DEQ-CFW_00086246

NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: August 4, 2008
Facility Data
Applicant (Facility's Name): DuPont Company - Fayetteville Works
Facility Address:
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
SIC: 3081 / Unsupported Plastics Film And Sheet
NAICS: 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
Karen Wrigley
Plant Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Technical Contact
Michael Johnson
Environmental Manager
[phone]
22828 NC Highway 87
West
Fayetteville NC,
28306+7332
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Christy Richardson
Date of Last Inspection: 04/16/2008
Compliance Code: 3/In Compliance - Inspectio
Permit Applicability (this application only)
SIP: 2D .0515, 2D .0521
NSPS: N/A
NESHAP: N/A
PSD: N/A
PSD Avoidance: VOC, SO2
NC Toxics: N/A
112(r): N/A
Other: 2D .1806 (odors), 2D .0541 (abrasive
blasting)
Application Data
Application Number: 0900009.08A
Date Received: 04/08/2008
Application Type: Modification
Application Schedule: TV-Sign-501(c)(2)
Existing Permit Data
Existing Permit Number: 03735/T32
Existing Permit Issue Date: 01/24/2008
Existing Permit Expiration Date: 01/31/2009
Review Engineer: Fern Paterson Comments / Recommendations:
Issue: 03735/T33
Rev ine�%s-S' nature, Date: Permit Issue Date: 08/04/08
1 � X/ Permit Expiration Date: 01/31/2009I I
1 9
I. Purpose of Application
The North Carolina Division of Air Quality (DAQ) received Application No. 0900009.08A from E.I. du Pont de
Nemours & Co., LLC (DuPont) on April 8, 2008. The application is for the following permit modifications:
(1) Construct and operate Polyvinyl Fluoride (PVF) Manufacturing No. 2 (ID No. FS-C).
(2) Add an abrasive blasting building (I) No. I-10) to the insignificant activity list in Attachment II of the permit.
DuPont is adding a building to enclose shot blast operations to clean product cylinders that are less than 8 feet
in length.
Pursuant to 15A NCAC 2Q .0317, DuPont will accept a PSD avoidance condition to limit VOC emissions from the
new PVF manufacturing operation (ID No. FS-C) and the existing PVF manufacturing operation (ID No. FS-B),
which commenced operation in September 2007. In addition, operation of the two PVF manufacturing operations
will result in an increased steam demand at the existing boilers of approximately 16,000 pounds of steam per hour,
which equates to about 19.7 million Btu per hour. DuPont will accept a PSD avoidance condition to limit SOz
emissions from the boilers to no greater than 702.5 tons per consecutive 12-month period. 1
' Johnson, Michael E. (DuPont Co., Fayetteville, NC). Letter to: Fern A. Paterson (NC DENR — DAQ, Raleigh, NC). 2008 Jul 24.
DEQ-CFW 00086246

Because avoidance conditions are required to avoid PSD permitting, the modification requires a significant
modification of the air quality permit pursuant to 15A NCAC 2Q .0516(b)(3). DuPont has requested a 2-Part
permitting procedure pursuant to 15A NCAC 2Q .0501(c)(2). DuPont submitted both the "Part I" and "Part H"
application for the proposed PVF manufacturing operations simultaneously. The "Part 2" application, assigned
Application No. 0900009.08B, was received by NC DAQ on April 8, 2008. DuPont has also submitted an
application for a Title V permit renewal, which was received on April 17, 2008.
H. Permit Modifications/Changes
The following table describes the modifications to the current permit.
Page(s)
Section
Description of Change(s)
N/A
Insignificant
Add "Abrasive blasting building" (ID No. I-10) to the insignificant activity
Activity List
list.
Global
Global
[Testing Requirement Citations] Change all references to 15A NCAC 2D
.0501(c) to 15A NCAC 2D .2601 to be consistent with a recent rule change.
1
Permit Cover Page
Amend permit revision numbers and issuance/effective dates.
5
Sec. 1, Table
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add table footnotes with procedural/Permit Shield information related to
the modification.
6
Sec. 2.1. A., Table
Add reference to PSD Avoidance Condition for SO2, which is located in
Section 2.2. A. 1. of the draft permit.
7
Sec. 2. L A.3.d.ii.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ protocol.
11
Sec. 2.1. B.2.c.ii.
Add clarification language to existing visible emission monitoring language
to be consistent with current DAQ protocol.
20
Sec. 2.1. G., Table
Add reference to PSD Avoidance Condition for SOZ, which is located in
Section 2.2. A. 1. of the draft permit.
23-26
Sec. 2.1. I.
- Revise source description of existing PVF process (ID No. FS-B).
- Add new PVF process (ID No. FS-C).
- Add clarification language to existing visible emission monitoring
language to be consistent with current DAQ protocol (Section 2.1. I.2.c.ii)
- Add PSD avoidance condition for VOC (Section 2.1. I.)
26-27
Section 2.2. A.
Add PSD avoidance condition limiting SOZ emissions from the existing
boilers to no greater than 702.5 tpy.
32-33
Sec. 2.2. B.3.
Add 15A NCAC 2D .0541 — "Control of Emissions from Abrasive
Blasting". This rule is state -enforceable only.
34-42
General Conditions
Update General Conditions with the most current version (v2.20), including
changes to General Condition JJ (Testing), new General Condition MM
(Fugitive Dust), and new General Condition NN (Modification Procedures).
III. Statement of Compliance
The DAQ has reviewed the compliance status of this facility. On April 16, 2008, Ms. Christy Richardson and Mr.
Tien Nguyen (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.
In November 2007, the facility was issued a Notice of Violation (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 00086247

IV. ;Regulatory Review
A. Polyvinyl Fluoride Manufacturing Facility No. 1 (ID No. FS-B)
Polyvinyl Fluoride Manufacturing Facility No. 2 (ID No. FS-C)
1. Description of Process/Modification
DuPont has an existing polyvinyl fluoride polymer (PVF) manufacturing operation (ID No. FS-B) that
was originally permitted on June 23, 2006 and commenced operation in September 2007. With this
application, DuPont is seeking authorization to construct and operate a second PVF manufacturing
process (ID No. FS-C),
The Fayetteville Works facility manufactures PVF in a solid powder form. PVF films are used in the
production of photovoltaic modules. In this process, PVF is formed from vinyl fluoride (VF) in a
continuous reactor. VF is a gas at atmospheric conditions, and is stored in a pressurized tank with a
polymerization inhibitor. VF is fed to the continuous reactor, first passing through a feed vessel in
which the inhibitor is removed and a small quantity of a modifier is added to improve product quality.
In the continuous reactor, a polymerization initiator is added to the VF and a crude PVF product is
formed. From the continuous reactor, the crude PVF passes through a series of separation equipment,
including separators, a filter press, and a steam -heated dryer.
Operation of the two PVF manufacturing operations will result in an increased steam demand at the
existing boilers of approximately 16,000 pounds of steam per hour, which equates to about 19.7
million Btu per hour.
PVF product is collected in a PVF Collection System, or baghouse.
A block flow diagram of the PVF manufacturing process is provided below.
Figure A.1-1: Block Flow Diagram of Proposed PVF Manufacturing Process
VF with
Pressurized VF
Storage Tank IFEP-CI
Modifier
00 VF Feed .: (FEP-C3Inhibitor System
Initiator Continuous Separator Flash Tank
Reactor System FEP-C4
FEP-C2 1 I PVF Isolation �I PVF Collection
J Tank System (baghouse)
Maintenance Header
Fugitives ......•••. Air Collected Around
Process Equipment
PVF Product
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As shown above, there are four point sources of emissions from the proposed PVF process:
FEP-Cl: VOC emissions from the VF feed system (non -HAP, non -TAP)
FEP-C2: VOC emissions from the maintenance header that draws air from around the process
equipment (non -HAP, non -TAP)
FEP-C3: VOC emissions from the Flash Tank, following the separator system (non -HAP, non -TAP)
FEP-C4: PM/PM-10/PM-2.5 emissions from the product collection system (non -HAP, non -TAP)
2. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
This regulation limits allowable particulate matter emissions from any stack, vent, or outlet of any
industrial process for which no other emissions control standards apply based on the process weight
rate. The PVF product collection system (Vent No. FEP-C4) is a potential source of PM emission
with a maximum product throughput of less than 30 tons per hour.
For process weights less than or equal to 60,000 pounds per hour (30 tons per hour), allowable PM
emissions are limited as follows:
E = 4.10*P^(0.67)
where: E = allowable PM emission rate in pounds per hour, and
P = process weight in tons per hour
Potential particulate matter emissions associated with the PVF manufacturing process are less than
15% of the allowable emission rate on a lb/hr-bases, and less than 2 tons per year on an annual basis.2
To demonstrate compliance with this standard, DuPont shall retain records on -site that are sufficient to
determine the process rate "P" in tons per hour.
15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
This regulation limits allowable visible emissions from any industrial process where a visible emission
can reasonably be expected to occur to no more than 20 percent opacity when averaged over a 6-
minute period, except that 6-minute periods averaging more than 87 percent opacity may occur not
more than once in any hour not more than four times in any 24-hour period. The PVF product
collection system (Vent No. FEP-C4) is a potential source of particulate matter with associated
opacity.
Monitoring. The permit will require monthly visible emissions observations of the affected exhaust
point, to check for visible emissions above "normal". The Permittee shall be required to establish what
constitutes "normal" emissions within 30 days of initial startup.
4. 15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions (State -Enforceable Only)
This standard forbids the Permittee from operating the PVF manufacturing operations 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.
5. 15A NCAC 2Q. 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.
2 DuPont has requested that emissions calculations, including emission factors, chemical names, and potential production rates, be protected as
Business Confidential information.
DEQ-CFW 00086249

DuPont, which is a chemical processing plant with a 100-tpy major source threshold, is an existing
major source under the PSD program.
To determine whether the proposed project is a major modification pursuant to the PSD permitting
program, potential emissions associated with PVF Manufacturing Facility No. 2 (ID No. FS-C) are
combined with PVF Manufacturing Facility No. 1 (ID No. FS-B), which commenced operation in
September 2007. As shown in the following table, VOC and S02 emissions increases associated with
the two projects could potentially exceed 40 tpy:
Table A.5-1. Summary of Potential Emissions Increases
Potential Emissions Increases Emissions t
PM"`
S02
NOx
CO
VOC
PVF Manufacturing Facility No. 1
17
N/A
N/A
N/A
>20
(ID No. FS-B)
PVF Manufacturing Facility No. 2
1.7
N/A
N/A
N/A
>20
(ID No. FS-C)'*"
"Debottleneck" of Boilers
w...
11.2
189.7
31.6
2.9
0.2
(ID Nos. PS-1 & PS-2)
TOTALS
14.6
189.7
31.6
2.9
>40.2
>PSD Significant Emission Rate?
I No
Yes
No
No
Yes
DuPont has requested that potential production rates be protected as Business Confidential information. To maintain
confidentiality of the potential production rates at the facility, exact potential emissions estimates are not provided in this table.
`i PM estimates include both PM-2.5 and PM-10.
Potential emissions estimates are from Application No. 0900009.06B, which requests authorization to construct and operate PVF
Manufacturing Facility No. 1 (ID No. FS-B) (Permit No. 03735T29).
.... Both PVF manufacturing lines use steam from the existing boilers. Total steam demand for the two PVF manufacturing lines is
approximately 19.7 mmBtu/hr heat. Debottlenecking emissions are estimated based on No. 6 fuel oil firing, 2.1% sulfur by
weight, and 8,760 hr/year.
PSD Avoidance for VOC Emissions
To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an enforceable 40
tpy VOC emission limitation on the two PVF manufacturing facilities pursuant to 15A NCAC 2Q
.0317. At each PVF manufacturing line, VOC emissions may occur at three individual point sources,
as follows:
- Analytical Equipment Vents (FEP-B1 and FEP-CI). VOC emissions from these points will be
monitored by a mass flow meter (in lbs). The measured flow rate is assumed to be 100% vinyl
fluoride.
- Maintenance Header Vents (FEP-B2 and FEP-C2). Emissions from these vents occur during
process/equipment maintenance activities, when the process is purged with nitrogen gas. The
purge stream, including both nitrogen and vinyl fluoride, is vented to the maintenance vent heaters
and then to the stack. VOC emissions from these points will be monitored by a mass flow meter
at the stack. The measured flow rate is assumed to be 50% vinyl fluoride.
- Flash Tank Vents (FEP-133 and FEP-C3). Unreacted vinyl fluoride that is NOT recovered in
the separator system is vented to the atmosphere from the flash tank vents. VOC emissions from
these vents will be monitored using DuPont's proprietary TMODS chemical process model,
including chemical equilibrium data, with vinyl fluoride flow rates to the reactors and pressures a
the separator system. Each hour, the Permittee shall monitor and record vinyl fluoride flow rate
and separator system pressure at each PVF manufacturing line. Once per calendar month, the
Permittee shall use the hourly process data in the TMOD model to determine monthly VOC
emission rate.
PSD Avoidance for SO, Emissions
To avoid PSD permitting pursuant to 15A NCAC 2D .0530, DuPont is requesting an enforceable 702.5
tpy S02 emission limitation on the three existing boilers. The requested PSD avoidance limit is
derived by adding 40 tpy, the significant emission rate for S02i to the baseline actual emissions of S02
determined from Calendar Years 2000-2001. DuPont used a 10-year look -back period to determine
baseline actual emissions due to numerous instances of extended periods of non -operation and
DEQ-CFW 00086250

unscheduled maintenance periods at the main boiler (ID No. PS-1) during the previous five years:
Derivation of the PSD avoidance limit is provided below:
SOZ emissions from existing boilers — CY2000: 688.0 tpy
SO, emissions from existing boilers — CY 2001: 637.1 tpy
Baseline Actual Emissions: 662.5 tpy
+ Significant Emission Rate: + 40.0 tpy
Allowable SO2 Emission Rate: 702.5 tpy
To demonstrate compliance with the SOZ emission limitation, each calendar month DuPont shall
monitor and record the monthly fuel combustion at the affected boilers, including sulfur content of fuel
oils, and calculate the associated SOZ emissions (in lb/month and tons/ 12-month period).
A Note on Fluorides
40 CFR 51.166(b)(49) defines a "regulated NSR pollutant" as,
(i) Any pollutant for which a national ambient air quality standard has been
promulgated and any pollutant identified under this paragraph (b)(49)(i) as a
constituent or precursor to such pollutant ...
(fi) Any pollutant that is subject to any standard promulgated under section 111 of the
Act;
(iii) Any Class I or II substance subject to a standard promulgated under or established
by title VI of the Act;
(iv) Any pollutant that otherwise is subject to regulation under the Act; except that any
or all hazardous air pollutants either listed in section 112 of the Act or added to the
list pursuant to section 112(b)(2) of the Act, which have not been delisted pursuant
to section 112(b)(3) of the Act, are not regulated NSR pollutants unless the listed
hazardous air pollutant is also regulated as a constituent or precursor of a general
pollutant listed under section 108 of the Act.
Inorganic fluorides, as detected using U.S. EPA Methods 13A and/or 13B, are subject to promulgated
standards under Section 111 of the Act (i.e. NSPS Standards), and are therefore regulated NSR
pollutants pursuant to (ii) above. Hydrogen fluoride (HF) is a regulated hazardous air pollutant (HAP),
and therefore exempt from the definition of regulated NSR pollutants pursuant to (iv) above.
Organic HAP, including polyvinyl fluorides, do not have an associated NAAQS (except as VOC), are
not regulated by a NSPS, and are not subject to a standard promulgated under or established by Title
VI of the Act. Therefore, organic fluorides that are not detected using U.S. EPA Methods 13A and/or
13B and not regulated NSR pollutants (except as VOC).
B. Abrasive Blasting Building (ID No. I-10) — State -Enforceable Only
DuPont is completing construction of an enclosed building to house periodic abrasive blasting operations
and comply with the requirements of 15A NCAC 2D .0541(c). PM emissions from the abrasive blasting
operations will be less than 2 tons per year based on historical use of blasting abrasive at the facility and
calculation methodology provided in Section 13.2.6 of U.S. EPA's AP-42.
This abrasive blasting operation is an insignificant activity because of size or production rate pursuant to
15A NCAC 2Q .0503(8) (ID No. I-10)
NOTE: Because DuPont has multiple small abrasive blasting operations located on -site, the Fayetteville
Regional Office (FRO) has requested that 15A NCAC 2D .0541, "Control of Emissions from Abrasive
Blasting" be included in the permit. In response to the FRO request, 15A NCAC 2D .0541 has been
included as a "facility -wide" requirement in Section 2.2.C. of the draft permit.
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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® Plus manufacturing 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 polymer manufacturing facility
(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 ammonium perfluoro-
octanoate (APFO) manufacturing facility (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).
VI. Draft/Proposed Permit Review Summary
• Ms. Christie Richardson (FRO) provided initial comments on the permit application, which were received in
the Raleigh Central Office (RCO) on April 23, 2008. Ms. Richardson requested that 15A NCAC 2D .0521
language in the permit be updated to be consistent with current DAQ protocol, that General Condition MM
("Fugitive Dust") be added to the permit to be consistent with current DAQ protocol, and that 15A NCAC 2D
.0541 ("Control of Emissions from Abrasive Blasting") be added to the permit due to the number of
insignificant shot blast operations existing at the facility. Ms. Richardson was provided a copy of the draft
permit for review on Friday, July 25, 2008. On July 28, 2008, Ms. Richardson commented on several
typographical type errors, and requested that a discussion of applicability of the PSD regulations to organic
fluorides be added to the Permit Review.
Mr. Michael Johnson (DuPont) was provided a draft permit for review on Friday, July 25, 2008. On Friday,
August 1, 2008, Mr. Johnson provided comments on the monitoring language for the VOC PSD avoidance
condition for the PVF manufacturing facilities, including information about monitoring methodology at each
affected vent. The draft permit was modified to be consistent with recommended language provided by Mr.
Johnson.
• Public notice is NOT required for this application.
• U.S. EPA review is NOT required for this application.
DEQ-CFW 00086252

VII.Other Regulatory Considerations
• The application fee of $867.00 was received on April 8, 2008.
• The Reduction and Recycling Form was received on April 8, 2008.
• A Professional Engineers Seal is NOT required for this application.
• A zoning consistency determination was received by the DAQ on April 8, 2008.
VIH. 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. 03735T33
DEQ-CFW 00086253