WQ0001122_Final Permit_20131220

A
NCDENR
North Carolina Department: of Environment and Natura
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
December 20, 2013
Cathy Curtis -- Owner
Curtis Insulation. Company, Inc.
10150 West Highway 97
Middlesex, North Carolina 27551
Dear Ms. Curtis:
Resources
John E. Skvarla, III
Secretary
Subject: .Permit No. WQ0001122
Curtis Insulation
Closed -Loop Recycle System
Nash County
In accordance with your permit renewal request received November 1, 2013, we are forwarding
herewith Permit No. WQ0001122, issued December 20, 2013, to Curtis Insulation Co. Inc. for the
continued operation of the subject wastewater treatment and closed -loop recycle facilities. Please note
that this renewed permit shall become effective on May 1, 2014 (i.e. the day after the expiration date of
the existing permit), which differs from the date of this letter.
This permit shall be effective until April 30, 2019, shall void Permit No. WQ0001122 issued
May 15, 2009 and shall be subject to the conditions and limitations as specified therein. Please pay
particular attention to the monitoring requirements listed in Attachment 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 that, as per Permit Condition N.S., the three monitoring wells are to be sampled
before reactivation of the recycle system for the parameters Iisted in Attachment C.
Please note the following permit conditions are new, or have been modified, since the last
permit issuance:
➢ Condition 1.1 —requires
the installation of a waste level gauge in the settling lagoon
9 Condition 1.2 -
requires abandonment of water supply wells within the Compliance Boundary
➢ Condition 1.3 —
describes the procedure for renewing this permit
➢ Condition 11.3-
— requires properly constructed monitor wells
➢ Condition 111.1.
— requires the facilities to be properly maintained and operated
➢ Condition 111.3.
—prohibits public access to the treatment facilities
WATER QUALITY PERMITTING SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Saksbury 5t., Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: http-llportal.nodenr.org/weblwq
An Equal Opportunely 1 A firmalive Aclion Employer

Ms. Cathy Curtis
December 20, 2013
Page 2 of 2
➢ Condition IV.3. — requires weekly measurements of the freeboard in the settling lagoon
➢ Condition IVA. — requires a record of all residuals removed from the facility
➢ Condition IV.7. —requires the submission of compliance monitoring data
➢ Condition VI.7. — requires that the permit be maintained until it is replaced by another permit
or the site is closed in accordance with closure regulations
➢ Condition VI_S. — subjects the permit to revocation or unilateral modification under certain
conditions
➢ Condition VI9. — prohibits expansion of the permitted facilities in certain circumstances
If any parts, requirements or limitations 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.
If you need additional information concerning this permit, please contact David Goodrich at (919)
807-6352 or at [e-mail].
Sincerely,
for T mas A. Reeder
cc: Nash County Health Department
Raleigh Regional Office, Water Quality Regional Operations Section
Protection and Enforcement Branch
Permit File WQ0001122
Notebook Pile WQ0001122

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMIkUSSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
CLOSED -LOOP RECYCLE SYSTEM 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
Curtis Insulation Co. Inc.
Nash County
FOR THE
continued operation of a 900 gallon per minute (GPM) wastewater treatment and closed -loop recycle
facility consisting of:
a 2.15 million gallon settling lagoon with recycle of wastewater back into the manufacturing facility
to serve Curtis Insulation Co., Inc., with no discharge of wastes to surface waters, pursuant to the
application received November 1, 2013, and in conformity with the project plans, specifications, and
other supporting data subsequently filed and approved by the Department of Environment and Natural
Resources and considered a part of this permit.
This permit shall be effective from May 1, 2014 until April 30, 2019, shall void Permit No. WQ0001122
issued May 15, 2009, and shall be subject to the following specified conditions and limitations:
I. SCHEDULES
A gauge to measure water levels in the settling lagoon shall be installed within 60 days of issuance of
this permit or prior to facility reactivation.. Caution shall be taken not to damage the integrity of the
liner (if provided) when installing the gauge. This gauge shall have readily visible permanent
markings, at inch or tenth of a foot increments, indicating the following elevations: maximum Iiquid
level at the top of the temporary liquid storage volume; minimum liquid level at the bottom of the
temporary liquid storage volume; and the Iowest point on top of the dam.
2. Within 60 days of reactivation of this facility, all water supply wells within the Compliance Boundary
shall be permanently abandoned. Within 30 days of abandonment, a Well Abandonment Record
(Form GW-30) listing this permit number and the appropriate monitoring well identification number
shall be completed for each well abandoned and mailed to the Division of Water Resources, Water
Quality Permitting Section, 1636 Mail Service Center, Raleigh, NC 27699-1636. A North Carolina
Certified WeII Contractor shall abandon the monitoring wells according to the North Carolina Well
Construction Standards (I SA NCAC 02C .0113) and local county rules.
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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 trap to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
I. The subject non -discharge facilities shall be effectively maintained and operated at all times so there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions including Division required actions, such as the construction of additional or
replacement wastewater treatment or recycle facilities.
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_
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.
4. The compliance boundary for the disposal system shall be specified in accordance with 15A NCAC
02L .0107(a). This disposal system was individually permitted prior to December 30, 1983;
therefore, the compliance boundary is established at either 500 feet from the effluent disposal area, or
at 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.
5. In accordance with 15A NCAC 02L .0108, the review boundary 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.
6. The facilities permitted herein shall be constructed according to the following setbacks:
a. The setbacks for storage and treatment units permitted under I5A NCAC 02H .0200 shall be as
follows (all distances in feet):
i. Surface waters: 50
ii. Any well with the exception of a Division approved groundwater monitoring weI1: 100
iii. Any property Iine: 50
M. 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 nor -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 pursuant to 15A NCAC 02T .1007, which at a minimum shall include operational
functions, maintenance schedules, safety measures and a spill response plan.
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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.
3. Public access to the wastewater treatment facilities closed -loop recycle system shall be prohibited.
4. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in
accordance with 15A NCAC 02T .1100. The Permittee shall maintain a residual management plan
pursuant to 15A NCAC 02T .1008.
5. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is
prohibited.
6. Freeboard in the settling lagoon shall not be less two (2) feet at any time.
7. 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.
N. 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.
2. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for
the required effluent, groundwater or surface water parameters.
Freeboard (i.e_, waste level to the lowest embankment elevation) in the settling lagoon 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.
4. 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_
Prior to plant reactivation, monitoring wells MW-1, MW-2 and MW-3 shall be inspected every
November to ensure the wells are in compliance with 15A NCAC 02C _0108 Well Construction
Standards. Records of such inspections must be maintained. Each monitoring well must be labeled as
required by 15A NCAC 02C .0108 (c) (11).
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6. Upon reactivation of this facility, monitoring wells shall be sampled initially before reactivation and
within 3 months prior to initiating waste disposal operations. Monitoring wells shall be sampled
thereafter at the frequencies and for the parameters specified in Attachment C. All mapping, we11
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.
7. 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
8. Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791-
4200, 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. Any occurrence at the facility resulting in the treatment of significant amounts of wastes that is
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.
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 be taken to ensure the problem does not recur.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
wastewater treatment and recycle facilities_
2. The Permittee or their designee shall inspect the wastewater treatment and recycle 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.
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3. 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 and recycle 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.
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,
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.
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).
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.
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.
6. The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein.
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 pursuant to 15A NCAC
02T .01050).
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.
g. 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).
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10. The Perrnittee 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 pursuant to 15A
NCAC 02T .0105(e) (3).
Permit issued this the 20th day of December, 2013, and effective May 1, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
l
r T as A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0001122
WQ0001122 Version 3.0 Shell Version 131016 Page 6 of 6

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS
Monitoring wells: MW-1, MW-2 & MW-3
Permit Number: WQ0001122 Version: 3.0
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
PCS Code
Parameter Description
Daily Maximum
Frequency Measurement
Sample Type
Footnotes
00680
Carbon, Total Organic (TOC)
mg/1
Annually
Grab
1,4
00400
pH
Range: 6,5 -- 8.5
su
Annually
Grab
1,2
82546
Water level, distance from measuring point
feet
Annually
Calculated
1, 2, 3
1. Annual monitoring shall be conducted every November.
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. If not already performed, 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. 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 individuall constituents
comprising this TOC concentration, If the TOC concentration as measured in the background monitor well exceeds I0 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.
5. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure I and this attachment.
WQ0001122 Version 3.0 Attachment C Page I of I

WQ0001122 Curtis Insulation Co. Inc.
820 East Nash Street
Spring Hope, NC 27582
Latitude: 350 57' 00" Longitude: -78' 05'. 50"
FIGURE 1
CURTIS INSULATION COMPANY, INC.
CLOSED -LOOP RECYCLE SYSTEM
NASH COUNTY
W Q0001122
MONITOR WELL LOCATION MAP