• Condition I a. Page 4 the Emission Unit Description for EU 31 through EU 35 should

read Unloadlng Station Tanks”.

• Condition I a. Page 4 the Emission Units for MPIEU 18 & 19 should refer to a third

vacuum pump. Perhaps MPIEU 2(L Note there is a discrepancy between the

designation of the emission points in the table on page 4 and how the points are

described on page 51 Condition 3—Table I k.

• Condition 3 Table I a. 2. vi. B. Page 20 should refer toCondition 3- Table I(o)4jnot

Table 1(o)(3) as written.

• Condition 3 Table I b. 2. vii. A Page 24 should refer to Condition 3- Table 1(o)4)not

Table 1(oX3) as written.

• Condition 3 Table I c. 2. vui:A. Page 27 should refer to CondItion 3- Table 1(o)L4Lnot

Table 1(o)(3) as written.

CondItion 3 Table I h. I. iv. D. jPage 43 should read “The pressure drop across thescrubber shall be less than 19 inches. water gauge.”

• Delete Condition 3 Table IL I. vi. C. Page .46. The spray condenser on 7 kettle

operates at atmospheric conditions with no packing or other means of creating a

pressure drop so monitoring of pressure drop is not a meaningful measure of Its

operation. .

• Delete Condition 3 Table 1j. 1. vi. C. Page 49. The spray condenser on 4 kettle also

operates at atmospheric conditions with no packing or other means of creating a

pressure drop so monitoring of pressure drop is not a meaningful measure of its

operation.

‘Condition 3 Table I I. 1. 1. 8. Page 55 please delete Multi-Purpose Plant and insert

Unloading Station Tanks.

• Condition 3 Table I mI.vi.C. Page 56 please delete the words “...and kettles.” The

oxide detection system does not involve the kettles.

• ConditIon 3 Appendix “K Page 73 Multi-Purpose Plant insignificant sources. The first

item should read Three vacuum pumps.

in addition, Croda requests that the General Emission Limitation from APC-2004/0723 for Oxides of Sulfur not

to exceed 0.1 ton per 12-month rolling period be transferred to AQM-003/00426 — Renewal 2.

In addition, Croda requests that the Emission Limitation from APC-200410723 for Carbon Monoxide of 34.0

pounds per batch for the ‘Kettles Area’ be transferred to AQM-003!00426 — Renewal 2 and white we

request 34.0 pounds per batch be retained for 7 kettle the emission the limitation for 4 kettle may bereduced to 30.0 pounds per batch.
Please 2. Renewal - AQM-003100426 Permit to requests Croda modifications the of summary isa this Amy

questions. any are there if me contact

Croda permit the from a. I 3—Table Condition Delete • of process the in is

#1. Boiler demolishing

Description Unit Emission the 4 Page a. I Condition • Blend read should 4 & 3 EU for

Tanks,.... Blend jQ— Area Tank

Description Unit Emission the 4 Page a. I Condition • 3A the include should 14 EU for

hotwelL autoclave

Description Unit Emission the 4 Page a. I Condition • should 35 EU through 31 EU for

Tanks. Station ‘Unloading read

19 & 18 EU MPI for Units Emission the 4 Page a. 1 Condition • third a to refer should the between discrepancy a is there Note 20. EU MPI Perhaps pump. vacuum

are points the how and 4 page on table the in points emission the of designation k. I 3—Table Condition 51 page on described

1oLnot Table - ConditionS to refer should 20 Page B. vi. 2. a. I Table 3 Gonditlon •

written. as 1(o)(3) Table

Table 3- ConditIon to refer should 24 Page A. vii. 2. b. I Table 3 Condition • I(o){4)not

written. as 1(oX3) Table

should 27 Page A. vii; 2. C. I Table 3 Condition • 1(o)(4not Table 3- Condition to refer

written. as 1(o)(3) Table

drop pressure ‘The read should 43 Page j, D. iv. 1. h. I Table 3 Condition • the across

gauge. water inches 19 than less be shall scrubber

kettle 7 on condenser spray The 46. Page C. vi. 1. I. I Table 3 Condition Delete •

a creating of means other or packing no with conditions atmospheric at operates its of measure meaningful a not is drop pressure of monitoring so drop pressure

operation.

kettle 4 on condenser spray The 49. Page C. vi. 1. j. I Table 3 Condition Delete • also

a creating of means other or packing no with conditions atmospheric at operates its of measure meaningful a not is drop pressure of monitoring so drop pressure

operation.

and Plant Multi-Purpose delete please 55 Page B. I. I. I. I Table 3 Condition • insert

Tanks. Station Unloading

The kettles.” “...and words the delete please 56 Page m.1.vi.C. I Table 3 Condition •

kettles. the involve not does system detection oxide
March 2, 2010

DuPont Stine-Haskell Research Center

P.O. Box 80249

Wilmington, DE 19880-0249

Attention: Robert F. Oranzi

Manager, Environmental Services

SUBJECT: Cancellation of Facility Air Permits:

APC-82f068-Operation (Al’) -Boiler No. 3

APC-82/094-Operation (Al’) -Boiler No. 4

Dear. Mr. Oranzi:

The Department accepts the cancellation request dated February 24, 2010 as formal notification to cancel the following Permits, related to DuPont Stine Haskell Research Center facility, located at 1090 Elkton Rd. Newark, DE 19714:Permit: APC-82/068-Operation (Al’) -Boiler No. 3 ‘

Permit: APC-82/094-Operátion (Al’) - Boiler No. 4

Operation of this equipment after the date ofthis letter shall constitute a violation of 7 DE Admin. Code 1100.

These two permits will be deleted from the Title V Permit Renewal: AOM-003!00279(Renewal 2’).

Please contact Lupe Reynolds at (302) 323-4542 if you have any questions or concerns.

Sincerely,

Paul E. Foster, P.E.

Program Manager

Engineering & Compliance Branch

PEF:ELD:GJR:gjr

F:\EngAndCompliance\GJR\GJR10028.doc

pc: Dover File Jack Sipple John Outten Frank Gao
ThROUGH: Everett 1. DeWhitt, PhD.

FROM: Lupe Reynolds

SUBJECT: Cancellation of Facility Air Permits:

APC-82/068-Oneration (Al) -Boiler No. 3APC-82/094-Operation (Al) -Boiler No. 4

DATE: March 1, 2010

BACKGROUND

On February 26, the Department received a letter from DuPont Stifle Haskell Research Center, signed by RobertF. Oranzi, Environmental Manager, indicating that Boilers No. 3 and No. 4 are inoperable and beyond repair.

Therefore, the Company requested to cancel the operating permit or these two boilers:

Permit: APC-82/068-Operation (Al) -Boiler No. 3

Permit: APC-82/094-Oi,eratioh (Al) -Boiler No. 4

RECOMMENDATION

I recommend sending the attached letter to the Company, confirming that the Department is cancelling the two

permits related to Boilers No. 3 and No. 4 and deleting them from Title V Permit Renewal: AOM

003/00279(Renewal 2).

PEF: ELD:GJR:gjr

F:\EngAndCompliance\GJR\G3R10028.doc

pc: Dover File

Jack Sipple

Frank Gao

Karen MattioDawn Minor

Joanna French

John Outten
March 2, 2010

DuPont Stine-Haskell Research Center

P.O. Box 80249

Wilmington, DE 19880-0249

Attention: Robert F. Oranzi

Manager, Environmental Services

SUBJECT: Cancellation of Facility Air Permits:

APC-82/068-Operation (Al) -Boiler No. 3

APC-82/094-Operation (Al) - Boiler No. 4

Dear. Mr. Oranzi:

The Department accepts the cancellation request dated February 24, 2010 as formal notification to cancel the

following Permits, related to DuPont Stifle Haskell Research Center facility, located at 1090 Elkton Rd. Newark, DE 19714:

Permit: APC-82/068-Oaeration (Al) - Boiler No. 3

Permit: APC-82/094-Operàtion (Al) -Boiler No. 4

Operation of this equipment after the date ofthis letter shall constitute a violation of 7 DE Admin. Code 1100.

These two permits will be deleted from the Title V Permit Renewal: AOM-003100279(Renewal 2).

Please contact Lupe Reynolds at (302) 323-4542 if you have any questions or concerns.

Sincerely,

Paul E. Foster, P.E.

Program Manager

Engineering & Compliance Branch

PEF:ELD:GJR:gjr

F:\EngAndCompliance\G)R\GJR10028.doc

pc: Dover File Jack Sipple John Outten Frank Gao
ThROUGH: Everett L. DeWhitt, PhD.

FROM: Lupe Reynolds

SUBJECT: Cancellation of Facility Air Permits:

APC-82/O68-Oeration (Al) -Boiler No. 3

APC-82/094-Operation (Al) -Boiler No. 4

DATE: March 1, 2010

BACKGROUND

On February 26, the Department received a letter from DuPont Stine Haskell Research Center, signed by RobertF. Oranzi, Environmental Manager, indicating that Boilers No. 3 and No. 4 are inoperable and beyond repair.

Therefore, the Company requested to cancel the operating permit or these two boilers:

Permit: APC-821068-Operation (Al) -Boiler No. 3

Permit: APC-82!094-Oneratioñ (Al) - Boiler No. 4

RECOMMENDATION

I recommend sending the attached letter to the Company, confirming that the Department is cancelling the twopermits related to Boilers No. 3 and No. 4 and déleUng them from Title V Permit Renewal: AOM

003100279(Renewal 2’).

PEF:ELD:G)R:gjr

F:\EngAndCompliance\GJR\GJR10028.doc

pc: Dover File

Jack Sipple

Frank Gao

Karen MattloDawn Minor

Joanna French

John Outten
March 2, 2010

DuPont Stine-Haskell Research CenterP.O. Box80249

Wilmington, DE 19880-0249

Attention: Robert F. Oranzi

Manager, Environmental Services

SUBJECT: Cancellation of Facility Air Permits:

APC-82/068-Operation (Al) - Boiler No. 3

APC-82/094-Operation (Al) - Boiler No. 4

Dear. Mr. Oranzi:

The Department accepts the cancellation request dated February 24, 2010 as formal notification to cancel the

following Permits, related to DuPont Stifle Haskell Research Center facility, located at 1090 Elkton Rd. Newark, DE 19714:

Permit: APC-82/068-Operation (Al) -Boiler No. 3

Permit: APC-82I094-Operátion (Al) -Boiler No. 4

Operation of this equipment after the date of this letter shall constitute a violation of 7 DE Admin Code 1100.

These two permits will be deleted from the Title V Permit Renewal: AQM-003!00279(Renewal 2).

Please contact Lupe Reynolds at (302) 323-4542 if you have any questions or concerns.

Sincerely,

Paul E. Foster, P.E.Program Manager

Engineering & Compliance Branch

PEF:ELD:GJR:gjr

F:\EngAndCompliance\GJR\GJR10028.doc

pc: Dover File Jack Spple

John Outten Frank Gao
ThROUGH: Everett L. DeWhitt, PhD.

FROM: Lupe Reynolds

SUBJECT: Cancellation of Facility Air Permits:

APC-82/068-Operation (Al) - Boiler No. 3

APC-82 /094-Operation (Al) -Boiler No. 4

DATE: March 1, 2010

BACKGROUND

On February 26, the Department received a letter from DuPont Stifle Haskell Research Center, signed by RobertF. Oranzi, Environmental Manager, indicating that Boilers No. 3 and No. 4 are inoperable and beyond repair.

Therefore, the Company requested to cancel the operating permit or these two boilers:

Permit: APC-82/068-Operation (Al) -Boiler No. 3

Permit: APC-82J094-Operatioñ (Al) -Boiler No. 4

RECOMMENDATION

I recommend sending the attached letter to the Company, confirming that the Department is cancelling the two

permits related to Boilers No. 3 and No. 4 and deleting them from Title V Permit Renewal: AOM

003/00279(Renewal 2).

PEF:ELD:GJR:gjr

F:\EngAndCompliance\GJR\G3R10028.doc

pc: Dover File

Jack Sipple

Frank Gao

Karen Mattio

Dawn Minor

Joanna French

John Outten
INVISTA S.à r.l.-Seaford Plant (INVISTA)

25876 DuPont Road

Seaford, DE 19973

ATTENTION: Steven R. Kimpton

Plant Manager

SUBJECT: Cancellation of Permits associated with Emission Units permanentiy shutdown

Dear Mr. Kimpton:

The Department accepts the cancellation requests dated December 31, 2009 and February 23, 2010 asformal notification to cancel all the permits identified in the Attachment below. The listed permits which

allow for the operation of the emission units described in the Attachment are hereby cancelled due to the

permanent shutdown of the associated emission units located at 25876 DuPont Road, Seaford, Delaware.

Operation of these emission units after the date of this letter shall constitute a violation of 7 DE Admin.

Code 1100.

Please contact Phanuel C. K. Bediako, Ph.D. at (302) 739-9402 if you have any questions or concerns.

Sincerely,

Paul E. Foster, P.E.

Program Manager

Engineering & Compliance Branch

PEF:JLF: PCKB:sr

f:\pckb\pckblOO27.doc

pc: Dover (Title V) File

Joanna L. French, P.E.

Phanuel C. K. Bediako, Ph.D.

Jack Sipple

Frank Gao

John Outten
APC-88/270-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 013)

APC-88/271-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 014)

APC-88/272-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 015)

APC-88/273-OPERATION dated July 15, 1988 24 MMBTU/hr DOWThERM Vaporizer

(EU 016)

APC-88/274-OPERATION dated July 15, 1988 46.4 MMBTU/hr DOWTHERM Vaporizer (EU 017)

APC-88/275-OPERATION dated July 15, 1988 46.4 MMBTU/hr DOWTHERM Vaporizer (EU 018)

APC-80/1406-OPERATION dated September 17, 1980 Lindberg Reclamation Unit’(Electric)

(EU 021)

• APC-80/ 1407-OPERATION dated September 17,11980 Lindberg Reclamation Unit (Electric)

(EU 022)

APC-80/1321-OPERATION (Amendment 1) dated Reflux Recovery Column on CP line III

May 12, 1982 Continuous Polymerization Processes

(EU 025A)

APC-82/1189-OPERATION dated October 10, 1982 Two polymerizers and scrubbing machines No. 21

and No. 22 (EU 025A)

APC-0th/0302-OPERATION dated April 5, 2004 North Scrubber System (EU 025B)

APC-2001/0303-OPERATION dated April 5, 2004 South Scrubber System (EU 025B)APC-2002/0741-OPERATION dated April 5, 2004 Middle Scrubber System (EU 0258)

APC-94/0853-CONSTRUCTION/OPERATION dated DOWTHERM Vent Condensers (EU 026)

November 8, 1996

APC-2005/0179-CONSTRUCTION/OPERATION dated Four (4) Adipic Acid Vacuum Conveyance SystemsOctober 5, 2005 (EU 036)

APC-2005/0180-CONSTRUCTION/OPERATION dated

October 5, 2005

APC-2005/0181-CONSTRUCTION/OPERATION datedOctober 5, 2005

APC-2005/0182-CONSTRUCTION/OPERATION dated

October 5, 2005
DATE: March 2, 2010

BACKGROUND INFORMATION:

The Department received a letter dated December 31, 2009 and a supplementary letter dated February 23, 2010 in which INVISTA requested an administrative amendment to the Title V permit. According to the letter, several operations have been permanently shut down as a result of therestructuring. The major thrust of this restructuring was the shutdown of all batch and continuous Nylon polymerization processes. Furthermore, Bulk Continuous Filament (BCF) spinning operations have been

discontinued. One (231) MMBTU/hr Combustion Engineering coal-fired boiler (Boiler No. 2) waspermanently shut down as a result of the July 28, 2009 Consent Decree between the EPA, the Department of Justice, DNREC, and INVISTA.

The Company requested that the emission units which have been permanently shut down be deleted from

the Title V permit and the associated 7 DE Admin. Code 1102 permits be cancelled. The Table identifies

all the permits which are to be cancelled.

LIST OF PERMITS TO BE CANCELLED

PERMIT NUMBER EQUIPMENT DESCRIPTION

APC-83/071-OPERATION (Amendment 5) (NOx RACT) 231 MMBTU/hr Combustion Engineering Boiler dated October 3, 2002 (EU 002)

APC-82/035-OPERATION dated August 28, 1981 Coal Car Thawing Unit (EU 006)

APC-88/268-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 011)

APC-88/270-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 013)

APC-88/271-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 014)

APC-88/272-OPERATION dated July 15, 1988 18 MMBTU/hr DOWTHERM Vaporizer

(EU 015)

APC-88/273-OPERATION dated July 15, 1988 24 MMBTU/hr DOWTHERM Vaporizer

(EU 016)

APC-88/274-OPERATION dated July 15, 1988 46.4 MMBTU/hr DOWTHERM Vaporizer (EU 017)

APC-88/275-OPERATION dated July 15, 1988 46.4 MMBTU/hr DOWTHERM Vaporizer (EU 018)

APC-80/1406-OPERATION dated September 17, 1980 Lindberg Reclamation Unit (Electric)

(EU 021)

APC-80/1407-OPERATION dated September 17, 1980 Undberg Reclamation Unit (Electric)

(EU 022)

APC-80/ 1321-OPERATION (Amendment 1) dated Reflux Recovery Column on CP Line III

May 12, 1982 Continuous Polymerization Processes

(EU 025A)
APC-94/0853-CONSTRUCTION/OPERATION dated DOWTHERM Vent Condensers (EU 026)

November 8, 1996

APC-2005/0179-CONSTRUCTION/OPERATION dated Four (4) Adipic Acid Vacuum Conveyance SystemsOctober 5, 2005 (EU 036)

APC-2005/0180-CONSTRUCTION/OPERATION dated

October 5, 2005

APC-2005/0181-CONSTRUCTION/OPERATION dated

October 5, 2005

APC-2005/0182-CONSTRUCTION/OPERATION datedOctober 5, 2005

RECOMMENDATION:

I recommend that the permits identified above be cancelled.

PEF:.]LF: PCKB:sr

f:\pckb\pckblOO27.clocpc: Dover (Title V) File

Jack Sipple

Frank GaoKaren Mattio, P.E.

Dawn Minor

Joanna French, P.E.John Outten