NCGNE1312_COMPLETE FILE - HISTORICAL_20180913

NORTH CAROLINA
Department of Environmental Qua

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----- -------_-_-____�
STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
tP- HISTORICAL FILE
DOC DATE
ab I% D q / --�)
YYYYMMDD

I,,itr It,ccned
Divi+ion of Energy, iltineral and Land Resources
1C. -Land Quality Section I I 1
National Pollutant Discharue Elimination Svstcrtt ` I� i
EnvironmentalQ!
No EXPOSURE; cER'nFICATION' for EACIR CEIVED
NCGNE0000 tJ
Quality SEP 13
201d
National Pollutant Discharge Elimination System application for ex 0�r 3ti '`'fa S &MWater Permit based
on NO EXPOSURE: ' v'V4A,%RERMiTTING
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means aft
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
industrial materials or activities include, but are not limited to: material handling equipment or activities,
Industrial machinery, raw materials, intermediate products, by-products, final products, or waste products,
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only --not for Individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
Please look for information about re -certification under the No Exposure section on this page:
https://deo,ng.Clov/about/divisions/energy-mineral-land-ro§ources/energy-mineral-land-permits/stormwater-
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Chadwick Conn
Contact Eco-Energy, LLC 0
Street Address 6100 Tower Circle, Suite Soo
City Fran In _ State TN ZIP Code 37067
Telephone No, 615 786-0401 Fax_ 615 778-2897
Page i of 7
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NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Eco•Energy C,hariotte LLC
Facility Contact Alan Porter
Street Address 6816 CSx way
City Chartotte State NC ZIP Code 28214
County Nteaklennurg
Telephone No, 980 365-6928 Fax: n/a n/a
3) Physical location information:
Please provide a narrative description of how to get to the facility {use street names. state road numbers, and
distance and direction from a roadway intersection). F,ur, 1•85. Take Em 34 onto FIei.�uom Onvo Nortrt, towwo$ hit. Holly- INc-27�.
Drmo Opp axaaa" IS arts and Uon rgnt alto Toaavute Road. Owe *Mommwely 0.6 "sand :Um lest onto CSx way, Faplrty is tocmea on Ina tan, at 016 CS)k Way.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands?C] Yes No
5) Is this a Federal facility? ❑ Yes 1d No
6) Latitude N35016 23.3904" Longitude w80°55' 23.5632" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
G New or Proposed Facility Date operation is to begin
13 Existing Date operation began December 2017
p Renewal of existing No Exposure Certification Certification No,: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater. Permit? ❑ Yes Of No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 5 1 7 1
10) Provide a brief description of the types of Industrial activities and products produced at this facility -
The primary business associated with the Eco-Energy Charlotte facility is the transfer of
ethanol from rail car to the Kinder Morgan Terminal located west of the facility via a pipeline.
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
*No
0 Yes
It yes, list the permit numbers for all current Non -Discharge permits for this facility:
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NCGNEOOOO No Exposure Certification
Ex osure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes 0 No ❑ NIA
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes
'i No
O NIA
c. Materials or products from past industrial activity
❑ Yes
ga No
❑ NIA
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes
01 No
❑ NIA
e. Materials or products during loadinglunloading or transporting activities
❑ Yes
(A No
❑ NIA
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes
0 No
❑ NIA
use [e.g.. new cars] where exposure to stormwater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels,
❑ Yes
116 No
❑ NIA
tanks, and similar containers
h. Materials or products handledlstored on roads or railways owned or maintained a Yes V3 No ❑ NIA
by the discharger
i. Waste material (except waste in covered, non -leaking containers (e.g., ❑ Yes 01 No ❑ N/A
dumpsters))
j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes X No 0 NIA
k. Particulate matter or visible deposits of residuals from roof statics andlor vents ❑ Yes 0 No ❑ NIA
not otherwise regulated ({.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes 151 No ❑ NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers © Yes ANo ❑ NIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No P1 NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any t3 Yes 0 No k( NIA
cracks. holes, or evidence of leaks, and are drain valves maintained locked
shut?
14) Secondary Containment. If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
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AWi i.WANF I act rawkwl 00POMP

NCGNE0040 No Exposure Certification
a. is secondary containment. provided for single above ground storage containers ❑ Yes ❑ No NIA
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title Ill Section 313 Superfund El Yes O No NIA
Amendments and Reauthorization Act (SARA) meter priority chemicals'?
d. Is secondary containment provided for hazardous substances" designated in ❑ Yes q No NIA
40 CFR §116?
e. Are release valves on all secondary containment structures locked? ❑ Yes O No NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? p Yes ;( No ❑ NIA
b. Is this facility a Small Quantity Generator (less than 1000 kg, of hazardous © Yes No D NIA
waste generated per month) of hazardous waste?
c_ Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste O Yes No I] NIA
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of
waste:
How is material stored.
Where is material stored:
How many disposal shipments per year. -
Name of transport I disposal
vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more In-depth evaluation of the site circumstances may be required.
Page 4 of 7
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NCGNEOOOO No Exposure Certification
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? O Yes 'EA No O N!A
b. Does your facility have coal piles on site?
Q Yes 'R,No O N/A
c. Does your facility store other fuel sources outside in piles, such as wood chips,
O Yes ;( No to NIA
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g..
Yes 0 No [] NIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: offloading header purge of denatured ethanol
e. If you answered yes to d., are those emissions permitted by an Air Quality
O Yes No 13 NIA
Permit? Please specify:
I. Please list any other environmental program permits (federal, state, etc.} not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: DWR# 16-1000 Program: NCDEQ 401 Permit
Permit: SAW-2014-00640 Program: ACOE 404 Permit
Permit: Program:
Petmit: Program:
Permit: _ Program:
Permit: Program:
Permit: Program:
Page 5of7
S W U-NCC NE Last roviseel 9128)2016

NCGNE0000 No Exposure Certification
17) Certiflcatlon:
I certify under penalty of law that I have read and undarstand the eligibility requirements far cieiming a condition of -fie
exposure' and obtaining an exclusion from NPDES stormwater permitting,
I cettity under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identihed in this document (except as allowed under 40 CFR 122,26(g)(2))
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertificalion form at least once
eachyeaC, and it requested, provide this certification to the operator of ttte local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or MS4 operator where the discharge is into the local MS4, to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand I
must keep a Copy of annual re -certifications on file at the facility.
In the event that the site no longer qualities for a No Exposure Exclusion. I understand that I must obtain coverage under
an NPOES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualitied personnel properly gathered and evaluated the information submitted Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
Information, the information submitted is to the best of my knowledge and belief true. accurate and complete I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the Information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate
Printed Name of Person Signing; Mr Chadwick Cann
Tile: VP
i t •� f t>
(Signature of Applicant) (DRlo j� �ign
Please note; This application for the No Exposure Exclusion is subject to approval by the NCDEQ
Regional Office prior to issuance. The Regional Office may inspect your facility for compliance
with no exposure conditions prior to that approval. The Regional Office may also inspect your
facility of any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(l) provides that:
Any person who knowingly makes any false statement, representation or ceniticatlon in any application record, repon, plan, or other
document filed or required to be maintainea under I!M. Antcle or a rule implementing this Article; or who knowingly makes a false
statement of a malerw tact in a rulemakrng proceeding or contested case under this Article; or who falsities, tampers with, of knowingly
renders inaocuraie any recording or monitoring device or methoa required to be operated or maintained under this Article or rules of the
IFnwronmentat Management] Commission implementing this Article shall be guilty of a Class 2 misalemeanor which may include a fine
not to exceed ten thousand dollars ($10.000)
There is currentf no fee for a No Exposure Exclusion,
Page 6 of 7
Cwi r-Nr"r$NF' r atf rnv�aal Gr9pl�rti R

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office
... [phone]
Mooresville Office_
[phone]
Raleigh Office ........
[phone]
Washington Office
...[phone]
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........
[phone]
Page 7 of 7
.qw+ i.Nr:rNP 1 act rAwigPH WM9niR

Michelle M. Brown
Environmental Consultant
igio Halifax Court
High Point, NC 27265
g16/834-6532
28 August 2018
Laura Alexander
DEMLR — Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: Eco-Energy Charlotte No Exposure Certification
Dear Ms. Alexander:
RECEIVED
SEP 13 2018
DEN,R-LAND Q1jAI-ITY
STOR"NATER pERMITI.ING
Please accept the enclosed No Exposure Certification, submitted on behalf of my client, Eco
Energy Distribution Charlotte, LLC (Eco Energy Charlotte). The Eco-Energy Charlotte facility is
located at 6816 CSX Way, in Charlotte, North Carolina.
The primary business associated with the Eco-Energy Charlotte facility is the transfer of ethanol
from rail cars to the Marathon Terminal located west of the facility. All transfer operations will
be safely conducted as per applicable Pollution Prevention Regulations and the Operations
Manual. The facility follows a Spill Prevention, Control, and Countermeasures (SPCC) Plan and
maintains a Facility Response Plan, per 40 CFR 112.
Eco-Energy Charlotte was constructed in 2017 and began operations in December 2017. The
Eco-Energy Charlotte facility does not have aboveground storage tanks onsite. There is no
storage of hazardous materials at the facility and no maintenance activities take place
onsite.
Unit trains arrive at the facility approximately once each week and include up to 96 rail cars,
each loaded with 30,000 gallons of denatured ethanol. The ethanol is off-loaded to a pipe that
flows directly to the Kinder Morgan Terminal located west of the facility, and offloading is
generally completed within 24 fours of the rail cars arrival at the facility.
The railcars are each connected to individual hoses during the offloading process; the cars are
not tethered together, thus isolating each rail car as an individual container. Each rail car is
inspected prior to connecting the off-loading hoses.
The facility has less than 1.66 tons per year of VOC emissions related to rail car unloading
equipment purges of denatured ethanol. Because the facility is located in Mecklenburg County
and emissions are less than five tons per year, the facility is exempt from permitting. However,
the facility is registered as Air Quality Source R666 with the County and maintains compliance
with the registration.
The facility applied for and received Section 401/404 Permits from NC DEQ and the ACOE.
The construction included a Wet Pond BMP for maintaining onsite stormwater. The Wet Pond
BMP is located south of the rail yard and it does not receive any additional offsite flow. It was
constructed to store and treat runoff from the facility and control the peak discharge for the 2-

Ms. Laura Alexander
28 August 2018
Eco-Energy Charlotte No Exposure Certification
Page 2 of 2
year and 10-year 6-hour storm, and it was placed outside of the local designated stream buffer.
Please see the attached diagram that shows the facility layout, including the location of the rail
spur, the drainage system, and the constructed Wet Pond BMP.
Secondary Containment
Secondary containment was constructed at the facility in the rail car off-loading area, and
consists of a constructed drainage system that flows to drainage ditches via a gravel bed of
stone to the under drain, which is composed of perforated PVC pipes. The under drain is
sloped to the center of the rail spur from the north and south ends of the spur; thereby
transferring any accumulated liquid to the drainage ditches on each side of the rail spur. For all
practical purposes, the under drain system and drainage ditches would hold approximately
1,000,000 gallons. representing 33 — 30,000 gallon tanker cars.
A gate valve was installed to restrict the flow out of the rail car drainage system to the
constructed Wet Pond BMP. The valve is to be closed before train off-loading begins, and is
open otherwise. Any discharge of ethanol would thus be contained within the drainage ditches
along the rail spur. Rainfall that collects within this area while a train is in station is contained
and may be released to the drainage inlet by manually opening the closed and locked valve
after inspecting the accumulated water and determining that releasing it will not result in a
release of petroleum products. The facility maintains an inspection log that documents the
opening and closing of the gate valve.
If you have any questions, or require additional information, please feel free to contact me by
phone at [phone], or by email at MichelleMBrownC7a aol.com.
Thank you,
Michelle M. Brown
Environmental Consultant
Enclosures:
No Exposure Certification Application
Facility Site Map
Facility Post Construction Development Map
CC: Chad Conn. Eco-Energy
Alan Porter, Eco-Energy Charlotte
Stephen Chambers, P.E., Chambers Engineering, PA

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