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OMB No. 2010-0032
Expiration Date 08/30/06
Performance Track Membership Renewal Application
2006















DuPont Front Royal
E.I. Du Pont de Nemours and Company, Inc.
Member since 2002



A030029



















Facility Contact



  Mr. James J. Nicola
  Environmental Manager
  (540) 622-1264
  jim.j.nicola-1@usa.dupont.com



Commitment 1

Air Emissions
Air Toxics
All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc. Specific
Acrylic Acid, Acrylonitrile, 1,2 Butylene Oxide, Cumene, Dibutyl Phthalate, Ethyl Acrylate, Ethyl Benzene, Ehylene Glycol, Formaldehyde, Glycol Ethers, 1,6 Hexamethlyene Diisocyanate, Maleic Anhydride, Methanol, Methyl Ethyl Ketone, Methyl Isobutyl Ketone, Methyl Methacrylate, Napthalene, Phenol, Phthalic Anhydride, 1,2 Propyleneimine, Styrene, Toluene, Triethylamine, and Xylene
DuPont Front Royal has initiated a project to target the reduction of HAP's through out the facility. The project includes abatement equipment on specific process equipment and continue efforts to reduce HAP emissions by means of improved work practices. By reducing fugitive emissions in the work place we also improve employee exposure whcih is very important from an Occupational Health view point.
No
Yes

2005 2008 
Pounds  
155,580 93,348 

Absolute goal

    

Gallons of Paint Produced

Yes
DuPont Front Royal is working to achieve a Synthetic Minor Status which requires total HAPs to be less than 25 tons per year and any single HAP to be less than 10 tons per year.

Commitment 2

Air Emissions
VOCs
All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc. Specific
Non-HAP VOC's. The major contributors are: Aliphatic HC, Aromatic HC, Butyl Acetate, Ethyl Acetate, Isobutyl Alcohol, Isopropyl alcohol, Methyl Ethyl Ketone, Methyl n-Amyl Ketone, Mineral Spirits, n-Bulyl Alcohol and 1,2-4 Trimethylbenzene
DuPont Front Royal site processes many solvents that are Non-HAP and is committed to reducing the air emissions created by these solvents. DuPont Front Royal has initiated a project that will reduce VOC air emissions by controlling the building exhaust from the manufacturing areas of the plant site by means of abatement equipment. DuPont also continues efforts at reducing emissions by continuous improvement on work practices and equipment design.
No
Yes


2005 2008 
Pounds  
69,020 41,412 


Absolute goal

    

Gallons of paint produced

Yes
The Facilities Title V permit has a limit of 268,000 of VOC's per year. Although we are currently well under the permit limit DuPont Front Royal is continuing efforts to reduce VOC air emissions. With the projects in process DuPont Front Royal plans to qualify for a Synthetic Minor Operating permit by year end 2006.

Commitment 3

Waste
Hazardous waste generation
All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc. All

Plant wide effort to reduce hazardous waste in all areas of the plant. DuPont Front Royal has been successful at continuous improvement with reference to hazardous waste reduction and we plan to continue these efforts. Specifically we plan to reduce waste generated in NCO (Nitrogen, Carbon, Oxygen) manufacturing by wash and save techniques i.e. save the wash on use as a raw material in the next batch.

No
Yes


In the table below, please enter your facility's amount of hazardous waste, broken down by waste management method. Please enter both the amounts that you manage currently and that you intend to manage in 2008. Include all hazardous waste that is treated on-site or sent off-site.
Reduce Hazardous Waste 
 2005 2008

Incineration 12,494,14411,817,892Pounds
6,247.075,908.95


Normalized goal

    

Gallons of paint produced

No

Commitment 4

Material Use
Hazardous materials used
All measurements should represent the performance level for the indicator across the entire facility. For many indicators, however, you may choose to focus your commitment on a specific subset of the indicator, e.g. a specific material, a specific group of toxic air emissions, a particular waste component, a specific VOC, etc. Specific
lead
DuPont Front Royal is introducing a new paint line PT-100 Series New Generation Tints for the Heavy Duty Truck industry. The PT-100 series paint line replaces current 500H paint line that uses leaded pigments to create requried "hiding" properties. DuPont has made a commitment to eliminate lead in any new paint lines in the future and to work with all customers to convert to the new no-lead paint lines currently being formulated by DuPont.
No



Yes



2005 2008 
Pounds  
94,710 89,975 


Absolute goal

    

gallons of paint produced

No




Attachments (if applicable) :



Section E: Self-Certification of Continued Program Participation



On behalf of DuPont Front Royal, I certify that:

  • I have read and agree to the terms and conditions for Membership Renewal and Participation in the National Environmental Performance Track, as specified in the National Environmental Performance Track Program Guide and in the Renewal Application Instructions;

  • I have personally examined and am familiar with the information contained in this Renewal Application. The information contained in this Renewal Application is, to the best of my knowledge and based on reasonable inquiry, true, accurate, and complete, and I have no reason to believe the facility would not meet all program requirements;

  • My facility has an environmental management system (EMS), as defined in the Performance Track EMS requirements, including systems to maintain compliance with all applicable Federal, State, tribal, and local environmental requirements in place at the facility, and the EMS will be maintained for the duration of the facility's participation in the program

  • My facility has conducted an objective assessment of its compliance with all Federal, State, tribal, and local environmental requirements, and the facility has corrected all identified instances of potential or actual noncompliance;

  • Based on the foregoing compliance assessment and subsequent corrective actions (if any were necessary), my facility is, to the best of my knowledge and based on reasonable inquiry, currently in compliance with applicable Federal, State, tribal, and local environmental requirements.


I agree that EPA's decision whether to accept participants into or remove them from the National Environmental Performance Track is wholly discretionary, and I waive any right that may exist under any law to challenge EPA's acceptance or removal decision.

I am the senior facility manager and fully authorized to execute this statement on behalf of the corporation or other legal entity whose facility is applying to this program.



______________________________________________________
Mr.  Charles K. Enzinger
Plant Manager
540 622-1216
CharlesK.Enzinger@usa.dupont.com
DuPont Front Royal
7961 Winchester Road
Front Royal, VA 22630
,
A030029



Environmental Requirements Checklist

Facility Identification Information




(A RCRA number is used in the RCRAInfo database for Resource Conservation and Recovery Act (RCRA) programs).
No


(A TRI number is used in the Toxics Release Inventory (TRI) for Emergency Planning and Community Right-to-Know Act).
Yes
22630DPNTFPOBOX

(An AFS number is used in the AIRS Facility Subsystem of the Aerometric Information Retrieval System (AIRS) for Clean Air Act programs).
No


(A PCS/NPDES number is used in the Permit Compliance System (PCS) for Clean Water Act programs monitoring National Pollutant Discharge Elimination System (NPDES) permits).
No


(A FIFRA number is given to facilities regulated by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)).
No



Air Characteristics



Yes

Yes

No

No

Yes

Subpart-Kb Standards of Performance for Volatile Organic Liquid Storage Vessels

Yes

Yes
MON/MCM

No


Yes

No

Yes
VOC, Particulates, SO2, NO2 & CO

n/a

Water Characteristics



No

No

No

No

No

Yes

No


n/a

Hazardous Waste Characteristics



Yes

No

No

No

n/a

Environmental Clean-Up, Restoration, and Corrective Action Characteristics



No


No


No

No

n/a

Other Environmental Characteristics



Yes

Yes

No

Yes

Yes

Yes

No

n/a