WQ0002829_Final Permit_20161209

Water Resources
ENVIRONMENTAL QUAI.ITY
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Drrector
December 9, 2016
GEORGE E. GOODRICH — MANAGING MEMBER
KDHWWTP, L.L.C.
POST OFFICE BOX 3629
KILL DEVIL HILLS, NORTH CAROLINA 27948
Dear Mr. Goodrich:.
Subject: Permit No. WQ0002829
KDHWWTP
High -Rate Infiltration and Non -
Conjunctive Reclaimed
Utilization System
Dare County
In accordance with your permit major modification request received February 17, 2016, and
subsequent additional information received June 14, 2016, July 8, 2016, August 22, 2016, September 12,
2016, and October 28, 2016, we are forwarding herewith Permit No. WQ0002829 dated December 9, 2016,
to KDHWWTP, L.L.C., for the continued operation of the high -rate infiltration and non -conjunctive
reclaimed utilization facilities, as well as the continued operation and subsequent modification of the
existing wastewater treatment facilities.
The modifications to the subject permit are as follows:
❖ The facility description has been revised to allow for modification of the existing wastewater
treatment plant from a conventional activated sludge extended aeration plant to a 5-stage
Bardenpho process with Integrated Fixed Film Activated Sludge. Modification of the existing
plant to this biological nitrogen removal (BNR) process will be accomplished by adding
internal baffle walls to the basins, adding mixers to the basins to keep the wastewater moving,
and adding media to the basins so that both suspended growth and attached growth microbes
will function as part of the treatment process. In addition to nitrogen removal, this process will
also achieve phosphorus removal with a design Total Nitrogen removal to 7 mg/L and a design
Total Phosphorus removal to 3 mg/L.
This permit shall be effective from the date of issuance until August 31, 2018, shall void Permit
No. WQ0002829 issued September 28, 2009, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements listed in Attachments A,
B and C for they may differ from the previous permit issuance. Failure to establish an adequate system for
collecting and maintaining the required operational information shall result in future compliance problems.
Please note the following permit conditions have been removed since the last permit issuance
dated September 28, 2009:
➢ Old Condition I1.7. — This condition has been deleted because it is covered under Condition
III.16.
State oFNorth Carolina I Environmental Quality I Water Resources R Water Quality Permitting I Nan -Discharge Permitting
1617 Mail Service Center j Raleigh, North Carolina 27699-1617
919 807 6464

Mr. George E. Goodrich
December 9, 2016
Page 2 of 2
➢ Old Condition 11.8. — This condition has been deleted because it is covered under Conditions
II. L and III.4.
➢ Old Condition I11.16. — This condition has been removed because it is covered under Condition
IV.11.
➢ Old Condition III.19. — This condition has been removed because it is covered under Conditions
II.1. and III.1.
Please note the following permit conditions are new since the last permit issuance dated
September 28, 2009:
➢ Condition 1.1. — States requirements for certification of construction by a North Carolina
licensed Professional Engineer upon completion of facility construction and modifications.
➢ Condition I.2. — States requirements for notification of the Division of Water Resources
Regional Office prior to startup of the modified facility.
➢ Condition I11.18. — States requirements for testing and calibrating the turbidimeter.
➢ Condition 1V.9. — States requirement for submittal of an annual report to the Division of Water
Resources.
If any parts, requirements or Iimitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
One set of approved plans is being forwarded to you. If you need additional information concerning
this permit, please contact David Schlobohm at [phone] or david.schlobohm ncdenn ov.
Sincerely,
;�Z-S. Jay Zimmerman, P.G., Direc
Division of Water Resources
cc: Dare County Health Department (EIectronic Copy)
Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Joseph J. Aniauf, PE — Anlauf Engineering, PLLC (Electronic Copy)
Beth Buffington, Public Water Supply Section — Protection and Enforcement Branch (Elect. Cpy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
HIGH -RATE INFILTRATION AND NON -CONJUNCTIVE RECLAIMED UTILIZATION
SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of Forth Carolina as
amended, and other applicable Laws, Rules and Regulations
PERMISSION IS HEREBY GRANTED TO
KDHWWTP, L.L.C.
Dare County
I.1161"M11:10
operation of a 500,000 gallon per day (GPD) permitted flow facility with a 660,000 GPD wastewater
treatment plant and a 500,000 GPD high -rate infiltration and non -conjunctive reclaimed utilization disposal
system consisting of the:
continued operation of a 660,000 GPD wastewater treatment plant consisting of: a manually cleaned
aluminum bar screen prior to the 43,00 gallon flow equalization basin A; a 43,000 gallon aerated flow
equalization basin A; a 118,000 gallon aerated flow equalization basin C; a 38,630 gallon aerated flow
equalization basin B with two 416 gallon per minute (GPM) equalization pumps; an aluminum flow splitter
box; a 312,000 gallon aeration Train A (see paragraph below for modifications); a 310,000 gallon aeration
Train B (see paragraph below for modifications); two 91,000 gallon clarifiers with rotating skimmers and
served by two 600 GPM variable speed sludge return pumps; a 35,000 gallon filter dosing tank with two
833 GPM filter dosing pumps; two 156 square foot (ft2) rapid sand filters served by a 781 cubic foot per
minute (CFM) air scour blower; a 20,000 gallon mudwell with two 280 GPM return pumps; two 71,655
aerated sludge digesters with a decant pump; four 1,479 CFM rotary positive blowers and an 800 CFM
centrifugal blower serving the flow equalization, aeration, and sludge digester basins; a 50,000 gallon
clearwell with two 957 GPM pumps; an effluent flow meter; a turbidimeter; an ultraviolet (UV) disinfection
system with four banks each rated at 400,000 GPD; a stand-by power system consisting of a 45 kilowatt
(kW) generator; and a 115 kW generator; and all associated piping, valves, controls and appurtenances; the
continued operation and subsequent conversion of the existing 312,000 gallon aeration Train A into: a
70,097 gallon pre -anoxic Zone I with four two horsepower (hp) mixers; a 32,903 aeration Zone 1A with
HDPE media; a 47,208 gallon aeration Zone 1B with HDPE media; a 55,791 gallon aeration Zone 2A with
HDPE media; a 24,319 gallon aeration Zone 213 with HDPE media and two 350 GPM recycle pumps; a
55,791 gallon post -anoxic Zone I with three 2 hp mixers; a 22,889 re -aeration Zone 1; and all associated
piping, valves, controls, and appurtenances; the
continued operation and subsequent abandonment of: a manually cleaned aluminum bar screen prior to the
118,000 gallon flow equalization basin C; and all associated piping, valves, controls, and appurtenances;
the
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continued operation and subsequent conversion of the existing 310,000 gallon aeration Train B into: a
70,195 gallon pre -anoxic Zone 2 with two 4 hp mixers; an 84,234 gallon aeration Zone 3 with HDPE media;
an 81,426 gallon aeration Zone 4 with HDPE media and two 350 GPM recycle pumps; a 56,156 gallon
post -anoxic Zone 2 with two 3 hp mixers; a 16,846 gallon re -aeration Zone 2; and all associated piping,
valves, controls and appurtenances; the
construction and operation of: a rotary drum fine screen with 3 to 6 millimeter (mm) openings; a chemical
feed system with a 55 gallon drum and a chemical metering pump supplying alkalinity to the existing
aluminum flow splitter box; a chemical feed system with a 55 gallon drum and a chemical metering pump
supplying carbon to the 55,791 gallon post -anoxic Zone 1; a chemical feed system with a 55 gallon drum
and a chemical metering pump supplying alum to the 22,889 re -aeration Zone 1; a chemical feed system
with a 55 gallon drum and a chemical metering pump supplying carbon to the 56,156 gallon post -anoxic
Zone 2; a chemical feed system with a 55 gallon drum and a chemical metering pump supplying alum to
the 16,846 gallon re -aeration Zone 2; and all associated piping, valves, controls and appurtenances; the
construction and operation of modifications permitted November 5, 2008 consisting of: two 416 GPM flow
equalization pumps for a build -out total of four 416 GPM flow equalization pumps; additional diffuser
assemblies for the equalization basins; additional diffuser assemblies for the aeration basins; additional
diffuser assemblies for the re -aeration zones; a 833 GPM filter dosing pump for a build -out of three 833
GPM filter dosing pumps; a 957 GPM clearwell pump for a build -out of three 957 GPM clearwell pumps;
and all associated piping, valves, controls, and appurtenances; the
continued operation of a high -rate spray infiltration system consisting of: three 7.5 hp pumps; seven 15 hp
pumps; approximately 1.35 acres of high -rate spray infiltration onto eight beds; and all associated piping,
valves, controls, and appurtenances; the
continued operation of an infiltration pond system consisting of: a 2,000 gallon pump station with two 7.5
hp pumps and alarms; two interconnected infiltration ponds (i.e., Pond 1) with a cumulative disposal area
of 2.1 acres; and all associated piping, valves, controls, and appurtenances; and the
continued operation of a non -conjunctive reclaimed water utilization system consisting of: an irrigation
pump station with a 25 hp pump and a 3 hp pump; approximately 24.55 acres of irrigation area within seven
zones; an all associated piping, valves, controls, and appurtenances
to serve the KDHWWTP, with no discharge of wastes to the surface waters, pursuant to the application
received February 17, 2016, and subsequent additional information received by the Division of Water
Resources, and in conformity with the project plans, specifications, and other supporting data subsequently
filed and approved by the Department of Environmental Quality and considered a part of this permit.
This permit shall be effective from the date of issuance until August 31, 2018, shall void Permit No.
WQ0002829 issued September 28, 2009, and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
i . Upon completion of construction and prior to operation of the modified permitted facility, a
certification (attached) shall be submitted from a licensed North Carolina Professional Engineer
certifying that the modified permitted facilities have been installed in accordance with this permit,
Division approved plans and specifications, and other supporting documentation, including the location
of all monitoring wells as applicable. if this project is to be completed in phases and partially certified
the Permittee shall retain the responsibility to track further construction approved under the same
permit, and shall provide a final certificate of completion once the entire project has been completed.
Mail the Certification to the Division of Water Resources, Water Quality Permitting Section, 1617 Mail
Service Center, Raleigh, NC 27699-1617. [15A NCAC 02T .0116(a)]
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2. The Washington Regional Office, telephone number [phone], shall be notified at least 48 hours
in advance (excluding weekends and holidays) of operation of the installed facilities such that an in -
place inspection can be made. Notification to the regional supervisor shall be made from 8:00 a.m.
until 5:00 p.m. on Monday through Friday, excluding State Holidays. [15A NCAC 02T .0108(b)(2)]
3. 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 .0105(d), 02T .0106, 02T .0109, 02T .0115(c)]
4. If the subject wastewater treatment, high -rate infiltration, or non -conjunctive reclaimed utilization
facilities are in noncompliance with the terms and conditions of this permit, governing statutes or
regulations, the subject facilities shall be connected to an operational publicly owned wastewater
collection system within 180 days of its availability. Prior to the initiation of these connection activities,
appropriate Division approval shall be received. [15A NCAC 02H .0404(e)]
II. PERFORMANCE STANDARDS
The subject non -discharge facilities 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 nuisance conditions due
to improper operation and maintenance, or failure of the high -rate infiltration or non -conjunctive
reclaimed utilization areas to adequately assimilate the effluent, the Permittee shall take immediate
corrective actions including Division required actions, such as the construction of additional or
replacement wastewater treatment, infiltration, or utilization facilities. [G.S. 143-215.1, 143-213.3(a)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this facility. [15A NCAC 02B .0200, 02L .0100]
3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with
15A NCAC 02C .0108 (Standards of Construction for Wells Other than Water Supply), and any other
jurisdictional laws and regulations pertaining to well construction. [15A NCAC 02C .0108]
4. Effluent quality shall not exceed the limitations specified in Attachment A. [15A NCAC 02T
.0108(b)(1), 02U .03001
5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T ,0705(m), 02U .0401(g), 02U .0402(m)]
6. A usable green area shall be maintained for effluent disposal. The green area shall contain at least
1,000 square feet of open green area for each residential unit served, or 2,500 square feet per thousand
gallons per day of waste flow, whichever is less. A green area is defined as an area suitable for waste
disposal, either in its natural state or which has been modified by planting a vegetative cover of grasses
or low growing shrubbery. [15A NCAC 02H .0404(g)(7)]
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7. The following shall be requirements for the reclaimed water distribution and utilization facilities:
a. All reclaimed water valves, storage facilities and outlets shall be tagged or labeled to warn the
public or employees that reclaimed water is not intended for drinking. Where appropriate, such
warning shall inform the public or employees to avoid contact with reclaimed water.
b. All reclaimed water piping, valves, outlets and other appurtenances shall be color -coded, taped or
otherwise marked to identify the source of the water as being reclaimed water.
i. AlI reclaimed water piping and appurtenances shall be either colored purple (i.e., Pantone 522)
and embossed or integrally stamped or marked "CAUTION: RECLAIMED WATER — DO
NOT DRINK" or be installed with a purple (i.e., Pantone 522) identification tape or
polyethylene vinyl wrap. The warning shall be stamped on opposite sides of the pipe and
repeated every three feet or less.
ii. Identification tape shall be at least three inches wide and have white or black lettering on purple
(i.e., Pantone 522) field stating "CAUTION: RECLAIMED WATER — DO NOT DRINK."
Identification tape shall be installed on reclaimed water pipelines in a visible manner, fastened
at least every 10 feet to each pipe length and run continuously the entire length of the pipe.
iii. Existing underground distribution systems retrofitted for the purpose of distributing reclaimed
water shall be taped or otherwise identified as noted above. This identification need not extend
the entire length of the distribution system, but shall be incorporated within 10 feet of crossing
any potable water supply line or sanitary sewer line.
c. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that permits
operation by authorized personnel only.
d. Hose bibs shall be located in locked, below grade vaults that shall be labeled as being of non -
potable quality. As an alternative to the use of locked vaults with standard hose bib services, other
locking mechanisms such as hose bibs which can only be operated by a tool may be placed above
ground and labeled as non -potable water.
[I 5A NCAC 02U .0403]
8. No direct cross -connections shall be allowed between reclaimed water and potable water systems,
unless such connection has been approved by the Department pursuant to 15A NCAC 18C .0406. [15A
NCAC 02U ,0403(f)]
9. The compliance and review boundaries for the reclaimed utilization system (i.e., Pond I and irrigation
areas permitted prior to September 1, 2006) are established at the property boundary. Any exceedance
of standards at the compliance or review boundary shall require action in accordance with 15A NCAC
02L .0106. [15A NCAC 02H .0219(k)(1)(C)(i)(Ul)]
10. The high -rate infiltration system was individually permitted on or after December 30, 1983; therefore,
the compliance boundary is established at either 250 feet from the effluent disposal area, or 50 feet
within the property boundary, whichever is closest to the effluent disposal area. An exceedance of
groundwater standards at or beyond the compliance boundary is subject to remediation action according
to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with North Carolina
General Statute 143-215.6A through 143-215.6C. [15A NCAC 02L A106(d)(2), 02L .0107(b)]
11. In accordance with 15A NCAC 02L .0108, the review boundary for the high -rate infiltration system is
established midway between the compliance boundary and the effluent disposal area. Any exceedance
of groundwater standards at the review boundary shall require action in accordance with 15A NCAC
02L .0106. [15A NCAC 02L .0106, 02L .0108]
12. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to
any sale or transfer of property affecting a compliance boundary. [15A NCAC 02L .0107(c)]
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13. In accordance with 15A NCAC 02L .0107(d), no wells, excluding Division approved monitoring wells,
shall be constructed within the compliance boundary except as provided for in 15A NCAC 02L
.0107(g). [ I5A NCAC 02L .01071
14. Except as provided for in 15A NCAC 02L .0107(g), the Pertnittee shall ensure any landowner who is
not the Permittee and owns land within the compliance boundary shall execute and file with the Dare
County Register of Deeds an easement running with the land containing the following items:
a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1);
b. Prohibits construction and operation of water supply wells within the compliance boundary; and
c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary
for purposes related to the permit.
The Director may terminate the easement when its purpose has been fulfilled or is no longer needed.
[15A NCAC 02L .0107(f)]
15. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for high -rate infiltration sites permitted under 15A NCAC 02H .0200 and 02H .0400
shall be as follows (all distances in feet):
i.
Any habitable residence or place of public assembly owned by the Permittee:
10
ii.
Any private or public water supply source:
100
iii.
Surface waters:
200
iv.
Groundwater lowering ditches:
200
v.
Surface water diversions:
200
vi.
Any well with exception of monitoring wells:
100
vii.
Any property line:
50
viii.
Subsurface groundwater lowering drainage systems:
200
ix.
Public right of way:
50
x.
Impounded public water supplies:
500
xi.
Public shallow groundwater supply:
500
[15A NCAC 02H .02190), 02H .0404(g)]
b. The setbacks for reclaimed utilization sites (i.e., Pond I and irrigation areas permitted prior to
September 1, 2006) shall be as follows (all distances in feet):
L Surface waters not classified SA: 25
ii. Surface waters classified SA: 100
iii. Any well with exception to monitoring wells: 100
[ 15A NCAC 02H .0219(k)]
c. The setbacks for storage and treatment units permitted under 15A NCAC 02H .0200 shall be as
follows (all distances in feet):
i. Any well with exception of monitoring wells:
ii. Any property line:
[15A NCAC 02T .02190)]
100
50
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III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater resulting
from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan,
which at a minimum shall include operational functions, maintenance schedules, safety measures and
a spill response plan. [15A NCAC 02T .0707]
2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the
Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more
certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the
previously cited rules. [15A NCAC 02T .0117]
3. A suitable year round vegetative cover on the non -conjunctive utilization sites shall be maintained at
all times, such that crop health is optimized, allows for even distribution of effluent and allows
inspection of the reclaimed utilization system. [15A NCAC 02T .0108(b)(1)]
4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the infiltration and
irrigation sites listed in Attachment B. [15A NCAC 02T .0108(b)(1)]
5. AlI waste application equipment shall be tested and calibrated at least once per permit cycle.
Calibration records shall be maintained at the facility for a period of no less than five years, and shall
be made available to the Division upon request. [15A NCAC 02T .0108(b)(1)]
6. Only effluent from KDHWWTP shall be disposed on the sites listed in Attachment B. [G.S. 143-215.1]
7. An automatically activated standby power source capable of powering all essential treatment units shall
be on site and operational at all times. If a generator is employed as an alternate power supply, it shall
be tested weekly by interrupting the primary power source. [15A NCAC 02H .0404(g)(3)]
8. No automobiles or machinery shall be allowed on the disposal sites except during equipment
installation or while maintenance is being performed. [15A NCAC 02T .0108(b)(1)]
9. Public access to the high -rate infiltration sites and wastewater treatment facilities shall be prohibited.
[I 5A NCAC 02T .0705(p)]
10. Public access to reclaimed water utilization sites shall be controlled during active site use. Such
controls may include the posting of signs showing the activities being conducted at each site. [15A
NCAC 02U .0501]
11. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .I 100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .0708. [15A NCAC 02T .0708, 02T .1100]
12. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited. [15A NCAC 02T ,0705(i)]
13. Freeboard in the infiltration basin (i.e., Pond 1) shall not be less than two feet at any time. [ 15A NCAC
02T .0705(c)]
14. A gauge to monitor waste levels in the infiltration basin (i.e., Pond 1) shall be provided. This gauge
shall have readily visible permanent markings, at inch or tenth of a foot increments, indicating the
following elevations: maximum liquid level at the top of the temporary liquid storage volume;
minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest point on
top of the dam. [ 15A NCAC 02T .0108(b)(1)]
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15. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e.,
outside toe of embankment to maximum allowable .temporary storage elevation on the inside of the
embankment), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible. [15A NCAC 02T
.0108(b)(1)]
16. All effluent shall be routed to the high -rate infiltration spray beds 1-A and 1-B should the limit for fecal
coliform (e.g., daily maximum concentration of 25 colonies per 100 mL) or turbidity (e.g.,
instantaneous maximum of 10 NTU) be exceeded, until the problems associated with the wastewater
treatment plant have been corrected. [15A NCAC 02T .0108(b)(1)]
17. The infiltration basin (i.e., Pond 1) shall be periodically cleaned to remove deposited materials that may
impede the infiltration process. Cleaning records shall be maintained at the facility for a period of no
less than five years, and shall be made available to the Division upon request. The Washington
Regional Office, telephone number [phone], shall be notified prior to each cleaning. [15A
NCAC 02T .0108(b)(1)]
18. The turbidimeter shall be tested and calibrated at a minimum of once per year. Calibration records
shall be maintained at the facility for a period of no less than five years, and shall be made available to
the Division upon request. [15A NCAC 02T .0108(b)(1)]
19. Spray beds shall be raked as needed and all vegetation shall be kept out of the spray beds at all times.
The spray beds shall also be raked when solids and ruts develop within the beds, which results in uneven
infiltration. [15A NCAC 02T .0108(b)(1)]
20. The application of chemicals to the high -rate infiltration spray beds is expressly prohibited. [15A
NCAC 02T .0108(b)(1)]
21. Adequate measures shall be taken to divert stormwater from the high -rate infiltration sites, the
infiltration basin, and the non -conjunctive reclaimed irrigation areas. [15ANCAC 02T .0108(b)(1)]
IV. 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
sampling reporting schedule shall be followed. [ 15A NCAC 02T .0108(c)]
2. A Division certified laboratory shall conduct all laboratory analyses for the required effluent,
groundwater or surface water parameters. [15A NCAC 02H .0800]
3. Flow through the treatment facility shall be continuously monitored, and daily flow values shall be
reported on Form NDMR.
The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy
and reliability of flow measurement consistent with accepted engineering and scientific practices.
Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of
less than ten percent from true flow; accurately calibrated at a minimum of once per year; and
maintained to ensure the accuracy of measurements is consistent with the selected device's accepted
capability. The Permittee shall maintain records of flow measurement device calibration on file for a
period of at least five years. At a minimum, documentation shall include:
a. Date of flow measurement device calibration,
b. Name of person performing calibration, and
c. Percent from true flow.
[I 5A NCAC 02T .0105(k)]
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4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for
the parameters specified in Attachment A. [15A NCAC 02T .0108(c)]
5. The Permittee shall maintain adequate records tracking the amount of effluent infiltrated. At a
minimum, these records shall include the following information for each infiltration and irrigation site
listed in Attachment B:
a. Date of infiltration;
b. Volume of effluent infiltrated;
c. Site infiltrated;
d. Loading rates to each infiltration site listed in Attachment B; and
e. Weather conditions.
[15A NCAC 02T .0108(c)]
6. The Permittee shall maintain adequate records tracking the amount of reclaimed water utilized.
Records shall be maintained for a minimum of five years. At a minimum, these records shall include
the following information for each utilization site listed in Attachment B:
a. Date of reclaimed water utilization;
b. Volume of reclaimed water irrigated;
c. Site irrigated;
d. Length of time site is irrigated;
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings;
£ Weather conditions; and
g. Maintenance of cover crops.
[ 15A NCAC 02T .0108(c)]
7. Freeboard (i.e., waste level to the lowest embankment elevation) in Pond I shall be measured to the
nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records shall be maintained at
the facility for a period of no less than five years, and shall be made available to the Division upon
request. [15A NCAC 02T .0108(c)]
Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Forth NDMR for
each PPI, three copies of all operation and utilization records (as specified in Condition IV.6.) on Form
NDAR-1 for every non -conjunctive utilization site listed in Attachment B, and three copies of all
operation and disposal records (as specified in Conditions IV.5. and IV.7.) on Form NDAR-2 for every
infiltration site in Attachment B shall be submitted on or before the last day of the following month. If
no activities occurred during the monitoring month, monitoring reports are still required documenting
the absence of the activity. All information shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(1)]
WQ0002829 Version 2.1 Shell Version 151201 Page 8 of 12

9. Pursuant to § 143-215.1 C., the Permittee shall provide to its users and the Division of Water Resources
an annual report summarizing the performance of the wastewater treatment, high -rate infiltration, and
reclaimed utilization facility and the extent to which the facility has violated this permit, or federal or
State laws, regulations, or rules related to the protection of water quality. This report shall be prepared
on either a calendar or fiscal year basis and shall be provided no later than 60 days after the end of the
calendar or fiscal year. Two copies of the annual report provided to the Permittee's users shall be
submitted to:
Division of Water Resources
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[G.S. 143-215.1C]
10. A record shall be maintained of all residuals removed from this facility. This record shall be maintained
at the facility for a period of no less than five years, and shall be made available to the Division upon
request. At a minimum, this record shall include:
a. Name of the residuals hauler;
b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality
agreeing to accept the residuals;
c. Date the residuals were hauled; and
d. Volume of residuals removed.
[15A NCAC 02T .0108(b)(1)]
11. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a
period of no less than five years, and shall be made available to the Division upon request. At a
minimum, this log shall include:
a. Date and results of power interruption testing on alternate power supply;
b. Date of calibration of flow measurement device;
c. Date of calibration of turbidimeter;
d. Visual observations of the plant and plant site;
e. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.); and
f. Dates high -rate infiltration beds were raked and inspected.
[15ANCAC 02T .0108(b)(1)]
12. Monitoring wells shall be sampled at the frequencies and for the parameters specified in Attachment
C. All mapping, well construction forms, well abandonment forms and monitoring; data shall refer to
the permit number and the well nomenclature as provided in Attachment C and Figure 1. [15A NCAC
02T ,0105(m)]
13. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance
Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last
working day of the month following the sampling month. The Compliance Monitoring Form (GW-59)
shall include this permit number, the appropriate well identification number, and one GW-59a
certification form shall be submitted with each set of sampling results. All information shall be
submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .0105(m)]
WQ0002829 Version 2.1 Shell Version 151201 Page 9 of 12

14. Noncompliance Notification:
The Permittee shall report by telephone to the Washington Regional Office, telephone number (252)
946-6481, 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. Treatment of wastes abnormal in quantity or characteristic, including the known passage of a
hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons,
rendering the facility incapable of adequate wastewater treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
e. Ponding in or runoff from the infiltration and irrigation sites.
f. Effluent breakout from the infiltration basin.
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 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
wastewater treatment, high -rate infiltration, and reclaimed utilization facilities. [15A NCAC 02T
.0108(b)]
2. The Permittee or their designee shall inspect the wastewater treatment, high -rate infiltration and
reclaimed utilization facilities to prevent malfunctions, facility deterioration and operator errors
resulting in discharges, which may cause the release of wastes 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 the
inspection, and this log shall be made available to the Division upon request. [15A NCAC 02T
.0108(b)]
Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the wastewater treatment, high -rate infiltration and
reclaimed utilization 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.
143-21.5.3(a)(2)]
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 permitted facilities are not constructed in accordance with the
conditions of this permit, the Division approved plans and specifications, and other supporting
documentation. [15A NCAC 02T .0110]
WQ0002829 Version 2.1 Shell Version 151201 Page 10 of 12

3. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, Division approved plans and specifications, and other supporting documentation. No
variances to applicable rules governing the construction or operation of the permitted facilities are
granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n).
[G. S. 143-21.5.1 ]
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 General Permit NCGO10000; 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. [15A NCAC 02T .0105(c)(6)]
5. In the event the permitted facilities change ownership or the Permittee changes their 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 property ownership documentation and other supporting
documentation as necessary. The Permittee of record shall remain fully responsible for maintaining
and operating the facilities permitted herein until a permit is issued to the new owner. [15A NCAC
02T .0104]
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0108(b)(1)]
The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority. [15A NCAC 02T
.0105G)]
8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. [ 15A NCAC 02T .0110]
9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein
shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). [15A
NCAC 02T .0120]
10. 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 9' day of December 2016
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
r-
JS. Jay Zimmerman, P.G., Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0002829
WQ0002829 Version 2.1 Shell Version 151201 Page 11 of 12

Permit No. WQ0002829 High -Rate Infiltration and Non -Conjunctive Reclaimed Utilization System
KDHWWTP, L.L.C. December 9, 2016
KDHWWTP Dare County
ENGINEERING CERTIFICATION
❑ Partial ❑ Final
In accordance with 15A NCAC 02T .0116,1, , as
a duly registered Professional Engineer in the State of North Carolina, having the Permittee's authorization
to ❑ periodically ❑ weekly ❑ fully observe the construction of the permitted facility, hereby state to the
best of my abilities that due care and diligence was used in the observation of the construction, such that
the facility was built within substantial compliance and intent of this permit, the Division -approved plans
and specifications, and other supporting documentation.
❑ Any variation to this permit, the Division -approved plans and specifications, and other supporting
documentation has been documented in the attached as -built drawings, and shall serve as the
Permittee's minor modification request to amend the permit accordingly.
Provide a brief narrative description of any variations:
THE COMPLETED ENGINEERING CERTIFICATION, INCLUDING ALL SUPPORTING
INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
WATER QUALITY PERMITTING SECTION
NON -DISCHARGE PERMITTING UNIT
By U.S. Postal Service:
1617 MAIL SERVICE CENTER
By Courier/Special DelivM:
512 N. SALISBURY ST.
RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604
WQ0002829 Version 2.1 Shell Version 151201 Page 12 of 12

ATTACHMENT A — LIMITATIONS AND MONITORING REQUIREMENTS
PPI 001— Total Effluent Disposed
Permit Number: WQ0002829 Version: 2.1
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCs
Code
Parameter Description
Units of
Measure
Monthly
Average
Monthly
Geometric Mean
Daily Minimum
Daily Maximum
Measurement
Frequency
Sample
Type
50050
Flow, in Conduit or thru Treatment Plant
GPD
500,000
Continuous
Recorder
PPI 002 — High -Rate Infiltration Effluent
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Code
Parameter ➢escription
Units of
Measure
Monthly
Average
Monthly
Geometric Mean
Daily Minimum
Daily Maximum
Measurement
Frequency
Sample
Type
00310
BOD, 5-Day (20 °C)
mg/L
10
Weekly' / 2 x Month 2
Composite
00940
Chloride (as Cl)
mg/L
3 x Year 3
Composite
31616
Coliform, Fecal MF, M-FC Broth, 44.5 °C
#/100 mL
14
43
Weekly' / 2 x Month 2
Grab
50050
Flow, in Conduit or thru Treatment Plant
GPD
327,735
Continuous
Recorder
00610
Nitrogen, Ammonia Total (as N)
mg/L
4
Weekly 112 x Month 4
Composite
00625
Nitrogen, Kjeldahl, Total (as N)
mg/L
Weekly' / 2 x Month 2
Composite
00620
Nitrogen, Nitrate Total (as N)
mg/L
Weekly' / 2 x Month 2
Composite
00600
Nitrogen, Total (as N)
mg/L
Weekly' / 2 x Month 2
Composite
00400
pH
su
1
6
9
5 x Week
Grab
00665
Phosphorus, Total (as P)
mg/L
Weekly I / 2 x Month a
Composite
70300
Solids, Total Dissolved — 180'C
mg/L
3 x Year 3
Composite
00530
Solids, Total Suspended
mg/L
20
Weekly' / 2 x Month 2
Composite
1. Weekly sampling shall be conducted from May 11 through August 3151,
2. 2 x Month sampling shall be conducted from September 111 through April 30u1.
3. 3 x Year monitoring shall be conducted in January, April, and September
W Q0002829 Version 2,1 Attachment A Page 1 of 2

PPI 003 — Non -Conjunctive Reclaimed Utilization Effluent
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PC5 Parameter Description Units of
Code on Measure
Monthly
Average
Monthly
Geometric Mean Daily Minimum
Daily Maximum
Measurement
Sample
Frequency
9 Y
Type
YP
00310 BOD, 5-Day (20 °C) mg/L
10
15
Weekly ' / 2 x Month 2 Composite
31616 Coliform, Fecal MF, M-FC Broth, 44.5 °C #/100 mL
14
25
Weekly' / 2 x Month 2 Grab
00610 Nitrogen, Ammonia Total (as N) mg/L
4
6
Weekly' / 2 x Month 2 Composite
00400 pH su
6
9
5 x Week
Grab
00530 Solids, Total Suspended mg/L
5
10
Weekly' / 2 x Month 2 Composite
00076 1 Turbidity, HCH Turbidimeter NTU 1
10
Continuous
Recorder
1, Weekly sampling shall be conducted from May 11 through August 311.
2. 2 x Month sampling shall be conducted from September 1' through April 30'.
PPI 004 — Reclaimed Water Distributed for Infiltration
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS Units of
CodeF Parameter Description Measure
Monthly
Average
Monthly
Geometric Mean Daily Minimum
Daily Maximum
Measurement
Sample
FrequencyT
e
Type
50050
Flow, in Conduit or thru Treatment Plant
GPD
136,283
Continuous
Recorder
PPI 005 — Reclaimed Water Distributed for Irrigation
EFFLUENT CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
PCS
Code
Parameter Descriti
pon
Units of
Measure
Monthly
Average
Monthly
Geometric Mean
Dal y Minimum
Daily Maximum
Measurement
Sample
Frequency a Y
Type
50050
Flow, in Conduit or thru Treatment Plant
GPD
215,456
Continuous
Recorder
WQ0002829 Version 2.1 Attachment A Page 2 of 2

ATTACHMENT B - APPROVED LAND APPLICATION SITES AND LIMITATIONS
KDHWWTP, L.L.C. - KDHWWTP
Permit Number: WQ0002829 Version: 2.1
INFILTRATIOMIRRIGATION AREA INFORMATION
APPLICATION LIMITATIONS
Basin 1
Field
Owner
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
Parameter
Hourly
Rate
Yearly
Max
Units
I -A
KDHWWTP, L.L.C.
Dare
36.0086770
-75.6699340
0.28
NIA
01284 -Non-Discharge Application Rate
10.0
GPDIft2
1-11
KDHWWTP, L.L.C.
Dare
36.0084120
-75.6697710
0.28
NIA
01284 -Non-Discharge Application Rate
10.0
GPD/ft2
3
KDHWWTP, L.L.C.
Dare
36.0073390
-75.6721650
0.06
NIA
01284-Non-Discharge Application Rate
10.0
GPD/ft2
4
KDHWWTP, L.L.C.
Dare
36.0076850
-75.6726090
0.12
NIA
01284 -Non-Discharge Application Rate
10.0
GPDIft2
5
KDHWWTP, L.L.C.
Dare
36.0072010
-75.6733780
0.06
NIA
01284 -Non-Discharge Application Rate
10.0
GPDIft2
6
KDHWWTP, L.L.C.
Dare
36.0069380
-75.6740200
0.21
NIA
01284-Non-Discharge Application Rate
10.0
GPD/ft2
7-A
KDHWWTP, L.L.C.
Dare
36.0060910
-75.6748290
0.17
NIA
01284 -Non-Discharge Application Rate
10.0
GPD/ft2
7-11
KDHWWTP, L.L.C.
Dare
36.0057470
-75.6746170
0.17
NIA
01284 -Non-Discharge Application Rate
10.0
GPD/ft2
Total Acreage for High -Rate Infiltration Areas
1.35
IRR-1
KDHWWTP, L.L_C.
Dare
36.0080560
-75.6783330
4.6
Ousley
01284 - Non -Discharge Application Rate
1.0
t 18
inches
IRR-2
KDHWWTP, L.L.C.
Dare
36.0080560
-75.675833-
6.47
Corolla
01284-Non-Discharge Application Rate
1.0
118
inches
IRR-3
KDHWWTP, L.L.C.
Dare
36.0097220
-75.676389'
3.27
Corolla
01284 - Non -Discharge Application Rate
1.0
118
inches
IRR-4
KDHWWTP; L.L.C.
Dare
36.0077780
-75.6705560
5.62
Ousley
01284-Non-Discharge Application Rate
1.0
118
inches
IRR-5
KDHWWTP, L.L.C.
Dare
36.009731 °
-75,6717900
0.94
Newhan
01284 - Non -Discharge Application Rate
1.0
118
inches
iRR-6
KDHWWTP, L.L.C.
Dare
36.009444"
-75.6694440
1.65
Ousley
01284 -Non-Discharge Application Rate
1.0
118
inches
IRR-7
KDHWWTP, L.L.C.
Dare
36.0086110
-75.6675000
2.00
Newhan
01284 -Non-Discharge Application Rate
1.0
118
inches
Total Acreage for Reclaimed Irrigation Zones
24.55
Pond I
KDHWWTP, L.L.C. Dare
36.004796-
-75.676753°
2A
NIA
01284-Non-Discharge Application Rate
1.49
GPD/ft2
Total Acreage for the 2 Interconnected Reclaimed Infiltration Ponds (Pond 1)
2.1
WQ0002829 Version 2.1 Attachment B Page i of 1

THIS PAGE BLANK

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS
Monitoring wells: CW-A, CW-C, CW-D, CW-F, CW-G, CW-E-1, CW-B-1
Permit Number: WQ0002829 Version: 2.1
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
PCS Code
Parameter Description
Daily Maximum
Frequency Measurement
Sample Type
Footnotes
00680
Carbon, Tot Organic (TOC)
mg/L
3 x Year
Grab
1,6
00940
Chloride (as Cl)
250
mg/L
3 x Year
Grab
1
31616
Coliform, Fecal MF, M-FC Broth, 44.5 °C
#/100 mL
3 x Year
Grab
1
00610
Nitrogen, Ammonia Total (as N)
1.5
mg/L.
3 x Year
Grab
1
00620
Nitrogen, Nitrate Total (as N)
10
mg/L
3 x Year
Grab
1
00400
pH
6.5-8.5
su
3 x Year
Grab
1,2
00665
Phosphorus, Total (as P)
mg/L
3 x Year
Grab
I
70300
Solids, Total Dissolved - 180 °C
500
mg/L
3 x Year
Grab
1
GWVOC
Volatile Compounds (GC/MS)
Present: Yes/No
Annually
Grab
1, 4, 5
82546
Water Level, Distance from measuring point
feet
3 x Year
Calculated
1, 2, 3
1. 3 x Year monitoring shall be conducted in .January, April & September; Annual monitoring shall be conducted every September.
2. The measurement of water levels shall be made prior to purging the wells. The depth to water in each well shall be measured from the surveyed point on the top of the casing. The measurement of
pH shall be made after purging and prior to sampling for the remaining parameters.
3. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top of
casing) of all monitoring wells shall be surveyed relative to a common datum.
4. Volatile Organic Compounds (VOC) - In November only, analyze by one of the fallowing methods:
a. Standard Method 6230D, PQL at 0.5 µg/L or less
b. Standard Method 6210D, PQL at 0.5 µg/L or less
c. EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
d. EPA Method 8260, Low Concentration, PQL at 0.5 µg/L or less
e. Another method with prior approval by the Water Quality Permitting Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be DWR certified to run any method used.
b. The method used must, at a minimum, include all the constituents listed in Table VIII of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 µg/L or less that must be supported by laboratory proficiency studies as required by DWR. Any constituents detected above the MDL but below
the PQL of 0.5 µg/L must be qualified (estimated) and reported.
5. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C, then the Washington Regional Office supervisor, telephone number [phone],
must be contacted immediately for further instructions regarding any additional follow-up analyses required.
6. If TOC concentrations greater than 10 mg/L are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/L, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
7. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 1 and this attachment.
WQ0002829 Version 2.1 Attachment C Page 1 of 1

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