6033_OrbitEnergy_email_20170712

From:
Aja, Deborah
Sent:
Wednesday, July 12, 2017 11:05 AM
To:
Wilson, Donna; Rice, Sarah M
Cc:
Watkins, Jason; Bradford, Teresa
Subject:
FW: Concord Energy Partners, LLC / Orbit Energy Charlotte, NC -- AD Plant, 600
Johnson Road, Charlotte, NC
Attachments:
Orbit Charlotte - Revised Waste Water Permit 6-1-17.pdf; ATT00001.htm;
Reception Cert Letter.pdf, ATT00002.htm; ABN Dwgs sent w Reception Cert.pdf;
ATT00003.htm
Donna and Sarah,
Please see the attachments from Joe Hack as well as the email below in case you did not already receive this
information.
Thanks,
Deb
Deborah Aja, Western District Supervisor
Field Operations Branch —Solid Waste Section
NCDEQ, Division of Waste Management
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
http://porta1.ncdenr.org/web/wm/sw
deborah.aia(@ncdenr.gov
Email correspondence to and from this address is subject to the North Carolina Public Records Law
and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Hack, Joe [mailto:[e-mail]]
Sent: Tuesday, July 11, 2017 5:53 PM
To: Aja, Deborah <[e-mail]>
Cc: Bradford, Teresa <[e-mail]>; Caudle, Aaron
<[e-mail]>
Subject: Fwd: Concord Energy Partners, LLC / Orbit Energy Charlotte, NC -- AD Plant, 600 Johnson Road,
Charlotte, NC
Deb, per our discussion I visited the site today. Below is the email they sent as a followup
Joe Hack

Mecklenburg County Solid Waste
from my Phone
Begin forwarded message:
From: "Zack Morgan" <[e-mail]>
To: "Hack, Joe" <[e-mail]>
Subject: Concord Energy Partners, LLC / Orbit Energy Charlotte, NC -- AD Plant,
600 Johnson Road, Charlotte, NC
Joe,
Good to meet you this morning. As I mentioned during our meeting, I am in-
house counsel with Entropy Investment Management, LLC which is the
management company for the majority owner of the AD plant located at 600
Johnson Road, Charlotte, NC. I wanted to take a moment to respond to the
deliverables and questions that you requested and raised this morning:
Financial Responsibility Obligations. As we discussed this morning,
the ownership structure for this facility is a bit complicated, but long
story short, the financially responsible party under all of the permits
is Orbit Energy Charlotte, LLC. Orbit Energy Charlotte, LLC is a
subsidiary of the holding company Concord Energy Partners, LLC,
which is majority owned by York Renewable Energy Partners, LLC
and minority owned by Bluesphere Corporation. Entropy
Investment Management, LLC (my employer) is the local asset
management group for York Renewable Energy Partners, LLC and
Entropy has engaged Mabon Energy, Inc. and EG Engineering
Services to manage the onsite construction and operation services,
respectively, being performed by its EPC Contractor Auspark LLC
which is the contractor constructing the site. Again though, the
FROs rest with Orbit Energy Charlotte, LLC.
2. Signage. If the signage out front at the street needs to match the
financially responsible party, we can have the signage modified
from Concord Energy Partners, LLC to Orbit Energy Charlotte,
LLC. Just let me know.
Wastewater Permit. Per your request during our conversation,
attached is a copy of the Wastewater Permit that we received for
the site from CLTWater. Please let me know of copies of any other
permits that you need. I believe all permits/site documentation
have been provided to Donna and DEQ but let me know of anything
that is missing.
4. Status of Construction Completion. We anticipate completing all
remaining construction and DEQ-requested modifications by August
15, 2017. I, along with Orbit Energy Charlotte, LLC's outside
environmental consultant Bruce Hickman with Hart Hickman, have

been coordinating with Donna Wilson at DEQ regarding the
finalization of the remaining conditions to transition our Permit to
Construct into a Permit to Operate. Bruce submitted the attached
certification on May 12, 2017. Neither Bruce nor I have received
any response from Donna to the certification submitted by Bruce to
Donna. We continue to finalize the construction of the remainder
of the facility in order to make way for the full pre -operative
inspection of the facility.
Anticipated Operations Date. We would anticipate being
operational under the full permit to operate on or around
September 1, 2017. Currently, the biggest open conditions that I
am aware of are in order to achieve this date are: (1) completion of
construction and implementation of modifications to the receiving
building requested by DEQ (noted in Bruce's certification letter
attached), and (2) the final inspection and certification of our site by
our independent engineer, Char-Meck permitting, CLTWater and
DEQ.
If there's any other information that I can provide in the meantime, please let
me know. Otherwise, we will continue to work toward construction completion
and will continue ramping up the facility in anticipation for the final inspection
and certification to DEQ.
Thanks,
Zack
Zack Morgan
Deputy General Counsel
Entropy Investment Management, LLC
14120 Ballantyne Corporate Place
Suite 400
Charlotte, NC 28277
zack.morgankEntropyIM.com
[phone]

CITY OF CHARLOTTE
CHARLOTTE WATER
CHARLOTTE, NORTH CAROLINA
PERMIT
To Discharge Wastewater Under The
Industrial Pretreatment Program
Permit Number 5016
In compliance with the provisions of Chapter23 ofthe Charlotte City Code, North Carolina General Statute 143-215.1, 40 CFR403, and
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission and the
City of Charlotte, the following industry,
Orbit Energy Charlotte LLC
hereafter referred to by name or as the Permittee, is hereby authorized to:
I. Operate a pretreatment facility, consisting of an equalization tank biological treatment with activated slud., and a DAF
system for clarification and recovery f activated slud,e located at 600 Johnson Road. Charlotte NC 28206-
2. After receiving authorization to construct from the Control Authority, construct and operate additional pretreatment units
as needed to meet final effluent limitations, monitoring requirements and all other conditions set forth in Parts 1, 11, and If[
hereof; and
3. Discharge wastewater from the pretreatment facility into the Sugar Creek Wastewater Treatment Plant, NPDES Number
NCO024937 in accordance with effluent limitations, monitoringrequirements and all other conditions set forth in Parts I,11
and III hereof.
This permit shall become effective October 1, 2016.
The permit modification shall become effective Jane 12017
This permit and the authorization to discharge shall expire on May 31, 2019.
Bill Gintert
Environmental Compliance Manager
Charlotte Water - System Protection
Environmental Management Division
4222 Westmont Drive
Charlotte, North Carolina 28217
Modified 6/1/2017

Pan I - Page I
Permit # 5016
PART L EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
A. Description of Discharges
Pine Description
001 Wastewater is generated from the pretreatment of liquid digestate that comes from the anaerobic digestion of organic food
waste. Pretreatment wastewater includes process wastewater, air -pollution control wastewater, equipment washdown, facility
washdown, and chiller condensate.
Pi
LE

Part I -Page 2
Permit # 5016
B. Effluent Limits And Monitoring Requirements -Final
Upon completion of Part 1. C.
1 and lasting until May 31 2019, the Permittee is authorized to discharge from Pipe 001 to the City of
Charlotte's POTW, Sugar Creek Wastewater Treatment Plant, NPDES Number NC0024937. This discharge shall be limited and
monitored as specified below.
Parameters and prohibitions not included below shall be regulated and limited in compliance with the
sewer use ordinance and all applicable federal categorical regulations.
Effluent Limitations (m¢/L)
Monitoring
Frequency
artless
otherwise noted
Limited
Daily Sample
Parameter
Maximum Type
City
Permittee
Flow (1)
0.124 MGD Metered
4**/3 months
Continuous
Ammonia as N
*** Comp.
4**/3 months
4**/3 months
CBODs
2100 Comp.
4**/3 months
4**/3 months
COD
*** Comp.
4**/3 months
4**/3 months
Cd,T
*** Comp.
4**/3 months
4**/3 months
Cr,T
** Comp.
4**/3 months
4**/3 months
Cu,T
*** Comp.
4**/3 months
4**/3 months
Hg, T
** Comp.
4**/3 months
4**/3 months
Cyanide
*** Grab
4**/3 months
4**/3 months
Oil & Grease,T
100 Grab
4**/3 months
4**/3 months
Ni,T
*t* Comp.
4**/3 months
4**/3 months
N, T
*** Comp.
4**/3 months
4**/3 months
Ag,T
*s* Comp.
4**/3 months
4**/3 months
TSS
**• Comp.
4**/3 months
4**/3 months
Zn,T
*** Comp.
4**/3 months
4**/3 months
PH
! S.U. Grab
4**/3 months
4**/3 months
Phosphorus, T
22 Comp.
4**/3 months
4**/3 months
PCB (2)
<0_003 Comp.
1**/3 months
1**/3 months
Total Toxic 5.O mg/ I Comp/Grab 1**/3 months 1**/3 months
Organics (3)
* pH must be greater than or equal to 6.0 and less than or equal to 12.0 at all times.
'* Grab or 24-how flow proportional composite samples collected for few consecutive discharge days or the given number
on the monitoring frequency
*** No limits at this time, only monitoring.
(1) Wastewater meter.
(2) See Part 111, F
(3) Total Toxic OWapics ("TTOs") is defined as all forgeable, base/neutral, and acid organic compounds specified in the "scope
and applicati ortions of 40 CFR, Part 136. Please see Part 111, E.
Modified 6/1/2017

Part 1- Page 3
Permit # 5016
C. Schedule of Compliance
The Permittee shall achirve rmmnlianre in ar-ri..,,.rsa..i
Activity
Deadline
A.
Complete the installation and calibration of the approved flow measurement
Prior to any process wastewater
devices for the process discharge monitoring point,
discharge.
B.
Notify CLTWater —System Protection in writing 48 hours before fast
48 hours before first discharge
discharge of process wastewater, and submit flowmeter calibration completed
by a manufacturer's authorized service representative.
2. The actions and time schedule set forth above may only be modified by written agreement of the parties upon the written
request of the Sewer Customer. Any request for amodification mustbe submitted in writing to the Environmental Compliance
Manager at least ten(10) days before the deadline which is proposed to be modified. Such request may be permitted, denied, or
made subject to such conditions as the Environmental Compliance Manager may determine in his/her sole and absolute
discretion.
D. Monitoring and Reporting
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored
discharge. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before
the effluent joins or is diluted by any other wastestream, body of water or substance. Monitoring points shall not be changed
without notification to, and approval by, the permit issuing authority.
2. Reporting
The Permittee shall monitor February, May, August, and November for the parameters listed in Part I, B.
above per Chapter 23 of the Charlotte City Code. Monitoring information documented on the CLTWmc,SP
developed forms along with a completed Periodic Self -Monitoring Report ("PSMR") Certification form shall be
delivered to the Control Authority no later than the twentieth day of the month following the month in which the
samples were taken. If no discharge occurs during the reporting period, "no discharge" shall be reported. Copies
of these and all other reports required herein shall be delivered to the Control Authority at the following
address. Electronic reporting and the use of electronic signatures are also permissible, see SUO Section 23-91
(P)
Charlotte Water
System Protection
4222 Westmont Drive
Charlotte, North Carolina 28217
b. If sampling performed by the Pennittee indicates a violation(s), the Permittee shall notify the Control Authority
within 24 hours of becoming aware of the violation(s). The Permittee shall also repeat the sampling(fom
consecutive discharge days) and analysis for the parameter(s) in violation and deliver the required monitoring
information, documented on the CLTWater-SP developed forms, along with a completed PSMR Certification
form to the Control Authority within thi ty(30) days of becoming aware of the violation(s).
3. Definitions
In addition to the definitions in the City Code, the following definitions and requirements apply:
a. A "comp." sample for monitoring requirements shall be defined as:
A 24 hour flow proportional composite sample which consists of a series of aliquots of equal volume collected from a
representative point in the discharge stream over a 24 hour period with the time intervals between aliquots determined
by a preset number of gallons passing though Pipe 001. Flow measurement between aliquot intervals shall be
determined by the approved flow measurement device, and the preset gallon interval between aliquot collection fixed
at no greater than 1/24 of the expected total daily flow through Pipe 001.

Part I -Page 4
Permit N 5016
b. A"grab" sample for monitoring requirements is definedas a single"dip and take' sample collected at a representative
point in the actively flowing discharge stream.
c. "4"/3 months" is defined as monitoring for four consecutive discharge days every three months. "1 **/3 months" is
defined as monitoring for one discharge day every three months.
d. "Continuous" for the purpose of flow monitoring is defined as the measure of discharge flow from the £ecilitywhich is
documented in the forth of a strip chart and occurs without interruption.
e. "Daily" or "day" is defined as any 24(twenty-four) how period.
f. "Control Authority" is defined as the City of Charlotte's Charlotte Water- System Protection ("CLTWater-SP").
g. "POTW" is the abbreviation for publicly owned treatment works.
h. The City of Charlotte Sewer Use Ordinance is contained in the Charlotte, North Carolina, City Code chapter 23,
article III.
4. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the methods prescribed in 40 CFRPart 136
and amendments thereto (unless specified otherwise in the monitoring conditions of this permit) by a laboratory certified by the
State of North Carolina to perform the analyses required on pretreatment program samples.
5. Additional Monitoring by Permittee
If the Permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using
approved analytical methods as specified above, the results of such monitoring shall be deliveredto the Control Authority. The
Control Authority may require more frequent monitoring or the monitoring of other pollutants not required in this permit by
written notification.
6. Reporting Requirements
a. Required analytical information shall be documented on the form prescribed by the CLTWater-SP known as the City
of Charlotte Industrial User CLTWater-SP Periodic Self -Monitoring Report("PSMR") Form by the laboratory
performing the analyses. Required information may include, but shall not be limited to, the following:
1. permit number and name of the industrial user(Permittee);
2. date sample(s) collected, interval flow volume and corresponding CDC number;
3. lab sample id, laboratory time, N.C.W.W. Laboratory Certification number, name and signature of
laboratory supervisor, and date signed; and
4. prep and analytical methods, prep and analysis start date(s) and times, prep and analysts initials, the
detection limit of the analysis and the analytical result in mg/I and/or parameter specific units.
b. Required sample handling and collection information shall be documented on the form prescribed by the CLTWater
SP known as the City of Charlotte Industrial User CLTWater-SP Chain of Custody ("CDC") Record Form. Required
information may include, but shall not be limited to, the following:
1. CDC number, permit number, permit effective dates, time of the industrial user (Permittee), and physical
facility address of the industrial user(Permittee);
2. sample type(composite or gab), composite type(flow, time or hand), and composite start and stop date(s)
and times;
3. time and signature of sample collector;
4. date sample(s) collected, time(s) grab(s) collected and time composite poured into individual sample bottles,
and sample(s)' description and location;
5. container type(plastic or glass) and volume, as well as number of containers, chemical preservative, and
analyses requested;
6. lab use only sections requiring documentation of lab sample id number(s), if samples were received on ice
and properly field preserved, ifvolatile organic samples had zero headspacs and Teflon septa, and if samples
were in proper containers upon receipt into the lab; and

Pan I -Page 5
Permit # 5016
7. date(s) and times samples relinquished and received prior to and upon receipt into the lab, the signatures and
affiliation of all individuals handling the samples prior to and upon receipt into the lab, and the N.C. W. W.
Certification Number of the lab receiving the samples(documented w the affiliation of the individual
receiving the samples for the lab).
c. Required composite sampling details, flow readings, and field pH information shall be documented on the form
prescribed by the CLTWater-SP known as the City of Charlotte Industrial User CLTWater-SP Field Measurement
Record ("FMR") Form. Required information may include, but shall not be limited to, the following:
1. time of industrial user(permittee), physical address of the facility, sampling location, and corresponding
COC number;
2, automatic composite sampler information such as composite type(flow, mtime), the identity of the individual
who programmed the sampler, programmed start collection date and time, actual samplerend collectiondate
and time, number of aliquots comprising the composite, programmed pulse or time interval, sampler flow
pulse equivalent, and documentation as to whether or not the composite sample was iced during collection;
3. hand composite information such as process wastewater start and stop discharge date(s) and times, aliquot
collection times, identity of the individual collecting the aliquots, and documentation as to whether or not the
aliquots were chilled upon collection;
4. flow measurement information such as meter type(s)(i.e. wastewater, water, in -product, etc.), meter reporting
units, dates and times non-resettable totalizers read initially and finally, final and initial non-resettable
totalizer readings, interval flow volume in gallons, and the identity of the individual(s) obtaining the non-
resettable totalizer readings;
5. field pH measurement information such as date and time pH sample collected, time field pH analysis
performed if different from the collection time, identity of the individual(s) collecting and analyzing the pH
sample, the pH result in S.U. as well as the sample temperature(in Celsius); and
6. miscellaneous information such as whether or not "upon set up of the automatic sampling equipment for day
1, the sample collection bottle and tubing were clean and if not, why?".
d. The Permittee shall certify to the accuracy of the self -monitoring submittal by properly completing the form
prescribed by the CLTWater-SP known as the City of Charlotte Industrial User CLTWater-SP Periodic Self.
Monitoring Report("PSMR") Certification Form, and having the appropriate company otficiahsee Part II, I. of this
permit) sign where specified. Required information may include, but shall not be limited to, the following:
I. permit number and time of the industrial user(permittee);
2. sample date(s) and monitoring event type(s);
3. documentation of violations(if my) as well m when and how the CLTWater-SP was notified ofthe violations
to comply with Part I, C. 2. b. of this permit; and
4. the time, signature, and title of the company official making the certification as well m the date signed.
D. Flow Measurement & Monitoring Point
I. The Permittee shall provide and operate monitoring facilities for the inspection, sampling and flow measurement of the
Permittee's process wastewater discharges.
2. The approved wastewater meter shall be calibrated, at a minimum, once every six months by the manufacturer's authorized
service representative.
3. The Permittee is responsible for the periodic maintenance and calibration of the approved measurement device to assure
accuracy. The Permittee shall, upon request of the Control Authority, furnish maintenance and calibration records.
4. There shall be inter face capability with an lsco model composite sampler (contact closure); the interface We shall be purchased
by the Permittee. The Control Authority monitoring shall take precedence; therefore, a splitter cable, purchased by the
Permittee, will enable both the Control Authority and the Permittee to monitor at the same time and insure no interruption
occurs in the Permittee's self -monitoring event.
5. The wastewater meter must have a non-resettable mechanical totalizer that reads in cubic feet or gallons.

Part I -Page 6
Permit # 5016
6. The wastewater meter most have permanent flow records (i.e. strip chart recordings) that include the following basic
information: date, time, totalizer reading (with units), interval flow volume (with wits), maximum flow rate (with units),
primary measuring device type, and scale of the chart printout (with units). Any interruption in such records is a violation of
this permit and may result in a fine of at least $100.00 each day the interruption is allowed to continue.
7. Flow monitoring equipment and the sampling point shall be located in an area accessible to the Control Authority personnel
without prior notification. The Control Authority most be supplied with any keys and/or other tools necessary to perform the
aforementioned.
8. There shall be no by-pass capability of the wastewater metering devices and monitoring point(s). Bypass is prohibited and the
Control Authority may take enforcement action against a user for an unauthorized bypass. The Permittes is required, within
thirty days after receipt of this permit, to deliver to the Control Authority certification that all process wastewaters discharged
into the City of Charlotte's POTW, flow through pipe 001 as specified in Part I, A. of this permit.
9. The wastewater meter shall have a back-up power source (battery or generator) to insure uninter omed measurement of the
discharge flow in the event of power failure. The back-up source shall provide power to the wastewater meter's sensor and
strip chart for a minimum of 12 hours.
10. The Permittee shall maintain strip charts and maintenance and calibration records for a minimum of three years.

Part II - Pagel
Permit # 5016
GENERAL CONDITIONS
A. Duty to Comply
The Permittee must comply with all conditions ofthis permit. Any permit noncompliance constitutes a violation of the City Code
and is grounds for possible enforcement action including, but not limited to, $25,000.00 Civil Penalty per occurrence.
B. Duty to Mitigate - Prevention of Adverse Impact
The Permittee shall take all reasonable steps to minimize orprevent any discharge in violation ofthis permitwhich has areasonable
likelihood of adversely affecting human health, the POTW, the waters receiving the POTW's discharge, or the environment.
C. Facilities Operation
The Permittee shall at all times maintain in good working order and operate as efficiently as possible, all control facilities or systems
installed or used by the Permittee to achieve compliance with the terms and conditions of this permit. Bypass of treatment facilities
is prohibited except when approved in advance by the Control Authority. Bypass approval shall be given only when such bypass is
in compliance with 40 CFR 403.17.
D. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be disposed
of in a manner such as to prevent any pollutants from such materials from entering the POTW. The Permittee is responsible for
assuring its compliance with any requirements regarding the generation, treatment, storage, and/or disposal of "Hazardous Waste" as
defined under the Federal Resource Conservation and Recovery Act.
E. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary noncompliance with the effluent
limitations of this permit because of factors beyond the reasonable control of the Permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed or inadequate treatment facilities, lack ofpreventative
maintenance, or careless or improper operations.
An upset may constitute an affirmative defense for action brought for the noncompliance. The Permittee has the burden ofproofto
provide evidence and demonstrate that none of the factors specifically listed above were responsible for the noncompliance.
F. Right of Entry
The Permittce shall allow the staff of the State of North Carolina Department of Environmental Quality, Division of Water
Resources, the Regional Administrator of the Environmental Protection Agency, the City of Charlotte, and/or their authorized
representatives, upon the presentation of credentials:
1. to enter upon the Permittee's premises where areal or potential discharge is located or in which records are required to be
kept under the terms and conditions of this permit; and
2. at reasonable times to have access to and copy records required to be kept under the terms and conditions of this permit; to
inspect any monitoring equipment or monitoring method required in this permit; and to sample my discharge of pollutants.
G. Availability of Records and Reports
The Permittee shall retain records of all monitoring information, including all calibration and maintenance records as well as copies
of reports and information used to complete the application for this permit for at leastthree years. All records that pertain to matters
that are subject to any type of enforcement action shall be retained and preserved by the Permittee until all enforcement activities
have concluded and all periods of limitation with respect to any and all appeals have expired.
Except for data determined to be confidential under the City Code, all reports prepared in accordance with terms ofthis permit shall
be available for public inspection at the City of Charlotte. As required by the Code, effluent data shall not be considered
confidential.

Pan 11- Page2
Permit 4 5016
H. Duty to Provide Information
The Permittee shall famish to the Control Authority or his designee, within a reasonable time, any information which the Director,
his designee, or the Division of Water Resources may request to determine whether cause exists for modifying, revoking and
reissuing, or terminating this permit or to determine compliance with this permit. The Permittee shall also famish, upon request,
copies of records required to be kept by this permit.
L Signatory Requirements
All reports or information delivered pursuant to the requirements of this permit must be signed and certified by the Authorized
Representative as defined in Chapter 23 of the City Code. Ifthe designation of an Authorized Representative is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, or overall responsibility for
company related environmental matters, a new authorization satisfying the requirements of this section must be submitted to the
Control Authority prior to or together with any reports to be signed by an authorized representative.
J. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance specified in such eftluentstandard orprohibition) is
established under Section 307(a) of the Federal Clean Water Act for a toxic pollutant which is present in the discharge and such
standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit may be revised or modified
in accordance with the toxic effluent standard or prohibition and the Perrittee so noted.
K. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the Permittee from civil or criminal penalties for noncompliance.
L. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee from any
responsibilities, liabilities, or penalties established pursuant to any applicable Federal and/or State law or regulation.
M. Penalties
Chapter 23 of the City Code provides that any person who violates a permit condition is subject to a civil penalty not to exceed
$25,000 per violation per day for as long as the violation(s) continues.
The District Attorney for the applicable Judicial District may, at the request ofthe Control Authority, prosecute non -compliant users
who violate the provisions of N.C.G.S. 143-215.6B.
N. Need to Halt or Reduce not a Defense
It shall not be a defense for a Pernittee in an enforcement action that it would have been necessary to halt or reduce the permitted
activity to maintain compliance with the conditions of the permit.
O. Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user, different premises, or a new or changed
operation without approval of the Control Authority.
P. Property Rights
This permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize
any injury to private property or any invasion of personal rights, nor any infringement of Federal, State or local laws or regulations.
Q. Severability
The provisions of this permit are severable and, if any provision of this permit or the application of any provision of this permit to
any circumstances is held invalid, the application of such provision to other circumstances and the remainder of this permit shall not
be affected thereby.

Part It - Page3
Permit # 5016
R. Permit Modification, Revocation, Termination
This pennitmay be modified, revoked and reissued or terminated with cause in accordance to the requirements of the City Code and
North Carolina General Statute or implementing regulations.
S. Reapplication for Permit Renewal
The Permittee is responsible for filing a complete and accurate application forreissuance of this permit at least 180 days priorto its
expiration date.
T. Dilution Prohibition
The Permittee shall not increase the use of potable or process water or in any other way attemptto dilute the discharge as a partial or
complete substitute for adequate treatment to achieve compliance with the limitations contained in this permit.
U. Notification of Changed Conditions
The Permittee shall give notice to the Control Authority 90 days prior to any planned facility expansion, production increase or
decrease, or process modification which has the potential to result in new or substantially increased or decreased discharges or a
change in the nature or quality of the discharge. This shall also apply to any substantial changes in the relative proportions or
dilution flow and regulated flow, whether increases or decreases. The Permittee shall not proceed with that facility expansion,
production increase, or process modification until receiving written approval from the Control Authority.
V. Construction
No construction of Pretreatment facilities or additions thereto shall begin until Final Plans and Specifications have been delivered to
the Control Authority and written approval and an Authorization to Construct have been issued.
W. Sludge Management Plan
Ninety days prior to the initial disposal of sludge generated by any pretreatment facility, the Permittee shall deliver a sludge
management plan to the Control Authority.
X. Categorical Standard Reopener
This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation
issued or approved under Sections 302(b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard
or limitation so issued or approved:
(I) contains different conditions or is otherwise more stringent than any effluent limitation in this permit; or
(2) controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable.
Y. Accidental Discharges and Slug Loads
The Permittee shall provide protection from accidental and slug discharges ofprohibited materials and other substances regulated by
this permit The Permittee shall also notify the POTW immediately of my changes at its facility affecting the potential for spills and
other accidental discharge, discharge of non -routine, episodic nature, a non -customary batch discharge, or a slug load as defined in
Section 23-77 of the City Code. The Permittee shall develop and implement a written slugispill control plan and submit it to the
Control Authority within 120 days ofreceipt of this permit for approval by the Control Authority. The plan shall include, but is not
limited to: description of discharge practices, including non -routine batch discharges; description of stored chemicals; procedures
for immediately notifying the POTW of slug discharges that would cause a violation of 40 CFR 403.5(b), with procedures for
notification within 5 days; and if necessary, procedures to prevent adverse impact from accidental spills, including inspection and
maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site tun -off,
worker training, building of containment structures or equipment, measures for containing toxic organic pollutants (including
solvents), and/or measures and equipment for emergency response. Acpy of this plan shall be delivered to the Control Authority
by the implementation date.

Part II - Page4
Permit # 5016
The Permittee shall notify the Control Authority immediately of all discharges that could cause problems to the POTW
including any slug loadings as defined by 40 CFR 403.5(b) and Section 23-77 of the City Code. If the Permittee experiences
such a discharge, they shall speak with the Operator -in -Charge at the Sugar Creek W WTP, telephone number [phone]
and with an individual of the Control Authority, telephone number [phone] immediately upon the first awareness of the
commencement of the discharge. Should the Permittee be unable to speak with the Operator -in -Charge and with the Control
Authority personnel upon calling the specified numbers, a message or the phone number where the Permittee can be reached
shall be left on the Control Authority's emergency phone by calling [phone].
A written follow-up report describing the cause of the discharge and measures taken to prevent similar future occurrences shall be
filed with the Control Authority by the Permittee within five(5) days of the discharge. Such written notification shall not relieve the
Permittee from any liability which may be incurred as a result of the discharge.
Z. General Prohibitive Standards
The Permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5(a) and (b) ofthe Federal pretreatment
regulations.

Part III -Pagel
Permit 45016
SPECIAL CONDITIONS
A. The permit shall be reopened and modified or revoked and reissued to comply with any applicable effluent standard or limitation for
the control of my pollutant shown through headworks analysis to contribute to interference, inhibition, pass though and/or toxicity
atthePOTW. Similarly, permitmodification or reissuance shall be made for any pollutantthat is otherwise limited by orappears on
the POTW's NPDES discharge permit and/or is limited by 503 sludge regulations. The permit as modified or reissued under this
paragraph may also contain any other requirements of local, State or Federal pretreatment regulations then applicable.
B. The Permittee was responsible for filing complete and accurate information for issuance of this renewed permit. Said information
consisted of an application dated January 22.2015, with corrections submitted Amust 9.201E and a site inspection on July 6 2016.
Should the Permittee determine that said information was incomplete and/or inaccurate in anymanner; the Permime shall notify the
Control Authority immediately in writing. Such notice shall identify the information which was incomplete and/or inaccurate and
shall include the new complete and accurate information as well as an explanation of the impact of the new complete and accurate
information on the existing permit.
C. The Permittee is responsible for communicating all requirements and conditions of this permit to all applicable persons.
D. Within one hundred and eighty days of the issuance of this permit, the permittee shall develop and deliver to the Control Authority a
waste minimization plan.
E. Total Toxic Organics ("TTO"). The following shall be summed and the total evaluated against the imposed limit, if any:
- All volatile compounds (specified in the Scope and Application portion of 40 CFR 136- Method 624) detected or reported as
undetected above 0.0I0 mg/l.
- All semi -volatile compounds (specified in the Scope and Application portion of 40 CFR 136- Method 625) detected or
reported as undetected above 0.100 mg/l.
F. All PCB compounds (specified in the Scope and Application portion of 40 CFR 136- Method 608) detected or reported as
undetected above 0.001 mg/l.
G. Any concentration of PCB greater than or equal to 0.003 ppm, as may be detected during Permittee or CLTWater monitoring
at effluent pipe 001, shall require an investigation into the cause of the presence of the PCB. A detailed report shall be
submitted to the Control Authority within five business days of first leaming of the presence of PCBs greater than or equal to
0.003 ppm in the Perrrrittee's effluent as measured at Pipe 001. If PCB concentration is greater than 10 ppm, the Permittee shall
immediately cease discharge until the Control Authority grants permission to resume discharge in writing.
H. Should the Permittee plan to accept grease trap waste directly, they shall notify CLTWater in writing at least 90 days prior to
receiving such waste. Permit will be modified upon such a request to include, but not limited to, the following:
- Retaining of grease hauler manifests
- Samples retained from each track received
- Onsite testing to screen for PCBs
I. The Permittee may receive recycled grease product from any recycled grease product supplier which screens all incoming loads
to the supplier's facility daily using the Magnetic Particle Enzyme -Linked Immunosorbent Assay (ELISA) analysis. The
following conditions apply:
1. No PCB's were detected, in the supplier's tests, above lOppm (parts per million) using the ELISA analysis for any
product which is to be received by the Pemrittee.
2. Certification by the supplier that ELISA analysis was ran and log records from ELISA analysis must be received from
recycled grease product supplier for each load received by the Permittee. Records shall be retained by the Permittee
for a minimum of 3 years and provided to CLTWater upon request.
3. Manifest records for each load shipped to the Permittee shall be delivered by the supplier to the Permittee. Records
shall be retained by the Permittee for a minimum of 3 years and provided to CLTWater upon request.
Modified 6/1 /2017 k

Part IV- Pagel
Permit # 5016
PER MODIFICATION HISTORY
June 1 2017 — Permit modification for the Permittee to accept recycled grease product. Special condition H added "directly" to the
language. Special Condition I was added. The permit end date was extended from September 30, 2018 to May 31, 2019 to allow for 2
years of monitoring prior to permit renewal.
October 1. 2016 — New Industrial User Permit issued. Most sampling parameters are set for monitoring only in order to establish
baseline data for the new industry. CBOD and Phosphorus limits have been set below 5%of the MAHL of Sugar Creek W WTP. Oil
and Grease limit set to limit the buildup of FOG in the collection system.
Modified 6/1/2017 4-