NCGNE1312_Application_20180913

K -1
"ZI.
t nvtronmentat
Quaiit r
Division of Ener*,, Mineral and Land Resources
Land Quality Section
National Pollutant I-Ascliarge Elintinaitort System
hr�it,ahk �c �sr: f,rrl.Y
i I Mic Kcxtwcd
t clli(lu1lu of ('oe era'r
Ni) vArk)SI<.�RI: C. ER I" HC A f iUN for F\c
' ECEIVED
NCGNE(fOQ4
SEP 13 2030
ftl 2 0
I
National Pollutant Discharge Elimination System application for exp EN, MJGatter Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for sformwater discharges associated with industrial activity in the State of North Carolina because
if qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery., raw materials, intermediate products, by-products, final products, or waste products,
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling, and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each faciliw 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. 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:
httgs://deg.nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land permits/stormwater-
For questions, please contact the DEMtR 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 Corin
Contact ECO -Energy, LLC -
Street Address 6100 Tower Circle, Suite 500
City i ra—HE -- --state T ZIP Code 37067
Telephone No. 615 7$6-0401 Fax: [phone]
Page 1 of 7
CWI I-NnnNF 1 aat rovicarl QJ?R!?(liR

NCGNEOOOO No Exposure Certification
2) Location of facility producing discharge:
Facility Name Eco -Energy Charlotte LLC
Facility Contact
Street Address
City
County
Telephone No,
Alan Porter
6816 CSX Way
Charlotte — State NC- ZIP Code 28214, ---,--
Mecklenburg
980 365-6928
Fax: na /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,orn 1.85, TaKe Exit 34 onto Freedom Drive North, row(ardS Mt Holly (NC ­ 27)
Drive approximately 1.8 mites and turn n9rit onto ToddWle Road, Drive approximately O,6 codes and turn lett onto G1,iX Way Facility is jocaieo on the left..atbat 6CSXV1;ay
(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? 0 Yes( No
5) Is this a Federal facility? 0 Yes jd 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:
0 New or Proposed Facility Date operation is to begin
13 Existing Date operation began December 2017
C3 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
$10 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 facility is the transfer of
ethanol from rail car to the Kinder Morgan Terminal located west of the facility
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
No
0 Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
qW1 1.Nr.r.NF= Page 2 of 7 Inqt r"'Impri Q/9R19(11r,

NCGNEOOOO No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where 13 Yes 0 No [I N/A
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
0 Yes
'0 No
0 N/A
c. Materials or products from past industrial activity
0 Yes
pt No
0 N/A
d. Material handling equipment (except adequately maintained vehicles)
0 Yes
K No
0 N/A
e. Materials or products during loading/un loading or transporting activities
0 Yes
14 No
E3 N/A
f. Materials or products stored outdoors (except final products intended for outside
0 Yes
No
13 N/A
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 YesNo
YX
0 N/A
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained [I Yes PO No 0 N/A
by the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., 0 Yes 0 No 0 N/A
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes fil No 0 N/A
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents 0 Yes R No 0 N/A
not otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored 0 Yes Vd No 0 N/A
(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 13 Yes )M No 0 N/A
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 N/A
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Ll Yes E-7 No N/A
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
.;W1 WrANF I ;act ravmori QOA/901 R

NCGNEO000No Exposure Certification
a. Is secondary containment provided for single above ground storage containers
0 Yes
0 N PN/A
(including drums, barrels, etcjwith acapacity ofmore than @6O'gal|one?
b. Is secondary containment provided for above ground storage containers stored
[]Yeo
0 N M
in close proximity to each other with eoombined capacity ufmore than 1,320 -
gallons?
c.|asecondary containment provided for Title III Section 3138uperfund
[3 Yes
0 N KNA\
Amendments and Reauthorization Act (8ARA) water priority chernicals*?
d.|osecondary containment provided for hazardous substances"designated in
E] Yes
ONo 1A N/A
�
4OCFR §118?
e. Are release valves on all secondary containment structures locked?
0 Yes
0 No P N/A
15) Hazardous Waste-,
a. Is this facility aHazardous Waste Treatment, Storage, orDisposal Facility? MYes ;(No 0 N/A
b.hnthis facility aSmall Quantity Generator (less than 10OOkg. cdhazardous MYem )#No El N/A
waste generated per month) ofhazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste MYao 0 N 13 N/A
generated per month) ofhazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of
waste:
How ismaterial stored:
Where ksmaterial stored:
_________
How many disposal shipments per year:
Name oftransport /disposal
vendor:
Vendor address:
Footnotes hoQuestions 14Qn. &dL
*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
"Note that amounts below the GGO-gyakm(single) and 1.320igeUmn(combinod)bulk storage minimums require
secondary containment. However, some exceptions may bemade for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16@Other information: Ifyou answer "Yem'toany oYthe following items, you might not beeligible for the
nwexposure exclusion. u`more In-depth evaluation afthe site circumstances may berequired.
Page 4cd7
mm//.mnnmF /°�t,"."~~^nORM,n

NCGNE0000 No Exposure Certification
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside?
b. Uoes 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? Please 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:
O Yes No O N/A
Ej Yes 'K No O N/A
p Yes (No O N/A
1;q Yes Q No O N/A
Oyes JONO Q N/A
Page 5 of 7
SWU-NCGNE Last revised 9128/2016

NCGNEOOOO No Exposure Certification
17) Certification:
i certify under penalty of law that i have read and understand the eligibility requirements for claiming a condition of -no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified 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 -Recertification form at least once
each year and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). 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 qualifies for a No Exposure Exclusion i understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted, Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information. the information submitted is to the best of my knowledge and belief true, accurate and complete, I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Mr Chadwick Conn
Title: VP
(Signature of Applicant) r syneleIIY
Please mote: 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 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 filed or required to be maintained under this Article or a rule implementing this Article, or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or rnethod required to be operated or maintained under this Article or rules of the
]Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10.000)
There is currently no fee for a No Exposure Exclusion, i
Page 6 of 7
sw+ r-ninnNF i acs rani-wi oi9mmir,

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.
UEMLR 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
G1An I-N(,nNF I act rovicari Q/9R/9MR

X
EI
01
?
a R
Q c ? }
w
c
}
Y
V
L
CN
W
'
m
Z
O
CL
ob
E
N
Vul
U
it
¢
U
w
y
Q
O

W
Q
J
z
D
W
H
O
00
U
Q
U
Q
0
J
Q
r
rri
Q
O
N
�
Q
M
H
O
OM
M
J
F_
rZ
r --
rn
z
O
a
LO
J
O
U
J
H
U
IN
Q
W
W
10�
r
I I
Q
,r
N
J
O
X
m
O
�Iq
w
U
D
Q
O
U)
�
O
W
EL
Q
Q
z
W
Q
J
z
D
I Scale: NTS
Drawn By:
Checked By
LaI
Lv
♦—
of
z
Lv
U -
z
O
UU')O
3:Lo LL
o - I- L
W
F_
U
Q
U
Q
0
Z
O
Q
O
Q
M
Q
M
W
OM
M
J
O
O
rZ
r --
rn
LO
O
H
IN
W
r
Q
,r
m
O
U
D
U)
X
O
p
Q
Q
0
VO
w
Q
0�
LL
a
Q
w
w
O>
Q
Q
J
D
D
W
W
O
O
LU
a.
Q
Q
Q
Q
o
W
W
M
O
0
Z)
LuIL
g
O
I Scale: NTS
Drawn By:
Checked By
LaI
Lv
♦—
of
z
Lv
U -
z
O
UU')O
3:Lo LL
o - I- L
I I VIM)/i`\i
\\\\ l61, \(\I \\\\\\\\\ tc
O O
� I _
y �llA
LL
LU U ?' \ V
J
O
Q
20
W
,I
LU
> Q /
Q mO \
W W j
� LU W
co \
O z X
W U
> Q z
Lu
W
w
z Q' X '/
Z) LL W
CO
2016
Chambers Engineering, PA
SJS 129 North First St., Albemarle, NC 28001 704-984-6427
NCBELS Firm License No. C-1660
SJS
w Q
\ Xz
EL 0
m
J
Post -Construction Development
Eco Energy Distribution - Charlotte, NC
Intermodal Ethanol Transfer Facility
PROJECT NO: 2015-945
SHEET
2
IN
r
,r
I I VIM)/i`\i
\\\\ l61, \(\I \\\\\\\\\ tc
O O
� I _
y �llA
LL
LU U ?' \ V
J
O
Q
20
W
,I
LU
> Q /
Q mO \
W W j
� LU W
co \
O z X
W U
> Q z
Lu
W
w
z Q' X '/
Z) LL W
CO
2016
Chambers Engineering, PA
SJS 129 North First St., Albemarle, NC 28001 704-984-6427
NCBELS Firm License No. C-1660
SJS
w Q
\ Xz
EL 0
m
J
Post -Construction Development
Eco Energy Distribution - Charlotte, NC
Intermodal Ethanol Transfer Facility
PROJECT NO: 2015-945
SHEET
2

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 2038
D3 N.R-LAND 011 ALITY
STORrMV'1ATER FE.RMlTTING
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 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 EMP.
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 grave{ 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 systerrr and drainage dilches would hold approximately
1.000,006 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 [e-mail].
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