WQ0001122_Final Permit_20190325

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
PRESTON G. CURTIS, III — VICE PRESIDENT
CURTIS INSULATION CO INC.
POST OFFICE BOX 880
SPRING HOPE, NORTH CAROLINA 27882
Dear Mr. Curtis:
NORTH CAROLINA
Environmental Quality
March 25, 2019
Subject: Permit No. WQ0001122
Curtis Insulation CLRS
Closed -Loop Recycle System
Nash County
In accordance with your permit renewal request received February 25, 2019, we are forwarding
herewith Permit No. WQ0001122 dated March 25, 2019, 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, 2019 (i.e., the day after the expiration date of the existing
permit).
This permit shall be effective from May 1, 2019 through January 31, 2025, shall void Permit No.
WQ0001122 issued December 20, 2013, and shall be subject to the conditions and limitations therein. The
Permittee shall submit a renewal application no later than August 4, 2024.
Please pay attention to the monitoring requirements listed in Section IV and 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.
The Division has removed the following permit conditions since the last permit issuance dated
December 20, 2013:
➢ Old Condition I.1. —The water level gauge has been installed.
➢ Old Condition VI.2. — This condition has been removed because the permit is not voidable.
The following permit conditions are new since the last permit issuance dated December 20,
2013:
➢ Condition I.I. —The Permittee shall notify the Division of Water Resources, Non -Discharge
Branch prior to reactivating the facility.
➢ Condition I.2. — The Permittee shall notify the Raleigh Regional Office prior to reactivating
the facility for an inspection.
➢ Condition III.8. — This condition specifies that a gauge to monitor waste levels in the 2.15 MG
settling lagoon shall be provided.
�{� North Carolina Department of Environmental Quality I Division of Water Resources
e:-�e—Dr v
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
Noam cnaourPu�
�� 919.707.9000

Mr. Preston G. Curtis, III
March 25, 2019
Page 2 of 2
➢ Condition 111. 10. — Metering equipment shall be tested and calibrated annually.
➢ Condition IV.5. — A maintenance log shall be kept at this facility which includes visual
observations of the plant and preventative maintenance.
➢ Condition VI. 10. — This condition states that the permit will not be renewed if the annual fee
is not paid.
➢ Attachment C — Monitoring parameters have been added and frequencies have been updated.
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. Otherwise, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Erick Saunders at (919)
707-3659 or erickson.saunders [e-mail].
Sincerely,
%Linda Culpepper, Director
Division of Water Resources
cc: Nash County Health Department (Electronic Copy)
Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
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 (MG) settling lagoon with recycle of wastewater back into the manufacturing facility;
and all associated piping, valves, controls, and appurtenances
to serve the Curtis Insulation CLRS, with no discharge of wastes to surface waters, pursuant to the
application received February 25, 2019, and in conformity with the Division -approved plans and
specifications considered a part of this permit.
This permit shall be effective from May 1, 2019 through January 31, 2025, shall void Permit No.
WQ0001122 issued December 20, 2013, and shall be subject to the following conditions and limitations:
I. SCHEDULES
1. Prior to resuming closed-loop recycle operations, the Permittee shall notify the Division in writing.
This notification shall be sent to the Division of Water Resources, Non -Discharge Branch, 1617 Mail
Service Center, Raleigh, NC 27699-1617, or Non-Discharge.Reports(a),ncdenr.aov. [15A NCAC 02T
.0108(b)(1)(B)]
2. The Permittee shall notify the Raleigh Regional Office, telephone number [phone], at least two
business days in advance of initial operation of the constructed facilities so that the Division can
conduct a startup inspection. [15A NCAC 02T .0108(b)(1)(B)]
Within 60 days of resuming closed-loop recycle operations, 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 water supply well
identification number shall be completed for each well abandoned and mailed to the Division of Water
Resources, Non -Discharge Branch, 1617 Mail Service Center, Raleigh NC 27699-1617. A North
Carolina Certified Well Contractor shall abandon the monitoring wells according to the North Carolina
Well Construction Standards (15A NCAC 02C.01 13) and local county rules. [15A NCAC 02C .0113,
02T .0108(b)(1)(B)]
WQ0001122 Version 4.0 Shell Version 180901 Page 1 of 6

II.
4. The Permittee shall request renewal of this permit on Division -approved forms no later than August 4,
2024. [15A NCAC 02T .0105(b), 02T .0109]
PERFORMANCE STANDARDS
The Permittee shall maintain and operate the subject non -discharge facilities 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, the Permittee shall take immediate corrective actions, including Division
required actions, such as the construction of additional or replacement wastewater treatment or recycle
facilities. [15A NCAC 02T .0108(b)(1)(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 02T .0108(b)(1)(A)]
3. Groundwater monitoring wells 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]
Disposal systems permitted on or after December 30, 1983 have a compliance boundary that is either
250 feet from the disposal system, or 50 feet within the property boundary, whichever is closest to the
disposal system. Any exceedance of groundwater standards at or beyond the compliance boundary
shall require corrective action. Division -approved relocation of the compliance boundary shall be noted
in Attachment B. Multiple contiguous properties under common ownership and permitted for use as a
disposal system shall be treated as a single property with regard to determination of a compliance
boundary. [15A NCAC 02L .0106(d)(2), 02L .0107(b), 02T .0105(h), G.S. 143-215.1(i), G.S. 143-
215.1(k)]
The review boundary is midway between the compliance boundary and the disposal system. Any
exceedance of groundwater standards at or beyond the review boundary shall require preventative
action. [15A NCAC 02L.0106(d)(1), 02L .0108]
6. The facilities herein were permitted per the following setbacks:
a. The storage and treatment units were modified January 31, 1989. The setbacks for storage and
treatment units originally permitted or modified from October 1, 1987 to January 31, 1993 are as
follows (all distances in feet):
i. Each private or public water supply source:
ii. Each well with exception of monitoring wells:
iii. Each property line:
iv. Nitrification field:
100
100
50'
20
1 Setbacks to property lines are not applicable when the Permittee, or the entity from which the
Permittee is leasing, owns both parcels separated by the property line.
[15A NCAC 02H .02190)(5)]
OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the subject facilities as a non -discharge system. [15A NCAC
02U.0101]
2. The Permittee shall maintain an Operation and Maintenance Plan, which shall include operational
functions, maintenance schedules, safety measures, and a spill response plan. [15A NCAC 02U
.0801(a)]
WQ0001122 Version 4.0 Shell Version 180901 Page 2 of 6

3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the subject non -discharge facilities, the Permittee shall designate and employ a certified
operator in responsible charge (ORC), and one or more certified operators as back-up ORCs. The ORC
or their back-up shall operate and visit the facilities as required by the WPCSOCC. [15A NCAC 02T
.0117]
4. The Permittee shall prohibit public access to the wastewater treatment, storage, and closed-loop recycle
facilities. [ 15A NCAC 02U .0404(b)(1)]
5. The Permittee shall dispose or utilize generated residuals in a Division -approved manner. [ 15A NCAC
02U .0802, 02T .1100].
6. The Permittee shall not divert or bypass untreated or partially treated wastewater from the subject
facilities. [15A NCAC 02T .0108(b)(1)(A)]
7. Freeboard in the 2.15 million gallon (MG) settling lagoon shall not be less than two feet at any time.
[ 15A NCAC 02U .0404(c)(6)]
8. A gauge to monitor waste levels in the 2.15 million gallon (MG) settling lagoon 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 02U .0801(f)]
9. A protective vegetative cover shall be established and maintained on all berms, pipe runs, erosion
control areas, surface water diversions, and earthen embankments (i.e., outside toe of embankment to
maximum allowable temporary storage elevation on the inside of the embankment). Trees, shrubs, and
other woody vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankments shall be kept mowed or otherwise controlled and accessible. [ 15A NCAC 02U .0801(g)]
10. Metering equipment shall be tested and calibrated annually. [ 15A NCAC 02U .0801(d)]
IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
facility's impact on groundwater and surface water. [ 15A NCAC 02T .0108(c)]
2. A Division -certified laboratory shall conduct all analyses for the required effluent, groundwater, and
surface water parameters. [15A NCAC 02H .0800]
3. Freeboard (i.e., waste level to the lowest embankment elevation) in the 2.15 million gallon (MG)
settling lagoon shall be measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly
freeboard records shall be maintained for five years, and shall be made available to the Division upon
request. [15A NCAC 02T .0108(c)]
4. The Permittee shall maintain a record of all residuals removed from this facility. This record shall be
maintained for five years, and shall be made available to the Division upon request. 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 02U .0802(b)]
WQ0001122 Version 4.0 Shell Version 180901 Page 3 of 6

5. A maintenance log shall be kept at this facility. This log shall be maintained for five years, and shall
be made available to the Division upon request. This log shall include:
a. Visual observations of the plant and plant site; and
b. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections
and cleanings, etc.).
[15A NCAC 02U .0801(h)]
6. Prior to resuming closed-loop recycle operations, 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. Inspection records shall be maintained. Each monitoring well shall be labelled
pursuant to 15A NCAC 02C .0108(c)(11). [15ANCAC 02T .0108(b)(1)(A)]
7. Monitoring wells MW -1, MW -2 and MW -3 shall be sampled within three months prior to resuming
closed-loop recycle operations. Monitoring wells shall be sampled thereafter 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)]
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.0 I 05(m)]
9. Noncompliance Notification:
The Permittee shall report to the Raleigh Regional Office, telephone number [phone], within
24 hours of first knowledge 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.) rendering the facility incapable of
adequate wastewater treatment.
c. Any facility failure resulting in a discharge to surface waters.
d. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Raleigh Regional Office within five days
of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to ensure
the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)]
WQ0001122 Version 4.0 Shell Version 180901 Page 4 of 6

V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the wastewater
treatment and recycle facilities. [15A NCAC 02U .0801(i)]
2. The Permittee shall inspect the wastewater treatment and recycle facilities to prevent malfunctions,
facility deterioration, and operator errors that may result in discharges of wastes to the environment,
threats to human health, or public nuisances. The Permittee shall maintain an inspection log that
includes the date and time of inspection, observations made, and 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 02U
.0801(h), 02U .0801(i)]
Division authorized representatives may, upon presentation of credentials, enter and inspect any
property, premises, or place related to the wastewater treatment and recycle facilities permitted herein
at any reasonable time for determining compliance with this permit. Division authorized
representatives may inspect or copy records 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)]
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.6B, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division -approved plans and specifications. [G.S. 143-215.1(d)]
3. Unless specifically requested and approved in this permit, there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T .0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T .0105(c)(6)]
5. If the permitted facilities change ownership, or the Permittee changes their name, the Permittee shall
submit a permit modification request on Division -approved forms. The Permittee shall comply with
all terms and conditions of this permit until the permit is transferred to the successor -owner. [G.S. 143-
215.1(d3)]
6. The Permittee shall retain a set of Division -approved plans and specifications for the life of the facilities
permitted herein. [15A NCAC 02T .0105(o)]
7. The Permittee shall maintain this permit until the proper closure of all facilities permitted herein, or
until the facilities permitted herein are permitted by another authority. [15A NCAC 02T .01050)]
WQ0001122 Version 4.0 Shell Version 180901 Page 5 of 6

8. This permit is subject to revocation or modification upon 60 -day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[15A NCAC 02T.0 110]
9. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.613, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.613, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[ 15A NCAC 02T.0 120(b), 02T .0120(d)]
10. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T.0 120(c)]
Permit issued this the 25' day of March 2019
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
coda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Man Jent Commission
Permit Number WQ0001122
WQ0001122 Version 4.0 Shell Version 180901 Page 6 of 6

ATTACHMENT C — GROUNDWATER MONITORING AND LIMITATIONS
Monitoring Wells: MW -1, MW -2, and MW -3
Permit Number: WQ0001122 Version: 4.0
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
1
70300
Solids, Total Dissolved - 180 °C
500
mg/L
3 x Year
Grab
1
82546
Water Level, Distance from measuring point
feet
3 x Year
Calculated
1, 2, 3
1. 3 x Year monitoring shall be conducted in March, July, and November; Annual monitoring shall be conducted in 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. 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 shall 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.
5. Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 1 and this attachment.
WQ0001122 Version 4.0 Attachment C Page 1 of 1

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