R. Permit Shield for Applicable Requirements [15A NCAC 2Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable requirements,
where such applicable requirements are included and specifically identified in the permit as of the date of permit
issuance.
2. A pen -nit shield shall not alter or affect:
a. The power of the Commission, Secretary of the Department, or Governor under NCGS 143-215.3(a)(12), or EPA
under Section 303 of the Federal Clean Air Act;
b. The liability of an owner or operator of a facility for any violation of applicable requirements prior to the effective
date of the permit or at the time of permit issuance;
c. The applicable requirements under Title IV; or
d. The ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain information to
determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit revision made
under 15A NCAC 2Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 2Q .0515.
S. Termination, Modification, and Revocation of the Permit [15A NCAC 2Q .0519]
The Director may terminate, modify, or revoke and reissue this permit if:
1. The information contained in the application or presented in support thereof is determined to be incorrect;
2. The conditions under which the permit or permit renewal was granted have changed;
DEQ-CFW 00068261

Permit 03735T35
Page 48
•
3. Violations of conditions contained in the permit have occurred;
4. The EPA requests that the permit be revoked under 40 CFR 70.7(g) or 70.8(d); or
5. The Director finds that termination, modification, or revocation and reissuance of the permit is necessary to carry out the
purpose ofNCGS Chapter 143, Article 21B.
T. Insignificant Activities [15A NCAC 2Q .0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is exempted from
any applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any
applicable requirement. The Permittee shall have available at the facility at all times and made available to an authorized
representative upon request, documentation, including calculations, if necessary, to demonstrate that an emission source or
activity is insignificant.
U. Property Rights [15A NCAC 2Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry [15A NCAC 2Q .0508(1) and NCGS 143-215.3(a)(2)]
s y require yaw, e emu ee s a a ow e , or
an authorized representative, to perform the following:
a. Enter the Permittee's premises where the permitted facility is located or emissions -related activity is conducted, or
where records are kept under the conditions of the permit;
b. Have access to and copy, at reasonable times, any records that are required to be kept under the conditions of the
permit;
c. Inspect at reasonable times and using reasonable safety practices any source, equipment (including monitoring and
air pollution control equipment), practices, or operations regulated or required under the permit; and
d. Sample or monitor substances or parameters, using reasonable safety practices, for the purpose of assuring
compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee under Section
114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for purposes of
inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such
authorized representative while in the process of carrying out his official duties. Refusal of entry or access may
constitute grounds for permit revocation and assessment of civil penalties.
W. Annual Fee Payment [15A NCAC 2Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 2Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C. Department of Environment and Natural
Resources. Annual permit fee payments shall refer to the permit number.
3. If, within 30 days after being billed, the Permittee fails to pay an annual fee, the Director may initiate action to terminate
the perni t under 15A NCAC 2Q .0519.
X. Annual Emission Inventory Requirements [15A NCAC 2Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 2Q
.0207(a) from each emission source within the facility during the previous calendar year. The report shall be in or on such
form as may be established by the Director. The accuracy of the report shall be certified by a responsible official of the
facility.
Y. Confidential Information [15A NCAC 2Q .0107 and 2Q. 0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 2Q .0107, the Permittee
may also submit a copy of all such information and claim directly to the EPA upon request. All requests for confidentiality
must be in accordance with 15A NCAC 2Q .0107.
DEQ-CFW 00068262

Permit 03735T35
Page 49
0
Z. Construction and Operation Permits [15A NCAC 2Q .0100 and .0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified facility or emission
source which is not exempted from having a permit prior to the beginning of construction or modification, in accordance with
all applicable provisions of 15A NCAC 2Q .0100 and .0300.
AA. Standard Application Form and Required Information [15A NCAC 2Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A NCAC 2Q .0505
and .0507.
BB. Financial Responsibility and Compliance History [15A NCAC 2Q .0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of substantial
compliance history.
CC. Refrigerant Requirements (Stratospheric Ozone and Climate Protection) [15A NCAC 2Q .0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment, which use Class I or 11
ozone -depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons listed as refrigerants in 40 CFR
the work practices, personnel certification requirements, and certified recycling and recovery equipment specified in 40
CFR Part 82 Subpart F.
2. The Permttee shall not knowingly vent or otherwise release any Class I or II substance into the environment during the
repair, servicing, maintenance, or disposal of any such device except as provided in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166. Reports shall be
submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases - Section 112(r) [15A NCAC 2Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section 112(r) of the
Clean Air Act, then the Permittee is required to register this plan in accordance with 40 CFR Part 68.
EE. Prevention of Accidental Releases General Duty Clause - Section 112(r)(1) -
FEDERALLY -ENFORCEABLE ONLY
Although a risk management plan may not be required, if the Permittee produces, processes, handles, or stores any amount of
a listed hazardous substance, the Permittee has a general duty to take such steps as are necessary to prevent the accidental
release of such substance and to minimize the consequences of any release.
FF. Title IV Allowances [15A NCAC 2Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Perrittee, but the Permittee may not use allowances
as a defense to noncompliance with any other applicable requirement. The Permittee's emissions may not exceed any
allowances that the facility lawfully holds under Title IV of the Federal Clean Air Act.
GG. Air Pollution Emergency Episode [15A NCAC 2D .0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode, the Permittee will be required to operate in
accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of an approved plan, with
the appropriate requirements specified in 15A NCAC 2D .0300.
HH. Registration of Air Pollution Sources [I 5A NCAC 2D .0200]
The Director of the DAQ may require the Pemuttee to register a source of air pollution. If the Permittee is required to
register a source of air pollution, this registration and required information will be in accordance with 15A NCAC 2D
.0202(b).
II. Ambient Air Quality Standards [15A NCAC 2D .0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any source of
air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality
DEQ-CFW 00068263

Permit 03735T35 40
Page 50
standards in 15A NCAC 2D .0400 to be exceeded at any point beyond the premises on which the source is located. When
controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of the
ambient air quality standards or are required to create an offset, the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and ReportinE Requirements [15A NCAC 2Q .0508(i)(16)]
If emissions testing is required by this pen -nit or the DAQ or if the Permittee submits emissions testing to the DAQ in support
of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A
NCAC 2D .2600 and follow the procedures outlined below:
1. The Permittee shall submit a completed Protocol Submittal Form to the DAQ Regional Supervisor at least 45 days prior
to the scheduled test date. A copy of the Protocol Submittal Form may be obtained from the Regional Supervisor.
2. The Permittee shall notify the Regional Supervisor of the specific test dates at least 15 days prior to testing in order to
afford the DAQ the opportunity to have an observer on -site during the sampling program.
3. During a camp g peno s, the Permittee shall operate a emission source(s) under maximum normal operating
conditions or alternative operating conditions as deemed appropriate by the Regional Supervisor or his delegate.
4. The Permittee shall submit two copies of the test report to the DAQ. The test report shall contain at a minimum the
following information:
b. A certification of the test results by sampling team leader and facility representative;
c A summary of emissions results and text detailing the objectives of the testing program, the applicable state and
federal regulations, and conclusions about the testing and compliance status of the emission source(s);
d. A detailed description of the tested emission source(s) and sampling location(s) process flow diagrams, engineering
drawings, and sampling location schematics should be included as necessary;
e. All field, analytical, and calibration data necessary to verify that the testing was performed as specified in the
applicable test methods;
f. Example calculations for at least one test run using equations in the applicable test methods and all test results
including intermediate parameter calculations; and
g. Documentation of facility operating conditions during all testing periods and an explanation relating these operating
conditions to maximum normal operation. If necessary, provide historical process data to verify maximum normal
operation.
The testing requirement(s) shall be considered satisfied only upon written approval of the test results by the DAQ.
The DAQ will review emission test results with respect exclusively to the specified testing objectives as proposed by the
Permittee and approved by the DAQ.
KK. Reopenim for Cause [I5A NCAC 2Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. Additional applicable requirements become applicable to a facility with remaining permit term of three or more
years;
b. Additional requirements (including excess emission requirements) become applicable to a source covered by Title
IV;
c. The Director or EPA finds that the permit contains a material mistake or that inaccurate statements were made in
establishing the emissions standards or other terms or conditions of the permit; or
d. The Director or EPA determines that the permit must be revised or revoked to assure compliance with the
applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable requirement is
promulgated. No reopening is required if the effective date of the requirement is after the expiration of the permit term
unless the term of the permit was extended pursuant to 15A NCAC 2Q .0513(c).
3. Except for the state -enforceable only portion of the permit, the procedures set out in 15A NCAC 2Q .0507, .0521, or
.0522 shall be followed to reissue the permit. If the State -enforceable only portion of the permit is reopened, the
procedures in 15A NCAC 2Q .0300 shall be followed. The proceedings shall affect only those parts of the permit for
which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be reopened, except in
cases of imminent threat to public health or safety the notification period may be less than 60 days.
DEQ-CFW 00068264

Permit 03735T35 16
Page 51
•
5. Within 90 days, or 180 days if the EPA extends the response period, after receiving notification from the EPA that a
permit needs to be terminated, modified, or revoked and reissued, the Director shall send to the EPA a proposed
determination of termination, modification, or revocation and reissuance, as appropriate.
LL. Reporting Requirements for Non -Operating Equipment [15A NCAC 2Q .0508(i)(16)]
The Pernttee shall maintain a record of operation for permitted equipment noting whenever the equipment is taken from and
placed into operation. During operation the monitoring recordkeeping and reporting requirements as prescribed by the
permit shall be implemented within the monitoring period.
MM. Fugitive Dust Control Requirement [15A NCAC 2D .0540] - STATE ENFORCEABLE ONLY
As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or
allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property
oun ary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property
boundaries for six minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or operator may
be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter from process operations that does not pass through a process stack or vent
is generated -within pi u : un o ing n oa ing areas, proces areas
stockpiles, stock pile working, plant parking lots, and plant roads (including access roads and haul roads).
NN. Specific Permit Modifications [15A NCAC 2Q.0501 and .0523]
1. For modifications made pursuant to 15A NCAC 2Q .0501(c)(2), the Permittee shall file a Title V Air Quality Permit
Application for the air emission source(s) and associated air pollution control device(s) on or before 12 months after
commencing operation.
2. For modifications made pursuant to 15A NCAC 2Q .0501(d)(2), the Permittee shall not begin operation of the air
emission source(s) and associated air pollution control device(s) until a Title V Air Quality Permit Application is
filed and a construction and operation permit following the procedures of Section .0500 (except for Rule .0504 of
this Section) is obtained.
3. For modifications made pursuant to 502(b)(10), in accordance with 15A NCAC 2Q .0523(a)(1)(C), the Pernittee
shall notify the Director and EPA (EPA - Air Planning Branch, 61 Forsyth St., Atlanta, GA 30303) in writing at least
seven days before the change is made. The written notification shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit renewal, the
Permittee shall submit a page "B5" of the application forms signed by the responsible official verifying that the
application for the 502(b)(10) change/modification, is true, accurate, and complete. Further note that modifications
made pursuant to 502(b)(10) do not relieve the Permittee from satisfying preconstruction requirements.
00. Mandatory Greenhouse Gas Reporting Requirements [15A NCAC 2Q .0508]
FEDERAL -ENFORCEABLE ONLY
If the Permittee is subject to requirements of 40 CFR 98.2(a), the Permittee shall submit all required reports to the
EPA Administrator in accordance with 40 CFR 98.
DEQ-CFW 00068265

Permit 03735T35
Page 52
0
ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CEM Continuous Emission Monitor
CAA Clean Air Act
DAQ Division of Air Quality
DENR Department of Environment and Natural Resources
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAPS National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PMto Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
SIC Standard Industrial Classification
SIP State Implementation Plan
SO2 Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound
DEQ-CFW 00068266

NORTH CAROLINA DIVISION OF
Region: Fayetteville Regional Office
AIR QUALITY
County: Bladen
Air Permit Review
NC Facility ID: 0960009
Inspector's Name: Christy Richardson
Date of Last Inspection: 05/12/2009
Compliance Code: 3 / In Compliance -
Permit Issue Date: February 22, 2010
Inspection
Facility Data
Permit Applicability (this application only)
Applicant (Facility's Name): DuPont Company - Fayetteville Works
SIP: N/A
NSPS: N/A
Facility Address:
NESHAP: Update "MON" Language
22828 NC Highway 87 West
PSD Avoidance: Revised Monitoring
Fayetteville, NC 28302
NC Toxics: N/A
112(r): N/A
I • 3081 / Unsup ported Plastics Film AndSheet-Other:
N/A
NAILS: 326113 / Unlarninated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Application Data
Application Numbers: 0900009.0813,
Facility Contact
Authorized Contact
Technical Contact
Michael Johnson
Karen Wrigley
Michael Johnson
0900009.08C, & 0900009.08E
Date Received: 04/08/2008, 04/17/2008, &
Environmental Manager
Plant Manager
Environmental Manager
12/09/2008
[phone]
[phone]
[phone]
Application Type: Significant Modification
22828 NC Highway 87
22828 NC Highway 87
22828 NC Highway 87
(Part Il), Renewal, and Significant Modification
West
West
West
(Part 11)
Fayetteville NC,
Fayetteville NC,
Fayetteville NC,
Application Schedule: TV -Renewal
28306+7332
28306+7332
28306+7332
Existing Permit Data
Existing Permit Number: 03735/T34
Existing Permit Issue Date: 01/15/2009
Existing Permit Expiration Date: 01/31/2009
Review Engineer: Fern Paterson, P.E.
Comments / Recommendations:
Issue 03735/T35
Revi En 's Signature: Date:
VkAoto
Permit Issue Date: 02/22/2010
Permit Expiration Date: 01/31/2015
I. Purpose of Application
The North Carolina Division of Air Quality (NC DAQ) received an application for renewal of its Title V Air Quality
Permit on April 17, 2008 (Application No. 0900009.08C). No permit revisions were requested as part of the
renewal application. However, NC DAQ consolidated the renewal applications with two "Part II" significant
modification applications, as follows:
Application_ No. Date Received Purpose of Application
0900009.0813 April 8, 2008 Operate Polyvinyl Fluoride (PVF) Process No. 2 (ID No. FS-
C). This facility was issued a permit using procedures in 15A
NCAC 2Q .0501(c)(2) in August 2008.
DEQ-CFW 00068267

0900009.08E December 9, 2008 Operate a new boiler (ID No. PS-C), allow natural gas firing
in existing boilers, and permit various decontamination
processes (ID Nos. NS-N, NS-O, and NS-P). These sources
were issued a permit using procedures in 15A NCAC 2Q
.0501(c)(2) in January 2008.
II. Permit Modifications/Changes
The following table describes the modifications to the current permit.
Page(s)
Section
Description of Change(s)
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
Global
Global
Change boiler ID Nos., as follows:
• ID No. PS-1 PS -A
• ID No. PS-2 -
3-5
Section 1, Table
• Add ID Nos. BS-F & BS-G, which were previously included on the
insignificant activity list (ID Nos. I-BI & I-B2).
• Remove ID Nos. BS-D, which is not longer at the facility.
-
0 Add MACT FFFF designations to all Butaeiteg sources.
• Remove all footnotes regarding modification procedures and Title V shield
applicability.
10-11
Section 2.1 A.5.
Revise PSD avoidance condition to include only NOx and SOZ and update
monitoring provisions to include specific compliance demonstration
methodology.
14-15
Section 2.1 B.4.
• Remove MACT KK requirements. All affected printing operations (ID No.
BS-D) have been removed from the facility.
• Add MACT FFFF requirements.
17-18
Section 2.1 CA.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
18-19
Section 2.1 C.5.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
19-20
Section 2.1 C.6.
Update PSD avoidance condition to include specific compliance demonstration
methodology.
20
Section 2.1 C.7.
(Formerly identified as 2.1 C.6, in error) Update PSD avoidance condition to
includespecific compliance demonstration methodology.
20-27
Section 2.1 C.8
Add facility -specific MACT FFFF requirements to the permit.
N/A
Former Section
Remove ID No. FS-A, which no longer operating at the facility.
2.1.D
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On May 12, 2009, Ms. Christy Richardson (FRO)
conducted a site inspection of the facility. At this time, the facility appeared to be operating in compliance with all
applicable requirements as provided in the air quality permit.
On January 6, 2009, the facility was issued a Notice of Violation (NOV)/Notice of Recommendation for
Enforcement (NRE) for operating the decontamination sources (ID Nos. NS-N, NS-O, and NS-P) without a permit.
DuPont is seeking to permit these sources as part of this application.
In November 2007, the facility was issued a NOV for failure to submit a Part II significant modification application
in a timely manner. Note that the required application was submitted and received by NC DAQ on October 11,
2007, and a revised permit was issued on January 24, 2008.
DEQ-CFW 00068268

IV. Regulatory Review
A. Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS -A), 139.4 million Btu per hour maximum
heat input,
Natural Gas/No. 2 fuel oil/No. 6 fuel oil -fired boiler (ID No. PS-B), 88.4 million Btu per hour maximum
heat input, and
Natural Gas/No. 2 fuel oil -fired boiler (ID No. PS-C) equipped with a low-NOx burner, 97 million Btu per
hour maximum heat input.
1. Applicable Regulatory Requirements:
• 15A NCAC 2D .0503
• 15A NCAC 2D .0516
• 15A NCAC 2D .0524 (ID No. PS-C, only)
• 15A NCAC 2Q .0317 (PSD Avoidance)
2. Chances _er the Title V Permit Renewal
a. Change of Nomenclature
All references to Boiler ID No. PS-1 have been changed to PS -A.
All references to Boiler ID No. PS-2 have been changed to PS-B.
b. Update the Existing PSD Avoidance Condition for Boiler No. 2 (ID No. PS-B)
The existing PSD Avoidance condition for Boiler No. 2 includes limits for PM, PM-10, SO2, and NOx.
The permit is revised to include only SOZ and NOx emission limits. NOx is a limiting pollutant, and
using NC DAQ-approved estimation procedures, the boiler cannot exceed the PM/PM-10 limits
without first violating the NOx limit. Therefore, limiting the NOx emission is sufficient to ensure that
the boiler will not emit PM/PM-10 at rates at or above the PSD significant emission rates. The SOZ
PSD avoidance condition has been left in place. The proposed permit was also updated to include
required emission estimation methods to define the monthly compliance determination method.
3. Revisions Per Application No. 0900009.08E
DuPont added natural gas firing capabilities to existing boilers (ID Nos. PS -A and PS-B). The boilers are
not NSPS-affected boilers based on their construction dates, and were already permitted to fire No. 2 and
No. 6 fuel oil. The boilers were capable of accommodating natural gas fuel firing, but DuPont will had to
install a natural gas supply line to the facility. Per 40 CFR 60.14(e)(14), the addition of anew fuel source
is NOT an NSPS modification, provided the existing facility was designed to accommodate the additional
fuel. This modification did not trigger any additional requirements.
DuPont is also permitted a new natural gas/No. 2 fuel oil fired package boiler (ID No. PS-C) with a
maximum heat input of 97 MMBtu/hr.
15A NCAC 2D .0503 — Particulates from Fuel Burning Indirect Heat Exchangers
This regulation limits particulate matter (PM) emissions from the firing of fuel in indirect heat
exchangers (in lb/mmBtu) based on the facility -wide heat input. The PM limit for the new boiler (ID
No. PS-C) is determined by summing the heat input of the existing boilers with the maximum
allowable heat input rate of the new boiler. The PM limit for the temporary boiler shall be 0.2268
lb/mmBtu, as demonstrated below:
Boiler ID No.
Heat Input Rate
ID No. PS -A
139.4 mmBtu/hr
ID No. PS-B
89.4 mmBtu/hr
ID No. PS -Temp
100.0 MMBtu/hr
ID No. PS-C
97.0 MMBtu/hr
Total Heat Input
424.8 mmBtu/hr
DEQ-CFW 00068269

PM Limit, as calculated pursuant to 15A NCAC 2D .0503(c)
E=1.090(Q)-0.2594
Where: E = Allowable emission limit for PM (in lb/mmBtu); and,
Q = Maximum heat input in MMBtu/hr
E = 1.090(424.8)1.2194
.E = 0.2268
PM emissions from the worst -case fuel (No. 2 fuel oil) are estimated to be less than 0.03 lb/mmBtu
using AP-42 emission factors, as follows:
2 lbPM filterable + 1.3 ZbPMcondensable
1,000gal 1,000gal
= 0 024lbPMtotal
140 mmBtu mmBtu
1,000gal
Because worst -case PM emission rates are estimated to be less than the allowable PM emission rate, no
monitoring, recordkeeping, or reporting is required to demonstrate compliance with this limitation.
ii. 15A NCAC 2D .0524 — 40 CFR 60, Subpart Dc, NSPS for Small Industrial -Commercial -Institutional
Steam Generating Units — This regulation is applicable to boilers that commenced construction,
reconstruction, or modification after June 9, 1989 AND that have a maximum heat input capacity equal
to or greater than 10 million Btu per hour and less than or equal to 100 million Btu per hour (i.e., 10
mmBtu/hr < Q < 100 nmiBtu/hr). The new boiler (ID No. PS-C) is affected by this NSPS.
The affected boiler is affected by the following emission standards:
— Sulfur Dioxide. The maximum sulfur content of any fuel oil received and fired in the Subpart Dc-
affected boiler shall not exceed 0.5 percent by weight. To demonstrate compliance with this
standard, the Permittee is required to retain copies of each fuel supplier certification, including the
sulfur content of the oil (in percent by weight). The Permittee is also required to submit a
semiannual report summarizing the monitoring activities (January 30`h and July 30`l').
— Visible Emissions. For any Subpart Dc-affected boiler with a maximum heat input capacity of
greater than or equal to 30 million Btu per hour, visible emissions shall not be more than 20
percent opacity when averaged over a six -minute period, except for one six -minute period per
hour of not more than 27 percent opacity. To demonstrate compliance with this standard, the
Permittee is required to conduct a Method 9 opacity observation within 60 days of installing the
unit. There are notification and test reporting requirements associated with this observation.
In addition, the affected boiler is required to keep a monthly record of the quantity of each fuel fired
pursuant to 40 CFR 60.48c(g)(2), as follows:
"As an alternative to meeting the requirements ofparagraph (g)(1) of this section,
the owner or operator of an affected facility that combusts only natural gas, wood,
fuels using fuel certification in §60.48c69 to demonstrate compliance with the SOz
standard, fuels not subject to an emissions standard (excluding opacity), or a
mixture of these fuels may elect to record and maintain records of the amount of
each fuel combusted during each calendar month. "
4
DEQ-CFW 00068270

iii. 15A NCAC 20.0317 — Avoidance Conditions for 15A NCAC 2D .0530; Prevention of Significant
Deterioration — DuPont is located in Bladen County, which is a designated attainment/unclassified area
for all pollutants regulated by the New Source Review (NSR) permitting program. Therefore,
emissions increases associated with proposed construction activities must be evaluated to determine
whether the Prevention of Significant Deterioration (PSD) program applies as provided in 15A NCAC
2D .0530. DuPont, which is a chemical processing plant with a 100-tpy major source threshold, is an
existing major source under the PSD program.
In August 2008 (Permit No. 03735T33), the Permittee limited allowable SOZ emissions from the three
existing boilers (ID Nos. PS -A, PS-B, and PS -Temp) to no greater than 702.5 tpy in order to avoid
PSD permitting for the proposed addition of a new Polyvinyl Fluoride (PVF) Process (ID No. FS-C).
Because the new boiler will have the potential to provide steam to the new PVF line, SOZ emissions
frpm the »�rq»nr _ced new holler (TTl N� PS-C)_mt�St he arldecl t� �()� emi¢�inns from the existing
boilers to demonstrate compliance with the existing PSD avoidance condition. Section 2.2.A.1. of the
draft permit has been modified to include the new boiler in the monthly compliance demonstration for
the existing PSD avoidance condition.
rmssions increases resu ring om t e costa anon o t e new of er an use o natura gas at t e
existing boilers are less than the significant emission rates for all PSD regulated pollutants, as shown in
the table provided below. The new boiler increases the reliability of steam supply for the site, and does
not debottleneck any process at the plant. Therefore, no PSD permitting was required for the proposed
boiler, nor was the new boiler restricted by any new PSD avoidance limitations.
Table. Summary of Potential Emissions Increases
NOTES:
1. All emissions estimated using AP-42 emission factors and assuming natural gas has a heat content of 1,020 Btu/scf.
2. No increased steam demand was anticipated as part of this proposed project. Therefore, to determine the worst -case emission increase
resulting from this proposed modification, NC DAQ determined the existing -potential emission rate (from fuel oil firing) and compared
it to the future -potential emission rate (from natural gas firing). The temporary, back-up boiler (ID No. PS -Temp) is only brought on -
site when there is a need (e.g., when other boilers have maintenance problems) and has never operated for more than 2,000 hours in a
calendar year (CY2004). Actual emissions increases for this boiler assume only 4,380 hours operation per year. No emissions
increases are estimated for PM-10, S02, or NOx because the emission factor (in lb/MMBtu) for these pollutants is lower for natural gas
than currently permitted fuel oils.
3. NOx emissions for the new boiler (ID No. PS-C) are calculated using the emission factor for low-NOx burners.
B. Butaciteo Process Area
Applicable Regulatory Requirements:
• 15A NCAC 2D .0515
• 15A NCAC 2D .0521
• 15A NCAC 2D .1806 (State -Enforceable Only)
• 15A NCAC 2D .1111 (40 CFR 63, Subpart FFFF)
5
DEQ-CFW 00068271

2. Changes per the Title V Permit Renewal
a. Remove Polyvinyl Butyral Sheeting Rotogravure Printing Operation (ID No. BS-D) and
associated spray scrubber (ID No. BCD-Dl)
This emission source is no longer operational. The source was affected by 40 CFR 63, Subpart KK
(MALT for the Printing and Publishing Industry). These requirements have been entirely removed
from the proposed permit.
b. Move PVA Dissolving System Batch Vents (i.e., PVA Unloading, Silos, & Dissolver Tank
Systems) from the insignificant activity list to the body of the permit, and rename the systems.
(ID No. I-B1 becomes BS-1; ID No. I-B2 becomes BS-2)
These emission sources are affected Group 2 process vents under 40 CFR 63, Subpart FFFF (NESHAP
for Misc. Organic Chemical Manufacturing).
c. 15A NCAC 2D .1111; 40 CFR 63, Subpart FFFF (Section 2.1 BA)
NESHAP for Miscellaneous Organic Chemical Manufacturing ("MON")
The Butacite® Polyvinyl Butyral Process has two affected existing miscellaneous organic chemical
manufacturing process units (MPCUs), including the Butacite® PVA Dissolving System (ID Nos. BS-
1 & BS-2)' and the Butacite® PVB Reactor System, which includes the remaining Butacite® process
vents. Both MCPU's are batch operations and total uncontrolled HAP emissions from both sources are
less than10,000 lbs/year. As defined in 40 CFR 63.2550, both existing MCPU's are Group 2 process
vents.
There are no control requirements for Group 2 batch process vents. However, pursuant to 40 CFR
63.2525(e), such sources must retain daily records of the completed batches and monthly records of
total emissions (or total batches, correlated to total emissions) from each affected MCPU.
As provided in DuPont's pre -compliance report, to demonstrate compliance with the standard,
DuPont's records must show that annual PVA production from Butacite® PVA Dissolving System (ID
Nos. BS-1 & BS-2) is no greater than 59,000,000 lbs and annual PVA usage at the Butacite® PVB
Reactor System to no greater than 50,857,000 lbs.
Wastewater.
Wastewater is generated from both the Butacite® MCPU's that contains methanol, a HAP listed on
Table 9 of 40 CFR 63, Subpart FFFF. Because the concentration of methanol in the wastewater falls
well below the Group 1 threshold of 30,000 ppmw (with concentrations ranging between 8 ppmw and
2,500 ppmw), Butacite® process wastewater is classified as Group 2. There are no control
requirements for Group 2 wastewater. However, pursuant to 40 CFR 63.2485(a) and 40 CFR
63.147(b)(8), the facility must retain a record identifying the stream, HAP concentration, and flowrate.
Heat Exchangers
The only use of cooling water in the Butacite® process is for cooling process reflux condensers.
Because the process flues in both MCPUs have HAP concentrations less than 5% HAP by weight,
there are not requirements for the heat exchangers pursuant to 40 CFR 63.104(a)(6).
' It is arguable that ID Nos. BS-1, which includes a PVA unloading system and storage silos, is not affected under 40 CFR 63, Subpart FFFF. Per
40 CFR 63.2550, an MPCU "includes any, all or a combination of reaction, recovery, separation, purification, or other activity, operation,
manufacture, or treatment which are used to produce a product or isolated intermediate." However, DuPont has included these sources in the
MCPU in their precompliance report and notification of compliance status, and NC DAQ has included them in the proposed permit as affected
sources.
DEQ-CFW 00068272

41
C. Nafiori Process Area
AAplicable Re ug latory Requirements:
• 15A NCAC 2D .0515
• 15A NCAC 213.0521
• 15A NCAC 2D .1806 (State -Enforceable Only)
• 15A NCAC 2D .1100 (State -Enforceable Only)
• 15A NCAC 2D .1111 (40 CFR 63, Subpart FFFF)
• 15A NCAC 2Q .0317 (PSD Avoidance)
2. Changes per the Title V Permit Renewal
a. vot ance on >< ton ec on
Vinyl Ethers North Process (ID No. NS-B); VOC emissions limited to less than 68.9 tpy
This section of the permit was updated to specify required emission estimation methods for
r1P Prmininn enmpjiance_with the emi�cinn limitation_ nn a monthlThasis
b. 15A NCAC 2D .0317; PSD Avoidance Condition (Section 2.1 C.5)
Resins Process (ID No. NS-G); VOC emissions limited to less than 40 tpy
This section of the permit was updated to specify required emission estimation methods for
determining compliance with the emission limitation on a monthly basis.
c. 15A NCAC 2D .0317; PSD Avoidance Condition (Section 2.1 C.6)
HFPA Process (ID No. NS-A); VOC emissions limited to less than 85.3 tpy
This section of the permit was updated to specify required emission estimation methods for
determining compliance with the emission limitation on a monthly basis.
d. 15A NCAC 2D .1111; 40 CFR 63, Subpart FFFF (Section 2.1 C.7)
NESHAP for Miscellaneous Organic Chemical Manufacturing ("MON")
The Nafion® processes at this facility manufacture plastic materials classified under SIC code 2821,
and are therefore existing affected sources under the "MON".2 The initial compliance date for the
sources was May 10, 2008. The proposed permit has been updated to include facility -specific "MON"
requirements for these affected sources. Facility -specific compliance information was obtained from
the Notification of Compliance Statute (NOCS) report, required by the rule, which was received by NC
DAQ on October 3, 2008.
Affected miscellaneous organic chemical manufacturing process units (MCPUs) at the Nafion®
process area include the following:
• MCPU-1: Hexafluoropropylene oxide (HFPO) manufacturing process (ID No. NS-A). This
process uses benzene and toluene, which are both regulated HAP.
• MCPU-2: Vinyl Ethers North (VEN) process (ID No. NS-B) manufactures the isolated chemical
intermediates "Dimer" and "Diadduct", both of which are acid fluorides, in a continuous process.
The Dimer process uses acetonitrile and the Diadduct process uses glycol ether.
• MCPU-3: Vinyl Ethers South (VES) process (ID No. NS-C) manufactures the isolated chemical
intermediates "PMPF" and "PEPF", both of which are acid fluorides, in a continuous process.
The process uses acetonitrile.
• MCPU-4: Polymers process manufactures a copolymer in a continuous polymerization process.
The process uses methanol in concentrations of 1%-2% by weight.
2 On the initial compliance date, DuPont also owned and operated various Butacite® manufacturing processes that were affected by the MON.
However, these processes are no longer operated at the facility.
7
DEQ-CFW 00068273

Neither halides nor halogen HAP compounds are processed, used, or generated from the affected
Nafion® sources.
Process Vents. All process vents at this facility are associated with continuous process operations.
Affected "continuous process vents" are defined in 40 CFR 63.2550, and include the requirement that
the exhaust stream contains total HAP at a concentration greater than 0.005% by weight at the point of
discharge to the atmosphere (or at the point of entry into a control device, if any). Multiple process
vents at the facility have total HAP concentrations of 0.005% by weight or less, and are therefore not
affected vents (Either Group 1 or Group 2).
Group 1 continuous process vents at existing sources are defined in 40 CFR 63.2550 as having a flow
rate > 0.005 standard cubic meters per minute (scmm) and a THE Index Value (calculated according
the 40 CFR 63 7455(b)):� 1 9 No process vents at the facility meet the Group 1 criteria for confinu -oils
process vents in 40 CFR 63, Subpart FFFF. The following table provides the basis for the vent/group
determination for each process vent at the facility.
Emission Source with
Associated Process Vent
Source Determination
Basis
HFPO'Process
Solvent Recycle Tank
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
Oxidation Column No. 3
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
VENProcess
Catalyst Tank
Group 2 Continuous
Flow rate < 0.005 scmm, as calculated
Process Vent
-using process information.
Reactor Vent Condenser
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by lab analysis.
SOR Condenser
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
AF Overhead Receiver
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
ABR Feed Tank
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
Catalyst Tank
Group 2 Continuous
Flow rate < 0.005 scmm, as calculated
Process Vent
using process information.
Reactor Vent Condenser
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
Stripper Column Condenser
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
AF Overhead Receiver
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
-Po1 mers=Process
Recirculation Tank
-7Process
Group 2 Continuous
THE > 350, as calculated using process
Veint
information.
DEQ-CFW 00068274

0
Emission Source with
Associated Process Vent
Source Determination
Basis
Recycle Tank Condenser
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
Recovery Tank
Not a "Continuous
Total HAP concentration < 0.005%, as
Process Vent"
determined by process modeling and mass
balance.
There are no Group 1 continuous process vents at this facility. Further, there are no Group 2 process
vents with a THE less than or equal to 5.0. Therefore, there are no applicable requirements for the
process vents in Table 1 of 40 CFR 63, Subpart FFFF and the requirements of 40 CFR 63.2455 are not
Storage Tanks. Group 1 storage tanks at an existing source have a capacity greater than or equal to
10,000 gallons and store a material that has a maximum true vapor pressure (MTVP) of total HAP
greater than or P ual to-L_OTsia All MALT -affected tanks at thig facilitV have a storage -capacity -of -
less than 10,000 gallons, and are therefore Group 2 storage tanks. There are no applicable
requirements for Group 2 storage tanks.
Transfer Racks. There are not transfer racks or loading arms in organic liquid service in any of the
Nafion® MCPUs. There are no transfer rack requirements applicable to this facility.
Equipment Leaks. In the Notification of Compliance Status, the facility indicated that they have
agitators, pumps, valves, connectors, and pressure relief valves in light liquid/vapor service that are
affected by the equipment leak requirements in 40 CFR 63, Subpart FFFF in each of the four affected
MCPUs. A table summarizing the types of affected equipment is provided below:
Type
Qty in Vapor
Service
Qty in Light
Liquid Service
Qty in Heavy
Liquid Service
Total Quantity
Agitators
1
0
0
1
Pumps
0
16
0
16
Valves
0
598
0
598
Connectors
0
2164
0
2164
Pressure Relief Valves
15
0
0
15
Equipment leak provisions for each of these types of fugitive emission sources have been added to the
proposed permit.
Wastewater
The only Nafion® process area that produces wastewater is MCPU-4, the polymer manufacturing
process. Wastewater is generated from MCPU-4 contains methanol, a HAP listed on Table 9 of 40
CFR 63, Subpart FFFF. Because the concentration of methanol in the wastewater falls well below the
Group 1 threshold of 30,000 ppmw (with concentrations no greater than 4,300 ppmw), the process
wastewater is classified as Group 2. There are no control requirements for Group 2 wastewater.
However, pursuant to 40 CFR 63.2485(a) and 40 CFR 63.147(b)(8), the facility must retain a record
identifying the stream, HAP concentration, and flowrate.
Heat Exchangers
A heat exchanger system is defined in 40 CFR 63.101 as any cooling tower system or once -through
cooling water system. The only use of cooling water in the Nafion® process is at MCPU-1, the HFPO
process (ID No. NS-A). This MCPU includes two closed -loop cooling systems, which are not affected
sources. It also includes two once -through systems that are affected sources. which contains four
individual heat exchangers. is for cooling process reflux condensers. Because the process flues in
DEQ-CFW 00068275

both MCPUs have HAP concentrations less than 5% HAP by weight, there are not requirements for
the heat exchangers pursuant to 40 CFR 63.104(a)(6).
3. Revisions per Application No. 0900009.08E
a. Description of Process/Modification
DuPont added the existing HFPO Product Container Decontamination Process, in which product
containers that are returned from customers are decontaminated by venting residual product to the
atmosphere, to the permit .3 The residual product (hexafluoropropylene oxide) is a regulated VOC.
Potential emissions from the decontamination process are estimated to be 100.3 tons VOC per year.
The process does not emit any federally -regulated hazardous air pollutants (HAPs) or state -regulated
toxic air pollutants (TAPs).
DuPont added the existing Vinyl Ethers Product Container Decontamination Processes, in which
product containers that are returned from customers are decontaminated by venting residual products
to the atmosphere, to the permit a The residual products (perfluoropropyl vinyl ether, ester vinyl ether,
and perfluorinated sulfonyl vinyl ether) are regulated VOCs. Potential emissions from the
decontamination processes (combined) are estimated to be 31.3 tons VOC per year.
b. 15A NCAC 2Q .0317 — Avoidance Conditions for 15A NCAC 2D .0530; Prevention of Significant
Deterioration
Potential emissions from the HFPO Product Container Decontamination Process exceed 40 tpy of
VOC. To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an
enforceable 40 tpy VOC emission limitation on the decontamination process pursuant to 15A NCAC
2Q .0317.
c. 15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions (State -Enforceable Only)
This standard forbids the Permittee from operating these processes without implementing management
practices or installing and operating odor control equipment sufficient to prevent odorous emissions
from the facility from causing or contributing to objectionable odors beyond the facility's boundary.
No new requirements have been added to the draft permit to demonstrate compliance with 15A NCAC
2D .1806.
D. Fluoroproducts polymer manufacturing development facility (ID No. FS-A) controlled by a wet scrubber
(ID No. FCD-Al) and fabric filter (ID No. FCD-A2)
1. AMlicable Regulatory Requirements:
• 15A NCAC 2D .0515
• 15A NCAC 2D .0521
• 15A NCAC 2D .1806 (State -Enforceable Only)
• 15A NCAC 2Q .0317 (PSD Avoidance)
2. Changes per the Title V Permit Renewal
a. 15A NCAC 2D .0317; PSD Avoidance Condition (Section 2.1 DA)
VOC emissions limited to less than 40 tpy
This section of the permit was updated to specify required emission estimation methods for
determining compliance with the emission limitation on a monthly basis.
3 The product is actually vented to a gaseous absorber (ID No. NCD-Hdrl), but because HFPO is not water soluble, it is assumed that no
emission reduction occurs, and all vented HFPO is released to the atmosphere.
° The products are actually vented to gaseous absorbers (ID Nos. NCD-Hdrl and NCD-Hdr2), but because they are not water soluble, it is
assumed that no emission reduction occurs, and all vented VOC is released to the atmosphere.
10
DEQ-CFW 00068276

•
•
E. Polymer Processing Aid Process (ID No. AS -A) controlled by a wet scrubber (ID No. ACD-Al) and a
building exhaust vent wet scrubber (ID No. ACD-A3) (voluntary use only)
1. Applicable Regulatory Requirements:
• 15A NCAC 2D .1806 (State -Enforceable Only)
• 15A NCAC 2D 1100 (State -Enforceable Only)
2. Changes per the Title V Permit Renewal
No changes were made to this section of the permit.
F. Wastewater Treatment Area consisting of an extended aeration biological wastewater treatment facility
(ID No. WTS-A) and two indirect steam -heated rotary sludge dryers (ID Nos. WTS-B and WTS-C)
core-relled�y-��xcru`pbGr=�i�,�.ist-zli-minater{-ID-lie: W-TCB-i
1. Applicable Regulatory Requirements:
• 15A NCAC 2D .1806 (State -Enforceable Only)
2. Changes per the Title V Permit Renewal
No changes were made to this section of the permit.
G. Temporary Boiler (ID No. PS -Temp), Natural Gas/No. 2 fuel oil -fired (greater than 30.0 and less than
100.0 million Btu per hour maximum heat input)
1. Applicable Regulatory Requirements:
• 15A NCAC 2D .0503
• 15A NCAC 2D .0524 (ID No. PS-C, only)
• 15A NCAC 2Q .0317 (PSD Avoidance)
2. Changes per the Title V Permit Renewal
No changes were made to this section of the permit.
H. SentryGlas® Process (ID No. SGS-A)
1. Applicable Re ug latory Requirements:
• 15A NCAC 2D .0521
• 15A NCAC 2D .1806 (State -Enforceable Only)
2. Changes per the Title V Permit Renewal
No changes were made to this section of the permit.
I. Polyvinyl Fluoride Polymer Manufacturing Area
1. Applicable Re ugulatory Requirements:
• 15A NCAC 2D .0515
• 15A NCAC 2D .0521
• 15A NCAC 2D .1806 (State -Enforceable Only)
• 15A NCAC 2Q .0317 (PSD Avoidance)
2. Changes per the Title V Permit Renewal
No changes were made to this section of the permit.
11
DEQ-CFW 00068277

C
V. Non -Applicable Regulations
A. 40 CFR 63, Subpart HHHHHH; Area Source Paint Stripping & Coating MACT
The Fayetteville Works paint operations (ID Nos. 1-09 and I-10) are not subject to the Area Source Paint
Stripping & Coating MACT in 40 CFR 63, Subpart HHHHHH.
The facility does not:
• Perform paint stripping using methylene chloride ("MeCl") for the removal of dried paint (including,
but not limited to, paint, enamel, varnish, shellac, and lacquer) from wood, metal, plastic, and other
substrates.
• Perform spray application of coatings to motor vehicles and mobile equipment including operations
that are located in stationary structures at ��{ fixed locatiio�7n4ss,,�and
)-mobile
repair and refinishing
4 4i. 4 M 4 LL. L va ion-, excep pra coating applications that meet the
definition of facility maintenance in §63.11180.
• Perform spray application of coatings that contain any of the target HAPs5 (chromium, lead,
manganese, nickel or cadmium) to a plastic and/or metal substrate on a part or product, except spray
coating applications that meet the definition of facility maintenance or space vehicle in §63.11180.
VI. Compliance Assurance Monitoring
Pursuant to 15A NCAC 2D .0614, the provisions of the Compliance Assurance Monitoring (CAM) rule are
applicable to emission units that meet all of the following criteria:
Criteria #l: The unit is subject to a non-exempt emission limitation or standard AND uses a
control device to achieve compliance with the limit or standard;
Criteria #2: The unit has pre -control potential emissions that are equal to or greater than 100%
of the amount (in tpy) required for a source to be classified as a major source (i.e.,
100 tpy of any criteria pollutant or 10 tpy of any HAP, North Carolina); and,
Criteria #3: The unit does not have a continuous compliance determination method (CCDM),
as defined in 40 CFR 64.1, specified in the permit.
Exempt emission limitations are provided 15A NCAC 2D .0614(b)(1), and include NSPS/MACT standards
proposed after Nov. 15, 1990, statopheric ozone protection and acid rain requirements, and trading program and
emissions caps applicable under 15A NCAC 2Q.
As summarized in the following Table, the facility does not include any controlled emission sources with an
uncontrolled PTE greater than Title V major source thresholds, and therefore is not subject to the CAM provisions in
15A NCAC 2D .0614.
Table — CAM Applicability Summary
Emission
Unit
Criteria #1: Control device
reqd. to comply with a non-
exempt limit?
Criteria #2: Pre -control
PTE >100% of major
source thresholds?
Criteria #3: CCDM
as provided in 40
CFR 64.1?
CAM
Source?
PS -A
No Uncontrolled
-
-
No
PS-B
No Uncontrolled
-
-
No
PS-C
No Uncontrolled
-
-
No
PS -Temp
No Uncontrolled
-
-
No
BS-1
No Uncontrolled
-
-
No
BS-2
No Uncontrolled
-
-
No
BS-A
No (Post-1990 MALT, Only)
-
-
No
5 A review of MSDSs for the coatings did not identify any of the affected metals listed. However, MSDS information does not
list compounds that are less than 1 % by weight. Based on the best information available about the coatings used at the facility,
NC DAQ has determined that the coatings are not affected under 40 CFR 63, Subpart HHHHHH.
12
DEQ-CFW 00068278

Emission
Unit
Criteria #1: Control device
reqd. to comply with a non-
exempt limit?
Criteria #2: Pre -control
PTE >100% of major
source thresholds?
Criteria #3: CCDM
as provided in 40
CFR 64.1?
CAM
Source?
BS-131.1
through
BS-B 1.4
No (Post-1990 MACT, Only)
-
-
No
BS-132.1
through
BS-B2.4
No (Post-1990 MACT, Only)
-
-
No
BS-C
No (Post-1990 MACT, Only)
-
-
No
BS-El
No (Post-1990 MACT, Only)
-
-
No
BS-E2
No (Post-1990 MACT, Only)
-
-
No
�-
o ncontro e
-
-
No
BS-E4
No (Uncontrolled)
-
-
No
NS-A
No (Post-1990 MACT, Only)
-
-
No
IN
Post=139fl 3vIA
-
-
NS-C
No (Post-1990 MACT, Only)
-
-
No
NS-D
No (Post-1990 MACT, Only)
-
-
No
NS-E
No (Post-1990 MACT, Only)
-
-
No
NS-F
No (Post-1990 MACT, Only)
-
-
No
NS-G
No (Post-1990 MACT, Only)
-
-
No
NS-H
No (Uncontrolled)
-
-
No
NS-I
No (Uncontrolled)
-
-
No
NS-J
No (Uncontrolled)
-
-
No
NS-K
No (Uncontrolled)
-
-
No
NS-L
No (State TAP, Only)
-
-
No
NS-M
No (Uncontrolled)
-
-
No
NS-N
No (Uncontrolled)
-
-
No
NS-O
No (Uncontrolled)
-
-
No
NS-P
No (Uncontrolled)
-
-
No
SW-1
No (Uncontrolled)
-
-
No
SW-2
No (Uncontrolled)
-
-
No
FS-A
No (Odors and Avoidance
Conditions, Only)
-
-
No
AS -A
No (Odors and State TAP,
Only)
-
-
No
WTS-A
No (Uncontrolled)
-
-
No
WTS-B
No (Odors, Only)
-
-
No
WTS-C
No (Odors, Only)
-
-
No
SGS-A
No (Uncontrolled)
-
No
FS-B
No (Uncontrolled)
-
-
No
FS-C
No (Uncontrolled)
-
-
No
Applicable Standard Notes:
(1) PSD avoidance conditions, applicable pursuant to 15A NCAC 2Q .0317. PSD avoidance conditions are exempt pursuant to 15A NCAC 2D
.0614(b)(E).
(2) Miscellaneous Organic NESHAP ("MON") requirements pursuant to 15A NCAC 2D. I I I I and 40 CFR 63, Subpart FFFF. This standard
was proposed after Nov. 15, 1990, and is exempt pursuant to 15A NCAC 2D .0614(b)(E).
13
DEQ-CFW 00068279

VH.Permit History:
The following list provides a very brief summary of permit revisions for this facility:
Permit No. Issuance Date
Description of Revision
03735T23 July 2003
Initial Title V Permit
03735T24 January 2004
Administrative amendment to the permit related to the permit effective
date.
03735T25 February 2004
Modification to add a temporary No. 2 fuel oil -fired boiler (ID No. PS -
Temp).
03735T26 May 2004
Administrative amendment to the permit related to modify permit
organization, thereby improving permit clarity.
03735T27 December 2004
Modification to add a SentryGlas® Process (ID No. SGS-A), change the
description of the _existing wastewater treatment plant and revise various
monitoring requirements for existing scrubbers.
03735T28 January 2006
Administrative amendment to the change the required annual compliance
certification due date from January 30 to March 1.
03735T29 June 2006
Modification to add a polyvinyl fluoride process (H) No. FS-B) and an
insignificant polyvinyl fluoride vacuuming system for housekeeping
purposes (ID No. I-1).
03735T30 September 2006
Replace an existing internal scrubber at the hexfluoropropylene epoxide
(HFPO) process (ID No. NS-A) in the Nafion Process Area
(debottlenecking).
03735T31 October 2007
Modification to authorize (1) the installation of a wet scrubber (ID No.
ACD-A3) on the building exhaust vent at the Polymer Processing Aid
Process (ID No. AS -A) and (2) add a tetrafluoroethylene (TFE) / carbon
dioxide (CO2) separation process (11) No. NS-M).
03735T32 January 2008
"Part 2" Sgnificant modification for the temporary rental boiler (ID No.
PS -Temp) and the hexafluoropropylene oxide (HFPO) manufacturing
facility (ID No. NS-A). Also authorize changes at the existing Butacite®
Extruder Lines (ID Nos. BS-El and BS-E2).
03735T33 August 2008
"Part 1" significant modification to construct and operate Polyvinyl
Fluoride (PVF) Process No. 2 (ID No. FS-C) and various insignificant
activities.
03735T34 January 2009
"Part 1" significant modification to construct and operate a new boiler (ID
No. PS-C), allow natural gas firing in existing boilers, and permit various
decontamination processes (ID Nos. NS-N, NS-O, and NS-P).
VHL Proposed Permit Review Summary
• Mr. Tien Nguyen (FRO) was provided a copy of the draft permit for review on November 13, 2009.
• Mr. Michael Johnson (DuPont) was provided a draft permit for review on November 13, 2009.
• Ms. Katy Forney and Ms. Gracy DeNois (U.S. EPA, Region IV) were provided a draft permit for review on
January 4, 2010.
IX. Other Regulatory Considerations
• The application fee for Application No. 0900009.0813 ($867.00) was received on April 8, 2008.
• The application fee for Application No. 0900009.08E ($867.00) was received on December 9, 2008.
• Reduction and Recycling Forms were received on April 8, 2008 and December 9, 2008.
• A Professional Engineers Seal is NOT required for this application.
• Zoning consistency determinations were received by the DAQ on April 8, 2008 and December 9, 2008.
14
DEQ-CFW 00068280

•
0
X. Recommendations
The permit modification application for E.I. du Pont de Nemours & Co., LLC, located in Duart Township, Bladen
County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and
requirements. NC DAQ has determined that this facility appears to be complying with all applicable requirements.
Issue Permit No. 03735T35
15
DEQ-CFW 00068281

Comprehensive Application Report for 0900009.08C
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
General Information:
Permit/Latest Revision: 03735/ T35
Permit code:
TV -Renewal
Application type:
Renewal
Engineer/Rev. location:
Fern Paterson/RCO
Regional Contact:
Tien Nguyen
Facility location:
Fayetteville Regional Office
Facility classification:
Title V
Clock is ON
Application is COMPLETE
Status is :
Issued
Contact Information
Type Name
Authorized Karen B Wrigley, Plant Manager
Technical/Permit Michael E Johnson, Environmental Manager
Received Completeness
04/17/2008 06/16/2009
Initial amount: Date received:
04/ 17/2008
Fund type: Deposit Slip #:
2333
Address
22828 NC Highway 87 West
22828 NC Highway 87 West
Acceptance Criteria
Received?
Acceptance Criteria Description
N/A
Application fee
Yes
Appropriate number of apps submitted
N/A
Zoning Addressed
N/A
Source recycling/reduction form
Yes
Authorized signature
N/A
PE Seal
0
m
p
C�
n
I
0
0
0
rn
w
N
00
N
02/22/201
Clock Start Calculated Issue Due
04/17 2008
Due: I Add. Amt Rcv'd: Date Rcv'd:
Fayetteville, NC 2
Fayetteville NC 2
Completeness Criteria
Received? Complete
reed: Location deposited: 10
Telephone
332 [phone]
332 [phone]

Comprehensive Application Report for 0900009.08C
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Application Events
Event Start Due Complete Comments
TV - Acknowledgment/Complete 04/25/2008 05/05/2008 04/25/2008
Draft permit to 1st line supervisor 11/13/2009 11/13/2009
Draft permit to region 11/13/2009 11/20/2009 11/18/2009
Draft permit to applicant 11/13/2009 01/04/2010
Pen -nit issued 02/22/2010 02/22/2010
02/22/201
hash
U
LI
i'

0
r'
6
J
I
0
0
0
rn
w
N
00
Comprehensive Application Report for 0900009.08C
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Outcome Information
Class before: Title V
Class after: Title V
2Q .0711: No 2D .1100:
No
NSPS: No NESHAPS/MACT:
Yes PSD/NSR:
PSDiNSR Avoid: No
Prohibitory Small:
PSD/NSR Status After: Major
General permit:
Multi -site permit: No
Multi. permits at facility:
Quarry permit: No
HAP Major (10/25 tpy):
2Q .0705 Last MACT/Toxics: NO
NESHAPS/GACT:
New Source RACT/LAER: NO
Existing Source RACT:
RACT/LAER Added Fee: NO
RACT Avoidance:
Regulations Pertaining to this Permit
Reference Rule
2D
.1806
2Q
.0317
2D
.0503
2D
.0515
2D
.0516
2D
.0521
2D
.0524
2D
.1100
2D
.1111
02/22/201
Permit/Revision: 03 73 5/T3 5
Revision Issue Date: 02/22/2010
No Accumulated process days (includes public noti e periods): 676
No Public notice/hearing/add info after 80 days:
No Manager's discretion: Appealed? No
No Current Permit Information:
Major Issue Effective Expiratio4 Rev lion #
NO 02/22/2010 02/22/2010 01 /31 /20 5 T35
NO
NO
Regulation Description
Control And Prohibition of Odorous Emissions
Avoidance Conditions
Particulates Fuel Burning Indirect Heat Exchangers
Particulates Miscellaneous Industrial Processes
Sulfur Dioxide Emissions Combustion Sources
Control of Visible Emissions
New Source Permance Standards
Control of Toxic Air Pollutants
Maximum Achievable Control Technology
3
I-]
•

Comprehensive Application Report for 0900009.08C
DuPont Company - Fayetteville Works - Fayetteville (0900009)
Bladen County
Audit Information Pertaining to this Application
Column Name
Date Changed
dt_App_Rec
04/25/2008
engineer
04/25/2008
reg_Cont
07/27/2009
Old Value
04/ 18/2008
724 (Mark Cuilla)
3328 (Christy Richardson)
New Value
04/17/2008
3358 (Fern Paterson)
4330 (Tien Nguyen)
02/22/201
Editor
Kathy
Kathy
James
•