DEQ-CFW_00088317

AIR PERMIT REVIEW
APPLICANT SITE LOCATION COUNTY
Dupont Company - Fayetteville Works Fayetteville
CONTACT PHONE APPLICABILITY:
Michael Johnson 910-678-1155
Bladen
TAX I (OTHER
NSPS I I NESHAP
APPLICATION No. REVIEWER SIGNATURE DATE
0900009.98 B Yongcheng Chen 13 January 1999
RECOMMENDATION AND COMMENT FEE CLASS
Issue Permit No. 03735R19 Title V
1. Purpose of Application:
Application was received on December 21, 1998 for the addition of a Flouroproducts
Polymer Manufacturing Development Facility (PMDF). This facility will be used to
develop new fluorochemical products and new processes to produce those products, and will
be called Flouroproducts Process Area in the permit. It is thought that once the
manufacturing process is functional, then a larger scale plant will be build (under a new
permit application); this current semiworks operation would then proceed on with a new
product manufacturing trial
Permit Contact for this Application:
The permit contact for this application :
Mr. Michael Johnson, Environmental Coordinator [phone].
The permit will be issued to Ms. Janet H. Waters, Plant Manager. (note new plant manager)
2. Application Chronology:
12/21/1998 FRO received application with fee of $781 and zoning consistency
information. Mr. Johnson delivered the application at a scheduled meeting
and explained the processes and previous permits.
12/22/1998 Acknowledgment letter sent.
12/28/1998 Called Mr. Johnson clarifying NCAC 2Q.0102(b)(1)(C).
DEQ-CFW 00088317

3. New Equipment/Change in Emission and Regulatory Review
The PMDF will include two air emission control devices:
a venturi scrubber (ID No. FCD-Al) and a fabric filter (ID No. FCD-A2).
The before -control potential emission rate is 0.1 lb/hr of HF for FCD-Al, and 140 lb/yr of
TSP for FCD-A2. The applicant stated in the application form that the corresponding
efficiency for these control devices is 0%.
The applicant believed that pollutant emissions from the PMDF will be insignificant
activities and will be categorically exempt per NCAC 2Q.0102(b)(1)(C)-Laboratory
Equipment. However, it was later concluded by FRO that according to NCAC
2Q.0102(a), if a source is subject to 2D.I 100, then the source is not exempted from permit
requirements, and the exemptions in Paragraph (b) of this Rule do not apply. If the PMDF
emits any toxic air pollutants (it does), then 2Q. 0102(b) will not apply and it can not be
exempted. Note since Dupont had modelled for all pollutants prior, any new process that
increases the emissions of any of the modelled toxic pollutant would require a permit
application be filed prior to installing the process.
The following paragraph will be added to the current permit in the permit items section:
FLUOROPRODUCTS PROCESS AREA
16. one Fluoroproducts Polymer Manufacturing Development Facility (ID No. FS-A)
consisting of
a. a venturi scrubber (ID No. FCD-Al) installed on upstream of the vent blower
venting to the stack (ID No. FEP-Al), and
b. a fabric filter (130 square feet of filter area, ID No. FCD-A2) installed on
downstream of the vent blower venting to the atmosphere (ID No. FEP-A2),
Potential/Uncontrolled Emissions due to this modification; note that since this is a semiworks
facility (working with different chemicals) it is thought that total VOCs can likely be greater than
40 tpy :
Permit
Maximum
Pollutant'
Potential
Uncontrolled
(tpy)
Cry)
Volatile Organic
< 40
1
believe to be >
1
Comnounds
40 tnv
2
DEQ-CFW 00088318

The following paragraph is added to the current permit in the "Special conditions and
limitations" :
"14. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - To comply with this permit and avoid the applicability of 15A
NCAC 2D .0530, "Prevention of Significant Deterioration," as requested by the Permittee,
volatile organic compound emissions from the fluoroproducts process area (ID No. FS-A)
shall be less than 40 tons per consecutive twelve (12) month period.
a. For compliance purposes, within thirty (30) days after each calendar year quarter, the
monthly volatile organic compound (VOC) emissions for the previous fourteen (14)
months shall be reported to the Regional Supervisor, Division of Air Quality. The
emissions must be calculated for each of the three twelve month periods over the
previous fourteen months.
b. The Permittee shall keep each monthly record on file for a minimum of three (3)
years."
Note that no specific Inspection/Monitoring conditions will be established for these control
devices, since the applicant stated that the corresponding efficiency for them is 0%.
Applicable Regulations:
There are no applicable requirements for the PMDF.
Specific Conditions/Permit Limitations - None
Permit or Regulatory Exemptions - None
Professional engineering certification of these control devices is not required.
4. NSPS, NESHAP, PSD, and Attainment Status:
a. New Source Performance Standards (NSPS)
NSPS do not apply to the PMDF..
b. National Emission Standards for HAPs (NESHM
NESHAP do not apply to the PMDF.
DEQ-CFW 00088319

c. PSD and Increment Consumption
Dupont has requested a PSD avoidance condition be put in the permit to limit the
emission increase at the PMDF for PSD applicability to be less than 39.9 tons per
year. This will be placed in the permit with quarterly reporting due.
There are no established increments for VOC emissions.
d. Attainment Status
Bladen County is attainment or unclassifiable for all criteria pollutants.
5. Facility Wide Toxic Air Pollutants
Previously, the company modelled for all concievable pollutants that might be emitted from
this process or future similar processes. Limits were placed in the permit for 95% of the
Ambient Air Limit (AAL) for each TAP. The results from the EPA SCREEN3 modeling
show that the emissions meet the Ambient Air Limit (AAL) for each TAP, and the resulting
permitted TAP limit in the current air permit are still germane. There are no significant
increases in emissions of toxic air pollutants. The facility presently is limited under 2D
.1100
6. Facility Compliance Status
The facility was last inspected on June 18, 1998 and found to be in compliance with all
applicable regulations and reporting requirements.
7. Facility Emissions Review
Facility Emissions Summary After Modifications - Criteria
As reported by Dupont in the Permit Application :
Pollutant
ActuA (cy97
Potential
t''
tpy
PM
40
159
SO2
548
2,299
NOx
124
415
CO
9
32
Volatile Organic Compounds
200
502
Facility wide emissions for HAP'S after this modification will be no change.
n
W
DEQ-CFW 00088320

8. Stipulation Review
As requested by the applicant, the following stipulation will be modified:
M16(a)(ii): "The minimum pH of the recirculated scrubbing solution shall be pH8 with a set
point of pH12" changed to "The minimum pH of the recirculated scrubbing solution shall be
pH8'1
The permit expiration date will remain the same as the current permit, that is until
November 30, 2003.
9. Recommendations
I recommend issuance of permit revision number 03735R19.
Review Engineer: _ Z`f�'2 6
L14— Date: 1 "-1 � - 71
Permit Coordinator: ----q-�— Date:
AQ Supervisor: x Date: 1-13 - i l
cc: DAQ Central Files (yellow copy)
FRO Copy
Title V File
G:\DATA\DAQ\BLADEN\00009\981221.R19 5
DEQ-CFW 00088321