AQ_F_0400061_20210624_PRMT_PmtApp

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Cavanaugh&Associates, P.A.
PO Box 11197 400el,
Winston Salem, NC 27116 C AVA N A U G H
www.CavanaughSolutions.com Stewaf:: ;�,; :;gh innov—
June 17, 2021
VIA ELECTRONIC DELIVERY AND MAIL RECEIVED
Heather Carter JUN 2 4 2021
Regional Supervisor, Fayetteville Regional Office
NCDEQ Division of Air Quality DEQ-FAYMEVILLE REGIONAL OFFICE
225 Green Street, Suite 714
Fayetteville, NC 28301
RE: Catawba Biogas, LLC
Air Permit No. 10593R00
Revised Application for Section .0300 Permit Modification
Dear Mrs. Carter,
This revised permit application for Catawba Biogas, LLC follows an email from Jeffrey Cole of the Division
of Air Quality, Fayetteville Regional Office on June 16, 2021, requesting that a revised permit application
be submitted to address two concerns: (1)the design of the CD-1 biogas flare and (2) control of
hydrogen sulfide (H2S) emissions during gas upgrading system downtime.
An application was submitted for Catawba Biogas on May 28, 2021, which proposed a limitation on the
daily volume of biogas combusted in the biogas flare when the CD-2 hydrogen sulfide removal system is
not operating.This limitation would allow the facility to remain below the 5.1 lb/day H2S emission rate
requiring a permit to emit toxic air pollutants defined in 15A NCAC 02Q.0711(b) for unobstructed,
vertically oriented emission release points. The CD-1 enclosed flare selected for the Catawba Biogas
facility is both unobstructed and vertically oriented, and thus 15A NCAC 02Q.0711(b) is applicable.The
proposed flare is a John Zink Company Enclosed ZTOF° Flare System.The enclosed flare is not equipped
with a rain cap and the flow of flue gas from the flare will be unobstructed. A standard manufacturer
drawing of the enclosed flare is enclosed with the revised permit application for reference. An
Applications Engineer with John Zink Company was contacted to verify that the flare is unobstructed.An
email from the Engineer confirmed that the flare is "unobstructed" and "open."
As stated, the 5.1 lb/day H2S emission limit will be met by limiting the volume of biogas combusted in
the CD-1 biogas flare when the hydrogen sulfide removal system is not operating. Combustion of biogas
without gas upgrading is anticipated to occur primarily during facility commissioning and during repairs
to the gas upgrading system.The anaerobic digesters are designed to allow at least one day of biogas
storage at the maximum production rate.The feedstock supply to the digester system will be promptly
reduced during gas upgrading system or hydrogen sulfide removal system downtime to decrease the
biogas production rate. It is not commercially attractive for the facility to utilize purchased feedstocks at
the maximum rate to produce biogas that will be flared onsite.Thus,the facility is financially
incentivized to, and will, limit the feedstock supply to the digester system when the gas upgrading
system is not operational.The feedstock supply to the digester system is carefully managed and
Page 1 of 2

controlled at the facility using a series of processing steps.The heated digesters used at the Catawba
Biogas facility respond quickly to changes in feedstock supply, and considerable changes in biogas
production begin to occur within hours after the feedstock feed rate is changed.This type of response is
expected for mixed, heated digester systems that are designed for high-rate feedstock conversion using
shorter retention times. Additionally, digester effluent is drained from the system each day and can be
drained from the digesters to provide additional headspace for biogas storage.To significantly reduce
biogas production, digester effluent can be drained from the tanks while the feedstock feed rate is
reduced, which would provide significantly increased biogas storage capacity (several days to over a
week) and reduced biogas production. Scheduled preventative maintenance activities for the gas
upgrading system will be used to prevent prolonged system downtime and to minimize the volume of
biogas that is flared at the facility by aligning repairs with reduced feedstock supply to the system.
Control►ing the rate of feedstock supply to the digester system will be used to reduce biogas production
during gas upgrading system downtime and allow the facility to comply with the daily limitation on the
volume of biogas combusted in CD-1 when the hydrogen sulfide removal system is not operational.
As requested, a revised permit application is enclosed below to incorporate the information presented
in this letter.The application fee for a small facility was included with the previous application submitted
to the Fayetteville Regional Office on May 28, 2021.Thank you for your assistance. Please contact me
with any further questions.
Regards,
Benjamin Cauthen, E.I.
Bioenergy Project Engineer
Cavanaugh &Associates, P.A.
www.ravanaughSolutions.com Page 2 of 2

Catawba Biogas, LLC Air Permit Modification June 17, 2021
Air Permit No. 10593R00
Overview of Air Permit Modification
This permit modification aims to limit the operation of the biogas flare(CD-1),which is both
unobstructed and vertically oriented,at the Catawba Biogas facility when the flare is used to combust
raw, unprocessed biogas, so that the flare does not exceed the emission rate for hydrogen sulfide (1-12S)
as defined in 15A NCAC 02Q.0711(b). During normal operation when the hydrogen sulfide removal
system (CD-2) is operating,the facility does not have the potential to exceed the hydrogen sulfide
emission rate of 5.1 Ibs/day defined in 15A NCAC 02Q.0711.Therefore,the proposed limitations only
apply to the facility when it is combusting unprocessed biogas that has not been treated using the
hydrogen sulfide removal system. It should be noted that, as this is a commercial facility, it is not
required to provide continuous operations, and can limit, reduce, or otherwise modify the facility
operations to reduce the amount of biogas produced by the facility as needed to ensure compliance
with 15A NCAC 02Q.0711.
The completed permit application for Catawba Biogas(0400061.18A) submitted to the Division of Air
Quality showed a potential hydrogen sulfide emission rate of 0.245 Ibs/hr when the flare is used to
combust the maximum flow rate of unprocessed biogas without hydrogen sulfide removal. If operated
for 24 hours at that emission rate,the facility would emit 5.9 Ibs/day of hydrogen sulfide which exceeds
the 5.1 Ibs/day emission rate defined in 15A NCAC 02Q.0711. This permit modification proposes to limit
the operation of the facility, using a limitation on the daily volume of biogas flared, so that the emission
rate is no longer exceeded. This limit to the operations can be further safeguarded by reducing the
biogas output of the facility through feedstock supply reduction and other process controls to slow the
anaerobic digestion process, which have a direct impact on biogas production.
Proposed Limitation
The following limitation is proposed for the Catawba Biogas facility as part of this permit modification.
The limitation will be used to maintain a hydrogen sulfide emission rate below 5.1 Ibs/day.
• Operating Limitation: When the hydrogen sulfide removal system (CD-2) is not operating,the
facility will combust no greater than 1,130,400 standard cubic feet(scf) of unprocessed biogas in
the biogas flare (CD-1) per 24-hour day.
The hydrogen sulfide emission rate calculations provided below show that the limitation listed above
will result in an emission rate below 5.1 Ibs/day.To ensure the limitation is enforced,the facility will
record the total volume of unprocessed biogas combusted in the flare each day to ensure the volume
listed above is not exceeded. Biogas flow to the flare will be stopped when the volume of unprocessed
biogas flared equals the volume defined above in the Operating Limitation. It should be noted that the
purpose of this facility is to upgrade biogas to renewable natural gas for injection into the existing
pipeline network, and it is to the commercial benefit of the facility to limit the flaring of its biogas to the
greatest extent practical. Flaring unprocessed biogas is to the financial detriment of the facility, and
thus,the facility operators will work diligently to limit such flaring.
The anaerobic digesters at the facility are designed to allow at least one day of biogas storage; meaning
that there is sufficient headspace in each digester to store the maximum expected biogas flow rate for
one day. Obviously, if the facility is operating at less than maximum capacity,the available headspace
Page 1 of 2

1
Catawba Bi ogas, LLC Air Permit Modification June 17, 2021
Air Permit No. 10593R00
provides for more than one day's production. During commissioning and startup when the facility is
anticipated to flare the greatest volume of unprocessed biogas,the anaerobic digesters are anticipated
to produce noticeably less than the maximum rated volume of biogas, and thus,the facility will be able
to store biogas and remain within the limitation defined above. When the facility reaches steady-state
operation and greater biogas production is achieved,the hydrogen sulfide removal system will be fully
commissioned and operational to remove hydrogen sulfide from the gas. The facility can ensure
compliance with the limitation set forth in the requested modified permit by reducing feedstock supply
to the anaerobic digesters to decrease biogas production for a period of time. The rate of feedstock
supply to the digester system is controlled at the facility using the feedstock processing equipment.The
digesters used at the facility are heated, mixed tanks that are designed for minimal feedstock retention
time and high-rate feedstock conversion. When the feedstock supply to the digesters is reduced, the
biological process will respond immediately and biogas production will be significantly reduced within
several hours.This reduction in biogas production occurs because the available feedstock in the
digesters for conversion to biogas has been reduced. Additionally, effluent is drained daily from the
digester system which reduces the liquid level in the digester and provides additional headspace for
biogas storage when the rate of feedstock supply has been reduced. Control of the feedstock supply to
the digester and reducing the liquid level in the digester system will enable the facility to reduce any
biogas flared to meet the limitation described above on a continuous basis.
Emission Rate Calculations
Detailed calculations for the limitation listed above are provided with this application to determine the
resulting H2S emission rate.The H2S emission rate resulting from the Operating Limitation is 5.0 Ibs/day.
The emission rate was calculated using a daily flared unprocessed biogas volume of 1,130,400 scf and a
biogas H2S concentration of 2,500 ppm.The daily volume would result in an average biogas flow rate to
the flare of 785 standard cubic feet per minute (scfm),which is 85%of the rated biogas volume of 924
scfm.This reduction in biogas production (85%of the rated capacity) can be achieved and maintained by
reducing the feedstock supply to the digester and lowering the liquid level in the digesters to create
additional headspace in times when the hydrogen sulfide removal system is not operational.
Application Documents
The additional documents provided as part of this modification are listed below.
A. NCDEQ Division of Air Quality Permit Application Forms
a. Form A
b. Form A2
c. Form D1
d. Form D5
B. H2S Emission Rate Calculation
C. John Zink Company Enclosed ZTOF Flare Standard Drawing
Page 2 of 2

FORM A
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
NOTE-APPLICATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING:
❑ Local Zoning Consistency Determination Appropriate Number of Copies of Application Application Fee(please check one option below)or modification only)
Responsible Official/Authorized Contact Signature ❑ P.E.Seal(if required) ❑ Not Required _ePayment ❑✓ Check Enclosed
GENERAL INFORMATION
Legal Corporate/Owner Name: Catawba Biogas,LLC
Site Name: Catawba Biogas,LLC
Site Address(911 Address)Line 1: 1133 Blewett Falls Road
Site Address Line 2:
City: Lilesville State: NC
Zip Code: 28091 County: Anson
CONTACT INFORMATION
Responsible Official/Authorized Contact: Invoice Contact:
Name/Title: Ted Niblock Name/Title: Ted Niblock
Mailing Address Line 1: PO Box 11197 Mailing Address Line 1: PO Box 11197
Mailing Address Line 2: Mailing Address Line 2:
City: Winston Salem State: NC Zip Code: 27116 City: Winston Salem State: NC Zip Code: 27116
Primary Phone No.: 215-932-8017 Fax No.: None Primary Phone No.: 215-932-8017 Fax No.: None
Secondary Phone No.: None Secondary Phone No.: None
Email Address: [e-mail] Email Address: [e-mail]
Facility/Inspection Contact: Permit/Technical Contact:
Name/Title: Ted Niblock Name/Title: Ted Niblock
Mailing Address Line 1: PO Box 11197 Mailing Address Line 1: PO Box 11197
Mailing Address Line 2: Mailing Address Line 2:
City: Winston Salem State: NC Zip Code: 27116 City: Winston Salem State: NC Zip Code: 27116
Primary Phone No.: 215-932-8017 Fax No.: None Primary Phone No.: 215-932-8017 Fax No.: None
Secondary Phone No.: None Secondary Phone No.: None
Email Address: [e-mail] Email Address: [e-mail]
APPLICATION IS BEING MADE FOR
New Non-permitted Facility/Greenfield Modification of Facility(permitted) J Renewal Title V ❑ Renewal Non-Title V
❑ Name Change Ownership Change ❑ Administrative Amendment ❑ Renewal with Modification
FACILITY CLASSIFICATION AFTER APPLICATION(Check Only One)
General Ld Small L✓ Prohibitory Small L-1 Synthetic Minor L Title V
FACILITY(Plant Site)INFORMATION
Describe nature of(plant site)operation(s):The plant will generate biomethane,also referred to as renewable natural gas(RNG),through the anaerobic digestion of poultry waste.The raw biogas will
undergo cleaning steps to upgrade it to RNG.The RNG will be injected into the existing natural gas pipeline and combusted off-site for electricity generation.The non-methane constituents of the biogas
will be combusted at the plant with one shrouded flare using natural gas as pilot fuel.The digestate and wastewater will undergo multiple conditioning steps.The digestate will be used offsite as an organic
fertilizer.The heat needed to run the process will be generated using a natural gas-fired boiler.The point sources of air emissions will be the shrouded flare and the natural gas-fired boiler.
Facility ID No.0400061
Primary SIC/NAICS Code:211130 Current/Previous Air Permit No.10593R00 Expiration Date:September 30,2027
Facility Coordinates: Latitude:34.971239 Longitude:-79.915973
Does this application contain ***If yes,please contact the DAQ Regional Office prior to submitting this
confidential data?
❑ YES NO application.*** (See Instructions)
PERSON OR FIRM THAT PREPARED APPLICATION
Person Name: Gus Simmons Firm Name:Cavanaugh&Associates,P.A.
Mailing Address Line 1:PO Box 11197 Mailing Address Line 2:
City:Winston Salem State:NC Zip Code:27116 County:Forsyth
Phone No.: 877-557-8923 Fax No.: None Email Address:[e-mail]
SIGNATURE OF RESPONSIBLE OFFICIAL/AUTHORIZED CONTACT
Name(typed):Ted Niblock Title:Manager
X Signature(Blue Ink): �� Date:
June 17,2021
Attach Additional Sheets As Necessary Page 1 of 2

FORM A (continued, page 2 of 2)
GENERAL FACILITY INFORMATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A
SECTION AA1 -APPLICATION FOR NON-TITLE V PERMIT RENEWAL
(Company Name)hereby formally requests renewal of Air Permit No.
There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
Is your facility subject to 40 CFR Part 68"Prevnetion of Accidental Releases"-Section 112(r)of the Clean Air Act? ❑ YES ❑ NO
If yes,have you already submitted a Risk Manage Plan(RMP)to EPA? ❑ YES ❑ NO Date Submitted:
Did you attach a current emissions inventory? ❑ YES NO
If no,did you submit the inventory via AERO or by mail? ❑ Via AERO ❑ Mailed Date Mailed:
SECTION AA2-APPLICATION FOR TITLE V PERMIT RENEWAL
In accordance with the provisions of Title 15A 2Q.0513,the responsible official of (Company Name)
hereby formally requests renewal of Air Permit No. (Air Permit No.)and further certifies that:
(1) The current air quality permit identifies and describes all emissions units at the above subject facility,except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 2Q.0500;
(2) The current air quality permit cits all applicable requirements and provides the method or methods for determing compliance with the applicable
requirements;
(3) The facility is currently in compliance,and shall continue to comply,with all applicable requiremetns. (Note: As provided under 15A NCAC 2Q.0512
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit);
(4) For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis;
(5) The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64.
The responsible official(signature on page 1)certifies under the penalty of law that all information and statements provided above,based on information and belief
formed after reasonable inquiry,are true,accurate,and complete.
SECTION AA3-APPLICATION FOR NAME CHANGE
New Facility Name:
Former Facility Name:
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been
modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if ther has been an ownership change
associated with this name change.
SECTION AA4-APPLICATION FOR AN OWNERSHIP CHANGE
By this application we hereby request transfer of Air Quality Permit No. from the former owner to the new owner as described below.
The transfer of permit responsibility,coverage and liability shall be effective (immediately or insert date.) The legal ownership of the
facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally
permitted facility that would require an air quality permit since the last permit was issued.
Signature of New(Buyer)Responsible Official/Authorized Contact(as typed on page 1):
X Signature(Blue Ink):
Date:
New Facility Name:
Former Facility Name:
Signature of Former(Seller)Responsible Official/Authorized Contact:
Name(typed or print):
Title:
X Signature(Blue Ink):
Date:
Former Legal Corporate/Owner Name:
In lieu of the seller's signature on this form,a letter may be submitted with the seller's signature indicating the ownership change
SECTION AA5-APPLICATION FOR ADMINISTRATIVE AMENDMENT
Describe the requested administrative amendment here(attach additional documents as necessary):
Attach Additional Sheets As Necessary Page 2 of 2

FORMs A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION -A2
112r APPLICABILITY INFORMATION -A3
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate A2
EMISSION SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted
EMISSION SOURCE EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE
ID NO. DESCRIPTION I ID NO. DESCRIPTION
Equipment To Be ADDED By This Application (New, Previously Unpermitted, or Replacement)
ES-1 Natural Gas-Fired Boiler
ES-2 Biogas Production Equipment CD-1,CD-2 One Shrouded Flare,Hydrogen Sulfide Removal Vessel
ES-3 Waste Liquefaction System
Existing Permitted Equipment To Be MODIFIED By This Application
Equipment To Be DELETED By This Application
112(r) APPLICABILITY INFORMATION A3
Is your facility subject to 40 CFR Part 68"Prevention of Accidental Releases"-Section 112(r)of the Federal Clean Air Act? Ll Yes No
If No,please specify in detail how your facility avoided applicability: The ammonia water stored at the facility will not exceed the threshold ammonia
concentration of 20%.The maximum ammonia concentration will be 19%.
If your facility is Subject to 112(r),please complete the following:
A. Have you already submitted a Risk Management Plan(RMP)to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150?
❑ Yes ❑ No Specify required RMP submittal date: If submitted,RMP submittal date:
B. Are you using administrative controls to subject your facility to a lesser 112(r)program standard?
['I Yes ❑ No If yes,please specify:
C. List the processes subject to 112(r)at your facility:
PROCESS LEVEL MAXIMUM INTENDED INVENTORY
PROCESS DESCRIPTION (1,2,or 3) HAZARDOUS CHEMICAL (LBS)
Attach Additional Sheets As Necessary

FORM D1
FACILITY-WIDE EMISSIONS SUMMARY
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D1
CRITERIA AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
AIR POLLUTANT EMITTED tons/yr tons/yr tons/yr
PARTICULATE MATTER(PM) 0.08 0.17 0.08
PARTICULATE MATTER<10 MICRONS(PM10) 0.03 0.14 0.07
PARTICULATE MATTER<2.5 MICRONS(PM2 5) 0.07 0.14 0.07
SULFUR DIOXIDE(S02) 1.91 98.90 1.91
NITROGEN OXIDES(NOx) 16.51 32.73 16.52
CARBON MONOXIDE(CO) 13.71 27.32 13.71
VOLATILE ORGANIC COMPOUNDS(VOC) 0.90 1.79 0.90
LEAD
GREENHOUSE GASES(GHG)(SHORT TONS)
OTHER
HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
EXPECTED ACTUAL
EMISSIONS POTENTIAL EMISSIONS POTENTIAL EMISSIONS
(AFTER CONTROLS/ (BEFORE CONTROLS/ (AFTER CONTROLS/
LIMITATIONS) LIMITATIONS) LIMITATIONS)
HAZARDOUS AIR POLLUTANT EMITTED CAS NO. tons/yr tons/yr tons/yr
Acetaldehyde(TH) 75070 2.48E-06 4.94E-06 2.48E-06
Acrolein(TH) 107028 2.94E-06 5.86E-06 2.94E-06
Ammonia(T) 7664417 6.24E-01 1.15E+00 6.24E-01
Arsenic unlisted compounds (TH) ASC-other 0.00E+00 0.00E+00 0.00E+00
Benzene(TH) 71432 3.43E-04 6.83E-04 3.43E-04
Benzo(a)pyrene (TH) 50328 1.96E-07 3.90E-07 1.96E-07
Beryllium metal(unreacted)(TH) 7440417 0.00E+00 0.00E+00 0.00E+00
Cadmium metal(elemental unreacted) (TH) 7440439 0.00E+00 0.00E+00 0.00E+00
Chromic acid(VI)(TH) 7738945 0.00E+00 0.00E+00 0.00E+00
Cobalt unlisted compounds(H) COC-other 1.37E-05 2.73E-05 1.37E-05
Formaldehyde(TH) 50000 1.22E-02 2.44E-02 1.22E-02
Hexane,n-(TH) 110543 2.94E-01 5.86E-01 2.94E-01
Lead unlisted compounds(H) PBC-other 8.16E-05 1.63E-04 8.16E-05
Manganese unlisted compounds(TH) MNC-other 0.00E+00 0.00E+00 0.00E+00
Mercury vapor (TH) 7439976 0.00E+00 0.00E+00 0.00E+00
Napthalene (H) 91203 9.96E-05 1.98E-04 9.96E-05
Nickel metal (TH) 7440020 0.00E+00 0.00E+00 0.00E+00
Selenium compounds(H) SEC 3.92E-06 7.81 E-06 3.92E-06
Toluene(TH) 108883 5.55E-04 1.11E-03 5.55E-04
Highest HAP-Ammonia 7664417 6.24E-01 1.15E+00 6.24E-01
Total HAPs 9.31E-01 1.76E+00 9.31E-01
TOXIC AIR POLLUTANT EMISSIONS INFORMATION-FACILITY-WIDE
INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS/LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE(TPER)IN 15A NCAC 2Q.0711
MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY.
Modeling Required?
TOXIC AIR POLLUTANT EMITTED CAS NO. Ib/hr lb/day lb/year Yes No
Acetaldehyde(TH) 75070 6.72E-07 1.61 E-05 4.96E-03 X
Acrolein(TH) 107028 7.96E-07 1.91E-05 5.88E-03 X
Ammonia(T) 7664417 1.66E-01 3.98E+00 1.25E+03 X
Arsenic unlisted compounds (TH) ASC-other 0.00E+00 0.00E+00 0.00E+00 X
Benzene(TH) 71432 9.28E-05 2.23E-03 6.86E-01 X
Benzo(a)pyrene (TH) 50328 5.30E-08 1.27E-06 3.92E-04 X
Beryllium metal(unreacted)(TH) 7440417 0.00E+00 0.00E+00 0.00E+00 X
Cadmium metal(elemental unreacted) (TH) 7440439 0.00E+00 0.00E+00 0.00E+00 X
Soluble chromate compounds,as chromium(VI)equivalent SoICR6 0.00E+00 0.00E+00 0.00E+00 X

Formaldehyde(TH) 50000 3.32E-03 7.96E-02 2.45E+01 X
Hexane,n-(TH) 110543 7.96E-02 1.91 E+00 5.88E+02 X
Hydrogen Sulfide 7783064 2.45E-01 5.00E+00 2.03E-02 X
Manganese unlisted compounds(TH) MNC-other 0.00E+00 0.00E+00 0.00E+00 X
Mercury vapor (TH) 7439976 0.00E+00 0.00E+00 0.00E+00 X
Nickel metal (TH) 7440020 0.00E+00 0.00E+00 0.00E+00 X
Toluene(TH) 108883 1.50E-04 3.61 E-03 1.11 E+00 X
Total TAPs 4.94E-01 1.10E+01 1.86E+031 I X
COMMENTS:
Attach Additional Sheets As Necessary

FORM D5
TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION
REVISED 09/22/16 NCDEQ/Division of Air Quality-Application for Air Permit to Construct/Operate D5
PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION,CONTROL,AND REGULATORY
DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM AS
NECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS. ADDRESS THE
FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:
A SPECIFIC EMISSIONS SOURCE(EMISSION INFORMATION)(FORM B and B1 through 1139)-SHOW CALCULATIONS USED,INCLUDING EMISSION
FACTORS, MATERIAL BALANCES,AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APPLICATION WERE DERIVED.
INCLUDE CALCULATION OF POTENTIAL BEFORE AND,WHERE APPLICABLE,AFTER CONTROLS. CLEARLY STATE ANY ASSUMPTIONS MADE AND
PROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS.
B SPECIFIC EMISSION SOURCE(REGULATORY INFORMATION)(FORM E2-TITLE V ONLY)-PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLE
TO INDIVIDUAL SOURCES AND THE FACILITY AS A WHOLE. INCLUDE A DISCUSSION OUTING METHODS(e.g.FOR TESTING AND/OR MONITORING
REQUIREMENTS)FOR COMPLYING WITH APPLICABLE REGULATIONS, PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON
PROCESS RATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONS(PREVENTION
OF SIGNIFICANT DETERIORATION(PSD),NEW SOURCE PERFORMANCE STANDARDS(NSPS),NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
POLLUTANTS(NESHAPS),TITLE V),INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BE APPLICABLE TO
THIS FACILITY. SUBMIT ANY REQUIRED INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS. INCLUDE EMISSION RATES
CALCULATED IN ITEM"A"ABOVE,DATES OF MANUFACTURE,CONTROL EQUIPMENT,ETC.TO SUPPORT THESE CALCULATIONS.
C CONTROL DEVICE ANALYSIS(FORM C and C1 through C9)-PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANY
CONTROL EFFICIENCIES LISTED ON SECTION C FORMS,OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEM"A"ABOVE. INCLUDE
PERTINENT OPERATING PARAMETERS(e.g.OPERATING CONDITIONS,MANUFACTURING RECOMMENDATIONS,AND PARAMETERS AS APPLIED FOR IN
THIS APPLICATION)CRITICAL TO ENSURING PROPER PERFORMANCE OF THE CONTROL DEVICES). INCLUDE AND LIMITATIONS OR MALFUNCTION
POTENTIAL FOR THE PARTICULAR CONTROL DEVICES AS EMPLOYED AT THIS FACILITY. DETAIL PROCEDURES FOR ASSURING PROPER OPERATION
OF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED.
I
D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS-(FORM E3-TITLE V ONLY)-SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USING
PROCESS,OPERATIONAL,OR OTHER DATA TO DEMONSTRATE COMPLIANCE.REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY
ANALYSIS IN ITEM"B"WHERE APPROPRIATE. LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TO
DEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS.
E PROFESSIONAL ENGINEERING SEAL- PURSUANT TO 15A NCAC 2Q.0112"APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL,"
A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FOR
NEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES. (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY).
l William G. Simmons, Jr., P.E. attest that this application for Catawba Biogas, LLC
has been reviewed by me and is accurate,complete and consistent with the information supplied
in the engineering plans, calculations, and all other supporting documentation to the best of my knowledge. I further attest that to the best of my knowledge the
proposed design has been prepared in accordance with the applicable regulations. Although certain portions of this submittal package may have been developed by
other professionals,inclusion of these materials under my seal signifies that I have reviewed this material and have judged it to be consistent with the proposed
design. Note: In accordance with NC General Statutes 143-215.6A and 143-215.6B,any person who knowingly makes any false statement,representation,or
certification in any application shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed$10,000 as well as civil penalties up to$25,000 per
violation.
(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING) PLACE NORTH CAROLINA SEAL HERE
NAME: William G. Simmons, Jr., P.E.
DATE: May 27, 2021 ����®®®�b®$�������
COMPANY: Cavanaugh & Associates, P.A. ffhgs
1%, ��� �
ADDRESS: _PO Box 11197 Winston Salem, NC 27116
TELEPHONE: [phone]
SIGNATURE: M S AL
PAGES CERTIFIED: 2S "Erm�issionate Calculation
(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENT #00#0 its" Z��
THAT IS BEING CERTIFIED BY THIS SEAL)
Attach Additional Sheets As Necessary

H,S Emission Rate Calculation for Operating Limitation
Daily Biogas Production to Flare: 1,130,400 scf/da
Biogas H2S Concentration: 2,500 ppm
Daily Biogas H2S to Flare: 2,826 scf/day
Biogas H2S Load to Flare: 250 Ibs/day See Equation 1 below.
Flare Oxidation Efficiency: 98 %
H2S Emission Rate: 5.00 Ibs/day
Equation 1: m —
MWxPxV
R x T
where: m = mass flow rate (Ibs/day)
MW = H2S molecular weight= 34.08 Ib/Ibmol
P= standard pressure = 14.7 psia
V=volumetric H2S production (scf/day)
R= gas constant= 10.73 (psia*ft3)/(Ibmol*R)
T= standard temperature =528 R
a
r

6 5 4 3 2 1
PARTS LIST
LUG DETAIL 1" 2'-1' 2'-1" 1' REM QTY DESCRIPTION MK:NO MATERIAL
SEE LIFTING 1 1 ENCLOSED ZTDF FLARE 0-701-1
EL 40'-0 7/8' 0' 1 t 20 2 4 8'FLARE TIP D-ST-1329-1
NS ONLY 3 1 PILOT ASSEMBLY ST11916-1
4 1 2"SIGHT PORT CA-ST-0600-1
5 1 SWIVEL SCANNER MOUNT ASSEMBLY CA-ST-1044-1
6 4 GASKET:8'150/RF x 1/16"THK G8-150-R NON-ASB
2T� C8 E 36'-6" - _"C12 C13 N10 I N8 1 1 7 32 BOLT,STUD:3/4"x 4 1/2'LG(PLATED) 58-6-4 1/2 A-193-87
D 1 TCV C5 .v 8 64 NUT,HVY HEX:3/4-IONC(PLATED) SN-6 A-194-2H
§"-- 9 4 BOLT,HEX HD:5/8"x 2 1/2"LG(PLATED) HB-5-2 1/2 A-307
202A a5' "' 19 12 _ _
10 4 NUT,REG HEX:5/8-11NC(PLATED) HN-5 A-307
305 N3 C4 I I I C6 N5 ONLY I - 11 10 BOLT,HEX HD:3/8"x 1 1/4"LG(PLATED) HB-3-1 1/4 A-307
6 PLACES 12 18 NUT,REG HEX:3/8-16NC(PLATED) HN-3 A-307
i 69. 13 4 BOLT,HEX HD:1/4'x 1"LG(PLATED) HB-2-1 A-307
BL-204 \ C13 14 4 NUT,REG HEX:1/4-20NC(PLATED) HN-2 A-307
C11 11 20 4'-0' 15 2 SCREW,HEX HO MACH:/10-24NC x 3/4'LG(PLATED)HCS-OID-3/4 A-307
I PNL-103 11 12 16 1 3/8"COPPER TUBING x 1'-0'LG COPPER
N5 ONLY 4'-4" 17 1 MALE CONNECTOR,1/9"NPT x 3/8'TUBING BRASS
8 PLACES 18 1 MALE ELBOW CONNECTOR,1/2"NPT x 3/8"TUBING BRASS
202E —_ - -
TE CB T' 270' Nt DAMPER FRAME DETAIL 19 6 SCREW,FLAT HD.SL 3/8-NC x 1'LC.(PLATED) FH-3 1 A-307
N2 _ N4 N5 20 2 WING NUT:3/8-i6NC(PLATED) WN-3 A-307
C9
1 C10CS 11t'
O1 1/4"PLATE 15 I _FE EL 4'_3 9/16
(A-36) I NOZZLE LEGEND
I 20I MK QTY DESCRIPTION
TE 16 I Ni 1 GAS CONNECTION:8"150f F.F.
C 202C 7'-0"O.D. TCV 17 j C4 N2 1 PILOT MTG CONN:3/8"PLATE FLG W 3"150 DRILLING
C11 CID 1 Q" I Preliminary and Confidential N5 C12 202B 16 _ �EL 3'-0" N3 1 BLOWER-8"CONN 10'O.D.x 3 8"PL W 4 3/8"STUDS ON 9 1/8"B.C. C
159' N3 12 N4-5 2 DAMPER CONN-SEE DETAIL N5 HINGED
TE PLAN VIEW 1 ® NB 11 4 FLARE TIP CONN-8'150/Rf
201 1
TRUE ORIENTATION RESTRICTION
ORIFICE 3" C2 1 PILOT GAS'CONNT W1/2 LUG
I 6" C4 1 PURGE CAIRDPRESSURE CONN FNPT
BL-204 1/2"FNPT
C5 1 SCANNER CONN-1/2"MNPT
PURGE AIR BLOWER DETAIL C6 1 SIGHT PORT-2'MNPT
SHIPPED LOOSE FOR CB-11 4 THERMOCOUPLE CONN-1"FNPT
1 SEE DAMPER FIELD INSTALLATION C12-13 2 SAMPLE PORT 4"FNPT WITH PLUG
SEE IGNITION FRAME DETAIL A BE
PANEL DETAIL I 203
EL 5'-9" DESIGN DATA
I 12 C5 5 „ WINDLOAD(PER ASCE 7-95,EXP.C) 110 M.P.N.
NS 12 i� SEISMIC(PER UBC-1994) ZONE 4
'¢'�i' z 13 74 SHEAR 0 BASE 9.5 K
I Irk.N4 N71 a MOMENT 0 BASE 180.0 K-FT
N1 EL 1'-6= SEE PURGE AIR EL 3'-10 3/8' NB
BLOWER DETAIL 2 2 EL 2'-10 1/8' N10 SHELL
15.0 K
B EL O'-O' 10 9 N2 - I - N9 SHELL DESIGN TEMPERATURE 500 F
IGNITION PANEL DETAIL B
B CORROSION ALLOWANCE 0.0
�L SHIPPED LOOSE FOR
6'-8"I.D. SEE BASE 3 C3 N4 NS LIFTING.NOT S
PLATE DETAIL FIELD INSTALLATION A;MAIN CRANE AT TOP REQUIRES SPREADER BAR,(NOT SUPPLIED BY JOHN ZINK CO.)
7'-4"B.C. Ni " B:CHOKE STACK AT APPROX.5'-0"EL WITH TAILING CRANE
TCV TCV C:LIFTING LUGS DESIGNED FOR 13 1/2 TON CROSBY ANCHOR SHACKLE AND
7'-B'O.D. C2 202A 2028 VERTICAL SLINGS.
ELEVATION 6"BOT 7 6 SHIPPED LOOSE FOR R7 7?, 1 5/8"0 HOLE INSULATION LEGEND
FIELD INSTALLATION
NOT TRUE ORIENTATION A:(1)OVERLAPPING LAYER OF 1"THICK 8 LB DENSITY,230D'F.BACKED WITH
g
C1 (1)LAYER,1"THICK 6 LB DENSITY,2300'F.ON INCONEL PINS AND KEEPERS.
4'-6" 3'-8' 8" I a B:(1)OVERLAPPING LAYER OF 1"THICK 6 LB DENSITY,2301Y F.ON INCONEL PINS ry
(N1 PROJECTION) AND KEEPERS.
PARTIAL SECTIONAL ELEVATION 3/4"PL.(A-36) GENERAL NOT s $
NOT TRUE ORIENTATION 1.TAG NUMBERS TO BE PRECEDED BY JOHN ZINK SALES ORDER NUMBER. $
345' 0' 15' 2.FLARE ASSEMBLY IS NOT TO BE USED AS AN ANCHOR POINT FOR CUSTOMER PIPING.
3.PRE-TENSION ANCHOR BOLTS BY THE'TURN OF THE NUT'METHOD/AISC.
315' 45' SEE INSULATION LEGEND B LIFTING LUG DETAIL 4.BOLT HOLES TO STRADDLE NORMAL CENTER LINES UNLESS NOTED. e
285' I 75 FILL BOTTOM OF STACK L�(12)1 1/4"P HOLES (2 REO'D.LOCATED AT 90'AND 270') 5.FINISH EXTERIOR CARBON STEEL,INSIDE OF SKIRT,BOTTOM OF FLOOR R
( (NOTE:CUT OFF LUGS AFTER STACK ERECTION) PLATE,AND MANIFOLD.SANDBLAST PER SSPC-SP-6 AND PRIME WITH R
__ ___ WITH PEA GRAVEL(NOT FOR 10 ANCHOR BOLTS SHERWIN WILLIAMS ZINC CLAD DOT INORGANIC ZINC RICH PRIMER N0. $
270 SUPPLIED BY JOHN ZINK CO.) (NOT SUPPLIED BY JOHN ZINK CO.) B69VZ20/069VZIB/B69D11(2-4 MILS D.F.T.)
A 255' i 105, I 3/8"PLATE A-36 FOR PARTS AND SERVICE:• TEL:1-ODO-755-4252•FAX:[phone]M [4MJOHN ZINK HAMWOFITHY ,
v (12)ON CENTERLINE e
225' 135' o Tii{x ima,m�0I= .4«I. JOHN
ZINKS COMPANY, LLC
195't8D,165' m bm.e1.m...M
b , -Zx
FOR:
ENCLOSED ZTOF FLARE
C. .r.uI a. l nt
a t_. USER: a
7'-0"O.D. x 40' H.
x\'1 onYl mornne eno�u.,O c..
FOUNDATION BOLT PATTER 7'-4" .c 6
P•rP..•.nm....00,ct h JOBSRE:
Allen P.rmluion 1 JMn 2N1,
"C.•P•ny. xl.ab.m DRAWN: CH x: APP: SHEET -
poM,yMurn•0 b JMn I
x0I6..hnn ZW�p.ro. S.O.W.6F- DATE: aTE: p1TF' 1 Of x
BASE PATE DETA��DETAIL LLC.Ax Hpm.wn.e. P.O.NO: ORNAW WNKR RE
NO. REVISION OESCRIPiION Br CHK All 047E SCALE NOT 70 SCALE D-F-XXXXXXX-301 0 g
6 5 2 1