NCGNE1312_COMPLETE FILE - HISTORICAL_20181227

---STORMWATER DIVISION CODING SHEET
RESCISSIONS .
PERMIT NO.
DOC TYPE
CXCOMPLETE FILE -HISTORICAL
DATE OF
.RESCISSION
ol
YYYYMMDD

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
December 27, 2018
Eco-Energy, LLC
Attention: Mr. Chadwick Conn
6100 Tower Circle, Suite 500
Franklin, Tennessee 37067
Subject: No -Exposure Certification NCGNE1312
6816 CSX Way
Charlotte, North Carolina 28214
Dear Mr. Chadwick Conn:
ROY COOPER
Governor
MICHAEL S. REGAN
,ticcn7um
S. DANIEL SMITH
brieri»l U+rec7ur
The Division of Energy, Mineral and Land Resources has reviewed your submittal of the No -
Exposure Certification form for Exclusion from NPDES Stormwater Permitting. Based on your
submittal and signed certification of no exposure at the above referenced facility, and the
inspection dated December 6, 2018, this Division is granting your conditional exclusion from
permitting as provided for under 40 CFR 122.26(g), which is incorporated by reference in North
Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to
maintain no -exposure conditions at your facility. If conditions change such that your facility can
no longer qualify for a No -Exposure exclusion, you are obligated to immediately obtain NPDES
permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to
enforcement as an unpermitted discharge.
You must self re -certify your No -Exposure status annually and the form can be downloaded by
visiting the following web page for the Division of Energy, Mineral and Land Resources
Stormwater Program:
littp:,;'/portal.ncdetit-.org/wel)/Ir/iipde,s-,storiiiN,N,,aier
The annual self re -certification does not need to be submitted to DEMI.R unless requested. A
copy should be maintained in your file.
Your conditional exclusion from permitting does not affect your facility's legal requirements to
obtain environmental permits that may be required under other federal, state, or local regulations
or ordinances.
State of Norilt Carolina � Frivironmental Quality `Fnerp, Minen l and Land Resources
Mooresville Regional Office 1 610 East Center Ave Ste 301 ` Mooresville, NC 28115
704 663 1699 '1'

Eco-Energy, LLC
NCGNE1312
December 27, 2018
Page 2 of 2
If you have any questions or need further information, please contact Ms. Angela Lee at (70 4)
663-1699, or at angela.lcc' %,ficdetir.gov.
Sincerely,
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
AL
Enclosure: Inspection Report
Annette Lucas, Stormwater Permitting Program, No- Exposure files NCGNE1312

Compliance Inspection Report
Permit: NCGNE1312 Effective: Expiration: Owner: Eco-Energy LLC
SOC: Effective: Expiration: Facility: Eco-Energy Charlotte LLC
County: Mecklenburg 6816 Csx Way
Region: Mooresville
Charlotte NC 28214
Contact Person: Alan Porter Title: Phone: [phone]
Directions to Facility:
From 1-85 take exit 34 onto Freedom Dr N towards Mt Holly (NC27). Right onto Toddville Rd drive 1 mile and turn left onto CSX way.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 1210612018 EntryTime: 11:00AM Exit Time: 11:50AM
Primary Inspector: Angela Y Lee Phone: [phone]
Secondary Inspector(s):
James D Moore Phone
Chris E. Graybeal
Reason for Inspection: Other Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page: 1

permit; NCGNE1312 Owner - Facility:Eco-EnergyLLC
Inspection Date: 12/0612018 Inspection Type : Technical Assistance Reason for Visit: Other
Inspection Summary:
The site was inspected due to a request for a No Exposure certification. Alan Porter was present for the inspection. A lock
on the discharge valve was placed. Per the inspection, it is found that the site qualifies for the No Exposure Certification.
Page: 2

Permit: NCGNE1312 Owner - Facility;Eco-EnergyLLC
Inspection Date: 121067201 S Inspection Type : Technical Assistance Reason for visit: Other
Page: 3

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Division of F.nErp-, llinernl and Land Resources E.,.,1, i P0 ;
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NO FX110SURF CERTIFICATION' ION' for 1'ACi�s�"1u��
Ln�Quulienrr�f NCGNE0000 f 1jj+�+• I �{ ED
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National Pollutant Discharge Elimination System application for ex� QFIV^•I 4s r '°
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SSo f�a irfts#er Permit eased
on NO EXPOSURE: 14 y"� - r ili�1I77111,G
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 all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff. `
I
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 materil intermediate ,product, final product or waste prodtWi. 'A 'sf& i 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 satt).
A No Exposure Certification must be provided for each facili qualifying for the no exposure exclusion. In
addition, the exclusion from NPOES permitting is available on a facility -wide basis only ---not for individual
outfalls, It 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-;rertiiication under the No Exposure section on this page:
htfos:/dgg nc_gov/about/divisioiis.eneLgy mineral-land-resourcesieneryy-miner_ai-[arrd•pesmuslstormwater-
For questions, please contact the DEMLR Regional Office for your area. (See page 6) — J
(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,
6100 Tower Circle, Suite 500 -
Street Address _
Franklin TN 37067
City State ZIPCode _,.W
Telephone No. 616 786-0401 -- --- ---- Fax: [phone] _
1;Vdi I.1E Y' tm:
Page I of 7
12

NCGNEOOOO No Exposure Certification
-2) • -Location of facility producing discharge: _...:._.... w__._..._-- _ .... -._... _...., _. _ _. .. ._...._ _ .._ -
Facility Name Cca-Cnergy Charlotte I.LC
Facility Contact Alan Porter
Street Address 6816 CSX Way
City Charlotte State N� ZI P Code 28214
County Mecklenburg
Telephone No. 980 . 365.6928 _ Fax: n%a . n/a�
3) Physical location Intormation:
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 intersectionl, FrDm 1.85. Take Extl?4 onin rreecom Drive PJorltt_towgra� Mt. HORV tNC-27r
Drive appsowna.ely 1.8 nxiti ar;,i bum right onto T0Wvllle HoaA, Ot;ve. trrNrroiisrrvl9iy u 6 miles and rum lest MG i;S x %Vey. Facility rs iocateo on the fah al -391 ri C5X 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?© Yes No
5) Is this a Federal tacility? © Yes Id No
6) Latitude N35°16' 23.3904" Longitude 'N50°55' 23,5632' (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
New or Proposed Facility Date operation is to begin
a Existing Date operation began December 2017
© Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater. Permit? 0 Yes 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: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 facitity 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)?
19 No
13 Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Page 2 of 7
RM I-rJj;r NF 3 tar rn,rivori Q!9p19rt1r

NCGNE0000 No Exposure Certification
Exposure Checklists (1Z - 14.1
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 p Yes * No p NIA
c. Materials or products from past industrial activity
❑ Yes
pj No
© NIA
d. Material handling equipment (except adequately maintained vehicles)
© Yes
No
❑ NIA
e. Materials or products during loadingiunloading or transporting activities
❑ Yes
No
❑ N/A
t. Materials or products stored outdoors (except final products intended for outside
❑ Yes
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,
0 Yes
¢ No
GI NIA
tanks, and similar containers
h, Materials or- products handled/stored on roads or railways owned or maintained ❑ Yes K No ©N/A
by the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., 0 Yes 0 No 0 NIA
dumpsters])
j. Application or disposal of process wastewater (uNess otherwise permitted) 0 Yes JO No 0 NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents 0 Yes tO No ❑ NIA
not otherwise regulated (i.e., under an air quality control permit) and evident inthe
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored ❑ Yes 1W No 0 NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m_ For any exterior ASTs, as weil as drums. barrels, tanks. and similarcontainers ❑ Yes 'K No ❑ 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 0 Yes 0 No I$ NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? if so, is it free of any 0 Yes Di No )( 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.
Page 3 of 7
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NCGNE0000 No Exposure Certification
a. Is aecorvdary+containment.prouided for single above ground storage containers
0 YesT
f:7 No 1 NIA
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
17 Yes
No N/A
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. is secondary containment provided for Title III Section 313 Supertund
p Yes
13 No NIA
Amendments and Reauthorization Act (SARA) water priority chemicals'?
d. Is secondary containment provided for hazardous substances" designated in
p Yes
p No NIA
40 CFR §116?
e. Are release valves on all secondary containment structures locked?
© Yes
p No IONIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
p Yes ;(No p NIA
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous
M Yes ll� No © NIA
waste generated per month) of hazardous waste?
c. Is this facility large Quantity Generator 0000 kg. or more of hazardous waste
E3 Yes > No (3 NIA
generated -par -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 / 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 minimts 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 66d-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts tress than the Reportable
Quantities of the hazardous substances Ilsted 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
CWI1.NrrNr aai eau car;GPial7njr

NCGNEOOOO No Exposure Certification
a. Uoes your facitity store used, recycled, or otherwise reclaimed pallets outside?
b. Does your facility have coal piles on site?
c. Does your facility store other fuel sources outside in piles, such as wood chips,
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e,g.,
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
Permit? Ptease specify:
f. Please list any other environmental program permits (federal, state. etc:) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: DWR# 16-1000 Program, NCDEQ 401 Permit
Permit: SAW-2014-00640 Program: ACQE 404 Permit
Permit: Program:
Permit: Program:
Permit Program:
Permit: Program:
Permit: Program:
Page 5 of 7
SWU-NCGNE
Oyes *No a NIA
[]Yes J& No a NIA
p Yes �K No O NIA
]PqYes U No O NIA
© Yes i� No 12 NIA
Last revised 9iMO 16

M.
NCGNEOOOO No Exposure Certification
17) Certification;
I certify under penalty of law that I have read and understand the eligibility requirements for daimina a condition of -an
exposure' and obtaining an exciutsion from NPOES stormwater permitting.
I certify under penalty of taw that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified in this document (except as allowed under 44 CFR 122,26(g)(2))
I understand that I am obligated to maintain no exposure conditions and gg_rrlplete_a,%yLEL 2rtiiicatton format least since
eagh veer and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy. Mineral, and Land Resources. or M54 operator where the discharge is Into the local MS4, to perform inspections
to contitm 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 quatifies for a No Exposure Exclusion. I understand that i must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the intormation 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 tamiliar with the information contained. in this, application and that to the best of my,knowiedge,and belief .......... ......,......
such information is true, complete, and accurate.
Printed Name of Person Signing: Mt Chadwick Conn
Title. VP _
(Signature of Applicant)
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 than approval. The Regional Office may also Inspect your
facility at any time in the future for compliance with the No Exposure Exclusion,
North Carolina General Statute 143.215.6 B(i) provides that,
Any person who knowingly makes any false statement, representation, or certification in any application record, report. plan, or other
document tiled or required to de meintalneo under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material tact in a ruiesnaking proctwa N of congested case under this Article: or who laisdies, tampers arid, or knowingly
renders inaccurate any recording or monitoring oaviae or methoo required to be operated or maintained under this Articte or ruses of trle
(Environmental Managements Commission impfement;ng this Article shall t:e guilty of a Ciaw 2 misdemeanor which may include a fine
not to exceW ten thousand dollars ($I0.00c).
There Is currently no fee for a No Exposure Exclusion,
Page 6 of 7
Gwi i.Nr:rNF rovldiM or:)R MJA

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.
n 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.
DEMLH 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
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DATE!'�.
December 2017
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EXISTING IMPERVIOUS AREA CALCULATION)
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TOTAL ON SITE
EX. IMPERVIOUS AREA
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IMPERVIOUS AREA ADDED
5,78 AC
IMPERVIOUS AREA TOTAL
5.78 AC
TOTAL AREA
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TOTAL AREA, LESS FRED AL EXANDER BLVD AREA
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-----
7.65 ACRES, Tc=8.5 MINS -
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MINS

Michelle M. Brown
Environmental Consultant
igio Haiiifaa Court
High Point, NC 27265
g161834-6532
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:
RL ,:jVF--
STQR"%"!A"ATER FzR ,11T7-1NG
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 hours of the rail cars arrival at the facility.
The railcars are each connected to individual hoses during the offloading process; the cars are
not tethered together, thus isolating each rail car as an individual container. Each rail car is
inspected prior to connecting the off-loading hoses.
The facility 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 4011404 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
26 August 2018
Eeo•Energy Charlotte No Exposure Certification
Page 2of2
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 MirhelleM6ro:vr%aplom
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