DEQ-CFW_00065856

Chemours,
The Chemours Company 910-483-4681 o
Fluoroproducts chemours.com
22828 NC Hwy 87 W
Fayetteville, NC 28306-7332
tF "
FAYETTEVILLE REGIONAL OFFICE
CERTIFIED MAIL ARTICLE NUMBER 7002 0860 0006 9104 8153
RETURN RECEIPT REQUESTED
October 27, 2016
Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
225 Green Street — Suite 714
Fayetteville, NC 28301
SUBJECT: Title V Air Permit Modification
Air Quality Permit No. 03735T42
Chemours Company — Fayetteville Works
Facility ID: 0900009
Dear Mr. Vozzo:
Enclosed are an original and two copies of an application to modify the Chemours Company —
Fayetteville Works' ("Chemours") Title V Air Permit.
To expedite the permit modification process, two copies of this application and the check for
the required application fee have been sent directly to the attention of Ms. Heather Sands in the
Division of Air Quality's central office in Raleigh, NC.
Chemours wishes to follow the procedures under 15A NCAC 02Q.0504, "Option for Obtaining
Construction and Operation Permit," to obtain a construction and operation permit via the
two-step process, and as such is submitting the step -one application and fee at this time.
This application is to allow for the modification of the IXM Membrane Coating Process
(ID No. NS-I) in which (1) four new spray guns will replace the existing two spray guns and
(2) the product mix will be changing to predominately a finished product membrane that
requires a greater application of the spray coating. Because the potential -to -emit VOC
emissions from this operation are seemingly large, albeit completely impractical, Chemours is
requesting the use of baseline actual emissions to projected actual emissions to avoid the
DEQ-CFW 00065856

Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
October 27, 2016
Page 2 of 5
applicability of the requirements of Prevention Of Significant Deterioration ("PSD") per 15A
NCAC 02D .0530(u).
DETAILS OF REQUESTED MODIFICATION
The IXM Membrane Coating Process is being modified to accommodate the future increased
production of the new Nafion® 2050 membrane.
Nafion® membranes are spray coated with zirconium oxide and SR resin (1,1,2,2-tetra-fluoro-
ethene,1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexafluoro-3-(1,2,2-trifluoro-ethen-oxy)propan-2-ylI
oxy-ethanesulfonyl fluoride) to enhance the performance of the membrane.
The Nafion® 2050 membrane requires twice the zirconium/resin coating than the other
Nafion® membranes. The current sales forecast shows that in calendar year 2021, the Nafion®
2050 membrane will become the major Nafion® membrane sold by Chemours.
To allow the membrane extrusion and production processes to operate normally, the Membrane
Coating Process must double the application rate of the coating when spraying the Nafion®
2050 membrane. This will be accomplished by increasing the number of spray guns in the IXM
Membrane Coating Process' spray booth from two to four.
VOLATILE ORGANIC COMPOUNDS (VOC) EMISSIONS
The zirconium/resin is applied to the membrane as a dispersion in a mixture of ethanol and
propanol. A small amount of a high molecular weight surfactant (Triton X-100) is added to
improve the wettability of the coating on the membrane, however this surfactant has a negligible
vapor pressure. Therefore all VOC emissions are exclusively from the evaporation of the
alcohols, which make up 81.79% by weight the total mass of the sprayed coating.
The potential -to -emit was determined by assuming that all four spray guns are spraying at their
maximum flow rate (200 ml/minute) continuously for 8,760 hours/year. This maximum
spraying rate equates to 367.73 tons of VOC per year as the potential -to -emit. That emission
rate is of course impractical because it is impossible for this facility to produce enough
membrane for that amount of coating.
The baseline actual emissions were determined by the highest two consecutive years as reported
in this site's annual air emissions inventory report. That two-year average was for calendar
years 2014 and 2015 and was 28.99 tons VOC per year.
The projected actual emission rate is determined by using the highest forecasted production,
which is 203,989 square meters of coated membrane in 2021, and the anticipated product split
of 80% of the Naflon® 2050 membrane and 20% for all other Nafion® membranes. Using the
current coating application rates for the two families of membrane results in a VOC emission
rate of 64.19 ton/year for the Spray Booth operation. The inclusion of the expected emissions
DEQ-CFW 00065857

Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
October 27, 2016
Page 3 of 5
from the three tanks in the Membrane Coating Process brings the total projected actual
emissions to 67.27 tons of VOC per year.
Therefore, the actual -to -projected -actual emissions increase is 38.28 tons VOC per year.
Chemours proposes the following new section be added to Section 2.1(C) "FPS/IXM Process
Area" that addresses the PSD avoidance condition for the IXM Membrane Coating Process:
7. 15A NCAC 02D .0530(u): USE OF PROJECTED ACTUAL EMISSIONS TO AVOID
APPLICABILITY OF REQUIREMENTS OF PSD
a. The Permittee has used projected actual emissions to avoid applicability of prevention of
significant deterioration requirements pursuant to application [enter application
number] for the Spray Coating Throughput Increase Project, consisting of an expansion
in the capacity of the spray coating process within the IXM Membrane Coating Process
(ID No. NS-I). In order to verify the assumptions used in the projected actual emissions
calculations, the Permittee shall comply with the requirements in Section 2.1 C.7.b, below.
Monitorin2/Recordkeepin2/Reportin2 [15A NCAC 02D .0530(u) and 2Q .0308]
b. The Permittee shall perform the following:
i. Upon commencement of regular operation of the modified unit, the Permittee shall
maintain records of annual VOC and emissions from the IXM Membrane Coating
Process (ID No. NS-I) in tons per year, on a calendar year basis related to the Spray
Coating Throughput Increase Project. The Permittee shall calculate these annual
emissions for five years following startup of regular operations of the modified unit.
ii. The Permittee shall submit a report to the director within 60 days after the end of each
calendar year during which these records must be generated. The report shall contain
the items listed in 40 CFR 51.166(r)(6)(v)(a) through (c).
iii. The Permittee shall make the information documented and maintained under this
condition available to the Director or the general public pursuant to the requirements
in 40 CFR 70.4(b)(3)(viii).
iv. The Permittee shall provide a comparison of the reported actual emissions (post -
construction emissions) for each of the five calendar years to the projected actual
emissions (pre -construction projection) as included below:
Pollutant
Projected Actual Emissions*
(tons per ear)
vOC
67.27
* 1 nese projections are noI enIorccame 1un11auutls, It Nt.vJcctcu -1
exceeded, consistent with 15A NCAC 02D .0530, the Permittee shall include,
in its annual report, an explanation as to why the actual rates exceeded the
projection.
DEQ-CFW 00065858

Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
October 27, 2016
Page 4 of 5
Due to the insertion of the above new subsection, the remaining subsection of Section 2.1 C
would need to be renumbered from 2.1 C.7 to 2.1 C.8, which would then read as follows:
8. 15A NCAC 02D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
(MACT), 40 CFR 63, Subpart FFFF: NESHAP for Miscellaneous Organic Chemical
Manufacturing (MON)
PARTICULATE MATTER (PM) EMISSIONS
The coating is a dispersion of zirconium oxide and SR resin in a mixture of ethanol and propanol
along with a small amount of a high molecular weight surfactant (Triton X-100). The PM
emissions would be exclusively from the zirconium oxide, the SR resin, and the Triton X-100
surfactant, which make up 16.68% by weight the total mass of the sprayed coating.
The spray booth utilizes paint arrestor filters; currently a double -layer of the Research Products
Spra-Gard Paint Arrestors Model 3232. These paint arrestor filters are an integral part of the
proper spray booth operation by preventing dust and overspray from re -circulating within the
booth and affecting the quality of the finish. In addition, flammable or explosive conditions
could be created if volatile vapors collected within the closed space. Also, the paint arrestor
filters keep the exhaust stack and fan free of overspray build-up, thereby ensuring that the
exhaust system properly removes the VOC vapors from the spray booth.
Pursuant to 15A NCAC 02Q.0 I 02(h)(3), filters that are an integral part of the paint spray booth
are not considered air pollution control devices.
The Spra-Gard Paint Arrestors Model 3232 were tested by LMS Technologies, Inc., to
determine the filters' spray removal efficiency and paint holding capacity. Testing of a single
layer of the filter showed that it was 99.37% efficient in removing the paint spray droplets from
a conventional air gun. Testing of a double layer of the filters showed that they were 99.77%
efficient in removing the paint spray droplets. The Paint Arrestance Filter Test Reports are
included as part of the Form D5 supporting documentation.
A visual observation was made of the residue left on a metal laboratory pan after the alcohols
had evaporated from the coating. The residue was a solid material that resembled dried latex
paint. It was readily obvious that the SR resin binds with the zirconium oxide and prevents the
zirconium from being easily friable. As a result of this observation, it is very reasonable to
assume that the arrestor filters capture efficiency for PM would be equal to the spray removal
efficiency of the filters.
Even though the IXM Membrane Coating Process' spray booth uses a double layer of the
Model 3232 paint arrestors and a 99.77% spray removal efficiency would be appropriate, to be
conservative the calculations in this application has assumed only a 98% efficiency.
DEQ-CFW 00065859

Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
October 27, 2016
Page 5 of 5
The potential -to -emit for PM was determined by assuming that all four spray guns are spraying
at their maximum flow rate (200 ml/minute) continuously for 8,760 hours/year. It was also
assumed that none of the coating was applied to the membrane, but rather the coating was
merely sprayed continuously into the spray booth. This worst -case scenario equates to a
potential -to -emit of 1.50 tons of PM per year, 0.81 tons PMio per year, and 0.62 tons PM2.5 per
year. Each of these emission rates are well less than the PSD significant emission rates listed
in 40 CFR 51.166(b)(23)(i), therefore the Prevention of Significant Deterioration rule (15A
NCAC 02D.0530) does not apply.
The emissions of particulates from miscellaneous industrial processes is regulated and limited
under 15A NCAC 02D.0515(a). For process rates less than or equal to 30 tons per hour, the
allowable emission rates for particulate matter from any stack, vent or outlet cannot exceed the
level calculated with the following equation:
E = 4.10(P)0.61
where "E" equals the maximum allowable emission rate for particulate matter in pounds per
hour and "P" equals the process rate in tons per hour. The projected actual emissions basis is
the forecasted 2021 production of 203,989 in of coated membrane, which would require
156,951 lb. of coating to be sprayed during 4,380 hours/year. This equates to a process rate of
0.0179 ton/hr and a calculated allowable emission rate of 0.277 lb. PM per hour. The projected
actual PM emissions were determined to be 0.072 lb. PM per hour. Therefore this requested
modification complies with 15A NCAC 02D.0515(a).
If you should have any questions additional or need additional information regarding this permit
modification request, please contact me at [phone].
Environmental Manager
Enclosures
DEQ-CFW 00065860

Zoning Consistency Determination
Facility Name
Facility Street Address
Facility City
Description of Processes
SIC Code/NAICS
Facility Contact
Phone Number
Mailing Address
Mailing City, State Zip
Chemours Company — Fayetteville Works
22828 NC Highway 87 W
Duart Township, Bladen County, North Carolina
Spray Coating Throughput Increase Project
2869 / 325120
Michael E. Johnson, PE
[phone]
22828 NC Highway 87 W
Fayetteville, NC 28306-7332
Based on the information given above:
Q I have received a copy of the air permit application (draft or final) AND...
Q The proposed operation IS consistent with applicable zoning and subdivision ordinances
Agency
Name of Designated Official
Title of Designated Official
Signature
Date
Bladen County Planning Department
Greg Elkins
Planning Director
10
k
Please forward to the mailing address listed above and the air quality offices listed below:
Attn: William Willets, PE
NCDEQ — Division of Air Quality
Permitting Section
1641 Mail Service Center
Raleigh, NC 27699-1641
Mr. Steven F. Vozzo
NCDEQ — Division of Air Quality
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, NC 28301
DEQ-CFW 00065861

FORM AA
ADMINISTRATIVE APPLICATION (GENERAL INFORMATION) �
1nc�n nn— ion NrOI K w 1
nF�nivicinn of Air Oualitv - Aoolication for Air Permit to Construct/Operate
NOTE- APPLICATION WILL NOT BE PROCESSED WITHOUT THE.FOLLOWINGt:
❑ Local Zoning Consistency Determination (new or ❑ Appropriate Number of Copies of Application ❑ Application Fee (if required)
modification only)
❑� Responsible Official/Authorized Contact Signature ❑ P.E. Seal (if required)
- GENERAL INFORMATION
Legal Corporate/Owner Name: The Chemours Company FC, LLC
site Name: Chemours Company - Fayetteville Works
Site Address (911 Address) Line 1: 22828 NC Highway 87 W
Site Address Line 2:
City: Fayetteville
State: North Carolina
Zip Code: 28306-7332
County: Bladen
CONTACT INFORMATION
Responsible Official/Authorized Contact:
Invoice Contact:
Namerritle: Ellis H. McGaughy / Plant Manager
NameiTitle: Michael E. Johnson / Environmental Manager
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 2:
Mailing Address Line 2:
City: Fayetteville State: North Carolina Zip Code: 28306-7332
City: Fayetteville State: NC Zip Code: 28306-7332
Primary Phone No.: 910-678-1224
Fax No.: 910-678-1267
Primary Phone No.: 910-678-1156
Fax No.: 910-678-1267
Secondary Phone No.:
Secondary Phone No.: 910-489-6436
Email Address: [e-mail]
Email Address: [e-mail]
Facility/Inspection Contact:
Permit/Technical Contact:
Namerfitle: Michael E. Johnson / Environmental Manager
Namerritle: Michael E. Johnson / Environmental Manager
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 2:
Mailing Address Line 2:
City: Fayetteville State: North Carolina Zip Code: 28306-7332
City: Fayetteville State: NC Zip Code: 28306-7332
Primary Phone No.: 910-678-1165
Fax No.: 910-678-1267
Primary Phone No.: 910-678-1155
1Fax No.: 910-678-1267
Secondary Phone No.: 910-489-6436
Secondary Phone No.: 910-489-64,
Email Address: [e-mail]
Email Address: [e-mail]
APPLICATION IS BEING MADE FOR
❑ New Non -permitted Facility/Greenfield 0 Modification of Facility (permitted) ❑ Renewal Title V ❑ Renewal Non -Title V
❑ Name Change ❑ Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification
FACILITY CLASSIFICATION AFTER APPLICATION (Check Only One):_-,
❑ General ❑ Small ❑ Prohibitory Small ❑ Synthetic Minor 0 Title V
FACILITY (Plant Site) INFORMATION
Describe nature of (plant site) operation(s):
Chemical and plastic resin manufacturing.
Facility ID No. 090009
Primary SIC/NAICS Code: 326113
Current/Previous Air Permit No. 03735T42 Expiration Date: 03-31-2021
Facility Coordinates: Latitude: 34 deg. 50 min. 38 sec.
Longitude: -78 deg. 50 min. 13 sec.
***If yes, please contact the DAQ Regional Office prior to submitting this
Does this application contain ❑ YES 0 NO application..*** (See Instructions)
confidential data?
PERSON OR FIRM THAT PREPARED APPLICATION '
Person Name: Michael E. Johnson
Firm Name:
Mailing Address Line 1: 22828 NC Highway 87 W
Mailing Address Line 2:
City: Fayetteville
State: NC
Zip Code: 28306-7332 County: Bladen
Phone No.: 910-678-1165
Fax No.: 910-678-1267
Email Address: [e-mail]
SIGNAT RE OF RESPONSIBLE OFFICIALIAUTHORIZED CONTACT
Name (typed): Ellis H. McGaughy Title: Plant Manager
X Signature(Blue Ink): �, Date:
r
l AttaEflhpt di Tonal Sheets As Necessary rage t or c
DEQ-CFW 00065862

FORM AA (continued, page 2 of 2)
ADMINISTRATIVE APPLICATION
w•nc—ni..iei... f Air fhmlih, -A nnlirafinn fnr Air Permit to Construct/Ooerate
(Company Name) hereby formally requests renewal of Air Permit No.
There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
Is your facility subject to 40 CFR Part 66 "Prevnetion of Accidental Releases" - Section 112(r) of the Clean Air Act? ❑ YES ❑ NO
If yes, have you already submitted a Risk Manage Plan (RMP) to EPA? ❑ YES ❑ NO Date Submitted:
Did you attach a current emissions inventory? ❑ YES ❑ NO
If no, did you submit the inventory via AERO or by mail? ❑ Via AERO ❑ Mailed Date Mailed:
APPLICATION FOR TITLE �/ PEIiAIIIT RENEWALa
In accordance with the provisions of Title 15A 2Q .0513, the responsible official of (Company Name)
hereby formally requests renewal of Air Permit No. (Air Permit No.) and further certifies that:
(1) The current air quality permit identifies and describes all emissions units at the above subject facility, except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 2Q .0500;
(2) The current air quality permit tits all applicable requirements and provides the method or methods for determing compliance with the applicable
requirements;
(3) The facility is currently in compliance, and shall continue to comply, with all applicable requiremetns. (Note: As provided under 15A NCAC 2Q .0512
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit);
(4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis;
(5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64.
The responsible official (signature on page 1) certifies under the penalty of law that all information and statements provided above, based on information and belief
formed after reasonable inquiry, are true, accurate, and complete.
t�� a + 3 +a z SECTION A�43= A�PLICi4TION FOR i4ME4C}IAPIGE mwe
New Facility Name:
Farmer Facility Name:
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been
modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if ther has been an ownership change
associated with this name change.
`"SECTION AA4=APPLICATION FOR 4N.O.WNERSHIP CHANOE`
By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below.
The transfer of permit responsibility, coverage and liability shall be effective (immediately or insert date.) The legal ownership of the
facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally
permitted facility that would require an air quality permit since the last permit was issued.
Signature of New (Buyer) Responsible Official/Authorized Contact (as typed on page 1):
X Signature (Blue Ink):
Date:
New Facility Name:
Former Facility Name:
Signature of Former (Seller) Responsible Official/Authorized Contact:
Name (typed or print):
Title:
X Signature (Blue Ink):
Date:
Former Legal Corporate/Owner Name:
In lieu of the seller's signature on this form, a letter may be submitted with the seller's signature indicating the ownership change
SECTION AA S aAP..PLICATIO.N FWAOMINISTRATIVElAMEWAENT
Describe the requested administrative amendment here (attach additional documents as necessary):
Attacrl AQOIiIOnal Jrieui5 Hs rvrrcraaary a— — —
DEQ-CFW 00065863

FORMS A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION - A2
112r APPLICABILITY INFORMATION - A3
REVISED 06/01/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate A2
EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted
EMISSION SOURCE EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE
ID NO. DESCRIPTION ID NO. DESCRIPTION
Equipment To Be ADDED ByThis'Application (New; Previously Unpermitted; or Replacement)
Existing Permitted Equipment To Be MODIFIED By This Application
NS-I IXM Membrane Coating Process none none
Equipment To Be DELETED By This Application
112(r) APPLICABILITY INFORMATION
A 3
Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases" - Section 112(r) of the Federal Clean Air Act?
(] Yes ❑ No
If No, please specify in detail how your facility avoided applicability:
If your facility is Subject to 112(r), please complete the following:
A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 66.10 or Part 68.150?
� Yes ❑ No Specify required RMP submittal date: June 30, 1999 If submitted, RMP submittal date: June 8, 1999
B. Are you using administrative controls to subject your facility to a lesser 112(r) program standard? RMP resubmitted 08-18-2014
❑ Yes [A No If yes, please specify:
C. List the processes subject to 112(r) at your facility:
PROCESS DESCRIPTION
PROCESS LEVEL
(1, 2, or 3)
HAZARDOUS CHEMICAL
MAXIMUM INTENDED
INVENTORY (LBS)
RSU (S03) Process
TFE/CO2 Separation Process
3
1
Sulfur trioxide
Tetrafluoroethylene
59,400
61,000
Attach Additional Sheets As Necessary
DEQ-CFW 00065864

FORM B
SPECIFIC EMISSION SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 06/01 /1 R NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate 1
EMISSION SOURCE DESCRIPTION:
IXM Membrane Coating Process
OPERATING SCENARIO 1 OF 1
EMISSION SOURCE ID NO: NS-1
CONTROL DEVICE ID NO(S): NONE
EMISSION POINT (STACK) ID NO(S): NEP-1
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Chemours NafionTM membranes are surface coated with a mixture of zirconium oxide (Zr02) and a fluoro-
polymer resin to improve the performance of the finished product. The solvent for the coating is a mixture of
ethanol and propanol. The coating is applied in a spray booth via four (4) air atomization spray guns in a non•
continuous operation. See attached flow diagram following this form.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1-B9 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil, gas, other burner (Form 131) ❑ Woodworking (Form 64) ❑ Manuf. of chemicals/coatings/inks (Form B7)
❑ Int.combustion engine/generator (Form 62) 2 Coating/finishing/printing (Form 65) ❑ Incineration (Form B8)
❑ Liquid storage tanks (Form B3) ❑ Storage silos/bins (Form 66) ❑ Other (Form 139)
START CONSTRUCTION DATE: December 2016 DATE MANUFACTURED: Unknown
MANUFACTURER / MODEL NO.: DeVllbiss AGX-550 EXPECTED OP. SCHEDULE: _24_ HR/DAY _5_ DAY/WK _36_ WK/YR
IS THIS SOURCE SUBJECT TO? ❑ NSPS (SUBPARTS?): NO Lj NESHAP (SUBPARTS?):
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25% MAR -MAY 25% JUN-AUG 25% SEP-Nov 25%
CRITERIA AIR 'POLLUTANTfMISSIONS%NFORMATIONFOR
THIS SOURCE ;
AIR POLLUTANT EMITTED
PARTICULATE MATTER (PM)
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
POTENTIAL EMISSIONS
(AFTER CONTROLS / LIMITS)
(BEFORE CONTROLS / LIMITS)
(AFTER CONTROLS / LIMITS)
Ib/hr
0.07
tons/yr
0.16
Ib/hr
0.21
tons/yr
0.90
Ib/hr
0.21
tons/yr
1.50
PARTICULATE MATTER<10 MICRONS (PM,o)
0.03
0.14.
0.19
0.81
0.19
0.81
PARTICULATE MATTER<2.5 MICRONS (PM2.$)
0.02
0.11
0.14
0.62
0.14
0.62
SULFUR DIOXIDE (S02)
0
0
0
0
0
0
NITROGEN OXIDES (NOx)
0
0
0
0
0
0
CARBON MONOXIDE (CO)
0
0
0
0
0
0
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
30.72
0
67.27
0
83.96
0
367.73
0
83.96
0
367.73
0
OTHER
0
1 0
0
0
0
0
HAZARDOUS AIR
POLLUTANT EMISSIONS INFORMATION
FOR THIS. SOURCE. '... .
HAZARDOUS AIR POLLUTANT
CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
POTENTIAL EMISSIONS
(AFTER CONTROLS / LIMITS)
(BEFORE CONTROLS / LIMITS)
(AFTER CONTROLS / LIMITS)
Ib/hr
tons/yr
Ib/hr
tons/yr
Ib/hr
tons/yr
None
TOXIC AIR
POLLUTANT EMISSIONS INFORMATION
FOR
THIS.SOURCE
TOXIC AIR POLLUTANT
CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS
Ib/hr
lb/day
Ib/yr
None
Attachments: (1) emissions calculations and supporting documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates)
and describe how these are monitored and with what frequency; and (3) describe any monitoring devices, gauges, or test ports for this source.
COMPLETE THIS FORM AND COMPLETE AND A7 I ACH APPROPFWA it: 81 rlrrwvn tsy rvrvvi rvR cH�.n J V VR.,L
Attach Additional Sheets As Necessary
DEQ-CFW 00065865

NITROGEN
ETHANOL
1-PROPANOL
2-PROPANOL
SR RESIN
Zr02 --►
TRITON X-100 -�
IXM Membrane Coating Process
ID No. NS-1
Flow Diagram
NEP-IA
ATMOSPHERE
CV/FA
BINDER
STORAGE
TANK
HI -SPEED
DISPERSION
TANK
PAINT
STORAGE
TANK
VENT
TO
ROOM
VENT
TO
ROOM
CV/FA I CONSERVATION VENT/FLAME ARRESTOR
C-► SPRAY GUN
AIR
COATED
NAFION®
MEMBRANE
i
i
i
UNCOATED
NAFION®
MEMBRANE
NEP-IB
ATMOSPHERE
BLOWER
MEMBRANE
COATING
SPRAY BOOTH
DEQ-CFW 00065866

FORM B5
oc�necnnciniiia EMISSION SOURCE (COATINGoFANPSHING/PRINermit to tTIING) B5
EMISSION SOURCE DESCRIPTION:
IXM Membrane Coating Process
EMISSION SOURCE ID NO: NS-1
CONTROL DEVICE ID NO(S): None
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(S): NEP-1
TYPE OF OPERATION: ❑ PRINTING [21 COATING ❑ OTHER FINISHING (Describe in process)
IS THIS OPERATION: ❑ CONTINUOUS (] NON -CONTINUOUS (Batch)
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Chemours NafionTI membranes are surface coated with a mixture of zirconium oxide and a fluoropolymer to
improve the performance of the finished product. The solvent for the coating is a mixture of ethanol, 1-propanol,
and 2-propanol. The coating is applied in a spray booth via four (4) air atomization spray guns in a non -continuous
operation. See attached flow diagram following this form.
WHAT IS BEING PRINTED/COATED/OR FINISHED? Nafion"Im membranes
CONTINUOUS_ TYPE OF PRINTING/COATING: ❑ FLEXOGRAPHIC ❑ ROTOGRAVURE ❑ LITHOGRAPHIC ❑ OFFSET
❑ OTHER (PLEASE SPECIFY):
NON CONTINUOUS ' `' TYPE OF SOURCE: ❑ STATION i] BOOTH ❑ WASH -OFF TANK ❑ OFFSET ❑ DIP TANK
❑ OTHER (PLEASE SPECIFY):
METHOD OF SPRAY: ❑ AIRLESS 21 AIR ATOMIZE ❑ ELECTROSTATIC ❑ HVLP ❑ OTHER (SPECIFY)
TRANSFER EFFICIENCY: 40%
EXHAUST CONTROL: ❑ NONE O DRY FILTER ❑ WATER WASH ❑ BAFFLES ❑ OTHER (SPECIFY)
PARTICULATE CAPTURE/FILTER EFFICIENCY: 98%
COATING/$OLVENLUSE,(If1CLUDE MSDS FOR EACI (MATERIAL) „
ACTUAL USAGE
MAXIMUM DESIGN CAPACITY
STATION NO.
COATING/SOLVENT/INK PRODUCT NAME AND FORMULA
NUMBER APPLIED AT THIS STATION/SOURCE
UNIT/HR
UNIT/YR
UNIT/HR
UNIT/YR
UNITS
1
Ethanol
10.45
45,770
29.93
262,217
pounds (lb.)
1
1-propanol
1.34
5,868
3.84
33,618
pounds (lb.)
1
2-propanol
17.52
76,736
50.19
439,622
pounds (lb.)
1
Triton X-100 (octyl phenol ethoxylate)
0.03
119
0.08
680
pounds (lb.)
1
Zirconium oxide
5.41
23,706
15.50
135,814
pounds (lb.)
1
Water
0.55
2,406
1.57
13,783
pounds (lb.)
1
1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-
[1,1,1,2,3,3-hexafluoro-3-(1,2,2-trifluoroethen-
oxy)propan-2-yl]oxy-ethanesulfonyl fluoride
polymer
0.54
2,347
1.54
13,447
pounds (lb.)
CLEAN-UP
2-propanol
0.40
1,704
0
0
pounds (lb.)
ATTACH ADDITIONAL SHEETS AS NEEDED
METHOD OF HEATING: ❑ STEAM ❑ DIRECT FIRED ❑ ELECTRIC ❑ OTHER (SPECIFY)
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
COMMENTS:
"Actual Usage" is based on the Projected Actual basis for this permit modification application. "Maximum Design
Capacity" is based on the Potential -to -Emit basis for this application.
Attach Additional Sheets As Necessary
DEQ-CFW 00065867

FORM D1
GAr_II ITv_WlnF FMIRSInNS Sl1MMARY
REVISED 06/01/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate D1
FLa- Rom
SF,,�ONFL
EXPECTED ACTUAL
EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(BEFORE CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
AIR POLLUTANT EMITTED
tons/yr
tons/yr
tons/yr
PARTICULATE MATTER (PM)
_ 10
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
PARTICULATE MATTER < 10 MICRONS (PM10)
— 10
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
PARTICULATE MATTER < 2.5 MICRONS (PM2.5)
^ 10
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
SULFUR DIOXIDE (SO2)
6
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
NITROGEN OXIDES (NOx)
— 80
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
CARBON MONOXIDE (CO)
— 50
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
VOLATILE ORGANIC COMPOUNDS (VOC)
— 360
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
LEAD
< 1
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
GREENHOUSE GASES (GHG) (SHORT TONS)
- 711,475 (CO2e)
Unchanged (site is
Major Source)
Unchanged (site is
Major Source
OTHER
"' HAZADOUSf�O� LU9TTEAl113S10SORMA4TIONILIfV1/ODE;
EXPECTED ACTUAL
EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(BEFORE CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
HAZARDOUS AIR POLLUTANT EMITTED
CAS NO.
tons/yr
tons/yr
tons/yr
Total HAPs (facility -wide)
>25
site is Major Source
>25
site is Major Source
>25
site is Major Source
The requested modification will not emit
any Hazardous Air Pollutants
T05Q(ili2,;,Q�?4'1ElISS
RS?l.f.0.l�ION��AI�
`p
INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (TPER) IN 15A
NCAC 2Q .0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY.
Modeling Required ?
TOXIC AIR POLLUTANT EMITTED
CAS NO.
Ib/hr
lb/day
lb/year
Yes
No
The requested modification will not emit
any Toxic Air Pollutants
X
COMMENTS:
The requested modification will not emit any Hazardous Air Pollutants or Toxic Air Pollutants.
Attach Additional Sheets As Necessary
DEQ-CFW 00065868

FORM D2
ells Pnl I I ITANT NFTTING WORKSHEET AND FACILITY -WIDE EMISSION SUMMARY
REVISED 06/01/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate D2
PURPOSE OF NETTING: AIR TOXICS There are no TAP emissions from the IXM Membrane Coating Process (ID No. NS-1)
TOXIC AIR POLLUTANT: CAS NO.:
EMISSION SOURCE ID NOS.:
se o EMISSIONS - USE APPROPRIATE COLUMNS ONLY
o s LB/YEAR LB/DAY LB/HR
MODIFICATION
INCREASE
- MINUS -
- MINUS -
- MINUS -
- MINUS -
MODIFICATION
DECREASE
= EQUALS =
= EQUALS =
= EQUALS =
= EQUALS =
NET CHANGE
FROM MODIFICATION
y • � ��` �
,SECTiOB - FA(�IL '! D�EMI,�
SS
CREDITABLE
INCREASE
MINUS -
MINUS -
MINUS -
MINUS -
CREDITABLE
DECREASE
= EQUALS =
= EQUALS =
= EQUALS =
= EQUALS =
NET CREDITABLE
CHANGE
�,�
SEGfONGCA(.L
_ p _ .SSIOI�iS f:
r, }
TOTAL FACILITY
EMISSIONS
TPER LEVELS (2Q .0711)
Are the total facility -wide emissions less than the TPER levels?: ❑ YES ❑ NO
If YES, no further analysis is required.
Air dispersion modeling analysis is required if the total facility -wide emission level is greater than the 2Q .0711 Toxic Air Pollutant Permitting Emissions Rate
(TPER) and the source emitting the toxic air pollutant is not exempted by 15A NCAC 2Q .0702(a)(27) "Exemptions".
CHECK HERE IF AN AIR DISPERSION MODELING ANALYSIS IS REQUIRED ❑
If air dispersion modeling analysis is required, complete the stack parameters section of Form D3-1 for each emission source that emits this TAP. Review the
modeling plan requirements.
COMMENTS:
Attach Additional Sheets As Necessary
DEQ-CFW 00065869

FORM D2A
AIR POLLUTANT "PROJECT ONLY" NETTING WORKSHEET
DFvicGn nrin114A NnnFnmivisinn of Air Quality - Aoolication for Air Permit to Construct/Operate 132A
PURPOSE OF NETTING: PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
PSD AIR POLLUTANT: Volatile Organic Compounds (VOC)
EMISSION SOURCE ID NO. AND DESCRIPTION: ID NO. NS-1 : IXM Membrane Coating Process
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
SECTION A @EMISSION OFFSETTING ANALYSIS FOR MODIFIED/NEW SOURCES IN PROJECT F
� Summa✓rise in this section � }�� '�� � '
using the B forms ..
EMISSIONS
TONSIYR
MODIFICATION INCREASE
38.28
- MINUS -
MODIFICATION DECREASE
0
= EQUALS =
"PROJECT" NET CHANGE FROM MODIFICATION
38.28
PSD SIGNIFICANCE LEVEL FOR SPECIFIC POLLUTANT [40 CFR 51.166(b)(23)]
40
IS THE "PROJECT' NET CHANGE LESS THAN THE SIGNIFICANCE LEVEL? �' YES ❑ NO
If YES, no further analysis is required.
If NO, then a further evaluation should be done using creditable emissions at the facility for each specific pollutant over a contemporaneous time period.
COMMENTS:
The VOC increase from this modification is the difference between the IXM Membrane Coating Process' historical
baseline actual emissions of 28.99 tons/year and the projected actual emissions of 67.27 tons/year.
Attach Additional 5neets As Necessary
DEQ-CFW 00065870

FORM D2A
AIR POLLUTANT "PROJECT ONLY" NETTING WORKSHEET
uencniniulainn of Air Oualitv - Annliration for Air Permit to Construct/ODerate D2A
PURPOSE OF NETTING: PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
PSD AIR POLLUTANT: Particulate Matter (PM)
EMISSION SOURCE ID NO. AND DESCRIPTION: ID No. NS-1 IXM Membrane Coating Process
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
SECTION A EMISSION OFFSETTING `ANALYSIS FOR MOQiFIED/NEVIi SOURCES IN PROJECT
i
Sumima a In this section t " ��
>Sg
EMISSIONS
n'b
�
TONS/YR
+using the'B fortes
MODIFICATION INCREASE
0
- MINUS -
MODIFICATION DECREASE
0.16
= EQUALS =
"PROJECT" NET CHANGE FROM MODIFICATION
-0.16
PSD SIGNIFICANCE LEVEL FOR SPECIFIC POLLUTANT [40 CFR 51.166(b)(23)I
25
IS THE "PROJECT" NET CHANGE LESS THAN THE SIGNIFICANCE LEVEL? ❑� YES NO
If YES, no further analysis is required.
If NO, then a further evaluation should be done using creditable emissions at the facility for each specific pollutant over a contemporaneous time period.
COMMENTS:
The reduction of PM emissions is due to a difference in the assumed spray removal efficiency of the paint arrestor
filters that are an integral part of the spray booth operation.
The Baseline Actual Emissions were based on an assumed 95% spray removal efficiency of the paint arrestor filters.
This removal efficiency assumption resulted in 0.32 tons PM per year as being the greatest emissions of PM during two
consecutive years within the 5-year period immediately preceding this permit application.
The Projected Actual Emissions are based on a conservative 98% removal efficiency, versus the current paint arrestor
filter's spray removal efficiency of 99.77% for the double layer of arrestor filters that is actually used. This removal
efficiency assumption results in 0.16 tons PM per year as being the estimate of PM emissions during the greatest
production level during the next five years.
Attach Additional Sheets As Necessary
DEQ-CFW 00065871

FORM D2A
AIR POLLUTANT "PROJECT OaoNEP TNGWORKSH EET
Dc/CCnna,n1,9 3nootoforAir mcorD2A
PURPOSE OF NETTING: PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
PSD AIR POLLUTANT: Particulate Matter <10 micron (PM10)
EMISSION SOURCE ID NO. AND DESCRIPTION: ID No. NS-I IXM Membrane Coating Process
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
-S CTO ION AC E ISSIO OFFSETTING ANALYSIS4FOR MMO IFS IEDINEW SOURCES IN PROJECT
K y .ft
OPT EMISSIONS
summarize in MIS sectionrr
TONSIYR
a using the I fo' ns ' ,
_ ..
MODIFICATION INCREASE
0
- MINUS -
MODIFICATION DECREASE
0.15
= EQUALS =
"PROJECT" NET CHANGE FROM MODIFICATION
-0.15
PSD SIGNIFICANCE LEVEL FOR SPECIFIC POLLUTANT [40 CFR 51.166(b)(23)] 15
IS THE "PROJECT" NET CHANGE LESS THAN THE SIGNIFICANCE LEVEL? El YES NO
If YES, no further analysis is required.
If NO, then a further evaluation should be done using creditable emissions at the facility for each specific pollutant over a contemporaneous time period.
COMMENTS:
The reduction of PM10 emissions is due to a difference in the assumed spray removal efficiency of the paint arrestor
filters that are an integral part of the spray booth operation.
The Baseline Actual Emissions were based on an assumed 95% spray removal efficiency of the paint arrestor filters.
This removal efficiency assumption resulted in 0.29 tons PM10 per year as being the greatest emissions of PM10 during
two consecutive years within the 5-year period immediately preceding this permit application.
The Projected Actual Emissions are based on a conservative 98% removal efficiency, versus the current paint arrestor
filter's spray removal efficiency of 99.77% for the double layer of arrestor filters that is actually used. This removal
efficiency assumption results in 0.14 tons PM10 per year as being the estimate of PM70 emissions during the greatest
production level during the next five years.
Attach Additional sneers AS Necessary
DEQ-CFW 00065872

FORM D2A
AIR POLLUTANT "PROJECT ONLY" NETTING WORKSHEET
\IICCtI ACI(1414 C ucnr=nlnivi�hn of Air nuanty - Annliration for Air Permit to Construct/Overate D2A
PURPOSE OF NETTING: PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
PSD AIR POLLUTANT: Particulate Matter <2.5 micron (PM2.5)
EMISSION SOURCE ID NO. AND DESCRIPTION: ID No. NS-1 IXM Membrane Coating Process
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
EMISSION SOURCE ID NO. AND DESCRIPTION:
OFFSETTING ANALYSIS MODIFIED/NEW
SOURCES IN PROJECT
-SECTION A EMISSION ,OR
s Summanze IIn this 'section < `
�����,�
EMISSIONS
T ,
TONSNR
using the B forms , -. =f
MODIFICATION INCREASE
0
- MINUS -
MODIFICATION DECREASE
0.11
= EQUALS =
"PROJECT" NET CHANGE FROM MODIFICATION
-0.11
PSD SIGNIFICANCE LEVEL FOR SPECIFIC POLLUTANT [40 CFR 51.166(b)(23)] 10
IS THE "PROJECT" NET CHANGE LESS THAN THE SIGNIFICANCE LEVEL? El YES ❑ NO
If YES, no further analysis is required.
If NO, then a further evaluation should be done using creditable emissions at the facility for each specific pollutant over a contemporaneous time period.
COMMENTS:
The reduction of PM2.5 emissions is due to a difference in the assumed spray removal efficiency of the paint arrestor
filters that are an integral part of the spray booth operation.
The Baseline Actual Emissions were based on an assumed 95% spray removal efficiency of the paint arrestor filters.
This removal efficiency assumption resulted in 0.22 tons PM2.5 per year as being the greatest emissions of PM2.5 during
two consecutive years within the 5-year period immediately preceding this permit application.
The Projected Actual Emissions are based on a conservative 98% removal efficiency, versus the current paint arrestor
filter's spray removal efficiency of 99.77% for the double layer of arrestor filters that is actually used. This removal
efficiency assumption results in 0.11 tons PM2.5 per year as being the estimate of PM2.5 emissions during the greatest
production level during the next five years.
Attach Additional Sheets As Necessary
DEQ-CFW 00065873

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
aG�ncFn MMI11a NcnFOInivision of Air Qualitv - Anolication 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 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).
l attest that this application for
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. l 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 l 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
R95 nnn nar vinlatinn
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME:
DATE:
COMPANY:
ADDRESS:
TELEPHONE:
SIGNATURE:
PAGES CERTIFIED:
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional sheets As Necessary
DEQ-CFW 00065874

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-1)
Spray Coating Throughput Increase Project
Potential Emissions (Before Control / Limits)
Basis and Assumptions:
(1) Four spray guns operating continuous at their maximum flow capacity
(2) Maximum flow capacity of one spray gun is 200 mL/minute
(3) Density of the coating is 0.97 kg/L
(4) Coating composition (worst -case composition resulting in highest VOC emissions):
29.16% Ethanol
3.74% 1-propanol
48.89% 2-propanol
0.08% Triton X-100 (octyl phenol ethoxylate)
15.10% Zirconium oxide (ZrO2)
1.53% Water
1.50% SR Resin [1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexa-
fluoro-3-(1,2,2-trifluoroethen-oxy)propan-2-yi]oxy-ethanesulfonyl fluoride]
(5) Coating composition is 81.79% VOC by weight (sum of the alcohols)
(6) All VOC is emitted to the atmosphere; 0% capture / control
(7) Coating composition is 16.68% PM by weight (Triton X-100, ZrO2, and SR Resin)
(8) The current paint arrestor filter spray removal efficiency is 99.37% for a single layer and
99.77% for a double layer of arrestor filters. While two layers are actually used in the Spray
Booth, a 98% removal efficiency will be used for the particulate matter estimation.
Total Potential Emissions
200 mL coating / minute / spray gun
0.200 L coating / minute / spray gun
0.97 kg / L (density of coating)
0.194 kg coating / minute / spray gun
0.428 lb. coating / minute / spray gun
4 spray guns
1.711 lb. coating / minute sprayed into the Spray Booth
899,181 lb. coating / year sprayed into the Spray Booth
VOC Potential Emissions
899,181 lb. coating / year sprayed into the Spray Booth
81.79% ib. VOC / lb. coating
735,456 lb. VOC / year
367.73 ton VOC / year
83.96 lb. VOC / hour
DEQ-CFW 00065875

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-1)
Spray Coating Throughput Increase Project
Potential Emissions (Before Control / Limits)
Particulate Matter ("PM") Potential Emissions
899,181 lb. coating / year sprayed in Spray Booth (projected actual basis)
16.68% Particulate Matter (solids) by weight
0.1668 lb. solids / lb. coating
149,941 lb. solids / year sprayed in Spray Booth
0% solids sprayed in Spray Booth adheres to the membrane
100% solids sprayed in Spray Booth reaches Paint Arrestor filters
149,941 lb. solids / year reaches Paint Arrestor filters
98% average spray removal efficiency of Paint Arrestor filters
146,942 lb. solids / year captured/controlled by Paint Arrestor filters
2,999 lb. total PM emissions / year
1.50 ton total PM / year
0.34 lb. total PM / hour
899,181 lb. coating / year sprayed in Spray Booth (projected actual basis)
0.1510 lb. ZrO2/ lb. coating
135,814 lb. ZrO2 / year sprayed in Spray Booth
60% ZrO2 sprayed in Spray Booth reaches Paint Arrestor filters
81,489 lb. ZrO2 / year reaches Paint Arrestor filters
98.0% average spray removal efficiency of Paint Arrestor filters
1,630 lb. ZrO2 emissions / year
1,630 lb. ZrO2 emissions / year
99.61 % Fraction of ZrO2 less than or equal to 10 micron diameter
1,623 lb. PM10 emissions / year
0.81 ton PM10 emissions / year
0.19 lb. PM,o emissions / hour
75.96% Fraction of ZrO2 less than or equal to 2.5 micron diameter
1,238 lb. PM2.5 emissions / year
0.62 ton PM2.5 emissions / year
0.14 lb. PM2.5 emissions / hour
Potential Emissions
(Before Controls / Limits)
AIR POLLUTANT EMITTED
lb/hr
tons/yr
Particulate Matter (PM)
0.34
1.50
Particulate Matter <10 microns (PM10)
0.19
0.81
Particulate Matter <2.5 microns (PM2.5)
0.14
0.62
DEQ-CFW 00065876

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Baseline Actual Emissions
Basis and Assumptions:
(1) Pursuant to 15A NCAC 02D .0530(b)(1)(A), for an existing emissions unit, baseline actual
emissions means the average rate, in tons per year, at which the emissions unit actually
emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the five year period immediately preceding the date that a complete permit
application is received by the Division for a permit required under this Rule.
(2) Therefore, the baseline actual emissions of the IXM Membrane Coating Process (ID No.
NS-1) is determined by the highest averge emissions from two consecutive annual air
emissions inventory reports, which were submitted to the NC Division of Air Quality.
(3) Coating composition is 16.68% PM by weight (Triton X-100, ZrO2, SR Resin)
(4) Coating composition is 15.09% ZrO2 by weight
(4) The capture/control efficiency of paint arrestor filters was conservatively assumed to be
95% during the 2010-2015 baseline period
Volatile Organic Compounds (VOC) -- Baseline Actual Emissions
Year
VOC
Emissions
(ton)
2-Year
Average
VOC
Emissions
(ton/yr)
Hours of
Operation
(hr)
2-Year
Average
Hours of
Operation
(hr/yr)
2010
26.90
2,802
2011
20.56
23.73
3,169
2,985
2012
26.75
23.65
3,037
3,103
2013
28.29
27.52
3,353
3,195
2014
1 28.29
j 28.29
3,353
3,353
2015
29.68
28.99
23369
2,861
VOC Baseline Actual Emissions = 28.99 ton / year
20.26 lb. / hour
DEQ-CFW 00065877

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Baseline Actual Emissions
Particulate Matter (PM) -- Baseline Actual Emissions
Year
PM Emissions
(ton)
2-Year
Average
PM
Emissions
(ton/yr)
Hours of
Operation
(hr)
2-Year
Average
Hours of
Operation
(hr/yr)
2010
0.310
2,802
2011
0.237
0.274
3,169
2,985
2012
0.309
0.273
3,037
3,103
2013
0.326
0.318
3,353
3,195
2014
0.237
0.282
3,353
3,353
2015
0.342
0.290
2,369
2,861
Total PM Baseline Actual Emissions = 0.318 ton / year
0.199 lb. / hour
16.68% lb. solids (ZrO2 plus SR Resin) / lb. coating
15.10% lb. ZrO2 / lb. coating
0.906 lb. ZrO2 / lb. solids
0.906 ton ZrO2 emissions / ton PM emissions
0.318 ton PM emissions / year
0.288 ton ZrO2 emissions / year
99.61 % Fraction of ZrO2 less than or equal to 10 micron diameter (PM10)
0.286 ton PM10 emissions / year
0.179 lb. PM10 emissions / hour
75.96% Fraction of ZrO2 less than or equal to 2.5 micron diameter (PM2.5)
0.218 ton PM2.5 emissions / year
0.137 lb. PM2_5 emissions / hour
Baseline Actual Emissions
AIR POLLUTANT EMITTED
Ib/hr
tons/yr
Particulate Matter (PM)
0.20
0.32
Particulate Matter <10 microns (PM10)
0.18
0.29
Particulate Matter <2.5 microns (PM2.5)
0.14
0.22
DEQ-CFW 00065878

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Binder Storage Tank Emissions
Basis and Assumptions:
(1) Binder Storage Tank is a fixed -roof vertical tank located inside a building
(2) The tank vents directly to the atmosphere through a stack with a conservation vent
(3) Due to the conservation vent, VOC emissions result only from the displacement of the
tank's headspace as the binder solution is added to the tank
(4) Total volume of VOC emissions is equal to the total volume of binder solution pumped
into the tank
(5) Assume the tank is in service 4,380 hours/year (50% uptime production rate)
(6) Composition of the liquid in the tank:
78.18% ethanol
10.02% 1-propanol
3.68% 2-propanol
4.11 % Water
4.01 % SR Resin [1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexa-
fluoro-3-(1,2,2-trifluoroethen-oxy)propan-2-yl]oxy-ethanesulfonyl fluoride]
(7) Water is not a VOC
TOTAL PROJECTED ACTUAL EMISSIONS
156,951 lb. coating / year sprayed onto membrane (projected actual basis)
74.95% by weight of coating is binder
117,635 lb. binder / year sprayed onto membrane
53,359 kg binder / year sprayed onto membrane
0.97 kg/L (density of the coating)
55,009 Liters binder / year sprayed onto membrane
55,009 Liters / year of headspace displaced from Binder Storage Tank
24.876 Liters / mole (molar volume @ 1 atmosphere and 300C
2,211 Moles of vapor emissions per year (projected actual emissions)
DEQ-CFW 00065879

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Binder Storage Tank Emissions
VOLATILE ORGANIC COMPOUNDS (VOC) PROJECTED ACTUAL EMISSIONS
TOTAL
CHEMICAL
Ethanol
1-propanol
2-propanol
Water
SR Resin
BINDER
wt % binder
78.18%
10.02%
3.68%
4.11%
4.01%
100.00%
g chemical /
0.7818
0.1002
0.0368
0.0411
0.0401
1.0000
g binder
-77777777777
Molecular Wt
46.1
69.1
69.1
18.0
1146
(g / mole)
mole chemical /
0.01697
0.00145
0.00053
0.00228
3.5E-05
0.02127
g binder
mole chemical /
0.79788
0.06820
0.02503
0.10725
0.00164
1.00000
mole binder
Vapor Pressure
78.7
28.7
59.8
31.8
0
M
d r
(mmHg@30°C)
Partial Pressure in
vapor space
62.8
2.0
1.5
3.4
0
69.7
(mmHg@30°C)
mole chemical /
0.9014
0.0281
0.0215
0.0490
0
1.0000
mole vapor
Total vapor
emissions
2,211
2,211
2,211
2,211
2,211
(moles/year)
k�$
Chemical's
w
emissions
1993
62
48
108
0
g5
(moles/year)
Molecular Wt&
46.1
69.1
69.1
69.1
1146
(g/mole)
Chemical's
emissions
91,829
4,296
3,283
7,481
0
106,889
(g /year)
Chemical's
emissions
202
9
7
16
0
236
(lb/year)
Binder Storage Tank Projected Actual VOC Emissions =
* VOC emissions exclude the water component
219
lb. VOC / year*
0.05
lb. VOC / hour
0.11
ton VOC / year
DEQ-CFW 00065880

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Hi -Speed Dispersion Tank Emissions
Basis and Assumptions:
(1) Hi -Speed Dispersion Tank Dimensions
Inside Diameter 23.5 inches 1.96 feet
Sidewall Height 37 inches 3.08 feet
Tank Volume 9.29 cubic feet 262.98 Liters
(2) Tank has a latched, non -sealed lid that is closed except when filling the tank
(3) The tank's lid is latched closed while in operation and is decontaminated of chemicals
between batches, therefore there are de minimus VOC emissions .during normal operation
(4) Basis (3) suggests that VOC emissions would occur only during the filling of the tank
(5) The Hi -Speed Dispersion Tank is in service for approximately 1 hour per paint batch
(6) Tank is filled four (4) times per day during 2050 Nafion® Membrane production
(7) Tank is filled two (2) times per day during all other Nafion® Membrane production
(8) Projected product split of Nafion® Membranes
80% 2050 Nafion® Membrane
20% Other Nafion® Membranes
(9) Assume 2 tank volumes (526.0 Liters) of vapor are emitted during each tank filling
(10) Assume the tank is in service 183 days/year (50% uptime production rate)
(11) Composition of the liquid in the tank:
29.16% ethanol
3.74% 1-propanol
48.89% 2-propanol
0.08% Triton X-100 (octyl phenol ethoxylate)
15.10% Zirconium oxide (ZrO2)
1.53% Water
1.50% SR Resin [1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexa-
fluoro-3-(1,2,2-trifluoroethen-oxy)pro pan-2-yl]oxy-ethanesulfonyl fluoride ]
(12) Neither zirconium oxide (ZrO2) [ an inorganic mineral ] nor water is a VOC
TOTAL PROJECTED ACTUAL EMISSIONS
4 Tank fillings per day during 2050 Nafion® Membrane production
80% 2050 Nafion® Membrane product split
2 Tank fillings per day during all other Nafion® Membrane production
20% Other Nafion® Membrane product split
3.6 Average tank fillings per day during all Nafion® Membrane production
525.97 Liters of vapor emissions per tank filling
1,893.5 Liters of vapor emissions per day (average basis)
183 Days of service per year
346,506 Liters of vapor emissions per year (projected actual emissions)
24.876 Liters / mole (molar volume @ 1 atmosphere and 300C
13,929 Moles of vapor emissions per year (projected actual emissions)
DEQ-CFW 00065881

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Hi -Speed Dispersion Tank Emissions
VOLATILE ORGANIC COMPOUNDS (VOC) PROJECTED ACTUAL EMISSIONS
Triton Triton
TOTAL
CHEMICAL
Ethanol
1-propanol
2-propanol
X-10000ATING
SR Resin
wt % paint
29.16%
3.74%
48.89%
0.08%
1.50%
83.36%
wt % binder
34.98%
4.48%
58.65%
0.09%
1.79%
100.00%
g chemical /
0.3498
0.0448
0.5865
0.0009
0.0179
1.0000
g binder
Molecular Wt
46.1
69.1
69.1
647
1146
(g / mole)
mole chemical /
0.00759
0.00065
0.00849
1.4E-06
1.6E-05
0.01675
g binder
mole chemical /
0.45340
0.03876
0.50682
0.00008
0.00093
1.00000
mole binder
Vapor Pressure
78.7
28.7
59.8
0
0
(mmHg@30°C)
Partial Pressure in
vapor space
35.7
1.1
30.3
0
0
67.1
(mmHg@30°C)
mole chemical /
0.5318
0.0166
0.4517
0
0
1.0000
mole vapor
Total vapor
emissions
13,929
13,929
13,929
13,929
13,929
moles ear
Chemical's
emissions
7,407
231
6,291
0
0�
,
� .
(moles/year)
Molecular Wt
46.1
69.1
69.1
647
1146
W
(g/mole)
V W4 4 ,,
Chemical's
emissions
341,224
15,963
434,683
0
0
791,869
(g /year)
Chemical's
emissions
752
35
958
0
0
1,746
(lb/year)
Hi -Speed Dispersion Tank Projected Actual Emissions = 1,746 Ib. VOC / year
0.40 lb. VOC / hour
0.87 ton VOC / year
DEQ-CFW 00065882

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Paint Supply Tank Emissions
Basis and Assumptions:
(1) Paint Supply Tank Dimensions
Inside Diameter 28.5 inches 2.38 feet
Sidewall Height Winches 3.00 feet
Tank Volume 13.29 cubic feet 376.3 Liters
(2) Tank has a latched, non -sealed lid that is closed except when filling the tank
(3) Tank is under slight vacuum when the the Membrane Coating Process is operating,
therefore there are no VOC emissions from the tank during normal operation
(4) Basis (3) suggests that VOC emissions would occur only during the filling of the tank
(5) Time to fill Paint Supply Tank is approximately 10 minutes
(6) Tank is filled four (4) times per day during 2050 Nafion0 Membrane production
(7) Tank is filled two (2) times per day during all other Nafion0 Membrane production
Projected product split of Nafion0 Membranes
80% 2050 Nafion0 Membrane
(8) 20% Other Nafion0 Membranes
(9) Assume tank volumes (0.0 Liters) of vapor are emitted during each tank filling
(10) Assume the tank is in service 183 days/year (50% uptime production rate)
(11) Composition of the liquid in the tank:
29.16% ethanol
3.74% 1-propanol
48.89% 2-propanol
0.08% Triton X-100 (octyl phenol ethoxylate)
15.10% Zirconium oxide (Zr02)
1.53% Water
1.50% SR Resin [1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexa-
fluoro-3-(1,2,2-trifluoroethen-oxy)propan-2-yl]oxy-ethanesulfonyl fluoride]
(12) Neither zirconium oxide (Zr02) [ an inorganic mineral ] nor water is a VOC
TOTAL PROJECTED ACTUAL EMISSIONS
4 Tank fillings per day during 2050 Nafion0 Membrane production
80% 2050 NafionO Membrane product split
2 Tank fillings per day during all other Nafion0 Membrane production
20% Other NafionO Membrane product split
3.6 Average tank fillings per day during all Nafion0 Membrane production
752.7 Liters of vapor emissions per tank filling
2709.7 Liters of vapor emissions per day (average basis)
183 Days of service per year
495,868 Liters of vapor emissions per year (projected actual emissions)
24.876 Liters / mole (molar volume @ 1 atmosphere and 300C
19,933 Moles of vapor emissions per year (projected actual emissions)
DEQ-CFW 00065883

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-1)
Spray Coating Throughput Increase Project
Paint Supply Tank Emissions
VOLATILE ORGANIC COMPOUNDS (VOC) PROJECTED ACTUAL EMISSIONS
Triton riton
TOTAL
CHEMICAL
Ethanol
1-propanol
2-propanol
X-10000ATING
SR Resin
wt % paint
29.16%
3.74%
48.89%
0.08%
1.50%
83.36%
wt % binder
34.98%
4.48%
58.65%
0.09%
1.79%
100.00%
g chemical /
0.3498
0.0448
0.5865
0.0009
0.0179
1.0000
g binder
Molecular Wt
46.1
69.1
69.1
647
1146
(g / mole)"
mole chemical /
0.00759
0.00065
0.00849
1.4E-06
1.6E-05
0.01675
g binder
mole chemical /
0.45340
0.03876
0.50682
0.00008
0.00093
1.00000
mole binder
Vapor Pressure
78.7
28.7
59.8
0
0
(mmHg@30°C)..
..
Partial Pressure in
vapor space
35.7
1.1
30.3
0
0
67.1
(mmHg@30°C)
mole chemical /
0.5318
0.0166
0.4517
0
0
1.0000
mole vapor
Total vapor}}"
emissions
19,933
19,933
19,933
19,933
19,933
' 3
(moles/year)
Chemical'sx
emissions
10,600
331
9,003
0
0
(moles/year)_
Molecular Wt
46.1
69.1
69.1
647
1146
(g/mole)
Chemical's
emissions
488,308
22,844
622,052
0
0
1,133,205
(g /year)
Chemical's
emissions
1,077
50
1,371
0
0
2,498
(lb/year)
Paint Supply Tank Projected Actual Emissions = 2,498 lb. VOC / year
0.57 Ib. VOC / hour
1.25 ton VOC / year
DEQ-CFW 00065884

Page 1 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Spray Booth Operation Emissions
Basis and Assumptions:
(1) 2050 NafionO Membrane accounts for 80% of the product mix
(2) Other Nafion0 Membranes account for 20% of the product mix
(3) Sprayed Coating to Membrane Ratios are:
2050 NafionO Membrane 0.85490 lb. sprayed coating / m2 membrane
Other NafionO Membranes 0.42745 lb. sprayed coating / m2 membrane
(4) Density of the coating is 0.97 kg/L
(5) Coating composition is:
29.16% ethanol
3.74% 1-propanol
48.89% 2-propanol
0.08% Triton X-100 (octyl phenol ethoxylate)
15.10% Zirconium oxide (Zr02)
1.53% Water
1.50% SR Resin [1,1,2,2-tetrafluoroethene, 1,1,2,2-tetrafluoro-2-[1,1,1,2,3,3-hexa-
fluoro-3-(1,2,2-trifluoroethen-oxy)pro pan-2-yl]oxy-ethanesulfonyl fluoride]
(6) Coating composition is 81.79% VOC by weight (sum of the alcohols)
(7) All VOC compounds are emitted to the atmosphere; 0% capture / control
(8) Coating composition is 16.68% PM by weight (Triton X-100, Zr02, SR Resin)
(9) The current paint arrestor filter spray removal efficiency is 99.37% for a single layer and
99.77% for a double layer of arrestor filters. While two layers are actually used in the Spray
Booth, a 98% removal efficiency will be used for the particulate matter estimation.
(10) Assume the tank is in service 4,380 hours/year (50% uptime production rate)
VOLATILE ORGANIC COMPOUNDS (VOC) PROJECTED ACTUAL EMISSIONS
Projected
Coating-to-
Nafion®
Coated
Membrane
Coating
Membrane
Membrane
Ratio
Required
Ethanol
1-Propanol
2-Propanol
Product
(m2 / year)
(lb / m2)
(lb / year)
(lb / year)
(lb / year)
(lb / year)
2050
163,191
0.85490
139,512
40,684
5,216
68,209
Other
40,798
0.42745
17,439
5,086
652
8,526
TOTAL
203,989
156,951
45,770
5,868
76,736
Total Emissions of Alcohols (VOCs) 1128,373 lb/year ,
Spray Booth Operations Projected Actual Emissions
128,373 lb. VOC / year
29.31 lb. VOC / hour
64.19 ton VOC / year
DEQ-CFW 00065885

Page 2 of 2
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Spray Booth Operation Emissions
PARTICULATE MATTER ("PM") PROJECTED ACTUAL EMISSIONS
156,951 lb. coating / year sprayed in Spray Booth (projected actual basis)
16.68% Particulate Matter (solids) by weight
0.1668 lb. solids / lb. coating
26,172 lb. solids / year sprayed in Spray Booth
40% solids sprayed in Spray Booth adheres to the membrane
60% solids sprayed in Spray Booth reaches Paint Arrestor filters
15,703 lb. solids / year reaches Paint Arrestor filters
98.0% average spray removal efficiency of Paint Arrestor filters
15,389 lb. solids / year captured/controlled by Paint Arrestor filters
314 lb. total PM emissions / year
0.16 ton total PM ! year
0.0717 lb. total PM / hour
156,951 lb. coating / year sprayed in Spray Booth (projected actual basis)
0.1510 lb. ZrO2 / lb. coating
23,706 lb. ZrO2 / year sprayed in Spray Booth
60% ZrO2 sprayed in Spray Booth reaches Paint Arrestor filters
14,224 lb. ZrO2 / year reaches Paint Arrestor filters
98.0% average spray removal efficiency of Paint Arrestor filters
284 lb. ZrO2 emissions / year
99.61 % Fraction of ZrO2 less than or equal to 10 micron diameter
283 lb. PM,() emissions / year
0.14 ton PM10 emissions / year
0.03 lb. PM10 emissions / hour
75.96% Fraction of ZrO2 less than or equal to 2.5 micron diameter
216 lb. PM2.5 emissions / year
0.11 ton PM2.5 emissions / year
0.02 lb. PM2.5 emissions / hour
Projected Actual
Emissions
(After Controls / Limits)
AIR POLLUTANT EMITTED
Ib/hr
tons/yr
Particulate Matter (PM)
0.07
0.16
Particulate Matter <10 microns (PM10)
0.03
0.14
Particulate Matter <2.5 microns (PM2.5)
0.02
0.11
DEQ-CFW 00065886

Page 1 of 1
IXM Membrane Coating Process (ID No. NS-I)
Spray Coating Throughput Increase Project
Projected Actual Emissions
VOLATILE ORGANIC COMPOUNDS ("VOC") PROJECTED ACTUAL EMISSIONS
Binder Storage Tank
219 lb / year
Hi -Speed Dispersion Tank
1,746 lb / year
Paint Supply Tank
2,498 lb / year
Spray Booth Operation
128,373 lb / year
Clean-up using 2-propanol
1,704 lb / year
TOTAL VOC EMISSIONS 134,540 lb / year
30.72 lb / hour
67.27 ton / year
Projected Actual
Emissions
(After Controls / Limits)
AIR POLLUTANT EMITTED Ib/hr tons/yr
Volatile Organic Compounds (VOC) 30.72 I 67.27
PARTICULATE MATTER ("PM") PROJECTED ACTUAL EMISSIONS
All particulate matter emissions are from the Spray Booth Operations
Projected Actual
Emissions
(After Controls / Limits)
AIR POLLUTANT EMITTED
Ib/hr
tons/yr
Particulate Matter (PM)
0.07
0.16
Particulate Matter <10 microns (PM10)
0.03
0.14
Particulate Matter <2.5 microns (PM2.5)
0.02
0.11
DEQ-CFW 00065887

Page 1 of 1
IXM Membrane Coating Process (ID No. NS-1)
Spray Coating Throughput Increase Project
Baseline Actual to Projected Actual Emissions
Projected
Baseline
Projected
minus
Actual
Actual
Baseline
Emissions
Emissions
Actual
Emissions
AIR POLLUTANT EMITTED
tons/yr
tons/yr
tons/yr
Volatile Organic Compounds (VOC)
28.99
67.27
38.28
Particulate Matter (PM)
0.32
0.16
-0.16
Particulate Matter <10 microns (PM10)
0.29
0.14
-0.15
Particulate Matter <2.5 microns (PM2.5)
0.22
0.11
-0.11
NOTE: The reduction of PM emissions is due to a difference in the assumed spray removal
efficiency of the paint arrestor filters. The Baseline Actual Emissions were based on
an assumed 95% spray removal efficiency of the paint arrestor filters. The Projected
Actual Emissions are based on a conservative 98% removal efficiency, versus the
current paint arrestor filter's spray removal efficiency of 99.77% for the double layer of
arrestor filters that is actually used.
DEQ-CFW 00065888

Tested for:
Filter Mfr.:
Filter Name/Model
Report#./Test#
Report Date:
PAINT ARRESTANCE FILTER TEST REPORT
Spray Removal Efficiency & Paint Holding Capacity
BASED ON 40 CFR PART 63 NATIONAL EMMISSION STANDARD
Research Products
Research Products
3232 Single layer
R 778 T 878
2-Dec-11
Test Information
FILTER DESCRIPTION (20" x 20" pad):
5 layers of paper with poly backing
PAINT DESCRIPTION:
High Solids Baking Enamel (S.W. Permaclad 2400, red)
PAINT SPRAY METHOD:
Conventional Air Gun at 40 PSI
SPRAY FEED RATE:
143 gr./min. 135 cc./min.
AIR VELOCITY:
150 FPM
Test Results
INITIAL PRESSURE DROP of Clean Test Filter
0.03 in. water
FINAL PRESSURE DROP of Loaded Test Filter
0.50 in. water
WEIGHT GAIN OF FILTER & TEST FRAME TROUGH
2641 grams
PAINT HOLDING CAPACITY of TEST FILTER
1630 grams = 3.6 lbs.
PAINT RUN-OFF
687 grams
WEIGHT GAIN - FINAL FILTER
14.8 grams = PENETRATION
AVERAGE REMOVAL EFFICIENCY of TEST FILTER
99.37 %
Pest Engineer: Jose Tizcareno
Supervising Engineer: K. C. Kwok, Ph.D.
Tel.: [phone]
%Removal Efficiency
100
80 ---
60
>
U 40 —
v
° 20
0
0 800 1600 2400 3200 4000
Wt. Paint Fed (g.)
LMS Technologies, Inc.
P. O. Box 24185; Edina, MN 55424
Fax: [phone]
DEQ-CFW 00065889

! t
Tested for:
Filter Mfi•.:
Filter Name/Model
Report#./Test#
Report Date:
PAINT ARRESTANCE FILTER TEST REPORT
Spray Removal Efficiency & Paint Holding Capacity
BASED ON 40 CFR PART 63 NATIONAL EMISSION STANDARD
Research Products
Research Products
3232 Double Pad
R 780 T 880
12-Dec-11
Test Information
FILTER DESCRIPTION (20" x 20" pad):
Double filters, paper with poly backing
PAINT DESCRIPTION:
High Solids Baking Enamel (S. W. Permaclad 2400, red)
PAINT SPRAY METHOD:
Conventional Air Gun at 40 PSI
SPRAY FEED RATE:
143 g0min. 135 cc./min.
AIR VELOCITY:
150 FPM
INITIAL PRESSURE DROP of Clean Test Filter
0.08 in. water
FINAL PRESSURE DROP of Loaded Test Filter
0.50 in. water
WEIGHT GAIN OF FILTER & TEST FRAME TROUGH
1593 grams
PAINT HOLDING CAPACITY of TEST FILTER
1516 grams = 3.3 lbs.
PAINT RUN-OFF
77 grams
WEIGHT GAIN - FINAL FILTER
3.6 grams = PENETRATION
AVERAGE REMOVAL EFFICIENCY of TEST FILTER
99.77 %
Test Engineer Jose Tizcareno
Supervising Engineer: K. C. Kwok, Ph.D.
Tel.: [phone]
%Removal Efficiency
100
80 --
60
c
v 40
as 20
0
0 500 1000 1500 2000 2500
Wt. Paint Fed (g.)
LMS Technologies, Inc.
P. O. Box 24185; Edina, MN 55424
Fax: [phone]
DEQ-CFW 00065890

FORM E1
TITLE V GENERAL INFORMATION
aFxnsFn name ii a NCDFo/Division of Air Quality - Application for Air Permit to Construct/Operate E1
IF YOUR FACILITY IS CLASSIFIED AS "MAJOR" FOR TITLE V YOU MUST COMPLETE
THIS FORM AND ALL OTHER REQUIRED "E" FORMS E2 THROUGH E5 AS APPLICABLE
Indicate here if your facility is subject to Title V by: ff Emissions ❑ Other
If subject to Title V by other, check or specify: I ❑ NSPS ❑ NESHAPS (MACT) ❑ TITLE IV
❑ OTHER (specify)
If you are or will be subject to any maximum achievable control technology standards (MACT) issued pursuant to
EMISSION SOURCE
EMISSION SOURCE ID DESCRIPTION MACT
HFPO, Vinyl Ethers North,
NS-A, NS-B, NS-C, Vinyl Ethers South, and Resins "MON MACT"
and NS-G Processes (40 CFR Part 63 Subpart FFFF)
Natural gas / No. 2 fuel oil - CAA § 1120); Case -by -Case MACT for
PS -A, PS-B, and PS-C fired boilers Boilers & Process Heaters
Natural gas / No. 2 fuel oil - "Boiler MACT"
PS -A, PS-B, and PS-C fired boilers (40 CFR Part 63 Subpart DDDDD)
RICE-01, RICE-02, Stationary Reciprocating 'RICE MACT"
and RICE-03 Internal Combustion Engines (40 CFR Part 63 Subpart ZZZZ)
List any additional regulations which are requested to be included in the shield and provide a detailed explanation as to
why the shield should be granted:
REGULATION EMISSION SOURCE EXPLANATION
Use of projected actual emissions to
avoid applicability of requirements of
Prevention Of IXM Membrane Coating PSD
Significant Deterioration Process (ID No. NS-I) [ 15A NCAC 02D .0530(u)
Comments:
This application is to allow for the modification of the IXM Membrane Coating Process (ID No. NS-I) in
which (1) four new spray guns will replace the existing two spray guns and (2) the product mix will be
changing to predominately a finished product membrane that requires a greater application of the spray
coating. Because the potential -to -emit VOC emissions from this operation are seemingly large but
completely impractical, the facility is requesting the use of baseline actual emissions to projected
actual emissions to avoid the applicability of the requirements of Prevention Of Significant
Deterioration ("PSD") per 15A NCAC 02D .0530(u).
Attach Aciclltlonal sneets As necessary
DEQ-CFW 00065891

FORM E2
EMISSION SOURCE APPLICABLE REGULATION LISTING
oFvicFn narni ii a NcnF=0/Division of Air Quality - Aoolication for Air Permit to Construct/Operate E2
EMISSION
SOURCE
ID NO.
EMISSION
SOURCE
DESCRIPTION
OPERATING SCENARIO
INDICATE PRIMARY (P)
OR ALTERNATIVE (A)
POLLUTANT
APPLICABLE
REGULATION
77
NCAC,2© 0503 z
A ti1/ood
PM
'IVCAC.2D 0504 4�
NS-1
IXM Membrane Coating
P
VOC
NCAC 02D .0530(u)
NS-1
IXM Membrane Coating
P
PM
NCAC 213.0515
NS-1
IXM Membrane Coating
P
VE
NCAC 2D .0521
Attach Additional Sheets As Necessary
DEQ-CFW 00065892

FORM E3
EMISSION SOURCE COMPLIANCE METHOD
oGvicFn narnii1F NCnFoinivicinn Of Air Duality - Anolication for Air Permit to Construct/Operate E3
Regulated Pollutant Volatile Organic Compounds (VOC)
Emission Source ID NO. NS-I
Applicable Regulation 15A NCAC 2D.0530
Alternative Operating Scenario (AOS) NO: 1 (only one operating scenario)
ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS
MONITORINGREQUIREMENTS 3 r
saeT 1. .
Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes 0 No
If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes 0 No
Describe Monitoring Device Type: Not applicable
Describe Monitoring Location: Not applicable
Other Monitoring Methods (Describe In Detail): The Permittee shall record the annual VOC usage by the
IXM Membrane Coating process (ID No. NS-I) in tons per year.
Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous
readings taken to produce an hourly average):
The Permittee shall calculate these annual emissions for five years following startup of regular
operations of the modified unit.
RECORDKEEPING REQUIREMENTS
Data (Parameter) being recording: The annual VOC usage by the IXM Membrane Coating process
(ID No. NS-I) in tons per year, on a calendar year basis.
Frequency of recordkeeping (How often is data recorded?): Annually
REPORTIN4tEQU1,REMENTS '� ;
Generally describe what is being reported: A report must be submitted that contains the items listed
in 40 CFR 51.166(r)(6)(v)(a) through (c), specifically (a) the name, address and telephone
number of the major stationary source, (b) the annual emissions as calculated pursuant to
paragraph (r)(6)(iii) of this section; and (c) any other information.
Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS
OTHER (DESCRIBE): Within 60 days after the end of each calendar year
Specify proposed reference test method: Not applicable
Specify reference test method rule and citation: Not applicable
Specify testing frequency: Not applicable
NOTE - Proposed test method subject to approval and possible change during the test protocol process
Attach Additional Sheets As Necessary
DEQ-CFW 00065893

FORM E3
EMISSION SOURCE COMPLIANCE METHOD
REVISED 06/01/16 NCDEQ/Division Of Air Quality - Application for Air Permit to Construct/Operate
E3
Regulated Pollutant Particulate Matter (PM)
Emission Source ID NO. NS-I
Applicable Regulation 15A NCAC 2D.0515
Alternative Operating Scenario (AOS) NO: 1 (only one operating scenario)
ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS
i MONITORING REQUIREMENTS# -}04
MRj<; x
Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes ❑X No
If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes ❑X No
Describe Monitoring Device Type: Not applicable
Describe Monitoring Location: Not applicable
Other Monitoring Methods (Describe In Detail): The Permittee shall maintain production records of the IXM
Membrane Coating process such that the process rates "P" in tons per hour, as specified by the
formulas contained in 15A NCAC 02D .0515 can be derived.
Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous
readings taken to produce an hourly average):
The total weight of all materials introduced into the process that may cause any emission of
particulate matter and the hours of operation will be recorded each calendar year quarter.
"' = RECORDKEEi?ING RE(2UIRENI'ENTS
Data (Parameter) being recording: The total weight of all materials introduced into the IXM Membrane
Coating process in pounds and the hours of operation of the process.
Frequency of recordkeeping (How often is data recorded?): Quarterly
Y h _
REPORTING REQUIREMENTS = �-- A �
`+,.:`-t.c's;N..
-
Generally describe what is being reported: The Permittee shall submit a semiannual summary report of
monitoring and recordkeeping activities. All instances of noncompliance from the requirements
of the permit must be clearly identified.
Frequency: ❑ MONTHLY ❑ QUARTERLY [] EVERY 6 MONTHS
❑ Other (DESCRIBE)
Specify proposed reference test method: Not applicable
Specify reference test method rule and citation: Not applicable
Specify testing frequency: Not applicable
NOTE - Proposed test method subject to approval and possible change during the test protocol process
Attach Additional Sheets As Necessary
DEQ-CFW 00065894

FORM E3
FMISSION SOURCE COMPLIANCE METHOD
REVISED 06/01 /16 NCDEQ/Division Of Air Quality - Application for Air Permit to Construct/Operate E3
Regulated Pollutant Visible Emissions (VIE)
Emission Source ID NO. NS-I Applicable Regulation 15A NCAC 2D.0521
Alternative Operating Scenario (AOS) NO: 1 (only one operating scenario)
ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS
MONITORING REQUIREMENTS
Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable? ❑ Yes 0 No
If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)? ❑ Yes 0 No
Describe Monitoring Device Type: Not applicable
Describe Monitoring Location: Not applicable
Other Monitoring Methods (Describe In Detail): No monitoring is required for visible emissions from this
source.
Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneous
readings taken to produce an hourly average):
RECORDKEEPING REQUIREMENTS
Data (Parameter) being recording: No recordkeeping is required for visible emissions from this source.
Frequency of recordkeeping (How often is data recorded?):
Generally describe what is being reported: No reporting is required for visible emissions from this source.
Frequency: ❑ MONTHLY ❑ QUARTERLY ❑ EVERY 6 MONTHS
❑ OTHER (DESCRIBE)
TESTING
Specify proposed reference test method: Not applicable
Specify reference test method rule and citation: Not applicable
Specify testing frequency: Not applicable
NOTE - Proposed test method subject to approval and possible change during the test protocol process
Attach Additional Sheets As Necessary
DEQ-CFW 00065895

k
FORM E4
EMISSION SOURCE COMPLIANCE SCHEDULE
REVISED 06/01/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate E4
COMPLIANCE STATUS WITH RESPECT TO ALL APPLICABLE REQUIREMENTS
Will each emission source at your facility be in compliance with all applicable requirements at the time of permit
[] Yes ❑ No If NO, complete A through F below for each requirement for
which compliance is not achieved.
I your facility be in compliance with all applicable requirements taking effect during the term of the permit and
El Yes ❑ No If NO, complete A through F below for each requirement for
which compliance is not achieved.
If this application is for a modification of existing emissions source(s), is each emission source currently in
)] Yes ❑ No If NO, complete A through F below for each requirement for
which compliance is not achieved.
A. Emission Source Description (Include ID NO.)
B. Identify applicable requirement for which compliance is not achieved
C. Narrative description of how compliance will be achieved with this applicable requirements:
D. Detailed Schedule of Compliance:
Ste s Date Expected
E. Frequency for submittal of progress reports (6 month minimum):
F. Starting date of submittal of progress reports:
Attach Additional Sheets As Necessary
DEQ-CFW 00065896

FORM E5
TITLE V COMPLIANCE CERTIFICATION (Required)
REVISED 06/01/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate
In accordance with the provisions of Title 15A NCAC 2Q .0520 and .0515(b)(4),
the responsible company official of:
Chemours Company - Fayetteville Works
SITE NAME:
22828 NC Highway 87 W
SITE ADDRESS:
Fayetteville, NC 28306-7332
CITY, NC:
Bladen
COUNTY:
03735T42
PERMIT NUMBER:
CERTIFIES THAT (Check the appropriate statement(s):
R] The facility is in compliance with all applicable requirements
❑ In accordance with the provisions of Title 15A NCAC 2Q .0515(b)(4) the responsible company official certifies that
the proposed minor modification meets the criteria for using the procedures set out in 2Q .0515 and requests that
these procedures be used to process the permit application.
❑ The facility is not currently in compliance with all applicable requirements
If this box is checked, you must also complete Form E4 'Emission Source Compliance Schedule"
The undersigned certifies under the penalty of law, that all information and statements
provided in the application, based on information and belief formed after reasonable inquiry,
are true, accurate, and complete.
P
Date: % �� � L.G�I 7
re of responsible com an offici ,QU RED, USE BLUE INK)
Ellis H. McGaughy, Plant Manager
Name, Title of responsible company official (Type or print)
Attach Additional Sheets As Necessary
E5
DEQ-CFW 00065897