AQ_F_1000126_20191126_PRMT_Permit

ROY COOPER ;ti"�STRrt��
Governor
l `
MICHAEL S.REGAN �• � _ �� ,;
Secretory
MICHAEL A.ABRAC71NSKAS NORTH CAROLINA
Director Environmental Quallity
November 26, 2019
Ms.Alison Marwitz
Senior Regulatory Specialist II
Ecolab Fumigation at MOTSU
655 Lane Oak Drive
Eagan, MN 55121.
Subject: Air Permit No. 10640R00
Ecolab Fumigation at MOTSU
Southport, Brunswick County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 1000126
Dear Ms. Marwitz:
In accordance with your completed application received November 22, 2019,we are
forwarding herewith Permit No. 10640R00 to Ecolab Fumigation at MOTSU, Southport, Brunswick
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. Snch 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. 1.50B-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. 150E-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 descrihed in this permit must be covered under a permit issued by the Division orAir
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
North Cara Iina Qeparlmeat of Environmental Quality I ❑ivision of Air❑uality
E Wilmington Regional Office 1 127 Cardinal drive Extension I Wilmington,NC 28405
910.788.7215 T 1 910.350.2004 F

Alison Marwitz
November 26, 2019
Page 2
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 November 26, 2019 until October 31, 2027, 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 a Teen field permit at the Military Ocean
Terminal at Sunny Poirot MOTSU or a methyl bromide himigation operation. 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 Dean Carroll at 910-
796-7242.
Sincerely,
l
Brad Newland, ilmington Regional Supervisor
Division of Air Quality,NC DEQ
Enclosures
c: Wilmington Regional Office - DAQ file
WiRO Permit Coordinator
Ibeam Doc Mod

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 1.O54OROO
Issue Date: November 26, 2019 Effective Date: November 26, 2019
Expiration Date: October 31, 2027 Replaces Permit: (new) ,
To construct and operate air emission source(s) and/or air cleaning devices), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21B of Chapter 143, General Statutes of North Carolina (NCGS)as amended, and other
applicable Laws, Rules and Regulations,
Ecolab Fumigation at MOTSU
6280 Sunny Point Road SE
Southport, Brunswick County, North Carolina
Permit Class: Synthetic Minor
Facility ID4 1000126
(the Permittee)is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-FUM-1 one fumigation operation utilizing methyl
bromide(MB)on impoWexport ��' N/A
commodities in shipping containers;this (multiple ten foot (multiple ten foot stacks in
fumigation operation will be portable and stacks in various places but staggered various places but staggered
will use MB cylinders,tarps,blowers,and aeration}
flexible ductwork aeration}
_....._. _._.. ._ ._._ _._ ._ ..__ ._ _.....—_... x..............._..... .., ,....... . .._........... .............
..- ..._.._._
in accordance with the completed application 1000126.19A received November 22, 2019 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environmental Quality, Division of Air Quality(DAQ) and are incorporated
as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC),Subchapter
213 .0202, 2I3 .0535, 2I3 .0540, and 2Q .0315.

Permit No. 10640ROO
Page 2
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 20 .0304(d) and (f). Pursuant to 15A NCAC 20
.0203(i),no permit application fee is required for renewal of an existing air permit (without
a modification request). The renewal request(with application Form A) 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 2026 calendar year.
3. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535,the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
4. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints are received or excessive
fugitive dust emissions from the facility are observed beyond the property boundaries for six
minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A), the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(1).
"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).

Permit No. 10640R00
Page 3
5. LIMITATION TO AVOID 15A NCAC 20 .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 Title V Permit," as requested by the Permittee,facility-wide
emissions shall be less than the following:
Pollutant Emission Limit
!(Tons per consecutive 12-monthperiod)
Individual HAPs
(methyl bromide} 10
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. The actual amount of methyl bromide used at the facility shall be less 10 tons
per consecutive 12-month periods. (this is a ruuning monthly total of 12
months of methyl bromide use.)
ii. Per the applicant, all of the methyl bromide used is assumed to be emitted.
b. Recordkeeping Requirements
i. The Permittee shall record monthly and total annually (for the previous 12
months) the following:
A. the actual amount of methyl bromide used at this facility.
c. Reporting Requirements -Within 30 days after each calendar year quarter, regardless
of the actual emissions,the Permittee shall submit the following:
i. emissions and/or operational data; the data should include monthly and 12
month totals for the previous 14 months.The data must be calculated for each
of the thrce 12 month periods over the previous 14 months.
G. Pursuant to 15A NCAC 02Q .0308 "Final Action on Permit Applications", as requested by
the Permittee, the facility shall comply with the following operating conditions:
1. The distance of the nearest fumigation pad to the property boundary at the base for
methyl bromide fumigation shall be no less than 4,000 feet.
2. Multiple emission stacks shall be employed with a minimum height of 10 feet.
These stacks may be located at different places and utilized at the same time.
3. The optimum dispersion time of day shall be utilized for aeration activities,being
mid-day from 10 am to G pm. Further, aeration shall be staggered every hour during
this time period (after the fumigation period has been completed).
4. No more than 90 lb/hr methyl bromide shall be aerated facility widc.It is assumed
that 100 % of all the methyl bromide used will be emitted, and in the first hour.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1),TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR

Permit No. 10640R00
Page 4
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-In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall he maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT-Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay
the annual Permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION- In accordance with 15A NCAC 20 .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING RE UIREMENT-In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional'Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or Processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed,or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-21.5.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effectuate 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.

Permit No. 10640R00
Page 5
7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605,reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include,but is not limited to,process weight rates,firing rates, hours of
Operation, and preventive maintenance schedules.
11. A violation of any term or condition of[his 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[he DAQ who requests entry or access for
purposes of inspection,and who presents appropriate credentials,nor shall any person
obstruct, hamper,or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid,or medical wastes,
including the Resource Conservation and Recovery Act(RCRA)administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT-In accordance with 15A NCAC 2Q .0110, the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ,upon request, the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 11.2(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

Permit No. 10640R00
Page b
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 iu 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.Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the 26'h day of November, 2019.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Brad Newl• n
Wilmington egional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 10640R00