DEQ-CFW_00086405

aUPANT DuPont Fluoroproducts
U ® 22828 NC Highway 87 W
Fayetteville, NC 28306-7332
September 13, 2007
Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
SUBJECT: Title V Permit Deviation
Nafion® Resins Process — Emissions Determination
Air Quality Permit No. 0373 5T3 0
Dear Mr. Vozzo:
The purpose of this letter is to notify the Division of Air Quality of a Title V permit
deviation and to inform the Division of a recently discovered error in the referenced permit.
Pursuant to Part I Section 3(I.A)(3) of the subject Title V permit, this letter is the required
notification of a permit deviation which occurred with the determination of VOC emissions
requirement specified in Part I Section 2.1(C)(5)(b) of the subject permit. That condition should
specify that the VOC emissions from the Nafion® Resins Process (ID No. NS-G) be calculated
within thirty (30) days of the end of each month. The VOC emission calculation for the month
of July 2007 was completed on September 5, 2007, or 36 days following the end of July.
The cause of this deviation was due to a lack of communication between key personnel and
the absence of an information system to notify other team members of the status of the monthly
VOC determination. This resulted in the late determination of the Resins Process emissions.
To prevent recurrence of this deviation, area personnel have been given personal contacts
stressing the importance of completing the report in a timely manner. in addition, electronic
reminders have been assigned to both the Resins Process team and the unit's environmental
coordinator. There will now be multiple levels of monthly reminders for area personnel.
DEQ-CFW 00086405

10
Mr. Steven F. Vozzo
NCDENR — Division of Air Quality
September 13, 2007
Page 2 of 2
It has come to the attention of DuPont that an inexplicable change occurred to the Part I
Section 2.1(C)(5)(b) PSD avoidance condition for the Nafion® Resins Process when the permit
was modified by the Division of Air Quality and issued on September 22, 2006. That
modification established the Section 2.1(C)(6) PSD avoidance condition for the HFPO Process.
With the requested BFPO Process permit modification, Section 2.1(C)(5)(b) was also
changed. This change was unrelated to the requested modification and was done without
DuPont's knowledge. Prior to the issuance of the current permit, this monitoring and
recordkeeping section for the Resins Process read:
"Calculations of VOC emission per month shall be made within 30 days of the end of each
month."
Following the HFPO Process permit modification, this unrelated section now reads:
"Calculations of VOC emission per month shall be made at the end of each month. VOC
emissions shall be determined by multiplying the total amount of each type of VOC-
containing material consumed during the month by the VOC content of the material."
Taken literally, the condition would require the monthly VOC emissions from the Resins Process
to be determined prior to the completion of that month, which is an impossibility.
It would appear that DAQ inadvertently and mistakenly changed Section 2.1(c)(5)(b). This
error has been communicated to Ms. Fern Paterson (DAQ Central Office Permitting Section)
who is currently reviewing a permit modification application and will soon issue a revised
Title V permit for this site.
If you have any questions regarding this permit deviation, or if you need any additional
information, please contact Michael Johnson at 678-1155.
By my below signature, I certify that I believe the information contained in this letter is true,
accurate, and complete.
Sincerely,
7(
c
Karen B. Wrigley
Plant Manager
DEQ-CFW 00086406