AQ_F_0900009_20221028_PRMT_PmtAddum

For inclusion in the Chemours — Fayetteville Work Facility's Vinyl
Ethers Expansion permit application submitted 10/28/2022.
RECEIVED
OCT 31 2022
/Q�169p--\
DEO-FAVETEVILLE REGIONAL OFFICE

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED 09/22/16 NCDEQIDivis!on of Air Quality-Application for Air Permit to Construct/Operate r D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and BI through 139)-SHOW CALCULATIONS USED,INCLUDING EMISSION FACTORS,
MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE
CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY
REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS.
B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO
INDIVIDUAL SOURCES AND THE FACILITY AS WHOLE. INCLUDE A DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR MONITORING REQUIREMENTS)
FOR COMPLYING WITH APPLICABLE REGULATIONS,PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER
OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS(PREVENTION OF SIGNIFICANT DETERIORATION
(PSD),NEW SOURCE PERFORMANCE STANDARDS(NSPS),NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS(NESHAPS),TITLE V),
INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY, SUBMIT ANY REQUIRED
INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM"A"ABOVE,DATES OF MANUFACTURE,
CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS.
C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL
EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE. INCLUDE PERTINENT
OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION)
CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE
PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE
INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED.
D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS,
OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM"B"
WHERE APPROPRIATE, LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE
APPLICABLE REGULATIONS.
E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).
11 Jeffrey Twaddle,P.E. attest that this application for vinyl ethers expansion
has been reviewed by me and is accurate,complete and consistent with the information supplied
in the engineering plans,calculations,and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design
has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other prolessionals,
inclusion of these materials under my seal signifies that I have reviewed this material and havejudged it to be consistent with the proposed design. Note: In accordance with
NC General Statutes 143-215.6A and 143-215.6B,any person who knowingly makes any false statement,representation,or certification in any application shall be guilty of a
Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME: Jeffrey Twaddle
DATE: 10/28/2022
s
COMPANY: ERM // -�➢r>
ADDRESS: 5000 Meridian Blvd,Suite 300,Franklin,TN 37067
TELEPHONE: 615-61
% e
SIGNATURE:
PAGES CERTIFIED: so tedCForms(C3 and CS) {:Ye�4�.Av�� (N7;�.; �`� °
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED 09/22/16 NCDEQIDivision of Air Quality-Application for Air Permit to Construct/Operate D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and B1 through B9)-SHOW CALCULATIONS USED,INCLUDING EMISSION FACTORS,
MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE
CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY
REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS,
B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO
INDIVIDUAL SOURCES AND THE FACILITY AS WHOLE. INCLUDE DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR MONITORING REQUIREMENTS)
FOR COMPLYING WITH APPLICABLE REGULATIONS,PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER
OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS(PREVENTION OF SIGNIFICANT DETERIORATION
(PSD),NEW SOURCE PERFORMANCE STANDARDS(NSPS),NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS(NESHAPS),TITLE V),
INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED
INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM"A"ABOVE,DATES OF MANUFACTURE,
CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS.
C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL
EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE. INCLUDE PERTINENT
OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION)
CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES), INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE
PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE
INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED.
D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS,
OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM"B"
WHERE APPROPRIATE, LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE
APPLICABLE REGULATIONS.
E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRINGA PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).
1, Jeffrey Twaddle,P.E. attest that this application for vinyl ethers expansion
has been reviewed by me and is accurate,complete and consistent with the information supplied
in the engineering plans,calculations,and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design
has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other professionals,
inclusion of these materials under my seal signifies that 1 have reviewed this material and havejudged it to be consistent with the proposed design. Note: In accordance with
NC General Statutes 143-215.6A and 143-215.6B,any person who knowingly makes any false statement,representation,or certification in any application shall be guilty of a
Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME: Jeffrey Twaddle
DATE: 10/28/2022
COMPANY: ERM /Jr
ADDRESS: 5000 Meridian Blvd,Suite 300,Franklin,TN 37067
TELEPHONE: [phone]
SIGNATURE: -
PAGES CERTIFIED: Aso Iated-Forms(C3 and C9)
r`PP
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED 09/22/16 NCDEQ/Dlvlslon of Air Quality-Application for Air Permit to ConstructlOperate D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and BI through 69)-SHOW CALCULATIONS USED,INCLUDING EMISSION FACTORS,
MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED. INCLUDE
CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND PROVIDE ANY
REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS.
B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE TO
INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR MONITORING REQUIREMENTS)
FOR COMPLYING WITH APPLICABLE REGULATIONS,PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON PROCESS RATES OR OTHER
OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS(PREVENTION OF SIGNIFICANT DETERIORATION
(PSD),NEW SOURCE PERFORMANCE STANDARDS(NSPS),NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS(NESHAPS),TITLE V),
INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO THIS FACILITY. SUBMIT ANY REQUIRED
INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES CALCULATED IN ITEM"A"ABOVE,DATES OF MANUFACTURE,
CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS.
C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY CONTROL
EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE. INCLUDE PERTINENT
OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS APPLIED FOR IN THIS APPLICATION)
CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION POTENTIAL FOR THE
PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION OF THE CONTROL DEVICE
INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED.
D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING PROCESS,
OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY ANALYSIS IN ITEM"B"
WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO DEMONSTRATE COMPLIANCE WITH THE
APPLICABLE REGULATIONS.
E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).
1, Jeffrey Twaddle,P.E. attest that this application for vinyl ethers expansion
has been reviewed by me and is accurate,complete and consistent with the information supplied
in the engineering plans,calculations,and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the proposed design
has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by other prolessionals,
inclusion of these materials under my seal signifies that I have reviewed this material and have judged it to be consistent with the proposed design. Note: In accordance with
NC General Statutes 143-215.6A and 143-215.6B,any person who knowingly makes any false statement,representation,or certification in any application shall be guilty of a
Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME: Jeffrey Twaddle
DATE: 10/28/2022
COMPANY: ERM
ADDRESS: 5000 Meridian Blvd,Suite 300,Franklin,TN 37087
TELEPHONE: [phone] n i t1 w
ar e
SIGNATURE:
PAGES CERTIFIED: Ass is d C Forms(C3 and C9) ti%�jv/�1r �o
-�R �QIN�;4 t CpQb�
Y6YYj0/0/111111^I(1`6�1\t`�i
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary