AQ_F_0800044_20160112_PRMT_Permit

PAT MCCRORY
6ovenior
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
January 12, 2016
Dr. David M. Peele, Ph.D.
President
Avoca Incorporated
P.O.Box 129
Merry Hill,North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T45
Facility ID: 0800044
Avoca Incorporated
Merry Hill,Bertie County,North Carolina
Fee Class: Title V
PSD Status: Major
Dear Dr. Peele:
In accordance with your completed Prevention of Significant Deterioration (PSD) application
deemed complete on September 1,2015,we are forwarding herewith Air Quality Permit No. 01819T45
to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, North Carolina, authorizing the
construction and operation, of the emission source(s) and associated air pollution control device(s)
specified herein. Additionally, any emissions activities determined from your Air Quality Permit
Application as being insignificant per 15A North Carolina Administrative Code 2Q .0503(8)have been
listed for informational purposes as an "ATTACHMENT." Please note the requirements for the annual
compliance certification are contained in General Condition P in Section 3. The current owner is
responsible for submitting a compliance certification for the entire year regardless of who owned the
facility during the year.
As the designated responsible official it is your responsibility to review,understand, and abide by
all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any
person who operates any emission source and associated air pollution control device subject to any term
or condition of the attached permit reviews, understands, and abides by the condition(s) of the attached
permit that are applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality 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. This hearing request must be in the form of a
written petition, conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both
the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714
and the Division of Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh,North Carolina
27699-1641. The form for requesting a formal adjudicatory hearing may be obtained upon request from
the Office of Administrative Hearings. Please note that this permit will be stayed in its entirety upon
receipt of the request for a hearing. Unless a request for a hearing is made pursuant to NCGS 15013-23,
this Air Quality Permit shall be final and binding 30 days after issuance.
State of North Carolina I Environmental Quality Air Quality
1641 Mail Service Center 217 W.Jones Street,Suite 4000 J Raleigh,NC 27609-1641
919 707 8400 T

Dr. Peele
January 12, 2016
Page 2
You may request modification of your Air Quality Permit through informal means pursuant to
NCGS 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 this Air Quality
Permit will become final and binding regardless of a request for informal modification unless a request
for a hearing is also made under NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in
this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of GS 143-215-108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure
to receive an Air Quality Permit or written approval prior to commencing construction is a violation
of GS 143-215.108A and may subject the Permittee to civil or criminal penalties as described in GS
143-215.114A and 143-215.114B.
Bertie County has been triggered for increment tracking under PSD for PM10, S02, and NOx.
However, no changes in actual emissions of these pollutants are associated with the permit
modification.
This Air Quality Permit shall be effective from January 12, 2016 until December 31, 2015,' is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein. Should you have any questions concerning this matter, please contact Betty
Gatano, P.E. at(919) 707-8736 or [e-mail].
Sincerely yours,
V42J,
William D. Willets, P.E., Chief,Permitting Section
Division of Air Quality,NCDEQ
Enclosure
c: Rob Fisher, Supervisor, Washington Regional Office
Heather Ceron, EPA Region 4
Central Files
Connie Horne(cover letter only)
This permit shall expire on the earlier of November 30,2020 or the date the renewal of Air Permit No.01819T44
has been issued or denied.

ATTACHMENT to Permit No. 01819T45
Insignificant Activities per 15A NCAC 02Q .0503(8)
Emission Control Device Control Device
Source ID No. Emission Source Description ID No. Description
IWWTP-ET1 Wastewater treatment plant equalization tank N/A N/A
No. 1 (65,500 gallon capacity)
IWWTP-ET2 Wastewater treatment plant equalization tank N/A N/A
No.2(65,500 gallon capacity)
Wastewater treatment plant aeration tank No.2
IWWTP-AT2 (63,500 gallon capacity) N/A N/A
Wastewater treatment plant aeration tank No. 3
IWWTP-AT3 (63,500 gallon capacity) N/A N/A
IWWTP-CLR Wastewater treatment plant clarifier(1,310 N/A N/A
gallon capacity)
ITK9238 No.2 fuel oil storage tank(50,000 gallon N/A N/A
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon N/A N/A
capacity)
ITK102 No.2 fuel oil storage tank(495 gallon N/A N/A
capacity)
ITK103 No. 2 fuel oil storage tank(495 gallon N/A N/A
capacity)
ITKFP No.2 fuel oil storage tank(270 gallon N/A N/A
capacity)
CD-Z-9215 One water spray fume
scrubber(0.5 gallons
per minute minimum
ECS process:batch preparation of water injection rate)
IECS ethylenediamine/copper sulfate solution
CD-Z-9216 One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
IES-PV Propane vaporizer N/A N/A
11 I-Briquette Sage Briquetting Machine N/A N/A
1. Because an activity is insignificant 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 A 100 "Control of Toxic Air
Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and MACT ZZZZ see the NC DAQ website:
htti)://dag.state.nc.us/toxics/areasources/.

Summary of Changes to Permit
The following changes were made to Avoca Incorporated,Merry Hill,Air Permit No01819T45:
Pages Section (Description of Changes
Cover and -- Updated all dates and permit revision numbers.
throughout
3-8 1.0 Equipment List • Added page numbers
• Added the following emission sources to the SFG operations:
o One 12,500 gallon storage tank(ID No.T-3006)
o One 12,500 gallon process tank(ID No.T-3007)
o Two reactors(ID Nos.R-3003 and R-3004)with process
condensers(ID Nos.EX-3004 and ES-3005)
o One centrifuge(ID No.C-3002)
o One dryer with(ID No.D-3002)with process condenser(ID No.
ES-3006)and a chilled water control condenser(ID No.CD-
3002)
• Added a second process condenser(ES-3002)on reactor(ID No.R-
3001)
• Added the chilled water condenser(ID No. CD-3003)and the
mineral oil scrubber(ID No.CD-3004-5)as optional controls on
several SFG emission sources.
• Corrected cross reference in footnote No. 1.
• Removed reference to two storage and recycle tanks(ID Nos.ES-M-
125A and ES-M-12513)from footnote No. 1. These tanks are not
part of the equipment subject to BACT specified in Section 2.2.13.
• Removed footnotes and asterisks relating to minor modifications for
emission sources(ID Nos.ES-ES-M-125A and 125B,E104,ES-TK-
PNE-1,and D-1002).
• Removed footnotes and asterisks for 502(b)(10)notification for
emission source(ID No.ES-MSDU-1024).
• Removed footnotes and asterisks relating to a 15A NCAC 2Q
.0501(c)(2)modification for emission sources(ID Nos.ES-13131,ES-
BB2,ES-RD,CD-BB1C and CD-BB1BH). The Permittee met this
requirement with the submittal of a Permit application on October
10,2012.
• Removed footnotes and asterisks relating to a 15A NCAC 2Q
.0501(c)(2)modification for emission sources in the SFG operation.
The Permittee met this requirement with the submittal of a Permit
application on May 30,2014.
9— 10 2.1.A.Lb
2.1.A.2.b Updated testing condition with most current version.
2.1.A.3.c
11— 12 2.1.B.Lb
2.1.B.2.b Updated testing condition with most current version.
2.1.B.4.b
16—17 2.1.D.Lb Updated testing condition with most current version.
2.1.D.2.b
19 2.1.E—Regulations • Added reference for avoidance of 15A NCAC 2D.0530,"Prevention
Table of Significant Deterioration'(PSD).
• Added reference for avoidance of 15A NCAC 2D.1112,"112(g)
Case-by-Case Maximum Achievable Control Technology."

Pages Section (Description of Changes
20 2.1.E.1 . Removed requirement for stack testing of the biomass boilers(ID
(old numbering) Nos. ES-BB 1 and ES-BB2). The testing was conducted on
December 6,2011 and approved by DAQ via memorandum dated
January 24,2012.
Renumbered the remaining section accordingly.
24—25 2.1.G Added permit condition for Best Available Control Technology
(BACT)limit under 15 NCAC 2D .0530,PSD for the modified SFG
operations.
26 2.2.A—Regulations Added reference for 15A NCAC 2D.1100,"Control of Air Toxics."
Table
29 2.2.B.Lb Updated testing condition with most current version.
41 2.2.0 Removed SFG operations from equipment list.
45 2.2.C.l.c.ii.(A)(1) Removed SFG operations from requirements for batch process vents
under 40 CFR Part 63,Subpart FFFF and renumbered the permit
condition accordingly. With the use of heptane,the SFG operations are
no longer subject to the 40 CFR Part 63,Subpart FFFF.
-- 2.2.C.2 Removed avoidance condition under 15A NCAC 2Q .0317 for 15A
NCAC 2D .0530,PSD,for the SFG operations. With the expansion of
the SFG operations,these operations become subject to PSD.
-- 2.2.C.3 Removed avoidance condition under 15A NCAC 2Q.0317 for Group
Process Vents under 40 CFR Part 63,Subpart FFFF. With the use of
heptane,the SFG operations are no longer subject to the 40 CFR Part
63,Subpart FFFF.
49 2.2.D.Le Added non-compliance statement.
49 2.2.E.1.d Added non-compliance statement.
51 —61 3.0 Updated the General Conditions and the List of Acronyms to the most
current version(V4.0: 12/17/2015).

State of North Carolina
N;C- Department of Environmental Quality
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T45 01819T44 January 12, 2016 December 31, 2020`
i This permit shall expire on the earlier of December 31,2020 or the date the renewal of Air Permit No.01819T44 has been
issued or denied.
Until such time as this permit expires or is modified or revoked,the below named Permittee is authorized to construct
and operate the emission source(s)and associated air pollution control device(s)specified herein,in accordance with
the terms, conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B
of Chapter 143,General Statutes of North Carolina as amended,and Title 15A North Carolina Administrative Codes
(15A NCAC), Subchapters 2D and 2Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission
source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application
to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Avoca, Inc.
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County, State, Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.O. Box 129
City, State, Zip: Merry Hill,NC 27957
Application Number: 0800044.15A
Complete Application Date: September 4,2015
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington, NC 27889
Permit issued this the 12th day of January, 2016.
William D. Willets,P.E.,Chief,Permitting Section
By Authority of the Environmental Management Commission

Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S)AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring, recordkeeping, and reporting
requirements)
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring,recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENTS
List of Acronyms

Permit 01819T45
Page 3
SECTION 1 - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances:
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. I ID No. Description
Rotocel Operations
13,27, ES-1001-2-1-P1 Rotocel extractor,desolventizer, CD-31209 One chilled water
43 PSD and solvent separation/recovery condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,43 ES-M-125A and M- Two storage and recycle tanks CD-1001-2-C-1 One chilled water
125B (19,500 gallons capacity each) condenser
MACT FFFF
CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,27, ES-1001-2-1-17 Process equipment leaks NA NA
43 PSD
MACT FFFF
13,27, ES-1001-2-1-WW Rotocel Operations wastewater NA NA
43 PSD stream
MACT FFFF
Recovery Operations
13,27, ES-1001-1-1-P1 Arcon process tank M-1 CD-1001-1-3 One chilled water
43 PSD condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,27, ES-1001-1-1-P2 Stripper T-5 and receiver M-21 CD-1001-1-T513 One chilled water
43 PSD condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
13,27, ES-1001-1-1-P3 Seven process tanks of various scrubber(8 gallons per
43 PSD capacities and one fixed roof minute minimum mineral
MACT FFFF methanol storage tank(7,050 oil injection rate)
gallon capacity)
13,27, ES-1001-1-1-F Process equipment leaks NA NA
43 PSD
MACT FFFF
13,27, ES-1001-1-1-WW Recovery Operations wastewater NA NA
43 PSD stream
MACT FFFF

Pages Section Description of Changes
20 2.1.E.1 • Removed requirement for stack testing of the biomass boilers(ID
(old numbering) Nos. ES-BB 1 and ES-BB2). The testing was conducted on
December 6,2011 and approved by DAQ via memorandum dated
January 24,2012.
• Renumbered the remaining section accordingly.
24—25 2.LG Added permit condition for Best Available Control Technology
(BACT)limit under 15 NCAC 2D.0530,PSD for the modified SFG
operations.
26 2.2.A—Regulations Added reference for 15A NCAC 2D.1100,"Control of Air Toxics."
Table
29 2.2.B.Lb Updated testing condition with most current version.
41 2.2.0 Removed SFG operations from equipment list.
45 2.2.C.l.c.ii.(A)(1) Removed SFG operations from requirements for batch process vents
under 40 CFR Part 63,Subpart FFFF and renumbered the permit
condition accordingly. With the use of heptane,the SFG operations are
no longer subject to the 40 CFR Part 63, Subpart FFFF.
-- 2.2.C.2 Removed avoidance condition under 15A NCAC 2Q.0317 for 15A
NCAC 213.0530,PSD,for the SFG operations. With the expansion of
the SFG operations,these operations become subject to PSD.
-- 2.2.C.3 Removed avoidance condition under 15A NCAC 2Q.0317 for Group
Process Vents under 40 CFR Part 63,Subpart FFFF. With the use of
heptane,the SFG operations are no longer subject to the 40 CFR Part
63,Subpart FFFF.
49 2.2.D.Le Added non-compliance statement.
49 2.2.E.l.d Added non-compliance statement.
51 —61 3.0 Updated the General Conditions and the List of Acronyms to the most
current version(V3.7: 09/21/2015).

Permit 01819T45
Page 4
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID Nc I I ID No. Description
Concrete Operations
27,42 ES-1001-1-2-P Six process tanks of various CD-1001-1-2 One chilled water
PSD capacities condenser
MACT FFFF
42 HB-1 One steam-heated hot box NA NA
MACT FFFF
42 HB-2 One steam-heated hot box NA NA
MACT FFFF
42 HB-3 One steam-heated hot box NA NA
MACT FFFF
42 HB-4 One steam-heated hot box NA NA
MACT FFFF
42 ES-1001-1-2-F Process equipment leaks NA NA
MACT FFFF
42 ES-1001-1-2-WW Concrete Operations wastewater NA NA
MACT FFFF stream
Sclareol Recrystallization(SFG) Operations
24 T-3001 One process tank(6,700 gallons Optional controls Optional controls
PSD capacity) CD-3003 Chilled water condenser
24 T-3002 through 3005 Four process tanks(2,538 gallons
PSD capacity each) CD-3004-S Mineral oil scrubber
24 T-3006 One storage tank(12,500 gallons
PSD capacity)
24 T-3007 One process tank(12,500 gallons
PSD capacity)
24 C-3001 and C-3002. Two centrifuges
PSD
24 R-3002 One reactor equipped with a
PSD chilled water process condenser
(EX-3003)
24 R-3003 One reactor equipped with a
PSD chilled water process condenser
(EX-3004)
24 R-3004 One reactor equipped with a
PSD chilled water process condenser
(EX-3005)
24 R-3001 One reactor equipped with two CD-3001 Chilled water condenser
PSD chilled water process condensers
(EX-3001 and ES-3002) Optional controls Optional controls
24 D-3001 One steam-heated dryer equipped CD-3003 Chilled water condenser
PSD with a chilled water process
condenser(EX-3002) CD-3004-S Mineral oil scrubber
24 D-3002 One steam-heated dryer equipped CD-3002 Chilled water condenser
PSD with a chilled water process
condenser(EX-3006) Optional controls Optional controls
CD-3003 Chilled water condenser
CD-3004-S Mineral oil scrubber
24 ES-1003-10-F Process equipment leaks NA NA
PSD

Permit 0 18 19T45
Page 5
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
24 ES-1003-10-WW SFG Process wastewater stream NA NA
PSD
Biological Conversion Equipment for Purification of Sclareolide
42 ES-1001-1-3-P Twelve process tanks of various NA NA
MACT FFFF capacities
42 G-17 One centrifuge NA NA
MACT FFFF
42 ES-1001-1-3-F Process equipment leaks NA NA
MACT FFFF
42 D-1202 One steam-heated dryer NA NA
MACT FFFF
42 A-2 One distillation column(6 gallons NA NA
MACT FFFF per minute nominal process rate)
42 ES-1001-1-3-WW Biological conversion equipment NA NA
MACT FFFF for purification of sclareolide
wastewater stream
Sclareolide(SDE) Operations
42 ES-1001-1-4-P Four process tanks of various NA NA
MACT FFFF capacities
42 M-20 One acetic acid storage tank NA NA
MACT FFFF (10,135 gallon capacity)
42 ES-1001-1-4-F Process equipment leaks NA NA
MACT FFFF
42 M-10 One batch reactor CD-M-34 One venturi-type wet
MACT FFFF scrubber(10 gallons per
42 M-10A One batch reactor minute minimum liquid
MACT FFFF injection rate)
42 D-1231A One batch reactor
MACT FFFF
42 D-1231B One batch reactor
MACT FFFF
42 ES-1001-1-4-WW SDE Operations wastewater NA NA
MACT FFFF stream
Plant Nutrient Extraction(PNE) Operations
42 D31214 One product extract reactor EX2203 One chilled water
MACT FFFF condenser
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)

Permit 01819T45
Page 6
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
42 D31211 One waste solids separator vessel EX2205 One chilled water
MACT FFFF (1,333 gallon capacity) condenser
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
42 ES-TK-PNE-1 Solvent Process Tank(9,500 NA NA
MACT FFFF gallons capacity
42 ES-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
42 ES-1003-2-1-WW PNE process wastewater stream NA NA
MACT FFFF
42 ES-1003-2-1-P Seven process tanks of various CD-Z-9215 2 One water spray fume
MACT FFFF capacities scrubber(0.5 gallons per
42 C-31203 One centrifuge minute minimum water
MACT FFFF injection rate)
42 D-1002 One dryer with a process chilled
MACT FFFF water condenser CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
42 D-2202 One reactor CD-Z-9215 2 One water spray fume
MACT FFFF scrubber(0.5 gallons per
42 D-1215 One reactor minute minimum water
MACT FFFF injection rate)
42 D-1218 One reactor
MACT FFFF CD-Z-9216 2 One water spray fume
42 D-1201 One steam-heated dryer scrubber(0.5 gallons per
MACT FFFF minute minimum water
injection rate)
42 ES-1003-2-2-F Process equipment leaks NA NA
MACT FFFF
42 ES-1003-2-2-WW EVG Operation wastewater stream NA NA
MACT FFFF
Botanical Extraction Operations
15,27, ES-1001-11-P Immersion extractor Z-1001, CD-1001-11-EX1002 One chilled water
43 PSD desolventizer Z-1002, condenser
CAM day tank 90024(6,000 gallon
MACT FFFF capacity), CD-1001-11-EX 1003 One cryogenic(nitrogen)
first-stage evaporator EX-1012, condenser system(40 OF
second-stage evaporator EX-1013, maximum 24-hour
distillation column EX-90008,and average outlet
nine process tanks of various temperature)
IL capacities

Permit 01819T45
Page 7
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
15,27, ES-1001-11-F Process equipment leaks NA NA
43 PSD
MACT FFFF
15 MHZ-1002 One plant material grinder(1,011 CD-1003-4-1 One bagfilter(244 square
pounds per hour nominal feed rate) feet of filter area)
15,27, ES-1001-11-WW Botanical extraction operation NA NA
43 PSD wastewater stream
MACT FFFF
Biomass Extraction Operations
15,27 ES-1004-1 Biomass extraction debagging CD-1004-1-FF1 One cartridge filter(6.7:1
PSD maximum air-to-cloth
ratio)
15,27 ES-1004-2-F Process equipment leaks NA NA
PSD
15,27 ES-1004-2-WW Biomass extraction operation NA NA
PSD wastewater stream
15,27 ES-1004-2-P Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
PSD desolventizer Z-41002, condenser
CAM day tank 490025(9,953 gallon
capacity), CD-1004-2EX1003 One cryogenic(nitrogen)
iso-hexane storage tank 490024 condenser system(40°F
(13,536 gallon capacity), maximum 24-hour
first stage evaporator EX-41012, average outlet
second stage evaporator temperature)
EX-41013,
distillation column EX-490008,
and
nine process tanks of various
capacities
15 ES-1004-2Silo Biomass silo loadout CD-1004-2-FF2 One bagfilter(254 square
feet of filter area)
15 ES-MSDU-1024 Molecular sieve I N/A N/A
Miscellaneous Operations
9,27 H-101 One No.2 fuel oil-fired boiler NA NA
2D.1109 case-by- (20.3 million Btu per hour
case MACT maximum heat input rate)
9,27 H-102 One No. 2 fuel oil-fired boiler NA NA
2D.1109 case-by- (20.3 million Btu per hour
case MACT maximum heat input rate)
9,27 H-103 One No.2 fuel oil-fired boiler NA NA
2D.1109 case-by- (25.2 million Btu per hour
case MACT maximum heat input rate)
19 ES-BB1 and ES-BB2 Two biomass/bio-based solids- CD-BB1C One simple cyclone(114
NSPS—Subpart De fired boilers(24 million Btu per inches in diameter)
MACT—Subpart hour maximum heat input rate
DDDDD each) CD-BB 1 BH One bagfilter(8,900
square feet of filter area)

Permit 01819T45
Page 8
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
19 ES-RD One No.2 fuel oil/propane-fired CD-BB1C One simple cyclone(114
rotary dryer(30.0 million Btu per inches in diameter)
hour maximum heat input rate)
CD-BB 1BH One bagfilter(8,900
square feet of filter area)
11 ES-PkGenl One No.2 fuel oil-fired limited CD-CatOxl One catalytic oxidizer
MACT ZZZZ use emergency generator(2,935 (695 °F minimum inlet
kilowatt maximum rated power temperature)
output)
27,43 WWTP-ATl Wastewater treatment plant NA NA
PSD aeration tank No. l
MACT FFFF
23 E101 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(587 horsepower
maximum rated power output)
23 E 102 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(760 horsepower
maximum rated power output)
23 E103 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(603 horsepower
maximum rated power output)
23 E104 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(401 horsepower
maximum rated power output)
23 FP One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ fire water pump(285 horsepower
maximum rated power output)
' The Permittee is permitted to operate sources(ID Nos ES-1001-1-1-P1,ES-1001-1-1-P2, and ES-1001-1-1-P3) without the
simultaneous operation of scrubber(ID No.CD-1001-2-S-1)under the conditions cited in Sections 2.2 B.l.c and d,below.
2 The Permittee is allowed to operate PNE and EVG operations without operating the water spray fume scrubber(ID No.CD-Z-
9215)and water spray scrubber(ID NO.CD-Z-9216)when using non-HAP solvents.

Permit 01819T45
Page 9
SECTION 2 — SPECIFIC LIITATIONS AND CONDITIONS
2.1 - Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Three No. 2 fuel oil-fired boilers (ID Nos.H-101,H-102, and H-103)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter 0.37 pounds per million Btu heat input 15A NCAC 213 .0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 21) .0521(d)
Visible emissions
40 percent opacity: H-101 and H-102 15A NCAC 21) .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 21) .1109
Control Technology (1120)Case-by-Case MACT)
1. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 2D
.0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping, or reporting is required for particulate emissions from the firing of No. 2
fuel oil in boilers(ID Nos.H-101,H-102, or H-103).
2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be
included when determining compliance with this standard.
Testing[15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0516.

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Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for sulfur dioxide emissions from the firing of No.
2 fuel oil in boilers(ID Nos. H-101,H-102,or H-103).
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers (ID Nos. H-101 and H-102) shall not be more than 40 percent opacity
when averaged over a six-minute period. However, six-minute averaging periods may exceed 40 percent
not more than once in any hour and not more than four times in any 24-hour period. In no event shall the
six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler(ID No. H-103) shall not be more than 20 percent opacity when averaged
over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than
once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
c. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.3.a or b, above, as applicable, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting[15A NCAC 2Q .0508(f)]
d. No monitoring,recordkeeping, or reporting is required for visible emissions from the firing of No. 2 fuel
oil in boilers(ID Nos. H-101,H-102,or H-103).
4. 15A NCAC 2D .1109: 112(J) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 112(j)- Case-by-Case MACT for Boilers &Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers (ID Nos.11-101, H-
102, and H-103). The initial compliance date for this work practice standard and the associated
monitoring,recordkeeping, and reporting requirements is August 17,2013. These conditions need not be
included on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance,the Permittee shall perform an annual boiler inspection and maintenance on boilers
as recommended by the manufacturer,or as a minimum,the inspection and maintenance requirement shall
include the following:
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Permittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement.The Permittee shall be deemed in noncompliance with 15A NCAC 2D
.1109 if the affected boilers are not inspected and maintained as required above.
Recordkeeping [15A NCAC 2Q .0508(f)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a logbook
(written or electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.

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The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-PkGenl) and one associated catalytic
oxidizer (ID No. CD-CatOxl)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 21) .0521(d)
Hazardous Air Pollutants Maximum Achievable Control Technology 15A NCAC 2D .1111
(40 CFR Part 63, Subpart ZZZZ)
Nitrogen Oxides Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator(ID No.ES-PkGenl) shall not exceed 2.3 pounds
per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.l.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for sulfur dioxide emissions from the firing of No.
2 fuel oil in limited use generator(ID No. ES-PkGenl).
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator (ID No. ES-PkGenl) shall not be more than 20 percent
opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period. In no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for visible emissions from the firing of No. 2 fuel
oil in limited use generator(ID No.ES-PkGenl).

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3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
140 CFR Part 63, Subpart ZZZZ]
Applicability [40 CFR §63.6580 and §63.6585]
a. For the limited use generator (ID No. ES-PkGenl), the Permittee shall comply with all applicable
requirements of 15A NCAC 21) .1111 "Maximum Achievable Control Technology"pursuant to 40 CFR
Part 63, Subpart ZZZZ "National Emission Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines (RICE)" including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR §63.6590(b)(1)(ii)and §63.6675]
b. In accordance with 40 CFR§63.6590(a)(2)(i)this source is considered an existing Limited Use source for
purposes of Subpart ZZZZ. To qualify as such, the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations,on limited use generator ES-PkGenl I.The Permittee shall conduct monthly monitoring
of hours of operation for this source as measured by the non-resettable hour meter.The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .I I I I if this monitoring is not performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGenl, as measured by the non-resettable hour meter,in a logbook(written or electronic format)on-site
and made available to an authorized representative upon request.
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring,recordkeeping,or reporting is required for hazardous air pollutant emissions from limited
use generator ES-PkGenl.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator (ID No. ES-PkGenl) shall discharge into the atmosphere less than 40 tons of
nitrogen oxides per consecutive 12-month period.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.4.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Operational Limitation [15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 BA.a, above, the operation of limited
use generator(ID No. ES-PkGenl) shall not exceed 1,500 hours in a consecutive 12-month period. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request. The Permittee

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shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not conducted, these
records are not maintained, or if the rolling total hours of operation for the limited use generator exceed
1,500 hours per consecutive 12-month period.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month period
between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months; and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period ending
during the reporting period.
C. Rotocel Operations, including:
• Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and one
associated chilled water condenser (ID No. CD-31209) venting to one packed tower scrubber (ID
No.CD-1001-2-S-1);
• Two storage and recycle tanks (ID No. ES-M-125A and M-12513) and one associated chilled water
condenser(ID No.CD-1001-2-C-1)venting to one packed tower scrubber(ID No.CD-1001-2-S-1);
• Process equipment leaks (ID No. ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations,including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser(ID
No. CD-1001-1-3) venting to one packed tower scrubber(ID No. CD-1001-2-S-1);
• One chilled water condenser (ID No. CD-1001-1-T513) venting to packed tower scrubber (ID No.
CD-1001-2-S-1)controlling emissions from:
o Stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage tank
(ID No. ES-1001-1-1-P3);
• Process equipment leaks (ID No.ES-1001-1-1-F); and
• Recovery Operations wastewater stream(ID No. ES-1001-1-1-WW)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Best Available Control Technology
See Sections 2.2 B.1 and 2.2 B.2 15A NCAC 2D .0530
Excluding two solvent recycle process tanks
Volatile organic (11)Nos.ES-M-125A and M-12513)
compounds Compliance Assurance Monitoring 15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Hazardous Air Pollutants Maximum Achievable Control Technology 15A NCAC 2D .1111
See Section 2.2 C.1 (40 CFR Part 63, Subpart FFFF)
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3

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Regulated Pollutant Limits/Standards Applicable Regulation
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 AA 15A NCAC 2D .I 100
1. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CFR Part 64
and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic compound
(VOC)emission limits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this permit.
Control Requirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (ID No. ES-M-125A and M-125B), arcon process tank
M-1 (ID No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight
process and storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower
scrubber (ID No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.1.c and d, below. In
addition, the Permittee shall maintain a daily average mineral oil temperature at the inlet of the packed
scrubber(ID No. CD-1001-2-S-1)of less than or equal to 100 degrees Fahrenheit(100 °F)whenever the
associated sources are operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.l.c.i
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 C.l.c.i through iii,below,are not performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral oil packed tower scrubber
(ID No. CD-1001-2-S-1) at least once each day that the sources listed in Section 2.1 C.1.b, above,
operate;
ii. The Permittee shall inspect, maintain, and operate mineral oil packed tower scrubber(ID No. CD-
1001-2-S-1)in accordance with Section 2.2 B.1.i,below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gauge associated with
mineral oil packed tower scrubber (ID No. CD-1001-2-S-1) in accordance with Section 2.2 B.l.j,
below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if mineral oil packed tower scrubber(ID No. CD-1001-2-S-1)
operates under conditions qualifying as an excursion for more than 5 percent of the operational time of
the sources listed in Section 2.1 C.l.b, above, during a consecutive 6-month period, then the Permittee
shall develop a Quality Improvement Plan(Q1P)in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed tower
scrubber (ID No. CD-1001-2-S-1) with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.Lb,above,while the associated emission sources are operating,except as allowed pursuant
to Sections 2.2 B.l.c and d,below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections, maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring,noting any excursions along with any actions taken to correct the inlet
mineral oil temperature of packed tower scrubber(ID No. CD-1001-2-S-1);

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iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber(ID
No. CD-1001-2-5-1) or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked
or delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December,and July 30 of each calendar year for the preceding six-month period between January
and June.All instances of deviations from the requirements of this permit must be clearly identified.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001,desolventizer Z-1002,day tank 90024,first-stage evaporator EX-1012,
second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks of various
capacities (ID No. ES-1001-11-1-P) and one associated chilled water condenser (ID No. CD-1001-
11-EX1002)venting to one cryogenic (nitrogen) condenser system (ID No. CD-1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagfilter(ID No.CD-1003-4-1);
• Process equipment leaks (ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream(ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debagging (ID No. ES-1004-1) and one associated cartridge filter (ID No. CD-
1004-1-FFl);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, iso-hexane storage tank
490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation column
EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P) and one associated
chilled water condenser(ID No. CD-1004-2EX1002)venting to one cryogenic(nitrogen)condenser
system(ID No. CD-1004-2EX1003);
• Process equipment leaks (ID No.ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
• Biomass extraction operations wastewater stream (ID No.ES-1003-10-WW);
• Biomass silo loadout(ID No. ES-1004-2Silo) and one associated bagfilter(ID No.CD-1004-2-FF2);
and
• Molecular sieve(ID No.ES-MSDU-1024)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder,biomass extraction
debagging, and biomass silo loadout:
Particulate matter E=4.1 OP" 15A NCAC 2D .0515
Where:E=allowable emission rate in pounds
per hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0530
Volatile organic See Sections 2.2 B.1 and 2.2 B.2
compounds
Compliance Assurance Monitoring 15A NCAC 2D .0614

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Regulated Pollutant Limits/Standards Applicable Regulation
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
Hazardous Air Maximum Achievable Control Technology 15A NCAC 2D .I I I I
Pollutants See Section 2.2 C.1 (40 CFR Part 63, Subpart FFFF)
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .I 100
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (ID No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
E=4.10xP0`
Where: E=allowable emission rate in pounds per hour; and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 D.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the plant material grinder,the biomass extraction debagging operation,
and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a cartridge filter
(ID No.CD-1004-1-FF1),and a bagfilter(ID No.CD-1004-2-FF2),respectively.To assure compliance,
the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In
addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and maintained.
d. The results of inspections and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any maintenance performed on the cartridge filter and bagfilters; and
iv. Variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not
maintained.

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Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the botanical extraction operations and the biomass extraction operations shall not
be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging
periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-
hour period.In no event shall the six-minute average exceed 87 percent opacity.[I 5A NCAC 2D.0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 D.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources for
any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly observation
must be made while the associated source is operating. If a source does not operate during a monthly
period, then a record documenting such non-operational status will satisfy this monitoring requirement
for that source. If visible emissions from a source are observed to be above normal, the Permittee shall
either:
i. Take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 D.2.a,
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping[15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request.The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting[15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.

Permit 01819T45
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3. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the immersion extractor(ID No. Z-1001), desolventizer(ID No. Z-1002), day tank(ID No. 90024),
first-stage evaporator(ID No.EX-1012), second stage evaporator(ID No.EX-1013),distillation column
(ID No. EX-90008) and nine process tanks (ID No. ES-1001-11-1-P) and the immersion extractor(ID
No. Z-41001), desolventizer (ID No. Z-41002), day tank (ID No. 490025), isohexane storage tank (ID
No. 490024), first-stage evaporator (ID No. EX-41012), second stage evaporator (ID No. EX-41013),
distillation column(ID No. EX-490008) and nine process tanks of various capacities (ID No. ES-1004-
2-P),the Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this
source complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D.3 of this permit.
Control Repuirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P) shall
be controlled by the associated cryogenic condenser system (ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system(ID No.CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40 degrees
Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003 whenever the
associated sources are operational when using non-water soluble solvents.The 12-hour average outlet
temperature must be maintained at less than or equal to 17 degrees Fahrenheit (17 °F) when using
water soluble solvents; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F for
cryogenic condenser system (ID No. CD-1004-2EX1003) whenever the associated sources are
operational when using non-water soluble solvents. The 12-hour average outlet temperature must be
maintained at less than or equal to 17 degrees Fahrenheit(17°F) when using water-soluble solvents
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.c.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D.3.c.i through iv,below,are not performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system(ID No.CD-1001-
1 1-EX1 003) at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour,when the associated sources listed in Section 2.1 D.3.b,above,
operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system(ID No.CD-1004-
2EX1003) at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour,when the associated sources listed in Section 2.1 D.3.b,above,
operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems (ID Nos. CD-1001-
11-EX1003 and CD-1004-2EX1003) in accordance with Section 2.2 B.Lg,below; and
iv. The Permittee shall install, maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems(ID Nos.CD-1001-11-EX1003 and CD-1004-2EX1003)in accordance
with Section 2.2 B.1.h,below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system (ID No. CD-1001-11-EX1003
or CD-1004-2EX1003) operate under conditions qualifying as an excursion for more than 5 percent of
the operational time of their associated sources listed in Section 2.1 D.3.b,above,during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR§64.8. For the purposes of this permit condition excursions

Permit 01819T45
Page 19
are defined as operation of cryogenic condenser system (ID No. CD-1001-11-EX1003 or CD-1004-
2EX1003) with a 12-hour average outlet temperature that exceeds the associated limit cited in Sections
2.1 D.3.b.i and ii, above,while the associated emission sources are operating.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections, maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring,noting any excursions along with any actions taken to correct the outlet
temperature of cryogenic condenser system(ID No. CD-1001-11-EX1003 or CD-1004-2EX1003);
iii. The results of any inspections or maintenance performed on cryogenic condenser system(ID No.CD-
1001-11-EX1003), cryogenic condenser system (ID No. CD-1004-2EX1003), or the associated
temperature gauges; and
iv. Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked
or delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December,and July 30 of each calendar year for the preceding six-month period between January
and June. All instances of deviations from the requirements of this permit must be clearly identified.
E. Two biomass boilers(ID Nos.ES-13131 and ES-13132)and an associated propane/No.2 fuel oil-fired
rotary dryer (ID No. ES-RD) operated in series controlled by a cyclone (ID No. CD-BBIC) in
series with a bagfilter(ID No. CD-1313113H)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Boilers(ID Nos. ES-13131 and 13132): 15A NCAC 2D .0503
matter 0.33 pounds per million Btu heat input
Particulate Rotary dryer(ID No.ES-RD): 15A NCAC 213 .0515
matter E=4.10(P)0.67
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 2D .0521
emissions period
N/A Initial notification requirements, 15A NCAC 2D .0524
Notification of boiler size and fuel combusted,and (40 CFR Part 60,Subpart Dc)
Record and maintain amount of each fuel combusted
during each calendar month.
PM,HCI,CO, Boilers(ID Nos.ES-13131 and 13132): 15A NCAC 2Q .I I I I MACT
Hg, Emission limits as specified in 40 CFR Part 63, (40 CFR Part 63, Subpart DDDDD)
Dioxins/Furans Subpart DDDDD
Volatile Emissions of VOCs shall be less than 40 tons per 15A NCAC 2Q .0317
Organic consecutive 12-month period (Avoidance of 15A NCAC 2D .0530)
Compounds See Section 2.2 D
Hazardous Air Rotary Dryer(ID No.ES-RD): 15A NCAC 2Q .0317
Pollutants n-hexane emissions shall be less than 10 tons per year (Avoidance of 15A NCAC 2D.1112)
See Section 2.2.E

Permit 01819T45
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1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos. ES-BB1 and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
heat input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(o]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.1.a.above,the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Monitoring [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the boilers (ID Nos. ES-BB1 and ES-BB2) shall be controlled by a
cyclone (ID No. CD-BBIQ in series with a bagfilter(ID No. CD-BB1BH). To assure compliance, the
Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition
to the manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's
inspection and maintenance recommendations, as a minimum, the inspection and maintenance
requirement shall include the following:
i. monthly external inspection of the ductwork, cyclone, and bagfilter noting the structural integrity;
and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone,bagfilter,
and ductwork is not inspected and maintained.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. a report of any maintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall submit a report of any
maintenance performed on the cyclone and bagfilter.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and December
and July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the rotary dryer(ID No. ES-RD) shall not exceed an allowable
emission rate as calculated by the following equation: [15A NCAC 2D .0515(a)]
E=4.10 x P°_61 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

Permit 01819T45
Page 21
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.2.a.above,the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour,as
specified by the formulas contained above(or the formulas contained in 15A NCAC 2D .0515)can be
derived, and shall make these records available to a DAQ authorized representative upon request. The
Permittee shall be deemed in noncompliance with 15A NCAC 21) .0515 if the production records are
not maintained or the types of materials and finishes are not monitored.
3. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.3.a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
4. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(ID Nos. ES-BB1,ES-BB2, and ES-RD) shall not
be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [15A
NCAC 213 .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 EA.a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 21) .0521.
For boilers(ID Nos. ES-BBI and ES-BB2)
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance,once a day the Permittee shall observe the emission points of the boilers (ID Nos.
ES-BBI and ES-BB2)for any visible emissions above normal. The daily observation must be made for
each day of the calendar year period to ensure compliance with this requirement.The Permittee shall be
allowed three(3)days of absent observations per semi-annual period. The Permittee shall establish
"normal"for the boilers in the first 30 days following the effective date of the permit. If visible
emissions from this source are observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or

Permit 01819T45
Page 22
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 EA.a.
above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer(ID No. ES-RD):
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
f. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil
in the rotary dryer(ID No.ES-RD).
5. 15A NCAC 2D.0524: NSPS 40 CFR PART 60 SUBPART Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as promulgated in 40 CFR
Part 60 Subpart Dc,including Subpart A"General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUIREMENTS-In addition to any other required by 40 CFR 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 60.7)or reconstruction(40 CFR 60.15) of an affected facility is
commenced,postmarked no later than 30 days after such date, and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Recordkeeping[15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR 60.48c or recordkeeping requirements of the
EPA,the Permittee shall record and maintain records of the amounts of each fuel fired during each day.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these records are not
maintained.

Permit 01819T45
Page 23
6. 15A NCAC 2D .1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers(ID Nos.ES-BB1 and ES-11112)are subject to 40 CFR Part 63, Subpart DDDDD.
F. Four Emergency Generators and Fire Water Pump (ID Nos. E101, E102, E103,E104, and FP)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521
N/A N/A 15A NCAC 2D .1111
(40 CFR Part 63, Subpart ZZZZ)
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 F.La.above,the Permittee shall be deemed
in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/is required for sulfur dioxide emissions from the firing of No. 2 fuel oil in
these sources.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-
minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed
87 percent opacity. [15A NCAC 2D .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 F. 2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil
in these sources.
3. 15A NCAC 2D.1111 140 CFR Part 63 Subpart ZZZZJ:
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management
Commission Standard 15A NCAC 2D .1111, "Maximum Achievable Control Technology"as
promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines,"by December 13, 2004.

Permit 01819T45
Page 24
Monitoring/Recordkeepinp,/Reporting [15A NCAC 2Q .0508(f)]
b. No monitoring/recordkeeping/reporting requirements.
G.Sclareol Recrystallization (SFG) Operations, including:
• One process tank (ID No. T-3001)*
• Four process tanks (ID Nos. T-3002 through 3005)"
• One storage tank (ID No. T-3006)"
• One process tank(ID No. T-3007)*
• Two centrifuges (ID Nos. C-3001 and C-3002)*
• One reactor equipped with a process chilled water condenser (EX-3001) with control
chilled water condenser (ID No. CD-3001)"
• One reactor equipped with a process chilled water condenser (EX-3003)(ID No. R-3002)*
• One reactor equipped with a process chilled water condenser (EX-3004) (ID No. R-3003)`
• One reactor equipped with a process chilled water condenser (EX-3005) (ID No. R-3004)*
• One steam heated dryer equipped with a process chilled water condenser (EX-3002) (ID
No. D-3001) with control chilled water condenser (ID No. CD-3001)"
• One steam heated dryer equipped with a process chilled water condenser (EX-3006) (ID
No. D-3002) with control chilled water condenser (ID No. CD-3002)*
• Process equipment leaks (ID No. ES-1003-10-F)
• SFG Operations wastewater stream (ID No. ES-1003-10-WW)
* These emission sources may be controlled with a chilled water condenser(ID No.CD-3003)in series with a mineral
oil scrubber (ID No. CD-3004-S). These control devices are optional controls. The Permittee has the option to
construct or not construct these devices and has the option to operate or not operate these devices.
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to comply with Best Available Control Technology(BACT),the SFG operations shall discharge
no more than 217.4 tons volatile organic compounds per consecutive twelve month period.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 G.l.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]
c. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions shall
be determined by multiplying the total amount of each type of VOC-containing material consumed during
the month by the VOC content of the material.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format).
e. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC
containing materials or the VOC emissions are not monitored and recorded as specified in Sections
2.1.G.1. c and d or if the VOC emissions exceed the limit in Section 2.1. G.La.

Permit 01819T45
Page 25
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a semi-annual report of the monitoring and recordkeeping activities
postmarked on or before January 30 of each calendar year for the preceding six-month period between
July and December and July 30 of each calendar year for the preceding six-month period between January
and June. The report shall contain the following:
i. the monthly volatile organic compound emissions for each of the previous 17 months; and
iii. the yearly volatile organic compound emissions for each consecutive 12-month period ending on
each month of the previous six-month period.

Permit 01819T45
Page 26
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources [all permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101, H-102, and H-1031
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 2D .0958
State-Enforceable Only
Toxic Air Pollutants Air Toxics evaluation for non-NESHAP 15A NCAC 21) .1100
emission sources
Odorous emissions State-Enforceable Only 15A NCAC 21) .1806
Odorous emissions must be controlled
1. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D.0958,for all sources that use volatile organic compounds(VOC)as solvents,
carriers,material processing media, or industrial chemical reactants, or in similar uses that mix,blend, or
manufacture volatile organic compounds, or emit volatile organic compounds as a product of chemical
reactions,the Permittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects,when not in
use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric,wood,paper products, and other absorbent materials with volatile organic
compounds,
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other coating
equipment into closable containers and close such containers immediately after each use, or transfer
such solvents to closed tanks,or to a treatment facility regulated under section 402 of the Clean Water
Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank or
a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 2D .0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush parts in the freeboard area,
ii. Take precautions to reduce the pooling of solvent on and in the parts,
iii. Tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all dripping
has stopped,whichever is longer,
iv. Not fill cleaning machines above the fill line,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 2D .0958(d)]
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum, perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations.If the required inspections are not conducted
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0958.

Permit 01819T45
Page 27
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with rule
15A NCAC 2D .0958.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. 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.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NESHAP source,any increase in toxic air pollutants must be evaluated.
B. Three No. 2 fuel oil-fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No.WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
(VOC)
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. The following Best Available Control Technology(BACT)limits shall not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tons per Condenser CD-31209
desolventizer,and solvent 10.8 pounds consecutive
VOC and packed tower
separation/recovery per hour 12-month
(ID No. ES-1001-2-1-P1) period scrubber CD-1001-2-5-1
Rotocel equipment leaks VOC N/A Leak detection and
(ID No. ES-1001-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(ID No. ES-1001-2-1-WW) VOC N/A wastewater treatment
tanks

Permit 01819T45
Page 28
Emission Source Pollutant BACT Emission Limits Control Technology
When Rotocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-1 When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete:
8.76 pounds per hour and 0.63
tons per consecutive 12-month
period
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-1001-1-
receiver M-21 VOC Operating and Recovery T5B
(ID No. ES-1 001-1-1-P2)
Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC N/A Fixed roofs
(ID No.ES-1001-1-1-P3)
Recovery equipment leaks VOC N/A MAR
(ID No.ES-1001-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting Wastewater treatment
(ID No.ES-1001-1-1-WW) of methanol-wash tanks and biological
treatment
Botanical extraction
immersion extractor, 61.76 tons per
desolventizer,first and Condenser CD-1001-11-
second stage evaporators, VOC 14.1 pounds consecutive EX1002 and condenser
distillation column, day tank, per hour period
CD-1001-11-EX1003
and multiple process tanks period
(ID No. ES-1001-11-P)
Botanical extraction
equipment leaks (ID No. ES- VOC N/A MAR
1001-11-F) (Fugitive)
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC N/A wastewater treatment
ES-1001-11-WW) I I I tanks

Permit 01819T45
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Emission Source Pollutant BACT Emission Limits Control Technology
Biomass extraction
immersion extractor,
desolventizer, day tank,
isohexane storage tank, first 61.8 tons per Condenser CD-1004-
and second stage VOCs 14.1 pounds consecutive 2EX 1002 and condenser
evaporators,distillation per hour period
CD-1004-2EX1003
column,and multiple process period
tanks
(ID No. ES-1004-2-P)
Biomass extraction
equipment leaks (ID No. ES- VOCs N/A LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs N/A wastewater treatment
ES-1004-2-WW) tanks
No. 2 fuel-oil fired boilers
(ID Nos. H-101,H-102,H- VOC 0.2 pounds per 1,000 gallons Combustion control
103)
Testing [15A NCAC 2Q .0508(o]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.2 B.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall limit the operation of the recovery stripper T-5 and receiver M-21 (ID No.ES-1001-
1-1-P2) while source (ID No. ES-1001-2-1-P1) is not operating to no greater than 34 days in any
consecutive 12-month period.
d. The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-P1) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises)while source(ID No. ES-1001-2-1-P1) is not operating to no greater than 6
days in any consecutive 12-month period.
e. The Permittee shall implement the leak detection and repair(LDAR)program of 40 CFR Part 63, Subpart
LTU, as per the requirements Section 2.2 B.2, below. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0530, if the MAR program requirements are not implemented.
f. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant(i.e.Wastewater Treatment Plant Aeration Tank No. 1;ID No.WWTP-AT1)
for volatile organic compounds (VOC), when the wastewater stream consisting of methanol-wash from
the recovery operations (ID No.ES-1001-1-1-WW) is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VOC is not
determined every week or if the mass removal efficiency is less than 95%.
g. Volatile organic compound(VOC)emissions from the emission sources listed in Section 2.2 B.La,above,
shall be controlled by the associated condensers. To assure compliance, the Permittee shall perform
periodic inspections and maintenance as recommended by the equipment manufacturer. In addition, the
Permittee shall perform an annual inspection of each condenser system, including the following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is under positive gauge pressure, leakage of the

Permit 01819T45
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contaminated gas stream.In order to monitor leakage of the coolant,the condensate shall be inspected
for the presence of coolant; and
ii. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
h. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.1.a, above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The temperatures
output from the sensors shall be continuously monitored and hourly values used to determine the 24-hour
average temperature at the condenser outlets. The Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0530 if the outlet temperatures of the condensers are not maintained below the limits in the
table below; or the condensers are not equipped with sensors to continuously measure the outlet
temperatures; or if those sensors are not inspected and maintained.
Emission Source Condenser ID No. Required Outlet Temperature
Recovery arcon tank M-1 CD-1001-1-3 45 OF, 24-hour average,when
(ID No. ES-1001-1-1-P1) source ES-1001-2-1-P1 is not
Recovery stripper T-5 and operating and the tanks are used
receiver M-21 (ID No.ES-1001- CD-1001-1-T5B for concrete processing in the
1-1-P2) recovery operation
-40°F, 24-hour average for non
Botanical extraction operations CD-1001-11-EX1003 Water soluble solvents,and
(ID No.ES-1001-11-P) 17°F, 24-hour average for water
soluble solvents
-40°F, 24-hour average for non
Biomass extraction operations water soluble solvents,and
(ID No. ES-1004-2-P) CD-1004-2EX1003 17°F, 24-hour average for water
soluble solvents
i. Volatile organic compound(VOC)emissions from the emission sources listed in Section 2.2 B.La,above,
shall also be controlled by the associated packed tower scrubber (ID No. CD-1001-2-S-1), except as
allowed pursuant to Sections 2.2 B.1.c and d, above. To assure compliance, the Permittee shall perform
periodic inspections and maintenance as recommended by the equipment manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's inspection
and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall
include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system(if so equipped),
and perform maintenance and repair when necessary to assure proper operation of the packed tower
scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530 if the packed tower scrubber
is not inspected and maintained.
j. The Permittee shall install, maintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor,and an emission stream inlet temperature sensor for packed tower scrubber
CD-1001-2-S-1 in accordance with manufacturer's recommendations. The Permittee shall be deemed in

Permit 01819T45
Page 31
noncompliance with 15A NCAC 2D .0530 if the flow meter and temperature sensors are not installed,
maintained, and calibrated,or if,except as allowed pursuant to Sections 2.2 B.Lc and d, above:
i. The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
ii. The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeeping [15A NCAC 2Q .0508(f)]
k. The Permittee shall maintain the following records:
i. VOC emissions for each calendar month,and for the consecutive 12-month period ending with each
calendar month, from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-PI is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-PI is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations (ID No.ES-1004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through j, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request.The logbook shall be updated at least monthly
and record the following:
(A)The date and time of each recorded action;
(B) The actual hours of operation of the recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and
recovery stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), when source ES-1001-2-1-
P1 is not operating;
(C) The actual hours of operation of recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and source
(ID No. ES-1001-2-1-P1)is not operating;
(D)The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
WWTP-AT1) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(E) The 24-hour average outlet temperature of the associated condenser(s)listed in Section 2.2 B.1.h,
above:
(1) When source (ID No. ES-1001-2-1-P1) is not operating and the Concrete Operations tanks
(ID No. ES-1001-1-2-P)are used for concrete processing in the recovery operation; and/or
(2) When the biomass extraction operations(ID No. ES-1004-2-P)is operating.
(F) The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream inlet
temperature of scrubber(ID No. CD-1001-2-5-1)at least once each day that source(ID No. ES-
1001-2-1-P1)operates;
(G)The results of maintenance performed on the condensers and scrubber listed in Section 2.2 B.La,
above, and the associated temperature sensors and flow rate gauges; and
(H)Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reportinn [15A NCAC 2Q .0508(f)]
1. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.La, above.
in. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July

Permit 01819T45
Page 32
and December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified. In
addition,the semiannual reports shall also contain the following:
i. The monthly VOC emissions from each of the following sources for each of the previous 17 months;
and
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3) when source(ID No.ES-1001-2-1-P1) is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3) when source (ID No. ES-1001-2-1-P1) is not operating and the recovery
process is processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations (ID No.ES-1004-2-P).
ii. The cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.m.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D.0530: Prevention of Significant Deterioration]
Equipment identification [15A NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified.Identification of the equipment does not require physical
tagging of the equipment.For example,the equipment may be identified on a plant site plan,in log entries,
by designation of process unit or affected facility boundaries by some form of weatherproof identification,
or by other appropriate methods. In addition to the above, the following equipment shall be specifically
identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe manner to perform monitoring;
(Connectors need not be individually identified if all connectors in a designated area or length of pipe
are identified as a group,and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rupture disk upstream of the pressure device;
iii. Valves,pumps, and connectors that are designated unsafe-to-monitor(i.e.,Permittee has determined
that monitoring personnel would be exposed to an immediate danger as a consequence of complying
with the monitoring requirements); and
iv. Valves that are difficult-to-monitor.(i.e.,Permittee has determined that the valve cannot be monitored
without elevating the monitoring personnel more than seven feet above a support surface or it is not
accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-to-
monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
explanation why the equipment is unsafe or difficult-to-monitor.These records must be kept at the plant
and be available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times,but not more frequently than the periodic monitoring schedule
otherwise applicable, and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment at
least once per calendar year and repair of the equipment if a leak is detected.
c. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process unit
shutdown.The identity of connectors designated as unsafe-to-repair and an explanation why the connector
is unsafe-to-repair shall be recorded.

Permit 01819T45
Page 33
Instrument and sensory monitoring for leaks [I5A NCAC 2Q .0508(f)]
d. Instrument monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak to
the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2, paragraph(a) of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis. The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there is
no instrument commercially available that will meet the performance criteria specified above, the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid, calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures specified
in Method 21 of 40 CFR part 60,appendix A.
iv. Calibration gases shall be zero air(less than 10 parts per million of hydrocarbon in air); and the gases
shall be mixtures of methane in air at a concentration no more than 2,000 parts per million greater
than the leak definition concentration of the equipment monitored. If the monitoring instrument's
design allows for multiple calibration scales,then the lower scale shall be calibrated with a calibration
gas that is no higher than 2,000 parts per million above the concentration specified as a leak, and the
highest scale shall be calibrated with a calibration gas that is approximately equal to 10,000 parts per
million. A calibration gas other than methane in air may be used if the instrument does not respond
to methane or if the instrument does not meet the performance criteria specified Method 21 of 40 CFR
part 60, appendix A. In such cases, the calibration gas may be a mixture of one or more of the
compounds to be measured in air.
v. Monitoring shall be performed when the equipment is in VOC service.
g. The Permittee may elect to adjust or not to adjust the instrument readings for background.
i. If the Permittee elects not to adjust instrument readings for background, the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,above.
In such cases, all instrument readings shall be compared directly to the applicable leak definition for
the monitored equipment to determine whether there is a leak or to determine compliance with
operational standards for pressure relief devices.
ii. If the Permittee elects to adjust instrument readings for background, the Permittee shall
(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B) Determine the background level using the procedures in Method 21 of 40 CFR part 60,appendix
A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored equipment
to determine whether there is a leak or to determine compliance operational standards for pressure
relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:

Permit 01819T45
Page 34
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at the
time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair.The written procedures may be included as part of the startup,shutdown,and
malfunction plan, or may be part of a separate document that is maintained at the plant site.
In such cases, reasons for delay of repair may be documented by citing the relevant sections
of the written procedure(i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts,there must be documentation that
the spare parts were sufficiently stocked on-site before depletion and the reason for depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
i. The Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days after
it is detected, except as provided for in delay of repair and/or unsafe to repair connectors.A first attempt
at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at repair for
pumps includes,but is not limited to,tightening the packing gland nuts and/or ensuring that the seal flush
is operating at design pressure and temperature. First attempt at repair for valves includes, but is not
limited to, tightening the bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the packing
gland nuts, and/or injecting lubricant into the lubricated packing.
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. Identification
that has been placed on equipment determined to have a leak, except for a valve or for a connector in
gas/vapor or light liquid service,may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below.The Permittee shall maintain a record
of the facts that explain any delay of repairs and, where appropriate, why the repair was technically
infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical,but no later than the end of the next process
unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed for a valve
if valve assembly replacement is necessary during the process unit shutdown, and valve assembly
supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the
supplies were depleted.Delay of repair beyond the second process unit shutdown will not be allowed
unless the third process unit shutdown occurs sooner than six months after the first process unit
shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if.
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair,and
(B) When repair procedures are effected, the purged material cannot be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a quality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg,below)will provide better performance,or the repair is completed as soon
as practical,but not later than 6 months after the leak was detected and one of the following is used;

Permit 01819T45
Page 35
(A) A dual mechanical seal system;
(B) A pump that meets has no external shaft penetrating the pump housing; or
(C) A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNapor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines a
leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak, the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with less
than one percent leaking valves.
(B) The Permittee may elect to monitor each valve once every four quarters for process units with
less than 0.5 percent leaking valves.
(C) The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the monitoring
frequency provisions to each subgroup. If the Permittee subdivides the valves in the group of process
units, then the following provisions apply.
i. The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup.Valves with less than
one year of monitoring data or valves not monitored within the last twelve months must be placed
initially into the most frequently monitored subgroup until at least one year of monitoring data
have been obtained.
(B) Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to a
less frequently monitored subgroup provided that the valves to be reassigned have not leaked for
the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the valve or
group of valves is to be reassigned to a subgroup being monitored annually). Non-repairable
valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so indicate
the performance in the next periodic report.If the overall performance of total valves in the applicable
process unit or group of process units is two percent leaking valves or greater,the Permittee shall no
longer subgroup and shall revert to the program required in Section 2.2 B.2.p.for that group of process
units.The Permittee can again elect to comply with the valve subgrouping procedures if future overall
performance of total valves in the process unit or group of process units is again less than two percent.
The overall performance of total valves in the applicable process unit or group of process units shall
be calculated as a weighted average of the percent leaking valves of each subgroup according to
following equation:

Permit 01819T45
Page 36
n
E(%VLi X V)
%V
LO
YV
i=1
Where: %V O=Overall performance of total valves in the applicable process unit or group of process
units
%VL; =Percent leaking valves in subgroup i,most recent value
Vi =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee shall maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for each subgroup for each monitoring period;
(C) Which valves are reassigned,the last monitoring result prior to reassignment,and when they were
reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next monitoring
period of the decision to subgroup valves. The notification shall identify the participating process
units and the number of valves assigned to each subgroup, if applicable, and may be included in the
next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for each process group(i.e.,botanical extraction,biomass
extraction, and Rotocel/recovery) for comparison with the sub grouping criteria specified in Section 2.2
B.2.m, above, and the percent leaking valves for each monitoring period for each process unit or valve
subgroup shall be calculated using the following equation:
%VL = VT
1XI00
T
Where: %VL = Percent leaking valves.
VL = Number of valves found leaking, excluding non-repairable valves and including those
valves found whose repair was not confirmed with both post leak repair monitoring and
periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly,or semiannual monitoring frequencies,the percent leaking valves shall be the arithmetic average
of the percent leaking valves from the last two monitoring periods. When determining monitoring
frequency for each process unit or valve subgroup subject to annual or biennial (once every 2 years)
monitoring frequencies, the percent leaking valves shall be the arithmetic average of the percent leaking
valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time the
valve is identified as leaking and non-repairable. Otherwise, a number of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in regulated
material service at a process unit or affected facility, the number of non-repairable valves exceeding

Permit 01819T45
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one percent of the total number of valves in regulated material service shall be included in the
calculation of percent leaking valves.
p. If a leak is determined,then the leak shall be repaired. After a leak has been repaired, the valve shall be
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and first
attempt at repair. The monitoring shall be conducted to determine whether the valve has resumed
leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides with
the time specified. Alternatively, other monitoring may be performed to satisfy the requirement
regardless of whether the timing of the monitoring period for periodic monitoring coincides with the
time above.
iii. If a leak is detected by monitoring that is conducted after leak repair,the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) If the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy the
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1,above,and the Permittee shall monitor the valve according to the written
plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
permit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that is
designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b, above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection,the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of 2,000
parts per million (ppm) or greater it shall be repaired using the procedures in Sections 2.2 B.2.i
through 2.2 13.21, above; or
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual
inspection provided that each pump is visually inspected as often as practical and at least monthly.
t. If, when calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak,the Permittee shall
implement a quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.gg,below.The
Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except that
pumps found leaking in a continuous process unit within one month after start-up of the pump shall
not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
%PL =I
(Pi P Ps)—Ps x 100
r
Where: %PL=Percent leaking pumps

Permit 01819T45
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PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current monitoring
period.
PT =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in gas and vapor service and in light liquid service standards [15A NCAC 2Q .0508(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater than or equal to 500 parts per million is measured,
a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this requirement
and shall be monitored and inspected according to the written plan specified in Section 2.2 B.2.b, above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but less
than 0.5 percent,then monitor within four years.The Permittee may comply with this requirement by
monitoring at least 40 percent of the connectors within two years of the start of the monitoring period,
provided all connectors have been monitored by the end of the four year monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical,but within the next six months,all connectors that have not yet been
monitored during the monitoring period if the percent leaking connectors is greater than or equal
to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new monitoring
period shall be started based on the percent leaking connectors of the total monitored connectors.],
or
(B) Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
iv. If, during the monitoring, a connector is found to be leaking, it shall be re-monitored once within 90
days after repair to confirm that it is not leaking.
v. The Permittee shall keep a record of the start date and end date of each monitoring period under this
section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows:
%CL =CL x 100
r
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
Ct = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried,insulated in a manner that prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet above
a permanent support surface or would require the erection of scaffolding, or
v. Not able to be accessed in a safe manner to perform monitoring

Permit 01819T45
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are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory, or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [15A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below, each pressure relief device in gas and vapor service
shall be operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of less
than 500 parts per million,as soon as practical,but no later than five calendar days after each pressure
release, except as provided for in delay of repair provisions of this permit;
ii. The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background,and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during the
monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar days
after each pressure release, except as provided for in delay of repair.
Ouality improvement program for pumps [15A NCAC 2Q .0508(f)]
bb. If, on a 6-month rolling average, at least the greater of either 10 percent of the pumps in a process unit or
three pumps in a process unit leak, the Permittee shall implement a quality improvement plan until the
number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in the
process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t, above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program.The data may be collected and the records may be maintained
on a process unit, affected facility, or plant site basis.
i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design(e.g., external shaft,flanged body); materials of construction; if
applicable,barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. The maximum instrument readings observed in each monitoring observation before repair, response
factor for the stream if appropriate, instrument model number, and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site)remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seal failures and were removed
from the process unit due to leaks. The inspection shall determine the probable cause of the pump seal
failure or of the pump leak and shall include recommendations, as appropriate, for design changes or
changes in specifications to reduce leak potential.
ee. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above, to determine the services, operating or maintenance practices, and pump or pump seal designs or
technologies that have poorer than average emission performance and those that have better than average
emission performance.The analysis shall determine if specific trouble areas can be identified on the basis
of service, operating conditions or maintenance practices, equipment design, or other process-specific
factors.

Permit 01819T45
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i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the service(s),operating conditions,or pump or pump seal designs
associated with poorer than average emission performance.A superior performing pump or pump seal
technology is one with a leak frequency of less than 10 percent for specific applications in the process
unit.A candidate superior performing pump or pump seal technology is one demonstrated or reported
in the available literature or through a group study as having low emission performance and as being
capable of achieving less than 10 percent leaking pumps in the process unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process unit
due to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site,a company, or
a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The quality
assurance program may establish any number of categories,or classes,of pumps as needed to distinguish
among operating conditions and services associated with poorer than average emission performance as
well as those associated with better than average emission performance. The quality assurance program
shall be developed considering the findings of the data analysis required under paragraph Section
2.2B.2.ee,above,and the operating conditions in the process unit.The quality assurance program shall be
updated each year as long as the process unit has the greater of either 10 percent or more leaking pumps
or has three leaking pumps.
i. The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage, or other applicable identified critical parameters.
(B) Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C) Provide for an audit procedure for quality control of purchased equipment to ensure conformance
with purchase specifications.
(D)Detail off-line pump maintenance and repair procedures. These procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program.
gg. Three years after the start of the quality improvement program, the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
been identified as superior emission performance technology and that comply with the quality assurance
standards for the pump category. Superior emission performance technology is that category or design of
pumps or pump seals with emission performance that when combined with appropriate process,operating,
and maintenance practices, will result in less than 10 percent leaking pumps for specific applications in
the process unit. Superior emission performance technology includes material or design changes to the

Permit 01819T45
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existing pump,pump seal, seal support system, installation of multiple mechanical seals or equivalent, or
pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number of
pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero integer
value. The minimum number of pumps or pump seals shall be one. Pump replacement shall continue
until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above, are pumps
determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the next
planned process unit shutdown,provided the number of pump seals and pumps replaced is equivalent
to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shall maintain records for the period of the quality improvement program for the process
unit prescribed below.
i. When using a pump quality improvement program,the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B) Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,above,
and any recommendations for design or specification changes to reduce leak frequency; and
(C) The beginning and ending dates while meeting the quality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak, the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream,the operating conditions and maintenance practices.
iv. All records documenting the quality assurance program for pumps as specified in the quality
assurance program,including records indicating that all pumps replaced or modified during the period
of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg, above.
Recordkeeging requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not physically
tagged and the Permittee is electing to identify the equipment through written documentation such as a
log or other designation.
J. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
nun. For valves,the Permittee shall maintain the monitoring schedule for each process unit and the valve
subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pump visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service,the Permittee shall keep records of the
dates and results of monitoring following a pressure release.
qq. For a pump QIP program,the Permittee shall maintain the following records:
i. Individual pump records as specified in Section 2.2 B.2.cc, above;
ii. Quality assurance program documentation as specified in Section 2.2 B.2.ff, above; and
iii. Quality improvement program records as specified in Section 2.2 13.21h, above.

Permit 01819T45
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Reporting requirements [15A NCAC 2Q .0508(f)]
rr. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January and
June.The report shall contain in summary format by equipment type(i.e.,valves in gas/vapor/light liquid
service,Pumps in light liquid service,and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves, pumps and connectors,and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired,and for valves and
connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
tt. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection instrument
reading of less than 500 parts per million, report the results of all monitoring to show compliance
conducted within the semiannual reporting period.
w. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report, if applicable,the initiation of a quality improvement program for pumps.
C. Sclareolide(SDE)Operations,including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity; ID No.M-20);
• Process equipment leaks(ID No.ES-1001-1-4-F);
• Four batch reactors (ID Nos. M-10, M-10A, D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate;ID No.CD-M-34); and
• SDE Operations wastewater stream (ID No.ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide,including:
• Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks (ID No.ES-1001-1-3-F);
• One distillation column(6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for sclareolide purification wastewater stream (ID No. ES-1001-
1-3-WW)
Ethyl Vanillin Glucoside(EVG)Operations,including:
• One water spray fume scrubber(0.5 gallon per minute minimum water injection rate; ID No.CD-
Z-9215)venting to one water spray fume scrubber(0.5 gallon per minute minimum water injection
rate;ID No.CD-Z-9216)controlling emissions from:
o Three reactors(ID Nos.D-2202,D-1215,and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks(ID No.ES-1003-2-2-F); and
• EVG Operations wastewater stream (ID No. ES-1003-2-2-WW)
Plant Nutrient Extraction(PNE)Operations,including one water spray fume scrubber(0.5 gallon per
minute minimum water injection rate; ID No. CD-Z-9215) venting to one water spray fume scrubber
(0.5 gallon per minute minimum water solution injection rate;ID No.CD-Z-9216)controlling emissions
from:

Permit 01819T45
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• One product extract reactor (ID No. D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities (ID No.ES-1003-2-1-P);
• One centrifuge(ID No. C-31203);
• One dryer equipped with a process condenser(ID No. D-1002);
• One process solvent tank(ID No. ES-TK-PNE-1)
• Process equipment leaks (ID No.ES-1003-2-1-F);
• One waste solids separator vessel(1,333 gallon capacity;ID No.D31211)and one associated chilled
water condenser(ID No.EX2205); and
• PNE Process wastewater stream(ID No.ES-1003-2-1-WW)
Concrete Operations,including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and HB-4);
• Process equipment leaks(ID No.ES-1001-1-2-F);
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser (ID No. CD-1001-1-2); and
• Concrete Operations wastewater stream (ID No. ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C,above;
Two Storage and Recycle Tanks (ID No.ES-M-125A and M-125B)
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D,above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No.WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s) describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Hazardous Air Pollutants(HAP) Maximum Achievable Control 15A NCAC 2D .1111
Technology (40 CFR Part 63, Subpart FFFF)
1. 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63, Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF,including Subpart A "General Provisions".For convenience,some of the relevant
definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435, 63.2440,
63.2445(b),and 63.2550]
Group 1 batch process vent means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions from all of the batch process vents are greater than or equal to 10,000
lb/yr at an existing source or greater than or equal to 3,000 lb/yr at a new source.
Group 2 batch process vent means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group I continuous process vent means a continuous process vent for which the flow rate is greater than
or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b),is less than or equal to 1.9 at an existing source and less than or equal
to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not meet the definition of a
Group 1 continuous process vent.

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Group l storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group l wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria for Group 1 status in §63.2485(c) for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in §63.132(d) for compounds in Table 8 to subpart G of this part 63.
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group 1 wastewater stream.
In organic HAP service means that a piece of equipment either contains or contacts a fluid(liquid or gas)
that is at least 5 percent by weight of total organic HAP as determined according to the provisions of
§63.180(d).The provisions of§63.180(d)also specify how to determine that a piece of equipment is not
in organic HAP service.
Miscellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in§63.2435(b).For the
purposes of this subpart, process includes any, all or a combination of reaction, recovery, separation,
purification, or other activity, operation, manufacture, or treatment which are used to produce a product
or isolated intermediate.
Nonstandard batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch. A nonstandard batch may be necessary as a result of a malfunction, but
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of an
MCPU as described by records specified in §63.2525(b).
Point of determination means each point where process wastewater exits the MCPU or control device.
Standard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions from a standard batch are based on the operating
conditions that result in highest emissions. The standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Requirements/Limitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.l.b.i through v,below:
i. The Permittee must submit a Notice of Compliance Status Report for the SIDE Operations, the
Concrete Operations,and/or the PNE Operations prior to the operation of those operations in organic
HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63, Subpart
FFFF apply to those operations,pursuant to 40 CFR §63.2520(d).
ii. Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to avoid
unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. If a Group 2 emission point becomes a Group 1 emission point,the Permittee must be in compliance
with the Group 1 requirements beginning on the date the switch occurs. An initial compliance
demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within 150 days after
the switch in group status occurs.The Permittee shall be deemed in non-compliance with 15A NCAC
2D .1111 if the Permittee does not meet these requirements. [40 CFR §63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR §63.6(e) for the affected sources. The Permittee is not, however, required to
address equipment leaks (except for control devices) or Group 2 emission points in the SSM Plan.
The SSM Plan must describe, in detail,procedures for operating and maintaining the affected sources

Permit 01819T45
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during periods of startup, shutdown, and malfunction; and corrective actions for malfunctioning
process, control, and monitoring equipment used to comply with Subpart FFFF. The SSM Plan does
not need to address any scenario that would not cause an affected source to exceed an applicable
emission limit in Subpart FFFF. The SSM Plan must be maintained on site and made available for
inspection by authorized personnel. [40 CFR §§63.6(e)(3)and 63.25250)]
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the
requirements of Sections 2.2 C.l.b.i through v, above.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
c. The Permittee shall comply with the specific requirements of Sections 2.2 C.l.c.i through vii,below:
i. Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.i(A)and(B),below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.g through j,
above.
(B) For continuous process vent associated with the Botanical Extraction Operations, the Permittee
shall perform the monitoring found in Sections 2.2 B.l.g and h, above.
ii. Batch process vents: To ensure compliance,the Permittee shall perform the monitoring of Sections
2.2 C.1.c.ii(A)through(C),below, for the affected batch process vents:
(A)For the batch process vents associated the EVG Operations and the Biological conversion
equipment for purification of sclareolide,the Permittee shall comply with the requirements of 40
CFR§63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF.To maintain Group 2 classification
for these emission sources the organic HAP emissions must be less than 10,000 pounds per
consecutive 365-day period,each source.The Permittee shall monitor the organic HAP emissions
from each of these emission sources,monthly, as follows:
(1) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 1.0(pounds x B
batch )
Where: B = The number of batches processed in the EVG Operations
(2) Organic HAP emissions from the Biological conversion equipment for purification of
sclareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x B
batch )
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B) The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.l.c.ii(A)(1)and(2), above.
(C)The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations,the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of 40
CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,combined.
The Permittee shall monitor the organic HAP emissions from these batch process vents, monthly, as
follows:
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:

Permit 01819T45
Page 46
Organic HAP= 11.3 pounds X B + 31.8 pounds X B
batch ) 1, ( batch ) "`
Where: B,,g = The number of regular batches processed in the EVG Operations; and
B,e, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.l.c.iii(A),above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Permittee shall comply
with the requirements of 40 CFR §63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair(LDAR)
program found in Section 2.2 B.2, above, for the equipment associated with the affected sources.
vi. Wastewater streams:For the wastewater streams associated with the affected miscellaneous organic
chemical manufacturing processes (MCPI), the Permittee shall comply with the requirements of 40
CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca, Inc.
facility; and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2,unless the conditions of Section 2.2 C.Lb.iv, above,have been met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will be
used to detect leaks of process fluids into cooling water.This plan shall require monitoring of one
or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more process
parameters or other conditions that indicate a leak. The plan shall include the following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s)or conditions(s)that shall constitute a leak. This shall be documented
by data or calculations showing that the selected levels or conditions will reliably identify
leaks. The monitoring must be sufficiently sensitive to determine the range of parameter
levels or conditions when the system is not leaking. When the selected parameter level or
condition is outside that range, a leak is indicated;
(3) The monitoring frequency which shall be no less frequent than monthly for the first 6 months
and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after discovery
of the leak.
(C) The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded, retain the most recent superseded plan at least until 5 years from
the date of its creation.
(D)If a leak is detected in any heat exchanger system, it shall be repaired as soon as practical but not
later than 45 calendar days after the Permittee receives results of monitoring tests indicating a
leak, unless the Permittee demonstrates that the results are due to a condition other than a leak.
Once the leak has been repaired, the owner or operator shall confirm that the heat exchange

Penn it 01819T45
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system has been repaired within 7 calendar days of the repair or startup,whichever is later,except
where the Permittee appropriately applies the delay of repair provisions found in Section 2.2
C.l.c.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the process.
Delay of repair is also allowed if repair is technically infeasible without a shutdown and any one
of the conditions listed in 40 CFR §63.104(e)(1)through(2)is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.c.i through vii, above.
Recordkeeping Requirements [15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.1.d.i through v,below:
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B) An identification of related process vents (including associated emissions episodes), wastewater
points of determination(PODs),and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents,the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of operating
and/or testing conditions for any associated control device;
(E) The process vents,wastewater POD,transfer racks,and storage tanks(including those from other
processes)that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G)Calculations and engineering analyses required to demonstrate compliance.
iii. For each affected MPCU with a Group 2 process vent,the Permittee shall retain the following records:
(A)A record of the day each batch was completed;
(B) A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a non-
standard batch; and
(D)Records of the daily 365-day rolling summations of emissions,or alternative records that correlate
to the emissions(e.g.,number of batches),calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream,the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds listed in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw), including documentation of the methodology used to determine concentration; and,
(D) Stream flow rate(in liters/min).
v. For each affected heat exchanger system, the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak,the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan, including the date the leak was discovered;
(C) The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.d.i through v, above.
Reporting [15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR §63.2460(b)(6) and 40 CFR §63.2520(e)(10).

Permit 01819T45
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f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and December,and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain the
following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard specified
in this subpart, include a statement that there were no deviations from the emission limits, operating
limits, or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period; and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable), as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered by
the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary format by equipment type, the number of
components for which leaks were detected and for valves, pumps and connectors show the percent
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required,and for valves and connectors, identify the number of
components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized,report that delay of repair has occurred and report the
number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report, if applicable,the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair,include
the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s)for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired, the expected date of repair.
D. Biomass boilers (ID Nos. ES-BB1 and BB2)
Rotary sage dryer (ID No. ES-RD
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation,the above emission sources shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]

Permit 01819T45
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Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]
b. For any sage sent to the dryer,the Permittee shall:
i. Measure the sage input on a daily basis,
ii. Measure the hexane content of the sage exiting the process on a weekly basis. The sampling shall
include collecting sage material as it exits the desolventizer before it enters the rotary dryer every
hour for a 24-hour period each week.
iii. Calculate daily VOC emissions by using the daily sage input and the hexane content(lb hexane/lb
sage)determined weekly for the sage drying until the next weekly result is obtained.
c. The facility has determined the potential VOC emissions from both boilers to be 3.57 tons per 12
months or 0.30 tons per month. The Permittee has requested to use 0.15 tons per month of VOC emitted
per boiler for any month in which the boiler(s)operate to determine compliance with this permit
condition.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format).
e. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the monitoring and
recordkeeping is not conducted and maintained as specified in Sections 2.2. D.l.b through d or if the
emissions exceed the limit specified in Section 2.2. D.La.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
i. The monthly VOC emissions for the previous 17 months. The emissions must be calculated for each
of the 12-month periods over the previous 17 months.
E. Rotary Sage Dryer(ID No.ES-RD)
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
LIMITATION TO AVOID 15A NCAC 2D .1112: 112(g)Case by Case Maximum Achievable Control
Technology
a. In order to avoid applicability of 112(g),n-hexane emissions from the rotary dryer(ID No. ES-RD)
shall be less than 10 tons per year.
Monitorini/Recordkeeping Requirements 115A NCAC 2Q .0508(f)]
b. Maintain monthly consumption records of each material containing n-hexane as follows:
i. Maintain a quantity of n-hexane in pounds used in the rotocel operations each month and for the 12-
month period ending on that month.
ii. Maintain a record of purchase orders and invoices of materials containing n-hexane that are used in
the rotocel operations.
iii. Utilize the calculations specified in Permit Condition No. 2.2-D.Lb. above and calculate n-hexane
emissions based on the n-hexane content utilized in the rotocel operations as determined at the
desolventizer as the emissions from the rotary dryer.
c. The Permittee shall keep a record of the applicability determination on site at the source for a period of
five years after the determination, or until the source becomes an affected source. The determination
must include the analysis demonstrating why the Permittee believes the source is unaffected pursuant to
40 CFR Part 63.10(b)(3)
d. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the monitoring and
recordkeeping is not conducted and maintained as specified in Sections 2.2.E.Lb and c. or if the
emissions exceed the limit specified in Section 2.2. E.La,

Permit 01819T45
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Reporting Requirements [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality
Supervisor,of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
i. The monthly n-hexane emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.

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SECTION 3 - GENERAL CONDITIONS (version 4.012/17/15)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in
15A NCAC 02D and 02Q.
2. The terms,conditions,requirements,limitations, and restrictions set forth in this permit are binding and
enforceable pursuant to NCGS 143-215.114A and 143-215.11413,including assessment of civil and/or
criminal penalties.Any unauthorized deviation from the conditions of this permit may constitute grounds
for revocation and/or enforcement action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other
aspects of the facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,
animal or plant life,or property caused by the construction or operation of this permitted facility,or from
penalties therefore,nor does it allow the Permittee to cause pollution in contravention of state laws or
rules,unless specifically authorized by an order from the North Carolina Environmental Management
Commission.
5. Except as identified as state-only requirements in this permit,all terms and conditions contained herein
shall be enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal
Clean Air Act.
6. Any stationary source of air pollution shall not be operated,maintained,or modified without the
appropriate and valid permits issued by the DAQ,unless the source is exempted by rule. The DAQ may
issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in
violation of any of the applicable requirements. A permitted installation may only be operated,
maintained,constructed,expanded,or modified in a manner that is consistent with the terms of this permit.
B. Permit Availability[15ANCAC 02Q .0507(k)and .0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the
permit term one complete copy of the application and any information submitted in support of the application
package. The permit and application shall be made available to an authorized representative of Department of
Environmental Quality upon request.
C. Severability Clause[15A NCAC 02Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be
invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those
held to be invalid,shall remain valid and must be complied with.
D. Submissions [15A NCAC 02Q.0507(e)and 02Q .0508(i)(16)]
Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,
notifications,request for renewal,and any other information required by this permit shall be submitted to the
appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. For
continuous emissions monitoring systems(CEMS)reports,continuous opacity monitoring systems(COMS)
reports, quality assurance(QA)/quality control(QC)reports,acid rain CEM certification reports, and NOx
budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall
be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641

Permit 01819T45
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All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
E. Duty to Comply [15A NCAC 02Q .0508(i)(3)]
The Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in
this permit.Noncompliance with any permit condition except conditions identified as state-only requirements
constitutes a violation of the Federal Clean Air Act. 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.
F. Circumvention- STATE ENFORCEABLE ONLY
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 pollution control device(s)and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 02Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A
NCAC 02Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q
.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC
02Q.0524 and 02Q .0505.
3. Minor Permit Modifications[15A NCAC 02Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC
02Q.0515.
4. Significant Permit Modifications [15A NCAC 02Q .0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A
NCAC 02Q .0516.
5. Reopening for Cause[15A NCAC 02Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q
.0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in
Section 1 must be reported to the Regional Supervisor,DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes;or
c. changes in the quantity or quality of materials processed.
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.
2. Section 502(b)(10)Changes [15A NCAC 02Q .0523(a)]
a. "Section 502(b)(10)changes"means changes that contravene an express permit term or condition.
Such changes do not include changes that would violate applicable requirements or contravene
federally enforceable permit terms and conditions that are monitoring(including test methods),
recordkeeping,reporting,or compliance certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if:
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;

Permit 01819T45
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iii. the Permittee notifies the Director and EPA with written notification at least seven days before the
change is made; and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions; and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10)changes shall be made in the permit the next time that the permit is revised or
renewed,whichever comes first.
3. Off Permit Changes [15A NCAC 02Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if
a. the change affects only insignificant activities and the activities remain insignificant after the change;
or
b. the change is not covered under any applicable requirement.
4. Emissions Trading [15A NCAC 02Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D, including subsequently adopted
maximum achievable control technology standards,emissions trading shall be allowed without permit
revision pursuant to 15A NCAC 02Q .0523(c).
LA Reporting Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D.0535(f)and 02Q
.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard
allowed by any rule in Sections .0500, .0900, .1200,or.1400 of Subchapter 0213; or by a permit condition;or
that exceeds an emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note:Definitions
of excess emissions under 02D.I I10 and 02D.II I I shall apply where defined by rule)
"Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and
conditions of this permit including those attributable to upset conditions as well as excess emissions as defined
above lasting less than four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS(15A NCAC 02D .0524),NESHAPS (15A
NCAC 02D.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of
excess emissions,reporting shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 02D .0524),NESHAPS (15A NCAC 02D.I 110 or
.I I 11),or these rules do NOT define"excess emissions,"the Permittee shall report excess emissions in
accordance with 15A NCAC 02D.0535 as follows:
a. Pursuant to 15A NCAC 02D.0535,if excess emissions last for more than four hours resulting from a
malfunction,a breakdown of process or control equipment,or any other abnormal condition,the
owner or operator shall:
i. notify the Regional Supervisor or Director 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 provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration; and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished; and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A
NCAC 02D.0535(f)(3).

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Permit Deviations
3. Pursuant to 15A NCAC 02Q .0508(f)(2),the Permittee shall report deviations from permit requirements
(terms and conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not
covered under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall
include the probable cause of such deviation and any corrective actions or preventative actions taken.
The responsible official shall certify all deviations from permit requirements.
I.B Other Requirements under 15A NCAC 02D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D.0535,
including 15A NCAC 02D.0535(c)as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of
the appropriate rule unless the owner or operator of the sources demonstrates to the Director,that the
excess emissions are a result of a malfunction. The Director shall consider,along with any other pertinent
information,the criteria contained in 15A NCAC 02D .0535(c)(1)through(7).
2. 15A NCAC 02D .0535(g). Excess emissions during start-up and shut-down shall be considered a
violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are
unavoidable.
J. Emereency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the
control of the facility,including acts of God,which situation requires immediate corrective action to
restore normal operation,and that causes the facility to exceed a technology-based emission limitation
under the permit,due to unavoidable increases in emissions attributable to the emergency. An emergency
shall not include noncompliance to the extent caused by improperly designed equipment, lack of
preventive maintenance,careless or improper operation,or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the conditions specified in 3.below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of
emissions that exceeded the standards or other requirements in the permit;and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time
when emission limitations were exceeded due to the emergency. This notice must contain a
description of the emergency, steps taken to mitigate emissions,and corrective actions taken.
4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the
burden of proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement
specified elsewhere herein.
K. Permit Renewal [15A NCAC 02Q .0508(e)and 02Q .0513(b)]
This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the
end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q
.0500 renewal application is submitted at least nine months before the date of permit expiration. If the
Permittee or applicant has complied with 15A NCAC 02Q .0512(b)(1),this 15A NCAC 02Q .0500 permit
shall not expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC 02Q
.0400 terminates the facility's right to operate unless a complete 15A NCAC 02Q .0400 renewal application is
submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q

Permit 01819T45
Page 55
.0400 requirements. In either of these events,all terms and conditions of these permits shall remain in effect
until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense[15ANCAC 02Q .0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information) [15A NCAC 02Q .0508(i)(9)]
1. The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director
may request in writing to determine whether cause exists for modifying,revoking and reissuing,or
terminating the permit or to determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies
are requested by the Director.For information claimed to be confidential,the Permittee may furnish such
records directly to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement[15ANCAC 02Q .0507(f)]
The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was
submitted in the permit application, shall promptly submit such supplementary facts or corrected information
to the DAQ. The Permittee shall also provide additional information as necessary to address any requirement
that becomes applicable to the facility after the date a complete permit application was submitted but prior to
the release of the draft permit.
O. Retention of Records [15A NCAC 02Q .0508(f)and 02Q .0508 (1)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at
least five years from the date of the monitoring sample,measurement,report,or application. Supporting
information includes all calibration and maintenance records and all original strip-chart recordings for
continuous monitoring information,and copies of all reports required by the permit. These records shall be
maintained in a form suitable and readily available for expeditious inspection and review. Any records
required by the conditions of this permit shall be kept on site and made available to DAQ personnel for
inspection upon request.
P. Compliance Certification[15A NCAC 02Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,
61 Forsyth Street SW,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for
the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the
permit,including emissions limitations, standards,or work practices. It shall be the responsibility of the
current owner to submit a compliance certification for the entire year regardless of who owned the facility
during the year. The compliance certification shall comply with additional requirements as may be specified
under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status(with the terms and conditions of the permit for the period covered by the
certification);
3. whether compliance was continuous or intermittent; and
4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 02Q .0520]
A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or
compliance certification required by this permit. All certifications shall state that based on information and
belief formed after reasonable inquiry,the statements and information in the document are true,accurate,and
complete.

Permit 01819T45
Page 56
R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable
requirements,where such applicable requirements are included and specifically identified in the permit as
of the date of permit issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission, Secretary of the Department,or Governor under NCGS 143-
215.3(a)(12),or EPA under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to
the effective date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV; or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain
information to determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit
revision made under 15A NCAC 02Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 02Q .05191
The Director may terminate,modify,or revoke and reissue this permit if.
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d); or
5. the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to
carry out the purpose of NCGS Chapter 143,Article 21 B.
T. Insignificant Activities [15A NCAC 02Q .0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is
exempted from any applicable requirement or that the owner or operator of the source is exempted from
demonstrating compliance with any applicable requirement. The Permittee shall have available at the facility
at all times and made available to an authorized representative upon request,documentation,including
calculations, if necessary,to demonstrate that an emission source or activity is insignificant.
U. Property Rights [15A NCAC 02Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry [15A NCAC 02Q .0508(1)and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow
the DAQ,or an authorized representative,to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is
conducted,or where records are kept under the conditions of the permit;
b. have access to and copy,at reasonable times,any records that are required to be kept under the
conditions of the permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including
monitoring and air pollution control equipment),practices,or operations regulated or required under
the permit; and
d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of
assuring compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee
under Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for
purposes of inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or

Permit 01819T45
Page 57
interfere with any such authorized 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.
W. Annual Fee Payment[15A NCAC 02Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C.Department of Environmental
Quality. Annual permit fee payments shall refer to the permit number.
3. If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate
action to terminate the permit under 15A NCAC 02Q .0519.
X. Annual Emission Inventory Requirements [15A NCAC 02Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A
NCAC 02Q .0207(a)from each emission source within the facility during the previous calendar year. The
report shall be in or on such form as may be established by the Director. The accuracy of the report shall be
certified by a responsible official of the facility.
Y. Confidential Information[15A NCAC 02Q .0107 and 02Q.0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q
.0107,the Permittee may also submit a copy of all such information and claim directly to the EPA upon
request. All requests for confidentiality must be in accordance with 15A NCAC 02Q .0107.
Z. Construction and Operation Permits [15A NCAC 02Q .0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified
facility or emission source which is not exempted from having a permit prior to the beginning of construction
or modification,in accordance with all applicable provisions of 15A NCAC 02Q .0100 and.0300.
AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A
NCAC 02Q .0505 and.0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q .0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of
substantial compliance history.
CC. Refrigerant Requirements(Stratospheric Ozone and Climate Protection)[15A NCAC 02Q.0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment,which
use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons
listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,
and maintain such equipment according to the work practices,personnel certification requirements,and
certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or 11 substance into the
environment during the repair,servicing,maintenance,or disposal of any such device except as provided
in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166.
Reports shall be submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases-Section 112(r) [15A NCAC 02Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section
112(r)of the Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part
68.

Permit 01819T45
Page 58
EE.Prevention of Accidental Releases General Duty Clause-Section 112(r)(1)—FEDERALLY-
ENFORCEABLE ONLY
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.
FF. Title IV Allowances [15A NCAC 02Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not
use allowances as a defense to noncompliance with any other applicable requirement. The Pennittee's
emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean
Air Act.
GG. Air Pollution Emergency Episode[15A NCAC 02D.0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to
operate in accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of
an approved plan,with the appropriate requirements specified in 15A NCAC 02D.0300.
HH. Registration of Air Pollution Sources [15A NCAC 02D .0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is
required to register a source of air pollution,this registration and required information will be in accordance
with 15A NCAC 02D .0202(b).
H. Ambient Air Ouality Standards [15A NCAC 02D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,
any source of air pollution shall be operated with such control or in such manner that the source shall not cause
the ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on
which the source is located. When controls more stringent than named in the applicable emission standards in
this permit are required to prevent violation of the ambient air quality standards or are required to create an
offset,the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q .0508(i)(16)]
Emission compliance testing shall be by the procedures of Section .2600,except as may be otherwise
required in Rules .0524, .0912, .1110, .1111, or.1415 of Subchapter 02D. If emissions testing is required by
this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance,
the Permittee shall perform such testing in accordance with 15A NCAC 02D.2600 and follow the procedures
outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing.Testing protocols are not required to be pre-approved by the
Director prior to air pollution testing.The Director shall review air emission testing protocols for pre-
approval prior to testing if requested by the owner or operator at least 45 days before conducting the
test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable
standard shall notify the Director at least 15 days before beginning the test so that the Director may at
his option observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates
during the period of air testing.The owner or operator of the source shall ensure that the equipment or
process being tested is operated at the production rate that best fulfills the purpose of the test. The
individual conducting the emission test shall describe the procedures used to obtain accurate process
data and include in the test report the average production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days
after sample collection unless otherwise specified in the specific conditions. The owner or operator may

Permit 01819T45
Page 59
request an extension to submit the final test report. The Director shall approve an extension request if he
finds that the extension request is a result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the
validity of the compliance test.The Director may:
i. Allow deviations from a method specified under a rule in this Section if the owner or operator
of the source being tested demonstrates to the satisfaction of the Director that the specified
method is inappropriate for the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative
method is necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test
method is specified in this Section if the methods can be demonstrated to determine compliance
of permitted emission sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source
subject to a rule in this Subchapter to determine the compliance status of that source or to verify any
test data submitted relating to that source. Any test conducted by the Division of Air Quality using
the appropriate testing procedures described in Section 02D .2600 has precedence over all other
tests.
KK. Reopening for Cause[15A NCAC 02Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three
or more years;
b. additional requirements(including excess emission requirements)become applicable to a source
covered by Title IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or other terms or conditions of the permit; or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with
the applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable
requirement is promulgated. No reopening is required if the effective date of the requirement is after the
expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q
.0513(c).
3. Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 02Q
.0507, .0521,or.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the
permit is reopened,the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall
affect only those parts of the permit for which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be
reopened,except in cases of imminent threat to public health or safety the notification period may be less
than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period,after receiving notification from the
EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the
EPA a proposed determination of termination,modification, or revocation and reissuance, as appropriate.
LL.Reporting Requirements for Non-Operating Equipment[15A NCAC 02Q .0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is
taken from and placed into operation. During operation the monitoring recordkeeping and reporting
requirements as prescribed by the permit shall be implemented within the monitoring period.
MM.Fugitive Dust Control Requirement[15A NCAC 02D.0540] - STATE ENFORCEABLE ONLY
As required by 15A NCAC 02D .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 or excessive fugitive dust emissions from

Permit 01819T45
Page 60
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 02D.0540(f).
"Fugitive dust emissions"means particulate matter from process operations 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).
NN. Specific Permit Modifications [15A NCAC 02Q.0501 and.0523]
1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2),the Permittee shall file a Title V Air
Quality Permit Application for the air emission source(s)and associated air pollution control device(s)
on or before 12 months after commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2),the Permittee shall not begin
operation of the air emission source(s)and associated air pollution control device(s)until a Title V Air
Quality Permit Application is filed and a construction and operation permit following the procedures of
Section .0500 (except for Rule .0504 of this Section) is obtained.
3. For modifications made pursuant to 502(b)(10),in accordance with 15A NCAC 02Q .0523(a)(1)(C),the
Permittee shall notify the Director and EPA(EPA-Air Planning Branch, 61 Forsyth Street SW,
Atlanta,GA 30303)in writing at least seven days before the change is made. The written notification
shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit
renewal,the Permittee shall submit a page'U" of the application forms signed by the responsible official
verifying that the application for the 502(b)(10)change/modification, is true, accurate, and complete.
Further note that modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying
preconstruction requirements.
00.Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and.0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency
(EPA), EPA's decision to not object to the proposed permit is considered final and binding on the EPA and
absent a third party petition,the failure to object is the end of EPA's decision-making process with respect to
the revisions to the permit.The time period available to submit a public petition pursuant to 15A NCAC 02Q
.0518 begins at the end of the 45-day EPA review period.

Permit 01819T45
Page 61
ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
SOz Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound

PAT MCCRORY
6ovenior
DONALD R. VAN DER VAART
Secretary
Air Quality SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Director
January 12, 2016
Dr. David M. Peele, Ph.D.
President
Avoca Incorporated
P.O.Box 129
Merry Hill,North Carolina 27957
SUBJECT: Air Quality Permit No. 01819T45
Facility ID: 0800044
Avoca Incorporated
Merry Hill,Bertie County,North Carolina
Fee Class: Title V
PSD Status: Major
Dear Dr. Peele:
In accordance with your completed Prevention of Significant Deterioration (PSD) application
deemed complete on September 1,2015,we are forwarding herewith Air Quality Permit No. 01819T45
to Avoca Incorporated, 841 Avoca Farm Road, Merry Hill, North Carolina, authorizing the
construction and operation, of the emission source(s) and associated air pollution control device(s)
specified herein. Additionally, any emissions activities determined from your Air Quality Permit
Application as being insignificant per 15A North Carolina Administrative Code 2Q .0503(8)have been
listed for informational purposes as an "ATTACHMENT." Please note the requirements for the annual
compliance certification are contained in General Condition P in Section 3. The current owner is
responsible for submitting a compliance certification for the entire year regardless of who owned the
facility during the year.
As the designated responsible official it is your responsibility to review,understand, and abide by
all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any
person who operates any emission source and associated air pollution control device subject to any term
or condition of the attached permit reviews, understands, and abides by the condition(s) of the attached
permit that are applicable to that particular emission source.
If any parts, requirements, or limitations contained in this Air Quality 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. This hearing request must be in the form of a
written petition, conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both
the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714
and the Division of Air Quality, Permitting Section, 1641 Mail Service Center, Raleigh,North Carolina
27699-1641. The form for requesting a formal adjudicatory hearing may be obtained upon request from
the Office of Administrative Hearings. Please note that this permit will be stayed in its entirety upon
receipt of the request for a hearing. Unless a request for a hearing is made pursuant to NCGS 15013-23,
this Air Quality Permit shall be final and binding 30 days after issuance.
State of North Carolina I Environmental Quality Air Quality
1641 Mail Service Center 217 W.Jones Street,Suite 4000 J Raleigh,NC 27609-1641
919 707 8400 T

Dr. Peele
January 12, 2016
Page 2
You may request modification of your Air Quality Permit through informal means pursuant to
NCGS 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 this Air Quality
Permit will become final and binding regardless of a request for informal modification unless a request
for a hearing is also made under NCGS 150B-23.
The construction of new air pollution emission source(s) and associated air pollution control
device(s), or modifications to the emission source(s) and air pollution control device(s) described in
this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to
construction unless the Permittee has fulfilled the requirements of GS 143-215-108A(b) and received
written approval from the Director of the Division of Air Quality to commence construction. Failure
to receive an Air Quality Permit or written approval prior to commencing construction is a violation
of GS 143-215.108A and may subject the Permittee to civil or criminal penalties as described in GS
143-215.114A and 143-215.114B.
Bertie County has been triggered for increment tracking under PSD for PM10, S02, and NOx.
However, no changes in actual emissions of these pollutants are associated with the permit
modification.
This Air Quality Permit shall be effective from January 12, 2016 until December 31, 2015,' is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein. Should you have any questions concerning this matter, please contact Betty
Gatano, P.E. at(919) 707-8736 or [e-mail].
Sincerely yours,
V42J,
William D. Willets, P.E., Chief,Permitting Section
Division of Air Quality,NCDEQ
Enclosure
c: Rob Fisher, Supervisor, Washington Regional Office
Heather Ceron, EPA Region 4
Central Files
Connie Horne(cover letter only)
This permit shall expire on the earlier of November 30,2020 or the date the renewal of Air Permit No.01819T44
has been issued or denied.

ATTACHMENT to Permit No. 01819T45
Insignificant Activities per 15A NCAC 02Q .0503(8)
Emission Control Device Control Device
Source ID No. Emission Source Description ID No. Description
IWWTP-ET1 Wastewater treatment plant equalization tank N/A N/A
No. 1 (65,500 gallon capacity)
IWWTP-ET2 Wastewater treatment plant equalization tank N/A N/A
No.2(65,500 gallon capacity)
Wastewater treatment plant aeration tank No.2
IWWTP-AT2 (63,500 gallon capacity) N/A N/A
Wastewater treatment plant aeration tank No. 3
IWWTP-AT3 (63,500 gallon capacity) N/A N/A
IWWTP-CLR Wastewater treatment plant clarifier(1,310 N/A N/A
gallon capacity)
ITK9238 No.2 fuel oil storage tank(50,000 gallon N/A N/A
capacity)
ITK9239 No.2 fuel oil storage tank(50,000 gallon N/A N/A
capacity)
ITK102 No.2 fuel oil storage tank(495 gallon N/A N/A
capacity)
ITK103 No. 2 fuel oil storage tank(495 gallon N/A N/A
capacity)
ITKFP No.2 fuel oil storage tank(270 gallon N/A N/A
capacity)
CD-Z-9215 One water spray fume
scrubber(0.5 gallons
per minute minimum
ECS process:batch preparation of water injection rate)
IECS ethylenediamine/copper sulfate solution
CD-Z-9216 One water spray fume
scrubber(0.5 gallons
per minute minimum
water injection rate)
IES-PV Propane vaporizer N/A N/A
11 I-Briquette Sage Briquetting Machine N/A N/A
1. Because an activity is insignificant 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 A 100 "Control of Toxic Air
Pollutants"or 2Q .0711 "Emission Rates Requiring a Permit".
3. For additional information regarding the applicability of GACT and MACT ZZZZ see the NC DAQ website:
htti)://dag.state.nc.us/toxics/areasources/.

Summary of Changes to Permit
The following changes were made to Avoca Incorporated,Merry Hill,Air Permit No01819T45:
Pages Section (Description of Changes
Cover and -- Updated all dates and permit revision numbers.
throughout
3-8 1.0 Equipment List • Added page numbers
• Added the following emission sources to the SFG operations:
o One 12,500 gallon storage tank(ID No.T-3006)
o One 12,500 gallon process tank(ID No.T-3007)
o Two reactors(ID Nos.R-3003 and R-3004)with process
condensers(ID Nos.EX-3004 and ES-3005)
o One centrifuge(ID No.C-3002)
o One dryer with(ID No.D-3002)with process condenser(ID No.
ES-3006)and a chilled water control condenser(ID No.CD-
3002)
• Added a second process condenser(ES-3002)on reactor(ID No.R-
3001)
• Added the chilled water condenser(ID No. CD-3003)and the
mineral oil scrubber(ID No.CD-3004-5)as optional controls on
several SFG emission sources.
• Corrected cross reference in footnote No. 1.
• Removed reference to two storage and recycle tanks(ID Nos.ES-M-
125A and ES-M-12513)from footnote No. 1. These tanks are not
part of the equipment subject to BACT specified in Section 2.2.13.
• Removed footnotes and asterisks relating to minor modifications for
emission sources(ID Nos.ES-ES-M-125A and 125B,E104,ES-TK-
PNE-1,and D-1002).
• Removed footnotes and asterisks for 502(b)(10)notification for
emission source(ID No.ES-MSDU-1024).
• Removed footnotes and asterisks relating to a 15A NCAC 2Q
.0501(c)(2)modification for emission sources(ID Nos.ES-13131,ES-
BB2,ES-RD,CD-BB1C and CD-BB1BH). The Permittee met this
requirement with the submittal of a Permit application on October
10,2012.
• Removed footnotes and asterisks relating to a 15A NCAC 2Q
.0501(c)(2)modification for emission sources in the SFG operation.
The Permittee met this requirement with the submittal of a Permit
application on May 30,2014.
9— 10 2.1.A.Lb
2.1.A.2.b Updated testing condition with most current version.
2.1.A.3.c
11— 12 2.1.B.Lb
2.1.B.2.b Updated testing condition with most current version.
2.1.B.4.b
16—17 2.1.D.Lb Updated testing condition with most current version.
2.1.D.2.b
19 2.1.E—Regulations • Added reference for avoidance of 15A NCAC 2D.0530,"Prevention
Table of Significant Deterioration'(PSD).
• Added reference for avoidance of 15A NCAC 2D.1112,"112(g)
Case-by-Case Maximum Achievable Control Technology."

Pages Section (Description of Changes
20 2.1.E.1 . Removed requirement for stack testing of the biomass boilers(ID
(old numbering) Nos. ES-BB 1 and ES-BB2). The testing was conducted on
December 6,2011 and approved by DAQ via memorandum dated
January 24,2012.
Renumbered the remaining section accordingly.
24—25 2.1.G Added permit condition for Best Available Control Technology
(BACT)limit under 15 NCAC 2D .0530,PSD for the modified SFG
operations.
26 2.2.A—Regulations Added reference for 15A NCAC 2D.1100,"Control of Air Toxics."
Table
29 2.2.B.Lb Updated testing condition with most current version.
41 2.2.0 Removed SFG operations from equipment list.
45 2.2.C.l.c.ii.(A)(1) Removed SFG operations from requirements for batch process vents
under 40 CFR Part 63,Subpart FFFF and renumbered the permit
condition accordingly. With the use of heptane,the SFG operations are
no longer subject to the 40 CFR Part 63,Subpart FFFF.
-- 2.2.C.2 Removed avoidance condition under 15A NCAC 2Q .0317 for 15A
NCAC 2D .0530,PSD,for the SFG operations. With the expansion of
the SFG operations,these operations become subject to PSD.
-- 2.2.C.3 Removed avoidance condition under 15A NCAC 2Q.0317 for Group
Process Vents under 40 CFR Part 63,Subpart FFFF. With the use of
heptane,the SFG operations are no longer subject to the 40 CFR Part
63,Subpart FFFF.
49 2.2.D.Le Added non-compliance statement.
49 2.2.E.1.d Added non-compliance statement.
51 —61 3.0 Updated the General Conditions and the List of Acronyms to the most
current version(V4.0: 12/17/2015).

State of North Carolina
N;C- Department of Environmental Quality
Division of Air Quality
AIR QUALITY PERMIT
Permit No. Replaces Permit No.(s) Effective Date Expiration Date
01819T45 01819T44 January 12, 2016 December 31, 2020`
i This permit shall expire on the earlier of December 31,2020 or the date the renewal of Air Permit No.01819T44 has been
issued or denied.
Until such time as this permit expires or is modified or revoked,the below named Permittee is authorized to construct
and operate the emission source(s)and associated air pollution control device(s)specified herein,in accordance with
the terms, conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B
of Chapter 143,General Statutes of North Carolina as amended,and Title 15A North Carolina Administrative Codes
(15A NCAC), Subchapters 2D and 2Q,and other applicable Laws.
Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission
source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application
to the permitting authority and received an Air Quality Permit,except as provided in this permit.
Permittee: Avoca, Inc.
Facility ID: 0800044
Facility Site Location: 841 Avoca Farm Road
City, County, State, Zip: Merry Hill,Bertie County, NC 27957
Mailing Address: P.O. Box 129
City, State, Zip: Merry Hill,NC 27957
Application Number: 0800044.15A
Complete Application Date: September 4,2015
Primary SIC Code: 2087
Division of Air Quality, Washington Regional Office
Regional Office Address: 943 Washington Square Mall
Washington, NC 27889
Permit issued this the 12th day of January, 2016.
William D. Willets,P.E.,Chief,Permitting Section
By Authority of the Environmental Management Commission

Table of Contents
SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLUTION
CONTROL DEVICE(S)AND APPURTENANCES
SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS
2.1 - Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring, recordkeeping, and reporting
requirements)
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
(Including specific requirements,testing, monitoring,recordkeeping, and reporting
requirements)
SECTION 3: GENERAL PERMIT CONDITIONS
ATTACHMENTS
List of Acronyms

Permit 01819T45
Page 3
SECTION 1 - PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR
POLLUTION CONTROL DEVICE (S) AND APPURTENANCES
The following table contains a summary of all permitted emission sources and associated air pollution control devices and
appurtenances:
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. I ID No. Description
Rotocel Operations
13,27, ES-1001-2-1-P1 Rotocel extractor,desolventizer, CD-31209 One chilled water
43 PSD and solvent separation/recovery condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,43 ES-M-125A and M- Two storage and recycle tanks CD-1001-2-C-1 One chilled water
125B (19,500 gallons capacity each) condenser
MACT FFFF
CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,27, ES-1001-2-1-17 Process equipment leaks NA NA
43 PSD
MACT FFFF
13,27, ES-1001-2-1-WW Rotocel Operations wastewater NA NA
43 PSD stream
MACT FFFF
Recovery Operations
13,27, ES-1001-1-1-P1 Arcon process tank M-1 CD-1001-1-3 One chilled water
43 PSD condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
scrubber(8 gallons per
minute minimum mineral
oil injection rate)
13,27, ES-1001-1-1-P2 Stripper T-5 and receiver M-21 CD-1001-1-T513 One chilled water
43 PSD condenser
CAM
MACT FFFF CD-1001-2-S-1 One packed tower
13,27, ES-1001-1-1-P3 Seven process tanks of various scrubber(8 gallons per
43 PSD capacities and one fixed roof minute minimum mineral
MACT FFFF methanol storage tank(7,050 oil injection rate)
gallon capacity)
13,27, ES-1001-1-1-F Process equipment leaks NA NA
43 PSD
MACT FFFF
13,27, ES-1001-1-1-WW Recovery Operations wastewater NA NA
43 PSD stream
MACT FFFF

Pages Section Description of Changes
20 2.1.E.1 • Removed requirement for stack testing of the biomass boilers(ID
(old numbering) Nos. ES-BB 1 and ES-BB2). The testing was conducted on
December 6,2011 and approved by DAQ via memorandum dated
January 24,2012.
• Renumbered the remaining section accordingly.
24—25 2.LG Added permit condition for Best Available Control Technology
(BACT)limit under 15 NCAC 2D.0530,PSD for the modified SFG
operations.
26 2.2.A—Regulations Added reference for 15A NCAC 2D.1100,"Control of Air Toxics."
Table
29 2.2.B.Lb Updated testing condition with most current version.
41 2.2.0 Removed SFG operations from equipment list.
45 2.2.C.l.c.ii.(A)(1) Removed SFG operations from requirements for batch process vents
under 40 CFR Part 63,Subpart FFFF and renumbered the permit
condition accordingly. With the use of heptane,the SFG operations are
no longer subject to the 40 CFR Part 63, Subpart FFFF.
-- 2.2.C.2 Removed avoidance condition under 15A NCAC 2Q.0317 for 15A
NCAC 213.0530,PSD,for the SFG operations. With the expansion of
the SFG operations,these operations become subject to PSD.
-- 2.2.C.3 Removed avoidance condition under 15A NCAC 2Q.0317 for Group
Process Vents under 40 CFR Part 63,Subpart FFFF. With the use of
heptane,the SFG operations are no longer subject to the 40 CFR Part
63,Subpart FFFF.
49 2.2.D.Le Added non-compliance statement.
49 2.2.E.l.d Added non-compliance statement.
51 —61 3.0 Updated the General Conditions and the List of Acronyms to the most
current version(V3.7: 09/21/2015).

Permit 01819T45
Page 4
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID Nc I I ID No. Description
Concrete Operations
27,42 ES-1001-1-2-P Six process tanks of various CD-1001-1-2 One chilled water
PSD capacities condenser
MACT FFFF
42 HB-1 One steam-heated hot box NA NA
MACT FFFF
42 HB-2 One steam-heated hot box NA NA
MACT FFFF
42 HB-3 One steam-heated hot box NA NA
MACT FFFF
42 HB-4 One steam-heated hot box NA NA
MACT FFFF
42 ES-1001-1-2-F Process equipment leaks NA NA
MACT FFFF
42 ES-1001-1-2-WW Concrete Operations wastewater NA NA
MACT FFFF stream
Sclareol Recrystallization(SFG) Operations
24 T-3001 One process tank(6,700 gallons Optional controls Optional controls
PSD capacity) CD-3003 Chilled water condenser
24 T-3002 through 3005 Four process tanks(2,538 gallons
PSD capacity each) CD-3004-S Mineral oil scrubber
24 T-3006 One storage tank(12,500 gallons
PSD capacity)
24 T-3007 One process tank(12,500 gallons
PSD capacity)
24 C-3001 and C-3002. Two centrifuges
PSD
24 R-3002 One reactor equipped with a
PSD chilled water process condenser
(EX-3003)
24 R-3003 One reactor equipped with a
PSD chilled water process condenser
(EX-3004)
24 R-3004 One reactor equipped with a
PSD chilled water process condenser
(EX-3005)
24 R-3001 One reactor equipped with two CD-3001 Chilled water condenser
PSD chilled water process condensers
(EX-3001 and ES-3002) Optional controls Optional controls
24 D-3001 One steam-heated dryer equipped CD-3003 Chilled water condenser
PSD with a chilled water process
condenser(EX-3002) CD-3004-S Mineral oil scrubber
24 D-3002 One steam-heated dryer equipped CD-3002 Chilled water condenser
PSD with a chilled water process
condenser(EX-3006) Optional controls Optional controls
CD-3003 Chilled water condenser
CD-3004-S Mineral oil scrubber
24 ES-1003-10-F Process equipment leaks NA NA
PSD

Permit 0 18 19T45
Page 5
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
24 ES-1003-10-WW SFG Process wastewater stream NA NA
PSD
Biological Conversion Equipment for Purification of Sclareolide
42 ES-1001-1-3-P Twelve process tanks of various NA NA
MACT FFFF capacities
42 G-17 One centrifuge NA NA
MACT FFFF
42 ES-1001-1-3-F Process equipment leaks NA NA
MACT FFFF
42 D-1202 One steam-heated dryer NA NA
MACT FFFF
42 A-2 One distillation column(6 gallons NA NA
MACT FFFF per minute nominal process rate)
42 ES-1001-1-3-WW Biological conversion equipment NA NA
MACT FFFF for purification of sclareolide
wastewater stream
Sclareolide(SDE) Operations
42 ES-1001-1-4-P Four process tanks of various NA NA
MACT FFFF capacities
42 M-20 One acetic acid storage tank NA NA
MACT FFFF (10,135 gallon capacity)
42 ES-1001-1-4-F Process equipment leaks NA NA
MACT FFFF
42 M-10 One batch reactor CD-M-34 One venturi-type wet
MACT FFFF scrubber(10 gallons per
42 M-10A One batch reactor minute minimum liquid
MACT FFFF injection rate)
42 D-1231A One batch reactor
MACT FFFF
42 D-1231B One batch reactor
MACT FFFF
42 ES-1001-1-4-WW SDE Operations wastewater NA NA
MACT FFFF stream
Plant Nutrient Extraction(PNE) Operations
42 D31214 One product extract reactor EX2203 One chilled water
MACT FFFF condenser
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)

Permit 01819T45
Page 6
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
42 D31211 One waste solids separator vessel EX2205 One chilled water
MACT FFFF (1,333 gallon capacity) condenser
CD-Z-9215 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
42 ES-TK-PNE-1 Solvent Process Tank(9,500 NA NA
MACT FFFF gallons capacity
42 ES-1003-2-1-F Process equipment leaks NA NA
MACT FFFF
42 ES-1003-2-1-WW PNE process wastewater stream NA NA
MACT FFFF
42 ES-1003-2-1-P Seven process tanks of various CD-Z-9215 2 One water spray fume
MACT FFFF capacities scrubber(0.5 gallons per
42 C-31203 One centrifuge minute minimum water
MACT FFFF injection rate)
42 D-1002 One dryer with a process chilled
MACT FFFF water condenser CD-Z-9216 2 One water spray fume
scrubber(0.5 gallons per
minute minimum water
injection rate)
Ethyl Vanillin Glucoside(EVG) Operations
42 D-2202 One reactor CD-Z-9215 2 One water spray fume
MACT FFFF scrubber(0.5 gallons per
42 D-1215 One reactor minute minimum water
MACT FFFF injection rate)
42 D-1218 One reactor
MACT FFFF CD-Z-9216 2 One water spray fume
42 D-1201 One steam-heated dryer scrubber(0.5 gallons per
MACT FFFF minute minimum water
injection rate)
42 ES-1003-2-2-F Process equipment leaks NA NA
MACT FFFF
42 ES-1003-2-2-WW EVG Operation wastewater stream NA NA
MACT FFFF
Botanical Extraction Operations
15,27, ES-1001-11-P Immersion extractor Z-1001, CD-1001-11-EX1002 One chilled water
43 PSD desolventizer Z-1002, condenser
CAM day tank 90024(6,000 gallon
MACT FFFF capacity), CD-1001-11-EX 1003 One cryogenic(nitrogen)
first-stage evaporator EX-1012, condenser system(40 OF
second-stage evaporator EX-1013, maximum 24-hour
distillation column EX-90008,and average outlet
nine process tanks of various temperature)
IL capacities

Permit 01819T45
Page 7
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
15,27, ES-1001-11-F Process equipment leaks NA NA
43 PSD
MACT FFFF
15 MHZ-1002 One plant material grinder(1,011 CD-1003-4-1 One bagfilter(244 square
pounds per hour nominal feed rate) feet of filter area)
15,27, ES-1001-11-WW Botanical extraction operation NA NA
43 PSD wastewater stream
MACT FFFF
Biomass Extraction Operations
15,27 ES-1004-1 Biomass extraction debagging CD-1004-1-FF1 One cartridge filter(6.7:1
PSD maximum air-to-cloth
ratio)
15,27 ES-1004-2-F Process equipment leaks NA NA
PSD
15,27 ES-1004-2-WW Biomass extraction operation NA NA
PSD wastewater stream
15,27 ES-1004-2-P Immersion extractor Z-41001, CD-1004-2EX1002 One chilled water
PSD desolventizer Z-41002, condenser
CAM day tank 490025(9,953 gallon
capacity), CD-1004-2EX1003 One cryogenic(nitrogen)
iso-hexane storage tank 490024 condenser system(40°F
(13,536 gallon capacity), maximum 24-hour
first stage evaporator EX-41012, average outlet
second stage evaporator temperature)
EX-41013,
distillation column EX-490008,
and
nine process tanks of various
capacities
15 ES-1004-2Silo Biomass silo loadout CD-1004-2-FF2 One bagfilter(254 square
feet of filter area)
15 ES-MSDU-1024 Molecular sieve I N/A N/A
Miscellaneous Operations
9,27 H-101 One No.2 fuel oil-fired boiler NA NA
2D.1109 case-by- (20.3 million Btu per hour
case MACT maximum heat input rate)
9,27 H-102 One No. 2 fuel oil-fired boiler NA NA
2D.1109 case-by- (20.3 million Btu per hour
case MACT maximum heat input rate)
9,27 H-103 One No.2 fuel oil-fired boiler NA NA
2D.1109 case-by- (25.2 million Btu per hour
case MACT maximum heat input rate)
19 ES-BB1 and ES-BB2 Two biomass/bio-based solids- CD-BB1C One simple cyclone(114
NSPS—Subpart De fired boilers(24 million Btu per inches in diameter)
MACT—Subpart hour maximum heat input rate
DDDDD each) CD-BB 1 BH One bagfilter(8,900
square feet of filter area)

Permit 01819T45
Page 8
Page Emission Source Emission Source Description Control Device Control Device
Nos. ID No. ID No. Description
19 ES-RD One No.2 fuel oil/propane-fired CD-BB1C One simple cyclone(114
rotary dryer(30.0 million Btu per inches in diameter)
hour maximum heat input rate)
CD-BB 1BH One bagfilter(8,900
square feet of filter area)
11 ES-PkGenl One No.2 fuel oil-fired limited CD-CatOxl One catalytic oxidizer
MACT ZZZZ use emergency generator(2,935 (695 °F minimum inlet
kilowatt maximum rated power temperature)
output)
27,43 WWTP-ATl Wastewater treatment plant NA NA
PSD aeration tank No. l
MACT FFFF
23 E101 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(587 horsepower
maximum rated power output)
23 E 102 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(760 horsepower
maximum rated power output)
23 E103 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(603 horsepower
maximum rated power output)
23 E104 One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ generator(401 horsepower
maximum rated power output)
23 FP One No.2 fuel oil-fired emergency N/A N/A
MACT ZZZZ fire water pump(285 horsepower
maximum rated power output)
' The Permittee is permitted to operate sources(ID Nos ES-1001-1-1-P1,ES-1001-1-1-P2, and ES-1001-1-1-P3) without the
simultaneous operation of scrubber(ID No.CD-1001-2-S-1)under the conditions cited in Sections 2.2 B.l.c and d,below.
2 The Permittee is allowed to operate PNE and EVG operations without operating the water spray fume scrubber(ID No.CD-Z-
9215)and water spray scrubber(ID NO.CD-Z-9216)when using non-HAP solvents.

Permit 01819T45
Page 9
SECTION 2 — SPECIFIC LIITATIONS AND CONDITIONS
2.1 - Emission Source(s) and Control Devices(s) Specific Limitations and Conditions
The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to
the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and
reporting requirements as specified herein:
A. Three No. 2 fuel oil-fired boilers (ID Nos.H-101,H-102, and H-103)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Particulate matter 0.37 pounds per million Btu heat input 15A NCAC 213 .0503
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
20 percent opacity: H-103 only 15A NCAC 21) .0521(d)
Visible emissions
40 percent opacity: H-101 and H-102 15A NCAC 21) .0521(c)
Hazardous Air Pollutants Case-By-Case Maximum Achievable 15A NCAC 21) .1109
Control Technology (1120)Case-by-Case MACT)
1. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of No. 2 fuel oil that are discharged from these
sources into the atmosphere shall not exceed 0.37 pounds per million Btu heat input. [15A NCAC 2D
.0503(a)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping, or reporting is required for particulate emissions from the firing of No. 2
fuel oil in boilers(ID Nos.H-101,H-102, or H-103).
2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be
included when determining compliance with this standard.
Testing[15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0516.

Permit 01819T45
Page 10
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for sulfur dioxide emissions from the firing of No.
2 fuel oil in boilers(ID Nos. H-101,H-102,or H-103).
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from boilers (ID Nos. H-101 and H-102) shall not be more than 40 percent opacity
when averaged over a six-minute period. However, six-minute averaging periods may exceed 40 percent
not more than once in any hour and not more than four times in any 24-hour period. In no event shall the
six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)]
b. Visible emissions from boiler(ID No. H-103) shall not be more than 20 percent opacity when averaged
over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than
once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute
average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
c. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 A.3.a or b, above, as applicable, the
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting[15A NCAC 2Q .0508(f)]
d. No monitoring,recordkeeping, or reporting is required for visible emissions from the firing of No. 2 fuel
oil in boilers(ID Nos. H-101,H-102,or H-103).
4. 15A NCAC 2D .1109: 112(J) CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL
TECHNOLOGY
Clean Air Act Section 112(j)- Case-by-Case MACT for Boilers &Process Heaters
a. The Permittee shall use best combustion practices when operating affected boilers (ID Nos.11-101, H-
102, and H-103). The initial compliance date for this work practice standard and the associated
monitoring,recordkeeping, and reporting requirements is August 17,2013. These conditions need not be
included on the annual compliance certification until after the initial compliance date.
Monitoring [15A NCAC 2Q .0508(f)]
b. To assure compliance,the Permittee shall perform an annual boiler inspection and maintenance on boilers
as recommended by the manufacturer,or as a minimum,the inspection and maintenance requirement shall
include the following:
i. Inspect the burner, and clean or replace any components of the burner as necessary;
ii. Inspect the flame pattern and make any adjustments to the burner necessary to optimize the flame
pattern; and
iii. Inspect the system controlling the air-to-fuel ratio, and ensure that it is correctly calibrated and
functioning properly.
The Permittee shall conduct at least one tune-up per calendar year for each boiler to demonstrate
compliance with this requirement.The Permittee shall be deemed in noncompliance with 15A NCAC 2D
.1109 if the affected boilers are not inspected and maintained as required above.
Recordkeeping [15A NCAC 2Q .0508(f)]
c. The results of inspection and maintenance performed on affected boilers shall be maintained in a logbook
(written or electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each inspection; and,
iii. The results of any maintenance performed on the boilers.

Permit 01819T45
Page 11
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1109 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
d. No reporting is required for the best combustion practices requirements for boilers.
B. One diesel-fired limited use generator (ID No. ES-PkGenl) and one associated catalytic
oxidizer (ID No. CD-CatOxl)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 21) .0521(d)
Hazardous Air Pollutants Maximum Achievable Control Technology 15A NCAC 2D .1111
(40 CFR Part 63, Subpart ZZZZ)
Nitrogen Oxides Emit less than 40 tons of NOx per 15A NCAC 2Q .0317 to avoid
consecutive 12-month period 15A NCAC 2D .0530
1. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from limited use generator(ID No.ES-PkGenl) shall not exceed 2.3 pounds
per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and
other substances shall be included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.l.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for sulfur dioxide emissions from the firing of No.
2 fuel oil in limited use generator(ID No. ES-PkGenl).
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from limited use generator (ID No. ES-PkGenl) shall not be more than 20 percent
opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period. In no event
shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring,recordkeeping,or reporting is required for visible emissions from the firing of No. 2 fuel
oil in limited use generator(ID No.ES-PkGenl).

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3. 15A NCAC 2D.1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
140 CFR Part 63, Subpart ZZZZ]
Applicability [40 CFR §63.6580 and §63.6585]
a. For the limited use generator (ID No. ES-PkGenl), the Permittee shall comply with all applicable
requirements of 15A NCAC 21) .1111 "Maximum Achievable Control Technology"pursuant to 40 CFR
Part 63, Subpart ZZZZ "National Emission Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines (RICE)" including Subpart A"General Provisions."
Emission Limits and Operational Requirements [40 CFR §63.6590(b)(1)(ii)and §63.6675]
b. In accordance with 40 CFR§63.6590(a)(2)(i)this source is considered an existing Limited Use source for
purposes of Subpart ZZZZ. To qualify as such, the Permittee must limit the operational hours of this
source to less than 100 hours per consecutive 12-month period in accordance with 40 CFR
§63.6590(b)(1)(ii). The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if this
source operates for 100 hours or more per consecutive 12-month period.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall install and maintain a non-resettable hour meter, in accordance with manufacturer's
recommendations,on limited use generator ES-PkGenl I.The Permittee shall conduct monthly monitoring
of hours of operation for this source as measured by the non-resettable hour meter.The Permittee shall be
deemed in noncompliance with 15A NCAC 2D .I I I I if this monitoring is not performed.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall maintain monthly records of the hours of operation of limited use generator ES-
PkGenl, as measured by the non-resettable hour meter,in a logbook(written or electronic format)on-site
and made available to an authorized representative upon request.
Reporting [15A NCAC 2Q .0508(f)]
e. No monitoring,recordkeeping,or reporting is required for hazardous air pollutant emissions from limited
use generator ES-PkGenl.
4. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS to avoid
15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of 15A NCAC 2D .0530(g) for major sources and major modifications,
limited use generator (ID No. ES-PkGenl) shall discharge into the atmosphere less than 40 tons of
nitrogen oxides per consecutive 12-month period.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 B.4.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Operational Limitation [15A NCAC 2Q .0508(f)]
c. In order to ensure compliance with the limit given in Section 2.1 BA.a, above, the operation of limited
use generator(ID No. ES-PkGenl) shall not exceed 1,500 hours in a consecutive 12-month period. The
Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the rolling total hours of
operation of the limited use generator exceed 1,500 hours per consecutive 12-month period.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
d. The Permittee shall conduct monthly monitoring of hours of operation of this source as measured by the
non-resettable hour meter and maintain monthly records of that monitoring in a logbook (written or
electronic format)on-site and made available to an authorized representative upon request. The Permittee

Permit 01819T45
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shall be deemed in noncompliance with 15A NCAC 2D .0530 if this monitoring is not conducted, these
records are not maintained, or if the rolling total hours of operation for the limited use generator exceed
1,500 hours per consecutive 12-month period.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semiannual summary report of monitoring and recordkeeping activities
postmarked or delivered on or before January 30 of each calendar year for the preceding six-month period
between July and December, and July 30 of each calendar year for the preceding six-month period
between January and June. The report must clearly identify all instances of deviations from the
requirements of this permit and include:
i. The monthly hours of operation for the limited use generator for each of the previous 17 months; and
ii. The total hours of operation for the limited use generator for each consecutive 12-month period ending
during the reporting period.
C. Rotocel Operations, including:
• Rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-1001-2-1-P) and one
associated chilled water condenser (ID No. CD-31209) venting to one packed tower scrubber (ID
No.CD-1001-2-S-1);
• Two storage and recycle tanks (ID No. ES-M-125A and M-12513) and one associated chilled water
condenser(ID No.CD-1001-2-C-1)venting to one packed tower scrubber(ID No.CD-1001-2-S-1);
• Process equipment leaks (ID No. ES-1001-2-1-F); and
• Rotocel Operations wastewater stream (ID No.ES-1001-2-1-WW)
Recovery Operations,including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1) and one associated chilled water condenser(ID
No. CD-1001-1-3) venting to one packed tower scrubber(ID No. CD-1001-2-S-1);
• One chilled water condenser (ID No. CD-1001-1-T513) venting to packed tower scrubber (ID No.
CD-1001-2-S-1)controlling emissions from:
o Stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2); and
o Seven fixed roof process tanks of various capacities and one fixed roof methanol storage tank
(ID No. ES-1001-1-1-P3);
• Process equipment leaks (ID No.ES-1001-1-1-F); and
• Recovery Operations wastewater stream(ID No. ES-1001-1-1-WW)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Best Available Control Technology
See Sections 2.2 B.1 and 2.2 B.2 15A NCAC 2D .0530
Excluding two solvent recycle process tanks
Volatile organic (11)Nos.ES-M-125A and M-12513)
compounds Compliance Assurance Monitoring 15A NCAC 2D .0614
Rotocel and Recovery Operations only
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Hazardous Air Pollutants Maximum Achievable Control Technology 15A NCAC 2D .1111
See Section 2.2 C.1 (40 CFR Part 63, Subpart FFFF)
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See section 2.2 A.3

Permit 01819T45
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Regulated Pollutant Limits/Standards Applicable Regulation
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 AA 15A NCAC 2D .I 100
1. 15A NCAC 2D .0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the Rotocel Operations and the Recovery Operations the Permittee shall comply with 40 CFR Part 64
and 15A NCAC 2D .0614 and shall ensure that this source complies with the volatile organic compound
(VOC)emission limits of 15A NCAC 2D .0530 by complying with Section 2.1 C.1 of this permit.
Control Requirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the rotocel extractor, desolventizer, and solvent separation/recovery (ID No. ES-
1001-2-1-P), two solvent recycle process tanks (ID No. ES-M-125A and M-125B), arcon process tank
M-1 (ID No. ES-1001-1-1-P1), stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), and eight
process and storage tanks (ID No. ES-1001-1-1-P3) shall be controlled by the associated packed tower
scrubber (ID No. CD-1001-2-S-1), except as allowed pursuant to Sections 2.2 B.1.c and d, below. In
addition, the Permittee shall maintain a daily average mineral oil temperature at the inlet of the packed
scrubber(ID No. CD-1001-2-S-1)of less than or equal to 100 degrees Fahrenheit(100 °F)whenever the
associated sources are operational.
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 C.l.c.i
through iii, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 C.l.c.i through iii,below,are not performed.
i. The Permittee shall monitor the inlet mineral oil temperature of mineral oil packed tower scrubber
(ID No. CD-1001-2-S-1) at least once each day that the sources listed in Section 2.1 C.1.b, above,
operate;
ii. The Permittee shall inspect, maintain, and operate mineral oil packed tower scrubber(ID No. CD-
1001-2-S-1)in accordance with Section 2.2 B.1.i,below; and
iii. The Permittee shall install, maintain, operate, and calibrate the temperature gauge associated with
mineral oil packed tower scrubber (ID No. CD-1001-2-S-1) in accordance with Section 2.2 B.l.j,
below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if mineral oil packed tower scrubber(ID No. CD-1001-2-S-1)
operates under conditions qualifying as an excursion for more than 5 percent of the operational time of
the sources listed in Section 2.1 C.l.b, above, during a consecutive 6-month period, then the Permittee
shall develop a Quality Improvement Plan(Q1P)in accordance with 40 CFR§64.8.
For the purposes of this permit condition excursions are defined as operation of mineral oil packed tower
scrubber (ID No. CD-1001-2-S-1) with an inlet mineral oil temperature that exceeds the limit cited in
Section 2.1 C.Lb,above,while the associated emission sources are operating,except as allowed pursuant
to Sections 2.2 B.l.c and d,below.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections, maintenance and calibrations conducted pursuant to Sections 2.1
C.l.c and d, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring,noting any excursions along with any actions taken to correct the inlet
mineral oil temperature of packed tower scrubber(ID No. CD-1001-2-S-1);

Permit 01819T45
Page 15
iii. The results of any inspections or maintenance performed on mineral oil packed tower scrubber(ID
No. CD-1001-2-5-1) or the associated temperature and flow rate gauges; and
iv. Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked
or delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December,and July 30 of each calendar year for the preceding six-month period between January
and June.All instances of deviations from the requirements of this permit must be clearly identified.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001,desolventizer Z-1002,day tank 90024,first-stage evaporator EX-1012,
second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks of various
capacities (ID No. ES-1001-11-1-P) and one associated chilled water condenser (ID No. CD-1001-
11-EX1002)venting to one cryogenic (nitrogen) condenser system (ID No. CD-1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagfilter(ID No.CD-1003-4-1);
• Process equipment leaks (ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream(ID No.ES-1001-11-WW)
Biomass Extraction Operations, including:
• Biomass extraction debagging (ID No. ES-1004-1) and one associated cartridge filter (ID No. CD-
1004-1-FFl);
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, iso-hexane storage tank
490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation column
EX-490008 and nine process tanks of various capacities (ID No. ES-1004-2-P) and one associated
chilled water condenser(ID No. CD-1004-2EX1002)venting to one cryogenic(nitrogen)condenser
system(ID No. CD-1004-2EX1003);
• Process equipment leaks (ID No.ES-1004-2-F);
• Wastewater tanks and other similar vessels(ID No.ES-1004-2-WW);
• Biomass extraction operations wastewater stream (ID No.ES-1003-10-WW);
• Biomass silo loadout(ID No. ES-1004-2Silo) and one associated bagfilter(ID No.CD-1004-2-FF2);
and
• Molecular sieve(ID No.ES-MSDU-1024)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Pollutant Limits/Standards Applicable Regulation
Plant material grinder,biomass extraction
debagging, and biomass silo loadout:
Particulate matter E=4.1 OP" 15A NCAC 2D .0515
Where:E=allowable emission rate in pounds
per hour
P=process weight in tons per hour
Visible emissions 20 percent opacity 15A NCAC 2D .0521(d)
Best Available Control Technology 15A NCAC 2D .0530
Volatile organic See Sections 2.2 B.1 and 2.2 B.2
compounds
Compliance Assurance Monitoring 15A NCAC 2D .0614

Permit 01819T45
Page 16
Regulated Pollutant Limits/Standards Applicable Regulation
Work practice standards 15A NCAC 2D .0958
See Section 2.2 A.1
Odorous emissions State-Enforceable Only 15A NCAC 2D .1806
See Section 2.2 A.3
Hazardous Air Maximum Achievable Control Technology 15A NCAC 2D .I I I I
Pollutants See Section 2.2 C.1 (40 CFR Part 63, Subpart FFFF)
Toxic Air Pollutants State-Enforceable Only 15A NCAC 2Q .0705/.0711
See Sections 2.2 A.2 and 2.2 A.4 15A NCAC 2D .I 100
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the plant material grinder (ID No. MHZ-1002), the biomass
extraction debagging operation (ID No. ES-1004-1), and the biomass silo loadout (ID No. ES-1004-2-
Silo) shall not exceed an allowable emission rate as calculated by the following equation: [15A NCAC
2D .0515(a)]
E=4.10xP0`
Where: E=allowable emission rate in pounds per hour; and
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 D.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the plant material grinder,the biomass extraction debagging operation,
and the biomass storage silo shall be controlled by a bagfilter (ID No. CD-1003-4-1), a cartridge filter
(ID No.CD-1004-1-FF1),and a bagfilter(ID No.CD-1004-2-FF2),respectively.To assure compliance,
the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In
addition to the manufacturer's inspection and maintenance recommendations, or if there is no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection and
maintenance requirement shall include the following:
i. A monthly visual inspection of the system ductwork and material collection unit for leaks; and
ii An annual (for each 12-month period following the initial inspection) internal inspection of the
cartridge filter and bagfilters for structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, cartridge
filter, and bagfilters are not inspected and maintained.
d. The results of inspections and maintenance shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall record the
following:
i. The date and time of each recorded action;
ii. The results of each inspection;
ii. The results of any maintenance performed on the cartridge filter and bagfilters; and
iv. Variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not
maintained.

Pernut 0 18 19T45
Page 17
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit the results of any maintenance performed on the cartridge filter or bagfilters
within 30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
delivered on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the botanical extraction operations and the biomass extraction operations shall not
be more than 20 percent opacity when averaged over a six-minute period.However,six-minute averaging
periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-
hour period.In no event shall the six-minute average exceed 87 percent opacity.[I 5A NCAC 2D.0521(d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 D.2.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring[15A NCAC 2Q .0508(f)]
c. To assure compliance, once a month the Permittee shall observe the emission points of these sources for
any visible emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. If practicable, the monthly observation
must be made while the associated source is operating. If a source does not operate during a monthly
period, then a record documenting such non-operational status will satisfy this monitoring requirement
for that source. If visible emissions from a source are observed to be above normal, the Permittee shall
either:
i. Take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or
ii. Demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2610 (Method 9) for 12 minutes is below the limit given in Section 2.1 D.2.a,
above.
If the above-normal emissions are not corrected per (i) above or if the demonstration in (ii) above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping[15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request.The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. The results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting[15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.

Permit 01819T45
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3. 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING
Applicability [15A NCAC 2D .0614 and 40 CFR§64.2]
a. For the immersion extractor(ID No. Z-1001), desolventizer(ID No. Z-1002), day tank(ID No. 90024),
first-stage evaporator(ID No.EX-1012), second stage evaporator(ID No.EX-1013),distillation column
(ID No. EX-90008) and nine process tanks (ID No. ES-1001-11-1-P) and the immersion extractor(ID
No. Z-41001), desolventizer (ID No. Z-41002), day tank (ID No. 490025), isohexane storage tank (ID
No. 490024), first-stage evaporator (ID No. EX-41012), second stage evaporator (ID No. EX-41013),
distillation column(ID No. EX-490008) and nine process tanks of various capacities (ID No. ES-1004-
2-P),the Permittee shall comply with 40 CFR Part 64 and 15A NCAC 2D .0614 and shall ensure that this
source complies with the volatile organic compound (VOC) emission limits of 15A NCAC 2D .0530 by
complying with Section 2.1 D.3 of this permit.
Control Repuirements/Parameter ranges [15A NCAC 2Q .0508(f)]
b. VOC emissions from the subject botanical extraction operations sources (ID No. ES-1001-11-1-P) shall
be controlled by the associated cryogenic condenser system (ID No. CD-1001-11-EX1003). VOC
emissions from the subject biomass extraction operations sources (ID No. ES-1004-2-P) shall be
controlled by the associated cryogenic condenser system(ID No.CD-1004-2EX1003). In addition:
i. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to 40 degrees
Fahrenheit below zero (40 °F) for cryogenic condenser system CD-1001-11-EX1003 whenever the
associated sources are operational when using non-water soluble solvents.The 12-hour average outlet
temperature must be maintained at less than or equal to 17 degrees Fahrenheit (17 °F) when using
water soluble solvents; and
ii. The Permittee shall maintain a 12-hour average outlet temperature of less than or equal to -40 °F for
cryogenic condenser system (ID No. CD-1004-2EX1003) whenever the associated sources are
operational when using non-water soluble solvents. The 12-hour average outlet temperature must be
maintained at less than or equal to 17 degrees Fahrenheit(17°F) when using water-soluble solvents
Monitoring [15A NCAC 2Q .0508(f)]
c. For VOC emissions: The Permittee shall perform the monitoring requirements of Sections 2.1 D.3.c.i
through iv, below. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if the
monitoring and recordkeeping requirements of Sections 2.1 D.3.c.i through iv,below,are not performed.
i. The Permittee shall monitor the outlet temperature of cryogenic condenser system(ID No.CD-1001-
1 1-EX1 003) at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour,when the associated sources listed in Section 2.1 D.3.b,above,
operate;
ii. The Permittee shall monitor the outlet temperature of cryogenic condenser system(ID No.CD-1004-
2EX1003) at least once each hour, and calculate the average outlet temperature for the consecutive
12-hour period ending with that hour,when the associated sources listed in Section 2.1 D.3.b,above,
operate; and
iii. The Permittee shall inspect, maintain, and operate cryogenic condenser systems (ID Nos. CD-1001-
11-EX1003 and CD-1004-2EX1003) in accordance with Section 2.2 B.Lg,below; and
iv. The Permittee shall install, maintain, operate, and calibrate the temperature sensors associated with
cryogenic condenser systems(ID Nos.CD-1001-11-EX1003 and CD-1004-2EX1003)in accordance
with Section 2.2 B.1.h,below.
d. For excursions: In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. Further, if cryogenic condenser system (ID No. CD-1001-11-EX1003
or CD-1004-2EX1003) operate under conditions qualifying as an excursion for more than 5 percent of
the operational time of their associated sources listed in Section 2.1 D.3.b,above,during a consecutive 6-
month period, then the Permittee shall develop a Quality Improvement Plan (QIP) for that cryogenic
condenser system in accordance with 40 CFR§64.8. For the purposes of this permit condition excursions

Permit 01819T45
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are defined as operation of cryogenic condenser system (ID No. CD-1001-11-EX1003 or CD-1004-
2EX1003) with a 12-hour average outlet temperature that exceeds the associated limit cited in Sections
2.1 D.3.b.i and ii, above,while the associated emission sources are operating.
Recordkeeping [15A NCAC 2Q .0508(f)]
e. The results of monitoring, inspections, maintenance and calibrations conducted pursuant to Sections 2.1
D.3.c and d, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each recorded action;
ii. The results of the monitoring,noting any excursions along with any actions taken to correct the outlet
temperature of cryogenic condenser system(ID No. CD-1001-11-EX1003 or CD-1004-2EX1003);
iii. The results of any inspections or maintenance performed on cryogenic condenser system(ID No.CD-
1001-11-EX1003), cryogenic condenser system (ID No. CD-1004-2EX1003), or the associated
temperature gauges; and
iv. Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0614 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked
or delivered on or before January 30 of each calendar year for the preceding six-month period between
July and December,and July 30 of each calendar year for the preceding six-month period between January
and June. All instances of deviations from the requirements of this permit must be clearly identified.
E. Two biomass boilers(ID Nos.ES-13131 and ES-13132)and an associated propane/No.2 fuel oil-fired
rotary dryer (ID No. ES-RD) operated in series controlled by a cyclone (ID No. CD-BBIC) in
series with a bagfilter(ID No. CD-1313113H)
The following table provides a summary of limits and standards for the emission source(s)described above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Particulate Boilers(ID Nos. ES-13131 and 13132): 15A NCAC 2D .0503
matter 0.33 pounds per million Btu heat input
Particulate Rotary dryer(ID No.ES-RD): 15A NCAC 213 .0515
matter E=4.10(P)0.67
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible 20 percent opacity when averaged over a six-minute 15A NCAC 2D .0521
emissions period
N/A Initial notification requirements, 15A NCAC 2D .0524
Notification of boiler size and fuel combusted,and (40 CFR Part 60,Subpart Dc)
Record and maintain amount of each fuel combusted
during each calendar month.
PM,HCI,CO, Boilers(ID Nos.ES-13131 and 13132): 15A NCAC 2Q .I I I I MACT
Hg, Emission limits as specified in 40 CFR Part 63, (40 CFR Part 63, Subpart DDDDD)
Dioxins/Furans Subpart DDDDD
Volatile Emissions of VOCs shall be less than 40 tons per 15A NCAC 2Q .0317
Organic consecutive 12-month period (Avoidance of 15A NCAC 2D .0530)
Compounds See Section 2.2 D
Hazardous Air Rotary Dryer(ID No.ES-RD): 15A NCAC 2Q .0317
Pollutants n-hexane emissions shall be less than 10 tons per year (Avoidance of 15A NCAC 2D.1112)
See Section 2.2.E

Permit 01819T45
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1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of sage or wood that are discharged from the
boilers(ID Nos. ES-BB1 and BB2) into the atmosphere shall not exceed 0.33 pounds per million Btu
heat input. [15A NCAC 2D .0503(a)]
Testing [15A NCAC 2Q .0508(o]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.1.a.above,the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0503.
Monitoring [15A NCAC 2Q .0508(f)]
c. Particulate matter emissions from the boilers (ID Nos. ES-BB1 and ES-BB2) shall be controlled by a
cyclone (ID No. CD-BBIQ in series with a bagfilter(ID No. CD-BB1BH). To assure compliance, the
Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition
to the manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's
inspection and maintenance recommendations, as a minimum, the inspection and maintenance
requirement shall include the following:
i. monthly external inspection of the ductwork, cyclone, and bagfilter noting the structural integrity;
and
ii. an annual internal inspection of the bagfilter's structural integrity.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if the cyclone,bagfilter,
and ductwork is not inspected and maintained.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic
format)on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. a report of any maintenance performed on the cyclone and bagfilter; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0503 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. Within 30 days of a written request from the DAQ,the Permittee shall submit a report of any
maintenance performed on the cyclone and bagfilter.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on
or before January 30 of each calendar year for the preceding six-month period between July and December
and July 30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
2. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES
a. Emissions of particulate matter from the rotary dryer(ID No. ES-RD) shall not exceed an allowable
emission rate as calculated by the following equation: [15A NCAC 2D .0515(a)]
E=4.10 x P°_61 Where, E=allowable emission rate in pounds per hour
P=process weight in tons per hour
Liquid and gaseous fuels and combustion air are not considered as part of the process weight.

Permit 01819T45
Page 21
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.2.a.above,the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0515.
Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)]
c. The Permittee shall maintain production records such that the process rates "P" in tons per hour,as
specified by the formulas contained above(or the formulas contained in 15A NCAC 2D .0515)can be
derived, and shall make these records available to a DAQ authorized representative upon request. The
Permittee shall be deemed in noncompliance with 15A NCAC 21) .0515 if the production records are
not maintained or the types of materials and finishes are not monitored.
3. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 E.3.a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 213 .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of wood or sage in
this source.
4. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boilers and rotary dryer(ID Nos. ES-BB1,ES-BB2, and ES-RD) shall not
be more than 20 percent opacity when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. [15A
NCAC 213 .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 EA.a. above,the Permittee shall be
deemed in noncompliance with 15A NCAC 21) .0521.
For boilers(ID Nos. ES-BBI and ES-BB2)
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance,once a day the Permittee shall observe the emission points of the boilers (ID Nos.
ES-BBI and ES-BB2)for any visible emissions above normal. The daily observation must be made for
each day of the calendar year period to ensure compliance with this requirement.The Permittee shall be
allowed three(3)days of absent observations per semi-annual period. The Permittee shall establish
"normal"for the boilers in the first 30 days following the effective date of the permit. If visible
emissions from this source are observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and within the
monitoring period and record the action taken as provided in the recordkeeping requirements below,
or

Permit 01819T45
Page 22
ii. demonstrate that the percent opacity from the emission points of the emission source in accordance
with 15A NCAC 2D .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 EA.a.
above.
If the above-normal emissions are not corrected per(i)above or if the demonstration in(ii)above
cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0521.
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were observed to
be in noncompliance along with any corrective actions taken to reduce visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not
maintained.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July 30 of each
calendar year for the preceding six-month period between January and June. All instances of deviations
from the requirements of this permit must be clearly identified.
For Rotary Dryer(ID No. ES-RD):
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
f. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil
in the rotary dryer(ID No.ES-RD).
5. 15A NCAC 2D.0524: NSPS 40 CFR PART 60 SUBPART Dc
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) as promulgated in 40 CFR
Part 60 Subpart Dc,including Subpart A"General Provisions."[15A NCAC 2D .0524]
b. NSPS REQUIREMENTS-In addition to any other required by 40 CFR 60.48c or notification
requirements to the EPA,the Permittee is required to NOTIFY the DAQ in writing of the following:
i. the date construction(40 CFR 60.7)or reconstruction(40 CFR 60.15) of an affected facility is
commenced,postmarked no later than 30 days after such date, and
ii. the date of actual initial start-up postmarked within 15 days of the actual date.
Recordkeeping[15A NCAC 2Q .0508(f)]
c. In addition to any other recordkeeping required by 40 CFR 60.48c or recordkeeping requirements of the
EPA,the Permittee shall record and maintain records of the amounts of each fuel fired during each day.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these records are not
maintained.

Permit 01819T45
Page 23
6. 15A NCAC 2D .1111 National Emission Standard for Hazardous Air Pollutants,40 CFR Part 63,
Subpart DDDDD—Boiler and Process Heaters
a. Two biomass boilers(ID Nos.ES-BB1 and ES-11112)are subject to 40 CFR Part 63, Subpart DDDDD.
F. Four Emergency Generators and Fire Water Pump (ID Nos. E101, E102, E103,E104, and FP)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Limits/Standards Applicable Regulation
Pollutant
Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 2D .0516
Visible emissions 20 percent opacity 15A NCAC 2D .0521
N/A N/A 15A NCAC 2D .1111
(40 CFR Part 63, Subpart ZZZZ)
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES
a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input.
Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be
included when determining compliance with this standard.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 F.La.above,the Permittee shall be deemed
in noncompliance with 15A NCAC 2D .0516.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/is required for sulfur dioxide emissions from the firing of No. 2 fuel oil in
these sources.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-
minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any
hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed
87 percent opacity. [15A NCAC 2D .0521 (d)]
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 F. 2.a. above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0521.
Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)]
c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil
in these sources.
3. 15A NCAC 2D.1111 140 CFR Part 63 Subpart ZZZZJ:
NESHAP for Stationary Reciprocating Internal Combustion Engines
a. The Permittee shall comply with all applicable provisions contained in Environmental Management
Commission Standard 15A NCAC 2D .1111, "Maximum Achievable Control Technology"as
promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants
for Stationary Reciprocating Internal Combustion Engines,"by December 13, 2004.

Permit 01819T45
Page 24
Monitoring/Recordkeepinp,/Reporting [15A NCAC 2Q .0508(f)]
b. No monitoring/recordkeeping/reporting requirements.
G.Sclareol Recrystallization (SFG) Operations, including:
• One process tank (ID No. T-3001)*
• Four process tanks (ID Nos. T-3002 through 3005)"
• One storage tank (ID No. T-3006)"
• One process tank(ID No. T-3007)*
• Two centrifuges (ID Nos. C-3001 and C-3002)*
• One reactor equipped with a process chilled water condenser (EX-3001) with control
chilled water condenser (ID No. CD-3001)"
• One reactor equipped with a process chilled water condenser (EX-3003)(ID No. R-3002)*
• One reactor equipped with a process chilled water condenser (EX-3004) (ID No. R-3003)`
• One reactor equipped with a process chilled water condenser (EX-3005) (ID No. R-3004)*
• One steam heated dryer equipped with a process chilled water condenser (EX-3002) (ID
No. D-3001) with control chilled water condenser (ID No. CD-3001)"
• One steam heated dryer equipped with a process chilled water condenser (EX-3006) (ID
No. D-3002) with control chilled water condenser (ID No. CD-3002)*
• Process equipment leaks (ID No. ES-1003-10-F)
• SFG Operations wastewater stream (ID No. ES-1003-10-WW)
* These emission sources may be controlled with a chilled water condenser(ID No.CD-3003)in series with a mineral
oil scrubber (ID No. CD-3004-S). These control devices are optional controls. The Permittee has the option to
construct or not construct these devices and has the option to operate or not operate these devices.
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to comply with Best Available Control Technology(BACT),the SFG operations shall discharge
no more than 217.4 tons volatile organic compounds per consecutive twelve month period.
Testing [15A NCAC 2Q .0508(f)]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.1 G.l.a, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]
c. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions shall
be determined by multiplying the total amount of each type of VOC-containing material consumed during
the month by the VOC content of the material.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format).
e. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of VOC
containing materials or the VOC emissions are not monitored and recorded as specified in Sections
2.1.G.1. c and d or if the VOC emissions exceed the limit in Section 2.1. G.La.

Permit 01819T45
Page 25
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a semi-annual report of the monitoring and recordkeeping activities
postmarked on or before January 30 of each calendar year for the preceding six-month period between
July and December and July 30 of each calendar year for the preceding six-month period between January
and June. The report shall contain the following:
i. the monthly volatile organic compound emissions for each of the previous 17 months; and
iii. the yearly volatile organic compound emissions for each consecutive 12-month period ending on
each month of the previous six-month period.

Permit 01819T45
Page 26
2.2 - Multiple Emission Source(s) Specific Limitations and Conditions
A. Facility-Wide Affected Sources [all permitted sources except for limited use emergency
generator ES-PkGenl and boilers H-101, H-102, and H-1031
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Work practice standards 15A NCAC 2D .0958
State-Enforceable Only
Toxic Air Pollutants Air Toxics evaluation for non-NESHAP 15A NCAC 21) .1100
emission sources
Odorous emissions State-Enforceable Only 15A NCAC 21) .1806
Odorous emissions must be controlled
1. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. Pursuant to 15A NCAC 2D.0958,for all sources that use volatile organic compounds(VOC)as solvents,
carriers,material processing media, or industrial chemical reactants, or in similar uses that mix,blend, or
manufacture volatile organic compounds, or emit volatile organic compounds as a product of chemical
reactions,the Permittee shall:
i. Store all material, including waste material, containing volatile organic compounds in tanks or in
containers covered with a tightly fitting lid that is free of cracks, holes, or other defects,when not in
use,
ii. Clean up spills of volatile organic compounds as soon as possible following proper safety procedures,
iii. Store wipe rags containing volatile organic compounds in closed containers,
iv. Not clean sponges, fabric,wood,paper products, and other absorbent materials with volatile organic
compounds,
v. Transfer solvents containing volatile organic compounds used to clean supply lines and other coating
equipment into closable containers and close such containers immediately after each use, or transfer
such solvents to closed tanks,or to a treatment facility regulated under section 402 of the Clean Water
Act,
vi. Clean mixing, blending, and manufacturing vats and containers containing volatile organic
compounds by adding cleaning solvent and close the vat or container before agitating the cleaning
solvent. The spent cleaning solvent shall then be transferred into a closed container, a closed tank or
a treatment facility regulated under section 402 of the Clean Water Act. [15A NCAC 2D .0958(c)]
b. When cleaning parts with a solvent containing a volatile organic compound,the Permittee shall:
i Flush parts in the freeboard area,
ii. Take precautions to reduce the pooling of solvent on and in the parts,
iii. Tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all dripping
has stopped,whichever is longer,
iv. Not fill cleaning machines above the fill line,
v. Not agitate solvent to the point of causing splashing. [15A NCAC 2D .0958(d)]
Monitoring [15A NCAC 2Q .0508(f)]
c. To assure compliance with paragraphs (a) and (b) above, the Permittee shall, at a minimum, perform a
visual inspection once per month of all operations and processes utilizing volatile organic compounds.
The inspections shall be conducted during normal operations.If the required inspections are not conducted
the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D .0958.

Permit 01819T45
Page 27
Recordkeeping [15A NCAC 2Q .0508(f)]
d. The results of the inspections shall be maintained in a logbook(written or electronic format) on-site and
made available to an authorized representative upon request. The logbook shall record the following:
i. The date and time of each inspection; and
ii. The results of each inspection noting whether or not noncompliant conditions were observed.
If the required records are not maintained the Permittee shall be deemed to be in noncompliance with rule
15A NCAC 2D .0958.
Reporting [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a summary report of the observations postmarked or delivered on or before
January 30 of each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All instances of
deviations from the requirements of this permit must be clearly identified.
STATE-ENFORCEABLE ONLY
2. 15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. 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.
STATE-ENFORCEABLE ONLY
3. 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS
a. For any non-NESHAP source,any increase in toxic air pollutants must be evaluated.
B. Three No. 2 fuel oil-fired boilers, as described in Section 2.1 A, above;
Rotocel Operations, as described in Section 2.1 C, above;
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D, above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No.WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s)describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Volatile organic compounds Best Available Control Technology 15A NCAC 2D .0530
(VOC)
1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. The following Best Available Control Technology(BACT)limits shall not be exceeded:
Emission Source Pollutant BACT Emission Limits Control Technology
Rotocel extractor, 47.31 tons per Condenser CD-31209
desolventizer,and solvent 10.8 pounds consecutive
VOC and packed tower
separation/recovery per hour 12-month
(ID No. ES-1001-2-1-P1) period scrubber CD-1001-2-5-1
Rotocel equipment leaks VOC N/A Leak detection and
(ID No. ES-1001-2-1-F) (Fugitive) repair(LDAR)
Rotocel wastewater stream Fixed roofs on
(ID No. ES-1001-2-1-WW) VOC N/A wastewater treatment
tanks

Permit 01819T45
Page 28
Emission Source Pollutant BACT Emission Limits Control Technology
When Rotocel is Operating: Condenser CD-1001-1-3
0.80 pounds per hour and 3.50 and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery arcon tank M-1 When Rotocel is NOT Condenser CD-1001-1-3
(ID No. ES-1001-1-1-P1) VOC Operating and Recovery
Process is processing
Concrete:
8.76 pounds per hour and 0.63
tons per consecutive 12-month
period
When Rotocel is Operating: Condenser CD-1001-1-
0.85 pounds per hour and 3.72 T5B and packed tower
tons per consecutive 12-month scrubber CD-1001-2-5-1
period
Recovery stripper T-5 and When Rotocel is NOT Condenser CD-1001-1-
receiver M-21 VOC Operating and Recovery T5B
(ID No. ES-1 001-1-1-P2)
Process is processing
Concrete:
4.89 pounds per hour and 1.99
tons per consecutive 12-month
period
Recovery process/storage
tanks VOC N/A Fixed roofs
(ID No.ES-1001-1-1-P3)
Recovery equipment leaks VOC N/A MAR
(ID No.ES-1001-1-1-F) (Fugitive)
95%mass removal from Fixed roofs on
Recovery wastewater stream VOC wastewater stream consisting Wastewater treatment
(ID No.ES-1001-1-1-WW) of methanol-wash tanks and biological
treatment
Botanical extraction
immersion extractor, 61.76 tons per
desolventizer,first and Condenser CD-1001-11-
second stage evaporators, VOC 14.1 pounds consecutive EX1002 and condenser
distillation column, day tank, per hour period
CD-1001-11-EX1003
and multiple process tanks period
(ID No. ES-1001-11-P)
Botanical extraction
equipment leaks (ID No. ES- VOC N/A MAR
1001-11-F) (Fugitive)
Botanical extraction Fixed roofs on
wastewater stream(ID No. VOC N/A wastewater treatment
ES-1001-11-WW) I I I tanks

Permit 01819T45
Page 29
Emission Source Pollutant BACT Emission Limits Control Technology
Biomass extraction
immersion extractor,
desolventizer, day tank,
isohexane storage tank, first 61.8 tons per Condenser CD-1004-
and second stage VOCs 14.1 pounds consecutive 2EX 1002 and condenser
evaporators,distillation per hour period
CD-1004-2EX1003
column,and multiple process period
tanks
(ID No. ES-1004-2-P)
Biomass extraction
equipment leaks (ID No. ES- VOCs N/A LDAR
1004-2-F)
Biomass extraction Fixed roofs on
wastewater stream(ID No. VOCs N/A wastewater treatment
ES-1004-2-WW) tanks
No. 2 fuel-oil fired boilers
(ID Nos. H-101,H-102,H- VOC 0.2 pounds per 1,000 gallons Combustion control
103)
Testing [15A NCAC 2Q .0508(o]
b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ.
If the results of this test are above the limit given in Section 2.2 B.La, above, the Permittee shall be
deemed in noncompliance with 15A NCAC 2D .0530.
Monitoring [15A NCAC 2Q .0508(f)]
c. The Permittee shall limit the operation of the recovery stripper T-5 and receiver M-21 (ID No.ES-1001-
1-1-P2) while source (ID No. ES-1001-2-1-P1) is not operating to no greater than 34 days in any
consecutive 12-month period.
d. The Permittee shall limit the total number of days during which the liquid flow into the recovery arcon
tank M-1 (ID No. ES-1001-1-1-P1) exceeds the liquid flow out of the arcon tank (i.e., days when the
liquid level in the tank rises)while source(ID No. ES-1001-2-1-P1) is not operating to no greater than 6
days in any consecutive 12-month period.
e. The Permittee shall implement the leak detection and repair(LDAR)program of 40 CFR Part 63, Subpart
LTU, as per the requirements Section 2.2 B.2, below. The Permittee shall be deemed in noncompliance
with 15A NCAC 2D .0530, if the MAR program requirements are not implemented.
f. The Permittee shall determine once a week, the mass removal efficiency of the on-site biological
wastewater treatment plant(i.e.Wastewater Treatment Plant Aeration Tank No. 1;ID No.WWTP-AT1)
for volatile organic compounds (VOC), when the wastewater stream consisting of methanol-wash from
the recovery operations (ID No.ES-1001-1-1-WW) is discharged to it.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the mass removal
efficiency of the on-site biological wastewater treatment plant (ID No. WWTP-AT1) for VOC is not
determined every week or if the mass removal efficiency is less than 95%.
g. Volatile organic compound(VOC)emissions from the emission sources listed in Section 2.2 B.La,above,
shall be controlled by the associated condensers. To assure compliance, the Permittee shall perform
periodic inspections and maintenance as recommended by the equipment manufacturer. In addition, the
Permittee shall perform an annual inspection of each condenser system, including the following:
i. The Permittee shall inspect and maintain the structural integrity of each condenser, including
inspection for leakage of coolant and, if the system is under positive gauge pressure, leakage of the

Permit 01819T45
Page 30
contaminated gas stream.In order to monitor leakage of the coolant,the condensate shall be inspected
for the presence of coolant; and
ii. The Permittee shall inspect and maintain the structural integrity of ductwork and piping leading to
and coming from each condenser.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the condensers are not
inspected and maintained.
h. To assure compliance, the Permittee shall install, maintain, operate, and calibrate, in accordance with
manufacturer's recommendations, a sensor to continuously measure the outlet temperature of each
condenser listed in Section 2.2 B.1.a, above. Each sensor shall be installed in an accessible location and
shall be maintained by the Permittee such that it is in proper working order at all times. The temperatures
output from the sensors shall be continuously monitored and hourly values used to determine the 24-hour
average temperature at the condenser outlets. The Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0530 if the outlet temperatures of the condensers are not maintained below the limits in the
table below; or the condensers are not equipped with sensors to continuously measure the outlet
temperatures; or if those sensors are not inspected and maintained.
Emission Source Condenser ID No. Required Outlet Temperature
Recovery arcon tank M-1 CD-1001-1-3 45 OF, 24-hour average,when
(ID No. ES-1001-1-1-P1) source ES-1001-2-1-P1 is not
Recovery stripper T-5 and operating and the tanks are used
receiver M-21 (ID No.ES-1001- CD-1001-1-T5B for concrete processing in the
1-1-P2) recovery operation
-40°F, 24-hour average for non
Botanical extraction operations CD-1001-11-EX1003 Water soluble solvents,and
(ID No.ES-1001-11-P) 17°F, 24-hour average for water
soluble solvents
-40°F, 24-hour average for non
Biomass extraction operations water soluble solvents,and
(ID No. ES-1004-2-P) CD-1004-2EX1003 17°F, 24-hour average for water
soluble solvents
i. Volatile organic compound(VOC)emissions from the emission sources listed in Section 2.2 B.La,above,
shall also be controlled by the associated packed tower scrubber (ID No. CD-1001-2-S-1), except as
allowed pursuant to Sections 2.2 B.1.c and d, above. To assure compliance, the Permittee shall perform
periodic inspections and maintenance as recommended by the equipment manufacturer. In addition to the
manufacturer's inspection and maintenance recommendations, or if there is no manufacturer's inspection
and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall
include the following:
i. An annual inspection of spray nozzles and packing materials, chemical feed system(if so equipped),
and perform maintenance and repair when necessary to assure proper operation of the packed tower
scrubber; and
ii. An annual inspection, cleaning, and calibration of all associated instrumentation.
iii. Additionally, whenever the packing is replaced, the Permittee shall inspect for nozzle plugging and
settling of the packing.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530 if the packed tower scrubber
is not inspected and maintained.
j. The Permittee shall install, maintain, operate, and calibrate a scrubbing liquid flow meter, a scrubbing
liquid inlet temperature sensor,and an emission stream inlet temperature sensor for packed tower scrubber
CD-1001-2-S-1 in accordance with manufacturer's recommendations. The Permittee shall be deemed in

Permit 01819T45
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noncompliance with 15A NCAC 2D .0530 if the flow meter and temperature sensors are not installed,
maintained, and calibrated,or if,except as allowed pursuant to Sections 2.2 B.Lc and d, above:
i. The scrubbing liquid injection rate is not maintained at or above eight gallons per minute;
ii. The scrubbing liquid inlet temperature exceeds 105 °F;
iii. The emission stream inlet temperature exceeds 90 °F; or
iv. The flow meter and temperature sensors are not operated.
Recordkeeping [15A NCAC 2Q .0508(f)]
k. The Permittee shall maintain the following records:
i. VOC emissions for each calendar month,and for the consecutive 12-month period ending with each
calendar month, from the following sources:
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-PI is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3)when source ES-1001-2-1-PI is not operating and the recovery process is
processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations (ID No.ES-1004-2-P).
ii. Results of any inspections, maintenance, and monitoring conducted pursuant to Sections 2.2 B.l.c
through j, above, shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request.The logbook shall be updated at least monthly
and record the following:
(A)The date and time of each recorded action;
(B) The actual hours of operation of the recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), and
recovery stripper T-5 and receiver M-21 (ID No. ES-1001-1-1-P2), when source ES-1001-2-1-
P1 is not operating;
(C) The actual hours of operation of recovery arcon tank M-1 (ID No. ES-1001-1-1-P1), when the
liquid flow into the arcon tank exceeds the liquid flow out of recovery arcon tank M-1 and source
(ID No. ES-1001-2-1-P1)is not operating;
(D)The mass removal efficiency of the on-site biological wastewater treatment plant (ID No.
WWTP-AT1) for VOC calculated once a week at a minimum when the wastewater stream
consisting of methanol-wash from the recovery operation (ID No. ES-1001-1-1-WW) is
discharged to it;
(E) The 24-hour average outlet temperature of the associated condenser(s)listed in Section 2.2 B.1.h,
above:
(1) When source (ID No. ES-1001-2-1-P1) is not operating and the Concrete Operations tanks
(ID No. ES-1001-1-2-P)are used for concrete processing in the recovery operation; and/or
(2) When the biomass extraction operations(ID No. ES-1004-2-P)is operating.
(F) The scrubbing liquid injection rate, scrubbing liquid inlet temperature, and emission stream inlet
temperature of scrubber(ID No. CD-1001-2-5-1)at least once each day that source(ID No. ES-
1001-2-1-P1)operates;
(G)The results of maintenance performed on the condensers and scrubber listed in Section 2.2 B.La,
above, and the associated temperature sensors and flow rate gauges; and
(H)Any variance from manufacturer's recommendations, if any,and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not
maintained.
Reportinn [15A NCAC 2Q .0508(f)]
1. Within 30 days of a request from the DAQ, the Permittee shall submit a report of any maintenance
performed on the condensers and scrubber listed in Section 2.2 B.La, above.
in. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July

Permit 01819T45
Page 32
and December and July 30 of each calendar year for the preceding six-month period between January and
June. All instances of deviations from the requirements of this permit must be clearly identified. In
addition,the semiannual reports shall also contain the following:
i. The monthly VOC emissions from each of the following sources for each of the previous 17 months;
and
(A)Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3) when source(ID No.ES-1001-2-1-P1) is operating;
(B) Rotocel and recovery operations (ID Nos. ES-1001-2-1-P1, ES-1001-1-1-P1, ES-1001-1-1-P2,
and ES-1001-1-1-P3) when source (ID No. ES-1001-2-1-P1) is not operating and the recovery
process is processing concrete;
(C) Botanical extraction operations(ID No.ES-1001-11-P); and
(D)Biomass extraction operations (ID No.ES-1004-2-P).
ii. The cumulative total VOC emissions from each of the sources listed in Section 2.2 B.l.m.i, above,
for each of the consecutive 12-month periods ending during the reporting period.
2. Leak Detection and Repair
[15A NCAC 2D.0530: Prevention of Significant Deterioration]
Equipment identification [15A NCAC 2Q .0508(f)]
a. Affected process equipment shall be identified.Identification of the equipment does not require physical
tagging of the equipment.For example,the equipment may be identified on a plant site plan,in log entries,
by designation of process unit or affected facility boundaries by some form of weatherproof identification,
or by other appropriate methods. In addition to the above, the following equipment shall be specifically
identified:
i. Connectors that are:
(A)Buried, insulated in a manner that prevents access by a monitor probe,
(B) Obstructed by equipment or piping that prevents access by a monitoring probe,
(C) Unable to be reached by a lift up to 25 feet above ground level,
(D)Inaccessible because it would require elevating the monitoring personnel more than seven feet
above a permanent support surface or would require the erection of scaffolding, or
(E) Not able to be accessed in a safe manner to perform monitoring;
(Connectors need not be individually identified if all connectors in a designated area or length of pipe
are identified as a group,and the number of connectors subject is indicated.)
ii. Pressure relief devices that are equipped with rupture disk upstream of the pressure device;
iii. Valves,pumps, and connectors that are designated unsafe-to-monitor(i.e.,Permittee has determined
that monitoring personnel would be exposed to an immediate danger as a consequence of complying
with the monitoring requirements); and
iv. Valves that are difficult-to-monitor.(i.e.,Permittee has determined that the valve cannot be monitored
without elevating the monitoring personnel more than seven feet above a support surface or it is not
accessible in a safe manner when it is in regulated material service.
b. The Permittee shall record the identity of equipment designated as unsafe-to-monitor and/or difficult-to-
monitor and the planned schedule for monitoring this equipment. The Permittee shall include an
explanation why the equipment is unsafe or difficult-to-monitor.These records must be kept at the plant
and be available for review by an inspector.
i. The Permittee shall have a written plan that requires monitoring of the equipment as frequently as
practical during safe-to-monitor times,but not more frequently than the periodic monitoring schedule
otherwise applicable, and repair of the equipment if a leak is detected.
ii. The Permittee shall have a written plan that requires monitoring of difficult to monitor equipment at
least once per calendar year and repair of the equipment if a leak is detected.
c. Connectors that are designated as unsafe-to-repair will be repaired before the end of the next process unit
shutdown.The identity of connectors designated as unsafe-to-repair and an explanation why the connector
is unsafe-to-repair shall be recorded.

Permit 01819T45
Page 33
Instrument and sensory monitoring for leaks [I5A NCAC 2Q .0508(f)]
d. Instrument monitoring shall be conducted for
i. Valves in gas/vapor or light liquid service;
ii. Pumps in light liquid service;
iii. Connectors in gas/vapor or light liquid service; and
iv. Pressure relief devices in gas/vapor service.
e. Sensory monitoring for leaks shall be conducted for pumps in light liquid service. Sensory monitoring
consists of visual, audible, olfactory, or any other detection method used to determine a potential leak to
the atmosphere.
f. Instrument monitoring shall comply with the following requirements,
i. Monitoring shall comply with Method 21 of 40 CFR part 60, appendix A.
ii. The detection instrument shall meet the performance criteria of Method 21 of 40 CFR part 60,
appendix A, except the instrument response factor criteria in section 3.1.2, paragraph(a) of Method
21 shall be for the representative composition of the process fluid not each individual VOC in the
stream. For process streams that contain nitrogen, air, water or other inerts that are not VOC, the
representative stream response factor shall be determined on an inert-free basis. The response factor
may be determined at any concentration for which monitoring for leaks will be conducted. If there is
no instrument commercially available that will meet the performance criteria specified above, the
instrument readings may be adjusted by multiplying by the representative response factor of the
process fluid, calculated on an inert-free basis.
iii. The detection instrument shall be calibrated annually by the manufacturer by the procedures specified
in Method 21 of 40 CFR part 60,appendix A.
iv. Calibration gases shall be zero air(less than 10 parts per million of hydrocarbon in air); and the gases
shall be mixtures of methane in air at a concentration no more than 2,000 parts per million greater
than the leak definition concentration of the equipment monitored. If the monitoring instrument's
design allows for multiple calibration scales,then the lower scale shall be calibrated with a calibration
gas that is no higher than 2,000 parts per million above the concentration specified as a leak, and the
highest scale shall be calibrated with a calibration gas that is approximately equal to 10,000 parts per
million. A calibration gas other than methane in air may be used if the instrument does not respond
to methane or if the instrument does not meet the performance criteria specified Method 21 of 40 CFR
part 60, appendix A. In such cases, the calibration gas may be a mixture of one or more of the
compounds to be measured in air.
v. Monitoring shall be performed when the equipment is in VOC service.
g. The Permittee may elect to adjust or not to adjust the instrument readings for background.
i. If the Permittee elects not to adjust instrument readings for background, the Permittee shall monitor
the equipment according to the procedures specified above in Section 2.2 B.2.f of this permit,above.
In such cases, all instrument readings shall be compared directly to the applicable leak definition for
the monitored equipment to determine whether there is a leak or to determine compliance with
operational standards for pressure relief devices.
ii. If the Permittee elects to adjust instrument readings for background, the Permittee shall
(A)Monitor the equipment according to the procedures specified above in Section 2.2 B.2.f, above;
(B) Determine the background level using the procedures in Method 21 of 40 CFR part 60,appendix
A;
(C) Traverse the potential leak interfaces with the instrument probe as close to the interface as
possible as described in Method 21 of 40 CFR part 60,appendix A; and
(D)Compare the arithmetic difference between the maximum concentration indicated by the
instrument and the background level to the applicable leak definition for the monitored equipment
to determine whether there is a leak or to determine compliance operational standards for pressure
relief devices.
h. When a leak is detected:
i. A weatherproof and readily visible identification, shall be attached to the leaking equipment, and
ii. Leak repair records shall be made that include the following:

Permit 01819T45
Page 34
(A)The date of first attempt to repair the leak;
(B) The date of successful repair of the leak;
(C) The maximum instrument reading measured by Method 21 of 40 CFR part 60, appendix A at the
time the leak is successfully repaired or determined to be non-repairable;
(D)Dates of process unit shutdowns that occur while the equipment is unrepaired; and
(E) Any delay of repair and the reason for the delay if a leak is not repaired within 15 calendar days
after discovery of the leak.
(1) The Permittee may develop a written procedure that identifies the conditions that justify a
delay of repair.The written procedures may be included as part of the startup,shutdown,and
malfunction plan, or may be part of a separate document that is maintained at the plant site.
In such cases, reasons for delay of repair may be documented by citing the relevant sections
of the written procedure(i.e. season operation).
(2) If delay of repair was caused by depletion of stocked parts,there must be documentation that
the spare parts were sufficiently stocked on-site before depletion and the reason for depletion.
Leak Repair [15A NCAC 2Q .0508(f)]
i. The Permittee shall repair each leak detected as soon as practical,but not later than 15 calendar days after
it is detected, except as provided for in delay of repair and/or unsafe to repair connectors.A first attempt
at repair shall be made no later than 5 calendar days after the leak is detected. First attempt at repair for
pumps includes,but is not limited to,tightening the packing gland nuts and/or ensuring that the seal flush
is operating at design pressure and temperature. First attempt at repair for valves includes, but is not
limited to, tightening the bonnet bolts, and/or replacing the bonnet bolts, and/or tightening the packing
gland nuts, and/or injecting lubricant into the lubricated packing.
j. The leak identification on a valve in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. The leak
identification on a connector in gas/vapor or light liquid service may be removed after it has been
monitored as specified in this permit and no leak has been detected during that monitoring. Identification
that has been placed on equipment determined to have a leak, except for a valve or for a connector in
gas/vapor or light liquid service,may be removed after it is repaired.
k. Delay of repair is allowed for any of the conditions specified below.The Permittee shall maintain a record
of the facts that explain any delay of repairs and, where appropriate, why the repair was technically
infeasible without a process unit shutdown.
i. Delay of repair of equipment for which leaks have been detected is allowed if repair within 15 days
after a leak is detected is technically infeasible without a process unit or affected facility shutdown.
Repair of this equipment shall occur as soon as practical,but no later than the end of the next process
unit shutdown. However, delay of repair beyond a process unit shutdown will be allowed for a valve
if valve assembly replacement is necessary during the process unit shutdown, and valve assembly
supplies have been depleted, and valve assembly supplies had been sufficiently stocked before the
supplies were depleted.Delay of repair beyond the second process unit shutdown will not be allowed
unless the third process unit shutdown occurs sooner than six months after the first process unit
shutdown.
ii. Delay of repair of equipment for which leaks have been detected is allowed for equipment that is
isolated from the process and that does not remain in VOC service.
iii. Delay of repair for valves and connectors is also allowed if.
(A)The Permittee determines that emissions of purged material resulting from immediate repair
would be greater than the fugitive emissions likely to result from delay of repair,and
(B) When repair procedures are effected, the purged material cannot be collected and destroyed or
reused in the process.
iv. Delay of repair for pumps is also allowed if repair requires replacing the existing seal design with a
new system that the Permittee has determined under a quality improvement program (Sections 2.2
B.2.bb through 2.2 B.2.gg,below)will provide better performance,or the repair is completed as soon
as practical,but not later than 6 months after the leak was detected and one of the following is used;

Permit 01819T45
Page 35
(A) A dual mechanical seal system;
(B) A pump that meets has no external shaft penetrating the pump housing; or
(C) A system that routes emissions to a process or a fuel gas system or a closed vent system and
control device;
Valves in GasNapor/Light Liquid Service [15A NCAC 2Q .0508(f)]
1. The Permittee shall monitor all valves using the method specified in this permit at the intervals, except
unsafe to monitor valves and maintain records as specified below. The instrument reading that defines a
leak is 500 parts per million or greater.
i. If at least the greater of two valves or two percent of the valves in a process unit leak, the Permittee
shall monitor each valve once per month.
ii At process units with less than the greater of two leaking valves or two percent leaking valves, the
Permittee shall monitor each valve once each quarter, except as provided below.
(A)The Permittee may elect to monitor each valve once every two quarters for process units with less
than one percent leaking valves.
(B) The Permittee may elect to monitor each valve once every four quarters for process units with
less than 0.5 percent leaking valves.
(C) The Permittee may elect to monitor each valve once every two years for process units with less
than 0.25 percent leaking valves.
iii. The Permittee shall keep a record of the monitoring schedule for each process unit.
m. The Permittee may choose to subdivide the valves in the group of process units and apply the monitoring
frequency provisions to each subgroup. If the Permittee subdivides the valves in the group of process
units, then the following provisions apply.
i. The overall performance of total valves in the group of process units to be subdivided shall be less
than two percent leaking valves.
ii. The initial assignment or subsequent reassignment of valves to subgroups shall be governed as
follows.
(A)The Permittee shall determine which valves are assigned to each subgroup.Valves with less than
one year of monitoring data or valves not monitored within the last twelve months must be placed
initially into the most frequently monitored subgroup until at least one year of monitoring data
have been obtained.
(B) Any valve or group of valves can be reassigned from a less frequently monitored subgroup to a
more frequently monitored subgroup provided that the valves to be reassigned were monitored
during the most recent monitoring period for the less frequently monitored subgroup. The
monitoring results must be included with that less frequently monitored subgroup's associated
percent leaking valves calculation for that monitoring event.
(C) Any valve or group of valves can be reassigned from a more frequently monitored subgroup to a
less frequently monitored subgroup provided that the valves to be reassigned have not leaked for
the period of the less frequently monitored subgroup (e.g., for the last 12 months, if the valve or
group of valves is to be reassigned to a subgroup being monitored annually). Non-repairable
valves may not be reassigned to a less frequently monitored subgroup.
iii. The Permittee shall determine every six months if the overall performance of total valves in the
applicable process unit or group of process units is less than two percent leaking valves and so indicate
the performance in the next periodic report.If the overall performance of total valves in the applicable
process unit or group of process units is two percent leaking valves or greater,the Permittee shall no
longer subgroup and shall revert to the program required in Section 2.2 B.2.p.for that group of process
units.The Permittee can again elect to comply with the valve subgrouping procedures if future overall
performance of total valves in the process unit or group of process units is again less than two percent.
The overall performance of total valves in the applicable process unit or group of process units shall
be calculated as a weighted average of the percent leaking valves of each subgroup according to
following equation:

Permit 01819T45
Page 36
n
E(%VLi X V)
%V
LO
YV
i=1
Where: %V O=Overall performance of total valves in the applicable process unit or group of process
units
%VL; =Percent leaking valves in subgroup i,most recent value
Vi =Number of valves in subgroup i
n =Number of subgroups.
iv. The Permittee shall maintain the following records:
(A)Which valves are assigned to each subgroup;
(B) Monitoring results and calculations made for each subgroup for each monitoring period;
(C) Which valves are reassigned,the last monitoring result prior to reassignment,and when they were
reassigned; and
(D)The results of the semiannual overall performance calculation.
v. The Permittee shall notify the DAQ no later than 30 days prior to the beginning of the next monitoring
period of the decision to subgroup valves. The notification shall identify the participating process
units and the number of valves assigned to each subgroup, if applicable, and may be included in the
next semi-annual periodic report.
vi. The Permittee shall submit in the semi-annual periodic reports the following information:
(A)Total number of valves in each subgroup, and
(B) The results of the semiannual overall performance calculation.
n. The Permittee perform percentage calculations for each process group(i.e.,botanical extraction,biomass
extraction, and Rotocel/recovery) for comparison with the sub grouping criteria specified in Section 2.2
B.2.m, above, and the percent leaking valves for each monitoring period for each process unit or valve
subgroup shall be calculated using the following equation:
%VL = VT
1XI00
T
Where: %VL = Percent leaking valves.
VL = Number of valves found leaking, excluding non-repairable valves and including those
valves found whose repair was not confirmed with both post leak repair monitoring and
periodic monitoring.
VT = The sum of the total number of valves monitored.
o. When determining monitoring frequency for each process unit or valve subgroup subject to monthly,
quarterly,or semiannual monitoring frequencies,the percent leaking valves shall be the arithmetic average
of the percent leaking valves from the last two monitoring periods. When determining monitoring
frequency for each process unit or valve subgroup subject to annual or biennial (once every 2 years)
monitoring frequencies, the percent leaking valves shall be the arithmetic average of the percent leaking
valves from the last three monitoring periods.
i. Non-repairable valves shall be included in the calculation of percent leaking valves the first time the
valve is identified as leaking and non-repairable. Otherwise, a number of non-repairable valves
(identified and included in the percent leaking valves calculation in a previous period) up to a
maximum of one percent of the total number of valves in VOC service at a process unit may be
excluded from calculation of percent leaking valves for subsequent monitoring periods.
ii. If the number of non-repairable valves exceeds one percent of the total number of valves in regulated
material service at a process unit or affected facility, the number of non-repairable valves exceeding

Permit 01819T45
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one percent of the total number of valves in regulated material service shall be included in the
calculation of percent leaking valves.
p. If a leak is determined,then the leak shall be repaired. After a leak has been repaired, the valve shall be
monitored at least once within the first three months after its repair.
i. This monitoring is in addition to the monitoring required to satisfy the definition of repaired and first
attempt at repair. The monitoring shall be conducted to determine whether the valve has resumed
leaking.
ii. Periodic monitoring may be used to satisfy this if the timing of the monitoring period coincides with
the time specified. Alternatively, other monitoring may be performed to satisfy the requirement
regardless of whether the timing of the monitoring period for periodic monitoring coincides with the
time above.
iii. If a leak is detected by monitoring that is conducted after leak repair,the Permittee shall:
(A)Use periodic monitoring to satisfy the requirement above, then the valve shall be counted as a
leaking valve, or
(B) If the Permittee elected to use other monitoring, prior to the periodic monitoring, to satisfy the
above requirement, then the valve shall be counted as a leaking valve unless it is repaired and
shown by periodic monitoring not to be leaking.
q. Any valve that is designated as an unsafe-to-monitor or difficult to monitor valve is exempt from the
requirements of Section 2.2 B.2.1,above,and the Permittee shall monitor the valve according to the written
plan specified in Section 2.2 B.2.b, above.
Pumps in light liquid service standards [15A NCAC 2Q .0508(f)]
r. The pumps shall be instrumentally monitored monthly to detect leaks by the method specified in this
permit. The instrument reading that defines a leak is 1,000 parts per million or greater. Repair is not
required unless an instrument reading of 2,000 parts per million or greater is detected. Any pump that is
designated as an unsafe-to-monitor pump is exempt from this requirement and shall be monitored and
inspected according to the written plan specified in Section 2.2 B.2.b, above.
s. Each pump shall be checked by visual inspection each calendar week for indications of liquids dripping
from the pump seal. The Permittee shall document that the inspection was conducted and the date of the
inspection. If there are indications of liquids dripping from the pump seal at the time of the weekly
inspection,the Permittee shall:
i. Monitor the pump as specified in this permit and if the instrument reading indicates a reading of 2,000
parts per million (ppm) or greater it shall be repaired using the procedures in Sections 2.2 B.2.i
through 2.2 13.21, above; or
ii. Eliminate the visual indications of liquids dripping.
Any pump that is located within the boundary of an unmanned plant site is exempt from the weekly visual
inspection provided that each pump is visually inspected as often as practical and at least monthly.
t. If, when calculated on a 6-month rolling average for the percent leaking pumps, at least the greater of
either 10 percent of the pumps in a process unit or three pumps in a process unit leak,the Permittee shall
implement a quality improvement program for pumps Sections 2.2.B.2.bb through 2.2 B.2.gg,below.The
Permittee shall not alter the process grouping used in calculating this percentage.
i. The number of pumps at a process unit shall be the sum of all the pumps in VOC service, except that
pumps found leaking in a continuous process unit within one month after start-up of the pump shall
not count in the percent leaking pumps calculation for that one monitoring period only.
ii. Percent leaking pumps shall be determined by the following equation:
%PL =I
(Pi P Ps)—Ps x 100
r
Where: %PL=Percent leaking pumps

Permit 01819T45
Page 38
PL =Number of pumps found leaking as determined through monthly monitoring. Do not
include results from inspection of unsafe-to-monitor pumps.
Ps =Number of pumps leaking within one month of start-up during the current monitoring
period.
PT =Total pumps in VOC, including pumps with duel mechanical seals, pumps with no
external shaft penetrating the pump housing, and unsafe to monitor pumps.
Connectors in gas and vapor service and in light liquid service standards [15A NCAC 2Q .0508(f)]
u. The Permittee shall monitor all connectors in gas and vapor and light liquid using instrumentation as
specified in this permit. If an instrument reading greater than or equal to 500 parts per million is measured,
a leak is detected. Any connector that is designated as unsafe-to-monitor is exempt from this requirement
and shall be monitored and inspected according to the written plan specified in Section 2.2 B.2.b, above.
v. The Permittee shall perform monitoring as specified below.
i. If the percent leaking connectors in the process unit was greater than or equal to 0.5 percent, then
monitor within 12 months(one year).
ii. If the percent leaking connectors in the process unit was greater than or equal to 0.25 percent but less
than 0.5 percent,then monitor within four years.The Permittee may comply with this requirement by
monitoring at least 40 percent of the connectors within two years of the start of the monitoring period,
provided all connectors have been monitored by the end of the four year monitoring period.
iii. If the percent leaking connectors in the process unit was less than 0.25 percent the Permittee shall
monitor at least 50 percent of the connectors within four years of the start of the monitoring period
and
(A)Monitor as soon as practical,but within the next six months,all connectors that have not yet been
monitored during the monitoring period if the percent leaking connectors is greater than or equal
to 0.35 percent of the monitored connectors [At the conclusion of monitoring, a new monitoring
period shall be started based on the percent leaking connectors of the total monitored connectors.],
or
(B) Monitor all connectors that have not yet been monitored within eight years of the start of the
monitoring period if the percent leaking connectors is less than 0.35 percent of the monitored
connectors.
iv. If, during the monitoring, a connector is found to be leaking, it shall be re-monitored once within 90
days after repair to confirm that it is not leaking.
v. The Permittee shall keep a record of the start date and end date of each monitoring period under this
section for each process unit.
w. Monitoring frequency shall be determined based on the percent leaking connectors and calculated as
follows:
%CL =CL x 100
r
Where: %CL = Percent leaking connectors as determined through periodic monitoring.
CL = Number of connectors measured at 500 parts per million or greater.
Ct = Total number of monitored connectors in the process unit.
x. Connectors that are:
i. Buried,insulated in a manner that prevents access by a monitor probe,
ii. Obstructed by equipment or piping that prevents access by a monitoring probe,
iii. Unable to be reached by a lift up to 25 feet above ground level,
iv. Inaccessible because it would require elevating the monitoring personnel more than seven feet above
a permanent support surface or would require the erection of scaffolding, or
v. Not able to be accessed in a safe manner to perform monitoring

Permit 01819T45
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are exempt from monitoring requirements. However if any inaccessible, ceramic or ceramic-lined
connector is observed by visual, audible, olfactory, or other means to be leaking, the visual, audible,
olfactory, or other indications of a leak to the atmosphere shall be eliminated as soon as practical.
Pressure relief devices in gas and vapor service standards [15A NCAC 2Q .0508(f)]
y. Except during pressure releases as specified below, each pressure relief device in gas and vapor service
shall be operated with an instrument reading of less than 500 parts per million.
z. After each pressure release:
i. The pressure relief device shall be returned to a condition indicated by an instrument reading of less
than 500 parts per million,as soon as practical,but no later than five calendar days after each pressure
release, except as provided for in delay of repair provisions of this permit;
ii. The pressure relief device shall be monitored no later than five calendar days after the restoration to
confirm the condition indicated by an instrument reading of less than 500 parts per million above
background,and
iii. The Permittee shall record the dates and results of the monitoring following a pressure release
including the background level measured and the maximum instrument reading measured during the
monitoring.
aa. Any pressure relief device that is equipped with a rupture disk upstream of the pressure relief device is
exempt from monitoring provided the Permittee installs a replacement rupture disk upstream of the
pressure relief device as soon as practical after each pressure release but no later than five calendar days
after each pressure release, except as provided for in delay of repair.
Ouality improvement program for pumps [15A NCAC 2Q .0508(f)]
bb. If, on a 6-month rolling average, at least the greater of either 10 percent of the pumps in a process unit or
three pumps in a process unit leak, the Permittee shall implement a quality improvement plan until the
number of leaking pumps is less than the greater of either 10 percent of the pumps or three pumps in the
process unit, calculated as a 6-month rolling average. Once the performance level is achieved, the
Permittee shall comply with the requirements in Sections 2.2 B.2.r through 2.2 B.2.t, above.
cc. The Permittee shall collect the following data and maintain records for each pump in each process unit
subject to the quality improvement program.The data may be collected and the records may be maintained
on a process unit, affected facility, or plant site basis.
i. Pump type (e.g., piston, horizontal or vertical centrifugal, gear, bellows); pump manufacturer; seal
type and manufacturer; pump design(e.g., external shaft,flanged body); materials of construction; if
applicable,barrier fluid or packing material; and year installed.
ii. Service characteristics of the stream such as discharge pressure, temperature, flow rate, and annual
operating hours.
iii. The maximum instrument readings observed in each monitoring observation before repair, response
factor for the stream if appropriate, instrument model number, and date of the observation.
iv. If a leak is detected,the repair methods used and the instrument readings after repair.
The Permittee shall continue to collect data on the pumps as long as the process unit or affected facility
(or plant site)remains in the quality improvement program.
dd. The Permittee shall inspect all pumps or pump seals that exhibited frequent seal failures and were removed
from the process unit due to leaks. The inspection shall determine the probable cause of the pump seal
failure or of the pump leak and shall include recommendations, as appropriate, for design changes or
changes in specifications to reduce leak potential.
ee. The Permittee shall analyze the data collected to comply with the requirements of Section 2.2 B.2.cc,
above, to determine the services, operating or maintenance practices, and pump or pump seal designs or
technologies that have poorer than average emission performance and those that have better than average
emission performance.The analysis shall determine if specific trouble areas can be identified on the basis
of service, operating conditions or maintenance practices, equipment design, or other process-specific
factors.

Permit 01819T45
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i. The analysis shall also be used to determine if there are superior performing pump or pump seal
technologies that are applicable to the service(s),operating conditions,or pump or pump seal designs
associated with poorer than average emission performance.A superior performing pump or pump seal
technology is one with a leak frequency of less than 10 percent for specific applications in the process
unit.A candidate superior performing pump or pump seal technology is one demonstrated or reported
in the available literature or through a group study as having low emission performance and as being
capable of achieving less than 10 percent leaking pumps in the process unit.
ii. The analysis shall include consideration of the following information:
(A)The data obtained from the inspections of pumps and pump seals removed from the process unit
due to leaks;
(B) Information from the available literature and from the experience of other plant sites that will
identify pump designs or technologies and operating conditions associated with low emission
performance for specific services; and
(C) Information on limitations on the service conditions for the pump seal technology operating
conditions as well as information on maintenance procedures to ensure continued low emission
performance.
iii. The data analysis may be conducted through an inter- or intra-company program (or through some
combination of the two approaches) and may be for a single process unit, a plant site,a company, or
a group of process units.
iv. The first analysis of the data shall be completed no later than 18 months after the start of the quality
improvement program. The first analysis shall be performed using data collected for a minimum of
six months. An analysis of the data shall be done each year the process unit or affected facility is in
the quality improvement program.
ff. The Permittee shall prepare and implement a pump quality assurance program that details purchasing
specifications and maintenance procedures for all pumps and pump seals in the process unit. The quality
assurance program may establish any number of categories,or classes,of pumps as needed to distinguish
among operating conditions and services associated with poorer than average emission performance as
well as those associated with better than average emission performance. The quality assurance program
shall be developed considering the findings of the data analysis required under paragraph Section
2.2B.2.ee,above,and the operating conditions in the process unit.The quality assurance program shall be
updated each year as long as the process unit has the greater of either 10 percent or more leaking pumps
or has three leaking pumps.
i. The quality assurance program shall implement the following procedures.
(A)Establish minimum design standards for each category of pumps or pump seal technology. The
design standards shall specify known critical parameters such as tolerance, manufacturer,
materials of construction,previous usage, or other applicable identified critical parameters.
(B) Require that all equipment orders specify the design standard (or minimum tolerances) for the
pump or the pump seal.
(C) Provide for an audit procedure for quality control of purchased equipment to ensure conformance
with purchase specifications.
(D)Detail off-line pump maintenance and repair procedures. These procedures shall include
provisions to ensure that rebuilt or refurbished pumps and pump seals will meet the design
specifications for the pump category and will operate so that emissions are minimized.
ii. The quality assurance program shall be established no later than the start of the third year of the
quality improvement program.
gg. Three years after the start of the quality improvement program, the Permittee shall replace the pumps or
pump seals that are not superior emission performance technology with pumps or pump seals that have
been identified as superior emission performance technology and that comply with the quality assurance
standards for the pump category. Superior emission performance technology is that category or design of
pumps or pump seals with emission performance that when combined with appropriate process,operating,
and maintenance practices, will result in less than 10 percent leaking pumps for specific applications in
the process unit. Superior emission performance technology includes material or design changes to the

Permit 01819T45
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existing pump,pump seal, seal support system, installation of multiple mechanical seals or equivalent, or
pump replacement.
i. Pumps or pump seals shall be replaced at the rate of 20 percent per year based on the total number of
pumps in light liquid service. The calculated value shall be rounded to the nearest nonzero integer
value. The minimum number of pumps or pump seals shall be one. Pump replacement shall continue
until all pumps subject to the requirements of Sections 2.2 B.2.r through 2.2 B.2.t, above, are pumps
determined to be superior performance technology.
ii. The Permittee may delay replacement of pump seals or pumps with superior technology until the next
planned process unit shutdown,provided the number of pump seals and pumps replaced is equivalent
to the 20 percent or greater annual replacement rate.
iii. The pumps shall be maintained as specified in the quality assurance program.
hh. The Permittee shall maintain records for the period of the quality improvement program for the process
unit prescribed below.
i. When using a pump quality improvement program,the Permittee shall record:
(A)The rolling average percent leaking pumps;
(B) Documentation of all inspections conducted under the requirements of Section 2.2 B.2.dd,above,
and any recommendations for design or specification changes to reduce leak frequency; and
(C) The beginning and ending dates while meeting the quality improvement plan requirements.
ii. If a leak is not repaired within 15 calendar days after discovery of the leak, the reason for the delay
and the expected date of successful repair.
iii. Records of all analyses required in the quality improvement plan including a list identifying areas
associated with poorer than average performance and the associated service characteristics of the
stream,the operating conditions and maintenance practices.
iv. All records documenting the quality assurance program for pumps as specified in the quality
assurance program,including records indicating that all pumps replaced or modified during the period
of the quality improvement program are in compliance with the quality assurance.
v. Records documenting compliance with the 20 percent or greater annual replacement rate for pumps
as specified in Section 2.2 B.2.gg, above.
Recordkeeging requirements [15A NCAC 2Q .0508(f)]
ii. The Permittee shall keep general and specific equipment identification if the equipment is not physically
tagged and the Permittee is electing to identify the equipment through written documentation such as a
log or other designation.
J. The Permittee shall keep a written plan for any equipment that is designated as unsafe- or difficult-to-
monitor.
kk. The Permittee shall maintain a record of the identity and an explanation for any equipment that is
designated as unsafe-to-repair.
11. The Permittee shall keep records for leak repair and records for delay of repair.
nun. For valves,the Permittee shall maintain the monitoring schedule for each process unit and the valve
subgrouping records.
nn. For pumps,the Permittee shall maintain documentation of pump visual inspections.
oo. For connectors,the Permittee shall maintain the monitoring schedule for each process.
pp. For pressure relief devices in gas and vapor or light liquid service,the Permittee shall keep records of the
dates and results of monitoring following a pressure release.
qq. For a pump QIP program,the Permittee shall maintain the following records:
i. Individual pump records as specified in Section 2.2 B.2.cc, above;
ii. Quality assurance program documentation as specified in Section 2.2 B.2.ff, above; and
iii. Quality improvement program records as specified in Section 2.2 13.21h, above.

Permit 01819T45
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Reporting requirements [15A NCAC 2Q .0508(f)]
rr. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked or
received on or before January 30 of each calendar year for the preceding six-month period between July
and December and July 30 of each calendar year for the preceding six-month period between January and
June.The report shall contain in summary format by equipment type(i.e.,valves in gas/vapor/light liquid
service,Pumps in light liquid service,and connectors in gas/vapor/light liquid):
i. The number of components for which leaks were detected
ii. The percent leakers for valves, pumps and connectors,and
iii. The total number of components monitored
The report shall also include the number of leaking components that were not repaired,and for valves and
connectors, identify the number of components that are determined to be non-repairable.
ss. Where any delay of repair is utilized, report that delay of repair has occurred and report the number of
instances of delay of repair.
tt. Report the valve subgrouping information.
uu. For pressure relief devices in gas and vapor service that are to be operated at a leak detection instrument
reading of less than 500 parts per million, report the results of all monitoring to show compliance
conducted within the semiannual reporting period.
w. Report, if applicable,the initiation of a monthly monitoring program for valves.
ww. Report, if applicable,the initiation of a quality improvement program for pumps.
C. Sclareolide(SDE)Operations,including:
• Four process tanks of various capacities(ID No.ES-1001-1-4-P);
• One acetic acid storage tank(10,135 gallon capacity; ID No.M-20);
• Process equipment leaks(ID No.ES-1001-1-4-F);
• Four batch reactors (ID Nos. M-10, M-10A, D-1231A, and D-1231B) and associated venturi-type
wet scrubber(10 gallons per minute minimum liquid injection rate;ID No.CD-M-34); and
• SDE Operations wastewater stream (ID No.ES-1001-1-4-WW)
Biological Conversion Equipment for Purification of Sclareolide,including:
• Twelve process tanks of various capacities (ID No.ES-1001-1-3-P);
• One centrifuge(ID No. G-17);
• One steam-heated dryer(ID No.D-1202);
• Process equipment leaks (ID No.ES-1001-1-3-F);
• One distillation column(6 gallon per minute nominal process rate; ID No.A-2); and
• Biological conversion equipment for sclareolide purification wastewater stream (ID No. ES-1001-
1-3-WW)
Ethyl Vanillin Glucoside(EVG)Operations,including:
• One water spray fume scrubber(0.5 gallon per minute minimum water injection rate; ID No.CD-
Z-9215)venting to one water spray fume scrubber(0.5 gallon per minute minimum water injection
rate;ID No.CD-Z-9216)controlling emissions from:
o Three reactors(ID Nos.D-2202,D-1215,and D-1218); and
o One steam-heated dryer(ID No.D-1201);
• Process equipment leaks(ID No.ES-1003-2-2-F); and
• EVG Operations wastewater stream (ID No. ES-1003-2-2-WW)
Plant Nutrient Extraction(PNE)Operations,including one water spray fume scrubber(0.5 gallon per
minute minimum water injection rate; ID No. CD-Z-9215) venting to one water spray fume scrubber
(0.5 gallon per minute minimum water solution injection rate;ID No.CD-Z-9216)controlling emissions
from:

Permit 01819T45
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• One product extract reactor (ID No. D31214) and one associated chilled water condenser (ID No.
EX2203);
• Seven processing tanks of various capacities (ID No.ES-1003-2-1-P);
• One centrifuge(ID No. C-31203);
• One dryer equipped with a process condenser(ID No. D-1002);
• One process solvent tank(ID No. ES-TK-PNE-1)
• Process equipment leaks (ID No.ES-1003-2-1-F);
• One waste solids separator vessel(1,333 gallon capacity;ID No.D31211)and one associated chilled
water condenser(ID No.EX2205); and
• PNE Process wastewater stream(ID No.ES-1003-2-1-WW)
Concrete Operations,including:
• Four steam-heated hot boxes (ID Nos.HB-1,HB-2,HB-3,and HB-4);
• Process equipment leaks(ID No.ES-1001-1-2-F);
• Six process tanks of various capacities (ID No. ES-1001-1-2-P) and one associated chilled water
condenser (ID No. CD-1001-1-2); and
• Concrete Operations wastewater stream (ID No. ES-1001-1-2-WW)
Rotocel Operations, as described in Section 2.1 C,above;
Two Storage and Recycle Tanks (ID No.ES-M-125A and M-125B)
Recovery Operations, as described in Section 2.1 C, above;
Biomass Extraction Operations, as described in Section 2.1 D,above;
Botanical Extraction Operations, as described in Section 2.1 D, above; and
Wastewater Treatment Plant Aeration Tank No. 1 (63,500 gallon capacity; ID No.WWTP-AT1)
The following table provides a summary of limits and standards for the emission source(s) describe above:
Regulated Pollutant Limits/Standards Applicable Regulation
Hazardous Air Pollutants(HAP) Maximum Achievable Control 15A NCAC 2D .1111
Technology (40 CFR Part 63, Subpart FFFF)
1. 2D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY"
[40 CFR Part 63, Subpart FFFF]
a. The Permittee shall comply with all applicable provisions, including the notification, testing,
recordkeeping, and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .1111 "Maximum Achievable Control Technology"as promulgated in 40 CFR
Part 63, Subpart FFFF,including Subpart A "General Provisions".For convenience,some of the relevant
definitions from 40 CFR Part 63, Subpart FFFF are included below: [40 CFR §§63.2435, 63.2440,
63.2445(b),and 63.2550]
Group 1 batch process vent means each of the batch process vents in a process for which the collective
uncontrolled organic HAP emissions from all of the batch process vents are greater than or equal to 10,000
lb/yr at an existing source or greater than or equal to 3,000 lb/yr at a new source.
Group 2 batch process vent means each batch process vent that does not meet the definition of Group 1
batch process vent.
Group I continuous process vent means a continuous process vent for which the flow rate is greater than
or equal to 0.005 standard cubic meter per minute, and the total resource effectiveness index value,
calculated according to §63.2455(b),is less than or equal to 1.9 at an existing source and less than or equal
to 5.0 at a new source.
Group 2 continuous process vent means a continuous process vent that does not meet the definition of a
Group 1 continuous process vent.

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Group l storage tank means a storage tank with a capacity greater than or equal to 10,000 gal storing
material that has a maximum true vapor pressure of total HAP greater than or equal to 6.9 kilopascals at
an existing source or greater than or equal to 0.69 kilopascals at a new source.
Group 2 storage tank means a storage tank that does not meet the definition of a Group 1 storage tank.
Group l wastewater stream means a wastewater stream consisting of process wastewater at an existing
or new source that meets the criteria for Group 1 status in §63.2485(c) for compounds in Tables 8 and 9
to this subpart and/or a wastewater stream consisting of process wastewater at a new source that meets
the criteria for Group 1 status in §63.132(d) for compounds in Table 8 to subpart G of this part 63.
Group 2 wastewater stream means any process wastewater stream that does not meet the definition of a
Group 1 wastewater stream.
In organic HAP service means that a piece of equipment either contains or contacts a fluid(liquid or gas)
that is at least 5 percent by weight of total organic HAP as determined according to the provisions of
§63.180(d).The provisions of§63.180(d)also specify how to determine that a piece of equipment is not
in organic HAP service.
Miscellaneous organic chemical manufacturing process means all equipment which collectively
function to produce a product or isolated intermediate that are materials described in§63.2435(b).For the
purposes of this subpart, process includes any, all or a combination of reaction, recovery, separation,
purification, or other activity, operation, manufacture, or treatment which are used to produce a product
or isolated intermediate.
Nonstandard batch means a batch process that is operated outside of the range of operating conditions
that are documented in an existing operating scenario but is still a reasonably anticipated event. For
example, a nonstandard batch occurs when additional processing or processing at different operating
conditions must be conducted to produce a product that is normally produced under the conditions
described by the standard batch. A nonstandard batch may be necessary as a result of a malfunction, but
it is not itself a malfunction.
Operating scenario means, for the purposes of reporting and recordkeeping, any specific operation of an
MCPU as described by records specified in §63.2525(b).
Point of determination means each point where process wastewater exits the MCPU or control device.
Standard batch means a batch process operated within a range of operating conditions that are
documented in an operating scenario. Emissions from a standard batch are based on the operating
conditions that result in highest emissions. The standard batch defines the uncontrolled and controlled
emissions for each emission episode defined under the operating scenario.
General Requirements/Limitations [15A NCAC 2Q .0508(f)]
b. The Permittee shall comply with the general requirements of Sections 2.2 C.l.b.i through v,below:
i. The Permittee must submit a Notice of Compliance Status Report for the SIDE Operations, the
Concrete Operations,and/or the PNE Operations prior to the operation of those operations in organic
HAP service (as defined at 40 CFR §63.2250) and such that provisions of 40 CFR Part 63, Subpart
FFFF apply to those operations,pursuant to 40 CFR §63.2520(d).
ii. Opening a safety device, as defined in §63.2550, is allowed at any time conditions require it to avoid
unsafe conditions. [40 CFR 63.2450(p)]
iii. The Permittee must comply with the applicable control requirements found in 40 CFR §§63.2455
through 63.2490 for the affected sources.
iv. If a Group 2 emission point becomes a Group 1 emission point,the Permittee must be in compliance
with the Group 1 requirements beginning on the date the switch occurs. An initial compliance
demonstration as specified in 40 CFR Part 63, Subpart FFFF must be conducted within 150 days after
the switch in group status occurs.The Permittee shall be deemed in non-compliance with 15A NCAC
2D .1111 if the Permittee does not meet these requirements. [40 CFR §63.2445(d)]
v. The Permittee must develop a written startup, shutdown, and malfunction plan (SSM Plan) that
complies with 40 CFR §63.6(e) for the affected sources. The Permittee is not, however, required to
address equipment leaks (except for control devices) or Group 2 emission points in the SSM Plan.
The SSM Plan must describe, in detail,procedures for operating and maintaining the affected sources

Permit 01819T45
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during periods of startup, shutdown, and malfunction; and corrective actions for malfunctioning
process, control, and monitoring equipment used to comply with Subpart FFFF. The SSM Plan does
not need to address any scenario that would not cause an affected source to exceed an applicable
emission limit in Subpart FFFF. The SSM Plan must be maintained on site and made available for
inspection by authorized personnel. [40 CFR §§63.6(e)(3)and 63.25250)]
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if it does not meet the
requirements of Sections 2.2 C.l.b.i through v, above.
Monitoring Requirements [15A NCAC 2Q .0508(f)]
c. The Permittee shall comply with the specific requirements of Sections 2.2 C.l.c.i through vii,below:
i. Continuous process vents: To ensure compliance, the Permittee shall perform the monitoring of
Sections 2.2 C.l.c.i(A)and(B),below, for the affected continuous process vents:
(A)For the continuous process vents associated with the Rotocel Operations and the Recovery
Operations, the Permittee shall perform the monitoring found in Sections 2.2 B.l.g through j,
above.
(B) For continuous process vent associated with the Botanical Extraction Operations, the Permittee
shall perform the monitoring found in Sections 2.2 B.l.g and h, above.
ii. Batch process vents: To ensure compliance,the Permittee shall perform the monitoring of Sections
2.2 C.1.c.ii(A)through(C),below, for the affected batch process vents:
(A)For the batch process vents associated the EVG Operations and the Biological conversion
equipment for purification of sclareolide,the Permittee shall comply with the requirements of 40
CFR§63.2460 and Table 2 of 40 CFR Part 63, Subpart FFFF.To maintain Group 2 classification
for these emission sources the organic HAP emissions must be less than 10,000 pounds per
consecutive 365-day period,each source.The Permittee shall monitor the organic HAP emissions
from each of these emission sources,monthly, as follows:
(1) Organic HAP emissions from the EVG Operations shall calculated using the following
equation:
Organic HAP= 1.0(pounds x B
batch )
Where: B = The number of batches processed in the EVG Operations
(2) Organic HAP emissions from the Biological conversion equipment for purification of
sclareolide shall calculated using the following equation:
Organic HAP= 11.62 pounds x B
batch )
Where: B = The number of regular batches processed in the Biological conversion
equipment for purification of sclareolide
(B) The Permittee may administratively amend this permit to modify the organic HAP emission
factors cited in the equations of Sections 2.2 C.l.c.ii(A)(1)and(2), above.
(C)The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iii. Process vents that emit hydrogen halide: For the batch process vents associated with the EVG
Operations,the Permittee shall comply with the requirements of 40 CFR §63.2465 and Table 3 of 40
CFR Part 63, Subpart FFFF. To maintain Group 2 classification for these batch process vents the
hydrogen halide emissions must be less than 1,000 pounds per consecutive 365-day period,combined.
The Permittee shall monitor the organic HAP emissions from these batch process vents, monthly, as
follows:
(A)Hydrogen halide emissions from the EVG Operations shall calculated using the following
equation:

Permit 01819T45
Page 46
Organic HAP= 11.3 pounds X B + 31.8 pounds X B
batch ) 1, ( batch ) "`
Where: B,,g = The number of regular batches processed in the EVG Operations; and
B,e, = The number of recovery batches processed in the EVG Operations
(B) The Permittee may administratively amend this permit to modify the hydrogen halide emission
factors cited in the equations of Sections 2.2 C.l.c.iii(A),above.
(C) The Permittee must notify DAQ at least 60 days before operating these batch process vents as
Group 1 batch process vents in accordance with 40 CFR §63.2460(b)(6)(ii) and 40 CFR
§63.2520(e)(10)(ii).
iv. Storage tanks: For the storage tanks that are part of the affected source,the Permittee shall comply
with the requirements of 40 CFR §63.2470 and Table 4 of 40 CFR Part 63, Subpart FFFF.
v. Equipment leaks: For the process equipment leaks from the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2480 and Table 6 of 40 CFR Part 63, Subpart FFFF.
The Permittee shall comply with the monitoring requirements of the leak detection and repair(LDAR)
program found in Section 2.2 B.2, above, for the equipment associated with the affected sources.
vi. Wastewater streams:For the wastewater streams associated with the affected miscellaneous organic
chemical manufacturing processes (MCPI), the Permittee shall comply with the requirements of 40
CFR§63.2485 and Table 7 of 40 CFR Part 63, Subpart FFFF, including:
(A)Identifying any operations that may generate maintenance wastewater and the procedures for
properly managing that maintenance wastewater in the SSM Plan developed for this Avoca, Inc.
facility; and
(B) Maintaining the conditions necessary for classification of the process wastewater from the
affected sources as Group 2,unless the conditions of Section 2.2 C.Lb.iv, above,have been met.
vii. Heat exchangers: For the heat exchangers associated with the affected sources, the Permittee shall
comply with the requirements of 40 CFR §63.2490 and Table 10 of Subpart FFFF, including:
(A)Preparation and implementation of a monitoring plan that documents the procedures that will be
used to detect leaks of process fluids into cooling water.This plan shall require monitoring of one
or more surrogate indicators (e.g., pH, conductivity, etc.) or monitoring of one or more process
parameters or other conditions that indicate a leak. The plan shall include the following:
(1) A description of the parameter or condition to be monitored and an explanation of how the
selected parameter or condition will reliably indicate the presence of a leak;
(2) The parameter level(s)or conditions(s)that shall constitute a leak. This shall be documented
by data or calculations showing that the selected levels or conditions will reliably identify
leaks. The monitoring must be sufficiently sensitive to determine the range of parameter
levels or conditions when the system is not leaking. When the selected parameter level or
condition is outside that range, a leak is indicated;
(3) The monitoring frequency which shall be no less frequent than monthly for the first 6 months
and quarterly thereafter to detect leaks;
(4) The records that will be maintained to document compliance with the requirements of this
section.
(B) If a substantial leak is identified by methods other than those described in the heat exchanger
monitoring plan and the method(s) specified in the plan could not detect the leak, the Permittee
shall revise the plan and document the basis for the changes no later than 180 days after discovery
of the leak.
(C) The Permittee shall maintain a copy of the heat exchanger monitoring plan on-site. If the
monitoring plan is superseded, retain the most recent superseded plan at least until 5 years from
the date of its creation.
(D)If a leak is detected in any heat exchanger system, it shall be repaired as soon as practical but not
later than 45 calendar days after the Permittee receives results of monitoring tests indicating a
leak, unless the Permittee demonstrates that the results are due to a condition other than a leak.
Once the leak has been repaired, the owner or operator shall confirm that the heat exchange

Penn it 01819T45
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system has been repaired within 7 calendar days of the repair or startup,whichever is later,except
where the Permittee appropriately applies the delay of repair provisions found in Section 2.2
C.l.c.vii(E),below.
(E) Delay of repair of heat exchange systems is allowed if the equipment is isolated from the process.
Delay of repair is also allowed if repair is technically infeasible without a shutdown and any one
of the conditions listed in 40 CFR §63.104(e)(1)through(2)is met.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.c.i through vii, above.
Recordkeeping Requirements [15A NCAC 2Q .0508(f)]
d. The Permittee shall comply with the requirements of Sections 2.2 C.1.d.i through v,below:
i. Create and retain a record of each time a safety device is opened to avoid unsafe conditions.
ii. Create and retain the following records on each affected MCPU:
(A)A description of the process and the type of process equipment used;
(B) An identification of related process vents (including associated emissions episodes), wastewater
points of determination(PODs),and storage tanks;
(C) The applicable control requirements pursuant to 40 CFR Part 63, Subpart FFFF, including the
level of required control, and for vents,the level of control for each vent;
(D)The control device or treatment process used, as applicable, including a description of operating
and/or testing conditions for any associated control device;
(E) The process vents,wastewater POD,transfer racks,and storage tanks(including those from other
processes)that are simultaneously routed to the control device or treatment process;
(F) The applicable monitoring requirements of this subpart and any parametric level that assures
compliance for all emissions routed to the control device or treatment process; and,
(G)Calculations and engineering analyses required to demonstrate compliance.
iii. For each affected MPCU with a Group 2 process vent,the Permittee shall retain the following records:
(A)A record of the day each batch was completed;
(B) A record of whether each batch operated was considered a standard batch;
(C) The estimated uncontrolled and controlled emissions for each batch that is considered to be a non-
standard batch; and
(D)Records of the daily 365-day rolling summations of emissions,or alternative records that correlate
to the emissions(e.g.,number of batches),calculated no less frequently than monthly.
iv. For each affected Group 2 wastewater stream,the Permittee shall retain the following records:
(A)MPCU identification and description;
(B) Stream identification code;
(C) Concentration of compounds listed in Table 8 and Table 9 of 40 CFR Part 63, Subpart FFFF(in
ppmw), including documentation of the methodology used to determine concentration; and,
(D) Stream flow rate(in liters/min).
v. For each affected heat exchanger system, the Permittee shall retain the following records:
(A)Monitoring data indicating a leak, the date when the leak was detected, and if demonstrated not
to be a leak,the basis for that determination;
(B) Records of any leaks detected by procedures other than those provided in the written heat
exchanger monitoring plan, including the date the leak was discovered;
(C) The dates of efforts to repair leaks; and,
(D)The method or procedure used to confirm repair of a leak and the date repair was confirmed.
The Permittee shall be deemed in non-compliance with 15A NCAC 2D .1111 if the Permittee does not
meet the requirements of Sections 2.2 C.1.d.i through v, above.
Reporting [15A NCAC 2Q .0508(f)]
e. For any process vents that change from Group 2 to Group 1, the Permittee shall comply with the
notification requirements of 40 CFR §63.2460(b)(6) and 40 CFR §63.2520(e)(10).

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f. The Permittee shall submit a semiannual compliance report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked or delivered on or before January 30
of each calendar year for the preceding six-month period between July and December,and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain the
following:
i. Company name and address;
ii. Statement by a responsible official with that official's name, title, and signature, certifying the
accuracy of the content of the report;
iii. Date of report and beginning and ending dates of the reporting period;
iv. If there are no deviations from any emission limit, operating limit or work practice standard specified
in this subpart, include a statement that there were no deviations from the emission limits, operating
limits, or work practice standards during the reporting period;
v. For each deviation from an emission limit, operating limit, and work practice standard, include the
following information:
(A)The total operating time of the affected source during the reporting period; and,
(B) Information on the number, duration, and cause of deviations (including unknown cause, if
applicable), as applicable, and the corrective action taken.
vi. Identification each new operating scenario which has been operated since the time period covered by
the last compliance report and has not been submitted in the previous compliance report. For the
purposes of this paragraph, a revised operating scenario for an existing process is considered to be a
new operating scenario;
vii. For the equipment listed below, report in a summary format by equipment type, the number of
components for which leaks were detected and for valves, pumps and connectors show the percent
leakers, and the total number of components monitored. Also include the number of leaking
components that were not repaired as required,and for valves and connectors, identify the number of
components that are determined to be non-repairable as described in 40 CFR§63.1025(c)(3).
(A)Valves in gas and vapor service and in light liquid service;
(B) Pumps in light liquid service;
(C) Connectors in gas and vapor service and in light liquid service; and,
(D)Agitators in gas and vapor service and in light liquid service.
viii.Where any delay of repair for leaks is utilized,report that delay of repair has occurred and report the
number of instances of delay of repair.
ix. For pressure relief devices, report the results of all leak monitoring to show compliance conducted
within the semiannual reporting period.
x. Report, if applicable,the initiation of a monthly leak monitoring program for valves.
xi. For each affected heat exchanger system for which the Permittee invokes the delay of repair,include
the following information:
(A)The presence of the leak and the date that the leak was detected.
(B) Whether or not the leak has been repaired.
(C) The reason(s)for delay of repair.
(D)If the leak is repaired, the owner or operator shall report the date the leak was successfully
repaired.
(E) If the leak remains unrepaired, the expected date of repair.
D. Biomass boilers (ID Nos. ES-BB1 and BB2)
Rotary sage dryer (ID No. ES-RD
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION
a. In order to avoid applicability of this regulation,the above emission sources shall discharge into the
atmosphere less than 40 tons of VOCs per consecutive 12-month period. [15A NCAC 2D .0530]

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Monitoring/Recordkeeping [15A NCAC 2Q .0508 (f)]
b. For any sage sent to the dryer,the Permittee shall:
i. Measure the sage input on a daily basis,
ii. Measure the hexane content of the sage exiting the process on a weekly basis. The sampling shall
include collecting sage material as it exits the desolventizer before it enters the rotary dryer every
hour for a 24-hour period each week.
iii. Calculate daily VOC emissions by using the daily sage input and the hexane content(lb hexane/lb
sage)determined weekly for the sage drying until the next weekly result is obtained.
c. The facility has determined the potential VOC emissions from both boilers to be 3.57 tons per 12
months or 0.30 tons per month. The Permittee has requested to use 0.15 tons per month of VOC emitted
per boiler for any month in which the boiler(s)operate to determine compliance with this permit
condition.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook(written or
electronic format).
e. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the monitoring and
recordkeeping is not conducted and maintained as specified in Sections 2.2. D.l.b through d or if the
emissions exceed the limit specified in Section 2.2. D.La.
Reporting [15A NCAC 2Q .0508(f)]
f. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
i. The monthly VOC emissions for the previous 17 months. The emissions must be calculated for each
of the 12-month periods over the previous 17 months.
E. Rotary Sage Dryer(ID No.ES-RD)
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
LIMITATION TO AVOID 15A NCAC 2D .1112: 112(g)Case by Case Maximum Achievable Control
Technology
a. In order to avoid applicability of 112(g),n-hexane emissions from the rotary dryer(ID No. ES-RD)
shall be less than 10 tons per year.
Monitorini/Recordkeeping Requirements 115A NCAC 2Q .0508(f)]
b. Maintain monthly consumption records of each material containing n-hexane as follows:
i. Maintain a quantity of n-hexane in pounds used in the rotocel operations each month and for the 12-
month period ending on that month.
ii. Maintain a record of purchase orders and invoices of materials containing n-hexane that are used in
the rotocel operations.
iii. Utilize the calculations specified in Permit Condition No. 2.2-D.Lb. above and calculate n-hexane
emissions based on the n-hexane content utilized in the rotocel operations as determined at the
desolventizer as the emissions from the rotary dryer.
c. The Permittee shall keep a record of the applicability determination on site at the source for a period of
five years after the determination, or until the source becomes an affected source. The determination
must include the analysis demonstrating why the Permittee believes the source is unaffected pursuant to
40 CFR Part 63.10(b)(3)
d. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the monitoring and
recordkeeping is not conducted and maintained as specified in Sections 2.2.E.Lb and c. or if the
emissions exceed the limit specified in Section 2.2. E.La,

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Reporting Requirements [15A NCAC 2Q .0508(f)]
e. The Permittee shall submit a semi-annual summary report,acceptable to the Regional Air Quality
Supervisor,of monitoring and recordkeeping activities postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December, and July 30 of each
calendar year for the preceding six-month period between January and June. The report shall contain
the following:
i. The monthly n-hexane emissions for the previous 17 months. The emissions must be calculated for
each of the 12-month periods over the previous 17 months.

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SECTION 3 - GENERAL CONDITIONS (version 4.012/17/15)
This section describes terms and conditions applicable to this Title V facility.
A. General Provisions [NCGS 143-215 and 15A NCAC 02Q .0508(i)(16)]
1. Terms not otherwise defined in this permit shall have the meaning assigned to such terms as defined in
15A NCAC 02D and 02Q.
2. The terms,conditions,requirements,limitations, and restrictions set forth in this permit are binding and
enforceable pursuant to NCGS 143-215.114A and 143-215.11413,including assessment of civil and/or
criminal penalties.Any unauthorized deviation from the conditions of this permit may constitute grounds
for revocation and/or enforcement action by the DAQ.
3. This permit is not a waiver of or approval of any other Department permits that may be required for other
aspects of the facility which are not addressed in this permit.
4. This permit does not relieve the Permittee from liability for harm or injury to human health or welfare,
animal or plant life,or property caused by the construction or operation of this permitted facility,or from
penalties therefore,nor does it allow the Permittee to cause pollution in contravention of state laws or
rules,unless specifically authorized by an order from the North Carolina Environmental Management
Commission.
5. Except as identified as state-only requirements in this permit,all terms and conditions contained herein
shall be enforceable by the DAQ,the EPA,and citizens of the United States as defined in the Federal
Clean Air Act.
6. Any stationary source of air pollution shall not be operated,maintained,or modified without the
appropriate and valid permits issued by the DAQ,unless the source is exempted by rule. The DAQ may
issue a permit only after it receives reasonable assurance that the installation will not cause air pollution in
violation of any of the applicable requirements. A permitted installation may only be operated,
maintained,constructed,expanded,or modified in a manner that is consistent with the terms of this permit.
B. Permit Availability[15ANCAC 02Q .0507(k)and .0508(i)(9)(B)]
The Permittee shall have available at the facility a copy of this permit and shall retain for the duration of the
permit term one complete copy of the application and any information submitted in support of the application
package. The permit and application shall be made available to an authorized representative of Department of
Environmental Quality upon request.
C. Severability Clause[15A NCAC 02Q .0508(i)(2)]
In the event of an administrative challenge to a final and binding permit in which a condition is held to be
invalid,the provisions in this permit are severable so that all requirements contained in the permit,except those
held to be invalid,shall remain valid and must be complied with.
D. Submissions [15A NCAC 02Q.0507(e)and 02Q .0508(i)(16)]
Except as otherwise specified herein,two copies of all documents,reports,test data,monitoring data,
notifications,request for renewal,and any other information required by this permit shall be submitted to the
appropriate Regional Office. Refer to the Regional Office address on the cover page of this permit. For
continuous emissions monitoring systems(CEMS)reports,continuous opacity monitoring systems(COMS)
reports, quality assurance(QA)/quality control(QC)reports,acid rain CEM certification reports, and NOx
budget CEM certification reports,one copy shall be sent to the appropriate Regional Office and one copy shall
be sent to:
Supervisor, Stationary Source Compliance
North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh,NC 27699-1641

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All submittals shall include the facility name and Facility ID number(refer to the cover page of this permit).
E. Duty to Comply [15A NCAC 02Q .0508(i)(3)]
The Permittee shall comply with all terms,conditions,requirements,limitations and restrictions set forth in
this permit.Noncompliance with any permit condition except conditions identified as state-only requirements
constitutes a violation of the Federal Clean Air Act. 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.
F. Circumvention- STATE ENFORCEABLE ONLY
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 pollution control device(s)and appurtenances.
G. Permit Modifications
1. Administrative Permit Amendments [15A NCAC 02Q .0514]
The Permittee shall submit an application for an administrative permit amendment in accordance with 15A
NCAC 02Q .0514.
2. Transfer in Ownership or Operation and Application Submittal Content [15A NCAC 02Q .0524 and 02Q
.0505]
The Permittee shall submit an application for an ownership change in accordance with 15A NCAC
02Q.0524 and 02Q .0505.
3. Minor Permit Modifications[15A NCAC 02Q .0515]
The Permittee shall submit an application for a minor permit modification in accordance with 15A NCAC
02Q.0515.
4. Significant Permit Modifications [15A NCAC 02Q .0516]
The Permittee shall submit an application for a significant permit modification in accordance with 15A
NCAC 02Q .0516.
5. Reopening for Cause[15A NCAC 02Q .0517]
The Permittee shall submit an application for reopening for cause in accordance with 15A NCAC 02Q
.0517.
H. Changes Not Requiring Permit Modifications
1. Reporting Requirements
Any of the following that would result in new or increased emissions from the emission source(s)listed in
Section 1 must be reported to the Regional Supervisor,DAQ:
a. changes in the information submitted in the application;
b. changes that modify equipment or processes;or
c. changes in the quantity or quality of materials processed.
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.
2. Section 502(b)(10)Changes [15A NCAC 02Q .0523(a)]
a. "Section 502(b)(10)changes"means changes that contravene an express permit term or condition.
Such changes do not include changes that would violate applicable requirements or contravene
federally enforceable permit terms and conditions that are monitoring(including test methods),
recordkeeping,reporting,or compliance certification requirements.
b. The Permittee may make Section 502(b)(10)changes without having the permit revised if:
i. the changes are not a modification under Title I of the Federal Clean Air Act;
ii. the changes do not cause the allowable emissions under the permit to be exceeded;

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iii. the Permittee notifies the Director and EPA with written notification at least seven days before the
change is made; and
iv. the Permittee shall attach the notice to the relevant permit.
c. The written notification shall include:
i. a description of the change;
ii. the date on which the change will occur;
iii. any change in emissions; and
iv. any permit term or condition that is no longer applicable as a result of the change.
d. Section 502(b)(10)changes shall be made in the permit the next time that the permit is revised or
renewed,whichever comes first.
3. Off Permit Changes [15A NCAC 02Q .0523(b)]
The Permittee may make changes in the operation or emissions without revising the permit if
a. the change affects only insignificant activities and the activities remain insignificant after the change;
or
b. the change is not covered under any applicable requirement.
4. Emissions Trading [15A NCAC 02Q .0523(c)]
To the extent that emissions trading is allowed under 15A NCAC 02D, including subsequently adopted
maximum achievable control technology standards,emissions trading shall be allowed without permit
revision pursuant to 15A NCAC 02Q .0523(c).
LA Reporting Requirements for Excess Emissions and Permit Deviations [15A NCAC 02D.0535(f)and 02Q
.0508(f)(2)]
"Excess Emissions"-means an emission rate that exceeds any applicable emission limitation or standard
allowed by any rule in Sections .0500, .0900, .1200,or.1400 of Subchapter 0213; or by a permit condition;or
that exceeds an emission limit established in a permit issued under 15A NCAC 02Q .0700. (Note:Definitions
of excess emissions under 02D.I I10 and 02D.II I I shall apply where defined by rule)
"Deviations"-for the purposes of this condition,any action or condition not in accordance with the terms and
conditions of this permit including those attributable to upset conditions as well as excess emissions as defined
above lasting less than four hours.
Excess Emissions
1. If a source is required to report excess emissions under NSPS(15A NCAC 02D .0524),NESHAPS (15A
NCAC 02D.1110 or.1111),or the operating permit provides for periodic(e.g.,quarterly)reporting of
excess emissions,reporting shall be performed as prescribed therein.
2. If the source is not subject to NSPS (15A NCAC 02D .0524),NESHAPS (15A NCAC 02D.I 110 or
.I I 11),or these rules do NOT define"excess emissions,"the Permittee shall report excess emissions in
accordance with 15A NCAC 02D.0535 as follows:
a. Pursuant to 15A NCAC 02D.0535,if excess emissions last for more than four hours resulting from a
malfunction,a breakdown of process or control equipment,or any other abnormal condition,the
owner or operator shall:
i. notify the Regional Supervisor or Director 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 provide:
• name and location of the facility;
• nature and cause of the malfunction or breakdown;
• time when the malfunction or breakdown is first observed;
• expected duration; and
• estimated rate of emissions;
ii. notify the Regional Supervisor or Director immediately when corrective measures have been
accomplished; and
iii. submit to the Regional Supervisor or Director within 15 days a written report as described in 15A
NCAC 02D.0535(f)(3).

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Permit Deviations
3. Pursuant to 15A NCAC 02Q .0508(f)(2),the Permittee shall report deviations from permit requirements
(terms and conditions)as follows:
a. Notify the Regional Supervisor or Director of all other deviations from permit requirements not
covered under 15A NCAC 02D .0535 quarterly. A written report to the Regional Supervisor shall
include the probable cause of such deviation and any corrective actions or preventative actions taken.
The responsible official shall certify all deviations from permit requirements.
I.B Other Requirements under 15A NCAC 02D.0535
The Permittee shall comply with all other applicable requirements contained in 15A NCAC 02D.0535,
including 15A NCAC 02D.0535(c)as follows:
1. Any excess emissions that do not occur during start-up and shut-down shall be considered a violation of
the appropriate rule unless the owner or operator of the sources demonstrates to the Director,that the
excess emissions are a result of a malfunction. The Director shall consider,along with any other pertinent
information,the criteria contained in 15A NCAC 02D .0535(c)(1)through(7).
2. 15A NCAC 02D .0535(g). Excess emissions during start-up and shut-down shall be considered a
violation of the appropriate rule if the owner or operator cannot demonstrate that excess emissions are
unavoidable.
J. Emereency Provisions [40 CFR 70.6(g)]
The Permittee shall be subject to the following provisions with respect to emergencies:
1. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the
control of the facility,including acts of God,which situation requires immediate corrective action to
restore normal operation,and that causes the facility to exceed a technology-based emission limitation
under the permit,due to unavoidable increases in emissions attributable to the emergency. An emergency
shall not include noncompliance to the extent caused by improperly designed equipment, lack of
preventive maintenance,careless or improper operation,or operator error.
2. An emergency constitutes an affirmative defense to an action brought for noncompliance with such
technology-based emission limitations if the conditions specified in 3.below are met.
3. The affirmative defense of emergency shall be demonstrated through properly signed contemporaneous
operating logs or other relevant evidence that include information as follows:
a. an emergency occurred and the Permittee can identify the cause(s)of the emergency;
b. the permitted facility was at the time being properly operated;
c. during the period of the emergency the Permittee took all reasonable steps to minimize levels of
emissions that exceeded the standards or other requirements in the permit;and
d. the Permittee submitted notice of the emergency to the DAQ within two working days of the time
when emission limitations were exceeded due to the emergency. This notice must contain a
description of the emergency, steps taken to mitigate emissions,and corrective actions taken.
4. In any enforcement proceeding,the Permittee seeking to establish the occurrence of an emergency has the
burden of proof.
5. This provision is in addition to any emergency or upset provision contained in any applicable requirement
specified elsewhere herein.
K. Permit Renewal [15A NCAC 02Q .0508(e)and 02Q .0513(b)]
This 15A NCAC 02Q .0500 permit is issued for a fixed term not to exceed five years and shall expire at the
end of its term. Permit expiration terminates the facility's right to operate unless a complete 15A NCAC 02Q
.0500 renewal application is submitted at least nine months before the date of permit expiration. If the
Permittee or applicant has complied with 15A NCAC 02Q .0512(b)(1),this 15A NCAC 02Q .0500 permit
shall not expire until the renewal permit has been issued or denied. Permit expiration under 15A NCAC 02Q
.0400 terminates the facility's right to operate unless a complete 15A NCAC 02Q .0400 renewal application is
submitted at least six months before the date of permit expiration for facilities subject to 15A NCAC 02Q

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.0400 requirements. In either of these events,all terms and conditions of these permits shall remain in effect
until the renewal permits have been issued or denied.
L. Need to Halt or Reduce Activity Not a Defense[15ANCAC 02Q .0508(i)(4)]
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the conditions of this permit.
M. Duty to Provide Information(submittal of information) [15A NCAC 02Q .0508(i)(9)]
1. The Permittee shall furnish to the DAQ,in a timely manner,any reasonable information that the Director
may request in writing to determine whether cause exists for modifying,revoking and reissuing,or
terminating the permit or to determine compliance with the permit.
2. The Permittee shall furnish the DAQ copies of records required to be kept by the permit when such copies
are requested by the Director.For information claimed to be confidential,the Permittee may furnish such
records directly to the EPA upon request along with a claim of confidentiality.
N. Duty to Supplement[15ANCAC 02Q .0507(f)]
The Permittee,upon becoming aware that any relevant facts were omitted or incorrect information was
submitted in the permit application, shall promptly submit such supplementary facts or corrected information
to the DAQ. The Permittee shall also provide additional information as necessary to address any requirement
that becomes applicable to the facility after the date a complete permit application was submitted but prior to
the release of the draft permit.
O. Retention of Records [15A NCAC 02Q .0508(f)and 02Q .0508 (1)]
The Permittee shall retain records of all required monitoring data and supporting information for a period of at
least five years from the date of the monitoring sample,measurement,report,or application. Supporting
information includes all calibration and maintenance records and all original strip-chart recordings for
continuous monitoring information,and copies of all reports required by the permit. These records shall be
maintained in a form suitable and readily available for expeditious inspection and review. Any records
required by the conditions of this permit shall be kept on site and made available to DAQ personnel for
inspection upon request.
P. Compliance Certification[15A NCAC 02Q .0508(n)]
The Permittee shall submit to the DAQ and the EPA(Air and EPCRA Enforcement Branch,EPA,Region 4,
61 Forsyth Street SW,Atlanta,GA 30303)postmarked on or before March 1 a compliance certification(for
the preceding calendar year)by a responsible official with all federally-enforceable terms and conditions in the
permit,including emissions limitations, standards,or work practices. It shall be the responsibility of the
current owner to submit a compliance certification for the entire year regardless of who owned the facility
during the year. The compliance certification shall comply with additional requirements as may be specified
under Sections 114(a)(3)or 504(b)of the Federal Clean Air Act. The compliance certification shall specify:
1. the identification of each term or condition of the permit that is the basis of the certification;
2. the compliance status(with the terms and conditions of the permit for the period covered by the
certification);
3. whether compliance was continuous or intermittent; and
4. the method(s)used for determining the compliance status of the source during the certification period.
Q. Certification by Responsible Official [15A NCAC 02Q .0520]
A responsible official shall certify the truth,accuracy,and completeness of any application form,report,or
compliance certification required by this permit. All certifications shall state that based on information and
belief formed after reasonable inquiry,the statements and information in the document are true,accurate,and
complete.

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R. Permit Shield for Applicable Requirements [15A NCAC 02Q .0512]
1. Compliance with the terms and conditions of this permit shall be deemed compliance with applicable
requirements,where such applicable requirements are included and specifically identified in the permit as
of the date of permit issuance.
2. A permit shield shall not alter or affect:
a. the power of the Commission, Secretary of the Department,or Governor under NCGS 143-
215.3(a)(12),or EPA under Section 303 of the Federal Clean Air Act;
b. the liability of an owner or operator of a facility for any violation of applicable requirements prior to
the effective date of the permit or at the time of permit issuance;
c. the applicable requirements under Title IV; or
d. the ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to obtain
information to determine compliance of the facility with its permit.
3. A permit shield does not apply to any change made at a facility that does not require a permit or permit
revision made under 15A NCAC 02Q .0523.
4. A permit shield does not extend to minor permit modifications made under 15A NCAC 02Q .0515.
S. Termination,Modification,and Revocation of the Permit[15A NCAC 02Q .05191
The Director may terminate,modify,or revoke and reissue this permit if.
1. the information contained in the application or presented in support thereof is determined to be incorrect;
2. the conditions under which the permit or permit renewal was granted have changed;
3. violations of conditions contained in the permit have occurred;
4. the EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d); or
5. the Director finds that termination,modification,or revocation and reissuance of the permit is necessary to
carry out the purpose of NCGS Chapter 143,Article 21 B.
T. Insignificant Activities [15A NCAC 02Q .0503]
Because an emission source or activity is insignificant does not mean that the emission source or activity is
exempted from any applicable requirement or that the owner or operator of the source is exempted from
demonstrating compliance with any applicable requirement. The Permittee shall have available at the facility
at all times and made available to an authorized representative upon request,documentation,including
calculations, if necessary,to demonstrate that an emission source or activity is insignificant.
U. Property Rights [15A NCAC 02Q .0508(i)(8)]
This permit does not convey any property rights in either real or personal property or any exclusive privileges.
V. Inspection and Entry [15A NCAC 02Q .0508(1)and NCGS 143-215.3(a)(2)]
1. Upon presentation of credentials and other documents as may be required by law,the Permittee shall allow
the DAQ,or an authorized representative,to perform the following:
a. enter the Permittee's premises where the permitted facility is located or emissions-related activity is
conducted,or where records are kept under the conditions of the permit;
b. have access to and copy,at reasonable times,any records that are required to be kept under the
conditions of the permit;
c. inspect at reasonable times and using reasonable safety practices any source,equipment(including
monitoring and air pollution control equipment),practices,or operations regulated or required under
the permit; and
d. sample or monitor substances or parameters,using reasonable safety practices,for the purpose of
assuring compliance with the permit or applicable requirements at reasonable times.
Nothing in this condition shall limit the ability of the EPA to inspect or enter the premises of the Permittee
under Section 114 or other provisions of the Federal Clean Air Act.
2. No person shall refuse entry or access to any authorized representative of the DAQ who requests entry for
purposes of inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper,or

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interfere with any such authorized 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.
W. Annual Fee Payment[15A NCAC 02Q .0508(i)(10)]
1. The Permittee shall pay all fees in accordance with 15A NCAC 02Q .0200.
2. Payment of fees may be by check or money order made payable to the N.C.Department of Environmental
Quality. Annual permit fee payments shall refer to the permit number.
3. If,within 30 days after being billed,the Permittee fails to pay an annual fee,the Director may initiate
action to terminate the permit under 15A NCAC 02Q .0519.
X. Annual Emission Inventory Requirements [15A NCAC 02Q .0207]
The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A
NCAC 02Q .0207(a)from each emission source within the facility during the previous calendar year. The
report shall be in or on such form as may be established by the Director. The accuracy of the report shall be
certified by a responsible official of the facility.
Y. Confidential Information[15A NCAC 02Q .0107 and 02Q.0508(i)(9)]
Whenever the Permittee submits information under a claim of confidentiality pursuant to 15A NCAC 02Q
.0107,the Permittee may also submit a copy of all such information and claim directly to the EPA upon
request. All requests for confidentiality must be in accordance with 15A NCAC 02Q .0107.
Z. Construction and Operation Permits [15A NCAC 02Q .0100 and.0300]
A construction and operating permit shall be obtained by the Permittee for any proposed new or modified
facility or emission source which is not exempted from having a permit prior to the beginning of construction
or modification,in accordance with all applicable provisions of 15A NCAC 02Q .0100 and.0300.
AA. Standard Application Form and Required Information [15A NCAC 02Q .0505 and .0507]
The Permittee shall submit applications and required information in accordance with the provisions of 15A
NCAC 02Q .0505 and.0507.
BB. Financial Responsibility and Compliance History [15A NCAC 02Q .0507(d)(4)]
The DAQ may require an applicant to submit a statement of financial qualifications and/or a statement of
substantial compliance history.
CC. Refrigerant Requirements(Stratospheric Ozone and Climate Protection)[15A NCAC 02Q.0501(e)]
1. If the Permittee has appliances or refrigeration equipment, including air conditioning equipment,which
use Class I or II ozone-depleting substances such as chlorofluorocarbons and hydrochlorofluorocarbons
listed as refrigerants in 40 CFR Part 82 Subpart A Appendices A and B,the Permittee shall service,repair,
and maintain such equipment according to the work practices,personnel certification requirements,and
certified recycling and recovery equipment specified in 40 CFR Part 82 Subpart F.
2. The Permittee shall not knowingly vent or otherwise release any Class I or 11 substance into the
environment during the repair,servicing,maintenance,or disposal of any such device except as provided
in 40 CFR Part 82 Subpart F.
3. The Permittee shall comply with all reporting and recordkeeping requirements of 40 CFR 82.166.
Reports shall be submitted to the EPA or its designee as required.
DD. Prevention of Accidental Releases-Section 112(r) [15A NCAC 02Q .0508(h)]
If the Permittee is required to develop and register a Risk Management Plan with EPA pursuant to Section
112(r)of the Clean Air Act,then the Permittee is required to register this plan in accordance with 40 CFR Part
68.

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EE.Prevention of Accidental Releases General Duty Clause-Section 112(r)(1)—FEDERALLY-
ENFORCEABLE ONLY
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.
FF. Title IV Allowances [15A NCAC 02Q .0508(i)(1)]
This permit does not limit the number of Title IV allowances held by the Permittee,but the Permittee may not
use allowances as a defense to noncompliance with any other applicable requirement. The Pennittee's
emissions may not exceed any allowances that the facility lawfully holds under Title IV of the Federal Clean
Air Act.
GG. Air Pollution Emergency Episode[15A NCAC 02D.0300]
Should the Director of the DAQ declare an Air Pollution Emergency Episode,the Permittee will be required to
operate in accordance with the Permittee's previously approved Emission Reduction Plan or, in the absence of
an approved plan,with the appropriate requirements specified in 15A NCAC 02D.0300.
HH. Registration of Air Pollution Sources [15A NCAC 02D .0202]
The Director of the DAQ may require the Permittee to register a source of air pollution. If the Permittee is
required to register a source of air pollution,this registration and required information will be in accordance
with 15A NCAC 02D .0202(b).
H. Ambient Air Ouality Standards [15A NCAC 02D.0501(c)]
In addition to any control or manner of operation necessary to meet emission standards specified in this permit,
any source of air pollution shall be operated with such control or in such manner that the source shall not cause
the ambient air quality standards in 15A NCAC 02D .0400 to be exceeded at any point beyond the premises on
which the source is located. When controls more stringent than named in the applicable emission standards in
this permit are required to prevent violation of the ambient air quality standards or are required to create an
offset,the permit shall contain a condition requiring these controls.
JJ. General Emissions Testing and Reporting Requirements [15A NCAC 02Q .0508(i)(16)]
Emission compliance testing shall be by the procedures of Section .2600,except as may be otherwise
required in Rules .0524, .0912, .1110, .1111, or.1415 of Subchapter 02D. If emissions testing is required by
this permit or the DAQ or if the Permittee submits emissions testing to the DAQ to demonstrate compliance,
the Permittee shall perform such testing in accordance with 15A NCAC 02D.2600 and follow the procedures
outlined below:
1. The owner or operator of the source shall arrange for air emission testing protocols to be provided to the
Director prior to air pollution testing.Testing protocols are not required to be pre-approved by the
Director prior to air pollution testing.The Director shall review air emission testing protocols for pre-
approval prior to testing if requested by the owner or operator at least 45 days before conducting the
test.
2. Any person proposing to conduct an emissions test to demonstrate compliance with an applicable
standard shall notify the Director at least 15 days before beginning the test so that the Director may at
his option observe the test.
3. The owner or operator of the source shall arrange for controlling and measuring the production rates
during the period of air testing.The owner or operator of the source shall ensure that the equipment or
process being tested is operated at the production rate that best fulfills the purpose of the test. The
individual conducting the emission test shall describe the procedures used to obtain accurate process
data and include in the test report the average production rates determined during each testing period.
4. Two copies of the final air emission test report shall be submitted to the Director not later than 30 days
after sample collection unless otherwise specified in the specific conditions. The owner or operator may

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request an extension to submit the final test report. The Director shall approve an extension request if he
finds that the extension request is a result of actions beyond the control of the owner or operator.
a. The Director shall make the final determination regarding any testing procedure deviation and the
validity of the compliance test.The Director may:
i. Allow deviations from a method specified under a rule in this Section if the owner or operator
of the source being tested demonstrates to the satisfaction of the Director that the specified
method is inappropriate for the source being tested.
ii. Prescribe alternate test procedures on an individual basis when he finds that the alternative
method is necessary to secure more reliable test data.
iii. Prescribe or approve methods on an individual basis for sources or pollutants for which no test
method is specified in this Section if the methods can be demonstrated to determine compliance
of permitted emission sources or pollutants.
b. The Director may authorize the Division of Air Quality to conduct independent tests of any source
subject to a rule in this Subchapter to determine the compliance status of that source or to verify any
test data submitted relating to that source. Any test conducted by the Division of Air Quality using
the appropriate testing procedures described in Section 02D .2600 has precedence over all other
tests.
KK. Reopening for Cause[15A NCAC 02Q .0517]
1. A permit shall be reopened and revised under the following circumstances:
a. additional applicable requirements become applicable to a facility with remaining permit term of three
or more years;
b. additional requirements(including excess emission requirements)become applicable to a source
covered by Title IV;
c. the Director or EPA finds that the permit contains a material mistake or that inaccurate statements
were made in establishing the emissions standards or other terms or conditions of the permit; or
d. the Director or EPA determines that the permit must be revised or revoked to assure compliance with
the applicable requirements.
2. Any permit reopening shall be completed or a revised permit issued within 18 months after the applicable
requirement is promulgated. No reopening is required if the effective date of the requirement is after the
expiration of the permit term unless the term of the permit was extended pursuant to 15A NCAC 02Q
.0513(c).
3. Except for the state-enforceable only portion of the permit,the procedures set out in 15A NCAC 02Q
.0507, .0521,or.0522 shall be followed to reissue the permit. If the State-enforceable only portion of the
permit is reopened,the procedures in 15A NCAC 02Q .0300 shall be followed. The proceedings shall
affect only those parts of the permit for which cause to reopen exists.
4. The Director shall notify the Permittee at least 60 days in advance of the date that the permit is to be
reopened,except in cases of imminent threat to public health or safety the notification period may be less
than 60 days.
5. Within 90 days, or 180 days if the EPA extends the response period,after receiving notification from the
EPA that a permit needs to be terminated,modified,or revoked and reissued,the Director shall send to the
EPA a proposed determination of termination,modification, or revocation and reissuance, as appropriate.
LL.Reporting Requirements for Non-Operating Equipment[15A NCAC 02Q .0508(i)(16)]
The Permittee shall maintain a record of operation for permitted equipment noting whenever the equipment is
taken from and placed into operation. During operation the monitoring recordkeeping and reporting
requirements as prescribed by the permit shall be implemented within the monitoring period.
MM.Fugitive Dust Control Requirement[15A NCAC 02D.0540] - STATE ENFORCEABLE ONLY
As required by 15A NCAC 02D .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 or excessive fugitive dust emissions from

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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 02D.0540(f).
"Fugitive dust emissions"means particulate matter from process operations 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).
NN. Specific Permit Modifications [15A NCAC 02Q.0501 and.0523]
1. For modifications made pursuant to 15A NCAC 02Q .0501(c)(2),the Permittee shall file a Title V Air
Quality Permit Application for the air emission source(s)and associated air pollution control device(s)
on or before 12 months after commencing operation.
2. For modifications made pursuant to 15A NCAC 02Q .0501(d)(2),the Permittee shall not begin
operation of the air emission source(s)and associated air pollution control device(s)until a Title V Air
Quality Permit Application is filed and a construction and operation permit following the procedures of
Section .0500 (except for Rule .0504 of this Section) is obtained.
3. For modifications made pursuant to 502(b)(10),in accordance with 15A NCAC 02Q .0523(a)(1)(C),the
Permittee shall notify the Director and EPA(EPA-Air Planning Branch, 61 Forsyth Street SW,
Atlanta,GA 30303)in writing at least seven days before the change is made. The written notification
shall include:
a. a description of the change at the facility;
b. the date on which the change will occur;
c. any change in emissions; and
d. any permit term or condition that is no longer applicable as a result of the change.
In addition to this notification requirement, with the next significant modification or Air Quality Permit
renewal,the Permittee shall submit a page'U" of the application forms signed by the responsible official
verifying that the application for the 502(b)(10)change/modification, is true, accurate, and complete.
Further note that modifications made pursuant to 502(b)(10)do not relieve the Permittee from satisfying
preconstruction requirements.
00.Third Party Participation and EPA Review [15A NCAC 02Q .0521, .0522 and.0525(7)]
For permits modifications subject to 45-day review by the federal Environmental Protection Agency
(EPA), EPA's decision to not object to the proposed permit is considered final and binding on the EPA and
absent a third party petition,the failure to object is the end of EPA's decision-making process with respect to
the revisions to the permit.The time period available to submit a public petition pursuant to 15A NCAC 02Q
.0518 begins at the end of the 45-day EPA review period.

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ATTACHMENT
List of Acronyms
AOS Alternate Operating Scenario
BACT Best Available Control Technology
Btu British thermal unit
CAA Clean Air Act
CAIR Clean Air Interstate Rule
CEM Continuous Emission Monitor
CFR Code of Federal Regulations
DAQ Division of Air Quality
DEQ Department of Environmental Quality
EMC Environmental Management Commission
EPA Environmental Protection Agency
FR Federal Register
GACT Generally Available Control Technology
HAP Hazardous Air Pollutant
MACT Maximum Achievable Control Technology
NAA Non-Attainment Area
NCAC North Carolina Administrative Code
NCGS North Carolina General Statutes
NESHAP National Emission Standards for Hazardous Air Pollutants
NOx Nitrogen Oxides
NSPS New Source Performance Standard
OAH Office of Administrative Hearings
PM Particulate Matter
PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10 Micrometers or Less
POS Primary Operating Scenario
PSD Prevention of Significant Deterioration
RACT Reasonably Available Control Technology
SIC Standard Industrial Classification
SIP State Implementation Plan
SOz Sulfur Dioxide
tpy Tons Per Year
VOC Volatile Organic Compound