AQ_F_0800107_20161208_PRMT_Permit

PAT MCCRORY
Governor
DONALD R.VAN DER VAART
w Secretary
Air Quality ENVIRONMENTAL QUALITY SHEILA C.HOLMAN�
Director
December 8; 2016
Mr, Garald Cottrell
President
W.E. Partners II, LLC
312 South Front Street, Suite 6
New Bern,NC 28562
Subject:, Air Permit No. 10126R03
W.E. Partners II, LLC
Lewiston Woodville, Bertie County, North Carolina
Permit:Class: Synthetic Minor
Facility ID# 0800107
Dear Mr. Cottrell:
J 'In accordance with your completed application received September 3,2015, we are
forwarding herewith Permit No. 10126R03 to W.E. Partners II,LLC, Lewiston Woodville,Bertie
County,North Carolina for the construction and operation of air emissions sources or air cleaning
devices and appurtenances. Additionally, any.emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an"ATTACHMENT" to the enclosed air permit. Please note the
records retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts,requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness.of
the entire permit: This hearing request must be in the form of a written petition, conforming to G.S.
15OB-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant.to G.S. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
150B-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for.informal modification unless a request for a hearing is
also made under G.S. 150B-23,
State of North Carolina I Environmental Quality I Air Quality
Washington Regional Office 1 943 Washington Square Mall I Washington,NC 27889
252 946 6481 T 1 252 975 3716 F

Mr. Garald Cottrell
December�, 2016
Page 2
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so-is a violation of G.S.143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from December 8, 2016 until November 30, 2024, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. A table listing those changes is
enclosed. The Permittee is responsible for carefully reading the entire permit and evaluating
the requirements of each permit stipulation. The Permittee shall comply with all terms,
conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance
with any permit condition is grounds for enforcement action,for permit termination,
revocation and reissuance, or modification, or for denial of a permit renewal application.
Should you have any questions concerning this matter,.please contact Betsy Huddleston at
252-948-3836.
Sincerely,
Robert P. Fisher,Regional Supervisor
Division of Air Quality,NC DEQ
RPF/eth
Enclosures
c: Washington Regional Office
(g:\AQ\Shared\Bertie08\00107\0 8A00107SMR03.doc)

The following changes have been made to the permit 10126R03:
-Page(s) Section Description of Change(s)
1 Permit Expiration Date The permit is now issued as effective for a period of eight years.
1 Source Table The fuel bunker has been removed from the permit and added to an
Insignificant Activities Attachment to the permit.
2 Condition A.2. A calendar year 2023 emissions inventory will be required for submittal with
the next permit renewal.
5-11 Condition A.11, This permit condition has been updated to reflect current language in other
per its for similar 6J GACT applicable boilers.
6 Condition A.I I.c.iii EPA has revised the particulate stack testing requirements for 6J GACT
and iv. new biomass boilers. For boilers constructed on or before September 14,
2016 with initial PM performance test results equal to or less than half of the
PM emission limit,performance testing must be conducted for PM by
September 14,2021, If those test results show that PM emissions are equal
to or less than half of the PM emission limit,performance tests for PM may
be conducted every fifth year thereafter. Each such performance test must be
conducted no more than 61 months after the previous performance.test. If
the test results are greater than half of the emission limit,triennial testing is
required.
11 Condition A.13. The condition has been modified to reference use of the most current DAQ
approved CO and NOx stack test rates for the boilers to calculate emissions.
12-13 Condition A,15, Session Law 2007-397,Senate Bill 3 Best Available Control,Technology
(BACT)limits and testing requirements are added to the permit.
Testing is due by May 31,2017.
-- Insignificant/Exempt The fuel bunker is added to this attachment.
Activities Attachment

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 10126R03
Issue Date: December 8, 2016 Effective Date: December 8, 2016
Expiration Date: October 31, 2024 Replaces Permit: 10126R02
To construct and operate air emission source(s).and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws,Rules and.Regulations,
W.E. Partners II,LLC
3539 Governors Road
Lewiston Woodville, Bertie County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 080010.7
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source, Control Device : Control System
Source ID Description ID Description
ESB=r one clean cellulosic biomass-fired boiler MC,1 rGU81
ti-cycloneW�
(NSPS; (29.4 million Btu per hour maximum tubes,each 9_inches in diameter)
NESHAP) heat input)
ESP-1 electrostatic precipitator
(9,222 sq ft total collection plate area,
( two fields with 60 kv charge per field)
......
ESB-2 o e clean cellulosic biomass-fired boiler MC-2 r(18ttubes,
i-cyclone
(NSPS, �(29.4�million Btu per hour maximum � each 9 inches in diameter)
NESHAP) heat input)*
ESP-1 electrostatic precipitator
j (9,222 sq ft total collection plate area,
It"'W'O"fi"e"Ids with.60 kv charge per field)
.._ _.: ..W ._-. _:. w_� W: :...w w.:.. _..:W. w:..., -.... ............
... _ ..-....
...
.
ESB-3 (one clean cellulosic biomass-fired boiler MC-3 multi-cyclone
.(NSPS, 1(29.4 million Btu per hour maximum (18 tubes,each 9 inches in diameter)
NESHAP) ;Iheat input)*
ESP-1 electrostatic precipitator
(9;222 sq ft total collection plate area,
two fields with 60 kv charge per field)
. ... . ..... p ' ....._. . .....*
Clean cellulosic biomass fuel must meet the definition as rovided in 40 CFR 241 2 or it must be approved as a non-
hazardous secondary material(NHSM),biomass fuel by EPA(40CFR 241.2 and 241.3).

Permit No. 10126R03
Page 2
in accordance with the completed application 0800107.15B received September 3, 2015 including
any plans, specifications,previous applications,and other supporting data,all of which are filed
with the Department of Environmental Quality, Division of Air Quality(DAQ) and are incorporated
as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING,REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
21) .0202,2D .0504,2D .0516,2D .0521,2D .0524(40 CFR 60, Subpart Dc),2D .0535,
2D .0540, 2D .0611, 2D .1111 (40 CFR 63; Subpart JJJJJJ), 2D .1806;2Q .0315,2Q .0317
(Avoidance), and.NCGS 62-133.8(g) State BACT(SB3).
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT-The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q
.0203(i),no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request(with AA application form) should be
submitted to the Regional Supervisor,DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall.submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C..
General Statute 143 215.65. The report shall be submitted to the.Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2023 calendar year..
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0504
"Particulates from Wood Burning Indirect Heat Exchangers,"particulate matter emissions
from the biomass-fired indirect heat exchangers shall not exceed the allowable emission
rates listed below:
.. .... _ ......_...
Source Emission Limit
(lbs/million Btu,, each)!
Three clean cellulosic biomass-fired boilers (29.4 MM13LWUr 0:43
maximum heat input each,ID Nos.ESB-I,ESB-2 and ESB-3)
4. SULFUR DIOXIDE CONTROL REQUiREMENT-As required by 15A NCAC 2D .0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the
combustion sources shall not exceed 2.3 pounds per million Btu heat input.
5. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions£ram the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six-minute period, except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour

Permit No. 10126R03
Page 3
period. However,sources which must comply with 15A.NCAC 2D .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comkply with applicable visible emissions requirements contained therein.
6. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" For the three
clean cellulosic biomass-fired boilers (29.4 MMBtu/hr maximum heat input each, ID Nos.
ESB-1, ESB-2 and ESB-3)the Permittee shall comply with all applicable provisions,
contained in Environmental Management Commission Standard 15A NCAC 2D.0524
"New Source Performance Standards" (NSPS)as promulgated in 40 CFR 60, Subpart Dc,
in Subpart A "General Provisions."
a. NSPS Recordkeeping Requirement The Permittee shall record and maintain
records of the amounts of fuel fired during each day. Records shall be maintained
for a period of two years following the dates of record.
7. NOTIFICATION REQUIREMENT-As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any'other abnormal
conditions, shall:
a; Notify the.Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
v. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
8. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary.If substantive complaints are received or excessive
fugitive dust emissions from the facility are observed beyond the property boundaries for six
minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).

Permit No. 10126R03
Page 4
"Fugitive dust emissions"means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles,stock pile working,plant parking lots,
and..plant-roads.(including access roads and haul roads).
9. MULTI-CYCLONE REQUIREMENTS -As required by 15A NCAC 2D..0611,particulate
matter emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements-To comply with the provisions of this.
permit and ensure that emissions do not exceed the.regulatory limits,the Permittee
shall,perform an annual (for each 12-month period following the initial.inspection)
internal inspection of each multi-cyclone system. In addition,the Permittee shall
perform monthly external inspections and maintenance(I&M) as recommended by
the manufacturer.
b. Recordkeeping Requirements-The results of all inspections and.any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a multi-cyclone logbook. Records of all maintenance activities shall be recorded in
the logbook. The multi-cyclone logbook(in written or electronic format) shall be
kept on-site and made available to DAQ personnel upon request.
10. ELECTROSTATIC PRECIPITATOR REQUIREMENTS - As required by 15A NCAC 2D
.061.1,particulate matter emissions shall be controlled as described in the permitted
equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and-ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform periodic inspections and maintenance(I&M) as recommended by the
manufacturer and as required by 40 CFR 63, Subpart JJJJJJ. In addition,the
Permittee shall perform an annual (for each 12=month period following the initial
inspection) inspection of the electrostatic precipitator.
b. As a minimum,the annual inspection will include the following:
L Visual checks of critical components such as rappers and ash removal
equipment;
ii. Checks for any equipment that does not generate an alarm in the de-energized
state,to ensure it is operational;
iii. Observations of particulate deposits on discharge and collecting electrodes,
for comparison with past and future inspections-,
iv. Checks for signs of plugging of gas distribution,plates, and excessive buildup
on inlet and outlet plenum floor surfaces
V. Checks for signs of hopper plugging; and

Permit No. 10126R03
Page 5
vi. Checks for broken rapper rod insulators,cracked support bushing insulators,
and broken or loose stabilizer bar insulators (if installed), and replacement as
required.
c. Recordkeeping Requirements -The results of all inspections and any variance from
Manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook:
The log book(in written or electronic format) shall be kept on-site and made
available to DAQ personnel upon request.
11. GENERALLY AVAILABLE CONTROL TECHNOLOGY-For the three clean.cellulosic
biomass fired boilers(ID Nos. ESBA,ESB-2 and ESB-3),the Permittee shall comply with
all applicable provisions, including the notification, testing, and monitoring requirements
contained in Environmental Management Commission Standard 15A NCAC 2D.1111,as
promulgated in 40 CFR 63, Subpart JJJJJJ(0), National Emission Standards for
Hazardous Air Pollutants for Area Sources:Industrial,'Commercial, and.Institutional
Boilers," including Subpart A "General Provisions."
a. Compliance Date -The owner.or operator of a new affected source must achieve
compliance upon startup of the source. New 6J Sources are defined as constructed
after June 4, 2010. [40 CFR 63.11194(c) and 63.11196(c)]
b. Emissions Limitation - The following permit limit shall not be exceeded,except
during periods of startup and shutdown:
_. . . ... .. ............ . . .... .... .. ...... .... . _ . __
Affected Source(s) Pollutant Emissions Limit
it-Three clean cellulosic biomass fired boilers , Filterable 0.0701b/MMBtu
! (ID Nos. ESBA,ESB-2 and ESB-3) Particulate Matter of heat input
The Permittee shall maintain the operating load of each affected boiler such that it
does not exceed 110 percent of the average operating load recorded during the most
recent performance stack test. [40 CFR.63.112.01(c),Table 3]
c. Performance Testing = The following performance test shall be conducted:.
r Affected Sources Pollutant Test Method
_ > _ _ _
T ee clean cellulosic biomass-fired boilers. Filterable
(ID Nos. ESB-1,ESB-2 and ESB-3) Particulate Matter Method 5
J. The Permittee shall conduct the required initial performance test within 180
days of startup of the affected sources. The results of this test shall be
submitted with the Notification of Compliance Status no later than 60 days
after the stack test. [40 CFR 63.11210(d)and 63.1125(e)]

Permit No. 10126R03
Page 6
ii. The Permittee must conduct all performance tests according to 40
CFR 63.7(c), (d), (f), and (h). The Permittee must also develop a site-specific
test plan according to the requirements of 40 CFR 63.7(c). [40 CFR
63.11212(a)]
iii. For new boilers that commenced construction or reconstruction on or before
September 14, 2016, when demonstrating initial compliance with the PM.
emission limit, if the boilers' performance test results showed that the PM
emissions are equal to or less than half of the PM emission limit, you do not
need to conduct further performance tests for PM[ until September 14,
2021, but must continue to comply with all applicable operating limits and
monitoring requirements. [40 CFR 63.11220(b)]
iv. If performance test results show that PM emissions are equal to or less than
half of the PM emission limit,then performance tests for PM may be
conducted every fifth year. Each such performance test must be conducted
no more than 61 months after the previous performance test. If any test
results are greater than half of the PM emission limit, subsequent
performance tests must be conducted on a triennial basis [40 CFR
63.11220(b)(4)]
V. At least 60 days prior to performing any required emissions testing,the
Permittee must submit two copies of a testing protocol to the Regional
Supervisor, DAQ for review and approval. All testing protocols must be
approved by the DAQ prior to performing such tests. [40 CFR 63.11225(a)]
via To afford the Regional Supervisor, DAQ, the opportunity to have an observer
present,the Permittee shall PROVIDE the Regional Office, in WRITING, at
least 15 days notice of any required performance test.
vii. The boilers are required to be re-tested upon any new fuel type permitted.
viii. The Division of Air Quality retains the exclusive right to approve equivalent
and alternative test methods, continuous monitoring procedures, and
reporting requirements.
ix. All associated testing costs are the responsibility of the Permittee.
d. Compliance Requirements= The Permittee shall comply with the following
requirements for each biomass boiler:
i. General Duty Clause-At all times the Permittee shall operate and maintain
any affected source, including associated air pollution control equipment and
monitoring equipment,in"a manner consistent with safety and good air
pollution control practices for minimizing emissions. [40 CFR 63.11205(a)]
ii. Boiler Tune-0-An initial boiler tune-up is required no later than 25 months
after the initial startup of the affected source. The Permittee shall comply
with the following with respect to the tune-up: [40 CFR 63,11223]

Permit No. 10126R03
Page 7
A. A biennial tune-up is required and shall be conducted no more than 25
months after the previous tune-up.
B. The Permittee shall conduct the tune-up while burning the type of fuel
(or fuels in the case of boilers that routinely burn two types of fuels at
.the same time)that provided the majority of the heat input to the.
boiler over the 12 months prior to the tune-up.
C. As applicable,inspect the burner,and clean or replace any
components of the burner as necessary., The Permittee may delay the
burner inspection until the next scheduled unit shutdown,but must
inspect each burner at least once every 36 months.
D. Inspect the flame pattern, as applicable, and adjust the burner as
necessary to optimize the flame pattern. The adjustment should be
consistent with the manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio, as applicable, and
ensure that it is correctly calibrated and functioning properly. The
Permittee may delay the air to fuel ratio inspection until the next
scheduled.unit shutdown,but must conduct the inspection at least
once every 36 months.
F. Optimize total emissions of carbon monoxide. This optimization
should be consistent with the manufacturer's specifications, if
available, and with any nitrogen oxide requirement to which the unit
is subject.
G. Measure the concentrations in the effluent stream of carbon monoxide
in parts per million,by volume,and oxygen in volume,percent,before
and after the adjustments are made(measurements may be either on a
dry or wet basis, as long as it is the same basis before and after the
adjustments are made). Measurements may be taken with a portable
CO analyzer.
iii. The Permittee must minimize the boilers' startup and shutdown periods
following the manufacturer's recommended procedures,if available. If
manufacturer's recommended procedures are not available,the Permittee
mustifollow recommended procedures for a unit of similar design for which
manufacturer's recommended procedures are available. [40 CFR
63.11223(g)]
e. ELECTROSTATIC PRECIPITATOR Monitoring and Continuous Compliance
Requirements - The Permittee shall comply with the following requirements:
i. Establishing OperatingLimits imits-For the electrostatic precipitator(ID No.
ESP-1)the Permittee shall establish the minimum secondary power
(secondary voltage'and secondary current)as defined in 40 CFR 63.11237
during the three-run performance stack test for particulate;the Permittee must

.Permit No. 10126R03
Page 8
collect secondary electric power data at a minimum of every 15 minutes
during the entire period of the performance stack testing and determine the
average total secondary electric power for each individual test run by
computing the average of all the 15-minute readings taken during each test run.
[40 CFR 63.11211(b), Table 6 to Subpart 6J]
The minimum secondary power must be re-established with any subsequent
performance tests.
ii. Demonstrating Continuous Compliance—For the electrostatic precipitator
(ID No. ESP-1)the Permittee shall:
A. Install and operate a secondary power continuous parameter
monitoring system that complies with the installation, operation,
maintenance, and performance evaluation requirements of 40 CFR
63.11221 and 40 CFR 63.11224.
B. Collect total secondary power data at a minimum of one cycle of
operation every 15 minutes. There must be data values from a
minimum of four successive cycles of operation representing each of
the four 15-minute periods in an hour, or at least two 15-minute data
values during an hour when monitoring system calibration, quality
assurance, or maintenance activities are being performed,to have a
valid hour of data. [40 CFR 63.11224(d),Table 7]
C. Reduce the data to 30-day rolling averages;calculate a 30-day rolling
average from all of the hourly averages collected for the 30-day
operating period using Equation 3 of 40 CFR 63.11224(d).
D. Maintain the 30-day rolling average secondary electric power at or
above the minimum established during the most recent particulate
performance testing.
E. Operation below the established minimum, or outside the allowable
range of the operating'limits constitutes:a deviation from the
operating limits except during performance tests conducted to
'determine compliance with the emission and operating limits or to
establish new operating lirnits. Operating limits are confirmed or re-
established during performance tests. [40 CFR.63.11222(a)(1)]
iii. Site Specific Monitoring Plans—The Permittee shall submit a site specific
monitoring plan 60 days before the initial performance test. [40 CFR
63.11205(c) and 40 CFR 63.11224(c)]
f. Recordkeepmg Requirements -In addition to any other recordkeeping requirements
of the EPA,the Permittee shall maintain the following records:

Permit No. 10126R03
Page 9
L. The Permittee must prepare an Annual Compliance Certification report for
the previous calendar year by March l"of each year starting March 1st of the
calendar year following start-up of the boiler. The report must meet the
requirements of 40 CFR 63.11225(b)(1-4).
ii. The Permittee must maintain copies of all required notifications and reports.
[40 CFR 63.11225(c)(1)]
iii. The Permittee must maintain the following records to document conformance
with the work practices, emission reduction measures, and management
practices:
A. Tune-up records -Records must identify each boiler,the date of tune-
up, the procedures followed for tune-up,the manufacturer's -
specifications to which the boiler was tuned, and the following:
I. The concentrations of CO in the effluent stream in parts per
million,by volume, and oxygen in volume percent,measured
at high fire or typical operating load,before and after the tune-
up of the boiler.
IL A description of any corrective actions taken as a part of the
tune-up of the boiler.
B. Records of non-waste determinations. [40 CFR 63.11225(c)(2)(ii)]
C. The Permittee must keep records of monthly fuel use by each affected
boiler, including the type(s) of fuel and amount(s) used. [40 CFR
63:11225(c)(2)(iv)]
iv. The Permittee must maintain records of the occurrence and duration of any
malfunction of the boiler,or of the associated air pollution control devices
and monitoring equipment. [40 CFR 63.1.1225(c)(4)]
V. The Permittee,must maintain records of actions taken during periods of
malfunction to minimize emissions in accordance with the general duty to .
minimize.emissions in 40 CFR 63.11205(a), including corrective.actions to
restore;the malfunctioning boiler, air pollution control, or monitoring
equipment to its normal or usual manner.of operation. [40 CFR
63 11225(c)(5)]
vi. The Permittee must maintain records of all inspection and monitoring data
required by 40 CFR 63.11221 and 40 CFR 63.11222, and the information
identified,in paragraphs 40 CFR 63.11225.(c)(6)(i) through(vi) for each
required inspection or monitoring..[40 CFR 63.11225(c)(6)]
vii. The Permittee.must keep each record for five years following the date of each
recorded action.. Each record must be kept on site or be accessible from a
.,central'location by computer or other means that instantly provide access at

k
Permit No. 10126R03
Page 10
the site for at least two years after the date of each recorded action. Records
may be kept off site for the remaining three years. [40 CFR 63.11225(d)]
g. Notification and Reporting Requirements-In addition to the notification and
reporting requirements of the Environmental Protection Agency (EPA),the
Permittee is required to NOTIFY the Regional Supervisor,DAQ, in WRITING, of
the following.
i. The Permittee shall submit an Initial Notification within 120 days after
startup of the source. [40 CFR 63.11225(a)(2)]
ii. The Permittee must submit a Notification of Intent to conduct a performance
test at least 60 days before the performance stack test is scheduled to begin.
[40.CFR 63.1.1225(a)(3)]
iii. The Permittee shall submit a Notification of Compliance Status within 60
days of:completing any.performance stack testing and within 6.0 days of
conducting subsequent performance tests. [40 CFR 63.11225{a)(4)]
A. The Permittee must include a signed statement in the notification that
indicates that the.Permittee conducted startups and shutdowns
according to the manufacturer's recommended procedures or
procedures specified for a boiler of similar design if manufacturer's
recommended procedures are not available. [40 CFR 63.11223(g)]
B. The notification must also be submitted electronically using the
Compliance and Emissions Data Reporting Interface(CEDRI)that is
accessed through EPA's Central Data Exchange (CDX)
(www.epa:gov/cdx).
iv. Annual Compliance Certification report must be prepared by March I of
each year and submitted upon request. If the source experiences any.
deviations from the applicable requirements,then the report must be
submitted to the Division of Air Quality by March 15th. The report must
meet the`requirements-of 40 CFR-63.11225(b)(1-4).
v. Within 60 days after the date of completing each performance test,the
Permittee must submit the results of the performance tests to EPA's
WebFIRE database by using CEDRI that is accessed through EPA's CDX
(www.epa.gov/cdx). Performance test data must be submitted in the file
format generated through use of EPA's Electronic Reporting Tool(ERT).
Only data collected using test methods on the ERT web site are subject to this
requirement for submitting reports electronicallytoWebFIRE. Owners or
operators who claim that some of the information being submitted for
performance tests is confidential business information(CBI)must submit a
complete ERT file including information claimed to be' CBI on.a compact
disk or other commonly used electronic storage media(including,but not
limited to,flash drives) to EPA. The electronic media must be clearly

Permit No. 101261103
Page 11
marked as..CBI and mailed to U.S. EPA/OAPQS/CORE CBI Office,
Attention: WebFIRE Administrator,MD C404-02,4930 Old Page Rd.,
Durham,NC 27703. The same ERT file with the CBI omitted must be
submitted to EPA via CDX as described earlier in this paragraph. At the
discretion of the delegated authority,the Permittee must also submit these
reports,including CBI, to the delegated authority in the format specified by
the delegated authority. For any performance test'conducted using test
methods that are not listed on the ERT Web site,.the owner or operator shall
submit the results of the.performance test in paper submissions to the
Administrator at the appropriate address listed in 40 CFR 63.13. [40.CFR
63.11225(e)]
12. CONTROL AND.PROHIBITION OF ODOROUS EMISSIONS -As required by 1.5A
NCAC 2D .1806 "Control and.Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
13._LIMITATION TO AVOID 15A NCAC 2Q_0501 Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor'Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
.Section and Requirement for a Permit," as requested by the Permittee, facility-wide
emissions.shall be less than the following:
ollutant Emission Limit
(Tons per consecutive 12-month period)
PM10 : 100 .
COry_� W_. _ 100 :-.�.
NOx 100 _._. _...
�- S02 100
VOC ; r00 . .
a. Recordkeeping Requirements -To ensure emissions do not exceed the limitations
above,the following shall be calculated and recorded monthly for the clean
cellulosic biomass boilers(ID Nos. ES13-1, ESB-2 and ESB-3):
i. the monthly tons of each fuel combusted;
H. monthly CO and NOk.emissions from each biomass fuel. Each fuel's
emission is calculated as follows:
f(lbs fuel)x(Btu/lb.average heat content)x(MMBtu/1.OE6 Btu)x(emission factor)]/2000
where the CO and NOx emission factors are the most current approved stack
test rates for the boilers. Any test rates/factors must be approved by the DAQ
prior to application for compliance with this condition; and

Permit No. 10126R03
Page 12
iii-. the rolling 12-month facility-wide CO and NOx emissions.
b. Reporting Requirements- Within 30 days after each calendar year, regardless of the
actual emissions, the Permi.ttee shall submit the following:
L. the tons of each fuel combusted per month in.the.calendar year;and
ii. for each calendar month, the rolling 12-month total facility-wide CO and
NOx emissions.
14. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" -In accordance with 15A NCAC 2Q .0317,to comply with this permit
and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant
Deterioration," as requested by the Permittee.,facility-wide PM and PMio emissions shall be
less than 250 tons per consecutive 12-month period.
a. Operations Restrictions To ensure emissions do riot exceed the limitations above,
the facility shall comply with Inspection and Maintenance Requirements listed in
Specific Conditions 9.; 10. and 11 of this Permit.
15. GENERAL ASSEMBLY OF NORTH CAROLINA SESSION LAW 2007-397 SENATE
BILL 3 (SB3)—Under the provisions of the Renewable Energy and Energy Efficiency
Portfolio Standard (REPS),the Permittee will be categorized as a new renewable energy
facility that delivers electric power to an electric power supplier. North Carolina General
Statute 62-133.7(g)requires biomass combustion processes at a new renewable energy
facility to meet Best Available Control Technology(BACT). The Permittee submitted a
revised BACT analysis to the Division of Air Quality on August 11,2015. The Division of
Air Quality completed'the BACT determination on November 21,2016. The following
BACT limits for biomass boilers ID Nos. ESB-1, ESB-2 and ESB-3 shall not be exceeded:
Pollutant SB3 BACT Emission Limit Compliance Method
Staged Combustion and
Good.Combustion Practices,
NOx 0.34 .lb/tnmBtu Initial Testing,then additional testing
(3-hr average) once per permit term thereafter
by test method determined by
DAQ approved testing protocol
SOa Firing Clean Permitted or approved NHSM biomass fuels
Cellulosic Biomass
Initial Testing then additional testing
0.05 lb/MMBtu once p.er permit term thereafter
PM/PM10/PM2.5 filterable and condensable) by test method determined by DAQ
(3-hour average) approved testing protocol
Good Combustion Practices
CO 0.45 lb/MMBtu Initial.Testing,then additional.testing
(3-hour average) once per permit term thereafter by test method
determined by DAQ approved testing protocol

Permit No. 10126R03
Page 13
Pollutant SB3 BACT Emission Limit Compliance Method
Compliance with applicable provisions for
VOC Good Combustion Practices inspection and maintenance of air pollution
control equipment.in 15A NCAC 02.D.0315
Compliance with applicable provisions for
Hg Good Combustion Practices inspection and maintenance of air pollution
control equipment in 15A NCAC 02D.0315
a. The initial performance testing for NOx, PM/PMlo/PM2.5 and CO on the boilers shall
.,be conducted no later than June 6,2017 (180 days from permit issuance date).
b. Following the initial testing,the Permittee shall demonstrate compliance by testing
the boilers for NOx, PNVPMio/PM2,5 and CO once every eight years (permit term).
The tests must be completed within 30 days before and 30 days after the eight-year
span between test dates.
c. PM testing conducted under Specific Condition l Ledii. and iv. for compliance with
the Boiler GACT may also qualify as testing for compliance with the BACT
emission limit.
d. The Permittee,shall arrange for air emission testing protocols to be provided to the
Director at least 45 days prior to air pollution testing. The Division of Air.Quality
shall review air emission testing protocols for pre-approval prior to testing.
e. To afford the Regional Supervisor, DAQ, the opportunity to have an observer
present,the Permittee shall provide the Regional Office, in writing, at least 15 days
notice of any required performance test(s).
f. The Permittee shall be responsible for ensuring that the boilers are operated at or
near maximum normal production rate a.§ determined by operations over the previous
12 months. The emission test report shall include data supporting the determination
of maximum normal production rate and shall include the average production rates
determined during each testing period.
g., If any test fails to.,demonstrate compliance with the corresponding BACT limit,
re-testing will be conducted, along with any additional testing that may be required
on either boiler per notice made by DAQ.
h. Two copies of the final air emission test reports shall be submitted to the Director not
later than 30 days after testing. The Permitte.e may request an extension to submit.the
final test report. The Director shall approve an extension request if she finds that the
extension request is a result of actions beyond the control of the owner or operator.
i. All associated testing costs are the responsibility of the Permittee.

Permit No. 10126R03
Page 14
16. The Permittee must notify the Division of Air Quality in writing within 30 days of beginning
use of a new clean cellulosic biomass fuel. For any fuel that is not clearly defined as clean
cellulosic biomass in 40 CFR 241 or.separately approved as a non-hazardous secondary
material(NHSM); biomass fuel by the Environmental Protection Agency,the Permittee
must first submit a NHSM determination request to the Division of Air Quality.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S..143-215.108(c)(1),TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA,MONITORING DATA NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor.
North Carolina Division of Air Quality
Washington Regional Office
943 Washington Square Mall
.Washington,NC 27889
252-946-6481
For identification purposes,each submittal should include the facility name as listed on the
permit,the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT-In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request,These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years,unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ.Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 2Q .0301,a new air permit
shall be obtained by the Permittee prior to establishing,building, erecting, using, or
operating the emission sources or air cleaning lequipmdnt at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT -In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted,new, or increased emissions must be
reported to the Regional Supervisor,'DAQ:
a. changes in the`information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.

Permit No. 10126R03
Page 15
If appropriate,modifications to the permit may then be made by the DAQ to reflect any
necessary,changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated.and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified-by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1),.this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ,
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S..143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State,or Local
water quality or land quality control authority.
10. in accordance with 15A NCAC`2D :0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to,the Regional Supervisor,DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include,but is not limited to,process weight rates,firing rates,hours of
operation,and preventive maintenance schedules. '
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.1148, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2),no person shall refuse entry or
access.to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and.who presents appropriate credentials,nor shall any person
obstruct,hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment.of civil penalties:
13. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State,or Local requirements
governing the handling, disposal,or incineration of hazardous,solid,or medical wastes,
including the Resource Conservation and Recovery Act(RCRA)administered by the
Division of Waste Management.

Permit No. 10126R03
Page 16
14. PERMIT RETENTION REQUIREMENT- In accordance with 15A NCAC 2Q .0110,the
Permittee shall retain a current copy of the air permit at the site.The Permittee must make
available to personnel of the DAQ, upon request,the current copy of the air permit for the
site.
15 CLEAN AIR ACT SECTION 112(r UIREMENTS - Pursuant to l5A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act,then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES GENERAL DUTY-Pursuant to Title I
Part A Section 112(r)(1)of the Clean Air Act "Hazardous Air Pollutants -Prevention of
Accidental Releases Purpose and General Duty," although a risk management plan may not
be required., if the Permittee produces,processes, handles, or stores any amount of a listed
hazardous substance, the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release.This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If'emissions
testing is required by this permit, or the DAQ, or if the Permittee`submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including;protocol approval,regional notification,report-submittal,and test
results approval:
Permit issued this the 8'of December,2016. .
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Robert P. Fisher
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 10126R03

ATTACHMENT to Permit No. 10126R03, December 8, 2016
Insignificant/Exempt Activities
Source Exemption Source of TAPS? Source of Title V
Regulation Pollutants?
1ISB 1 bunker (h)(5)Green wood fuel storage bker 2Q .0102 No Yes
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 'Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here: http://www.ncair.org_/permits/insi /