NCGNE1314_COMPLETE FILE - HISTORICAL_20190603

STORMWATER DIVISION CODING SHEET
.NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
-5( HISTORICAL FILE
DOC DATE
11 'DOI q o� OL
YYYYMMDD

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Interim Director
Eco-Energy, LLC
Attn: Chadwick Conn
6100 Tower Circie, Suite 500
Franklin, TN 37067
NORTH CAROLINA
Environmental Quality
June 3, 2019
Subject: No Exposure Certification NCGNE1314
Eco-Energy Selma, LLC
Johnston County
Mr. Conn:
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES
Stormwater Permitting form. Based on your submittal and signed certification of no exposure at the above
referenced facility as well as observations made by Thad Valentinewith the Raleigh Regional Office on
March 01, 2019, the Division is granting your conditional exclusion from permitting as provided for under
40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your No Exposure Certification, you are obligated to maintain no
exposure conditions at your facility. If conditions change such that your facility can no longer quafify for
the No Exposure Certification, you are obligated to immediately obtain NPDES permit coverage for your
stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted
discharge. You must self re -certify annually using the enclosed form or obtain NPDES permit coverage for
any storniwater discharges from your facility. The annual self re -certification does not need to be
submitted to DEMLR unless requested.
Your conditional exclusion from permitting does rot affect your facilities legal requirement to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Thad Valentine at [phone].
Sincerely,
forS. Daniel Smith
Enclosure
cc: Stormwater Permitting Program, No Exposure Files (w/o enclosure)
North Carolina Department of Environmental Quality I Division or Energy, Mineral and Land Resources
J Ru16gh Req_ inntrf Office 11628 Mail Service Ccnler I'SSQO B;irrcr t [)rive j ItalcYgh. Nurlh Carohna 27601)
Ii11,t]l_ln
919.79L.i2oO

,Pa
Michelle M. Brown
Environmental Consultant
igto Halifax Court _
High Point, NC 27265
9r61834-6532
p'f `%
29 August 2018
Laura Alexander
DEMLR — Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Eco-Energy Selma No Exposure Certification
Dear Ms. Alexander:
Please accept the enclosed No Exposure Certification for Exclusion, submitted on behalf of my
client, Eco Energy Distribution Selma, LLC (Eco Energy Selma), The Eco-Energy Selma facility
is located at 3812 Buffalo Road, in Selma, North Carolina.
The primary business associated with the Eco-Energy Selma facility is the transfer of ethanol
from rail cars to the Marathon Terminal located west of the facility. All transfer operations will
be safely conducted as per applicable Pollution Prevention Regulations and the Operations
Manual. The facility follows a Spill Prevention, Control, and Countermeasures (SPCC) Plan and
maintains a Facility Response Plan, per 40 CFR 112.
Eco-Energy Selma was constructed in 2016 and began operations in January 2017. The Eco-
Energy Selma facility does not have aboveground storage tanks onsite. There is no storage of
hazardous materials at the facility and no maintenance activities take place onsite.
Unit trains arrive at the facility approximately once each week and include up to 96 rail cars,
each loaded with 30,000 gallons of denatured ethanol. The ethanol is off-loaded to a pipe that
flows directly to the Marathon Terminal located adjacent to the facility, and offloading is
generally completed within 24 hours of the rail cars arrival at the facility.
The railcars are each connected to individual hoses during the offloading process; the cars are
not tethered together, thus isolating each rail car as an individual container. Each rail car is
inspected prior to connecting the off-loading hoses.
The facility applied for and received a permit from the DAQ for emissions from three
aboveground storage tanks, a truck loading rack, and rail yard offloading header purge. The
only air emissions at the facility currently occur from the header purge during rail car offloading.
The ASTs and truck loading rack are not scheduled for construction at the facility at this time.
The facility applied for and received Section 401 /404 Permits from NC DEQ and the ACOE.
The construction included a sand filter system and an onsite wetland/bioretention basin to serve
as BMP's for the site as a whole in maintaining onsite stormwater. The BMP's for this site do

h,I
Ms. Laura Alexander
29 August 2018
Eco-Energy Selma No Exposure Certification
Page 2 of 2
not receive any additional offsite flow. The wetlandlbicretention basin is ir;cated south of the rail
yard. The sand filter system is located north of the entrance driveway.
Please see the attached diagram that shoves the facility. layout. including the location of the rail
spur.. the drainage system, and the constructed wetiandlbiors ention basin
Secondary Containment
Secondary containment was constructed at the facility in the rail car off-loading area. and
consists of a constructed drainage system. that flows to drainage ditches via a gravel bed cf
stone to the under drain, which is comoosed of perforated PVC pipes. The under drain is
sloped to the center of the rail spur from the north and south, ends of the spur, thereby
transferring any accumulated liquid to the drain}ace ditches or, each side of the rail spur For all
practical purposes. the under drain system{ and drainage ditches would hold approximately
1,497,620 gallons. representing 49 — 30,OOC galiorr tanker cars
valve -was installed to restrict the flog; out of the rai; car drainage system to tf=
constructed wetland/bioretention basin. The valve is to be closed before train off-loading
begins, and is open otherwise. Any discharge of ethanol rr;ouid thus be contained within the
drainage ditches along the rail spur Riiniall that col leczs within this area while a train is in
station is contained and may by released to the drainage inlet by manually opening the closed
and locked valve after inspecting the accumulated ,crater and determining that releasing it will
not result in a release of petroleum products. The facility maintains an inspection log that
documents the opening and closing of the gate valve
If you have any questions, or require additionnai intorrnation. a!s•ase feel free to Contact me by
phone at [phone], or by email at
Thank you,
Michelle M- Brown
Environmental Consultant
Enclosures:
No Exposure Certification Application
Facility Site Map
Facility Stormwater Post Construction Nlao
CC: Chad Conn, Eco-Energy
David Rodriguez. Eco-Energy Sehna
Stephen Chambers. P.E.. Chambers Engineering, Pr.

. V k
I W M
Division ot' Enerqn Alitteral awl I —end RcsoulTes
Land Quality Section
1AP( )S(,JR1.-• CVRTHCA­Fi ( )N 1-1ir
WGNI-0000
National Pc?lutanl Discharge Elimination System application for exclusion frorii a'Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes d'Gle's.,not require a
permit for stormwater discharges associated with industrial activity in the State of Nor-th'C'a;'ro'--Iina because
it qualifies for a no exposure exclusion. A condition of no exposure at art industrial facility means all
industrial materials and activities are protected by a stor.-77 resistant shelter (with sorne exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, Your facility must c ntinL e
0 1
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limitea to,, material handling equipment or activities,
industrial machinery, raw materials. intermediate products. by-products, final products. or waste products -
Material handling activities include the storage. loading and unloading, transportation, or conveyance of
ally law maletidl, illiellifeLfiale PludUCt, filial Pl ULIUC f Vt waste ptuduc!, A slutrij iLsi6ta/yt Sheller is Ilut
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. 'Sealed" means
banded or otherwise secured and with locked or non -operational raps or valves,- adequately maintained
vehicles used in material handling: and final products. other than products that would be mobilized in
i stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify
that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms a n d conditions of 40 CFR 122.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
PjeaSe ;:CjCjk lor fnlDrmaticjri wriout llrdr:r the No ihs nice.
For questions, please contact the DEMLR Regional Office for your area (See page 6)
iPrease pr�Fi- Gr
1 Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Chad%.,Yick Conn
Contact Eco-Energy, LLC
Street Address 6100
TowerF.CircleSie00
. ..---1. .Tank1inCity tat1 zt p . co e. 37.
0..6.. ..7
Telephone No. ........
5)';5 778-2897
..... ....... .
pagC 7
�Wfl

A
i
NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Eco-Enorgy Selma, LLC
Facility Contact David Rodriguez
Street Address 3612 Buffalo Road _
City Selma_ State NC ZIP Code 27576
County Johnston
Telephone No. 919 975-4072 mm Fax n/a rt/a_
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). 1 `° "`° Ex 041, or. in'JS %CE tc.o..,r,j, Cn [R,IN.A! i.I,irso just 11a;1
oafner, ccroinue onto us 7aVV, Take exit 333 onto Bul.a!o Aoau GJC• 1003i. Turn rgnl onto Buffa;a 7caa.=ac-arJ 's lacalol an ore :; nr al 36; 2 6011110 Roau
A co of a ma with the facility clear) located on it should be included with the cenific { copy p y y a#ion application.)
4) Is the facility located on Native American Lands? ❑ Yes 1R No
5) Is this a Federal facility? © Yes 14No
b) Latitude N35°32' 52.651' Longitude W78'18' 13.43" (deg., min., seconds)
___7)_ This NPDES Na-Exposure Exclusion application applies to which of the following:_
0 New or Proposed Facility Date operation is to begin _.... ...
��_
t3 Existing Date operation began January 2017 �r
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE _._ ........
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes % No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) thal describes the primary industrial
activity at this facility
SIC Code: 5 1 7 1
10) Provide a brief description of the types of industrial activities and products produced at this facility:
The primary business associated with the Eco-Ene_rgy_Selm_a facility is the transfer of
ethanol from rail car to the Marathon Terminal located *vest of the facility via a pipeline.
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
*No
p Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Page 2 of 7
CWI I_Nr..r NF I :c: ro,ucor! t717A17n�F

r
NCGNEOOOO No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes IiD No © NIA
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes
fA No
O NIA
c. Materials or products from past industrial activity
❑ Yes
tO No
❑ NIA
d. Material handling equipment (except adequately maintained vehicles}
❑ Yes
�1 No
❑ NIA
e. Materials or products during loading/unloading or transporting activities
❑ Yes
b3 No
❑NIA
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes Nd No ❑ NIA
use [e.g., new cars] where exposure to stormtvater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels. ❑ Yes t No ❑ NIA
tanks, and similar containers
h. Matorials or products handled/stored en roads or railways owned or maimained ❑ Yes ®Nu ❑ NIA
by the discharger
i. Waste material (except waste in covered, non -leaking containers je g., ❑ Yes P No ❑ NIA
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) O Yes J$ No 0 N/A
k. Particulate matter or visible deposits of residuals from roof stacks andlor vents ❑ Yes R) No © NIA
not otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not property stored ❑ Yes 56 No ❑ NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums. barrels. tanks, and sim+lar containers ❑ Yes A� No ❑ NIA
stored outside, has the facility had any releases in the oast three (3) years?
l
13) Above Ground Storage Tanks (ASTs); If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No k NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is ii Iree of any ❑ Yes ❑ No X'N/A
cracks, holes, or evidence of leaks. and are drain valves maintained forked
shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are riot eligible for the
no exposure exclusion.
cwi 1.NrrNF-
Page 3 of 7
I nor ro,,'co,l Qi7R!?r11A

NCGNE0000 No Exposure Certification
a. Is secondary containment provided for single above ground storage containers
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1.320-
gallons?
c. Is secondary containment provided for Title II I Section 313 Superfund
Amendments and Reautharizaticn Act (SARA) water priority chemicals'?
d. Is secondary containment provided for hazardous substances" designated in
40 CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage. or Disposal Facility?
b.-Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous
waste generated per month) of hazardous waste?
c_ Is this facility a Large Quantity Generator 0000 kg. or more of hazardous waste
generated per month) of hazardous waste"
If you answered yes to Questions b. or c„ please provide the following information:
waste:
Type(s) of
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport 1 disposal
vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
❑ Yes 0 No I� NIA
❑ Yes ❑ No 4 NIA
E3 Yes ❑ No �9( NIA
Yes ❑ No 0 NIA
❑ Yes ❑ No `NIA
p Yes Zi No ❑ N/A
❑ Yes _ li� No ❑ NIA
❑ Yes 'C�No ❑ NIA
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis arnounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 4C CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) buck storage minimums require
secondary containment, However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required_
Page 4 of 7
CWILNf'1;NF i Act rawncA,1 R19R,7,M1F

e
NCGNEOU00 No Exposure Certification
a. Duds your facility store used, recycled, or otherwise reclaimed pallels outside? p Yes )d No ❑ NIA
b. Does your facility have coal piles on site?
0 Yes '%I1Vo ❑ NIA
c. Does your facility store other luel sources oulside in piles, such as wood chips,
❑ Yes No ❑ NIA
sawdust, etc.?
d. Does your facility have air emissions associated wilf7 its inaustrial activity (e.g..
V,Yes O No ❑ N/A
degreasing operations, plating, painting and metal finishing)? If so. describe the
indusVial acllviiy: offloading header purge is only ins!alleu omission unit !or the facility
e. If you answered yes to d , are those emissions permitted by an Air Quality
t' Yes ❑ No Q NIA
Permit? Please specify: 10419R00
f, Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permils, etc.):
Permit: DWR# 15-0417 Program: NCDEQ 401 Permit
Permit: SAW-2015-00325 Program: ACOE 404 Permit
Permit: _ Program:
Permit: Program:
Permit: Program
Permit: Program:
Permit: Program:
Page 5 of 7
SWU,NCGNE Lflsi revsec Ma12016

A .I
NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that f have read and understand the eligibility requirements for claiming a condition of "no
exposure- and ootaining an exclusion from NPDES stormwater permitting.
certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial'activities or
materials from the industrial facility or site identified to this document (except as allowed under 40 CFR t22.2E(g)(2)).
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertification form at least once
each year, and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). 1 understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or MS4 operator where the discharge is into the local MS4, to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand I
must keep a copy of annual re -certifications on file at the €acilily.
In the event that the site no longer qualities for a No Exposure Exclusion, I understand that i must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from she facility. Additionally, I certily under penalty of
law that this document and all attachments were prepared under my direction or supervision In accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
-" information, -the information submitted Is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true. complete, and accurate.
Printed Name of Person Signing: Mr. Chadwick Ginn --_
Tltie� VP
(Signature of Applicant) IC'3r y,ca+,•^r!+
Please note: This application for the No Exposure Exclusion is subject to approval by the NCDEO
Regional Office prior to Issuance. The Regional Office may Inspect your facility for compliance
with no exposure conditions prior to that approval. The Regional Office may also inspect your
facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statemem. representation. or certification in any application. record. report. plan. or other
document filed or required to be maintained under this A-6de or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rWemakina proceeding or contested case under this Anicte: or wno falsilies. tampers with, or knowingly
renders inaccurate any recording or monitoring device or meinod requued to be operated or maintaineu under this Ailicle or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may imitia a fine
not to exceed ten thousand dollars (S10.000).
There is currently no fee for a No Exposure Exclusion. I
(sage B of 7
SWrt-Nr:RNF I act ravicnri Qr7A17MR

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f SAND FILTER "
J WQV ADJUST: 463 OF
SAND FILTER "A" '%, J,
VJQV ADJUST: 1,007 OF DRAINAGE AREA FOP,
SAND FILTER'
DRAINAGE AREA FOR \ _ 100%AREA: PE VI
SAND FILTER "A" 100 /o IMPERVIOUS
AREA: 0.37 AC
/ 100% IMPERVIOUS
OFFICE BUILDING &I 1 /; SEX. JURISDICTIONAL \`
PARKING""
ARKING
WETLAND
DRAINAUL AREA FOR
STORMWATER WETLAND
AREA: 4,00 AC
\
100% IMPERVIOUS
\� EX. JURISDIG IONAL
VVETLAN
STORMWATER WETLAND:
WOV VOLUME: 14.520 CF ^:
DRAWN BY: AGD
DATE: 5/15
DWG. NO.: STORMWATER MAPS.DW
1 " = 200'
C hhaimbcars Enginieering, PA
129 Ptoeh Fust St., A6emarle, NC 260C1 70J-9&5��127
tGELS Fain L tense No C-166D
ECO ENERGY - SELMA, NC STORMWATER MAP - POST CONSTRUCTION APPENDIX D

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SOURCE:
1. USGS TOPOGRAPHIC MAP, ACCESSED
VIA wN.arcgisonline.com
0 2,000 4,000
SCALE; 1" = 2000'
NC DWO 401 WQ & Staffer Permit Application
Eco-Energy Intermodal Facility PROJECT LOCATION MAP
1501 West Oak Street, Selma, North Carolina
GE1
Chambers Engineering, PA
Albermarle, North Carolina I Project 1412320 June 2015 Fig. 1
J:1ProjecWGl ambers Engine ering11501 Wesf Oak St Selma I' ClWetlandtPermitApplica:ion%Site Location.mxo

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?: }stbpnmemal Service, Inc.
Report To:
Victor Brown
Amspec
4117 VSnntaomery St.
Savannah GA, 31.105
Project Name : L'L•DS Selma
Location : Franklin, TN
Lab ID: S19D001-02
Client Sample 41): F-[:DS SBLbIA
1lairit: Water
Page 2 of 3
Work Order Number: S49D001
Report Print Date: 47&2010
Chain of Custody Number: 043052
Laboratori Analysis Report
Collection Date: 03028119 13:00
Rcceiyed Date: 040/19 09:33
Collected By: VictorProun
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Report To:
Victor Brown
Amspec
4117 Momaornery St.
Savannah GA- 31405
Project Nemc : BEDS Selma
Location : Franklill, rFN
Lab ID: S19D001-W
Client Sample 1D; 1?EDS SELMA
Nlatric: Water
Page I of3
Work Order Nnmber: S19DOOi
Report Print Date: 478/2019
Chain of Custody Number: 043052
Lahoratury Analysis Report
Collection Dale: 03f28111) 13:00
Received Date: 0.1101' 19 09:33
Collected 13p: Victor Br(jµn
Mor Date.
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Result lin its r.aor mDI. PI)I. Anu Frst
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Services. Inc. I30.%irpoa Par:: Drive 528 Qunch Rd_ 610 Perrot A%c. N. 19h) I iaNrn Bled. Ste 101
1460 W. McNah Road. Garden Cii} OA Al 101 rurt ` l-J, FL 33811 Okeechobee. l'1.341172 I.Acljvd. I 33803
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Report To
Victor Brown
Amspec
4117 Montgomery St.
Savannah GA, 31405
Page 2 of 2
Work Order Number -
Report Print Date:
Chain of Custody Number:
S19D110
4/22/2019
043131
Project [Name : EEDS Selma
Location : Franklin, TN
Notes and Definitions
U Indicated that the compound was analyzed for but not detected. This shall be used to indicate that the specific component was not
detected. The value associated with the qualifier shall be the laboratory method detection limit.
QC = Data Qualifier Code as defined by DEP 62-1 %
MDL = Method Detection Limit: The minimum concentration that can be measured and reported with 99 percent confidence that the concentration is greater than
zero, but the exact concentration cannot be reliably quantifted.
PQL= practical Quantitai ion Lint it: cite minimum concentration oFan anaiyte (substance) [hat can be measured with a high degree of confidence that the analyte is
present at or above that concentration.
Unless otherwise indicated, soil results are reported on actual (wet) weight basis.
These test results meet ail NELAP requirements and relate only to this sample.
Analyses not NELAP certified are designated with it "—"
Final report reviewed by:
a4ua'-� !" ' 4/22/2019 11:23:49AM
Christine M. Riddle
Florida -Spectrum Environmentai Services,inc.
NELAP Certification# E87671
Georgia FPD 9833
Tel: [phone] Fax: [phone]
E-mail: cAddlelUenviro.corn
Report issue date
Florida -Spectrum Environmental spectrum Laboratorie3 Pernbroke I ghoratory Big Lake Laboratory Lakeland Laboratories
Services, Inc:. 180 Airport Park Drive 528 Gooch Rd. 610 Parrot Ave. N. 1910 Harden Blvd, Ste 101
1460 W. McNab Road, Garden City, GA 31401 Fort Mead, FL 33841 Okeechobee, Fl, 34972 Lakeland, FL 33803
Fort Lauderdale, FL33309
www.flenviro.corn

WIN
pcctrum
ijvlroilmentat Services, Inc.
Report To:
Victor Brown
Amspec
4117 Montaomery St.
Savannah GA,31405
Project Name : EEDS Selma
Location : Franklin, tN
Lab ID: S191)110-01
Client Sample ID: EEDS SELMA
Matrix: Water
Pagel of 2
Work Order Number:
Report Print Date:
Chain of Custody Number:
Laboratory Analysis Report
�i
S19D110
4/22/2019
043131
Collection Date: 04/11/19 18:00
Received Date: 04/12/19 10:00
Collected By: Victor Brown
Date Date —
'ual,fier ailulinn
Parameter Result 'o",, Units t.a w N!1)L PQ1, llet}rod Extracted Analyzed Analyst
OilAGrease{HEM) 5.30 mgJL 1 1,60 5.00 EPA 04l15 1739 1 04118 13:13 1 CR
Florida -Spectrum Environmental Spectrum Laboratories Pembroke Laboralery l3ip Lake Laboratory
Services, Inc. 180 Airport Park Drive 528 Gooch Rd, 610 Parrot Ave, N.
1460 W. McNab Road, Garden City, GA 31401 Fort Mead, FL 33841 Okeechobee, FL 34972
Fort Lauderdale, FL 33309
Lakeland Laboratories
1910 Harden Blvd, Ste 101
Lakeland, FL 33903
www.fleiiviro.com

WIN
ectrum
nmentcl Sarrkes, Inc.
Report TO:
Page 3 of 3
VictorRroan
Work orderNrtruiber:
SlQDG91
Amspec
Report Print Dale:
4 8,2019
a 117 Nlontt:omery St.
Chain of Custodv Number:
043052
Savannah GA, 3140i
Project fame : FE[3S Selma
Location : rranklin, IN
Nolen and Dei'tnilions
U Indicated that the tempaund wws analyzed For but nut detected. '[his shall be used to indicate that the specilic component ssas not
deteClCd. 'I he value a5SOClated s, hh the qualifier ahAl he the lahoraton; method delcetiun limit.
Ol' 3 Data (,luadifaer Cndc as defined b} DLP 62-1641_
MU - Melhod Detection I.irnir The minimum canccntrntirm that c:rn he measured and « pened ti i& Q' percent conlidcncc mat the cuncenlraliun is gr,�atcr alan
reru, but the csact antccnna[iun cannot be reliably 4uanr&0cd.
PQL - Practical Ouanlitalion I.imh: the mimmum eoncenuatiun ol'an :ma!}tc (,uWancc) that can be measured µith a high degree of hinhdCrhe that tire 411:111tc iz
present at ar A31 c that cuncenlralion.
linlcss uthem ise indicated. soil resa![s are reporrcd on actual (u Ce} &cikhl bnsij.
hose tut results meat all N'81-.IP requircmenh, and relate only to this iamplc.
Analyses not N'Pl,AII cenilied arc ddignated ssiih a "-"-
Final report revie%ked by:
a/,v.
4/812019 12:29;13PM
Christine M. Riddle
Report issue date
Florida -Spectrum Em iromu mal Services,lrc.
%Tf.AP Certiiicalion-q Fi87671
Gcorcia O'D #833
1'el: 912-23 8-5050 1-as: 912-234-4.415
E-mail: c.riddlcal ctniru.cow
I�tmida-Spectrum F.nyirenmentyt Spectrnrr Luheruunr.
Pemhmlr Laboratoc} hlig Lake lahe'amr I.Acl:md I.Aoratorics
.Services. Inc. I%1 Airport Part. Dn,e
328 Gooch Rd. 1,10 Patrol Ave N. 14I0 [Ludes Hhd. Ste IUI
1*0 W. \lcNa6 Road. Gardat Cm, CrA 3i401
Fort dead, FL 33S41 Ulecchoheo, I t.3w72 t,Acland, Fi.33soS
For Lnudcrda!e, I I. 33307
µw%.Flensiru.com

• a iorlde
ectrum
"-1Rts'�renmenrol Services, Inc.
Report To: Page I of 3
Victor Brown Work Order Number: S19D001
Amspec Report Print Date: 4IS2019
41 17 Montenmcrn St. Chain of Custody \umher: 043052
Savannah GA. 31405
Project Name : EMS Sclma
Location : Frank Iin, T.N
Lan Ill: Si9D001-01
Client Sample 11): EEDS SELMA
Matriv: Hater
Lahorator} AnahSis Report
Collection hate: 0328119 13:00
Reccired late: 0.L01/l9 09:33
Collected By! Victor Brown
D• Da tr t)a I
Pa r4+meter t1�•i�nrr na„"O" \Ir Ih,IJ Fa Ira rtrd An.1cml ,inch+t
Result _ cMfz 1',.;15 r•rr„� AIM. Pljt.
Chcmlcal Utsgen Nniand 48,7 I -IL i 12.13 1 360 11u6 gift W-02 11 01 0.1f02 16:20 �IFi
F1ortda.Spectrum F: ns ironmcniai Spectrum I-4&1runrics I'cmhrui;c I. ahwalnry 11,g Lake Luhnr91on I.d.eland I.ahmahlric5
Seiviecs, Inc. 180 Airport Par:; Dcr+e 528 GNr h lid, 610 I'avcn Asa, N. 1910 f larden tnvd, Sic 1 J I
1160 V". Slcl ah Road, Carden Clh, CIA 11_p61 I"art Stcad, FL 338.11 Okccchuhec. F1.34o;2 I.Acland. 1'1.33sol
1'0r1 Laududale. FI.33JO
w� ".nem im.cunr

bride
®utrum
. � ;` mertlul SatNcef, Ine.
Report To:
Victor Brown
Amspec
4l 17 N1nntRnmery St.
Savannah GA. 31405
Project Name : EEDS Selma
Location : Franklin, TN
Lab ID: S19DOO1-02
Client Sample ID: FCDS SCUMA
Matrix: Water
Page 2 of 3
Work Order Number: St9D1101
Report Print hate: 4!812O19
Chain of Custody Number: 0,13052
Laboratory Analysis Report
Collection Date. 03128(19 13:00
Received Date. O4,01/19 09:33
Collected IIy: Victor Brown
mu Datc Dan
pu.nnrr nm„a,
Parameter Resuft Units r.ero. Nim. PQI_ Methud Ettracled .ka2lyud Artalrel
Chemical l ,gen Demand 3't.5 rngJl_ 1 12 31, A 1 Hach %+IOC O-602 11 01 01,02 16 S1f:
Florida -Spectrum linv imnmenial
Scnius, lac.
labO A'..MS Nah Rnad.
Fun i.auder-hIC. FL 33309
SNctmm I,ahommric% I'embruke I.ahurutory Big I.ake Laboraw� I.Aeland Lahuremrics
ISO Airpon park IJri%c 513 Gaxh Rd. 61 U Parral Acc S'lQ I O 1lnrden Dhd, Slr 101
Garden C:itp, GA 31 101 rw ,ttcnd. rt. 33w Okeechobee- FL 31072 Lakaland. FI.33903
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Environmental
Quality
Division of Energy, Nlineral and [..and Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION tin• i✓xclutiiun
I i iR AOHNCY U1,1? � PNL Y
Djie Rrco%ed
1'r.0 ?,�mlh Il.n
1�rrSi Gtalc ul {'u�rPa •r
NS
\CG\ E.0000 RECEIVED
National Pollutant Discharge Elimination System application for exclusion f599 JSQ%� ter Permlt based
__ \I^ Cv[fACI Inc.
Submission of this No Exposure Certification constitutes notification'thaillydiiu ffatilityldoe�gi t require a
O
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. in
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
if approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST 8E self re -certified at least annually.
Please look for information about re -certification under the No Exposure section on this page:
httr)sa/deo, nc,aov/about/divisions/energy-minerall-land-resources/energy-minerai-land-permits/stormwater-
permits/nWes-industrial-sw
For questions, please contact the DEMtR Regional Office for your area. (See page 6)
([Tease print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Chadwick Conn
Contact Eco-Ever y, LLC
Street Address 6100 Tower Circle, Suite 500
City ran Tto State TN ZIP Code 37067
Telephone No. 615 786-0401 Fax: [phone]
Wage 1 of 7
curs!-N%rNr- I pcl rn.4i .H 017R19n1r

NCGNEO000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Eco-Energy Selma, LLC
Facility Contact David Rodriguez
Street Address
3812 Buffalo Road
City a ma State ZIP Code 27576
County Johnston _
Telephone No. 919 975-4072 Fax: n/a n/a
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names. state road numbers, and
distance and direction from a roadway intersection). "1-do, Take Exit 309 ra Mergp onto us 7CE tOwaio$ smdhltek;, aoraeno<o. JV%t er5t
Garner, tontinue onto US 70W, Take eat 333 onto Buffalo Toad (NC-1003), Turn right onto BuMato Roan. Facis,ty is iotatod on the ngrn, at 3812 L3urinlo Aoea,
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands?© Yes M No
5) Is this a Federal facility? © Yes 14 No
6) Latitude N35°32' 52.65" Longitude W78°18' t3.a8" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
New or Proposed Facility
© Existing
Date operation is to begin
Date operation began January 2017
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? 0 Yes 0 No
If yes. what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 5 1 7 1
10) Provide a brief description of the types of industrial activities and products produced at this facility:
The primary business associated with the Eco-Energy_Selma facility is the transfer of
ethanol from rail car to the Marathon Terminal located west of the facilityvia a pipeline
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
�iNo
© Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Page 2 of 7
cwt I_Nrr,NF t act rCtacnrl MgA»n,F

NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes @J No ❑ NIA
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes
0 No
o NIA
c. Materials or products from past industrial activity
❑ Yes
19 No
❑ NIA
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes
'K No
❑ NIA
e. Materials or products during ioadinglunloading or transporting activities
❑ Yes
V No
❑ NIA
I. Materials or products stored outdoors (except final products intended for outside
❑ Yes
t No
❑ NIA
use [e.g., new cars] where exposure to stormwater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums. barrels.
17 Yes
'0 No
❑ NIA
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained ❑ Yes ® No ❑ NIA
by the discharger
i. Waste material (except waste in covered, non leaking containers [e.g., ❑ Yes IP No 0 NIA
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes 0 No 13 NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents ❑ Yes ;dNo ❑ NIA
not otherwise regulated (i.e,, under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes 8f No ❑ NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes eNo Cl NIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No fit NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No JNIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked
shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
Page 3 of 7
qw! t-Nr.r.NF ! act rokAcPri 0r9A19r}1A

NCGNE0000 No Exposure Certification
a. Is secondary containment provided for single above ground storage containers
❑ Yes 0 No ti NIA
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. is secondary containment provided for above ground storage containers stored
[3 Yes ❑ No NIA
in close proximity to each other with a combined capacity of more than 1.320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
❑ Yes O No NIA
Amendments and Reauthorization Act (SARA) water priority chemicals'?
d. is secondary containment provided for hazardous substances" designated in
❑ Yes © No NIA
40 CFR §116?
e. Are release valves on all secondary containment structures locked?
[]Yes ❑ No p�N/A
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment. Storage, or Disposal facility?
b. is this facility a Small Quantity Generator (less than 1000 kg. of hazardous
waste generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
waste:
vendor:
Type(s) of
How is material stored:
Where is material stored:
How many disposal shipments per year.
Name of transport I disposal
Vendor address:
Footnotes to Questions 14) c. & d.
❑ Yes Id No ❑ NIA
0 Yes IS(No O NIA
0 Yes Bk No ❑ NIA
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title Ill SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1.320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
Page 4 of 7
CWI LtUr:C:NF 1 eat rnviaarl 019gl7n7F

NCGNE0000 No Exposure Certification
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? 0 Yes )d No 0 NIA
b. Does your facility have coal piles on site?
p Yes 1"o 0 NIA
c. Does your facility store other fuel sources outside in piles, such as wood chips,
0 Yes No 0 NIA
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e,g.,
gYes ❑ No n NIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: offloading header purge is only installers emission unit for the facility
e. It you answered yes to d., are those emissions permitted by an Air Quality
,Yes 0 No 0 NIA
Permit? Please specify: 10419R00
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: DWR# 15-0417 Program: NCDEQ 401 Permit
Permit. SAW-2015-00325 Program: ACOE 404 Permit
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Page 5 of 7
sWU-NCGNE Last reviseo 9;2&2016

NCGNEOOOO No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
1 certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identifled in this document (except as allowed under 40 CFR 122.26(9)(2)).
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertification form at least once
fir, and it requested, provide this cerUlication to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or M84 operator where the discharge is into the local MS4, to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand I
must keep a copy of annual re -certifications on file at the facility.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted Is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Mr, Chadwick Cann
Title: VP
(Signature of Applicant) (D4re Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the NCDEQ
Regional Office prior to issuance. The Regional Office may Inspect your facility for compliance
with no exposure conditions prior to that approval. The Regional Office may also inspect your
fatly at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who kmwingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintairiw under this Article or rules of the
JEnvirormental Management} Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may indtlde a fine
not to exceed ten thousand dollars (510.000),
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
gwt+.Nr:rNF t act ro%Acae QJ7A1W)1A

i1twO0E�
.x
I�
SOURCE:
1. USGS TOPOGRAPHIC MAP, ACCESSED
VIA www.arogisonline.com
0
oP 91
i3
13'Naiional C�eograph`c Society,-c�be i
2,000 4,000
SCALE: 1" = 2000'
NC DWQ 401 WQ & Buffer Permit Application
Eco-Energy Intermodal Facility PROJECT LOCATION MAP
1501 West Oak Street, Selma, North Carolina E I
Chambers Engineering, PA
Albermarle, North Carolina Project 1412320 1 June 2015 Fig. 1
J:IProiects4Chambers Engineering11501 West Oak St Selma NC1WetlandlPermitApplicationtiSite Location.mxd

SAND FILTER "A" _ l��r:�/ /
WQV ADJUST: 1,007 CF
/ DRAINAGE AREA FOR
SAND FILTER "A" / `\
0* AREA: 0.37 AC 1 \
100% IMPERVIOUS /
OFFICE BUILDING & • /
PARKING,
\` i� tt / /r•�.®/.ai. _ \`gin \ \ � >,
DRAWN BY: AGD
IDATE: 6115
DWG. NO.: STORMWATER MAPS.DW
1" = 200'
SAND FILTER "B" \ \ \ \
WQV ADJUST: 463 CF
DRAINAGE AREA FOR
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Ohambers Engineering, PA
129 North First St., Albemarle, NC 28001 704.984-6427
NCBELS Firm License No C-1660
ECO ENERGY - SELMA, NC STORMWATER MAP - POST CONSTRUCTION
APPENDIX D

Michelle M. Brown
Environmental Consultant
igio Halifax Court
High Point, NC 27265
g161834-6532
29 August 2018
Laura Alexander
DEMLR — Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Eco-Energy Selma No Exposure Certification
Dear Ms. Alexander:
RECEIVED
SEP 13 2010
S70RIV1�'da €RF} '€V1ITTING
Please accept the enclosed No Exposure Certification for Exclusion, submitted on behalf of my
client, Eco Energy Distribution Selma, LLC (Eco Energy Selma). The Eco-Energy Selma facility
is located at 3812 Buffalo Road, in Selma, North Carolina.
The primary business associated with the Eco-Energy Selma facility is the transfer of ethanol
from rail cars to the Marathon Terminal located west of the facility. All transfer operations will
be safely conducted as per applicable Pollution Prevention Regulations and the Operations
Manual. The facility follows a Spill Prevention, Control, and Countermeasures (SPCC) Plan and
maintains a Facility Response Plan, per 40 CPR 112.
Eco-Energy Selma was constructed in 2016 and began operations in January 2017. The Eco-
Energy Selma facility does not have aboveground storage tanks onsite. There is no storage of
hazardous materials at the facility and no maintenance activities take place onsite.
Unit trains arrive at the facility approximately once each week and include up to 96 rail cars,
each loaded with 30,000 gallons of denatured ethanol. The ethanol is off-loaded to a pipe that
flows directly to the Marathon Terminal located adjacent to the facility, and offloading is
generally completed within 24 hours of the rail cars arrival at the facility.
The railcars are each connected to individual hoses during the offloading process; the cars are
not tethered together, thus isolating each rail car as an individual container. Each rail car is
inspected prior to connecting the off-loading hoses.
The facility applied for and received a permit from the DAQ for emissions from three
aboveground storage tanks, a truck loading rack, and rail yard offloading header purge. The
only air emissions at the facility currently occur from the header purge during rail car offloading.
The ASTs and truck loading rack are not scheduled for construction at the facility at this time.
The facility applied for and received Section 401 /404 Permits from NC DEQ and the ACOE.
The construction included a sand filter system and an onsite wetland/bioretention basin to serve
as BMP's for the site as a whole in maintaining onsite stormwater. The BMP's for this site do

Ms. Laura Alexander
29 August 2018
Eco-Energy Selma No Exposure Certification
Page 2 of 2
not receive any additional offsite flow. The wetland/bioretention basin is located south of the rail
yard. The sand filter system is located north of the entrance driveway.
Please see the attached diagram that shows the facility layout, including the location of the rail
spur, the drainage system, and the constructed wetland/bioretention basin.
Secondary Containment
Secondary containment was constructed at the facility in the rail car off-loading area, and
consists of a constructed drainage system that flows to drainage ditches via a gravel bed of
stone to the under drain, which is composed of perforated PVC pipes. The under drain is
sloped to the center of the rail spur from the north and south ends of the spur; thereby
transferring any accumulated liquid to the drainage ditches on each side of the rail spur, For all
practical purposes, the under drain system and drainage ditches would hold approximately
1,497,620 gallons, representing 49 — 30,000 gallon tanker cars.
A gate valve was installed to restrict the flow out of the rail car drainage system to the
constructed wetlandlbioretention basin. The valve is to be closed before train off-loading
begins, and is open otherwise. Any discharge of ethanol would thus be contained within the
drainage ditches along the rail spur. Rainfall that collects within this area while a train is in
station is contained and may be released to the drainage inlet by manually opening the closed
and locked valve after inspecting the accumulated water and determining that releasing it will
not result in a release of petroleum products. The facility maintains an inspection log that
documents the opening and closing of the gate valve.
If you have any questions, or require additional information, please feel free to contact me by
phone at [phone], or by email at MiehelleMBrown aol.com.
Thank you,
Michelle M. Brown
Environmental Consultant
Enclosures:
No Exposure Certification Application
Facility Site Map
Facility Stormwater Post Construction Map
CC: Chad Conn, Eco-Energy
David Rodriguez, Eco-Energy Selma
Stephen Chambers, P.E., Chambers Engineering, PA