NCG050149_COMPLETE FILE - HISTORICAL_20130702

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V Cco 0,5-01 y
DOC TYPE
\' HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
n c� o 13 D02
YYYYMMDD

ATMA
FILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Acting Director Secretary
July 2, 2013
Will Anderson, Plant Manager
12700 General Dr.
Charlotte, NC 28273
Subject: Compliance Evaluation Inspection
Otto Industries
12700 General Dr., Charlotte, NC
NPDES Stormwater Permit NCGO50000
Certificate of Coverage — NCG050149
Mecklenburg County
Dear Mr. Anderson:
On May 23, 2013, David Buetow and Erin Hall from Charlotte -Mecklenburg Stormwater Services (CMSWS),
conducted a site inspection of the Otto Industries facility located at 12700 General Drive in Charlotte,
Mecklenburg County, North Carolina. The site drains to Steele Creek, Class C waters located in the Catawba
River Basin The site visit and file review revealed that the subject facility is covered by NPDES General
Stormwater Permit — NCG050000.
This inspection was conducted as part of a cooperative working agreement between Mecklenburg County and
the Division of Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part li Section H. The following observations were
noted during the Charlotte -Mecklenburg Stormwater Services inspection (please see the attached addendum
for information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP1
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ® No 0
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes Z - No ❑
3) AnallVticall Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ❑ Not Applicable
4) Permit and Outfalls
Outfall 001 was not accessible during the inspection. Please provide access to this Outfall as required by the
general permit.
5) City of Charlotte Stormwater Ordinance Review:
The permittee was in compliance with the City of Charlotte Stormwater Ordinance at the time of inspection.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 361 Mooresville, NC 28115
Phone (744) 663;16991 Fax: J 4) 663-6W � Customer Service: 1-877$2M748
Internet http://portal.ncdonr.orgtwebtwq
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1 Y
Will Ande'rson, Otto Industries
Cornpliarice Evaluation Inspection, Page 2
July 2, 2013
Thank you for the assistance and cooperation during the inspection. Overall, the facility's Stormwater program
was well developed and implemented and this Office commends the permittee's efforts to ensure compliance
with your NPDES permit.
If you have any questions, comments, or need assistance understanding any aspect of your permit, please do
not hesitate to contact David Buetow with CMSWS at [phone] or Ms. Marcia Albcco of the Division of
Water Quality at [phone].
Sincerely,
for Michael L. Parker
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
cc: Rusty Rozzelle, MCWQP
Craig Miller, City of Charlotte
Water Quality Central Files
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone]d01 Customer Service: 1-877-623,6748
Internet httpJlportal.ncdenr.orgltiveblvvq
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Will Anderson, Otto Industries
Compliance Evaluation Inspection, Page 3
July 2, 2013
ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicable to both the general permits and
individual stormwater permits is the requirement to develop and implement site -specific comprehensive
Stormwater Pollution Prevention plans (SPPP)- These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following webpage:
http://portal.ncdenr.orgtwebfwgfws/su/npdessw#General_Permits _NPDES. Permit text, technical bulletins,
discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES
General Stormwater Permit] can be found on this website.
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. Please see the
above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein.
Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of
the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. if this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permiee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked.
• Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable
non-stormwater discharge or is covered by another permit, authorization, or approval.
• There are currently 19 active general permits- Permit conditions vary accordingly; however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
lvlooresvLe Regional C5m
Location: 610 East Center Ave., suite 301 Mooresville, NC 28115
Phone: JD4) 663-1699 ti Fax: (704) 6B-F0 4 Customer Service: 1-877-623-6748
Internet httpJ/p0ftal.n0denr.orgtweb1wq
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Will Anderson, Otto Industries
Compliance Evaluation Inspection, Page 4
July 2, 2013
o Collection, reporting, and recording of Qualitative Monitoring
o Collection, reporting, and recording of Vehicle Maintenance Monitoring (if applicable)
o Records — Visual monitoring shall be documented and records maintained at the facility along
with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall
also be maintained on site. The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and all original strip -chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this general permit
for a period of at least 5 years from the date of the sample measurement, report, or application.
o Expiration — The permittee is not authorized to discharge after the expiration date of the general
permit. In order to receive automatic authorization to discharge beyond the expiration date, the
permittee shall submit forms and fees as are required by the agency authorized to issue permits
no later than 180-days prior to the expiration date. Any permittee that has not requested
renewal at least 180 days prior to expiration, or any permittee that does not have a permit after
the expiration and has not requested renewal at least 180 days prior to expiration, will be
subject to enforcement. Failure to renew your permit is a violation.
o Transfer —The Certificate of Coverage (CDC) issued pursuant to this general permit is not
transferable to any person expect after notice to and approval by the Director. The Director may
require modification or revocation and reissuance of the Certificate of Coverage to change the
name and incorporate such other requirements as may be necessary under the Clean Water
Act. The Permit is NOT transferable.
o Name Change, Closure, or Facility Ownership change — Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of Water
Quality views changes of name or ownership as a modification that requires the Director's
approval and reissuance of the permit. Name and ownership changes require you to complete a
Name/Ownership Change Form from the Division and mail it back to the Division of Water
Quality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
Moomville Reginat Offim
Lombon: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax[phone]M4 Customer 5ervioe:1-877-62U798
Internet ht01/porta1.nodenr.orglwebfwq
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F
Compliance Inspection Report
Permit: NCGO50149 Effective: OM1108 Expiration: 05131113 Owner: Ottci industries
SOC: Effective: Expiration: Facility: Otto Industries
County: Mecklenburg
12700 General Dr
Region: Mooresville
Charlotte NC 28241
Contact Person: Kerry Young Title: Phone: [phone]
Directions to Facility: -
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection Date: 05/2312013 Entry Time: 09:00 AM Exit Time: 11:50 AM
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparef/Printing/PaperA eather/Rubber Stormwater
Discharge COC
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
■ Storm Water
(See attachment summary)
Page: 1

Permit: NCGO50149 owner - Facility: Otto industries
Inspection Date: 05/23/2013 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
Otto Industries is a manufacturer of plastic waste containers for commercial and residential use, including refuse and
recycling carts, litter receptacles, etc. Containers are made of HDPE from pellets that are melted in molding machines.
Compliance History_
The facility was inspected on April 22, 2008, by Charlotte -Mecklenburg Storm Water Services (CMSWS). The Division of
Water Quality issued a Notice of Violation as a result of the inspection. The facility was compliant during the follow-up
inspection on July 22, 2008.
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Aboveground Storage Tanks (ASTs) —
Two 550-gallon and one 1,000-gallon aboveground storage tanks (ASTs) of hydraulic fluid with secondary containment
and 250-gallon totes and 55-gallon drums are located in the Main building. Lubricants in 55-gallon drums and 60-gallon
totes were also located in the Main building. A 1,000-gallon used oil AST was located under cover outside the Main
building_
Vehicle Equipment area(s) —
No vehicle maintenance is conducted on site.
Page: 2

0
I
Permit: NGG050149 Owner - Facility: Otto Industries
Inspection Date: 05t2312013 •- -Inspection Type. Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
❑ ❑
❑
# Does the Plan include a General Location (USGS) map?
■
❑ ❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑ ❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑ ❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑ ❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑ ❑
❑
# Does the facility provide all necessary secondary containment?
■
n n
❑
# Does the Plan include a BMP summary?
■
❑ ❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑ ❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑ ❑
❑
# Does the facility provide and document Employee Training?
■
❑ n
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑ ❑
❑
# Is the Plan reviewed and updated annually?
■
❑ 0
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑ ❑
D
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑ ❑
❑
Comment: The Stormwater Pollution Prevention Plan (SPPP) was prepared for Otto
Industries by MACTEC, now AMEC. Housekeeping was excellent throughout the
facility. Copies of employee training records from 2008 to 2013 are included in the
SPPP and the plan is reviewed and revised annually. Semi-annual stormwater facility
inspections were conducted on 12/15/10, 3/15/11, 11115111, 2/9112, 11/23/12 and
2/20/13.
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehide Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
Yes No NA NE
■❑i!❑
Yes No NA NE
❑ ❑ ■ ❑
rl❑■❑
Yes No NA NE
■❑D0
❑ ■ ❑ ❑
Page-3

Permit: NCG050149 Owner - Facility: Otto Industries
Inspection Date: 05/23/2043 Inspection Type: Compliance Evaluation Reason. for visit: Routine
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment, Outfall 1 is designated as the discharge from the silt basin located on the
north end of the property. Outfalls 2 and 3 are storm drains located at the front of the
facility adjacent to General Dr. Outfall 1 could not be accessed due to vegetation.
Please be advised that the general permit (Standard Conditions Part III, Section C,
paragraph 1) requires the proper operation and maintenance of all systems installed to
maintain compliance with the permit. Please provide access to Outfaill 001.
■ 0 0 0
Page: 4

A- jLA
NGDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
February 27, 2009
Phil Bader, Safety & Environmental Fleet Manager
Otto Industries
12700 General Drive
Charlotte, North Carolina 28273
Subject: Follow-up Compliance Evaluation Inspection
Otto Industries
12700 General Drive, Charlotte, NC 28273
Stormwater Permit COC# NCG050149
Mecklenburg County, NC
Dear Mr. Bader:
Enclosed is a copy of the Follow-up Compliance Evaluation Inspection (CEI) report for
the inspection conducted at the subject facility on July 22, 2008, by Ms. Erin Hall of Charlotte -
Mecklenburg Storm Water Services (CMSWS). Compliance documentation was submitted to
CMSWS on February 24, 2009 from MACTEC Engineering and Consulting, Inc. (MACTEC) on
behalf of the subject facility. This inspection was conducted as part of a cooperative working
agreement between Mecklenburg County and the Division of Water Quality. In addition, the
inspection was conducted on behalf of the City of Charlotte in compliance with the City's
NPDES Permit, NCS000240, Part H Section H. Thank you for your assistance and cooperation
during the follow-up inspection.
The follow-up inspection found that Otto Industries has implemented the corrective
actions as stated in a response letter from MACTEC dated January 30, 2009, to CMSWS. This
letter was submitted on behalf of the subject perrnittee. The corrected actions include:
Updating the Stormwater Pollution Prevention Plan (SPPP) USGS location map to
include accurate latitude and longitude coordinates for the points of discharge,
Updating the SPPP to include a narrative description of potential pollutants expected.
in the stormwater discharge, a list of significant spills for the past three years, and a
feasibility study,
• Documentation that the permittee has completed the required employee training,
Mooresville Regional Office
Location: 610 East Center Ave,, Suite 301 Mooresville, NC 26115 One
Phone: [phone] Fax; (704) 663-60401 Customer Service: 1-877-623-6743 NorthCarolina
Internet: wwncvvaterquality.org
M Equal Opperuziiy 1 At rnnafive Action E moDyer - 50% Recyc:eCl10% Post C,�:sumer pacer

Mr. P. Bader, Otto Industries
Follow-up CEI, Page 2
February 27, 2009
• Documentation that the permittee has certified the evaluation of the stormwater
outfalls for the presence of non-stormwater discharges,
• Documentation that the Stormwater Pollution Prevention Plan has been updated;
Documentation that the Stormwater Facility Inspection Program has been
implemented, and
• Documentation that the semi-annual qualitative monitoring program has been
implemented -
The enclosed follow-up inspection report should be self-explanatory; however should you
have any questions concerning this report or have any questions regarding your permit, please do
not hesitate to contact Ms_ Allocco of this Office at [phone].
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
CC' NPS-ACO Unit
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
Kerry Reed, P.E.
MACTEC Engineering and Consulting, Inc.
2801 Yorkmont Rd., Suite 100
Charlotte, NC 28208

r-
Compliance Inspection Report
Permit: NCGO50149 Effective: 06/01/08 Expiration: 05/31113 Owner: Otto Industries
SOC: Effective: Expiration: Facility: Otto Industries
County: Mecklenburg
12700 General Dr
Region: Mooresville
Charlotte NC 28241
Contact Person: Kerry Young Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: Phone:
Inspection pate: 0712212008 Entry Time: 09:00 AM Exit Time: 09:45 AM
Primary Inspector: Water Quality Program Mecklenburg County Phone:
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Pr ntinglPaper/E_eather/Rubber Storrnwater
Discharge COC
Facility Status: ■ Compliant 0 Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page:1

Permit: NCGO50149 (honer — Facility: Otto Industries
Inspection Date: 07/22/08 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Facility Description:
Otto Industries manufactures plastic pallets and plastic waste containers such as residential carts, commercial
containers, and recycle bins. The Charlotte Plant is divided into two operating sections for the manufacture of new
waste containers and the maintenance and replacement of used waste products. New waste containers are produced
from high -density polyethylene (HDPE) through plastic injection molding. HDPE pellets are shipped to the facility via
railway cars where they are melted, mixed with colors, and molded into various plastic products. These molded
products are then assembled into finished products.
No vehicle washing or hazardous materials storage occurs on site. Southeast Industrial Equipment conducts on -site
maintenance to facility forklifts on an as needed basis and facility trucks are maintained off site.
Compliance History:
According to Charlotte -Mecklenburg Storm Water Services (CMSWS) files, a Notice of Violation was issued to Otto
Container Management on ,January 18, 2008, for a discharge of commercial wastewater to the storm drain system.
Ms_ Erin Hall and Ms. Heather Sorensen of the MCWQP inspected Otto industries on April 22, 2008 and a Notice of
Violation was issued regarding the stormwater inspection on May 21, 2008. CMSWS also conducted stormwater
sampling on July 22, 2008, and those results were transmitted to Otto Industries on September 17, 2008.
Industrial Ooerations/City of Charlotte Stormwater Ordinance Review:
Staging Area —
The Staging Area is located adjacent to the Manufacturing Building on the north side_ This area is located outside and
is used as a temporary storage area for recently molded and assembled carts before being transported to the
inventory yard. During the initial inspection this area was heavily stained and slick and a significant amount of water
was observed coming from this area. Upon investigation it was found that pallet washing (non-stormwater flow with
greasellubricant) had been performed along with the discharge of mop water (wastewater discharge) from the Staging
Area door where it flowed outside through the Staging Area. The facility is posted advising against this practice in this
area.
The follow-up inspection on July 22, 2008, confirmed that the facility has relocated the mop station away from this
area_ The new mop station area is equipped with a sink over a drain where used mop water is discharged to the
odAvater separator then to the sanitary sewer system. All mops, mop buckets, and squeegees are located in this area.
The paved area at the Staging Area had noticeably less staining. Facility personnel indicated that they have worked on
getting this area cleaned.
Compressor Room (previously written as Chiller Room) —
This room is connected to the Manufacturing Building. The Compressor Room is accessed from the outside adjacent
to the Staging Area. An air compressor is located in this room. Oil spots were observed on the concrete ramp
immediately outside the door. The air compressor blowoff is being discharged immediately inside the door on the floor.
It appeared that oil from the blowoff was being tracked outside exposing it to stormwater runoff.
The follow-up inspection on July 22, 2008, confirmed that air compressor condensate is discharged to the oibWater
separator via a closed circuit system.
Page: 2

r
Permit: NCG050149 Owner - Facility- Otto Industries
Inspection Date: 07/22/08 Inspection Type: Compliance Evaluation Reason for Visit: Fallow -up
Industrial ODerationslCity of Charlotte Stormwater Ordinance Review:
General Assembly -
The General Assembly area is located inside the OCM Building at the shipping dock. Stock bases of new waste
containers are brought into this area where lid attachment and hot stamping takes place. At the time of inspection dark
brown water was observed in the General Assembly area. Per facility personnel, the water is rainwater that
accumulates in the stock bases. Rainwater is dumped out as stock bases.are brought in. Dirt as well as oil from
machines in this area appeared to be mixing in with the discharged rainwater. This water is pushed outside via the
dock doors using a squeegee. Otto employees were observed using the squeegee during the inspection. The area
outside immediately beyond the dock door openings had moderate staining_ Inspectors asked facility personnel to
immediately cease the operation of using the squeegee to push the brown water outside.
The follow-up inspection on July 22, 2008, confirmed that the facility has taken actions to prohibit the practice of using
the squeegee to push water outside the dock doors_ The facility has posted signs at the dock doors stating to not push
water outside. If also states that water must be mopped up and discarded in the sink located in the mop station area.
Accumulated rainwater in new, large containers is discarded outside before containers are brought in.
Page: 3

Permit: NCG050149 Owner - Facility: Otte Industries
Inspection Date. 07122/2008 Inspection Type- Compliance 'Evaluation
Reason for Visit. Follow-up
Stormwater Pollution Prevention Plan
Yes
No
NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
n n
# Does the Plan include a General Location (l1SGS) map?
■
n
Cl n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n U
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
n n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
# Does the facility provide all necessary secondary containment?
■
n
n n
# Does the Plan include a BMP summary?
■
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
In n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n n
# Does the Facility provide and document Employee Training?
■
n
n n
# Does the Plan include a list of Responsible Party(s)?
■
n
n n
# Is the Plan reviewed and updated annually?
■
n
n n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n n
Comment: The initial inspection found that the permittee's Stormwater Pollution
Prevention Plan (SPPP) was February 1996; no documentation could be provided
which showed annual reviewslupdates to the plan. The SPPP contained a general
location (USGS) map, but it did not include the name of the municipal storm sewer
system that receives discharges from Outfall 002. The permittee had not evaluated
feasible alternatives to its current practices and documented this review in the SPPP.
The SPPP did not include a list of spills that have occurred at the facility in the past
three years. Per facility personnel, some employee training had taken place in 2008 but
the permittee could not provide records of previous training.
Documentation for employee training for 2008 was presented to CMSWS during a
follow-up inspection on July 22, 2008. Compliance documentation submitted to
CMSWS on February 24, 2009, confirmed all the above deficiencies have been
corrected.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually'? ■ n 0 n
Page: 4

V
Permit: NCGO50149 Owner - Facility: Otto Industries
Inspection Date: 07/22/'2008 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Comment: The initial inspection found that the permittee had not conducted the
required semi-annual qualitative monitoring_
Compliance documentation submitted to CMSWS on September 22, 2008, from the
permittee confirmed that qualitative monitoring has been conducted semi-annually for
2008 for Outfalls 001, 002, and 003.
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment: The permittee uses < 55 gallons of new motor oil on average per month at
the facility.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# if the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: During the initial inspection the permittee did not have a copy of its general
permit or Certificate of Coverage on site. In addition, facility personnel were not able to
locate Outfall 001 and there was a question whether additional stormwater outfalls
(more than two identified by the permittee) were located at the facility. The permittee
was asked to review stormwater flow on site to ensure all stormwater outfalls associated
with industrial activities have been identified, included in the SPPP, and monitored.
The follow-up inspection conducted on July 22, 2008, revealed that the subject facility
had a copy of its Certificate of Coverage and permit readily available onsite. The
updated SPPP identified Outfall 003 after review of the stormwater flow on site.
Yac Nn NA NF
nn■C)
nn■n
Yes No NA NE
Page- 5

t � f�ncnae� r. tastey, uovernor
O� RpG
William G. Ross Jr., Secret
North Carolina Department of Environment and Natural Resources
C� 'C Coieen H. Sullins, Director
Division of Water Quality
September 17, 2008
Mr. Phil Bader, Safety and Environmental Fleet Manager
Otto Industries
I2700 General Drive
Charlotte, North Carolina 28273
Subject: Stormwater Monitoring Results
Otto Industries - Stormwater Permit COC NCG050149
Mecklenburg County, NC
Dear Mr. Bader:
Enclosed are the monitoring results from the laboratory analyses performed on stormwater
discharge from the subject facility. Stormwater was sampled from a concrete stormwater pipe located at
the rear of the facility adjacent to the railroad tracks. This stormwater pipe has not been identified by the
subject facility as a Stormwater Discharge Outfall. The samples analyzed were grab samples collected
during the sampling investigation performed on July 22, 2008, by Mr. Ron Eubanks and Mr. Christopher
Elmore of Charlotte -Mecklenburg Storm Water Services. This sampling investigation was conducted as
part of a cooperative working agreement between Mecklenburg County and the Division of Water Quality.
In addition, the sampling investigation was conducted on behalf of the City of Charlotte in compliance
with the City's NPDES Permit, NCS000240, Part II Section H.
The enclosed monitoring results indicate that the stormwater discharged on July 22, 2008,
contained a slightly elevated concentration of zinc. The subject facility's permit does not require analytical
monitoring. However, please review any possible sources of zinc in the facility's processes and take
steps/actions to reduce the concentration of zinc leaving your site as appropriate. Through the
development and implementation of stormwater management programs it is the Division of Water
Quality's expectation that stormwater discharges at industrial sites covered by NPDES stormwater permits
do not impact receiving waters.
The enclosed results should be self-explanatory; however should you have any questions
concerning the sampling results or have any questions regarding your permit, please do not hesitate to
contact Ms. Marcia Allocco of this Office at [phone].
Sincerely,
1
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: NPS-ACO Unit
44
Rusty Rozzelle, Mecklenburg County
w Craig Miller, City of Charlotte N�oStltCaro�;na
NCDENR
Mooresville Regional Office Division of Water Quality Phone 704.663-t699 Customer Service
Internet: wwwncw&erquaiitv,org, 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal OpportunrtylAffsmative Adon Employer- 50% Recyded110% Post Consumer Paper

ANALYTICAL RESULTS SHEET
Name of Facility: Otto Industries
Grab: E Composite: ❑
Sample Date(s): July 22, 2008
NPDES Permit No.: NCG050149
Sample Location: Stormwater pipe adjacent to RR tracks
County. Mecklenburg
Temperature
22.10 OC
Fecal coliform (CFU/100 mL)
**/l00 mL
Dissolved Oxygen
7.59 mg/L
E. Coli (MPN/100 mQ
**1100 mL
Conductivity
31 µS/cm
Ammonia -nitrogen (NH3-N)
0.12 mg/L
pH
6.96 SU
Total Kjeldahl Nitrogen (TKN)
1.6 mg/L
Turbidity
3.2 NTU
Nitrate/Nitrite-nitrogen (NO2 and NO3)
0.82 mg/L
Biological Oxygen Demand, 5-day (13005)
4.4 mg/L
Total Phosphorus (P)
0.17 mg/L
Chemical Oxygen Demand (COD)
28 mg1L
Chromium (Cr)
< 5.0 µglL
Total Suspended Solids (TSS)
< 2.0 mg/L
Copper (Cu)
5.8 µg&
Total Sediment Concentration
42 mg/L
Lead (Pb)
< 5.0 µ91L
Oil & Grease
12 mg/L
Zinc (Zn)
290 µg/L
' denotes a violation of the permit benchmark values.
did not collect due to hold time.

Laboratory Analysis Report
Report Date: 8/12/2008 10:04 AM
LABORATORY SERVICES DIVISION
LOCATION: Otto Industries
LOC ID: W-IND
SAMPLE DATE -TIME: 7/22/2008 22:10 CHAIN OF CUSTODY #: 080723125859
SAMPLE DESCRIPTION: Grab
Parameter
Result
Units
RL
Method
Start Date/
Time Analyst
AC76707 BIOCHEMICAL OXYGEN DEMAND
4.4
mg/L
2.0
SM 5210B
7/23/2008
18:10
NVR
AC76707 CHEMICAL OXYGEN DEMAND
28
Mg/L
10
HACH 8000
7/29/2008
13.37
NVR
AC76707 AMMONIA -NITROGEN
0.12
mg/L
0.10
SM 4500-NH3 H
7129/2008
13:15
AUT
AC76107 NITRATEINITRITE
0.82
mg/L
0,05
EPA 353.2
7123/2008
15:23
MKV
AC76707 TOTAL KJELDAHL NITROGEN
1.6
mglL
0.25
EPA 351.2
713111008
9:25
AMT
AC76707 TOTAL KJELDAHL NITROGEN DIGESTION
Completed
EPA 351.2
7/30/2008
10:20
AMT
AC76707 TOTAL PHOSPHORUS
0.17
mg1L
0,010
SM 4500-P F
7/28/2008
16:10
MLL
AC76707 TOTAL PHOSPHORUS DIGESTION
Completed
SM 4500-P F
7/28/2008
1 D:45
MLL
AC76707 CHROMIUM BY ICPMS
-c S.0
ug/L
5.0
EPA 200.8
712412008
15:45
KGB
AC76707 COPPER BY ICPMS
5-8
uglL
2.0
EPA 200.8
7124/2008
15:45
KGB
AC76707 LEAD BY ICPMS
<5.0
ug/L
5.0
EPA 200.8
724f2008
15:45
KGB
AC76707 ZINC BY ICPMS
290
ug/L
30
EPA 200.8
728/2008
14:30
KGB
AC76707 SUSPENDED SEDIMENT CONCENTRATION
42
mglL
3.6
ASTM D3977.97
8/4/2008
15:20
TCV
AC76707 TOTAL SUSPENDED SOLIDS
<2.0
mg/L
2.0
SM 2540D
712412D08
10:53
TYM
AC76707 HEXANE EXTRACTABLE MATERIAL (OSG)
12
mg/L
5.0
EPA 1664A
7/23/2008
13.56
WMC
A076707 TURBIDITY
3.2
NTU
0.50
SM 2130B
712312008
15:11
TYM
METALS DIGESTION EPA 200.0 7/24/2008 8:37 5TP
Comment:
Laboratory P Su ervism L-�r
Laboratory Certifications: CM -Environmental Laborat Services N.C.DHHS LaWratory No. 37417; N.G. DENR No. 192
Brookshire: N-C. DENR No. N.C. DHi IS LaboratoryNo. 37605
Page i of 1

Otto Industries, Inc.
12700 General Drive Charlotte Nortk Carolina
November 6, 2008
Mr. Robert Krebs
Division of Water Quality
Regional Supervisor
Surface Water Protection Section
Mooresville Region Office
Subject: Stormwater Monitoring Results
Dear Mr. Krebs:
RECFIVI:D
NOV - 7 '2008
.. F• s :y� h`�: f
DWG- rft_, vVater jc w ark
I received your correspondence and test results that resulted from the July 2008 -grab
samples" that were completed on our property. The test results showed slightly elevated
levels of zinc. As a result you asked us to determine the cause and take corrective action
to eliminate the potential increase.
After receiving your letter I reviewed materials information searching for the material(s)
that may increase our zinc levels. We determined that our "lift bars" and cart "axels" are
coated in zinc. We were storing these outside and the manufacturer of these does not
always wrap or package these. We relocated these away from the water flow and are now
ensuring that they ate wrapped or covered so that any participation does not filter through
these collecting zinc and then discharging into our storm water. To summarize our
corrective action:
We determined the source of the zinc. We then corrected the storage of the
materials to keep them away from the "Sheet Flow" of the water in our storage
area, and we are now securing them with "tarps or like protection to keep any type
of participation away from the materials to minimize or eliminate any release of
zinc from the materials.
Otto Industries, Inc. and I would like to thank you for your assistance and your staff s
assistance this year in the renewal of our permits and the reorganization of our
Environmental Department at Otto.

Otto Industries, Inc.
12700 General Drive Charlotte North Carolina
Effective September 1, 2008 I was given the management responsibilities of our
Environmental Department and I have ensured we have complied with all Local, State
and Federal directives to date. Every employee at Otto from our CEO to our employees
washing our carts understands and demands 100% compliance in all of our environmental
areas. We recently purchased a "cart washer" that has the best environmental ratings for
overall performance, and has a final discharge product that is clean enough to drink. This
equipment was very expensive to purchase and to maintain but it also makes us a leader
in our industry. Again thank you for your assistance and please contact me if the outlined
plan to correct our zinc levels needs modified in any way. I can be reached at (704) 910-
9603 or [phone], ext. 273.
Sincerely
Phil Bader
Fleet Safety and Environmental
Manager, OCM, LLC. And
Otto Industries, Inc.

nyC6 9S9 ��(
Otto Environmental Systems North America,
Inc. and Otto Container Management, LLC.
RECEIVED
June 20, 2008
jUN 2 3 2008
NC DENR MRO
DWO-Surface Dater Protection
To: Ms. Marsha Allocco VIA �7-A x,
From: Phil Bader
Re. NOV Response Otto Environmental Systems North America
Dear Ms. Allocco:
Please find our attached response to the NOV we received. 1 will send a hard copy in the
US Mail as well. Please feel free to contact me at [phone] for any clarification.
Thank you, Have a good Day.

June 19, 2008
Ms. Marcia Allocco
Division of Water Quality
Surface Water Protection Section
Mooresville Regional Office
610 E Center Ave.
Mooresville, NC 28115
OTTO Environmental Systems North America, LLC
1W12700 General Drive
Charlotte, North Carolina 28273
Telephone [phone]
Facsimile [phone]
mK"ECEIVED
J U N 2 3 2008
RE: Notice of Violation
Tracking Number: NOV-2008-PC-0359
Dear Ms. Allocco:
NC DENR MRO
UM-5duce Vidier Fro#eCtion
l am responding to the attached Notice of Violation that I received in my office on or about
May 21, 2008.
Our plant manager, Cooper Bishop, our maintenance supervisor Kerry Young, and Tara Harvey
and myself from the safety and environmental unit met with Ms. Erin Hall and Ms. Heather
Sorensen from Charlotte -Mecklenburg Storm Water Services. I will address each compliance
issue separately and in the same order as addressed in the Notice of Violation mentioned
above.
I began working at Otto Environmental Systems North America„ Inc. in January of 2008 and
met Ms. Sorensen on my first day. Ms. Sorensen had pin -pointed the discharge of water from
our property that she believed was responsible for increasing the fecal matter counts in an
adjacent "beaver pond" and stream. I have attached for your reference the letter dated
January 18, 2008 from Ms. Sorensen, as well as my reply dated January 30, 2008.
As I stated in the January response, Otto Environmental Systems North America, Inc. and Otto
Container Management, LLC are good corporate citizens that are actively looking for ways to
improve our operations and improve our environmental stance in the communities in which
we live and work in. I was recruited by the company to assist in environmental compliance at
all of our sites nationwide.
When Ms. Sorensen identified the discharge of water from our property, we immediately
stopped the practice, corrected it, and developed our short term plan to continue our
operations that met Ms. Sorensen's approval. Our next step was the commitment to invest
over $150,000 in a specialized wash system to continue to show our support as a good
environmental citizen and to remain a leader in our industry. This specialized equipment will
wash multiple units at the same time and leave a small amount of sterilized discharge. This
will be the final corrective measure to the initial practice that created this problem.
In keeping with our role as a good environmental citizen the majority of the issues noted in
the report were corrected prior to receiving the May 21, 2008 letter from Mr. Krebs. During

OTTO Environmental Systems North America, LLC
12700 General Drive
Charlotte, North Carolina 28273
Telephone [phone]
Facsimile [phone]
the process that generated this report, we did
identify an environmental compliance plan that had
been established in the past for the site. We shared this plan with Ms. Hall. We have
determined that the site has had a plan to set operational practices, train employees and
track and report any spills that may occur. We have also identified that turn over of several
key positions has left a void at times in communication of what has been done to ensure
compliance, not in the compliance itself.
our current ptan is a tiered structure that ensures compliance in reporting and training as
well as monthly monitoring by the environmental safety unit, as well as the environmental
safety team. We have taken all recommendations from Ms. Hall and
Ms. Sorensen and placed them into practice at the level suggested, or in some cases, a more
stringent practice has been put in place.
To address the points raised in the Notice of Violation mentioned above:
I have followed up with the State of North Carolina and learned that our NPDES permit
is currently being renewed and forwarded to Mr. Kerry Young's attention.
• We do have a Spill Prevention Plan for our individual operations that
incorporates the entire operation.
We are currently training several supervisors and managers as "trainers" in a
"train the trainer" training course. After completing the scheduled training for
the trainers we will then continue to train all employees identified as critical in
our SPCC plan. The Notice of Violation stated that "no employee training was
being completed". I personally trained 13 employees in Charlotte in February
and March of 2008 prior to this action. I would be happy to provide these
training records upon request. We stilt have many more employees to train,
however, the training is ongoing as noted.
All of the identified issues from January 18, 2008 were stopped that day and
corrected. The operation that created the problem was in place due to a
letter being issued from CMUD that was apparently not understood completely
on our end. As I understand, the letter gave permission to discharge into the
sanitary sewer, which unfortunately, we mistook this for the storm sewer. I
have seen in the past that for the untrained a sewer is a sewer.
• We have several dumpsters close to our current washing area for trash removal.
Employees clean up as needed and after each shift. This is our practice as
recommended.
We have a set poticy to keep used, unwashed containers covered in the yard so
that no rain water will collect. If this does happen, employees have been
trained to bring the container inside the building and to dump it in the proper
collection area that leads to the sanitary sewer. All of our plant employees
have been trained and have signed off to not dump this water in the yard
where it will make it into the water table.

OTTO Environmental Systems North America, LLC
1W12700 General Drive
Charlotte, North Carolina 28273
Telephone [phone]
Facsimile [phone]
The fire pump room was noted with no
violation or recommendation. On the moming of the April 22, 2008 inspection,
we had required monthly testing completed on the fire maintenance tine. This
is done in accordance with the laws of North Carotina and discharge of potable
water does take place during this maintenance and testing.
• Staging Area: The report is accurate and we will review two known incidents:
(1) The discharge with 95% + of the flow was the result of washing plastic
pallets in this area. The pallets were molded earlier in the spring prior
to pollen season. We received complaints from our customers about
shipments being delivered with pollen on them, and as a result, rinsed
the pallets off utilizing potable water from our system. No chemicals
were or are used for this process and the only result is potable water
with totally organic materials being discharged. This is a low volume
operation that creates no residual waste; we monitor and ensure
compliance in water usage for this operation.
(2) The second and smatter discharge was an employee breaking company
policy on dumping mop water in this area. This practice was and is
against policy and the employee has been reprimanded. The mop
station has been relocated away from this area to an area with a drain
that goes to the oil/water separator and then to the sanitary sewer for
the discharge. The cleaning chemical we use is called Orange-X and is
a natural water -based citrus cleaner made by Wepack here in
Charlotte.
Chiller Room (Compressor Room):
The report is not accurate. There are visible stains on the concrete ramp
outside of the chiller room that are the result of repair work completed in
years past. All compressor blow -off is designed to discharge back into the
chiller room and then to a floor drain and the oil/water separator. The blow -
off circuit was equipped with (2) Yd" ball valves that did make it possible for
the discharge to be blown off on the floor. During the audit the valves were
closed to route the discharge to the proper area and we have now removed
the handles to eliminate the casual operation. The valves have also been
plugged to further impede any discharges of blow -off.
General Assembly:
The report is accurate. Stock bases brought in from the outside may contain
trace amounts of rainwater. Water may be discharged on the floor and may
mix with any residue on the floor. During the audit this occurred and a
squeegee was used to push the water outside. There was not oil or chemicals
in the water, but it did contain dirt. We have now removed the squeegees and
placed mop and bucket in the area. All water is now mopped and signs were
posted to advise all employees of the proper methods. Employees have also
been properly trained. Supervisors and Managers will monitor on a daily
basis.

OTTO Environmental Systems North America, LLC
12700 General Drive
Charlotte, North Carolina 28273
Telephone [phone]
Facsimile [phone]
• Diesel Fuel Storage Tanks and Diesel
Fueling Area:
The report is not accurate. This appears to be a comment from a past audit.
We do not store diesel and we do not have tanks matching the sizes of these
tanks to store anything.
SPPP Plan: The report states that we have an SPPP plan, however, it also
states that we do not train employees and that the plan is not monitored and
updated annually. The report also states that we do not have a formal
inspection of the facility for storm -water. As previously stated, training
started in February of 2008 and is ongoing. Records were not available when
Ms. Hall and Ms. Sorensen were at our facility, however, we will provide them
upon request. We continue to train as stated. We have added the storm -
water monitoring to our monthly facility inspection for review by the
environmental inspection team.
We have been reviewing all aspects of our operations for environmental compliance and
good housekeeping practices that are required in the OSHA general duty clause. We have
taken all suggestions and put them into practice at the level required or at a more stringent
level. We have opened our doors and welcomed you to assist us in changing the issues
identified. We have made corrections that were needed, and will continue to train and gain
environmental strength. Other than the January 2008 issue we have operated without any
environmental issues or NOV's or any regulatory fines that I am aware of for over ten years.
Please do not hesitate to Contact me if you require any additional information or any
clarification. My direct number is 704-910-9603.
Sincerely,
Phil Bader
Environmental and Fleet Manager
Otto Environmental Systems North America, Inc.
& Otto Container Management, LLC
Cc: Steve Stradtman, CEO
Paul Blair, Operations Director
David Springs, VP of OCM

Njgr� Michael F. Easley, Govemor
`OHO RQG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
CO r7.. Alan W. Klimek, R.E. Director
Division of Water Quality
O
i NOWT. OFF
April 28, 2003 REGOW OFFICE
Bahrija Hati Wcriw-n
Otto Industries
12900 General Dr APR 3 Q m3
Charlotte, NC 28241 f'
Subject: NPDES Stormwater Permit Renewal
Otto Industries ^+,
CDC Number NCGO50149 "VA R OVALITv
Mecklenburg County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG050000, the
Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This
permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection
Agency, dated December 6, 1983.
The following information is included with your permit package:
A new Certificate of Coverage
• A copy of General Stormwater Permit NCGO50000
• A copy of the Analytical Monitoring Form (DMR)
• A copy of the Qualitativel Monitoring Form
A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
may require modification or revocation and reissuance of the Certificate of Coverage. This permit does
not affect the legal requirements to obtain other permits which may be required by the Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office
Stormwater and General Permits Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Mooresville Regional Office
I WA
NCDrNR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 6237748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG050000
- CERTIFICATE OF COVERAGE No. NCG050149
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Otto Industries
is hereby authorized to discharge stormwater from a facility located at
Otto Industries
12900 General Dr
Charlotte
Mecklenburg County
to receiving waters designated as a UT to Steele Creek, a class C stream, in the Catawba River
Basin in accordance with the effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG050000 as attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

0— to
OMACTEC
engineering and constructing a better tomorrow
January 30, 2009
Ms. Erin Hall
Mecklenburg County Water Quality Program
Division of Water Quality
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Re: Response to Notice of Violation NOV-2008-PC-0359
Otto Container Management, LLC
12700 General Drive
Charlotte, North Carolina
MACTEC Project: 6228-08-4777
Dear Ms. Hall:
MACTEC Engineering and Consulting, Inc. (MACTEC) is currently providing consulting services to
Otto Container Management, LLC (Otto) for compliance with NPDES General Permit NCGO50000 at the
above -referenced site. Otto received a Notice of Violation from the North Carolina Department of
Environment and Natural Resources (NCDENR) dated May 21, 2008 for violations of their NPDES
permit as detailed in the Stortmwater Pollution. Prevention Plan (SWPPP), Qualitative Monitoring, and
Permit and Outfalls.
MACTEC has revised Otto's SWPPP and has enclosed a draft with this letter. In order to ensure that the
SWPPP meets all requirements, we respectfully request that you review the draft SWPPP and provide
feedback prior to finalizing the SWPPP for implementation and certification by Otto management. A list
of deficiencies you identified in an email dated December 29, 2008, the section of the revised SWPPP
that addresses these deficiencies, and comments on future stormwater management to prevent these
deficiencies in the future are summarized below:
Deficiency: USGS map: the municipal separate storm sewer system needs to be identified for
Outfal] 002 **(Any other outfalls identified at your facility should be on this map as well.
Analytical monitoring conducted by our office was from the concrete stormwater pipe along the
railroad spur. This outfall was not identified on your facility's map)_
Section in Revised SWPPP: Figures 1,2, and 3; See 2.2.7
Comment: MACTEC conducted a site visit on January 22, 2009 and reviewed site surveys.
MACTEC determined that the stormwater pipe located along the railroad spur eventually
discharges to an underground conveyance system which discharges to the silt basin and Outfall
001. MACTEC identified an additional outfall (Outfali 003) where stormwater discharges off the
site.
Deficiency: Narrative description of potential pollutants in stormwater from each outfall.
Section in Revised SWPPP: Table 2
Comment: Potential pollutants were identified for each stormwater outfall and summarized in
Table 2 of the SWPPP.
MACTEC Engineering and Consulting, Inc.
2801 York monl Rood, Suite JOG 9 Charbue, NC 28208 0 Phone: [phone] • Fox:.704.357,8638 wwr+• •corn

Otto Container Management. LLC
Response w Nonce of violation NO='-2008-PC-0359
MACTEC Pmject 6228-08-4777
January 29. 2009
Deficiency: Feasibility study
Section in Revised SWPPP: Table 3
Comment: A Feasibility Study that summarizes facility areas, potential improvements, and
comments on whether there are obstacles to malting these improvements has been included in
Table 3 of the SWPPP. If improvements are implemented in the future, they will be documented
in the SWPPP and the SWPPP will be amended if necessary.
Deficiency: List of significant spills in past 3 years.
Section in Revised SWPPP: Table 7
Comment: A list of significant spills, including the non -permitted discharge identified in an
NOV from the Charlotte -Mecklenburg Storm Water Services dated January 18, 2008, have been
included in Table 7 of the SWPPP.
Deficiency: Documentation that the SWPPP has been reviewed/updated annually.
Section in Revised SWPPP: "Annual Compliance' page v; Sec 9.4; tables
Comment: The SWPPP has been reviewed and revised in January 2009. The revised SWPPP
includes areas at the beginning of the SWPPP and with each table to document annual reviews.
Once the draft SWPPP is finalized, a copy of the signed management certification will be sent to
the Division of Water Quality.
Deficiency: Documentation for the Stormwater Facility inspection Program.
Section in Revised SWPPP: Sec 9.1, Appendix D
Comment: MACTEC conducted a site visit on January 22, 2009 with Mr. Phil Bader, Otto's
Ficett. Safety and Environments] Manager and conducted an inspection of the facility, operations,
and the stormwater system during the site visit. Documentation of facility inspections will be
maintained in Appendix D of the SWPPP.
Deficiency: Documentation that stormwater outfalls have bum evaluated for non-stormwater
discharges.
Section in Revised SWPPP: Sec 9.5; Appendix F
Comment: MACTEC conducted a site visit on January 22, 2009 with Mr. Phil Bader, Otto's
Fleet Safety and Envirorimental Manager and conducted an inspection of the stormwater outfalls
during the site visit. Although MACTEC observed non-stormwater runoff at the facility (e.g.
rainwater captured in new containers was released onto the paved areas when they were being
moved), non-stormwater discharges were not observed at the outfalls. Documentation of non-
stormwater discharges will be maintained in Appendix F of the SWPPP.
Deficiency: Qualitative monitoring: **] received documentation for qual. mon. for 2008. The
April 2008 was not during a representative rain event. Please follow the definition for a rep. rain
event as indicated in your permit.
Section in Revised SWPPP: Sec 9.2; Appendix E
Comment: Otto has retained MACTEC to conduct their qualitative monitoring for 2009_ When
completed, a copy of the qualitative monitoring report for Year 1 -- Period 2 will be sent to the
Division of Water Quality. Documentation of qualitative monitoring will be maintained in
Appendix E of the SWPPP.

Otto Container Management, LLC
Response to Notice of Violation NOV-2008-PC-0354
MAMCProject 6228-08-4777
January 29. 2009
Please do not hesitate to contact the undersigned at 704-357-8600 if you have questions or comments_
Sincerely,
lVMACTEC ENGINEERING AND CONSULTING, INC.
C- -!—
Kerry A. Reed, P.E.
Project Engineer
Cc: Mr. Phil Bader, Otto Container Management, LLC
Ms. Marcia Aliocco, NCDENR, DWQ
]e�se
Tor Principal

si
IYlIL116L11'. 1:�lLY, VVYLIIIVI �nj��
William G. Ross Jr., Secret e..C�
North Carolina Department of Environment and Natural Resourc
Colten H. Sullins, Director
Division of Water Quality
May 21, 2008
CERTIFIED MAIL 7007 1490 0004 4509 5140
RETURN RECEIPT REQUESTED
Mr. Phil Bader, Safety & Environmental FIeet Manager
Otto Industries
12700 General Drive
Charlotte, North Carolina 28273 H
Subject: Notice of Violation
Tracking Number: NOV-2008-PC-0359
Compliance Evaluation Inspection
Otto Industries
Stormwater Permit Number COC NCG050149
Mecklenburg County, NC
Dear Mr. Bader:
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted at the subject facility on April 22, 2008, by Ms. Erin Hall and Ms. Heather
Sorensen of Cbarlotte-Mecklenburg Storm Water Services. This inspection was conducted as
part of a cooperative working agreement between Mecklenburg County and the Division of
Water Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part H Section H. Thank you for your
assistance and cooperation during the inspection.
This report is being issued as a Notice of Violation (NOV) due to the permittee's failure
to comply with requirements stated in the facility's general stormwater permit. This is in
violation of the subject Stormwater Permit and North Carolina General Statute (G.S.) 143-215.1,
as detailed in the Stormwater Pollution Prevention Plan, Qualitative Monitoring, and Permit
and Outfalls sections of the enclosed report. Pursuant to G.S- 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of any permit
issued pursuant to G.S. 143-215.1.
WDENR
lNe Carolina
,o,
� atm.CQ1lb,
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: inax.ncwaterquality.ors 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Mr. Phil Bader, Otto Industries
NOV-2008-PC-0359, Page 2
May 21, 2008
In addition, several housekeeping issues were observed during the inspection and
recommendations regarding these issues are provided in the Industrial Operations/City of
Charlotte Stormwater Ordinance Review section of the report.
It is requested that a written response be submitted to this Office by June 20, 2008,
addressing the above -noted violations in the enclosed report. In responding to the violations,
please address your continents to the attention of Ms. Marcia Allocco at the letterhead address.
The enclosed report should be self-explanatory; however should you have any questions
concerning this report or have any questions regarding your permit, please do not hesitate to
contact Ms. Allocco of this Office at [phone].
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: NPS-ACO Unit
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
1 r

Compliance Inspection Report
Permit: NCGO50149 Effective: 05/01/03 Expiration: 04/30/08 Owner: Otto Industries
SOC: Effective: Expiration: Facility: Otto Industries
County: Mecklenburg
92700 General Dr
Region. Mooresville
Charlotte NC 28241
Contact Person: Kerry Young Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Certification: - Phone:
Inspection Date: 04122/2008 Entry Time: 09:30 AM Exit Time: 12:30 PM
Primary Inspector: Water Quality Program Mecklenburg County Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/LeatherlRubber Stormwater
Discharge COC
Facility Status: C) Compliant ■ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: i

Pennit NCGO50149 Owner - Facility: Otto Industries
Inspection Date: 04/22/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility Description:
Otto Industries manufactures plastic pallets and plastic waste containers such as residential carts, commercial
containers, and recycle bins. The Charlotte Plant is divided into two operating sections for the manufacture of new
waste containers and the maintenance and replacement of used waste products. New waste containers are produced
from high -density polyethylene (HDPE) through plastic injection molding. HDPE pellets are shipped to the facility via
railway cars where they are melted, mixed with colors, and molded into various plastic products. These molded
products are then assembled into finished products.
No vehicle washing or hazardous materials storage occurs on site. Southeast Industrial Equipment conducts on -site
maintenance to facility forklifts on an as needed basis and facility trucks are maintained off site.
Compliance History:
The permitteelfacility does not have any prior compliance issues with the NC Division of Water Quality and the
following information was found in the Charlotte -Mecklenburg Storm Water Services (CMSWS) files.
A Notice of Violation was issued to Otto Container Management on January 18, 2008, for discharging commercial
wastewater to the storm drain system.
Industrial Ooerations/City of Charlotte Stormwater Ordinance Review:
OCM Building -
The OCM Building is located on the north side of the property along General Drive. Old cart washing occurs once or
twice per week inside the OCM Building, A pressure washer is stored outside adjacent to the building with the hose
connected to the inside wash area. The wash area consists of a drain with a concrete berm and cinder blocks. The
drain is connected to the sanitary sewer system. Per facility personnel, a letter was received by Charlotte Mecklenburg
Utilities allowing the discharge of wastewater to the sanitary sewer system. This letter could not be presented at the
time of inspection.
It is recommended the facility properly dispose of trash and debris from the wash area after each washing cycle,
OCM Pad -
The OCM Pad is located adjacent to the OCM Building. This area is primarily used for in-service cart (old and/or
broken) storage, maintenance, and/or repair. Carls are stored outside on a paved surface. Maintenance in the form of
replacing lids, wheels, and axles is conducted in this area. Other maintenance is conducted inside the OCM Building.
New carts are also stored in the OCM Pad area. Parts from these are used to repair old and/or broken carts. New carts
are wrapped in plastic to prevent rainwater accumulation.
It is recommended the facility keep lids in the closed position on carts as well as storing recycle bins upside down on
pallets to prevent rainwater accumulation.
Fire Pump Room -
The Fire Pump Room is connected to the OCM Building. A small pipe was observed coming from the fire pump room.
The fire pump is equipped with wet seals, which allows seepage of water in under normal conditions. The pipe directs
this water outside to keep the room dry. The discharge is potable water and is an allowable discharge under the
NPDES permit. A larger non-stormwater release was observed within this area that did not appear to be the normal,
routine pump water discharge. Per facility personnel, maintenance on the fire pump was conducted earlier that
morning. The maintenance process involved water discharge from the fire pump.
Page: 2

4
Permit: NCG050149 Owner — Facility: Otto Industries
Inspection Date: 04/22/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Staging Area —
The Staging Area is located adjacent to the Manufacturing Building on the north side of the facility. This area is located
outside and is used as a temporary storage area for recently molded and assembled carts before being transported to
the inventory yard_ The area is a paved surface. Occasional rework is conducted in this area such as washing pollen
off pallets and restacking carts to different heights based on customer requirements. This area was heavily stained and
slick. At the time of inspection a significant amount of water was observed coming from this area. Per facility
personnel, pollen had previously been washed off pallets creating the non-stormwater flow. Upon further investigation,
a grease and/or lubricant substance was observed floating on the water's surface, Facility personnel revealed that an
employee had discharged mop water earlier that morning from the Staging Area door where it flowed outside through
the Staging Area_ The facility has a sign posted immediately inside this door stating to please not throw mop water
outside. Per facility personnel, mop water should be disposed of to a drain inside the building that is connected to the
sanitary sewer system via an oil/water separator.
All illegal discharges of wastewater must cease immediately and the permittee must ensure proper disposal.
Chiller Room —
This room is connected to the Manufacturing Building. The Chiller Room is accessed from the outside adjacent to the
Staging Area_ An air compressor is located in this room. Oil spots were observed on the concrete ramp immediately
outside the door. The air compressor blowoff is being discharged immediately inside the door on the floor. It appeared
that oil from the blowoff was being tracked outside exposing it to stormwater runoff.
Air compressor blowoff should be contained and disposed of properly.
General Assembly —
The General Assembly area is located inside the OCM Building at the shipping dock. Stock bases of new waste
containers are brought in to this area where lid attachment and hot stamping takes place. At the time of inspection dark
brown water was observed in the General Assembly area. Per facility personnel, the water is rainwater that ;
accumulates in the stock bases. Rainwater is dumped out as stock bases are brought in. Dirt as well as oil from
machines in this area appeared to be mixing in with the discharged rainwater. This water is pushed outside via the
dock doors using a squeegee. Otto employees were observed using the squeegee during the inspection. The area
outside immediately beyond the dock door openings had moderate staining. Inspectors asked facility personnel to
immediately cease the operation of using the squeegee to push the brown water outside.
The facility should investigate alternative methods for cleaning this area_ Recommendations include discarding
rainwater from new stock bases outside before bringing stock bases inside, covering stock bases to prevent rainwater
accumulation, or using a vacuum inside to remove the dirty wafer then properly dispose it.
Regrind_Area —
The Regrind Area is located outside adjacent to the Manufacturing -Building on the north side of the facility. Non -
repairable, old, and/or discolored waste containers are sent through a grinding machine. The grinding machine is
covered on top. The plastic regrind is discharged from the machine into large totes. Some regrind is dispersed onto the
paved surface during the grinding process. Regrind is swept into piles on a routine basis and discarded accordingly.
The regrind is combined with the shipped HDPE pellets to manufacture the facility's new waste containers. Otto
employees were observed sweeping this area at the time of inspection.
Page: 3

Permit: NCGO60149 Owner— Facility' Otto Industries
Inspection Date 04/22/08 Inspection Type: Compliance Evaluation Reason for Visit Routine
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
Diesel Fuel Storage Tanks — Two 8,000-gallon aboveground diesel storage tanks are located inside a shared concrete
containment structure One 2,000-gallon diesel tank is also located within the concrete containment structure and is
empty and out of service. Stormwater that collects inside the containment structure is discharged by a manual sump
pump to an oil/water separator, and then discharged to the wash bay. From the wash bay the stormwater is sent to
the on -site wastewater treatment plant that includes an oil skimmer. The treated discharge is released to CMU
sanitary sewer system. In the event of a spill, Haz-Mat Transportation and Disposal is utilized to remove and properly
dispose of the spilled material. An underground storage tank is connected to the oil/water separator to reclaim spilled
fuel. A Diesel Fuel Spill Kit is located adjacent to the Diesel Storage Tank area. The oillwater separator is monitored
for disposal every two to three weeks. This area appeared to be in good condition.
Diesel Fueling Area — This area is adjacent to the Diesel Fuel Storage Tanks; it is located under cover and is not
exposed to stormwater. A trench drain is located near the fueling pump and the concrete surface is sloped towards
the drain to catch any spilled materials. The trench drain leads into the Diesel Fuel Storage Tank containment
structure. Fluids that collect inside the containment structure are discharged by a manual sump to an oillwater
separator and then discharged to the wash bay. From the wash bay the discharge is sent to the on -site wastewater
treatment plant that includes an oil skimmer. Treated discharge is released to CMU sanitary sewer system. This area
appeared to be in good condition.
Material Storage —
Several flammable storage cabinets were observed within the facility. One non -portable (1,000-gallon) and two
portable (one 375-gallon and one 500-gallon) aboveground hydraulic fluid tanks are located inside the facility. The
1,000-gallon tank has secondary containment. A pipe is connected to the secondary containment leading down into
the floor drain. All floor drains within the facility are connected to an oil/water separator that discharges to the sanitary
sewer system. The facility has a 2,000-gallon oil reclaim underground storage tank (UST) where oil from the oillwater
separator is recycled and then reused by the facility's machines. Shamrock Environmental services the oillwater
separator on an annual basis. Dilmar Oil Service maintains the facility's UST. Four large silos for HDPE storage are
located outside.
Railroad Spur Area —
The main railroad line and spur are located to the east of the facility. Railroad cars deliver HDPE pellets used for the
facility's manufacturing process. A vacuum hose is used to transfer pellets from the railroad cars to large silos. Catch
bins are placed under the hose connections to catch dispersed pellets. Pellets and regrind were observed on the
ground along the railroad spur. Per facility personnel, pellets not contained in the catch bins are shoveled and
disposed of through an outside company.
Page: 4

Permit: NGG050149 Owner - Facility: Otto Industries
Inspection Date: 04122/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■ n n n
# Does the Plan include a General Location (USGS) map?
■ n n n
# Does the Plan include a "Narrative Description of Practices"?
■ n n n
# Does the Plan include a detailed site map including outfali locations and drainage areas?
■ n n n
# Does the Plan include a list of significant spills occurring during the past 3 years?
n ■ n n
# Has the facility evaluated feasible alternatives to current practices?
n ■ n n
# Does the facility provide all necessary secondary containment?
n n ■ n
# Does the Plan include a BMP summary?
■ n n n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ n n n
# Does the Plan include a Preventative Maintenance- and Good Housekeeping Plan?
■ n n n
# Does the facility provide and document Employee Training?
n ■ n n
# Does the Plan include a list of Responsible Party(s)?
■D 0 El
# is the Plan reviewed and updated annually?
n ■ n n
# Does the Plan include a Stormwater Facility Inspection Program?
❑ ■ n n
Has the Stormwater Pollution Prevention Plan been implemented?
n ■ n n
Comment: The permittee's Stormwater Pollution Prevention Plan (SPPP) is currently
dated February 1996; no documentation could be provided showing annual
reviews/updates to the plan. The SPPP contains a general location (USGS) map, but it
does root include the name of the municipal storm sewer system that receives
discharges from Outfall 002. The permittee has not evaluated feasible alternatives to its
current practices and documented this review in the SPPP.
The SPPP does not include a list of spills that have occurred at the facility in the past
three years. Per facility personnel, some employee training has taken place in 2008 but
the permittee could not provide records of previous training.
Qualitative Monitoring
Yes
No NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
n
■ n
n
Comment: The permittee has not conducted semi-annual qualitative monitoring as
required by the permit.
Analytical Monitoring
Yes
No NA
NE
Has the facility conducted its Analytical monitoring?
n
n ■
n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Q
n ■
n
Page, 5

I
Permit: NCG050149 Owner - Facility: Otto Industries
Inspection Date: 04122/2008 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Comment: The permittee uses < 55 gallons of new motor oil per month when
averaged over a calendar year and therefore is not required to conduct analytical
monitoring.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: The permittee does not have a copy of its general permit or Certificate of
Coverage at the site.
The stormwater outfalls have not been evaluated for the presence of non-stormwater
discharges. At the time of inspection, facility personnel were not able to locate Outfall
001; therefore this outfall was not observed.
Outfails 001 and 002 —
The facility has two outfalls (001 and 002) identified on their site map dated February
1996. Outfall 001 discharges drainage from a silt basin that receives runoff from the
north side of the plant. The silt basin discharges to an unnamed tributary to Steele
Creek_ Outfall 002 is a storm drain that collects runoff from the south side of the plant
and discharges to a second unnamed tributary to Steele Creek.
Please see the following page for additional information regarding stormwater outfalls
Yes No NA NE
0 00
13 0 ID
nn■n
n■nn
Page:6

f ' P`erMit NCGO50149 Owner-- Facility: Otto Industries
Inspection Date: 04/22/08 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Permit and Outfalls Section (cant.):
Potential Outfalls —
Potentially two additional stormwater outfalls were identified during the inspection.
A concrete stormwater pipe is located along General Drive to the south of the shipping and receiving driveway.
Stormwater discharged as sheet flow from the paved area in front of the OCM Building collects in a detention area to
the west and eventually discharges from the concrete pipe along General Drive. Stormwater from this outfall drains to
the north along General Drive where it discharges to the same unnamed tributary to Steele Creek as Outfall 001.
However, stormwater from this outfall would bypass the silt basin unlike Outfall 001. This was not identified on the site
map as an outfall.
A stormwater conveyance ditch is located in between the railroad spur and the facility's fence. A concrete stormwater
pipe with rip -rap at the opening was observed along the ditch. Some dead grass was observed along the conveyance
ditch from the point of this opening to approximately 200 feet to the next stormwater conveyance pipe. This stormwater
pipe had moderate staining inside_ It could not be determined to where this stormwater pipe discharges. According to
the site map the pipe appears to connect with the stormwater conveyance that eventually discharges at Outfall 001 _
The permittee shall review stormwater flow on site to ensure all stormwater outfalls associated with industrial activities
have been identified, included in the SPPP, and monitored.
Page: 7

P
AW
O�0� W A rFj9pG Michael F- Easley, Governor
YSecretary
r North Car 11f . } Resources
..
Director
t:• �r 1 �. ;. �` 3iu ion of Waber Quality
:T 4
August 31, 2007 SEP a W. "W'
i,
Mr. Richard L Marshall a'
Exopack Advanced Coatings
PO Box 368
Matthews, NC 28106-7003 - ,•,.. r� , = • r.
Subject: NPDES General Permit NCG050000
Certificate of Coverage NCG050150
Exopack Advanced Coatings
Formerly Intelicoat Technologies, LLC
Mecklenburg County
Dear Mr. Marshall:
Division personnel have reviewed and approved your request to transfer coverage under the General Permit,
received on August 30, 2007.
Please find enclosed the revised Certificate of Coverage. The terms and conditions contained in the General
Permit remain unchanged and in full effect. This revised Certificate of Coverage is issued under the requirements of
North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at (919) 733,5083, extension 502.
Sincerely,
ORIGINAL SIGNED BY
{EN PICKLE
Coleen H. Sullins
cc DWQ Central Files
Mooresville Regional Office, Water Quality Section
Stormwater Permitting Unit
ow
NaNCarolina
rurally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, TIC 27699-1617 Phone [phone] Customer Service
Internal: h2o.enr.slatem-us 512 N. Salisbury St Raleigh, NC 27604 FAX [phone]
An Equal bpportunitylAlfumaWe Action Employer- 50% Racycledl10% Post Consumer Paper

it
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG050000
CERTIFICATE OF COVERAGE No. NCG050150
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
EXOPACK ADVANCED COATINGS
is hereby authorized to discharge stormwater from a facility located at
EXOPACK ADVANCED COATINGS
700 CRESTDALE STREET
MATTHEWS
MECKLENBURG COUNTY
to receiving waters designated as a UT to Fourmile Creek, a class C stream, in the Catawba River Basin in
accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11, 111, IV,
V, and VI of General Permit No. NCGO50000 as attached.
This certificate of coverage shall become effective August 31, 2007.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 31, 2007. ORIGINAL SIGNED BY
KEN PICKLE
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

UNITED. STATES.:
:DEPARTMENT: -.OF
GEOLOGICAL SURVEY
s21 '25
elk
.IOW., •. }}�� i
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sf,/,l�ii:4:�4'
3e8600am.N.

ArF Michael F. Easley, Governor
`OtE_i RQG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
�! Alan W. Klimek, P.E. Director
Division of Water Quality
0 �
April 28, 2003
Bahrija Hati
Otto Industries
12900 General Dr
Charlotte, NC 28241
Subject: NPDES Stormwater Permit Renewal
Otto Industries
COC Number NCGO50149
Mecklenburg County
Dear Permittee:
In response to your renewal application for continued coverage under general permit NCG050000, the
Division of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This
permit is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection
Agency, dated December 6, 1983_
The following information is included with your permit package:
A new Certificate of Coverage
A copy of General Stormwater Permit NCGO50000
A copy of the Analytical Monitoring Form (DMR)
A copy of the Qualitativel Monitoring Form
• A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division
may require modification or revocation and reissuance of the Certificate of Coverage. This permit does
not affect the legal requirements to obtain other permits which may be required by the Department of
Environment and Natural Resources, or relieve the permittee from responsibility for compliance with any
other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or decree.
If you have any questions regarding this permit package please contact Aisha Lau of the Central Office
Stormwater and General Permits Unit at [phone], ext. 578.
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater & General Permits Unit Files
Mooresville Regional Office
WrNR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCGO50000
CERTIFICATE OF COVERAGE No. NCG050149
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Otto Industries
is hereby authorized to discharge stormwater from a facility located at
Otto Industries
12900 General Dr
Charlotte
Mecklenburg County
to receiving waters designated as a UT to Steele Creek, a class C stream, in the Catawba River
Basin in accordance with the effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III, IV, V, and VI of General Permit No. NCG050000 as attached.
This certificate of coverage shall become effective May 1, 2003.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day April 28, 2003.
for Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

W A
—i
BAHRIJA HATT
OTTO INDUSTRIES
12900 GENERAL DR
CHARLOTTE. NC 28241
Dear Perrnittec:
Ailichael F. Easley, Governor
William G. Ross Jr_, Secretary
North Carolina Department of Environment and Natural Resources-
. ,
Alan_ 1N_ Klimek,.P_E -rector.
Division of Waieir' Ouality
Seplemher 4. 2002
L 2002
Subject: NPDES Stormwater Permit Coverage Renewal
Otto lndustries
COC Number NCO050149
Mecklenburg County
Your facility is currently covered for stormwater discharge under General Permit NCG050000. This permit expires
on March 31, 2003. The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by early spring. of 2003. Once the permit is reissued, your facility would he eligible for
continued coverage under the reissued permit_
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit coverage will be expiring. Enclosed you will find a Permit Coverage Renewal
Application Form. The application must be completed and returned by October 2, 2002 in order to assure
continued coverage under the general permit. Due to staff and budget constraints, letters confirming our receipt of
the completed application will not be sent.
Failure to request renewal within the time period specified, may result in a civil assessment of at least $250.00.
Larger penalties may be assessed depending on the delinquency of the request. Discharge of stormwater from your
facility without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1
and could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the I 1 categories of "storm water discharges associated with industrial activity," (except
construction activities). if you feel your facility can certify a condition of "no exposure", i.e. the facility industrial
materials and operations. are not exposed to stormwater. you can apply for the no exposure exclusion. For additional
information contact the Central Office Stormwater Staff member listed b0ow or check the Stormwater & General
Permits Unit Web Site at http://h2o.enr.state.nc.us/suJstormwater.htm]
If the subject stormwater discharge to waters of the state has been terminated. please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form_ You will be notified when the
rescission process has been completed.
If you have any questions regarding the permit renewal procedures please contact Mike Parker of the Mooresville
Regional Office at 704-663-1699 or Aisha Lau of the Central Office Stormwater Unit at [phone], ext. 578
Sincereiv.
Bradley Bennett. Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
Mooresville Regional Office
"A
NCDENR
N, C. Division of Water Quality 1617 Mail Service Carter Raleigh, NC 27699-1617 [phone] Customer Service
1- 800-623-i748

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
10/24/2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
OTTO INDUSTRIES
12900 GENERAL DR
CHARLOTTE, NC 2824 t
1 • •
NCDENR
NORTH CARouNA DEPAi2TMENT of
ENVIRONMENT AND NATURAL REsouRGEs
Subject: NOTICE OF VIOLATION
FAILURE TO SUBMIT RENEWAL APPLICATION
OTTO INDUSTRIES
NCGO50000
COC NUMBER NCGO50149
MECKLENBURG COUNTY
Dear Permittee:
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is a violation of NCGS § 143.215.1 (c)(1) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 stays prior to expiration or permittee that does not have a
permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to
enforcement procedures as provided in NCGS § 143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the
subject discharge has been terminated, please complete the enclosed rescission request form_ A valid reason for
requesting rescission is required, incomplete forms will be returned and you will still be subject to possible
escalated action. Mailing instructions for submitting rescission request are listed on the bottom of the form. You
will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Aisha Lau of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 579.
Sincerely,
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

To: Tim O'Hare
From: Delonda Alexander
Phone: [phone] x584
DIVISION OF WATER QUALITY
1617 Mail Service Center
Raleigh, NC 27699-1617
[phone]
FAX [phone]
-71
isn. r ,y - s �
Fax: [phone]
Date: 03/01 /02
Pages: 2 (including cover sheet)
❑ Urgent ❑ For Review ❑ Please Comment ❑ Please Reply ❑ As Requested
.RKTI1,TI -►1rti�
Tim — Here is the letter that was sent out, renewing your stormwater permit in 1998. As we
discussed, a new COC was not issued. Your old COC is still valid, in combination with this letter.
The general permit and monitoring forms can be downloaded from our web site at:
A.
;+7 httii a/tti2o:enr. state. nc. us/su/storm water.html
,If you have any other questions, please do not hesitate to call.
�Jl WTI ���� • --d �y5�) • • • • • • • • •
— 7
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Fax:919- -0719
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 30, 1998
LEO MILES ]R.
OTTO INDUSTRIES
12900 GENERAL - DRIVE
CHARLOTTE, NC 28241
A�IR
ID E N R
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG050149
Mecklenburg County
�I . _ i,I —
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
a A copy of the stormwater general permit.
m A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
A Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program which outlines program components
and addresses frequently asked questions.
a A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater and General Permits Unit at telephone number [phone]
Sincerely,
f oA. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
Depart;iiant of Environment,
Haalth and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
November 12, 1993
Mr. Leo Miles Jr.
Gebr. Otto KG
Postfach 14 60
Kreurtal, NC 59100
Subject: General Permit No. NCG050000
Gebr. Otto KG
COC NCGO50149
Mecklenburg County
Dear Mr. Miles:
In accordance with your application for discharge permit received on October 14, 1993, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 919/733-
5083.
Sincerely,
Original Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
cc: Mooresville Regional Office
Mecklenburg County
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DMSION OF ENVIRONMENTAL MANAGEMENT
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Gebr. Otto KG
is hereby authorized to discharge stormwater from a facility located at
Otto Industries, Inc.
12700 General Drive
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Steele Creek in the Catawba River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts 1, II, III
and IV of General Permit No. NCG050000 as attached.
This Certificate of Coverage shall become effective November 19, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit
Signed this date November 19, 1993.
Origina4 Signed BY
Coleen H. Sullins
A. Preston Howard, Jr., F.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
December 28, 1993
Mr. Leo Miles Jr
Otto industries, Inc.
12700 General Dr.
Charlotte, NC 28241
E::)EHNR
Subject: General Permit No. NCG050000
Otto Industries, Inc.
COC NCG050149
Mecklenburg County
Dear Mr. Miles:
In accordance with your application for discharge permit received on October 14, 1993, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 919/733-
5083.
Sincerely,
v t2 rCi r +-LA, I- S errr
A. Preston Howard, Jr., P. E.
cc: Mooresville Regional Office
Mecklenburg County
P.O. Box 29635, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NPDES FACILITY AND PERMIT DATA
UPDATE OPTION TRXID 5NU KEY NCGO50149
PERSONAL DATA FACILITY APPLYING FOR PERMIT REGION
FACILITY NAME> OTTO INDUSTRIES COUNTY> MECKLENBURG 03
ADDRESS: MAILING (REQUIRED) LOCATION (REQUIRED)
STREET: 12900 GENERAL DRIVE STREET: 12900 GENERAL DRIVE
CITY: CHARLOTTE ST NC ZIP 28241 CITY: CHARLOTTE ST NC ZIP 28241
TELEPHONE [phone] DATE FEE PAID: 10/14/93 AMOUNT: 400.00
STATE CONTACT> ULMER PERSON IN CHARGE LEO MILES JR.
1=PROPOSED,2=EXIST,3=CLOSED 1 1=MAJOR,2=MINOR 2 1=MUN,2=NON-MUN 2
LAT: LONG: N=NEW,M=MODIFICATION,R=REISSUE> N
DATE APP RCVD 10/14/93 WASTELOAD REQS
DATE STAFF REP REQS / / WASTELOAD RCVD
DATE STAFF REP RCVD / / SCH TO ISSUE
DATE TO P NOTICE / / DATE DRAFT PREPARED 11/09/93
DATE OT RG COM REDS / / DATE DENIED
DATE OT RG COM RCVD / / DATE RETURNED
DATE TO EPA / / DATE ISSUED 11/12/93 ASSIGH/CHANGE PERMIT
DATE FROM EPA / / EXPIRATION DATE 08/31/97
FEE CODE C 0 ) 1=C>10MGD),2=(>1MGD),3=(>0.1MGD),4=C(0.1MGD),5=SF,6=(GP25,64,79),
7=(GP49,73)8=(GP76)9=(GP13,34,30,52)0=CNOFEE) DIS/C 73 CONBILL ( )
COMMENTS:
MESSAGE: LATITUDE/LONTITUDE MUST BE ALL NUMERIC

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
10/24/2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
OTTO INDUSTRIES
12900 GENERAL DR
CHARLOTTE, NC 28241
RFAENT
,,,e. ,,,,:ES
NOR I -I CARCi Fm-&-lDi564f TMENT OF'A 0T-FICE
ENVIRONMENT ANIr) NATURAL RESOURCES
NOV 0 7 2002
Subject: NOTICE OF VIOLATION
FAILURE TO SUMMIT RENEWAL APPLICATION
OTTO INDUSTRIES
NCGO50000
COC NUMBER NCG050149
MECKLENBURG COUNTY
Dear Permittee:
This letter is to inform you that, as of the date of this letter, the Division of Water Quality has not received a
renewal request for the subject permit certificate of coverage. This is a violation of NCGS §143.215.1 (c)(1) which
states "All applications shall be filed with the commission at least 180 days in advance of the date on which it is
desired to commence the discharge of wastes or the date on which an existing permit expires, as the case may be".
Any permittee that has not requested renewal at least 180 days prior to expiration or permittee that does not have a
permit after the expiration and has not requested renewal at least 180 days prior to expiration, will be subjected to
enforcement procedures as provided in NCGS §143-215.6 and 33 USC 1251 et. seq.
In order to prevent continued, escalated action, including the assessment of civil penalties you must submit a
completed permit coverage renewal application to the attention of the "Stormwater and General Permits Unit" at
the letterhead address within ten (10) days of your receipt of this letter (renewal application enclosed). If the
subject discharge has been terminated, please complete the enclosed rescission request form. A valid reason for
requesting rescission is required, incomplete forms will be returned and you will still be subject to possible
escalated action. Mailing instructions for submitting rescission request are listed on the bottom of the form. You
will be notified when the rescission process has been completed.
Thank you for your prompt attention to this situation. If you have any questions regarding this matter, please
contact Aisha Lau of the central office Stormwater and General Permits Unit at 919-733-5083, ext. 578.
Sincerely,
44AY
for Alan W. Klimek, P.E.
Director, Division of Water Quality
cc: Stormwater and General Permits Unit Files
Central Files
Mooresville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone]a3 FAX [phone]
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