DEQ-CFW_00086883

DuPont Fluoroproducts
U o 22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Received
JUL 18 2007
Permits section
July 16, 2007
Dr. Donald R. van der Vaart
NCDENR — Division of Air Quality
Permitting Section
1641 Mail Service Center
Raleigh, NC 27699-1641
SUBJECT: Request for Modification of Title V Air Permit No. 03735T30
APFO Manufacturing Facility Building Exhaust Wet Scrubber and
TFE/CO2 Process
DuPont Company — Fayetteville Works
Dear Dr. van der Vaart:
Enclosed are two copies of an application, and the required confidential information, to modify
the subject Title V air permit to allow for the installation and operation of a new wet scrubber in
the existing Ammonium Perfluorooctanoate (APFO) Manufacturing Facility and to allow for the
installation and operation of a new tetrafluoroethylene (TFE) and carbon dioxide (CO2) process.
You will find the confidential information for this application in a separate envelope. DuPont
requests that this information be treated as business confidential.
Also enclosed you will find a check for $867.00 to cover the cost of the required application fee.
As required by our Title V permit, the original and two copies of this application have been
delivered to the Fayetteville Regional Office.
The purpose of submitting this application directly to your office is to assist the Division of Air
Quality in issuing the modified Title V permit in a timely manner.
The first part of this permit modification application is to allow for the. installation and operation
of a wet scrubber to remove ammonium perfluorooctanoate (APFO) and/or perfluorooctanoic
acid (PFOA) from the building exhaust air that is vented from the APFO Manufacturing Facility.
Stack testing conducted in early 2006 determined that the potential emissions of these
unregulated chemicals is approximately sixty (60) pounds per year. DuPont intends to
E.I. du Pont de Nemours and Company
DEQ-CFW 00086883

pr. Donald R. van der Vaart
NCDENR — Division of Air Quality
July 16, 2007
voluntarily install a water eductor scrubber to reduce the emissions of these compounds. Since
this wet scrubber is not required to compliance purposes, DuPont is claiming a capture and
control efficiency of 0% for this control device. Accordingly, the 15A NCAC 2Q.0112
requirement for a professional engineer's seal is not applicable for this application.
The second part of this permit modification application is to allow for the installation and
operation of a new process that will separate the incoming tetrafluoroethylene (TFE) that is used
as a raw material in several of the fluoroproducts processes, from the carbon dioxide (CO2) used
to make the TFE non-flammable for transportation. This new process will replace the existing
process (NS-L) whereby the incoming TFE is separated from anhydrous hydrogen chloride
(HCl). One of the benefits of the new process is the improved safety of transporting, handling,
and storing carbon dioxide in lieu of anhydrous hydrogen chloride. Additionally, the emissions
of VOC compounds will be reduced and the emissions of a toxic air pollutant (HCl) will be
eliminated. Once this new process is operational and the TFE/HCl process (NS-L) is shutdown,
an administrative modification application will be submitted to the Division of Air Quality to
remove NS-L from the subject Title V Air Permit.
If you should have any additional questions, please feel free to contact me at [phone].
Michael E. Johnson
Environmental Manager
Enclosures
DEQ-CFW 00086884