20070280 Ver 1_Application_20070216

69
SF'Al'~IGLER
ENVIRONMENTAL, It~tC.
2oo7o2so
Land Planning • Permitting • Environmental Consulting • Construction Management • Expert Testimony
February 16, 2007 ~, ~~ r
VIA HAND DELIVERY ~~~~ i ~~~ ~~T
/Ms. Cyndi Karoly, 401/Wetlands Supervisor 7 copies w/fee ($200) RECEIVED
NCDWQ Wetlands/401 Office
Crabtree Boulevard
1650 Mail Service Center
Raleigh, NC 27699-1650
Ms. Cynthia Vanderwiele, Express Review Coordinator Icopy
NCDWQ Wetlands/401 Office
Crabtree Boulevard
1650 Mail Service Center
Raleigh, NC 27699-1650
Mr. Ken Averitte 1 copy
NCDWQ Fayetteville Regional Office
225 Green Street
Suite 714
Fayetteville, NC 28301-5094
Mr. Ronnie D. Smith 3 copies
US Army Corps of Engineers
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, NC 28403
RE: E85 Ethanol Plant 404/401 PCN
Ladies and Gentlemen:
Please find attached the requisite number of copies of a PCN for less than 0.48 acres of permanent wetland impact in Fayetteville, Cumberland
County. There are no additional temporary or off-site impacts. This PCN is associated with a major economic development initiative and industrial
facility that will manufacture E85 ethanol fuel for the eastern United States. This will be the first plant of its kind in the eastern US, and a
groundbreaking ceremony is scheduled for the first week of April. We, as Agents for the Applicant, would appreciate the expeditious review and
approval/authorization of this PCN. Please contact me directly if you have any questions.
Sincerely,
Spangler E r mental, Inc.
Ja angler
President
Attachments
CC: Mark Dassel--E85, Inc.
Paul Jordan-NC Dept. of Commerce
Phyllis Owens-Cumberland Co. Business Council
Allan Campbell, PE-FruCon Engineering, Inc.
John Shady-Malcolm Pirnie Engineering
Gordon Rose, PE-McKim & Creed
224 Fayetteville. Street, Suite 400 P.O. Box 387 Raleigh, N.C. 27602 te1919-546-0754 fax [phone] toll free. 1-866-SPANGLER
3961-B Market Street Wilmington, N.C. 28403 te1910-343-9375 fax 910-34,3-8351 wwwspanglerenvironmental.com

85iC1C
February 12, 2007
To Whom It May Concern:
e85, Inc.
PO Box 560
Kingston, WA 98346
+1.360.297.7619 (P)
+1.360.297.7617 (F)
www.e85.us
This letter serves to inform you that E85, Inc. Optionee of property located on
approximately one hundred and fifty (150) acres of land located east of the Good Year
tire plant in Fayetteville, NC and further located on the immediate western boundary of
the CSX rail line authorizes Spangler Environmental, Inc. to act as our technical agent
for the purposes of environmental issues, including wetland and stream identification,
permitting, mitigation planning and regulatory agency coordination at the property known
as Cape Fear River Holdings, LLC property, and as shown in Cumberland County
records as tax parcel numbers 0541-68-6116 and 0541-66-3131. All site visits by
regulatory personnel must be coordinated in advance with our agent, Spangler
Environmental, Inc. This letter supersedes all previous Agent-related correspondence.
The following contact persons should be copied on all correspondence:
Property Optionee (Agent):
E85, Inc.
C/O Mark W. Dassel
PO Box 560
Kingston, WA 98346
360.297.7619 (O)
360.860.1787 (C)
Technical Agent:
James A. Spangler
Spangler Environmental, Inc
PO Box 387
Raleigh, NC 27602-0387
919-546-0754
Fax [phone]
Sincerely,
E85, Inc.
7 `~
Mark .Dassel
Senio Vice President and Director

,..
I~ F /
Office Use Only:
USAGE Action ID No.
RECEIVED
DWQ No.
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L 0 0 7 0 2 8 0
If any particular item is not applicable to this project, please enter "Not Applicable" or "N/A" rather than
leaving the space blank.
I.
II.
Processing
Check all of the approval(s) requested for this project:
Section 404 Permit
^ Section 10 Permit
401 Water Quality Certification
^ Riparian or Watershed Buffer Rules
2. Nationwide, Regional or General Permit Number(s) Requested: NWP 39 / GC 3402
3. If this notification is solely a courtesy copy because written approval for the 401 Certification
is not required, check here: ^
4. If payment into the North Carolina Ecological Enhancement Program (NCEEP) is proposed
for mitigation of impacts (see section VIII -Mitigation), check here: ^
Applicant Information
1. Owner/Applicant Information
Name: E85, Inc.
Mailing Address: C/O Mr. Mark Dassel, PO Box 560, Kingston, WA 98346
Telephone Number: 360-297-7619 Fax Number:
E-mail Address:dasse1.e85(cr~,~mail.com
2. Agent Information (A signed and dated copy of the Agent Authorization letter must be
attached if the Agent has signatory authority for the owner/applicant.)
Name: James A. Spangler
Company Affiliation: Spangler Environmental, Inc.
Mailing Address: PO Box 387, Raleigh, NC 27602
Telephone Number: 919-546-0754 Fax Number: 919-546-0757
E-mail Address:~pan~ler(a,span~lerenvironmental.com
Page 1 of 9

III. Project Information
Attach a vicinity map clearly showing the location of the property with respect to local
landmarks such as towns, rivers, and roads. Also provide a detailed site plan showing property
boundaries and development plans in relation to surrounding properties. Both the vicinity map
and site plan must include a scale and north arrow. The specific footprints of all buildings,
impervious surfaces, or other facilities must be included. If possible, the maps and plans should
include the appropriate USGS Topographic Quad Map and NRCS Soil Survey with the property
boundaries outlined. Plan drawings, or other maps may be included at the applicant's discretion,
so long as the property is clearly defined. For administrative and distribution purposes, the
USACE requires information to be submitted on sheets no larger than 11 by 17-inch format;
however, DWQ may accept paperwork of any size. DWQ prefers full-size construction
drawings rather than a sequential sheet version of the full-size plans. If full-size plans are
reduced to a small scale such that the final version is illegible, the applicant will be informed that
the project has been placed on hold until decipherable maps are provided.
1. Name of project: E85--100 MGY DENATURED ETHANOL PLANT
2. T.I.P. Project Number (NCDOT Only): N/A
3. Property Identification Number (Tax PIN): Cumberland Co. 0541-68-6116 and 0541-66-
3131
4. Location
County: Cumberland Nearest Town: Fayetteville
Subdivision name (include phase/lot number):N/A
Directions to site (include road numbers, landmarks, etc.): 401 North from Fayetteville.
Turn Right on Bethune Road, lust past Goodyear Plant. Site is at end of Bethune Road
5. Site coordinates, if available (UTM or Lat/L,ong):
(Note - If project is linear, such as a road or utility line, attach a sheet that separately lists the
coordinates for each crossing of a distinct waterbody.)
Describe the existing land use or condition of the site at the time of this application: Partially
wooded, majority recently clearcut. Undeveloped rural
6. Property size (acres): 150 acres +/-.
7. Nearest body of water (stream/river/sound/ocean/lake):UT to Cape Fear River
8. River Basin: Cape Fear (03030004)
(Note -this must be one of North Carolina's seventeen designated major river basins. The
River Basin map is available at http://h2o.enr.state.nc.us/admin/maps/.)
Describe the purpose of the proposed work: (See Exhibit 5) Construction of 100 million
~allon/year ethanol fuel (E85) production facility including 13 000 + linear feet of new rail
Page 2 of 9

r
line (dual loop plus rail ladder), rail ladder for on- and off-load of bulk materials above-
ground tank farm, automobile access fire-protection roads roadway infrastructure
improvements, storm water and utility infrastructure construction and industrial process
builin~s and infrastructure.
List the type of equipment to be used to construct the project: Mechanical
Describe the land use in the vicinity of this project:Adiacent land uses include Goodyear
Plant (industrial. Norfolk Southern rail line (industrial) and undevelopedlwooded/clearcut
industrial-zoned acreage. Rural/residential/farm acreage adioins parcel to be developed but
is separated by wetlands and wooded- pine stands from the proposed facility
IV. Prior Project History
If jurisdictional determinations and/or permits have been requested and/or obtained for this
project (including all prior phases of the same subdivision) in the past, please explain. Include
the USACE Action ID Number, DWQ Project Number, application date, and date permits and
certifications were issued or withdrawn. Provide photocopies of previously issued permits,
certifications or other useful information. Describe previously approved wetland, stream. and •
buffer impacts, along with associated mitigation (where applicable). If this is a NCDOT.project;
list and describe permits issued .for prior segments of the same T.LP. project; along with '
construction schedules.
Prior permits issued include NC Division of Air Quality Permit #09722R00• (Site Number
06/26/00221 (Attached as Exhibit 22) issued February 5 2007 Storm water permit and
wastewater pre-discharge permits are pending from Fayetteville PWC
V. Future Project Plans
Are any additional permit requests anticipated for this project in the future? If so, describe the
anticipated work, and provide justification for the exclusion of this work from the current
application: No other 404 permits or 401 certifications are anticipated for this project

Page 3 of 9

VI. Proposed Impacts to Waters of the United States/Waters of the State
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
wetlands, open water, and stream channels associated with the project. The applicant must also
provide justification for these impacts in Section VII below. All proposed impacts, permanent
and temporary, must be listed herein, and must be clearly identifiable on an accompanying site
plan. All wetlands and waters, and all streams (intermittent and perennial) must be shown on a
delineation map, whether or not impacts are proposed to these systems. Wetland and stream
evaluation and delineation forms should be included as appropriate. Photographs may be
included at the applicant's discretion. If this proposed impact is strictly for wetland or stream
mitigation, list and describe the impact in Section VIII below. If additional space is needed for
listing or description, please attach a separate sheet.
1. Wetland Impacts
Wetland Impact
Site Number
(indicate on ma
Type of Impact* Area of
Impact
acres Located within
100-year Floodplain**
es/no Distance to
Nearest Stream
linear feet
Type of Wetland***
A (Exhibit 10) Permanent_ 0.015 No >1,000 Forested wetland
B/C (Exhibit 7) Permanent 0.139 No >1,000 Forested wetland.
D_(Exhibit 8) Permanent ~ 0.318 No >1,000 Clear-cut (for. :wetland?)

0.~}1a. '
List eacn impact separately and identity temporary impact'3. Impacts include, but are not limited to: mechanized clearing, grading, fill,
excavation, flooding, ditching/drainage, etc. For dams, separately list impacts due to both structure and flooding.
** 100-Year floodplains are identified through the Federal Emergency Management Agency's (FEMA) Flood Insurance Rate Maps
(FIRM), or FEMA-approved local floodplain maps. Maps are available through the FEMA Map Service Center at 1-800-358-9616, or
online at http://www.fema.~.
*** List a wetland type that best describes wetland to be impacted (e.g., freshwater/saltwater marsh, forested wetland, beaver pond,
Carolina Bay, bog, etc.)
List the total acreage (estimated) of existing wetlands on the property: est. 18.5 acres
Total area of wetland impact proposed: 0.48 acres
2. Stream Impacts, including all intermittent and perennial streams
Stream Impact
Site Number
(indicate on ma)
Type of Impact* Length of
Impact
(linear feet)
Stream Name** Average Width
of Stream
Before Im act Perennial or
Intermittent?
leases eci )
None

Page 4 of 9

k List each impact separately and identify temporary impacts. Impacts include, but are not limited to: culverts and associated rip-ran.
dams (separately list impacts due to both structure and flooding), relocation (include linear feet before and after, and net loss/gain),
stabilization activities (cement wall, rip-rap, crib wall, gabions, etc.), excavation, ditching/straightening, etc. If stream relocation is
proposed, plans and profiles showing the linear footprint for both the original and relocated streams must be included.
** Stream names can be found on USGS topographic maps. If a stream has no name, list as UT (unnamed tributary) to the nearest
downstream named stream into which it flows. USGS maps are available through the USGS at 1-800-358-9616, or online at
www.usgs.gov. Several Internet sites also allow direct download and printing of USGS maps (e.g., www.topozone.com,
www.mapouest.com, etc.).
Cumulative impacts (linear distance in feet) to all streams on site: None
3. Open Water Impacts, including Lakes, Ponds, Estuaries, Sounds, Atlantic Ocean and any
other Water of the U.S.
Open Water Impact
Site Number
(indicate on ma)
Type of Impact* Area of
Impact
acres)
Name of Waterbody
(if applicable) Type of Waterbody
(lake, pond, estuary, sound
ba ,ocean, etc.)
None.' „ -

"` List each impact separately and identify temporary impacts. Impacts include, but are not limited to: fill, excavation, dredging,
flooding, drainage, bulkheads, etc.
4. Pond Creation
If construction of a pond is proposed, associated wetland and stream impacts should be
included above in the wetland and stream impact sections. Also, the proposed pond should
be described here and illustrated on any maps included with this application.
Pond to be created in (check all that apply): ^ uplands ^ stream ^ wetlands
Describe the method of construction (e.g., dam/embankment, excavation, installation of
draw-down valve or spillway, etc.): N/A
Proposed use or purpose of pond (e.g., livestock watering, irrigation, aesthetic, trout pond,
local stormwater requirement, etc.): N/A
Size of watershed draining to pond: N/A Expected pond surface area: N/A
VII. Impact Justification (Avoidance and Minimization)
Specifically describe measures taken to avoid the proposed impacts. It may be useful to provide
information related to site constraints such as topography, building ordinances, accessibility, and
financial viability of the project. The applicant may attach drawings of alternative, lower-impact
site layouts, and explain why these design options were not feasible. Also discuss how impacts
Page 5 of 9

were minimized once the desired site plan was developed. If applicable, discuss construction
techniques to be followed during construction to reduce impacts.
Seven different site plans were prepared and analyzed for wetland impacts (See Exhibit 14). The
preferred alternative achieves impact minimization in light of the following:
• railroad horizontal curve and vertical curve design constraints
• fire protection access road requirements
• provision for over 3.5 acres of storm water detention/treatment
• industrial facility grading design finish floor/conveyor connection/pumping and
operation constraints (see Exhibit 6)
• overhead utility line constraints (31 feet of vertical clearance and 15 feet of horizontal
clearance from both the 7,200 V South River EMC lines and the 1 Z.5 KV Progress
Energy Lines)
• automobile/truck traffic engineering design constraints (vertical and horizonatal design
seed curve radii andtraffic circulation/staging/parkin fg_ or separate bulk production
material trucks and employee vehicles).
Construction methods to minimize impacts include the following_
• accessing rail-crossing location via proposed fire protection access road.
THE ONLY IMPACTS ASSOCIATED WITH THE PREFERRED ALTERNATIVE ARE FOR RAIL
- L1NE CONSTRUCTION AND FIRE PROTECTION ROAD ACCESS TO THE RAIL~L'INE ON
SHARED ALIGNMENT. _ ~ ,, ; ,
VIII. Mitigation
DWQ - In accordance with 15A NCAC 2H .0500, mitigation may be required by the NC
Division of Water Quality for projects involving greater than or equal to one acre of impacts to
freshwater wetlands or greater than or equal to 150 linear feet of total impacts to perennial
streams.
USACE - In accordance with the Final Notice of Issuance and Modification of Nationwide
Permits, published in the Federal Register on March 9, 2000, mitigation will be required when
necessary to ensure that adverse effects to the aquatic environment are minimal. Factors
including size and type of proposed impact and function and relative value of the impacted
aquatic resource will be considered in determining acceptability of appropriate and practicable
mitigation as proposed. Examples of mitigation that may be appropriate and practicable include,
but are not limited to: reducing the size of the project; establishing and maintaining wetland
and/or upland vegetated buffers to protect open waters such as streams; and replacing losses of
aquatic resource functions and values by creating, restoring, enhancing, or preserving similar
functions and values, preferable in the same watershed.
If mitigation is required for this project, a copy of the mitigation plan must be attached in order
for USACE or DWQ to consider the application complete for processing. Any application
lacking a required mitigation plan or NCWRP concurrence shall be placed on hold as
incomplete. An applicant may also choose to review the current guidelines for stream restoration
in DWQ's Draft Technical Guide for Stream Work in North Carolina, available at
http://h2o.enr.state.nc.us/ncwetlands/strm~ide.html.
Page 6 of 9

1. Provide a brief description of the proposed mitigation plan. The description should provide
as much information as possible, including, but not limited to: site location (attach directions
and/or map, if offsite), affected stream and river basin, type and amount (acreage/linear feet)
of mitigation proposed (restoration, enhancement, creation, or preservation), a plan view,
preservation mechanism (e.g., deed restrictions, conservation easement, etc.), and a
description of the current site conditions and proposed method of construction. Please attach
a separate sheet if more space is needed.
Mitigation is not reauired for this project as impacts of less than 0.5 acre are proposed
However, all remaining wetlands inside the rail loop (approximately 14.2 acres) can be
placed into conservation easement dedicated to a third party or deed restriction prohibiting
future impacts to those remaining wetlands inside the rail loop can be recorded within 30
days of permit/certification issuance/coverage as a condition of approval Mitigation via this
method will include preservation of nearly 30:1, and enhancement/restoration within the
preserved area through natural seed recruitment of wetland areas clear-cut previous) a~ an
proximate ratio of 15:1. This mitigation is 100% on-site.
2. Mitigation may also be made by payment into the North Carolina Wetlands Restoration
Program (NCWRP) with the NCWRP's written agreement. Check the box indicating that
-- _ you would like to pay into the NCWRP. Please note that payment into the NCWRP must be
reviewed and approved before it can be used to satisfy mitigation requirements. Applicants
will be notified early in the review process by the 401/Wetlands. Unit if payment into the
NCWRP is available as an option. For additional information regarding the application
process for the NCWRP, check the NCWRP website at http://h2o.enr.state.nc.us/wro/index.htm. If
use of the NCWRP is proposed, please check the appropriate box on page three and provide
the following information:
Amount of stream mitigation requested (linear feet): None
Amount of buffer mitigation requested (square feet): None
Amount of Riparian wetland mitigation requested (acres): None
Amount ofNon-riparian wetland mitigation requested (acres): None
Amount of Coastal wetland mitigation requested (acres): None
IX. Environmental Documentation (DWQ Only)
Does the project involve an expenditure of public funds or the use of public (federal/state/local)
land?
Yes ^ No
If yes, does the project require preparation of an environmental document pursuant to the
requirements of the National or North Carolina Environmental Policy Act (NEPA/SEPA)?
Note: If you are not sure whether a NEPA/SEPA document is required, call the SEPA
coordinator at [phone] to review current thresholds for environmental documentation.
Yes ^ No
If yes, has the document review been finalized by the State Clearinghouse? If so, please attach a
copy of the NEPA or SEPA final approval letter.
Page 7 of 9

Yes ^ No
X. Proposed Impacts on Riparian and Watershed Buffers (DWQ Only)
It is the applicant's (or agent's) responsibility to determine, delineate and map all impacts to
required state and local buffers associated with the project. The applicant must also provide
justification for these impacts in Section VII above. All proposed impacts must be listed herein,
and must be clearly identifiable on .the accompanying site plan. All buffers must be shown on a
map, whether or not impacts are proposed to the buffers. Correspondence from the DWQ
Regional Office may be included as appropriate. Photographs may also be included at the
applicant's discretion.
Will the project impact protected riparian buffers identified within 15A NCAC 2B .0233
(Meuse), 15A NCAC 2B .0259 (Tar-Pamlico), 15A NCAC 2B .0250 (Randleman Rules and
Water Supply Buffer Requirements), or other (please identify )?
Yes ^ No ~ If you answered "yes", provide the following information:
Identify the square feet and acreage of impact to each zone of the riparian buffers. If buffer
mitigation is required calculate the required 'amount of mitigation by applying the buffer
multipliers.

Zone* Impact:.
(s uare feet) Multiplier Required
Miti ation
1 N/A 3,
2 N/A 1.5
Total N/A
* Zone 1 extends out 30 feet perpendicular from near bank of channel; Lone "l extends an
additional 20 feet from the edge of Zone 1.
If buffer mitigation is required, please discuss what type of mitigation is proposed (i.e., Donation
of Property, Conservation Easement, Riparian Buffer Restoration /Enhancement, Preservation or
Payment into the Riparian Buffer Restoration Fund). Please attach all appropriate information as
identified within I SA NCAC 2B .0242 or .0260.
N/A
XI. Storm water (DWQ Only)
Describe impervious acreage (both existing and proposed) versus total acreage on the site.
Discuss stormwater controls proposed in order to protect surface waters and wetlands
downstream from the property.
Impervious acreas?e: approximately 18.1 acres proposed. 0.0 acres existins;. Construction BPS
Lursuant to S/e Plan approved by NCDLR-LQS shall be implemented. Post-construction storm
water detention/retention treatment of approximately 3.8 surface acres is provided on the plan,
with adequate separation from wetlands for level-spreaders and vegetated buffers. No direct
discharge into wetlands or streams shall occur. Plans are pending_approval from PWC.
Page 8 of 9

XII. Sewage Disposal (DWQ Only)
Clearly detail the ultimate treatment methods and disposition (non-discharge or discharge) of
wastewater generated from the proposed project, or available capacity of the subject facility.
Diischarge into Fayetteville PWC existing infrastructure.
XIII. Violations (DWQ Only).
Is this site in violation of DWQ Wetland Rules (15A NCAC 2H .0500) or any Buffer Rules?
Yes ^ No
Is this anafter-the-fact permit application?
Yes ^ No
XIV. Other Circumstances (Optional):
It is the applicant's responsibility to submit the application sufficiently in advance of desired
construction dates to .allow. ,processing • time: for these permits. However, an applicant may
choose to list constraints. associated with construction or sequencing that may impose limits on .
work schedules (e.g., draw-down schedules for lakes, dates .associated with Endangered. and;
Threatened Species, accessibility problems,. or-other issues outside of the applicant's control):
This is a maior economic development project for Cumberland County and the- only plant of :its _
kind proposed in North- Carolina: This site is the only location within economically feasible ~•
distance from highway.: infrastructure (I-295 and I-95 are less than 2 miles- south) and rail
infrastructure (immediate)~adjacent); with adequate utility infrastructure in place, and with,.:
existing Industrial zoning in place. Negotiations with Norfolk Southern on minimum design
tolerances have limited the ability to further minimize impacts due to the rail. line. loop, and fire-
protection access to rail cars carr~g bulk ethanol fuel requires the construction of the fire
protection access road on alignment with the rail loop. The production facility and rail
infrastructure have been re-designed seven times to minimize and subsequently eliminate
wetland impacts. This site has recently been nearly completely clear-cut for silviculture)
purposes. Wetlands on the site are of low quality, with the exception of those that have not been
impacted by logging. Permits have been issued by other state re ug latorv agencies for this
facility.
2.15- c~7
Date
(Agent's signature is valid only if an authorization letter from the applicant is provided.) AGENT
AUTHORIZATION IS INCLUDED.
Page 9 of 9

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E85 404/401 PCN EXHIBIT 13
224 Fayetteville Street
Suite 400
SPANGLER P•0- Box 387
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919-546-0754 919-546-0757 Fax

E85 Fayetteville 404/401 PCN
Alternatives Considered /Impact Minimization Comparisons
Alternative # /Description /Impact
1 (Exhibit 15) Process facility optimally located adjacent to existing Norfolk Southern Rail line.
Minimal impervious area because of minimized roadway infrastructure.
TOTAL IMPACT 11.84 ACRES
1.1 (Exhibit 16) Facility moved inside rail loop to minimize wetlands impacts. Increase rail
impervious area. Requires that rail bridge over access roads. Radii of rail curves tighter than
allowable by Norfolk Southern. No off-load rail ladder, no fire protection. TOTAL IMPACT
3.04 ACRES
2 (Exhibit 17) Facility moved outside single rail loop. Increase impervious area by 40%. One rail
loop curve radius of rail loop tighter than allowable. Topographic features under plant site
necessitate large area-wide fill of wetlands. TOTAL IMPACT 2.39 ACRES
3 (Exhibit 18) Facility moved outside rail loop. Rail loop shortened and impervious area reduced.
Rail loop too short to allow for off-load rail ladder or effective transfer from existing Norfolk
Southern right-of--way. Single rail loop with no fire protection access. TOTAL IMPACT 0.918
ACRES
4 (Exhibit 19) Facility outside dual rail loop, rail curves adjusted to allow for future off-load rail
ladder inside loop. Forces facility to impact northern wetlands. TOTAL IMPACT 1.85 ACRES
5 (Exhibit 20) Facility separated to minimize impact to northern wetlands, necessitates placement
of bulk ethanol storage tanks inside rail loop, limiting off-load rail ladder. Lacking fire
protection access road adjacent to loop. TOTAL IMPACT 0.49 ACRE
6 (Exhibit 21) Facility outside rail loops, but no longer segmented and eliminates impact to
northern wetland. Plan lacks storm water facility, and does not include rail ladder. TOTAL
IMPACT 0.48 ACRE
PREFERRED ALTERNATIVE (Exhibit 5) Facility outside rail loop, rail ladder and storm water
locations added, fire protection access road around loop added. TOTAL IMPACT 0.48 ACRE
E85 ---Fayetteville
404/401 PCN
EXHIBIT 14
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ENVIRONMENTAL, (NC.

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E85 404/401 PCN EXHIBIT 22

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N~DENR.
North Carolina Department of Environment and Natural Resources
DIVISION OF AIR QUALITY
Michael F. Easley, Governor
February 5, 2007
Mr. Mark Dassel
Senior Vice President
E85, Inc.
PO Box 560
Kingston, WA 98346
Subject: Air Permit No. 09722R00
E85, Inc.
Fayetteville, Cumberland County, North Carolina
Fee Class: Synthetic Minor
Site Number: 06/26/00221
Dear Mr. Dassel:
William G. Ross Jr., Secretary
B. Keith Overcash, P.E., Director
In accordance with your completed application received December 4, 2006 and additional
information received January 24, 2007, we are forwarding herewith Permit No. 09722R00 to E85,
Inc., Fayetteville, Cumberland 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 or 15A NCAC 2Q .0503 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 maybe obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 150B-23, this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
150B-22. This request must be submitted in writing to the Director and must identify the specific
Fayetteville Regional Office flue
Systel Building, 225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5094 NorthCarc~lina
Phone: [phone] /FAX: [phone] /Internet: www.ncair.org ~~~~N~ J/~
An Equal Opportunity /Affirmative Action Employer - 50% Recycled / 10% Post Consumer Paper f "

Mark Dassel
February 5, 2007
Page 2
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. 150B-23.
Unless exempted by a condition of this permit or the regulations, construction of new
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 February 5, 2007 until January 31, 2009, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
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.
Should you have any questions concerning this matter, please contact Christy Richardson at (910)
433-3377.
Sincerely,
/~
Steven Vozzo
Regional Air Quality Supervisor
CTR
Enclosures
Central Files
Fayetteville Regional Office

Permit No. 09722R00
Page 2
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIItONMENT AND NATURAL RESOURCES
DIVISION OF A1R QUALITY
AIR PERMIT NO. 09722R00
Issue Date: February 5, 2007
Expiration Date: January 31, 2009
Effective Date: February 5, 2007
Replaces Permit: (new)
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,
E85, Inc.
557 Bethune Drive
Fayetteville, Cumberland County, North Carolina
Fee Class: Synthetic Minor
Site Number: 06/26/00221
(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
;Raw Material Receiving and Storage
ES-1201 Rail Receiving CD-1203 Baghouse (Size To $e Determined)
(NSPS) (unloading pit with 2-wall enclosure)
ES-1202 Truck Receiving (with 2-wall enclosure) CD-1204 Baghouse (Size To Be Determined)
(NSPS)
_
_ _ .
ES-1205 _
Grain Bin Feed #1 CD-1205 .
Baghouse (Size To Be Determined)
(NSPS) (Size To Be Determined)
ES-1206 Grain Bin Feed #2 CD-1206 Baghouse (Size To Be Determined)
(NSP
) ze
o
e
eterm
ne
(
)
ES-1207 Grain Bin Feed #3
(NSPS) (Size To Be Determined)
ES-1208 Scalper /Surge Bin
(NSPS} Si
T
B
D
i
d
S
CD-1207 Baghouse {Size To Be Determined)
CD-1208 Baghouse (Size To Be Determined)

Permit No. 09722R00
Page 3
...._ ___.._
Emission _______. _~ __.. _._.___ _ _._ __... _ .___ ... _ .
Emission Source _ _. _. _.__.- --
Control -. - -.---- _ ..._..__--_- _ -._ y__ _. _.. _.._ .._.
Control S stem
:Source ID Description ~ System ID Description

.Ethanol P
rocessing __ .._ __
' CD-1302 ~ Hammermills Discharge Baghouse
ES-1300 Four (4) Grain Hammermills
"
~ (Stze To Be Determined)
(maximum capacity of 35 tons per hour each) Hammermills Baghouse
CD-1301 (Size To Be Determined)

Fermentation Process
CD-1401 __
Pre Fermentation Scrubber

ES-1400
(maximum 115,000,000 gallons per year- ;
. ._. _. (Size To Be Determined)
____..__._ _____._.. __..____._.
denatured) CD-1402 ~ Main Fermentation Scrubber
(Size To Be Determined)
--
ES-1500 Distillation /Dehydration Process (maximum CD-1501 ' Distillation Scrubber
115,000,000 gallons per year -denatured) (Size To Be Determined)
!Distillers Dried Grain Solubles (DDGS) Processing, Storage, and Loadout
ES-1600 Evaporation Process N/A N/A
ES-1700 " Stillage Decanting N/A j N/A
Two (2) Natural Gas-Fired Swiss Combi DDGS
ES-1800 Dryers (64 mmBTU/hr each) with low NOX CD-1800 Integrated Thermal Oxidizer
burners and integrated thermal oxidizer
ES-1851 Dry DDGS Storage Silo CD-1851 Baghouse (Size To Be Determined)

ES-1852
Dry DDGS Transfer to Loadout ;
CD-1852 _.. _..
Baghouse (Size To Be Determined)
__
ES-1853 __..... g __ _ ___...
Wet DDGS Stora e and Loadout _.
N/A _ .._.._. __. _. ___._ _
N/A
Product and Denaturant Storage

ES-2800
Ethanol Shift Tank #1(200,000 gallons capacity, __
N/A __
N/A
(NSPS) 200 proof, internal floating roof) ~
ES-2900 'Ethanol Shift Tank #2 (200,000 gallons capacity, N/A N/A
(NSPS) 200 proof, internal floating roof)
ES-3000 Denaturant Gasoline Tank (250,000 gallons N/A N/A ,
(NSPS) capacity, internal floating roof)
ES-3100 :Product Storage Tank #1 (1,600,000 gallons, 200 N/A N/A
(NSPS) proof, internal floating roof)
ES-3200 Product Storage Tank #2 (1,600,000 gallons, 200 N/A N/A
(NSPS) proof, internal floating roof)
ES-2150 Truck and Rail Product Loadout with Flare CD-2151 ~ Natural Gas-Fired Flare
(2.75 mmBTU/hr maximum capacity)
- __
Power House _
ES-2201 Natural Gas-Fired Boiler with ultra-low NOx N/A N/A
(NSPS) ;burners (146.5 mmBTU/hr maximum heat input) ,
ES-2202 Natural Gas-Fired Boiler with ultra-low NO,
N/A
N/A
(NSPS) .burners (146.5 mn-BTU/hr maximum heat input)

ES-2500 No. 2 Fuel Oil-Fired Generator
N/A
N/A
(4,500 kW maximum capacity)

Permit No. 09722R00
Page 4
Emission . Emission Source Control Control System
:Source ID ~ Description i System ID Description
_. _
_ _____
;Fugitive Emissions
ES-LDAR Fugitive Emission from Equipment Leaks N/A ~ N/A i
_ ~.
ES-Roads Fugitive Emissions from Plant Roads and Parking ; N/A N/A
Areas
..Wastewater Treatment
ES-2400 ~ Biomethanator and Flare CD-2401 Methane Flare
(5.42 mmBTU/hr maximum capacity)
in accordance with the completed application 2600221.06A received December 4, 2006, and
additional information received January 24, 2007, including any plans, specifications, previous
applications, and other supporting data, all of which are filed with the Department of Environment
and Natural Resources, 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
2D .0202, 2D .0503, 2D .0515, 2D .0516, 2D .0521, 2D .0524 (40 CFR 60, Subpart Kb,
Subpart Db, Subpart DD, Subpart VV), 2D .0535, 2D .0605, 2D .0958, 2D .1100, 2D .1806,
2D .2100, 2Q .0304, 2Q .0315, 2Q .0317 {Avoidance) and 2Q .0711.
2. EMISSION INVENTORY REQUIREMENT - At least 90 days prior to the expiration date
of this permit, the Permittee shall submit the air pollution emission inventory report 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. The report shall document air
pollutants emitted for the 2006 calendar year. The Regional Office will send information on
how to submit the emissions inventory, along with a reminder to renew your permit, about
six months prior to your permit expiration. If you do not receive this information, please
contact the Regional Supervisor, DAQ.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0503
"Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions
from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates
listed below:
Source Emission Limit (lbs/million Btu)
Natural Gas-Fired Boiler (ES-2201) 0.25
Natural Gas-Fired Boiler (ES-2202) 0.25

Permit No. 09722R00
Page 5
4. 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 .OS 15, 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) 0'67 for P <= 30 tons/hr, or
E = 55 * (P) °'" - 40 for P >30 tons/hr
SULFUR DIOXIDE CONTROL REQUIREMENT - As required by 15A NCAC 2D .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.
6. 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 asix-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 15A NCAC 2D .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
7. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the Natural
Gas-Fired Boilers (ID Nos. ES-2201 & ES-2202), the Permittee shall comply with all
applicable provisions, including the notification, testing, reporting, recordkeeping, and
monitoring requirements contained in Environmental Management Commission Standard
15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as referenced in 40
CFR 60, Subpart Db, (Standards for Performance for Industrial-Commercial-Institutional

a. NSPS Reporting Requirements - In addition'to any other notification requirements to
the Environmental Protection Agency (EPA), the Permittee is required to NOTIFY
the Regional Supervisor, DAQ, in WRITING, of the following:
The date construction (40 CFR 60.7) or reconstruction (40 CFR 60.15) of an
affected source is commenced, postmarked no later than 30 days after such
date. This requirement shall not' apply in the case ofmass-produced facilities
which are purchased in completed form;
ii. The actual date of initial start-up of an affected source, postmarked within 15
days after such date; and
iii. Prior to initial startup of the affected facilities, the Permittee must submit the
following, in writing to the Regional Supervisor, DAQ:
1. The category (high heat release rate or low heat release rate) as
defined in 60.41b which describes the affected sources; and

~- Permit No. 09722R00
Page 6
2. The monitoring requirements option as outlined in 60.48b, which the
Permittee has elected to conduct.
iv. Within 30 days after each six-month period of the calendar year, the
Permittee must submit, in writing to the Regional Supervisor, DAQ, excess
emission reports for any excess emissions, which occurred during the
reporting period. Excess emission is defined as "any calculated 30-day
rolling average nitrogen oxides emission rate, as determined under 60.46b(e),
which exceeds the applicable emission limits in 60.44b.
b. NSPS Emissions Limitations - As required by 15A NCAC 2D .0524, the following
emission limits shall not be exceeded:
Affected Source(s) Pollutant Emission Limit
_. _ _..
O. l O lbs/mmBTU
` Natural Gas-Fired Boilers NOx (for boilers with low heat release rate)
_. _
ES-2201 & ES-2202
( ) 0.20 lbs/mmBTU
(for boilers with high heat release rate)
i. The emissions rates are determined on a 30-day rolling average basis.
ii. The applicable NOx standards apply at all times including periods of startup
shutdown, or malfunction.
c. NSPS Performance Testing - As required by 15A NCAC 2D .0524, the following
performance tests shall be conducted:
To detennine compliance with the emission limits for nitrogen oxides required under
60.44b, the owner of operator of an affected facility shall conduct the performance
test as required under 60.8 using the continuous system for monitoring nitrogen
oxides under 60.48(b). For the initial compliance test, nitrogen oxides from the
steam generating units are monitored for 30 successive steam generating unit
operating days and the 30-day average emission rate is used to determine compliance
with the nitrogen oxide emission standards. The 30-day average is calculated as the
average of all hourly emissions data recorded by the monitoring system during the
30-day test period.
i. All performance tests shall be conducted in accordance with EPA Reference
Methods, contained in 40 CFR 60, Appendix A.
ii. The EPA Administrator retains the exclusive right to approve equivalent and
alternative test methods, continuous monitoring procedures, and reporting
requirements.
iii. Within 60 days after achieving the maximum production rate at which the
equipment will be operated, but not later than 180 days after the initial start-
up of the equipment, the Permittee shall conduct the required performance

Permit No. 09722R00
Page 7
test(s) and submit two copies of a written report of the test(s) to the Regional
Supervisor, DAQ.
iv. The Permittee shall be responsible for ensuring, within the limits of
practicality, that the equipment or process being tested is operated at or near
its maximum normal production rate or at a lesser rate if specified by the
Director or his delegate.
v. All associated testing costs are the responsibility of the Permittee
d. NSPS Recordkeeping_Requirements -The Permittee shall maintain records of the
following information for each steam generating unit operating day:
i. Calendar date;
ii. The average hourly nitrogen oxides emission rates (expressed as NOZ) (ng/J
or lb/mmBTU heat input) measured or predicted;
iii. The 30-day average, nitrogen oxides emission rates (ng/J or lb/mmBTU heat
input) calculated at the end of each steam generating unit operating day from
the measured or predicted hourly nitrogen oxide emission rates for the
preceding 30 steam generating unit operating days;
iv. Identification of the steam generating unit operating days when the calculated
30-day average nitrogen oxides emission rates are in excess of the nitrogen
oxides emissions standards under 60.44b, with the reasons for such excess
emissions as well as a description of corrective actions taken;
v. Identification of the steam generating unit operating days for which pollutant
data have not been obtained, including reasons for not obtaining sufficient
data and a description of corrective actions taken;
vi. Identification of the times when emission data have been excluded from the
calculation of average emission rates and the reasons for excluding data;
vii. Identification of "F" factor used for calculations, method of determination,
and type of fuel combusted;
viii. Identification of the times when the pollutant concentration exceeded full
span of the continuous monitoring system;
ix. Description of any modifications to the continuous monitoring system that
could affect the ability of the continuous monitoring system to comply with
Performance Specification 2 or 3;
x. Results of daily CEMS drift tests and quarterly accuracy assessments as
required under appendix F, Procedure 1; and
xi. All records must be maintained for a minimum of two years.

- Permit No. 09722R00
Page 8
e. NSPS Monitoring Requirements -The Permittee shall
Comply with the provisions of 60.48b (b), (c), (d), (e}(2), (e)(3), and (f) by
installing, calibrating, maintaining, and operating a continuous monitoring
system to record nitrogen oxides emission rates; OR
ii. Monitor steam generating unit operating conditions and predict nitrogen
oxides emission rates as specified in a plan submitted pursuant to 60.49b(c).
The plan shall be submitted for approval within 360 days of initial startup of
the affected facility.
8. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the
affected facility equipment (raw material receiving and storage), the Permittee shall comply
with all applicable provisions, including the notification, testing, reporting, recordkeeping,
and monitoring requirements contained in Environmental Management Commission
Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as referenced
in 40 CFR 60, Subpart DD, (Standards for Performance for Grain Elevators), and including
Subpart A "General Provisions."
a. NSPS Reporting Requirements - In addition to any other notification requirements to
the Environmental Protection Agency (EPA), the Permittee is required to NOTIFY
the Regional Supervisor, DAQ, in WRITING, of the following:
i. The date construction (40 CFR 60.7) of an affected source is commenced,
postmarked no later than 30 days after such date; and
ii. The actual date of initial start-up of an affected source, postmarked within 15
days after such date.
b. NSPS Emissions Limitations - As required by 15A NCAC 2D .0524, the following
emission limits shall not be exceeded:
__ _ _...
Affected Source(s) Pollutant Emission Limit
_. _
_ _
Rail Receiving (ES-1201)
__ _
Truck Receiving (ES-1202)
Grain Bin Feed #1 (ES-1205) PM < 0.01 gr/dscf
_ _ PM & Opacity & 0% opacity
Grain Bin Feed #2 (ES-1206)
__ __
Grain Bin Feed #3 (ES-1207)
,-
Scalper /Surge Bin (ES-1208)

Permit No. 09722R00
Page 9
c. NSPS Performance Testing - As required by 1 SA NCAC 2D .OS24, the following
performance tests shall be conducted:
Affected Source(s) Pollutant Test Method
Rail Receiving (ES-1201)
__ __
Truck Receiving (ES-1202);
___ . Method S,
Grain Bin Feed #1 (ES-1205)
_.... __ _. i PM & Opacity i, Method 2, &
Grain Bin Feed #2 (ES-1206) Method 9
Grain Bin Feed #3 (ES-1207)
Scalper /Surge Bin (ES-1208)
i. All performance tests shall be conducted in accordance with EPA Reference
Methods, contained in 40 CFR 60, Appendix A.
ii. The EPA Administrator retains the exclusive right to approve equivalent and
alternative test methods, continuous monitoring procedures, and reporting
requirements.
iii. Within 60 days after achieving the maximum production rate at which the
equipment will be operated, but not later than 180 days after the initial start-
up of the equipment, the Permittee shall conduct the required performance
test(s) and submit two copies of a written report of the test(s) to the Regional
Supervisor, DAQ.
iv. The Permittee shall be responsible for ensuring, within the limits of
practicality, that the equipment or process being tested is operated at or near
its maximum normal production rate or at a lesser rate if specified by the
Director or his delegate.
v. All associated testing costs are the responsibility of the Permittee.
9. 1SA NCAC 2D .OS24 "NEW SOURCE PERFORMANCE STANDARDS" -For the
affected facility equipment, the Permittee shall comply with all applicable provisions,
including the notification, testing, reporting, recordkeeping, and monitoring requirements
contained in Environmental Management Commission Standard 1SA NCAC 2D .OS24,
"New Source Performance Standards" (NSPS) as referenced in 40 CFR 60, Subpart VV,
(Standards for Performance for Equipment Leaks of VOC in the Synthetic Organic
Chemicals Manufacturing Industry) including Subpart A "General Provisions."
a. NSPS Reportin~_Requirements
i. The Permittee is required to NOTIFY the Regional Supervisor, DAQ, the
date construction (40 CFR 60.7) or reconstruction (40 CFR 60.1 S) of an
affected source is commenced, postmarked no later than 30 days after such
date. This requirement shall not apply in the case ofmass-produced facilities
which are purchased in completed form;

Permit No. 09722R00
Page 10
ii. The Permittee is required to NOTIFY the Regional Supervisor, DAQ, the
actual date of initial start-up of an affected source, postmarked within 15 days
after such date;
iii. The Permittee shall submit semiannual reports to the Regional Supervisor,
DAQ beginning six months after the initial startup date.
The initial semiannual report to the Administrator shall include the following
information in addition to that required for all other semiannual reports:
A. process unit identification.
B. number of valves subject to the requirements of 40 CFR 60.482-7,
excluding those valves designated for no detectable emissions under
the provisions of 40 CFR 60.482-7(f).
C. number of pumps subject,to the requirements of 40 CFR 60.482-2,
excluding those pumps designated for no detectable emissions under
the provisions of 40 CFR 60.482-2(e) and those pumps complying
with 40 CFR 60.482-2(f).
D. number of compressors subject to the requirements of 40 CFR
60.482-3, excluding those compressors designated for no detectable
emissions under the provisions of 40 CFR 60.482-3(i) and those
compressors complying with 40 CFR 60.482-3(h).
All semiannual reports to the Regional Supervisor, DAQ shall include the
following information, summarized from the information in 40 CFR 60.486:
A. process unit identification.
B. For each month during the semiannual reporting period,
I. number of valves for which leaks were detected as described
in 40 CFR 60.482-7,
II. number of valves for which leaks were not repaired as
described in 60.482-7 and 60.482-9,
III. number of pumps for which leaks were detected as described
in 40 CFR 60.482-2,
IV. number of pumps for which leaks were not repaired described
in 40 CFR 60.482-2 and 40 CFR 60.482-9,
V. number of compressors for which leaks were detected as
described in 40 CFR 60.482-3,

Permit No. 09722R00
Page 11
VI. number of compressors for which leaks were not repaired
described in 40 CFR 60.482-3 and 40 CFR 60.482-9, and
VII. the facts that explain each delay of repair and, where
appropriate, why a process unit shutdown was technically
infeasible.
C. Dates of process unit shutdowns, which occurred within the
semiannual reporting period.
D. If the Permittee chooses to comply with the provisions of 40 CFR
60.483-1 or 60.483-2 as an alternative standard, the Permittee shall
notify the Regional Supervisor, DAQ of the alternative standard
selected 90 days before implementing either of the provisions.
E. Revisions to items reported in the initial semiannual report if changes
have occurred since the initial report or subsequent revisions to the
initial report.
iv. The Permittee shall report the results of all performance tests in accordance
with 40 CFR 60.8 of the General Provisions. The provisions of 40 CFR
60.8(d} do not apply to affected facilities subject to the provisions of this
subpart except that an owner or operator must notify the Regional Supervisor,
DAQ of the schedule for the initial performance tests at least 30 days before
the initial performance tests.
b. NSPS Recordkeeping_Requirements
i. When each leak is detected as specified in 40 CFR 60.482-2, 60.482-3,
60.482-7, and 60.482-8, the following requirements apply:
A. A weatherproof and readily visible identification, marked with the
equipment identification number, shall be attached to the leaking
equipment.
B. The identification on a valve may be removed after it has been
monitored for 2 successive months as specified in 40 CFR 60.482-7
and no leak has been detected during those 2 months.
C. The identification on equipment except on a valve, maybe removed
after it has been repaired.
ii. When each leak is detected as specified in 40 CFR 60.482-2, 60.482-3,
60.482-7, and 60.482-8, the following information shall be recorded in a log
and shall be kept for 2 years in a readily accessible location:
A. the instrument and operator identification numbers and the equipment
identification number,

Permit No. 09722R00
Page 12
B. the date the leak was detected and the dates of each attempt to repair
the leak,
C. repair methods applied in each attempt to repair the leak,
D. "Above 10,000" if the maximum instrument reading measured by the
methods specified in 40 CFR 60.485 after each repair attempt is equal
to or greater than 10,000 ppm,
E. "Repair delayed" and the reason for the delay if a leak is not repaired
within 15 calendar days after discovery of the leak,
F. the signature of the owner or operator (or designate) whose decision it
was that repair could not be effected without a process shutdown.
G. the expected date of successful repair of the leak if a leak is not
repaired within 15 days,
H. dates of process unit shutdowns that occur while the equipment is
unrepaired, and
I. the date of successful repair of the leak.
iii. The following information pertaining to the design requirements for closed
vent systems and control devices described in 40 CFR 60.482-10 shall be
recorded and kept in a readily accessible location:
A. detailed schematics, design specifications, and piping and
instrumentation diagrams,
B. the dates and descriptions of any changes in the design specifications,
C. a description of the parameter or parameters monitored, as required in
40 CFR 60.482-10(e), to ensure that control devices are operated and
maintained in conformance with their design and an explanation of
why that parameter (or parameters) was selected for the monitoring,
D. Periods when the closed vent systems and control devices required in
40 CFR 60.482-2, 60.482-3, 60.482-4, and 60.482-5 are not
operated as designed, including periods when a flare pilot light does
not have a flame, and
E. dates of startups and shutdowns of the closed vent systems and
control devices required 40 CFR 60.482-2, 60.482-3, 60.482-4, and
60.482-5.

Permit No. 09722R00
Page 13
iv. The following information pertaining to all equipment subject to the
requirements in 40 CFR 60.482-1 to 60.482-10 shall be recorded in a log
that is kept in a readily accessible location:
A. a list of identification numbers for equipment subject to the
requirements of this subpart,
B. a list of identification numbers for equipment that are designated for
no detectable emissions under the provisions of 40 CFR 60.482-2(e),
60.482-3(i) and 60.482-7(f),
C. the designation of equipment as subject to the requirements of 40
CFR 60.482-2(e), 60.482-3(i), or 60.482-7(f) shall be signed by the
owner or operator,
D. a list of equipment identification numbers for pressure relief devices
required to comply with 40 CFR 60.482-4,
E. the dates of each compliance test as required in 40 CFR 60.482-2(e),
60.482-3(i), 60.482-4, and 60.482-7(f),
F. the background level measured during each compliance test required
in 40 CFR 60.482-2(e), 60.482-3(i), 60.482-4, and 60.482-7(f),
G. the maximum instrument reading measured at the equipment during
each compliance test required in 40 CFR 60.482-2(e), 60.482-3(i),
60.482-4, and 60.482-7(f), and
H. a list of identification numbers for equipment in vacuum service.
v. The following information pertaining to all valves subject to the requirements
of 40 CFR 60.482-7(g) and (h) and to all pumps subject to the requirements
of 40 CFR 60.482-2(g) shall be recorded in a log that is kept in a readily
accessible location:
A. a list of identification numbers for valves and pumps that are
designated as unsafe-to-monitor, an explanation for each valve or
pump stating why the valve or pump is unsafe-to-monitor, and the
plan for monitoring each valve or pump.
B. a list of identification numbers for valves that are designated as
difficult-to-monitor, an explanation for each valve stating why the
valve is difficult-to-monitor, and the schedule for monitoring each
valve.
vi. The following information shall be recorded in a log that is kept in a readily
accessible location:

Permit No. 09722R00
Page 14
A. design criterion required in 40 CFR 60.482-2(d)(5) and 60.482-
3(e)(2) and explanation of the design criterion; and
B. any changes to this criterion and the reasons for the changes.
vii. The following information shall be recorded in a log that is kept in a readily
accessible location for use in determining exemptions as provided in 40 CFR
60.480(d):
A. An analysis demonstrating that equipment is not in VOC service.
vii. Information and data used to demonstrate that a piece of equipment is not in
VOC service shall be recorded in a log that is kept in a readily accessible
location.
viii. The following information shall be recorded for valves complying with 40
CFR 60.483-2:
A. schedule of monitoring, and
B. the percent of valves found leaking during each monitoring period.
c. NSPS Emissions Limitations
40 CFR 60.482-2 Standards: Pumps in light liquid service
Each pump in light liquid service shall be monitored monthly to detect leaks
by the methods specified in 40 CFR 60.485(b), except as provided in 40
60.482-1(c) and for the following pumps:
A. pumps equipped with dual mechanical seal systems that include a
barrier fluid system as provided in 40 CFR 60.482-2 (d).
Requirements for the dual mechanical seals are:
I. Each dual mechanical seal system is operated with the bamer
fluid at a pressure that is at all times greater than the pump
stuffing box pressure; or
each dual mechanical seal system is operated with the barrier
fluid at a pressure that is at all times greater than the pump
stuffing box pressure; or
each dual mechanical seal system is equipment with a barrier
fluid degassing reservoir that is routed to a process or fuel gas
system or connected by a closed vent system to a control
device that complies with the requirements of §60.482-10; or

Permit No. 09722R00
Page 15
each dual mechanical seal system is equipped with a system
that purges the barrier fluid into a process stream with zero
VOC emissions to the atmosphere.
II. Each pump is checked by visual inspection, each calendar
week, for indications of liquids dripping from the pump seals.
III. The barrier fluid system shall be in heavy liquid service or
shall not be in VOC service. Each bamer fluid system shall be
equipped with a sensor that will detect failure of the seal
system, barrier fluid system, or both. The Permittee shall
determine, based on design considerations and operating
experience, a criterion that indicates failure of the seal system,
the barrier fluid system, or both.
IV. The sensors shall be checked daily or shall be equipped with
an audible alarm. Leaks are detected by the following:
Affected Source(s) Pollutant Leak detected
Pumps in light liquid service VOC ~ Sensor failure detection based upon
established criterion
Pumps in light liquid service VOC Liquids dripping from pump seal
When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in 40 CFR
60.482-9. A first attempt at repair shall be made no later than 5 calendar
days after each leak is detected.
B. pumps designated for no detectable emissions, as indicated by an
instrument reading of less than 500 ppm above background, as
provided in 40 CFR 60.482-2 (e),
C. pumps equipped with a closed vent system capable of capturing and
transporting any leakage from the seal or seals to a process or to a fuel
gas system or to a control device that complies with the requirements
of 40 CFR 60.482-10
Each pump in light liquid service shall be checked by visual inspection each
calendar week for indications of liquids dripping from the pump seal. Leaks
are detected by the following limits:
Affected Source(s) Pollutant Leak detected
__ __ _.
Pumps in light liquid service VOC 10,000 ppm
_-_
Pumps in light liquid service VOC 'Liquids dripping from pump seal

Permit No. 09722R00
Page 16
When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in 40 CFR
60.482-9. A first attempt at repair shall be made no later than 5 calendar
days after each leak is detected.
Pumps deemed unsafe=to-monitor maybe exempted from monthly
monitoring and weekly visual inspections by 40 CFR 482-2 (g).
ii. 40 CFR 60.482-3 Standards: Compressors
Each compressor shall be equipped with a seal system that includes a bamer
fluid system and that prevents leakage of VOC to the atmosphere, except as
provided in 40 CFR 60.482-1(c) and for the following compressors:
A. compressors equipped with a closed vent systems to capture and
transport leakage from the compressor drive shaft back to a process or
fuel gas system or to a control device that complies with the
requirements of 40 CFR 60.482-10 as provided in 40 CFR 60.482-3
(h)•
B. compressors designated for no detectable emissions, as indicated by
an instrument reading of less than 500 ppm above background, as
provided in 40 CFR 60.483 (i).
Each compressor seal system shall be:
A. Operated with the barrier fluid at a pressure that is greater than the
compressor stuffing box pressure; or
B. Equipped with a barrier fluid system degassing reservoir that is routed
to a process or fuel gas system or connected by a closed vent system
to a control device that complies with the requirements of 40 CFR
60.482-10; or
C. Equipped with a system that purges the barrier fluid into a process
stream with zero VOC emissions to the atmosphere.
The barrier fluid system shall be in heavy liquid service or shall not be in
VOC service. Each barrier fluid. system shall be equipped with a sensor that
will detect failure of the seal system, barrier fluid system, or both. The
Permittee shall determine, based on design considerations and operating
experience, a criterion that indicates failure of the seal system, the barrier
fluid system, or both.
The sensors shall be checked daily or shall be equipped with an audible
alarm. Leaks are detected by the following:

Permit No. 09722R00
Page 17
Affected Source(s) Pollutant Leak detected
Compressors VOC Sensor failure detection based upon
established criterion
When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in 40 CFR
60.482-9. A first attempt at repair shall be made no Iater than 5 calendar
days after each leak is detected.
iii. 40 CFR 60.482-4 Standards: Pressure relief devices in gas/vapor service
Except during pressure releases, each pressure relief device in gas/vapor
service shall be operated with no detectable emissions, as indicated by an
instrument reading of less than 500 ppm above background.
After each pressure release, the pressure relief device shall be returned to a
condition of no detectable emissions, as indicated by an instrument reading of
less than 500 ppm above background, as soon as practicable, but no later than
5 calendar days after the pressure release, except as provided in 40 CFR
60.482-9.
No later than 5 calendar days after the pressure release, the pressure relief
device shall be monitored to confirm the conditions of no detectable
emissions, as indicated by an instrument reading of less than 500 ppm above
background.
Pressure relief devices meeting the following specifications may be exempted
from the above requirements:
A. any pressure relief device that is routed to a process or fuel gas system
or equipped with a closed vent system capable of capturing and
transporting leakage through the pressure relief device to a control
device as described in 40 CFR 60.482-10 as provided in 40 CFR
60.482-4(c).
B. any pressure relief device that is equipped with a rupture disk
upstream of the pressure relief device as provided in 40 CFR 60.482-
4(d).
iv. 40 CFR 60.482-5 Standards: Sampling connection systems
Each sampling connection system shall be equipped with aclosed-purged,
closed-loop, or closed-vent system, except as provided in 40 CFR 60.482-1.
Gases displaced during filling of the sample container are not required to be
collected or captured.
Each closed-purge, closed-loop, or closed-vent system shall:

Permit No. 09722R00
Page 18
A. return the purged process fluid directly to the process line; or
B. collect and recycle the purged process fluid to a process; or
C. be designed and operated to capture and transport all the purged
process fluid to a control device that complies with the requirements
of 40 CFR 60.482-10; or
D. collect, store, and transport the purged process fluid to any of the
following systems or facilities:
I. A waste management unit as defined in 40 CFR 63.111, if the
waste management unit is subject to, and operated in
compliance with the provisions of 40 CFR part 63, subpart G,
applicable to Group 1 wastewater streams;
II. A treatment, storage, or disposal .facility subject to regulation
under 40 CFR part 262, 264, 265, or 266; or
III. A facility permitted, licensed, or registered by a State to
manage municipal or industrial solid waste, if the process
fluids are not hazardous waste as defined in 40 CFR part 261.
In situ sampling systems and sampling systems without purges are exempt
from the above requirements.
v. 40 CFR 60.482-6 Standards: Open ended valves or lines
Each open-ended valve or line shall be equipped with a cap, blind flange,
plug, or a second valve, except as provided in 40 CFR 60.482-1(c).
The cap, blind flange, plug, or second valve shall seal the open end at all
times except during operations requiring process fluid flow through the open-
ended valve or line.
Each open-ended valve or line equipped with a second valve shall be
operated in a manner such that the valve on the process fluid end is closed
before the second valve is closed.
When a double block-and-bleed system is being used, the bleed valve or line
may remain open during operations that require venting the line between the
block valves but shall be equipped with a cap, blind flange, plug, or a second
valve at all other times.
The following valves and lines are exempt from the above requirements:

Permit No. 09722R00
Page 19
A. Open-ended valves or lines in an emergency shutdown system, which
are designed to open automatically in the event of a process upset, are
exempt from the above requirements.
B. Open-ended valves or lines containing materials which would
autocatalytically polymerize or would present an explosion, serious
overpressure, or other safety hazard if capped or equipped with a
double block and bleed system as specified in paragraphs (a) through
(c) of this section are exempt from the requirements of paragraphs (a)
through (c) of this section.
vi. 40 CFR 60.482-7 Standards: Valves in as/vapor service and in light liquid
service.
Each valve shall be monitored monthly to detect leaks by the methods
specified in §60.485(b}. Leaks are detected by the following limit:
Affected Source(s) Pollutant Leak detected
Valves in gas/vapor service and in VOC 10,000 ppm ;
light liquid service.
Any valve for which a leak is not detected for 2 successive months maybe
monitored the first month of every quarter, beginning with the next quarter,
until a leak is detected. If a leak is detected, the valve shall be monitored
monthly until a leak is not detected for 2 successive months.
When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in 40 CFR
60.482-9. A first attempt at repair shall be made no later than 5 calendar
days after each leak is detected. First attempts at repair include, but are not
limited to, the following best practices where practicable:
A. tightening of bonnet bolts;
B. replacement of bonnet bolts;
C. tightening of packing gland nuts; and
D. injection of lubricant into lubricated packing.
The following valves may be exempted from the above requirements:
A. Valves designated for no detectable emissions, as indicated by an
instrument reading of less than 500 ppm above background, maybe
exempted from the above requirements as provided in 40 CFR
60.482-7(fl.

Permit No. 09722R00
Page 20
B. Valves designated as an unsafe-to-monitor maybe exempted from the
above requirements as provided in 40 CFR 60.482-7(g).
The Permittee may elect to use one of the alternative standard for valves, 40
CFR 60.483-1 or 40 CFR 60.483.2. If so, the Permittee shall notify the
Regional Supervisor, DAQ of the alternative standard selected 90 days before
implementing either of the provisions.
vii. 40 CFR 60.482-8 Standards: Pumps and valves in heavy liquid service
pressure relief devices in li t liquid or heavy liquid service and connectors
If evidence of a potential leak is found by visual, audible, olfactory, or any
other detection method at pumps and valves in heavy liquid service, pressure
relief devices in light liquid or heavy liquid service, and connectors, the
Permittee shall follow either one of the following procedures:
A. The Permittee shall monitor the equipment within 5 days by the
method specified in §60.485(b). Leaks are detected by the following
limit:
___-- _ ._
Affected Source(s) Pollutant Leak detected
Pumps and valves in heavy liquid service,
pressure relief devices in light liquid or heavy VOC + l 0,000 ppm
liquid service, and connectors
When a leak is detected, it shall be repaired as soon as practicable, but
not later than 15 calendar days after it is detected, except as provided
in 40 CFR 60.482-9. A first attempt at repair shall be made no later
than 5 calendar days after each leak is detected.
First attempts at repair include, but are not limited to, the following
best practices where practicable:
I. tightening of bonnet bolts;
II. replacement of bonnet bolts;
III. tightening of packing gland nuts; and
IV. injection of lubricant into lubricated packing.
B. The Permittee shall eliminate the visual, audible, olfactory, or other
indication of a potential leak.
viii. 40 CFR 60.482-9 Standards: Deli of repair

~, Permit No. 09722R00
Page 21
Delay of repair of equipment for which leaks have been detected will be
allowed if repair within 15 days is technically infeasible without a process
unit shutdown. Repair of this equipment shall occur before the end of the
next process unit shutdown.
Delay of repair beyond a process unit shutdown will be allowed for a valve, if
valve assembly replacement is necessary during the process unit shutdown,
valve assembly supplies have been depleted, and valve assembly supplies had
been sufficiently stocked before the supplies were depleted. Delay of repair
beyond the next process unit shutdown will not be allowed unless the next
process unit shutdown occurs sooner than 6 months after the first process unit
shutdown.
Delay of repair of equipment will be allowed for equipment which is isolated
from the process and which does not remain in VOC service.
.Delay of repair for valves will also be allowed if:
A. the Permittee demonstrates that emissions of purged material resulting
from immediate repair are greater than the fugitive emissions likely to
result from delay of repair, and
B. when repair procedures are effected, the purged material is collected
and destroyed or recovered in a control device complying with 40
CFR 60.482-10.
Delay of repair for pumps will also be allowed if:
A. repair requires the use of a dual mechanical seal system that includes a
barrier fluid system, and
B. repair is completed as soon as practicable, but not later than 6 months
after the leak was detected.
ix. 40 CFR 60.482-10 Standards: Closed vent systems and control devices
Standard for vapor recovery systems:
Affected Source(s) 'Pollutant Emission limit
Efficiency of 95 percent or greater; or
Vapor recovery systems VOC 20 parts per million by volume
(whichever is less stringent)

Permit No. 09722R00
Page 22
Standard for enclosed combustion devices:
Affected Source(s) Pollutant Emission limit
_ _ __ .. _
Efficiency of 95 percent or greater; or
-20 parts per million by volume, on a dry basis,
corrected to 3 percent oxygen;
(whichever is less stringent)
Enclosed combustion devices .
OR
VOC
i Provide a minimum residence time of 0.75
''seconds at a minimum temperature of 816 °C.
Flares used to comply with this subpart shall comply with the requirements of
40 CFR 60.18.
The Permittee shall monitor control devices to ensure that they are operated
and maintained in conformance with their designs.
Each closed vent system shall be inspected according to the following
procedures:
A. If the vapor collection system or closed vent system is
constructed ofhard-piping, the Permittee shall comply with the
following requirements:
I. Conduct an initial inspection according to the procedures in 40
CFR 60.485(b); and
II. Conduct annual visual inspections for visible, audible, or
olfactory indications of leaks.
B. If the vapor collection system or closed vent system is constructed of
ductwork, the owner or operator shall:
I. Conduct an initial inspection according to the procedures in 40
CFR 60.485(b); and
II. Conduct annual inspections according to the procedures in 40
CFR 60.485(b).
Leaks from the above inspections are indicated by the following limit:
Affected Source(s) Pollutant Leak detected
Closed vent systems and VOC Instrument reading greater than 500 parts per
control devices million by volume above background

Pennit No. 09722R00
Page 23
When a leak is detected by instrument reading or visual inspection, it~ shall be
repaired not later than 15 calendar days after it is detected. A first attempt at
repair shall be made no later than 5 calendar days after each leak is detected.
The following vapor collection systems and closed vent systems are exempt
from the above inspection requirements:
A. If the vapor collection system or closed vent system is operated under
a vacuum, it is exempt from the inspection requirements.
B. Any parts of the closed vent system that are designated as unsafe to
inspect are exempt from the inspection requirements as provided in 40
CFR 60.482-10(j).
C. Any parts of the closed vent system that are designated as difficult to
inspect are exempt from the inspection requirements as provided in 40
CFR 60.482-10(k).
The Permittee shall record the following information:
A. Identification of all parts of the closed vent system that are
designated as unsafe to inspect, an explanation of why the equipment
is unsafe to inspect, and the plan for inspecting the equipment.
B. Identification of all parts of the closed vent system that are
designated as difficult to inspect, an explanation of why the
equipment is difficult to inspect, and the plan for inspecting the
equipment.
C. For each inspection during which a leak is detected, a record of the
information specified in 40 CFR 60.486(c).
D. For each inspection conducted in accordance with 40 CFR 60.485(b)
during which no leaks are detected, a record that the inspection was
performed, the date of the inspection, and a statement that no leaks
were detected.
E. For each visual inspection conducted for vapor collection systems or
closed vent systems constructed ofhard-piping during for which no
leaks are detected, a record that the inspection was performed, the
date of the inspection, and a statement that no leaks were detected.
Closed vent systems and control devices used to comply with provisions of
this subpart shall be operated at all times when emissions maybe vented to
them.

,. Permit No. 09722R00
Page 24
d. NSPS Performance Testing
The Permittee shall comply with the testing procedures in 40 CFR 60.485.
i. As required by 60.485(b), The Permittee shall determine compliance with the
standards in 40 CFR 60.482, 60.483, and 60.484 as follows:
Affected Source(s) 'Pollutant Test method
Method 21
Pumps in light liquid service,
compressors, and pressure
relief devices in gas/vapor
service
..._._ _
Calibration gases:
VOC ~ Zero air (less than 10 ppm of hydrocarbon in
air); and a mixture of methane or n-hexane and
air at a concentration of about, but less than,
10,000 ppm methane or n-hexane.
ii. As required by 60.485(c), the Permittee shall determine compliance with the ~.,
no detectable emission standards in 40 CFR 60.482-2(e), 60.482-3(i), ,
60.482-4, 60.482-7(f), and 60.482-10(e) as follows:
Affected Source(s) Pollutant ~ Test method
_.
' ~ Method 21
Pumps in light liquid
service, compressors,
pressure relief devices in
gas/vapor service, valves in
gas/vapor service and in
light liquid service, closed
vent systems and control
devices
VOC
Calibration gases:
Zero air (less than 10 ppm of hydrocarbon in air);
and a mixture of methane or n-hexane and air at a
concentration of about, but less than, 10,000 ppm
methane or n-hexane.
Method 21 shall be used to determine the
background level. All potential leak interfaces
shall be traversed as close to the interface as
possible. The arithmetic difference between the
maximum concentration indicated by the
instrument and the background level is compared
with 500 ppm for determining compliance.
iii. The Permittee shall test each piece of equipment unless he demonstrates that a
process unit is not in VOC service, i.e., that the VOC content would never be
reasonably expected to exceed 10 percent by weight. The methods of 40 CFR
60.485(d) shall be used to demonstrate this.

Permit No. 09722R00
Page 25
iv. The Permittee shall demonstrate that equipment is in light liquid service by
showing that all the following conditions apply:
A. The vapor pressure of one or more of the components is greater than
0.3 kPa at 20 °C (1.2 in. H2O at 68 °F). Standard reference texts or
ASTM D2879-83, 96, or 97 {incorporated by reference-see 40 CFR
60.17) shall be used to determine the vapor pressures.
B. The total concentration of the pure components having a vapor
pressure greater than 0.3 kPa at 20 °C (1.2 in. H2O at 68 °F) is equal
to or greater than 20 percent by weight.
C. The fluid is a liquid at operating conditions.
v. The Permittee shall determine compliance with the standards of flares by the
procedures listed in 40 CFR 60.485(g)
vi. Samples used in conjunction with Conditions A.9.d.iii, iv, and v shall be
representative of the process fluid that is contained in or contacts the
equipment or the gas being combusted in the flare.
10. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -For the
following equipment, The Permittee shall comply with all applicable provisions, including
the notification, testing, reporting, recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .0524 for NSPS as
promulgated in 40 CFR 60, Subpart Kb (Standards of Performance for Volatile Organic
Liquid Storage Vessels), indicated below, and including Subpart A "General Provisions."
The following tanks are equipped with internal floating roofs:
Tank ID No. 'Tank Description
__
ES-2800 ethanol shift tank (200,000 gallons capacity)
ES-2900 ethanol shift tank (200,000 gallons capacity)
ES-3000 ,denaturant gasoline tank (250,000 gallons capacity)
_ __
ES-3100 'product storage tank #1 (1,600,000 gallons capacity) i..
........ ...
.. _. _.
ES-3200 :product storage tank #Z (1,600,000 gallons capacity}
a. NSPS Reporting_Requirements - In addition to any other notification requirements to
the Environmental Protection Agency (EPA), the Penmittee is required to NOTIFY
the Regional Supervisor, DAQ, in WRITING, of the following:
i. The date construction (40 CFR 60.7) or reconstruction (40 CFR 60.15) of an
affected source is commenced, postmazked no later than 30 days after such
date. This requirement shall not apply in the case ofmass-produced facilities
which are purchased in completed form;

Permit No. 09722R00
Page 26
ii. The actual date of initial start-up of an affected source, postmarked within 15
days after such date;
iii. As an attachment to the actual date of start-up report, a report that describes
the control equipment and certifies that the control equipment meets the
specifications of 40 CFR 60.112b(a)(1) and 40 CFR 60.113b(a)(1) (see
emissions limitations and testing requirements below).
iv. If any of the conditions described in 40 CFR 60.113b(a)(2) are detected
during the annual visual inspection required by 40 CFR 60.113b(a)(2), a
report shall be furnished to the Regional Supervisor, DAQ within 30 days of
the inspection. Each report shall identify the storage vessel, the nature of the
defects, and the date the storage vessel was emptied or the nature of and date
the repair was made (see testing requirements below).
v. After each inspection required by 40 CFR 60.113b(a)(3) that finds holes or
tears in the seal or seal fabric, or defects in the internal floating roof, or other
control equipment defects listed in 40 CFR 60.113b(a)(3)(ii), areport shall be
furnished to the Regional Supervisor, DAQ within 30 days of the inspection.
The report shall identify the storage vessel and the reason it did not meet the
specifications of 40 CFR 60.112b(a)(1) or §60.113b(a)(3) and list each repair
made (see emissions limitations and testing requirements below).
b. NSPS Recordkeeping Requirements
i. The Permittee shall keep a record of each inspection performed as required
by 40 CFR 60.113b (a)(1), (a)(2), (a)(3), and (a)(4). Each record shall
identify the storage vessel on which the inspection was performed and shall
contain the date the vessel was inspected and the observed condition of each
component of the control equipment (seals, internal floating roof, and
fittings). These records shall be kept for a minimum of two years. (see
testing requirements below).
ii. The Permittee keep readily accessible records showing the dimensions of the
facility storage vessel and an analysis showing the capacity of the storage
vessel for the life of each source.
iii. For each storage vessel, a record of the VOL stored, the period of storage,
and the maximum true vapor pressure of that VOL during the respective
storage period shall be maintained. These records shall be kept for a
minimum of two years.
c. NSPS Emissions Limitations -The facility storage vessels, will all have design
capacities greater than or equal to 151 m 3 and each will contain a VOL that, as
stored, has a maximum true vapor pressure equal to or greater than 5.2 kPa but less
than 76.6 kPa. Each will be controlled by a fixed roof in combination with an
internal floating roof. As required by 40 CFR 60.112b(a)(1):

Permit No. 09722R00
Page 27
The internal floating roof shall rest or float on the liquid surface (but not
necessarily in complete contact with it) inside a storage vessel that has a fixed
roof. The internal floating roof shall be floating on the liquid surface at all
times, except during initial fill and during those intervals when the storage
vessel is completely emptied or subsequently emptied and ref lied. When the
roof is resting on the leg supports, the process of filling, emptying, or
refilling shall be continuous and shall be accomplished as rapidly as possible.
ii. Each internal floating roof shall be equipped with one of the following
closure devices between the wall of the storage vessel and the edge of the
internal floating roof:
A. A foam- or liquid-filled seal mounted in contact with the liquid
(liquid-mounted seal). Aliquid-mounted seal means afoam- or
liquid-filled seal mounted in contact with the liquid between the wall
of the storage vessel and the floating roof continuously around the
circumference of the tank.
B. Two seals mounted one above the other so that each forms a
continuous closure that completely covers the space between the wall
of the storage vessel and the edge of the internal floating roof. The
lower seal may be vapor-mounted, but both must be continuous.
C. A mechanical shoe seal. A mechanical shoe seal is a metal sheet held
vertically against the wall of the storage vessel by springs or weighted
levers and is connected by braces to the floating roof. A flexible
coated fabric (envelope) spans the annular space between the metal
sheet and the floating roof.
iii. Each opening in a noncontact internal floating roof except for automatic
bleeder vents (vacuum breaker vents) and the rim space vents is to provide a
projection below the liquid surface.
iv. Each opening in the internal floating roof except for leg sleeves, automatic
bleeder vents, rim space vents, column wells, ladder wells, sample wells, and
stub drains is to be equipped with a cover or lid which is to be maintained in
a closed position at all times (i.e., no visible gap) except when the device is in
actual use. The cover or lid shall be equipped with a gasket. Covers on each
access hatch and automatic gauge float well shall be bolted except when they
are in use.
v. Automatic bleeder vents shall be equipped with a gasket and are to be closed
at all times when the roof is floating except when the roof is being floated off
or is being landed on the roof leg supports.
vi. Rim space vents shall be equipped with a gasket and are to be set to open
only when the internal floating roof is not floating or at the manufacturer's
recommended setting.

Permit No. 09722R00
Page 28
vii. Each penetration of the internal floating roof for the purpose of sampling
shall be a sample well. The sample well shall have a slit fabric cover that
covers at least 90 percent of the opening.
viii. Each penetration of the internal floating roof that allows for passage of a
column supporting the fixed roof shall have a flexible fabric sleeve seal or a
gasketed sliding cover.
ix. Each penetration of the internal floating roof that allows for passage of a
ladder shall have a gasketed sliding cover.
d. NSPS Performance Testing -After installing the permanently affixed roof and
internal floating roof on each facility tank, the Permittee shall:
As required by 40 CFR 60.113b(a)(1), visually inspect the internal floating
roof, the primary seal, and the secondary seal (if one is in service), prior to
filling the storage vessel with VOL. If there are holes, tears, or other
openings in the primary seal, the secondary seal, or the seal fabric or defects
in the internal floating roof, or both, the owner or operator shall repair the
items before filling the storage vessel.
ii. As required by 40 CFR 60.113b(a)(2), for Vessels equipped with aliquid-
mounted or mechanical shoe primary seal, visually inspect the internal
floating roof and the primary seal or the secondary seal (if one is in service)
through manholes and roof hatches on the fixed roof at least once every 12
months after initial fill. If the internal floating roof is not resting on the
surface of the VOL inside the storage vessel, or there is liquid accumulated
on the roof, or the seal is detached, or there are holes or tears in the seal
fabric, the owner or operator shall repair the items or empty and remove the
storage vessel from service within 45 days. If a failure that is detected during
inspections required in this paragraph cannot be repaired within 45 days and
if the vessel cannot be emptied within 45 days, a 30-day extension maybe
requested from the Regional Supervisor, DAQ, in the inspection report
required in 40 CFR 60.115b(a)(3). Such a request for an extension must
document that alternate storage capacity is unavailable and specify a schedule
of actions the company will take that will assure that the control equipment
will be repaired or the vessel will be emptied as soon as possible.
iii. As required by 40 CFR 60.113b(a)(3), for vessels equipped with adouble-
seal system:
A. Visually inspect the vessel as specified in Condition A.1 O.d.iv of this
Permit at least every 5 years; or
B. Visually inspect the vessel as specified in Condition A.1 O.d.ii of this
Permit.

Permit No. 09722R00
Page 29
iv. As required by 40 CFR 60.113b(a)(4), visually inspect the internal floating
roof, the primary seal, the secondary seal (if one is in service), gaskets,
slotted membranes and sleeve seals (if any) each time the storage vessel is
emptied and degassed. If the internal floating roof has defects, the primary
seal has holes, tears, or other openings in the seal or the seal fabric, or the
secondary seal has holes, tears, or other openings in the seal or the seal fabric,
or the gaskets no longer close off the liquid surfaces from the atmosphere, or
the slotted membrane has more than 10 percent open area, the Permittee shall
repair the items as necessary so that none of the circumstances specified in
this Condition exist before refilling the storage vessel with VOL. In no event
shall inspections conducted in accordance with this provision occur at
intervals greater than 10 years in the case of vessels conducting the annual
visual inspection as specified in Conditions A.1 O.d.ii and A.1 O.d.iii.B. of this
Permit and at intervals no greater than 5 years in the case of vessels specified
in Condition A.10.d.ii.A of this Permit.
v. As required by 40 CFR 60.113b(a)(5), Notify the Regional Supervisor, DAQ,
in writing at least 30 days prior to the filling or refilling of each storage
vessel for which an inspection is required above to afford the DAQ the
opportunity to have an observer present. If the inspection required by
Condition A.1 O.d.iv of this section is not planned and the Permittee could not
have known about the inspection 30 days in advance or refilling the tank, the
Permittee shall notify the Regional Supervisor, DAQ at least 7 days prior to
the refilling of the storage vessel. Notification shall be made by telephone
immediately followed by written documentation demonstrating why the
inspection was unplanned. Alternatively, this notification including the
written documentation maybe made in writing and sent by express mail so
that it is received by the Regional Supervisor, DAQ, at least 7 days prior to
the refilling.
1 l .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,
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.

Permit No. 09722R00
Page 30
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.
12. TESTING REQUIREMENT -Under the provisions of North Carolina General Statute 143-
215.108 and in accordance with 15A NCAC 2D .0605, the Permittee shall demonstrate
compliance with the emission limit(s) by testing the emission source(s) for the specified
pollutant(s) as follows:
_
Affected Source(s)
.... ..
.__ _._
'Pollutant
Emission Limit ~ Test Method

__.
_
atural Gas-Fired Boiler (ES-2201) _

NOX

0.011 lbs/mmBTU ,
_
Natural Gas-Fired Boiler (ES-2202) _.
: NOX
0.011 Ibs/mmBTU

Two (2) Natural Gas-Fired Swiss _ __ _ __
Combi DDGS Dryers (ES-1800)
._ . _. _ _ NOX 15.91bs/hr ';DAQ Approved Methods

Natural Gas-Fired Boiler (ES-2201)
_ ... _ _

CO
_....
' 0.0221bs/mmBTU
Natural Gas-Fired Boiler (ES-2202) CO ~ 0.022 lbs/mmBTU
a. At least 45 days prior to performing any required emissions testing, the Permittee
must submit a testing protocol to the Regional Supervisor, DAQ for review and
approval. All testing- protocols must be approved by the DAQ prior to performing
such tests.
b. To afford the Regional Supervisor, DAQ, the opportunity to have an observer
present, the Permittee shall PROVIDE the Regional Office, in WRITING, at least 15
days notice of any required performance test(s).
c. The test results must be submitted to the Regional Supervisor, DAQ, in accordance
with the approved procedures of the Environmental Management Commission within
180 days of the initial operation date.
d. This permit maybe revoked, with proper notice to the Permittee, or enforcement
procedures initiated, if the results of the test(s) indicate that the facility does not meet
applicable limitations.
e. The source shall be responsible for ensuring, within the limits of practicality, that the
equipment or process being tested is operated at or near its maximum normal
production rate, or at a lesser rate if specified by the Director or his delegate.
f. All associated testing costs are the responsibility of the Permittee.
13. WORK PRACTICES REQUIREMENTS - As required by 15A NCAC 2D .0958(c) "Work
Practices for Sources of Volatile Organic Compounds," the Perrnittee shall adhere to the
following required work practices:

r
Permit No. 09722R00
Page 31
a. The Permittee shall store all VOC-containing material not in use (including waste
material) in containers covered with a tightly fitting lid that is free of cracks, holes,
or other defects.
b. The Permittee shall clean up spills as soon as possible following proper safety
procedures.
c. The Permittee shall store wipe rags in closed containers.
d. The Permittee shall not clean sponges, fabric, wood, paper products, and other
absorbent materials.
e. The Permittee shall drain solvents used to clean supply lines and other coating
equipment into closable containers and close containers immediately after each use.
f. The Permittee shall clean mixing, blending, and manufacturing vats and containers
by adding cleaning solvent, closing the vat or container before agitating the cleaning
solvent.
g. The Permittee shall pour spent cleaning solvent into closable containers and close
containers immediately after each use.
14. 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
Two (2) Natural Gas-Fired Swiss Combi 3.38 ]b/yr
DDGS Dryers (ES-1800)
Denaturant Gasoline Tank (ES-3000) ~ Benzene (71-43-2) 21.45 lbs/yr
Truck and Rail Product Loadout with Flare 0.68 ]bs/yr
(ES-2150)
_ _ __
__ _ __ _
Two (2) Natural Gas-Fired Swiss Combi 'Formaldehyde (50-00-0) ' 0.47 lbs/hr
DDGS Dryers (ES-1800)
a. Restrictions -The Permittee shall at all times properly operate, inspect, and maintain
the control devices, as specified in Specific Condition 18, to ensure compliance with
the above toxic air pollutant limits. This data must be reevaluated if the removal
efficiencies listed in Specific Condition 18 cannot be achieved.
15. 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
odor control equipment sufficient to prevent odorous emissions from the facility from
causing or contributing to objectionable odors beyond the facility's boundary.

Permit No. 09722R00
Page 32
16.40 CFR Part 68 "ACCIDENTAL RELEASE PREVENTION REQUIREMENTS: RISK
MANAGEMENT PROGRAMS UNDER THE CLEAN AIR ACT, SECTION 112(r)" -The
Permittee shall comply with all applicable requirements in accordance with 40 CFR Part 68
including submitting a Risk Management Plan to EPA pursuant to 40 CFR 68.150 or as
specified in 40 CFR 68.10.
17. ZONING SPECIFIC CONDITION -Prior to construction or operation of the facility under
this permit, the Permittee shall comply with all lawfully adopted local ordinances that apply
to the facility at the time of construction or operation of the facility. The local zoning
authority shall have the responsibility of enforcing all lawfully adopted local zoning or
subdivision ordinances.
18. 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

Individual HAPs __
10
Total HAPs
__ 25
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. the Permittee shall properly operate, inspect, and maintain the control devices
at all times and
ii. the Permittee shall conduct source testing as specified in this condition and in
specific condition no. 12.
b. Inspection and Maintenance Requirements -
i. Bagfilter 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 regulated limits, the
Permittee shall perform periodic inspections and maintenance (I&M) as
recommended by the manufacturer. In addition, the Permittee shall perform
an annual internal inspection of each bagfilter system.
ii. Scrubber 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 periodic inspections and maintenance (I&M) as

Permit No. 09722R00
Page 33
recommended by the manufacturer. In addition, the Permittee shall perform
an annual internal inspection of each scrubber system.
As a minimum, the I&M program and each annual inspection should include
the following:
1. inspection of spray nozzles, packing material, chemical feed system
(if so equipped), and the cleaning/calibration of all associated
instrumentation annually.
2. two weeks following initial start-up and startup following major
maintenance of each scrubber, the Permittee shall shut down the
system and inspect for nozzle plugging and settling of the packing.
iii. Thermal Oxidizer Requirements -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 periodic inspections and maintenance (I&M) as recommended
by the manufacturer. As a minimum, the Permittee shall perform an annual
internal inspection of each primary heat exchanger and associated inlet/outlet
valves to ensure. structural integrity.
iii. Flare System Requirements -The flare system shall be operated at all times
when emissions may be vented to it. The presence of the flare pilot flame
shall be monitored using a thermocouple or any other equivalent device to
detect the presence of a flame. The Permittee shall perform annual
inspections of the flare system. In addition, the Permittee shall perform
inspections and maintenance periodically as recommended by the
manufacturer.
c. Monitoring Requirements -Following the submittal of control device specifications
to the Regional Supervisor, DAQ, as specified below, monitoring requirements will
be included in the air permit.
d. Control Device Specification and Testing Requirements -
i. Before facility start-up, the Permittee must specify and submit to the
Regional Supervisor, DAQ, as a minimum, the following control device
parameters and document the validity of these parameters:
1. For Bagfilters: Filter surface area, inlet air flow rate, filter maximum
operating temperature, filter material, filter cleaning procedures,
method for determining when to clean the filters, and method for
determining when to replace bags.
2. For Scrubbers: Pressure drop, minimum liquid injection rate, percent
of liquid recirculated, inlet airflow rate, type of packing, and inlet gas
temperature.

Permit No. 09722R00
Page 34
3. For Flares: Inlet airflow rate, combustion temperature, and residence
time.
ii. As required by 15A NCAC 2Q .0112, the control device technical
information to include design, determination of applicability and
appropriateness, and determination and interpretation of performance must be
sealed by a professional engineer registered in North Carolina, except as
exempted under 15A NCAC 2Q .0112(c). The Permittee must submit this
information to the Regional Supervisor, DAQ, before facility start-up.
iii
Affected Source(s)
Under the provisions of North Carolina General Statute 143-215.108 and in
accordance with 15A NCAC 2D .0605, the Permittee shall perform and
submit to the Regional Supervisor, DAQ, the results of stack tests of the
following emission sources and associated control devices to ensure
compliance with the emissions limits listed below and to compare the
removal efficiencies (capture efficiencies X control efficiencies) achieved
with those listed below:
.. _ ___
Facility-wide Control Device(s) Removal ,Test Methods
' Emission Limit(s) Efficiency
_.
Pre-Fermentation Scrubber ' VOC >_ 99.37% ;
SingO HAPO< 0 PY (CD-1401) HAPs>_ 99.37%
Total HAP < 25 TPY Main Fermentation Scrubber VOC >_ 99.5%
(CD-1402) 'HAPs >_ 99.5%
Fermentation Process (ES-1400)
Distillation /Dehydration Process VOC < 100 TPY Distillation Scrubber VOC ? 99.67% DAQ Approved
(ES-1500) Single HAP < 10 TPY (CD-1501) !HAPs >_ 99.67% Methods
Total HAP < 25 TPY
PM-10 < 100 TPY PM-10 > 90%
Two (2) Natural Gas-Fired Swiss ' CO < 100 TPY Integrated Thermal Oxidizer CO > 90%
Combi DDGS Dryers (ES-1800) VOC < 100 TPY (CD-1800) VOC> 95%
Single HAP < 10 TPY ' HAPs ? 95%
Total HAP < 25 TPY
1. If any emission rates or removal efficiencies achieved during the
stack testing indicate emission rates that are higher than those listed in
the initial application, the Pennittee must recalculate facility-wide
emissions using the rates obtained in the stack tests and include the
results and conclusions with the stack test results.
2. In the event that the facility cannot meet the limits specified above,
the Permittee will take immediate steps to reduce emissions below
major source thresholds, including, but not limited to, adding
additional control systems or reducing production capacity. Failure to
demonstrate facility-wide emissions of less than 100 tons per year for
VOC and/or less than 10 tons per year for acetaldehyde will require
the Permittee to submit an application for an Air Permit under the
requirements of 15A NCAC 2Q .0500, "Title V Procedures." Failure
to demonstrate PTE of less than 100 tons per year for VOC will
require the Permittee to submit an application for an Air Permit under
the requirements of 15A NCAC 2D .0530, "Prevention of Significant

~, Permit No. 09722R00
Page 35
Deterioration." Also, failure to demonstrate PTE of less than 100 tons
per year for VOC and/or less than 10 tons per year for acetaldehyde
will be considered a violation for operating without a proper Air
Permit.
3. All source testing shall meet the following requirements:
a. At least 45 days prior to performing any required emissions
testing, the Permittee must submit a testing protocol to the
Regional Supervisor, DAQ, for review and approval. All
testing protocols must be approved by DAQ prior to
performing such tests.
b. To afford the Regional Supervisor, DAQ, the opportunity to
have an observer present, the Permittee shall PROVIDE the
Regional Office, in WRITING, at least 15 days notice of any
required performance test(s).
c. The test results must be submitted to the Regional Supervisor,
DAQ, in accordance with the approved procedures of the
Environmental Management Commission within 180 days of
initial operation date. If the facility is not operating at
greater than 90% capacity at the time of the initial test, the
facility must perform a second test when the facility is at
more than 90% production capacity.
d. This permit maybe revoked, with proper notice to the
Permittee, or enforcement procedure initiated, if the results of
the tests indicate that the facility does not meet applicable
limitations
e. The source shall be responsible for ensuring, within the limits
of practicality, that the equipment or process being tested is
operated at or near its maximum normal production rate, or at
a lesser rate if specified by the Director or his delegate.
f. All associated testing costs are the responsibility of the
Permittee.
e. Recordkeeping Requirements
i. The Permittee shall record monthly and total annually the following:
1. particulate matter (PM-10) emissions, carbon monoxide (CO)
emissions, volatile organic compounds (VOC) emissions, acetaldehyde
(single highest HAP) emissions, and total HAP emissions

Permit No. 09722R00
Page 36
ii. A logbook shall be kept on site for each control device and made available to
Division of Air Quality personnel upon request. The Pennittee shall record
all inspection, maintenance and monitoring requirements listed above in the
logbook. Any variance from the manufacturer's recommendations shall be
investigated with corrections made and date of actions recorded in the
logbook.
f. Reporting Requirements -Within 30 days after each calendar year quarter,
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 14 months. The data must be
calculated for each of the three 12 month periods over the previous 14
months.
A. particulate matter (PM-10) emissions, carbon monoxide (CO)
emissions, volatile organic compounds (VOC) emissions,
acetaldehyde (single highest HAP} emissions, and total HAP
emissions.
ii. summary of all control device monitoring and recordkeeping activities
described above for the previous 3 months.
19. LIMITATION TO AVOID 15A NCAC 2D .0530 "PREVENTION OF SIGNIFICANT
DETERIORATION" - In accordance with 15A NCAC 2Q .0317, to comply with this permit
and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant
Deterioration," as requested by the Permittee, emissions shall be limited as follows:
Affected Source(s) Pollutant Emission Limit
(Tons Per Consecutive 12-month Period)
__ _ _ _ ___
Facility Wide VOC 100
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the facility shall comply with the Operations Requirements listed in Specific Permit
Condition no. 18, "Limitation to Avoid 15A NCAC 2Q .0501."
b. Recordkee~ng and Reporting Requirements -The Permittee shall comply with the
Recordkeeping and Reporting Requirements listed in Specific Permit Condition no.
18, "Limitation to Avoid 15A NCAC 2Q .0501."
20. LIMITATION TO AVOID 15A NCAC_ 2D .1111 "MAXIMUM ACHIEVABLE
CONTROL TECHNOLOGY" - To comply with this permit and avoid the applicability of
15A NCAC 2D .1111 "Maximum Achievable Control Technology," as requested by the
Permittee, facility-wide individual hazardous air pollutant (HAP) emissions shall be less
than 10 tons per consecutive 12-month period, and facility-wide total HAP emissions shall
be less than 25 tons per consecutive 12-month period. The Permittee shall be deemed in

a
Permit No. 09722R00
Page 37
noncompliance with this condition and 15A NCAC 2D .1111 if the HAP emissions exceed
this limit.
a. The synthetic minor requirements for HAPs specified above in Specific Condition
no. 18 shall satisfy the requirements for MACT avoidance.
b. The Permittee shall properly operate, inspect, and maintain the control devices as
specified above in Specific Condition no. 18.
21. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT -Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed
toxic air pollutants (TAPS), the Permittee has made a demonstration that facility-wide actual
emissions do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q
.0711. 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 .0711.
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:
Chronic Acute Systemic ~ Acute
Pollutant :Toxicants Toxicants Irritants
(Ib/day) (Ib/hr) (Ib/hr)
Acetaldehyde (75-07-0) ' 6.8
Acetic acid (64-19-7) 0.96
Ammonia (as NH3) (7664-41-7} ~ ~Q
Dichlorobenzene(p), 1,4- (106-46-7)
_ _... _ _
Ethyl acetate (141-78-6)
___
Manganese & compounds (MNC)
___ _
Toluene (108-88-3)
_ _ _.
Xylene (1330-20-7)

r
Permit No. 09722R00
Page 38
22. Equipment Specifications Reporting -
a. Prior to startup of the facility, the Permittee shall submit the following to the
Regional Supervisor, DAQ, in writing:
1. Equipment specifications and updated permit application forms for all
applicable emission sources and control devices; and
2. Manufacturer guarantees for NOX and CO emissions on both boilers (ID
Nos. ES-2201 & ES-2202).
b. Prior to installation, the Permittee shall submit the following to the Regional
Supervisor, DAQ, in writing:
1. Equipment specifications for the No. 2 fuel oil-fired emergency generator
(ID No. ES-2500) and fire pump (ID No. IES-2505) so that a determination
can be made on the applicability of NSPS Subpart IIII (Stationary
Compression Ignition Internal Combustion Engines). ~ ~ .
23. Operational Limitation for NOx -The Permittee has claimed the integral equipment
selected, and configured, will result in facility-wide NOX emissions below 100 tons per year.
Equipment shall meet the following limitations:
Affected Source(s) Pollutant Emission Limit
Natural Gas-Fired Boiler (ES-2201) NOX ~ 0.011 lbs/mmBTU
_.._ __ .
Natural Gas-Fired Boiler (ES-2202) ; NOX :0.011 Ibs/mmBTU
Two (2) Natural Gas-Fired Swiss NOX 15.91bs/hr
Combi DDGS Dryers (ES-1800)
To ensure emissions do not exceed the limitations above, the Permittee shall:
a. Maintain manufacturer's emission rate guarantees;
b. Conduct on-site testing as specified in Stipulation 12; and
c. Maintain documentation on-site to verify types of burners tested above.

Permit No. 09722R00
Page 39
B. GENERAL CONDITIONS AND LIMITATIONS
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 Air Quality Supervisor
North Carolina Division of Air Quality
Fayetteville Regional Office
Systel Building
225 Green Street, Suite 714
Fayetteville, NC 28301-5094
[phone]
2. RECORDS RETENTION REQUIREMENT -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. PERMIT RENEWAL 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(1), no permit application fee
is required for renewal of an existing air permit. The renewal request should be submitted to
the Regional Supervisor, DAQ.
4. 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.
5. EQUII'MENT RELOCATION -Anew 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.
6. 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. The facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source maybe operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. REPORTING REQUIREMENT - 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

Permit No. 09722R00
Page 40
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.
8. This permit is nontransferable by the Permittee. Future owners and operators must obtain a
new air permit from the DAQ.
9. 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.
10. 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.
11. 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 maybe
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.
12. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
13. 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.
14. The Permittee must comply 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.
15. PERMIT RETENTION REQUIREMENT -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.
lb. CLEAN AIR ACT SECTION 112(r) RE ~UIR.EMENTS -Pursuant to 40 CFR Part 68
Accidental Release Prevention Requirements: Risk Management Programs Under the
Clean Air Act, Section 11 Z(r)," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permittee is required to register this plan in accordance with 40 CFR Part 68.

Permit No. 09722R00
Page 41
17. 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.
Permit issued this the 5`h of February 2007.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Regional Air Quality Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 09722R00

i
r ~
Y
ATTACHMENT to Permit No. 09722R00, February 5, 2007
Insignificant /Exempt Activities
Date of 'Exemption ;Source :Source of
Source ;Application Regulation iof TAPS? Title V
_ _ _ ;Pollutants?'
IES 2505 -Fire Purnp 2Q 0102
(maximum capacity to be determined) 12/04/2006 ; (c)(2)(E)(i) No No
IES-2300 -Cooling Tower 12/04/2006 2Q '0102 Yes Yes
(c)(2)(E)(i)
___
__
__
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."