AQ_F_0800107_20130118_PRMT_FacPrmtLtr

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]04 Mellen Rd.
J ®� L N New Bern,NC 28562
O:360.750.358383
Energy Solutions Group F:360.750.3483
January 18, 2013
Ms.Betsy Huddleston
Washington Regional Office
NCDENR-Division of Air Quality
943 Washington Square Mall
Washington,NC 27889
RE: Allowed Solid Fuels under Permit#10064R00 for the W.E.Partners I,LLC facility at Cofield,NC and
Permit#I0064ROI for the W.E. Partners II,LLC at Lewiston,NC.
Dear Ms.Huddleston;
As documented under Permit #10064R00 and Permit #10126R01, for the Cofield and Lewiston biomass
cogeneration plants,the facilities are currently permitted to use the following solid fuels;
• Green wood chips,bark and other logging residues
• Peanut hulls
• Cotton gin residues
• Soybean hulls
As you are aware, Environmental Protection Agency has recently promulgated the latest iteration of the rule
40 CFR 241.2, defining Non-Hazardous Secondary Materials That Are Solid Waste;
As defined in 40 CFR 241.2: "Clean cellulosic biomass means those residuals that are akin to
traditional cellulosic biomass, including, but not limited to: agricultural and forest-derived biomass
(e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, tree harvesting
residuals from logging and sawmill materials, hogged fuel, wood pellets, untreated wood pallets);
urban wood (e.g., tree trimmings, stumps, and related forest-derived biomass from urban settings);
corn stover and other biomass crops used specifically for the production of cellulosic biofuels(e.g.,
energy cane, other fast growing grasses, byproducts of ethanol natural fermentation processes);
bagasse and other crop residues (e.g.,peanut shells, vines, orchard trees, hulls, seeds, spent grains,
cotton byproducts, corn and peanut production residues, rice milling and grain elevator operation
residues); wood collected from forest fire clearance activities, trees and clean wood found in
disaster debris, clean biomass from land clearing operations, and clean construction and
demolition wood. These fuels are not secondary materials or solid wastes unless discarded.
In addition, the revised rule established a"Categorical Non-Waste Determinations for resonated woods are
non-wastes when used as fuels.
Based on the above, I am requesting a determination from the Washington Regional NCDEQ to determine if
the following fuel needs to be specifically added to Permit #10064ROO and Permit #10126R01 and, if so,
please proceed with doing so. If not specifically needed to be added, then please provide confirmation that
we can proceed with using the following clean materials as solid fuel for the facilities.
• Untreated pallets
• Clean wood from disaster debris
• Clean biomass from land clearing operations
• Clean construction and demolition wood
• Resonated woods.
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Should you have additional questions or require additional information, please do not hesitate in contacting
me at the number above.
Sincerely,
Garald B.Cottrell
President
Wellons Energy Solutions LLC.
W.E. Partners I,LLC
W.E. Partners 11,LLC
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