WQ0039924_More Information (Received)_20230104

State of North Carolina
Department of Environmental Quality
nWR Division of Water Resources
NON -DISCHARGE PERMIT OWNERSHIP/NAME CHANGE
Division of Water Resources INSTRUCTIONS FOR FORM: NDPONC 06-16 & SUPPORTING DOCUMENTATION
This form is for ownership changes or name changes of a non -discharge system permit. Please note that "Permtttee"
references the existing permit holder, and that "Applicant" references the entity applying for the ownership/name change.
For more information, visit the Water Quality Permitting Section's Non -Discharge Permitting Unit website
A. Non -Discharge Permit Ownership/Name Change (FORM: NDPONC 06-16) Application (All Applications):
.2T Submit an original completed and appropriately executed Non -Discharge Permit Ownership/Name Change (FORM: NDPONC
06-16) application.
�J The Existing Permittee's Certification shall be signed in accordance with 15A NCAC_ 02T .0106(b). Per 15A NCAC 02T
.0106(c), an alternate person may be designated as the signing official if a delegation letter is provided from a person who
meets the criteria in 15A NCAC 02T .0106(b}.
The Applicant's Certification shall be signed in accordance with 15A NCAC 02T .0106(h). Per 15A NCAC 02T .0106(c �, an
alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria
in 15A NCAC 02T .0106(b).
B. Existing Permit (All Applications):
Submit a copy of the most recently issued permit.
C. Property Ownership Documentation (All Applications):
➢ Per 15A NCAC 02T .0504(f), 15A NCAC 02T .0604(e), 15A NCAC 02T .0704(f), 15A NCAC 02T .0804, 15A NCAC 02T
.1004(d), 15A NCAC 02T .1104(d)(7}, 15A NCAC 02T .1104(e)(51, 15A NCAC 02U .0201(e} or 15A NCAC 02U .0202(i7,
the Applicant shall demonstrate they are the owner of all property containing the non -discharge system facilities:
Legal documentation of ownership (i.e., GIS, deed or article of incorporation), or
❑ Written notarized intent to purchase agreement signed by both parties with a plat or survey map, or
❑ Written notarized lease agreement that specifically indicates the intended use of the property and has been signed by both
parties, as well as a plat or survey map. Lease agreements shall adhere to the requirements of 15A NCAC 02L .0107.
D. Certificate of Public Convenience and Necessity (All Applications where the Applicant is a Privately -Owned Public Utility):
❑ Per 15A NCAC 02T .0115(a)(11, provide one copy of the Certificate of Public Convenience and Necessity from the North
Carolina Utilities Commission demonstrating the Applicant is authorized to hold the utility franchise for the area to be served
1A by the non -discharge system.
E. Operational Agreements (All Applications where the Applicant is a Home/Property Owners' Association or Developer of lots to
be sold):
➢ Home/Property Owners' Associations
❑ Per 15A NCAC 02T .0115(c), submit an original properly executed Operational Agreement (FORM: HOAJ.
/A ❑ Per 15A NCAC 02T .0115(c), submit an original proposed or approved Articles of Incorporation, Declarations and By-
laws.
➢ Developers of lots to be sold
❑ Per 15A NCAC 02T .0115(h), submit an original of the properly executed Operational Agreement (FORM: DEV).
F. Operation and Maintenance Agreement (All Applications for Single -Family Wastewater Irrigation Systems):
❑ Per 15A NCAC 02T .0604(h), submit an original of a notarized Operation and Maintenance Agreement (FORM: SFRWWIS
O&M) that has been signed and dated by all deeded property owners.
1A
THE COMPLETED APPLICATION AND SUPPORTING DOCUMENTATION SHALL BE SUBMITTED TO:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE BRANCH
BY U.S. Postal Service: By Courier/Special Delivery:
1617 MAIL SERVICE CENTER 512 N. SALISBURY ST.
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH. NORTH CAROLINA 27604
TELEPHONE NUMBER: [phone]
INSTRUCTIONS FOR FORM: NDPONC 06-16 & SUPPORTING DOCUMENTATION Page 1 of 1

State of North Carolina
Department of Environmental Quality
nWR Division of Water Resources
NON -DISCHARGE PERMIT OWNERSHIP/NAME CHANGE
Division of Water Resources FORM: NDPONC 06-16
I. EXISTING PERMITTEE INFORMATION:
1. Permittee's name: von Drehle Corporation LLC
2. Signature authority's name: Michael Mennine per 15A NCAC 02T .0106(bl Title: Mill Manager
3. Permittee's mailing address: PO BOX 159, 126 First Street
City: Cordova State: NC Zip: 28330-
4. Permittee's contact information: Phone number: [phone] Email Address: michael.menn' a7vondrehle.com
5. Demonstration of historical consideration for permit approval— 15A NCAC n?T 01?0:
Has the Permittee or any parent, subsidiary or other affiliate exhibited the following?
a. Has been convicted of environmental crimes under Federal law or G.S. 143-215.613? ❑ Yes or ® No
b. Has previously abandoned a wastewater treatment facility without properly closing that facility? ❑ Yes or ® No
c. Has unpaid civil penalty where all appeals have been abandoned or exhausted? ❑ Yes or ® No
d. Is non -compliant with an existing non -discharge permit, settlement agreement or order? ❑ Yes or ® No
e. Has unpaid annual fees in accordance with 15A NCAC 02T .0105(e)(21? ❑ Yes or ® No
IL FACILITY INFORMATION:
1. Facility name: Marcal Cordova LLC
2. Facility's physical address: 126 First Street
City: Cordova State: NC Zip: 28330- County: Richmond
II. PERMIT INFORMATION:
1. Existing permit number: WQ0039924 and most recent issuance date: June 28, 2018
2. Existing permit type: Land Application of Residual Solids (503 Exempt)
3. Reason for the permit application: Change of Ownership
4. Has the facility been constructed? ® Yes or ❑ No
IV. APPLICANT INFORMATION:
1. Applicant's name: Marcal Cordova LLC
2. Signature authority's name: Michael Menning per 15A NCAC 02T .0106(bl Title: Mill Manager
3. Applicant's mailing address: PO Box 159, 126 First Street
City: Cordvoa State: NC Zip: 28330-
4. Applicant's contact information: Phone number: 910 995-7565 Email Address: michael.menning{uvondrehle.com
5. Demonstration of historical consideration for permit approval — 15A NCAC 02T .0120:
Has the Applicant or any parent, subsidiary or other affiliate exhibited the following?
a. Has been convicted of environmental crimes under Federal law or G.S. 143-215.6B? ❑ Yes or ® No
b. Has previously abandoned a wastewater treatment facility without properly closing that facility? ❑ Yes or ® No
c. Has unpaid civil penalty where all appeals have been abandoned or exhausted? ❑ Yes or ® No
d. Is non -compliant with an existing non -discharge permit, settlement agreement or order? ❑ Yes or ® No
e. Has unpaid annual fees in accordance with 15A NCAC 02T .0105( e 12 )? ❑ Yes or ® No
FORM: NDPONC 06-16 Pagel of 2

I C h Gw K'I'M 1 :;�
Existing Permittee's C rtification per 15A NCAC
O2T .0106(bl:
I, V "!� �� /' !A'/'117 YPY, attest that this application for
(Signature Authority's name & title from Application Item 1.2.)
4 LLB
(Facility name from Application Item 1I.1.)
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that prior to reissuance of the permit
into the Applicant's name, any discharge of wastewater from this non -discharge system to surface waters or the land will result in an
enforcement action that may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the
Division of Water Resources should a condition of the existing permit be violated. I also understand that if all required parts of this
application package are not completed and that if all required supporting information and attachments are not included, this application
package will be returned as incomplete. I further certify that the existing Permittee or any affiliate has not been convicted of an
environmental crime, has not abandoned a wastewater facility without proper closure, does not have an outstanding civil penalty where
all appeals have been exhausted or abandoned, are compliant with any active compliance schedule, and do not have any overdue annual
fees per 15A NCAC 02T .0105f ef.
NOTE — In accordance with General Statutes 143-215.6 A and 143-215.6B, any person who knowingly makes any false statement,
representation, or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date:
Applicant's Certification per 15A NCAC 02T .0106(b):
I, MIG�(it / J111enmP-.r; k111
Authority's name &'title from Application Item IV.2.)
(Facility name from Application Item I1.1.)
that this application for
has been reviewed by me and is accurate and complete to the best of my knowledge. I understand that after reissuance of the permit
into the Applicant's name, any discharge of wastewater from this non -discharge system to surface waters or the land will result in an
enforcement action that may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the
Division of Water Resources should a condition of this permit be violated. I also understand that if all required parts of this application
package are not completed and that if all required supporting information and attachments are not included, this application package
will be returned to me as incomplete. I further certify that the Applicant or any affiliate has not been convicted of an environmental
crime, has not abandoned a wastewater facility without proper closure, does not have an outstanding civil penalty where all appeals have
been exhausted or abandoned, are compliant with any active compliance schedule, and do not have any overdue annual fees per 15A
NCAC 02T .0105t
NOTE — In accordance with General Statutes ' 43-215.6A and 143-215.6B, any person who knowingly makes any false statement,
representation, or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to
exceed $10,000 as well as civil penalties up to $25,000 per violation.
Signature: Date: 0D
FORM: NDPONC 06-16 Page 2 of 2

ROY COOPER
Governor
MIC;HAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Division of Water Resources
Non -Discharge Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
To Whom It May Concern:
NORTH CAROLINA
Environmental Quality
December 20, 2022
Subject: Permit No. WQ0039924
Permit No. NCG050152
Signature Authority Designation
Marcal Cordova LLC
Richmond County
As an appropriate signing official for Marcal South LLC (business name) as designated by 15A NCAC
2T .0106, I hereby delegate authority to sign and certify all permit applications, reports or other permit
related documents to the following individual(s) for the following permit types (sewer, spray, land
application) and/or permit numbers:
Person
Permit Tyne
Position
Currenft in
or Permit
Position
Number
Mill Manager
Michael
Industrial
Menning
Byproduct
Residuals
Permit
If you have any questions, please contact me at the following:
Permittee/Applicant name (please print): Marcal Cordova LLC/Matthew Goodlin
Title: Chief Financial Officer
Complete mailing address: mgoodlingraaimarcalgper.com
City: Elmwood Park State: NJ Zip: 07042
Telephone number: [phone] Facsimile number: ( )
Sincerely,
Matthew Goodling, Chief Financial Officer
00.r North Carolina Department of Environmental Quality I Division of Water Resources
W 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NCR HCnROUNA 1
°+V.M^r 0-ft\ 919.707.9000

Appendix 1: Signing Authority Documents

Delegation of Authority for Environmental Matters
Cordova, NC Mill Operations
As Chief Operating Officer of von Drehle Corporation, I hereby ratify and confirm the authority
of each Plant Manager (PM) and Process Engineer (PE) listed below to act as the responsible
official and/or the duly authorized representative for the purpose of overseeing environmental
compliance matters at the facility(ies) they manage (Covered Facility). The Plant Manager will
be the Permittee, and the Process Engineer will be the ORC and will receive training at the
earliest opportunity to receive certification.
This Delegation of Authority includes, without limitation, the authority to execute and submit
all environmental applications, certifications, and reports required by the Covered Facility, as
well as the authority to act with respect to facilities in the United States as the "responsible
official" as that term is defined at 40 C.F.R. § 70.2 and corresponding United States Federal,
State and Local agency regulations.
To the extent allowed by applicable law, the PM or PE may re -delegate this authority, in writing,
to any appropriately trained facility manager for the specific purpose of executing any monthly
discharge monitoring or similar wastewater report that may be required under a National
Pollutant Discharge Elimination Systems (NPDES) or comparable state of local wastewater
discharge permit, any stormwater audits, air monitoring, and /or any other environmental
requirements.
The Delegation of Authority will remain in effect until revoked or superseded.
von Drehle Corporation
Jason Gscheidmeier, Chief Operating Officer
Effective Date: August 15th, 2022
COVERED FACILITY STATE TITLE
CORDOVA NC Plant Manager
CORDOVA NC Process Engineer
NAME
Mike Menning
Mitchell Luckie

Appendix 2: Existing Permit as required by
application

Wrel'71 Y: [K t1witii
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
K71 RA :1
DISTRIBUTION OF CLASS A INDUSTRIAL BYPRODUCT RESIDUALS PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
von Drehle Corporation
Richmond County
FOR THE
operation of a residuals management program for von Drehle Corporation and consisting of the distribution
of Class A industrial byproduct residuals generated by the approved facility listed in Attachment A with no
discharge of wastes to surface waters, pursuant to the application received April 16, 2018, and in conformity
with other supporting data subsequently filed and approved by the Department of Environmental Quality
and considered a part of this permit. The use and disposal of residuals are regulated under Title 40 Code of
Federal Regulations Part 257. This permit does not exempt the Permittee from complying with the federal
regulations.
This permit shall be effective from the date of issuance until May 31, 2023, and shall be subject to the
following specified conditions and limitations:
I. SCHEDULES
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application.
[15A NCAC 02T .0108(b)(2), 02T .0105(d), 02T .0109]
H. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times so
there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of prolonged
nuisance conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the Fayetteville Regional Office supervisor, and take any immediate
corrective actions. [G.S. 143-215.11
2. This permit shall not relieve the Permittee of responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [15A NCAC 02B .0200,
02L .0100]
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Only residuals generated by the facility listed in Attachment A are approved for distribution in
accordance with this permit. [G.S. 143-215.1]
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not exceed
the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
75
85
4,300
Monthly Average
Concentration
(milligrams per kilogram)
41
39
1,500
Arsenic
Cadmium
Copper
Lead
840
300
Mercury
57
75
17
n/a
Molybdenum
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
[15A NCAC 02T .l 105]
5. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) and (b)(2). Exceptions to this requirement shall be specified in Attachment A. [15A NCAC
02T .1106]
6. Setbacks for treatment and storage facilities shall be as follows:
Setback Description Setback
I feet
Habitable residence or place of public assembly under separate ownership or not to 100
be maintained as part of the prqject site
Property lines 50
Private or public water supply 100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and 50
wetlands
Wells with exception to monitoring wells 100
[15A NCAC 02T .1108]
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7. Setbacks for Class A land applied bulk residuals shall be as follows:
Setback by residual type
(feet)
Setback Description
Liquid Cake'
Private or public water supply 100 100
Surface waters (streams — intermittent and perennial,
100
25
perennial waterbodies, and wetlands
Surface water diversions (ephemeral streams,
0
waterwa s, ditches)25
Groundwater lowering ditches (where the bottom of
25
0
the ditch intersects the SHWT
Wells with exception to monitoring wells
100
100
Bedrock outcrops
25
0
' Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without flowing, as well as can be handled, transported and
spread as a solid (e.g., using a backhoe, front end loader, slinger spreader, broadcast spreader or
other equipment designed for handling solid materials) without leaving any significant liquid
fraction behind.
[ 15A NCAC 02T .1108]
8. Bulk residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in exceedance
of agronomic rates. Appropriate agronomic rates shall be calculated using expected nitrogen
requirements based on the determined Realistic Yield Expectations (RYE) using any of the following
methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina State
University Department of Soil Science (hit p://nutrients.soil.nesu.edu/vields/index.ph ). A copy
shall be kept on file and reprinted every five years in accordance with Condition IV.6.
c. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture. and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
ii. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter 1
(http://www.ncagr.gov/SWC/tech/documents/9th_Guidance Doc 100109.pdf).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (MRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards (ft_p:/tftp-fc.sc,e ov.usda.eov/NH / ractice-standards/standar-�,%5�'::. -.-.'_:.
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
[I5ANCAC 02T .I 109(b)(1)(k)]
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9. The Permittee shall not distribute Class A industrial byproduct residuals that have a sodium adsorption
ratio (SAR) of 10 or higher without prior written Division approval. The Permittee may seek approval
by demonstrating that the entity accepting the residuals is: aware of the effects of a high SAR content;
has agreed on proper residual application rates; and has agreed to operational considerations to ensure
that the high SAR content will not adversely impact the receiving sites. Recommendations regarding
sodium application rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site
integrity and conditions conducive to crop growth, can be obtained from the local Cooperative
Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, a North Carolina Licensed Soil Scientist, or an agronomist. [15A NCAC 02T
.010")(1)]
M. OPERATION AND MAINTENANCE REQUIREMENTS
The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards. [15A NCAC 02T .1110]
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) Modifications
to the O&M Plan shall be approved by the Division prior to utilization of the new plan. The O&M Plan,
at the minimum, shall include:
a. Operational functions;
b. Maintenance schedules;
c. Safety measures;
d. Spill response plan;
e. Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be taken
by the inspector in the event that noncompliance is observed pursuant to the noncompliance
notification requirements under the monitoring and reporting section of the permit;
f. Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen reduction requirements (e.g. facilities that distribute multiple times per year but
have an annual sampling frequency, may need to sample during winter months when pathogen
reduction is most likely to be negatively affected by cold temperatures).
[15A NCAC 02T .1100]
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Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in responsible
charge (ORC) and one or more certified operators as back-up ORCs in accordance with 15A NCAC
08G .0201. The ORC or his back-up shall visit the facilities in accordance with 1.5A NCAC 08G. 0204,
or as specified in the most recently approved O&M plan (i.e., see Condition 111I.2.), and shall comply
with all other conditions of 15A NCAC 08G. 0204. For more information regarding classification and
designation requirements, please contact the Division of Water Resources' Protection and Enforcement
Branch at [phone]. At the time of this permit issuance, a certified ORC is not required for the
subject Distribution of Class A Residuals program. [15A NCAC 02T .0117]
4. When the Permittee land applies bulk residuals, a copy of this permit and a copy of O&M Plan shall be
maintained at the land application sites during land application activities. [15A NCAC 02T
.0108(b)(1)]
When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles. [15A NCAC 02T .1110]
When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters. [G_S. 143-215.1 ]
7. When the Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on land
application sites onto which residuals are applied, or application shall be in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of Agriculture
and Consumer Services, the Natural Resource Conservation Service, or an agronomist and as approved
by the Division. [15A NCAC 02T .1109(b)(1)]
8. Bulk residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under section
4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of surface
water or groundwater standards;
d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of the
residuals would occur;
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within a
24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.e., greater than O.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
h. If the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in a
USDA no -till program shall be exempted from meeting this vegetative cover requirement;
i. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
j. If the vertical separation of bedrock and the depth of residuals application is less than one foot;
k. Application exceeds agronomic rates.
[ 15A NCAC 02T .1109]
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9. The Permittee shall notify all third -party entities receiving bulk distributed Class A industrial byproduct
residuals that land application activities occurring on the third -parry's property shall meet the
requirements in 15A NCAC 02T .1108(b)(1) and 02T .1109(b) (i.e., Conditions II.8. and III.S.,
respectively). [15ANCACO2T.1103(5)]
10. All residuals shall be adequately stored to prevent untreated leachate runoff. The finished product may
be placed on a concrete pad, placed under shelter or physically covered until it is distributed to a third -
party entity. If bulk residuals are to be applied, the residuals may be staged at the application site for
up to 30 days for biological residuals, and 60 days for non -biological residuals. If an alternate storage
site is used, approval must be obtained from the Division. [15A NCAC 02T .0108(b)(1)]
11. A label shall be affixed to the bag or other container in which residuals are sold or given away for land
application, or an information sheet shall be provided to the person who receives Class A residuals. At
a minimum, the label or information sheet shall contain the following:
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland, etc.);
d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
[15A NCAC 02T. I 109(a)]
12. The Permittee shall not distribute bulk residuals to any person or entity known to be applying residuals
contrary to the conditions of this permit. The Permittee shall report to the Fayetteville Regional Office
as per reporting conditions under Condition IV.8. any person or entity known to be applying residuals
contrary to the condition of this permit. [15A NCAC 02T .I 103(a)]
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IN. MONITORING AND REPORTING REQUIREMENTS
1. Any Division -required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed. [15A NCAC 02T .0108(c)]
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). Residuals that tests or is classed as a hazardous or toxic waste under 40
CFR Part 261 shall not be used or disposed under this permit. The analyses [corrosivity, ignitabdity,
reactivity, and toxicity characteristic leaching procedure (TCLP)l shall be performed at the
frequency specified in Attachment A, and the Permittee shall maintain these results for a minimum of
five years. Any exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
1 Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (1.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.008
Toxaphene (0.5)
Trichloroethylene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
. Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
[15A NCAC 13A .0102(b), 02T .l 101, 02T .1105)
WQ0039924 Version 1.0 Shell Version 171103 Page 7 of 10.

3. An analysis shall be conducted on the residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio(SAR)
Calcium
Percent Total Solids
TKN
Copper
Lead
Magnesium
pH
Phosphorus
Zinc
Plant Available Nitrogen
(by calculation)
[15A NCAC 02T .1101]
4. Residuals shall be monitored for compliance with pathogen reduction requirements at the frequency
specified in Attachment A, and at the time indicated in the sampling and monitoring sections of the
approved O&M plan. The required data shall be specific to the stabilization process utilized, and
sufficient to demonstrate compliance with the Class A pathogen reduction requirements in 15A NCAC
02T .1106 (a) and (b)(2) shall be met. Any exceptions from the requirements in this condition shall be
specified in Attachment A. [15A NCAC 02T .1106, 02T .1107, 02T .l 111(c)]
5. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall be
in accordance with the monitoring requirements in 15A NCAC 02B .0505. [15A NCAC 02B .0505]
6. The Permittee shall maintain records tracking all bulk residual distribution or land application events
performed by the Permittee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of distribution/land application;
c. Name and address of recipient of residuals;
d. Volume of residuals distributed to each recipient;
e. Intended use of residuals;
f. If land application events performed by the Permittee:
i. When the agronomic rate is on the basis of Nitrogen, then the Nitrogen Application Rate based
on RYES (if using data obtained from the North Carolina State University Department of Soil
Science Website, the printout page shall be kept on file and reprinted every five years).
ii. When the agronomic rate is on the basis of some other nutrient than Nitrogen, then this shall
be included as part of the Operations & Maintenance Plan required in Condition III.2. A set of
calculations shall be performed to show that the residuals are being applied at an agronomic
rate on the basis of this limiting nutrient. These records shall be kept for a minimum of five
years and shall be available for inspection.
[ 15A NCAC 02T .0108(a)]
WQ0039924 Version 1.0 Shell Version 171103 Page 8 of 10

iY
7. Three copies of an annual report shall be submitted on or before March 1 ". The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting Forms.
Instructions for reporting and annual report forms are available at
[[�Lfiieq.+sc..goKAL-ul .-1i,-;;:is/water-resources/water-resource-- .� ^its/wastewater-branctynon-
discharg-permitt ng unit/reporting-forms, or can be obtained by contacting the Non -Discharge
Permitting Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15ANCAC 02T .1111(a)]
8. Noncompliance Notification
The Permittee shall report by telephone to the Fayetteville Regional Office, telephone number (910)
433-3300, as soon as possible, but in no case more than 24 hours or on the next working day following
the occurrence or first knowledge of the occurrence of any of the following:
a. Distribution of residuals abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
betaken to ensure that the problem does not recur. [15A NCAC 02T .0105(1), 02T .0108(b)(1)]
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan. [15A NCAC 02T .0108(b)]
2. Prior to each bulk residuals distribution event, the Permittee or his designee shall inspect the residuals
storage, transport and distribution facilities to identify malfunctions, facility deterioration and operator
errors that could result in discharges to the environment, a threat to human health or a public nuisance.
The Permittee shall maintain an inspection log that includes, at a minimum, the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken. The Permittee
shall maintain this inspection log for a period of five years from the date of inspection, and this log
shall be made available to the Division upon request. [15A NCAC 02T .0108(b)]
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the distribution sites or facilities permitted herein at
any reasonable time for the purpose of determining compliance with this permit; may inspect or copy
any records required to be maintained under the terms and conditions of this permit; and may collect
groundwater, surface water or leachate samples. [G.S. 143-215.3(a)(2)]
WQ0039924 Version 1.0 Shell Version 171103 Page 9 of 10

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an
enforcement action by the Division in accordance with North Carolina General Statutes 143-215.6A to
143-215.6C. [G.S. 143-215.6A to 143-215.6C]
2. This permit shall become voidable if the residuals distribution events are not carried out in accordance
with the conditions of this permit. [15A NCAC 02T .0110]
3. This permit is effective only with respect to the nature and volume of residuals described in the permit
application and other supporting documentation. [G.S. 143-215.1]
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in
15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under the Division's General Permit NCG010000; any requirements pertaining to wetlands under 15A
NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter
143 of the General Statutes. [15ANCAC 02T A105(c)(6)]
In the event the residuals program changes ownership or the Permittee changes his name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner. [15A NCAC 02T .0104]
6. This permit is subject to revocation or unilateral modification upon 60-day notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110]
7. Unless the Division Director grants a variance, expansion of the permitted residuals program contained
herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
[ 15A NCAC 02T .0120]
8. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay
the annual fee accordingly shall be cause for the Division to revoke this permit. [15A NCAC 02T
.0105(e)(3)]
Permit issued this the 28' day of June 2018
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Dinda Culpepper, Interim Director
ivision of Water Resources
By Authority of the Environmental Ma ent Commission
Permit Number WQ0039924
WQ0039924 Version 1.0 Shell Version 171103 Page 10 of 10

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Appendix 3: Proof of Ownership as required by
application

Delaware'
Page 1
The First State
I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF'THE STATE OF
DELAWARE, DD HEREBY CERTIFY "mwu CORDOVA LLC" IS DULY FORMED
UNDER THE LAWS OF THE STATE OF DELAWARE AND ZS ZN GOOD STANDING AND
HAS A LEGAL EXISTENCE SO FAR AS THE RECORDS OF TAIS OFFICE SHOW, AS
OF TAX EIGHTH DAY OF DECEMBER, A.D. 2022.
AND I DO HEREBY FURTHER CERTIFY THAT THE SAID , RcAL CORDOVA
LLC" WAS FORM$D ON THE TWENTY-NINTH DAY OF NOVEMBER, A.D. 2022,
AND I DO HEREBY FURTHER CERTIFY THAT THE ANNUAL TAXES HAVE BEEN
ASSESSED TO DATE.
�.ars '•
7160067 8300
5R# 20224214665
You may verify this certificate online at corp.delaware.gov/authver.shtmi
Authentication: 205044812
Date:12-M22
Certification# C202234201021-1 Reference# C202234201021- Page: 4 of 4

�-NORTH CAROLINA
Department of the Secretary of State
CERTIFICATE OF AUTHORITY
I, ELAINE F. MARSHALL, Secretary of State of the State of North Carolina, do hereby
certify that
MARCAL CORDOVA LLC
having filed on this date an application conforming to the requirements of the General
Statutes of North Carolina, a copy of which is hereto attached, is hereby granted
authority to transact business in the State ofNorth Carolina.
Scan to verify online.
IN WITNESS WHEREOF, I have hereunto set
my hand and affixed my official seal at the City
of Raleigh, this 9th day of December, 2022.
A (" & - ". A 7$*. /' W, 6
Document Id: C202234201021 Secretary of State
Verify this certificate online at https://www.sosne.gov/verification

�aNORTH CAROLINA
Department of the Secretary of State
To all whom these presents shall come, Greetings:
I, ELAINE R MARSHALL, Secretary of State of the State of North Carolina, do hereby
certify the following and hereto attached to be a true copy of
APPLICATION FOR CERTIFICATE OF AUTHORITY
OF
MARCAL CORDOVA LLC
the original of which was filed in this office on the 9th day of December, 2022.
IN WITNESS WHEREOF, I have hereunto set my
hand and affixed my official seal at the City of
Raleigh, this 9th day of December, 2022.
online.�can to verify
Certification# C20223420IO21-1 Reference# C202234201021-1 Page: I of 4 Secretary of State
Verify this certificate online at https://www.sosnc.govlveiification

SOSID: 2537168
Date Filed: 12/9/2022 7.30:00 AM
Elaine F. Marshall
North Carolina Secretary of State
State of North Carolina C2022 342 01021
Department ofthe Secretary of State — - - ---
APPLICATION FOR CERTIFICATE OF AUTHORITY
FOR LINATED LIABILITY COMPANY
Pursuant to §5713-7-03 of the General Statutes of North Carolina, the undersigned limited liability company hereby applies for a
Certificate of Authority to transact business in the State cfNorth Carolina, and for that purpose submits the following:
3
1. The name ofthe limited liability company is Mamal Cordova LLC
and if the limited liability company name is unavailable for use in the State ofNortb Carolina, the name the limited
liability company wishes to use is
2. The state or country under whose laws the limited liability company was formed is Delaware
3. Principal office information: (Select either a or b.)
a. ® The limited liability company has a principal office.
The principal office telephone number. 484-515-7145
The street address and county of the principal office of the limited liability company is:
Number and Street: 126 First Street
city: Cordova State; NC zip code.28330 County: Richmond
The mailing address, 1f dWerentfrom the street address, of the principal office of the corporation is:
Number and Street:
City: _._ — State: Zip Code: Coumtx:
b. ❑ The limited liability company does not have a principal office.
4. The name of the registered agent in the State ofNorth Carolina is: Capitol Corporate Services, Inc.
5. The street address and county of the registered agent's office in the State of North Carolina is:
Number and Street:176 Mine Lake CT, Ste 100
city: Raleigh -.__ State: NC
Zip Code: 27615 county: Wake
6. The North Carolina mailing address, if different from the street address, of the registered agent's office In the State of North
Carolina is:
Number and Street:
City:_ _ _ _ _ State: NC
BUSINESS REGISTRATION DIVISION
(Revised July 2017)
Zip Code: County:
Q.O. SOX 29622 RALEIGH, NC 27626-0622
(From L-09)
Certification# C202234201021-1 Reference# C202234201021- Page: 2 of 4 !

APPLICATION FOR CERTIFICATE OF AUTIiORITV
Page I
7. The names, titles. and usual business addresses of the current company officials of the litilited liability company are:
(nse rurochrnenr ijnecessory) ('this discameru rarest he signed by is person lisre rl in item 7;)
Name and 7717e Business Address
Rob Baron, CEO & President One Market Street, Elmwood Park, NJ 07407
Matt Goodling, CFO & Secretary One Market Street, Elmwood Park, NJ 07407
8. .hashed is a certificate of existence (or document of similar import), duly authenticated by the secretary of state or other official
having custody of limited liability company records in the state or countryof formation: The Certificate of Existence must be'
less than six months old. A photocavy of the certification cannot be acce )led.
9. If the limited liability company is required to use a fictitious name in order to transact business in this State, a copy or the
resolution of its managers adopting the fictitious name is attached.
10. (Optional): Please provide a business e-mail address: _
The Secretary of State's Office will e-mail the business automatically ai the address proidded above at no cost when a document
is riled. Tlw e-mail provided will not be viewable on the websitc For more information on why this service is of%red, please see
the instructions for this document.
I 1 This application will be ef)ective upon riling, unless n delayed date and/or time is specified-,
This the -7 day of December , 24 22
Marcal Cordova LLC
' ire o 're(11 ' 'Un C r III,
Signaunr qjC nr1 ny rcial
Notes:
1. Filing fee is S250. This document must be riled with the Secretary of State.
BUSINESS REGISTRATION DIVISION
(Revised Jul), 2017)
Rob Baron, President
7),pc, or Print Name and TWO
P.O. BOX 29622
RALEIGH, NC 27626-0622
(Tone L-09)
Certification# C202234201021-1 Reference# C202234201021- Page: 3 of 4

Delaware Page
The First State
I, JEFFREY W. BULLOCK, SECRETARY OF STATE OF THE STATE OF
DELAWARE, DO HEREBY CERTIFY THE ATTACHED IS A TRUE AND CORRECT
COPY OF THE CERTIFICATE OF FORMATION OF "MARCAL CORDOVA LLC",
FILED IN THIS OFFICE ON THE TWENTY—NINTH DAY OF NOVEMBER, A.D.
2022, AT 12:33 O'CLOCK P.M.
7160067 8100
SR# 20224121811
nr
'
.iNTrey w Swam Secretary d-sm.
Authentication: 204955791
Date: 11-29-22
You may verify this certificate online at corp.delaware.gov/authver.shtml

State of Delaware
Secretary of State
Division of Corporations
CERTIFICATE OF FORMATION Delivered 12:33 PM M2912022
FILED 12:33 PD111/29/2022
OF SR 20224121811 - File\umber 7160067
MARCAL C.ORDOVA LLC
This Certificate of Formation of Marcal Cordova LLC (the "Company") is being duly executed and
filed by the undersigned, as an authorized person to form a limited liability company under the Limited
Liability Company Act of the State of Delaware (the ""Act").
It is hereby certified as follows:
I . The name of the Company is: Marcal Cordova LLC.
2. The address of the registered office of the Company in. the State of .Delaware is 108 Lakeland
Avenue, Dover, Delaware 19901. The name of the Company's Registered agent at suchaddress is
Capitol Services, .Inc.
IN WITNESS WHE-141OF, the undersigned, an authorized person has executed this Certificate of
Formation this 29th day of November, 2022.
)JasoM. Peters, A€ithorized Person
45528963vl