AQ_F_0800044_20221214_PRMT_PmtRvw_21A

NORTH CAROLINA DIVISION OF Region: Washington Regional Office
AIR QUALITY County: Bertie
Application Review NC Facility ID: 0800044
Inspector's Name: Betsy Huddleston
Issue Date: December 14,2022 Date of Last Inspection: 09/18/2020
Com liance Code: 3/Compliance-inspection
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Avoca LLC SIP: 15A NCAC 02D .0503,.0504, .0515, .0516,
.0521, .0614,and.1806
Facility Address: NSPS: 15A NCAC 02D .0524-Subpart Dc
Avoca LLC NESHAP: 15A NCAC 02D .1111 -Subpart FFFF,
841 Avoca Farm Road ZZZZ,and DDDDD
Merry Hill,NC 27957 PSD: 15A NCAC 02D .0530
PSD Avoidance: N/A
SIC:2087/Flavoring Extracts And Syrups,nec NC Toxics: 15A NCAC 02D .1100
NAILS: 31193/Flavoring Syrup and Concentrate Manufacturing 112(r): N/A
Other: N/A
Facility Classification:Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0800044.21A
Brian Conner Augustinus Gerritsen Brian Conner Date Received: 06/30/2021Application Type: Renewal
EH&S Manager Vice President EH&S Manager
[phone] [phone] [phone] Application Schedule: TV-Renewal
PO Box 129 PO Box 129 PO Box 129 Existing Permit Data
Merry Hill,NC 27957 Merry Hill,NC 27957 Merry Hill,NC 27957 Existing Permit Number: 01819/T53
Existing Permit Issue Date: 08/06/2019
Existing Permit Expiration Date: 12/31/2021
Total Actual emissions in TONSIYEAR:
CY S02 NOX vOC CO PM10 Total HAP Largest HAP
2019 2.67 31.81 1403.40 23.73 0.3540 303.38 264.35
[Methanol(methyl alcohol)]
2018 2.57 30.93 1280.53 20.88 0.5840 368.93 299.66
[Methanol(methyl alcohol)]
2017 3.20 34.63 1268.61 25.45 0.5040 353.95 298.22
[Methanol(methyl alcohol)]
2016 2.67 30.68 1221.52 21.50 0.5050 338.82 269.99
[Methanol(methyl alcohol)]
2015 3.10 33.91 939.80 24.70 0.5350 263.87 207.17
[Methanol(methyl alcohol)]
Review Engineer: David B.Hughes Comments/Recommendations:
Issue 01819/T54
Review Engineer's Signature: Date: December 14,2022 Permit Issue Date: December 14,2022
Permit Expiration Date: November 30,2027

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I. Purpose of Applications
Application No. 0800044.21A
This permitting action is a renewal of an existing Title V permit pursuant to 02Q .0513. The existing
Title V permit(01819T53)was issued on August 6,2019,with an expiration date of December 31,
2021. The renewal application 0800044.21A was received on June 30,2021, or at least six months
prior to the original expiration date December 31,2021. Therefore,the existing permit shall not
expire until the renewal permit has been issued or denied. All terms and conditions of the existing
permit shall remain in effect until the renewal permit has been issued or denied.
II. Facility Description
Avoca owns and operates a facility located at 841 Avoca Farm Road,Merry Hill,North Carolina.
The Avoca facility extracts oils and nutrients from various types of plants for use in flavorings,
fragrances, food additives,and dietary supplements. The main product of the facility is sclareol
which is extracted from sage grown on farms in counties surrounding the Avoca Plant.
The process operations at the facility include rotocel,recovery, sclareol re-crystallization(SFG),
sclareolide(SDE-1 and 2),plant nutrient extraction(PNE), ethyl vanillin glucoside(EVG),botanical
extraction, and biomass extraction. Miscellaneous operations include;two No. 2 fuel oil-fired boilers
(ID Nos. H-101 and H-102,20.3 million Btu per hour heat input each), one propane-fired boiler(ID
No. H-104, 33.5 million Btu per hour),two biomass boilers(ID Nos. ES-BB1 and ES-BB2),24
million Btu per hour heat input each), four No. 2 fuel oil-fired emergency generators(ID Nos. E101,
E102, E104 and E105), one No. 2 fuel oil-fired fire water pump(ID No. FP), one wastewater
treatment plant aeration tank(ID No. WWTP-AT1), and one flaker deconditioner(ID No. ES-DEC-
2001).
Avoca has requested the following updates to the current permit.
1. Permit Condition 2.1 A—The permit conditions include 15A NCAC 02D .1109 for Case-by-Case
MACT for the boilers. This requirement expired in May 19,2019 with the replacement of the
federal MACT 40 CFR 63, Subpart DDDDD and thus Avoca requests to remove this condition
from the table and permit.
2. Permit Condition 2.1 E—The permit conditions for the two biomass boilers ES-BB 1 and ES-BB2
currently indicate that they are subject to 15A NCAC 02D .0503. When the boilers were initially
installed,they were permitted to fire sage(a plant material)and wood. The firing of sage was not
successful,and thus the boilers are now fired with 100%wood. A such, 15A NCAC 02D .0504 is
applicable to the biomass boilers instead of 02D .0503. Avoca requests to update in the current
permit
3. The current permit does not denote that the Biomass Extraction Operations are subject to 40 CFR
Part 63 Subpart FFFF in the Table in Section 1. Permit Condition 2.1 D does list biomass
extraction as subject to Subpart FFFF as well as in Permit Condition 2.2.C. Avoca request adding
40 Part 65 Subpart FFFF applicability to the Table in Section 1.
The Division of Air Quality(DAQ)has reviewed and accepted these requests. The updates have been
implemented into the new Title V Air Permit No. 01819T54.
III.History/Background/Application Chronology

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January 12,2017—Permit No. 01819T47 issued as a Title V renewal.
July 27,2017—Permit No. 01819T48 issued as an administrative amendment. Ownership change
from Avoca, Inc. to Ashland, LLC. No change to the facility name has been requested,therefore,
remains Avoca, Inc.
April 26,2019—Betsy Huddleston of the Winston-Salem Regional Office (WaRO) completed the
annual compliance inspection of the facility.
August 17,2017—Permit No. 01819T49 issued as a Minor Modification Permit. For the
modification,updated emission sources (existing and new equipment) and added Primary and
Secondary Operating Scenarios to emission sources in Section 2.1 B.1 and 2.1 D.
April 17,2018—Permit No. 01819T50 issued as an administrative amendment. Changed facility
name from Avoca, Inc.to Avoca LLC.
September 4,2018-Permit No. 01819T51 issued as a Minor Modification Permit. For the
modification, added a new Flaker Deconditioner(ID No. ES-DEC-2001)controlled by a simple
cyclone(ID No. CD-MHZ-2001).
April 22,2019—Permit No. 01819T52 issued as a Minor Modification Permit. For the modification,
replaced existing No. 2 fuel oil-fired boiler(ID No. H-103)with a new propane-fired boiler(ID No.
H-104). Also includes an alternative operating scenario for monitoring of the chilled water condenser
(ID No. CD-4002) and mineral oil scrubber(ID No. CD-4003-5)installed on the new sclareolide
operations(ID No. SDE-2).
August 6,2019—Permit No. 01819T53 issued as a Minor Modification Permit. For the
modification,removed an existing No. 2 fuel oil-fired rotary dryer(ID No. ES-RD) and simple
cyclone(ID No. CD-BB I C).
June 30,2021—DAQ received Permit Application 4100772.21A, as a Title V renewal. The
application was deemed complete for processing.
March 4,2022 -DRAFT permit sent to Permittee, Supervisor,WSRO and Samir Parekh for
comment. Brian Conner(Avoca LLC)provided comments on draft permit and review via e-mail on
April 4,2022. Samir Parekh provided comments pertaining to CAM via email on March 14,2022.
Betsy Huddleston(WaRO)provided comments on the air permit review on March 29,2022.
July 26,2022—Sent updated DRAFT permit to Dale Overcash for review. Incorporated the latest
permit language from Joe Voelker. The new language is for emission sources—Two No. 2 fuel oil-
fired boilers (ID Nos. H-101 and H-102)(2.1 A.5 -MACT 40 CFR 63, Subpart DDDDD), One
Propane-fired boiler(ID No. H-104)(2.1 A.4-NSPS 40 CFR 60, Subpart Dc and 2.1 A.6 -MACT
40 CFR 63, Subpart DDDDD), One diesel-fired emergency generator(ID No. E105) and one
associated catalytic oxidizer(ID No. CD-CatOxl) (2.1 B.3—MACT 40 CFR 63, Subpart ZZZZ),and
Two biomass boilers(ID Nos. ES-13131 and ES-13132)controlled by bagfilter(ID No. CD-BB1BH)
(2.1 EA—NSPS 40 CFR 60, Subpart Dc and 2.1 E.5—MACT 40 CFR 63, Subpart DDDDD).
August 3,2022—Dale Overcash sent his comments via email regarding the two No. 2 fuel oil-fired
boilers(ID Nos. H-101,H-102, and H-104)and two biomass boilers(ID Nos. ES-BB1 and ES-13132).

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August 12,2022—Teams meeting with Dale Overcash,David B. Hughes, and Joseph Voelker to
discuss language for Air Permit No. 01819T54 regarding Ultra Low Sulfur Liquid(USLD) for two
No. 2 fuel oil-fired boilers(ID Nos. H-101 &H-102), one propane-fired boiler(ID No. H-104) and
two biomass boilers (ID Nos. ES-BB 1 &ES-BB2).
September 9,2022—David B. Hughes sent Dale Overcash the most recent draft with language
regarding USLD for two No. 2 fuel oil-fired boilers(ID Nos. H-101,H-102), one propane-fired boiler
(ID No. H-104), and two biomass boilers(ID No. ES-BB1 and ES-13132)for his review before
sending to Public Notice and EPA review.
September 27,2022—Dale Overcash sent David B. Hughes a email confirming that the Air Permit
No. 01819T54 was acceptable to send to Public Notice and EPA Review.
October 6,2022 -Draft permit and review sent to 30-day public comment and 45-day EPA review
periods.
November 5,2022-30-day public comment period ended;no comments received.
November 20,2022—45-day EPA Review period ended;no comments received.
December 13,2022—Jenny Sheppard(DAQ)updated TVEE.
December 14,2022—Air Permit No. 01819T54 issued as a Title V permit.
IV. Permit Modifications/Changes and WEE Discussion
The following table provides a summary of the changes to the permit.
Page No. Section Description of Changes
Global Global -Updated the application number and complete date.
-Updated permit revision number to T54.
-Updated the issuance/effective dates to permit.
Cover Letter Cover Letter -Updated PSD increment tracking statement.
3 List of Acronyms -Moved List of Acronyms from end of permit.
4- 9 Section 1 -Removed 15A NCAC 02D .1109 1120); Case-by-Case MACT
Equipment Table designations.
-Removed footnotes 3 and 4 due to the fact the dates are past
due for Case-by-Case MACT and MACT DDDDD.
-Removed footnotes 5, 6,and 7. The minor modifications are
being subjected to public and EPA review with this renewal
process; therefore,receiving the permit shield.
-Added MACT FFFF applicability to emission sources(ID Nos.
MHZ-1002, ES-1004-1, ES-1004-2-F, ES-1004-2-WW, ES-
1004-2Silo, and ES-MSDU-1024).
-Changed One No. 2 fuel oil-fired emergency generator ID No.
from ES-PkGenl to E105.
-Moved Three No. 2 oil-fired emergency generators (ID Nos.
E101, E102, and E103) and One No. 2 fuel oil-fired emergency
fire water pump (ID No.FP)to Insignificant Activities list.

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Page No. Section Description of Changes
10 2.1 A -Removed 15A NCAC 02D .1109 1120); Case-by-Case
Table MACT.
--- 2.1 A.4 -Removed 15A NCAC 02D .1109 1120); Case-by-Case
MACT.
11 2.1 A.4 -Updated 40 CFR Part 60 Subpart Dc shell language for one
propane-fired boiler(ID No. H-104).
11 - 15 2.1 A.5 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
two No. 2 fuel oil-fired boilers(ID Nos. H-101 and H-102).
15 - 17 2.1 A.6 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
one propane-fired boiler(ID No. H-104).
18 2.1 B -Changed One No. 2 fuel oil-fired emergency generator ID No.
from ES-PkGenl to E105.
18 2.1 B -Removed 15A NCAC 02Q .0317 to avoid 15A NCAC 02D
Table .0530.
18 2.1 B.La&c -Changed One No. 2 fuel oil-fired emergency generator ID No.
2.1 B.2.a&c from ES-PkGenl to E105.
2.1 B.3.a
18 2.1 B.3 -Updated 40 CFR Part 63 Subpart ZZZZ language for one
diesel-fired emergency generator(ID No. E105).
--- 2.1 B.4 -Removed 15A NCAC 02Q .0317: AVOIDANCE
CONDTIONS to avoid 15A NCAC 02D .0530: PREVENTION
OF SIGNIFICANT DETERIORATION.
25 2.1 E -Replaced 15A NCAC 02D .0503 with 15A NCAC 02D .0504.
Table
25 &26 2.1 E.1 -Replaced 15A NCAC 02D .0503 language with 15A NCAC
02D .0504 language.
27 2.1 EA -Updated 40 CFR Part 60 Subpart Dc shell language for two
biomass boilers(ID Nos. ES-BB 1 &ES-13132).
27 -32 2.1 E.5 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
two biomass boilers (ID Nos. ES-BB 1 &ES-13132).
--- 2.1 F -Removed Three Emergency Generators and Fire Water Pump
(ID Nos. E101,E102,E104, &FP)from permit and added
them to the Insignificant Activities list.
37 2.1 I.l.c.ii -Removed annual internal inspection for cyclone (ID No. CD-
MHZ-2001). DAQ doesn't require annual internal inspections
for cyclones that aren't equipped with a door.
62 & 63 Section 3 -Moved Insignificant Activities list and removed footnote 3.
Insignificant -Moved Three No. 2 oil-fired emergency generators(ID Nos.
Activities E101, E102, and E103) and One No. 2 fuel oil-fired emergency
fire water pump (ID No. FP)to Insignificant Activities list to
permit.
64- 72 Section 4 -Updated shell conditions(v6.0, 01/07/2022).
General Conditions
There were significant modifications to the equipment descriptions needed in Title V Equipment
Editor(TVEE).

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V. Regulatory Review
The facility is currently subject to the following regulations:
15A NCAC 02D .0503, "Particulates from Fuel Burning Indirect Heat Exchangers"
15A NCAC 02D .0504, "Particulates from Wood Burning Indirect Heat Exchangers"
15A NCAC 02D .0515, "Particulates from Miscellaneous Industrial Processes"
15A NCAC 02D .0516, "Sulfur Dioxide Emissions from Combustion Sources"
15A NCAC 02D .0521, "Control of Visible Emissions"
15A NCAC 02D .0524,New Source Performance Standards(40 CFR 60, Subparts Dc)
15A NCAC 02D .0530, "Prevention of Significant Deterioration"
15A NCAC 02D .0614, "Compliance Assurance Monitoring"
15A NCAC 02D .1100, Control of Toxic Air Pollutants (State-Enforceable Only)
15A NCAC 02D .1111, "Maximum Achievable Control Technology(40 CFR 63, Subparts FFFF,
ZZZZ, and DDDDD)"
15A NCAC 02D .1806, "Control and Prohibition of Odorous Emissions" (State-Enforceable Only)
A. Two No.2 Fuel Oil-fired Boilers (ID Nos. H-101 and H-102) and One Propane-fired
Boiler(ID No. H-104)
1. 15A NCAC 02D .0503—Particulates from Fuel Burning Indirect Heat Exchangers
Emissions of particulate matter(PM)from the combustion of No.2 fuel oil that are discharged from
the sources into the atmosphere from boilers(ID Nos.H-101 and H-102)shall not exceed 0.37
pounds per million Btu(lb/MMBtu)input. Emissions of PM from the combustion of propane that
are discharged from the sources in to the atmosphere from boiler(ID No.H-104)shall not exceed
0.33 lb/MMBtu heat input. The AP-42 emission factor for particulate emitted from No.2 fuel oil
combustion is 0.014 lb/MMBtu(at 140,000 Btu/gal). Propane particulate emissions are considered
negligible(NC LPG combustion spreadsheet cites 0.00053 lb/MMBtu). There are no
monitoring/recordkeeping/reporting conditions for the boilers under this rule in the permit.
Continued compliance is expected.
2. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources
The sulfur dioxide(S02)emitted by the boilers shall not exceed 2.3 lb/MMBtu heat input. The AP-
42 factor for No.2 fuel oil sulfur dioxide emission is 0.5 lb/MMBtu(sulfur content is less than 0.5%
and heat content is assumed approximately 140,000 Btu/gal). There are no
monitoring/recordkeeping/reporting conditions for the boilers under this rule in the permit.
Continued compliance is expected.
3. 15A NCAC 02D .0521 —Control of Visible Emissions
Boilers H-101 and H-102 are limited to an opacity of 40%. Boiler H-103 is limited to 20%opacity.
The limits may not be exceeded more than once in any hour and not more than four times in any 24-
hour period. There are no permit monitoring/recordkeeping/reporting requirements for the boilers
under this rule. Continued compliance is expected.

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4. 15A NCAC 02D .0524—New Source Performance Standards(40 CFR Part 60, Subpart Dc—
Standards of Performance for New Stationary Sources
See Section VI.for discussion.
5. 15A NCAC 02D .1111—Maximum Achievable Control Technology(40 CFR Part 63, Subpart
DDDDD—National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial,
Commercial,and Institutional Boilers and Process Heaters
See Section VI.for more details.
B. Emergency Engines/Generators (ID Nos.E101,E102,E104, & FP)and E105)
1. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources
The sulfur dioxide emitted by the generators shall not exceed 2.3 lb/MMBtu heat input. The S02
AP-42 emission factor from large engines(>500 hp)is 0.5 lb/MMBtu. These engines fire ultra-low
sulfur diesel. There are no monitoring/recordkeeping/reporting conditions under this rule in the
permit for the engines. Continued compliance is expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
The engines are all limited to an opacity of 20%. The limits may not be exceeded more than once
in any hour and not more than four times in any 24-hour period. There are no
monitoring/recordkeeping/reporting requirements for the engines under this rule. Continued
compliance is expected.
3. 15A NCAC 02D .1111 —Maximum Achievable Control Technology 40 CFR Part 63, Subpart
ZZZZ—National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion En ig nes
See Section VI.for more details.
4. 15A NCAC 020 .0317: Avoidance Conditions to avoid 15A NCAC 02D.0530: Prevention of
Siwnificant Deterioration
Emergency generator(ID No.E105)is currently subject to this regulation. However,Joseph
Voelker of Raleigh Central Office Permitting Section of DAQ ran the Potential to Emit(PTE)
calculations at 500 hour per year for an emergency engine(consistent with EPA and DAQ policy for
permitting)and using the DAQ spreadsheet,the PTE for all PSD pollutants are well under the PSD
significance theresholds. As such no PSD avoidance is necessary for this emergency engine. The
regulation has been removed from the permit.
C. Rotocel Operations,including:
• Rotocel extractor, desolventizer, and solvent separation/recovery(ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No. CD-1001-2-S-1);
• Two storage and recycle tanks (ID No. ES-M-125A and M-125B) and one associated chilled
water condenser(ID No. CD-1001-2-C-1)venting to one packed tower scrubber(ID No. CD-
1001-2-S-1);

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• Process equipment leaks(ID No. ES-100 1-2-1-F); and
• Rotocel Operations wastewater stream(ID No. ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1)and one associated chilled water condenser
(ID No. CD-1001-1-3)venting to one packed tower scrubber(ID No. CD-1001-2-S-1);
• One chilled water condenser(ID No. CD-1001-1-T5B)venting to packed tower scrubber(ID
No. CD-100 1-2-S-1) controlling emissions from:
Stripper T-5 and receiver M-21 (ID No. ES-100 1-1-1-P2); and
Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(ID No. ES-1001-1-1-P3);
• Process equipment leaks(ID No. ES-100 1-1-1-F); and
• Recovery Operations wastewater stream(ID No. ES-1001-1-1-WW)
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration
See Section VI.for more details.
2. 15A NCAC 02D .0614—Compliance Assurance Monitoring
See Section VI.for more details.
3. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Only
See Section VII. for more details.
4. 15A NCAC 020 .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
5. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001,desolventizer Z-1002,day tank 90024,first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks
of various capacities(ID No.ES-1001-11-1-P)and one associated chilled water condenser(ID
No. CD-1001-I I-EX 1002)venting to one cryogenic(nitrogen)condenser system(ID No. CD-
1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagfilter (ID No.CD-1003-4-
1);
• Process equipment leaks(ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream(ID No. ES-1001-11-WW)

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Biomass Extraction Operations, including:
• Biomass extraction debagging(ID No. ES-1004-1) and one associated cartridge filter(ID No.
CD-1004-1-17171);
PrimM Operating Scenario(POS)
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, iso-hexane storage
tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation
column EX-490008 and nine process tanks of various capacities(ID No.ES-1004-2-P)and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen)condenser system(ID No. CD-1004-2EX 1003);
Secondary Operating Scenario(SOS)
• Immersion extractor Z-41001, day tank 490025, storage tank 490024, first-stage evaporator
EX-4102, second stage evaporator EX-41013, distillation column EX-490008, nine process
tanks of various capacities (ID No. ES-1004-2-P); tray dryer (RV-1002) equipped with a
bagfilter(DC-1001)vented to a condenser(HX-1001) and a solvent knockout pot(TK-1002);
all vented to one associated chilled water condenser (ID No. CD-1004-2EX1002) venting to
one cryogenic(nitrogen) condenser system(ID No. CD-1004-2EX1003);
• Process equipment leaks(ID No. ES-1 004-2-F);
• Wastewater tanks and other similar vessels(ID No. ES-1004-2-WW);
• Biomass extraction operations wastewater stream(ID No. ES-1003-1 0-WW);
• Biomass silo loadout(ID No. ES-1 004-2Silo) and one associated bagfilter(ID No. CD-1004-
2-FF2); and
• Molecular sieve(ID No. ES-MSDU-1024)
1. 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter(PM)from the plant material grinder(ID No.MHZ-1002),the
biomass extraction debagging operation(ID No. ES-1004-1),tray dryer(ID No.RV-1002),and the
biomass silo loadout(ID No.ES-1004-2-Silo)shall not exceed an allowable emission rate.
(a) The allowable emission rates for particulate matter from any stack, vent, or outlet, resulting
from any industrial process for which no other emission control standards are applicable, shall
not exceed the level calculated with the equation E= 4.10(P)061 calculated to three significant
figures for process rates less than or equal to 30 tons per hour. For process rates greater than
30 tons per hour, the allowable emission rates for particulate matter shall not exceed the level
calculated with the equation E= 55.0(P)O-"—40 calculated to three significant figures. For the
purpose of these equations `E"equals the maximum allowable emission rate for particulate
matter in pounds per hour and `P"equals the process rate in tons per hour.
To demonstrate compliance,Avoca is required to perform inspections and maintenance as
recommended by the manufacturer. At a minimum the bagfilters and system ductwork must be
externally inspected monthly and internally inspected annually. Continued compliance is expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
This permit condition applies to the Biomass debagger and silo. Each is limited to an opacity of 20%
under this rule. The limits may not be exceeded more than once in any hour and not more than four
times in any 24-hour period. To ensure compliance,Avoca is required to observe visible emissions
from the debagger and silo baghouses on a semi-annual basis. Avoca is required to submit a semi-
annual summary report for VE observations of the operations. Continued compliance is expected.

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3. 15A NCAC 02D .0530—Prevention of Significant Deterioration
See Section VI.for more details.
4. 15A NCAC 02D .0614—Compliance Assurance Monitoring
See Section VI.for more details.
5. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Qn1
See Section VII. for more details.
6. 15A NCAC 02Q .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
7. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
E. Two Biomass Boilers(ID Nos.ES-BBI and ES-BB2)controlled by a bagfilter(ID No.CD-
BBIBIT)
1. Avoca has requested replacing regulation 15A NCAC 02D .0503 with 15A NCAC 02D .0504.
When the boilers were initially installed,they were permitted to fire sage(a plant material)and
wood. The firing of sage was not successful,and thus the boilers are now fired with 100%
wood. The regulatory review of 15A NCAC 02D .0504 is presented below. No other
regulatory review is required at this time.
15A NCAC 02D .0504: Particulates from Wood Burning Indirect Heat Exchangers
This rule applies to emission sources that burn 100%wood. The following equation is used to
calculate the allowable emissions of PM:
E= 1.1698 x Q-0.2211
Where E is the allowable emission limit for particulate matter in pounds per million Btu
(lb/MMBtu) and Q is the maximum heat input million Btu per hour(MMBtu/hr). The heat input
for each boiler is 24 MMBtu/hr each. The allowable emission limit for each boiler is 0.58
lb/MMBtu.
Using AP-42 emission factors,PM emissions from wood residue combustion are estimated to be
less than 0.0114 lb/MMBtu. The emission factors for fabric filters for wood residue combustion
is 0.1 lb/MMBtu. The boilers are expected to comply with this standard for wood firing.
2. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources

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The sulfur dioxide(SO2)emitted by the boilers shall not exceed 2.3 lb/MMBtu heat input. The
boilers combust only wood chip. Sage is no longer burned. The SOz AP-42 emission factor for
wood combustion is 0.025 lb/MMBtu. There are no monitoring/recordkeeping/reporting conditions
for the boilers under this rule in the permit. Continued compliance is expected.
3. 15A NCAC 02D .0521 —Control of Visible Emissions
Boilers ES-BB 1 and ES-BB2 are limited to an opacity of 20%. The limits may not be exceeded
more than once in any hour and not more than four times in any 24-hour period. Avoca is required to
observe boiler opacity once a day. "Normal"is any VE below 20%. Continued compliance is
expected.
4. 15A NCAC 02D .0524—New Source Performance Standards(40 CFR Part 60,%Dc—Standards of
Performance for New Stationary Sources
See Section VI.for more details.
5. 15A NCAC 02D .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart
DDDDD—National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,
Commercial,and Institutional Boilers and Process Heaters
See Section VI.for more details.
F. Sclareol Recrystallization(SFG) Operations,including:
• One process tank(ID No.T-3001)*
• Four process tanks(ID Nos. T-3002 through 3005)*
• One storage tank(ID No.T-3006)`
• One process tank(ID No.T-3007)`
• Two centrifuges(ID Nos.C-3001 and C-3002)*
• One reactor (ID No. R-3001) equipped with two process chilled water condensers (EX-
3001 and EX-3002)with control chilled water condenser(ID No. CD-3001)*
• One reactor(ID No.R-3002)*equipped with a process chilled water condenser(EX-3003)
• One reactor(ID No.R-3003)*equipped with a process chilled water condenser(EX-3004)
• One reactor(ID No.R-3004)*equipped with a process chilled water condenser(EX-3005)
• One steam heated dryer(ID No.D-3001)equipped with a process chilled water condenser
(EX-3002)with control chilled water condenser(ID No.CD-3001)`
• One steam heated dryer(ID No.D-3002)equipped with a process chilled water condenser
(EX-3006)with control chilled water condenser(ID No. CD-3002)*
• Process equipment leaks(ID No.ES-1003-10-F)
• SFG Operations wastewater stream(ID No.ES-1003-10-WW)
* These emission sources may be controlled with a chilled water condenser(ID No. CD-3003)
in series with a mineral oil scrubber(ID No. CD-3004-S). These control devices are optional
controls. The Permittee has the option to construct or not construct these devices and has the
option to operate or not operate these devices.
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration

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Avoca submitted a PSD application for the SFG expansion(T45 issued). SFG is limited to no more
than 217.4 tons VOC emitted per consecutive 12-month period.
Monitoring/Recording
• VOC emissions must be calculated and recorded at the end of each month. VOC emissions must
be calculated by multiplying the total amount of each VOC-containing material consumed during
the month by the VOC content of the material.
Reporting
• Avoca must submit semi-annual reports containing the following data:
i. the monthly VOC emissions for each of the previous 17 months;and
ii. the yearly VOC emissions for each consecutive 12-month period ending on each month of
the previous six-month period.
2. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Only
See Section VII. for more details.
3. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
G. Sclareolide(SDE-1) Operations,including:
• Eleven (11) process tanks of various capacities (ID No. ES-1001-1-3-P, Tank ID Nos. M-
2,M-4,M-4A,M-39,M-44,M-15,M-17,M-17A,M-16,M-11,and TK-1210);
• One centrifuge(ID No. G-17);
• One steam-heated dryer with process condenser(ID No.D-1202);
• Filters(ID No.ES-1001-1-3-Filters);
• SDE-1 process equipment leaks (ID No.ES-1001-3-F); and
• SDE-1 wastewater stream(ID No.ES-1001-1-3-WW)
1. 15A NCAC 02Q .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
2. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
H. Sclareolide(SDE-2) Operations,including:
• One chilled water condenser(ID No. CD-4002) in series with a mineral oil scrubber (ID
No. CD-4003-S)controlling emissions from the following:

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o One 17,900 gallon virgin solvent tank(ID No. T-4001);
o Two 6,000 gallon process tanks(ID Nos. T-4017 and T-4018);
o One 4,200 gallon reactor with process condenser(EX-4001)(ID No.R-4004);
o One 4,200 gallon reactor with process condenser(EX-4002)(ID No.R-4005);
o One 4,200 gallon reactor with process condenser(EX-4003)(ID No.R-4044);
o One 1,500 gallon reactor(ID No.R-4015); and
o One centrifuge(ID No. C-4001)
• One dryer with process condenser(EX-4004)with associated chilled water condenser(ID
No. CD-4001)in series with a chilled water condenser(ID No. CD-4002) and mineral oil
scrubber(ID No. CD-4003-S)
• SDE-2 process equipment leaks (ID No.ES-4000-F); and
• SDE-2 wastewater stream(ID No.ES-4000-WW)
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration
Avoca submitted a PSD application for the SDE-2 expansion(T46 issued). SDE-2 is limited to no
more than 354.4 tons of VOC emitted per consecutive 12-month period.
Monitoring/Recordkeeping
• VOC emissions must be calculated and recorded at the end of each month. VOC emissions must
be calculated by multiplying the total amount of each VOC-containing material consumed during
the month by the VOC content of the material.
Reporting
• Avoca must submit semi-annual reports containing the following data:
i. the monthly VOC emissions for each of the previous 17 months;and
ii. the yearly VOC emissions for each consecutive 12-month period ending on each month of
the previous six-month period.
2. 15A NCAC 020 .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
3. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
I. One Maker Deconditioner(ID No.ES-DEC-2001)
1. 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter(PM)from the flaker deconditioner(ID No.ES-DEC-2001)shall not
exceed an allowable emission rate.

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(a) The allowable emission rates for particulate matter from any stack, vent, or outlet, resulting
from any industrial process for which no other emission control standards are applicable,shall
not exceed the level calculated with the equation E= 4.10(P)061 calculated to three significant
figures for process rates less than or equal to 30 tons per hour. For process rates greater than
30 tons per hour, the allowable emission rates for particulate matter shall not exceed the level
calculated with the equation E= 55.0(P)0-1—40 calculated to three significant figures. For the
purpose of these equations `E"equals the maximum allowable emission rateforparticulate
matter in pounds per hour and `P"equals the process rate in tons per hour.
The deconditioner emissions are controlled by a cyclone(ID No. CD-MHZ-2001). The permit
condition requires monthly visual external inspection of the cyclone. Condition 2.11.l.c.ii was
removed. DAQ doesn't require annual inspections of simple cyclones that aren't equipped with a
door. The results of the monthly visual external inspection must be recorded in a logbook. Submittal
of a semi-annual summary report of the inspection activities is required. Continued compliance is
expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
This permit condition applies to the deconditioner. The deconditioner is limited to an opacity of 20%
under this rule. The limits may not be exceeded more than once in any hour and not more than four
times in any 24-hour period. To ensure compliance,Avoca is required to observe the deconditioner
opacity once per month and record observations in a logbook. Semi-annual summary reports are
required. Continued compliance is expected.
VI. NSPS,NESHAPS/MACT,PSD, 112(r), CAM
NSPS
The Permittee is currently subject to New Source Performance Standards (NSPS),40 CFR 60,
Subpart Dc"Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units."
40 CFR Part 60, Subpart Dc—Standards of Performance for Small Industrial Commercial
Institutional Steam Generating Units
40 CFR Part 60,Dc is applicable to units that began construction,modification,or reconstruction
after June 9, 1989, and has a maximum design heat input capacity between 10 and 100 MMBtu/hr.
The two biomass boilers(ID Nos.ES-BB1 and ES-BB2)have a heat input capacity of 24 MMBtu/hr
each. The boilers utilize wood material as the primary fuel currently. The boilers are considered
affected facilities under Subpart Dc since the units were constructed on or after June 9, 1989 (began
operation October 2011). Boiler(ID No.H-104)was installed in 2019 with a rated capacity of
33.475 MMBtu/hr thus is also considered an affected facility subject to Subpart Dc. Boiler H-104
utilizes propane as the primary fuel.
Avoca acknowledges the following:
1. There are no SO2 standards for wood boilers or propane boilers
2. Boilers ES-BB1 and ES-BB2: There are no PM or opacity standards for wood boilers with a heat
input less than 30 MMBtu/hr.
3. Boiler H-104 has a heat input rating greater than 30 MMBtu/hr,but there are no PM or opacity
standards subject to the boiler as it will only fire a gaseous(propane) fuel.

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As such,Avoca boilers are not subject to any PM,opacity or SO2 requirements listed in Subpart Dc
for any of the subject boilers.
Record keeping and reporting requirements outlined in 60.48c will also apply to these boilers.
Specifically,60.48c(a) sets forth the initial reporting requirements of 60.7(a)(1&3). Written
notification is required for the following:
• Notification of the date construction is commenced. This must be postmarked no later than 30
days after such date.
• This notification was submitted on May 26,2011,for ES-13131 and ES-13132. Avoca,Inc.
began construction of the two biomass boilers on May 2,2011.
• Boiler H-104 was received as a"mass-produced unit which was purchased and was
delivered in completed form"as outlined in 40 CFR Part 60.7(a)(1). Based on this
provision,it was interpreted that no notification of construction is required for boiler H-
104.
• Notification of the actual date of initial start-up postmarked within 15 days of the actual date.
• This notification was submitted in October 2011 (October 14 for Boiler ES-BB 1 and
October 31 for Boiler ES-13132). Boiler ES-BB 1 commenced operation on October 10,
2011, and Boiler ES-13132 commenced operation on October 24,2011.
• This notification was submitted in January 2019 for Boiler H-104. Boiler H-104
commenced operation on or about January 15,2019.
60.48c(a)(1) stipulates the inclusion of the design heat input of the boilers along with the types of
fuels to be combusted. 60.48c(2-4)are not applicable to any of these boilers. 60.48c(g)requires and
allows the affected facility to record and maintain the amounts of each fuel used during each calendar
month. This permit renewal does not affect this status.
NESHAPS/MALT
National Emissions Standards for Hazardous Air Pollutants(NESHAP)are applicable to major
sources of HAP. A HAP major source is defined as having potential emissions in 10 tpy or more for
any individual HAP and/or potential emissions of 25 tpy or more for total HAP. The following
NESHAPs are applicable to emission sources at the Avoca facility.
40 CFR Part 63, Subpart FFFF—Miscellaneous Organic Chemical Manufacturing NESHAP
(the"MON")
Facility-wide: Heat Exchange Systems
Avoca utilizes a cooling tower system to cool various processes at the Merry Hill facility. The heat
exchange system is subject to heat exchange systems monitoring per 40 CFR 63.2490(Subpart FFFF)
and 40 CFR 63.104(Subpart G),by reference.
Rotocel Operations
The Rotocel operations are subject to 40 CFR Part 63, Subpart FFFF(MON). These operations are
continuous processes and thus are subject to the requirements for continuous process vents.
The Rotocel miscellaneous organic chemical process unit(MCPU)has previously been determined in
the MON Notification of Compliance Status(NOCS)report as having a Group 2 continuous process
vent based on a calculated THE value of> 1.9. The THE accounts for the two 19,500-gallon

Page 16 of 27
process/storage tanks(ID Nos. ES-125A and ES-125B). The two 19,500-gallon process/storage tanks
when only storing material would never achieve a vapor pressure threshold to change the
determination from Group 2 storage tanks. Equipment leaks comply via 40 CFR Part 63, Subpart
UU. There are only Group 2 process wastewater streams from the Rotocel MCPU;however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the Rotocel MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the process vents,equipment leaks,
storage tanks, fugitives or wastewater requirements for MON.
Recovery Operations
The Recovery operations are subject to the(MON). These operations are continuous processes and
thus are subject to the requirements for continuous process vents.
The Recovery MCPU vents emissions from the Acron process tank(ID No. M-1), stripper(ID No. T-
5), and receiver(ID No. M-21)process vents to the Rotocel MCPU control device. The THE
calculated for Rotocel includes the Recovery MCPU contribution and therefore determined to be
Group 2. Additionally,there are other continuous process vents (not venting to the Rotocel control
device)in the Rotocel MCPU that have been determined to be Group 2. There is one Group 2 storage
tank(ID No. M-25)with no control requirements. Equipment leaks comply via 40 CFR Part 63,
Subpart UU. There is one Group 1 process wastewater stream from the Recovery MCPU that is
discharged to—and controlled by—the 95%efficient biological treatment system. There are no
transfer racks in the Recovery MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the process vents,equipment leaks,
storage tanks, fugitives or wastewater requirements for MON.
Concrete Operations
These operations are not currently operating. The current permit indicates the Concrete Operations
are subject to MON and, if they operate,Avoca will submit an NOCS update prior to utilizing HAP.
Avoca is not requesting any updates to this scenario at this time.
Sclareol Recrystallization(SFG) Operation
The SFG operations were previously subject to the MON due to the use of n-hexane. Avoca changed
operations and is no longer using a HAP in these operations and thus SFG is no longer subject to
MON.
Sclarecolide Operations (SDE-1 and SDE-2)
SDE Operations(SDE-1)utilize n-hexane(HAP) in the process and as such was determined to be
subject to the existing source requirements under the MON. The existing SDE-1 was determined to
be a Group 2 source under Subpart FFFF and therefore for compliance the facility tracked the number
of each type of batch in order to remain a Group 2 batch process with batch process vent emissions
less than 10,000 lb/yr.
The SDE equation is:

Page 17 of 27
Organic HAP= [2.27(pounds/tank f ill)x Btf] + [4.80(pounds/batch)x Breg] +
[3.66(pounds/batch)x B,J+ [4.19(pounds/batch)x Bte]
Where: Breg=The number of regular batches processed in the SDE Operations; and
Bree=The number of recrop batches processed in the SDE Operations
Bte=The number of third crop batches processed in the SDE Operations; and
Btf=The number of hexane tank(M-2)fills.
The SDE-1 MCPU does not have any MON-subject storage tanks; all are considered to be process
tanks. If any of the process tanks were used as storage tanks, all would potentially be Group 2
because they are less than 10,000 gallons in size. Equipment leaks comply via 40 CFR Part 63,
Subpart UU. There are only Group 2 process wastewater streams from the SDE-1 MCPU; however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the SDE-1 MCPU.
The SDE-1 operations have not operated since March 2017. Avoca request to keep this process
permitted in the event there is a need for future operation.
SDE-2 MCPU was determined to be a new source under the MON. It has Group 1 batch process
vents, and thus must reduce the organic HAP by>95%. The emissions from SDE-2 are controlled
with a Mineral Oil System(MOS System)which consists of a chilled water condenser(ID No. CD-
4002) and mineral oil scrubber(ID No. 4003-S). Avoca is monitoring the following:
• Process gas temperature into the absorber is not> 10517°
• Mineral oil temperature into the absorber is not> 105F°
• Mineral oil temperature in the stripper is not<20017°
• Mineral oil flowrate to the stripper is not> 10 gpm and
• Install calibrate and operate a flow indicator at the inlet and outlet of control device to identify no
flow.
The SDE-2 MCPU has one MON-subject storage tank that is a Group 1 tank. The virgin hexane
material tank(ID No. T-4001)is 17,900 gallons. The tank has a total HAP maximum true vapor
pressure of approximately 13.6 kPa. The tank will be vented in the closed vent system to the MOS
system and thus is reduced by 95%. Equipment leaks comply via 40 CFR Part 63, Subpart UU.
Wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the SDE-2 MCPU.
Ethyl Vanillin Glucoside(EVG)Operations
The EVG operations are subject to the MON since the operations have the potential to utilize
methanol and chloroform(trichloromethane).
The current permit contains the following equation for Group 2 batch process vents;
Organic HAP= [1.0(pounds/batch)x B]
Where: B=The number of batches processed in the EVG Operations
The EVG MCPU does not have any MON-subject storage tanks; all are considered to be process
tanks. If any of the process tanks were used as storage tanks, all would potentially be Group 2
because they are less than 10,000 gallons in size. Equipment leaks comply via 40 CFR Part 63,

Page 18 of 27
Subpart UU. There are only Group 2 process wastewater streams from the EVG MCPU; however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the EVG MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the equipment leaks, storage tanks,
fugitives or wastewater requirements for MON.
40 CFR Part 63, Subpart ZZZZ—Stationary Reciprocating Internal Combustion Engines
(RICE MALT)
The MACT standard for stationary reciprocating internal combustion engines(RICE)was first
promulgated on June 15,2004, and only regulated existing and new stationary RICE at major sources
of HAP with a site rating>500 brake horsepower(hp).
On February 17,2010,EPA finalized the newest portions of the RICE NESHAP. Under these new
regulations,many previously unregulated engines,including those designated for emergency use,
became subject to federal regulations,including emissions standards,control requirements,or
management practices.
A stationary RICE is"existing"if it commenced construction or reconstruction before December 19,
2002, for RICE with a site rating of>500 hp located at a major source of HAP. A stationary RICE is
"existing"if it commenced construction or reconstruction before June 12, 2006, for RICE with a site
rating of<500 hp located at a major source of HAP.
The Avoca Merry Hill plant has the following emergency units at the site subject to 40 CFR Part 63,
Subpart ZZZZ:
• One No. 2 fuel oil-fired emergency generator(ID No.E105, 2,935 hp)and associated
catalytic oxidizer(ID No. CD-CatOXI)that was installed on May 12, 2005. As such,this
unit is considered a"new"source.
• Three No. 2 fuel oil-fired emergency generators (ID Nos.E101,E102,and E104, 587 hp,
760 hp, and 401 hp,respectively)that were constructed before June 12,2006,and therefore
are all considered"existing sources"; and
• One compression ignition emergency fire pump(ID No.FP,285 hp)that was constructed
before June 12,2006, and therefore is an"existing source."
Engine E104 and FP(Units<500 hp)
Based on the hp ratings these engines must meet the requirements listed below:
During S
• Minimize the engine's time spent at idle and minimize the engine's startup to a period needed
for appropriate and safe loading of the engine,not to exceed 30 minutes.
Work Practice Standards:
• Change oil and filter every 500 hours of operation or annually,whichever comes first;
• Inspect air cleaner every 1,000 hours of operation or annually,whichever comes first;
• Inspect all hoses and belts every 500 hours of operation or annually,whichever comes first,
and replace as necessary;
• Install non-resettable hours meter; and

Page 19 of 27
• Operate and maintain the engine and after-treatment control device (if any) according to the
manufacturer's emission—related written instructions or develop a maintenance plan.
Recordkeeping:
• Copies of Notifications
• Occurrence and duration of each malfunction of engine, control or monitoring equipment
• Records of maintenance performed
• Actions taken during malfunction to minimize emissions
• Records of hours of operation recorded with non-resettable hours meter
• Records to show continuous compliance with operating and maintenance requirements.
Reporting_
• Semiannual report of monitoring and recordkeeping activities
All engines(E101,E102,E104 and FP) and E105
• Must be in compliance with emission limitations and operating limitations at all times.
• Operate and maintain source in a manner consistent with safety and good air pollution control
practices for minimizing emissions.
• Operation other than emergency,maintenance, and testing, emergency demand response and
operation in non-emergency more than 50 hours per year is prohibited.
• No time limit for emergency operations
• May operate engine for following times for a maximum of 100 hours each calendar year:
• Maintenance checks and readiness testing
• Emergency demand response
• Periods where a deviation of voltage or frequency of 5%or greater below standard
voltage or frequency.
• Emergency stationary RICE 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. 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 a facility to supply
power to an electric grid or otherwise supply power as part of a financial arrangement with
another entity.
This permit renewal does not affect these requirements. Continued compliance is expected.
40 CFR Part 63, Subpart DDDD—Boiler and Process Heater NESHAP
40 CFR Part 63, Subpart DDDDD applies to industrial, commercial, and institutional boilers and
process heaters located at a major source of HAP emissions. An affected source is any existing,new
or reconstructed industrial, commercial,and institutional boilers and process heaters located at a
major source of HAP emissions.
Three boilers at this facility are classified as new sources per 40 CFR 63.7490(b)since the units are
located at a major source of HAP and commenced construction on or after June 4,2010; (ID Nos. ES-
BB1,ES-BB2, and H-104). There are also two existing boilers(ID Nos. H-101 and H-102). These
boilers fire ultra-low sulfur diesel(ULSD) fuel.
Biomass Boilers (ES-BBI and ES-BB2)

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The biomass boilers are considered stokers designed to burn biomass/bio-based solid(40 CFR
63.7499(d)). The boilers must comply with the emission limitations in Table 1,work practice
standards in Table 3, and operating limits in Table 4 of Subpart DDDDD.
The boilers have demonstrated compliance with the following emission limits found in Table 1 for a
stoker designed to burn biomass/bio-based solids.
• PM: 0.03 lb/MMBtu heat input
• HCL: 0.022 lb/MMBtu heat input
• CO: 620 ppm by volume
• Hg 8.0 E-07 lb/MMBtu heat input
The boilers have complied with the work practices standards in Table 3 for a new unit subject to
emission limits:
• Minimize the unit's startup and shutdown periods following the manufacturer's recommended
procedures.
• The facility has developed operating limits for the boilers listed in Table 4.
• The bagfilter installed on the boilers is equipped with a bag leak detection system.
Performance Testing
Avoca performed testing for the boilers on February 21, 2013, and December 19,2013 and
demonstrated compliance. Per 40 CFR 63.7515(b),Avoca conducted two consecutive tests with each
limit less than 75%of the standard. As such, a retest of the boilers are increased to within 37 months
of the last test. Avoca has performed subsequent testing on December 14,2016,and December 19,
2019. The next test is required January 19,2023.
Operating Limits
The following criteria as outlined in Table 4 of Subpart DDDDD were utilized to establish the
operating limits:
• Fabric Filter Control: Install and operate a bag leak detection system according to 40 CFR
63.7525 and operate such that the alarm does not sound more than 5% of the operating time
during each 6-month period.
• Performance Testing: Maintain the operating load of each unit such that it does not exceed
110%of the highest hourly average operating load recorded during the most recent test.
• Oxygen Analyzer System: For boilers and process heaters subject to CO emission limit that
demonstrate compliance with an 02 analyzer system as specified in 40 CFR 63.7525(a),
maintain the 30-day rolling average oxygen content at or above the lowest hourly average
oxygen concentration measured during the CO performance test, as specified in Table 8. This
requirement does not apply to units that install an oxygen trim system since these units will
set the trim system to the level specified in 40 CFR 63.7525(a). The boilers at Avoca are
equipped with an oxygen trim system.
During the last performance testing the operating limits were set as follows using the Subpart
DDDDD regulations:
• Boilers are equipped with a bag leak detection system.

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• Operating Load: The operating limit is 1.1 times this maximum load or 24,049 lb/hr total
steam output [from December 2019 test]
• Oxygen Limit: The minimum oxygen content recorded by the oxygen trim system during the
performance test was 10.2% for Boiler 1 and 8.6% for Boiler 2 [from December 2019 test].
Per 40 CFR 63.7525(a)(7), operate an oxygen trim system with the oxygen level set no lower
than the lowest hourly average oxygen concentration measured during the most recent CO
performance test as the operating limit for oxygen according to Table 7 of this subpart.
Fuel Testing
Avoca is not performing fuel testing as a method of demonstrating compliance.
Monitoring/Recordkeeping and Reporting
Avoca is keeping records of all oxygen and steam outputs from the boilers. The bag leak detection
data is also recorded and maintained electronically. Per 40 CFR 63.7550,Avoca is submitting
semiannual reports as outlined in Table 9 and uploading data to the CEDRI system.
Energy Assessment(EA)Requirement
The one-time EA is not required for new boilers.
Tune-Up Requirements
Per Table 3,new boilers with a continuous trim system must perform a tune up every 5 years (last
tune up was September 1,2021)
Notice of Compliance Status
The last NOCS for ES-BB 1 and ES-BB2 was submitted February 6, 2020.
Two No.2 Fuel Oil-Fired Boilers(H-101 and H-102)
The ULSD fired boilers at the Avoca site are considered existing affected under Subpart DDDDD.
The boilers are designed to fire ULSD No. 2 fuel oil, and are rated at 20.3 MMBtu/hr each. The
boilers are classified as units designed to burn light liquid subcategory(40 CFR 63.7499(u)). The
boilers are required to document compliance with the emission limits in Table 2 to Subpart DDDDD.
• PM: 0.0079 lb/MMBtu heat input
• HCL: 0.0011 lb/MMBtu heat input
• CO: 130 ppm by volume on a dry basis, 3%Oz
• Hg: 2.0 E-06 lb/MMBtu heat input
Performance Testing/Monitoring/Recordkeeping and Reporting
Testing was performed on August 20 and 21, 2019 and documented compliance. Per 40 CFR
63.7515(h)units designed to burn light liquid fuel and that combust ULSD do not need to conduct
further performance tests if compliance is demonstrated during the initial testing and they
demonstrate ongoing compliance with emission limits by monitoring and recordkeeping the type of
fuel combusted on a monthly basis.

Page 22 of 27
Fuel Testing
Avoca is not performing fuel testing as a method of demonstrating compliance.
Energy Assessment(EA)Requirement
The one-time EA was required for existing boilers H-101 and H-102. The EA was completed on May
9,2019.
Tune Up Requirements
Per Table 3,new and existing boilers without a continuous trim system and heat capacity greater than
10 MMBtu/hr must perform an annual tune-up. The last annual tune-up was performed on July 13,
2021.
Notice of Compliance Status
The NOCS for H-101 and H-102 was submitted October 3,2019 for this one-time test.
Propane Boiler(H-104)
The propane boiler is not subject to emission limits or testing requirements. The boiler will be a"unit
designed to burn gas 1 subcategory"since it fires propane and will be subject to the work practice
standards in Table 3 in Subpart DDDDD.
Tune-Up Requirements
Initial tune-up for the boilers at the facility(Table 3 of the rule)
• No continuous trim system and heat capacity greater than 10 MMBtu/hr: Tune up with 13
months of startup.
Subsequent Tune-up Requirements [40 CFR 63.7515(d)]
• No continuous trim system: Each annual tune-up must be no more than 13 months after the
previous tune-up.
Energy Assessment(EA)Requirements
An EA is not required for new boiler H-104
Recordkeeping Requirements
Records of the dates and the results of each required boiler tune-up.
Reporting Requirements
Periodic Compliance Reporting:
The boilers are subject only to a requirement to conduct a annual tune-up, and not subject to
emission limits or operating limits. Therefore,Avoca may submit an annual compliance report,
as applicable instead of a semi-annual compliance report [40 CFR 63.7750(b)].

Page 23 of 27
• The annual report must be postmarked or submitted no later than January 31.
• Electronic compliance reporting under CEDRI electronic system is operational and reports
should be uploaded to the system.
Avoca states in their application that all Compliance reports have been submitted by January 31 each
year and uploaded into CEDRI.
Notice of Compliance Status
If there is an initial compliance requirement,then a NOCS is required.
Since this is a new boiler:
1. a tune-up at start-up was not required;
2. an energy assessment was not required; and
3. performance testing was not required.
Thus, an NOCS is not required for this unit.
The applicability of this Subpart to these sources is not affected with this renewal. Continued
compliance is expected.
PSD
North Carolina has implemented the federal PSD requirements of 40 CFR 51.166 under North
Carolina Regulation 15A NCAC 02D .0530. The PSD program regulates emissions from major
stationary sources of regulated air pollutants. For the purposes of the PSD program, a major
stationary source is defined as any one of the following;
1. Any stationary source that is listed as one of the 28 named source categories in Title 40 of the
Code of Federal Regulations (40 CFR), Part 51.166(b)(1)(i) which emits, or has the potential
to emit, 100 tons per year(tpy) or more of any pollutant subject to regulation under the ACT,-
2. Any stationary source that is not listed as one of the 28 named source categories in 40 CFR
Part 51.166(b)(1)(i) which emits, or has the potential to emit, 250 tons per year(TPY) or
more of any pollutant subject to regulation under the ACT.
According to the application,the Avoca facility has previously been identified by DAQ as a chemical
plant and is a 100 tpy major source. The facility is currently operating under PSD BACT
requirements for multiple sources as well as PSD avoidance conditions for several emission sources.
Avoca is not requesting any changes to the current permit conditions.
112(rl—The facility is not subject to Section 112(r)of the Clean Air Act requirements because it
does not store one or more of the regulated substances in quantities above the thresholds in the Rule.
This permit modification does not affect this status.
CAM
40 CFR Part 64 is applicable to any pollutant-specific emission unit,if the following three conditions
are met:
• the unit is subject to any(non-exempt: e.g.pre November 15, 1990, Section 111 or Section
112 standard)emission limitation or standard for the applicable regulated pollutant.
• the unit uses any control device to achieve compliance with any such emission limitation or

Page 24 of 27
standard.
• the unit's pre-control potential emission rate exceeds either 100 tpy(for criteria pollutants)
or 10/25 tpy(for HAP's).
Avoca has previously evaluated Part 64 and has determined that four emission sources are subject to
this rule and CAM is included in the current permit.
The applicability analysis for the sources that are equipped with a control device and evaluated for
CAM are shown in the following table below.
Source Name DAQ Applicable Pollutant Uncontrolled Major Subject to
Rule Emissions Source CAM/
(tons/yr) Threshold
(tons/ r)
Yes—
Rotocel 15A NCAC 02D VOC >100 100 included
Operations .0530 in the
current
permit
Yes—
Recovery 15A NCAC 02D VOC >100 100 included
Operations .0530 in the
current
permit
Sclareol No
Recrystallization 15A NCAC 02D VOC >100 100
SFG .0530
Sclareolide No Applicable VOC NA 100 No
SDE-1 Regulation
Sclareolide 15A NCAC 02D No—see
(SDE-2) 1111 MACT Subpart VOC/HAP >100 100 below
FFFF
Plant Nutrient No Applicable
Extraction Regulation VOC NA 100 No
PNE
Ethyl Vanillin No Applicable
Glucoside Regulation VOC NA 100 No
(EVG)
Yes—
Botanical 15A NCAC 02D VOC >100 100 included
Exaction .0530 in the
current
permit
Yes—
Biomass 15A NCAC 02D VOC >100 100 included
Extraction .0530 in the
current
permit

Page 25 of 27
Biomass Boilers 15A NCAC 02D No—see
ES-BB 1 &ES- 1111 MACT Subpart PM NA 100 below
BB2 DDDDD
Emergency No Applicable NO. NA 100 No—see
Generator E105 Regulation below
SDE-2
SDE-2 are subject to 40 CFR 63, Subpart FFFF,and therefore exempt from applicability to CAM for
the control of VOC. Based on the above information, SDE-2 is not subject to the CAM regulations.
Biomass Boilers ES-BB1 and ES-13132
The boilers are subject to 40 CFR 63, Subpart DDDDD, and therefore exempt from the applicability
to CAM for the control of PM. Based on the above information,the boilers are not subject to CAM
regulations.
Emergency Generator E105
The limited use generator is equipped with a catalytic oxidizer which controls VOC and CO. The
avoidance limit is for NOx which is not controlled by the control device. Thus,the unit is not
applicable to CAM since the unit does not use a control device to achieve compliance with any such
emission limitation or standard.
VII. Facility Wide Air Toxics
15A NCAC 02D .1100: Control of Toxic Air Pollutant Emissions
A toxic air pollutant(TAP)permit application shall include an evaluation of the TAP emissions from
a facility for any non-NESHAP source. See discussion in 15A NCAC 02Q .0700: "Toxic Air
Pollutant Procedures."
15A NCAC 020 .0700: Toxic Air Pollutant Procedures
This rule establishes procedures for documenting compliance for a modification that results in an
increase in NC air toxics. Compliance can be demonstrated by:
1. Documenting that facility wide emissions are below the thresholds in 15A NCAC 02Q .0711
2. Netting to show there has been a no net increase in NC air toxics; or
3. Modeling to document compliance with the ambient levels in 15A NCAC 02D .1100.
Based upon recent legislative action exempting sources subject to 40 CFR Part 61 or Part 63 from the
North Carolina Air Toxics program, sources that are subject to a MACT or GACT requirement would
be exempt from the NC Air Toxics program and the associated modeling requirements. Certain
operations are subject to the MON NESHAP and Avoca previously provided a model that
documented compliance with NC Air Toxics in the April 2013 construction application. Permit
Condition 2.2 A.1 simply states for any non-NESHAP source, any increase in toxic air pollutants
must be evaluated. Avoca's toxics limitations were removed from permit T40. As allowed under
Session Law 2012-91 House Bill 952,the facility is not required to evaluate toxics from MACT
sources(the burden belongs to DAQ). All of the modeled toxics sources are MACT,FFFF,DDDDD,
or ZZZZ affected. Changes in toxics emissions due to the modifications made under T40 and T41

Page 26 of 27
were modeled by Avoca and reviewed by Alexander Zarnowski(5/01/2013)and Tom Anderson
(5/16/2013). The DAQ permit reviews stated that the modifications did not pose unacceptable toxics
health risks. Modifications in T42 through T52 did not require re-modeling by DAQ Permits.
Avoca requested removal of all NC Air Toxics from the permit since all sources of air toxics are
covered under a NESHAP. DAQ has thus removed all TAPS from the permit.
VIII.Facility Emissions Review
See Table in the header for a summary of the actual emissions as reported to DAQ from the years
2015 to 2019.
IX. Stipulation Review
The facility was last inspected by Betsy Huddleston on 1/25/2019, 1/29/2019 and 1/30/2019
(Inspection Report—04/26/2019). Based on her observations the facility appeared to be in
compliance with their Title V permit requirements.
X. Affected State(s)Review
A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice
will provide for a 30-day comment period,with an opportunity for a public hearing. Consistent with
15A NCAC 02Q .0525,the EPA will have a concurrent 45-day review period. Copies of the public
notice shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 02Q
.0522, a copy of each permit application,each proposed permit and each final permit pursuant shall
be provided to EPA. Also,pursuant to 02Q .0522,a notice of the DRAFT Title V Permit shall be
provided to each affected State at or before the time notice is provided to the public under 02Q .0521.
XI. Conclusions,Comments, and Recommendations
PE Seal
Pursuant to 15A NCAC 02Q .0112"Application Requiring a Professional Engineering Seal,"a
professional engineer's seal(PE Seal)is required to seal technical portions of air permit applications
for new sources and modifications of existing sources as defined in Rule .0103 of this Section that
involve:
(1) design;
(2) determination of applicability and appropriateness; or
(3) determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer's seal(PE Seal)was not required for this renewal.
Zoning
A zoning consistency determination was not required for this renewal.
Recommendations
WaRO recommends issuance of the permit and was sent a DRAFT permit prior to issuance(See
Section III of this document for a discussion).
The Raleigh Central Office(RCO)concurs with WaRO's recommendation to issue the Air Permit
No. 01819T54.

Page 27 of 27

NORTH CAROLINA DIVISION OF Region: Washington Regional Office
AIR QUALITY County: Bertie
Application Review NC Facility ID: 0800044
Inspector's Name: Betsy Huddleston
Issue Date: December 14,2022 Date of Last Inspection: 09/18/2020
Com liance Code: 3/Compliance-inspection
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Avoca LLC SIP: 15A NCAC 02D .0503,.0504, .0515, .0516,
.0521, .0614,and.1806
Facility Address: NSPS: 15A NCAC 02D .0524-Subpart Dc
Avoca LLC NESHAP: 15A NCAC 02D .1111 -Subpart FFFF,
841 Avoca Farm Road ZZZZ,and DDDDD
Merry Hill,NC 27957 PSD: 15A NCAC 02D .0530
PSD Avoidance: N/A
SIC:2087/Flavoring Extracts And Syrups,nec NC Toxics: 15A NCAC 02D .1100
NAILS: 31193/Flavoring Syrup and Concentrate Manufacturing 112(r): N/A
Other: N/A
Facility Classification:Before: Title V After: Title V
Fee Classification: Before: Title V After: Title V
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0800044.21A
Brian Conner Augustinus Gerritsen Brian Conner Date Received: 06/30/2021Application Type: Renewal
EH&S Manager Vice President EH&S Manager
[phone] [phone] [phone] Application Schedule: TV-Renewal
PO Box 129 PO Box 129 PO Box 129 Existing Permit Data
Merry Hill,NC 27957 Merry Hill,NC 27957 Merry Hill,NC 27957 Existing Permit Number: 01819/T53
Existing Permit Issue Date: 08/06/2019
Existing Permit Expiration Date: 12/31/2021
Total Actual emissions in TONSIYEAR:
CY S02 NOX vOC CO PM10 Total HAP Largest HAP
2019 2.67 31.81 1403.40 23.73 0.3540 303.38 264.35
[Methanol(methyl alcohol)]
2018 2.57 30.93 1280.53 20.88 0.5840 368.93 299.66
[Methanol(methyl alcohol)]
2017 3.20 34.63 1268.61 25.45 0.5040 353.95 298.22
[Methanol(methyl alcohol)]
2016 2.67 30.68 1221.52 21.50 0.5050 338.82 269.99
[Methanol(methyl alcohol)]
2015 3.10 33.91 939.80 24.70 0.5350 263.87 207.17
[Methanol(methyl alcohol)]
Review Engineer: David B.Hughes Comments/Recommendations:
Issue 01819/T54
Review Engineer's Signature: Date: December 14,2022 Permit Issue Date: December 14,2022
Permit Expiration Date: November 30,2027

Page 2 of 27
I. Purpose of Applications
Application No. 0800044.21A
This permitting action is a renewal of an existing Title V permit pursuant to 02Q .0513. The existing
Title V permit(01819T53)was issued on August 6,2019,with an expiration date of December 31,
2021. The renewal application 0800044.21A was received on June 30,2021, or at least six months
prior to the original expiration date December 31,2021. Therefore,the existing permit shall not
expire until the renewal permit has been issued or denied. All terms and conditions of the existing
permit shall remain in effect until the renewal permit has been issued or denied.
II. Facility Description
Avoca owns and operates a facility located at 841 Avoca Farm Road,Merry Hill,North Carolina.
The Avoca facility extracts oils and nutrients from various types of plants for use in flavorings,
fragrances, food additives,and dietary supplements. The main product of the facility is sclareol
which is extracted from sage grown on farms in counties surrounding the Avoca Plant.
The process operations at the facility include rotocel,recovery, sclareol re-crystallization(SFG),
sclareolide(SDE-1 and 2),plant nutrient extraction(PNE), ethyl vanillin glucoside(EVG),botanical
extraction, and biomass extraction. Miscellaneous operations include;two No. 2 fuel oil-fired boilers
(ID Nos. H-101 and H-102,20.3 million Btu per hour heat input each), one propane-fired boiler(ID
No. H-104, 33.5 million Btu per hour),two biomass boilers(ID Nos. ES-BB1 and ES-BB2),24
million Btu per hour heat input each), four No. 2 fuel oil-fired emergency generators(ID Nos. E101,
E102, E104 and E105), one No. 2 fuel oil-fired fire water pump(ID No. FP), one wastewater
treatment plant aeration tank(ID No. WWTP-AT1), and one flaker deconditioner(ID No. ES-DEC-
2001).
Avoca has requested the following updates to the current permit.
1. Permit Condition 2.1 A—The permit conditions include 15A NCAC 02D .1109 for Case-by-Case
MACT for the boilers. This requirement expired in May 19,2019 with the replacement of the
federal MACT 40 CFR 63, Subpart DDDDD and thus Avoca requests to remove this condition
from the table and permit.
2. Permit Condition 2.1 E—The permit conditions for the two biomass boilers ES-BB 1 and ES-BB2
currently indicate that they are subject to 15A NCAC 02D .0503. When the boilers were initially
installed,they were permitted to fire sage(a plant material)and wood. The firing of sage was not
successful,and thus the boilers are now fired with 100%wood. A such, 15A NCAC 02D .0504 is
applicable to the biomass boilers instead of 02D .0503. Avoca requests to update in the current
permit
3. The current permit does not denote that the Biomass Extraction Operations are subject to 40 CFR
Part 63 Subpart FFFF in the Table in Section 1. Permit Condition 2.1 D does list biomass
extraction as subject to Subpart FFFF as well as in Permit Condition 2.2.C. Avoca request adding
40 Part 65 Subpart FFFF applicability to the Table in Section 1.
The Division of Air Quality(DAQ)has reviewed and accepted these requests. The updates have been
implemented into the new Title V Air Permit No. 01819T54.
III.History/Background/Application Chronology

Page 3 of 27
January 12,2017—Permit No. 01819T47 issued as a Title V renewal.
July 27,2017—Permit No. 01819T48 issued as an administrative amendment. Ownership change
from Avoca, Inc. to Ashland, LLC. No change to the facility name has been requested,therefore,
remains Avoca, Inc.
April 26,2019—Betsy Huddleston of the Winston-Salem Regional Office (WaRO) completed the
annual compliance inspection of the facility.
August 17,2017—Permit No. 01819T49 issued as a Minor Modification Permit. For the
modification,updated emission sources (existing and new equipment) and added Primary and
Secondary Operating Scenarios to emission sources in Section 2.1 B.1 and 2.1 D.
April 17,2018—Permit No. 01819T50 issued as an administrative amendment. Changed facility
name from Avoca, Inc.to Avoca LLC.
September 4,2018-Permit No. 01819T51 issued as a Minor Modification Permit. For the
modification, added a new Flaker Deconditioner(ID No. ES-DEC-2001)controlled by a simple
cyclone(ID No. CD-MHZ-2001).
April 22,2019—Permit No. 01819T52 issued as a Minor Modification Permit. For the modification,
replaced existing No. 2 fuel oil-fired boiler(ID No. H-103)with a new propane-fired boiler(ID No.
H-104). Also includes an alternative operating scenario for monitoring of the chilled water condenser
(ID No. CD-4002) and mineral oil scrubber(ID No. CD-4003-5)installed on the new sclareolide
operations(ID No. SDE-2).
August 6,2019—Permit No. 01819T53 issued as a Minor Modification Permit. For the
modification,removed an existing No. 2 fuel oil-fired rotary dryer(ID No. ES-RD) and simple
cyclone(ID No. CD-BB I C).
June 30,2021—DAQ received Permit Application 4100772.21A, as a Title V renewal. The
application was deemed complete for processing.
March 4,2022 -DRAFT permit sent to Permittee, Supervisor,WSRO and Samir Parekh for
comment. Brian Conner(Avoca LLC)provided comments on draft permit and review via e-mail on
April 4,2022. Samir Parekh provided comments pertaining to CAM via email on March 14,2022.
Betsy Huddleston(WaRO)provided comments on the air permit review on March 29,2022.
July 26,2022—Sent updated DRAFT permit to Dale Overcash for review. Incorporated the latest
permit language from Joe Voelker. The new language is for emission sources—Two No. 2 fuel oil-
fired boilers (ID Nos. H-101 and H-102)(2.1 A.5 -MACT 40 CFR 63, Subpart DDDDD), One
Propane-fired boiler(ID No. H-104)(2.1 A.4-NSPS 40 CFR 60, Subpart Dc and 2.1 A.6 -MACT
40 CFR 63, Subpart DDDDD), One diesel-fired emergency generator(ID No. E105) and one
associated catalytic oxidizer(ID No. CD-CatOxl) (2.1 B.3—MACT 40 CFR 63, Subpart ZZZZ),and
Two biomass boilers(ID Nos. ES-13131 and ES-13132)controlled by bagfilter(ID No. CD-BB1BH)
(2.1 EA—NSPS 40 CFR 60, Subpart Dc and 2.1 E.5—MACT 40 CFR 63, Subpart DDDDD).
August 3,2022—Dale Overcash sent his comments via email regarding the two No. 2 fuel oil-fired
boilers(ID Nos. H-101,H-102, and H-104)and two biomass boilers(ID Nos. ES-BB1 and ES-13132).

Page 4 of 27
August 12,2022—Teams meeting with Dale Overcash,David B. Hughes, and Joseph Voelker to
discuss language for Air Permit No. 01819T54 regarding Ultra Low Sulfur Liquid(USLD) for two
No. 2 fuel oil-fired boilers(ID Nos. H-101 &H-102), one propane-fired boiler(ID No. H-104) and
two biomass boilers (ID Nos. ES-BB 1 &ES-BB2).
September 9,2022—David B. Hughes sent Dale Overcash the most recent draft with language
regarding USLD for two No. 2 fuel oil-fired boilers(ID Nos. H-101,H-102), one propane-fired boiler
(ID No. H-104), and two biomass boilers(ID No. ES-BB1 and ES-13132)for his review before
sending to Public Notice and EPA review.
September 27,2022—Dale Overcash sent David B. Hughes a email confirming that the Air Permit
No. 01819T54 was acceptable to send to Public Notice and EPA Review.
October 6,2022 -Draft permit and review sent to 30-day public comment and 45-day EPA review
periods.
November 5,2022-30-day public comment period ended;no comments received.
November 20,2022—45-day EPA Review period ended;no comments received.
December 13,2022—Jenny Sheppard(DAQ)updated TVEE.
December 14,2022—Air Permit No. 01819T54 issued as a Title V permit.
IV. Permit Modifications/Changes and WEE Discussion
The following table provides a summary of the changes to the permit.
Page No. Section Description of Changes
Global Global -Updated the application number and complete date.
-Updated permit revision number to T54.
-Updated the issuance/effective dates to permit.
Cover Letter Cover Letter -Updated PSD increment tracking statement.
3 List of Acronyms -Moved List of Acronyms from end of permit.
4- 9 Section 1 -Removed 15A NCAC 02D .1109 1120); Case-by-Case MACT
Equipment Table designations.
-Removed footnotes 3 and 4 due to the fact the dates are past
due for Case-by-Case MACT and MACT DDDDD.
-Removed footnotes 5, 6,and 7. The minor modifications are
being subjected to public and EPA review with this renewal
process; therefore,receiving the permit shield.
-Added MACT FFFF applicability to emission sources(ID Nos.
MHZ-1002, ES-1004-1, ES-1004-2-F, ES-1004-2-WW, ES-
1004-2Silo, and ES-MSDU-1024).
-Changed One No. 2 fuel oil-fired emergency generator ID No.
from ES-PkGenl to E105.
-Moved Three No. 2 oil-fired emergency generators (ID Nos.
E101, E102, and E103) and One No. 2 fuel oil-fired emergency
fire water pump (ID No.FP)to Insignificant Activities list.

Page 5 of 27
Page No. Section Description of Changes
10 2.1 A -Removed 15A NCAC 02D .1109 1120); Case-by-Case
Table MACT.
--- 2.1 A.4 -Removed 15A NCAC 02D .1109 1120); Case-by-Case
MACT.
11 2.1 A.4 -Updated 40 CFR Part 60 Subpart Dc shell language for one
propane-fired boiler(ID No. H-104).
11 - 15 2.1 A.5 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
two No. 2 fuel oil-fired boilers(ID Nos. H-101 and H-102).
15 - 17 2.1 A.6 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
one propane-fired boiler(ID No. H-104).
18 2.1 B -Changed One No. 2 fuel oil-fired emergency generator ID No.
from ES-PkGenl to E105.
18 2.1 B -Removed 15A NCAC 02Q .0317 to avoid 15A NCAC 02D
Table .0530.
18 2.1 B.La&c -Changed One No. 2 fuel oil-fired emergency generator ID No.
2.1 B.2.a&c from ES-PkGenl to E105.
2.1 B.3.a
18 2.1 B.3 -Updated 40 CFR Part 63 Subpart ZZZZ language for one
diesel-fired emergency generator(ID No. E105).
--- 2.1 B.4 -Removed 15A NCAC 02Q .0317: AVOIDANCE
CONDTIONS to avoid 15A NCAC 02D .0530: PREVENTION
OF SIGNIFICANT DETERIORATION.
25 2.1 E -Replaced 15A NCAC 02D .0503 with 15A NCAC 02D .0504.
Table
25 &26 2.1 E.1 -Replaced 15A NCAC 02D .0503 language with 15A NCAC
02D .0504 language.
27 2.1 EA -Updated 40 CFR Part 60 Subpart Dc shell language for two
biomass boilers(ID Nos. ES-BB 1 &ES-13132).
27 -32 2.1 E.5 -Updated 40 CFR Part 63, Subpart DDDDD shell language for
two biomass boilers (ID Nos. ES-BB 1 &ES-13132).
--- 2.1 F -Removed Three Emergency Generators and Fire Water Pump
(ID Nos. E101,E102,E104, &FP)from permit and added
them to the Insignificant Activities list.
37 2.1 I.l.c.ii -Removed annual internal inspection for cyclone (ID No. CD-
MHZ-2001). DAQ doesn't require annual internal inspections
for cyclones that aren't equipped with a door.
62 & 63 Section 3 -Moved Insignificant Activities list and removed footnote 3.
Insignificant -Moved Three No. 2 oil-fired emergency generators(ID Nos.
Activities E101, E102, and E103) and One No. 2 fuel oil-fired emergency
fire water pump (ID No. FP)to Insignificant Activities list to
permit.
64- 72 Section 4 -Updated shell conditions(v6.0, 01/07/2022).
General Conditions
There were significant modifications to the equipment descriptions needed in Title V Equipment
Editor(TVEE).

Page 6 of 27
V. Regulatory Review
The facility is currently subject to the following regulations:
15A NCAC 02D .0503, "Particulates from Fuel Burning Indirect Heat Exchangers"
15A NCAC 02D .0504, "Particulates from Wood Burning Indirect Heat Exchangers"
15A NCAC 02D .0515, "Particulates from Miscellaneous Industrial Processes"
15A NCAC 02D .0516, "Sulfur Dioxide Emissions from Combustion Sources"
15A NCAC 02D .0521, "Control of Visible Emissions"
15A NCAC 02D .0524,New Source Performance Standards(40 CFR 60, Subparts Dc)
15A NCAC 02D .0530, "Prevention of Significant Deterioration"
15A NCAC 02D .0614, "Compliance Assurance Monitoring"
15A NCAC 02D .1100, Control of Toxic Air Pollutants (State-Enforceable Only)
15A NCAC 02D .1111, "Maximum Achievable Control Technology(40 CFR 63, Subparts FFFF,
ZZZZ, and DDDDD)"
15A NCAC 02D .1806, "Control and Prohibition of Odorous Emissions" (State-Enforceable Only)
A. Two No.2 Fuel Oil-fired Boilers (ID Nos. H-101 and H-102) and One Propane-fired
Boiler(ID No. H-104)
1. 15A NCAC 02D .0503—Particulates from Fuel Burning Indirect Heat Exchangers
Emissions of particulate matter(PM)from the combustion of No.2 fuel oil that are discharged from
the sources into the atmosphere from boilers(ID Nos.H-101 and H-102)shall not exceed 0.37
pounds per million Btu(lb/MMBtu)input. Emissions of PM from the combustion of propane that
are discharged from the sources in to the atmosphere from boiler(ID No.H-104)shall not exceed
0.33 lb/MMBtu heat input. The AP-42 emission factor for particulate emitted from No.2 fuel oil
combustion is 0.014 lb/MMBtu(at 140,000 Btu/gal). Propane particulate emissions are considered
negligible(NC LPG combustion spreadsheet cites 0.00053 lb/MMBtu). There are no
monitoring/recordkeeping/reporting conditions for the boilers under this rule in the permit.
Continued compliance is expected.
2. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources
The sulfur dioxide(S02)emitted by the boilers shall not exceed 2.3 lb/MMBtu heat input. The AP-
42 factor for No.2 fuel oil sulfur dioxide emission is 0.5 lb/MMBtu(sulfur content is less than 0.5%
and heat content is assumed approximately 140,000 Btu/gal). There are no
monitoring/recordkeeping/reporting conditions for the boilers under this rule in the permit.
Continued compliance is expected.
3. 15A NCAC 02D .0521 —Control of Visible Emissions
Boilers H-101 and H-102 are limited to an opacity of 40%. Boiler H-103 is limited to 20%opacity.
The limits may not be exceeded more than once in any hour and not more than four times in any 24-
hour period. There are no permit monitoring/recordkeeping/reporting requirements for the boilers
under this rule. Continued compliance is expected.

Page 7 of 27
4. 15A NCAC 02D .0524—New Source Performance Standards(40 CFR Part 60, Subpart Dc—
Standards of Performance for New Stationary Sources
See Section VI.for discussion.
5. 15A NCAC 02D .1111—Maximum Achievable Control Technology(40 CFR Part 63, Subpart
DDDDD—National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial,
Commercial,and Institutional Boilers and Process Heaters
See Section VI.for more details.
B. Emergency Engines/Generators (ID Nos.E101,E102,E104, & FP)and E105)
1. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources
The sulfur dioxide emitted by the generators shall not exceed 2.3 lb/MMBtu heat input. The S02
AP-42 emission factor from large engines(>500 hp)is 0.5 lb/MMBtu. These engines fire ultra-low
sulfur diesel. There are no monitoring/recordkeeping/reporting conditions under this rule in the
permit for the engines. Continued compliance is expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
The engines are all limited to an opacity of 20%. The limits may not be exceeded more than once
in any hour and not more than four times in any 24-hour period. There are no
monitoring/recordkeeping/reporting requirements for the engines under this rule. Continued
compliance is expected.
3. 15A NCAC 02D .1111 —Maximum Achievable Control Technology 40 CFR Part 63, Subpart
ZZZZ—National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating
Internal Combustion En ig nes
See Section VI.for more details.
4. 15A NCAC 020 .0317: Avoidance Conditions to avoid 15A NCAC 02D.0530: Prevention of
Siwnificant Deterioration
Emergency generator(ID No.E105)is currently subject to this regulation. However,Joseph
Voelker of Raleigh Central Office Permitting Section of DAQ ran the Potential to Emit(PTE)
calculations at 500 hour per year for an emergency engine(consistent with EPA and DAQ policy for
permitting)and using the DAQ spreadsheet,the PTE for all PSD pollutants are well under the PSD
significance theresholds. As such no PSD avoidance is necessary for this emergency engine. The
regulation has been removed from the permit.
C. Rotocel Operations,including:
• Rotocel extractor, desolventizer, and solvent separation/recovery(ID No. ES-1001-2-1-P) and
one associated chilled water condenser (ID No. CD-31209) venting to one packed tower
scrubber(ID No. CD-1001-2-S-1);
• Two storage and recycle tanks (ID No. ES-M-125A and M-125B) and one associated chilled
water condenser(ID No. CD-1001-2-C-1)venting to one packed tower scrubber(ID No. CD-
1001-2-S-1);

Page 8 of 27
• Process equipment leaks(ID No. ES-100 1-2-1-F); and
• Rotocel Operations wastewater stream(ID No. ES-1001-2-1-WW)
Recovery Operations, including:
• Arcon process tank M-1 (ID No. ES-1001-1-1-P1)and one associated chilled water condenser
(ID No. CD-1001-1-3)venting to one packed tower scrubber(ID No. CD-1001-2-S-1);
• One chilled water condenser(ID No. CD-1001-1-T5B)venting to packed tower scrubber(ID
No. CD-100 1-2-S-1) controlling emissions from:
Stripper T-5 and receiver M-21 (ID No. ES-100 1-1-1-P2); and
Seven fixed roof process tanks of various capacities and one fixed roof methanol storage
tank(ID No. ES-1001-1-1-P3);
• Process equipment leaks(ID No. ES-100 1-1-1-F); and
• Recovery Operations wastewater stream(ID No. ES-1001-1-1-WW)
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration
See Section VI.for more details.
2. 15A NCAC 02D .0614—Compliance Assurance Monitoring
See Section VI.for more details.
3. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Only
See Section VII. for more details.
4. 15A NCAC 020 .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
5. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
D. Botanical Extraction Operations, including:
• Immersion extractor Z-1001,desolventizer Z-1002,day tank 90024,first-stage evaporator EX-
1012, second stage evaporator EX-1013, distillation column EX-90008 and nine process tanks
of various capacities(ID No.ES-1001-11-1-P)and one associated chilled water condenser(ID
No. CD-1001-I I-EX 1002)venting to one cryogenic(nitrogen)condenser system(ID No. CD-
1001-11-EX1003);
• Plant Material Grinder(ID No. MHZ-1002) and one associated bagfilter (ID No.CD-1003-4-
1);
• Process equipment leaks(ID No. ES-1001-11-1-F); and
• Botanical extraction operations wastewater stream(ID No. ES-1001-11-WW)

Page 9 of 27
Biomass Extraction Operations, including:
• Biomass extraction debagging(ID No. ES-1004-1) and one associated cartridge filter(ID No.
CD-1004-1-17171);
PrimM Operating Scenario(POS)
• Immersion extractor Z-41001, desolventizer Z-41002, day tank 490025, iso-hexane storage
tank 490024, first-stage evaporator EX-41012, second stage evaporator EX-41013, distillation
column EX-490008 and nine process tanks of various capacities(ID No.ES-1004-2-P)and one
associated chilled water condenser (ID No. CD-1004-2EX1002) venting to one cryogenic
(nitrogen)condenser system(ID No. CD-1004-2EX 1003);
Secondary Operating Scenario(SOS)
• Immersion extractor Z-41001, day tank 490025, storage tank 490024, first-stage evaporator
EX-4102, second stage evaporator EX-41013, distillation column EX-490008, nine process
tanks of various capacities (ID No. ES-1004-2-P); tray dryer (RV-1002) equipped with a
bagfilter(DC-1001)vented to a condenser(HX-1001) and a solvent knockout pot(TK-1002);
all vented to one associated chilled water condenser (ID No. CD-1004-2EX1002) venting to
one cryogenic(nitrogen) condenser system(ID No. CD-1004-2EX1003);
• Process equipment leaks(ID No. ES-1 004-2-F);
• Wastewater tanks and other similar vessels(ID No. ES-1004-2-WW);
• Biomass extraction operations wastewater stream(ID No. ES-1003-1 0-WW);
• Biomass silo loadout(ID No. ES-1 004-2Silo) and one associated bagfilter(ID No. CD-1004-
2-FF2); and
• Molecular sieve(ID No. ES-MSDU-1024)
1. 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter(PM)from the plant material grinder(ID No.MHZ-1002),the
biomass extraction debagging operation(ID No. ES-1004-1),tray dryer(ID No.RV-1002),and the
biomass silo loadout(ID No.ES-1004-2-Silo)shall not exceed an allowable emission rate.
(a) The allowable emission rates for particulate matter from any stack, vent, or outlet, resulting
from any industrial process for which no other emission control standards are applicable, shall
not exceed the level calculated with the equation E= 4.10(P)061 calculated to three significant
figures for process rates less than or equal to 30 tons per hour. For process rates greater than
30 tons per hour, the allowable emission rates for particulate matter shall not exceed the level
calculated with the equation E= 55.0(P)O-"—40 calculated to three significant figures. For the
purpose of these equations `E"equals the maximum allowable emission rate for particulate
matter in pounds per hour and `P"equals the process rate in tons per hour.
To demonstrate compliance,Avoca is required to perform inspections and maintenance as
recommended by the manufacturer. At a minimum the bagfilters and system ductwork must be
externally inspected monthly and internally inspected annually. Continued compliance is expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
This permit condition applies to the Biomass debagger and silo. Each is limited to an opacity of 20%
under this rule. The limits may not be exceeded more than once in any hour and not more than four
times in any 24-hour period. To ensure compliance,Avoca is required to observe visible emissions
from the debagger and silo baghouses on a semi-annual basis. Avoca is required to submit a semi-
annual summary report for VE observations of the operations. Continued compliance is expected.

Page 10 of 27
3. 15A NCAC 02D .0530—Prevention of Significant Deterioration
See Section VI.for more details.
4. 15A NCAC 02D .0614—Compliance Assurance Monitoring
See Section VI.for more details.
5. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Qn1
See Section VII. for more details.
6. 15A NCAC 02Q .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
7. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
E. Two Biomass Boilers(ID Nos.ES-BBI and ES-BB2)controlled by a bagfilter(ID No.CD-
BBIBIT)
1. Avoca has requested replacing regulation 15A NCAC 02D .0503 with 15A NCAC 02D .0504.
When the boilers were initially installed,they were permitted to fire sage(a plant material)and
wood. The firing of sage was not successful,and thus the boilers are now fired with 100%
wood. The regulatory review of 15A NCAC 02D .0504 is presented below. No other
regulatory review is required at this time.
15A NCAC 02D .0504: Particulates from Wood Burning Indirect Heat Exchangers
This rule applies to emission sources that burn 100%wood. The following equation is used to
calculate the allowable emissions of PM:
E= 1.1698 x Q-0.2211
Where E is the allowable emission limit for particulate matter in pounds per million Btu
(lb/MMBtu) and Q is the maximum heat input million Btu per hour(MMBtu/hr). The heat input
for each boiler is 24 MMBtu/hr each. The allowable emission limit for each boiler is 0.58
lb/MMBtu.
Using AP-42 emission factors,PM emissions from wood residue combustion are estimated to be
less than 0.0114 lb/MMBtu. The emission factors for fabric filters for wood residue combustion
is 0.1 lb/MMBtu. The boilers are expected to comply with this standard for wood firing.
2. 15A NCAC 02D .0516—Sulfur Dioxide Emissions from Combustion Sources

Page 11 of 27
The sulfur dioxide(SO2)emitted by the boilers shall not exceed 2.3 lb/MMBtu heat input. The
boilers combust only wood chip. Sage is no longer burned. The SOz AP-42 emission factor for
wood combustion is 0.025 lb/MMBtu. There are no monitoring/recordkeeping/reporting conditions
for the boilers under this rule in the permit. Continued compliance is expected.
3. 15A NCAC 02D .0521 —Control of Visible Emissions
Boilers ES-BB 1 and ES-BB2 are limited to an opacity of 20%. The limits may not be exceeded
more than once in any hour and not more than four times in any 24-hour period. Avoca is required to
observe boiler opacity once a day. "Normal"is any VE below 20%. Continued compliance is
expected.
4. 15A NCAC 02D .0524—New Source Performance Standards(40 CFR Part 60,%Dc—Standards of
Performance for New Stationary Sources
See Section VI.for more details.
5. 15A NCAC 02D .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart
DDDDD—National Emission Standards for Hazardous Air Pollutants for Major Sources:Industrial,
Commercial,and Institutional Boilers and Process Heaters
See Section VI.for more details.
F. Sclareol Recrystallization(SFG) Operations,including:
• One process tank(ID No.T-3001)*
• Four process tanks(ID Nos. T-3002 through 3005)*
• One storage tank(ID No.T-3006)`
• One process tank(ID No.T-3007)`
• Two centrifuges(ID Nos.C-3001 and C-3002)*
• One reactor (ID No. R-3001) equipped with two process chilled water condensers (EX-
3001 and EX-3002)with control chilled water condenser(ID No. CD-3001)*
• One reactor(ID No.R-3002)*equipped with a process chilled water condenser(EX-3003)
• One reactor(ID No.R-3003)*equipped with a process chilled water condenser(EX-3004)
• One reactor(ID No.R-3004)*equipped with a process chilled water condenser(EX-3005)
• One steam heated dryer(ID No.D-3001)equipped with a process chilled water condenser
(EX-3002)with control chilled water condenser(ID No.CD-3001)`
• One steam heated dryer(ID No.D-3002)equipped with a process chilled water condenser
(EX-3006)with control chilled water condenser(ID No. CD-3002)*
• Process equipment leaks(ID No.ES-1003-10-F)
• SFG Operations wastewater stream(ID No.ES-1003-10-WW)
* These emission sources may be controlled with a chilled water condenser(ID No. CD-3003)
in series with a mineral oil scrubber(ID No. CD-3004-S). These control devices are optional
controls. The Permittee has the option to construct or not construct these devices and has the
option to operate or not operate these devices.
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration

Page 12 of 27
Avoca submitted a PSD application for the SFG expansion(T45 issued). SFG is limited to no more
than 217.4 tons VOC emitted per consecutive 12-month period.
Monitoring/Recording
• VOC emissions must be calculated and recorded at the end of each month. VOC emissions must
be calculated by multiplying the total amount of each VOC-containing material consumed during
the month by the VOC content of the material.
Reporting
• Avoca must submit semi-annual reports containing the following data:
i. the monthly VOC emissions for each of the previous 17 months;and
ii. the yearly VOC emissions for each consecutive 12-month period ending on each month of
the previous six-month period.
2. 15A NCAC 02D .1100—Control of Toxic Air Pollutants(State-Enforceable Only
See Section VII. for more details.
3. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
G. Sclareolide(SDE-1) Operations,including:
• Eleven (11) process tanks of various capacities (ID No. ES-1001-1-3-P, Tank ID Nos. M-
2,M-4,M-4A,M-39,M-44,M-15,M-17,M-17A,M-16,M-11,and TK-1210);
• One centrifuge(ID No. G-17);
• One steam-heated dryer with process condenser(ID No.D-1202);
• Filters(ID No.ES-1001-1-3-Filters);
• SDE-1 process equipment leaks (ID No.ES-1001-3-F); and
• SDE-1 wastewater stream(ID No.ES-1001-1-3-WW)
1. 15A NCAC 02Q .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
2. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
H. Sclareolide(SDE-2) Operations,including:
• One chilled water condenser(ID No. CD-4002) in series with a mineral oil scrubber (ID
No. CD-4003-S)controlling emissions from the following:

Page 13 of 27
o One 17,900 gallon virgin solvent tank(ID No. T-4001);
o Two 6,000 gallon process tanks(ID Nos. T-4017 and T-4018);
o One 4,200 gallon reactor with process condenser(EX-4001)(ID No.R-4004);
o One 4,200 gallon reactor with process condenser(EX-4002)(ID No.R-4005);
o One 4,200 gallon reactor with process condenser(EX-4003)(ID No.R-4044);
o One 1,500 gallon reactor(ID No.R-4015); and
o One centrifuge(ID No. C-4001)
• One dryer with process condenser(EX-4004)with associated chilled water condenser(ID
No. CD-4001)in series with a chilled water condenser(ID No. CD-4002) and mineral oil
scrubber(ID No. CD-4003-S)
• SDE-2 process equipment leaks (ID No.ES-4000-F); and
• SDE-2 wastewater stream(ID No.ES-4000-WW)
1. 15A NCAC 02D .0530—Prevention of Significant Deterioration
Avoca submitted a PSD application for the SDE-2 expansion(T46 issued). SDE-2 is limited to no
more than 354.4 tons of VOC emitted per consecutive 12-month period.
Monitoring/Recordkeeping
• VOC emissions must be calculated and recorded at the end of each month. VOC emissions must
be calculated by multiplying the total amount of each VOC-containing material consumed during
the month by the VOC content of the material.
Reporting
• Avoca must submit semi-annual reports containing the following data:
i. the monthly VOC emissions for each of the previous 17 months;and
ii. the yearly VOC emissions for each consecutive 12-month period ending on each month of
the previous six-month period.
2. 15A NCAC 020 .1111 —Maximum Achievable Control Technology(40 CFR Part 63, Subpart FFFF
—National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical
Manufacturing
See Section VI.for more details.
3. 15A NCAC 02D .1806—Control and Prohibition of Odorous Emissions (State-enforceable only
The facility is subject to this regulation because it has the potential to be a source of odorous
emissions. It requires the facility to utilize management practices or odor control equipment
sufficient to prevent odorous emissions from causing or contributing to objectionable emissions
beyond the facility boundaries.
I. One Maker Deconditioner(ID No.ES-DEC-2001)
1. 15A NCAC 02D .0515—Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter(PM)from the flaker deconditioner(ID No.ES-DEC-2001)shall not
exceed an allowable emission rate.

Page 14 of 27
(a) The allowable emission rates for particulate matter from any stack, vent, or outlet, resulting
from any industrial process for which no other emission control standards are applicable,shall
not exceed the level calculated with the equation E= 4.10(P)061 calculated to three significant
figures for process rates less than or equal to 30 tons per hour. For process rates greater than
30 tons per hour, the allowable emission rates for particulate matter shall not exceed the level
calculated with the equation E= 55.0(P)0-1—40 calculated to three significant figures. For the
purpose of these equations `E"equals the maximum allowable emission rateforparticulate
matter in pounds per hour and `P"equals the process rate in tons per hour.
The deconditioner emissions are controlled by a cyclone(ID No. CD-MHZ-2001). The permit
condition requires monthly visual external inspection of the cyclone. Condition 2.11.l.c.ii was
removed. DAQ doesn't require annual inspections of simple cyclones that aren't equipped with a
door. The results of the monthly visual external inspection must be recorded in a logbook. Submittal
of a semi-annual summary report of the inspection activities is required. Continued compliance is
expected.
2. 15A NCAC 02D .0521 —Control of Visible Emissions
This permit condition applies to the deconditioner. The deconditioner is limited to an opacity of 20%
under this rule. The limits may not be exceeded more than once in any hour and not more than four
times in any 24-hour period. To ensure compliance,Avoca is required to observe the deconditioner
opacity once per month and record observations in a logbook. Semi-annual summary reports are
required. Continued compliance is expected.
VI. NSPS,NESHAPS/MACT,PSD, 112(r), CAM
NSPS
The Permittee is currently subject to New Source Performance Standards (NSPS),40 CFR 60,
Subpart Dc"Standards of Performance for Small Industrial-Commercial-Institutional Steam
Generating Units."
40 CFR Part 60, Subpart Dc—Standards of Performance for Small Industrial Commercial
Institutional Steam Generating Units
40 CFR Part 60,Dc is applicable to units that began construction,modification,or reconstruction
after June 9, 1989, and has a maximum design heat input capacity between 10 and 100 MMBtu/hr.
The two biomass boilers(ID Nos.ES-BB1 and ES-BB2)have a heat input capacity of 24 MMBtu/hr
each. The boilers utilize wood material as the primary fuel currently. The boilers are considered
affected facilities under Subpart Dc since the units were constructed on or after June 9, 1989 (began
operation October 2011). Boiler(ID No.H-104)was installed in 2019 with a rated capacity of
33.475 MMBtu/hr thus is also considered an affected facility subject to Subpart Dc. Boiler H-104
utilizes propane as the primary fuel.
Avoca acknowledges the following:
1. There are no SO2 standards for wood boilers or propane boilers
2. Boilers ES-BB1 and ES-BB2: There are no PM or opacity standards for wood boilers with a heat
input less than 30 MMBtu/hr.
3. Boiler H-104 has a heat input rating greater than 30 MMBtu/hr,but there are no PM or opacity
standards subject to the boiler as it will only fire a gaseous(propane) fuel.

Page 15 of 27
As such,Avoca boilers are not subject to any PM,opacity or SO2 requirements listed in Subpart Dc
for any of the subject boilers.
Record keeping and reporting requirements outlined in 60.48c will also apply to these boilers.
Specifically,60.48c(a) sets forth the initial reporting requirements of 60.7(a)(1&3). Written
notification is required for the following:
• Notification of the date construction is commenced. This must be postmarked no later than 30
days after such date.
• This notification was submitted on May 26,2011,for ES-13131 and ES-13132. Avoca,Inc.
began construction of the two biomass boilers on May 2,2011.
• Boiler H-104 was received as a"mass-produced unit which was purchased and was
delivered in completed form"as outlined in 40 CFR Part 60.7(a)(1). Based on this
provision,it was interpreted that no notification of construction is required for boiler H-
104.
• Notification of the actual date of initial start-up postmarked within 15 days of the actual date.
• This notification was submitted in October 2011 (October 14 for Boiler ES-BB 1 and
October 31 for Boiler ES-13132). Boiler ES-BB 1 commenced operation on October 10,
2011, and Boiler ES-13132 commenced operation on October 24,2011.
• This notification was submitted in January 2019 for Boiler H-104. Boiler H-104
commenced operation on or about January 15,2019.
60.48c(a)(1) stipulates the inclusion of the design heat input of the boilers along with the types of
fuels to be combusted. 60.48c(2-4)are not applicable to any of these boilers. 60.48c(g)requires and
allows the affected facility to record and maintain the amounts of each fuel used during each calendar
month. This permit renewal does not affect this status.
NESHAPS/MALT
National Emissions Standards for Hazardous Air Pollutants(NESHAP)are applicable to major
sources of HAP. A HAP major source is defined as having potential emissions in 10 tpy or more for
any individual HAP and/or potential emissions of 25 tpy or more for total HAP. The following
NESHAPs are applicable to emission sources at the Avoca facility.
40 CFR Part 63, Subpart FFFF—Miscellaneous Organic Chemical Manufacturing NESHAP
(the"MON")
Facility-wide: Heat Exchange Systems
Avoca utilizes a cooling tower system to cool various processes at the Merry Hill facility. The heat
exchange system is subject to heat exchange systems monitoring per 40 CFR 63.2490(Subpart FFFF)
and 40 CFR 63.104(Subpart G),by reference.
Rotocel Operations
The Rotocel operations are subject to 40 CFR Part 63, Subpart FFFF(MON). These operations are
continuous processes and thus are subject to the requirements for continuous process vents.
The Rotocel miscellaneous organic chemical process unit(MCPU)has previously been determined in
the MON Notification of Compliance Status(NOCS)report as having a Group 2 continuous process
vent based on a calculated THE value of> 1.9. The THE accounts for the two 19,500-gallon

Page 16 of 27
process/storage tanks(ID Nos. ES-125A and ES-125B). The two 19,500-gallon process/storage tanks
when only storing material would never achieve a vapor pressure threshold to change the
determination from Group 2 storage tanks. Equipment leaks comply via 40 CFR Part 63, Subpart
UU. There are only Group 2 process wastewater streams from the Rotocel MCPU;however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the Rotocel MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the process vents,equipment leaks,
storage tanks, fugitives or wastewater requirements for MON.
Recovery Operations
The Recovery operations are subject to the(MON). These operations are continuous processes and
thus are subject to the requirements for continuous process vents.
The Recovery MCPU vents emissions from the Acron process tank(ID No. M-1), stripper(ID No. T-
5), and receiver(ID No. M-21)process vents to the Rotocel MCPU control device. The THE
calculated for Rotocel includes the Recovery MCPU contribution and therefore determined to be
Group 2. Additionally,there are other continuous process vents (not venting to the Rotocel control
device)in the Rotocel MCPU that have been determined to be Group 2. There is one Group 2 storage
tank(ID No. M-25)with no control requirements. Equipment leaks comply via 40 CFR Part 63,
Subpart UU. There is one Group 1 process wastewater stream from the Recovery MCPU that is
discharged to—and controlled by—the 95%efficient biological treatment system. There are no
transfer racks in the Recovery MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the process vents,equipment leaks,
storage tanks, fugitives or wastewater requirements for MON.
Concrete Operations
These operations are not currently operating. The current permit indicates the Concrete Operations
are subject to MON and, if they operate,Avoca will submit an NOCS update prior to utilizing HAP.
Avoca is not requesting any updates to this scenario at this time.
Sclareol Recrystallization(SFG) Operation
The SFG operations were previously subject to the MON due to the use of n-hexane. Avoca changed
operations and is no longer using a HAP in these operations and thus SFG is no longer subject to
MON.
Sclarecolide Operations (SDE-1 and SDE-2)
SDE Operations(SDE-1)utilize n-hexane(HAP) in the process and as such was determined to be
subject to the existing source requirements under the MON. The existing SDE-1 was determined to
be a Group 2 source under Subpart FFFF and therefore for compliance the facility tracked the number
of each type of batch in order to remain a Group 2 batch process with batch process vent emissions
less than 10,000 lb/yr.
The SDE equation is:

Page 17 of 27
Organic HAP= [2.27(pounds/tank f ill)x Btf] + [4.80(pounds/batch)x Breg] +
[3.66(pounds/batch)x B,J+ [4.19(pounds/batch)x Bte]
Where: Breg=The number of regular batches processed in the SDE Operations; and
Bree=The number of recrop batches processed in the SDE Operations
Bte=The number of third crop batches processed in the SDE Operations; and
Btf=The number of hexane tank(M-2)fills.
The SDE-1 MCPU does not have any MON-subject storage tanks; all are considered to be process
tanks. If any of the process tanks were used as storage tanks, all would potentially be Group 2
because they are less than 10,000 gallons in size. Equipment leaks comply via 40 CFR Part 63,
Subpart UU. There are only Group 2 process wastewater streams from the SDE-1 MCPU; however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the SDE-1 MCPU.
The SDE-1 operations have not operated since March 2017. Avoca request to keep this process
permitted in the event there is a need for future operation.
SDE-2 MCPU was determined to be a new source under the MON. It has Group 1 batch process
vents, and thus must reduce the organic HAP by>95%. The emissions from SDE-2 are controlled
with a Mineral Oil System(MOS System)which consists of a chilled water condenser(ID No. CD-
4002) and mineral oil scrubber(ID No. 4003-S). Avoca is monitoring the following:
• Process gas temperature into the absorber is not> 10517°
• Mineral oil temperature into the absorber is not> 105F°
• Mineral oil temperature in the stripper is not<20017°
• Mineral oil flowrate to the stripper is not> 10 gpm and
• Install calibrate and operate a flow indicator at the inlet and outlet of control device to identify no
flow.
The SDE-2 MCPU has one MON-subject storage tank that is a Group 1 tank. The virgin hexane
material tank(ID No. T-4001)is 17,900 gallons. The tank has a total HAP maximum true vapor
pressure of approximately 13.6 kPa. The tank will be vented in the closed vent system to the MOS
system and thus is reduced by 95%. Equipment leaks comply via 40 CFR Part 63, Subpart UU.
Wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the SDE-2 MCPU.
Ethyl Vanillin Glucoside(EVG)Operations
The EVG operations are subject to the MON since the operations have the potential to utilize
methanol and chloroform(trichloromethane).
The current permit contains the following equation for Group 2 batch process vents;
Organic HAP= [1.0(pounds/batch)x B]
Where: B=The number of batches processed in the EVG Operations
The EVG MCPU does not have any MON-subject storage tanks; all are considered to be process
tanks. If any of the process tanks were used as storage tanks, all would potentially be Group 2
because they are less than 10,000 gallons in size. Equipment leaks comply via 40 CFR Part 63,

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Subpart UU. There are only Group 2 process wastewater streams from the EVG MCPU; however,
wastewater is discharged to a 95%efficient biological treatment system. There are no transfer racks
in the EVG MCPU.
There are no changes associated with these operations that must be reflected in a notification or
semiannual report. Avoca is not requesting any updates for the equipment leaks, storage tanks,
fugitives or wastewater requirements for MON.
40 CFR Part 63, Subpart ZZZZ—Stationary Reciprocating Internal Combustion Engines
(RICE MALT)
The MACT standard for stationary reciprocating internal combustion engines(RICE)was first
promulgated on June 15,2004, and only regulated existing and new stationary RICE at major sources
of HAP with a site rating>500 brake horsepower(hp).
On February 17,2010,EPA finalized the newest portions of the RICE NESHAP. Under these new
regulations,many previously unregulated engines,including those designated for emergency use,
became subject to federal regulations,including emissions standards,control requirements,or
management practices.
A stationary RICE is"existing"if it commenced construction or reconstruction before December 19,
2002, for RICE with a site rating of>500 hp located at a major source of HAP. A stationary RICE is
"existing"if it commenced construction or reconstruction before June 12, 2006, for RICE with a site
rating of<500 hp located at a major source of HAP.
The Avoca Merry Hill plant has the following emergency units at the site subject to 40 CFR Part 63,
Subpart ZZZZ:
• One No. 2 fuel oil-fired emergency generator(ID No.E105, 2,935 hp)and associated
catalytic oxidizer(ID No. CD-CatOXI)that was installed on May 12, 2005. As such,this
unit is considered a"new"source.
• Three No. 2 fuel oil-fired emergency generators (ID Nos.E101,E102,and E104, 587 hp,
760 hp, and 401 hp,respectively)that were constructed before June 12,2006,and therefore
are all considered"existing sources"; and
• One compression ignition emergency fire pump(ID No.FP,285 hp)that was constructed
before June 12,2006, and therefore is an"existing source."
Engine E104 and FP(Units<500 hp)
Based on the hp ratings these engines must meet the requirements listed below:
During S
• Minimize the engine's time spent at idle and minimize the engine's startup to a period needed
for appropriate and safe loading of the engine,not to exceed 30 minutes.
Work Practice Standards:
• Change oil and filter every 500 hours of operation or annually,whichever comes first;
• Inspect air cleaner every 1,000 hours of operation or annually,whichever comes first;
• Inspect all hoses and belts every 500 hours of operation or annually,whichever comes first,
and replace as necessary;
• Install non-resettable hours meter; and

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• Operate and maintain the engine and after-treatment control device (if any) according to the
manufacturer's emission—related written instructions or develop a maintenance plan.
Recordkeeping:
• Copies of Notifications
• Occurrence and duration of each malfunction of engine, control or monitoring equipment
• Records of maintenance performed
• Actions taken during malfunction to minimize emissions
• Records of hours of operation recorded with non-resettable hours meter
• Records to show continuous compliance with operating and maintenance requirements.
Reporting_
• Semiannual report of monitoring and recordkeeping activities
All engines(E101,E102,E104 and FP) and E105
• Must be in compliance with emission limitations and operating limitations at all times.
• Operate and maintain source in a manner consistent with safety and good air pollution control
practices for minimizing emissions.
• Operation other than emergency,maintenance, and testing, emergency demand response and
operation in non-emergency more than 50 hours per year is prohibited.
• No time limit for emergency operations
• May operate engine for following times for a maximum of 100 hours each calendar year:
• Maintenance checks and readiness testing
• Emergency demand response
• Periods where a deviation of voltage or frequency of 5%or greater below standard
voltage or frequency.
• Emergency stationary RICE 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. 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 a facility to supply
power to an electric grid or otherwise supply power as part of a financial arrangement with
another entity.
This permit renewal does not affect these requirements. Continued compliance is expected.
40 CFR Part 63, Subpart DDDD—Boiler and Process Heater NESHAP
40 CFR Part 63, Subpart DDDDD applies to industrial, commercial, and institutional boilers and
process heaters located at a major source of HAP emissions. An affected source is any existing,new
or reconstructed industrial, commercial,and institutional boilers and process heaters located at a
major source of HAP emissions.
Three boilers at this facility are classified as new sources per 40 CFR 63.7490(b)since the units are
located at a major source of HAP and commenced construction on or after June 4,2010; (ID Nos. ES-
BB1,ES-BB2, and H-104). There are also two existing boilers(ID Nos. H-101 and H-102). These
boilers fire ultra-low sulfur diesel(ULSD) fuel.
Biomass Boilers (ES-BBI and ES-BB2)

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The biomass boilers are considered stokers designed to burn biomass/bio-based solid(40 CFR
63.7499(d)). The boilers must comply with the emission limitations in Table 1,work practice
standards in Table 3, and operating limits in Table 4 of Subpart DDDDD.
The boilers have demonstrated compliance with the following emission limits found in Table 1 for a
stoker designed to burn biomass/bio-based solids.
• PM: 0.03 lb/MMBtu heat input
• HCL: 0.022 lb/MMBtu heat input
• CO: 620 ppm by volume
• Hg 8.0 E-07 lb/MMBtu heat input
The boilers have complied with the work practices standards in Table 3 for a new unit subject to
emission limits:
• Minimize the unit's startup and shutdown periods following the manufacturer's recommended
procedures.
• The facility has developed operating limits for the boilers listed in Table 4.
• The bagfilter installed on the boilers is equipped with a bag leak detection system.
Performance Testing
Avoca performed testing for the boilers on February 21, 2013, and December 19,2013 and
demonstrated compliance. Per 40 CFR 63.7515(b),Avoca conducted two consecutive tests with each
limit less than 75%of the standard. As such, a retest of the boilers are increased to within 37 months
of the last test. Avoca has performed subsequent testing on December 14,2016,and December 19,
2019. The next test is required January 19,2023.
Operating Limits
The following criteria as outlined in Table 4 of Subpart DDDDD were utilized to establish the
operating limits:
• Fabric Filter Control: Install and operate a bag leak detection system according to 40 CFR
63.7525 and operate such that the alarm does not sound more than 5% of the operating time
during each 6-month period.
• Performance Testing: Maintain the operating load of each unit such that it does not exceed
110%of the highest hourly average operating load recorded during the most recent test.
• Oxygen Analyzer System: For boilers and process heaters subject to CO emission limit that
demonstrate compliance with an 02 analyzer system as specified in 40 CFR 63.7525(a),
maintain the 30-day rolling average oxygen content at or above the lowest hourly average
oxygen concentration measured during the CO performance test, as specified in Table 8. This
requirement does not apply to units that install an oxygen trim system since these units will
set the trim system to the level specified in 40 CFR 63.7525(a). The boilers at Avoca are
equipped with an oxygen trim system.
During the last performance testing the operating limits were set as follows using the Subpart
DDDDD regulations:
• Boilers are equipped with a bag leak detection system.

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• Operating Load: The operating limit is 1.1 times this maximum load or 24,049 lb/hr total
steam output [from December 2019 test]
• Oxygen Limit: The minimum oxygen content recorded by the oxygen trim system during the
performance test was 10.2% for Boiler 1 and 8.6% for Boiler 2 [from December 2019 test].
Per 40 CFR 63.7525(a)(7), operate an oxygen trim system with the oxygen level set no lower
than the lowest hourly average oxygen concentration measured during the most recent CO
performance test as the operating limit for oxygen according to Table 7 of this subpart.
Fuel Testing
Avoca is not performing fuel testing as a method of demonstrating compliance.
Monitoring/Recordkeeping and Reporting
Avoca is keeping records of all oxygen and steam outputs from the boilers. The bag leak detection
data is also recorded and maintained electronically. Per 40 CFR 63.7550,Avoca is submitting
semiannual reports as outlined in Table 9 and uploading data to the CEDRI system.
Energy Assessment(EA)Requirement
The one-time EA is not required for new boilers.
Tune-Up Requirements
Per Table 3,new boilers with a continuous trim system must perform a tune up every 5 years (last
tune up was September 1,2021)
Notice of Compliance Status
The last NOCS for ES-BB 1 and ES-BB2 was submitted February 6, 2020.
Two No.2 Fuel Oil-Fired Boilers(H-101 and H-102)
The ULSD fired boilers at the Avoca site are considered existing affected under Subpart DDDDD.
The boilers are designed to fire ULSD No. 2 fuel oil, and are rated at 20.3 MMBtu/hr each. The
boilers are classified as units designed to burn light liquid subcategory(40 CFR 63.7499(u)). The
boilers are required to document compliance with the emission limits in Table 2 to Subpart DDDDD.
• PM: 0.0079 lb/MMBtu heat input
• HCL: 0.0011 lb/MMBtu heat input
• CO: 130 ppm by volume on a dry basis, 3%Oz
• Hg: 2.0 E-06 lb/MMBtu heat input
Performance Testing/Monitoring/Recordkeeping and Reporting
Testing was performed on August 20 and 21, 2019 and documented compliance. Per 40 CFR
63.7515(h)units designed to burn light liquid fuel and that combust ULSD do not need to conduct
further performance tests if compliance is demonstrated during the initial testing and they
demonstrate ongoing compliance with emission limits by monitoring and recordkeeping the type of
fuel combusted on a monthly basis.

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Fuel Testing
Avoca is not performing fuel testing as a method of demonstrating compliance.
Energy Assessment(EA)Requirement
The one-time EA was required for existing boilers H-101 and H-102. The EA was completed on May
9,2019.
Tune Up Requirements
Per Table 3,new and existing boilers without a continuous trim system and heat capacity greater than
10 MMBtu/hr must perform an annual tune-up. The last annual tune-up was performed on July 13,
2021.
Notice of Compliance Status
The NOCS for H-101 and H-102 was submitted October 3,2019 for this one-time test.
Propane Boiler(H-104)
The propane boiler is not subject to emission limits or testing requirements. The boiler will be a"unit
designed to burn gas 1 subcategory"since it fires propane and will be subject to the work practice
standards in Table 3 in Subpart DDDDD.
Tune-Up Requirements
Initial tune-up for the boilers at the facility(Table 3 of the rule)
• No continuous trim system and heat capacity greater than 10 MMBtu/hr: Tune up with 13
months of startup.
Subsequent Tune-up Requirements [40 CFR 63.7515(d)]
• No continuous trim system: Each annual tune-up must be no more than 13 months after the
previous tune-up.
Energy Assessment(EA)Requirements
An EA is not required for new boiler H-104
Recordkeeping Requirements
Records of the dates and the results of each required boiler tune-up.
Reporting Requirements
Periodic Compliance Reporting:
The boilers are subject only to a requirement to conduct a annual tune-up, and not subject to
emission limits or operating limits. Therefore,Avoca may submit an annual compliance report,
as applicable instead of a semi-annual compliance report [40 CFR 63.7750(b)].

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• The annual report must be postmarked or submitted no later than January 31.
• Electronic compliance reporting under CEDRI electronic system is operational and reports
should be uploaded to the system.
Avoca states in their application that all Compliance reports have been submitted by January 31 each
year and uploaded into CEDRI.
Notice of Compliance Status
If there is an initial compliance requirement,then a NOCS is required.
Since this is a new boiler:
1. a tune-up at start-up was not required;
2. an energy assessment was not required; and
3. performance testing was not required.
Thus, an NOCS is not required for this unit.
The applicability of this Subpart to these sources is not affected with this renewal. Continued
compliance is expected.
PSD
North Carolina has implemented the federal PSD requirements of 40 CFR 51.166 under North
Carolina Regulation 15A NCAC 02D .0530. The PSD program regulates emissions from major
stationary sources of regulated air pollutants. For the purposes of the PSD program, a major
stationary source is defined as any one of the following;
1. Any stationary source that is listed as one of the 28 named source categories in Title 40 of the
Code of Federal Regulations (40 CFR), Part 51.166(b)(1)(i) which emits, or has the potential
to emit, 100 tons per year(tpy) or more of any pollutant subject to regulation under the ACT,-
2. Any stationary source that is not listed as one of the 28 named source categories in 40 CFR
Part 51.166(b)(1)(i) which emits, or has the potential to emit, 250 tons per year(TPY) or
more of any pollutant subject to regulation under the ACT.
According to the application,the Avoca facility has previously been identified by DAQ as a chemical
plant and is a 100 tpy major source. The facility is currently operating under PSD BACT
requirements for multiple sources as well as PSD avoidance conditions for several emission sources.
Avoca is not requesting any changes to the current permit conditions.
112(rl—The facility is not subject to Section 112(r)of the Clean Air Act requirements because it
does not store one or more of the regulated substances in quantities above the thresholds in the Rule.
This permit modification does not affect this status.
CAM
40 CFR Part 64 is applicable to any pollutant-specific emission unit,if the following three conditions
are met:
• the unit is subject to any(non-exempt: e.g.pre November 15, 1990, Section 111 or Section
112 standard)emission limitation or standard for the applicable regulated pollutant.
• the unit uses any control device to achieve compliance with any such emission limitation or

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standard.
• the unit's pre-control potential emission rate exceeds either 100 tpy(for criteria pollutants)
or 10/25 tpy(for HAP's).
Avoca has previously evaluated Part 64 and has determined that four emission sources are subject to
this rule and CAM is included in the current permit.
The applicability analysis for the sources that are equipped with a control device and evaluated for
CAM are shown in the following table below.
Source Name DAQ Applicable Pollutant Uncontrolled Major Subject to
Rule Emissions Source CAM/
(tons/yr) Threshold
(tons/ r)
Yes—
Rotocel 15A NCAC 02D VOC >100 100 included
Operations .0530 in the
current
permit
Yes—
Recovery 15A NCAC 02D VOC >100 100 included
Operations .0530 in the
current
permit
Sclareol No
Recrystallization 15A NCAC 02D VOC >100 100
SFG .0530
Sclareolide No Applicable VOC NA 100 No
SDE-1 Regulation
Sclareolide 15A NCAC 02D No—see
(SDE-2) 1111 MACT Subpart VOC/HAP >100 100 below
FFFF
Plant Nutrient No Applicable
Extraction Regulation VOC NA 100 No
PNE
Ethyl Vanillin No Applicable
Glucoside Regulation VOC NA 100 No
(EVG)
Yes—
Botanical 15A NCAC 02D VOC >100 100 included
Exaction .0530 in the
current
permit
Yes—
Biomass 15A NCAC 02D VOC >100 100 included
Extraction .0530 in the
current
permit

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Biomass Boilers 15A NCAC 02D No—see
ES-BB 1 &ES- 1111 MACT Subpart PM NA 100 below
BB2 DDDDD
Emergency No Applicable NO. NA 100 No—see
Generator E105 Regulation below
SDE-2
SDE-2 are subject to 40 CFR 63, Subpart FFFF,and therefore exempt from applicability to CAM for
the control of VOC. Based on the above information, SDE-2 is not subject to the CAM regulations.
Biomass Boilers ES-BB1 and ES-13132
The boilers are subject to 40 CFR 63, Subpart DDDDD, and therefore exempt from the applicability
to CAM for the control of PM. Based on the above information,the boilers are not subject to CAM
regulations.
Emergency Generator E105
The limited use generator is equipped with a catalytic oxidizer which controls VOC and CO. The
avoidance limit is for NOx which is not controlled by the control device. Thus,the unit is not
applicable to CAM since the unit does not use a control device to achieve compliance with any such
emission limitation or standard.
VII. Facility Wide Air Toxics
15A NCAC 02D .1100: Control of Toxic Air Pollutant Emissions
A toxic air pollutant(TAP)permit application shall include an evaluation of the TAP emissions from
a facility for any non-NESHAP source. See discussion in 15A NCAC 02Q .0700: "Toxic Air
Pollutant Procedures."
15A NCAC 020 .0700: Toxic Air Pollutant Procedures
This rule establishes procedures for documenting compliance for a modification that results in an
increase in NC air toxics. Compliance can be demonstrated by:
1. Documenting that facility wide emissions are below the thresholds in 15A NCAC 02Q .0711
2. Netting to show there has been a no net increase in NC air toxics; or
3. Modeling to document compliance with the ambient levels in 15A NCAC 02D .1100.
Based upon recent legislative action exempting sources subject to 40 CFR Part 61 or Part 63 from the
North Carolina Air Toxics program, sources that are subject to a MACT or GACT requirement would
be exempt from the NC Air Toxics program and the associated modeling requirements. Certain
operations are subject to the MON NESHAP and Avoca previously provided a model that
documented compliance with NC Air Toxics in the April 2013 construction application. Permit
Condition 2.2 A.1 simply states for any non-NESHAP source, any increase in toxic air pollutants
must be evaluated. Avoca's toxics limitations were removed from permit T40. As allowed under
Session Law 2012-91 House Bill 952,the facility is not required to evaluate toxics from MACT
sources(the burden belongs to DAQ). All of the modeled toxics sources are MACT,FFFF,DDDDD,
or ZZZZ affected. Changes in toxics emissions due to the modifications made under T40 and T41

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were modeled by Avoca and reviewed by Alexander Zarnowski(5/01/2013)and Tom Anderson
(5/16/2013). The DAQ permit reviews stated that the modifications did not pose unacceptable toxics
health risks. Modifications in T42 through T52 did not require re-modeling by DAQ Permits.
Avoca requested removal of all NC Air Toxics from the permit since all sources of air toxics are
covered under a NESHAP. DAQ has thus removed all TAPS from the permit.
VIII.Facility Emissions Review
See Table in the header for a summary of the actual emissions as reported to DAQ from the years
2015 to 2019.
IX. Stipulation Review
The facility was last inspected by Betsy Huddleston on 1/25/2019, 1/29/2019 and 1/30/2019
(Inspection Report—04/26/2019). Based on her observations the facility appeared to be in
compliance with their Title V permit requirements.
X. Affected State(s)Review
A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice
will provide for a 30-day comment period,with an opportunity for a public hearing. Consistent with
15A NCAC 02Q .0525,the EPA will have a concurrent 45-day review period. Copies of the public
notice shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 02Q
.0522, a copy of each permit application,each proposed permit and each final permit pursuant shall
be provided to EPA. Also,pursuant to 02Q .0522,a notice of the DRAFT Title V Permit shall be
provided to each affected State at or before the time notice is provided to the public under 02Q .0521.
XI. Conclusions,Comments, and Recommendations
PE Seal
Pursuant to 15A NCAC 02Q .0112"Application Requiring a Professional Engineering Seal,"a
professional engineer's seal(PE Seal)is required to seal technical portions of air permit applications
for new sources and modifications of existing sources as defined in Rule .0103 of this Section that
involve:
(1) design;
(2) determination of applicability and appropriateness; or
(3) determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer's seal(PE Seal)was not required for this renewal.
Zoning
A zoning consistency determination was not required for this renewal.
Recommendations
WaRO recommends issuance of the permit and was sent a DRAFT permit prior to issuance(See
Section III of this document for a discussion).
The Raleigh Central Office(RCO)concurs with WaRO's recommendation to issue the Air Permit
No. 01819T54.

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