HomeMy WebLinkAboutDEQ-CFW_00087538DEQ-CFW 00087538
0 3.0 NAFIONO PROCESS
:7
Several different highly specialized fluorinated hydrocarbons are produced in the
Nafion® area. One of the products produced is the actual Nafion® product which is a
membrane used in the production of caustic and chlorine gas from sodium chloride.
The Nafion® area consists of several process units including:
• Hexfluoropropylene epoxide process (HFPO);
• Vinyl ethers process (Vinyl Ethers 1 and Vinyl Ethers 2);
• Resin/polymer production process (XR/CR Process);
• Membrane production and coating processes;
• and several support operations (RSU, Liquid Waste Stabilization, MMF, and E-2
process).
The Nafion® area also contains semiworks facilities which include laboratory, testing,
and R&D operations, pilot -scale production operations, and short-term plant -scale testing
operations support the Nafion® process area.
It is worth pointing out that the Nafion® area is somewhat unique in the sense that many
of the process operations are carried out on a much smaller scale than is typically
associated with a chemical manufacturing facility. This is attributable to the fact (as
stated above) that the products manufactured are highly specialized and tend to be
produced in relatively small volumes. In many ways, the Nafion® process areas are
comparable to what is typically considered "pilot -scale" operations, from the standpoint
of both equipment sizes and variability of process operations.
Figures 3-1 and 3-2 outline process flow in the Nafion® area. As was done for the
Butacite® process, a new nomenclature has been developed for the Nafion® emission
unit, control device, and emission point identification numbers.
A complete emissions inventory and regulatory applicability analysis has been performed
for the Nafion® area. A summary of these analyses are included in the following tables:
Table 3-1
Summary of Nafion® Emission Units
Table 3-2
Summary of Applicable Requirements
Table 3-3
Summary of Compliance Monitoring
Table 3-4
Summary of Old Versus New Identification Numbers for the
Nafion® Process
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DEQ-CFW 00087539
0 General comments regarding the Nafion@ area processes are as follows:
•
1. The Nafion@ process is equipped with a set of identical waste gas scrubbers which
control emissions from several of the processes. The waste gas scrubber headers run
throughout the Nafion@ area. Because the waste gas scrubbers are associated with
several emissions units, the C-Form for the scrubbers is not attached to any individual
emission unit, but rather is included at the end of this section. Inputs to the scrubbers
on the C-Form include total input from the entire Nafion@ area.
2. In general, because of their relatively small size, only a few of the Nafion@ emission
units are subject to air regulations with specific emission limits, although all of the
Nafion@ emission units were included in a facility -wide North Carolina air toxics
modeling demonstration (see Section 5 for additional detail) that was done in 1995.
3. None of the Nafion® area process units are subject to any underlying requirement that
limits hourly VOC emissions. Because of this, and due to the inherent variability and
complexity of many of the Nafion@ area processes, potential hourly VOC emissions
have not been quantified for several of the emission units.
4. Each of the Nafion@ area process unit emissions includes both point source and
"process -related" fugitive (i.e. equipment leak) emissions. "Process -related" as used
in this context refers to any fugitive emissions directly associated with the process,
but does not include fugitive emissions associated with support equipment such as the
Nafion@ area refrigeration system. Fugitive emissions associated with the Nafion@
refrigeration system which services several of the process units have been identified
as a separate emission unit.
5. The existing air permit for the Nafion@ Area includes a scrubber installed on the
No. 2 Vinyl Ethers equipment (item 3g) that DuPont believes should be exempt from
permitting, and also includes "FPX" process equipment (item 3e) that are no longer in
operation and should be removed from the permit.
6. Actual and Potential emissions from the Nafion@ area processes have been estimated
using either:
�rK ntly submitted permit application data (HFPO,
Semiworks, and E-2 Process);
1994 Emissions Inventory data; or
Vinyl Ethers 2,
• 1995 Emissions Inventory data.
In general, determination of whether or not to use 1994 or 1995 emissions inventory
data was made based on whichever year gave the worst -case emissions. Emissions
calculation data for the Nafion@ area processes are included in Addendum A.
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DEQ-CFW 00087540
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CONFIDENTIAL
I;RM—Southeast, Inc.
NAFION 'NPROCESS FIGURE
CHARLOTTE, NORTH CAROUNA DU PONT — FAYETTEVILLE WORKS 3-1
ERM I DUART, NORTH CAROLINA
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CONFIDENT�AL
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ERM—Southeast, Inc. FLUOROCARBON PROCESSES
CHARLOTTE. NORTH CAROLINA DUPONT FAYETTEVILLE - WORKS 3-2
ERM I DUART, NORTH CAROLINA
3-4
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TABLE 3-1
SUMMARY OF NAFION® EMISSION UNITS
HFPO Process
NS-A
NCD-Hdrl or
Waste Gas Scrubber 1 or
NEP-Hdrl or
NCD-Hdr2
Waste Gas Scrubber 2
NEP-Hdr2
No. 1 Vinyl Ethers Process
NS-B
NCD-Hdrl or
Waste Gas Scrubber 1 or
NEP-Hdrl or
NCD-Hdr2
Waste Gas Scrubber 2
NEP-Hdr2
No. 2 Vinyl Ethers Process
NS-C
NCD-Hdrl or
Waste Gas Scrubber 1 or
NEP-Hdrl or
NCD-Hdr2
Waste Gas Scrubber 2
NEP-Hdr2
RSU Process
NS-D
NCD-Hdrl or
Waste Gas Scrubber 1 or
NEP-Hdrl or
NCD-Hdr2
Waste Gas Scrubber 2
NEP-Hdr2
Liquid Waste Stabilization
NS-E
NCD-Hdrl or
Waste Gas Scrubber 1 or
NEP-Hdrl or
NCD-Hdr2
Waste Gas Scrubber 2
NEP-Hdr2
MMF Process
NS-F
NCD-F and
Caustic Scrubber
NEP-Hdrl or
NCD-Hdrl/Hdr2
Waste Gas Scrubbers 1 or 2
NEP-Hdr2
Resins Process
NS-G
NCD-G
Caustic Scrubber
NEP-G
Nafion® Membrane Process
NS-H
--
--
NEP-H1
NEP-H2
Nafion@) Membrane Coating
NS-I
--
--
NEP-1
Nafion@) Semiworks
NS-J
NEP-J1
--
--
NEP-J2
NEP-J3
E-2 Process
NS-K
--
--
NEP-K1 through K21
Nafion® Refrigerant System
NS-Ref Fug
--
--
Not Applicable
Fugitive Emissions
No. 1 Vinyl Ethers
Insig-N1
See Note 1
See Note 1
--
Reactor Purge System
No. 2 Vinyl Ethers
Insig-N2
See Note 1
See Note 1
--
Reactor Purge System
MMF Sodium Methoxide
Insig-N3
See Note 1
See Note 1
Note]: Each of these systems are equipped with dust suppressers; however, uncontrolled emissions are less than five tons per year, and
therefore, these units are exempt from permitting.
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TABLE 3-2
SUMMARY OF APPLICABLE REQUIREMENTS FOR NAFION® FACILITY'
Emission Unit Descriptiow
Emission -Unit
ID No.
Applicable Requirement:
Regulatory'Citafion
HFPO Process
NS-A
No applicable requirements
N/A
No. 1 Vinyl Ethers Process
NS-13
VOC emissions from No. 1 Vinyl Ethers
< 68.9 tpy
Avoid 15A NCAC 2D.0530
No. 2 Vinyl Ethers Process
NS-C
No applicable requirements
N/A
RSU Process
NS-D
No applicable requirements
N/A
Liquid Waste Stabilization
NS-E
No applicable requirements
N/A
MNIF Process
NS-F
No applicable requirements
N/A
Resins Process
NS-G
Resins Process VOC emissions < 40 tpy
Avoid. 15A NCAC 213.0530
Nafion® Membrane Process
NS-H
No applicable requirements
N/A
Nafion@ Membrane Coating
NS-I
PM emissions < 1.05 Ib/hr
Opacity < 20%
15A NCAC 2D.0515
15A NCAC 2D.0521
Na:Fon® Semiworks
NS-J
No applicable requirements
N/A
E-2 Process
NS-K
No applicable requirements
N/A
Nafion® Refrigerant System
Fugitive Emissions
N-Ref Fug
No applicable requirements
N/A
Notes:
1. ,All of the Nafion® emissions units are subject to the facility -wide North Carolina air toxics emission limits.
2. 'No. 2 Vinyl Ethers reactor is equipped with a N2 purge system that results in insignificant PM emissions and is exempt from
permitting.
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TABLE 3-3
SUMMARY OF COMPLIANCE MONITORING FOR NAFIONO FACILITY
Emission Unit Description Applicable Requirement Compliance Monitoring'
No. 1 Vinyl Ethers Process VOC emissions from No. l VEs < 68.9 tpy Will report VOC emissions from vinyl ethers on a rolling
(NS-B) 12-month average basis.
Resins Process VOC emissions from Resins Process < 40 tpy. Will report quarterly the VOC emissions from Resins
(NS-G) Process on a rolling 12-month average basis.
Nafion® Membrane Coating PM emissions < 1.05 lb/hr No formal monitoring plan is proposed; Opacity monitoring
(NS-I) Opacity < 20% will be performed if there are any indications of opacity
problems.
Note:
1. Emissions from each of the Nafion® emission units will be tracked and reported as part of the annual emissions inventory report.
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TABLE 3-4
SUMMARY OF THE OLD VERSUS NEW IDENTIFICATION NUMBERS
FOR THE NAFION® PROCESS
Emission Unit Descrrptiori
1'dew Source
Old Source +Control lDe�vic Nevv Control
<Old Control,;'
H1FPO Process
ID No.
>il<i Na: t3" i 1<D
Description 1i ev tee
llevace ID ..
NS-A
NS-1
No. I Vinyl Ethers Process
NS-B
NS-2, NS-3,
NS-4, NS-5
No. 2 Vinyl Ethers Process
NS-C
NS-15 and Wet Scrubber --
NCD-8
PPVE-AOS-1
RSU Process
NS-D
NS-6
Liquid Waste Stabilization
NS-E
NS-7
MMF Process
NS-F
NS-8 Caustic Scrubber NCD-F
Resins Process
NS-G
NS-9, NS-16
Nafion® Membrane Process
NS-H
NS-1 I Caustic Scrubber NCD-G
NCD-2
Nafion® Membrane Coating
NS-I
NS-12
Spray Booth Filter
--
NCD-4
Na:6on Semiworks
NS-J
SW-1, SW-2,
and NS-J3
E-2Process
NS-K
NS-K
Naf on® Refrigerant System
N-Ref Fug
Fugitive Emissions
--
Nafion® Processes
--
--
Waste Gas Scrubber I
NCD-Hdrl
NCD-1
NS-A through NS-F
Nafion® Processes
--
--
Waste Gas Scrubber 2
NCD-Hdr2
NCD-7
NS-A through NS-F
Notes:
1. Emissions controlled by this
scrubber are insignificant, and therefore, this control device should be removed from the permit (See
NS-C D6 Form).
2. The spray booth filter is an integral part of the spray booth and is not a control device. See NCAC 2Q.0I 02(b)(2)(D). Therefore, this filter should be
removed from the permit.
3. Remove FPX facilities from permit (existing ID Nos.
NS-14, NCD-5, and NCD-6). FPX facilities no longer exist at site.
g Aprojects\fayett\butnaf
FILENAME: NONCONF/NAF-B1.DBF R-1 SECTION B
EMISSION SOURCE (GENERAL) FB
REVISED: 04115194
AIR DUALITY SECTION
ISSION SOURCE DESCRIPTION: HFPO Process
EMISSION SOURCE iD NO: NS-A
CONTROL DEVICE ID NO(S): NCD-Hdrl or NCD-Hdr2
EMISSION POINT IO NO(S): NEP-Hdrl or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
DESCRIBE PROCESS: Production of Hexafluoropropylene oxide (HFPO) by the oxidation of Hexafluoropropylene
(HFP). (Includes associated reaction, refining, and recycle facilities)
OPERATION DATE: 1986; 1996 (mod)
SEASONAL VARIATIONM JAN•MAR: 25 APR•JUN: 25 JUL•SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS • CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoropropylene (HFP - includes
lb
CONFIDENTIAL
recycled HFP)
Oxygen
lb
CONFIDENTIAL
MATERIALS ENTERING PROCESS • BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS le.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Form D3 -2 .
MENTS:
DEQ-CFW 00087547
4
4
CONFIDENTIAL
ERM—Southeast; inc. 1 Hl i ^v PROUC EjS
CHARLOTTE, NORTH CAROLINA
DUPONT — FAYETTEVILLE WORKS
DUART, NORTH CAROLINA
FIGURE
011M
3-►o _
DEQ-CFW 00087548
FILENAME: 1VAF-D3-I.DBF R-10 SECTION D
D3-1
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
('see note in instructions concendng state as toxics regulations)
OVISED: 04/15194 AIR QUALITY SECTION
LL
EMISSION SOURCE DESCRIPTION: HFPO Process
EMISSION SOURCE ID NO.: KS -A IS THIS SOURCE A FUGITIVE SOURCE? 1 1 YES I 1 NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
1,2
See Comments
8.51
113,000
74,580
Hydrogen Fluoride*
Benzene*
Toluene*
COMMENTS:VOC emissions are taken directly from the HFPO modification permit application (submitted
11195). Emissions include both fugitive and point source emissions. Potential hourly emissions vary
depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the HFPO process. See the D6 Form and Addendum A for
re detail.
*Note: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements
DEQ-CFW 00087549
FILENAME: NAF-D3 -2. DBF R-10 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04/15/94 AIR QUALITY SECTION
SSION SOURCE DESCRIPTION: HFPO Process
EMISSION SOURCE 10 NO: NS-A
REGULATED
POLLUTANT
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
D3.2
COMMENTS: There are no federally enforceable applicable requirements associated with the HFPO process.
3-�z
DEQ-CFW 00087550
NAF-D3-3.DBF R-7
SECTION D
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
REVISED: 04/15/94
AIR QUALITY SECTION
' EMISSION SOURCE DESCRIPTION: HFPO Process
EMISSION SOURCE ID NO: NS-A
REGULATED
POLLUTANT
ONGOING SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
QTY. EMITTED
BEFORE REDUCTION
(LBS/YEAR)
QTY. EMITTED
AFTER REDUCTION
(LBS/YEAR)
PLANNED SOURCE
REDUCTION
ACTIVITIES
(ENTER CODES)
A11
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
,3- ►3
DEQ-CFW 00087551
•
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-A
Emission Unit Description: BFPO Process
A. Emissions Estimation Approach:
Actual and potential emissions from HFPO are defined by the HFPO expansion permit
application that was submitted November 1995. Emission calculations from this application are
attached in Addendum A. As part of the application, potential VOC emissions (both point source
and fugitive) were defined as 56.5 tons per year. Actual emissions are estimated as 37.3 tons
VOC. Potential hourly emissions are not quantified because they depend upon several
interrelated parameters. HAPs which may be emitted from the HFPO process include hydrogen
fluoride, benzene, and toluene.
B. Regulatory Information:
There are no federally enforceable regulations that apply to the HFPO process.
Emissions of North Carolina toxic air pollutants (TAPS) from the entire facility are limited and
TAP emissions from this unit count towards the overall limits (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device Information:
Point source emissions from this process unit can be controlled by either of the waste gas
scrubbers. The waste gas scrubbers control acid fluoride emissions. The waste gas scrubbers are
periodically inspected per standard operating procedures to insure proper operation.
D. Compliance Information:
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the HFPO process will continue to be tracked and reported as part of
the required annual emissions inventory.
gAprojects\fayett\d6al I
3- A
DEQ-CFW 00087552
FILENAME: NAF-A5.DBF R-1 SECTION A FA�
' EMISSION SOURCE►CONTROL DEVICE ALTERNATIVE OPERATING SCENARIOS
,IdgaVISED: 04/15/94 Ain UUALI IT atl, I IUn
ISSION SOURCE ID NO: NS-B
CONTROL DEVICE ID NO: NCD-Hdr1 or NCD-Hdr2
PRIMARY OPERATING SCENARIO (DESCRIBE): AOS-1 : Production of PPVE
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO. A09-2: Production of PMVE/PEVE
ESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO. AOS-3 : Production of PSEPVE
DESCRIBE ALTERNATIVE OPERATING SCENARIO (AOS) NO. AOS-4 : Production of EVE
COMMENTS: There is no "Primary" operating scenario, so the four modes of operation have been assigned
AOS No's 1-4
3 -�S
DEQ-CFW 00087553
FILENAME: N0NC0NF\NAF-B1.DBF R-2 SECTION B
I ]
EMISSION SOURCE (GENERAL) B1
,„REVISED: 04115194 AIR QUALITY SECTION
ISSION SOURCE DESCRIPTION: No.1 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B
CONTROL DEVICE ID NO(S): NCD-Hdri or NCD-Hdr2
EMISSION POINT ID NO(SI: NEP-Hdri or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-1
DESCRIBE PROCESS: Production of PPVE along with associated reaction and purification steps.
OPERATION DATE: 1979
SEASONAL VARIATIONI%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoropropylene Oxide (HFPO)
lb
CONFIDENTIAL
Sodium Carbonate (Na2CO3)
lb
CONFIDENTIAL
MATERIALS ENTERING PROCESS • BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Forms D3 -2 and E-4 .
MEN T J:
3-�t�
DEQ-CFW 00087554
FILENAME: N01VCO1VF\NAF-B1.DBF R-3 SECTION B
EMISSION SOURCE (GENERAL) B1
,,,,REVISED: 04115194
AIR QUALITY SECTION
1SSION SOURCE DESCRIPTION: No. 1 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B
CONTROL DEVICE ID NO(S): NCD-Hdri or NCD-Hdr2
EMISSION POINT ID NO(S): NEP-Hdri or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-2
DESCRIBE PROCESS: Production of PMVE and PEVE along with associated reaction and purification steps.
OPERATION DATE:
SEASONAL VARIATION/%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoropropylene Oxide (HFPO)
lb.
CONFIDENTIAL
Precursor (COF2, PAF)
lb.
CONFIDENTIAL
Sodium carbonate
lb
CONFIDENTIAL
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Forms D3 -2 and E- 4 .
MENTS: `001-2
c - Carboxyl F1llOr1Qe
PAF - Perfluoroacetyl Fluoride
3-N7
DEQ-CFW 00087555
FILENAME: N0NCONF\NAF-B1.DBF R-4 SECTION B
EMISSION SOURCE (GENERAL) B1
REVISED: 04/15194 AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: No. 1 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B
CONTROL DEVICE ID NO(S): NCD-Hdri or NCD-Hdr2
EMISSION POINT ID NO(S): NEp-Hdri or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-3
DESCRIBE PROCESS: Production of PSEPVE along with associated reaction and purification steps.
OPERATION DATE:
SEASONAL VARIATION(%) JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoro Propylene Oxide (HFPO)
lb.
CONFIDENTIAL
Precursor (RSU)
lb.
CONFIDENTIAL
Sodium carbonate and Trisodium phosphate
lb.
CONFIDENTIAL
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.)AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Forms D3 -2 and E- 4 .
MENTS: RSU - Rearranged Sul ton
DEQ-CFW 00087556
4
FILENAME: NONCONF\1VAF-131.DBF R-5 SECTION B
EMISSION SOURCE (GENERAL) B 1
F.VISED: 04/15/94
AIR QUALITY SECTION
"SSION SOURCE DESCRIPTION: No.1 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B
CONTROL DEVICE ID NO(S): NCD-Hdri or NCD-Hdr2
EMISSION POINT ID NO(S): NEP-Hdrl or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-4
DESCRIBE PROCESS: Production of EVE along with associated reaction and. purification steps.
OPERATION DATE:
SEASONAL VARIATION/%l JAN-MAR: 25 APR-JUN: 25 JUL-SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
UNITS
TYPE
Hexafluoro Propylene Oxide (HFPO)
lb.
CONFIDENTIAL
Precursor (MMF)
lb.
CONFIDENTIAL
Sodium carbonate and Trisodium phosphate
lb.
CONFIDENTIAL
ATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
UNITS
TYPE
MAXIMUM DESIGN CAPACITY IBATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Forms D3 -2 and E-4 .
,LAMENTS: MKF - Methyl Malonyl Fluoride
3-�
DEQ-CFW 00087557
•
i c- l Z-VD AM 1 =1
CONRDENTIAL
ERM—Southeast, Inc. NO. 1 VINYL ETHERS PROCESS FIGURE
CHARLOTTE, NORTH CAROLINA DUPONT—FAYETTEVILLE WORKS
ERM DUART, NORTH CAROLINA I NS—B
FILENAME: NAF-D3-l.DBF R-9 SECTION 0
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
0 ('see note in instructions concerning state air toxics regulations)
REVISED: 04115/94 AIR QUALITY SECTION
i
EMISSION SOURCE DESCRIPTION: No.1 Vinyl Ethers Process
EMISSION SOURCE ID NO.: NS-B IS THIS SOURCE A FUGITIVE SOURCE? ( ► YES ( 1 NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO: All
EMISSION RATE IN EMISSION RATE IN
LBSIHR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
1,2
See Comment
4.32
137,800
37,800
Hydrogen Fluoride*
Acetonitrile*
Glycol Ethers*
COMMENTS: Emissions include both fugitive and point source emissions. Potential hourly VOC emissions
vary depending upon which vinyl ether process is being operated and process conditions, and are not
antified. Furthermore, there are no applicable limits associated with hourly VOC emissions from
.nyl ethers. Actual VOC emissions are based on 1994 operations. See the D6 Form and Addendum A for
ore detail on the No. 1 Vinyl Ether Process emissions.
*Note: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements.
3-a\
DEQ-CFW 00087559
FILENAME: NAF-D3-2.DBF R-8 SECTION D D3-2
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04115/94 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: No.1 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B ALTERNATIVE OPERATING SCENARIO (ADS) NO: All
REGULATED APPLICABLE
POLLUTANT EMISSION AND OPERATING LIMITS REQUIREMENT
VOC (total) Emissions from No. I vinyl ethers < 68.9 tpy. Avoid 15A NCAC 2D.0530
COMMENTS: VOC emissions cap istaken to AVOID applicability of NCAC 2D.0530.
3-zz.
DEQ-CFW 00087560
FILENAME: NAF,-D3-3.DBF R-6 SECTION D D3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
'EVISED: 04/15/94 AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: No. i Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-B I i
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBSNEAR) (LBSNEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3- a3
DEQ-CFW 00087561
•
lJ
•
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID:
Emission Unit Description:
Operating Scenarios:
NS-B
No. 1 Vinyl Ethers Process
All (AOS 1 through 4)
A. Emissions Estimation Approach:
Emissions from the vinyl ethers process include point source emissions and fugitive emissions.
All point source emissions are routed to the waste gas scrubber. The only federally regulated
pollutant emitted from the No. 1 Vinyl Ethers process is VOC. Actual VOC emissions in 1994
were 18.9 tons (See Addendum A). Potential emissions are defined by the PSD avoidance limit
of 68.9 tons per year. Actual hourly VOC emissions from the No. 1 Vinyl Ethers process are
estimated as actual annual emissions divided by hours of operation or 18.93 tons * 2,000 / 8760
which equals 4.321bs/hour. Potential hourly emissions are not quantified because they depend
upon several interrelated parameters. HAPs which may be emitted from the No. 1 Vinyl Ethers
process include: Hydrogen fluoride, acetonitrile, and glycol ethers.
B. Regulatory Information:
The only federal permit condition that applies to this emissions unit is a VOC emissions cap
taken to avoid applicability of NCAC 2D.0530 - Prevention of Significant Deterioration (PSD).
The PSD avoidance limit is a 68.9 tons per year of VOCs.
Emissions of North Carolina toxic air pollutants (TAPs) from the entire facility are limited and
TAP emissions from this unit count towards the overall limit (see the "facility -wide D6 Form"
for additional detail on compliance with the TAP limits). The facility -wide TAP limits are state -
only permit requirements.
C. Control Device Information:
Point source emissions from this process unit can be controlled by either of the waste gas
scrubbers. The waste gas scrubbers control acid fluoride emissions. The waste gas scrubbers are
periodically inspected per standard operating procedures to insure proper operation. This process
is also equipped with a water -spray dust suppresser used to knock down particulates when the
reactor is periodically purged with nitrogen. However, uncontrolled potential emission rates are
approximately 0.5 tons, and therefore, this emission point is considered insignificant.
D. Compliance Information:
VOC emissions from this emission unit are tracked by entering process data into spreadsheets
developed to calculate emissions. Emissions will be calculated monthly on a rolling 12-month
basis and will be reported quarterly.
gAprojects\fayett\d6al I
DEQ-CFW 00087562
FILENAME: NAF-E4 . DBF R-1 SECTION E �4
COMPLIANCE PLAN (METHOD OF COMPLIANCE)
r
L
4
REVISED 04115/94
AIR QUALITY SECTION
EMISSION SOURCE ID NO. N3-B
REGULATED POLLUTANT VOC
APPLICABLE REGULATION 15A NCAC 2D. 053 0
ALTERNATIVE OPERATING SCENARIO (ADS) NO:N/A
MONITORING REQUIREMENTS
IS ENHANCED MONITORING APPLICABLE?
( ) YES (X ) NO
IS ENHANCED MONITORING PROTOCOL ATTACHED?
( 1 YES (g ► NO
MONITORING DEVICE TYPE: Flowmeter (3)
MONITORING LOCATION: Inlet to ECD No. NCD-Hdrl or NCD-Hdr2
OTHER MONITORING METHODS (DESCRIBE IN DETAIL):
GENERALLY DESCRIBE THE FREQUENCY AND DURATION OF MONITORING AND HOW THE DATA WILL BE RECORDED (i.e., every 15 minutes,1 minute instantaneous readings taken to produce an
houdyaverage): Vent flows measured and
integrated on a flow totalizer. The totalizer readings
are recorded monthly. Emissions
are determined based on flow rates and engineering
calculations.
TEST METHODS
REFERENCE TEST METHOD DESCRIPTION: N/A
REFERENCE TEST METHOD CITATION:
RECORDKEEPING REQUIREMENTS
DATA (PARAMETER) BEING RECORDED: Vent totalizer readings: reactor, crude tanks, and product tank.
FREQUENCY OF RECOROKEEPING (HOW OFTEN IS DATA RECORDED):
Data is recorded in the No. 1 Vinyl Ethers Process Log on
a monthly basis.
REPORTING REQUIREMENTS
GENERALLY DESCRIBE WHAT IS REPORTED: VOC emissions
from vinyl ethers on a rolling 12-month average
basis.
FREQUENCY: ( 1 MONTHLY
( g ► QUARTERLY ( i ONCE EVERY 6 MONTHS
( I ONCE PER YEAR
( ) OTHER (DESCRIBE):
DEQ-CFW 00087563
FILENAME: NAF-A5.DBF R-2 SECTION A A5
EMISSION SOURCE►CONTROL DEVICE ALTERNATIVE OPERATING SCENARIOS
REVISED: 04115194 AIR QUALITY SECTION
SOURCE ID NO: NS-C
DEVICE ID NO: NCD-Hdri or NCD-Hdr2
PRIMARY OPERATING SCENARIO (DESCRIBE): Primary: Production of PEVE and PMVE
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO. AOS-I : Production of PPVE
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO.
DESCRIBE ALTERNATIVE OPERATING SCENARIO (ADS) NO.
COMMENTS:
DEQ-CFW 00087564
FILENAME: NAF-B1.DBF R-13 SECTION B F
11
I EMISSION SOURCE (GENERAL)
REVISED: 04115194 AIR QUALITY SECTION
SSION SOURCE DESCRIPTION: No. 2 Vinyl Ethers Process EMISSION SOURCE 10 NO: NS-C
CONTROL DEVICE ID NO(S): NCD-Hdri or NCD-Hdr2 EMISSION POINT 10 NO(S): NEp-Hdrl or REP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: primary
DESCRIBE PROCESS: Reaction of HFPO with PAF and COF2 to produce PEVE and PMVE. (Includes associated
reaction and purification steps).
OPERATION DATE: May 1, 1996
SEASONAL YARIATIONIV JAN•MAR: 25 APR•JUN: 2.5 JUL-SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoropropylene oxide
lb
CONFIDENTIAL
Precurser (COF2, PAF)
lb
CONFIDENTIAL
Sodium Carbonate
lb
CONFIDENTIAL
MATERIALSENTERING PROCESS •BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Form D3-2.
MENTS:
zn
DEQ-CFW 00087565
FILENAME: NAF-BI.DBF R-14 SECTION B
EMISSION SOURCE (GENERAL) B1
DEVISED: 04/15194 AIR QUALITY SECTION
MISSION SOURCE DESCRIPTION: No. 2 Vinyl Ethers Process
EMISSION SOURCE 10 NO: NS-C
CONTROL DEVICE ID NO(S): NCD-Hdrl or 1VCD-Hdr2
EMISSION POINT ID NO(S): Npp-Hdri or NEP-Hdr2
INDICATE WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: AOS-1
DESCRIBE PROCESS: production of PPVE along with associated reaction and purification steps.
OPERATION DATE: May 1, 1996
SEASONAL VARIATION(%l JAN•MAR: 25 APR•JUN: 25 JUL•SEP: 25 OCT-DEC: 25
MATERIALS ENTERING PROCESS • CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Hexafluoropropylene oxide
lb
CONFIDENTIAL
Sodium carbonate
1b
CONFIDENTIAL
MATERIALS ENTERING PROCESS • BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS (e.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Form D3 -2 .
u urn.
IYI
DEQ-CFW 00087566
0
f'
6
n
I�
0
0
0
00
i G- - L-y, I- I KhIK/JU
CONFIDENTIAL
InERM—Southeast, Inc. NO. 2 VINYL ETHERS PROCESS
CHARLOTTE, NORTH CAROLINA DUPONT - FAYETTEVILLE WORKS
ERM I DUART, NORTH CAROLINA
FIGURE
NS—C
FILENAME: NAF-D3-I.DBF R-11 SECTION D
D3.1
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
('see note in instructions concerning state air toxics regulations►
SFn- ul15194 AIR OUALITY SECTION
EMISSION SOURCE DESCRIPTION: No. 2 Vinyl Ethers Process
EMISSION SOURCE ID NO.: NS-C IS THIS SOURCE A FUGITIVE SOURCE? ( 1 YES 1 1 NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO: All
EMISSION RATE IN EMISSION RATE IN
LBSIHR LBSIYR
EMISSION FACTOR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
VOC
1,2
See Comment
6.64
68,380
58,000
Hydrogen Fluoride*
Acetonitrile*
Glycol Ethers*
COMMENTS: Emissions include both point source and fugitive emissions. Emissions are estimated based
on the permit application submitted in 1995. Potential hourly emissions vary depending upon process
conditions, and are not quantified. Furthermore, there are no applicable limits associated with
urly emissions from the No. 2 Vinyl Ethers process. See the D6 Form and Addendum A for additional
ail on the emissions calculations.
*Note: Emission of HAPs are not quantified because there are no federally enforceable applicable
requirements.
6-30
DEQ-CFW 00087568
FILENAME: NAF-D3-2.DBF R-11 SECTION D
SPECIFIC EMISSION SOURCE (REGULATORY ANALYSIS)
REVISED: 04/15/94 AIR QUALITY SECTION
ISSION SOURCE DESCRIPTION: No. 2 Vinyl Ethers Process
EMISSION SOURCE ID NO: NS-C
ALTERNATIVE OPERATING SCENARIO (AOS) N0: Al l
REGULATED
POLLUTANT
EMISSION AND OPERATING LIMITS
APPLICABLE
REQUIREMENT
See Comment
COMMENTS: There are no federally enforceable requirements associated with the No. 2 Vinyl Ethers
process.
J-3 I
DEQ-CFW 00087569
FILENAME: NAF-D3-3.DBF R-8 SECTION D D3-3
SPECIFIC EMISSION SOURCE (REDUCTION AND RECYCLING ACTIVITIES)
Ift EVISED: 04/15/94 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: No. 2 vinyl Ethers
EMISSION SOURCE ID NO: NS-C
REGULATED ONGOING SOURCE QTY. EMITTED QTY. EMITTED PLANNED SOURCE
POLLUTANT REDUCTION BEFORE REDUCTION AFTER REDUCTION REDUCTION
ACTIVITIES (LBS/YEAR) (LBS/YEAR) ACTIVITIES
(ENTER CODES) (ENTER CODES)
All
COMMENTS: DuPont maintains ongoing efforts to minimize emissions.
3.32
DEQ-CFW 00087570
SECTION D - FORM D6
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID: NS-C
Emission Unit Description: No. 2 Vinyl Ethers Process (Vinyl Ethers South)
Operating Scenarios: All (Primary and AOS,1)
A. Emissions Estimation Approach:
Emissions from the vinyl ethers process include point source emissions and fugitive emissions.
Potential emissions from this process were defined in the recent permit application (2/95) and
follow-up correspondence letter dated September 7, 1995 (see Addendum A). Potential VOC
emissions from the process have been defined as 34.19 tons per year. For the purpose of this
application, actual emissions are estimated as 85% of potential or 29 tons per year. Potential
hourly emissions are not quantified because they depend upon several interrelated parameters.
HAPs which may be emitted from the No. 2 Vinyl Ethers process include: Hydrogen fluoride,
acetonitrile, and glycol ethers.
B. Reg_ulatoa Information:
There are no federally enforceable regulations that apply to the No. 2 Vinyl Ethers process.
Emissions of North Carolina toxic air pollutants TAPs from the entire facility are limited and
p ( ) tY
TAP emissions from this unit count towards the overall limit (see the D6 Form for facility -wide
requirements for additional detail on compliance with the TAP limits). The facility -wide TAP
limits are state -only permit requirements.
C. Control Device Information:
Point source emissions from this process unit can be controlled by either of the waste gas
scrubbers. The waste gas scrubbers control acid fluoride emissions. The waste gas scrubbers are
periodically inspected per standard operating procedures to insure proper operation.
The process is also equipped with a water -spray dust suppresser used to knock down particulates
when the reactor is periodically purged with nitrogen. However, uncontrolled potential emission
rates are approximately 0.5 tons, and therefore, this emission point is considered insignificant.
Note that the existing facility operating permit identifies the water -spray dust suppresser as a
control device, but because the emissions are insignificant the dust suppresser should be removed
from the permit.
gAprojects\fayett\d6al I
3-33
DEQ-CFW 00087571
•
•
•
SECTION D - FORM D6 (continued)
ENGINEERING ANALYSIS TO SUPPORT PERMIT APPLICATION
Emission Unit ID:
Emission Unit Description:
Operating Scenarios:
D. Compliance Information:
NS-C
No. 2 Vinyl Ethers Process
All (Primary and AOS 1)
As stated above, there are no specific federal requirements applicable to this emissions unit.
However, emissions from the No. 2 Vinyl Ethers process will continue to be tracked and reported
as part of the required annual emissions inventory.
gAprojects\fayett\d6a11
3-3�
DEQ-CFW 00087572
FILENAME: N0NC0NF\NAF-B1.DBF R-10
I • {
REVISED:04115/94
SECTION B
EMISSION SOURCE (GENERAL)
AIR QUALITY SECTION
ION SOURCE DESCRIPTION: RSU Process
"71NDICATE
EMISSION SOURCE ID NO: NS-D
OL DEVICE ID NO(S►: NCD-Hdrl or NCD-Hdrl
EMISSION POINT ID NO(S): NEP-Hdrl or NEP-Hdr2
WHETHER THIS SOURCE IS SUBJECT TO NSPS OR NESHAPS REGULATIONS
ALTERNATIVE OPERATING SCENARIO (ADS) NO: 0
DESCRIBE PROCESS: Production of rearranged sultone (RSU) by reaction of, tetrafluoroethylene (TFE) and
sulfur trioxide (S03). (Includes associated reaction and purification steps)
OPERATION DATE: 1980
SEASONAL VARIATION JAN•MAR: 25 APRJUN: 2.5 JUL•SEP: 25 OCT•DEC: 25
MATERIALS ENTERING PROCESS • CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNITIHR)
REQUESTED CAPACITY
LIMITATION (UNITIHR)
TYPE
UNITS
Sulfur Trioxide (S03)
lb.
CONFIDENTIAL
Tetrafluoroethylene (TFE)
lb.
CONFIDENTIAL
MATERIALS ENTERING PROCESS • BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN CAPACITY (BATCHESIYR):
MAXIMUM DESIGN CAPACITY (BATCHESIHR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTUIHR):
MAX. CAPACITY HOURLY FUEL USE:
MAX. CAPACITY YEARLY FUEL USE:
DESCRIBE ANY MONITORING DEVICES, GAUGES, OR TEST PORTS:
INDICATE ALL REQUESTED STATE AND FEDERALLY ENFORCEABLE PERMIT LIMITS le.g., materials of operation, material input rates, emission rates, etc.) AND DESCRIBE HOW THESE LIMITS ARE
MONITORED AND WITH WHAT FREQUENCY. See Forms 1)3 -2 and E4 .
MEN T S:
3-35
DEQ-CFW 00087573
J
r-
�J
ERM Southeast, Inc. RSU PROCESS
CHARLOTTE, NORTH CAROLINA
DUPONT — FAYETTEVILLE WORKS
DUART, NORTH CAROLINA
FIGURE
NS—D
3- 3u
DEQ-CFW 00087574
FILENAME: NAF-D3-I.DBF R - 1 SECTION D
SPECIFIC EMISSION SOURCE (EMISSION INFORMATION)
D3.1
('see note in instructions concerning state air toxics regulations)
&ISED: 04115194 AIR QUALITY SECTION
EMISSION SOURCE DESCRIPTION: RSU Process
EMISSION SOURCE 10 NO.: NS-D IS THIS SOURCE A FUGITIVE SOURCE? ( 1 YES ( ) NO
ALTERNATIVE OPERATING SCENARIO (ADS) NO:
EMISSION RATE IN EMISSION RATE IN
EMISSION FACTOR LBSIHR LBSIYR
POLLUTANT TYPE POTENTIAL ACTUAL POTENTIAL ACTUAL
voc
1,2
See Comment
2.58
28,440
3,158
S02
1,2
See Comment
0.773
8,164
896
Hydrogen Fluoride*
COMMENTS: Emissions include both point source and fugitive emissions. Potential hourly emissions
vary depending upon process conditions, and are not quantified. Furthermore, there are no applicable
limits associated with hourly emissions from the RSU process. Actual emissions are based on the 1994
production rate and potential emissions are based on mass balance equations. See the D6 Form and
dendum A for additional detail.
*Note: Emission of FIAPs are not quantified because there are no federally enforceable applicable
requirements.
3-31
DEQ-CFW 00087575