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HomeMy WebLinkAboutAQ_F_0900066_20140801_PRMT_Permit M North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, III Governor Secretary August 1, 2014 Mr. Kraig Westerbeek V.P. Feed Manufacturing and Transportati Murphy-Brown, LLC Bladenboro Feed Mill PO Box 856 Warsaw,NC 28398 Subject: Air Permit No. 08155R09 Murphy-Brown, LLC- Bladenboro Feed Mill Bladenboro, Bladen County,North Carolina Permit Class: Synthetic Minor Facility ID#0900066 Dear Mr. Westerbeek: In accordance with your completed application received July 3, 2014, we are forwarding herewith Permit No. 08155R09 to Murphy-Brown, LLC- Bladenboro Feed Mill,Bladenboro, Bladen County,North Carolina for the construction and operation of air emissions sources or air cleaning devices and appurtenances. Additionally, any emissions activities determined from your air permit application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for information purposes as an "ATTACHMENT"to the enclosed air permit. Please note the records retention requirements are contained in General Condition 2 of the General Conditions and Limitations. If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of the entire permit. This hearing request must be in the form of a written petition, conforming to G.S. 150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center,Raleigh,NC 27699-6714. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and binding. You may request modification of your air permit through informal means pursuant to G.S. 15013-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that the permit will become Fayetteville Regional Office-Division of Air Quality Systel Building,225 Green Street,Suite 714,Fayetteville,North Carolina 28301-5094 Phone:910-433-33001 FAX:910-485-7467 Internet:www.ncdonr.gov An Equal Opportunity 1 Affirmative Action Employer-Made In part by recycled paper Kraig Westerbeek August 1, 2014 Page 2 final and binding regardless of a request for informal modification unless a request for a hearing is also made under G.S. 15013-23. Unless exempted by a condition of this permit or the regulations, construction of new air pollution sources or air cleaning devices, or modifications to the sources or air cleaning devices described in this permit must be covered under a permit issued by the Division of Air Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may subject the Permiittee to civil or criminal penalties as described in G.S. 143-215.114A and 143- 215.114B. This permit shall be effective from August 1,20t4 until April 30, 2015, is nontransferable to future owners and operators, and shall be subject to the conditions and limitations as specified therein. Changes have been made to the permit stipulations. The Permiittee is responsible for _ carefully reading the entire permit and evaluating the requirements of each permit stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance with any permit condition is grounds for enforcement action, for permit termination, revocation and reissuance, or modification, or for denial of a permit renewal application. Should you have any questions concerning this matter, please contact Gregory Reeves at 910-433-3300. Sincerely, `Steven F. Vozzo, Regional upervisor Division of Air Quality,NCDENR GWR Enclosures c: Fayetteville Regional Office NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF AIR QUALITY AIR PERMIT NO. 08155R09 Issue Date: August 1, 2014 Effective Date: August 1, 2014 Expiration Date: April 30, 2015 Replaces Permit: 08155R08 _ To construct and operate air emission source(s) and/or air cleaning device(s), and for the discharge of the associated air contaminants into the atmosphere in accordance with the provisions of Article 2 1 B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other applicable Laws, Rules and Regulations, Murphy-Brown,LLC- Bladenboro Feed Mill 255 Bryant Swamp Road Bladenboro, Bladen County,North Carolina Permit Class: Synthetic Minor Facility ID# 0900066 (the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air cleaning devices and appurtenances described below: i •- `iT •6yt : MM F4 �R"y Etevata gihon ' y ; ES-001 Truck grain receiving pit CD-107 Bagfilter (850 square feet of filter area) ES-002 F Receiving tumhead negative air system CD-1213 Bagfilter 332 square feet of filter area ES-003 FReceiving turnhead negative air system �CD 124 �(209 agfilter ...................... square feet of filter area} ES-004 Pneumatic receiving system CD-129 Bagfilter (200 square feet of filter area) ES-005 Pneumatic receiving system rD-T337rBagfilter (200 square feet of filter area) ES 009 Ground gram negative air system CD 21$ Bagfilter ---'±(300 square feet of filter area) ES 016a One(T)load-out system having twenty(20} NIA I (NESHAP) load out bins Permit No. 08155R09 Page 2 ES-016b One(1)load-out system having twenty(20) NIA (NESHAP) Load-out bins _ ....... ES-017 Rail Car Receiving N/A Truck grain receiving pit, 15,000 bushes ES-018 max throughput,with 3-sided shelter with roof' NIA ES-020a Wet grain storage silo,55,000 bushels capacity, NIA ES-020b Wet grain storage silo,55,000 bushels capacity NIA Utlrty Operation .F �.. �'� �� A Generator,No.2 fuel oil fired, 750 KW, Onan ES-016 Model D970636382 and Serial 86930A,with NIA (NESHAP) turbocharger and low temperature aftercooler control devices. ES 014 Natural gas/No.2 fuel oil fired boiler(20.925 ; NIA (NSPS) million Btu per hour maximum heat input) .. . . ...... ES-013 1 Natural gas/No.2 fuel oil-fired boiler(20.925 NIA (NSPS) million Btu per hour maximum heat input) 7777 " F t Few era ES-007a Hammer mill system.(capacity: 53 tons/hour} Bagfilter ...... ... CD-212 ES-007b Hammer mill system(capacity: 53 tons/hour) (1,620 square feet of filter area) - Y__...stem�_,.p '.__... . d'O1n) : Airlancomode1121ASTI2-IIbagfilter ES-008b Hammer m 11 system(capacity: 53 tons/hour CD-315 (1,640 square feet of filter area) Y ( p t5' } ES-010 Pelleting system CD-508 Three(3)cyclones installed in parallel ? (NESHAP) (capacity: 60 tons/hour) (54 inches in diameter each) ES-011 Pelletmg system Three(3)cyclones installed in parallel (NESHAP) (capacity. 60 tonsihour) CD-608 (54 inches in diameter each) Pelletmg system Three(3)cyclones installed in parallel ES-012 CD 708 (capacity 60 tons/hour) (54 inches in diameter each) _. ... ..._ ... .. ES-015 Mixed feed tarnhead negative air system Bagfilter P .................... ......... CD 422 ............ ............ (NESHAP) (capacity:36...tons/hour) (209 square feet of filter area) F...................... ES 019 Natural gas fired grain dryer,47.8 million Btu NIA per hr maximum heat input ... ....... ........ ES-021 ..Grain dryer truck loadout NIA ES-022 Bagging Operation NIA in accordance with the completed application 0900066.1413 received July 3, 2014 including any plans, specifications,previous applications, and other supporting data, all of which are filed with the Department of Environment and Natural Resources,Division of Air Quality (DAQ) and are incorporated as part of this permit. This permit is subject to the following specified conditions and limitations including any TESTING, REPORTING, OR MONITORING REQUIREMENTS: Permit No. 08155R09 Page 3 A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein. The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code(NCAC), Subchapter 2D .0202, 2D .0503, 2D .0515, 2,D .0516, 2.1) .0521, 2D .0524 (40 CFR 60, Subpart Dc), 2D .0535, 2D .0540, 2D .0611, 2D .1111 (40 CFR 63, Subpart DDDDDDD, Subpart ZZZZ), 2D .1806, 2Q .0315, 2Q .0317 (Avoidance) and 2Q .0711. 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT -The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q -- .0203(i), no permit application fee is required for renewal of an existing air permit(without a modification request). The renewal request (with AA application form) should be submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this permit, the Permittee shall submit the air pollution emission inventory report (with Certification.Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ and shall document air pollutants emitted for the 2013 calendar year. 3. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers,"particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below: natural gas/No. 2 fuel oil-fired boiler (20.925 million Btu per hour maximum heat input) 0.41 (ES-014) natural gas/No. 2 fuel oil-fired boiler (20.925 million Btu per hour maximum heat input) 0.41 (ES-013) Permit No. 08155R09 Page 4 4. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes,"particulate matter emissions from the emission sources shall not cxcccd allowable emission rates. The allowable emission rates are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be determined by the following equation(s), where P is the process throughput rate in tons per hour (tons/hr) and E is the allowable emission rate in pounds per hour(lbslhr). E=4.10.* (P) 11•67 for P<= 30 tons/hr, or E= 55 * (P) 0-11- 40 for P>30 tonslhr 5. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. 6. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However, sources which must comply with 15A NCAC 2D .0524 "New Source Performance Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" must comply with applicable visible emissions requirements contained therein. 7. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For natural gas/No. 2 fuel oil-fired boiler(20.925 million Btu per hour maximum heat input) (ID No. ES-013) and natural gas/No. 2 fuel oil-fired boiler (20.925 million Btu per hour maximum heat input) (ID No. ES-014), the Permittee shall comply with all applicable provisions, including the notification,testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart Dc, including Subpart A"General Provisions." a. NSPS Reporting Requirements - In addition to any other notification requirements to the Environmental Protection Agency(EPA), the Permittee is required to NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following: i. The sulfur content of the distillate oil combusted in an affected source shall not exceed 0.5 percent by weight. Within 3 0 days after each six-month period of the calendar year(by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June), the Permittee must submit in writing to the Regional Supervisor, DAQ, the sulfur content of the distillate oil combusted in an affected source. If fuel supplier certification is used to demonstrate compliance, fuel supplier certification shall include the following information: Permit No. 08155R09 Page 5 A. The name of the oil supplier; B. A statement from the oil supplier that the oil complies with the specification under the definition of distillate oil in 40 CFR 60.41(c); and C. A certified statement signed by the owner or operator of an affected source that the records of fuel supplier certification submitted represent all of the fuel combusted during the reporting period. b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping requirements of the EPA, the Permittee is required to maintain records as follows: i. The amounts of each fuel combusted during each month; and ii. All records required under this section shall be maintained for a period of two years following the date of such record. c. NSPS Emissions Limitations - As required by 15A NCAC 2D .0524, the following permit limits shall not be exceeded: � � x natural gas/No. 2 fuel oil-fired boiler .(20.925 million Btu per hour maximum heat input) Sulfur content 0.5%by weight (ES-013) natural gas/No. 2 fuel oil-fired boiler (20.925 million Btu per hour maximum heat input) Sulfur content` 0.5%by weight (ES-014) 8. NOTIFICATION REQUIREMENT-As required by 15A NCAC 2D .0535,the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration, and V. an estimated rate of emissions. Permit No. 08155R09 Page 6 b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 9. FUGITIVE DUST CONTROL REQUIREMENT- As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A), the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). "Fugitive dust emissions" means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as: unloading and loading areas,process areas stockpiles,stock pile working, plant parking lots, and plant roads(including access roads and haul roads). 10. FABRIC FILTER REQUIREMENTS including cartridge filters, baghouses, and other dry filter,particulate collection devices-As required by 15A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance Requirements - To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform, at a minimum, an annual (for each 12 month period following the initial inspection) internal inspection of each bagfilter system. In addition,the Permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. b. Recordkeeping Requirements - The results of all inspections and any variance from manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. The logbook (in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request. 11. CYCLONE REQUIREMENTS - As required'by 15A NCAC 2D .0611,particulate matter emissions shall be controlled as described in the permitted equipment list. a. Inspection and Maintenance Requirements - To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform an annual (for each 12 month period following the initial inspection) inspection of the cyclone system. In addition,the Permittee shall perform periodic inspections and maintenance(I&M) as recommended by the manufacturer. Permit No. 08155R09 Page 7 b. Recordkeeping_Requirements - The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a cyclone logbook. Records of all maintenance activities shall be recorded in the logbook. The cyclone logbook(in written or electronic format) shall be kept on-site and made available to DAQ personnel upon request. 12. 15A NCAC 2D .I I I I "GENERALLY AVAILABLE CONTROL TECHNOLOGY" - Area Source Standards for Prepared Feeds Manufacturing(GACT 7D) - The Permittee shall comply with all applicable provisions, including the notification,testing, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .1111; as promulgated in 40 CFR 63, Subpart DDDDDDD (7D), "National Emission Standards for Hazardous Air Pollutants Area Source Standards for Prepared Feeds Manufacturing", including Subpart A "General Provisions." a. 40 CFR 63.11620 - Compliance Dates for Existing and New Sources i. A prepared feeds manufacturing affected source is existing if you commenced construction or reconstruction of the facility on or before July 27, 2009. ii. A prepared feeds manufacturing affected source is new if you commenced construction or reconstruction of the facility after July 27, 2009. iii. Existing sources have a compliance date of January 5, 2012. iv. The compliance date for new sources is upon start-up. b. Operations Standards -As required by 15A NCAC 2D .1111 and 40 CFR 63, Subpart DDDDDDD (71)),the following operational standards are applicable to prepared feed manufacturing facilities that use a material containing chromium(Cr). in amounts greater than 0.1 % by.weight, or a material containing manganese (Mn) in amounts greater than 1.0 %by weight and are Area Sources of HAPs. NOTE: the pre-mix or supplement or concentrate ingredients stand alone for comparison to the Cr > 0.1 %by weight or Mn > 1.0 %by weight issue; not the actual ingredient% into the overall animal feed production. The affected source is the collection of all equipment and activities necessary to produce animal feed from the point in the process where a material containing Cr or Mn is added,to the point where the finished animal feed product leaves the facility. Permit No. 08155R09 Page 8 c. 40 CFR 63.11621 - Standards for New and Existing Facilities i. Management Practices - In all areas of the affected source where materials containing Cr or Mn are stored,used, or handled,you shall comply with the following management practices: A. You shall perform housekeeping measures to minimize excess dust. These measures shall include,but not be limited to: L You shall use either an industrial vacuum system or manual sweeping to reduce the amount of dust; II. At least once per month,you shall remove dust from walls, ledges, and equipment using low pressure air or by other means, and then sweep or vacuum the area; III. You shall keep doors shut except during normal ingress and egress. B. You shall maintain and operate all process equipment in accordance with manufacturer's specifications and in a manner to minimize dust creation. ii. Any Cr or Mn raw materials shall be stored in closed containers. iii. Mixers shall be covered during operation(except when materials are being added) and shall be operated so as to minimize dust. Materials containing Cr or Mn shall be added in a manner that minimizes emissions. iv. A device shall be installed and operated at the Ioadout end of each bulk loader to reduce the distance between the loading arm and the truck or railcar (i.e., loadout chutes/socks/flex hose). V. For pelleting operations at EXISTING FACILITIES with an average daily feed production level exceeding 5 0 tons per day, you shall capture emissions and route them to a cyclone designed to reduce emissions of particulate matter. The initial determination of the average daily feed production level is based on the one-year period prior to the compliance date.For existing sources, the initial average daily feed production level is based on the amount offeed productproduced between May 4, 2011 and May 4, 2012, divided by the number of operating days during that period. The cyclone shall be operated in accordance with good air pollution control practices and manufacturer's specifications and operating instructions, if available, or standard operating procedures shall be developed by the facility owner or operator to ensure proper operation and maintenance of the cyclone. Permit No. 08155R09 Page 9 vi. For pelleting operations at NEW FACILITIES with an average daily feed production level exceeding 50 tons per day, you shall capture emissions and route them to a cyclone designed to reduce emissions of particulate matter (PM, not PM-10)by 95 percent or greater. "Average Daily Feed Production Level" is defined as the average amount of animal feed products produced each day over an annual period. For new sources, the initial average feed daily production level is based on the design production rate. The subsequent average daily feed production levels are determined annually and are based on the amount of animal feed products produced in a calendar year divided by the number of days in which the production processes were in operation. You shall also comply with the three requirements below(A, B, and C): A. FOR NEW Facilities - You shall demonstrate that the cyclone is designed to reduce emissions PM by 95 percent or greater using one -- of the three methods below. I. Manufacturer's Specifications, II. Certification by a Professional Engineer or a Responsible Official, or III. Method 5 performance test for PM. B. You shall establish an inlet flow rate, inlet velocity, pressure drop, or fan amperage range that represents proper operation of the cyclone in accordance with paragraph(b)(v)(A)above. (See 40 CFR 63.11621(e)(2)) C. You shall maintain and operate the cyclone in accordance with manufacturer's specifications. If manufacturer's specifications are not available,you shall develop and follow standard maintenance and operating procedures that ensure proper operation of the cyclone. d. 40 CFR 63.11622 -Monitoring Requirements for New and Existing Sources i. The Permittee shall conduct quarterly inspections of each cyclone for corrosion, erosion, or any other damage that could result in air in-leakage, and record results of any maintenance of repairs in a logbook to be maintained on site. ii. For NEW Facilities - When the pelleting process is in operation,the Permittee shall monitor the inlet flow rate, inlet velocity,pressure drop, or fan amperage at least once per day, and record the results of this monitoring in a logbook to be maintained on site. For EXISTING Facilities - When the pelleting process is in operation, the Permittee shall monitor the cyclone weekly for proper air pollution control practices and manufacturer's specifications and operating instructions (if available) or standard operating procedures developed by the facility owner or operator. Permit No. 08155R09 Page 10 iii. The monthly housekeeping requirement (dusting and sweeping/vacuuming) shall be tracked and dated in a logbook to be maintained on site at all times. iv. Inspect the device required at the loadout end of a bulk loader monthly and record results of any maintenance or repairs in a logbook to be maintained on site. e. 40 CFR 63.11623 - Testing Requirements - FOR NEW Sources ONLY i. If a performance test is utilized to demonstrate compliance with the required 95 percent or greater reduction in particulate matter emissions on a cyclone for PM mass emission rate, Method 5 shall be used. f. 40 CFR 63.11624 -Notifications, Reporting, and Recordkeeping i. Initial Notification date for Existing Sources was May 5,2010. For New Sources,the Initial Notification is due no later than 120 days after you become subject to this Subpart. The initial notification shall include: A. Name, address,phone number, and email address of the owner or operator. B. Address (physical address) of the affected source. C. An identification of the relevant standard (i.e., 7D). D. A brief description of the operation. E. Per 63.11624(c)(1), one copy of all Notifications shall be kept on site. ii. Notification of Compliance Status OCS -report is required as follows: A. The NOCS for existing sources is due to NC DAQ on or before May 4, 2012. B. The NOCS for new sources is due within 120 days after initial start- up or by October 18, 2010,whichever is later. C. The NOCS shall include: I. Company name and address. IL A statement by a responsible official with that official's name, title,phone number, email address, and signature certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all relevant standards and requirements. Permit No. 08155R09 Page 11 III. For cyclones at NEW Facilities,the range of acceptable parametric readings for each cyclone (inlet flow rate, inlet velocity,pressure drop, or fan amperage). For EXISTING Facilities, records showing proper air pollution control practices and manufacturer's specifications and operating instructions (if available) or standard operating procedures developed by the facility owner or operator. IV. If daily production is less than 50 tons per day(meaning cyclones are not applicable), the source shall: a. keep production records on site. b. submit an Initial Average Daily Feed Production Level in the Notification of Compliance Status/ACC report and keep on site. iii. NOCS for New Sources After the Compliance Date - If you own or operate a source that becomes an affected source after the applicable compliance date of January 5, 2012 for existing sources, or if you begin operating a newly affected source, you shall submit a Notification of Compliance Status within 120 days of the date that you commence using materials containing Cr or Mn. This NOCS shall contain the information in paragraph e. (ii)(C)(I) - (ii)(C)(IV) above. iv. Annual Compliance Certification- An annual compliance certification report shall be prepared each year by March 1 for the previous year containing the information specified in A. - F. below. You shall submit the report to NC DAQ if you had any instances of paragraph C. or D. in that year. Keep one copy on site at all times. A. Company name and address. B. A statement by a responsible official with that official's name,title, phone number, email address, and signature certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all relevant standards and requirements. C. If the source is not in compliance,include a description of deviations from the applicable requirements,the time periods during which the deviations occurred, and the corrective actions taken. Permit No. 08155R09 Page 12 D. For NEW Sources -Identification of all instances when the daily inlet flow rate, inlet velocity, pressure drop, or fan amperage was outside the range that constitutes proper operation of the cyclone(s). In these instances, include the time periods when this occurred and the corrective actions taken. For EXISTING Sources - Rccords showing -- proper air pollution control practices and manufacturer's specifications and operating instructions (if available) or standard operating procedures developed by the facility owner or operator. E. If this facility is not required to install and operate cyclones on the pelleting operation due to average daily feed production of 50 tpd or less, a notification is required if the average daily feed production level for the previous year exceeded 50 tpd. If this occurs, a cyclone shall be installed and made operational by July 1 of the following -- year. F. If this facility is required to install and operate cyclones on the pelleting operation due to average daily feed production being greater than 50 tpd, a notification is required if the average daily feed production level for the previous year was 50 tpd or less and the facility is no lower required to comply with the cyclone requirements. g. 40 CFR 63.11624 c - Records. You shall maintain the following records on site: i. Records of all monthly and quarterly inspections and any corrective actions required by this Subpart shall be maintained in a logbook on site. ii. One copy of the Initial Notification and the NOCS on site at all times. iii. One copy of the Annual Compliance Certification on site at all times. iv. For each device used at the loadout end of a bulk loader(i.e., chutes/socks/ flex hose),you shall keep records including the following information: A. date, place,and time of each inspection. B. person performing the inspection. C. results of the inspection, including the date, time, and duration of the corrective action period from the time the inspection indicated a problem to the time of the indication that the device was replaced or restored to operation. Permit No. 08155R09 Page 13 V. For each cyclone installed,you shall keep records including the following information: A. For NEW Sources - If you demonstrate that the cyclone is designed to reduce emission of particulate matter(PM, not PM-10) by 95 percent or greater by manufacturer's specifications, you shall keep the records of: I. Information from the manufacturer regarding the design efficiency of the cyclone, II. The inlet flow rate, inlet velocity,pressure drop, or fan amperage range that represents proper operation of the cyclone, and - III. The operation and maintenance procedures to ensure proper operation of the cyclone. B. For NEW Sources - If you demonstrate that the cyclone is designed to reduce emissions of particulate matter by 95 percent or greater by certification by a professional engineer,you shall keep the records of: I. Certification regarding the design efficiency of the cyclone, along with supporting information, II. The inlet flow rate, inlet velocity, pressure drop, or fan amperage range that represents proper operation of the cyclone, and III. The standard maintenance and operating procedures that ensure proper operation of the cyclone. C. For NEW Sources - If you demonstrate that the cyclone is designed to reduce emissions of particulate matter by 95 percent or greater by a performance test, you shall keep the records of: I. Results of the testing conducted in accordance with § 63.11623 (Method 5), II. The inlet flow rate, inlet velocity, pressure drop, or fan amperage range that represents proper operation of the cyclone, and III. The standard maintenance and operating procedures that ensure proper operation of the cyclone. D. For NEW Sources - You shall keep records of all quarterly inspections, including the following: I. Date,place, and time of each inspection, Permit No. 08155R09 Page 14 II. Person performing the inspection, III. Records of the daily inlet flow rate, inlet velocity,pressure drop, or fan amperage measurements, and IV. Results of the inspection, including the date,time, and duration of the corrective action period from the time the inspection indicated a problem to the time of the indication that the cyclone was restored to proper operation. E. For EXISTING Sources - You shall keep records of all quarterly inspections, including the following: I. Date,place, and time of each inspection, II. Person performing the inspection, III. Records of the operation of the cyclone showing proper air pollution control practices and manufacturer's specifications and operating instructions were followed, if available, or standard operating procedures developed by the facility owner or operator were followed. IV. Results of the inspection, including the date, time; and duration of the corrective action period from the time the inspection indicated a problem to the time of the indication that the cyclone was restored to proper operation. V. Records of weekly visual inspections of the operating cyclone, including a record of any corrective action taken as a result of the inspection. vi. If daily feed production level is less than 50 tons per day,the source shall keep daily feed production records on site. (The Average Daily Feed Production Level is defined above.) The Notification of Compliance Status and/or ACC report shall indicate this level in the year that the daily feed production level is less than 50 tons per day. vii. Records shall be in a form suitable and readily available for expeditious review. All records shall be maintained for 5 years and shall be kept on-site for a minimum of 2 years. Records may be kept offsite for the remaining 3 years. Permit No. 08155R09 Page 15 viii. Per 40 CFR 63.11624(d) - Facilities that discontinue Cr and Mn after January 5, 2010 shall submit a Notification to the agency (NC DAQ)that they are no longer subject to the rule (indicating an effective date). The Notification shall include the Company's Name and Address, and a statement by a responsible official indicating that the facility no longer uses materials that contain Cr or Mn. This statement should also include an effective date for the termination of use of materials that contain Cr or Mn, and the responsible official's name, title, phone number, e-mail address and signature. 13. 15A NCAC 2D .I I I I "National Emission Standards for Hazardous Air Pollutants"- For the Generator, Onan D970636382 (ID No. ES-016),the Permittee shall comply with all applicable provisions, including the maintenance and recordkeeping requirements contained in Environmental Management Commission Standard 15ANCAC 2D .I 111, as promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines(RICE)", including Subpart A "General Provisions." The Permittee shall comply with the definition of emergency stationary RICE in 40 CFR 63.6675 and the following stationary RICE provisions. a. Compliance Date - The compliance date is May 3, 2013. b. Maintenance and Work Practices - Pursuant to 40 CFR 63.6603(a), 63.6625(e), (f), and (h) and 63.6640(f)the Permittee shall comply with the following: i. Change the oil and filter every 500 hours of operation or annually, whichever comes first. The Permittee has the option to utilize an oil analysis program as described in Section c. below in order to extend the specified oil change requirements. ii. Inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary. iii. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. j iv. Operate and maintain the engine and control device(if any) according to the manufacturer's emission related written instructions or maintenance plan developed by the Permittee that minimizes emissions from the engine to the extent practicable. V. Install a non-resettable hour meter if one is not already installed. vi. Minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. Permit No. 08155R09 Page 16 vii. If the engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedules required in Sections b.i.,b.ii., and b.iii., above, or if performing the management practice on the required schedules would otherwise pose an unacceptable risk under federal, state or local law, the management practices can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice shall be performed as soon as possible after the -- emergency has ended or the unacceptable risk has abated. The Permittee shall report any failure to perform the management practice on the schedule required and the federal, state, or local law under which the risk was deemed unacceptable. viii. If the Permittee does not operate the engine according to the requirements in Sections A. through C. below, then the engine will not be considered an. emergency engine under NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines. A. There is no time limit on the use in emergency situations. B. The Permittee may operate the engine for any combination of the purposes specified in Sections (i)through(iii) below for a maximum of 100 hours per calendar.year. (i) The engine may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission authority or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Division of Air Quality (DAQ) Regional Supervisor for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of the engine beyond 100 hours per calendar year. (ii) The engine may operate for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergency or other authorized entity as determined by the Reliability Coordinator has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. (iii) The engine may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Permit No. 08155R09 Page 17 C. Pursuant to 40 CFR 63.6640(f)(4),the engine may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in Section b.viii.B above. Except as provided in Sections (i) and(ii) below, the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for the facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. (i) Prior to May 3, 2014,the 50 hours per year for non-emergency situations can be used for peak shaving or non-emergency demand response to generate income for the facility, or to otherwise supply power as part of a financial arrangement with another entity if the engine is operated as part of a peak shaving (load management program)with the local distribution system operator and the power is provided only to the facility itself or to support the local distribution system. (ii) The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if ALL of the following conditions are met: (I) The engine is dispatched by the local balancing authority or local transmission or distribution system operator. . (II) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. (III) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC,regional, state,public utility commission or local standards or guidelines. (IV) The power is provided only to the facility itself or to support the local transmission and distribution system. (V) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state,public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. Permit No. 08155R09 Page 18 ix. At all times the Permittee shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to DAQ which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. c. Oil Analysis Program Pursuant to 40 CFR 63.6625(i),the Permittee may utilize an oil analysis program in order to extend the oil change requirements specified in Section b.i. above. The oil analysis must be performed at the same frequency specified for changing the oil. If any of the limits listed below are exceeded, the Permittee shall change the oil within two (2)business days of receiving the results of the analysis. If the engine is not in operation when the results of the analysis are received, then the oil must be changed within two (2) business days or before commencing operation, whichever is later. i. Total base number is less than 30 percent of the total base number of the oil when new; or ii. Viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or iii. Water content (by volume) is greater than 0.5%. If all of the above limits are not exceeded, the Permittee is not required to change the oil before continuing to use the engine. d. Fuel Requirements -Per 40 CFR 63.6604(b),beginning January 1, 2015, emergency engines that meet all the following conditions shall use diesel fuel that meets the requirements in 40 CFR 80.510(b) for nonroad diesel fuel i. Greater than 100 brake HP; ii. Displacement of less than 30 liters per cylinder; iii. Operates for the purposes specified in Section b.viii.C.ii. above or operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Sections b.viii.B.(ii) or b.viii.B.(iii) above. Permit No. 08155R09 Page 19 Any existing diesel fael purchased prior to January 1, 2015 may be used until depleted. The diesel fael requirements of 40 CFR 80.510(b) are shown below: FSulfur content 15 ppm maximum. E Cetane index or A minimum cetane index of 40; or omatic content A maximum aromatic content of 35 volume percent. e. Recordkeeping - Pursuant to 40 CFR 63.6655(d),(e) and(f),the Permittee shall keep records for at least five (5) years showing: i. The engine was operated and maintained according to the manufacturer's emission related operation and maintenance instructions or the Permittee's maintenance plan which must provide for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. ii. If applicable,the parameters that are analyzed as part of the oil analysis program, the results of the analysis, and the oil changes for the engine. iii. The hours of operation of the engine that is recorded through the non- resettable hour meter. The Permittee shall document how many hours are spent for emergency operation; including what classified the operation as .emergency and how many hours are spent for non-emergency operation. If the engine is used for purposes specified in.Sections b.viii.B.(ii), b.viii.B.(iii), or b.viii.C.(ii) above,then the Permittee shall keep records of the notification of the emergency situation, and the date, start time and end time of the engine operation for these purposes. f. Reporting- Pursuant to 40 CFR 63.6650(h), if the engine is greater than 100 brake HP that operates for the purposes specified in Section b.viii.C.(ii) above, or operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in Sections b.viii.B.(ii)or b.viii.B.(iii) above, the Permittee shall submit an annual report to the DAQ Regional Supervisor. The first annual report shall be submitted no later than March 31, 2016 and cover the calendar year 2015. Subsequent annual reports shall be submitted by March 31 of each year and cover the previous calendar year. Permit No. 08155R09 Page 20 The annual report must also be submitted electronically to EPA through the specific NESHAP Subpart ZZZZ reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX). However, if the reporting form specific to NESHAP Subpart ZZZZ is not available in CEDRI at the time that the report is due, the written report shall be submitted to EPA at the appropriate address listed in Section 63.13; EPA Region IV Director,Air, Pesticides and Toxics Management Division Atlanta Federal Center 61 Forsyth Street Atlanta, GA 30303-3104 The annual report shall contain the following information: i. Company name and address where the engine is located. ii. Date of the report and beginning and ending dates of the reporting period. iii. Engine site rated horsepower and model year for each engine. iv. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place. V. Hours operated for the purposes specified in Sections b.viii.B.(ii) and b.viii.B.(iii), including the date, start time, and end time for engine operation. vi. Number of hours the engine is contractually obligated to be available for the purposes specified in Sections Kviii.B.(ii)and b.viii.B.(iii). vii. Hours spent for operation for the purpose specified in Section b.viii.C.(ii) including the date, start time, and end time for engine operation. The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. viii. If there were no deviations from the fuel requirements in Section d. above that apply to the engine (if any), a statement that there were no deviations from the fuel requirements during the reporting period. ix. If there were deviations from the fuel requirements in Section d. that apply to the engine (if any), information on the number, duration, and cause of deviations, and the corrective action taken. Permit No. 08155R09 Page 21 14. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. 15. LIMITATION TO AVOID 15A NCAC 2Q .0501 -Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities, to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than the following: ..... .. u .N, PMio 100 a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the following restrictions shall apply: i. Throughput of the overall milling process shall not exceed 1,600,000 tons per consecutive 12-month period; ii. Throughput of the Grain Drying Process (ID No. ES-018) shall not exceed 200,000 tons per consecutive 12-month period; and iii. Throughput of the bagging operation(ID No. ES-022) shall not exceed 50,000 tons per consecutive 12-month period. b. Recordkeeping Requirements i. The Permittee shall record monthly and total annually the following: A. Overall milling process throughput, tons B. Grain Drying System (ID No. ES-018) throughput, tons I C. Bagging Operation(ID No. ES-22) throughput,tons i Permit No. 08155R09 Page 22 16. AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subs JJJJJJ -hi accordance with 15A NCAC 2Q .0317,the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ (6J) "Industrial, Commercial, and Institutional Boilers Area Sources." The Permittee is permitted to operate two natural gas/No. fuel oil- fired boilers (ID Nos. ES-013 and ES-014). Per 40 CFR 63.11195(e),these sources are exempt from this Subpart because they are defined as gas-fired boilers in 40 CFR 63.11237. In order to maintain this exemption, the Permittee is allowed to fire liquid fuel only during periods of gas curtailment,gas supply interruptions, startups, or for periodic testing on liquid fuel(periodic testing not to exceed a combined total of 48 hours during any calendar year). a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. b. If the Permittee fires liquid fuel for reasons other than gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel,the Permittee is no longer exempt from Subpart JJJJJJ (0). As required by 40 CFR 62.11225(g),the Permittee must provide notice within 30 days of the fuel switch. The notification must identify: i. The name of the owner or operator of the affected source,the location of the source, the boiler(s) that have switched fuels, and the date of the notice. ii. The date upon which the fuel switch occurred. As required by 40 CFR 63.11210(h),the Permittee must demonstrate compliance within 180 days of the effective date of the fuel switch. I Permit No. 08155R09 Page 23 17. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed toxic air pollutants (TAPs),the Permittee has made a demonstration that facility-wide actual emissions do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711. The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 2Q .0711. a. A permit to emit any of the below listed TAPS shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. b. PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible for obtaining a permit to emit TAPS and for demonstrating compliance with the requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants". c. In accordance with the approved application,the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: 'w Is Acetaldehyde (75 07 0) 6.8 Acrolein (107-02-8) 0.02 Ammonia(as NH3) (7664-41-7) 0.68 Benzene (71-43-2) . 8.1 — Benzo(a)pyrene(Component of 83329/POMTV& 56553/7PAH) 2.2 (50-32-8) -. .. ...... ............... 0.04 Formaldehyde (50-00-0) _ Hexane, n- (110-54-3) 7F 23 Toluene (10$ 88 3) 98 14.4 i Permit No. 08155R09 Page 24 B. GENERAL CONDITIONS AND LIMITATIONS 1. TWO COPIES OF ALL DOCUMENTS, REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to the: Regional Supervisor North Carolina Division of Air Quality Fayetteville Regional Office Systel Building 225 Green Street, Suite 714 Fayetteville,NC 28301-5094 910-433-3300 For identification purposes, each submittal should include the facility name as listed on the permit, the facility identification number, and the permit number. 2. RECORDS RETENTION REQUIREMENT - Any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years, unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUIPMENT RELOCATION - A new air permit shall be obtained by the Permittee prior to establishing, building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT- Any of the following that would result in previously unpermitted, new, or increased emissions must be reported to the Regional Supervisor, DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities; or c. changes in the quantity or quality of materials processed. 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. Permit No. 08155R09 Page 25 6. This permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect, conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred. The facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air pollution. Unless otherwise specified by this permit, no emission source may be operated without the concurrent operation of its associated air cleaning device(s) and appurtenances. 7. This permit is nontransferable by the Permittee. Future owners and operators must obtain a new air permit from the DAQ. 8. This issuance of this permit in no way absolves the Pere-ttee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. 9. This permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority. 10. Reports on the operation and maintenance of the facility shall be submitted by the Permittee to the Regional Supervisor,DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include, but is not limited to, process weight rates, firing rates,hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection, and who presents appropriate credentials, nor shall any person obstruct, hamper, or interfere with any such representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. The Permittee must comply with any applicable Federal, State, or Local requirements governing the handling, disposal, or incineration of hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act(RCRA) administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT - The Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ,upon request,the current copy of the air permit for the site. Permit No. 08155R09 Page 26 15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS -Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. 16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY- Pursuant to Title I Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of Accidental Releases -Purpose and General Duty," although a risk management plan may not be required, if the Permittee produces,processes, handles, or stores any amount of a listed hazardous substance,the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is fcdcrally-enforceable only. 17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing to the DAQ in support of a permit application or to demonstrate compliance, the Permittee shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ procedures including protocol approval, regional notification, report submittal, and test results approval. Permit issued this the 15t of August, 2014. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Steven F. Vozzo Regional Supervisor By Authority of the Environmental Management Commission Air Permit No. 081551109 ATTACHMENT to Permit No. 08155R09, August 1, 2014 Insignificant/Exempt Activities I TA TES-108 - Storage Silos 2Q .0102 (c)(2)(E)(ii) No Yes TES-107 - Storage Silos 2Q .0102 (c)(2)(E)(ii) r No Yes TES -1 - Storage Silos 2Q .0102 (c)(2)(E)(ii) No Yes TES-104 Storage Silos 2Q .0102 (c)(2)(E)(ii) No Yes TES-103 - Storage Silos 2Q .0102 (c)(2)(E)(ii) No Yes .... TES-102 - Storage Silos 2Q .01.02 (c)(2)(E)(ii) No Yes .. TES-101 - Storage Silos 2Q .0102 (c)(2)(E)(ii) No Yes 1. Because an activity is exempted from being required to have a permit or permit modification does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable, emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates Requiring a Permit." I i