DEQ-CFW_00086945

DuPont, 0900009
Subject: DuPont, 0900009
From: Robert Kennedy <[e-mail]>
Date: Mon, 24 Sep 2007 08:45:50 -0400
To: Fern Paterson <[e-mail]>, Jim Moser <[e-mail]>
Fern,
Here are my comments on the DuPont draft T31. Since I'm getting into this
application late, let me know if these issues have already been discussed.
Emission source table - in the body of the permit (2.1 Section C) emission sources
controlled by NCD-Hdrl and NCD-Hdr2 are described as controlled by "and/or" or "or"
these control devices, but the source table reads as if both control devices are
attached to each emission source.
1 Section B. Butacite Process - the emission source table lists four emission
sources (BS-B1.1 through BS-B1.4) controlled by BCD-B1, but in section B, th four
1/ sources are grouped into BS-B1. Ditto for BS-B2.1 thgough BS-B2.4. Page 9 jIx"d
,/-1 Section B. Butacite Process - BS-C is the 1lonly ou c in thisa(�c�ion wUth�tC.�..-
particulate or VE requirements. Page 11-12 01- J�A �� — - AO G U' 9
2.1 Section E. APFO Manufacturing - inspection records for the wet scrubber must be
t� kept, but there is nothing requiring the inspection toy�e completed or listi g( he 1
minimum frequency of the inspections. Page 20 — h0 ' O fvc Sye
rp�tne�y�,(
2.1 Section G. Temporary Boiler - the sulfur dioxide emis�on i( limited to 40 tons,
and DuPont is required to record and report the gallons of #2 burned, but the gallons
and emissions are not tied together. Should there be a limit of the number of
gallons of .5% sulfur oil
burned? Should DuPont calucate sulfur dioxide emissions.
Page 22 alK / wo a e�
-- oQor��
2.1 Section I. Polyvinyl Fluoride Polymer - if E is abov/Ita,
al, DuPont can correct
within the monitoring period. The monitoring period is 3; should the
correction time be changed to 1 day or 5 days? Page 25 Y 4o cog +- 6-
2.2 Section B. Toxics - inspection records for the scrubbers must be kept, but there
is nothing requiring the inspection to be completed or listing the minimum frequency
of the insp �cti� ��,�
ons� in this seciton. Page 31 / �4�•
L 6I\tor- raK.
I'm in a taff meeting starting at 0930. I'll call later in the AM.
Thanks,
Bob
of 1 9/24/2007 9:27 AM
DEQ-CFW 00086945