AQ_F_1600149_20140421_PRMT_Permit

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
April 21, 2014
Mr. Michael Herz
VP/Infrastructure
WFNC1 Project US LLC
4700 Homewood Court, Suite 320
Raleigh,NC 27609
Subject: Air Permit No. 10338ROI
WFNC1 Project US LLC
Morehead City, Carteret County,North Carolina
Permit Class: Small
Facility ID# 1600149
Dear Mr. Herz:
In accordance with your completed application received March 18, 2014, we are forwarding
herewith Permit No. 10338R01 to WFNC1 Project US LLC, Morehead City, Carteret County,
North Carolina for the construction and operation of air emissions sources or air cleaning devices
and appurtenances. 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
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
Wilmington Regional Office-Division of Air Quality
127 Cardinal Drive Extension,Wilmington,North Carolina 28405
Phone:[phone]/FAX:[phone]
Internet:www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper

Michael Herz
April 21, 2014
Page 2
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from April 21, 2014 until October 31, 2021, is nontransferable
to future owners and operators, and shall be subject to the conditions and limitations as specified
therein.
This permit is the result of a request for an ownership change with a request to add
another dome headhouse (#2) (emission source ID ES-TP#4), and fabric filter(Control System
Description CD-FF-041. The Permittee is responsible for carefully reading the entire permit
and evaluating the requirements of each permit stipulation. The Permittee shall comply with
all terms, conditions, requirements, limitations and restrictions set forth in this permit.
Noncompliance with any permit condition is grounds for enforcement action, for permit
termination, revocation and reissuance, or modification, or for denial of a permit renewal
application.
Should you have any questions concerning this matter,please contact Linda Willis at (910)
796-7235.
Sincerely,
Brad Newland
Wilmington Regional Supervisor
Division of Air Quality
Enclosures
c: Wilmington Regional Office
WiRO Permit Coordinator
IBeam Doc Mod

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 10338ROI
Issue Date: April 21, 2014 Effective Date: April 21, 2014
Expiration Date: October 31, 2021 Replaces Permit: 10338R00
To construct and operate air emission source(s)and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
WFNC1 Project US LLC
113 Arendell Street
Morehead City, Carteret County,North Carolina
Permit Class: Small
Facility ID# 1600149
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission 1 Emission Source Control Control System
Source ID j Description ; System ID j Description
ES-TP#1 lassociated
Railcar unloading and !CD-FF-01 jCD-FF-01 Fabric Filter
conveyor system '(3,117 square feet of filter
!area)
DES-TP#2 (Transfer Building#1 ICD-FF-02 1CD-FF-02 Fabric Filter(866
square feet of filter area)
DES-TP#3 Dome#1 Headhouse and CD-FF-03 CD-FF-03 One Fabric Filter
associated conveyor system (866 square feet of filter
area)
ES-TP#4 Dome#2 Headhouse and CD-FF-04 ICD-FF-04 One Fabric Filter
! associated conveyor system (866 square feet of filter
(area)
!ES-TP#5 IDome Reclaim Transfer CD-FF-05 One fabric filter(6,495
(Building#2 ( square feet of filter area)
in accordance with the completed application 1600149.14A received March 18, 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.

Permit No. 10338ROI
Page 2
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0515, 2D .0521, 2D .0535, 2D .0540, 213 .0611, and 2D .1806.
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 2020 calendar year.
3. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the emission sources shall not exceed 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(lbs/hr).
E=4.10 * (P) 0 ' for P <= 30 tons/hr, or
E =55 X (P) all- 40 for P >30 tons/hr
4. 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 213 .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
5. 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:

Permit No. 10338ROI
Page 3
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
6. 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).
7. 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. Recordkee iinng_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.

Permit No. 10338ROI
Page 4
The logbook(in written or electronic format) shall be kept on-site and made
available to DAQ personnel upon request.
8. 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.
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
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington,NC 28405
910-796-7215
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.

Permit No. 10338R0I
Page 5
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. 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 Permittee of liability for any potential
civil penalties which may be assessed for violations of State law which have occurred prior
to the effective date of this permit.
9. 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, 143-215.11413, 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. 10338R0I
Page 6
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 I I2(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases - Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces,processes, handles, or stores any amount of a listed
hazardous substance, the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance, the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification, report submittal, and test
results approval.
Permit issued this the 21S`of April, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
rad Newla d
Wilmington Regional Superv'sor
Division of Air Quality
By Authority of the Environmental Management Commission
Air Permit No. 10338R0I