DEQ-CFW_00065405

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January 25, 2016
Mr. Steven F. Vozzo, Regional Supervisor
Division of Air Quality, NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301-5094
Subject: Annual Air Permit Summary
Kuraray America, Inc. — Fayetteville
Kuraray Interlayer Solutions
Air Permit No. 10396R00
Permit Class: Synthetic Minor
Facility ID# 0900091
Dear Mr. Vozzo:
In accordance with Kuraray's Air Permit requirements the following is a summary of all control
device monitoring and recordkeeping activities described above for the previous 12 months.
There were no permit deviations.
The control monitoring devices for this permit are as follows:
Butacite® Polyvinyl Butyral Flake Dryer (BCD-C) is inspected annually (9/30/2015), no
issues were found. Monthly Inspections of the Ductwork Baghouse exhaust were
conducted and no issues were found.
Butacite® Scrubber A(41) (Control System ID BCD-B1, ID Nos. BS-B.1.1 through BS-
B.1.4) (inspected 8/14/2015) and Butacite® Scrubber B(92) (Control System ID. BCD-
B2, ID Nos. BS-13.2.1 through BS-B.2.4) (inspected 8/14/2015) were annually inspected,
no issues were found. Periodic inspections have been implemented and one was
completed on August 28, 2015 for both scrubbers.
Butyraldehyde Storage Tank (ID BS-A) and the Butacite® Sheeting Extrusion Lines (ID
BS-El and BS-E2) annual and periodic (semi-annual) inspections (the manufacturer did
not have any recommendations so we set up the periodic inspections as semi-annual)
these were performed in 2015.This was a new requirement for Kuraray's Air permit
(not required in DuPont's Air Permit). After Kuraray's Air Permit was issued the
equipment referenced above had to be set up in the SAP System by the area
Mechanical Engineer and a down time scheduled in order to conduct the inspection.
Previously the Butyraldehyde Storage Tank was inspected every three years, it now
set up on an annual inspection. Butyraldehyde Storage Tank (ID BS-A) were inspected
4/30/2015 for the annual requirement and on 9/15/2015 for a periodic inspection
requirement. There will be two periodic inspections done in 2016.
DEQ-CFW 00065405

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The ButaciteOO Sheeting Extrusion Lines (ID BS-El and BS-E2) were inspected
3/24/2015 for the annual requirement and one periodic inspection was set up and
conducted on 8/28/2015. There will be two periodic inspections done in 2016.
• MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT)
For each affected MCPU with Group 2 Process Vent, including the Butacite0 PVA
Unloading System and Silos (ID. No. BS-F), the Butacite0 PVA Dissolving System (ID.
No. BS-G), the Butacite0 Flake Reactor System (ID Nos. BS-B1.1 through BS-131.4 and
BS-BS2.1 through BS-132.4), Butacite® Flake Dryer (ID No. BS-C), the permittee
complied with all applicable provisions, including notification, testing, recordkeeping,
and monitoring requirements. Records were maintained of the daily 365-day rolling
summations of emissions, or alternative records that correlate to the emissions, or
alternative records that correlate to the emissions (eg. number of batches), these are
calculated monthly.
Records are maintained on file for each of the Butacite0 Group 2 Wastewater Streams.
This includes: MPCU Identification and description; stream identification codes;
concentration of compounds and stream flow rate (L/min).
The above annual summary should include all required information, if there is any
additional information needed, please contact Hope Walters [phone].
Sincerely,
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J
E. Ross Crews, Jr.
Site Manager
DEQ-CFW 00065406