AQ_F_1000060_20211018_PRMT_Permit_03753R14

ROY COOPER e"STA
TE'
Governor
ELIZABETH S.BISER u `�
Seemlary
ha,�s+e
MICHAEL A.ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
October 18, 2021
Mr. Mike Rouse
Facility Manager
Carolina Pole Leland, Inc.
P.O. Box 370
Leland,NC 28451
Subject: Air Permit No. 03753R14
Carolina Pole Leland, Inc.
Leland, Brunswick County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1000060
Dear Mr. Rouse:
In accordance with your completed application received September 29, 2021, we are
forwarding herewith Permit No. 03753R14 to Carolina Pole Leland, Inc., Leland, Brunswick
County,North Carolina for the construction and operation of air emissions sources or air cleaning
devices and appurtenances. Additionally,any emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the
records retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 150B-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
Unless exempted by a condition of this permit or the regulations, construction of new
North Carolina Department of Environmental Quality I Division of Air Quality
Wilmington Regional Qffioe 1127 Cardinal Drive Extension I Wimington,NC 28405
N.TIM CMIt%MN
pi N tl 910.796.7215 T 1 910.350.2004 F

Mike Rouse
October 18, 2021
Page 2
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from October 18, 2021 until September 30, 2029, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Thu permit revision is a result of a permit renewal request with no other chances. The
Permittee is responsible for carefully reading the entire permit and evaluating the
requirements of each permit stipulation. The Permittee shall comply with all terms,
conditions, requirements, limitations and restrictions set forth in this permit. Noncompliance
with any permit condition is grounds for enforcement action, for permit termination,
revocation and reissuance, or modification, or for denial of a permit renewal application.
Should you have any questions concerning this matter, please contact Jmanda Dunston at
910-796-7238.
Sincerely,
Brad Newland, Wil ington Regional Supervisor
Division of Air Quality,NC DEQ
Enclosures
c: Wilmington Regional Office
WiRO Permit Coordinator
Ibeam Doc Mod_

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 03753R14
Issue Date: October 18, 2021 Effective Date: October 18, 2021
Expiration Date: September 30, 2029 Replaces Permit: 03753R13
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, Brunswick County,North Carolina
Permit Class: Synthetic Minor
Facility ID# 1000060
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
Tone wood/bark-fired boiler rmuluccyhcelone 46h -five(16.0 million Btu per hour sin diameter
ES-1 (NESHAP 6J) aximum heat input) CDl
constructed 1951,put in
service in 1988
Three steam heated dry kilns
ES-2 (approximately two X 9,000 N/A N/A
cubic feet each and one X
12,000 cubic feet)
ES-3 (NESHAP 6Q) wood preserving operations, N/A N/A
fugitive emissions
one wood-fired boiler(20.1 two(2)conventional Multi.
ES-4 million Btu per hour cyclones in series(16 tubes,
(NSPS De,NESHAP 61) maximum heat input) CD2 six(6)inches in diameter
constructed 1999,put in — —-- each) ---
service in 2017
in accordance with the completed application 1000060.21 A received September 29, 2021 including
any plans, specifications, previous applications, and other supporting data, all of which are filed
with the Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated
as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING. REPORTING, OR MONITORING REQUIREMENTS•

Permit No. 03753RI4
Page 2
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code(NCAC), Subchapter
2D .0202, 2D .0504, 2D .0521, 2D .0524 (40 CFR 60, Subpart Dc), 2D .0535, 2D .0540, 2D
.0611, 2D .1100, 2D .1111 (40 CFR 63, Subpart JJJJJJ, Subpart QQQQQQ -- Wood
Preserving Area Sources) and 2Q .0315.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT-The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request(with application Form A) should be submitted
to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration date of this
permit,the Permittee shall submit the air pollution emission inventory report(with
Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C. General
Statute 143 215.65. The report shall be submitted to the Regional Supervisor,DAQ and shall
document air pollutants emitted for the 2028 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0504
"Particulates from Wood Burning Indirect Heat Exchangers," particulate matter emissions
from the wood burning indirect heat exchangers shall not exceed the allowable emission
rates listed below:
_....._r_. ssion Limit
Source (bm'mill on Btu)
one wood/bark-fired boiler (16.0 million Btu per hour 0.63
maximum heat input, ES-1)
one wood-fired boiler (20.1 million Btu per hour 0.60
maximum heat input, ES-4
4. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured as of July 1, 1971, shall not be more than 40 percent opacity when averaged
over a six-minute period, except that six-minute periods averaging not more than 90 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with a visible emissions standard in 15A
NCAC 2D .0524 "New Source Performance Standards" or .I 110 "National Emission
Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521
visible emissions standard.
5. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For one wood-
fired boiler(20.1 million Btu per hour maximum heat input) constructed 1999, put in service
in 2017 (ID No. ES-4),the Permittee shall comply with all applicable provisions, including
the notification, testing, reporting, recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source
I

Permit No. 03753R14
Page 3
Performance Standards" (NSPS)as promulgated in 40 CFR 60, Subpart De, including
Subpart A "General Provisions."
a. NSPS Reporting Requirements - In addition to any other notification requirements to
the Environmental Protection Agency (EPA),the Permittee is required to NOTIFY
the Regional Supervisor, DAQ, in WRITING, of the following:
i. The date construction(40 CFR 60.7) or reconstruction(40 CFR 60.15) of an
affected source is commenced,postmarked no later than 30 days after such
date. This requirement shall not apply in the case of mass-produced facilities
which are purchased in completed form;
ii. The actual date of initial start-up of an affected source,postmarked within 15
days after such date. If the affected source is permitted to bum multiple fuels,
then the actual date of start-up, for each fuel, must be submitted and
postmarked within 15 days after such date;
b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping
requirements of the EPA, the Permittee is required to maintain records as follows:
i. The amounts of each fuel combusted during each month; and
ii. All records required under this section shall be maintained for a period of two
years following the date of such record.
6. NOTIFICATION REQUIREMENT - As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i, the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.

Permit No. 03753RI4
Page 4
7. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 213 .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints are received or excessive
fugitive dust emissions from the facility are observed beyond the property boundaries for six
minutes in any one hour(using Reference Method 22 in 40 CFR, Appendix A), the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile working, plant parking lots,
and plant roads (including access roads and haul roads).
8. MULTI-CYCLONE REQUIREMENTS -As required by 15A NCAC 2D .0611, particulate
matter emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform an annual (for each 12 month period following the initial inspection)
internal inspection of the multi-cyclone system. In addition, the Permittee shall
perform periodic inspections and maintenance (I&M) as recommended by the
manufacturer.
b. Recordkeeping Requirements - The results of all inspections and any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a multi-cyclone logbook. Records of all maintenance activities shall be recorded in
the logbook. The multi-cyclone logbook(in written or electronic format) shall be
kept on-site and made available to DAQ personnel upon request.
9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REOUIREMENT- Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration, the
permit limits in the table below shall not be exceeded. The Permittee has submitted a toxic
air pollutant dispersion modeling analysis dated February 9, 2016 for the facility's toxic air
pollutant emissions as listed in the below table. The modeling analysis was reviewed and
approved by the DAQ Air Quality Analysis Branch(AQAB) on March 1, 2016. Placement
of the emission sources, configuration of the emission points, and operation of the sources
shall be in accordance with the submitted dispersion modeling analysis and should reflect
any changes from the original analysis submittal as outlined in the AQAB review memo.
Affected Source(s) Toxic Air Emission
Pollutant P Limit
Three steam heated dry kilns (approximately two X 9,000 Acrolein 0.1841b/hr
cubic feet each and one X 12,000 cubic feet, ES-2) (107-02-8)
Three steam heated dry kilns (approximately two X 9,000 Formaldehyde
cubic feet each and on X 12,000 cubic feet, ES-2) (50-00-0) 0.5041b/hr

Permit No. 03753R14
Page 5
a. Recordkeeping Requirements—The following recordkeeping requirements apply:
i. The three kilns were modeled at the maximum batch capacity; meaning Kiln
1 and 2 together(9,000 cubic feet each)at a capacity of 108,000 bd-ft total
softwood per 55 hours (or 1,964 bd-ft per hour) and Kiln 3 (12,000 cubic
feet) at a capacity of 144,000 bd-ft softwood per 72 hours (or 2,000 bd-ft per
hour). This equated o 3,458,333 cubic feet of total wood dried annually.
Thus, the facility shall keep a logbook of all batch production cycles showing
the amount of cubic feet in each kiln during each batch during the calendar
year. This logbook shall be kept on site at all times and made available to the
DAQ inspector upon request. No reports are required to a sent to the
Regional Supervisor.
b. Reporting Requirements—For compliance purposes, the following shall be retained
on site for review and inspection by the Regional Inspector, DAQ at any time:
i. The kiln drying production rates as described in paragraph a.(i). No reports
are required to be sent to the Regional Supervisor. These records shall be
kept on site for a minimum of two years.
10. 15A NCAC 2D .I I I I "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" - For the
following equipment,the Permittee shall comply with all applicable provisions, including the
notification,testing, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 2D .I 111, "Maximum Achievable Control Technology" as
promulgated in 40 CFR 63, Subpart(s) below, including Subpart A "General Provisions."
(Emission Sources) Regulation
Facility Wide Subpart 000000 -- Wood Preserving Area Sources
Pressure treatment processes. These requirements are only for facilities using wood
preservatives containing chromium, arsenic, dioxin/furan or methylene chloride.
a. Emission Standards—Pursuant to 40 CFR 63.11430.
i. Wood preservatives shall be applied to the wood product inside a retort or
similarly enclosed vessel.
ii. Treated wood product shall be stored on drip pads or in a primary
containment area to convey preservative drippage to a collection system until
dripping has ceased.
iii. The pressure retort or vessel shall be fully drained to the extent possible prior
to opening the vessel door.
iv. All spills shall be promptly collected.
V. In the event of a malfunction, corrective actions or preventative measures
shall be completed prior to resuming operation.
b. Recordkeeping Requirements—Pursuant to 40 CFR 63.1140.
i. The owner or operator shall maintain records of the following:
A. The type of treatment process

Permit No. 03753R14
Page 6
B. The types and amounts of wood preservative used at the facility
C. Charge records identifying the pressures inside the retorts.
ii. The Permittee shall make the records available for inspection upon request of
DAQ personnel.
iii. These records must be maintained for 5 years, with the last 2 years of data
retained on site. The remaining 3 years of data may be maintained offsite.
c. Reporting Requirements—Pursuant to 40 CFR 63.11431, the Permittee shall submit
the following reports to the DAQ:
i. Initial notification form of applicability no later than 90 days after the
compliance date of July 17, 2007. (This was completed on August 27, 2007.)
ii. Notification of compliance status report no later than 90 days after the
compliance date of July 17, 2007. This notification shall list:
A. The following certification of compliance statement: "This facility
complies with the management practices to minimize air emissions
from the preservative treatment of wood in accordance with 40 CFR
63.11430."
B. The signature of a responsible official.
(Note: A and B were completed on August 27, 2007.)
iii. A report of any deviations from the requirements of Subpart QQQQQQ
within 30 days of the deviation.
11. GENERALLY AVAILABLE CONTROL TECHNOLOGY- For the one wood/bark-fired boiler
(16.0 million Btu per hour maximum heat input)constructed 1951, put in service in 1988 (ID No.
ES-1)and one wood-fired boiler (20.1 million Btu per hour maximum heat input) constructed 1999,
put in service in 2017 (ID No. ES-4),the Permittee shall comply with all applicable provisions,
including the notification, testing, and monitoring requirements contained in Environmental
Management Commission Standard 15A NCAC 2D .1 111, as promulgated in 40 CFR 63, Subpart
JJJJJJ, " National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial,
Commercial, and Institutional Boilers", including Subpart A "General Provisions."
a. Compliance Dates(40 CFR 63.11196) - The owner or operator of an existing source is
required to comply with the tune-up and the energy assessment requirements no later than
March 21, 2014.
b. Compliance Requirements - As required by 15A NCAC 2D .1111, the Permittee shall
comply with the following requirements:
i. General Duty Clause (40 CFR 63.11205(a)) - At all times the Permittee shall operate
and maintain any affected source, including associated air pollution control
equipment and monitoring equipment, in a manner consistent with safety and good
air pollution control practices for minimizing emissions.
ii. Boiler Tune-up (40 CFR 63.11223) - An initial boiler tune-up is required by March
21, 2014. If the unit is not operating on the required date for a tune-up,the tune-up
must be conducted within thirty days of startup. The Permittee shall comply with the
following with respect to the tune-up:
I

Permit No. 03753R14
Page 7
A. Periodic tune-ups: A biennial tune-up is required and shall be conducted no
more than 25 months after the previous tune-up. The following units are only
required to conduct a tune-up every five years: seasonal boilers (shutdown for
7 consecutive months or 210 consecutive days each 12-month period due to
seasonal conditions; only biomass or oil), limited-use boilers, and units with
oxygen trim systems, as defined in 40 CFR 63.11237. Each five-year tune-up
must be conducted within 61 months of the previous tune-up.
B. Fuel required for the tune-up: The permittee shall conduct the tune-up while
burning the type of fuel (or fuels in the case of boilers that routinely burn two
types of fuels at the same time)that provided the majority of the heat input to
the boiler over the 12 months prior to the tune-up.
C. As applicable, inspect the burner, and clean or replace any components of the
burner as necessary. The Permittee may delay the burner inspection until the
next scheduled unit shutdown, but must inspect each burner at least once
every 36 months (72 months for 5-year tune-ups).
D. Inspect the flame pattern, as applicable, and adjust the burner as necessary to
optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure
that it is correctly calibrated and functioning properly. The Permittee may
delay the air to fuel ratio inspection until the next scheduled unit shutdown,
but must conduct the inspection at least once every 36 months(72 months for
5-year tune-ups).
F. Optimize total emissions of carbon monoxide. This optimization should be
consistent with the manufacturer's specifications, if available, and with any
nitrogen oxide requirement to which the unit is subject.
G. Measure the concentrations in the effluent stream of carbon monoxide in
parts per million, by volume, and oxygen in volume percent, before and after
the adjustments are made (measurements may be either on a dry or wet basis,
as long as it is the same basis before and after the adjustments are made).
Measurements may be taken with a portable CO analyzer.
iii. Energy Assessment (40 CFR 63.11214(c)) -A one-time initial energy assessment is
required by March 21, 2014. The energy assessment must be performed by a
qualified energy assessor. An energy assessment completed on or after January 1,
2008,that meets or is amended to meet the energy assessment requirements in this
section satisfies the energy assessment requirement. This energy assessment
requirement does not apply to limited use boilers as defined in 40 CFR 63.11237. A
facility that operates under an energy management program compatible with ISO
50001 that includes the affected units satisfies the energy assessment requirement.
The energy assessment must include:
A. A visual inspection of the boiler system.

Permit No. 03753RI4
Page 8
B. An evaluation of operating characteristics of the facility, specifications of
energy using systems,operating and maintenance procedures,and unusual
operating constraints.
C. Inventory of major systems consuming energy from affected boilers and
which are under control of the boiler owner or operator .
D. A review of available architectural and engineering plans, facility operation
and maintenance procedures and logs, and fuel usage.
E. A list of major energy conservation measures that are within the facility's
control.
F. A list of the energy savings potential of the energy conservation measures
identified.
G. A comprehensive report detailing the ways to improve efficiency, the cost of
specific improvements, benefits, and the time frame for recouping those
investments.
c. Notification and Reporting Requirements- In addition to the notification and reporting
requirements of the Environmental Protection Agency (EPA), the Permittee is required to
NOTIFY the Regional Supervisor, DAQ, in WRITING, of the following:
i. Initial Notification (per 40 CFR 63.9(b)and 40 CFR 63.11225(a)(2)) is required by
January 20, 2014.
ii. Notification of Compliance Status(40 CFR 63.11225(a)(4)) is required by July 19,
2014.
iii. Compliance Report must be prepared by March I of every other year(or every five
years depending on the frequency of the tune-up requirements) starting March 1 the
year following the first periodic tune-up, and submitted upon request. The report
must meet the requirements of 40 CFR 63.11225(b)(I-2).
d. Recordkeeping Requirements - In addition to any other recordkeeping requirements of the
EPA,the Permittee shall maintain the following records as defined under 40 CFR
63.11225(c):
i. Copies of all required notifications.
ii. Maintain the following records to document conformance with the work practices,
emission reduction measures,and management practices:
A. Tune-up records-records must identify each boiler, the date of tune-up,the
procedures followed for tune-up, the manufacturer's specifications to which
the boiler was tuned, and the following:
I. The concentrations of CO in the effluent stream in parts per million,
by volume, and oxygen in volume percent, measured at high fire or
typical operating load, before and after the tune-up of the boiler.

Permit No. 03753R14
Page 9
II. A description of any corrective actions taken as a part of the tune-up
of the boiler.
III. The type and amount of fuel used over the 12 months prior to the
tune-up of the boiler but only if the unit was physically and legally
capable of using more than one type of fuel during that period. Units
sharing a fuel meter may estimate the fuel use by each unit.
B. A copy the Energy Assessment required by 40 CFR 63.11214(c).
C. Seasonal boilers- For each boiler that meets the definition of seasonal boiler,
you must keep records of days of operation per year.
D. Records of non-waste determinations per 40 CFR 63.11225(c)(2)(ii).
iii. Malfunction Records - Records of the occurrence and duration of each malfunction
of the boiler, or of the associated air pollution control and monitoring equipment.
Records of actions taken during periods of malfunction to minimize emissions in
accordance with the general duty to minimize emissions in 40 CFR 63.11205(a),
including corrective actions to restore the malfunctioning boiler, air pollution
control, or monitoring equipment to its normal or usual manner of operation.
iv. Record Retention- You must keep each record for 5 years following the date of each
recorded action.
12. LIMITATION TO AVOID 15A NCAC 20 .0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic
Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and
Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than
the following:
Pollutant Emission Limit
,(Tons per consecutive 12-month period)
VOC 1 100
a. Operations Restrictions - To ensure emissions do not exceed the limitations above, the
following restrictions shall apply:
i. The total amount of board-feet dried in kiln#3 shall be less than 144,000 bd-ft per
batch in 72 hours (on average)throughout the calendar year. The total amount of
board-feet dries in kiln#1 and 2 shall be less than 108,000 bd-ft total per batch in 55
hours (on average)throughout the calendar year. These are the same operational
limits as in the toxics condition above (A.9).
ii. Kiln Annual Limit and VOC emissions; 41,500,000 bd-ft total annual actual
production= 84.9 ton/yr VOC. Plus: 41,500,000 bd-ft(which converts to 3,458,333
cu. ft. per year) = 13.1 ton/yr VOC from the Wood Preserving operation. Plus: VOC
PTE emissions from the wood/bark fired boiler are 1.50 ton/yr. Summation=(84.9
+ 13.1 + 1.50) = 99.5 ton/yr VOC.
b. Recordkeeping Requirements

Permit No. 03753R14
Page 10
i. Kiln Annual Limit=41,500,000 bd-ft total annual actual production is equivalent to
3,458,333 cu. Ft. dried per year. The facility shall record the actual amount of
softwood dried in all three kilns in cu. Ft. per batch per month throughout the
calendar year. The same limit applies to the wood preserving operation(this applies
to the pentachlorophenol or any other organic (VOC)wood preserving operation and
recordkeeping is required to verify this limit also).No recordkeeping is required for
the boiler use since the VOC PTE(8,760 hours)= 1.5 ton/yr accounted for above.
c. Reporting Requirements - Within 30 days after each calendar year quarter, regardless of the
actual emissions,the Permittee shall submit the following:
i. emissions and/or operational data listed above in paragraph b. below. The data
should include monthly and 12 month totals for the amount of cu. ft. dried per month
and per year on a rolling monthly basis throughout the calendar year. A running 12
month total shall be reported to the DAQ Regional Supervisor every quarter.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS TEST DATA MONITORING DATA NOTIFICATIONS. REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington,NC 28405
910-796-7215
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
j 2. RECORDS RETENTION REQUIREMENT- In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT- Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing,building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.

Permit No. 037531114
Page 11
5. REPORTING REQUIREMENT- In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effectuate an overall reduction in air pollution.
Unless otherwise specified by this permit,no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State,or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to,process weight rates, firing rates, hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.

Permit No. 03753R14
Page 12
13. In accordance with G.S. 143-215.108( )( ),c 1 this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act(RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110,the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request, the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r) REOUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section I I2(r)of the Federal Clean Air Act, then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases-Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces, processes, handles, or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 213 .2600 and follow all DAQ
procedures including protocol approval, regional notification,report submittal, and test
results approval. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the 18s' of October, 2021.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
—Aw �&/
rad Newland
Wilmington Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 03753R14
I

ATTACHMENT to Permit No. 03753R14, October 18, 2021
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
IES-2 - Wood waste handling operation, '2Q 0102 (h)(5) No I No
fugitive emissions (Facility ID 002)
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 'Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here:
hgps:Hdeg.nc.gov/ggpermitconditions