DEQ-CFW_00065375

•
U
NORTH CAROLINA DIVISION OF
AIR QUALITY
Air Permit Applicability Review
Issue Date: 05/08/2017
Facility Data
Applicant (Facility's Name): Kuraray America, Inc. - Fayetteville
Facility Address:
Kuraray America, Inc. - Fayetteville
22824 NC Hwy 87 West
Fayetteville, NC 28306
SIC: 3081 / Unsupported Plastics Film And Sheet
NAICS: 326113 / Unlaminated Plastics Film and Sheet (except Packaging)
Manufacturing
Facility Classification: Before: Synthetic Minor After: Synthetic Minor
Fee Classification: Before: Synthetic Minor After: Synthetic Minor
Contact Data
Facility Contact N Authorized Contact 11 Technical Contact
Jay Stone
Safety Manager
[phone]
22824 Hwy NC 87 West
Fayetteville, NC 28306
Ross Crews
Site Manager
[phone]
22824 NC Hwy 87 West
Fayetteville, NC 28306
Review Engineer: Gregory Reeves
Review Engineer's Signature: Date:
A, /_a-elypt7
Hope Walters
E, H & S Competency
Consultant
[phone]
22824 NC Hwy 87 West
Fayetteville, NC 28306
1. Purpose of Applicability Determination:
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900091
Inspector's Name: Gregory Reeves
Date of Last Inspection: 03/22/2017
Com liance Code: 3 / Com liance -ins ection
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance:
NC Toxics:
112(r):
Other:
PERMIT APPLICABILITY
REVIEW
IMBIBING PROCESS
Application Data
Application Number: 0900091.14A
Date Received: 07/15/2014
Application Type: Greenfield Facility
Application Schedule: State
Existing Permit Data
Existing Permit Number: N/A
Existing Permit Issue Date: N/A
Existing Permit Expiration Date: N/A
Comments / Recommendations:
AIR PERMIT NOT REQUIRED
Kuraray America, Inc. — Fayetteville is an existing specialty chemical production facility located in Fayetteville,
Bladen County. The company plans to install a new chemical process (the "Imbibing Process") to produce a
new specialty chemical film product. The company has requested a determination of whether this installation
requires an air permit for the facility.
No confidential information was supplied with this application.
The facility contact for this application is Aaron Evans, Mechanical Engineer (910-433-7124).
DEQ-CFW 00065375

Kuraray America, Inc. — Fayetteville
Permit Applicability Review
Tracking Number 3054
Page 2 of 4
2. Application Chronology:
04/26/17 Hope Walters sent Greg Reeves an email regarding a new chemical process that
Kuraray is intending to install in the facility. This new process would involve the use
of silane and would emit ethanol and methanol as byproducts of the chemical reaction.
The email contained MSDS for two silane products that might be used, and a picture of
the proposed equipment.
04/26/17 Greg Reeves spoke with Aaron Evans, Mechanical Engineer at Kuraray (910-433-
7124), regarding the proposed process. Mr. Evans was requested to submit information
on the potential ethanol and methanol emissions. Particle size of the material fed to the
system and methods of transport in equipment to storage silos was also discussed.
04/26/17 Aaron Evans emailed information on product quantities and emissions of methanol and
ethanol projected for 2018 and 2019.
3. Equipment and Process Evaluated:
This applicability concerns an existing facility. The facility produces specialty plastic materials that are used in
various applications, including automobile windshields, safety pane window glass, high security window glass,
and hurricane resistant glass panes.
The equipment being evaluated is a proposed installation of blending, pumping, and handling equipment for a
new process. This process will use existing feed stock currently used in the facility (Polyvinyl Butyral) and
react this material with one of several silane compounds to produce a new product. The chemical reaction
releases ethanol and methanol. The particle size and the mechanical characteristics of the material used in the
process indicate that only an extremely small amount of particulate matter will be produced by the process.
Particulate emissions will be controlled by an existing fabric filter.
4. NSPS, NESHAP, PSD, Attainment Status, and 112(r):
• NSPS — There are no current NSPS regulations that apply to this facility.
• NESHAP — NESHAP Subpart FFFF "Miscellaneous Organic Chemical Manufacturing" applies
to the existing process.
• PSD — Does not apply to this operation.
• Attainment Status — Bladen County is in attainment for ozone and PM2.5.
• 112(r) — None of the listed chemicals is stored at the facility in amounts that exceed the threshold
quantities. Therefore, the facility is not required to maintain a written Risk Management Plan (RMP).
5. Facility Compliance Status:
There have been no negative compliance incidents at this facility. This facility was previously a part of the
DuPont — Fayetteville Works facility (now Chemours Company — Fayetteville Works)(Facility ID 0900009).
DEQ-CFW 00065376

Ay America, Inc. — Fayetteville
Permit Applicability Review
Tracking Number 3054
Page 3 of 4
6. Emissions Review:
Process Information:
In the new process, silane is injected into a blender with Polyvinyl Butyral to achieve a concentration of
approximately 1,000 ppm silane (feed rate of 1 gram of silane per kilogram of feed material). The silane is
totally consumed in the reaction.
In the reaction, for each kg of product produced, 1 g of silane is consumed, 0.3 kg of methanol is emitted, and
0.4 kg of ethanol is emitted.
2019
Usages and. Erntsions
Asa sand Erri s ons
Projected Product Demand (kg)
1,085,000
2,456,000
Silane Consumption (kg)
1,085
2,456
Methanol Emissions (kg)
336.35
761.36
Ethanol Emissions (k)
401.45
908.72
Max Methanol Emissions (tons/yr)
0.37
0.84
Max Ethanol Emissions (tons/yr)
0.44
1.00
Emissions after this process has been installed, using the proposed maximum methanol emissions from 2019 as
listed above, are as follows:
2i113 Aral Emissions.-
P6 ential'Emisstons
Potential Etntssia�ts
Pollutant
orislyr
before C©ttfirals tpy
after'antrois tpy
PM
4.20
293
0.30
PM10
4.20
293
0.30
PM2.5
4.20
293
0.30
SO2
0
0
0
NO.
0
0
4.17
CO
0
0
0.90
VOC
33.74
250
48.50
HAP (Methanol)
2.76
5.60
4.42
DEQ-CFW 00065377

Kuraray America, Inc. — Fayetteville
Permit Applicability Review
Tracking Number 3054
- Page 4 of 4
7. Air Tonics
There are no toxics emissions from this new process. Silane, methanol and ethanol are not considered TAPs
under the North Carolina toxics rules. Methanol is considered a HAP and a VOC under federal rules.
8. Conclusion, Comments, and Recommendations:
The Imbibing Process will emit VOC and HAP at a maximum potential before control emission rate of less than
5 tons per year for each pollutant, and therefore is exempt from air permitting requirements under 2Q .0102
(h)(5)•
Therefore, an air permit is not required.
I recommend issuing a letter of exemption to Kuraray America, Inc. — Fayetteville (Facility ID 0900091).
This process should be added to the facility's Insignificant/Exempt Activities listing during the next permit
revision. This will be noted on the facility file Pink Sheet.
\GWR
Review Engineer: Date:
Permit Coordinator: v Date: J !)
DAQ Supervisor: Date:IV
DEQ-CFW 00065378