DEQ-CFW_00086946

DuPont, 0900009
Subject: DuPont, 0900009
From: Robert Kennedy <[e-mail]>
Date: Mon, 24 Sep 2007 09:07:14 -0400
To: Fern Paterson <[e-mail]>, Jim Moser <[e-mail]>
Fern,
There are two issues in the review that I did not include with the draft permit
issues.
I inspected DuPont on 7 September 2007 and found the facility to appear to be in
complaince. The inpection report is not complete yet and therefore not in IBEAM
Documents. Page 4
You sent me a draft permit on Septembe i h, not August 18th. Page 7
Thanks,
Bob
1 of 1 9/24/2007 9:28 AM
DEQ-CFW 00086946

Re: DRAFT Title V Permit
Subject: Re: DRAFT Title V Permit
From: Michael E Johnson <[e-mail]>
Date: Tue, 18 Sep 2007 16:02:53 -0400
To: [e-mail]
Fern:
Attached is your draft permit with my mark-ups using the Word track -changes
feature.
H e is a description of my changes:
Cover page - greeting: Changed Mr. Hudson to Ms. Wrigley
2) Insignificant Activities List: Added I-8 for the several
self-contained abrasive blasting cabinets that are on site and I-9 for the
several spray paint booths that are on site.
V' Part I Section 1 - Equipment List: Removed the minimum vacuum listed
for the NS-G venturi scrubber since (1) it does not show up anywhere else
in the permit, (2) a large vacuum is not a necessary parameter to control
air emissions, meaning any vacuum will prevent the fluorinator from
venting, (3) the venturi is only used during the SR Resin campaign and then
only for the resin that is fluorinated, and (4) the level of vacuum only
affects the production rates not emissions.
4I Part I Section 1 - Equipment List: Added the word "Semiworks" to
SW-1 and SW-2 to make it more descriptive and to make it consistent with
the wording in Section 2.1(C).
16) Part I Section 1 - Equipment List: Added the words "(State
enforceable, only)" to AS -A to denote the ACD-Al scrubber as being only for
TAP control and to make it consistent with the wording you added for the
BBucite scrubbers BCD-B1 and BCD-B2.
Part I Section 1 - Equipment List: Added the words "(State
enforceable, only)" to WTS-B and WTS-C to denote the WTCD-1 scrubber as
being only for odor control and to make it consistent with the wording you
7a d for the Butacite scrubbers BCD-B1 and BCD-B2.
�7J1/ Part I Section 2.1(E): The process description is a little ambiguous
since it could be interpreted that both listed wet scrubbers are on the 3
building exhaust vent. I have moved the wording around to make it clear as @
to the building exhaust scrubber.
8) Part I Section 2.1(I)(1)(c): This section has
rates 'P' in tons" that is not in the other 2D.0515
all the 2D.0515 sections read the same?
�) Part I Section 2.1(I)(1)(d): This section has
"maintenance performed on the bagfilters", but there
cortrol device associated with this process.
a phase about "process GJ- wCPto
• •'
sections. Shouldn't v 1
a statement about
is no air pollution
1 ) Part I Section 2.1(I)(2): We talked about this section only applying `
to the product collection system vent (FEP-B4), and I don't know if you
plan on adding some words to the permit to make that clear, or if it will
just be obvious to the DAQ inspector when he/she is here as to which stack
is subject to this requirement.
11) Parrt II Section 1 Table: The su rscript on the NS-M entry is the
footnote 4, but it should be footnote Also, footnote 5 states that the
NS-M and CD-A3 modifications are a 501(c)(2) change, but shouldn't it be a
502(b)(10) change?
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9/18/2007 4:15 PM
DEQ-CFW 00086947

Re: DRAFT Title V Pernut
Let me know if you have any questions.
Mike
(See attached file: Permit T31 DRAFT.doc)
Michael E. Johnson
Environmental Manager
DuPont Company
Fayetteville Works
[phone]
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