Permit Review for Dupont Teijin R03

Permit Review for Dupont Teijin R03 - July 6, 2005

1. Purpose of Application:

The application is for permit renewal with no modifications. Dupont Teijin Films, Cedar Creek Site, is a batch chemical manufacturing facility that uses dimethyl terephthalate and ethylene glycol to manufacture polyethylene terephthalate (PET) chips for film products.

2. Application Chronology:

12/06/04 DAQ sent EI/renewal reminder letter.

03/02/05 DAQ received EI and renewal request.

06/03/05 Tom McKinney conducted an inspection.

06/06/05 Facility provided updated information on storage tanks and ID numbers.

07/05/05 EI review completed and entry in ED with updated ID numbers.

3. Changes in Equipment and Emissions:

The facility recently repaired the 2^nd DMT storage tank used as a backup. The dimethyl terephthalate (DMT) is a raw material that is received as a molten liquid in tank trucks. The DMT tends to degrade to produce methanol emissions. Therefore, a gravity spray scrubber (with ethylene glycol as the scrubbing liquid) followed by a demister is used to control emissions of DMT and methanol from the DMT storage. The remaining emissions after the scrubber are then routed to the batch plant’s thermal oxidizer. The permit renewal will revise the equipment list to show that the second DMT tank is operational (each tank can hold 300,000 gallons). The second tank appeared in the permit in the 1990s. However, it has been out of service for several years due to a leakage problem, related to the heating coils, and was removed from R02. The revised permit lists two DMT storage tanks each with 300,000 gallons capacity.

4. NSPS, PSD, NESHAPs, and Chemical Accident Prevention (112r):

The natural gas/No. 2 fuel oil-fired heater (39.3 million Btu per hour) will continue to be subject to NSPS Subpart Dc. The revised permit will retain the NSPS Subpart Dc language and the fuel oil restriction of 0.5 percent sulfur by weight. In adition, the revised permit will retain the PSD avoidance limit of 100 tpy for sulfur dioxide emissions from the combustion units, with recordkeeping and reporting requirements. The avoidance limit is 100 tpy (rather than 250 tpy) since this is a SOCMI facility.

The revised permit will retain the MACT avoidance condition for Subpart JJJ (Group IV Polymers and Resins). The permit indicates that compliance with the synthetic minor condition will satisfy the requirements for MACT avoidance.

The facility does not use any chemical listed under the 112(r) chemical accident prevention program in excess of its threshold quantity. Note that 1,3-butadiene and acetaldehyde are 112(r) chemicals. However, they are emitted as chemical by-products of the process, and are not stored as raw materials or products. As a result, the 10,000 pounds threshold level for these two chemicals is not exceeded. Therefore, the facility is not subject to the 112(r) program. In addition, they are not subject to OSHA’s Process Safety Management Standard.

5. Toxics Review:

The revised permit will retain the 2D .1100 limits for acetaldehyde and 1,3-butadiene, and the 2Q .0711 TPER value for 1,4-dioxane.

6. Facility Emissions Review:

The actual emissions reflect information from the inventory submittal. The potential emissions reflect data from earlier permit reviews. Note that the sulfur dioxide emissions are limited by both a PSD avoidance condition and a synthetic minor condition. The HAP emissions are limited by the synthetic minor and MACT avoidance conditions and are based on use of the thermal oxidizer.

TABLE 1: Facility-Wide Emissions:

Pollutant

Actuals

2004

(tpy)

Potential Emissions

with Limits/Controls

(tpy)

Potential Emissions

without Limits/Controls

(tpy)

1.6

9.3

PM10

1.6

2.8

5.4*

SO2

0.09

(synthetic minor)

200**

VOCs

NOx

9.4

56.2**

18.2***

Methanol

(HAP)

9.9

(synthetic minor)

Acetaldehyde

(HAP, TAP)

0.43

1.6

7.9****

other HAPs

(mostly biphenyl, toluene, and ethylene glycol)

2.5

TOTAL HAPs

24.9

(synthetic minor)

* Total reflects 2.8 tpy for the Dowtherm heaters and 2.6 tpy for the solid state process units.

** Based on firing No. 2 fuel oil.

*** Based on firing natural gas.

**** The 7.9 tpy reflects data from an earlier application submittal.

7. Stipulation Review:

The following regulations are applicable to this facility:

Regulation	Affected Sources	Requirements
15A NCAC 2D .0503	Dowtherm heaters	Limits PM emissions
15A NCAC 2D .0516	Dowtherm heaters	Limits SO2 from combustion
15A NCAC 2D .0521	Facility-wide	Limits opacity
15A NCAC 2D .0524	Dowtherm heater DWT-1	NSPS Subpart Dc
15A NCAC 2D .0530	Facility-wide	PSD avoidance limit of 100 tpy for SO2
15A NCAC 2D .0535	Facility-wide	Notification requirement
15A NCAC 2D .0515	Solids handling	Limits PM emissions
15A NCAC 2D .0611	Control devices	I & M and recordkeeping
15A NCAC 2D .0958	VOC sources	VOC work practices
15A NCAC 2D .1100	Facility-wide	Limits acetaldehyde and 1,3-butadiene
15A NCAC 2D .1806	Facility-wide	Limits odorous emissions
15A NCAC 2Q .0315	Facility-wide	Synthetic minor SO2 and HAPs
15A NCAC 2Q .0711	Facility-wide	TPER for 1,4-dioxane
15A NCAC 2D .0202	Facility-wide	Emissions inventory requirement

8. Conclusions, Comments, and Recommendations:

The application is for permit renewal. The ID numbers have been updated and the backup DMT storage tank has been added to the revised permit. It is recommended that 08907R03 be issued to Dupont Teijin Films.