DEQ-CFW_00086801

RCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor Division of Air Quality William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
30 November 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Karen Wrigley, Plant Manager
E.I. du Pont de Nemours & Co., LLC
DBA, DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Duart Township, North Carolina 28306-7332
SUBJECT: Notice of Violation -Failure to Submit Operating Permit Application in a Timely Manner
DuPont Company - Fayetteville Works Permit No. 03735T31
Duart Township, North Carolina, Bladen County 06/09-00009
Dear Ms. Wrigley:
On 23 February 2004, you received a construction permit for boiler PS -Temp. This permit included a stipulation in Part
II Section 2 requiring a "complete Title V application for a significant modification for the operation of the following emission
sources (PS -Temp) within twelve (12) months of commencing operation of the No. 2 fuel oil -fired boiler". The Division of Air
Quality (DAQ) Fayetteville Regional Office (FRO) received a letter from DuPont Fayetteville Works, dated 25 January 2005;
this letter stated that the operation of the rental boiler (PS -Temp) would commence on or about 26 January 2005. A similar
letter, dated 26 April 2006, stated that the operation of rental boiler (PD-Temp) commenced during April 2006. DAQ FRO
received the complete Title V application for the operation of temporary boiler PS -Temp on 11 October 2007; approximately 33
months after the January 2005 commencement of operation and 18 months after the April 2006 commencement of operation.
As stated in the "subject" above, this letter represents a Notice of Violation for failure to submit a complete Title V
application for temporary boiler PS -Temp within twelve months of commencing operation. This General Statute provides that
civil penalties of not more than ten thousand ($10,000) may be assessed against any person who violates any classification,
standard, or limitation established pursuant to General Statute 143-215.107, Air Quality Standards and Classifications. Please
refer to the enclosed Pollution Prevention/Small Business insert for further information.
If you have any questions regarding this matter, please call Bob Kennedy, Environmental Engineer, at [phone].
You are reminded that these violations must be property accounted for on the next annual Title V compliance certification due on
or before 1 March 2008.
cerel ,
r
- / �IA
Steven F. Vozzo
Regional Air Quality Supervisor
Enclosure
cc: DAQ Central Files
FRO County Files
Fayetteville Regional Office - Division of Air Quality One
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043 NorthCarolina
Phone: [phone]\ Fax: [phone] \ Internet: http://www.ncair.org ;Vatulvllaff
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
DEQ-CFW 00086801

A /
NORTH CAROLINA DIVISION OF
AIR QUALITY
Inspection Report
Date: 09/10/2007
Facility Data
DuPont Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28302
Lat: 34d 50.6100m Long: 78d 50.3460m
SIC : 3081 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Contact Data
Facility Contact d Authorized Contact
Michael Johnson Karen Wrigley
Environmental Manager Plant Manager
[phone] 1 [phone]
Inspector's Signature:
Date of Signature: Pli P
6".
Technical Contact
Michael Johnson
Environmental Manager
[phone]
Fayetteville Regional Office
DuPont Company - Fayetteville Works
NC Facility ID 0900009
County/FIPS: Bladen/017
Compliance Data
Inspection Date 09/07/2007
Inspector's Initials Robert Kennedy
Operating Status O / Operating
Compliance Code 3 / In Compliance - Inspection
Action Code FS/FULL COMPLIANCE
EVALUATION
Permit Data
Permit 03735 / T30
Issued 9/22/2006
Expires 1/31/2009
Classification Title V
Permit Status Active
Comments:
ISTEPS Action #39
1) DIRECTIONS TO SITE: Dupont Company - Fayetteville Works is located on NC Highway 87 in Bladen County.
From Fayetteville, take Highway 87 south. The entrance to the facility is approximately 18 miles from FRO on the
left side of Highway 87 just before the Cumberland/Bladen County line.
2) FACILITY DESCRIPTION: Dupont Company - Fayetteville Works is a chemical manufacturing facility located
in Bladen County. The facility employs approximately 750 employees and contractors on a 24X7 basis. DuPont
Fayetteville consists of six individual manufacturing plants (though one is not yet operating), a boiler house and a
waste treatment operation. The facility is subject to NESHAP Subpart KK, Printing and Publishing Industry, as well
as the upcoming Subpart FFFF, Miscellaneous Organic NESHAP. Several processes also have PSD avoidance
conditions. The facility has two permanent boilers as well as one temporary boiler; the temporary boiler is
disconnected from the system and waiting shipment off the site.
3) PRE -INSPECTION SUMMARY: On 7 September 2007, I, Robert Kennedy, met with Mike Johnson,
Environmental Manager. During the pre -inspection conference, we discussed the recent and future changes to the
permit. Mr. Johnson confirmed that there have been no changes in emissions since the previous inspection / permit
modification and that the emissions sources listed on the permit had not changed. Mr. Johnson, along with
Technical Engineers from each manufacturing facility, led a tour of each individual plant and provided the required
records.
The Polyvinyl Fluoride Polymer manufacturing facility is constructed and will startup in mid -September.
DuPont submitted a permit modification request on 18 July 2007; the application is in the draft permit status. This
application includes a number of sources detailed in the following sections of this report; it also includes a number n
of sandblast and paint operations as insignificant sources, some of these were observed during the 9 August 2006Ci
inspection and a 9 August 2007 visit.
v ti,
DEQ-CFW 00086802

4) PERMITTED EMISSION SOURCES: At the time of the inspection, DuPont Company — Fayetteville Works was
operating under Permit No. 03735T30 which includes the following emission sources:
Emission
Control
Source
Emission Source Description
Device
Control Device Description
ID No.
ID No.
No.2/No. 6 fuel oil -fired boiler (139.4
PS-1
million Btu per hour maximum heat
N/A
N/A
input)
No. 2/No. 6 fuel oil -fired boiler (88.4
PS-2
million Btu per hour maximum heat
N/A
N/A
input)
No. 2 fuel oil -fired boiler (greater than
PS -Temp*
30.0 and less than 100.0 million Btu
N/A
N/A
per hour maximum heat input)
BS-A
Butyraldehyde storage tank
BCD -A
Brine -cooled condenser
Packed -bed column scrubber with mist
BS-B1
Butacite® flake reactors (4 units)
BCD-B1
eliminator (8 gallons per minute waterinjection
rate averaged over a 3-hour
period)
Packed -bed column scrubber with mist
BS-B2
Butacite® flake reactors (4 units)
BCD-B2
eliminator (8 gallons per minute water
injection rate averaged over a 3-hour
eriod)
BCD-Cl
Cyclone separator
BS-C
Butacite® flake dryer
BCD-C2
Fabric filter (6,858 square feet of filter
area)
BS-D
Polyvinyl butyral sheeting rotogravure
Multi -stage horizontal spray scrubber
printing operation
BCD-D1
(6 gallons per minute of water flow to
each nozzle, averaged over a 3-hour
period)
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
NS-A
Hexfluoropropylene epoxide process
averaged over a 3-hour period)
(HFPO)
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
NS-B
Vinyl Ethers North process
averaged over a 3-hour period)
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
NS-C
Vinyl Ethers South process
averaged over a 3-hour period)
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hour period)
DEQ-CFW 00086803

Emission
Control
Source
Emission Source Description
Device
Control Device Description
ID No.
ID No.
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-D
RSU Process
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-E
Liquid waste stabilization
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-F
MMF process
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
Venturi vacuum jet caustic scrubber
NS-G
Resins process
NCD-G
(minimum vacuum of -80 kPa gauge)
NS-H
Nafion® membrane process
N/A
N/A
NS-I
Nafion® membrane coating
N/A
N/A
NS-J
Nafion® semiworks
N/A
N/A
NS-K
E-2 Process
N/A
N/A
Baffle -plate scrubber (7,000
NCD-Hdrl
kilogram/hour liquid injection rate
averaged over a 3-hour period)
NS-L
TFE/HCl separation unit
Baffle -plate scrubber (7,000
NCD-Hdr2
kilogram/hour liquid injection rate
averaged over a 3-hourperiod)
SW-1
Polymerization operation
N/A
N/A
SW-2
Laboratory hood
N/A
N/A
Wet scrubber (3 gallons per minute
water injection rate averaged over a 3-
FS-A
Fluoroproducts polymer
FCD-Al
hour period)
manufacturing development facility
FCD-A2
Fabric filter (125 square feet of filter
area)
Wet scrubber (30 gallons per minute
ACD-Al
water injection rate averaged over a 3-
AS -A
APFO manufacturing facility
ACD-A2
hour period)
Condenser
WTS-A
Wastewater treatment area consisting
Impingement -type wet scrubber with
WTS-B
of an extended aeration biological
mist eliminator (29 gallons per minute
WTS-C
wastewater treatment facility and two
WTCD-1
dilute potassium hydroxide injection
indirect steam -heated rotary sludge
rate)
dryers
If
v0
3
y
DEQ-CFW 00086804

Emission
Control
Source
Emission Source Description
Device
Control Device Description
ID No.
ID No.
SGS-A**
SentryGlas(V Plus Manufacturing
N/A
N/A
FS-B***
Polyvinyl Fluoride polymer
N/A
N/A
manufacturing facility
5) APPLICABLE AIR QUALITY REGULATIONS: Regulations will be discussed for each various manufacturing
process as listed on the current air permit.
* Powerhouse (PS-1 and PS-2)*
The facility is permitted to operate one No. 2/No. 6 fuel oil -fired boiler (139.4 mmBtu/hr maximum heat input) and
one No. 2/No. 6 fuel oil -fired boiler (88.4 mmBtu/hr maximum heat input). These two boilers share the same stack.
The larger boiler has a steam capacity of 113,000 pounds of steam per hour and was manufactured in 1969. The
smaller boiler was manufactured in 1982 with a steam capacity of 72,000 pounds per hour. They are both pre-NSPS
boilers; however, Boiler PS-2 does have a PSD avoidance condition for PM, PM-10, NO,, and S02. The software
used at the boiler house allows the operator to track criteria pollutant emissions for the PSD avoidance requirement
for the smaller boiler. The smaller boiler operates infrequently. But at the time of the inspection, both boilers were
operating; Boiler 1 firing No. 6 fuel oil and Boiler 2 firing No. 2 fuel oil.
15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS —
Particulate emissions from each of the boilers shall not exceed 0.2667 lbs/mmBtu.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.0241bs/mmBtu and 0.16 lbs/mmBtu
for No. 6 fuel oil.
15A NCAC 2D .0516 SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES — The sulfur
dioxide emissions from each boiler shall not exceed 2.3 pounds per million Btu heat input. The sulfur content
of No. 6 fuel oil shall not exceed 2.1 % sulfur by weight. The Permittee shall maintain fuel certs for all No. 6
fuel oil shipments.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.507 lbs/mmBtu and 2.20 lbs/mmBtu
for No. 6 fuel oil. As long as the No. 6 fuel does not exceed the fuel sulfur limit, the regulatory limit will not be
exceeded during normal operation. Fuel certs were reviewed during the inspection and total fuel usage as well
as average sulfur content are given to Mike Johnson after each month. Sulfur content of the No. 6 fuel oil
ranged between 1.665% and 2.06% by weight on the last few loads.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS = Visible emissions from Boiler PS-lshall not
exceed 40% opacity. Visible emissions from PS-2 and PS -Temp shall not exceed 20% opacity. The permittee
shall record a daily visible emissions evaluation (normal or above normal) and maintain a logbook showing the
results of each evaluation. These results from monitoring must be submitted to DAQ in a semi-annual report.
IN COMPLIANCE — Both Boiler PS-1 and PS-2 vent through the same stack, and both were operating during
the inspection. I observed approximately 5% VE on the day of the inspection. The logbook appeared to be up
to date. The records showed all "normal' observations. The facility has four certified smoke readers and at
least one is present during each shift. The reader stated that if an above normal reading was ever observed, he
would immediately conduct a Method 9. On 9 August 2007, Robert Kennedy observed heavy puffs of VE from
the boiler #2, and on 29 September 2005, Christy Richardson and Steven Vozzo observed heavy VE from the
boilers. The 2007 incident is attributed to a faulty oxygen sensor, and the 2005 incident is attributed to a faulty
air damper control.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from Boiler PS-2 shall not exceed the following: 25 TPY PM, 15 TPY PM-10, 40
TPY NOx, and 40 TPY S02. The Permittee shall keep monthly records of fuel usage, fuel sulfur content, and
maintain fuel certifications. Quarterly reporting is also required for monthly emissions (14 month period), fuel
DEQ-CFW 00086805

usage, and sulfur content. The Permittee must also define all deviations in the report.
IN COMPLIANCE — All reports show that the facility well below these emissions limits. The current
electronic record listed NOx at 14 tons, S02 at 20 tons, PM at 4 tons, and PM10 at 1 ton. Boiler PS-1 is used the
majority of the time with Boiler PS-2 used only when there is a demand. Fuel certifications were reviewed
during the inspection.
* Butacite® Process Area (all sources labeled with BS- and BCD-)*
The Butacite® manufacturing operation includes a polyvinyl butyral sheeting and rotogravure printing operation.
The operation produces flexible glass laminate for car windshields. The printing (tenting) operation is subject to
MACT Subpart KK, Printing and Publishing, requirements and controlled by a permanent total enclosure (testing
conducted per EPA Method 24) for the printing operation room exhaust and a multi -stage horizontal spray scrubber
(testing conducted per EPA Method 18) to control emissions of dimethylformamide (DMF). The butacite process
area includes the butyraldehyde storage tank, with emissions and potential odors from the butyraldehyde controlled
by a brine -cooled (ethylene glycol) condenser. The process also includes the Butacite flake reactors, controlled by
packed -bed column scrubbers, and a butacite flake dryer, controlled by a cyclone separator and fabric filter.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES —
Particulate matter emissions from the Butacite process shall not exceed E=4.10*P°'67. The permittee shall
maintain production records. The Permittee shall perform a monthly visual and annual internal inspection on
baghouses BCD-Cl and BCD-C2. A logbook detailing these inspections must also be kept up to date.
IN COMPLIANCE — The flaking process is controlled by bagfilters to reduce particulate matter emissions.
Visual inspections on these bagfilters are performed on a monthly basis and annual inspections are performed
once a year. The last annual inspection of the cyclone was completed on 12 April 2007, the baghouse on 25
September 2006.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the flake dryer BS-C
shall not exceed 20% opacity. The Peimittee shall record a monthly visible emissions evaluation (normal or
above normal) and maintain a logbook showing the results of each evaluation.
IN COMPLIANCE — During the inspection, I observed 0% VE. VE evaluations are performed daily despite
the monthly requirement, and all readings in the logbook were normal (`no fines' or `no visual fines').
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The Butacite
process shall not operate without odor control equipment. An objectionable odor shall not be detected from
these sources. Liquid flow rate for BCD-B 1 and BCD-132 shall be at least 8 gallons per minute and the
differential pressure shall be less than 30 inches of water over a three-hour period.
IN COMPLIANCE — Odorous emissions from the butyraldehyde storage tank BS-A are controlled by a
condenser BCD -A. Odorous emissions from the flake reactor lines BS-B 1 and BS-132 are controlled by packed -
bed scrubbers BCD-B 1 and BCD-B2. The liquid flow rate was 8.6 gpm to 10 gpm on records observed on the
day of the inspection. The differential pressure was generally between 8 inches and 30 inches of water with a
few points below 7.8 inches. Alarms automatically sound if the limits are exceeded. Only a slight odor was
detected outside the building.
40 CFR Part 60 Subpart KK: NATIONAL EMISSIONS STANDARDS FOR PRINTING AND
PUBLISHING INDUSTRY — The printing operation BS-D must have scrubber control with an overall organic
HAP control efficiency of atleast 95 percent. The water flow rate in the scrubber must be greater than 6 gallons
per minute. The airflow rate must be greater than 63 standard cubic feet per minute and the fan exit velocity
must be greater than 3,950 feet per minute over a three-hour period. If startup, shutdown, maintenance
procedures differ from the SSMP, DAQ must be notified.
IN COMPLIANCE — The tenting operation takes place in a permanent total enclosure, which is controlled by a
three -stage horizontal scrubber BCD-D 1 with a control efficiency of greater than 97%. The scrubber utilizes
de -mineralized water to remove organic HAPs. The system is interlocked so that if any one of the scrubber Ci
parameters exceeds the regulated limit, the entire process will shut down. Set points for water flow, airflow, c!j
and exhaust velocity are set well above the permit liriit. Set points for each parameter are as follows: 6.5 y
gal/min for water flow rate, 68 scfm for air flow rate, and 4200 ft/min for fan exit velocity. This section has r.,j
® J
y-
V
ti
DEQ-CFW 00086806

not operated since October 2006 but will startup in the summer of 2008.
* Nafon® Process Area (all sources labeled with NS- and NCD-)*
The Nafion operation produces a variety of relatively uncommon monomer and polymer chemicals. Some of the
monomers are shipped.offsite, while others are used onsite in the production of various polymers. The polymers are
shipped offsite or used onsite to produce Nafion® membrane material. A principal use of the membrane is in the
extraction / production of chlorine and sodium hydroxide at chlor-alkali plants. The two waste gas scrubbers located
at Nafion are used to control the emissions of various pollutants including hydrogen fluoride and acid fluorides. The
Nafion process will be subject to the Miscellaneous Organic NESHAP.
With air permit 03735T30, the facility was allowed to replace a `scrubber' in the hexfluoroporpylene epoxide
process. This `scrubber' is a process separator, not a control device. Since this `scrubber' is a process bottleneck,
the facility has requested a PDS avoidance limit for VOCs due to this equipment change. Mike Johnson explained
that this was only phase one of a project that would occur over the next couple of years. The second phase will
consist of even more expansion and additional increase in production. The current modification request also adds a
TFE/CO2 unit..
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES —
Particulate matter emissions from the Nafion process shall not exceed E=4.10*P0'67. The Permittee shall
maintain production records.
IN COMPLIANCE — During the inspection, I reviewed the production records.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the membrane
coating process NS-I shall not exceed 20% opacity. No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — During the inspection, I observed 0% VE.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The Nafion
process shall not operate without odor control equipment.
IN COMPLIANCE — Odorous emissions from the Nafion process are controlled by two baffle -plate scrubbers
NCD-Hdr1 and NCD-Hdr2. The control devices also have monitoring parameters that are continually recorded
and interlocked into the system. All the facility's monitoring parameters are recorded and viewable in an Aspen
program. A slight odor was detected close to the building, but, no noticeable odor was detected away from the
building.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — VOC emissions from the Vinyl Ethers North process, NS-B, shall not exceed 68.9 TPY
VOC. The baffle -plate tower scrubbers must maintain a liquid flow rate of at least 7,000 kilograms per hour.
The Permittee shall keep monthly records of VOC emissions.
IN COMPLIANCE — The liquid flow rate set point is still set to exceed the 16,500 kg/hr previous permit limit.
The scrubber utilizes a potassium hydroxide solution in the scrubber and is interlocked to shut the system down
at 7,000 kg/hr and to alarm at 16,500 kg/hr. All reports show that the facility is not close to exceeding these
emissions limits; both flow rates were in the 17,500 to 18,200 range during the inspection. VOC emissions are
calculated using stack test results, material balances, and flow rates / concentrations on a monthly basis. These
records are submitted to Mike Johnson within 30 days of the following month. The current emissions are 3.5
tons for July and 44.1 tons per 12-month period.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the resin process NS-G shall not exceed the following: 40 TPY VOC. The
Permittee shall keep monthly records of VOC emissions.
IN COMPLIANCE — The current emissions are 2.9 tons for July and 29.2 tons per 12-month period.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the resin process NS-A shall not exceed the following: 85.3 TPY VOC. The
Permittee shall keep monthly records of VOC emissions.
DEQ-CFW 00086807

IN COMPLIANCE — The current emissions are 5.8 tons for July and 42.9 tons per 12-month period
40 CFR Part 60 Subpart FFFF: MISCELLANEOUS ORGANIC NESHAP (MON) — The Nafion process
must comply with all provisions of this MACT. The MON requires 99% control efficiency. The compliance
date was 10 November 2006, but has been extended by EPA to May 10, 2008.
IN COMPLIANCE — The scrubbers currently controlling the Nafion process (NCD-Hdrl and Hdr2) meet the
control efficiency requirement. The scrubbers were tested at 99.6% efficiency in August 2003. Initial
notification was received on 2 March 2004.
* Fluoroproducts Polymer Manufacturing Development Facility (PMDF/Teflon) (all sources labeled with FS-
and FCD-)*
The Fluoroproducts PMDF operation is a continuous process designed to produce fluoropolymer resins. The
process includes a wet scrubber and a fabric filter (125 ft2 filter area). The final product is an extruded plastic pellet
used to make Teflon products. The emissions from the process include acid fluorides and hydrogen fluoride.
15A NCAC 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES —
Particulate matter emissions from the PMDF shall not exceed E=4.10*Po-". The Permittee shall maintain
production records. The Pemuttee shall perform a monthly visual and annual internal inspection on baghouse
FCD-A2. A logbook detailing these inspections must also be kept up to date. The facility must report semi-
annually a summary report of monitoring and recordkeeping activities.
IN COMPLIANCE — The PMDF is controlled by bagfilters to reduce particulate matter emissions. Visual
inspections on these bagfilters are performed on a monthly basis and annual inspections are performed once a
year. All the monthly inspections were recorded; the last annual inspection was recorded on 29 June 2007.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the PMDF shall not
exceed 20% opacity. No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — During the inspection, I observed 0% VE.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The PMDF shall
not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE — The scrubber is only used during purge for maintenance activities and is used to control
acid fluorides. During the inspection, I observed a very slight odor near the building.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the PMDF shall not exceed the following: 40 TPY VOC. The Permittee
shall keep monthly records of VOC emissions. Quarterly reporting is also required for monthly emissions (14
month period).
IN COMPLIANCE — All reports show that the facility is well below these emissions limits. The CY2006
total VOC emission was 23.5 tons; the 2007 emission through July was 28.1 tons.
* Ammonium Perfluorooctanate (APFO) Manufacturing Facility (all sources labeled with AS- and ACD-)*
The ammonium perfluorooctanoate (APFO) process began operation in December of 2002. The APFO reaction
process uses perfluorooctanoate (brought in by truck in its iodide/salt form) reacted with sodium hydroxide (stored in
totes) to form the acid fluoride. The acid fluoride is then reacted with ammonia to produce the ammonium salt.
Fuming sulfuric acid (oleum) is received by truck and used as a solvent in the process. Currently, APFO and the
associated perfluorooctanoic acid (PFOA), also known as C8, are not regulated as toxic or hazardous air pollutants.
However, the EPA is currently reviewing the chemical with the possibility of its designation in the future as a
regulated pollutant. However, due to historical pollution and health effects concerns and recent controversy regarding
the Dupont facility in West Virginia, and the recent activities by the U.S. EPA to develop and review toxicity data for
this chemical, the DAQ file includes several documents and articles related to APFO, PFOA, or C8. The current p
modification request is to remove a condenser that is no longer being utilized and to add a wet scrubber to the buildings
exhaust vent. The APFO process is subject to the 112(r) chemical accident prevention, program for oieiim.
v
3
DEQ-CFW 00086808

15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The APFO
facility shall not operate without implementing a management plan or without odor control equipment.
IN COMPLIANCE — The APFO process is controlled by a scrubber and associated demister. During
the inspection, I did not detect an odor near the facility.
15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS — Emissions from the APFO facility
shall be controlled by a wet scrubber. The liquid flow rate in the packed bed section shall be at least 30 gallons
per minute and the differential pressure across the bed shall be a maximum of 12 inches of water. An alarm is
required for the pressure monitoring. All inspections shall be kept in a logbook.
IN COMPLIANCE — The scrubber is interlocked so that the system will shut down, almost instantaneously, if
the parameters are exceeded. During the inspection, the liquid flow rate was in the 36 gpm to 40 gprn, and the
differential pressure was approximately —0.1 in H2O. APFO is a surfactant; therefore, the DP increases
occasionally due to `suds' in the scrubber.
Results of the stack tests in March 2006 and April 2006 show that approximately 62 lbs of PFOA is emitted
from this facility per year. To further reduce these emissions, the current modification request seeks to add a
HEPA filter to control PFOA (a particulate) from the building exhaust. The building exhaust appears to be the
source of most (80-90%) of these emissions.
During late 2006, the facility had an air release when the fiberglass filter in the demister formed a hole. A
technician noted flakes falling from the stack and manually shut the system down. The scrubber and APFO
manufacturing facility are interlocked and the system should automatically shut down when the scrubber
malfunctions. When asked why the system did not automatically shut down during the late 2006 incident, the
Process Engineers explained that the permitted scrubber parameters were never exceeded. The scrubber was
operating properly; however, the demister had a hole and foam was released from the stack. To ensure that this
problem does not occur again, the facility is using only water as solution in the demister and the atomizer has
been replaced to prevent localized wear on the fiberglass filter. The facility is also adding additional
interlocked parameters such as a foam detection switches and adding a plastic sleeve so that technicians can see
what is occurring in the demister exhaust stream.
* Wastewater Treatment Area (all sources labeled with WTS- and WTCD-)*
For the wastewater treatment operations, the Title V permit specifies two rotary sludge dryers controlled by an
impingement -type wet scrubber with mist eliminator (29 gallons per minute dilute potassium hydroxide solution).
The Miscellaneous Organic NESHAP (MON) will also address emissions from wastewater. With respect to
quantity of emissions, methanol is the most significant air pollutant from the wastewater treatment operation.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The wastewater
treatment facility shall not operate without management plan or odor control equipment. An objectionable odor
shall not be detected from these sources. The sludge dryers shall be controlled by a caustic injection scrubber.
An I&M logbook is also required for the scrubber. '
IN COMPLIANCE — Odorous emissions from the sludge dryers are controlled by a scrubber utilizing
potassium hydroxide solution. Wastewater treatment odors were noted surrounding the wastewater treatment
facility but were not present at boundary lines. The sludge dryers are located inside a building. On the day of
the inspection, the system was not operating.
* Temporary Boiler (PS -Temp)*
This boiler is permitted for No. 2 fuel oil and is brought on -site on an `as needed' basis. The boiled was on site but
disconnected and awaiting transport off the site.
15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS —
Particulate emissions from the temporary boiler shall not exceed E=1.090*Q-0.2194 Ibs/mmBtu.
IN COMPLIANCE — The AP-42 emissions factor for No. 2 fuel oil is 0.024 lbs/mmBTU.
DEQ-CFW 00086809

6)
7) COMPLIANCE HISTORY: There appears to have been no compliance issues over the last five-year period.
15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS (Subpart Dc) — The sulfur content
of all received fuel oil shall not exceed 0.5% sulfur by weight. The Permittee shall maintain fuel certifications
and monthly amounts of fuel burned.
IN COMPLIANCE — Fuel certs indicate fuel oil is less than 0.5% sulfur by weight; actually 0.0015% sulfur.
15A NCAC 2Q .0317 PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE
CONDITIONS — Emissions from the temporary boiler PS -Temp shall not exceed the following: 40 TPY SO2-
The Permittee shall keep monthly records of the amount of fuel combusted. Quarterly reporting is also required
for monthly combustion and all deviations (14 month period).
IN COMPLIANCE — All reports show that the facility is not close to exceeding these emissions limits.
* SentryGlas® Plus Manufacturing Facility (SGS-A)*
The SentyGlas plant began operation in 2005 and manufactures rigid plastic glass laminate. This product is similar
to the Butacite product; however, this material is much stronger, even explosion proof. The facility has a crushing
system used to crush the pelletized raw material. Crushed material is sent to a silo, which is controlled by a
baghouse that vents indoors. The entire process takes place in a clean room to avoid contamination by lint, dirt, etc.
15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS — Visible emissions from the SentryGlas
manufacturing facility shall not exceed 20% opacity. No monitoring, recordkeeping, or reporting required.
IN COMPLIANCE — This facility was not operating at the time of the inspection, the shift had ended.
15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS — The SentryGlas
manufacturing facility shall not operate without implementing a management plan or without odor control
equipment.
IN COMPLIANCE — This facility was not operating at the time of the inspection, the shift had ended
* Polyvinyl Fluoride (PVF) Polymer Manufacturing Facility (FS-B)*
This facility was added to the permit on June 23, 2006. The facility is completely constructed and is scheduled to
start operation mid -September 2007.
* Facility -Wide Toxics Limits*
15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS — The Permittee shall maintain records
of production rates, throughputs, material usage, excess emissions, and control equipment failures. The
Permittee shall also report in a quarterly report, all TPER exceedances, the maximum 1-hour emission rate, the
maximum 24-hour emissions rate, and the maximum 12-month emissions rate. The liquid flow rate in the
Nafion scrubbers shall be at minimum 7,000 kg/hr. The Permittee shall maintain a logbook of all inspection
and maintenance activities on the applicable scrubber.
IN COMPLIANCE — The liquid flow rate set point is still set to exceed the 16,500 kg/hr previous limit. The
scrubber utilizes a potassium hydroxide solution in the scrubber and is interlocked to shut the system down at
7,000 kg/hr. During the inspection, both flow rates were in the 17,500 to 18,200 range, and the I&M logbook
appeared to be in order.
CHEMICAL ACCIDENT PREVENTION AND 112(r): The Nafion process is subject to 112(r) for sulfur
trioxide, tetrafluoroethylene, and hydrogen chloride. The APFO process is subject to 112(r) for oleum. The facility
submitted the initial Risk Management Plan to the U.S. EPA in June 1999. In addition, the facility is subject to the
OSHA Process Safety Management Standard.
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DEQ-CFW 00086810

8) CONCLUSIONS AND RECOMMENDATIONS: Based on the observations made during the 7 September 2007
inspection, DuPont Company — Fayetteville Works appeared to be operating in compliance with the requirements
outlined in their current air permit, 03735T30.
DEQ-CFW 00086811

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