5106_Blackwood_Airpermit_20190329

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL A. ABRACZINSKAS
Director
Mr. Ryan Conrad
Vice President
Blackwood Associates, LLC
699 West Dillman Road
Bloomington, IN 47401
NORTH CAROLINA
Environmental Quality
March 29, 2019
Subject: Air Permit No. 10312R02
Blackwood Associates, LLC
Newton Grove, Johnston County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 5100210
Dear Mr. Conrad:
In accordance with your completed application received March 4, 2019, we are forwarding
herewith Permit No. 10312R02 to Blackwood Associates, LLC, Newton Grove, Johnston County,
North Carolina for the construction and operation of air emissions sources or air cleaning devices
and appurtenances. Additionally, any emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the
records retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
Unless exempted by a condition of this permit or the regulations, construction of new
North Carolina Department of Environmental Quality I Division of Air Quality
�i Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, NC 27609
4 7f:tCN:iLNl4 ��
0"Allmmt of Brvke —ul owl ��""`� 919.791.4200 T 1 919.881.2261 F

Ryan Conrad
March 29, 2019
Page 2
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from March 29, 2019 until September 30, 2026, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
Facility name and ownership changed from West Farms — Shaving Mill to Blackwood
Associates, LLC.
Should you have any questions concerning this matter, please contact Elisabeth Nystrom at 919-
791-4200.
Sincerely,
/ I
T. Ray Stewa J ., E., CPM, Regional Supervisor
Division of Air uality, NC DEQ
AEN
Enclosures
c: Raleigh Regional Office

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 10312R02
Issue Date: March 29, 2019
Expiration Date: September 30, 2026
Effective Date: March 29, 2019
Replaces Permit: 10312ROI
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina (NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Blackwood Associates, LLC
1683 Barefoot Road
Newton Grove, Johnston County, North Carolina
Permit Class: Synthetic Minor
Facility ID# 5100210
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID Description
wood -fired fluidized bed burner (20 million
ES-2, ES-3 Btu/hour heat input, ID No. ES-2) connected CD-2 cyclone (96 inches in diameter)
to a rotary shavings dryer (1620 cubic foot
per hour capacity, ID No. ES-3)
in accordance with the completed application 5100210.19A received March 4, 2019 including any
plans, specifications, previous applications, and other supporting data, all of which are filed with the
Department of Environmental Quality, Division of Air Quality (DAQ) and are incorporated as part
of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter

Permit No. 10312R02
Page 2
2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0535, 2D .0540, 2D .1100, 2D .1806, 2Q
.0315 and 2Q .0711.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and (f). Pursuant to 15A NCAC 2Q
.0203(i), no permit application fee is required for renewal of an existing air permit (without
a modification request). The renewal request (with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202, pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2025 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the emission sources shall not exceed allowable emission rates. The allowable emission rates
are, as defined in 15A NCAC 2D .0515, a function of the process weight rate and shall be
determined by the following equation(s), where P is the process throughput rate in tons per
hour (tons/hr) and E is the allowable emission rate in pounds per hour (lbs/hr).
E = 4.10 * (P) 0-" for P <= 30 tons/hr, or
E = 55 * (P) 0- " - 40 for P >30 tons/hr
4. SULFUR DIOXIDE CONTROL REQUIREMENT -As required by 15A NCAC 213.0516
"Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the
combustion sources shall not exceed 2.3 pounds per million Btu heat input.
5. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six -minute period, except that six -minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with a visible emissions standard in 15A
NCAC 2D .0524 "New Source Performance Standards" or. I 110 "National Emission
Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521
visible emissions standard.
6. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,

Permit No. 10312R02
Page 3
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
7. FUGITIVE DUST CONTROL REQUIREMENT - As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints are received or excessive
fugitive dust emissions from the facility are observed beyond the property boundaries for six
minutes in any one hour (using Reference Method 22 in 40 CFR, Appendix A), the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas, process areas stockpiles, stock pile working, plant parking lots,
and plant roads (including access roads and haul roads).
8. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT - Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration, the
following permit limits shall not be exceeded:
Affected Source(s) Toxic Air Pollutant Emission Limit
Arsenic & Compounds (total mass of
elemental AS, arsine and all inorganic 3.85 pounds per year
compounds) (ASC (7778394))
!Nos.
burner/dryer (ID Benzene (71-43-2) 498.88 pounds per year
ES-2 and ES-3) Formaldehyde (50-00-0) 1.11 pounds per hour
r(7 Hy
drogen chloride (hydrochloric acid)
647-01-0) )9.12 pounds per day
Manganese & compounds (MNC) 0.77 pounds per day
9. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 15A
NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" the Permittee shall not
operate the facility without implementing management practices or installing and operating

Permit No. 10312R02
Page 4
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.
10. LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of
Section and Requirement for a Permit," as requested by the Permittee, facility -wide
emissions shall be less than the following:
Pollutant Emission Limit
(Tons per consecutive 12-month period)
PM10 100
VOC 100
CO 100
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. The throughput of oven dried shavings shall not exceed 23,450 tons per
consecutive 12-month period.
b. Inspection and Maintenance Requirements -
i. Cyclone Requirements - Particulate matter emissions shall be controlled as
described in the permitted equipment list. To comply with the provisions of
this permit and ensure that emissions do not exceed the regulatory limits, the
Permittee shall perform an annual (for each 12 month period following the
initial inspection) inspection of the cyclone system. In addition, the Permittee
shall perform periodic inspections and maintenance (I&M) as recommended
by the manufacturer.
c. Recordkeeping Requirements
i. The Permittee shall record monthly and total annually the following:
A. The throughput of oven dried shavings, and
B. The facility -wide PM-10, CO, and VOC emissions.
d. Reporting Requirements - Within 30 days after each calendar year, regardless of the
actual emissions, the Permittee shall submit the following:
emissions and/or operational data listed below. The data should include
monthly and 12 month totals for the previous 12 month period.
A. The throughput of oven dried shavings, and
B. The facility -wide PM-10, CO, and VOC emissions.
11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed

Permit No. 10312R02
Page 5
toxic air pollutants (TAPs), the Permittee has made a demonstration that facility -wide actual
emissions, where one or more emission release points are obstructed or non -vertically
oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q
.0711(a). The facility shall be operated and maintained in such a manner that emissions of
any listed TAPS from the facility, including fugitive emissions, will not exceed TPERs listed
in 15A NCAC 2Q .071 I (a).
a. A permit to emit any of the below listed TAPS shall be required for this facility if
actual emissions from all sources will become greater than the corresponding
TPERs.
b. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible
for obtaining a permit to emit TAPS and for demonstrating compliance with the
requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".
c. In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the
TPERs as listed below:
Pollutant
Carcinogens
(lb/yr)
Chronic
Toxicants
(lb/day)
Acute Systemic
Toxicants
(lb/hr)
Acute
Irritants
(lb/hr)
Acetaldehyde (75-07-0)
F—r
6.8
Acrolein (107-02-8)
0.053
6.02
Arsenic & Compounds (total mass of
elemental AS, arsine and all inorganic
compounds) (ASC (7778394))
Benzo(a)pyrene (Component of
83329/POMTV & 56553/7PAH) (50-
32-8)
2.2
Beryllium Metal (unreacted)
(Component of BEC) (7440-41-7)
0.28
Cadmium Metal, elemental, unreacted
(Component of CDC) (7440-43-9)
0.37
Carbon tetrachloride (56-23-5)
460
F—
Chlorine (7782-50-5)
F 0. 99
0.23
Chlorobenzene (108-90-7)
46
290
�—
Chloroform (67-66-3)
Chromium (VI) Soluble Chromate
Compounds (Component of CRC)
I
0.013
(SolCR6)
i
1DEHP (Di(2-ethylhexyl)phthalate)
(117-81-7)
FO.63

Permit No. 10312R02
Page 6
Ethylene dichloride (1,2-
dichloroethane) (107-06-2) 260
Hexachlorodibenzo-p-dioxin 0.0051
1,2,3,6,7,8 (57653-85-7)
MEK (methyl ethyl ketone, 2- I 78 F22.4
butanone) (78-93-3)
F(74
rcury, vapor (Component of HGC) 0.013
39-97-6)
Methyl chloroform (71-55-6) 1 250 I 1 64
Methylene chloride (75-09-2) 1600 0.39 F—
Nickel metal (Component of N1C)
0.13
(7440-02-0)
PCB (polychlorinated biphenyls)
(1336-36-3) 5.6
E
Pentachlorophenol (87-86-5) 0.063 0.0064 �—
P
(tetrachloroethylene) (127-18-4) erchloroethylene i 3QOQ F
Phenol (108-95-2)
Styrene (10042-5) �—
TCE (trichloroethylene) (79-01-6) 4000
Tetrachlorodibenzo-p-dioxin, 2,3,7,8-
(Component of CLDC & 0.Q002
83329/POMTV) (1746-01-6)
Tetrachloroethane, 1,1,2,2- (79-34-5) 430
0.24
2.7
Toluene (108-88-3) 1 1 98 1 1 14.4
Vinyl chloride (75-01-4) 26 F �—
Xylene (mixed isomers) (1330-20-7) 57 1 F-16.4

Permit No. 10312R02
Page 7
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS
REPORTS, TEST DATA, MONITORING DATA, NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
919-791-4200
For identification purposes, each submittal should include the facility name as listed on the
permit, the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years, unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a), the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities; or
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309, this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In

Permit No. 10312R02
Page 8
accordance with G.S. 143-215.108(c)(1), the facility shall be properly operated and
maintained at all times in a manner that will effectuate an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1), this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1), this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include, but is not limited to, process weight rates, firing rates, hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.11413, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. In accordance with G.S. 143-215.108(c)(1), this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State, or Local requirements
governing the handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and Recovery Act (RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - In accordance with 15A NCAC 2Q .0110, the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request, the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS - Pursuant to 15A NCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section I I2(r) of the Federal Clean Air Act, then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.

Permit No. 10312R02
Page 9
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases - Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces, processes, handles, or stores any amount of a listed
hazardous substance, the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally -enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance, the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval, regional notification, report submittal, and test
results approval. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the 291h of March, 2019.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
T. Ray Ste rt Jr., P.E., CP
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 10312R02

ATTACHMENT to Permit No. 10312R02, March 29, 2019
Insignificant / Exempt Activities
Source
rfES-1A - green wood chipper/shaver
(25 tons per hour capacity)
S-2A - green wood chipper/shaver
5 tons per hour capacity)
S-3A - woodwaste handling
Exemption
Regulation
Source of Source of Title V
TAPs? Pollutants?
2Q .0102 (h)(5) No
i
Yes
I2Q .0102 (h)(5)
No Yes
2Q .0102 (h)(5)
I No
J Yes
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP, NSPS, and NCAC rules may be found here:
htips:Hdeq. nc. gov/about/divisions/air-quality/air-quality-permits/specific-permit-conditions-
regulatory-wide