NCG060387_Email RE Secondary Containment Question_20180709

Georgoulias, Bethany
From: Broadway, Chad <[e-mail]>
Sent: Monday, July 09, 2018 10:42 AM
To: Georgoulias, Bethany
Subject: [External] Secondary Containment Question - Orbit Energy - NCG060387
Attachments: Charlotte AD -- Letter to Charlotte Mecklenburg Storm Water Services RE Facility
Inspection 6-25-18.pdf
Hi Bethany,
One of our local facilities, Orbit Energy— NCG060387, has received numerous violations from my program (Water
Quality), Solid Waste, and Air Quality over the previous year, and our agencies are having a combined meeting with
Orbit Energy corporate representatives later this week to discuss the violations. The facility, which produces methane
for energy production through anaerobic digestion of food waste/byproduct, has received three NOVs by my group for
discharges of food slurry to the receiving stream. As part of the corrective actions required by our most recent site visit,
we've asked Orbit Energy to submit a written response detailing how they plan to protect the stream from future
discharges, including determining applicability of secondary containment requirements under the NCG06 permit and
how they plan to comply with those requirements.
I assume that the food slurry qualifies as "Liquid raw materials, manufactured products, waste materials or by-products
with a single aboveground storage container having a capacity of greater than 660 gallons" and would be subject to
secondary containment requirements, but given the unique type of material, I just wanted to verify that is
accurate. Past that, the facility has proposed a "spill containment wall" (see the last page of the attached document)
that should prevent direct discharges to the receiving stream, but would result in flow being directed to storm drainage
catch basins, which flow to the facility's dry detention basin. In this scenario, it appears that they are using the basin to
account for the volume of the largest capacity tank (^'2.2 million gallons). It seems like in order to comply with the
permit, the discharge orifice for the dry detention basin would need to be equipped with a manually activated valve that
remains closed until accumulated water is able to be evaluated. From my understanding, there are no plans at this point
to retrofit the basin to include a valve. Do you have any input or comments on this proposal? I emailed Bradley about
this during an unrelated conversation about individual permits earlier last month and he said he would discuss this with
you and Annette Lucas, so you may already be aware of this inquiry. Thanks as always for your input.
Chad Broadway, Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
Mecklenburg County Water Quality Program
2145 Suttle Avenue
Charlotte, NC 28208
704-280-1497 (mobile)
chad. broadway@ mecknc.gov
http://charlottenc.gov/StormWater
Storm Water's WHY statement: We are passionate about making our environment safe and healthy by reducing
flood losses and improving water quality for all.

Charly tte,4rechl�n b� rg
STORM
WATER
Services