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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 gAprojectsWayettlbutnaf 13_ 1 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. g:\proj ects\fay ett\butn of 3-z, DEQ-CFW 00087540 LE W w CONFIDENTIAL I;RM—Southeast, Inc. NAFION 'NPROCESS FIGURE CHARLOTTE, NORTH CAROUNA DU PONT — FAYETTEVILLE WORKS 3-1 ERM I DUART, NORTH CAROLINA E • CONFIDENT�AL II I I Pri ia� ■ ERM—Southeast, Inc. FLUOROCARBON PROCESSES CHARLOTTE. NORTH CAROLINA DUPONT FAYETTEVILLE - WORKS 3-2 ERM I DUART, NORTH CAROLINA 3-4 DEQ-CFW 00087542 0 r' 6 n I 0 0 0 w 14 cn w 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. gAprojects\fayett\butnaf 0 0 0 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. g Ap ro j ects\fay ett\butn of C.� 0 rn p C� m I 0 0 0 co v cn P, cn 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. gApro j ects\fayett\butnof 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