DEQ-CFW_00067104

El
10
NORTH CAROLINA DIVISION OF
AIR QUALITY
Application Review
Issue Date: December 14, 2016
Facility Data
Applicant (Facility's Name): Chemours Company - Fayetteville Works
Facility Address:
Chemours Company - Fayetteville Works
22828 NC Highway 87 West
Fayetteville, NC 28306
SIC: 2869 / Industrial Organic Chemicals,nec
NAICS: 32512 / Industrial Gas Manufacturing
Facility Classification: Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data
Facility Contact
Authorized Contact
Technical Contact
Michael Johnson
Ellis McGaughy
Michael Johnson
Environmental Manager
Plant Manager
Environmental Manager
[phone]
[phone]
[phone]
22828 NC Highway 87
22828 NC Highway 87
22828 NC Highway 87
West
West
West
Fayetteville, NC
Fayetteville, NC 28306
Fayetteville, NC
28306+7332
28306+7332
T..tol An*nal omiccinnc in TnNgfVFAR!
Region: Fayetteville Regional Office
County: Bladen
NC Facility ID: 0900009
Inspector's Name: Gregory Reeves
Date of Last Inspection: 03/03/2016
Compliance Code: 3 / Compliance -
Permit Applicability (this application only)
SIP:
NSPS:
NESHAP:
PSD:
PSD Avoidance: 02D .0530(u)
NC Toxics:
112(r):
Other:
Application Data
Application Number: 0900009.16A
Date Received: 10/28/2016
Application Type: Modification
Application Schedule: TV-Sign-501(c)(2) Part I
Existing Permit Data
Existing Permit Number: 03735/T42
Existing Permit Issue Date: 04/22/2016
Existing Permit Expiration Date: 03/31/2021
CY
S02
NOX
vOC
CO
PM10
Total HAP
Largest HAP
2015
5.50
55.45
290.39
42.10
8.94
36.82
17.06
[Methanol (methyl alcohol)]
2014
1.95
76.26
332.17
38.10
8.60
33.58
19.57
[Methanol (methyl alcohol)]
2013
0.2100
80.13
312.90
30.45
9.47
33.71
19.93
[Methanol (methyl alcohol)]
2012
1.23
63.76
260.86
29.24
7.95
28.44
18.70
[Methanol (methyl alcohol)]
2011
2.74
73.06
271.17
31.42
11.31
29.39
17.51
[Methanol (methyl alcohol)]
Review Engineer: Heather Sands
Signature: Date:12/14/2016
Comments / Recommendations:
Issue 03735/T43
Permit Issue Date: December 14, 2016
Permit Expiration Date: March 31, 2021
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I. Purpose of Application
The Chemours Company — Fayetteville Works (Chemours) currently holds Title V Permit No. 03735T42
with an expiration date of March 31, 2021, for a chemical manufacturing company in Fayetteville, Bladen
County, North Carolina. This permit application (No. 0900009.16A) is the first step of a two-step
significant modification of their Title V permit being made under 15A NCAC 02Q .0501(c)(2).
Under 15A NCAC 02Q .0501(c)(2), Chemours is required to obtain a construction and operation permit
as specified in 15A NCAC 02Q .0504 and then file a complete application within 12 months after
commencing operation to modify the construction and operation permit to meet the requirements of 02Q
.0500.
II. Project Description
Chemours is proposing to make changes to their IXM Membrane Coating Process (ID No. NS-I) to: (1)
replace two existing spray guns with four new spray guns; and (2) change the product mix to a
predominately finished product membrane that requires an increase in volume of the spray coating
application. The purpose of this modification is to accommodate a future increased production of the new
Nafion® 2050 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.
The IXM Membrane coating process only emits volatile organic compounds and particulate matter. The
following discussion summarizes the sources of emissions as well as the potential emissions from the
Spray Coating Throughput Increase Project.
A. Volatile Organic Compound Emissions
In their permit application, Chemours stated that a 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 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 percent 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 milliliters per minute) continuously for 8,760 hours/year. This maximum spraying rate
equates to a VOC potential -to -emit (PTE) of 367.73 tons per year. Chemours provided a detailed
calculation of the VOC emissions in their permit application.
B. Particulate Matter Emissions
According to the Chemours permit application, 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. The PM emissions would be exclusively from the zirconium oxide, the SR resin, and the
surfactant, which make up 16.68 percent by weight the total mass of the sprayed coating.'
Chemours provided calculations for the coating contents. The coating is 81.79 percent by weight VOC, 16.68 percent by weight
solids, and 1.5 percent by weight water.
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The spray booth utilizes paint arrestor filters. 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. Since the paint arrestor filters are an integral part of the paint spray booth, they 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 percent 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 percent efficient in removing the paint
spray droplets. (The Paint Arrestance Filter Test Reports were 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, Chemours stated that it was 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, Chemours conservatively
calculated emissions in their application using an assumed control efficiency of 98 percent.
The PTE for PM emissions was determined by assuming that all four spray guns are spraying at their
maximum flow rate (200 milliliters per 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.
III. Application History
October 28, 2016 Chemours submitted permit application No. 0900009.16A for the first step of a
two-step significant modification to their Title V permit. Chemours is proposing
to modify their IXM Membrane Coating Process.
October 31, 2016 DAQ sent Chemours an acknowledgement letter indicating that the application
for permit modification was complete.
December 5, 2016 Draft permit sent to Chemours and FRO for review.
December 5, 2016 Comments received from FRO.
December 5, 2016 Comments from Chemours were received.
December 14, 2016 Permit Issued
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IV. Permit Modifications
The following changes were made to The Chemours Company — Fayetteville Works Air Permit No.
03735T42.
Table 1. Summary of Changes to Permit
Old Page
New Page
Condition No.
Description of Change(s)
No.
No.
Cover letter
Cover letter
--
- Amended application type, permit revision numbers and dates.
Cover letter
Cover letter
Summary of changes
- Updated with summary of changes to permit.
attachment
attachment
to permit
1
1
Permit Cover Page
- Updated permit revision number and permit issuance date
3 — 56
3 — 58
All
- Updated permit revision number in header;
- Updatedpermit language to match permit shell.
21 — 34
21 — 35
Section 2.1 C
- Added a row to the summary of limits and standards table for the VOC
02D .0530(u) condition.
- Added new Section 2.1 C.7 for the use of projected actual emissions to
avoid applicability requirements of PSD and renumbered remaining
conditions.
37 — 39
38 — 40
Section 2.1 F
- Corrected paragraph numbering by changing Section 2.1 F.6 to Section
2.1 F.5.
41 - 45
42 — 46
Section 2.2 B
- Corrected typographic errors in Section 2.2 B.1. Exceedance was spelled
incorrectly.
--
47
Section 2.2 C
- Added new section for requirement to submit a Title V Permit
Application for the second step of the significant modification.
V. Regulatory Review — State Rules
In addition, the IXM Membrane Process is currently subject to the following North Carolina regulations:
• 15A NCAC 02D .0515: Particulates from Miscellaneous Industrial Processes; and
• 15A NCAC 02D .0521: Control of Visible Emissions
The following discussion summarizes each of these regulations. In addition, the IXM Membrane Process
will not be subject to 15A NCAC 02D .0530 by utilizing projected actual emissions for their project
netting. See Section VI.A for additional details.
A. 15A NCAC 02D .0515: Particulates from Miscellaneous Industrial Processes
This rule applies to stacks, vents, or outlets emitting particulates from industrial processes with no other
applicable standards. The allowable emission rate is in terms of pounds per hour and is calculated using
the following equation:
For process rates up to 30 tons per hour:
E = 4.10(P)0.67
Where: E = Allowable emission rate in pounds per hour
P = Process weight in tons per hour
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The IXM Membrane Coating Process (ID No. NS-I) is subject to this rule (see Section 2.1 C.1 of the
current permit, T42). Compliance is determined by keeping records of production and semiannual
reporting.
Chemours estimates that the process weight after Spray Coating Throughput Increase Project will be
0.0179 tons per hour of coating, resulting in an allowable emission rate for the IXM Membrane Coating
Process of 0.277 pounds per hour. Chemours projects that the maximum PM emissions (based on the
maximum projected firing rate as determined from the forecasted level of production, see Section XI.A,
below for additional details) will be approximately 0.072 pounds per hour. Therefore, compliance will
continue to be expected and no changes to the permit are necessary as a result of this project.
B. 15A NCAC 02D .0521: Control of Visible Emissions
This regulation applies to fuel burning operations and industrial processes where visible emissions can be
reasonably expected to occur. The IXM Membrane Coating Process is subject to the 20-percent opacity
limit in this rule (See Section 2.1 C.2 of the current permit, T42) and no
monitoring/recordkeeping/reporting is required for visible emissions from this source. The projected PM
emissions resulting from this project (and therefore the visible emissions) are very low and compliance
with the 20-percent opacity limit will continue to be expected. No changes to the permit are necessary as
a result of this project.
VI. Regulatory Review - Federal Rules (NSPS, NESHAP/MACT, NSR/PSD, CAM)
The IXM Membrane Coating Process is not subject to any federal NSPS and NESHAP. Therefore, this
section will discuss New Source Review (NSR)/Prevention of Significant Deterioration (PSD) and
Compliance Assurance Monitoring (CAM).
A. New Source Review and Prevention of Significant Deterioration
Chemours is located in Bladen County, which is designated as an attainment/unclassifiable area for all
pollutants regulated by the NSR permitting program. In the current permit, Chemours has several PSD
avoidance conditions which limit emissions from different emission sources, but not the limits do not
apply to the IXM Membrane Coating Process.
The PSD regulations apply to new major stationary sources or existing major sources that propose a
major modification. Chemical manufacturing is listed as one of the 28 source categories under federal
PSD regulation as being subject to regulation with potential emissions greater than 100 tpy of any PSD-
regulated pollutant. As shown in the summary of total annual emissions above, Chemours emits more
than 100 tpy of VOC, and as such, Chemours is a major source under PSD.
A project is considered a major modification if there is a physical change in or a change in the method of
operation of a major stationary source that would result in both a significant emissions increase and a
significant net emissions increase. In order to determine whether a project results in a significant net
increase, the NC regulations under 15A NCAC 02D .0530 allow for project netting. Under project
netting, emission increases and decreases from all emission units at the source that are defined as the
project are used and compared to the significant emission rates.
For the Spray Coating Throughput Increase Project, the only PSD regulated pollutants emitted are VOC
and particulates (PM/PMIo/PM2.5). The VOC emission units involved in the project are the membrane
coating spray booth, the binder storage tank, the hi -speed dispersion tank, and the paint storage tank, as
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well as increased cleanup chemicals using 2-propanol. The spray booth is also a source of particulate
emissions. No other PSD regulated pollutants are emitted from these sources.
The first step is to determine whether there is a significant increase in emissions due to the project by
comparing the VOC and PM/PM1o/PM2.5 potential -to -emit from the IXM Membrane Coating Process to
the PSD significant emission rates (SER) as defined in the PSD regulation. Table 2, below, presents the
potential -to -emit for the Spray Coating Throughput Increase Project. As discussed previously, the VOC
potential -to -emit from the membrane coating spray booth alone was calculated by assuming that all four
spray guns are spraying at the 200-milliliter per minute maximum flow rate continuously for 8,760 hours
per year. The PM/PM1o/PM2.5 potential -to -emit was also calculated using the maximum spray gun flow
rate at 8,760 hours per year and assuming none of the coating was applied to the membrane but was
sprayed continuously into the spray booth. As shown in Table 2, VOC potential emissions are greater
than the 40-tpy PSD SER, but PM/PM1o/PM2.5 potential emissions are below their respective SER.
Therefore, the project is not considered to be have a significant increase in PM/PMIo/PM2.5 emissions and
further analysis will be necessary for VOC emissions.
The second step is to determine if there is a significant net increase in emissions of VOC using project
netting. A significant net increase in emissions is projected to have occurred if the difference between the
emissions after the project and the emissions before the project are greater than the significant emission
rate for that pollutant. The emissions prior to the project are baseline actual emissions (BAE). As required
by 15A NCAC 02D .0530, the BAE are calculated as 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. Baseline actual emissions for the IXM Membrane Coating Process were obtained
from annual emission inventories and were the total from the spray booth, three storage tanks, and
cleanup. The two consecutive years of VOC emissions that were the highest were reported in calendar
years 2014 and 2015 providing the BAE of 29.0 tpy.
As allowed under 40 CFR 51.166(r)(6) and 15A NCAC 02D .0530(u), for projects involving existing
emissions units at a major stationary source, Chemours elected to use projected actual emissions (PAE) to
represent the emissions after the project. Projected actual emissions mean the maximum annual rate, in
tons per year, at which an existing emissions unit is projected to emit a regulated pollutant in any one of
the 5 years (I2-monthperiod) following the date the unit resumes regular operation after the project, or in
any one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit that regulated NSR pollutant. Chemours calculated projected actual
emissions by using the highest forecasted production of 203,989 m2 of coated membrane in 2021 and the
anticipated product split of membrane production. Table 3, below, shows the PAE for the IXM Membrane
Coating Process Spray Booth is projected to be 64.2 tpy and the PAE of the three tanks in the Membrane
Coating Process plus cleanup chemicals is projected to be 3.08 tpy, resulting in the total PAE from the
project to 67.3 tpy.
As shown in Table 3, the net VOC emissions impact (i.e., PAE — BAE) from the IXM Membrane Coating
Process is less than the 40-tpy significant emission rate (67.3 tpy — 29.0 tpy = 38.3 tpy). Therefore, the
process does not result in a significant net increase in VOC emissions and is not subject to PSD. Based on
the information above, proposed PSD avoidance limits will be added to the permit for the IXM
Membrane Coating Process as a 15A NCAC 02D .0530(u) condition. Under this condition, Chemours
will be required to monitor and record VOC emissions from the IXM Membrane Coating Process each
year. Because the project involved increasing the design capacity of the spray booths, Chemours will be
required to maintain these records for 10 years following resumption of regular operations of the IXM
Membrane Coating Process following the modifications. Annual reports of the emissions calculations and
comparisons to PAE for VOC will also be required.
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Table 2. Potential -to -Emit for Membrane Coating Process
Source
Potential -to -Emit (tP)a
VOC
PM10
PM2.5
PM
IXM Membrane Spray Booth
368
1.50
0.81
0.62
IXM Membrane Coating Process tanks
15.5
0
0
0
Project Total
383
1.5
0.81
0.62
PSD Significant Emission Rate (SER)
40
25
15
10
Greater than PSD SER?b
Yes
No
No
No
apotential-to-emit calculated by assuming that all four spray guns are spraying at their
maximum flow rate (200 milliliters per minute) continuously for 8,760 hours per year.
NOTE: Tank cleaning does not occur when spray booth is operated 8,760 hours per year.
blf greater than the PSD SER, further PSD analyses will be necessary and will be
presented in Section VII, below.
Table 3. Project Netting Analysis for Chemours Spray Coating Throughput Increase Project
Boiler
VOC Emissions
( )
Baseline Actual Emissions (BAE)a
24-month Period that Represents Baseline per Pollutant
CY2014 — CY2015
IXM Coating Membrane Process'
29.0
Total
29.0
Projected Actual Emissions (PAE)"
IXM Coating Membrane Process Spray Booth
Operation
64.2
IXM Membrane Coating Process Tanks
3.08
Total
67.3
Project Net Increase (PAE - BAE)
38.3
PSD Significant Emission Rate for VOC (PSER)
40
Is Net Increase > PSER?
NO
aAnnual average baseline emissions are calculated for the 24-month period that
represents the highest emissions over the five years prior to the project
(CY2014 and 2015).
bAverage of emissions reported in the 2014 and 2015 annual emissions
inventory. Emissions reported are the total for coating process, including spray
booths, coating process tanks, and tank cleaning.
°Projected actual emissions were calculated using the production rate
determined by using the highest forecasted production, which is 203,989 m2 of
coated membrane in 2021 and anticipated product split of different membranes.
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B. Compliance Assurance Monitoring
The compliance assurance monitoring (CAM) rule requires owners and operators to conduct monitoring
to provide a reasonable assurance of compliance with applicable requirements under the act. Monitoring
focuses on emissions units that rely on pollution control device equipment to achieve compliance with
applicable standards. An emission unit is subject to CAM, under 40 CFR Part 64, if all of the following
three conditions are met:
The unit is subject to any (non-exempt, e.g., pre -November 15, 1990, Section 111 or 112 standard)
emission limitation or standard for the applicable regulated pollutant.
The unit uses any control device to achieve compliance with any such emission limitation or standard.
The unit's pre -control potential emission rate exceeds 100 percent of the amount required for a source
to be classified as a major source; i.e., either 100 tpy (for criteria pollutants) or 10 tpy of any
individual/25 tpy of any combination of HAP.
The IXM Membrane Process emits VOC and particulate matter. The membrane process spray booths are
equipped with filters that are considered an integral part of the paint spray booth and not air pollution
control devices [see 15A NCAC 02Q .0102(h)(3)]. The membrane process tanks are not equipped with a
control device for VOC control. Therefore, since control devices are not used to achieve compliance with
any emission limitations or standards, CAM does not apply.
VII. Facility Wide Air Toxics
According to their permit application, the emissions units impacted by the proposed Spray Coating
Throughput Increase Project do not emit toxic air pollutants (TAP). Therefore, no changes to the permit
will be necessary as related to TAP.
VIII. Facility Emissions Review
The table above (in the review summary) represents the criteria pollutant (plus total HAP) from the latest
available reviewed facility emissions inventory (2015).
IX. Facility Compliance Status
DAQ has reviewed the compliance status of this facility. During the most recent full facility -wide
inspection, conducted on March 3, 2016, Greg Reeves of the Fayetteville Regional Office indicated that
the facility appeared to be in compliance with all applicable requirements.
X. Draft Permit Review Summary
On December 5, 2016, a final draft version of Permit No. 03735T43 and the associated permit review
document were sent to Mr. Ellis McGaughy, the Responsible Official for Chemours, and Mr. Greg
Reeves, FRO for their review and comments. On December 5, 2016, FRO and Chemours submitted
minor editorial comments on the draft permit and permit review. These comments were incorporated into
the permit and review.
XI. Public Notice/EPA and Affected State(s) Review
Public notice not required at this time. This permit action is for the first step of a two-step process as per
15A NCAC 2Q .0501(c)(2).
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XII. Conclusions, Comments and Recommendations
PE Seal
Pursuant to 15A NCAC 02Q .0112 "Application requiring a Professional Engineering Seal," a
professional engineer's seal (PE Seal) is required to seal technical portions of air permit applications for
new sources and modifications of existing sources as defined in 15A NCAC 02Q .0103 that involve:
(1) design;
(2) determination of applicability and appropriateness;
(3) or determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer's seal (PE Seal) WAS NOT required for this modification.
Zoniny-
A Zoning Consistency Determination per 2Q .0304(b) WAS required for this proposed modification. The
permit application and zoning request were submitted to the Bladen County, NC, Planning Department on
October 27, 2016. Proof of the submittal was included in the permit application.
Recommendations
This permit modification application has been reviewed by NC DAQ to determine compliance with all
procedures and requirements. NC DAQ has determined that this facility appears to be complying with all
applicable requirements.
Recommend Issuance of Permit No. 03735/T43. FRO has received a copy of this permit and submitted
comments that were incorporated as described in Section X.
DEQ-CFW 00067112