DEQ-CFW_00071372

DIVISION OF AIR QUALITY
Technical Services Section
August 22, 2013
MEMORANDUM
Bladen County
To: Steven Vozzo, Fayetteville Regional Office (FRO)
From: Gregg O'Neal, P.E., Stationary Source Compliance Branch (SSCB)
Subject: E.I. du Pont de Nemours and Company, DBA, DuPont Company — Fayetteville Works
Duart Township, Bladen County, NC, Facility ID 0900009, Permit No. 03735T37
Protocol for CFR 98.124(g)(2)(i), Hydrogen Chloride Emissions Testing of
Nafion Process (Source ID Nos. NS-A, NS-B, NS-D, NS-E, NS-F), Tracking No. 2013-127ST
Nafion Vinal Ether South (Source ID No. NC-C), Tracking No. 2013-128ST
Testing to be Performed by Entec Services, Inc. on August 13 through 14, 2013
Note the required testing is for the Part 98 Mandatory Greenhouse Gas Reporting Subpart L
Fluorinated Gas Production. The administrator at this time for the required testing is the EPA in
Washington DC.
The test protocols NCDAQ Tracking Nos. 2013-127ST and 2013-128ST are for the 10 year testing
requirement listed in CFR 98.124(g)(2)(i). NCDAQ is not the administrator for this subpart and
therefore cannot give an approval. The e-mail on the next page was sent to the facility to direct
them to the correct contact person with authority to approve DuPont's request for testing deviations.
If there are any questions concerning this matter, please contact me at [phone] or
gregq. oneal(a_ncdenr.gov.
cc: Central Files, Bladen County
IBEAM Documents - 0900009
DEQ-CFW 00071372

Oneal, Gregg
From: Oneal, Gregg
Sent: Wednesday, July 31, 2013 2:52 PM
To: 'dianne,[e-mail]';'[e-mail]'
Cc: Reeves, Gregory W; Vozzo, Steven
Subject: Method 26 Destruction device performance testing for CFR 98.124(g)(2)(i) (August 2013)
Dianne,
I just got off the phone with Debbie Otinger with EPA. I believe she is the correct administrator contact for the proposed
testing. You submitted two testing protocols to NCDAQ for review and approval in order to meet the every 10 year
testing requirement listed in CFR 98.124(g)(2)(i). Since we are not the administrator for this subpart I do not have the
authority to approve your request for both Method 26 deviations and your request to waive the Method 26 audit.
Debbie's phone number is 202-343-9149. Please feel free to contact me if l can be of any further assistance.
Thanks,
Gregg O'Neal
Thomas Gregg O'Neal, III, P.E., Environmental Engineer
Stationary Source Compliance Branch
NC DENR, Division of Air Quality
Technical Services Section
NC DENR, Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
Phone/Fax:[phone]S
Fax:[phone]
www.ncair.ore
[e-mail]
Email correspondence to and from this address is subject to the North Carolina Public Records taw
and may be disclosed to third parties unless the content is exempt by statute or other regulation.
DEQ-CFW 00071373

7/26/13 Protocol Tracking Form - SSCB Internal
Page 1 of 1
Facility Name: DuPont Company - Fayetteville Works Facility ID: 0900009
Tracking No.: 2013-128ST Proposed Test Date: 08/14/2013
Permit No.: 03735 Revision No.: T37 County: Bladen Region: FRO
Protocol Reviewer: Gregg O'Neal Protocol Review Assigned Date: 07/26/2013
Emission Sources:
NS-C Nafion Vinyl Ethers South process [MACT FFFF]
NS-C Nafion Vinyl Ethers South process [MACT FFFF]
NS-C Nafion Vinyl Ethers South process [MACT FFFF]
Draft Submitted: (1) (2)
Draft Returned: (1) (2)
Final Draft Approval:
Final Letter/Memo Issued:�c ZR�'
Notes:
(3 )_
(3 )_
Date:_
/�%r
DEQ-CFW 00071374

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DEQ-CFW 00071375

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TO: SHANNON VOGEL
Protocol Transmittal Form - from Region to SSCB
Facility Name: DuPont Company - Fayetteville Works
Tracking No.: 2013-128ST
Permit No.: 03735 Revision No.: T37
Protocol Received in Region: 06/28/2013
Protocol Sent to SSCB: 07/16/2013
Proposed Test Date: 08/14/2013
Assigned Inspector: Gregory Reeves
Comments:
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JUL 1 13 t it
AIR QUALITY
;. ^PY SOURC'F cU�api „P„
7/16/2013
Facility ID: 0900009
County: Bladen
U_ J U L 1 7 2013
Region: FRO
DEQ-CFW 00071376

r.rw.r
L PROTOCOL SUBMITTAL FORM (Rev. 2010a)
HCDENR Dm.g1rnN OF Ant OUALITY PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultants, and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAO Regional
Supervisor at Ieast 45 days prior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary, attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available from the DAQ website (http://daq.state.ne.us/enf/soureetesv)
Specify Appropriate Regional Office: (check one)
❑ Asheville ® Fayetteville ❑ Mooresville ❑ Raleigh ❑ Washington ❑ Wilmington ❑ Winston-Salem
Facility Name: Dupont Fayetteville Works
Testing Company: Entec Services, Inc.
Facility ID No: 0900009
Facility Contact Person / mailing address & email:
Testing Company Contact Person / mailing address & email:
Ms. Dianne Fields
Mr. Keith Poole RECEIVED
DuPont Inc.
Entec Services, Inc.
22828 NC Hwy 87 West
301 Brookdale Street JU 2 ���3
Fayetteville, NC 28306
Kannapolis, NC 28083
Email Address: [e-mail] REGIONAL OFFICE
Email Address: [e-mail]
Phone:[phone]
Fax:[phone]
Phone:[phone]
Fax:
Mobile No.:
Mobile No.: 704-796-73,
Air Permit Number & Revision: 03537T37
Permitted Source Name and ID No.: Nafiong Vinyl Ethers South
Process (ID No. NS-C)
Permitted Maximum Process Rate:
Maximum Normal Operation Process Rate:
Target Process Rate for Testing:
not applicable
60.4 kg/hr
60.4 kg/hr
1.1) What is the Mecific purpose for the proposed testing? (permit condition, NSPS, NESHAP, etc, see gui "ee do c : 9 ' ulQtia� �y �}
jj �/
requires an emissions test every 10 years to determine the destruction efficiency of this wet scrubber.
Is this an initial performance test? ❑ Yes or ®No
1.2) List all state and federal regulations that apply to the proposed testing (see guidance doc): 40 CFR 98.1 )(i) JUL 2011
1.3) Will the test results be used for other regulatory purposes (e.g., emission inventories, permit application, 9:1, W&1h50t11td&Ab-dW, J
® Yes or ❑ No If yes, explain. Emitted quantities of acid fluoride compounds, reported as hydrogen fluoride on the annual
emissions inventory, are based on the control efficiency of this wet scrubber.
1.4) How will production/process & control device data be documented during testing (list specific control equipment, process parameters,
instrumentation that will be used, frequency of data collection, collected by computer/manually, etc.)? TEST WILL NOT BE
ACCEPTED WITHOUT APPROPRIATE PRODUCTION/PltOCESS & CONTROL DEVICE OPERATION DATA.
Data will be collected using computer historian IP21 and/or DCS backup historian on documented on frequency of every 5 minutes. The
following process tags will be used in IP21 to document production/process & control device data: VE-S PM: 1883FT production flow;
VE-S PE: 1858FT production flow; VES WGS recirculation flow 2223FC; VES WGS inlet flow 2205FG; VES WGS outlet flow
2243FG
1.5) Provide a brief description of the source (including control equipment) and attach source or process flow diagram from source through
stack exit: Nafion® Vinyl Ethers South process controlled by a baffle -plate scrubber (control device ID No. NCD-Hdr2)
1.6) Provide a brief description of the sampling location, attach schematic of sampling location, and indicate whether concurrent testing will
be conducted at other sampling locations (Approval of protocol without this data will not exempt you from -Method 1 criteria):
The sample locations are on the inlet to the WGS immediately downstream of inlet flow 2205FG and the exhaust of WGS immediately
downstream of outlet flow 224317G.
DEQ-CFW 00071377

PROTOCOL SUBMITTAL FORM (Rev. 2010a)
NCDENR. DIVISION OF AIR QUALITY PAGE 2 OF 2
2.1) Provide the following information for each test parameter.
Comments
Target
Proposed
Number of
Test Run
# of Sampling
Pollutant
Test Method
Test Runs
Duration
Points
BF
Modified 26*
3
60 min
N/A
Inlet and outlet Testing Very High
Concentration on Inlet.
2.2) Will all testing be conducted in strict accordance with the applicable test methods? If answer is no, attach
❑ yes
® No
complete documentation of all modifications and/or deviations to the applicable test methods.
2.3) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites?
®Yes
El No
Attach supporting documentation.
2.4) Has cyclonic flow been documented at this source (EPA Method 1 Section 11.4)?
❑ Yes
®No
ABSENCE OF CYCLONIC FLOW MUST BE VERIFIED DURING CURRENT TESTING.
2.5) Will the oxygen concentration be determined by ❑ EPA Method 3 via Orsat or ❑ strict EPA Method 3A (specify)
❑Yes
®No
If answer is no, see Question 2.2 above. (Fyrites are NOT allowed per 15A NCAC 2D .2606)
2.6) Do any of the proposed test methods require analysis of EPA audit samples? If yes, notify Regional Office
® yes
❑ No
a minimum of 45 days prior to testing to allow for audit sample preparation and shipment.
2.7) Has all testing equipment been calibrated within the past year? If answer is no, explain.
Yes
❑ No
2.8a) Have all calibration gases been certified by EPA Protocol 1 procedures? (Answer only as applicable)
❑ Yes
❑ No
2.8b) Is a dilution system (via EPA Method 205) proposed? (Answer only as applicable)
❑ Yes
❑ No
2.8c) Attach a summary of e4cted calibration gas concentrations for all proposed instrumental test methods.
2. = i , prr ssed test schedule? DAO Regional Supervisor must be notified a minimum of 15 days prior to the actual test dates)
OES NO CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
Wednesday August 14, 013
Additional Comments: Flows ill be determined by installed flow meters.
**Inlet Method 26 modified to large teflon impingers due to high concentrations expected.
Signatures: Representatives from the permitted facility and the contracted testing company must provide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
c
DigitallyW. Keith DN:m= .Keitgned byW. ole,o=h Poole
'; DN: rn=, In,, h Poole, is Enter
,Services, Inc, ou=Technkal Writer,
email="[e-mail],
Poole /
D;te: 1.013.06.2611'.0057.04W
PermittedIlacility Representative Date
Testing Company Representative Date
Name: Dianne Fields
Name: W. Keith Poole RECCC
IVED
Title: Nafion/Fluoromonomers Manufacturing
Title: Carolinas Operations M013
Technical Sr Engineer
Company: DuPont Inc.
Company: Entec Services, Inc.
ENR-FAYETTEMLLE REGIONAL OFFICE
DEQ-CFW 00071378

Outlet
Sample
Point
Inlet Knock out pot
TO VENT STACK
��

k*Ewmm
CES, SII'+11 .
STACK TESTING AND POLLUTION
CONTROL. SYSTEM EVALUAnON
July 19, 2013
Ms. Shannon Vogel
NCDENR — Technical Services
1641 Mail Service Center
Raleigh, NC 27699
Dear Ms. Vogel,
The Dupont Chemical Company plant in Fayetteville, NC has scheduled compliance testing for August
13 and 14 on two scrubbers (Permit IDs NCD-HDR-1 and NCD-HDR-2). Entec Services, Inc. has been
subcontracted to perform this sampling. Protocols were submitted earlier this week outlining the
sampling.
In researching this project, it was discovered that the concentrations of HF were extremely high,
approximately 800,000 ppm on the inlet and exhaust concentrations averaging about 3,000 ppm. An
approved audit provider (ERA) was contacted but informed us that the only available audits ranged from
5 — 500 ppm. Based on this information, Entec would like to submit a request for a variance on the audit
requirement for this project. If you have questions or need additional information, please call either Keith
Poole or Dan McCombs at 704.933.0244.
Sincerely,
Entec Services, Inc.
U �o-�,
W. Keith Poole
Carolinas Operations Manager
Cc: Ms. Diane Fields — Dupont Chemical
Mr. Steven Vozzo — Fayetteville Regional Office
Entec File
301 Brookdale St., Kannapolis, NC 28083 P.704.933.0244 ENTECSERVICES.COM
DEQ-CFW 00071380

ff
da
"' PROTOCOL SUBMITTAL FORM (Rev. 2010a)
NCDENR DIVISION OF AIR QUALITY PAGE 1 OF 2
Purpose: The goals of the Protocol Submittal Form are to initiate communication between representatives of the permitted facility,
the testing consultants, and the DAQ as well as to identify and resolve any specific testing concerns prior to testing.
Instructions: Use Guidance Document to fill out this form. Submit all forms and additional information to the DAO Retionai
Supervisor at least 45 days prior to testing. Complete one form for each sampling location. If this form does not supply
sufficient space to completely answer all questions or if additional relevant information is necessary, attach additional
documentation and/or information to the original form. Questions and/or comments should be directed to the appropriate
Regional Supervisor.
This form and its Guidance Document are available from the DAQ website (http://daq.state.nc.us/enVsoureetest/)
Specify Appropriate Regional Office: (check one)
❑ Asheville ® Fayetteville ❑ Mooresville ❑ Raleigh ❑ Washington ❑ Wilmington ❑ Winston-Salem
Facility Name: Dupont Fayetteville Works
Testing Company: Entec Services, Inc.
Facility ID No: 0900009
Facility Contact Person / mailing address & email:
Testing Company Contact Person / mailing address & email:
Ms. Dianne Fields
Mr. Keith Poole
DuPont Inc.
Entec Services, Inc.
22828 NC Hwy 87 West
301 Brookdale Street
Fayetteville, NC 28306
Kannapolis, NC 28083
Email Address: [e-mail]
Email Address: [e-mail]
Phone:[phone]
Fax:[phone]
Phone:[phone]
Fax:
Mobile No.:
I
Mobile No.: 704-796-7308
Air Permit Number & Revision: 03537T37
Permitted Source Name and ID No.: Nafion® Vinyl Ethers South
Process (ID No. NS-C)
Permitted Maximum Process Rate:
Maximum Normal Operation Proce�Rate:Target
Process Rate for Testing:
not applicable
60.4 kg/hr
60.4 kg/hr
1.1) What is the s ep cific purpose for the proposed testing? (permit condition, NSPS, NESHAP, etc, see guidance doc): Part 98 Subpart L
requires an emissions test every 10 years to determine the destruction efficiency of this wet scrubber.
Is this an initial performance test? ❑ Yes or ® No
1.2) List all state and federal regulations that apply to the proposed testing (see guidance doc): 40 CFR 98.124(g)(2)(i)
1.3) Will the test results be used for other regulatory purposes (e.g., emission inventories, permit application, etc.) beyond that stated above?
® Yes or ❑ No If yes, explain. Emitted quantities of acid fluoride compounds, reported as hydrogen fluoride on the annual
emissions inventory, are based on the control efficiency of this wet scrubber.
1.4) How will production/process & control device data be documented during testing (list specific control equipment, process parameters,
instrumentation that will be used, frequency of data collection, collected by computer/manually, etc.)? TEST WILL NOT BE
ACCEPTED WITHOUT APPROPRIATE PRODUCTION/PlbCESS & CONTROL DEVICE OPERATION DATA.
Data will be collected using computer historian IP21 and/or DCS backup historian on documented on frequency of every 5 minutes. The
following process tags will be used in IP21 to document production/process & control device data: VE-S PM: 1883FT production flow;
VE-S PE: 1858FT production flow; VES WGS recirculation flow 2223FC; VES WGS inlet flow 2205FG; VES WGS outlet flow
2243FG
1.5) Provide a brief description of the source (including control equipment) and attach source or process flow diagram from source through
stack exit: Nafion(V Vinyl Ethers South process controlled by a baffle -plate scrubber (control device ID No. NCD-Hdr2)
1.6) Provide a brief description of the sampling location, attach schematic of sampling location, and indicate whether concurrent testing will
be conducted at other sampling locations (Approval of protocol without this data will not exempt you from Method 1 criteria):
The sample locations are on the inlet to the WGS immediately downstream of inlet flow 2205FG and the exhaust of WGS immediately
downstream of outlet flow 2243FG.
DEQ-CFW 00071381

w
AVONVA
MV�
NCDENA� PROTOCOL SUBMITTAL FORM (Rev. 2010a)
R 11NIC1rnN nr A m nin A T M.-.,
PAGE 2 OF 2
2.1) Provide the following information for each test parameter.
--
Comments
Target
Pollutant
Proposed
Test Method
Number of
Test Runs
Test Run
Duration
# of Sampling
posts
BF
Modified 26*
3
60 min
N/A
Inlet and outlet Testing Very High
Concentration on Inlet.
2.2) Will all testing be conducted in strict accordance with the applicable test methods? If answer is no, attach
complete documentation of all modifications and/or deviations to the applicable test methods.
❑ Yes
® No
2.3) Does the proposed sampling location meet the minimum EPA Method 1 criteria for acceptable measurement sites?
Attach supporting documentation.
® Yes
❑ No
2.4) Has cyclonic flow been documented at this source (EPA Method 1 Section 11.4)?
ABSENCE OF CYCLONIC FLOW MUST BE VERIFIED DURING CURRENT TESTING.
Yes
®No
2.5) Will the oxygen concentration be determined by ❑ EPA Method 3 via Orsat or ❑ strict EPA Method 3A (specify)
If answer is no, see Question 2.2 above. (Fyrites are NOT allowed per 15A NCAC 2D .2606)
❑ Yes
® No
2.6) Do any of the proposed test methods require analysis of EPA audit samples? If yes, notify Regional Office
a minimum of 45 days prior to testing to allow for audit sample preparation and shipment.
®Yes
❑ No
2.7) Has all testing equipment been calibrated within the past year? If answer is no, explain.
® Yes
❑ No
2.8a) Have all calibration gases been certified by EPA Protocol 1 procedures? (Answer only as applicable)
❑ Yes
❑ No
2.8b) Is a dilution system (via EPA Method 205) proposed? (Answer only as applicable)
❑ Yes
Q No
2.8c) Attach a summary of expected calibration gas concentrations for all proposed instrumental test methods.
2.9) What is proposed test schedule? DAO Regional supervisor must be notified a minimum of 15 days prior to the actual test date(s)
THIS FORM DOES NOT CONSTITUTE 15 DAY REGIONAL OFFICE NOTIFICATION
Wednesday August 14, 2013
Additional Comments: Flows will be determined by installed flow meters.
**Inlet Method 26 modified to large teflon impingers due to high concentrations expected.
Signatures: Representatives from the permitted facility and the contracted testing company must Provide signatures below certifying
that the information provided on this form and any attached information is accurate and complete.
Permitted acility Representative Date
Testing Company Representative
Date
Name: Dianne Fields
Name: W. Keith Poole
Title: Nafion/Fluoromonomers Manufacturing
Technical Sr EngineerTitle:
Carolinas Operations Manager
Company: DuPont Inc.
Company:. Entec Services, Inc.
DEQ-CFW 00071382