DEQ-CFW_00073586

NORTH CAROLINA DIVISION OF
AIR QUALITY
Permit Issue Date:
Air Permit Review
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306
SIC: 3081 / Unsupported Plastics Film And Sheet
NAILS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Facility Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC
28306+7332
Contact Data
Authorized Contact
Ellis McGaughy
Plant Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC 28306
Technical Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville, NC
28306+7332
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Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Gregory Reeves
Date of Last Inspection: 06/20/2013
Compliance Code: 3 / Compliance -
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other: NSPS and MACT Avoidance
Application Data
Application Number: 0900009.13C
Date Received: 11/X/2013
Application Type: Modification
Application Schedule: TV-502(b)(10)
Existing Permit Data
Existing Permit Number: 03735/T37
Existing Permit Issue Date: 08/17/2011
Existing Permit Expiration Date: 01/31/2015
Review Engineer: Jenny Kelvington Comments / Recommendations:
Issue 03735/T38
Review Engineer's Signature: Date: Permit Issue Date: December 16, 2013
Permit Expiration Date: January 31, 2015
I. Purpose of Application
NC DAQ received an application on October 31, 2013 for a significant modification to the Title V Air
Quality Permit at the DuPont facility located in Fayetteville, North Carolina. DuPont requested the
following changes:
- Removal of No. 6 fuel oil as a type of fuel that can be burned in boilers (ID Nos. PS -A, PS-B, and
PS-C);
- Removal of the boiler testing requirements established in the permit to demonstrate compliance with
the Case -by Case MACT emissions limits that apply when No. 6 fuel oil is burned; and
- Replacement of existing NSPS and MACT conditions for the temporary boiler (ID No. PS -Temp)
with avoidance conditions limiting the number of consecutive days the boiler may remain on site to
less than 180 days.
- Addition of an insignificant activity.
DEQ-CFW 00073586

In addition to these permit changes, each change DuPont has implemented using the 502(b)(10)
notification process since the last significant permit modification or renewal will be incorporated into this
modification. The revisions include:
Notification No.
502(b)(10) Change
0900009.13C
Decreasing in the filter area for bagfilter (ID No. BCD-C2) from 6,858 square feet to
6,245 square feet.
0900009.13C
Replacing an aqueous COZ scrubber system with a gas separation "permeator" system to
eliminate wastewater discharge from the vinyl ethers north process (ID No. NS-B).
H. Permit Revisions
No. 6 Fuel Removal
DuPont has requested that No. 6 fuel oil be removed as a fuel option for boilers (ID Nos. PS -A and PS-
B). As a result of removing this fuel, the permit will be revised as follows:
• The description of the two boilers in Section 2.1 A and 2.2 A will be changed to:
Natural gas/No. 2 fuel oil -fired boiler (ID No. PS -A), 139.4 million Btu per hour maximum heat input
Natural gas/No. 2 fuel oil -fired boiler (ID No. PS-B), 88.4 million Btu per hour maximum heat input
• The reference to No. 6 fuel oil will be removed from the summary table and the following permit
conditions: 2.1 A. La, l .d, 5.c.ii, 5.d.i, and 5.e.i and 2.2 A. l .c.ii and 5.d.i.
• The following permit conditions will be deleted: 2.1 A.2.d, 2.e, 2.f, Id, 3.e, 3.g, 6.b, and 6.c.
• The following permit conditions will be renumbered: 2.1 A.3.f, 6.d, 6.e, 61, and 6.g.
Temporary Boiler NSPS and MACT Avoidance Conditions
DuPont has requested that the existing NSPS and MACT conditions for the temporary boiler (ID No. PS -
Temp) be replaced with avoidance conditions limiting the number of consecutive days the boiler may
remain on site to no more than 180 days. As a result, the permit will be revised as follows:
• The NSPS and MACT reference in the summary table in Section 2.1 F will replaced with
references to 2Q .0317 avoidance conditions.
• The following existing permit conditions will be deleted: 2.1 F.2 (all) and 2.1 F.4 (all)
• The following new permit conditions will be added: 2.1 F.2 (2D .0516); F.3 (2D .0521), F.4 (2Q
.0317), and F.6 (2Q .0317)
Filter Size Change for Fabric Filter (ID No. BCD-C2)
DuPont has changed the fabric filter size of BCD-C2 using the 502(b)(10) notification process. The
control device description in the Section 1.0 table permit change has been updated to show the filter area
is now 6,245 square feet.
Aqueous CO, Scrubber System Replacement with a Gas Separation "Permeator" System
No change to the permit is required.
DEQ-CFW 00073587

Summary of Changes to Previous Permit (No. 03735T37)
Page(s)
Section
Description of Change(s)
Insignificant
Added "Polyvinyl Fluoride Process No. 2 house vacuum system" as an
N/A
Activities List
insignificant activity.
Amend permit revision numbers and issuance/effective dates and update to most
1
Permit Cover Page
recent shell version
• Removed No. 6 fuel oil from the descriptions for boilers PS -A, PS-B, and PS-C.
3 to 6
1.0
• Revised the fabric filter size for BCD-C2 from 6,858 ft2 to 6,245 ft2'.
• Added page numbers of applicable requirements.
• Removed No. 6 fuel oil from the descriptions for boilers PS -A, PS-B, and PS-C.
6 to 11
2.1 A
• Removed all the applicable requirements pertaining to the firing of No. 6 fuel
oil.
• Replaced the NSPS and MACT conditions with avoidance conditions limiting
the number of consecutive days the temporary boiler may remain on site to 180
31 to 33
2.1 F
days.
• Added 2D .0516 and 2D .0521 conditions for the temporary boiler.
39 to 40
2.2 A
• Removed No. 6 fuel oil from the descriptions for boilers PS -A, PS-B, and PS-C.
46
General Conditions
Updated General Conditions to most recent shell version 3.6.
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On June 20, 2013, Mr. Greg Reeves (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. The facility has
received one Notice of Violation (NOV) in the past five years. On January 6, 2009, a NOV with a Notice
of Recommendation for Enforcement (NRE) for operating the decontamination sources (1D Nos. NS-N,
NS-O, and NS-P) without a permit. These sources are now incorporated into the permit. Continued
compliance is expected.
IV. Regulatory Review
No. 6 Fuel Removal
The removal of No. 6 fuel oil as an option for boilers (PS -A and PS-B) results in a potential 97.4 tons per
year potential decrease in sulfur dioxide emissions.
Applicable Regulatory Requirements
• 15A NCAC 2D .1109 (Revised)
The initial compliance date for the emission limitations and associated monitoring, recordkeeping,
and reporting requirements in Case -by -Case Boiler MALT permit condition is December 12, 2013.
This condition limits the emissions offilterable PM, mercury, and carbon monoxide when No. 6fuel
oil is burned in an affected boiler and requires initial stack testing within 180 days and periodic stack
testing, thereafter, to demonstrate compliance with the limits. Because the emissions limits apply
only to No. 6 fuel combustion and because stack testing is intended to be performed when No. 6 is
fired in the boiler(s), these limits and testing requirements have been removed from the permit.
The boilers will continue to be subject to work practice standards in the permit effective December
12, 2013. These practices include annual burner inspection and maintenance and recordkeeping.
Compliance is expected.
DEQ-CFW 00073588

Temporary Boiler NSPS and MACT Avoidance Conditions
Applicable Regulatory Requirements
• 15A NCAC 2D. 0516 (Added)
This regulation limits SO2 emissions to no more than 2.3 lb/mmBtu of heat input. Compliance is
indicated as DuPont plans to burn only fuels in the boiler that emit no more than 0.06 lb SO2 per
million Btu of heat input.
• 15A NCAC 2D .0521 (Added)
The combustion of natural gas and distillate fuel oil is inherently low in visible emissions.
Compliance is indicated.
• 15A NCAC 2D .0524 (Removed)
• 15A NCAC 2D .1109 (Removed)
• 15A NCAC 2Q .0317 (NSPS and MACT Avoidance Added)
In order to avoid the applicability of 15A NCAC 2D. 0524 and 2D. 1109, the temporary boiler may
not remain on site for more than 180 consecutive days. This boiler is not currently on site and there
are no plans for their use in the near future. Additionally for NSPS avoidance, the maximum sulfur
content of the fuel burned in the boiler shall not contribute to more than 0.06 lb/mmBtu of SO2
emissions. DuPont is expected to limit operation to less than I80 consecutive days and use compliant
fuel when in use. Compliance is expected.
Filter Size Change for BCD-C2
Applicable Regulatory Requirements:
• 15A NCAC 2D .0515; Particulates emissions limited to E = 4.10 pO.67
• 15A NCAC 2D .0521; Visible emissions limited to 20% opacity
The 9% reduction in the filter size of the fabric filter controlling emissions from the Butacite
polyvinyl butyral flake dryer (ID No. BS-Q is not expected to affect DuPont ability to comply with
the particulate and visible emissions limits. During the most recent facility inspection no visible
emissions were observed from this process and all inspection records were up to date. Continued
compliance is expected.
Aqueous CO, Scrubber System Replacement with a Gas Separation "Permeator" System for the
Vinyl Ethers North Process (ID No. NS-B)
The Vinyl Ethers North (VEN) process 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. As a result of the scrubber replacement with a gas
separation system, CO2 emissions will increase by 267 tons per year but the emissions of all other
pollutants will be unchanged.
Applicable Regulatory Requirements:
• 15A NCAC 2D .1806 (Odors — Not Affected)
The system replacement does not increase odors.
• 15A NCAC 2D .1100 (Air Toxics Limits - Not Affected)
The system replacement does not increase the emissions of any air toxic pollutant.
• 15A NCAC 2Q .0317 (VOC emissions limited to less than 68.9 tpy - Not Affected)
The system replacement does not increase the VOC emissions.
• 15A NCAC 2D .1111 (Leak Detection and Repair "LDAR" Requirements)
The VEN process includes 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
DEQ-CFW 00073589

FFFF and subject to equipment leak provisions in the permit. DuPont will be subject to these
provisions for any additional pumps, valves, connectors, and pressure relief valves, etc. in light
liquid/vapor service. they add as a result of the system replacement. DuPont has an extensive LDAR
program with monthly leak inspections and physical identification tags for each affected unit.
Continued compliance is expected.
V. 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 (ID 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 Nafiori 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 (ID No. NS-M).
03735T32 January 2008
"Part 2" Significant 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).
03735T35 February 2010
Permit renewal and "Part 2" significant modification for the Polyvinyl
Fluoride (PVF) Process No. 2 (ID No. FS-C), new boiler (ID No. PS-C),
natural gas firing in existing boilers, and various decontamination
processes (ID Nos. NS-N, NS-O, and NS-P).
03735T36 December 2010
Significant modification to add the 1120) — Part 2 MACT Hammer
requirements for Boilers & Process Heaters
03735T37 August 2011
Minor modification to allow the calculation of vinyl fluoride emissions
from the polyvinyl fluoride manufacturing maintenance headers based on
the density of the stream using densitometers.
DEQ-CFW 00073590

VI. Proposed Permit Review Summary
• Mr. Greg Reeves (FRO) was provided a copy of the draft permit for review on November 1, 2013.
• Mr. Michael Johnson (DuPont) was provided a draft permit for review on November 1, 2013. Mr.
Johnson requested the addition of insignificant
• U.S. EPA, Region IV was provided a draft permit for review on November 6, 2013. EPA has
chosen not to target the permit for review.
• The Public Notice for this permit was posted on the NC DAQ website at www.ncair.ora on
November 6, 2013. No comments were received.
VII. Other Regulatory Considerations
• The application including the Reduction and Recycling form was received on October 31, 2013.
• The application fee for Application No. 0900009.013C ($889.00) was received on November 15,
2013.
• A Professional Engineers Seal is NOT required for this application.
• A zoning consistency determination is NOT required for this application.
VIII. 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. 03735T38
DEQ-CFW 00073591