WQ0002702_Regional Office Historical File Pre 2018 (24)

('nvironment and Natural .Resources
Michael F. Easley, Governor.
Williatn G. Ross Jr., Secretary.
James D. Simons, P.G.; P.E.
Director and State Geologist
NOTICE OF DEFICIENCY
November 25, 2008
CERTIFIED MAID
RETURN RECEIPT 12EQUESTED
7001 2510 0000 6682 0486
Buie Land Company, Inc.
Attn: Randall Andrews
2042 Buie-Philadelphus Road
Red Springs, NC 28377-
Dear Randall or Charlie Andrews:
I%
A4 147A 6
NCDENR
Division of Land Resources'�'�
RE; Notice of Deficiency, `Para Mine
Permit Number: 78-29
Robeson County, North Carolina
River Basin.: LUMBER
On 11/24/2008, an inspection of the subject mine was perfotxl}cd by Eric
Matuszewski, Sally McKinney, and Lvangel.yli l,owery-Jacobs of this office.
Deficiencies were observed that require your prompt attention..
The deficiencyies discovered and -the necessary corrective actions are as follows:
1. 005 -- All mining boundaries (6.,12 acres) shall be permanently marked at the
site on t00. foot intervals unless tlic line of sight allows for. larger spacing
intervals.
Mining boundary markers were not visible at the time of the inspection.
2. OC4.B: All drainage from the. affected area around the mine excavation shall
be, diverted internal to said excavation.
The mine pit drains. into an open -ditch and is.discharged into an off -site body
of wate.f.
Land Quality Section [phone] Fax [phone]
225 Green Street, Suite 114/ Systel Building, Fayettevi Ile, North Carolina 28301-5043
AN EQUAL OPI'OI2TUNIIrY \ ArI' IIZMA'rIVE ACTION EMPLOYER— 50% RI CYCLED / 10% POST CONSUMER PAPER
c,}

�,8::Berrhs shall be constructed or vegetation in the form of evergreens
and/or red tips shall be planted along the entire property line that parallels NC
Hwy 72 around the property line that parallels the existing soil access road for
a minimum of 250 feet. Said berms shall be a minimum of six feet in height
with sideslopes that maintain adequate vegetation. Said trees shall be planted
on six foot staggered spacings and shall be a minimum height of four feet.
The berm does not extend along the entire property line that parallels NC Hwy
72 or the property line that parallels the existing soil access road.
4. OC10A -- No on -site disposal of refuse or other solid waste that is generated
outside of the mining permit area shall be allowed within the boundaries of
the mining permit area unless authorization to conduct- said, disposal bAs first'
been obtained from both the Division of Solid Waste grid the Laiid Qiialiiy
Section, Department of Environment and Natural Resources. The method of
disposal shall be consistent with the approved reclamation plan.
Immediately remove solid waste from within the mine boundaries and dispose
of waste in a disposal facility approved by the Division of Waste
Management.
5. OC1013: Mining refuse as defined by G.S. 74-49 (1.4) ofthe Mining Act of
1971 generated on -site and directly associated with the mining activity may be
disposed of ina. designated refuse area. All other waste products must be
disposed of in a disposal facility approved by the Division of Waste
Management. No petroleum products, acids, solvent or their storage
containers of any other material that may be considered hazardous shall be
disposed of within the permitted area.
Multiple piles of off -site generated waste were observed during the inspection.
The piles varied in their.content (cement blocks, household debris, plastic
bags, plastic gasoline dispensers, an unidentified white granular substance).
These piles are to be removed from within the mine boundaries aad disposed
of in facilities approved the Division Waste Managernent and the Division. of
Hazardous Waste Management.
6. OC12: Mining refuse as defined by G.S. 74-49. (14) of the Mining Act of
1971 generated on' -site and directly associated with the mining activity may be
disposed of in a designated refuse area. All other waste products must be
disposed of in a.disposal facility appyp ed by the Division of Waste
Management. No petroleum. products, acids, solvent or th.dir'storage
containers or any other material that may be considered hazardous shall be
disposed of within the permitted. area.

Multiple piles of off -site generated waste were observed during the inspection.
The piles varied in their content (cement blocks, household debris, plastic
bags, plastic gasoline dispensers, an unidentified white granular substance).
'These piles are to be removed from within the mine boundaries and disposed
of in facilities approved the Division Waste Management and the Division. of
Hazardous Waste Management.
7. RC2D: No contaminants shall be permanently disposed of at the mine site.
On -site disposal of waste shall be in accordance with Operating Condition
Nos. I O.A.. through P.
The mining site is not in. compliance with Operating; Conditions 10A and I OB,
as described in items 4 and 5 of this Notice.
If the previously described deficiencies are not corrected within 30 days following your
receipt of this Notice this platter will be referred to the Director., Division of Land
Resources/Department of Environment and Natural Resources, for issuance of a "Notice of
Violations" in an effort to secure compliance. In addition, failure to correct the deficiencies may
result in the assessment of civil penalties and/or injunctive relief against you.
Do not hesitate to contact Eric Matuszewski or me at [phone] regarding any
questions you may have.
Sincerely,
M. Stephen Cook, C.P.E.S.C.
Regional Engineer
Land Quality Section
MSClsyn-
Enclosure: Inspection Report
cc: Floyd Williams, PG, CPG, CPESC
Dennis Shackleford, FRO Solid Waste Management
Christy Richardson, FRO; :Division of Air Quality
3

orth Carolina Department of Environment and Natural Resources,
Division of Land Resources, Land Quality Section
U-MW 1NSPECTInM REPORT
(PERMITTED MINE)
1. MINE NAME Mica, rn i a e 2. MINING PERMIT 4 I S °-11
3. OPERATORtonmA Q Ae^rt,�eL 4. COUNTY__ kploe h M
5. ADDRESS a o y Pil-
6. PERMIT EXPIRATION DATE 7. RIVER BASIN sj. MjzA•4_j
S. Person(s) contacted at site -�
9. Was mine operating at time of inspection? ❑ Yes Yd No 10. Pi6tures? (, ;Yes ❑ No
11. Date last inspected: a / l 1 / (_l� 12. Any mining since last inspection? . 41 Yes ❑ No
13. Is the mine in compliance with the Operating Conditions of the Permit? ❑ Yes D( No
If no, explain:
OC.
� r t
'/ o
iUS it
14. Is the mine in eompliance with the Re niation Conditions of the :Permit? 0 Yes WNo
a
If no, explain: i s d a (f5 a +0 t aju �& auaAbo ah o r. v :tg.; t I
15. Did any of the, above deficiencies result in offsite damage? ❑. Yes No If yes, describe the
type and severity of the damage:
no
16. Cogective measures needed and/or taken:
CL001crizum
tl
17. Other recommendations and comments:
18. Is the Annual Reclamation Report +/-map accurate? ❑ Yes No (Explain) ❑ Not Reviewed
guoc+ amigs 01 OA&Ato 6141/wf
tLe-1 tot dad '1VI 11-k
19. Follow-up inspection needed? WYes ❑ No La `wed date / l !
20. No. of additional pages of Inspection Report_. 21. Copy of Report sent to operator
(date)
INSPECTED BY:w�jjip"i . DATE 4 l / Zq/n
Telephone No: (
White copy to file Yellow copy to operator Pink copy to .Mining Specialist 10197

r
NCDENR &;
Nortn Carolina Department of Environment and Natural Resources
DIVISION OF AIR QUALITY
Michael F. Easley, Govemor
C1ER'I'IFIEi). MAIL RETURN RI,CEIP I' REQUESTED
7099 3400 00161988 51.03
September 8, 2008
Mr. Randall Andrews, Owner
Buie Land Company, Inc.
2700 NC: Hwy 72 West
Lumberton, NC 28360
SUB.11_,'CT:Cc*
ivt11'c ty tlssess7ncnt for V°rolatiioi("s)
21) .1900n 1=ta t
File No.: DAQ 2008-113
Violator: Buie I.,and Company, Inc. .
County: Robeson
Dear Mr. Andrews:
l
FRI0
William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
This letter transmits notice. of civil penalty assessed against .Buie Land Company, Inc. in the.amount of
$2,000 and $183 investigative costs, for a total of. $2:,183.
Enclosed is a copy of -the assessment document explaining this penalty. This action was taken under the
authority vested.in me. by the delegation pursuant to.North Carolina General Statutes (NCGS) 143-215.114A(d).
Any new or continuing violation(s) may be the subject of a new enforcement action,. including additional penalty.
You must take one of the tlu•ee actions outlined Below within thirty (.30) claysfronr the date of receipt of
this letter•. Please be.advised that if you fail to exercise one of the following options within thirty (30) days,
you will lose your right to appeal or contest this case andyouur cirse will he forwarded to the Attorney
Gener•ril's Of.ce for eollectiort.
1. Subixiit payment oftite penalty:
Payment should be made directly to the order of the North Carolina Department of Environment and Natural
Resources (NCDENR). When submitting payment, please reference your DAQ case number on your check to
insure, proper posting. Please do not include the attached waiver form when submitting payment. Payment of the
penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit
payment to the attention of:
Egforcement Group - Payment
Department of Environment and Natural Resources
Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641
1641 Mail Service Center, Raleigh, NC 27699-1641T��11� 7 ,
2728 Capital Blvd., Raleigh, NC 27604 1�101111cc11��,)1.1T1c1
Phone: [phone] / FAX: [phone] / Internet: www.ncainorl; /
An Equal Opportunity / Af irmativc Action F.,mploycr- 50%Recycled/10%PostC:onsumer Paper f� off

secl, that it is the policy for NCDENR to charge and collect a processing fee of $25.00 for
Checks on rvlt.icl: payment has been refused by the brink bectruse qf insufficient funds or because of an
invalid bank account.
OR
2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited'to consideration of the five factors listed below as they
may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of the factual statements contained in the
civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a. request must be accompanied by a waiver' of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues a.re in dispute. Please prepare a detailed statement that.establishes why you
believe civil penalty should be remitted, aiid submit it io the address listed below. In determining whether a
remission request will be approved; th6T6llowing factors shall be considered:
(1) whether one or more of the civil penaltyassessment factors in NCGS 14313-282.1(b) were
wrongfully applied to the detriment of the violator;
(2) whether the violator promptly abated. continuing environmental damage resulting from the
violation;
(3) whether the violation ,Was inadvdi,ten t or a result of an accident;
(4) whether the violator has been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment -for the remaining necessary
remedial actions.
Please note that all evidence presented in support: of your request for remission must be submitted in writing.
If you chose this option, do not send in lrayinent at this time. The Director of the Division of Air Quality
(DAQ) will review your evidence and inform you of his/her decision in the matter of your remission request.
The response will provide details regarding the case status, directions for payment, and provision for further'
appeal of the penalty to the Environmental Management Commission's Committee on Civil Pendlty Remissions
(Committee). Please be advised that the Committee cannot consider information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission. .
In order to request remission, .you must complete and submit the enclosed "Request for- Remission of Civil
Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts".form within thirty (30) days
of receipt of this notice. The DAQ also requests that you complete and submit the enclosed "A.Viification,or
Remission Request." .Both forms should be submitted to the following address:.
Enforcement Group - Reinksio.n
Department of Environment and Natural Resources
Division of Aii• Quality
1641 Mail Service Center
Raleigh, North Carolina 21699-1641

Page 3
OR
3. File a petition for an administrative bearing with the Office of Admiieistrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an
administrative hearing. You may obtain the petition form from the Office of Administrative .Hearing (OAH).
You must file the petition with the OAH within thirty (30) days of receipt of this notice. A petition is considered
filed when it is received in the Office of Administrative Hearings during normal office hours. The OAH accepts
filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p,m., except for official state holidays.
The original and one (1) copy of the petition must be fled with the OAH. The. petition may.be faxed, provided
the original and one copy of the document is received in the OAH within five (5) business days following the
faxed transmission. The mailing address for the OAH is as follows:
Office of.Administrative 1-:learings
6714 Mail Service Center
Raleigh, NC 2769976714
Telephone [phone] Facsimile: [phone]
A copy of the petition must also be seined on NCDENR as follows:
Mary Penny ll-iompson, General Counsel
North Carolina Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-160.1
Please Indicate the DAQ case nuin6er, as found on Page 1 of this letter, on ,your petition to -OAI-I
Failure to exercise one of the opkioris above within thirty (30) days of receipt of this letter, as evidenced by
an internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney
General's Office for collection of the penalty through a civil action. Please be advised that additional penalties
may be assessed if the violations that are the subieet of this action have not been corrected.
If you have any questions concerning this matter, please contact Jennifer White at [phone].
Sieciitvercash,
B, P.E.
Enclosures: Assessment Document
cc: Steve;l F.. 'Vo!'Lo, SllperVlso3• Fayetteville.Re.gional Office
Enforcement File (DAQ 2008-1.13)

I CAROLIN/'
rSON
IN I IIL' M.A.1 11,K OF: NORTH CARULINA
ENVIRONMENTAL MANAGEMENT COMMISSION
BUIE LAND COMPANY } CASI? NO. 2008-113
FOR VIOLATION OF: )
15A NCAG 2D .1900 )
"OPEN BURNING" ) CIVIL PENALTY ASSESSMENT
)
)
Acting pursuant to North Carolina General. Statutes (G.S.) 143-215.11.4A,1, B.-Keith Overeash, P.E., Director of the
Division of Air Qualit}r (DAQ), lnalce the following: '
I.. FINDINGS OF FACT:
A. On I 1 January 2008, Mr. Steven Vozzo of the Fayetteville Regional Office of the Division of Air Quality (FRO
DAQ) received a complaint from Mr. Bobby Nelms ofNC Division of Waste Management, Hazardous Waste
Section. Mr. Nelms stated that on 10 January 2008, he had observed a large.snioldering pile of materials at a
business facility that included creosote poles and. other construction debris. Mr. Neh is stated that while at the
site, he was informed that the observed pile was created so the local fire department would have a place to
practice fire training. * Mr. Nelms stated that the location of the burn site was at The Tara Group of Lumberton,
Inc., 2700 NC Highway 72 West near Lumberton, Robeson County, NC. 'The Buie Land Cornpany, Inc owns
the property where the burning occurred.
B. On 11. January 2008, Mr. Neil Joyner (FRO DAQ) investigated this complaint.. Mr. Joyner was accompanied by
Mr. Andrew Iiammonds of the Fayetteville Regional Office of the: Division of Waste Ivlanagenlent. Upon arrival,
Mr. Joyner observed a smoldering pile of materials that included wooden poles similar to telephone poles, a green
powdery substance, plywood, wooden boards, nails, metallic banding, metallic filter, tree stumps, metal parts, saw
blades, metallic drum lids, and painted lumber. The burn pile measured 39 feet by 63 feet in area. The smoke from
the observed smoldering wooden poles had a strong creosote -like odor. The pile was 672 feet from a house that
appeared to be occupied.
C. On I I January 2008, Mr. Randall Andrews stated to Mr. Joyner by phone that:
a. His company, Buie Land Company, owned the property at this burn site.
b. The Raft Swamp Volunteer Fire Dept. had burned the observed smoldering pile as a training exercise
Oil his property. 171e was not at the site (luring the training exercise. lie understood that the fire dept.
was planning to burn unpainted wooden pallets. The pallets came from Industrial and Agricultural
Chemicals, another of his companies, located between Red Springs and Lumberton, NC.
c. He (lid not realize that the fire department had included 2-3 utility poles in the fire. He (lid not tell them
to burn the poles, but assumed that the poles were from his property. He did not notice other materials
in the pile besides wooden pallets until yesterday.
D. .On 25 January 2008, FRO DAQ .issued Buie 1.4nd Company a Notice of Violation/Notice of Recommendation
of Enforcement (NOV/NRE) for allowing the fire department to burn a pile of debris.

11
E. On 8 February 2008, PRO DAQ received a written response to the NOWNRE from Mr. Randall Andrews of
Buie Land Company. He stated that lie did not know that there was any regulation against burning wooden
pallets. He stated that had he known this, he would never have asked the Raft Swamp Fire Dept. to -use them in
a training exercise. Mr. Andrews failed to provide FRO with the requested inforination regarding materials in
the fire and their origins
F. Compliance History: No record of previous violations.
The costs of investigation or inspection in this matter totaled $183.00
CONCLUSIONS OF .LAW:
A. Buie Land Company was in violation of 1.5A NCAC 2D.1900, for causing, allowing or permitting open
burning, as reflected in fart I, Findings of Fact, above.
B. G.S. 143-215.1 AA provides that a. civil penalty of not more than twenty-five thousand dollars per violation
may be assessed against a person who violates or fails to act in accordance with the terms, conditions, or
requirements of a permit required by NCGS 143-215.108 or who violates any regulation adopted by the
Environmental Management Commission.
C. G.S. 143-215.3(a)(9) provides that the costs of any investigation or inspection may be assessed against a
person who violates or fails to act in accordance with the terms, conditions, or requirements of a permit
required by G.S. 143-215.108 or who violates any regulation adopted by the Environmental Management
Commission.
Based upon the above Findings of Fact and Conclusions of Law,] make the following:
DECISION:
Buieland Company is hereby assessed a civil penalty of:
-2 allo
For one (I ) violation of 15A NCAC 2D.1900, "Open Binning."
$ t F?p t 'TOTAL CIVIL PENALTY, which is percent: of the maximum penalty
authorized.by G.S. 143-2:15.114A.
$ 183.00 Investigation costs
$, TOTAL, AMOUNT DUE

Pursuant to G.S. 143-215.114A in determining the amount of the penalty, 1 considered the factors listed in G.S. 14313-
282.1(b) and 15A NCAC 27 .0106, which are the following: ,
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting,, from the violation(s);
2) The duration and gravity of the violation(s);
3) The effect on ground or surface water quantity or quality or on air quality;
4) The cost of rectifying the damage;
5) The amount of money saved by noncompliance;
6) Whether the violation was committed willfully or intentionally;
7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
8) The cost to the State of the enforcement zKi
p� ell,
Date ercash9PE., irector
Division of Air Quality .

I
i. Complete'ttems 1, 2. and 3. Alao oomPlete
Item 4 It Restrlcted 081" IS desired.
i td print tour name and address on the reverse
so that we can retum the crud to YOU.
M Attach this card to the back of the maliplece,
or on the (tent It apace permits.
1. Artict• Addressed to:
DAQ 2008-It3 CPA 0910=008
vlr. Randall Andrews
Buie Land Company, Inc.
voo NC Hwy 72 West
Lumberton. NC 28360
8. (A*ded Neme) C. Date of OGAWW
0. to daemy addre" dt fewd from item 17 0 Yes
tt yES, emar degvwy addre" below: 0 No
3. a Zipe
SrNfled Mail 0 Exprosa Mail
tpr Merc�andtea
0 aepteterad �^ aet�eipt
C3 Insured Melt C.0.0.
4. tiesdlcted Oa&INOI r 0" Fee) I3 Yea
2• Artx3e Number 7099 3400 0016 7988 5103
(transfer from service !abet)
Ps Form 3811, February 2003 Domeatic Return RacelPt
UNITED STam3)Po J.:
• Sender: please print your name, address, and ZIP+4 in this box •
NC DIVISION OF AIR QUALITY
ATTN: ENFORCEMENT
1641 MAID SERVICE CENTER
RALEIGH NC 27699-1641
Paz T Lrlrttrrtlrilrr{�ltt•{,1rt,iillrlitrt.lrrlrrrll{ilrrl1liilrr(it

RCDENR
North Carolina Department.of Environment and Natural Resources
DIVISION OF AIR QUALITY
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
CTRTI..FIED MAIL RETURN RECEIPT REQUESTED
7099 3400 001.6 7988 5080
Mr. Charles.Andre'ws
'I'ara Group Lumberton,
`1�r
of .Inc.
2700 NC: I-1.wy 72 West
l.,umberton, NC 28360
�,►�,
N/V
SUBJECT: Civil Penalty Assessment for Violation(s)
hj" . .,
2D .1900 Ct�pei i3:ttrn'�in
- �° 9
File No.: Ali),
0>
Violator: Tara Group of Lumberton, .Inc.
CO
County: Robeson
Dear Mr. Andrews:
']'his letter transmits notice of civil penalty -assessed against Tara Group of Lumberton, Inc. in the amount of
$1,000 and.$183 investigative costs, for a total 001,1 ,
Enclosed is a copy of the assessment document explaining this penalty. 'Phis action was taken under the
autlxority vested in me by the delegation.pursuant to North Carolina General Statutes (NCGS) 143-215.114A(d).
Any new or. continuing violation(s) may be the subject of a new enforcement action, including. additional penalty.
You must take one of the three actions outlined below'within thirty (30) flays.from the slate of receipt of
this letter. Please be advised that rf you fail to exercise one of the following options within thirty (30) days,
,you will lose your right to dlipeal or contest this case and your: case ivill-be fortvai (Ied to the Attorney
Ger:ere'l s Office for collection.
1. Submit payment of the penalty:
Payment should be made directly to the order of the North Carolina Department of Environment and Natural
Resources (NCDENR). When submitting payment, please rei'erence. your DAQ case number. oil your check to
insure proper posting. Please do not include the attached waiver form when submitting payment.. Payment of the
penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit
payment to the attention of:
Bnforcement Group - Payment
Department of Environment and Natural Resources
Division of Air Quality
1.641 Mail Service Center
Raleigh, NC 27699-1641
1641 Mail Service Center, .Raleigh, NC 27699-1041 �T.lie
2728 Capital Blvd„ Raleigh, NC 27604 i�l {.}ftbICcll'ofiiia
Phone: [phone] / PAX: [phone] / Internet: www.ncair.org Nafitrally
An Equal Opportunity / Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

)8
Pised, that it is the policy for NCDENR to charge and collect a processing fee. of $25. 00 for
checks on which payment has been refused by the bank because of insufficient funds or because of an
invalid batik account.
OR
2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they
may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s) occurred or the accuracy of the factual statements contained in the
civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right: to an administrative hearing and a stipulation and
agreenient.tilat rio,faci:ual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believecivil.pcnalty sliould-be remitted, and submit it to the address listed below. In determining whether a
remission request will be approved, the following factors shall be considered:
(1) vvhkher one; or in' ore.of the civil penalty assessment factors in NCGS 143I3-282.1.(b) were
wrongfully applied to the detriment of the violator;
(2) whether the..violator promptly abated continuing environmental damage resulting from the
:violation; .
(3) whether the violation was inadvertent or a result of an accident;
(4); . whether. the;violalor has been assessed civil penalties for any previous violations; or
(5) .whetliec haytl e"nt of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing.
If you chose this option, do not send in payment at this tune. The Director of the Division of Air Quality
(D.AQ) will review your evidence and inform you of his/her decision in the matter ofyour remission request.
The response will provide details regarding the case statics, directions for payment, and provision for further
appeal of the penalty. to the .Environmental Management Commission's Committee on Civil Penalty Remissions
(Committee). Please be advised that the Committee cannot consider information that was not part of the original
remission request considered by the Director. Therefore, it is very important that you prepare a complete and
t'hOrbllgh statement in support of your request for remission.
Ill order to request.remission, you must complete and submit the enclosed "Request for Remission of Civil
Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days
cif receipt of this notice. The DAQ also requests that you complete and submit the enclosed ".lust f cation for
Retnission Request." Both forms should be submitted to the following address:
Enforcement Group - Remission
Department of Environment and Natural Resources
Division of Air Quality
1641 Mail Service Center
Raleigh, North Carolina.27699-1.641

f
1
Fage drews
OR
3. File a petition for an administrative hearing with the Office of Acimireistrative Bearings:
if you wish to contest any statement in the attached assessment document you must file a petition for an
administrative hearing. You may obtain the petition forin from the Office of Administrative Hearing (OAH).
You must file the petition with the OAH within thirty (30) days of receipt of this notice. A petition is considered
filed when it is received in the Office of Administrative Hearings during normal office hours. The OATI accepts
filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays.
The original and otte (1.) copy of the petition must be filed with the OAH. The petition may be faxed, provided
the original and one copy of the document is received in the OAH within five (5) business days following the
faxed transmission. The mailing address for the OAH is as follows:
Office of Administrative .Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tclephone*(91.9) 733-2698 Facsimile: [phone]-
A copy of the petition must also be served on NCDLNR as follows:
Mary Pehny Thompson, General Counsel
North Carolina .Department of 1:.nvironment and Natural Resources
160E Mail Service Center
Raleigh, North Carolina 27699-1601
Please Didicate the DAQ case number, as found on Page 1 of this letter, on your petition to OA-H.
Failure to- exercise one of the options above within thirty (30) days of receipt of this letter, as -evidenced by
an internal date/time received stamp (not a postmark), will'result in this smatter being referred to the Attorney
General's Office for collection of the penalty through a civil action. Please be advised that additional penalties
may be assessed. if the violations that are the subject of this action have not been corrected.
If you have any questions concerning this matter, please contact Jennifer White at [phone].
Sincer
�y
h Overcash, P.E.
Enclosures,. Assessment Document
cc: Steven F. Vozzo, Supervisor Fayetteville Regional Office
Enforcement File (DAQ 2008-115)

H CAROLINA
3ESON
IN THE MATTER OF:
THE T ARA GROUP OF LUMBERTON, )
INC. )
FOR VIOLATION OF: )
}
15A NCA.0 2D .1.900 )
"OPEN BURNING" )
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
CASE NO, 2008-115
CIVIL PENALTY ASSESSMENT
Acting pursuant to North Carolina. General Statutes (G.S.) 143-215.114A,1, B, Keith Overcash, P.E., Director of the
Division of Air Quality (DAQ), make the following:
I. FINDINGS OF FACT:
A. On 1 I January 2008, Mr. Steven Vozzo of the Fayetteville Regional Office of the Division of Air Quality (FRO
DAQ) received a complaint from Mr. Bobby Nelms of NC Division of Waste Management, Hazardous Waste
Section. Mr. Nelms stated that on 10 January 2008, he had observed a large smoldering pile of materials at a
business facility that included creosote poles and other construction debris. Mr. Nelms stated that while at the
site, he was informed that the observed pile was created so -the local fire department would have a place to
practice fire training. Mr. Nelms stated that the location of the burn site was at The Tara Group of Lumberton,
Inc., 2700 NC Highway 72 West near Lumberton, Robeson County,.NC. The property where the burning
occurred is owned by the Buie Land Company, Inc.
B. On 11 January 2008, Mr. Neil Joyner (FRO DAQ) investigated this complaint. Mr. Joyner was accompanied by
Mr. Andrew flarmnonds of the Fayetteville Regional Office of the Division of Waste Management. Upon arrival,
Mr. Joyner observed a smoldering pile of materials that included. wooden utility poles, a green powdery substance,
plywood, wooden boards, nails, metallic banding, metallic filter, tree stumps, metal parts, saw blades, metallic drum
lids, and painted lumber, The Burn pile neasured 39 feet by 63 feet in area. The smoke from the smoldering
wooden poles had a strong.creosote-Iike. odor. The pile was measured to, be approximately 672 feet from.a house
that appeared to be occupied.
C. On 14 January 2008, Mr. Charles Andrews, Owner, The 'Para Group of Lumberton, Inc., talked by phone to Mr.
Neil Joyner and Mr. Steven Vozzo of the FRO DAQ. Mr. Andrews stated that lie allowed the Raft Swamp
Volunteer Fire Dept. to burn the materials at his company's facility for fire training of new fire fighters. The
fire department had binned at the site a couple of times previous to this burn. The pile consisted of scrap wood
from the community that had been piled up for a training burn. Some CCA wood somehow got bumped into
the pile. His company at
the utility poles that were burned. He also stated that his company, a construction
business, was renting the property from his father's company, Buie Land Company.
D. On 25 January 2008, FRO DAQ issued The Tara Group of Lumberton, Inc. a Notice of Violation/.Notice of
Recommendation of Enforcement (NOV/NRE) for allowing the fire department to burn a pile of debris. The
certified mail green card indicates receipt of the NOV/NRE on 28 January 2008. As of the date of this
assessment, FRO DAQ has received no written response to the NOVJNRE.
E. Compliance History: No record of previous violations.
F. The costs of investigation or inspection in this matter totaled $183.00

North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor
mgOnX21)-10%
CEWrI IFD MAIL
RFTiJRN RFCEIPT REQUESTED
Randall Andrews
Safety .Manager
Industrial & Agricultural Chemicals, Inc.
2042 .Buie Philadelphus Road
Red Springs, NC 28377
William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
SUI3JECTtd�ta�;�taf�;��a�n � <a� �t�t•.euis� �i!Iaiintaiui Itrsba��aont'�1�ati��. Aaatc� .lit�>�rir�€I�' .
and
ex �a►t ddett n�alFl f®xs�rnataan >i�atfeb y leg- 1tgg-®.pet ati011-,
In l C ustYial & Agriculturahemicals, nc. Perintt lo. OG125R09
Red Springs, .North Carolina, Robeson County 06/78-00168
Dear Mr. Andrews:
On 31. July 2008, Steven Vozzo; Mitchell Revels, and Christy Richardson, of the Fayetteville Regional
Office, conducted an annual compliance inspection of Industrial & Agricultural Chemicals, Inc. in Red Springs, NC.
During the inspection, Mr. Revels and staff observed that records were not adequate for the bagfilter and scrubber
inspections. Also, during the inspection, we observed a small scale trial run of the battery recycling operation for
which the facility has submitted a permit application. Additional information will be required prior to permitting
this process. The violation and requirement for additional permit information are described below.
(1) Notice of Violation -for Failure to Maintain Infection and Maintenance Records.
During the inspection, Mr. Andrews was not able to provide complete inspection or maintenance records for the
bagfulters (ID Nos. C-1, CD -I PB-3, C-4, CD-FPB-2, C-5, and DA-2) and aqueous contact scrubbers (ID Nos.
D-3 and D-4). Specific Condition and Limitation A.B. of Air Permit No. 06125R09 states that your facility
shall perform periodic inspection and maintenance as required by the manufacturer for the bagfilter and scrubber
systems. The specific condition also requires that your facility perform an annual internal inspection of each
bagfilter and scrubber system. It appears that some inspections may have been done, but documentation was
limited. Since records did not indicate that annual inspections had been performed on the control devices listed
above, Industrial & Agricultural Chen icals, Inc. is in violation of this regulation.
Additionally, other record keeping appeared not to be kept up to date. Suggestions were made to you during the
inspection conference on ways to improve your record keeping system. This office also understands that you
are preparing the .requested updated process diagram for your facility. Since much of your operation is a batch
process, records are needed on daily and even hourly production. This information will be imperative in order
to renew your air permit in the next six months.
Fayetteville Regional Office -- Division of Air Quality One
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043 Nor thCarolina
Phone: [phone] Fax: [phone] Internet: http:/Mww.ncair.org
An Equal Opportunity/Affirmative Action %ployer - 50% Recycled/10% Post Consumer Paper Gitmrally

Industrial & Agricultural Chemicals, Inc.
Notices of Violation / PA.I --- l I August 2008
Page 2
(2) Permit Additional Information Le-g<lyding the Alkaline _Battcy Recyclin Y. aeration.
During the inspection, a trial run of the alkaline battery recycling operation was performed. following this
observation, and after conducting further research, it appears that additional information will be required in
order to process your permit application for an alkaline battery recycling facility. This office is concerned
that all the emissions have not been evaluated. The -following items/concerns should be addressed:
® Detailed description of how your facility plans to eliminate al t plastic materials prior to drying;
® Detailed process flow diagram of the battery recycling operation;
a An. analysis of all emissions generated or emitted during this process (including emissions froth inherent
mercury) and toxics demonstrations if required.
e Detailed description of the emission controls your facility plans to use to control these emissions
Your permit application will remain on hold until you and your consultant address the additional concerns
and submit a completed permit application. :Please note that the alkaline buttery recycling; operation is not on
Your current air permit and should not be operated until an air permit has been issued.
Please submit a written response to this Office by 27 August .2008 as to actions taken to bring about
compliance and any additional information or description of any mitigating circumstances in reference to the
violation. The response should outline steps that you plan to take or have taken.. to return to compliance. As stated
above, your permit application for• a battery recycling facility will not be processed until a complete permit
application, addressing the additional items of concern, is submitted.
As stated. in the ".subject" above, this letter represents a Notice of Violation for the recordkeeping issues
observed on 31. July 2008. The above violation and any future violation of an air duality regulation are subject
to the assessment of civil penalties as per North Carolina General Statute 143-21.5.114A. This General Statute
provides that civil penalties of not more .than twenty-five thousand ($25,000) may be assessed against any
person who violates any classification, standard, or limitation established pursuant to General Statute 143-
21.5.107, "Air Quality Standards and Classifications." In addition, each day of continuing violation after written
notification from the Division of Air Quality shall be considered a separate offense. In addition, please refer to
the enclosed Pollution.Ptevention/Small Business insert for further information if you need assistance.
The Division strongly .recommends that you carefully examine your current permitstipulations and request
explanation from this Office as necessary. We appreciate your prompt attention to these matters. If you have any
questions regarding this matter or if we can provide any additional information or assistance, please call Christy
Richardson, Environmental 13ngineer, at (9.10) 433-3377, or me at [phone].
Sincerely,
.' Steven F. Vozzo
Regional Air Quality Supervisor
fin.closure — Pollution Prevention Brochure
SF'V%ctr
cc: DAQ Central Tiles
FRO County Files

V8/2008 15:04
9197153605 DWM
RUMA
-A&
NCDEN
January 29, 2008
CERTIFIED MAIL
RETURN RECEIPT R�UUESTED
Mr. Randall F- Andrews
2042 Buie Phil Road
Red Springs, NC 28377
Dear Mr. Andrews:
PAGE 02/06
L&bt,j Fi l
DwM
k/O V
IMMER ATE ACT] -ON
NOTICE OF VI1T�4N
Docket ## 2008-039
On December 18, 1980, the State of North Carol,.In Hazardous Waste Section (Section) was
authorized to operate the State Resource Conservation and Recovery Act (RCRA) Hazardous
Waste Program under the Solid Waste Management Act (Act), N.C.G.S. 130A, Artiel W 9 and
riles promulgated thereto at 15A NCAC 13,A, (Rules), in lieu of the Federal RCRA. prosta m.
On January 10, 2008, Mr. Bobby Nelms, Environmental Senior Specialist, with this office,
conducted an investigation at the TARA Group office and grounds. The property is located at
2700 NC Highway 72 west in Lumberton, North- Carolina The January 10, 2008 investig ation
was conducted in response to a complaint alleging the improper disposal of chemicals at f xe
property.
Statement f Faeta—RAlated to Respondent's. Management of Hazardous Was
The January 10, 2008 investigation revealed that the land behind the TARA shop was used E for
the ruining of sand and that various types of material had been dumped on the site. There avers
two distinct areas of concern.
The first area, which was closest to the office, had been used to dump caustic soda sludge uad
gypsum. According to Mr. Randall. F. Andrews, owner of the property, the material was p laced
there temporarily until it could be mixed together as a fertilizer to be applied to the land. ! ►t the
time of this investigation it was apparent that the material had been we, but not liquid, wh ,.n
placed in this location. This material will be mixed and used as a fertilizer on the land as
discussed. during our Meeting.
The area of primary concern was located back further behind the office area. This area hac l been
used to burn pallets for, the local fire department to practice extinguishing. The debris pile
contained burned remains of creosote poles and rttetal from unidentified sources. Addition wily,
near the burned creosote poles, there were areas of ash which appeared Been in color. The green
IJ`i'1 I':rf :rl �'C'• t%iC� i_,:? ilA)'. kalei!jh:,(.arciin,
Ph -one 9'19-I33-�49J61 F^
X
An Fgwq! 1110ailuulyr ! q(iar*,lii;o • ;;run rnhlr, �r;:i F'i 1}!qa r,,l: ,^. I,?I

IPP0
008 15:04 9197153605 DWM
color of this ash indicates that there is potential of contamination from burned CCA treat, A.
Poles. During a later conversation with bdr. Andrews, he stated that the poles :had been
purcbased and had been burned accidentally.
Statutorvy and Rggnlatory Background
PAGE 03l06
A. 40 CFR 261.1(a), adopted by reference at 15A NCAC 13A .0106(a), identifies those solid
wastes which are subject to regulation as hazardous wastes under Parts 262 biro ugh 265
and Parts 270, 271, and 124 of this Chapter and which are subject to the notification
requirements of Section 3010 ofRCRA.
B. 40 CFR 261.2(b), adopted by reference at 15A NCA.0 13A .0106(a), states that rlaterials
.are solid waste if they are abandoned, by being [1) disposed of; or [2] br:rned or
incinerated; or [3] accumnulated, stored, or treated (but not recycled) before or it E lieu of
being abandoned by being disposed of, burned, or incinerated.
C. 40 CFR 261.3(a), adapted by reference at I SA NCAC 13A .0106(a), states that a: Aid
waste, as defined in Section 261.2 is a hazardous waste if:
It is not excluded from regulation as a hazardous waste under Section 261.4(b);
and
2. :ft meets any of the following criteria:
i. It exhibits the characteristics of hazardous waste identified in Subp art C.
ii. It is listed in Subpart D and has not been excluded from the lists in
Subpart D render Sections 260.20, and 260.22 of this chapter.
HL It is a mixture of solid waste and, hazardous waste that is listed .in S abpart
D solely because it exhibits one or more of the characteristics of hazardous
waste identified in Subpart C, unless the resultant mixture no long
exhibits any characteristic ofhazardous waste identified in Subpart C.
iv. It is a mixture of solid waste and one or more lrvwdous wastes 1 isted in
Subpart D and had not been excluded from this paragraph under Sections
260.20 and 260.22 of this chapter.
D. NCGS 130A-290(6), deftnes "Disposal" w the discharge, deposit, injection., di imping,
spilling, leaking or placing of any solid waste into or on any land or water so -;hat the
solid waste or, any constituent part of the solid vnMe may enter the environtmer it or be
emitted into the air or discharged into any waters, including groundwater.
E. 40 CFR. l 24.2, adopted by reference at 15.A NCAC 13A .0105(a) defmnes "Ov� rice' or
"Operator" as the owner or operator of any "facility or activity" subject to rel elation
under the ItCRA program.

W8/200815:04 9197153605 DWM PAGE 04/06
F. NCGS 130A-290(22), defines "Person" as an individual, corporation, company,
associatiou, partnership, unit of local government, State agency, federal agency or utb. r
legal entity.
G_ NCGS 130A-290(41), defines "Storage" as the containment of solid waste, either on a
temporary basis or for a period of years, in a manner which does not constitute di: posal.
H. 40 CFR. 260.10, adopted by reference in 15A NCAC .0102(b), defines a "geoexator" as
°`any person, by site, whose act or process produces hazardous waste identified . sr listed
in part 261 or whose act first causes a hazardous waste to become subject to regi nation."
The EPA has long recognized that, in the event of a violation of RCRA and the h.- zardous
waste rules, "co -generators" of. hazardous waste can be jointly and severally liable for
improper management of hazardous waste. 45 FR 72024, 72026 (October 30,19f 0).
Violations Rggnirring Immediate Aeiion
Z. It is the determination of the Section that the burn pile residue located at the TAR &. Group
property in Lumberton, North Carolina constitutes storage and. disposal of, solid/ha zardous
waste subject to all applicable requirements of 40 CFR Part 261 through Part M5 and
Part 270, incorporated by reference in 15A NCAC 13A .0106 -- .0110 and .0113.
Specifically, for the burned residue on said property:
1. 40 CFR 26111, adopted by reference at 15A NCAC 13A .01.07(a), requires that a
person who generates a solid waste, as defined in 40 CFR 261.2, must tie termine
if the waste is a hazardous waste using the following method:
a. He should first determine if the waste is excluded from regulatio it under
40 CFR 261.4.
b. He must then determine if the waste is listed as a hazardous waste i i
Subpart Ii of 40 CFR Part 261.
C. If the waste is not ,listed as a hazardous waste in Subpart D of 40 C FR Part
261, he roust determine wbetkier the waste is identified in Subpart C of 40
CFR Part 261 by either.
i. Testing the waste according to the methods set forth in Su apart C
of 40 CFR Part 261, or according to an equivalent method
approved by the Administrator under 40 CFR 260.21; or
ii. Applying knowledge of the hazard characteristic of the waste in
light of the materials or the processes used -
Randall F. Andrews, is in violation of 40 CFR 262.11, adopted by reference at 15A
NCAC 13A .0107(a), in that a solid waste was generated on the property as defined in 40
CFR, 261.2 and a determination was not made by the generator whether that wash: was a
hazardous waste.

V8/2010815:04 9197153605 DWM
PAGE 05106
2. 15A NCAC 13A .0109(a), requires that any person who treats, stores, or disposer; of
hazardous waste shall comply with the requirements set forth in this section. The:
treatment, storage or disposal of hazardous waste is prohibited except as provides l in 40
CFR Parts 264 and 265, adopted by reference in 15A NCAC 13,A .0109 .0110.
Randall F. Andrews is in violation of 1.5A NCAC 13A .0109(a), in that bazardcus waste
has potentially been. stored and disposed without complying with the requires Tents set
forth in 40 CFR Parts 264 and 265, adopted by reference in 15A NCAC 13A .0109 and
.0110.
COMPLMNCE SCHEDULE
Within 30 days from receipt of this notice, Randall F. Andrews shall comply with the following
requirements:
1. Comply with 40 CFR 262.11, adopted by reference at 15A NCAC 13A .010 7(a). An
immediate determination of hazardous characteristics must be completed for all areas of
the burn pile which potentially could contain contamination.
2. Comply with 40 CFR 262.12, adopted by reference at 15,A. NCAC 13A .0107(a). Prior to
shipment of any hazardous waste, an EPA. Identification Number must be obutined for
this site. You may contact Mr. Jim Edwards with. this office at [phone] to make
provisions for obtaining the I.D. number.
3. Comply with 15A NCAC 13A .0109(a). Randall F. Andrews shall no longer store or
dispose of hazardous waste without full compliance with this section. Pending . hipment
of hazardous waste for proper disposal, Randall F. Andrews, must comply with 40 C>:`R
262.34(a), adopted by reference at 15A NCAC 13A .0107(c), which states that:
a. If the waste is placed in containers the generator must comply with Subpart I of
40 CFR Pare 265 or if the waste is placed iu tanks, the generator Must comply
with Subpart J of 40 CFR Part 265, except 265.197(c) and 265.200. 'No waste
piles are allowed.
b. The date upon which each. period of accurrnulation begins mast be clearly marked
and visible for inspection on each container.
C. While being accumulated on -site, each container and tank must be labeled or
marked cl early with the words, "Hazardous Waste"; and
d. The generator must comply with the requirements for owners or. open-ators in
Subparts C and D in 40 CFR Part 265, Section 265.16 and 268.7(a)(4).

IPP/20POE) 15 004 9197153605 DWM PAGE 06106
Potential Consequences of Failure to Cgm I
You must comply with each requirement of this Immediate Action Notice of Violation.
(IANOV); however, compliance will not divest the Section of its authority to ssue an
administrative penalty for the violations cited in this Lk-NOV and additional violations c ited in a
subsequent Compliance Order with Administm i,ve Penalty, hi accordance with NCG 5 130A-
22(a), the penalty shall not exceed thirty-two thousand live hundred dollars ($32,500.00;, per day
in the case of a first violations. Each day of a continuing violation shall constitute a separate
violation.
pursuant to NCGS 130A.-1 S, a violation of any provision of the Actor the Rules may als,) result
in the Section initiating an action for injunctive relief. If an injunction is obtained, you V. ill be
subject to both, the civil and criminal contempt powers of the North Carolina General COTlrts of
Justice.
If you should have questions concerning the issuance of this IANOV, you may contact
Mr. Bobby Nehns at (91.0) 602-3329.
Sincerely,
R
&7k
J
E i eth W. Cannon, Chief
Hazardous Waste Section
cc: Central Files
Mike Williford
Bobby Nelms
Harvi Cooper

4 9197153605
DWM
Fax Cover Sheet
DENA?
Division of Waste Management
Hazardous Waste Section
Compliance Branch
DATE: i L-1 _0 91*'
TO:
FAX #:
FROM
TELEPHONE #:
Number of sheets
COMMENTS:
PAGE 01/06

f
ATMA - -
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
CI<,I7'I'II<IrD MAIL
RETURN RIi CEIPT lZUQUE, S'I'L''D
Division of Air Quality
fL`5 Jaituary 20MUP
Mr. Charles Andrews, Owner / Registered Agent
The'rara Group of Lumberton, Inc.
2700 NC Highway 72 West
[,unlberton, NC 28360
William G. Ross, Jr., Secretary
B. Keith Overcash, RE., Director
SC1.13JI�it:T: Noticc etf'�1ic�1,�YJ%c�ri.(l�Totic [rf�Rectiru-rr�enclatiorr ar i� 1fforc'�-`•etne r: � r�en 13�ru;n ► g
1. ie Tara Group of Lunlbe)ton, Inc.
Lumberton, .NC, Robeson County 6/72-00000
l)earMr. Andrews:
�Ct7r1�1�] '�u7�J 1"ia'i 200 i� Joyner, of this Office, investigated a complaint lodged against you, by
the NC Division of Waste Management (NCDWM), for open burning of creosol poles, constniction
debris, and o1ber it)du8.trial waste on your business property at 2700 NC Efighway 72 West near
Liiniberton, Robeson County, NC. Mr. Andrew 1Iammouds ofthe NCDWM accompanied Mr. Joyner on
this investigation. NC 11:acardous Waste Section had earlier investigated this complaint 10 January 200S.
Upon arrival, Mr. Joyner observed an open burning pile of iaterials that: included wooden poles, a green
powdery substance, plywood, wooden boards, nails, inetallie banding, metallic filter, tree stunnps, metal
parts, saw blades, metallic drurn lids, and painted lumber. Mr. Joyner also observed evidence of previous
burning on the property. Mr. Joyner spoke with you by phone with your father, Mr. Randall Andrews,
owner of Buie Land Company and Industrial and Agricultural Chemicals. He stated he owned! the
property where the observed materials were burned, but your company rented this property aiA you had
coordinated this burning with the local fire department.
On l I January 2008, Mr. Joyner was told at the front office of your facility that you were out of
town at tl:ic Lime. On 14 January 2008, Mr. Joyner and I spoke with you by phone and you stated that
your company had recently allowed the Raft Swaulp lire Department: to burn the observed pile of
materials for a fire training exercise on this property that you were renting. You stated that your father,
Randall Andrews, dumped much of this material from his other businesses and you were not able to
provide detailed information for what you allowed the fire department to burin. You also stated thatt the
fire department had previously burned at the site. Mr. Joyner had left a copy of the NC Open Burning
regulations for you at your facility and during the conversation, I explained to you front therm why this
burn was not allowed. '1 his burn is considered a waste disposal bill-ii. Also be advised that burning a pile
of dernolished illaterials is not allowed for fire training, This letter is to officially inform you that to
hermit,_allow, or cause such open burning is a. violation of North Carolina Adininistrative Code 1.5A 2D
.1900, "Open Burning." Please review the enclosed brochure and insert expl.ainirig, this regulation before
eOndllotiilg any fntlire opei) btli'liing, If you have any questions, please call. this Office at [phone].
Fayelleville Regional Office - Division of Air Quality. UJ1C
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043 NorthCarolina
Main Phone: [phone] DAQ Fax: [phone] Internet: http://www.ncair.org
An Equal Opportunity/Atfirrnalive Action Employer — 60% Recycled/10% Post Consumer Paper Natffrallff

NOWNRE --The Tara Sup of l_,urnberton, Inc.
25 January 2008
Page 2
:quested to find a legal method for the disposal of these wastes. Additional information
concerning solid Waste disposal can be obtained frorn a Division of 'Waste M. magcmcnt Specialist at
[phone]. In addition, please refer to the enclosed Pollution Prevention/Small Business insert for
further information if you need assistance.
In some cases, people have obtained burn permits from the NC forest Service and have then
conducted open bUrnings in violation of other state and local laws. Please note that in almost all cases on
the back of the NC forest Service permit are the NC Air Quality regulations and that [their burn permit.
indicates you must abide by our rules as well as theirs, .Please also realize that various counties,
townships, and/or fire departments have [.heir own regulations in addition to the various State burning
regulations. Prior to buriiin,g, yclti are_rec irec� to coilsider.afl these regulations and tomake certain you
arc xlreelin-g t:-be most rests ictrve regttlati.ott(s).
As stated ]hl the "subject" above, this letter represents not only a Notice of Violation for tale opera
burning investigated on 11 January 2008, but puts you on notice that: this office is preparing an
enforcement report addressing the violation observed. The above violation and any future violation of an
air quality regulation are subject to the assessment of civil penalties as per North Carolina General Statute
1.43-21.5.1.14A.. Tllis General Statute provides that civil penalties of not more than twenty five thousand
dollars ($25,000) may be assessed against any person who violates any classification, standard, 01.
limitation established pursuant to General Statute 143-21.5.107, "Air Quality Standards and
Classifications." lip addition, each. day of continuing violation after written notification from the Division
of Air Quality shall be considered a separate offense.
Please submit a wifften response to this office by S February 2008, as to actions taken to bring
about compliance and any additional information or description of ariy mitigating circumstances that you
believe should affect the outcome of the enforcement evaluation. Please provide air exact list of
materials, and an approximate quantity, tbat you placed in this area. .Include the som-ce for each
of the materials. After the above date, in lieu of any mitigating circumstances brought to our attention,
this office will submit the enforcement report to the l_)irector of the Division of Air Quality, including
recomr-xiendat:ions for the assessment of appropriate civil penalties. Please be advised that neither this
letter, nor any subsequent action, absolve you from responsibility for any violation or damage to public or
private property or from any enforcement action available to this agency.
We appreciate your immediate attention to this errvirom ental concert]. if you have any
questions, please call Neil Joyner, Envtroumetltal Specialist, 01• Robert HTiydeth, i3nviromxrental Engineer,
at [phone].
Sixi�erely,
r`
.•-S even I�. VozzO �:J
Regiorra.l Air Quality Supervisor
Fayetteville Regional Office
SF V\caj
atmchments - OB Brochure, OB Insert, and P2 Insert
cc: (w/o attachment)
'FRO Enforcement Files
FRO Complaint Files
Mr. Andrew 13anmronds, NCDWM SW FRO
Mr. Bobby Nelms, NCDWM Hazardous Waste
Donnie Blackburn, President, Raft Swamp Voluriteer Fire Department

m Complete Items 1; 2, and 3. Also Complete a
Item 4 if Restricted,U] Iivrery is desired; X
is Print your name and address on the reverse
so that.we can return the card to you. FD.
® Attach this card to the back of the malipiece,
or on the front if space permits.
-
1. Article Addressed to:
MR CHART ES AN.DREWS
THE TARA GROUP Or LUMBE
Agent
Rec Ived by (Pd tee e e C. Date of Delivery
Is delivery address different from item 1? Oyes
If YES, -.enter delivery address below: D No
2700 NC HWY 72 WEST a. Service Type
LUMBERTON NC 28360 ►� Certified Mail ❑ Express Mall
Registered ❑ Returri Receipt for Merchandise
Cl insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
z. ArttoieNumber �. 7001 2510. 0000 6682 6556
(Transfer from service label)
PS Form'3811. February 2004. ; Domestic Return Receipt
102595-02-M•1540

�aj � .
NC®ENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor Division of Air Quality Williarn G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
25 January 2008
CT;RTI1liILD MAIL
.tzie,TURN RTCTIPT Rrww sTE])
Mr. Randall Andrews, Owner and Registered Agent
Buie Land Cornlfariy, Inc.
2700 NC 1-Iighway 72 West
Lumberton, North Carolina 28360
StJ.RI ,CI': Notice of Violation/Notice of Recorntnendlition for E nforcement: Open Burning
- Buic Land Company, Luc.
- Industrial & .A.gricultu.ral Chemicals, Inc.
Lumberton, NC, Robeson County 6/72-00000
Dear Mr. Andrews,
On 11 January 2008, Neil Joyner, of this Office, investigated a complaint lodged against you, by
the NC Division of Waste Management (NCDWM:), for open burning of creosol poles, construction
debris, and other industrial waste on your business property at 2700 NC highway 72 West near
Lumberton, Robeson Cotinf:y, N'C. Mr. Andrew T.-Iamrnonds of the NC*D WM' accorupanied :Mr. Joyner on
this investigation. NC Hazardous Waste Section 11ad earlier investigated this complaint 1.0 January 2008.
Upon arrival, Mr. Joyner observed an open burning bile of materials that included wooden poles, a green
powdery substance, plywood., wooden boards, nails, metallic banding, metallic filter, tree stumps, metal
parts, saw blades, metallic drum lids, 1,ud painted lumber, Mr. Joyner also observed evidence of previous
burning on the property. Mr. Joyner spoke with you by phone and you stated that your company, Buie
Land C:oinpaily, owned the property where the observed materials were burned. You stated that you
understood that the fire dept. had recently burned the observed materials as a training exercise on the
property. You stated that your son, Charles Andrews, was coordinating this burning with the 1::u•e
department. Mr. Joyner left a copy of the Open Burning regulations for you at the facility office and
during the conversation, he explained front then] why this burn was not allowed.
On 14 January 2008, 1 spoke by phone with your son, Mr. Charles Andrews, of The Tara Group
of Lumberton, Inc. and he stated that his company was renting this land from you. l:le stated that his
company had recently allowed the Raft Swarnp fire Department to burn the observed pile of materials as
a fire training exercise on the property. He also stated that the fire department had burned at the site
previously. Additionally, he stated that he did not know exactly all the waste materials you had brought
to this pile front your other business, Industrial & Agricultural Chemicals, Inc. Be advised that burning a
pile of demolished materials is not allowed tb.r fire training and is considered to be waste disposal.
This letter is to officially inform you that to permit,-_ al.lgw, or_,cause such open burning is a
violation of North Carolina Administrative Code 15A 2D .1900" "Open Burning." Please review the
Fayetteville Regional Office -- Division of Air Quality A 1.V TOne.
225 Green Street, Suite 714, Fayetteville, North Carolina 28301.5043 OBI thCarollila
Main Phone: [phone] DAQ Fax: [phone] Internet: hllp:l/vaww.ocair.org
An Equal OpportunilylAffintrative Action Employer — 50% Recycled110% Post Consumer Paper l L dy

NOV/NR]," - .ti _lie Land Company, Isle.
25 January 2008
Page 2
enclosed brochure and insert explaining this regulation before conducting any future open burning. If you
have any questions, please call this Office at [phone]. You are requested to find a legal method
for the disposal of these wastes. Additional information. concerning solid waste disposal can be obtained
from a Division of Waste Management Specialist at [phone]. In addition, please refer to the
enclosed POI lutio:rl Prevention/SIlia 11 Business insert for further irlfornla.tion if you need assistance. .
In some cases, people have obtained Burn Permits from the NC forest Service and have then
conducted open turnings in violation of other state and local laws. Please ].tote that in almost all eases oil
the back of the NC: Forest Service permit are the NC Air Quality regulations and that their burn permit
indicates you Must abide by our rules as well as theirs. Please also realize that various counties,
townships, and/or fire departments have their own regulations in addition to the various State burning
regulations. Prig to burniiqg_y_qt� ai_e required.to consider a-11 these re nilations and to make certain von
are meeting the most restrictive re ulation_(s),
As stated in the "subject" above, this letter represents not only a Notice of Violation for the open
burgling investigated on l I. January 2008, but puts you on. notice that this office is preparing an
enforcement report addressing the violation observed. The above violation and any future violation of all
air quality regulation ace subject to the assessment of civil penalties as per North Carolina General Statute
143-215.114A. This General Statute provides that civil penalties of not more than twenty five thousand
dollars ($25,000) may be assessed against any personwho violates any classification, standard, or
limitation established pursuant to General Statute 1.43-215.107, "Air Quality Standards and
Classifications." In addition, each day of continuing violation after written notification from the Division
of Air Quality shall be considered a separate offense.
Please submit a written response to this office by A Februat y 2008, as to actions taken to bring
about compliance and any additioual information or description Of any mitigating circumstances that you
believe should affect the outcome of the enforcement evaluation. Please provide all exact list of
materials, and all approximate quantity, that you placed in this area. Include the source for each
of the materials. After the above date, in lieu of any mitigating circumstances brought to our attention,
this office will submit the enforcement report to the Director of the Division of Air Quality, including
recommendations for the assessment of appropriate civil penalties. Please be advised that neither this
letter, not any subsequent action, absolve you from .responsibility for any violation or damage to public or
private property or from any enfbr-eenlent il.etlOn available to this agency.
We appreciate your inimodiate attention to this environmental concern. Tf you have any
questions, please call 'Neil JOyncr, Environmental. Specialist, or Robert. Iiayden, Envil'onnlcntal I n.gineer,
at: [phone].
SfeVe.l1I. VO'7,70��
Regional Air Quality Supervisor -
Fayetteville Regional Office
STN\caj
attaclunelrts 013 Brochure, Ol3 Insert, aad P2 lnsel't
cc: FRO Corn.plaint files
Mr. Andrew Hagumonds, NCDWM SW PRO
Mr. Bobby Nelms, NCDWM 1-lazardons Waste

p Complete items 1; 2, and 3..Also complete
item 4 if. Restricted Dellvery is desired.
M Print your name: and address on the reverse
so that we can return the oard,to you.
IN Attach this"card to the ¢ack of the mallpieco,
or on the front if space permits.
1. AtticleAddressed to "
MR R.ANDALL ANDREWS
BUIE 1;,AND COMPANY 1NC ; •
A.
X ❑ Agent
U Cl Addressee
Q. ece�ed by ( Printed Name} C. Date of Delive
�> � L GJ--L l�-g�-
D. is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: 0 No
2700 NC-FIWY 72 WL)`I 3. Service Type
LUMBERTON NC 28360 Certified Mail o express Mail
Registered 0 Retum Receipt for Merchandise
© Insured Mall 0 C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number 7001 2510 0000 6682 6549
(rTrnsfer /role service label} __..
PS Form 3811, February 2004 Domestic Return Receipt 102595.02•M.1540
I

Ash
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
Division of Waste Management
Dexter R. Matthews, Director
January 16, 2008
CERTIFIED MAIL
Return Receipt Requested
70012510 0006 9499 5211
Randall Andrews, President
Buie Land Company, Inc.
2700 NC Hwy 72 West
Lumberton, North Carolina 28360
William G. Ross Jr., Secretary
Subject: Notice of Violation
Robeson County, North Carolina
IS780801
Non -Facility
Dear Mr. Andrews:
Pursuant to North Carolina General Statue's 130A-22(a) and to 15A North Carolina Administrative
Code 13B, you are hereby informed that you are operating a non -conforming solid waste disposal site/open
dump on your property located on Melvin Lane in Lumberton, Robeson County, North Carolina.
On January 11, 2008, Neil Joyner with the Division of Air Quality and I inspeeted a rion-eonforiiiing
solid waste disposal site on your property located behind Tara Groups office at 2700 NC Hwy 72, Lumberton
in Robeson County, North Carolina PIN 937360821900. The inspection revealed an area of open burning that
was still smoldering with mixed waste streams. Adjacent to this area was a load of construction waste
consisting of plastic pipes, metal, plywood, concrete and other types of waste. There were several piles of
waste that consisted of concrete with rebar, asphalt, concrete mixed with metal and soil and two large piles of
charred debris and soil. Also noted at this time were 7-10 loads of bottom ash as described by you that you are
planning to experiment with in various applications? The open dumping of solid waste on your property
constitutes a violation of the North Carolina Solid Waste Management Rules, codified at 15A NC
Administrative Code 13B; specifically:
15A N.C. Administrative Code 13B .0201(a) states that "no person shall establish, or allow to be
established on his land a solid waste management facility, or otherwise treat, store, or dispose of solid
waste unless a permit for this facility has been obtained from the Division of Waste Management."
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043 One
Phone: [phone] FAX: [phone] Internet: http://wastenot.enr.state.nc.us NNatzmalloff
oftthCarohna
An Equal Opportunity / Affirmative Action Employer- 50 % Recycled 110 % Post Consumer Paper

.r ua -j i. v, --
You are in violation of section 13B .0201(a) in that a solid waste management facility has been established on
your land without a permit from the Division of Waste Management.
Based on the foregoing, discontinue all dumping operations on your property and within 15 days
of receipt of this notice comply with 15A NCAC 13B .0502 Open Dumps by taking the following actions.
1. Remove and properly dispose of all of the waste that is on your property.
2. Remove and properly dispose of the coal ash that has been dumped on the property.
3. Ensure that all waste is removed from the site and transported to a facility permitted to
accept the waste.
4. Do not burn or bury any of the waste. In addition, documentation that will indicate
the waste has been properly disposed of will be required to resolve this Notice of
Violation. Please mail receipts to the North Carolina Department of Environment and
Natural Resources, Division of Waste Management, Drew Hammonds, 225 Green
Street, Suite 714, Fayetteville, NC 28301.
Pursuant to N.C.G.S. 130A 22(a) and 15A N.C.A.C. 13B .0701 -.0707, an administrative penalty
of up to $15,000.00 per day may be assessed for each violation of the Solid Waste Management Laws and
Regulations.
We solicit your cooperation and would like to avoid taking further additional enforcement actions.
At the same time, it is your responsibility to comply with the requirements of the North Carolina
Administrative Code. If you have any questions regarding this matter, please feel free to contact me at
(910)-433-3351.
Sincerely,
Drew Hammonds
Environmental Senior Specialist
Solid Waste Section
Regional Representative
Cc: Mark Poindexter, Field Operations Branch Head
Dennis Shackelford, Eastern Area Supervisor
Amy Kadrie, Compliance Officer
Neil Joyner, Division of Air Quality
Steve Edge, Robeson County Solid Waste Director

00
C rf�T
NC DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WASTE MANAGEMENT
ACTIVITY REPORT
Date: 10 January 2008 Report By: Bobby Nelms No: 036
Subject: Randall Andrews Property
Location: 2700 NC Highway 72 West
City: Lumberton, NC Zip: 28360 County: Robeson
Contact Person: Randall Andrews Tel#: [phone]
Reason for visit: Complaint Investigation
REPORT:
On this date, I visited the referenced site to investigate a compliant referred to me by
SWS personnel in the Fayetteville Regional Office. The complaint alleged that waste
material had been illegally dumped on property behind the TARA Group facility located
at the. address above.
Upon arrival at the site, I spoke to Ms. Denis Andrews who gave me permission to walk
over the property. I found two distinct areas of concern and began to photograph these
areas when Mr. Randall Andrews, owner, arrived. Mr. Andrews and I had met before so
my introduction was merely a formality. I explained my reason for being there, and
asked him to show me around.
Mr. Andrews showed me an area which he had used to dump caustic soda sludge from
tank bottoms and Gypsum. He explained that he intended to mix the material and use it
as a fertilizer on his property. He stated that the material was not liquid when it was
dumped on the site and the appearance of the site seemed to indicate the accuracy of his
claim.
A separate area, and likely the area of most concern, was a bum pile located further back
from the office building. This area had been used to bum debris, including creosote
poles, for the purpose of allowing the local fire department an opportunity to practice
extinguishing large fires. There were areas of green ash which concerned me since there
was the possibility of CCA treated poles having been burned. If there were, in fact
treated poles there, they had been completely consumed in the fire.
I discussed the areas and my concerns with Mr. Andrews who was very compliant and
willing to take care of whatever needed to be done in order to resolve the issues. I
explained the he would be receiving an Immediate Action NOV from the Section at a
later date and that he would need to comply with the requirements spelled out within the

explained my duty and intention to report the matter to the DAQ and to the
adrews understood and thanked me for my time.
An IANOV will follow this report and a follow up visit will be conducted at a later date.
Activity type: Complaint

NO V
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
B. Keith Overcash, P.E,, Director
WawbI 2.001-4
CERT.II' IED MAIL
RETURN RECEIPT REQUESTED
Randall Andrews, President
Industrial & Agricultural Chemicals, Inc.
2042 Buie Phil Road
Red Springs, NC 28377
SUBJECT: Notice of Violation 4 ; leForti°lm
Industrial & Agricultural Chemicals, Inc. Permit No. 06125R09
Red Springs, North Carolina, Robeson County 06/78-00168
Dear Mr. Andrews:
Your current air permit, identified above, includes at least I (one) stipulation requiring that a report
be sent to this Office, no later than 30 January 2005. Your facility failed to comply with this requirement. If
you have not already e so, EJease provide tlxis Office with the retort s within 10 (ten) days of receipt of
this letter. Once the report(s) are received in our Office, a compliance determination, based upon the conie.int
of the reports) shall be made If it is determined during this review that your facility is/was not oaerating in
compliance an additional Notice of Violation or, depending on the type of violation and severity, a Notice of
Violation/Notice of Recommendation for Enforcement shall be issued to your facility.
As stated in the "subject" above, this letter represents a Notice of Violation for failure to submit a
required report by the deadline specified in your air permit. This General Statute provides that civil penalties
of not more than ten thousand ($10,000) may be assessed against any person who violates any classification,
standard, or limitation established pursuant to General Statute 143-215.107, Air Quality Standards and
Classifications.
The Division strongly recommends that you carefully examine your current permit stipulations and
request explanation fiom this Office as necessary. If you have any questions regarding this matter, please call
Mitchell Revels, Environmental Chemist, at.[phone].
Sincerely,
4
Steven. F. Vozzo
Regional Air Quality Supervisor
cc: DAQ Central Files
FRO County Files
Fayetteville Regional Office -Division of Air Quality 19;�r
225 Green Street Suite 714, Fayetteville, Norlh Carolina 28301.5043Phone: [phone] Fax: [phone] Internet: httpl/www,rrair.org
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

0
®.Complete items 1, 2, and 3. Also complete
item 4 if Restricted delivery is desired.
M Print your name and address on the reverse
s4 that we can return the card to you.
ev Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
.eceived by (Please Print Clearly) B, Date of Delivery
C.`S' tur�`.
❑ Agent
- UILIP 'e U-0-Addressee
D. Is delivery addross afferent from item 1? ❑ Y@s
If YES, enter delivery address below: ❑ No
MR RANDALL ANDRIsWS
TNDUSTRJAL & AGRICULTURAL
2042 BUIR PHIL ROAD 3. service Type
RED SPRINGS NC 28377 Certified Mail ❑ Express Mail
❑ Registered 0 Return Receipt for Merchandise ;
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. Article Number 7001 2510 Q003 8090 23S6
(Transfer from service tabor) -----•----- — --~- -"
PS Form 3811, March 2001 Domestic Return Receipt 102695-o1-M•1424
i

25 January 2008
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Charles Andrews, Owner / Registered Agent
The Tara Group of Lumberton, Inc.
2700 NC Highway 72 West
Lumberton, NC 28360
SUBJECT: Notice of Violation/Notice of Recommendation for Enforcement: Open Burning
The Tara Group of Lumberton, Inc.
Lumberton, NC, Robeson County 6/72-00000
Dear Mr. Andrews:
On 11 January 2008, Neil Joyner, of this Office, investigated a complaint lodged against you, by
the NC Division of Waste Management (NCDWM), for open burning of creosol poles, construction
debris, and other industrial waste on your business property at 2700 NC Highway 72 West near
Lumberton, Robeson County, NC. Mr. Andrew Hammonds of the NCDWM accompanied Mr. Joyner on
this investigation. NC Hazardous Waste Section had earlier investigated this complaint 10 January 2008.
Upon arrival, Mr. Joyner observed an open burning pile of materials that included wooden poles, a green
powdery substance, plywood, wooden boards, nails, metallic banding, metallic filter, tree stumps, metal
parts, saw blades, metallic drum lids, and painted lumber. Mr. Joyner also observed evidence of previous
burning on the property. Mr. Joyner spoke with you by phone with your father, Mr. Randall Andrews,
owner of Buie Land Company and Industrial and Agricultural Chemicals. He stated he owned the
property where the observed materials were burned, but your company rented this property and you had
coordinated this burning with the local fire department.
On 11 January 2008, Mr. Joyner was told at the front office of your facility that you were out of
town at the time. On 14 January 2008, Mr. Joyner and I spoke with you by phone and you stated that
your company had recently allowed the Raft Swamp Fire Department to burn the observed pile of
materials for a fire training exercise on this property that you were renting. You stated that your father,
Randall Andrews, dumped much of this material from his other businesses and you were not able to
provide detailed information for what you allowed the fire department to burn. You also stated that the
fire department had previously burned at the site. Mr. Joyner had left a copy of the NC Open Burning
regulations for you at your facility and during the conversation, I explained to you from them why this
burn was not allowed. This burn is considered a waste disposal burn. Also be advised that burning a pile
of demolished materials is not allowed for fire training. This letter is to officially inform you that to
permit, allow, or cause such open burning is a violation of North Carolina Administrative Code 15A 2D
.1900, "Open Burning." Please review the enclosed brochure and insert explaining this regulation before
conducting any future open burning. If you have any questions, please call this Office at [phone].

NOV/NRE — The Tara Group of Lumberton, Inc.
25 January 2008
Page 2
re requested to find a legal method for the disposal of these wastes. Additional information
concerning solid waste disposal can be obtained from a Divism ion of Waste Manageent Specialist at
[phone]. In addition, please refer to the enclosed Pollution Prevention/Small Business insert for
further information if you need assistance.
In some cases, people have obtained burn permits from the NC Forest Service and have then
conducted open bumings in violation of other state and local laws. Please note that in almost all cases on
the back of the NC Forest Service permit are the NC Air Quality regulations and that their burn permit
indicates you must abide by our rules as well as theirs. Please also realize that various counties,
townships, and/or fire departments have their own regulations in addition to the various State burning
regulations. Prior to burning, you are required to consider all these regulations and to make certain you
are meeting the most restrictive re lgu ation(s).
As stated in the "subject" above, this letter represents not only a Notice of Violation for the open
burning investigated on 11 January 2008, but puts you on notice that this office is preparing an
enforcement report addressing the violation observed. The above violation and any future violation of an
air quality regulation are subject to the assessment of civil penalties as per North Carolina General Statute
143-215.114A. This General Statute provides that civil penalties of not more than twenty five thousand
dollars ($25,000) may be assessed against any person who violates any classification, standard, or
limitation established pursuant to General Statute 143-215.107, "Air Quality Standards and
Classifications." In addition, each day of continuing violation after written notification from the Division
of Air Quality shall be considered a separate offense.
Please submit a written response to this office by 8 February 2008, as to actions taken to bring
about compliance and any additional information or description of any mitigating circumstances that you
believe should affect the outcome of the enforcement evaluation. Please provide an exact list of
materials, and an approximate quantity, that you placed in this area. Include the source for each
of the materials. After the above date, in lieu of any mitigating circumstances brought to our attention,
this office will submit the enforcement report to the Director of the Division of Air Quality, including
recommendations for the assessment of appropriate civil penalties. Please be advised that neither this
letter, nor any subsequent action, absolve you from responsibility for any violation or damage to public or
private property or from any enforcement action available to this agency.
We appreciate your immediate attention to this environmental concern. If you have any
questions, please call Neil Joyner, Environmental Specialist, or Robert Hayden, Environmental Engineer,
at [phone].
Sincerely,
Steven F. Vozzo
Regional Air Quality Supervisor
Fayetteville Regional Office
SFV\caj
attachments - OB Brochure, OB Insert, and P2 Insert
cc: (w/o attachment)
FRO Enforcement Files
FRO Complaint Files
Mr. Andrew Hammonds, NCDWM SW FRO
Mr. Bobby Nelms, NCDWM Hazardous Waste
Donnie Blackburn, President, Raft Swamp Volunteer Fire Department

Pagel of 3
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FindLaw> State Resources> North Carolina> Primary Materials> North Carolina Court Opinions
An unpublished opinion of the North Carolina Court of Appeals does not constitute controlling legal authority. Citation is
disfavored, but may be permitted in accordance with the provisions of Rule 30(e)(3) of the North Carolina Rules of
Appellate Procedure.
NO. COA06-1458
NORTH CAROLINA COURT OF APPEALS
Filed: 19 June 2007
ALCHEM, INC.,
RANDALL ANDREWS,
Petitioner,
v . Wake County
No. 05 CVS 012073
N.C. DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES, DIVISION
OF WATER QUALITY,
Respondent.
Appeal by petitioner Alchem, Inc., from order entered 22 June 2006 by Judge A. Leon Stanback, Jr., in Wake County
Superior Court. Heard in the Court of Appeals 10 May 2007.
The Yarborough Law Firm, P.A., by H. Addison Winters, for Alchem, Inc., petitioner appellant.
Attorney General Roy Cooper, by Assistant Attorney General Stormie D. Forte, for the State.
McCULLOUGH, Judge.
On 28 December 2004 the Division of Water Quality of the North Carolina Department of Environment and Natural
Resources ("NCDENR- DWQ") issued a water quality permit to Alchem, Incorporated ("petitioner"). NCDENR-DWQ sent
a letter along with the permit notifying petitioner of its right to object to any terms or conditions set forth in the permit by
requesting an adjudicatory hearing through filing a written petition in the Office of Administrative Hearings ("OAH") within
30 days following receipt of the permit. Petitioner received the permit on 18 January 2005. On10 February 2005, petitioner
wrote a letter to NCDENR-DWQ requesting an extension of 90 days to examine and respond to the permit. Subsequently,
on 8 March 2005 petitioner wrote a letter to NCDENR-DWQ stating certain objections and questions with regard to the
permit.
Petitioner thereafter submitted a written letter to OAH stating its intention to appeal the conditions set forth in the permit
on 29 April 2005 and on 4 May 2005 OAH issued a notice of contested case and assigned the case to an administrative law
judge ("ALJ"). NCDENR-DWQ filed a motion to dismiss on 25 May 2005. On 29 July 2005, the ALJ issued a final
decision granting NCDENR-DWQ's motion to dismiss where OAH lacked subject matter jurisdiction over the proceedings.
On 29 August 2005, petitioner filed a petition for judicial review in Wake County Superior Court for review of the ALJ's
order dismissing petitioner's case. NCDENR-DWQ filed a motion to dismiss the petition for judicial review under N.C. Gen.
Stat. § lA-1, Rule 41(b) for failure to comply with the rules requiring a petition for a contested case hearing to be filed
within 30 days from notification to the permittee of the Commission's decision. On 22 June 2006, the court entered an order
dismissing the petition for judicial review. From this order petitioner appeals.
On appeal petitioner contends the lower court erred in failing to reverse or remand the case to OAH for failure to enter
findings of fact and conclusions of law, failing to state its standard of review and making additional findings of fact, failing
to makecertain findings of fact and conclusions of law, concluding that petitioner failed to allege wrongdoing pursuant to
N.C. Gen. Stat. § 150B-23 and dismissing the petition for judicial review based on incomplete findings of fact. It appears
that petitioner has confused the actual issues in the instant case. (See footnote 1)
http://caselaw.1p.findlaw. com/scripts/getcase.pl?court=nc&vol=appeals2007/&invo1=0614... 12/9/2008

and Codes
Page 2 of 3
'An order of the ALJ issued pursuant to a written pre -hearing motion granting a party's requested relief for failure of the
other party to comply with procedural requirements is a final decision under N.C. Gen. Stat. § 15013-36(c)(3) [(2005)]" and
a petitioner is entitled to immediate judicial review under N.C. Gen. Stat. § 150B-43. Lincoln Cty. DSS v. Hovis, 150 N.C.
App. 697, 700, 564 S.E.2d 619, 621 (2002); N.C. Gen. Stat. § 150B-43 (2005).
N.C. Gen. Stat. § 150B-36(c)(3) grants an ALJ the authority to allow a parry's requested relief upon a pre -hearing motion.
An order entered by an ALJ pursuant to a written pre -hearing motion that either dismisses the contested case for failure of
the petitioner to prosecute or grants the relief requested when a party does not comply with procedural requirements is
directly appealable to the superior court. N.C. Gen. Stat. § 150B-36(c)(3)(2005). This Court has stated that, even though
"the superior court's scope of review regarding an ALJ's final decision issued pursuant to section 1 50B-3 6(c) does not fall
precisely within the plain language of any provision in N.C. Gen. Stat. § 150B-51," the standard of review is that stated in
N.C. Gen. Stat. § 15013-51(b). Lincoln v. N.C. Dept of Health & Human Servs., 172 N.C. App. 567, 571, 616 S.E.2d 622,
625 (2005); see also Hovis, 150 N.C. App. at 701, 564 S.E.2d at 621-22. Therefore, the superior court reviews decisions
rendered under N.C. Gen. Stat. § 150B-36(c) to determine "whether the decision of an ALJ contains errors of law, is
supported by substantial evidence, and is neither arbitrary nor capricious." Hovis, 150 N.C. App. at 701, 564 S.E.2d at 625.
Under this review and analysis, this Court must make a factual inquiry under the whole record test and a legal inquiry under
the de novo standard in order to determine whether the superior court erred.
However, in the instant case, such review is not applicable nor dispositive where the superior court dismissed the petition
for judicial review instead of granting appellate review of the ALJ's decision and applying the standards set forth in N.C.
Gen. Stat. § 15013-51(b).
The administrative code provides that the Rules of Civil Procedure "'shall apply"' to contested cases. Lincoln, 172 N.C.
App. at 572, 616 S.E.2d at 626; N.C. Admin. Code tit. 26, r.3.0101(a) (June 2006). Under the Rules of Civil Procedure, Rule
41(b) allows a court to dismiss an action "[f]or failure of the plaintiff to prosecute or to comply with these rules or any order
of court[.]" N.C. Gen. Stat. § IA-1, Rule 41(b). The North Carolina General Statutes set forth the proper procedure by
which a permittee may object or challenge a permit issued by an administrative agency.
A permit applicant or permittee who is dissatisfied with a decision of the Commission may commence a contested case
by filing a petition under G.S. 150B-23 within 30 days after the Commission notifies the applicant or permittee of its
decision. If the permit applicant or permittee does not file a petition within the required time, the Commission's decision is
final and is not subject to review.
N.C. Gen. Stat. § 143-215.1(e)(2005) (emphasis added).
"The time limitation, whether established by another statute, federal statute, or federal regulation, or this section, shall
commence when notice is given of the agency decision to all persons aggrieved who are known to the agency[.]" N.C. Gen.
Stat. § 15013- 23(f) (2005). The requirements set forth under the administrative code are mandatory, and a petition shall be
dismissed for lack of subject matter jurisdiction where a petitioner failed to comply with the standards set forth in order to
obtain judicial review. See Lewis v. N.C. Dept of Human Resources, 92 N.C. App. 737, 739, 375 S.E.2d 712, 714 (1989)
("The right to appeal to an administrative agency is granted by statute, and compliance with statutory provisions is necessary
to sustain the appeal.").
In the instant case, the lower court made findings and the record supports that petitioner received notice of the permit and
its contents on 18 January 2005, and that on 2 May 2005, petitioner filed a petition for a contested case hearing with OAH.
This iswell outside of the 30-day limitation placed on filing a petition for a contested case set by the statute. Therefore the
lower court properly dismissed the petition for judicial review under N.C. Gen. Stat. § IA-1, Rule 41(b) where the OAH
lacked subject matter jurisdiction to hear the petition based on the untimely filing and petitioner is not entitled to review. See
N.C. Gen. Stat. § 143- 215.1(e). Further, a review of the order and record on appeal reveals that the findings of fact and
conclusions of law set forth in the lower court's order address all matters before the court and any contention that such
findings or conclusions are incomplete is wholly without merit.
Moreover, the court concluded as a matter of law that OAH lacked subject matter jurisdiction over the petition for a
contested case hearing. Conclusions of law are reviewed by an appellate court under a de novo standard. See Starco, Inc. v.
AMG Bonding & Ins. Services, 124 N.C. App. 332, 336, 477 S.E.2d 211, 215 (1996). As stated supra, it is clear from the
record that the petitioner failed to file the petition for a contested case hearing within the statutory required deadline of 30
days; and where such statutory rules are mandatory, OAH was deprived of jurisdiction.
Petitioner's assignments of error are overruled.
Accordingly, the order of the lower court dismissing the petition for judicial review is affirmed.
Affirmed.
Judges BRYANT and STROUD concur.
Report per Rule 30(e).
Footnote: I
Petitioner cites numerous cases regarding the superior court's role as an appellate court under the administrative code in
which there was a final decision issued by an ALJ, an agency decision and then judicial review of the prior proceedings by
the superior court. In the instant case, the ALJ issued a final order dismissing the case and allowing for immediate appeal to
the superior court. Therefore, the procedural requirements stand in stark contrast to those cited by petitioner.
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PWCarolina
partment of Environment and Natural Resources
Michael F. Easley, Governor.
William G. Ross Jr., Secretary.
James D. Simons, P.G.; P.E.
Ditector and State Geologist
NOTICE OF DEFICIENCY
,N.or� enr�b cr2 5�0 $
CERTIFIED MAIL
RETURN RECEIPT 12EQ11JES'1ED
7001 2510 0000 6682 0486
Buie Land Company, Inc.
Attn: Randall Andrews
2042 Buie-Philadelphus Road
Red Springs, NC 28377-
Dear Randall or Charlie Andrews:
ur
N1
Division 'of Land Resources
RE• > otice if�=leiciency;rl aaMlitre
Permit Number: 78-29
Robeson County, North Carolina
River Basin: LUMBER
On 11/24/2008, an inspection of the subject mine was performed by&Wb
+Matuszew ki;�Sally McKinney, and Lvangelyli Lowery -Jacobs of this office.
Deficiencies were observed that require your prompt. attention..
The deficiencyies discovered and,the necessary corrective actions are as follows:
1. 005 — All mining boundaries (6..12 acres) shall be permanently marked at the
site on 100. foot intervals unless the line of sight allows f6r.larger. spacing
intervals.
Mining boundary markers were not visible at the tune of the inspection.
2. OC4.13: All drainage from the. affected area around the mine excavation shall
be, diverted internal to said excavation. .
The mine pit drains. into an open -ditch and is. discharged into an off -site body
of water: .
Land Quality Section [phone] Fax [phone]
225 Green Street, Suite 1141 Systel riuilding, Fayetteville, North Carolina 28301-5043
AN EQUAL OPPOI2'l't)Nl'I'Y \ AFFIRMATIVE ACTION EMPLOYER— 50% RECYCLED / I t1% POST CONSUMER PAPER

C8:.Berrns shall be constructed or vegetation in the form of evergreens
,I I- red tips shall be planted along the entire property line that parallels NC
Hwy 72 around. the property line that parallels the existing soil access road for
a minimum of 250 feet. Said berms shall be a minimum of six feet in height
with sideslopes that maintain adequate vegetation. Said trees shall be planted
on six foot staggered spacings and shall be a minimum height of four feet.
The berm does not extend along the entire propert line that parallels NC Ilwy
72 or the property line that parallels the existing soil access road.
4. OC10A -- No on -site disposal of refuse or other solid waste that is generated
outside of the mining permit area shall be allowed within the boundaries of
the mining permit area unless authorization to conduct saiddispmdl has first
been obtained from both the Division of Solid Waste and the Cand Qualify
Section, Department of Envirotunent and Natural Resources. The methodof
disposal shall be consistent with the approved reclamation plan.
Immediately remove solid waste from within. the mine boundaries and dispose
of waste in a disposal facility approved by the Division of Waste
Management.
5. OC1013: Mining refuse as defined by G.S. 74-49 (14) of the Mining Act of
1971 generated on -site and directly associated with the mining activity may be
disposed of in a designated refuse area. All other waste products must be
disposed of in a disposal facility approved by the Division of Waste
Management. No petroleum products, acids, solvent or their storage
containers or any other material that may be considered hazardous shall be
disposed of within the permitted area.
Multiple piles of off site generated waste were observed during the inspection.
The piles varied in their. content (cement blocks, household debris, plastic
bags, plastic gasoline dispensers, an unidentified white granular substance).
These piles are to be removed from within the mine boundaries and disposed
of in facilities approved the Division Waste Management and the Division. of
Hazardous Waste Management.
6. OC12: Mining refuse as defined by G.S. 74-49. (14) of the Mining Act of
1971 generated on' -site and directly associated with the mining activity may be
disposed of in a designated refuse area. All other waste products must be
disposed of in a disposal facility ap
proved .by.the Division of Waste
1vl.anal;eicnerit. No petroleum products, acids, solvent or their storage
containers or any other material that may be considered hazardous shall be
disposed of within the permitted area.

Multiple piles of off --site generated waste were observed during the inspection.
The piles varied in their content (cement blocks, household debris, plastic
bags, plastic gasoline dispensers, 0M� ntif d whtt gr-anus s, bstance;},
These piles are to be removed from within the mine boundaries and disposed
of in facilities approved the Division Waste Management and the Division. of
Hazardous Waste Management.
7. RC2D: No contaminants shall be permanently disposed of at the mine site.
On -site disposal of waste shall be in accordance with Operating Condition
Nos. 10.A. through ll.
The mining site is not in. compliance with Operating Conditions IOA and 1013,
as described in iterns 4 and 5 of this Notice.
If the previously described deficiencies are not corrected. within 30 days following your
receipt of this Notice this matter will be referred to the Director., Division of Land
Resources/Department of Environment and Natural Resources, for issuance of a "Notice of
Violations" in an effort to secure compliance. In addition, failure to correct the deficiencies may
result in the assessment of civil penalties and/or injunctive relief against you.
Do not hesitate to contact .F.,ric Matuszewski or me at [phone] regarding any
questions you may have.
Sincerely,
M. Stephen Cook, C.P.E.S.C.
Regional Engineer
Land Quality Section
MSC1sym
Enclosure: Inspection Report
cc: Floyd Williams, PG, CPG, CPESC
Dennis Shaekleford, FRO Solid Waste Management
Christy Richardson, FRO; Division of Air Quality

North Carolina Department of Environment and Natural Resources,
Division of Land Resources, Land Quality Section
MINE INSPECTION REPORT
(PERMITTED MINE)
1. MINE NAME Tam► _ m:,� 2. MINING PERMIT # '1 0,-Z`(
3. OPERATOR&u�ndooQ Amd_%neu 4. COUNTY __,obs,-�c�,_r R.
5. ADDRESS a a t a [3u 4e P hao'& P hu rn Raagt
6. PERMIT EXPIRATION DATE 7. RIVER BASIN kWA_ .j
8. Person(s) contacted at site -�
9. Was mine operating at time of inspection? ❑ Yes 9No 10. Pidtures? RYes El No
11. Date last inspected: a / I I / 0 12. Any mining since last inspection? •❑ Yes ❑ No
13. Is the mine in compliance with the Operating Conditions of the Permit? ❑ Yes 0( No
If no, explain:
OC.
`1. r t 1 ` IV C.
'/
ehol �-i end whife
14. Is the mine in eompliance with the Re amaI' n Conditions of the Permit? ❑ Yes WNo
If no, explain: aS; r ( oa -# f "J" ;--ka► yCL,;t o rth a q
_
At 02infaga
15. Did any of the above deficiencies result in offsite damage? ❑ Yes X No If yes, describe the
type and severity of the damage:
no Aft-S&C (Unex ir1 cm, aa&a a gX4. '0
16. CorFective measures needed and/or taken: S).1 U;ndes. ,o V M%:A f,ea c_XQ
h
17. Other recommendations and comments:
18. Is the Annual Reclamation Report +/_map accurate? ❑ Yes No (Explain) ❑ Not Reviewed
©.�
�rretr" • tS- ��' t ri-tCcc���i/x� `1'h.� � c� � .
,�Q.�.�i�r�
19. Follow-up inspection needed? D&es ❑ No Do 10_tXA4bv@o%ed date
20. No. of additional pages of Inspection Report ,. 21. Copy of Report sent to operator
(date)
INSPECTED BY: c w i DATE I l/ /
Telephone No:
White copy to fele Yellow copy to operator Pink copy to Mining Specialist 10197

State of North Carolina
Department of Environment
and Natural Resources
.Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
M4
IL
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: Alchem Inc.
Permit No.: W00016338
Last Amended Date: N/A
SOC Issuance Date(if applicable): N/A
Permittee Contact: 431i'—r
9
ORC Name: N/A
ORC Cert.#: N/A
Reason for Inspection
County: Rowan County
Issuance Date: Pe B Cr
Expiration Date: N10*01!01-
Expiration Date: N/A
Telephone No.: 704/ 279-7908
Telephone No.: 704/ -
ORC:
X ROUTINE COMPLAINT X FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation Sludge —X-Other
Inspection Summary: (additional comments may be included on attached pages)
The facility was inspected using the permit conditions in the permit WQ0016338, dated
ngd tjze settlement agreement dated
Gv✓�
Ellen Huffinan, APS MRO, Peggy Finley APS MRO, Cho',, DWQ Lab Certification,
attended the inspection on % 0 - ff--()e Physical readings of to perature and pH were
taken at the new sampling port ov, % n to rit24 i , by
ALCHEM and observed by Chet Whiting, DWQ. Chet Whiting will be sending a separate report
regarding the laboratory inspection and current testing procedures. See photos attached. A pH
reading of the water in lagoon #1 , lam as SU, and lagoon #3 was
SU . fw� C)
v
i.
Continued on page 2
Is a follow-up inspection necessary _X yes _ no
Inspector(s) Name(s)/Title(s) Ellen Huffman / Env. Specialist II
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection December 5, 2006

7•
J

Water Recycle System/residuals bauxite disposal pg 2
WQ0016338, WQ0002702 ALCHEM, Inc.
Inspection Summary Continued
The freeboard is ,CC in lagoon 1, _ in lagoon 2 and lagoon 3 ° Spent bauxite sand
has been dug up around the sides of lagoons 1 & 2 to make space for process water to recycle
back into the wash system. There is a section of lagoon #1 wall that has been compromised and
is much thinner than the rest of the lagoon wall. A cement pad has been poured in the bauxite fill
area. There is compaction documentation in a report from Delta Environmental (in the MRO
files) regarding the pad construction. See photos attached.
Type of System
Spent bauxite residuals disposal
Record Keeping
Y/N
Y Copy of current permit available at residual generating site
Y Current metals analysis (2 x's year)
Y TCLP analysis- 1 x per permit cycle, starting in 1999.
N/E Hauling records (# gal and/or ton hauled during calendar year to date)
N/E Records of lime purchased
Y Fill inspection log (records).
comment: DWQ APS has not allowed ALCHEM to use the disposal area for spent bauxite since
December 12, 2006 NOV was issued. The 2006 Annual report records reflect a higher pH than
what was found during this inspection.
Treatment (check treatment type(s) used)
Wash Recycle System permit WQ0002712 issued December 28, 2004.
Transport 1V/A
Spill control p an in transport vehicle?
Does transport vehicle appear to be maintained?
Comments: Currently there is no transport of spent (bauxite) material off site for disposal.
Operation & Maintenance records N/A
Disposal Reuse Area
Describe storage:
No Site condition adequate
YES Signs of runoff / ponding
Monitoring wells) Y/N: Y
The wells at this site are associated with the water recycle system permitted under WQ0002702

yr, l - J'1
-k-

M
i
k.
i
j
7
Revised Air Permit Modification Application
(In response to Additional Information Request dated Oct. 2, 2008)
Industrial & Agricultural Chemicals, Inc.
2042 Buie Philadelphus Rd
Red Springs, NC 28377
Delta Project No. 6E080-5063-P
This report was prepared by:
P— Y
8008 Corporate Center Drive, Suite 900
Charlotte, North Carolina 28226
October 9008
3
FRO }

SUSTAINABLE STRATEGIES FOR GLOBAL LEADERS
0-11,,
October 21, 2008
Mr. Steven Vozzo,�
Regional Supervisor('
North Carolina Department of Environment
and Natural Resources
Division of Air Quality -- Fayetteville Regional Offic ,�• ��
225 Green Street, Suite 714 d) j
Fayetteville, North Carolina 28301 }1
Subject: Permit Additional Information Request October 2, 2008
Industrial & Agricultural Chemicals, Inc.
2042 Buie Philadelphus Rd.
Red Springs, Robeson County, North Carolina
Air Permit No. 06125R09
Dear Mr. Voz7o:
Oil behalf of our client, Industrial & Agricultural Chemicals, Inc. (I&AC), we are
submitting this letter and the attached information in response to the Additional
Information Request letter written by NCDENR on October 2, 2008. The attached
application revisions address the four items described in the additional information
request.
E ) Detailed description of how your facility plans to eliminate plastic
materials prior to drying. 'rile facility plans to install an air line at the
end of the screening operation to separate the heavier metal oversize
materials form the lightweight paper and plastic. The paper and plastic
will be blown into a cyclone where it will be collected for disposal. The
D E. LTA cyclone will be installed to prevent the paper and plastic from
discharging into the dust collector and clogging the €ilter. The cyclone
was added to the process flow diagrams and an additional C4 form was
added to the revised application.
2) Detailed process flow diagram of the battery recycling operations.
The revised application attached includes a detailed process flow diagram
for the alkaline battery recycling process and the micronutrient process.
'theses are the two processes that will be used in the battery recycling,
operation.
3) An analysis of all emission generated or emitted during the process
(including inherent mercury) and toxics demonstrations. The
emissions for each emission source associated with the battery recycling
operation have been included on the respective 13 form along with more
detailed emission calculations. 'tine battery recycling operation will not
cause an increase in sulfur dioxide, nitrogen oxide, carbon monoxide, or
volatile organic compound emissions. The new emission will have an
impact on particulate matter emissions and may introduce two new toxic
pollutants, manganese and mercury. Manganese is the material WAC
wishes to extract from the batteries for their micronutrient process.
Mercury is present in alkaline batteries at low levels. Roth manganese
and mercury could possibly be emitted in the particulate form from the
process due to dust generated from material handling. Mercury will not
be emitted from the process in vapor form because the boiling point of
mercury (674 deg. F) is higher than the temperature in the dryer (350 --
400 deg. C). The manganese and mercury (lust emission calculations
IaIO �xl
�tn\ttwxrnl.{AISuMf
8008 Corporate Center Drive Suite 100 Charlotte, NC 28226 USA
Phone; 704.541.9890 / 800.477.741.1 Fax:[phone]
wWw.deltaenv.com

Response to Additional Information Request
Industrial & Agricultural Chemicals
Red Springs, North Carolina
Delta Protect No SE080-5063-P
Page 2 of 2
show that with existing emission controls, the toxic air pollutant emissions will not exceed the rates
requiring a permit.
4) Detailed description of the emission conti-ols yotir facility plans to use to control these emissions.
The facility plans to connect the new emission sources to existing pollution control equipment at tine
facility. The new emission units for the alkaline battery recycling process will be connected to existing
baghouse C-l. Tile new emission sources associated with the micronutrient process will be connected to
existing baghouses C-4 and DA-2.
The revised application is attached for your review. Ploase contact Steve Walls at Delta Consultants at [phone]
or Mr. Randall Andrews at [phone] ext. 23, if you have any questions during your review of the permit
modification.
Sincerely,
G✓h�
Stephen Walls
Project Manager
Delta Consultants
Enclosures
8008 Corporate Center Drive Suite 100 Charlotte, NC 28226 USA
Phone: [phone] Fax:[phone]
www.clel-0anv.coILL

Table of Contents
Form Al
Form A2, A3
Battery Recycling Process
• Process Description
• Process Flow Diagram
• Forms for new Hammer Mill BB-HM-1 (B and B9 forms)
• Forms for new Hammer Mill BB-HM-2 (B and B9 forms)
• Forms for existing Screener SS-2 (B and B9 forms)
• Forms for new Screener BB-SC-1 (B and B9 forms)
• Forms for new Screener BB-SC-2 (B and B9 forms)
+ Control device form for new BB-CY-1 (part of SS-2, BB-SC-1, and BB-
SC-2) -
• Control device form for existing CA (connected to BB-HM-1, BB-HM-
2, BB-SC-1, and BB-SC-2)
• Emission Calculations
Micronutrient/Granulation Process
• Process Description
• Process Flow Diagram
• Forms for new Closed Ribbon Blender FP-9 (B and B9 forms)
• Control device form for existing DA-2 (connected to FP-9)
• Forms for new Hammer Mill GB-HM-I (B and B9 forms)
• Forms for new Screener GB-AS-1 (B and B9 forms)
• Control device form for existing C-4 (connected to GB-HM-1 and GB-
RS-1)
• Emission Calculations
Facility -Wide Emissions
• Form D1
Air Toxics Emission Review
Mercury Analysis of Batteries
*Note: Zoning consistency not included, provided in the original application.

FORM ,Al
FACILITY (General Information)
REVISED 11/01/02 NCDENR/Divislon of Air Quality - Application for Air Permit to Construct/Operate Al
.r _ .a:,�� T,^,Nml[E-.ARF'.4IC,A,;T,�(Ql!�,WiLL;NO'f; Rl� PI�OCESS�D NIIiTHOi�'�'flt� FO1�i�O'I14diNCar,.
❑ Local Zoning Consistency Determination (if required) H Facility Reduction & Recycling Survey Form (Form A4) ❑ Application Fee
❑ Responsible OfficiallAuthorized Contact Signature appropriate Number of Copies of Application ❑P.E. Seal (if required)
, l--
Legal Corporate/Owner Name: Industrial & Agricultural Chemicals, Inc.
Site Name: Industrial & Agricultural Chemicals, Inc.
Site Address (911 Address) Line 1: 2042 Buie Philadelphus Rd
Site Address Line 2:
City: Red Springs
State: NC
Zip Code: 28377
County: Robeson
- ,... .. . a . .... ..... :.. .... ,.. h�{ > .a
:-:,.0 ON"Mom:=,.::::<,:.;,w,
PermiMchnicat Contact: Randall F. Andrews
FaclllfyAnspecflon Contact: Randall F. Andrews
Name/Title: President
NamelTitle; President
Mailing Address Line 1: 2042 Buie Philadelphus
Mailing Address Line 1: 2042 Buie Philadelphus
Mailing Address Line 2:
Mailing Address Line 2:
City: Red Springs Slate: NC Zip Code: 28377
City: Red Springs State: NC Zip Code: 28377
Phone No. [phone] Fax No. (area code)
Phone No. [phone] Fax No. ( area code)
Email Address:
lEmail Address:
Responsible ONcial/Authorized Contact: Randall F. Andrews
Invoice Contact: Randall F. Andrews
NamelTitle: President
Name/Title: President
Mailing Address Line 1: 2042 Buie Philadelphus
Mailing Address Line 1: 2042 Buie Philadelphus
Mailing Address Line 2:
Mailing Address Line 2:
City: Red Springs State: NC Zip Code: 28377
City: Red Springs State: NC Zip Code: 28377
Phone No, [phone] IF.x No. ( area code)
Phone No. [phone] IFax No, (area code )
Email Address:
Email Address:
❑ New Non -permitted Facility/Greenfield Modification of Facility (permitted) ❑ Renewal with Modification
❑ Renewal (TV Only)
« � F : GII.iTY:CLA: IFICAt O AI":1C Ft-AI?i?LiCATIbN Gheck;Oni •"?dne "�'•<:�:, ; �;>:�
A $S
LJ General U Small U Prohibitory Small L2rj Synthetic Minor ❑Title V
Describe nature of (plant site) operation(s): Facility ID No.: _ _ _ 7800168 _ _ _ _ _ _ _ ___ _
Industrial Agricultural Chemicals, Inc. (IAC) processes by-products from various industries to blend for agriculture fertilizer IAC arse receives by-products, repackages and distributes
them to various customers. Some of these prodcuts are spent catalyst, metals and other trace elements.
Primary SICINAICS Code: 5191 CurrenUPrevlous Air Permit No. 06125R09 Expiration Date 2128/2009
Facility Coordinates: Latitude: 34d 45.13333m Longitude: 79d 0.3167m
Does this application contain confidential data? ❑ YES ❑✓ NO
FIRfVI Tlissl'i .jPREPAREI,?
APf?LIC{l11't�N
Person Name: Stephen Wails
Firm Name: Della Consultants
Mailing Address Line 1: 8008 Corporate Center Drive Suite 100
Mailing Address Line 2:
City: Charlotte
Stale: NC
Zip Code: 28226 County: Mecklenburg
Phone No. [phone]
Fax No. [phone]
Email Address: stevew2(dideltoenv,com
iss%,,,:r.`'✓;as.:;.�:;>:;;:;a,r:,..:, .:•.:cz_',>:,,.(,i;;:: .�:; :.
;, ,,, ,, ,,,,,,,, , , ., , .:r.-.:,. ;SIGNA?URE
.... ..: .... ... _
OF RIrSPONSIBLE;OFFICIALJAU"�HORIZ�i)
--a`.:;.r:.,:;:';:i„c:.3td:,.: J<;>r :_�=<:::<;. :c.::a
COfyTA:CY', ' �- .:,.,••
Name (typed): Randall F. Andrews Title: President
X Signature(Blue Ink): Date:
Attach Additional Sheets As Necessary

FORMS A2, A3
EMISSION SOURCE LISTING FOR THIS APPLICATION - A2
112r APPLICABILITY INFORMATION - A3
REVISED 04/10/07 NCDENRIDivision of Air Quality - Application for Air Permit to constructioperate r A
EMISSION
EMISSION SOURCE
ID NO,
SOURCE LISTING: New, Modified, Previously Unpermitted, Replaced, Deleted
EMISSION SOURCE CONTROL DEVICE CONTROL DEVICE
DESCRIPTION ID NO. DESCRIPTION
k...,,:4,:
, u..-H::�,.;;•�q Vim..
t
�
�• :1"hl. <A lit;.a loitt��
�;.�v... :�... p�....
:, ;,:: ,.p �v a,.sl:, .n:::�..>, t,. ;.:d .x►t`` � labe
Neva= r...i u. =U ';�.I'tii.��. _,R I�'►-.ii" �t
C ,.y � �....
1313-HM-1
Hammer Mill
C-1
One bagfilter (2592 ft4 of filter area)
1313-HM-2
Hammer Mill
C-1
One bagfilter (2592 f of filter area)
B13-SC-1
Screener with associated cyclone BB-CY-
C-1
One bagfilter (2592 fe of filter area)
BB-SC-2
Screener with associated cyclone BB-CY-
C-1
One bagfilter (2592 W of filter area)
FP-9
Closed Ribbon Blender
DA-2
One bagfilter (2592 W of filter area)
GB-HM-1
Hammer Mill
C-4
One bagfilter (5184 ft of filter area)
GB-RS-1
Screener
C-4
One bagfilter (5184 ft of filter area)
-.:,�: _<.............rt• ..;-,,,:,.:.,
...., .,_,,,,.,..<. _._..� ..: . .
y
. s t ., a :E t nt:7`
me v,....:...�.....1..:,:.
.... ...._,..<,.............,. 9 . _........ fit! p .
Se=M00 D:13
ii A n% 3• ,
e. - -
SS-2
Add cyclone (BB-CY-1) to air emission
stream to remove paper and plastc prior
to dust collector C-1.
C-1
One bagfilter (2592 fe of filter area)
� y
p
Is your facility subject to 40 CFR Part 68 "Prevention of Accidental Releases•' - 5ecuon i i zV) or the reaerai dean Air Act f r
if No, please specify In detail how your facility avoided applicability: No regulated substances above threshold
your facility is Subject to 112(r), please complete the following:
A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 68.10 or Part 68.150?
Yes d No d Specify required RMP submittal date: If submitted, RMP submittal date:
B. Are you using administrative controls to subject your facility to a lesser 112(r) program standard?
Yes di No d If yes, please specify:
Attach Additional Sheets As Necessary

Air Permit Mortification Horns
.Battery Recycling Process

Battery Building ftocess Description
Industrial & Agriculture Chemicals, Inc
Red Springs, North Carolina
Delta Project No. 5EOOSO-5063-P
Raw unbroken alkaline batteries are manually placed onto a belt conveyor, which conveys the batteries to
the two Hammer Mills (BB-1-IM-1 and BB-HM-2). The I-lmmer Mills break the casing on the batteries
then grinds the battery casing and internal components. The Hammer Mills are located inside 20-foot
scaled shipping containers that have a negative pressure applied to capture dust emissions; however, the
batteries are wet after grinding which reduces the amount of list generated. The dust captured within the
sealed shipping container discharges to a Dust Collector (C-1) for pollution control.
The ground batteries are then screw conveyed from the Hammer Mills to a dump hopper. The clump hopper
is stored inside the facility and allowed to air dry prior to screening. The dump hopper is manually
transferred to one of three Screeneis (SS-2, BB-SC-1, or BB-SC-2) located inside the Battery Building. The
Screeners physically separate the ground batteries into three process and waste streams. The fine material
that falls through the screen .is a dry powder that contains Manganese (Mn) and Zinc (Zn). This dry powder
is screw conveyed into a super sack. Air is blown through the oversize material that does not fall through
the screen to separate the lightweight materials from the heavier metal components. The lightweight
materials consist of paper and plastic that surrounds the battery casing. These lightweight materials arc
blown into a Cyclone (BB-CY-1) where the larger pieces of paper and plastic are collected and sent to an
of€site landfill for disposal. The smaller dust particles from the cyclone discharge into the Dust Collector
(C-1),
The heavier oversize material consists of metal with wet Mn and Zn powder adhering to tine surface. This
material goes over the top of the Screeners (SS-2, BB -SC -I, or BB-SC-2) and is conveyed into a dump
hopper. The contents of the dump hopper are then manually placed on a belt conveyor that conveys the
heavier oversize material into the Calciner (&2) for drying, The wet Mn and Zn powder dries and falls
away from the metal and is screw conveyed back to the Screeners to separate the metal pieces from the dry
Mn and Zn powder. The remaining metal pieces are shipped offsite and recycled. The Calciner and
Screeners are also located inside the Battery Building and dust emissions discharge into the Dust Collector
(C-1) for particulate removal.

Flame I- Alkaline Battery Recycling Process Flow Diagram
Industrial & Agricultural Chemicals
Red Springs, NC
Delta Project No. SE080-5063-P
Particulate Emissions
I
Dust Collector
C-1
99.99%
Dust emissions from sources
$B-HM-I, B13-11M-2, SS-2, BB-SC-1,13B-SC-2, 6-2, and BB-CY-1
-------p_—`rr—__—ysm_^��"�_..._—
Lightweight materials iaeluding-------------------------
� w.>l� �Q t
paper and plastic That surrounds
hattequsing. Hll-CY-I
Hammer MiNs j Screens
Raw Material 10 BB-IIN-1 (5 (ph) SS-2 (2 tph) Paper and plastic
(Alkaline Batteries) " EiN BB-SC-1 (3 tph) to landfill I
BB-Nisi-2 (5 tph) v BB-SC-2 (3 tph) 1
e Heavy oversize items including iron,
Air stcel, and other metal with Mn and Zu
( Dry powdered h 'j containing paste.
matiSanese and AnC�
To micronuirient _ pass dnough the I
I process screen into super I
I sack.
I Calciner (Dryer)
I h: 2 (10 tph)
Screens
SS-2 (2 tph)
( 13I3-SC-1(3 I
Iph) I
I BB-SC-2 (3 I
I i
Ilea, mchals to local recycler
I I

FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12/01 /01 NCDENRIDivision of Air Quality -Application for Air Permit to Construct/Operate 1 1
EMISSION SOURCE DESCRIPTION: BB-1 (Hammer Mill)
EMISSION SOURCE ID NO: BB-HM-1
CONTROL DEVICE ID NO(S): C-1
OPERATING SCENARIO 1 OF 1 JEMISSION
POINT (STACK) ID NO(S): CA Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Alkaline dry cell batteries are pulverized.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM Bi-B9 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil, gas, other burner (Form 81) ❑ Woodworking (Form B4) ❑ Manufact. of chemicals/coatings/inks (Form 137)
Int.combustion engine/generator (Form B2; ❑ Coating/finishing/printing (Form B5) ❑ Incineration (Form B8)
❑ Liquid storage tanks (Form 83) ❑ Storage silos/bins (Form 86) X Other (Form 89)
START CONSTRUCTION DATE: OPERATION DATE: DATE MANUFACTURED:
MANUFACTURER I MODEL NO.: EXPECTED OP. SCHEDULE: HRIDAY DAYANK WK/Y
IS THIS SOURCE SUBJECT TO? NSPS(SUBPART?):_N NESHAP(SUBPART?):—N, MACT (SUBPART?): N—
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240 IVISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS I LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS I LIMITS) (AFTER CONTROLS] LIMITS)
Ib/hr
I tons/yr
lb/hr I
tonslyr
Ib/hr
tonslyr
PARTICULATE MATTER (PM)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<10 MICRONS (PM ,o)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<2.5 MICRONS (PM2.6)
SULFUR DIOXIDE (S02)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
".-'...:`;: .",-`"„=`.-;:�c�-HAz'ARD-,O SAIR•POLLl1�'ANT�EMlSSIO SITU,F'OR1�lA1''IONFOR:Y'H1SSQij/7(:�'-
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
Ib/hr
tonslyr
ib/hr
tons/yr
Iblhr
tonslyr
°•"�--=�� •• ' �w�:`7'OXIGAIRIsQLLUTAN7:EMtSSION.S,IIVFQl2M�47"1.0(11 FORTHlS;S0111a'G.E
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS I LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Ib/hr I Ib/day lblyr
Manganese
Source Test
See facility wide emissions on form D-1 for TAP Evaluation
Mercury
Source Test
See facility wide emissions on form D-1 for TAP Evaluation
Attachments: (1) emissions calculations and supporting documentation; (2) Indicate all requested state and federal enforceable permit omits (e.g. hours of operation, emission rates) and
describe how these are monitored and with what frequency; and (3) de
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE U7 THROUG14 89 1-URM FOR EACH 50UR E
Attach Additional Sheets As Necessary

FORM R9
EMISSION SOURCE (OTHER)
REVISED: 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate 139
EMISSION SOURCE DESCRIPTION: Hammer Mill
EMISSION SOURCE ID NO: BB-HM-1
CONTROL DEVICE ID NO(S C-1
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Alkaline dry cell batteries are pulverized.
M' N EiiING PI2QCE 1 U U
;- .:;
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE
UNITS
Alkaline dry cell batteries
tons
5
None
;MATT=RIAtNTRI�EG .PR4ClS,S BAC(i 0pE>iA7tQN
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR); (BATCHESIYR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE:
REQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:

FORM R
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12/01101 NCDENRIDivision of Air Quality - Application for Air Permit to Construct/Operate 13
EMISSION SOURCE DESCRIPTION: BB-1 (Hammer Mill)
EMISSION SOURCE ID NO: BB-HM-2
CONTROL DEVICE ID NO(S): C-1
OPERATING SCENARIO 1 OF 1
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Alkaline dry cep batteries are pulverized.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM 81-B9 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil, gas, other burner (Form B1; []Woodworking (Form B4) ❑ Manufact. of chemicals/coatings/inks (Form 137)
Int.combustion engine/generator (Form B2 ❑ CoatingKnishing/printing (Form B5) []Incineration (Form BB)
❑ Liquid storage tanks (Form 133) ❑ Storage silos/bins (Form B6) X Other (Form 69)
START CONSTRUCTION DATE: JOPERATION DATE: DATE MANUFACTURED:
MANUFACTURER / MODEL NO.: I EXPECTED OP. SCHEDULE: HRIDAY DAYIWK WK/Y
IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?):,N NESHAP (SUBPART?):_N� MACT (SUBPART?): N
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240 VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
—- yNFOR
siti :• :; GRITERIA,A(l2 P-.,OL WWII 1S;.SOUR
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS I LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (AFTER C:ONTROLSIUMITS)
ib/hr
tonslyr
Ib/hr
tonslyr
Iblhr
tons/yr
PARTICULATE MATTER (PM)
Best Engineering Judgement
1,00E-04
3.12E-04
4.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<io MICRONS (PIM16)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<2.5 MICRONS (PM2.6)
SULFUR DIOXIDE (SO2)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
':;'?�;':iz^b`^:x"ram>,i::`}.z:': c;s:;pi'•.::r
H. A�AF,2bOUS'AIR.PO�L�U7'AAtT:E11+11$.SJOtVS:INFOR1VJ4`7'IUN=FOR.,THtS
`S.OfJ.RCE >
s":e":.a¢.ir<:r..,
.>. ,.
.t.
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL
(BEFORECONTROLSILIMITS)
EMSSIONS
(AFTER CONTROLS/LIMITS)
iblhr
tonslyr
Ib/hr
tonslyr
Iblhr
tons/yr
�,.�..,•,:,... �:. •. ,<•,,,.:..<„, :..,.:.70XIG..41R.. .OrLLUTAN,T.EM..,ISSIQN..$ lN-....:.
FORMA
..T ..
Q.:.......�..
It.:�.
,.._:....
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS I LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Ib/hr lb/day Ib/yr
Manganese
Source Test
See Facility Wide Emissions Summary (Form 131) for TAP evaluation
Mercury
Source Test
See Facility Wide Emissions Summary (Form 01) for TAP evaluation
Attachments: (1) emissions calculations and supporting, documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates) and describe
how these are monitored and with what frequency; and (3) de
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE S1 THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
REVISED: 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate
Sg
EMISSION SOURCE DESCRIPTION: Hammer Mill
EMISSION SOURCE ID NO: BB-HM-2
CONTROL DEVICE ID NO(S: C-1
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Alkaline dry cell batteries are pulverized.
=: ;=s> NIAEFfi4f:S„NTF;INGROCEuS>+CatV1INUbU.SpRC1SS t;_`=
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE
UNITS
Alkaline dry cell batteries
tons
5
None
:i>
';�VIgTEItlALS':IJTERIftG PROGES$ *ATCtt OPERAfiON
r' x=;
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHES/YR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE:
REQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:

FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12101/01 NCDENR/D)v1sIon of Air Quality -Application for Air Permit to Construct/Operate l o l
EMISSION SOURCE DESCRIPTION:
JEMISSION SOURCE ID NO: SS-2
CONTROL DEVICE 10 NO(S): C-1
OPERATING SCENARIO 1 OF _ 1 _ _
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammer mill process with associated cyclone BB-CY-1.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1.B9 ON THE FOLLOWING PAGES):
❑ Coal,wood,oit, gas, other burner (Form 131) Cj Woodworking (Form B4) ❑ Manufact, of chemicals/coat(ngsfrnks (Form B7)
Int.combuslion engine/generator (Form 82) n Coating/finishing/printing (Form 85) ❑ Incineration (Form 138)
Liquid storage tanks (Form 133) 0 Storage siloslbins (Form B6) X Other (Form B9)
START CONSTRUCTION DATE: JOPERAT18M DATE: JDATE MANUFACTURED:
MANUFACTURER 1 MODEL NO.: 1EXPECTED OP. SCHEDULE: HRIDAY _ DAYIWK _ WK/YR
IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?):.__N_._._-_ _ NESHAP (SUBPART?):_,-_w N-_,-__., MACT (SUBPART?); _ N_.___.
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 ' MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240
VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
.w 7 MW 7" T pocc
0rA N. T. 0" JoNS �r F,o RMAr MFo
T URC
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTERCONrROLS1LIMITS)
POTENTIAL EMSSIONS
(nEFORE CONTROLSI LIMITS) (AFT6RCONTROISILIMITS)
Ib/hr
tonslyr
Ib1hr
tonslyr
ib/hr
tonslyr
PARTICULATE MATTER (PM)
Best Engineering Judgement
4,00E-05
1,25E-04
0.40
1.75
4.00E-05
1.75E-04
PARTICULATE MATTER-10MICRONS (PM,e)
Best Engineering Judgement
4.00E-05
1.25E-04
0.40
1.75
4,00E-05
1.75E-04
PARTICULATE MATTER<2 a MICRONS (MA
SULFUR DIOXIDE (SQ2)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
US<, i'P.,
.AIR
T
'U NTE SSJON
QIa4...::A. M .........
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFT[:RCONfROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (APTERCONTIiOLSIUMITS)
Ib/hr
tonslyr
iblhr
tonslyr
Ib/hr
tons/yr
:).,;,, •::..T O Lt! S S=! FO
J
R<.:
5.:. . UR
Ers:`::r�:<:.;.��>,-::v�'<;;�:;:'<=�vs>>;:�;
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Ib/hr I Ibiday ib/yr
Manganese
Source Test
See Facility Wide Emissions Summary (Form 01) for TAP evaluation
Mercury
Source Test
See Facility Wide Emissions Summary (Form D1) for TAP evaluation
Attachments (1) emissions calculations and supporting documentation; (2) Indicate all requested stale and federal enforceable permit limits (o.g. hours of operation, emission rates) and desefte
how these are monitored andwilli what frequency; and (a) de
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B9 THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
REVISED: 12/01/01 NCDENR10ivision of Air Quality - Application for Air Permit to ConstructlOperate B9
EMISSION SOURCE DESCRIPTION: Sizing Screen
EMISSION SOURCE ID NO: SS-2
CONTROL DEVICE ID NO(S) C-1
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(Sy C-1 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammer mill process with associated cyclone BB-CY-1.
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR
TYPE
UNITS
Alkaline dry cell batteries
tons
2
None
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE .
UNITS
MAXIMUM DESIGN (BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHESNR):
FUEL USED:
ITOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE:
IREQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
Attach Additional Sheets as Necessary

� f
t
E
FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
RPVMFn 12/01/01 NCDENRlDivtslon of Air Quailty -Application forA(r Permit to Construct/Operate
AMMI
EMISSION SOURCE DESCRIPTION; JEMISSION
SOURCE ID NO: BB-SC-1
CONTROL DEVICE ID NO(S): C-1
OPERATING SCENARIO 7OF 1 JEMISSION
POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammer mill process with associated Cyclone BB-CY-1.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM 131-80 ON THE FOLLOWING PAGES):
F] Coal,wood,oil, gas, other burner (Form 81) ❑ Woodworking (Form 84) ❑ Manufact. of chemicals/coatingslinks (Form B7)
❑ Int.combustion engine/generator (Form 62) n Coating/finishing/printing (Form B5) ❑ Incineration (Farm BB)
❑ Liquid storage tanks (Form 83) ❑ Storage silos/bins (Form B6) X Other (Form 89)
START CONSTRUCTION DATE: 1OPERATION DATE: )ATE MANUFACTURED:
MANUFACTURER MODEL NO.: 1EXPECTED OP. SCHEDULE: HR/DAY ! DAYANK _ WKIYR
IS THIS SOURCE SUBJECT TO? NSPS (SU8PART?):_N_ NESHAP (SUBPART?):__._ N._,-,, MACT (SUBPART?): N-
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240
VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION:_ ___ % OPACITY
t •„`r . . �-:. .. :,,,,. CR17;ER/A.�4lR.,R.Ol,1.(J.TANT
.. :. e:
EM1SSlQNS 111(FQRMA?LO..N...POR.xT'HfS
�;.+T-
SOURCE � �>.-; r..... .....
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LeeTS) (AFTERCONTROLS/LIMITS)
Ib1hr
tonslyr
Ib/hr
lonslyr
Itrlhr
tonslyr
PARTICULATE MATTER (PM)
Best Engineering Judgement
6.00E-05
1.87E-04
0.60
2,63
6.00E-05
2.63E-04
PARTICULATE MATTER<tB MICRONS (PM„)
Best Engineering Judgement
6.00E-05
1.87E-04
0.60
2.63
6-00E•05
2.63E-04
PARTICULATE MATTER<2.6 MICRONS (I'M2.5)
SULFUR DIOXIDE (SO2)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
�s<'-��°~'<-,<'� `:?�,'..-:<:� :,..- HAZARDOUS:.4fEt'pOL•LUTANT'EM1SSlpNS.:INF,ORMATIOAf
FORTH/5.SQUR
"=°`'``'
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL
(er•FORECONTROLS/LIMRS)
EMSSIONS
(AFTER CONTROLS/LIMITS)
Iblhr
tonslyr
Iblhr
tonslyr
Ib/hr
I tonslyr
. . , - ,;
TE S !0 `INRORMA.714
i :: •.R!';T,IH
5�12U12GE';=;�>��::«:�::-.::,::.:.
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS If LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Iblhr IIblday Ib/yr
Manganese
Source Test
See Facility Wide Emissions Summary (Form 01) for TAP evaluation
Mercury
Source Test
See Facility Wide Emissions Summary (Form D1) for TAP evaluation
Alinenments: (1) emissions calcuialions and supporting documentation: (2) indicate all requested state and federal enforceabte permit ilmits (e.g. hours of operation, emission rates) and describe
how thoso are monitored and with what frequency; and (3) do
COMPLETE THIS FORM AND COMPLETE ANo ATTACH APPROPMA f E l:sT 1 nnuu[an ua ruacm run cflt,,n avurn.c
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
REVISED:12/01/01 NCOENR/Division of Alr Quality - Application for Air permit to Construct/Operate B9
EMISSION SOURCE DESCRIPTION: Sizing Screen
EMISSION SOURCE ID NO: BB-SC-1
CONTROL DEVICE ID NO(S) C-1
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammer mill process with associated cyclone BB-CY-1.
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR
TYPE
UNITS
Alkaline dry Cell batteries
tons
3
None
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH
TYPE
UNITS
MAXIMUM DESIGN BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHES/YR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION STUIHR):
MAX. CAPACITY HOURLY FUEL USE;
IREQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
Attach Additional Sheets as Necessary

FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12/01/01 NCDENR/DIVIsIon of Alr Quality - Application for Air Permit to ConstructlOperate
EMISSION SOURCE DESCRIPTION:
EMISSION SOURCE ID NO: BB-SC-2
CONTROL DEVICE 10 NO(S): C-1
OPERATING SCENARIO _ . 1..-_.__._..__.- OF 1
EMISSION POINT (STACK) ID NO(S): C-1 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammor mill process with associated cyclone BB-CY-1.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1.B9ON THE FOLLOWING PAGES):
E]Coal,wood,oil, gas, other burner (Form B1) O Woodworking (Form 84) [] Manufact, of chemicals/coatings/inks (Form B7)
❑ Int.combustion enginelgenerator (Farm 132) ❑ Coating/finishingfprinling (Form 85) ❑ Incineration (Form 138)
Liquid storage tanks (Form B3) n Storage silos/bins (Form 66) X Other (Form 139)
START CONSTRUCTION DATE: 1OPERATION DATE: JDATE MANUFACTURED:
MANUFACTURER / MODEL NO.: 1EXPECTED OP. SCHEDULE: _ HRIDAY _ DAYPNK ... -_....... _ WKIYR
IS THIS SOURCE SUBJECT TO? NSPS (SUBPART7):_N^ NESHAP (SUBPART7):_,__,._N_.,___ MACT (SUBPART7):___N_
PERCENTAGE ANNUAL'rHROUGHPUT(I): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240
VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
S
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CON TROLS I LIMITS)
POTENTIAL EMSSIONS
(nEFORF CONTROLS I I•IMITS) (AFTERCONTROLSrL.IrATS)
Iblhr
tonslyr
Iblhr
lonslyr
Ib1hr
tons/yr
PARTICULATE MATTER (PM)
Best Engineering Judgement
6.ODE-05
1.87E-04
0.60
2.63
6.00E-05
2.63E-04
PARTICULATE MATTER<10 MICRONS (PMID)
Best Engineering Judgement
6.00E-05
1.87E-04
0.60
2.63
6.00E-05
2.63E-04
PARTICULATE MATTER<2.6 MICRONS (PM: 5)
SULFUR DIOXIDE (S02)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
PQLLifJTANX;EM15510NS,(NFOR
A1-IMF0-R;TyIS;SO0CE
=. a°.
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTERCONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS I LIMITS) (AFTER CONTROLS I LIMITS)
Ib/hr
tonslyr
Iblhr
tonslyr
fblhr
tonslyr
::T I l >P. L .T NT E ION :INISOR ATl
_�,::OXC,AR,..,OL U.A.,...MJSS. ..5... ... .....QN....R........:..._
.FO �T
IS.:SOURCE:
..
�-->�<+-,; �;'z�:'•s�=�>�
:..:....,.,..: <..._
,,,:: •.._>.: �:
-„ :;_.__•
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS I LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Whir lb/day iblyr
Manganese
Source Test
See Facility Wide Emissions Summary (Form D1) for TAP evaluation
Mercury
Source Test
See Facility Wide Emissions Summary (Form DI) for TAP evaluation
Attachments: (1) emissions calculations and supporting documentation; (2) indicate all requested state and fedora] enforceable permit limits (o.q. hours of operation, emission rates) and describe
hour these are monitored and with what frequency; and (3) do
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B? THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
REVISED: 12/01/01 NCDENRIDivlslon of Air Quality - Application for Air Permit to Construct/Operate B9
EMISSION SOURCE DESCRIPTION: Sizing Screen
EMISSION SOURCE ID NO: 1313-SC-2
CONTROL DEVICE ID NO(S) C-1
OPERATING SCENARIO: 1__ OF 1
EMISSION POINT (STACK) ID NO($): C-1 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out bulk from hammer mill process with associated cyclone 1313-CY-1.
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE
UNITS
Alkaline dry cell batteries
tons
3
None
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHESIYR):
FUEL USED:
ITOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE:
IREQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
Attach Additional Sheets as Necessary

FORM C4
CONTROL DEVICE (CYCLONE, MULTICYCLONE, OR OTHER MECHANICAL)
REVISED 12/01/01 NCDENRIDivision of Alr Quality -Application for Air Permit to Construct/Operate C4
CONTROL DEVICE ID NO: 12113-CY-1
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): SS-2, BB-SC-1, BB-SC-2
EMISSION POINT (STACK) ID NO(S): C-1 Stack 1POSITION
IN SERIES OF CONTROLS NO. 1 OF 2 UNITS
MANUFACTURER:
MODEL NO:
DATE MANUFACTURED:
PROPOSED OPERATION DATE:
>.<:.:wrw'•r =<<'>' •-:.�°',.";` - Y {� ..$__�{�.AR jffiM
PROPOSED START CONSTRUCTION DATE:
OF--_, _--„
P.E. SEAL REQUIRED (PER 20.0112)? d YES d NO
DESCRIBE CONTROL SYSTEM:
This cyclone is not used for pollutant emission control, rather it is used to remove large pieces of plastic and paper from the emission stream prior to the baghouse.
The primary function of this unit is to protect the baghouse fillers from becoming blocked by large pieces of paper and plastic.
POLLUTANTS) COLLECTED:
BEFORE CONTROL EMISSION RATE (LBIHR):
CAPTURE EFFICIENCY: % % % %
CONTROL DEVICE EFFICIENCY: % % % %
CORRESPONDING OVERALL EFFICIENCY: % % % %
EFFICIENCY DETERMINATION CODE:
TOTAL EMISSION RATE (LB/HR):
PRESSURE DROP (IN. H20): MIN MAX WARNING ALARM? 6 YES & NO
INLET TEMPERATURE (°F): MIN MAX
OUTLET TEMPERATURE (°F): MIN MAX
INLET AIR FLOW RATE (ACFM):
BULK PARTICLE DENSITY (LB1FT'):
POLLUTANT LOADING RATE (GR/FT'):
....:..,.
.... r....,.._..,„ . Y L
h11U1:7Ryt.`1.
LENGTH (INCHES):
INLET VELOCITY FT/SEC):
4 CIRCULAR 4 RECTANGLE
NO, TUBES:
WIDTH (INCHES):
DIMENSIONS (INCHES) See Instructions
IF WET SPRAY UTILIZED
DIAMETER OF TUBES:
HEIGHT (INCHES):
H:
Dd:
LIQUID USED:
HOPPER ASPIRATION SYSTEM?
d YES d NO
VELOCITY (FTISEC.):
W:
Lb:
FLOW RATE (GPM):
NO. TRAYS:
De:
D:
Le:
S:
MAKE UP RATE (GPM):
LOUVERS?
d YES d NO
NO. BAFFLES:
TYPE OF CYCLONE: 0 CONVENTIONAL d HIGH EFFICIENCY ei OTHER
DESCRIBE MAINTENANCE PROCEDURES:
F►
RT(cLE SIZE DISTfiiBtJTttlN ;'
A .. ,.... , .. ..
SIZE
(MICRONS)
WEIGHT%
OF TOTAL
CUMULATIVE
DESCRIBE INCOMING AIR STREAM:
0-1
1-10
10-25
25-50
50-100
>100
TOTAL = 100
DESCRIBE ANY MONITORING DEVICES, GAUGES, TEST PORTS, ETC:
ON A SEPARATE PAGE, ATTACH A DIAGRAM OF THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S):
Attach Additional Sheets As Necessary

FORM C9
CONTROL DEVICE (FABRIC FILTER)
RF\ASFn 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate C1
CONTROL DEVICE ID NO: C-1
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S):
BB-HM-1, BB-HM-2, BB -
SC-1, BB-SC-2, BB-CY-
1, SS-2, E-2
EMISSION POINT (STACK) 10 NO(S): C1 Stack
POSITION IN SERIES OF CONTROLS
NO. 2 OF 2 UNITS
MANUFACTURER:
MODEL NO:
DATE MANUFACTURED:
PROPOSED OPERATION DATE-
�:.:S:.y;a. iL.;J';e'x::
...
=a..„a.;,,.,,PROPOSED
. a,
START CONSTRUCTION DATE:
OF _ 1�
P.E. SEAL REQUIRED (PER 2Q .0112)?
X YES NO
DESCRIBE CONTROL SYSTEM:
One existing bagfilter (2592 W of filter area)
POLLUTANT(S) COLLECTED:
i'Iyl
"s
BEFORE CONTROL EMISSION RATE (LB/HR):
73.60
j
CAPTURE EFFICIENCY:
100 %
% o�
CONTROL DEVICE EFFICIENCY:
99.99 %
% o�
CORRESPONDING OVERALL EFFICIENCY:
99.99 %
% %
I
EFFICIENCY DETERMINATION CODE:
2
TOTAL EMISSION RATE (LB/HR):
7.36E-03
(
PRESSURE DROP (IN. HA): MIN: MAX:
GAUGE? dr YES d NO WARNING ALARM? 4 YES 4 NO
1
BULK PARTICLE DENSITY (LBIFTl):
INLET TEMPERATURE Cr-): MIN
MAX
's
POLLUTANT LOADING RATE: 4 L131HR
d GR/FT4
OUTLET TEMPERATURE (°F): MIN
MAX
INLET AIR FLOW RATE (ACFM):
FILTER MAX OPERATING TEMP. CF):
NO. OF COMPARTMENTS:
NO.OF BAGS PER COMPARTMENT:
LENGTH OF BAG IN.):
{
DIAMETER OF BAG (IN,):
DRAFT:
INOUCEDJNEG. FORCEDIPOS.
FILTER SURFACE AREA (FTZ):
#
AIR TO CLOTH RATIO: FILTER MATERIAL:
e} WOVEN FELTED
�'�.,_•...�..,..1•-.,_.....__�... ��-....._.
DESCRIBE CLEANING PROCEDURES:
..,
6 AIR PULSE
6 SONIC
SIZE WEIGHT % CUMULATIVE
i
6 REVERSE FLOW
d SIMPLE BAG COLLAPSE
(MICRONS) OF TOTAL
d MECHANICAL/SHAKER
6 RING BAG COLLAPSE
0-1
d OTHER
1-10 100
?
DESCRIBE INCOMING AIR STREAM:
70-25
!
Particulates from drying of grinded up
alkaline dry cell batteries
25-50
50-100
>100
TnTAL
= 100
METHOD FOR DETERMINING WHEN TO CLEAN:
6 AUTOMATIC P TIMED MANUAL
i METHOD FOR DETERMINING WHEN TO REPLACE THE BAGS:
r
R ALARM ® INTERNAL INSPECTION 4 VISIBLE EMISSION d OTHER
SPECIAL CONDITIONS:
MOISTURE BLINDING 4 CHEMICAL RESISTIVITY 6 OTHER
EXPLAIN:
}
{
! ON A SEPARATE PAGE ATTACH A DIAGRAM SHOWING THE RELATIONSHIP OF THE CONTROL DEVICE TO I
Attach Additional Sheets As Necessary

HAMMERMILL (BB-HM-1)
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tans/hr) =
5.00
Emission Factor
Ibs PM / ton Process = 0.20
Uncontrolled Emissions PM
Ib/hr =
1.00
Ibs/year =
6,240
tons/year =
3.12
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
Ibs/year =
0.62
tons/year =
3.12E-04
hrs/year =
Process Rate (tons/hr) =
Emission Factor
Ibs PM / ton Process =
Uncontrolled Emissions PM
Ibs/hr =
Ibs/year =
tons/year =
Controlled Emissions PM
Fabric Filter Efficiency (%) =
Ibs/hr = 1
Ibs/year =
tons/year = 4
-PM Emission Factor Source: NCDENR Industrial & Agricultural Chemicals, Inc. (lAC) Air Permit Review March 11,
2004; Application No, 7800168.02A
Allowable PM Emissions
15A NCAC 2D.0515 (Particulates from Miscellaneous Industrial Processes)
P (tons/hr) = 5.00
Allowable emission rate (lb/hr) = E = 4.10(P) 0.67
- 12.05 lb PM/hr
1
Note: PM is assumed to equal PM10
5.001
1.00
8,760
4.38

HAMMERMILL (BB-HM-2)
Expected Actual Emissions
Operation
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
5.00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ib/hr =
1.00
Ibs/year =
6,240
tons/year =
3.12
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
Ibs/year =
0.62
tons/year =
3.12E-04
Potential Emissions
Operation
hrs/year =
8760
Process Rate (tons/hr) =
5,00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ibs/hr =
1.00
Ibs/year =
8,760
tons/year =
4.38
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
lbs/year =
0.88
tons/year =
4.38E-04
-PM Emission Factor Source: NCDENR Industrial $ Agricultural Chemicals, Inc. (IAQ Air Permit Review March 11,
2004; Application No. 7800166.02A
Allowable PM Emissions
15A NCAC 213.0515 (Particulates from Miscellaneous Industrial Processes)
P (tons/hr) = 5.00
Allowable emission rate (Whr) = E = 4.10(P) 0.67
= 12.05 lb PM/hr
Note: PM is assumed to equal PM10

Estimated Emissions from Modification
Industrial and Agricultural, Inc.
Red Springs, NC
hrs/shift =
shifts/day =
days/week =
weeks/year =
hours/year =
Process Rate (tons/hr) =
Emission Factor
Ibs PM / ton Process =
Uncontrolled Emissions PM
Ib/hr =
lbs/year =
tons/year =
Controlled Emissions PM
Fabric Filter Efficiency (%) =
Ibs/hr
Ibs/year
tons! ear =
SCREENER (SS-2)
8
3
5
52
6240
2.00
1
hrs/year =
Process Rate (tons/hr) =
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ibslhr =
0.40
Ibs/year =
3,504
tons/year =
1.75
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibslhr =
4.00E-05
Ibs/year =
0.35
tonstyear =
1.75E-04
-PM Emission Factor ,Source: NCDENR Industrial & Agricultural Chemicals, Inc. (IAQ Air Permit Reviow March 11.
2004, Application No. 7800168.02A
P (tons/hr) = 2.00
Allowable emission rate (lb/hr) = E = 4.10(P) 0.67
6.52 lb PM/hr
Note: PM is assumed to equal PM10
I

SCREENER (BB-SC-1)
Expected Actual Emissions
Operation
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
3.00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ib/hr =
0.60
Ibs/year =
3,744
tons/year =
1.87
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
6.00E-05
lbs/year =
0.37
tons/year =
1.87E-04
ns
fro
hrs/year =
i
Process Rate (tons/hr) = 3.00
I
Emission Factor
Ibs PM / ton Process = 0.20
Uncontrolled Emissions PM
Ibs/hr =
0.60
Ibs/year =
5,256
tons/year =
2.63
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
6.00E-05
lbs/year =
0.53
tons/year =
2.63E-04
-PM Emission Factor Source: NCDENR Industrial & Agricultural Chemicals, Inc. (IAC) Air Permit Review March 11,
2004; Application No. 7800168.02A
Ons
garb
P (tons/hr) = 3.00
Allowable emission rate (lb/hr) = E = 4.10(P) 0.67
- 8.56 lb PM/hr
Note: PM is assumed to equal PM10

SCREENER (BB-SC-2)
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
3,00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ib/hr =
0.60
Ibs/year =
3,744
tons/year =
1.87
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
lbs/hr =
6,00E-05
lbs/year =
0.37
tons/year =
1.87E-04
hrs/year =
Process Rate (tons/hr) =
Emission Factor
Ibs PM / ton Process =
Uncontrolled Emissions PM
Ibs/hr =
Ibs/year
tons/year =
Controlled Emissions PM
Fabric Filter Efficiency (%) =
Ibs/hr =
Ibs/year =
tons/year =
-PM Emission Factor Source: NCDENR Industrial & Agricultural Chemicals, Inc. (JAC) Air Permit Review March 11,
2004; Application? No. 7800168.02A
P (tons/hr) = 3.00
Allowable emission rate (lb/hr) = E = 4.10(P) 0-67
= 8.56 lb PM/hr
(Vote: PM is assumed to equal PM10
3.001
0.201
0.60
5,256
2.63

Aix• Permit Modification Forms
Micronutrient Process

Granulation Building Process Description
Industrial & Agriculture Chemicals, Inc
Red Springs, North Carolina
Delta Project No. 5EO080-5063-P
The dry Mn and Zn powder from the Battery Building becomes one of the raw materiab that enter the
micronutrient process. This process takes the Mn and Zn powder and manufactures a fertilizer product that
contains approximately 5% Mn by weight. The dry Mn and Zn powder is placed in a Closed Ribbon
Blender (FP 9) with some other dry, non-VOC/FLAP materials (e.g. sodium borate, copper oxide, etc.) for
mixing. Some of the dry material from the Closed Ribbon Blender is bagged and sold as a product, while
some is transferred to the Granulation Building for additional processing. The dry powder containing Mn
and Zn is mixed with other inorganic liquid raw materials in a closed Pug Mill. The material from the Pug
Mill is conveyed to Screeners (SS-3 or GB-RS-I) where the fine powder is separated from the larger
agglomerated pieces. From the Screeners, the fine powder is placed into the rotary dryer (E4) for drying
prior shipping out as a product. The larger agglomerated pieces are transferred to the Flammer Mill (GB-
HM-1) where the material is ground into smaller pieces. These smaller pieces are transferred back to the
Screeners (SS-3 and GB-RS-1), where the material is separated again. The process involving the Hammer
Mill and the Screeners is repeated until the agglomerated pieces are all broken down into a powder that
meets the proper mesh specifications for the customer.

Figure 2: Micronutrient Process Flow Dlaeram
Industrial & Agricultural Chemicals
Red Springs, NC
Delta Project No. 5C080-5063-P
Particulate Matter Particulate Matter
tf;P-9
Dust Collector
C-4
ust emissions from source Dust emissions from sources
SS-3, GB-RS-1, GO-IIM-I1l3-I®`
} I I
Rntary Drygr I
Other Lary non- � E-1 (5 (ph) }
} HAP materials
} I Pine materials
( Dry Mn and CI sc try_ Rihlrnn
} Zn Powder ]il n Irr I SS-3 (5 tph}
( from Battery TP-� (S Iph) } GO-RS-1(5 tph) f
I Process
} } I
I I Large Agglomerated }
I } 1
} } Finished Product I
} Finish cd Product Fertilimr(mce }
} Pcrtilircr trace ! Agglomerated material is run elements }
} elements } through the hammer mill and approximately 5% }
approximately 5°10 I sercens until material is small Mu by weight.
} Mn by weight. } enough to fit through screen
} } I larnme). Mill
} I GII-HM-I (S 1ph)
} } I
} } I
} I }

. FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12/01/01 NCDENR/Division of Air Quality - Application for Air Permit to Construct/Operate B
EMISSION SOURCE DESCRIPTION: Ribbon Blender
EMISSION SOURCE ID NO: FP-9
CONTROL DEVICE ID NO($): DA-2
OPERATING SCENARIO 1_ OF 1
EMISSION POINT (STACK) ID NO(S): DA-2 stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Ribbon blender for mixing dry raw materials. Water spray is applied to suppress dust generation.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1-B9 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil, gas, other burner (Form B1) ❑ Woodworking (Form 134) ❑ Manufact. of chemicals/coatingshnks (Form 87)
Int.combustion engine/generator (Form 82' ❑ Coating/finishing/printing (Form B5) ❑ Incineration (Form B8)
❑ Liquid storage tanks (Form B3) (:]Storage silos/bins (Form 65) X Other (Form B9)
START CONSTRUCTION DATE: OPERATION DATE: DATE MANUFACTURED:
MANUFACTURER / MODEL NO.: 1EXPECTED OP. SCHEDULE: HR/DAY DAY/W(( WK/Y
IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?):_ N NESHAP (SUBPART?):--___N__ MACT (SUBPART?): N
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240 VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
CRITTER 1R P LLCl.T I EMISS10IV5=1. ORililA7i.UIVzFOMTH
/S. SOURCE
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS I LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS I LIMITS) (AFTER CONTROLS I LIMITS)
Iblhr
tons/yr
Iblhr
tons/yr
Ib/hr
tons/yr
PARTICULATE MATTER (PM)
Best Engineering Judgement
3.50E-04
1.09E-03
3.50
15.33
3.50E-04
1.53E-03
PARTICULATE MATTER<10 MICRONS (PtN,o)
Best Engineering Judgement
3.50E-04
1.09E-03
3.50
15.33
3.50E-04
1.53E-03
PARTICULATE MATTER<2.5 MICRONS (PM2.5)
SULFUR DIOXIDE (S02)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
:BHA^ R17,OiIS.-AI .I'OL
>(!1'A1V<T�I�MISSIONS
111i ORIV7A:7`lON F0 ..1''fI
Sa;SCiUPtC,�
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTERCONTROLS/LIMITS)
POTENTIAL
(BEFORE CONTROLS/LIMITS)
EMSSIONS
(AFTER CONTROLS/LIMITS)
Ib/hr
tons/yr
Ib/hr
tons/yr
Ib/hr
Ions/yr
None
(:TOXIC'�l1R.PC2LLC19AN>T
LM1SSlONS INFURNIATION
RC?R: H!>:SOl1RC.
, a
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Iblhr I lb/day Ib/yr
Manganese
Source Test
See facility wide emissions on form D-1 for TAP Evaluation
Mercury
Source Test
See facility wide emissions on form 0-1 for TAP Evaluation
Attachments: (1) omissions calculations and supporting documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates) and describe
how these are monitored and with what frequency: and (3) describe any monitoring devices, gauges, or test ports for this source.
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE B1 THROUGH B9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

�. •
EMISSION SOURCE (OTHER)
oc�necn• ao�natna IJ['nFtdRrniviainn of Air Duality - Ann lication for Air Permit to ConstructlOpe rate 139
EMISSION SOURCE DESCRIPTION: Ribbon Blender
EMISSION SOURCE ID NO: FP-9
CONTROL DEVICE ID Nop DA-2
EMISSION POINT (STACK) ID NO(S): FP-9 Stack
OPERATING SCENARIO: 1 OF 1
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Ribbon blender for mixing dry raw materials. Water spray is applied to suppress dust
generation.
M,A. ERIAt,��N�t~�tltdG pRbC.ESS M'CQNTI .,. ;,., ,• .�R
,
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE
UNITS
Agglomerated pieces of fertilizer product
tons
5
None
. TER . 0. N7 Fi1{VC>PRQG S:;'t:,:%3ACCH=Q,PE.,11TI0(vf;`?,::1:?
:. a
MAX, DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED GAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHES / HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHESNR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX, CAPACITY HOURLY FUEL USE:
REQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
Attach Additional Sheets as Necessary

FORM C1
CONTROL DEVICE (FABRIC FILTER)
REVISED 12/01/01 NCDENRIDivision of Air Quality -Application for Air Permit to Construct/Operate C1
CONTROL DEVICE ID NO: DA-2
B-1, B-2, B-3, B-5, B-7, B-9,
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE )D NOS : B-9, M-3, and FP-9
EMISSION POINT (STACK) ID NO(S);
POSITION IN SERIES OF CONTROLS
NO. 1 OF 1 UNITS
MANUFACTURER:
MODEL NO:
DATE MANUFACTURED.
PROPOSED OPERATION DATE:
- OPEI2A'CING`S P.�IA. 0:z,`;,'>ss;;c=•z;.;�',:: r:>?
PROPOSED START CONSTRUCTION GATE:
1 OF 1
P.E. SEAL REQUIRED (PER 2Q .0112)? X YES NO
DESCRIBE CONTROL SYSTEM:
One bagfilter (2592 ftz of filter area)
POLLUTANT($) COLLECTED: PM
BEFORE CONTROL EMISSION RATE (l.B1HR): 30.30
CAPTURE EFFICIENCY: 100 %
CONTROL DEVICE EFFICIENCY: 99.99 %
CORRESPONDING OVERALL EFFICIENCY: 99.99 %
EFFICIENCY DETERMINATION CODE: 2
TOTAL EMISSION RATE (L8/HR); 3.03E-03
% % %
%
PRESSURE DROP (IN, Hz0): MIN: MAX: GAUGE? 9 YES e) NO WARNING ALARM? d YES ri NO
BULK PARTICLE DENSITY (L8/FT3):
INLET TEMPERATURE (°F): MIN
MAX
POLLUTANT LOADING RATE: 6 LB1HR d GR/FT3
OUTLET TEMPERATURE CF): MIN
MAX
INLET AIR FLOW RATE (ACFM):
FILTER MAX OPERATING TEMP. (°F):
NO. OF COMPARTMENTS:
IND, OF BAGS PER COMPARTMENT:
LENGTH OF BAG (IN.):
DIAMETER OF BAG (IN.):
DRAFT: d INDUCEDINEG, a FORCEDJPOS.
FILTER SURFACE AREA (FT2):
AIR TO CLOTH RATIO:
FILTER MATERIAL:
a WOVEN d FELTED
DESCRIBE CLEANING PROCEDURES:
6 AIR PULSE 6 SONIC
d REVERSE FLOW 6 SIMPLE BAG COLLAPSE
4 MECHANICALISHAKER 6 RING BAG COLLAPSE
d OTHER
3`P/1
�
7ICILSiZ'#CIS`rtftlHUTl91V:°%"`_`'?i% `
_ ^CUMULATIVE
SIZE
(MICRONS)
WEIGHT %
OF TOTAL
%
0-1
1-10
100
DESCRIBE INCOMING AIR STREAM:
Particulates from drying of grinded up alkaline dry cell batteries
10-25
25.50
50-100
>100
TOTAL = 100
METHOD FOR DETERMINING WHEN TO CLEAN:
d AUTOMATIC 6 TIMED 0 MANUAL
METHOD FOR DETERMINING WHEN TO REPLACE THE BAGS:
4 ALARM 4 INTERNAL INSPECTION d VISIBLE EMISSION t( OTHER
SPECIAL CONDITIONS:
4 MOISTURE BLINDING b CHEMICAL RESISTIVITY 4 OTHER
EXPLAIN:
DESCRIBE MAINTENANCE PROCEDURES:
ON A SEPARATE PAGE, ATTACH A DIAGRAM SHOWING THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S):
Attach Additional Sheets As Necessary

FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRED FOR ALL SOURCES)
REVISED 12/01101 NCDENRIDivision of Air Quality -Application for Air Permit to ConstructlOperate
EMISSION SOURCE DESCRIPTION: IEMISSION
SOURCE ID NO: GS-RS-1
CONTROL DEVICE ID NO(S): C4
OPERATING 5CENARlO
EMISSION POINT (STACK) 11) S}: C•4 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out agglomoraled and fine material from blending process.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM Bl-B9 ON THE FOLLOWING PAGES):
Coal,wood,oil, gas, other burner (Form Bt) Ij Woodworking (Form BQ C j Manufact. of chemicals/coatingstinks (Form 07)
❑ Int combustion onginelgenerator (Form B2: [Coatinglrtnisiiingfprinting (Farm B5) ❑ Incineration (Form 138)
[]Liquid storage tanks (Form 133) DSImage stlos/bins (Form B6) X Other (Form B9)
START CONSTRUCTION DATE: JOPERATION DATE: JDATE MANUFACTURED:
MANUFACTURER / MODEL NO.: I EXPECTED OR SCHEDULE: _-._.-_.. HRIDAY _ _ DAYIWK WK/Y
IS THIS SOURCE SUBJECT TO? NSPS(SUBPART?):—N_ NESHAP (SUBPART7):_,N_ MACT (SUBPART?):^N_
PERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION; 6240
VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
.::S,,;U•,.tn5}ar.,:.:> ;�;y'r::;1r,:Hs :;:=.,:.
,_...,':-•,.-xr<..CliITER.gAfI2:pQLL,TAINT.,-:E(y1/SSlO
-
SliVFIaRMe?i'T/OIV:FQft7hl�S,Sf)vow_;i<=„•,;:-....
- ,z,_>Yi(:,;::;;S;Sci'
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
Iblbr
lonslyr
Ib1hr
tans! r
Iblhr
Ions! r
PARTICULATE MATTER (PM)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<10 MICRONS (PMI.)
Best Engineering Judgement
1.00E-04
3.12E-04
1'00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER�2.5 MICRONS (PM,,,)
SULFUR DIOXIDE (SO2)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
a >-I ' 'HAIR. UO S AlR°POI
LUiA. TM S$IONS;'.(NFORINgTIOI
EQR
h;
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS !LIMITS) (AFTER CONTROLS/LIMITS)
Iblhr
tonslyr
Iblhr
tonslyr
Ibihr
tonslyr
:�:,c;:;::;='iti��'::v.%y{.,:.+;:;::c;;>.::.•.o:;':x:;;?.. ..r-.
,;,;;-;,<::,:..,.,�.•;, ;; �% ,.-;.: , TOX1G AIR=P,.O��t1TAh(T
.. ,
Ely1('S$!ON$ INFORMA,.
TlON
, : :. - SY::r ?,a�zi:;�:i� �J<r>'.':�=:,<?Y' :in,'::;,•'i:
FORTN,IS S„Q_URCE , .... _::. .: ,<..<. ,,;.:. -�:� �'::,::
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO,
EF SOURCE
lb/hr I Iblday lb/yr
Manganese
Source Test
See Facility Wide Emissions Summary (Forth 01) for TAP evaluation
Marcury
Source Test
Set, Facility Wide Emissions Summary (Form 04) for TAP evaluation
Attachments: (1) emissions calcutallons and supporting docunrcntanon; (2) indicale all requested stale and federal enforceable permit Emits (e.g. hours of operation, emission rates) and
describe how those are monitored and wilt whal frequency; and (5) de
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE 81 THROUGH 89 FORM FOR I=AGH SOURGE
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
REVISED, 12/01/01 NCDENR/Divislon of Air Qualitv • Application for Air Permit to Construct/Op.erate. B9
EMISSION SOURCE DESCRIPTION: Sizing Screen
EMISSION SOURCE ID NO: GB-RS-1
CONTROL DEVICE ID NO(S) C-4
OPERATING SCENARIO: 1 OF __,_,_.1
EMISSION POINT (STACK) ID NO(S): C 4 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Sizing screen used to separate out agglomerated and fine materials from blending process.
MATERIALS ENTERING PROCESS - CONTINUOUS PROCESS
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE
UNITS
Alkaline dry cell batteries
tons
5
None
MATERIALS ENTERING PROCESS - BATCH OPERATION
MAX. DESIGN
CAPACITY (UNIT/BATCH)
REQUESTED CAPACITY
LIMITATION (UNITIBATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHES/HOUR):
REQUESTED LIMITATION (BATCHES / HOUR): (BATCHES/YR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE;
IREQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:
Attach Additional Sheets as Necessary

FORM B
SPECIFIC EMISSIONS SOURCE INFORMATION (REQUIRE® FOR ALL SOURCES)
REVISED 12/01/01 NCDENR/Division of Air Quality -Application for Air Permit to Construct/Operate B
EMISSION SOURCE DESCRIPTION: Hammer Mill
EMISSION SOURCE ID NO: GB-HM-1
CONTROL DEVICE ID NO(S): C-4
OPERATING SCENARIO 1 OF 1
EMISSION POINT (STACK) ID NO(S): 0-4 Stack
DESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAM):
Agglomerated pieces of fertilizer product are pulverized.
TYPE OF EMISSION SOURCE (CHECK AND COMPLETE APPROPRIATE FORM B1-139 ON THE FOLLOWING PAGES):
❑ Coal,wood,oil, gas, other burner (Form B1) ❑ Woodworking (Form B4) ❑ Manufact. of chemicalslcoatingslinks (Form B7)
❑ Inl.combustion enginelgenerator (Form B2: ❑ Coating/finishing/printing (Form 135) ❑ Incineration (Form B8)
❑ Liquid storage tanks (Form B3) ❑ Storage silos/bins (Form 136) X Other (Form 139)
START CONSTRUCTION DATE: OPERATION DATE; DATE MANUFACTURED:
MANUFACTURER / MODEL NO.: EXPECTED OP. SCHEDULE: __ HR/DAY _ DAYIWK WK/Y
IS THIS SOURCE SUBJECT TO? NSPS (SUBPART?):�N NESHAP (SUBPART?):�NT MACT (SUBPART?): N
PERCENTAGE ANNUAL THROUGHPUT (%)-. DEC-FEB 25 MAR -MAY 25 JUN-AUG 25 SEP-NOV 25
EXPECTED ANNUAL HOURS OF OPERATION: 6240
VISIBLE STACK EMISSIONS UNDER NORMAL OPERATION: % OPACITY
..ate t-.:¢,��s.
.�=:.�-:..... - �.=�,�._^.:•,--._ •:CRlTERA-�A1R AN:T�EM .1..
;`'w•::;.. �;
$. U.
AIR POLLUTANT EMITTED
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
Ib/hr
tons/yr
Ib/hr
tonslyr
Ib/hr
tonslyr
PARTICULATE MATTER (PM)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<10 MICRONS (PM,o)
Best Engineering Judgement
1.00E-04
3.12E-04
1.00
4.38
1.00E-04
4.38E-04
PARTICULATE MATTER<2.5 MICRONS (PM2.6)
SULFUR DIOXIDE (S02)
NITROGEN OXIDES (NOx)
CARBON MONOXIDE (CO)
VOLATILE ORGANIC COMPOUNDS (VOC)
LEAD
OTHER
s.� :�,�< ?P...' 1 O S
A oU�AI OL- • U T:E .S ..� ..N
NF . RMA_.
TIONl=OR•=T.IS..�SUU
�
C -
R ;:A::= -
HAZARDOUS AIR POLLUTANT AND CAS NO.
SOURCE OF
EMISSION
FACTOR
EXPECTED ACTUAL
(AFTER CONTROLS/LIMITS)
POTENTIAL EMSSIONS
(BEFORE CONTROLS/LIMITS) (AFTER CONTROLS/LIMITS)
ib/hr
tonslyr
Iblhr
tonslyr
Iblhr
tonslyr
None
,:.,..:;,.,.::.:.:�_-_:_ „ ...:...,. - .• .OL-LUTAN:T�
N . MISSIONS) A> .1
FO . . _N
INDICATE EXPECTED ACTUAL EMISSIONS AFTER CONTROLS I LIMITATIONS
TOXIC AIR POLLUTANT AND CAS NO.
EF SOURCE
Ib/hr I lb/day Ib/yr
Manganese
Source Test
See facility wide emissions on form D-1 for TAP Evaluation
Mercury
Source Test
See facility wide emissions on form D-1 for TAP Evaluation
Attachments: (1) emissions calculations and supporting documentation; (2) indicate all requested state and federal enforceable permit limits (e.g. hours of operation, emission rates) and describe
how these are monitored and with what frequency; and (3) describe any monitoring devices, gauges, or lest ports for this source.
COMPLETE THIS FORM AND COMPLETE AND ATTACH APPROPRIATE Q1 THROUGH S9 FORM FOR EACH SOURCE
Attach Additional Sheets As Necessary

FORM B9
EMISSION SOURCE (OTHER)
ne.nomn eemain, ruenVtirarn—lainnofate03milty-AnnlicationfarAirPermittoConstruct/Operate 139
EMISSION SOURCE DESCRIPTION: Hammer Mill
EMISSION SOURCE ID NO: GB-HM-1
CONTROL DEVICE ID NO(S C4
OPERATING SCENARIO: 1 OF 1
EMISSION POINT (STACK) ID NO(S): C-4 Stack
DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM):
Agglomerated pieces of fertilizer product are pulverized.
MAX. DESIGN
CAPACITY (UNIT/HR)
REQUESTED CAPACITY
LIMITATION(UNIT/HR)
TYPE I
UNITS
Agglomerated pieces of fertilizer product
tons
5
None
Me Ar�cp �5.1.� N {�
C�YTIrR�tY�,i' ..ri!..�.1: A'fGH Q.P
f�t,1 i_, ,'
MAX. DESIGN
CAPACITY (UNITIBATCH)
REQUESTED CAPACITY
LIMITATION (UNIT/BATCH)
TYPE
UNITS
MAXIMUM DESIGN (BATCHESI HOUR):
REQUESTED LIMITATION (BATCHES I HOUR): (BATCHES/YR):
FUEL USED:
TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR):
MAX. CAPACITY HOURLY FUEL USE:
REQUESTED CAPACITY ANNUAL FUEL USE:
COMMENTS:

FORM C1
CONTROL DEVICE (FABRIC FILTER)
olnf..:..,--.. -9 At. Ann11—Hnn fnr Air P-4 to f nnctninVOnnratn I C1
GB-HM-1, SS-3, G13-RS-1,
CONTROL DEVICE 10 NO: C-4
CONTROLS EMISSIONS FROM WHICH EMISSION SOURCE ID NO(S): E-1
EMISSION POINT (STACK) ID NOISY
POSITION IN SERIES OF CONTROLS NO. 1 OF 1 UNITS
MANUFACTURER:
MODEL NO:
DATE MANUFACTURED:
PROPOSED OPERATION DATE.
PROPOSED START CONSTRUCTION DATE:
1 OF
P.E. SEAL REQUIRED (PER 20.0112)? X YES NO
_1^
DESCRIBE CONTROL SYSTEM:
One bagfiller (5184 fe of filter area)
POLLUTANT($) COLLECTED: PM
BEFORE CONTROL EMISSION RATE (1,81HR): 38.00
CAPTURE EFFICIENCY: 100 % % %
CONTROL DEVICE EFFICIENCY: 99.99 %
CORRESPONDING OVERALL EFFICIENCY: 99.09 % % % %
EFFICIENCY DETERMINATION CODE; 2
TOTAL EMISSION RATE (LBMR): 3.80E-03
PRESSURE DROP (IN. H20): MIN: MAX: GAUGE? 4 YES 4 NO WARNING ALARM? d YES 4 NO
BULK PARTICLE DENSITY (1-13l17T3):
JINLET TEMPERATURE (°F); MIN MAX
POLLUTANT LOADING RATE: 4 LBJHR 4 GRlFT'J
I OUTLET TEMPERATURE (°F): MIN MAX
INLET AIR FLOW RATE (ACFM):
FILTER MAX OPERATING TEMP. (°F):
NO. OF COMPARTMENTS:
NO. OF BAGS PER COMPARTMENT:
LENGTH OF BAG (IN.):
DIAMETER OF BAG (IN.):
DRAFT: 0 INDUCED/NEG. t7 FORCEDIPOS.
FILTER SURFACE AREA (FT2):
AIR TO CLOTH RATIO: IFILTER MATERIAL: 4 WOVEN d FELTED
DESCRIBE CLEANING PROCEDURES:
4 AIR PULSE 4 SONIC SIZE WEIGHT% CUMULATIVE
4 REVERSE FLOW 4 SIMPLE BAG COLLAPSE (MICRONS) OF TOTAL
4 MECHANICAUSHAKER 4 RING BAG COLLAPSE 0-1
4 OTHER 1-10 100
DESCRIBE INCOMING AIR STREAM:
10-25
_
25-50
Particulates from drying of grinded up alkaline dry cell batteries
50-100
>100
TOTAL = 100
METHOD FOR DETERMINING WHEN TO CLEAN:
4 AUTOMATIC d TIMED 4 MANUAL
METHOD FOR DETERMINING WHEN TO REPLACE THE BAGS:
d ALARM P, INTERNAL INSPECTION d VISIBLE EMISSION 4 OTHER
SPECIAL CONDITIONS:
4 MOISTURE BLINDING 4 CHEMICAL RESISTIVITY 4 OTHER
EXPLAIN:
DESCRIBE MAINTENANCE PROCEDURES:
ON A SEPARATE PAGE, ATTACH A DIAGRAM SHOWING THE RELATIONSHIP OF THE CONTROL DEVICE TO ITS EMISSION SOURCE(S):
Attacn Aaalttonat meets Hs Necessary

i
RIBBON BLENDER (FP-9)
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
5.00
Emission Factor
Ibs PM / ton Process =
0.70
Uncontrolled Emissions PM
Ib/hr =
3.50
Ibs/year =
21,840
tons/year =
10.92
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
3.50E-04
Ibs/year =
2.18
tonslyear =
1.09E-03
hrs/year =
Process Rate (tons/hr) _
Emission Factor
Ibs PM / ton Process =
Uncontrolled Emissions PM
Ibs/hr =
Ibs/year =
tons/year =
Controlled Emissions PM
Fabric Filter Efficiency (%) _
Ibs/hr = 3
Ibs/year =
tons/year = 1
-PM Emission Factor Source: NCDENR industrial & Agricultural Chemicals, Inc. (lAQ Air Permit Review March 11,
2004, Application No. 7800188.02A
ons
'artii
P (tons/hr) = 5.00
Allowable emission rate (lb/hr) _ E = 4.10(P) 0.67
12.05 lb PM/hr
Note-, PM is assumed to equal PM10
i
0
5.00'.
0.701
3.50
30,660
15.33
99.991

s
Estimated Emissions from Modification
Industrial and Agricultural, Inc.
t Red Springs, NC
HAMMERMILL (GB-HM-1)
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
6.00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
lb/hr =
1.00
Ibs/year =
6,240
tons/year =
3.12
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
Ibs/year =
0.62
tons/year =
3.12E-04
Potential Emissions
Operation
hrs/year = 8760
Process Rate (tons/hr) = 5.001
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ibs/hr =
1.00
Ibs/year =
8,760
tons/year =
4.38
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
Ibs/year =
0.88
tons/year =
4.38E-04
-PM Emission Factor Source: NCDENR Industrial & Agricultural Chemicals, Inc. (IAC) Air Permit Review March 11,
2004; Application No. 7800168.02A
15A NCAC 213.0515 (Particulates from Miscellaneous Industrial Processes}
P (tons/hr) = 5.00
Allowable emission rate (lb/hr) = E = 4.10(P) 0.67
12.05 lb PM/hr
Note: PM is assumed to equal PM10
I

I
SCREENER (GB-RS4)
Expected Actual Emissions
Operation
hrs/shift =
8
shifts/day =
3
days/week =
5
weeks/year =
52
hours/year =
6240
Process Rate (tons/hr) =
5,00
Emission Factor
Ibs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ib/hr =
1.00
Ibs/year =
6,240
tons/year =
3.12
Controlled Emissions PM .
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
ibs/year =
0,62
tons/year =
3.12E-04
Potential Emissions
Operation
hrs/year =
8760
Process Rate (tons/hr) =
5.00
Emission Factor
lbs PM / ton Process =
0.20
Uncontrolled Emissions PM
Ibs/hr =
1.00
Ibs/year =
8,760
tons/year =
4.38
Controlled Emissions PM
Fabric Filter Efficiency (%) =
99.99
Ibs/hr =
1.00E-04
lbs/year =
0.88
tons/year =
4.38E-04
-PM Emission Factor Source: NCDENR Industrial & Agricultural Chemicals, Inc. (IAC) Air Permit Keview Marcn 7 7,
2004; Application No. 7800168.02A
ons
'arb
P (tons/hr) = 5.00
Allowable emission rate (lblhr) = E = 4,10(P) 0.67
12.05 lb PM/hr
Note: PM is assumed to equal PM10
I
a

FORM D9
FACILITY -WIDE EMISSIONS SUMMARY
REVISED 12/01/01 NCDENR/Division of Air Quality -Application for Air Permit to Construct/Operate DI
?•,>�;>=t:a:;': ... ::..: ......... .. .�,RlT�RIA,AIR,POLI,U7'�1NT;�MISSIONS,sINFORMA'!'l�E�.,
PI!iC!(.I'ilf{NID�r w„<• .
EXPECTED ACTUAL EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(BEFORE CONTROLS/
LIMITATIONS)
POTENTIAL EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
AIR POLLUTANT EMITTED
tonslyr
tonslyr
tonslyr
PARTICULATE MATTER (PM)
2.32
803.41
37.93
PARTICULATE MATTER < 10 MICRONS (PM1e)
2.32
420.81
18.90
PARTICULATE MATTER < 2.5 MICRONS (PM2.5)
2.32
420.81
18.90
SULFUR DIOXIDE (S02)
<1
50.3
50.3
NITROGEN OXIDES (NOx)
<1
0.15
0.15
CARBON MONOXIDE (CO)
<1
3.54
3.54
VOLATILE ORGANIC COMPOUNDS (VOC)
<1
14.2
14.2
LEAD
OTHER
:. ;HxARpoU ,gIR:P041»il¢�la
l EAfl S$IQN$:i(VUINt„ TION
FA I� TY WIDE
EXPECTED ACTUAL EMISSIONS
(AFTER CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(BEFORE CONTROLS /
LIMITATIONS)
POTENTIAL EMISSIONS
(AFTER CONTROLS 1
LIMITATIONS)
HAZARDOUS AIR POLLUTANT EMITTED
CAS NO.
tonslyr
tonslyr
tons/yr
,_--
-
INDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS. EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (TPER)
IN 15A NCAC 2Q .0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM 02 IF NECESSARY.
Modeling Required ?
TOXIC AIR POLLUTANT EMITTED
CAS NO.
Iblhr
lb/day
lb/year
Yes
No
Manganese
7439-96-5
0.02
X
Mercury
7439-97-6
0.001
X
COMMENTS:
Facility -wide uncontrolled potential emissions estimated by adding the uncontrolled potential emissions from the new sources proposed in this application to the
existing facility -wide uncontrolled PTE presented in NCDENR's air permit review document 3/11104.
Attach Additional Sheets As Necessary

Air Toxics Emission Review

Alkaline Battery Process Emissions
Industrial & Agricultural Chemicals
Red Springs, NC
Delta Project No. SE080-5063-P
Caleiner Emissions
Typical batch size = 12,000 Ibs
j Typical batch time = 2 hrs
Dust emission factor = 7 ft/ton
Mfg, design removal efficiency _ 99.99 %
I Weight percent Mn in dust = 20 %
Max. possible wt. % I-Ig in dust — 0.005 % (50 ppm)
Quantity of dust emitted from process (lbs) = Batch size (lbs) / Hatch time (hrs) / 2,000 lbs/ton x. Emission factor (71bs/ton)
Quantity of dust emitled from process (lbs) = 12,000 lbs / 2 hrs / 2,000 x 7
Quantity of dust emitted from process 21 lbs/hr (uncontrolled)
99.9% of the dust is retained in the dust collector, while the remaining 1% is emitted.
j Quantity of dust emitted through dust collector (lbs) 21 lbs/hr x 0.000
Quantity of dust emitted through dust collector D.00 lbs/hr
Manganese
j The dust contains approximately 20% Manganese
i Aourly Mn emission rate (lbs/hr) -, 0.00 lbs/hr x 0.20
Hourly Mn emission rate •= 0.000 lbs/hr
Calculate daily emission rate for TPFR comparison
Daily Mn emission rate (lbs/day) -=- 0.000 lbs/hr x 24 hrs/day
Daily Mn emission rate = 0.010 lbs/day
Calculate yearly emission rate
Yearly Mn emission rate (lbs/year) 3.679
Mew
The dust could contain up to approximately 0.008% Mercury
Hourly Hg emission rate (lbs/hr) = 0.00 lbs/hr x 0.005
Hourly Hg emission rate = 1.0513-05 lbs/hr
Calculate daily emission rate for TPER comparison
Daily fig emission rate (lbs/day) - 1.05E-05 lbs/hr x 24 .hrs/day
Daily I-fg emission rate = 0,000 lbs/day
Calculate yearly emission rate
Yearly Hg emission rate (lbs/year) : 0.092
I
I

i
Rotary Dryer Emissions
'typical batch size = 100,000 lbs
} Typical batch time = 6 his
Dust emission factor = 7 lbs/ton
Mfg, design removal efficiency = 99.99 %
Weight percent Mn in dust = 5 %
j Max. possible wt. % fig in dust = . 0.00S % (50 pp-)
Quantity of dust emitted from process (lbs) = Batch size (lbs) / Batch time (lus) ! 2,000 lbs/ton x Emission factor (7 lbs/ton)
Quantity of dust emitted from process (lbs) = 100,000 lbs / 6 tars / 2,000
l Quantity of dust emitted from process 58 lbs/hr (uucontrolled)
99.9% of the dust is retained in the dust collector, while the remaining 0.01 % is emitted.
Quantity of dust emitted through dust collector (lbs) =- 58 Ibs/hr x 0.000
Quantity of dust emitted OR ongh dust collector = 0.01 lbs/hr
Manganese
The dust contains approximately 5% Manganese
Hourly Mn emission rate (lbs/hr) = 0.01 lbs/hr x 0.050
Hourly Mn emission rate = 0.000 lbs/fir
Calculate daily emission rate for TPBR comparison
Daily Mn emission rate (lbs/clay) = 0.000 lbs/ln• x 24 brs/day
Daily Mn emission rate = 0.007 lbs/day
Calculate yearly emission rate
[ Yearly Mn emission rate (lbs/year) 2.555
i
Mercru
The dust could contain up to approximately 0.008% Mercury
k Hourly 11g emission rate (lbs/hr) = 0.01 Ibs/hr x 0.005
f Hourly fig emission rate = 2.92E-05 lbs/hr
Calculate daily emission rate forTPliR comparison
Daily fig emission rate (lbs/day) 2.92E-05 lbs/hr x 24 hrs/day
Daily fig emission rate = 0.001 lbs/day
Calculate yearly emission rate
Yearly fig emission rate (lbs/year): 0.256
Regulatory Comparison
NCDENR DAQ Emission Rate for Permitting =
0.63 lbs Mn /clay
NCDENR DAQ Emission Rate for Permitting —
0.013 lbs fig/day
"See 15A NCAC 02Q0711
Combined Mn emissions from this process =
0.02 lbs/day
Combined I"Ig emissions from this process =
O.00I lbs/day
Is compliance demonstrated ? YES
x 7

Mercury Analysis of Batteries

t
>..,..Waters Agricultural Laboratories, Inc.
f Fertilizer Analph.v Report
�* P.O. Bvi 382 * 2S7 iV won 7l'ig/nvrcy * Can,1114, IU4,orgfej 3173&o3s2 *]MOne. ('229) 3$6-7216
st►sp ro: �-�—
INDUSTRIAL AG
2042 BUIEPHIL ROAD
RED SPRINGS, NC 28377-
01.0wer: Ildl7USTRIAL AG
Tt'-'3
Lab Ntunbe6
Claimed Content:
Mercury _ 0,04 ppnl
Results Reported On W=WETIAS�RECEiVEOIeA$lS
"D v,4,-�Qv
Date Submitted: 9/15/2008
Report Cate: 9116/2008
This document may be reproduced only in its entirety. Waters Agricultural oboratories has no Control over thZ n)dnner In Which sanij)* 5re
taken, therefore, analysis is based solely on the sample as received. Lab liabillty Is limited to the fee assessed on the referenced sample.

Y
FROM FAX 18 189.E 01:35Al''l F1
Waters .A,grieiaittxra i�abt�rataries, Inc.
Fertilizer Analysis Report
! P.A. lfax 3S2 'A 2S7 iMpis-twi 111glrmarp * Cewillla, Cenrglu 31790-0.382 'phone: (229) 336•7216
Sl�ip'l o: Ovowor. INDUSTRIAL AG
INDUSTRIAL AC Sa<nplgNcunbece -�"� �Y��'
2042 BUIEPHIL ROAD Date Submitted: 9198/2008
RED SPRINGS, NO 28377- Lab Number: gpg7 Report Date; 9/1612008
Claimed (:oriteat:
0
Mercuryr_ f 0.036 PPrn
Results Reliorted On W�WET(AS RECLfVED)flAStu8
Rentiirks
This document may be reproduced only in its entirety. Waters Agricultural Laboratories has no control over the manner in which samples are
taken, therefore, analysis is based solely on the sample as received. (.ab liability Is Ilmitad to the fee assessed on the referenced sample.

ATRaF."
Aft
dft�
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor Division of Air Quality William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
11 August 2008
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Randall Andrews
Safety Manager
Industrial & Agricultural Chemicals, Inc.
2042 Buie Philadelphus Road
Red Springs, NC 28377
SUBJECT: Notice of Violation — Failure to Maintain Inspection and Maintenance Records,
and
Permit Additional Information — Battery Recycling Operation
Industrial & Agricultural Chemicals, Inc. Permit No. 06125R09
Red Springs, North Carolina, Robeson County 06/78-00168
Dear Mr. Andrews:
On 31 July 2008, Steven Vozzo, Mitchell Revels, and Christy Richardson, of the Fayetteville Regional
Office, conducted an annual compliance inspection of Industrial & Agricultural Chemicals, Inc. in Red Springs, NC.
During the inspection, Mr. Revels and staff observed that records were not adequate for the bagfilter and scrubber
inspections. Also, during the inspection, we observed a small-scale trial run of the battery recycling operation for
which the facility has submitted a permit application. Additional information will be required prior to permitting
this process. The violation and requirement for additional permit information are described below.
(1) Notice of Violation - for Failure to Maintain Inspection and Maintenance Records.
During the inspection, Mr. Andrews was not able to provide complete inspection or maintenance records for the
bagfilters (ID Nos. C-1, CD-FPB-3, C-4, CD-FPB-2, C-5, and DA-2) and aqueous contact scrubbers (ID Nos.
D-3 and D-4). Specific Condition and Limitation A.13. of Air Permit No. 06125R09 states that your facility
shall perform periodic inspection and maintenance as required by the manufacturer for the bagfilter and scrubber
systems. The specific condition also requires that your facility perform an annual internal inspection of each
bagfilter and scrubber system. It appears that some inspections may have been done, but documentation was
limited. Since records did not indicate that annual inspections had been performed on the control devices listed
above, Industrial & Agricultural Chemicals, Inc. is in violation of this regulation.
Additionally, other record keeping appeared not to be kept up to date. Suggestions were made to you during the
inspection conference on ways to improve your record keeping system. This office also understands that you
are preparing the requested updated process diagram for your facility. Since much of your operation is a batch
process, records are needed on daily and even hourly production. This information will be imperative in order
to renew your air permit in the next six months.
Fayetteville Regional Office - Division of Air Quality One
225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5043 No>t thCarolina
Phone: [phone] Fax: [phone] Internet: http://www.ncair.org
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper Natutrallp,

Industrial & Agricultural Chemicals, Inc.
Notices of Violation / PAI —11 August 2008
Page 2
(2) Permit Additional Information regarding the Alkaline Battery Recycling Operation.
During the inspection, a trial run of the alkaline battery recycling operation was performed. Following this
observation, and after conducting further research, it appears that additional information will be required in
order to process your permit application for an alkaline battery recycling facility. This office is concerned
that all the emissions have not been evaluated. The following items/concerns should be addressed:
• Detailed description of how your facility plans to eliminate all plastic materials prior to drying;
• Detailed process flow diagram of the battery recycling operation;
• An analysis of all emissions generated or emitted during this process (including emissions from inherent
mercury) and toxics demonstrations if required.
• Detailed description of the emission controls your facility plans to use to control these emissions
Your permit application will remain on hold until you and your consultant address the additional concerns
and submit a completed permit application. Please note that the alkaline battery recycling operation is not on
your current air permit and should not be operated until an air permit has been issued.
Please submit a .written response to this Office by 27 August 2008 as to actions taken to bring about
compliance and any additional information or description of any mitigating circumstances in reference to the
violation. The response should outline steps that you plan to take or have taken to return to compliance. As stated
above, your permit application for a battery recycling facility will not be processed until a complete permit
application, addressing the additional items of concern, is submitted.
As stated in the "subject" above, this letter represents a Notice of Violation for the recordkeeping issues
observed on 31 July 2008. The above violation and any future violation of an air quality regulation are subject
to the assessment of civil penalties as per North Carolina General Statute 143-215.114A. This General Statute
provides that civil penalties of not more than twenty-five thousand ($25,000) may be assessed against any
person who violates any classification, standard, or limitation established pursuant to General Statute 143-
215.107, "Air Quality Standards and Classifications." In addition, each day of continuing violation after written
notification from the Division of Air Quality shall be considered a separate offense. In addition, please refer to
the enclosed Pollution Prevention/Small Business insert for further information if you need assistance.
The Division strongly recommends that you carefully examine your current permit stipulations and request
explanation from this Office as necessary. We appreciate your prompt attention to these matters. If you have any
questions regarding this matter or if we can provide any additional information or assistance, please call Christy
Richardson, Environmental Engineer, at [phone], or me at [phone].
Sincerely,
Steven F. Vozzo
Regional Air Quality Supervisor
Enclosure — Pollution Prevention Brochure
SFV/ctr
cc: DAQ Central Files
FRO County Files

Page 1 of 1
Print - Maps
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610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Telephone: [phone]
Fax: [phone]
To:
From: 0,
� �'35-)'L�3
�'i-p -I) Watt
❑ Urgent at -or Review ❑ Please Comment ❑ Please Reply ❑ Please Recycle

RE: ALCHEM Civil Penalty Appeal
1
Subject: RE: ALCHEM Civil Penalty Appeal
From: "Leach, Janet" <[e-mail]>
Date: Fri, 20 Apr 2007 11:10:45 -0400
To: "Ellen Huffman" <[e-mail]>
If you and PDF a copy of the CPA to me via email, that would be great. If not, fax
it at 716-6766. Then place a copy of the entire file in the snail mail. Thanks
much. Don't forget to let me know the potential witnesses and their titles.
-----Original Message-----
From: Ellen Huffman­-fZna1l to:ellen.huf-fm cmai1.netI
Sent: Friday; April 20, 2007 8:19 AM
To: Leach, Janet
Subject:f'Re: ALCHEM Civil Penalty Appeal
L,_)
Hello Janet--�--w-rote--the assessment. I just got beck in the office. I
can fax , email, snail mail you a copy. Which you you prefer?
Ellen in MRO.
Leach, Janet wrote:
On March 22, 2007, we received an appeal from the above -subject violator.
issued a civil penalty assessment dated February 20, 2007 to Alchem citing
violations of NC Gen. Stat. § 143-215.1(a)(6) and Part I.1 and II.3 of DWQ
WQ0016338 at 8135 Red Road, Rockwell, NC.
DWQ
alleged
Permit
We need the file and a list of potential witnesses. If they are the same as the
petition for the Permit, I have that list. However, I do need the assessment as
soon as possible.
Please pass this on to the proper source. Thanks much.
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
C.
q
1 of 1 oo
i/ 4/20/2007 3:44 PM

RE: Alchem
Subject: RE: Alchem
From: "Leach, Janet" <[e-mail]>
Date: Fri, 20 Apr 2007 16:07:42 -0400
To: "Ellen Huffman" <[e-mail]>
Thanks, but I need a signed copy. If you could fax a copy, that would
be fine. Anytime we ask for documents with signatures on them, we need
the signed copy for court purposes. The PDF allows you to scan the
document and email the signed copy to us. If your office is incapable
of scanning, then, we will need you to fax it to us. I am sorry if I
confused you before. If you could fax me a copy on Monday, that would
be great. Thanks again and have a nice weekend.
-----Original Message -----
From: Ellen Huffman [mailto:ellen.huffman@ncmail
Sent: Friday, April 20, 2007 11:25 AM
To: Leach, Janet
Cc: andrew pitner
Subject: Alchem
net
Janet,
Please note that the NOV is dated Dec. 20, 2006 and the assessment is
Feb. 20, 2007.
Ellen Huffman
Environmental Specialist II
North Carolina Dept. of Environment & Natural Resources
Aquifer Protection
610 East Center Avenue
Mooresville, NC 28115
Ph: 704.663.1699 Fax: [phone]
1 of 1 4/20/2007 4:19 PM