DEQ-CFW_00086289

41,
Received
aUPONT
DuPont Fluoroprotlucts
® 22828 NC Highway 87 W
P.err,iits Sedlon Fayetteville, NC 28306-7332
April 3, 2008
Mr. William Willets
NCDENR — Division of Air Quality
Permits Section
1641 Mail Service Center
Raleigh, NC 27699-1641
SUBJECT: Title V Air Permit Modification
Air Quality Permit No. 03735T32
DuPont Company — Fayetteville Works
Facility ID: 03/09/00009
Dear Mr. Willets:
Enclosed are four copies of an application, the required confidential information, and two checks
for the required application fee, to allow for the construction and operation of a second polyvinyl
fluoride manufacturing facility at the DuPont Company — Fayetteville Works.
As required by the subject permit, two original and four copies of an application, and two copies
of the required confidential information, have been sent to the attention of Mr. Steven Vozzo at
the Division of Air Quality's regional office in Fayetteville.
DuPont is opting to obtain a construction and operation permit pursuant to 15A NCAC 2Q.0504,
and as such is submitting both the Part.1 application and fee and the Part 2 application and fee
with this single submission.
This application is for the following three modifications:
1. to establish as a new emission source the Polyvinyl Fluoride Manufacturing Facility No. 2
(Emission Source ID No. FS-C);
2. to change the identification of the current Polyvinyl Fluoride Polymer Manufacturing Facility
to the Polyvinyl Fluoride Manufacturing Facility No. 1 (Emission Source ID No. FS-B); and
3. to establish the Abrasive Blasting Building (Emission Source ID No. I-10) as an insignificant
activity.
DEQ-CFW 00086289

Mr. William Willets
NCDENR — Division of Air Quality
April 3, 2008
Page 2 of 3
You will find all of the confidential information for this application in a separate envelope.
Pursuant to North Carolina General Statutes §132-1.2, §143-215.3C(a), and §143-215.65,
DuPont requests that access to the information which is contained in the confidential information
package, which would divulge information regarding methods or processes entitled to protection
as trade secrets and confidential business information, be restricted exclusively to Division of Air
Quality personnel.
Polyvinyl Fluoride Manufacturing Facility No. 2 (Emission Source ID No. FS-C)
DuPont is requesting a construction and operating permit to build a new manufacturing facility to
produce polyvinyl fluoride (PVF). This facility will be similar to the polyvinyl fluoride
manufacturing facility (ID No. FS-B) that commenced operation in September 2007.
Because of the contemporaneous time period of the two PVF manufacturing facilities, for the
purpose of the Title V air permit, the two facilities are considered to be a single modification of
the permit.
Since the combined potential -to -emit of the two facilities would exceed 40 tons of VOC per year,
DuPont is requesting, pursuant to 15A NCAC 2Q.0317(a), that terms and conditions be placed in
the permit to avoid the applicability of 15A NCAC 2Q.0530 (Prevention of Significant
Deterioration) for the combined VOC emissions from the existing Polyvinyl Fluoride
Manufacturing Facility No. 1 (Emission Source ID No. FS-B) and the new Polyvinyl Fluoride
Manufacturing Facility No. 2 (Emission Source ID No. FS-C).
Polyvinyl Fluoride Manufacturing Facility No. 1 (Emission Source ID No. FS-B)
In 2006, the DuPont Company — Fayetteville Works applied for and was issued a Title V air
permit modification to construct and operate a new facility to manufacture polyvinyl fluoride.
That facility is identified in the permit as the Polyvinyl Fluoride Polymer Manufacturing Facility.
Due to the proposed addition of the Polyvinyl Fluoride Manufacturing Facility No. 2 (Emission
Source ID No. FS-C), it will be less confusing and more consistent to change the identification of
this facility to the Polyvinyl Fluoride Manufacturing Facility No. 1 and retain its emission source
identification number as FS-B.
Therefore, DuPont is requesting the above identification change as an administrative
modification to the permit.
Abrasive Blasting Building -(ID No. I-10)
The DuPont Company — Fayetteville Works is completing the construction, of an enclosed
building to perform periodic abrasive blasting operations to comply with the requirements of
15A NCAC 2D.0541(c).
DEQ-CFW 00086290

4,
Mr. William Willets
NCDENR — Division of Air Quality
April 3, 2008
Page 3 of 3
As it was described in an August 28, 2007 letter to Mr. Steven Vozzo, NCDENR DAQ FRO,
DuPont operates an abrasive blasting operation in which metal parts are blasted prior to painting
on an as -needed basis.
The abrasive blasting operation consumed approximately sixty (60) tons of DuPontTM Starblast®
blasting abrasive in 2006. 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.
Based on this emission factor and the amount of abrasive consumed, the total particulate matter
emitted in 2006 would have been 3,240 pounds or 1.62 tons. Since the abrasive blasting activity
level of 2006 is normal for this site, it can be assumed that the uncontrolled particulate matter
emissions from this source would be less than two (2) tons per year.
Since the anticipated particulate matter emissions from the abrasive blasting operation is less
than five (5) tons per year, this operation should be classified as an insignificant activity per 15A
NCAC 2Q .0503(8) and as such should be added the Title V permit's insignificant activities list.
Summary
DuPont is submitting this modification application under the rules set forth in 15A NCAC
2Q.0501(c)(2) meaning the first permit application should result in a construction and operation
permit per NCAC 2Q.0504, and the second application should have the review process that
includes the required public. notification and EPA review.
If you should have any questions additional or need additional information, please feel free to
contact me at [phone].
Enclosures
Environmental Manager
DEQ-CFW 00086291