received^^ |p r'»^ 'i/2)/,7 quality/permits/2018_public_notice... · process for...

7BROS.

RECEIVED^^ |p r'»"^ 'i/2)/,73944 River Road Wilmington, NC, 28412

NOV 2 ] 2057 PO BOX-3600 S College Rd STEE-200Wilmington, NC, 28412

DAQ WIRO Phone-919-798-7889

A lication for Air Permit for fumi ationO eration-Permanent Site 1408Cronl Drive Delco NC USA 28436

Received

NOV 2 7 2(11^ 1^. ^ F<^Dear Environmental Protection Division- Air Protection Branch, A :- n-._u» c^^t:,

Please find enclosed an application for an air permit on behalf of Malec Brothers Transport LLC (MALEC). The airpermit is to cover export fumigation activities undertaken on site with the use of Methyl Bromide CHsBr. Alsoenclosed is a cheque to cover payment for the fees associated with this application.

MALEC is seeking approval to use and ventilate the use of Methyl Bromide, which is classified as a hazardous airpollutant (HAP). MALEC foresee a potential to emit up to 140 tonne of Methyl Bromide per annum at this facility inDelco, NC.

Understanding the requirements of CAA112(g) as implemented by EPA's regulations at 40 CFR 63. 40 through 63, 44and also North Carolina's regulations at NCAC 02D. 1112, we appreciate that that no owner or operator mayconstruct a major source of MAP without approval from the appropriate permitting authority, in this case being theNorth Carolina Department of Environmental Quality (NCDENR).

Export fumigation is a requirement of treaties in regards to international export, APHIS PPQ certifies treatmentsperformed in the US for destination countries that require same prior to issuing phytosanitary certificates. Eachprocess for pre-shipment fumigation is mandated in detail by the USDA APHIS PPQ Treatment Manual. The approachto fumigation has varied little in the last 40+ years.

All fumigation procedures are mandated by the USDA APHIS PPQ manual, which will be strictly adhered too. Inconjunction with the APHIS requirements, MALEC will opt to mimic the high standards of process, control andequipment as used within its sister facility located in Lara, Victoria, Australia, operational without incident sinceinception in 2012.

Best regards

'^ ^.^<^^

James Harris

CEO- USA Operations

Malec Brothers Transport Limited Liability

11/20/2017

FORMAGENERAL FACILITT INFORMATION

Received

NOV 2 7 2017 ^ ^\7^

REVISED 09/22/16

D

a

NCDEQ/Division of Air Quality . Application tor Air Permit to ConstrucUOpeM

NOTE- APMJCATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING:

Q Appropriate Number of Copies of Applicatior D Application Fee (ir required)

Responsible OfficisiWuthorized Contact Signature

Local Zoning Consistency Determinalton (new ormodificaikn) only)

Legal Corporale/Owner Name:

Site Name: Delco

Site Address (911 Address] Line 1.

Site Address Line 2:

City: Delco

Zip Code:

D PE Seal (if required)

GENERAL INFORMATION

Malec Brothers Transport Limited Liability Company

MOaCronl Drive

28436

NC

vs

Zip Code Vie

Fax No. +61)352741411

Zip Cede:

Fax No:

3216 (Australia). 81 352741411

State:

County:

CONTACT INFORMATIONInvoice Contact:

Name/Title. Leah Matheson

Mailing Address Line 1: po BOX 5312

Mailing Address Line 2'

28412 City: North Geetonfl Slate:

Primary Phone No. : +61 352741000

Secondary Phone No.

Email Address-leah 'naleccomay

PermWTwhnlcal Contact:

Name/Title: James Harris - GEO US Operalions

Mailing Address Line 1 3600 S College Road STE E-200

Mailing Address Line 2.

City: Wilmington State: NC Zip Code:

Pnmary Phone No.: 919-79B-7889 Fax No.

Secondary Phone No. : ...61401752563

Email Address: 'ames maiec.com.au

APPLICAT»N IS BEING MADE FOR./New Non-permitted Facilily/GreenlieU D Modification of Facility (permitted) D Renewal Title V D Renewal Non-Title VD Name Change D Owneiship Change D Administrative Amendmeni D Renewal with Modification

FACILFTY CLASSIFICATION AFTER APPLICATION heck OnGenera] Small Prohibitory Small Synthetic Minor . ' Title V

FACB-rTY (Plant Site) INFORMATIONSescribe nature of (plant site) operation(s): Fumigation of Export commodoties in shipping containers with methyl bromide as mandated oy the USDA or as certified by the USDA for entry'equiremenls to forign countries

Responsible OfRciaVAutllorlzeiS Contact:

Name/Title; James Harris - CEO US Operations

Mailing Address Line 1: 3600 S ColleBe Road STE E-200

Mailing Address Line 2:

City Wilmington State: NC

Primary Phone No . 919-798-7389

Secondary Phone No +61401752563Email Address; m

Facllltf/lnspection Contact:

Name/T;tle: Matthew Malec - Company Director/President

Mailing Address Line 1: 36UO s' Coltegu Road s'l'K E-2UO

Mailing Address Line 2

City; Wilmlngton State: N'C

Prinary Phone No 919-798-7889

Secondary Phone No: +61418521636

Email Address: maltl-ewamaiec-iaxn.au

Zip Code:

Fax No.

28412

+61 352741411

28412.*61 352741411

Primary SIC/NAICS Code: N/A

Facility Coordinates:

Does this application containconfidential data?

FaeilityiDNo

Curreni/Previous Air Permit No NW Expiration Date:

D YES

Latitude: 34 2657B3

[3 NO

PERSON OR FIRM THAT PREPARED APPLICATION

Longitude:-78. 100354*"lf yes, please contact the DAQ Regional Office prior to submitting thisapplication."* (See Instructions)

Firm hiamp' . Ift. l F!IPerson Name: famus Harris

Mailing Address Line 1; 3600 S College Road 8TE E-200 Mailing Address Line 2: PO BOX 5321 North Geelong, Victoria

City: Wilmington State: N/C Zip Code: 3215 County Australia

Phone No: 919-798-7889 Fax No : '+615274141 Email Address: James. ; malec com.auSIGNATURE OF RESPONSIBLE OFFICIAUAUTHORIZED CONTACT

me (lyoed) - ^ ~ . " " Titte:» -'. - yQX Signalure(Blue Ink): ^^// ^-, -'/ ^ ^ Date:

'/ Attach Additional Sheets As Nece ary Page 1 of 2

REVISED 09/22/16

FORM A (continued, page 2 of 2)GENERAL FACILinr INFORMATION

NCDEQ/DivIsion of Air Quality - Application for Air Permit to ConstrucUOptrateSECTION AA1 -APPLICATION FOR NON.TrTLE V PERMIT RENEWAL

(Company Name) hereby formally requests renewal of Air Permit N(

There have been no modifications to the originally permitted facility or tfe operations therein that wouk? require an air permit since the last permit was issuedlsyou'racility5ubjectto40CFRPart68"PrevnetlonofABcldental Releases"-Sectlon 112(r)ofthedeanAirAct? 0 YES D NO

If yes, have you already submitted a Risk Manage Plan (RMP) to SPA? D YES D MO Date SubmittedDid you attach a current emissions inventory? D YES D NOIfno. didyousubmitthelnventoiyviaAEROorbymai;? D Via AERO D Mailed Date Mailed:

SECTION AA2. APPLICATION FOR TITLE V PERntff RENEWALin accordance with the provisions of Title 15A 20 0513, the responsible official of tCompany Name)hereby formally requests renewal of Air Permit No (Air Permit No) and further certifies that:

(1)

(2)

;3)

d)(5;

The current air quality permit .dentifies and describes all emissions units at the above subject facility, except where such unite are exempted under theNorth Carolina Title V regulations at 15A NCAC 2Q 05GO;

The cufrent air quality permit cits ali applicable requirements and provides the method or methods for aete'-ming compHance with the app'icab'erequirements;

The facility is currently in compliance, and shall continue to comply, with all applfcaUe requiremetns (Note: As provided under ISA NCAC 2Q C512compliance wiih the conditions of the permit shall be deemed compliance with the applicable requirements spec.fieaily identineii in the permit);For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis;The facility snail fulfill applicable enhanced monitoring requirements and submit a compliance certilicaiion as required by 40 CFR Part 64

The responsibfe official (signature on page 1) certifies under the penalty of law that all inforniation and statements provided abcve, based en infarmatior. and belierformed alter reasonable inquiry, are true. accurate, and complete

SECTION AA3. APPLICATION FOR NAME CHANGE

Mew Facility Name:

Former Facllily Name

An official facility name change is requested as described above for [he a;r permit mentioned on page 1 of this form Complete the other sections if there have beenmoaincat.ons to the onginaily premitted facil'ty that would requie an air quality pemii since the las! permit was issued and if (her has been an ownership changpas&jciated 'A-^-h this name change

SECTION AA4. APPLICATION FOR AN OWNERSHIP CHANGEBy is application we nereby request transfer cf Air Quality Permit No from the fomer owner to She "ew o'.w.er as descnbed belowThe transfer of perm:t respo"s:b;!ity; co'/erage and 'iabili!:/ shall be effecti' jjmmsdiately or insert date ) The !ega! c'*nershlp cf thefacility described on page 1 o- this form nas been or will be trsnsfered ar (date) There have been no n-od'fications to the arisin3liypermitted facility that -vculd require an air quality pen-iit s'nce the 'ast permit waa issued

.Sianalyrejariitew f^uyer) Resnonsible Officiat/Aulhorized Ga.iiact fas twed or oace 1!

X Signature (Blue Ink)

Dale

Mew Facility Name

roriner Facility Name:

S'nnfllure pl Former (Sellsr) Resjxinsi.bXOffLCialWuthorized Conlacl

Naate (lypea or print;:

Title

X Signature (Blue Ink).

Date:

Former Legal Corporate/Owner Name:

In lieu of the seller's signature on this form, a letter may be submitted with the seller's signature indicating the ownership change

e rwiuesle^

Attach Additional Sheets As Necessary Page 2 of 2

REVISED 09/22/16

EMISSION SOURCE

ID NO,

FORMS A2, A3EMISSION SOURCE LISTING FOR THIS APPLICATION - A2

112r APPLICABILITf INFORMATION - A3NCDEQ/Dlvision of Air Quality . Application for Air Permit to Construct/Operate

EMISSION SOURCE LISTING: New, Modified, Previousl Un rmitted. Re laced, DeletedA2

EMISSION SOURCEDESCRIPTION

CONTROL DEVICE

ID NO.

Equipment To Be ADDED By This Ap lication New, Previousl Un

CONTROL DEVICE

DESCRIPTION

rmitted, orRe lacement)

Exiatin Permitted E ui ment To Be MODIFIED B This A licatton

E ui ment To Be DELETED By This Application

112{r) APPUCABILIT^ INFORMATION ^Is your facility subject to 40 CFR Part 68 "Preventfon of Accidental Releases" - Section 112(r) of the Federal Clean Air Act? Yes -r NoIf No. please specify in detail how your facility avoided applicability: Facility does not hold regulated compounds in excess of threshold quantaties.

If your facility is Subject to 112(r), please complete the following;A. Have you already submitted a Risk Management Plan (RMP) to EPA Pursuant to 40 CFR Part 68 10 or Part 68.150?D Yes Q No Specify required RMP submittal date: _N/A_ If submitted, RMP submittai date: __ Wf

B. Are you using administrative controls to subject your facility to a lesser 11 2(r) program standard?D Yes D No IF yes, please specify:

C. List the processes subject to 112(r) at your facility:N/A

PROCESS DESCRIPTIONPROCESS LEVEL

(1, 2, or 3) HAZARDOUS CHEMICALMAXIMUM INTENDED

INVENTORY (LBS)

Attach Additional Sheets As Necessary

FOR BSPECIFIC EMISSION SOURCE INFORIWATION (REQUIRED FOR ALL SOURCES)

REVISED 09/22/16 NCDEO/Division of Air Quality - Application for Air Permit to Construct/OperateEMISSION SOURCE DESCRIPTION: Methyl Bromide emissions from fumigation of export EMISSION SOURCE ID NO: MBcomodoties in shipping containers, subject to USDA APHIS direct supervision.

OPERATING SCENARIO -1_ OF " 1_ EMISSION POINT (STACK) ID NO(S): N/ADESCRIBE IN DETAILTHE EMISSION SOURCE PROCESS (ATTACH FLOW DIAGRAIW):Please see attached exhibit B & B9.

B

TYPE OF EMISSION SOURCE (CHECK AND CONIPLETE APPROPRIATE FORM B1-B9 ON THE FOLLOWING PAGES):Coal. wood.oil, gas, other burner (Form B1) D Woodworking (Form B4) D Manuf. of chemicals/coatings/inks (Form B7)

D Int. combustion engine/generator (Form B2) d Coating/finishing/prlntmg (Form B5) D Incineration (Form B8)Liquid storage tanks (Form 83) Q Storage silos/bins (Form 86) ^ Other (Form B9)

START CONSTRUCTION DATE: 10/06/17 DATE MANUFACTURED:

MANUFACTURER / MODEL NO. : EXPECTED OP. SCHEDULE: _S_ HR/DAY _5_ DAY/WK 52 WK/YRIS THIS SOURCE SUBJECT TO? NSPS (SUBPARTS?):_No_ NESHAP (SUBPARTS?): NOPERCENTAGE ANNUAL THROUGHPUT (%): DEC-FEB 20% MAR-MAY 30% JUN-AUG 30% SEP-NOV20%

CRITERIA AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCESOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONSEMISSION (AFTER CONTROLS.' LIMITS) (BEFORE CONTROLS / LIMITS) (AFTER CONTROLS I LiMITS)

AIR POLLUTANT EMITTED FACTOR Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yrPARTICULATE MATTER (PM)PARTICULATE MATTER<10 MICRONS (PMio)

PARTICULATE MATTER<2 5 MICRONS (PM;;)SULFUR DIOXIDE (S02)NITROGEN OXIDES (NOx)CARBON MONOXIDE (CO)

VOLATILE ORGANIC COMPOUNDS (VOC) MeBr 100% Emmisi 32.42 140 32,42 140 32.42 140LEAD

OTHER

HAZARDOUS AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCESOURCE OF EXPECTED ACTUAL POTENTIAL EMISSIONSEMISSION {AFTER CONTROLS/LIMITS) (BEFORE CONTROLS; LIMITS! (AFTER CONTROLS f LIMITS)

HAZARDOUS AIR POLLUTANT CAS NO. FACTOR Ib/hr tons/yr Ib/hr tons/yr Ib/hr tons/yrMethyl Bromide 74-83-9 100% Emmisi 32.42 140 32.42 140 32-42 140

TOXIC AIR POLLUTANT

TOXIC AIR POLLUTANT EMISSIONS INFORMATION FOR THIS SOURCE

EXPECTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS

Ib/hr Ib/dav Ib/yr

SOURCE OFEMISSION

CAS NO. FACTOR

Altachmerts; (1) emissnns catculations and supporting documentation; (2» indicate all requested state and federal enforceable permit limits (e g hours of operation, emission rates! anddescribe how these are monitored and 'mth what frequency, and (3) describe any monitoring devices, gauges, or test parts for this source

COMPLETE THIS FORM AND COMPLETE AND A TTACH APPROPRIA TE B1 THROUGH B9 FORM FOR EACH SOURCEAttach Additional Sheets As Necessary

3944 River Road Wilmington, NC, 28412

PQ BOX - 3600 S College Rd STE E - 200Wilmington, NC, 28412

Phone-919-798-7889

Exhibits B & B9

Description of Process causing Emission Source

Export commodities are treated in shipping containers with methyl bromide gas as per USDArequirements. The containers are placed onto an impervious surface, fans/ monitoring and dispensing linesare fitted to the container. The fumigant is then injected into the container and the commodity is left toexpose to the gas for 16-72 hours. During this time monitoring of the concentration inside the containeroccurs as well as teak detection around the container perimeter. If a teak is found, it is to be rectified usingequipment such as duct tape, sand bags etc. If the container is not able to sufficiently contain the gas afterrectification, the container will be deemed unsuitable for fumigation and shipping. The container will beunloaded and returned to empty container facility or wrapped in appropriate sheeting for re-fumigation.

Once the fumigation period and concentration levels have met requirements for USDA, the container willbe ventilated. To ensure the facility is not overwhelmed with methyl bromide gas the following procedureswill be followed;

<^ a single container door to be opened,^ 5 minutes later the second door can be opened and so on.

This allows for controlled release of methyl bromide into the atmosphere, ensuring the site levels do notexceed safe working levels. MALEC management will ensure levels of methyl bromide exposure to thefacility during ventilation remains at a safe level through the use of a multi use gas detector ie. Micro 5.

The Micro 5 device displays atmospheric levels of methyl bromide in parts per million (PPM). With the safelevel of methyl bromide concentrations to be Sppm or the acceptable short-term exposure rate of 20ppmto also be acceptable. If concentration levels are found to be higher than the safe levels then additionalprocedures will be followed such as;

^ spacing container ventilations further apart,^ only partially opening doors,^ waiting for wind speed to increase.

This will ensure that the atmosphere is not overwhelmed with methyl bromide concentrates.

^3944 River Road Wilmington, NC, 28412

PO BOX - 3600 S College Rd STE E - 200

Witmingtoa NC, 28412

Phone-919-798-7889

Process Flow Chart

FORM B9EMISSION SOURCE (OTHER)

REVISED 09/22/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construe (/Operate

fEu^SSSOURCE DESCRIPTION: Nethyl Bromide emissions fromQ'»-""^ EMISSION SOURCE ID NO: MB

CONTROL DEVICE ID NO(S): N/AOPERATING SCENARIO:

B9

OF _1_

DESCRIBE IN DETAIL THE PROCESS (ATTACH FLOW DIAGRAM): Please see exhibits B & B9.EMISSION POINT (STACK) ID NO(S): N/A

MATEHIALS ENTERING PROCESS - CONTINUOUS PROCESS

TYPE UNITS

N/A

MAX. DESIGN

CAPACIFl' (UNIT/HR)

REQUESTED CAPACIT/

LIMn-ATION(UNIT/HR)

MATERIALS ENTERING PROCESS - BATCH OPERATION

TYPE UNITS

Methly Bromide Introduced to Shipping Containers Container

MAX. DESIGN

CAPACITf(UNIT/BATCH)

2700 Cubic Ft. (unit)

REQUESTED CAPACITi'

LIMITATION (UNIT/BATCH)

300 Units per Week

MAXIMUM DESIGN (BATCHES / HOUR): 10

REQUESTED LIMITATION (BATCHES / HOUR): 10

FUEL USED: N/A

MAX. CAPACITY HOURLY FUEL USE: N/A

COMMENTS:

(BATCHES/YR): 20, 000 Shipping Containers

TOTAL MAXIMUM FIRING RATE (MILLION BTU/HR): N/A

REQUESTED CAPACITl'ANNUAL FUEL USE: N/A

Attach Additional Sheets as Necessary

REVISED 09/22/16

FOR D1FACILITY-WIDE ENIISSIONS SUMMARY

NCDECVDivision of Air Quality - Application for Air Permit to Construct/OperateCRITERIA AIR POLLUTANT EMISSIONS INFORMATION - FACILITy-WIDE

EXPECTED ACTUALEMISSIONS

(AFTER CONTROLS /

LIMITATIONS)

tnns/yr

POTENTIAL EMISSIONS(BEFORE CONTROLS/

LIMITATIONS)

tons/yrAIR POLLUTANT EMITTED

PARTICULATE MATTER (PM)

PARTICULATE MATTER < 10 MICRONS (PM,o)

PARTICULATE MATTER < 2. 5 MICRONS (PM;;)SULFUR DIOXIDE (SO;)

NITROGEN OXIDES (NOx)CARBON MONOXIDE (CO)

VOLATILE ORGANIC COMPOUNDS (VOC) 140 140LEAD

GREENHOUSE GASES (GHG) (SHORT TONS)OTHER

HAZARDOUS AIR POLLUTANT EMISSIONS INFORUffATION . FACIUTY-WIDE

EXPECTED ACTUALEMISSIONS

(AFTER CONTROLS /

LIMITATIONS)

CAS NO- tons/yr

74-83-9 13972

76-06-2 0. 28

D1

POTENTIAL EMISSIONS

(AFTER CONTROLS /LIMITATIONS)

tons/yr

140

HAZARDOUS AIR POLLUTANT EMITTED

Methyl Bromide

Ctiloropicrin (smell additive to Methyl Bromide)

POTENTIAL EMISSIONS(BEFORE CONTROLS /

LIMITATIONS)

tons/yr

139. 75

0. 28

POTENTIAL EMISSIONS

(AFTER CONTROLS/

LIMITATIONS)

tons/yr

13972

028

TOXIC AIR POLLUTANT EMISSIONS INFORMATION . FACIUTYWIDEINDICATE REQUESTED ACTUAL EMISSIONS AFTER CONTROLS / LIMITATIONS EMISSIONS ABOVE THE TOXIC PERMIT EMISSION RATE (TPER) IN 15ANCAC 2Q 0711 MAY REQUIRE AIR DISPERSION MODELING. USE NETTING FORM D2 IF NECESSARY

TOXIC AIR POLLUTANT EMITTED CAS NO [b/hr Ib/day Ib/year

Modeling Required ?

Yes No

COMMENTS:


REVISED 09/22/16

FORM D3MODELING REQUEST FORMS <3 pages)

NCDEQ/Dlvlslon of Air Quali - Application for Air Permit to ConstnicUOpBrata 03-1

If the applicant desires, the NCDAQ/AQAB will perform the Initial modeling compliance demonstration using EPA approved screening and, if applicable and where possible, refined models Ifthe model results indicate the facilily will be unable to demonstrats compliance with applicable Acceptable Ambient Level(s) the appBcant will be notified and will be required to perform thecompliance demonstration using established modeling protocol and modeling analysis requirements as deHned in the North Carolina Administrative Code 15A NCAC 20 1100 and 2Q 0700and In the Guidelines for Evaluating the Impacts of Toxic Pollutants in North Carolina.

To perform the dispersion modeling compliance demonslration, the AQAB will require the following data:

1. WTRODUCTION

Provide a brief description of the modification and/or addition necessitating the toxic modeling request:

2. EMISSIONS DATA - FacBty-wide Bmtestons, Iff souroa, of all modeled toxics.

CRITERIA OR TOXIC AIR POLLUTANT (TAP)MAXIMUM TOXIC AIR POLLUTANT fTAP) EKBSSIONS (After Controls!

Emission Point ID Itiafyear Ibs/day ibsfhrN/A


S. SXBICETOTANW

POINT SOURCE

Emission Point ID

Stack Description

Stack Height (ft or m)-AGL

Stack Temperature (OF oroK)

Stack Exit Vetodty (Ws or m/s)

Stack Diamster (ft or m)

Slack Base EievaUon (ft) - MSL

Stack UTM Coordinates (m)

NAD version 27 / 83 (circle one)

Latitude

Longitude

Rain Cap? (Y/N)

Vertical Stack? ̂ /N)

IOR:

Seurea date miiu wnW aw laeetf en t,i8 .ppf6p?ei|» acufea (AiaBr^ailan. EBeh unliasa toufce tt c'araTmdas a pedn, .'as, gf-vBhJina .au(0». Nota- For hiBifiwma or idumB .Qi.re* dtta, contact DAQ.'AOAB. D3-2

STACK DATA

N/A

E

N

Zone

°N

°w

AREA SOURCE

(contact DAQ far clarification of

Input data requirements)

Emission Point ID

Source Descriphon

Area Source Height (ft or m) -AGL

Area Source Length (ft or m)

Area Source Width (ft or m)

Source Base Elevation (ft) - MSL

Area Sourcs UTM Coordinates (m)

NAD version 27 / 83 (circle one)

Latitude

Longitude

tw'

AREA SOURCE DATA

(for each area source, submit a separata detailed description oftha area souree, to tnclude

dimensions of the area and »l»va11ons. Ateo include source on sita map.)

N/A

E

N

Zone

'N

°w

VOLUME SOURCE

(contact OAQ for clarification of

Input data requiremanta)

Emission Point ID

Source Description

Volume Source Height (ft or m). AGL

Volume Source Length (ft or m)

Volume Source Bldg Height (ft or m)

Source base Elevation (ft) - MSL

Volume Source UTM Coordinates (m)

NAD version 27183 (drda one)

E

N

Zone

VOLUME SOURCE DATA

(for each roluma source, submit a separate detailed description of the vttlinne aouroe, toInclude dimensions oftta volume souroe when amissions beglne to dlspBrae.)

N/A

Latitude

Longitude

ft-feetm- meters

t°R °N

"w

AGL-Above Ground level

UTM- Univsrsal Transversa Mercatorm/s- meters per second

MSL- Mean Sea Level

Kelvin (degreea)=273+((oF-32}x 5/9)

Attach Additional Sheets As Necessary Pag«2of3

4. SITE DATA

A detailed site diagram must be submitted and shouU indude all of the information listed betaw:

- Property boundaries

- Scale and true north indicator

- All existing and proposed buiklings or structures on site

- Locations ofall emission sources (existing and proposed) listed in Section 2, Page 1 of Form 03- All public n'ghts-of-way traversing tne property (e g roads, railroad tracks, rivers, etc )- UTM coordinates or [atitude/longilude of at least one point (e.g. source or building comer)

A USGS Contour Map must also be submitted with the location of your facility dearly designated

A certified plat map from County Register of Deeds or a signed survey map

D3-3

6. BUILDINC DATA

BuUdlng ID

Buildins Description

Building Height (ft or m)

Building Length (ft or m)

Building Width (ft arm)

Uat »sch bufding. List liera of different haights on a slngto building aa saparNs buMlngs

N/A

6. MISCELLANEOUS DATA

Facility Operating Limits(Operating hours, fuel limits, orother enforceable limits)

7. FACU. ITV IDENT1FICATON

f an operating schedule 's not given, cortinuous operattons will be assumed (i.e 24 hoursfday, 8760hours/year).

Note- if compliance is demonstrated using Ihe above facility operating limits, these limits will be imposed as apermit restriction

Fadlity Name:

Facility Address Street;

City:

County:

Facility ID:

N/A

Point of Contact Name:

Title:

Phone:

Email:


FOR D5TECHNICAL ANALYSIS TO SUPPORT PERMIT APPLICATION

REVISED 09/22/16 NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate D5PROVIDE DETAILED TECHNICAL CALCULATIONS TO SUPPORT ALL EMISSION, CONTROL, AND REGULATORY

DEMONSTRATIONS MADE IN THIS APPLICATION. INCLUDE A COMPREHENSIVE PROCESS FLOW DIAGRAM ASNECESSARY TO SUPPORT AND CLARIFY CALCULATIONS AND ASSUMPTIONS, ADDRESS THE

FOLLOWING SPECIFIC ISSUES ON SEPARATE PAGES:

A SPECIFIC EMISSIONS SOURCE (EMISSION INFORMATION) (FORM B and B1 through B9> - SHOW CALCULATIONS USED, INCLUDING EMISSIONFACTORS^ MATERIAL BALANCES, AND/OR OTHER METHODS FROM WHICH THE POLLUTANT EMISSION RATES IN THIS APP-UCATK3N"WERE'DERIVEDINCLUDE CALCULATION OF POTENTIAL BEFORE AND, WHERE APPLICABLE, AFTER CONTROLS CLEARLY STATE ANY ASSUMPTIONS MADE'AN'DPROVIDE ANY REFERENCES AS NEEDED TO SUPPORT MATERIAL BALANCE CALCULATIONS

B SPE.CIFIC-EMISSICIN SC>URCE (RESULATORY INFORMATION)(FORNI E2 . TITLE V ONLY). PROVIDE AN ANALYSIS OF ANY REGULATIONS APPLICABLETOJ.NDMDUA!:SO_URCESAND THE FACILITY AS A WHOLE INCLUDE A DISCUSSION OUTING METHODS (e g FOR TESTING AND/OR'MONITORING"REQULRE.MENTS) FOR COMPLYING WITH APPLICABLE REGULATIONS, PARTICULARLY THOSE REGULATIONS LIMITING EMISSIONS BASED ON'PRO.CE.SSRATES OR OTHER OPERATIONAL PARAMETERS. PROVIDE JUSTIFICATION FOR AVOIDANCE OF ANY FEDERAL REGULATIONi"(PR_EVENTION.OFSIGNIFICANT DETERIORATION (PSD), NEW SOURCE PERFORMANCE STANDARDS (NSPS), NATIONAL EMISSION STANDARDS FORHAZARDO!JSAIR_POI-1-UTANTS (NESHAPS), TITLE V), INCLUDING EXEMPTIONS FROM THE FEDERAL REGULATIONS WHICH WOULD OTHERWISE BEAPPUCABLE TO THIS FACILITY SUBMIT ANY REQUIRED INFORMATION TO DOCUMENT COMPLIANCE WITH ANY REGULATIONS INCLUDE EMTsSIONRATES CALCULATED IN ITEM "A" ABOVE, DATES OF MANUFACTURE, CONTROL EQUIPMENT, ETC. TO SUPPORT THESE CALCULATIONS"

C CONTROL DEVICE ANALYSIS (FORM C and C1 through C9) - PROVIDE A TECHNICAL EVALUATION WITH SUPPORTING REFERENCES FOR ANYCONJROLEFF!CIENCIESI-ISTEDON SECTION c FORMS, OR USED TO REDUCE EMISSION RATES IN CALCULATIONS UNDER ITEuT-A" ABOVE INCLUDEPER.TINENTOPERATING PARAMETERS (@.g OPERATING CONDITIONS, MANUFACTURING RECOMMENDATIONS, AND PARAMETERS AS APPLIED FOR"!N-IHI.S-APPL"CAI'ON)_CRITICAI- TO_ENSUFilNG PROPER PERFORMANCE OF THE CONTROL DEVICES) INCLUDE AND LIMITATIONS OR MALFUNCTONPOLENTLA-LFORT'1E.PAR_T. ICU.L.AF!CONTROL DEVICES AS EMPLOYED AT 7WS FACILITY DETAIL PROCEDURES FOR ASSURING PROPER OPERATIONOF THE CONTROL DEVICE INCLUDING MONITORING SYSTEMS AND MAINTENANCE TO BE PERFORMED

D PROCESS AND OPERATIONAL COMPLIANCE ANALYSIS - (FORM E3 - TITLE V ONLY) - SHOWING HOW COMPLIANCE WILL BE ACHIEVED WHEN USINGPROCESS' OP_ERATIONAI- OR °THER DATA TO DEMONSTRATE COMPLIANCE REFER TO COMPLIANCE REQUIREMENTS IN THE REGULATORY'ANALYSISiN LTEIUI "B" WHERE APPROPRIATE LIST ANY CONDITIONS OR PARAMETERS THAT CAN BE MONITORED AND REPORTED TODEMONSTRATE COMPLIANCE WITH THE APPLICABLE REGULATIONS.

E PROFESSIONAL ENGINEERING SEAL - PURSUANT TO 15A NCAC 2Q 0112 "APPLICATION REQUIRING A PROFESSIONAL ENGINEERING SEAL"A PROFESSIONAL ENGINEER REGISTERED IN NORTH CAROLINA SHALL BE REQUIRED TO SEAL TECHNICAL PORTIONS OF THIS APPLICATION FORNEW SOURCES AND MODIFICATIONS OF EXISTING SOURCES (SEE INSTRUCTIONS FOR FURTHER APPLICABILITY;

'. i^i/n attest that this application torftas been reviewed by me and is accurate, complete and consistent with the information supplied

in the engineering plans, calculations and all other supporting documentation to the best of my knowledge I further attest that to the best of my knowledge theproposed design /ias been pneparecf m sccortsnce with the applicable regulations Although certain portions of this submittal package may have been developed byother professionals, inclusion of these materials under my seal signifies that I have reviewed this material and have judged it to be consistent with the proposed'design Note. In acconjance with NC General Statutes 143-Z15.6A and 143-2156B, any person who Knowingly makes any false statement, repvsentat'ion. orcertification in any application shall tse guilty of a Class 2 misdemeanor which may include a fine not to exceed $10,000 as wall as civil penalties up lo 125, 600 perviolation

(PLEASE USE BLUE INK TO COMPLETE THE FOLLOWING)NAME:

DATE:

PLACE NORTH CAROLINA SEAL HERE

COMPANY:

ADDRESS:

TELEPHONE:

SIGNATURE:

PAGES CERTIFIED:

N/A N/A

(IDENTIFY ABOVE EACH PERMIT FORM AND ATTACHMENTTHAT IS BEING CERTIFIED BY THIS SEAL)


FORM ElTITLE V GENERAL INFORMATION

REVISED 06/01/18 NCDECUDivjalon of Air Quality. Application for Air Permit toConstrucUOperate

IF YOUR FACIUTY IS CLASSIFIED AS "MAJOR" FOR TITLE V YOU MUST COMPLETE

THIS FORM AND ALL OTHER REQUIRED "E" FORMS (E2 THROUGH E5 AS APPLICABLE)Indlcaia here If your facility is subject to TIIteV by: 0 EIWISSIONS ^ OTHER

If subject to TitlaV by "OTHER", specify why: D NSPS D NESHAP (MACT) D TITLE IVd OTHER (specify)

If you are or will be subjecl to any maiilmum achievable conlrol technology standards (MACT) issued pureuant !o secllon112(d) of the Clean Air Act, specify below;

EMISSION SOURCE

EMISSION SOURCE ID DESCRIPTION MACTMB Fumi alion Activities.

El

List any additional regulation which are requested to Be Included In Ihe shield end provide a detailed explanation as to whyIhe shield should be granted:

REGULATION BMfSS/OW SOURCE <lnc»ucfe ID) BCPL/WATIOH

Comments: Containw Fumigation Is subjectto bB completed as per procedures in the APHIS treatment manual: Section 2.9 Methyl Bromide Cloaed^loor Conlalnar Fumigation


FOR E2EMISSION SOURCE APPLICABLE REGULATION LISTING

REVISED OS/22/16 NCOEQ/Droislon of Air Quality - Application for Air Permit to Construct/OperateEMISSION EMISSION OPERATING SCENARIOSOURCE SOURCE INDICATE PRIMARY (P) APPLICABLEID NO. DESCRIPTION OR ALTERNATIVE (A) POLLUTANT REGULATIONES1 Coal/Wood Boiler P-Coal PM NCAC2D.0503

E2

A-Wood PM NCAC2D.0504

MB Fumigation Activities P - Methyl Bromide /VC/IC02D.1112


REVISED 09/22/16

FOR E3EMISSION SOURCE COMPLIANCE IWETHOD

NCDEQ/Division Of Air Quality - ApplicaUon for Air Permit to Construct/Operate

Regulated Pollutant - Methyl Bromide

Applicable Regulation - NCAC 02D.1112Emission Source ID NO. MB

Alternative Operating Scenario (AOS) NO:

ATTACH A SEPARATE PAGE TO EXPAND ON ANY OF THE BELOW COMMENTS

MONITORING REQUIREMENTS

Is Compliance Assurance Monitoring (CAM) 40 CFR Part 64 Applicable?If yes, is CAM Plan Attached (if applicable, CAM plan must be attached)?Describe Monitoring Device Type:

Describe IVIonitoring Location:

Other Monitoring Methods (Describe In Detail):

a YESD YES

B NOB NO

Describe the frequency and duration of monitoring and how the data will be recorded (i.e., every 15 minutes, 1 minute instantaneousreadings taken to produce an houriy average):

N/A

RECORDKEEPING REQUIREMENTS

Data (Parameter) being recording:

Frequency of recordkeeping (How often is data recorded?);

N/A

REPORTING REQUIREMENTS

Generally describe what is being reported:

N/A

Frequency: D MONTHLY

D OTHER (DESCRIBE):D QUARTERLY

TESTING

Specify proposed reference test method:

Specify reference test method rule and citation:

Specify testing frequency:

D EVERY 6 MONTHS

N/A

NOTE - Proposed test method sub ect to approval and possible chan e durin the test protocol processAttach Additional Sheets As Necessary

REVISED 09/22/16

FOR E4EMISSION SOURCE COMPLIANCE SCHEDULE

NCOEQ/Division of Air Quality - Application for Air Permit to ConstructfOperate

COMPLIANCE STA TUS WITH RESPECT TO ALL APPLICABLE RE UIREMENTS

E4

Will each emission source at your facility be in compliance with all applicable requirements at the time of permit issuance and continue to comply withthese requirements?

YES D NO If NO, complete A through F below for each requirement for whichcompliance is not achieved.

Will your facility be in compliance with all applicable requirements taking effect during the term of the permit and meetsuch requirements on a timely basis?

YES D NO If NO, complete A through F below for each requirement for whichcompliance is not achieved.

If this application is for a modification of existing emissions source(s), is each emission source currently in compliance with all applicable requirements?

D YES Q NO If NO, complete A through F below for each requirement for whichcompliance is not achieved.

A. Emission Source Description (Include ID NO.) Methyl Bromide - ME3Br - MB

B. Identify applicable requirement for which compliance is not achieved:

FumigatFon Controllad under supeFvlslon of USDA APHIS staff.

C. Narrative description of how compliance will be achieved with this applicable requirements:

By following directives and instruction from USDA APHIS staff.

D. Detailed Schedule of Compliance:Stepfsl

N/ADate Expected

E. Frequency for submittal of progress reports (6 month minimum):

N/A

F. Starting date ofsubmittal of progress reports: N/A


REVISED 09/2 2/16

TITLE V COMPLIANCE CERTIFICATION (Required)NCDEQ/Dfvislon of Air Quality - Application for Air Permit to ConstrucUOperate E5

in accordance with the provisions of Title 15A NCAC 20 .0520 and .0515W(4) the responsible company official of:

Received

Air Permits Section

SITE NAME:

SITE ADDRESS:

ciry, NC :

COUNTY:

PERMIT NUMBER :

Malec Brothers Tr

1408 Cronly Drive

Delco, NC

Columbus County

N/A

CERTIFIES THAT (Check the appropriate statementts):

_lj The facility is in compliance with all applicable requirements

[^J In accordance with the provisions of Title 15A NCAC 2Q .0515(b)(4) the responsible company official certifies that the proposed minormodincstton meets the criteria for using the procedures set out in 2Q .0515 and requests that these procedures be used to process the permitapplication.

-^1 The facility is not currently in compliance with all applteable requirementsIf this box is checked, you must also complete Form E4 "Emission Source Compliance Schedule"

The undersigned certifies under the penalty of law, that all information and statements provided in the application, based oninformation and belief formed after reasonable inquiry, are true, accurate, and complete.

4 /^/. ^

' ^c.^

Signature of respo e company official (REQUIRED, USE BLUE INK)

/,

Date: Zo

'^Â^Âve^ . ô ('yv^^v-^jName, Title of responsible company official (Type or print)


11/01/2017

FORM E6COMPLIANCE ASSURANCE MONITORING (CAM) PLAN (4 pages)

REVISED 09/22/16 NCDEQ/Dlvlskan of Air Quality. Application for Air Permit to ConstructfOperate E6-1

For CAM-affected emission units, the applicant must submit additional Information In the form of a CAM Plan as required under 40 CFR 64.

For information about the CAM rule and this form, please refer to 40 CFR 64 and 15A NCAC 20 0614.Additional information (including guidance documents may be found at the following URLs:

tjllBS. /Awww. i ena uc'v/ltntemsicamj]tn3liZt^L//ri^!l?-S^_aJ>"uyd!Y@i<3a^JMy-alite/ai:-. auaJily^nte

SOURCE INFORMATION1. Facility Name; Malec Brothers Transport LLC2. Permit Number: N/A

3. Date Form Pre ared:

BASIS OF CAM SUBMITTA1.4. Mark the appropriate box below as to why this CAM Plan is being submitted as part of this a plication:

D Renewal Application: AU; Emission Units (Polliitant Specific Emission Units [PSEUs] considered separately with respect to EACH regulated airpollutant) for which a CAM Plan has NOT yet been approved needs to be addressed in this CAM Plan submittalSee Renewal Procedures per 15 A NCAC 2Q 0513

0 Initial Application (Submitted after 4/20/1998); Only large PSEUs (PSEUs with potential post control device emissions of an applicable regulated airpollutant that are equal to or greater than major source threshold levels) need to be addressed in this CAM Plan submittal.See Initial Application Procedures per ISA NCAC 2Q 0505(1).

[_] Significant Modification to Large PSEUs: Only large PSEUs (PSEUs with potential post control device emissions of an applicable regulated airpollutant that are equal to or greater than major source threshold levels) being modified after 4/20/1998 need to be addressed in this CAM Plan submittalFor large PSEUs with an approved CAM Plan, only address the appropriate monitoring requirements affected by the significant modificationSee Significant Modification Procedures per 15 A NCAC 20 0516

CAM APPLICABIUTY DETERMINATION5. To determine CAM applicability, a PSEU must meet ALL of the following criteria (If not, then the remaindBr of this form need not be completed):

A The PSEU is located at a major source;B The PSEU is subject to an emission limitation or standard for the applicable regulated air pollutant that is NOT exempt,

List of EXEMPT ̂mfssiffn Lifnilations or Standards below OR as provided in 15A NCAC 20 .0614(b)f11:. NSPS (40 CFR Part 60) or NESHAP (40 CFR Part 61 and 63) proposed after 11/15/1990. Stratospheric ozone protection requirements.. Acid Rain program requirements

. Emission limitations or standards for which a Title V permit specifies a continuous compliance determination method, as defined in theCAM rule (40 CFR 64. 1), Continuous Compliance Determination Method

« An emission cap that meets the requirements soecified in 40 CFR 70 4(b)(12)II ths PSEU is subject to both Exempt and Not Exempt emission standards for the same pollutant, then the facility is requirea to detemine theCAM applicability for Wot Exempt emission standards.

C The PSEU uses an add-on control device to achieve compliance with an emission limitation or standard;D The PSEU has potential pre-control device emissions of the applicable regulated air pollutant that are equal to or greater than major source

threshold levels; and

E The PSEU is NOT an exempt backup utility power emission unit that is municpally owned and appropriately documentd as provided in15A NCAC 2D .0614(b){2).


BACKGROUND DATA AND INFORMATION E6-26. Complete the following table for AU^ PSEUs that need to be addressed in this CAM Plan submittal. This section Is to be used to provide

background data and information for each PSEU in order to supplement the submlttal requirements specified in 40 CFR 64.4.If additional space is needed, please attach and label additional sheets as a propriate.

.EmissionPSEU PSEU Control Limitation CTl . 'Monitoring

Des ""tlon Pollutant Davlce Standanl R . rement

Indicate the emission limitation or standard for any applicabls requirement that constitutes an emisson limitation, emission standard, or standard ofperformance Examples of emission limitations or standards may include a permitted emission limitation, applicable regulations, work practices, process orcontrol device parameters, or other forms of specific design, equipment, operational or maintenance requirementsIndicate the monitoring requirements for the control device that are required by an applicable regulation or permit condition.

Attach Additional Sheets As Necessary page 2 of 4

* CAM MONITORiNG APPROACH CRITERIA E6-3Complete this section for EACH PSEU and for each affected pollutant that needs to be address&d in this CAM Plan submiKal. This section may becopied as neaded for each PSEU. This section is to be used to orovide monitoring data and information for EACH indicator selected for EACH PSEU inorder to meet the monHoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected for a PSEU or if additionalspace is need, attach and label with the apprtopriate PSEU designation, pollutant, and indicator Nos.

PSEU DESIGNATION POLLUTANT "INDICATOR N0.1 "INDICATOR NO. 2

7a. General CriteriaDescribe the monitoring approach used tomeasure the indicators

Establish the appropriate indicator iar,^e orthe procedures for establishing the indicatorrange which provides a reasonableassurance of compliance

Provide QyaJ.ilYjnjo. r&wmenl Ran (QIP1Threshold levels

7b. Performance criteria

Provide the SpecificahaDJBrjt&tainingRepresenoiive OBia (Such as detectorlocation and installation specifications)

Provide S'lalitv Assurance and Quality

Control (OA/QC) Practices that are adequateto ensure the continuing validity of the data,

considering manufacturerer's

recommendations

' Provide the MfinitonnflJFrgsiygn. fflProvide the Data Collection Procedures that

will be used

Provide the Data Averaging Period for the

purpose of determining whether an

excursion or exceedance has occurred

If a Continuous Emission Monitoring System (CEMS), Continuous Opacity Monitoring System (COMS), or Predictive Emission Monitoring System (PEMS) is used,then this section need not be completed ONU£ for the GEMS, COMS, or PEMS, EXCEPT that the Special Criteria Information of 40 CFR 64 3(d) must be providedSpecial Criteria Information may be provided on a separate sheetDescribe all indicators to be monitored which satis<y 40 CFR 64 3(a) Indicators of emission control perfbrnnance !br the control device and associated capturesystem may include measured or predicted emissions (including visible emissions or opacity), process and control device operating parameters that affect controldevice (and capture system) efficiency or emission rates, or recorded findings of Inspection and maintenance activities

Indicator ranges may be based on a single maximum or minimum value or at multiple levels that are relevant to distinctly differsnt operating condilions, expressedas a lunction of process variables, expressed as maintaining the applicable indicator in a particular operational status or designated condition, or established asInterdependent between more than one indicator In addition, unless specifically stated otherwise by an applicable requirement, the owner or operator shall monitorthe indicators to detect any bypass of the control deivce (or capture system) to the atmosphereThe QIP threshold is based on the number of excursions identified in a reporting period (Example: if the historical monitoring date (or a facility indicates that theindicator range was exceeded 10 times in a 6-month period, the threshold could be established at no more than 10 excursions outside the indicator range during a6-month reporting period. ) The threshold levels also could be established based on the duration of excursions as a percentage of operating time

At a minimum, the owner of a large PSELI must collect four or more data values equally spaced over each hour and average the values All other PSEUs mustcollect data at least once per24.hour period or possibly more to provide reasonable assurance of complliance Over the anticipated range of operating conditions


RATIONALE AND JUSTIFICATION E6-4Complete this section for EACH PSEU and for each affected pollutant that needs to be addressed in this CAIW Plan submittal. This section may becopied as needed. Use this section to provide monitoring data and informafa'on for EACH indicator selected for EACH PSEU In order to meet themonitoring design criteria specified in 40 CFR 64.3 and 64.4. If more than two indicators are being selected fora PSEU or if additional speace is needed,attach additional sheets and label with the appropriate PSEU designation, pollutant, and Indicator Nos.

POLLUTANT

INDICAT«RS ANB THE MONITQRIN^APPRfilA.Qy, ProvkJe the rationale and justification for the selection of the indicators and the monitoring approach used tomeasure the indicators Also provide any data suporting e rationale and justification Explain the reasons for any differences behAfeen the verification ofoperational status or the quality assurance and control practices proposed and the manufacturer's recommendations (Ifaddiional space is needed, attach andlabel with the aopropirate PSEU designation and pollutant).

10. INDICATOR RANGES: Provide the rationale and justification for the selection of the indicator ranges The rationale and justification shall indicate how EACHindicator range was selected by either a SamElanceoj.PgrfonTSQseJgs!, a Test Plan and Schedule, or by EnainegnnflAgsessmenls Depending on which"method is being used for each indicator range, include the specific information required below for that specific indicator range (If additional space is needed,attach and label with tha appropriate PSEU designation and pollutant):

MPLIANCE or PERFORMANCE TEST (Indicator ranges determined from control device operating parameter data obtained during a compliance orperformance test conducted under regulatoiy specified conditions or under conditions representative of maximum potential emissions under anticipatedoperating conditions. Such data may be supplemented by engineering assessments and manufacturer's recommendations) The rationale and justificationshall include a summary of the compliance or performance test results that were used to determine the Indicator range and documentation indicating that nocharges have taken place (hat could result in a significant change in the control system perfommace or the selected indicator ranges since the compliance orperformante test was conducted and approved by DAQ

. TES1 PLAN ANDSCHEDULE (Indicator ranges wili be determined from a proposed implementation plan and schedule for installing, testing, and performingany other appropriate activities prior to use of the monitoring). The rationale and justfflcation shall Include the proposed implementation plan and schedule !ha!will provide for use of the monitoring as expeditiously as practical after approval of this CAM Plan, but in no case shall the schedule far completing installationand beginning operation of the minitoring exceed 180 days after approval

* ENGINEERING ASSESSMENTS (Indicator ranges or the procedures for establishing indicator ranges are deteimined from engineering assessments and otherdata, such as manufacturer's design criteria and historical monitoring data, because factofs specific to the type of monitoring, control device, or PSEU makecompliance or performance testing unnecessary). The rationale and justification shall include documentaion demonstrating that compliance testing is notrequired to establish the indicator range.

RATIONALE AND JUSTIFICATION:

Attach Additional Shaets As Necessaiy Page 4 of 4

^_., _ ^ ^BROS. TRANSPORT GBOUP"

Facility Map -1408 Cronly Drive, Delco, NC 28436, USA.


PO BOX - 3600 S College Rd STE E - 200Wilmington, NC, 28412

Phone-919-798-7889

Timber Packaging Area(blue) 200ft x 300ft

Transport

Loading/Unloading Area(Green) 1

Fumigation Area (red)60ft x 280ft

ministrative Area

(yellow) 60ft x 130ft

/

Ooooie

^.^'^-^ .1.TnANSponreww



Wilmington, NC, 28412

Phone-919-798-7889

MACT Analysis

MALEC Brothers Transport LLC. (MALEC) submits this application for a case-by-case maximumachievable control technology (MACT) determination pursuant to the U. S. EnvironmentalProtection Agency's (USEPA's) case-by-case MACT regulations at 40 CFR §63. 43.

Following substantial transparent interaction with NCDENR over recent months and logistical analysis withRMS (Red Mountain Timberland manager and sole source ofsawlog supply to MALEC), MALEC hasspecifically secured the 1408 Cronly Drive, Delco, 28436, NC, USA property as a sawlog loading tocontainer and fumigation facility due to its favourable position to the;

^

^

Y

^

Red Mountain forest resource (efficient distribution ofsawlogs),economical transport route to Wilmington Port (haulage route),out-of-town, remote to community location,other industrial sites, (International Paper Co. and other chemical handling industries),

^ Columbus County (county has provided their complete support to this site).

The facility will provide quarantine and pre-shipment (QPS) fumigation services primarily for sawlogsbeing exported through the facility.

The fumigation facility will be designed and operated to comply with the applicablerequirements of the U. S. Department of Agriculture's (USDA) Animal and Plant HealthInspection Service (APHIS), the regulatory body that oversees QPS treatments in the U. S.The primary famigant that will be used at the facility is Methyl bromide (CHsBr, alsocommonly known as bromomethane).

Methyl bromide has been a principal QPS treatment tool of APHIS for over 40 years. In 1992, however,methyl bromide was deemed a depleter of stratospheric ozone under the terms of an international treaty, theMontreal Protocol on Substances That Deplete the Ozone Layer, and therefore subject to "phase-out" of itsuse. USEPA, in implementing the requirements of the Montreal Protocol, has greatly restricted useof methyl bromide. Its use for QPS applications such as those that will be performed at the MALECDelco, NC facility, however, has been preserved until such time as there is a replacementfor it, and consequently it is specifically authorized by the QPS exemption under Title VI(Stratospheric Ozone Protection) of the Clean Air Act (CAA).

Methyl bromide is a hazardous air pollutant (HAP) under CAA § 112. Proposed methylbromide emissions from fumigation activities at the MALEC Delco, NC facility are expected toexceed 10 tons per year. Therefore, the facility will be classified as a major source ofHAPemissions. Major sources ofHAP emissions are subject to USEPA's MACT requirementsunder CAA§ 112.

USEPA has not established a source category under CAA § 112(c) for fumigation facilities norpromulgated MACT standards for fumigation facilities pursuant to CAA § 112(d). Therefore,the MALEC facility is subject to the requirement for a case-by-case MACT determinationpursuant to CAA § 112(g).

The principal business of the facility will be the fumigation ofsawlogs destined for export to othercountries - primarily softwoods destined for numerous ports within China. This fiimigation is conductedunder the direct, on-site supervision ofofiRcers ofUSDA APHIS.



Phone-919-798-7889

APHIS has developed a series of detailed fumigation protocols for commodities through itsPlant Protection and Quarantine (PPQ) division. The protocols and treatment schedules arepublished in the PPQ Treatment Manual, a document of over 900 pages. Further, aU QPSfumigation conducted by MALEC at Delco, NC is performed under the direct, on-sitesupervision of an APHIS officer. In addition, all fumigation at the site is performed inaccordance with USEPA's Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)pesticide label requirements as well as the PPQ Treatment Manual, and applicable internationalphytosanitary standards.

The treatment protocols published in the Treatment Manual are highly prescriptive and dictatedetailed requirements for many aspects of the fumigation process, in particularly the following APHISTreatment Manual requirements:

. Section 2-4: Methyl Bromide Tarpaulin Fumigation

. Section 2-9: Methyl Bromide Closed-door Container Fumigation

USEPA has not listed fumigation operations in any source category pursuant to CAA § 112(c)nor has USEPA promulgated any MACT standards for fumigation sources pursuant to CAA §112(d). No case-by-case MACT determination pursuant to CAA § 1 12(g) has been made forany facility conducting large-scale QPS fumigation using methyl bromide.

MALEC has explored the possibility of performing some sawlog fumigations using sulfiirylfluoride(brand names Vikane and ProFume), a ftimigant that is not classified as a HAP, as areplacement for some of its methyl bromide use. Certain countries have accepted logs treated inother parts of the world with sulfuryl fluoride, but not from the US.

No add-on emission capture device such as a scrubber or filter will be employed at the MALEC facility tocapture and control methyl bromide emissions during aeration. Rather, MALEC will utilize a series of workpractices and jO^eratmgUmits^jmn^ potential impacts from methyl bromide'emissions,

The websites of several air pollution control equipment vendors present information regardingmethyl bromide control systems, As summarized below, after being investigated thoroughly these are notfeasible options for an operation the size of the proposed MALEC operation.

According to their website (http://www. tigg. com/industrial-fumigation. html andhttp://www. tigg. com/news. html) TIGG Corporation and Chemtura Corporation (formerly GreatLakes Corporation) have cooperatively developed a methyl bromide recapture system that is inuse at a handful of fumigation facilities in the US. The system processes air fromfumigation chambers through activated carbon to capture approximately 80 percent of themethyl bromide. The spent carbon must then be transported offsite for disposal or thermalreactivation at a permitted facility.

The TIGG website provides photographs ofskid-mounted systems with relatively small carbonvessels and blowers that are capable of handling emissions from individual containers. Thewebsite also discusses applications for fumigation of food and berries. We note that foodapplications use lower concentrations and lower doses of methyl bromide than are required bythe APHIS protocols for timber. Based on research on the technology, it has beeninstalled only at small-scale food fumigation facilities.

^

^k-fc^^-t^a-. dB -<.^BROS. TRANSPORT GSOUP



Phone-919-798-7889

TIGG has not installed its methyl bromide capture systems at any large-scale log QPS fumigation facilities.

In summary, the TIGG/Chemtura. carbon capture system is not in use at other existing or similar sources,and does not have the capacity required for the sawlog fumigation activities performed at the MALECfacility,

The foltowing discussion regarding Value Recovery's methyl bromide technology is based oninformation provided on its website (www. valuerecovery. net); papers presented at the annualMethyl Bromide Alternatives Outreach conferences; a Powerpoint presentation to the VirginiaDepartment of Environmental Quality; our review of permitting documentation (obtained fromthe San Luis Obispo County Air Pollution Control District) associated with the GuadalupeCooling Company facility in California; and a meeting held with representatives of ValueRecovery on May 6, 2014;? documents provided by the Miami-Dade County Department ofRegulatory and Economic Resources (RER), Division of Environmental ResourcesManagement, regarding the South Florida Logistics Center, and permitting documentationprovided by the Florida Department of Environmental Protection website(http://appprod. dep. state. fl.us/air/emission/apds/listpermits.asp).

Value Recovery, Inc. offers a two-stage system for recovering and destroying methyl bromideemissions from fumigation facilities. We understand that the Authority to Construct (ATC)permit for the M&L Commodities site in California (discussed above) is premised on the use ofthis system. However, as mentioned above the fumigation system at M&L has not beenconstructed, and the ATC has expired.

Information provided by the Value Recovery website indicates that the system employs vapoqihasecarbon adsorption to capture methyl bromide vapors during the aeration phase. Afteraeration is complete, methyl bromide is driven off the carbon using warm air, which is thenintroduced into a scmbber that contains a sodium thiosulfate solution (Note: some of the ValueRecovery literature indicates that the system uses sodium thiosulfate, while other documentsindicate potassium thiosulfate). The methyl bromide reacts with the sodium thiosulfate toproduce methyl thiosulfate and sodium bromide.

The Value Recovery website provides information regarding some laboratory and bench-scaletreatability studies using this approach. We can find no information regarding full-scalecommercial systems. The website provides drawings, but no photographs, offall-scalecommercial systems, and no list of clients or facilities employing such systems is provided.

Nordiko Quarantine Systems Pty Ltd (Nordiko), located in Sydney^Australia, provides cargofumigation systems for the shipping industry. Products identified by its website(www nordiko. com. au) include -fumigation consoles that attach to the rear of individualshipping containers, degassing systems (e. g., small, skid-mounted mobile blowers andductwork) for individual shipping containers, carbon-adsorption based ventilation systems thatcan be used to re-capture residual fumigants (i. e., fumigants that have off-gassed from thecommodity during transportation) from individual shipping containers, gas circulation andheating systems for tarpaulin fumigation systems, a small under-tarp system, and chillerfumigant recovery systems for individual shipping containers.

^3944 River Road Wilmington, NC, 28412


Witmington, NC, 28412

Phone-919-798-7889

The website also includes a trailer-mounted capture system including six 55-gallon dmms ofcarbon, identified as a "Large Scale Mobile Log Stack Fumigant Recapture System. " Based ona methyl bromide carbon adsorption capacity range of 5 percent by weight, this system iscapable of capturing about 65 pounds of methyl bromide.

As previously discussed, fumigation of a typical batch ofsawlogs at the MALEC facilityemploys up to 120 pounds of methyl bromide per hour. Thus, the capacity of the Nordikosystem is well below that required for the MALEC facility.

The Nordiko website does not identify fumigant recovery equipment for large-scale log QPS fumigationssuch as those performed at the MALEC Delco, NC facility. And, as discussed above, there is no indicationthat Nordiko has an office in the United States.

Desclean Belgie N.V. (Desclean), based in Antwerp, Belgium, provided services and equipmentto support various aspects of the fumigation industry in Europe. Desclean reportedly providedsmall, carbon-based methyl bromide adsorption systems, simitar to those provided by others.We understand that Desclean filed bankmptcy and ceased operations during 2011 or 2012. Itswebsite (w\vw. desclean. be) is no longer active.

As previously discussed in this application, the use of methyl bromide for fumigation at thefacility will be performed in accordance with a series of existing regulations and limitations, whilstimplementing techniques and procedures that have been successfully used in our Australian Operations formany years. These additional controls are discussed below;

^ Fumigation will not occur in bulk or stack as it has been found to cause a flooding of the atmospherewhilst ventilating. All fumigations will occur in individual shipping containers with more controlover the release of methyl bromide into the atmosphere. During the ventilation of all fumigations aGas PPM Detector will be used throughout the facility, outside of the initial 30-foot danger zone.The gas alert allows reading of methyl bromide in parts per million. The rate for safe level of methylbromide concentrations being 5ggm, with an acceptable short-term exposure period of^Oppm.During ventilation procedures this device will be constantly monitored and alarms set onceatmospheric rates exceed safe levels. Ventilation will then be suspended whilst management decideon the best course of action moving forward, ie. Wait for higher winds, continue ventilation spacingout the^/entilations, allowing doors to be partially opened rather than fully to allow for adequatedispersant.

As no formal MACT standards have been established for methyl bromide fumigations, MALEC willcontinue to seek and unprove practices as technologies advance, ensuring best possible practice is alwaysfollowed.

There is no viable option for an add-on methyl bromide capture and control system for the large-scale logQPS fumigations nor is there potential to deviate from USDA mandated practices. There is no large-scalesawlog QPS fumigation facility anywhere in the United States employing an add-on capture and controlsystem for methyl bromide. Thus, add-on capture and control systems such as carbon adsorption andincineration or disposal are not "achieved in practice" by any other similar source. However, there areoperational and other work practices, both those specified by USDA APHIS and those proposed byMALEC, that can be employed as MACT to reduce the ambient air concentrations of methyl bromideemitted from the MALEC facility.

^-^(^i-/^r: lV/7/;<f^^^\^/RECEIVED.

Zoning Consistency Determination DEC 2 ° 2017

AQ WIROFacility Name V-

Facility Street Address J i+D?, CR^fJty DRIV/^ DfiLm, N-C, ^^^

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Facility City

Description of Process

SIC/NAICS Code

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Phone Number

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Bas on the infonnation iven above:

I have received a copy of the air permit application (draft or final) AND...

n There are no applicable zoning ordinances for this facility at this time

r The proposed operation IS consistent with applicable zoning ordinances

F~ The proposed operation IS NOT consistent with applicable zoning ordinances(please include a copy of the mles in the package sent to the air quality office)

n The determination is pending further infonnation and can not be made at this time

P/ Other: s ' ^ i-o ;'^ U^ ^ rows Sr.^^1^ F ^ s c^ef ('Plo^nn^ Bo^^ ^ Jfl. M. u.^r^' /<{"^. (S^r^, e, /)A^si'ftvz^s

Agency

Name of Designated Official

Title of Designated Official

Signature

Date

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Please forward to the facility mailing address listed above and the air quality officeat the a ro riate address as checked on the back of this fonn.

Courtesy of the Small Business Enviromnental Assistance Programsb.ncdenr. ov 877-623-6748

Patel, Urva P

From:Sent:

To:Cc:Subject:

James Harris <[email protected]>Tuesday, January 23, 2018 11:27 PMWillets, William; David Smith; Pjetraj, Michael; Cuilla, MarkMatthew Malec; Newland, Brad; Carroll, Dean; Willis, Linda; Patel, Urva P; Reid, MikeRE: [External] Draft Permit Comments

CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment toreport.spam @ nc.gov.

William,

Please find our comments to the questions below, highlighted in red. If you have any further questions pleasedo not to hesitate to make contact ASAP.

. What commodities will Malec be fumigating?

-Southern Yellow Pine Logs in 40' Shipping Containers.

Note that the allowable fumigant will be limited to methyl bromide as prescribed in the permitapplication.

-Agreed, Methyl Bromide is the only fumigant used.

. Please confirm that Malec will only fumigate commodities in containers and that no bulk fumigationwill be used.

-Malec will only fumigate in 40' Containers, no bulk fumigation will occur on site.

What is the methyl bromide charge rate (lb/1000ft3)?

-The rate is dependent on temperature, with colder temperatures requiring higher dosage. Themaximum dosage rate in the coldest temperature will be 51b/1000ft3. In weather over 70 degreesFahrenheit this rate reduces to 31b/1000ft3.

What is the total methyl bromide charge per fumigation based on fumigating 300 containers of 2700cubic feet per container per week (Ib)?

-In temperatures under 70 degrees (Assuming all containers are High Cube) (2700/1000*5*300) =, 4, 050

y/ .^'1; 4, 050 LB per week

- InTefffperatures over 70 degrees (Assuming all containers are high cube) (2700/1000*3*300) = 2, 430-^T

LB per week

. What is the treatment time (hr)?

-Standard treatment time is 16 hours, this can be extended to 24 hours if required due to top up/redose asrequired.

. What is the retention rate (%)? There seems to be some discrepancy between the application and oneof your responses below.

-In application I did advise all product is ventilated, our equipment measures concentrate in containerand also parts per million and have never been able to confirm the actual amount released. Afterdiscussions with Jim Sargent our Entomology expert he has been able to confirm that whilst we areventing due to molecular breakdown between the actual amount ventilated is between 40-60%, 50%as an average. Unfortunately in our operations we have not been able to measure this and are relianton our experts opinion.

. What is your aeration technique (passive or active) and air exchange, rate (/hr)? Your presentation onJanuary 16 seemed to indicate that you would be using a fan and stack but one of your commentsbelow implies that that is no the case.

-Our aeration process is active and involves/ circulation fans that are installed in the containers for

fumigation and also the use of a high powered fan connected to the duct system as presented.Originally when permit was submitted we were only looking to use the circulation fans for ventilation.After further communication between NCDNR, our supplier Cardinal Pro and internal conversations wehave developed this active system to achieve best possible practice.

What is the total aeration time for approximately 45 containers per day (300 per week)?

-This is difficult and is dependent on many variables, as a general rule 4 hours per container for activeventilation will suffice, the bulk of the gas leaves within the first 10 minutes. With desorption of thecommodity resulting in the remaining low level gas output. This would then take approximately 6hours.

. Describe the stack (if used) parameters. Height, diameter, flow rate.

-Yes stack to be used, 30 foot stack. 16" Ducting connected to a high powered fan with a minimumcapacity of 5200cfm. The fan we are having built by engineers actually exceeds GOOOcfm, with theUSDA standard of 5200cfm minimum introduced to our procedures.

^A &^'. <-^1 6©^l4<t-t^u!.^ <^ ^+UjeAJ>^ teSAtn O^

.^. What is the Methyl Bromide Commodity Fumigation Buffer Zone based on the worst case scenario for

the above parameters.

-According to the EPA website 10 Feet. According to the USDA Methyl Bromide Treatment Manual 30feet during aeration.

I hope the above has clearly answered your questions and once again do not hesitate to contact us with furtherquestions.

Regards

James Harris

Chief Operating Officerlee Brothers Transport Group

ames malec. com. au

Phone Australia - +(613) 5274-1000Phone USA - +(1) 910-232-3723

^ '

From: Willets, William [mailto:william. willets@ncdenr. gov]Sent: Wednesday, 24 January 2018 5:01 AM

To: James Harris <james@malec. com. au>; David Smith <david. smith@smithagriinternational. com. au>; Pjetraj, Michael<michael. pjetraj@ncdenr. gov>; Cuilla, Mark <mark. cuilta@ncdenr. gov>Cc: Matthew Malec <matthew@malec. com. au>; Newland, Brad <brad. newland@ncdenr. gov>; Carroll, Dean<dean. carroll@ncdenr. gov>; Willis, Linda <linda. willis@ncdenr. gov>; Patel, Urva P <Urva. Patel@ncdenr. gov>; Reid, Mike<mike. reid@ncdenr. gov>Subject: RE: [External] Draft Permit Comments

James,

Please see below for responses to your initial comments highlighted in red,

Please provide responses to the following questions. Your responses to this additional information request willbecome part of your initial permit application received November 21, 2017. Your responses should not delayour continued development of the permit conditions/ but please respond in as timely a manner as possible.

What commodities wilt Malec be fumigating?

. Note that the allowable fumigant will be limited to methyl bromide as prescribed in the permitapplication.

Please confirm that Malec will only fumigate commodities in containers and that no bulk fumigationwill be used.

What is the methyl bromide charge rate (lb/1000 ft3)?

What is the total methyl bromide charge per fumigation based on fumigating 300 containers of 2700cubic feet per container per week (Ib)?

. What is the treatment time (hr)?

What is the retention rate (%)? There seems to be some discrepancy between the application and oneof your responses below.

. What is your aeration technique (passive or active) and air exchange rate (/hr)? Your presentation onJanuary 16 seemed to indicate that you would be using a fan and stack but one of your commentsbelow implies that that is no the case.

What is the total aeration time for approximately 45 containers per day (300 per week)?

Describe the stack (if used) parameters. Height, diameter, flow rate.

What is the Methyl Bromide Commodity Fumigation Buffer Zone based on the worst case scenario forthe above parameters.

Thanks,

William

William D. Willets, P. E.Chief, Permitting SectionDivision of Air QualityNorth Carolina Department of Environmental Quality

9197078726 officewilliam.willets ncdenr. ov

217 W. Jones Street1641 Mail Service CenterRaleigh, NC 27699-1641

t -^"Nothing Compares-^^s-

Email correspondence to and from this address is subject to theNorth Carolina Public Records Law and may be disclosed to third parties.

From: James Harris mailto:"ames malec. com. au]Sent: Monday, January 22, 2018 9:22 AMTo: David Smith <david. smith smitha riinternational. com. au>; Pjetraj, Michael <michael. etra' ncdenr. ov>; Willets,William <william. willets ncdenr. ov>; Cuilla, Mark <mark. cuilla ncdenr. ov>Cc: Matthew Malec <matthew malec. com. au>; Newland, Brad <brad. newland ncdenr. ov>; Carroll, Dean<dean. carroll ncdenr. ov>

Subject: [External] Draft Permit Comments

CAUTION: External email. Do not click links oropen attachments unless verified. Send all suspicious emailas an attachment toreport. spam (S) nc. gov.

William & Team,

Further to our presentation to you and the NCDEQ team in Raleigh, NC, last Tuesday and your offices supply of the DraftAir Permit Conditions for our review, we are pleased to provide comment below; We are also pleased to inform you,that our application to Columbus County for the special use permit for our Delco site was formally and unanimouslyapproved Tuesday evening.

Upon review of the Draft Air Permit Conditions, and following consultation with our US entomology expert, we drawyour attention to discrepancies between the Product Label, EPA requirements and the Draft permit. These discrepanciesare highlighted below;

Whilst it would be easy just to accept the terms and conditions, we believe it paramount to ensure that all parties areaccurately informed of all processes in our continuing transparency.

Section H (i) Refers to the use of a buffer zone of 250 feet. As you saw within our presentation this distance is wellbeyond the physical boundary distances of our Delco site. It is also highlighted that the Product Label requires aminimum 10 feet requirement for aeration buffer zones which is also consistent with EPA requirements, USDA PPQrequirements require a minimum 30'. We would ask that the zone be logically reduced to 30' which provides consistencybetween the EPA, Product Label and USDA requirements. We note; we are only completing container fumigation on siteand no stack work, resulting in the largest possible chamber being a HQ.40' container with a square foot capacity of2,700 cubic feet.

The below document is published on the EPA website:

Methyl Bromide Commodity and Structural Fumigation Buffer Zones

Active Aeration: Open Area Vertical Stack 25 feet

Aeration Time: Under 8 hours

htt s: www. e a. ov sites reduction files 2015-10 documents mebrbz aer25ft o en area 8 or less. df

We will re-evaluate this upon receiving the information requested above.

Section H (ii) - Informing local community prior to starting fumigation. We have attended two public hearings inrelations to our planned operations and proactively addressed all resident or committee concerns through these publicforums. These forums were part of Malec being issued a Special Use Permit to fumigate on site, this has now beenissued by Columbus County. To re-notify residents when there have already been public notices and perimeter signingaround the Delco property appears excessive and of little practical benefit.

The practical benefit to notifying neighbors of the ongoing fumigation operations is to avoid any unintentional intrusiononto the fumigation site and inform people of signs of exposure and appropriate medical treatment for any saidexposure.

Section H (iii) - To place signage. We propose the placement of signage on each approaching entry point to the actualfumigation site, not the property itself. The fumigation site will be contained behind a physical chain barrier withbollards at each corner which closes the site to any access (not just public, but sub contractors and workers on site). Wepropose that signage be placed on all 4 sides of the danger zone/fumigation zone as to clearly define this area. Ourmethod of signage ensures that the danger zone is clearly signed to prevent unauthorised access.

This approach seems reasonable and will be verified by our inspectors before operations commence.6

Fumigation Method/Technique Section J. We propose to use the same methods and techniques for all fumigations aswe have successfully undertaken (without incident) within Australia for many years. We believe any deviation or changeto the process should be provided to the regional supervisor prior to implementation rather than on a specifictimeframe.

We wilt re-evaluate this upon receiving the information requested above.

Section J (iii) High levels of Methyl Bromide release can only occur in a highly unlikely event, ie; a truck crashing throughpermitter fence at high speed and crashing into chemical storage area. We propose that any spill of bromide exceeding100 pounds would be reportable as DOA will also need to be notified.

We will re-evatuate this in light of federal 112® requirements.

Section K(i) We would ask for clarification, highlighting the requirement for "Information for Neighbours"

See responses to h(ii) and (iii) above.

Section K (ii)We find this statement unclear. We believe that, rather than monitoring at the property boundary,monitoring should occur outside the immediate danger/buffer/treatment zone. This ensures, not just public, but alsoworker safety within the site. If levels of Sppm are exceeded outside the danger area then the danger/treatment andbuffer zones need to be extended. If 5ppm is exceeded outside the safety area then property boundary monitoring willbe required immediately. If property boundary levels exceed Sppm (except in reportable, emergency situations) thenfumigation will be suspended until appropriate procedures are in place that have been verified by an externalfumigation expert and regional manager for Air Quality notified.

Please be aware that levels of methyl bromide that are safe for workers who are subject to limited exposure times andP{PE requirements are not necessarily protective of general public health. We are re-evaluating monitoring,recordkeeping and reporting requirements.

Section K (A) Not all fumigation would be released, please see below; statement from our independent US expert inFumigation and Entomology, Mr James Sargent.

"The range of emissions generally, is somewhere between 40% and 60% or an average just under 50%. In other words,not all the fumigant used is emitted. The methyl bromide molecule is an active molecule and may brominate ormethylate other molecules besides being tied up in the logs or substrate. You can still provide records of the amount ofmethyl bromide used but the amount used should not be the consideration of the quantity of methyl bromideemissions"

Please review the questions above regarding aeration and retention rate. The permit application indicates that 100% ofthe fumigant used will be emitted.

Section K (B&D) Remote monitoring devices are used and worn by all fumigation personal wherein concentration levelsover 5ppm whilst in the danger zone are monitored. We believe that all readings exceeding 5ppm outside the dangerzone should be reported. Exceedance of this level outside property boundary (except in emergency situations) wouldresult in shutdown and independent audit of procedures as suggested above, it also contradicts section K(ii) of thepermit.

We are re-evaluating monitoring, recordkeeping and reporting requirements.

Section M (i) Dates will need to be updated once permit issued.7

These dates are actually fixed for purposes of defining the 12-month recordkeeping requirements.

Section 0 becomes irrelevant if the above suggestions are implemented, as we propose that any change inmethodology/procedures be notified before occurrence.

We will re-evaluate this upon receiving the information requested above.

We trust the above comments make sense. We encourage you to promptly adopt same and to now move to the publicnotification period.

We are continuing with internal review of these permit conditions And hope to remain on the schedule discussed lastTuesday.

Regards

James Harris

Chief Operating Officerlee Brothers Transport Group

"ames malec. com. au

Phone Australia - +(613) 5274-1000Phone USA - +(1) 910-232-3723

^

BIKS. nwHS

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