DEQ-CFW_00086178

0 AIR EMISSIONS INVENTORY SUPPORTING DOCUMENTATION
Emission Source ID No.:
I-2
Emission Source Description:
Nafion® Waste DMSO Storage Tank
Process Description:
This tank is used as an intermediate storage space for disposal of DMSO (dimethyl
sulfoxide) offsite. DMSO is used in the Nafion® Products Hydrolysis process and is disposed of
onsite via the site's wastewater treatment plant ("WWTP"). When the material in Hydrolysis
can no longer be used for the process, the chemical is transferred to the Waste DMSO Storage
Tank. From this tank, the DMSO solution is pumped to the WWTP at a rate of 5 gallons per
minute. The tank is open to the atmosphere with a gooseneck pipe coming off the top that ends
12" above the diked area.
Basis and Assumptions:
- Direct vent to atmosphere
Tank volume = 6000 gallons or 802 ft3
- DMSO vapor pressure = 0.46 mm Hg @ 20°C
- Molar volume of an Ideal Gas @ 0°C and 1 atm = 359 ft3/(lb-mole)
- Molecular Weight of DMSO = 78 (78 lb DMSO / lb -mole DMSO)
- Assume one complete tank volume turnover per day for point source emissions.
- Assume DuPont Good Emission Factor on Equipment Leaks for fugitive emissions
(See Appendix A).
- Flange emissions were used for all equipment except valves and pumps.
Information Inputs and Source of Inputs:
Information
Source
Total DMSO (lb/yr)
Pump -out to WWTP is 5 gallons per hour. Assume pump -out is
constant for 8760 hours per year. Total gallons would therefore be
43,800 gallons per year.
Vapor pressure
MSDS #22310402, CAS #67-68-5
Tank volume
Procedure PR-70, W1535321, or NBPF000351
Number of Each Type
W1535321 and verifying at source
of Equipment
% Production per
Assume 25% per quarter since tank is typically containing waste.
Quarter
DEQ-CFW 00086178

•
•
•
Dimethyl sulfoxide (DMSO)
Point Source Emissions Determination:
Vapor pressure of DMSO = 0.46 mm Hg at 20°C
Mole fraction DMSO in vapor (using Dalton's law):
CAS No. 67-68-5
Mole fraction DMSO = Vapor pressure DMSO = 0.46 mm Hg = 0.000605 mole DMSO
Total pressure in tank 760 mm Hg mole gas in tank
Molar volume at 0°C and 1 atm = 359 ft3 =>
Pounds of DMSO per tank volume:
Molar volume at 20°C and 1 atm = 385 ft3
802 ft3 * lb -mole * 0.000605 mole DMSO * 78 lb DMSO = 0.098 lb DMSO
tank volume 385 ft3 lb -mole gas in tank mole DMSO tank volume
Total DMSO emissions per year from tank volume, assuming one tank volume per day:
0.098 lb DMSO * 1 tank volume * 365 days * 1 ton = 0.018 ton DMSO / yr
tank volume day year 2000 lbs
Fugitive Emissions Determination:
Equipment
Component
Number of
Com onents
Good Factor
(lb/hr/com onent)
Emissions
(lb/hr)
Emissions
(ton/yr)
Pump Seal
1
0.0075
0.0075
0.033
Heavy Liquid Valve
20
0.00352
0.0704
0.308
Open-ended Line
1
0.0215
0.0215
0.094
Flange/Connection
9
0.00031
0.00279
0.012
Total
0.447
Good factor (lb/hr/component) x Number of Components = Emissions (lb/hr)
Emissions (lb/hr) x 1 ton / 20001bs x 24 hr/day x 365 days/year = Emissions (ton/yr)
Total fugitive DMSO emissions per year = 0.447 ton DMSO / year
Emissions Summary:
Point Source Emissions + Fugitive Emissions = Total Emissions
0.018 ton DMSO / year + 0.447 ton DMSO / year = 0.47 ton DMSO / year
DEQ-CFW 00086179

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APPENDIX A: FUGITIVE EMISSION LEAK RATES FOR PROCESS EQUIPMENT
Fugitive emission studies have been done on a number of DuPont facilities and the
measurements were considerable lower than emission factors recommended by the EPA for
SOCMI chemical processes. These screening and bagging data have been used to establish
"typical" emission factors from DuPont facilities. The data separated into three categories of
emission levels for "as found" emissions form plants who were not involved in LDAR programs.
As a result of this effort, three sets of DuPont factors were developed: "superior", "excellent",
and "good." The superior factors are typical of processes that contain extremely hazardous
materials, i.e. phosgene (COC12), chlorine (C12), and hydrogen fluoride (HF). A set of example
questions to help guide DuPont sites as to when to use the different categories was also
developed and is discussed in the next section. The three categories represent the range found at
DuPont facilities, but still are much lower than EPA SOCMI factors. All three sets of factors are
listed below.
EMMISION FACTORS (Ib/hr/component)
COMPONENT
SERVICE
SUPERIOR
EXCELLENT
GOOD
EPA
SOCMI
Pump Seals
Light Liquid
xxxxx
0.00115
0.0075
0.109
Pump Seals
Heavy Liquid
xxxxx
0.00115
0.0075
0.047
Valves
Gas
xxxxx
0.00039
0.00549
0.012
Valves
Light Liquid
xxxxx
0.00036
0.00352
0.016
Valves
Heavy Liquid
xxxxx
0.00036
0.00352
0.00051
Pressure Relief
Seals
Gas/Vapor
xxxxx
0.00012
0.00013
0.23
Open Ended
Lines
All
xxxxx
0.001
0.0215
0.0037
Flanges
All
xxxxx
0.00018
0.00031
0.0018
Sampling
Connections
All
xxxxx
0.00018
0.00031
0.033
Compressor Seals
Gas/Vapor
N/A
N/A
N/A
0.50
Overall Emission
Factor
1/10,000
1/20
1/3
1/1
Heavy liquid means a liquid with a true vapor pressure of less than 0.3 kPa (0.04 psia) at a
temperature of 294.3 °K (70 °F); or which has 0.1 Reid Vapor Pressure; or which when distilled
requires a temperature of 421.95 °K (300 °F); or greater to recover 10 percent of the liquid as
determined by ASTM method D86-82.
0 Light liquid means a liquid that is not a heavy liquid.
DEQ-CFW 00086180

0 Which factors should I use?
•
The factors suggested above represent DuPont "experience" and more accurately reflect
OVERALL fugitive emissions from DuPont facilities, i.e. the DuPont culture. The comparisons
were made with a limited database and the factors suggested here reflect a comparison of overall
or aggregate emission levels to those predicted by EPA SOCMI factors. It should be pointed out
that individual DuPont factors did vary from specific source service factors suggested by EPA,
i.e. light or heavy liquid service. For the "Superior" category, the individual factors are
extremely small numbers, and therefore, it is suggested to calculate the emission estimate with
EPA SOCMI factors, and then divide the total by the 10,000 factor. Since there is considerable
variability in ANY individual component leak rate due to type, age, size, service, etc., it is also
suggested to check overall predicted emissions from the "Excellent" and "Good" categories in
the same way, i.e. use EPA factors and then divide by 20 or 3, respectively.
In order to determine which factors to use, a series of questions were developed to index a
facility into one of the three categories. These are general guidance, and not definitive in the
sense of black or white. Additionally, use of the DuPont Factors may be challenged by State
Environmental Agencies since they do vary from EPA prescribed factors. However, past
validation efforts gave overall estimates within 10-20% of those based on DuPont factors. For
additional information and assistance, please call Tom Kittleman, Ducom 366-4718.
Superior factors should only be sued by facilities that use extremely hazardous materials, i.e.
phosgene, chlorine or HF. The maintenance culture of these operations is to detect and repair
leaks immediately due to the inherent toxicity of the chemicals. Most other processes/facilities
will be either excellent or good.
The "Excellent" factors listed above should be used only after HONESTLY answering the list of
questions attached, and at least 4 or 5 answers are "Yes." otherwise use "Good".
QUESTIONS FOR DETERMINING UNIT -SPECIFIC FACTOR CATEGORY
1. Are techniques available and used to routinely locate specific leaks? Examples include SOZ
bombs, ammonia solution, special detectors (such as those for HCN or phosgene), chemical
badges, and sniff testers.
2. Do you perform leak checks in this process area at least once per day?
3. Are specific procedures used on each start-up to minimized fugitive emissions? Examples
include hydrostatic tests, special leak tests, etc.
4. Do you have a documented check list startup procedure that helps locate routine leaks?
5. Do you have a formal procedure that requires leaks be repaired in a timely manner, including
use of overtime if necessary?
DEQ-CFW 00086181

SARA 313 2008
All units in Lbs.
Material Balance For: Methylene Chloride
<-------- -----------------------
R= 0
B = 3661
I
I
A =
0
<--------
PROCESS
--------->
G= 0
J=
0
I = 10482
--------------->
--------->
-------->
H = 0
<--------------
K =
------------------------
6821
<--------
I
I
I
I
---------->
I
C= 0 I
I
I
I
I
I
I F=
0
<---------- I
I ---------->
S= 0
M = 24
N = 8162
------>
L = 1365
A = Emitted to Air - Permitted Point Source
B = Emitted to Air - Fugitive & Releases
0
3661
C = Emitted to Ground - (Release)
0
F = Rework inventory on pad
0
G = Generated In Process - (Specify How)
0
H = Destroyed or Transformed in Process - (Specify How)
0
1 = Introduced into Process - (Raw Ingredients Consumed)
10482
J = Shipped off with Product
0
K = Generated as Waste in Current Year
6821
L = Waste Stored from Previous Year
1365
M = Waste Stored at End of Current Year
24
N = Total Waste Shipped During Current Year
8162
R = Returned to System w/o Recycling Step (From Prev Year)
0
S = Diallylamine & Propylene Oxide added to adjust pH.
0
NOTES: All this waste was shipped to Heritage WTI
F - Precursors rework approximately 0 Ibs in 2008.
12/31/08 there were 0 rework drums on the inventory pad
+Beg. Inv. 21037
+Purchas 9600
-End Inv. 20155
Total 10482
6/9/2009
DEQ-CFW 00086182

Riverwater Sodium Hypochlorite (as Chlorine"°te) Fugitive Emissions Basis
River
Domestic
Equipment Component
Water
Water
Total
Excellent Rating
Service
Emissions
Service
Service
Components
(lb/hr/component)
(hr/yr)
(lb/yr)
Valves
1
1
2
0.00039
8760
7
Pressure Relief Seals
0
0
0
0
Open Ended Lines
0
0
0
0
Connections including fusible plugs
33
3
36
0.00018
8760
57
Sampling Connections
0
0
0
0
Total Pounds of Chlorine 64
Note: To be.conservative, it is assumed that the sodium hypochorite with a vapor pressure of 17 mmHg at 20 degrees C has the same fugitive
emissions as would anhydrous chlorine with a vapor pressure of 5100 mmHg.
QUESTIONS FOR DETERMINING UNIT -SPECIFIC FACTOR CATEGORY
1. Are techniques available and used to routinely locate specific leaks? Examples include SO2 bombs, ammonia solution, special detectors (such
as those for HCN or phosgene), chemical badges, and sniff testers.
Yes
2. Do you perform leak checks in this process area at least once per day?
Yes, Continous Monitor.
3. Are specific procedures used on each start-up to minimized fugitive emissions? Examples include hydrostatic tests, special leak tests, etc.
Yes
4. Do you have a documented check list startup procedure that helps locate routine leaks?
Yes
5. Do you have a formal procedure that requires leaks be repaired in a timely manner, including use of overtime if necessary?
Yes

•
2008 Air Emissions Inventory Supporting Documentation
Emission Source ID No.: I-5
Emission Source Description: Site -Wide Laboratories
Process and Emission Description:
The DuPont Company -Fayetteville Works has several laboratories located throughout the
site. The use of normal laboratory chemicals result in assumed emissions of these
compounds.
Basis and Assumptions:
The amount of the laboratory chemicals used in the various laboratories is not easily
quantified due to the current procurement procedures. In previous years these quantities
could and were determined. During those years, it was assumed that 100% of the laboratory
chemicals purchased were emitted as air emissions.
To be conservative, it will be assumed that the annual emission of laboratory chemicals is the
summation of the emissions that occurred in the four (4) year period from 2003 to 2006.
Information Inputs and Source of Inputs:
Information Inputs
Source of Inputs
Total pounds of laboratory chemicals
reported from 2003 through 2006.
Assumed conservative high estimates
Point Source Emissions Determination:
For the purpose of this report, it is assumed that all emissions are point source via the lab
hoods.
Equipment Emissions and Fugitive Emissions Determination:
For the purpose of this report, it is assumed that all emissions are point source via the lab
hoods.
DEQ-CFW 00086184

0 Point Source Emission Determination
•
Is
Emission Source ID No.: I-5
VOC Emissions Determination
The emission of VOC is determined by summing the total laboratory emissions
reported in the air emissions inventories from 2003 to 2006.
2003-2006 Summation Sitewide Laboratory Chemicals
Compounds
2003
2004
2005
2006
48-month
Total
Acetic Acid
252
258
403
913
Acrolein
1
1
Benzene
1
2
2
5
Bromine
17
9
26
Chloroform
1
1
Ethyl Acetate
5
12
17
Ethylene Dichloride
262
132
147
541
Hydrogen Chloride
80
15
95
n-Hexane
3
3
Nitric Acid
22
87
109
Toluene
31
31
Total VOC emissions would be the sum of the above compounds except for
bromine, hydrogen chloride, and nitric acid.
Total VOC emissions 1,512 lb. VOC
0.756 tons VOC
DEQ-CFW 00086185

0 2008 Air Emissions Inventory Supporting Documentation
•
Emission Source ID No.: I-6
Emission Source Description: Outdoor Abrasive Blasting Operation
Process and Emission Description:
The DuPont Company - Fayetteville Works has a free-standing structure that is used to
abrasive blast large metal parts prior to painting.
Basis and Assumptions:
The abrasive blasting activity in this structure is infrequent. Purchasing records of the
abrasive media used in this operation is the basis of the abrasive media consumption.
Per the AP-42 Section 13.2.6 particulate emission factors for abrasive blasting of mild steel
panels with a five mile per hour wind speed, total particulate matter emissions would be 27
pounds per 1,000 pounds of abrasive. The choice of this low wind speed is appropriate since
the blasting operation is conducted inside an enclosure.
Information Inputs and Source of Inputs:
Information Inputs
Source of Inputs
Total pounds of abrasive media
Fluor Daniels personnel responsible for the
abrasive blasting operation.
Point Source Emissions Determination:
For the purpose of this report, it is assumed that all emissions are fugitive.
Equipment Emissions and Fugitive Emissions Determination:
For the purpose of this report, it is assumed that all emissions are fugitive.
DEQ-CFW 00086186