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HomeMy WebLinkAboutDEQ-CFW_00086265cou PONT FAYETTEVILLE WORKS APPLICATION TO MODIFY THE TITLE V AIR PERMIT (PERMIT NO. 03735T32) TO CONSTRUCT AND OPERATE THE POLYVINYL FLUORIDE MANUFACTURING FACILITY NO.2 APRIL 2, 2008 DEQ-CFW 00086265 Facility Name Facility Street Address Facility City Description of Process SIC Code/NAICS Zoning Consistency Determination DuPont Company — Fayetteville Works 22828 NC Highway 87 W Duart Township, Bladen County, North Carolina Polyvinyl Fluoride Manufacturing Facility No. 2 3081 / 326113 Facility Contact Michael E. Johnson Phone Number (910) 678-1155 Mailing Address 22828 NC Highway 87 W Mailing City, State Zip Fayetteville, NC 28306-7332 Based on the information given above: Q I have received a copy of the air permit application (draft or final) AND... Q The proposed operation IS consistent with applicable zoning and subdivision ordinances Agency Bladen County Planning Department Name of Designated Official Greg Elkins Title of Designated Official Planning Director Signature i, N� " Date q— 3— 08 Please forward to the mailing address listed above and the air quality offices listed below: Attn: Major Source Review Branch Supervisor NCDENR — Division of Air Quality Permitting Section 1641 Mail Service Center Raleigh, NC 27699-1641 Mr. Steven F. Vozzo NCDENR — Division of Air Quality Fayetteville Regional Office 225 Green Street — Suite 714 Fayetteville, NC 28301 DEQ-CFW 00086266 FORM Al FACILITY (General Information) REVISED 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate Al NOTE APPLICATION WILL N ' T BE PIR ESSEp NlITHOUT THE FOLLOWING: , 0 Local Zoning Consistency Determination (if required) 0 Facility Reduction & Recycling Survey Form (Form A4) 21 Application Fee 0 Responsible Official/Authorized Contact Signature IM Appropriate Number of Copies of Application ❑ P.E. Seal (if required) GENERAL INFORMATION` - Legal Corporate/OwnerName: E.I. du Pont de Nemours & Company Site Name: DuPont Company - Fayetteville Works Site Address (911 Address) Line 1: 22828 NC Highway 87 W Site Address Line 2: City: Fayetteville state: North Carolina Zip Code: 28306-7332 County: Bladen CONTACT'FNFORNIATIOh i Permit/Technica/ Contact: Facility/inspection Contact: Name/Title: Michael E. Johnson, Environmental Manager Name/Title: (Same as Permit/Technical Contact) Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 1: Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306 City: State: Zip Code: Phone No. 910.678.1155 lFax No. 910.678.1247 Phone No. ( ) Fax No. ( ) Email Address: michael.e.johnson@usa.dupont.com Email Address: Responsible Official/Authorized Contact: Invoice Contact: Name/Title: Karen B. Wrigley / Plant Manager Name/Title: (Same as Permit/Technical Contact) Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 1: Mailing Address Line 2: Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306 City: State: Zip Code: Phone No. 910-678-1546 Fax No. 910-678-1247 Phone No. ( ) Fax No. ( ) Email Address: karen.b.wrigley@usa.dupont.com Email Address: APPLICATION:ISBEING'MADEFOR , ❑ New (non -permitted) Facility/Greenfield Modification of Facility (permitted) ❑ Renewal With Modification ❑ Renewal (TV Only) FACII�I7Y'CLASSII=LCATlO[�t AFTER APPLiCATzION (Chick Only One) - ❑ General ❑ Small ❑ Prohibitory Small ❑ Synthetic Minor 0 Title V (Must include Form(s) E) FACILITY (Plant Site)"WFORMATION Describe nature of (plant site) operation(s): Chemical manufacturing facility. Primary SIC/NAICS Code: 3081, 3083, 2821, 2869 Current/PreviouS Air Permit No. 03735T32 Facility Coordinates: Latitude: 34 deg. 50 min. 30 sec. Longitude: -74 deg. 50 min. 10 sec. Does this application contain confidential data? ❑ No I] Yes (See Instructions) PERSON QR FlRM THAT PREBARED,APPLICATION Person Name: Michael E. Johnson Firm Name: Mailing Address Line 1: 22828 NC Hwy 87 W Mailing Address Line 2: City: Fayetteville State: NC Zip Code: 28306-7332 county: Bladen Phone No. 910-678-1155 Fax No. 910-678-1247 Email Address: Michael.E.Johnson@USA.dupont.com SIGNATURE;OF RESPONSIBLE OFFICIAUAUTHORIZED CONTACT Name (typed): Karen B. Wrigley Title: Plant Manager X Signature(Blue Ink): I Date: 4'�/ax.4� 0 4 joa/o8 Attach Additional Sheets As Necessary DEQ-CFW 00086267 FORMs A2, A3 EMISSION SOURCE LISTING FOR THIS APPLICATION - A2 112r APPLICABILITY INFORMATION - A3 REVISED 04/10/07 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate IA2 EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted EMISSION SOURCE EMISSION SOURCE CONTROL DEVIC CONTROL DEVICE ID NO. DESCRIPTION I ID NO. DESCRIPTION I FS-C I Polyvinyl Fluoride Manufacturing I None I Facility No.2 A3 Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases" - Section 112(r) of the Federal Clean Yes 0 No ❑ Air Act? If No, please specify in detail how your facility avoided applicability: If your facility is Subject to 112(r), please complete the following: A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150? Yes 0 No ❑ Specify required RMP submittal date: June 30, 1999 If submitted, RMP submittal date: June 8, 1999 RMP resubmitted on June 3, 2004 B. Are you using administrative controls to subject your facility to a lesser 112(r) program standard? Yes ❑ No 0 If yes, please specify: Attach Additional Sheets As Necessary DEQ-CFW 00086268 FORM A4 0 0 n n C 0 0 0 00 0) N 0) t9 DATE: 04102/2008 Does facility have an environmental mangement system in place? ( ) YES ( X) NO If so, is facility ISO 14000 Certified? ( ) YES ( ) NO Facility Name: DuPont Company -Fayetteville Works Permit Number: 03735T32 Facility ID: 0900009 County: Bladen Environmental Contact: Michael E. Johnson Mailing Address Line 1: 22828 NC Highway 87 W Phone No. ( 910 ) 678-1155 Fax No. ( 910 ) 678-1247 Mailing Address Line 2: Zip Code: 28306-7332 County: Bladen City: Fayetteville State: NC Email Address: michael.e.johnson@usa.dupont.com EMISSIONSAIR •URCE REDUCTIONS Any Air Emissions Source Reductions in the past year?( ) YES (X)NO Enter Code for Date Reduction Quantity Emitted Quantity Emitted Has reduction activity been Source Description and ID Alr Pollutant Emission Reduction Option Implemented from prior annual from current annual discontinued? If so, when Addition detail about source Option (See Codes) (mo/yr) report to DAQ (Ib/yr) report to DAQ (Iblyr) was it discontinued? (mo/vr ■ ■ ■ • f Any Reductions or Recycling Activities in the past year?( )YES(X)NO Enter Code for Date Reduction Quantity Emitted Quantity Emitted Ha�itdisco ction activhy been Source Description or Activh Pollutant or Recycled or p y Reduced Materials Emission Reduction Option Implemented from prior annual from current annual disued? If so, when Addition detail about source Option (See Codes) (mo/yr) report report wantinued? (mo/vr z `5myscorn RENSED IIO> For assistance with FORM A4, please contact the North Carolina Division of oyqu�ione �eVenF on �nd Environmental Assistanr.P at d_RDn.7a3-nd3a nr nnwactamr»r,a.ro nr., FORM B SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES) REVISED 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate I B EMISSION SOURCE DESCRIPTION: polyvinyl Fluoride Manufacturing Facility N0.2 EMISSION SOURCE ID NO: FS-C CONTROL DEVICE ID NO(S): None OPERATING SCENARIO 1 OF 1 EMISSION POINT (STACK) ID NO(S) FEP-C1,C2,C3,C4 DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM): Vinyl fluoride (VF) reacts in a continuous reactor to form crude polyvinyl fluoride (PVF). The PVF is then isolated in a separator system followed by a filter press and a dryer. The final product is a solid powder. TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1-B9 ON THE FOLLOWING PAGES): ❑ Coal,wood,oil, gas, other burner (Form B1) ❑ Woodworking (Form 134) ❑ Manufact. of chemicals/coatings/inks (Form 67) ❑ Int.combustion engine/generator (Form B2) ❑ Coating/finishing/printing (Form 135) ❑ Incineration (Form 68) ❑ Liquid storage tanks (Form B3) ❑ Storage silos/bins (Form 66) ff] Other (Form B9) START CONSTRUCTION DAT July 08 1OPERATION DATE Aug 09 DATE MANUFACTURED: July 2008 MANUFACTURER / MODEL NO.: n/a 1EXPECTED OP. SCHEDULE: 24 HR/DAY 7 DAY/WK 50 WK/YR IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?): NO NESHAP (SUBPART?): NO MACT (SUBPART?): No PERCENTAGE ANNUAL THROUGHPUT (%): JAN-MAR 25 APR-JUN 25 JUL-SEP 25 OCT-DEC 25 EXPECTED ANNUAL HOURS OF OPERATION: —8300 IVISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: —0 % OPACITY GR/TERIA A%R POLLIUTANT EM/SSfOIVS INFORMA`TIOht FOR JFtfS:SO'tIRGE= r AIR POLLUTANT EMITTED SOURCE OF (AFTER EMISSION FACTOR EXPECTED ACTUAL CONTROLS/LIMITS) POTENTIAL EMISSIONS (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS) Ib/hr tons/ r Ib/hr tons/ r Ib/hr tons! r PARTICULATE MATTER (PM) 0.3 1 1.1 0.4 1.7 0.4 1.7 PARTICULATE MATTER<10 MICRONS (PMio) 0.3 1.1 0.4 1.7 0.4 1.7 PARTICULATE MATTER<2.5 MICRONS (PM2.5) U 1.1 0.4 1.7 0.4 1.7 SULFUR DIOXIDE (S02) 0 0 0 0 0 0 NITROGEN OXIDES (NOx) 0 0 0 0 0 0 CARBON MONOXIDE (CO) 0 0 0 0 0 0 VOLATILE ORGANIC COMPOUNDS (VOC) 4.7 1 16.3 6.1 26.8 6.1 26.8 LEAD 0 0 0 0 0 0 OTHER 0 0 0 0 0 0 HAZARDOUS A/R POLLUTANT EM/SS/0�1tS:fNFOR11iJATlON;FOR TV $ SOURGE HAZARDOUS AIR POLLUTANT AND CAS NUMBER SOURCE OF (AFTER EMISSION FACTOR EXPECTED ACTUAL CONTROLS/LIMITS) POTENTIAL EMISSIONS (BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS) Ib/hr tons/ r Ib/hr tons/ r Ib/hr tons/ r None ,. - TOX/CAtR POL�;'UTANT EIt�tSStONS /NFORM.4TION FQR THfS.SOURCE - _ ' INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS 1 LIMITATIONS TOXIC AIR POLLUTANT AND CAS NO. EF SOURCE Ib/hr lb/day Ib/ r None Attachments: (1) emissions calculations and supporting documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates) and describe how these are monitored and with what frequency; and (3) describe any monitoring devices, gauges, or test ports for this source. COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOURCE Attach Additional Sheets As Necessary DEQ-CFW 00086270 FORM 139 - Confidential EMISSION SOURCE (OTHER) REVISED: 12/01/01 NCnFNRmivisinn of Air Onality _ Annlirntinn for Air Permit to Cnnstrurt/Onerate B9 EMISSION SOURCE DESCRIPTION: Polyvinyl Fluoride Manufacturing Facility No. 2 EMISSION SOURCE ID NO: FS-C CONTROL DEVICE ID NO(S): None OPERATING SCENARIO: 1 OF 1 EMISSION POINT (STACK) ID NO(S; FEP-C1, C2, C3, C4 DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM): Vinyl fluoride (VF) reacts in a continuous reactor to form crude polyvinyl fluoride (PVF). The PVF is then isolated in a separator system followed by a filter press and a dryer. The final product is a solid powder. NtATER1ALSNTRING P.;IOCESS COfi1TINU0USPROGESS MAX. DESIGN CAPACITY UNIT/HR REQUESTED CAPACITY LIMITATION UNIT/HR TYPE UNITS Vinyl Fluoride lb. Confidential d-Linonene (inhibitor) lb, Confidential Propylene (modifier) lb. Confidential Water soluable salt (inhibitor) lb. Confidential „ `MA[EIALS ENTERING_PROCESS BATCH OPERATION MAX. DESIGN CAPACITY UNIT/BATCH REQUESTED CAPACITY LIMITATION UNIT/BATCH TYPE UNITS MAXIMUM DESIGN BATCHES / HOUR): REQUESTED LIMITATION (BATCHES / HOUR): (BATCHES/YR): FUEL USED: Not applicable (NA) ITOTAL MAXIMUM FIRING RATE (MILLION BTU/HR): NA MAX. CAPACITY HOOF NA REQUESTED CAPACITY ANNUAL FUEL USE: NA COMMENTS: Process flow diagram attached as separate page. Attach Additional Sheets as Necessary DEQ-CFW 00086271 POLYVINYL FLUORIDE MANUFACTURING FACILITY NO.2 EMISSION SOURCE ID NO. FS-C PROCESS FLOWCHART INHIBITED VINYL FLUORIDE VINYL ---► STORAGE TANK FLUORIDE IF MODIFIER FEED SYSTEM REMOVED INHIBITOR ANALYTICAL FEP-Cl ---- EQUIPMENT ----♦ INITIATOR -►I PVF REACTOR FEP-C4 �1 PRODUCT COLLECTION PVF ISOLATION SYSTEM EQUIPMENT PRODUCT CRUDE PVF SEPARATOR SYSTEM VO(, FEP-C3 O� FLASH TANK F ), FEP-C2 MAINTENANCE HEADER------------�' QLTl'VE-o ---------- FROM PROCESS EQUIPMENT DEQ-CFW 00086272 FORM D1 FACILITY -WIDE EMISSIONS SUMMARY REVISED 12/01/01 NCDENR/Division of Air Qualitv - Application for Air Permit to Construct/Operate D1 CRITERIA AIR POLLUTANTTEMLSSIONS If�IFORMA'CION FACILITY VIitDE EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS / (BEFORE CONTROLS / (AFTER CONTROLS / LIMITATIONS) LIMITATIONS) LIMITATIONS AIR POLLUTANT EMITTED tons/ r tons/ r tons/ r Unchanged (site is Unchanged (site is PARTICULATE MATTER (PM) —50 Major Source) Major Source) Unchanged (site is Unchanged (site is PARTICULATE MATTER < 10 MICRONS (PM,,) ~50 Major Source) Major Source) Unchanged (site is Unchanged (site is PARTICULATE MATTER < 2.5 MICRONS (PM,.,) —50 Major Source) Major Source) Unchanged (site is Unchanged (site is SULFUR. DIOXIDE (S02) —600 Major Source) Major Source) Unchanged (site is Unchanged (site is NITROGEN OXIDES (NOx) —100 Major Source) Major Source) Unchanged (site is Unchanged (site is CARBON MONOXIDE (CO) -15 Major Source) Major Source) VOLATILE ORGANIC COMPOUNDS (VOC) ^-215 Major Source Major Source LEAD OTHER HAZAI2DUUS AlR POLLUTANT EMISSIONS ItYFQRMi4TlON fAC,tLITY W[C3E , , , EXPECTED ACTUAL EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS (AFTER CONTROLS / (BEFORE CONTROLS / (AFTER CONTROLS / LIMITATIONS) LIMITATIONS) LIMITATIONS HAZARDOUS AIR POLLUTANT EMITTED CAS NO. tons/ r tons/ r tons/ r Total HAPs >25 (site is Major Source) >25 (site is Major >25 (site is Major Source) Source) f + f TQXCCSAIR POLLk1TAN[T ElilltSSIONS iNFO'RMATION FAt [L)TY WIDL= INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (TPER) IN 15A NCAC 2Q .0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY. Modeling Required ? TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day lb/year Yes No No TAPs will be emitted from this X modification. COMMENTS: As indicated above, the site is a major source for criteria pollutants and HAPs. The proposed operation of the Polyvinyl Fluoride Manufacturing Facility No. 2 (ID No. FS-C) will not change any of the current classifications. VOC is the only pollutant emitted from this process. The Polyvinyl Fluoride Manufacturing Facility No. 2 does not emit any HAPs or any TAPS. Attach Additional Sheets as Necessary DEQ-CFW 00086273 FORM D2 AIR POLLUTANT NETTING WORKSHEET Revised:12/01101 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D2 PURPOSE OF NETTING: ❑ AIR TOXICS ❑ PSD (100/250 tons per year) ❑ PSD SIGNIFICANT LEVELS AIR POLLUTANT: None CAS NO.: EMISSION SOURCE ID NOS.: }L c`rvt� - F ^f _4 i 5z ! S -i �. ft •'e'i' 1.^ '_ f _ ,'_�;`� .�_ �_t �-S€�TkQ�IA=_�M�SS�Ot�t=OF,F-SE�k{�IGAN��YS�S�F.Qk4CODkfr<IED/I�tE1tV SQURCES -=', :, �' �; Souk a (rt thjs section EMISSIONS - USE APPROPRIATE COLUMNS ONLY LB/YEAR LB/DAY LB/HR '� ;urgifie Ei forFs° MODIFICATION INCREASE - MINUS - MINUS - - MINUS - MINUS - MODIFICATION DECREASE = EQUALS = = EQUALS = = EQUALS = = EQUALS = NET CHANGE FROM MODIFICATION SECTION S FPCIUTY;WIQE EMkSSkQN NE k f ING ANALYSIS CREDITABLE INCREASE - MINUS - - MINUS - - MINUS - - MINUS - CREDITABLE DECREASE = EQUALS = = EQUALS = = EQUALS = = EQUALS = NET CREDITABLE CHANGE �; `SEC�'fOl�f G FACILITY WIE}E= EMf���IONS � r TOTAL FACILITY EMISSIONS TPER LEVELS (2Q .0711) CHECK HERE IF AN AIR DISPERSION MODELING ANALYSIS IS REQUIRED ❑ COMMENTS: The Polyvinyl Fluoride Manufacturing Facility No. 2 will have no emissions of Toxic Air Pollutants. The combined potential emissions of VOCs from the Polyvinyl Fluoride Manufacturing Facility No. 1 and the Polyvinyl Fluoride Manufacturing Facility No. 2 will be greater than the 40 ton per year significant level for PSD applicability. A PSD avoidance condition of 40 tons VOC per year is being requested for the combined VOC emissions from these two facilities. Attach Additional Sheets As Necessary DEQ-CFW 00086274 FORM D3 MODELING REQUEST FORMS (3 pages) REVISED: 02/20/03 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate 53 If the applicant desires, the NCDAQ/AQAB will perform the initial modeling compliance demonstration using EPA approved screening and, if applicable and where possible, refined models. If the model results indicate the facility will be unable to demonstrate compliance with applicable Acceptable Ambient Level(s) the applicant will be notified and will be required to perform the compliance demonstration using established modeling protocol and modeling analysis requirements as defined in the North Carolina Administrative Code 15A NCAC 2D .1100 and 2Q .0700 and in the Guidelines for Evaluating the Impacts of Toxic Pollutants in North Carolina. To perform the dispersion modeling compliance demonstration, the AQAB will require the following data: �Koaurlonr = Provide a brief description of the modification and/or addition necessitating the toxic modeling request: The Polyvinyl Fluoride Manufacturing Facility No. 2 will have no emissions of Toxic Air Pollutants. Therefore, modeling is neither needed nor requested. Subsequently, pages 2 and 3 of this form are not included in this application. d iox�cs 2 EMIS[ONS DgTA Facilrty wide em►ssrons, (?Y source, of all;modeleLL TOXIC AIR POLLUTANT (TAP) MAXIMUM TOXIC AIR POLLUTANT (TAP) EMISSIONS (After Controls) Emission Point ID Ibs/ ear Ibs/da Ibs/hr I Attach Additional Sheets As Necessary Page 1 of 3 DEQ-CFW 00086275 FORM D4 EXEMPT AND INSIGNIFICANT ACTIVITIES SUMMARY �� REVISED: 12/01/01 NCDENR/Division of Air Quality - Anolicatinn for Air Permit* Construct/nperate 1 D4 1 AC `IVT�E8 EXEMPT ©'t 6 O�Q2 QR r .._1NSGN1kt4NTGTVIIESFERC. QSQR TITHE USE}URCES SIZE OR PRODUCTION BASIS FOR EXEMPTION OR DESCRIPTION OF EMISSION SOURCE RATE INSIGNIFICANT ACTIVITY Per AP-42 Section 13.2.6, particulate emission factors for abrasive blasting of mild steel panels with a five mile per Less than 100 hour wind speed, total particulate tons abasive is Abrasive blasting building matter emissions would be 27 pounds used per year '�` per 1,000 pounds of abrasive. Based on this, 100 tons of abrasive would generate 5400 lb. or 2.7 ton PM. 2. 3. 4. 5. 6. 7. 8. Attach Additional Sheet As Necessary DEQ-CFW 00086276 FORM D TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION REVISED: 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate D5 PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION, CONTROL, AND REGULATORY DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES: A. SPECIFIC EMISSIONS SOURCE (EMISSION INFORMATION) (FORM B) - SHOW CALCULATIONS USED, INCLUDING EMISSION FACTORS, MATERIAL BALANCES, AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE CALCULATION OF POTENTIAL BEFORE AND, WHERE APPLICABLE, AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS. B. SPECIFIC EMISSION SOURCE (REGULATORY INFORMATION)(FORM E2 - TITLE V ONLY) - PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS (e.g. FOR TESTING AND/OR MONITORING REQUIREMENTS) FOR COMPLYING WITH APPLICABLE REGULATIONS, PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF AN FEDERAL REGULATIONS (PREVENTION OF SIGNIFICANT DETERIORATION (PSD), NEW SOURCE PERFORMANCE STANDARDS (NSPS), NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAPS), TITLE V), INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM "A" ABOVE, DATES OF MANUFACTURE, CONTROL EQUIPMENT, ETC. TO SUPPORT THESE CALCULATIONS. C. CONTROL DEVICE ANALYSIS (FORM C) - PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL EFFICIENCIES LISTED ON SECTION C FORMS, OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM "A" ABOVE. INCLUDE PERTINENT OPERATING PARAMETERS, (e.g. OPERATING CONDITIONS, MANUFACTURING RECOMMENDATIONS, AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION) CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED. D. PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS - (FORM E3 - TITLE V ONLY) - SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS, OPERATIONAL, OR OTHER DATA TO DEMONSTRATE COMPLIANCE. REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM "B" WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS. E. PROFESSIONAL ENGINEERING SEAL - PURSUANT TO 15A NCAC 2Q .0112 "APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL," A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY). 1, attest that this application for has been reviewed by me and is accurate, complete and consistent with the information supplied in the engineering plans, calculations, and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other professionals, inclusion of these materials under my seal signifies that / have reviewed this material and have judged it to be consistent with the proposed design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement, representation, or certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per violation. (PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE NAME: DATE: COMPANY: ADDRESS: TELEPHONE: SIGNATURE: PAGES CERTIFIED: (IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT THAT IS BEING CERTIFIED BY THIS SEAL) Attach Additional Sheets As Necessary -- See Attached Calculation Sheet DEQ-CFW 00086277 FORM E1 TITLE V GENERAL INFORMATION REVISED: 12/01/01 Division of Air Quality - Application for Air Permit to Construct/Operate 99 {F`C�tR_FACii 1TV iC CCCiFfF�l jqs "MA tAl?";;FOP TtTI )~\/1fCL IUfI)CT,(`®[ylDl'=ATE [-A THIS. FORM AND ALL OTHER REQUIRED "E"' FORMS {E2 iTt-6R0t1GN E3 AS APPLICABLE ) Indicate here if your facility is subject to Title V by: I] Emissions ❑ Other If subject to Title V by other, check or specify: ❑ NSPS ❑ NESHAPS (MACT) ❑ TITLE IV Other, specify: If you are or will be subject to any maximum achievable control technology standards (MACT) issued pursuant to section 112(d) of the Clean Air Act, specify below: EMISSION SOURCE EMISSION SOURCE ID DESCRIPTION MACT SS-D Sutacite Tinting "Printing MACT" (40 CFR Part 63 Subpart KH Throughout Facility Facility Wide "MON MACT" (40 CFR Part 63 Subpart FFFF) List any additional regulation which are requested to be included in the shield and provide a detailed explanation as to why the shield should be granted: REGULATION EMISSION SOURCE (Include ID) EXPLANATION Comments: Attach Additional Sheets As Necessary DEQ-CFW 00086278 FORM E2 EMISSION SOURCE APPLICABLE REGULATION LISTING REVISED 121C Division of Air Quality - Application for Air Permit to Construct/Operate EMISSION EMISSION OPERATING SCENARIO SOURCE SOURCE INDICATE PRIMARY (P) APPLICABLE ID NO. DESCRIPTION OR ALTERNATIVE (A) POLLUTANT REGULATION 6 77777' [R 707---7777717 -,A 04 Polyvinyl Fluoride FS-B Manufacturing NCAC 2Q.0317 - Avoidance FS-C Facilities No. 1 and P voc conditions for 15A NCAC 2D.0530 No.2 Polyvinyl Fluoride NCAC 213.0515 -Particulate matter FS-C Manufacturing P PM for vent FEP-C4 only Facilities No.2 Polyvinyl Fluoride NCAC 2D.0521 - Visible emissions FS-C Manufacturing P VE for vent FEP-C4 only Facilities No.2 Polyvinyl Fluoride NCAC 2D.1806 - Odor (State -Only FS-C Manufacturing P Odor Requirement) Facilities No.2 Attach Additional Sheets As Necessary DEQ-CFW-00086279 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality -Application for Air Permit to Construct/Operate E3 Neguiated Pollutant voc Emission Source ID NO. FS-B and FS-C Applicable Regulation NCAC 2Q.0317 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS 11lfONITORING REQUIREMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? E] Yes 0 No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, I minute instantaneous readings taken to produce an hourly average): 'RE REQUIREMENTS ING� E U Nt Data (Parameter) being recording: VOC emissions will be determined via engineering calculations Frequency of recordkeeping (How often is data recorded?): Monthly REPORTING FEQUIREMENTS Generally describe what is being reported: Monthly VOC emissions will be determined monthly and will be reported to N.C. Division of Air Quality every six months. Frequency: F] MONTHLY ❑ QUARTERLY EVERY 6 MONTHS ❑ OTHER (DESCRIBE): TE STING Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW-00086280 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate Regulated Pollutant Farticuiate matter Emission Source ID NO. FS-C Applicable Regulation NCAC 2D.0515 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes MX No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes MX No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, I minute instantaneous readings taken to produce an hourly average): -:1RECORDKEEPINGREQUIREMENTS Data (Parameter) being recording: Production reocords will be maintained and will be available to a DAQ representative upon request. Frequency of recordkeeping (How often is data recorded?): Annual REPORTINGREQUIREMENTS Generally describe what is being reported: None Frequency: r-1 MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER (DESCRIBE): TESTING7 Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW-00086281 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality -Application for Air Permit to Construct/Operate E3 I Regulated Pollutant Visible emissions Emission Source ID NO. FS-C Applicable Regulation NCAC 2D.0521 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS MONITQRING REQUIREMENTS Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes No If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes 0 No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable -- This process does not produce visible emissions as demonstrated by the existing PVF Manufacturing Facility No. 1 that has has been in operation since Setember 2007. Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous readings taken to produce an hourly average): REGORD,KEEP,ING k2EQ9,10-EMENTS Data (Parameter) being recording: Visible emissions will be determined via visual observation Frequency of recordkeeping (How often is data recorded?): Monthly REPORTING REQUIREMENTS Generally describe what is being reported: None Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS ❑ OTHER (DESCRIBE): TESTW G Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW 00086282 FORM E3 EMISSION SOURCE COMPLIANCE METHOD REVISED 12/01/01 NCDENR/Division Of Air Quality - Application for Air Permit to Construct/Operate Regulated Pollutant Odor Emission Source ID NO. FS-C Applicable Regulation NCAC 2D.1806 Alternative Operating Scenario (AOS) NO: ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS 5''M- iT [REM Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable" D Yes No L-J If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? EJ Yes FX1 No Describe Monitoring Device Type: Not applicable Describe Monitoring Location: Not applicable Other Monitoring Methods (Describe In Detail): Not applicable Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, I minute instantaneous readings taken to produce an hourly average): REC Data (Parameter) being recording: Not applicable Frequency of recorckeeping (How often is data recorded?): Generally describe what is being reported: Not applicable Frequency: ❑ MONTHLY ❑ QUARTERLY Fj EVERY 6 MONTHS ❑ OTHER (DESCRIBE): TESTING Specify proposed reference test method: Not applicable Specify reference test method rule and citation: Not applicable Specify testing frequency: Not applicable NOTE - Proposed test method subject to approval and possible change during the test protocol process Attach Additional Sheets As Necessary DEQ-CFW-00086283 FORM E4 EMISSION SOURCE COMPLIANCE SCHEDULE Revised 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate I E4 COMPLIANCE STATUS WITH RESPECT TO ALL APPLICABLE REQUIREMENTS Will each emission source at your facility be in compliance with all applicable requirements at the time of permit issuance and continue to comply with these requirements? 0 Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. Will your facility be in compliance with all applicable requirements taking effect during the term of the permit and meet such requirements on a timely basis? El Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. If this application is for a modification of existing emissions source(s), is each emission source currently in compliance with all applicable requirements? 0 Yes ❑ No If NO, complete A through F below for each requirement for which compliance is not achieved. A. Emission Source Description (Include ID NO.) B. Identify applicable requirement for which compliance is not achieved: C. Narrative description of how compliance will be achieved with this applicable requirements: D. Detailed Schedule of Compliance: Ste s Date Expected E. Frequency for submittal of progress reports (6 month minimum): Not applicable F. Starting date of submittal of progress reports: Not applicable Attach Additional Sheets As Necessary DEQ-CFW 00086284 z FORM E5 "TITLE V COMPLIANCE CERTIFICATION (Required) Revised 01/01/07 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate E5 In accordance with the provisions of Title 15A NCAC 2Q .0520 and .0595(b)(4), the responsible company official of - SITE NAME: DuPont Fayetteville Works SITE ADDRESS: 22828 NC Highway 87 W CITY, NC: Fayetteville, NC 28306 COUNTY: Bladen PERMIT NUMBER: 03735T32 CERTIFIES THAT (Check the appropriate statement): 0 The facility is in compliance with all applicable requirements ❑ in accordance with the provisions of Title 15A NCAC 2Q .0515(b)(4) the responsible company official certififies that the proposed minor modification meets the criteria for using the procedures set out in 2Q .0515 and requests that these procedures be used to process the permit application. ❑ The facility is not currently in compliance with all applicable requirements if this box is checked, you must also complete form E4 "Emission Source Compliance Schedule" The undersigned certifies under the penalty of law, that all information and statements provided in the application, based on information and belief formed after reasonable inquiry, are true, accurate, and complete. Date: 0Y/0_)_/0,5 Signature of responsible companoffibW (REQUIRED, USE BLUE INK) Karen B. Wrigley, Plant Manager Name, Title of responsible company official (Type or print) Attach Additional Sheets As Necessary DEQ-CFW 00086285 � fiocziv,.od NORTH CAROLINA DIVISION OF AIR QUALITY Permit Issue Date: To: Fern Paterson, RCO Permits From: Christy Richardson, FRO 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 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 (910)678-1155 22828 NC Highway 87 West Fayetteville NC, 28306+7332 Contact Data Authorized Contact Karen Wrigley Plant Manager (910) 678-1546 22828 NC Highway 87 West Fayetteville NC, 28306+7332 Regional Engineer: Christy Richardson Regional Engineer's Signature: Date: Facility Description Technical Contact Michael Johnson Environmental Manager (910) 678-1155 22828 NC Highway 87 West Fayetteville NC, 28306+7332 .permits Section Region: Fayetteville Regional Office County: Bladen NC Facility ID: 0900009 Inspector's Name: Robert Kennedy Date of Last Inspection: 11/28/2007 Compliance Code: 4/In Compliance - Certification Permit Applicability (this application only) SIP: NSPS: NESHAP: PSD: PSD Avoidance: NC Toxics: 112(r): Other: 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 Comments / Recommendations: Issue 03735/T33 Permit Issue Date: Permit Expiration Date: Dupont Company - Fayetteville Works (0900009) is a chemical manufacturing facility located in Bladen County. The Plant consists of six individual manufacturing processes: Butacite® Process Area, Nafion® Process Area, Fluoroproducts Polymer Manufacturing Development Facility (PMDF/Teflon), Ammonium Perfluorooctanate (APFO) Manufacturing Facility, SentryGlas® Plus Manufacturing Facility and a new process, Polyvinyl Fluoride Polymer Manufacturing Facility. The facility is subject to NESHAP Subpart KK, Printing and Publishing Industry, and Subpart FFFF, Miscellaneous Organic NESHAP. The facility has two permanent boilers as well as one temporary boiler, which is transient and comes on and off site as needed. DEQ-CFW 00086286 Purpose DuPont Company — Fayetteville Works has submitted the Part 1 and Part 2 permit applications for the addition of a new Polyvinyl Fluoride Manufacturing Facility (ID No. FS-C). The facility is also requesting that the currently permitted PVF facility (FS-B) be renamed to facility no. 1. DuPont has also requested that the abrasive blasting building be added to the list of insignificant activities (ID No. I-10). This P&O serves as the regional comments for both the Part 1 (0900009.08A) and Part 2 (0900009.08B) applications. Permit Modification Issues The following is a detailed description of each of the proposed changes detailed in the application narrative provided by DuPont — Fayetteville Works (Items 1-3) as well as those changes proposed by FRO (Items 4-5): (1) Addition of a Polyvinyl Fluoride (PVF) Manufacturing�Facility No. 2 (ID No. FS-C). DuPont is requesting to add a polyvinyl fluoride manufacturing facility similar to the PVF facility that began operation in Fall 2007. DuPont has requested to take a PSD avoidance limit for VOC for the two facilities combined (total emissions from both PVF Manufacturing Facility No. 1 and Facility No. 2 ). In addition to PSD avoidance, this PVF facility will be subject to 2D .0515 (Vent FEP-C4 only), 2D .0521 (Vent FEP-C4 only), and 2D .1806. Toxics does not need to be addressed since no TAPS are emitted from this process. (2) Rename Source ID No. FS-B. The Permittee has requested that the current PVF Polymer Manufacturing Facility be renamed to Polyvinyl Fluoride Manufacturing Facility No. 1 (ID No. FS-B) to be consistent with the nomenclature of the new facility. (3) Addition of Insignificant Source — Abrasive Blasting Building (ID No. I-10). The facility is currently constructing a building which will be used to shot blast product cylinders (less than 8 feet long). Using AP-42 (13.2.6) emission factors, uncontrolled emissions from this source were calculated to be 1.6 TPY during CY 2006. After a review of data from past years, it appears that this source should remain below 2 tons of PM per year. Therefore, this source should be listed as an insignificant activity per 15A NCAC 2Q .0503(8). The facility is subject to 15A NCAC 2D ,0541 and has numerous shot blast operations; therefore, this stipulation needs be added to the permit for clarification. (4) Update the standard language for VE Monitoring requirements. The monitoring requirements language for VE needs to be updated to include the new "minimum of 12 minutes" language. (5) Include the Fugitive Dust Rule (21) .0540). There is no reason to expect that this facility will have issues complying with the fugitive dust rule; however, a decision was made during PWG meeting to add this regulation to all TV and non -TV permits. Facility Compliance Status The facility was last inspected by Christy Richardson and Tien Nguyen on April 16, 2008 and appeared to be operating in compliance with all requirements outlined in their current air permit. In November 2007, the facility was issued a Notice of Violation (NOV) for failure to submit operating permit application (Part 2) in a timely manner. The facility was issued a compliance addition information (CAI) letter in August 2007 concerning the permit applicability of a paint operation and shot blast operation as well as abnormal visible emissions from the boilers noted during two recent site visits. DEQ-CFW 00086287 Emissions Inventory Review The largest criteria pollutant emissions as reported on the CY 2006 AQEI were volatile organic compounds at 256 tons and sulfur dioxide at 548 tons. The vast majority of the VOC and SO2 emissions were a result of combustion of fuel oil in the boilers and Nafion manufacturing process. The largest HAP/TAP emissions as reported on the CY 2006 AQEI were methanol at 42 tons, toluene at 2 tons, CFC-113 at <1 ton, acetonitrile at 6 tons, hydrogen fluoride at 1.5 tons, and methylene chloride at 8 tons. Additional Items There are no additional issues listed on the FRO Facility Tracking Form (pink sheet) in the facility folder. Recommendation FRO recommends that RCO issue the revised air permit (03735T33 & T34) to DuPont Company -. Fayetteville Works. If DuPont - Fayetteville Works submits any revisions to this application, FRO requests a copy of the submittal for additional review. Also, FRO would like to review the draft permit and draft review prior to being issued to the company or for public review. Regional Engineer: '' �^" )C Date: 4-12! 12cx�' 1Y Permit Coordinator: Date: � 6 1®g AQSupervisor: - - Date: q-z'i-w \CTR FRO Files RCO Files DEQ-CFW 00086288