Inspection by Christy Richardson on August 9, 2006

 

 

1)    DIRECTIONS TO SITE:  Dupont Company - Fayetteville Works (09/00009) is located on NC Highway 87 in Bladen County, North Carolina.  From Fayetteville, take Highway 87 south.  The entrance to the facility is approximately 18 miles from FRO on the left side of Highway 87 just before the Cumberland/Bladen County line.

 

 

2)       FACILITY DESCRIPTION:  Dupont Company - Fayetteville Works is a chemical manufacturing facility located in Bladen County.  The Plant currently consists of five individual manufacturing processes.  Each process will be explained in greater detail later in this report.  The facility is subject to NESHAP Subpart KK, Printing and Publishing Industry, as well as the upcoming Subpart FFFF, Miscellaneous Organic NESHAP.  Several processes also have PSD avoidance conditions.  The facility has two permanent boilers as well as one temporary boiler, which is transient and comes on and off site as needed.   

 

 

3)       PRE-INSPECTION SUMMARY:  On 9 August 2006, Markus Elliott and I, Christy Richardson, met with Mr. Mike Johnson, Environmental Manager.  During the pre-inspection conference, Mr. Johnson explained all recent changes to the facility as well as upcoming projects.  Mr. Johnson confirmed that there have been no changes in emissions since the previous inspection / permit modification and that the emissions sources listed on the permit had not changed.  Mr. Johnson, along with Technical Engineers from each manufacturing facility, led us on an extended tour of each individual plant, concentrating specifically on APFO manufacturing, wastewater treatment facilities, and Nafion® manufacturing changes.  Mr. Johnson described in detail the changes associated with phase one expansion of Nafion® and the changes associated in phase two.  A permit application has been received by FRO and RCO concerning the phase one changes and PSD avoidance conditions.  Mr. Johnson explained that phase two changes would cause a PSD review.  Mr. Johnson and APFO Technical Engineers also explained in detail the results of PFOA (C8) stack testing as well as planned changes / upgrades to the APFO manufacturing facility.  During the inspection, Markus Elliott and I observed two small paint booths and sand blasters.  The units were very small and were used only for maintenance activities.  Mr. Johnson is planning to add these sources to his next permit modification to be included as insignificant activities on their air permit.       

   

4)       PERMITTED EMISSION SOURCES:  At the time of the inspection, DuPont Company – Fayetteville Works was operating under Permit No. 03735T29 which includes the following emission sources:

 

Emission Source

ID No.

Emission  Source Description

Control Device

ID No.

Control Device Description

PS-1

No.2/No. 6 fuel oil-fired boiler (139.4 million Btu per hour maximum heat input)

N/A

N/A

PS-2

No. 2/No. 6 fuel oil-fired boiler (88.4 million Btu per hour maximum heat input)

N/A

N/A

PS-Temp*

No. 2 fuel oil-fired boiler (greater than 30.0 and less than 100.0 million Btu per hour maximum heat input)

N/A

N/A

BS-A

Butyraldehyde storage tank

BCD-A

Brine-cooled condenser

BS-B1

Butacite® flake reactors (4 units)

BCD-B1

Packed-bed column scrubber with mist eliminator (8 gallons per minute water injection rate averaged over a 3-hour period)

BS-B2

Butacite® flake reactors (4 units)

 

BCD-B2

Packed-bed column scrubber with mist eliminator (8 gallons per minute water injection rate averaged over a 3-hour period)

BS-C

Butacite® flake dryer

BCD-C1

BCD-C2

Cyclone separator

Fabric filter (6,858 square feet of filter area)

BS-D

 

 

Polyvinyl butyral sheeting rotogravure printing operation

 

BCD-D1

Multi-stage horizontal spray scrubber (6 gallons per minute of water flow to each nozzle, averaged over a 3-hour period)

NS-A

 

Hexfluoropropylene epoxide process (HFPO)

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-B

Vinyl Ethers North process

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-C

Vinyl Ethers South process

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-D

RSU Process

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-E

Liquid waste stabilization

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-F

MMF process

NCD-Hdr1

 

 

NCD-Hdr2

 

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

NS-G

Resins process

NCD-G

Venturi vacuum jet caustic scrubber (minimum vacuum of -80 kPa gauge)

NS-H

Nafion® membrane process

N/A

N/A

NS-I

Nafion® membrane coating

N/A

N/A

NS-J

Nafion® semiworks

N/A

N/A

NS-K

E-2 Process

N/A

N/A

NS-L

TFE/HCl separation unit

NCD-Hdr1

 

 

NCD-Hdr2

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

Baffle-plate scrubber (7,000 kilogram/hour liquid injection rate averaged over a 3-hour period)

SW-1

Polymerization operation

N/A

N/A

SW-2

Laboratory hood

N/A

N/A

FS-A

Fluoroproducts polymer manufacturing development facility

FCD-A1

FCD-A2

Wet scrubber (3 gallons per minute water injection rate averaged over a 3-hour period)

Fabric filter (125 square feet of filter area)

AS-A

APFO manufacturing facility

ACD-A1

ACD-A2

Wet scrubber (30 gallons per minute water injection rate averaged over a 3-hour period)

Condenser

WTS-A

WTS-B

WTS-C

 

Wastewater treatment area consisting of an extended aeration biological wastewater treatment facility and  two indirect steam-heated rotary sludge dryers

WTCD-1

Impingement-type wet scrubber with mist eliminator (29 gallons per minute dilute potassium hydroxide injection rate)

SGS-A**

SentryGlas® Plus Manufacturing

N/A

N/A

FS-B***

Polyvinyl Fluoride polymer manufacturing facility

N/A

N/A

 

 

 

 

5)    APPLICABLE AIR QUALITY REGULATIONS:  Regulations will be discussed for each various manufacturing process as listed on the current air permit.

 

* Powerhouse (PS-1 and PS-2)*

The facility is permitted to operate one No. 2/No. 6 fuel oil-fired boiler (139.4 mmBtu/hr maximum heat input) and one No. 2/No. 6 fuel oil-fired boiler (88.4 mmBtu/hr maximum heat input).  These two boilers share the same stack.  The larger boiler has a steam capacity of 113,000 pounds of steam per hour and was manufactured in 1969.  The smaller boiler was manufactured in 1982 with a steam capacity of 72,000 pounds per hour.  They are both pre-NSPS boilers; however, Boiler PS-2 does have a PSD avoidance condition for PM, PM-10, NOx, and SO2.  The software used at the boiler house allows the operator to track criteria pollutant emissions for the PSD avoidance requirement for the smaller boiler.  Note that the smaller boiler is operated infrequently.  At the time of the inspection only the larger boiler was operating (firing No. 6 fuel oil). 

 

15A NCAC 2D .0503  PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS –Particulate emissions from each of the boilers shall not exceed 0.2667 lbs/mmBTU.  Semi-annual reporting of fuel usage is required for the steam generation unit.  No monitoring, recordkeeping, or reporting required  

IN COMPLIANCE – The AP-42 emissions factor for No. 2 fuel oil is 0.024 lbs/mmBTU and 0.16 lbs/mmBTU for No. 6 fuel oil.   Emissions testing, monitoring, recordkeeping, and reporting are not required for particulate emissions from the combustion of No. 2 and No. 6 fuel oil in these boilers.

 

15A NCAC 2D .0516  SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES – The sulfur dioxide emissions from each boiler shall not exceed 2.3 pounds per million BTU heat input.  The sulfur content of No. 6 fuel oil shall not exceed 2.1% sulfur by weight.  The Permittee shall maintain fuel certs for all No. 6 fuel oil shipments.  The facility must report semi-annually a summary report of fuel certifications.

IN COMPLIANCE – The AP-42 emissions factor for No. 2 fuel oil is 0.507 lbs/mmBTU and 2.20 lbs/mmBTU for No. 6 fuel oil.  As long as the No. 6 fuel does not exceed the fuel sulfur limit, the regulatory limit will not be exceeded during normal operation.  Fuel certs were reviewed during the inspection and total fuel usage as well as average sulfur content are given to Mike Johnson after each month.  Sulfur content was approximately 2.03% by weight on the last five to ten loads.   The most recent semi-annual report was submitted 31 July 2006.

 

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS – Visible emissions from Boiler PS-1shall not exceed 40% opacity.  Visible emissions from PS-2 and PS-Temp shall not exceed 20% opacity.  The permittee shall record a daily visible emissions evaluation (normal or above normal) and maintain a logbook showing the results of each evaluation.  These results from monitoring must be submitted to DAQ in a semi-annual report.           

IN COMPLIANCE – Both Boiler PS-1 and PS-2 vent through the same stack; however, only Boiler PS-1 was operating during the inspection.  The opacity from PS-1 appeared to be approximately 10% on the day of the inspection; however it was difficult to obtain a reading since the skies were overcast.  The logbook appeared to be completed and up to date.  The records showed all “normal” observations.  The facility has four certified smoke readers and at least one is present during each shift.  The reader stated that if an above normal reading was ever observed, he would immediately conduct a Method 9.  The most recent semi-annual report was submitted 31 July 2006.      

 

15A NCAC 2Q .0317  PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS – Emissions from Boiler PS-2 shall not exceed the following:  25 TPY PM, 15 TPY PM-10, 40 TPY NOx, and 40 TPY SO2.  The permittee shall keep monthly records of fuel usage, fuel sulfur content, and maintain fuel certifications.  Quarterly reporting is also required for monthly emissions (14 month period), fuel usage, and sulfur content.  The Permittee must also define all deviations in the report.

IN COMPLIANCE – All reports show that the facility is not close to exceeding these emissions limits.   The sulfur limit reached a high of 21TPY in second quarter 2005.  The most recent quarterly report was received on 31 July 2006.  Boiler PS-1 is used the majority of the time with Boiler PS-2 used only when there is a demand.  Fuel certifications were reviewed during the inspection.  The facility maintains an electronic record of the running total of PSD emissions from boiler PS-2.     

 

 

 

 

* Butacite® Process Area (all sources labeled with BS- and BCD-)*

The Butacite® manufacturing operation includes a polyvinyl butyral sheeting and rotogravure printing operation.  The operation produces flexible glass laminate for car windshields.  The printing (tenting) operation is subject to MACT Subpart KK, Printing and Publishing, requirements and controlled by a permanent total enclosure (testing conducted per EPA Method 24) for the printing operation room exhaust and a multi-stage horizontal spray scrubber (testing conducted per EPA Method 18) to control emissions of dimethylformamide (DMF).  The butacite process area includes the butyraldehyde storage tank, with emissions and potential odors from the butyraldehyde controlled by a brine-cooled (ethylene glycol) condenser.  The process also includes the Butacite flake reactors, controlled by packed-bed column scrubbers, and a butacite flake dryer, controlled by a cyclone separator and fabric filter.

 

15A NCAC 2D .0515  PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES –Particulate matter emissions from the Butacite process shall not exceed E=4.10*P0.67.  The permittee shall maintain production records.  The Permittee shall perform a monthly visual and annual internal inspection on baghouses BCD-C1 and BCD-C2.  A logbook detailing these inspections must also be kept up to date.  The facility must report semi-annually a summary report of monitoring and recordkeeping activities. 

IN COMPLIANCE – The flaking process is controlled by bagfilters to reduce particulate matter emissions.  Visual inspections on these bagfilters are performed on a bi-monthly basis and annual inspections are performed once a year.  The most recent semi-annual report was received on 31 July 2006. 

 

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS – Visible emissions from the flake dryer BS-C shall not exceed 20% opacity.  The permittee shall record a monthly visible emissions evaluation (normal or above normal) and maintain a logbook showing the results of each evaluation.  These results from monitoring must be submitted to DAQ in a semi-annual report.           

IN COMPLIANCE – The visible emissions from BS-C appeared to be approximately 0% opacity on the day of the inspection.   The most recent semi-annual report was submitted 31 July 2006.  VE evaluations are performed daily despite the monthly requirement and all readings in the logbook were normal.

 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The Butacite process shall not operate without odor control equipment.  An objectionable odor shall not be detected from these sources.  Liquid flow rate for BCD-B1 and BCD-B2 shall be atleast 8 gallons per minute and the differential pressure shall be less than 30 inches of water over a three-hour period.  

IN COMPLIANCE – Odorous emissions from the butyraldehyde storage tank BS-A are controlled by a condenser BCD-A.  Odorous emissions from the flake reactor lines BS-B1 and BS-B2 are controlled by packed-bed scrubbers BCD-B1 and BCD-B2.  The liquid flow rate was 10 gal/min on the day of the inspection and the DP was approximately 0 inches of water.  Alarms automatically sound if the limits are exceeded.  The Butacite process did have a stringent odor indoors; however, only a slight odor was detected outside the building.   

 

40 CFR Part 60 Subpart KK:  NATIONAL EMISSIONS STANDARDS FOR PRINTING AND PUBLISHING INDUSTRY – The printing operation BS-D must have scrubber control with an overall organic HAP control efficiency of atleast 95 percent.  The water flow rate in the scrubber must be greater than 6 gallons per minute.  The airflow rate must be greater than 63 standard cubic feet per minute and the fan exit velocity must be greater than 3,950 feet per minute over a three-hour period.  If startup, shutdown, maintenance procedures differ from the SSMP, DAQ must be notified.  A summary report is required in the semi-annual report.    

IN COMPLIANCE – The tenting operation takes place in a permanent total enclosure, which is controlled by a three-stage horizontal scrubber BCD-D1 with a control efficiency of greater than 97%.  The scrubber utilizes de-mineralized water to remove organic HAPs.  The system is interlocked so that if any one of the scrubber parameters exceeds the regulated limit, the entire process will shut down.  Set points for water flow, airflow, and exhaust velocity are set well above the permit limit. Set points for each parameter are as follows:  6.5 gal/min for water flow rate, 68 scfm for air flow rate, and 4200 ft/min for fan exit velocity.   The most recent semi-annual report was received on 31 July 2006.  

 

 

 

 

 

* Nafion® Process Area (all sources labeled with NS- and NCD-)*

The Nafion operation produces a variety of relatively uncommon monomer and polymer chemicals.  Some of the monomers are shipped offsite, while others are used onsite in the production of various polymers.  The polymers are shipped offsite or used onsite to produce Nafion® membrane material.  A principal use of the membrane is in the extraction / production of chlorine and sodium hydroxide at chlor-alkali plants.  The two waste gas scrubbers located at Nafion are used to control the emissions of various pollutants including hydrogen fluoride and acid fluorides.  The Nafion process will be subject to the Miscellaneous Organic NESHAP.

 

The facility recently submitted a permit application for modification to the Nafion® process.  The ‘scrubber’ that DuPont has requested to replace is not a control device, the unit is a process separator which separates raw materials from process materials and is not vented.  Currently, this separator is a bottleneck for the Nafion ® process.  Replacing the separator with a new larger unit will allow the facility to increase production as well as criteria pollutant emissions.  The facility has requested a PSD avoidance limit for VOCs due to this equipment modification.  Mike Johnson explained that this was only phase one of a project that would occur over the next couple of years.  The second phase will consist of even more expansion and additional increase in production.  A PSD Review will be performed during phase two of this project, which is proposed to occur in late 2007. 

 

15A NCAC 2D .0515  PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES –Particulate matter emissions from the Nafion process shall not exceed E=4.10*P0.67.  The permittee shall maintain production records.  The facility must report semi-annually a summary report of monitoring and recordkeeping activities.  

IN COMPLIANCE – The most recent semi-annual report was received on 31 July 2006. 

 

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS – Visible emissions from the membrane coating process NS-I shall not exceed 20% opacity.  No monitoring, recordkeeping, or reporting required.           

IN COMPLIANCE – The visible emissions from NS-I appeared to be approximately 0% opacity on the day of the inspection.  

 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The Nafion process shall not operate without odor control equipment. 

IN COMPLIANCE – Odorous emissions from the Nafion process are controlled by two baffle-plate scrubbers NCD-Hdr1 and NCD-Hdr2.  The control devices also have monitoring parameters that are continually recorded and interlocked into the system.  All the facility’s monitoring parameters are recorded and viewable in an Aspen program.  A slight odor was detected close to the liquid waste stabilization tank; however, no noticeable odor was detected away from the facility. 

 

15A NCAC 2Q .0317  PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS – Emissions from the Vinyl Ethers North process NS-B shall not exceed the following:  68.9 TPY VOC.  The baffle-plate tower scrubbers must maintain a liquid flow rate of at least 7,000 kilograms per hour.  The permittee shall keep monthly records of VOC emissions.  Quarterly reporting is also required for monthly emissions (14 month period). 

IN COMPLIANCE – The liquid flow rate set point is still set to exceed the 16,500 kg/hr previous permit limit.  The scrubber utilizes a potassium hydroxide solution in the scrubber and is interlocked to shut the system down at 7,000 kg/hr and to alarm at 16,500 kg/hr.   All reports show that the facility is not close to exceeding these emissions limits.  VOC emissions are calculated using stack test results, material balances, and flow rates / concentrations on a monthly basis.  These records are submitted to Mike Johnson within 30 days of the following month.  The most recent quarterly report was received on 31July 2006. 

 

15A NCAC 2Q .0317  PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS – Emissions from the resin process NS-G shall not exceed the following:  40 TPY VOC.  The permittee shall keep monthly records of VOC emissions.  Quarterly reporting is also required for monthly emissions (14 month period). 

IN COMPLIANCE – All reports show that the facility is not close to exceeding these emissions limits.   The most recent quarterly report was received on 31July 2006. 

 

 

 

40 CFR Part 60 Subpart FFFF:  MISCELLANEOUS ORGANIC NESHAP (MON) – The Nafion process must comply with all provisions of this MACT.  The MON requires 99% control efficiency.  The compliance date was 10 November 2006, but has been extended by EPA to May 10, 2008.        

IN COMPLIANCE – The scrubbers currently controlling the Nafion process (NCD-Hdr1 and Hdr2) meet the control efficiency requirement.  The scrubbers were tested at 99.6% efficiency in August 2003.  Initial notification was received on 2 March 2004. 

 

 

 

* Fluoroproducts Polymer Manufacturing Development Facility (PMDF/Teflon)  (all sources labeled with FS- and FCD-)*

The Fluoroproducts PMDF operation is a continuous process designed to produce fluoropolymer resins.  The process includes a wet scrubber and a fabric filter (125 ft2 filter area).  The final product is an extruded plastic pellet used to make Teflon products.  The emissions from the process include acid fluorides and hydrogen fluoride.

 

15A NCAC 2D .0515  PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES –Particulate matter emissions from the PMDF shall not exceed E=4.10*P0.67.  The permittee shall maintain production records.  The Permittee shall perform a monthly visual and annual internal inspection on baghouse FCD-A2.  A logbook detailing these inspections must also be kept up to date.  The facility must report semi-annually a summary report of monitoring and recordkeeping activities. 

IN COMPLIANCE – The PMDF is controlled by bagfilters to reduce particulate matter emissions.  Visual inspections on these bagfilters are performed on a monthly basis and annual inspections are performed once a year.  Possible particulate matter emissions come from the pellets impacting the steel tubing during the production process.  The bagfilter captures approximately 2-3 55 gallon drums per year.  The most recent semi-annual report was received on 31 July 2006. 

 

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS – Visible emissions from the PMDF shall not exceed 20% opacity.  No monitoring, recordkeeping, or reporting required.           

IN COMPLIANCE – The visible emissions from FS-A appeared to be approximately 0% opacity on the day of the inspection.  

 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The PMDF shall not operate without implementing a management plan or without odor control equipment. 

IN COMPLIANCE – No odor was detected surrounding this facility.  The scrubber is only used during purge for maintenance activities and is used to control acid fluorides.   

 

15A NCAC 2Q .0317  PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS – Emissions from the PMDF shall not exceed the following:  40 TPY VOC.  The permittee shall keep monthly records of VOC emissions.  Quarterly reporting is also required for monthly emissions (14 month period). 

IN COMPLIANCE – All reports show that the facility is not close to exceeding these emissions limits.   The most recent quarterly report was received on 31 July 2006. 

 

 

 

* Ammonium Perfluorooctanate (APFO) Manufacturing Facility (all sources labeled with AS- and ACD-)*

The ammonium perfluorooctanoate (APFO) process began operation in December of 2002.  The APFO reaction process uses perfluorooctanoate (brought in by truck in its iodide/salt form) reacted with sodium hydroxide (stored in totes) to form the acid fluoride.  The acid fluoride is then reacted with ammonia to produce the ammonium salt.  Fuming sulfuric acid (oleum) is received by truck and used as a solvent in the process.  Currently, APFO and the associated perfluorooctanoic acid (PFOA), also known as C8, are not regulated as toxic or hazardous air pollutants.  However, the EPA is currently reviewing the chemical with the possibility of its designation in the future as a regulated pollutant.  However, due to historical pollution and health effects concerns and recent controversy regarding the Dupont facility in West Virginia, and the recent activities by the U.S. EPA to develop and review toxicity data for this chemical, the DAQ file includes several documents and articles related to APFO, PFOA, or C8.  The condenser is no longer being utilized and will be removed from the permit during the next permit revision.  The APFO process is subject to the 112(r) chemical accident prevention program for oleum. 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The APFO facility shall not operate without implementing a management plan or without odor control equipment. 

IN COMPLIANCE – No odor was detected surrounding the APFO facility. The APFO process is controlled by a scrubber and associated demister. 

 

15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS – Emissions from the APFO facility shall be controlled by a wet scrubber.  The liquid flow rate in the packed bed section shall be at least 30 gallons per minute and the differential pressure across the bed shall be a maximum of 12 inches of water.  An alarm is required for the pressure monitoring.  All inspections shall be kept in a logbook. 

IN COMPLIANCE – The scrubber is interlocked so that the system will shut down, almost instantaneously, if the parameters are exceeded.  The liquid flow rate set point is set to approximately 40 gallons per minute.  The differential pressure was approximately 0 in H2O on the day of the inspection.  APFO is a surfactant; therefore, the DP increases occasionally due to ‘suds’ in the scrubber.  

 

In March 2006, the facility conducted a stack test on the APFO facility while running the purification campaign.  In April 2006, the facility conducted a stack test on the APFO facility while running the virgin campaign.  DuPont submitted a stack test protocol and test method for these two stack tests.  The results from these tests did not concur with samples taken from the building exhaust and the scrubber exhaust.  DuPont – Fayetteville conducted another virgin campaign stack test in June 2006 without notifying DAQ of the retest.  The April and June stack test results did agree so the facility provided results from the stack tests on the day of the inspection.  Stack test results show that approximately 62 lbs of PFOA are emitted from this facility per year.  To further reduce these emissions, the facility is going to add a HEPA filter to control PFOA (a particulate) from the building exhaust.  The building exhaust appears to be the area where most (80-90%) of the facility emissions are coming from.  A permit application should be sent to our office within the next few weeks requesting the addition of this filter and the removal of the condenser. 

 

During late 2006, the facility had an air release when the fiberglass filter in the demister formed a hole.  A technician noted flakes falling from the stack and manually shut the system down.  The scrubber and APFO manufacturing facility are interlocked and the system should automatically shut down when the scrubber malfunctions.  When asked why the system did not automatically shut down during the late 2006 incident, the Process Engineers explained that the permitted scrubber parameters were never exceeded.  The scrubber was operating properly; however, the demister had a hole and foam was released from the stack.  To ensure that this problem does not occur again, the facility is using only water as solution in the demister and the atomizer has been replaced to prevent localized wear on the fiberglass filter.  The facility is also adding additional interlocked parameters such as a foam detection switches and adding a plastic sleeve so that technicians can see what is occurring in the demister exhaust stream.     

 

 

 

* Wastewater Treatment Area  (all sources labeled with WTS- and WTCD-)*

For the wastewater treatment operations, the Title V permit specifies two rotary sludge dryers controlled by a impingement-type wet scrubber with mist eliminator (29 gallons per minute dilute potassium hydroxide solution).  The Miscellaneous Organic NESHAP (MON) will also address emissions from wastewater.  With respect to quantity of emissions, methanol is the most significant air pollutant from the wastewater treatment operation.

 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The wastewater treatment facility shall not operate without management plan or odor control equipment.  An objectionable odor shall not be detected from these sources.  The sludge dryers shall be controlled by a caustic injection scrubber.  An I&M logbook is also required for the scrubber.    

IN COMPLIANCE – Odorous emissions from the sludge dryers are controlled by a scrubber utilizing potassium hydroxide solution.  Wastewater treatment odors were noted surrounding the wastewater treatment facility but were not present at boundary lines.  The sludge dryers are located inside a building.  On the day of the inspection, the door was open.  The wastewater operator stated that the door was open so that the dumpster could be emptied.  I explained that the doors were to remain closed; otherwise the scrubber was not doing its designed job.  The scrubber was last inspected on September 1, 2005 during the annual facility shutdown period.       

 

* Temporary Boiler  (PS-Temp)*

Note that the temporary boiler listed on the permit equipment list is not currently at the site.  This boiler is permitted for No. 2 fuel oil and is brought on-site on an ‘as needed’ basis and was removed from the facility on July 12, 2006. 

 

15A NCAC 2D .0503  PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS –Particulate emissions from the temporary boiler shall not exceed E=1.090*Q-0.2594 lbs/mmBTU.  Semi-annual reporting of fuel usage is required for the steam generation unit.  No monitoring, recordkeeping, or reporting required.  

IN COMPLIANCE – The AP-42 emissions factor for No. 2 fuel oil is 0.024 lbs/mmBTU.   Emissions testing, monitoring, recordkeeping, and reporting are not required for particulate emissions from the combustion of No. 2 fuel oil in these boilers.

 

15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS (Subpart Dc) – The sulfur content of all received fuel oil shall not exceed 0.5% sulfur by weight.  The Permittee shall maintain fuel certifications and monthly amounts of fuel burned.  A summary report of these fuel certs must be submitted in a semi-annual report. 

IN COMPLIANCE – Fuel certs indicate fuel oil is less than 0.5% sulfur by weight.  The most recent semi-annual report was received on 31 July 2006. 

 

15A NCAC 2Q .0317  PREVENTION OF SIGNIFICANT DETERIORATION AVOIDANCE CONDITIONS – Emissions from the temporary boiler PS-Temp shall not exceed the following:  40 TPY SO2.  The permittee shall keep monthly records of the amount of fuel combusted.  Quarterly reporting is also required for monthly combustion and all deviations (14 month period). 

IN COMPLIANCE – All reports show that the facility is not close to exceeding these emissions limits.  The highest yearly average is approximately 4.1 TPY SO2 during second quarter 2005.  The most recent quarterly report was received on 31 July 2006. 

 

 

 

* SentryGlas® Plus Manufacturing Facility  (SGS-A)*

The SentyGlas plant began operation in 2005 and manufactures rigid plastic glass laminate.  This product is similar to the Butacite product; however, this material is much stronger, even explosion proof.  The facility has a crushing system used to crush the pelletized raw material.  Crushed material is sent to a silo, which is controlled by a baghouse that vents indoors.  The entire process takes place in a clean room to avoid contamination by lint, dirt, etc.

 

15A NCAC 2D .0521 CONTROL OF VISIBLE EMISSIONS – Visible emissions from the SentryGlas manufacturing facility shall not exceed 20% opacity.  No monitoring, recordkeeping, or reporting required.           

IN COMPLIANCE – The visible emissions from SGS-A appeared to be approximately 0% opacity on the day of the inspection.  

 

15A NCAC 2D .1806  CONTROL AND PROHIBITION OF ODOROUS EMISSIONS – The SentryGlas manufacturing facility shall not operate without implementing a management plan or without odor control equipment. 

IN COMPLIANCE – No odor was detected surrounding this facility.     

 

 

 

* Polyvinyl Fluoride (PVF) Polymer Manufacturing Facility  (FS-B)*

This facility was added to the permit on June 23, 2006.  The facility has begun ground work for this site but does not plan to begin operation until fall 2007.

 

 

 

 

 

 

 

* Facility-Wide Toxics Limits*

 

15A NCAC 2D .1100 CONTROL OF TOXIC AIR POLLUTANTS – The permittee shall maintain records of production rates, throughputs, material usage, excess emissions, and control equipment failures.  The Permittee shall also report in a quarterly report, all TPER exceedances, the maximum 1-hour emission rate, the maximum 24-hour emissions rate, and the maximum 12-month emissions rate.  The liquid flow rate in the Nafion scrubbers shall be at minimum 7,000 kg/hr.  The Permittee shall maintain a logbook of all inspection and maintenance activities on the applicable scrubber.

IN COMPLIANCE – The liquid flow rate set point is still set to exceed the 16,500 kg/hr previous limit.  The scrubber utilizes a potassium hydroxide solution in the scrubber and is interlocked to shut the system down at 7,000 kg/hr.   The most recent quarterly report received on 31 July 2006 did not show any exceedances of toxic air pollutant limits.

 

 

6)    CHEMICAL ACCIDENT PREVENTION AND 112(r):  The Nafion process is subject to 112(r) for sulfur trioxide, tetrafluoroethylene, and hydrogen chloride.  The APFO process is subject to 112(r) for oleum.  The facility submitted the initial Risk Management Plan to the U.S. EPA in June 1999.  In addition, the facility is subject to the OSHA Process Safety Management Standard.

 

 

7)    COMPLIANCE HISTORY:  There appears to have been no compliance issues over the last five-year period. 

 

 

8)    CONCLUSIONS AND RECOMMENDATIONS:  Based on the observations made during the 9 August 2006 inspection, DuPont Company – Fayetteville Works appeared to be operating in compliance with the requirements outlined in their current air permit, 03735T29.