2018 SHAMROCK ENVIRONMENTAL PERMIT

City
6 J North
August 31, 2018
of Greensboro
Carolina Water Resources Department
Steve Davis
SHAMROCK ENVIRONMENTAL
6106 Corporate Park Drive
Brown Summit, North Carolina 27214
Dear Mr. Davis :
Enclosed is the renewal of Significant Industrial User Permit #P065 effective September 1,
2018. Also included is the City of Greensboro Local Pollutant Allocation Document.
The Permittee and the State of North Carolina have 30 days from receipt to comment on this
permit. If you have any comments or objections to the permit, please notify the City of
Greensboro in writing no later than October 01, 2018. If no written objections are received
within 30 days, the permit will be considered final and binding.
Please return a signed copy of the signatory page (Page 2) to the City of Greensboro. The
signature requirement is to make the signatory official aware of his/her responsibilities. In
addition, the signature of a high ranking official on a permit document displayed at a facility
reminds all employees that the company has a legal commitment to comply.
Sincerely,
Frank Skee
Pretreatment Coordinator
Encl: Permit /Standard Conditions/Permit Synopsis/Local Pollutant Allocation Document

rA
City
6 J North
of Greensboro
Carolina
SHAMROCK ENVIRONMENTAL 01/02
STATEMENT OF RECEIPT
For 2018 Industrial User Permit #P065
2018 Permit Received by:
Name of program: Industrial Waste Services
Water Resources Department
City of Greensboro

CITY OF GREENSBORO
WATER RESOURCES DEPARTMENT
INDUSTRIAL WASTE SECTION
SIGNIFICANT INDUSTRIAL USER
WASTEWATER DISCHARGE PERMIT
SIU PERMIT NUMBER P065
SHAMROCK ENVIRONMENTAL CORPORATION
IS AUTHORIZED TO DISCHARGE WASTEWATER
FROM A FACILITY LOCATED AT
6106 CORPORATE PARK DRIVE
BROWNS SUMMIT, NORTH CAROLINA
into the City of Greensboro Sanitary Sewer System
to the T.Z. OSBORNE Water Reclamation Facility
[NPDES PERMIT NUMBER NC0047384]
in accordance with the limitations and conditions set forth in this permit.
This permit shall become effective
SEPTEMBER 1, 2018
This permit and the authorization to discharge shall
expire at midnight on
AUGUST 31, 2023
or upon permit reissuance, whichever comes first.
Frank Skee Date
Pretreatment Coordinator
September 1, 2018 Permit Renewal

Page 2, SIU Permit #P065
SHAMROCK BROWN SUMMIT
INDUSTRY OFFICIAL RESPONSIBLE FOR PERMIT COMPLIANCE
This signatory official shall be responsible for permit compliance, including monitoring, report
submittals, accidental discharge notification, and permit renewal. Although certain of these
activities may be delegated to other individuals, the Signatory Official is ultimately responsible
for compliance with all permit conditions, limits, activities and terms.
I am aware of my responsibilities as Signatory Official and I am aware of the terms and
conditions set forth in this wastewater discharge permit and the City of Greensboro Sewer Use
and Pretreatment Ordinance.
Signatory Official NAME (PLEASE PRINT)
Signatory Official TITLE (PLEASE PRINT)
Signatory Official Signature
Date:
If there is a change of the Signatory Official for this facility, the City of Greensboro shall be
notified of such change within thirty (30) days. A new page 2, "INDUSTRY OFFICIAL
RESPONSIBLE FOR PERMIT COMPLIANCE" shall be submitted to the Industrial Waste Section
with the name, title and signature of the new official.
September 1, 2018 Permit Renewal

Page 3, SIU Permit #P065
SHAMROCK BROWN SUMMIT
SECTION I — PERMIT MODIFICATION HISTORY
DATE MODIFIED
REASON & DESCRIPTION OF MODIFICATION OR ACTION
September 15, 2001
Page 5 - D. Waste/Wastewater Discharge modified to include requirement for
profiling of all wastestreams before discharge to the POTW
PERMIT RENEWAL
May 1, 2003
With inclusion of Compliance Schedule and Centralized Waste Treatment
Categorical limits effective December 22, 2003
May 9, 2003
Permit Modification
Based on Comments from Shamrock [Outlined in Permit Cover Letter]
July 1, 2003
Permit Modification
Based on Comments from Shamrock [Outlined in Permit Cover Letter]
November 15, 2003
Changes to Section IV - Special Permit Conditions - Flow Measurements due to
recent changes in City of Greensboro flow measurement/sampling requirements
January 1, 2004
Change Section III- Effluent Limitations due to amendment of regulation by EPA
effective December 22, 2003,
Transfer o f flow from North Buffalo to T. Z. Osborne. A new lift station, Reedy
January 1, 2005
Fork, was constructed to handle growth on the North side of town. The North
Buffalo facility could not handle the increase in flow.
June 1, 2007
PERMIT RENEWAL
To get Shamrock permit into T. Z. Osborne permit renewal cycle
Modifications and correction submitted by Shamrock during the permit renewal
comment period. Section ILB Ammonia stripping moved under incorrect pipe -
September 1, 2007
should be Pipe 02, clarification of monitoring location under Section II. C.; Section
III- Sampling frequency for Pipe 01 and Pipe 02 changed to quarterly with the
exception of cyanide at Pipe 02,
PERMIT RENEWAL
Section II.B - Pretreatment process modified for clarity of what process belongs to
each pipe; Page 5, Section III - changed from daily maximum of 150,000 to
monthly average of 80,000 - cadmium, nickel and cobalt pollutant limits
decreased - changed from daily and monthly average to a daily maximum only
September 1, 2008
based on historical data; Page 6, Section III - changed from daily maximum of
75,000 to monthly average of 35,000; Page 7, Section IV.A3 - Flow submittal due
date incorporated; Section IV. A.5 - added additional contact; Section IV.B.
Monitoring Report Submittal - included requirements when there is no discharge
during a reporting period; Section IV.C. Tanker Wash Records - modified to
include requirements should the tanker wash be used.
September 1, 2018 Permit Renewal

Page 3A, SIU Permit #P065
SHAMROCK BROWN SUMMIT
DATE MODIFIED
REASON & DESCRIPTION OF MODIFICATION OR ACTION
Categorical limit concentrations reinstated for nickel, cobalt and antimony. Limits
January 1, 2009
previously submitted as local limits. Cadmium changed from daily max of 0.050
mg/1 to a daily max. of 0.060 mg/l and a monthly average of 0,050 mg/l; Page 10.F.
Waste/Wastewater Receipt Categorization deleted [Effective 12-22-03]
Permit Modification
1) Pages 5a & 5b, Section III -Changed minimum sampling requirement for City to
July 1, 2011
1/year. 2) Page 6, Section IV.A.4.- changed effluent meter calibration requirement
from once per six-month period to once a calendar year; 3) Page 6, Section IV.A.5.
and 6. - deleted names from permit and included the position titles only.
September 14, 2012
Page 5A, Section III - changed monthly average flow from 80,000 gallons per day to
100,000 gallons per day based on past usage and anticipated growth.
Page 5A, Section III - changed Pipe 01 monthly average flow from 100,000 gallons per
June 14, 2013
day to 125,000 gallons per day based on past usage and anticipated growth. Page 5B,
Section III - changed Pipe 02 monthly average flow from 35,000 gallons per day to
50,000 gallons per day based on past usage and anticipated growth
PERMIT RENEWAL
Section IV. - Added Special Condition) (Slug/Spill Control Plan) per DWQ guidance;
September 1, 2013
Section III- increased cadmium daily maximum Pipe 01; Added selenium to Pipe 01
"quarterly"
and Pipe 02 POTW monitoring; Changed monitoring from to 2/6 months
with all samples to be taken in 15t 3 months of each semi-annual period; Renumbered
pages.
Permit Modification
June 6, 2016
Codified and extended temporary Pipe 02 flow increase from 50,000 gpd to 150,000
gpd Monthly Average. Added Ammonia monitoring for Pipe 02.
Permit Modification
April 19, 2018
Set provisional limits for Pipe 01 Cyanide while investigating likely sources of
interference.
PERMIT RENEWAL
September 1, 2018
Added Ammonia SOP language; Special Conditions changes; Modified Flow
Language; Added Flow Measurement Calibration/Verification Section; Added
Detection Limits and Matrix Interferences Section
September 1, 2018 Permit Renewal

Page 4, SIU Permit #P065
SHAMROCK BROWN SUMMIT
SECTION II - GENERAL INFORMATION
A. Description of Di
Pipe 01 - Process Wastewater from 40 CFR Part 437 Subpart A - Metal Bearing Wastes and
Subpart B - Oily Wastes, tanker truck wash, and initial de -emulsification wastewater from
Shamrock Environmental II on Patton Avenue
Pipe 02 - Process wastewater from 40 CFR Part 437 Subpart C - Organic Waste
Pipes 01 and 02 do NOT include domestic waste discharge from the facility.
B. Authorization Statement
1. The permittee is hereby authorized to discharge wastewater in accordance with the effluent
limitations, monitoring requirements, and all other conditions set forth in this Industrial User
Pretreatment Permit (IUP) into the sewer collection system and wastewater treatment facility
of the City of Greensboro
2. The permittee is hereby authorized to continue operation of and discharge wastewater from
the following treatment or pretreatment facilities. These facilities must correspond to the
treatment units listed on both the application and inspection forms.
Pipe 01 Pretreatment Processes
Pipe 02 Pretreatment Processes
Screening
Receiving/Equalization Tanks
Chemical precipitation
Ammonia stripping (mobile)
Dissolved Air Flotation (DAF)
Sedimentation
Plate and Frame Filter Presses
pH Neutralization
Neutralization/pH adjustment
Biological Treatment (incidental)
Non -aerated Equalization Tanks
Oil/Water Separator
Clarifiers
Filtration
Flocculation
Sedimentation
Grit Removal
Spill Protection
3. The permittee is hereby authorized to, if requested by the City of Greensboro and after
receiving Authorization to Construct (A to C) from the City of Greensboro, construct and
operate additional pretreatment units as needed to meet final effluent limitations.
September I, 2018 Permit Renewal

Page 4A, SIU Permit #P065
SHAMROCK BROWN SUMMIT
l.. 1VIUML0111% LVC dL1VI1
Pipe 01(A&B Wastewaters) Automatic sampler located at the northwest end of the tank farm
(near the discharge flume) just outside the northern corner of the containment wall. When
facing the front of the samplers, the sampler is on the left.
Pipe 02 (C Wastewaters) Automatic sampler located at the northwest end of the tank farm
(near the discharge flume) just outside the northern corner of the containment wall. When
facing the front of the samplers, the sampler is on the right.
Pipe 01 and Pipe 02 do not include domestic wastewaters
D. Composite Sampling Technique
A composite sample for the purposes of this permit for Pipe 01 and Pipe 02 is:
A Flow Proportional Composite sample taken over the entire workday by an automatic sampler
interfaced with the effluent flow meter.
September 1, 2018 Permit Renewal

Page 5, SIU Permit #P065
SHAMROCK BROWN SUMMIT
Effective September 1, 2018
SECTION III - EFFLUENT LIMITS AND MONITORING REQUIREMENTS PIPE 01
PIPE 01 IS REGULATED BY FEDERAL CATEGORICAL STANDARDS FOR CENTRALIZED WASTE
TREATMENT SUBPART D-MULTIPLE WASTREAMS [SUBPART A & B] [40 CFR Part 437.46(c)]
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING FREQUENCY
Daily Maximum
Monthly Average
Sample
Type
PERMITTEE
CITY OF
GREENSBORO
Flow (gallons per day)
125,000
#
Continuous
pH (standard units)
5.0 -12.0
Grab
1/6 months
BOD ++ (mg/1)
M
C
1/6 months
Suspended Solids++ (mg/1)
M
C
1/6 months
Ammonia (lbs/day)^^
M
C
Profiles ^^
months
Chemical Oxygen Demand
(mg/1)*
Immediately report all
values >10,000 mg/l*
C
1/month*
1/6 months
Cadmium (Total) (mg/1)
0.10 mg/1
0.050 mg/1
C
2/6 months
1/6 months
Chromium (Total) (mg/1)
0.947 mg/l
0.487 mg/l
C
2/6 months
1/6 months
Copper (Total) (mg/1)
0.405 mg/l
0.301 mg/l
C
2/6 months
1/6 months
Lead (Total) (mg/1)
0.222 mg/l
0.172 mg/l
C
2/6 months
1/6 months
Nickel (Total) (mg/1)
3.95 mg/l
1.45 mg/l
C
2/6 months
1/6 months
Zinc (Total) (mg/1)
2.87 mg/l
0.641 mg/1
C
2/6 months
1/6 months
Silver (Total) (mg/1)
0.120 mg/1
0.0351 mg/1
C
2/6 months
1/6 months
Cyanide (Total) (mg/1)
0.50 mg/1
-
Grab
2/6 months
1/6 months
Arsenic (Total) (mg/1)
0.162 mg/l
0.104 mg/l
C
2/6 months
1/6 months
Cobalt (Total) (mg/1)
0.192 mg/1
0.124 mg/1
C
2/6 months
1/6 months
Mercury (Total) (mg/1)
0.00234 mg/l
0.000739 mg/l
C
2/6 months
1/6 months
Antimony (Total) (mg/1)
0.249 mg/1
0.206 mg/1
C
2/6 months
1/6 months
Titanium (Total) (mg/1)
0.0947 mg/l
0.0618 mg/l
C
2/6 months
1/6 months
Tin (Total) (mg/1)
0.409 mg/1
0.120 mg/l
C
2/6 months
1/6 months
vanadium (Total) (mg/1)
0.218 mg/l
0.0662 mg/1
C
2/6 months
1/6 months
Bis(2-ethylhexyl)
phthalate (mg/1)
0.267 mg/1
0.158 mg/1
C
2/6 months
1/6 months
Carbazole (mg/1)
0.392 mg/l
0.233 mg/l
C
2/6 months
1/6 months
n-Decane (mg/1)
5.79 mg/l
3.31 mg/1
C
2/6 months
1/6 months
Fluoranthene (mg/1)
0.787 mg/1
0.393 mg/1
C
2/6 months
1/6 months
n-Octadecane (mg/1)
1.22 mg/l
0.925 mg/l
C
2/6 months
1/6 months
Selenium (Total) (mg/1)
M
C
1/6 months
++ All BOD concentrations over 200 mg/l and all Total Suspended Solids concentrations
over 200 mg/l are subject to an Industrial Waste Surcharge
# The Greensboro Industrial Waste Section does not consider Flow to be a pollutant and
flow data is not considered to be a report.
*See Special Conditions Section: Surrogate Process Control Sampling
^^ See Special Conditions Section:
C - Composite Sample [See Section II Part D for permit -specific definition]
G - Grab Sample
M- Monitoring Only [See Local Pollutant Allocation Document to determine if an Allocation has
been issued for this parameter]
September 1, 2018 Permit Renewal

Page 5A, SIU Permit #P065
SHAMROCK BROWN SUMMIT
Effective September 1, 2018
SECTION III - EFFLUENT LIMITS AND MONITORING EQUIREMENTS PIPE 02
PIPE 02 IS REGULATED BY THE FEDERAL CATEGORICAL PRETREATMENT STANDARDS FOR
CENTRALIZED WASTE TREATMENT
SUBPART C-ORGANICS TREATMENT AND RECOVERY [40 CFR Part 437.35]
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING FREQUENCY
Daily
Maximum
Monthly
Average
Sample
Type
PERMITTEE
CITY OF
GREENSBORO
Flow (gallons per day)
150,000
#
Continuous
pH (standard units)
5.0 -12.0
Grab
1/6 months
BOD ++(mg/1)
M
C
1/6 months
Suspended Solids++(mg/1)
M
C
1/6 months
Ammonia (lbs/day)^^
M
C
Profiles ^^
1/6 months
Chemical Oxygen Demand
(mg/1)*
Immediately report all
values >10,000 mg/1*
C
1/month *
Cadmium (Total)(mg/1)
M
C
1/6 months
Chromium (Total)(mg/1)
M
C
1/6 months
Copper (Total) (mg/1)
M
C
1/6 months
Lead (Total) (mg/1)
M
C
1/6 months
Nickel (Total) (mg/1)
M
C
1/6 months
Zinc (Total) (mg/1)
M
C
1/6 months
Selenium (Total) (mg/1)
M
C
1/6 months
Silver (Total)(mg/1)
M
C
1/6 months
Cyanide (Total) (mg/1)
M
Grab
2/6months
1/6 months
o-Cresol (mg/1)
1.92 mg/l
0.561 mg/1
C
2/6months
1/6 months
p-Cresol (mg/1)
0.698 mg/1
0.205 mg/1
C
2/6 months
1/6 months
2,4,6-Trichlorophenol
(mg/1)
0.155 mg/l
0.106 mg/1
C
2/6 months
1/6 months
*See Special Conditions Section: Surrogate Process Control Sampling
++ All BOD concentrations over 200 mg/l and all Total Suspended Solids concentrations
over 200 mg/1 are subject to an Industrial Waste Surcharge.
^^ See Special Conditions Section:
# The Greensboro Industrial Waste Section does not consider Flow to be a pollutant and
flow data is not considered to be a report.
C - Composite Sample [See Section II Part D for permit -specific definition]
G - Grab Sample
M- Monitoring Only [See Local Pollutant Allocation Document to determine if an
Allocation has been issued for this parameter]
September 1, 2018 Permit Renewal

Page 6, SIU Permit #P065
SHAMROCK BROWN SUMMIT
SECTION IV - SPECIAL PERMIT CONDITIONS
A. FLOW MEASUREMENT
Compliance with the flow limit in this permit shall be documented in the following manner:
1. The Permittee shall provide and maintain a refrigerated composite sampler and primary
flow measurement device for flow proportional sampling and flow measurement of the
permittee's process wastewater discharge.
2. The effluent process flow meter readings shall be recorded daily and the daily effluent flow
calculated in gallons per day. Flow measurement records shall be submitted to the City of
Greensboro Industrial Waste Section monthly. Data is to be submitted by the 15t' of each
month for the previous month's flow measurements.
3. The permittee shall maintain permanent flow records and maintenance and calibration
records on -site for a minimum of three years. These records shall be available to the City of
Greensboro Industrial Waste Section during inspections or upon request.
Immediate notification, within 24 hours of becoming aware of the problem, shall be provided
to the Pretreatment Coordinator [336-433-7227] or Pretreatment Compliance Specialist [336-
373-3285] by phone or e-mail for any periods in which the effluent meter is inoperable with
the exception of periods for maintenance/calibration. This notification shall include the
cause of the malfunction/failure, anticipated repair time and/or plan of action to allow the
permittee to comply with the requirement to record the flow meter readings daily.
5. Malfunction/failure of effluent flow meters that are used for sewer billing purposes shall also
be immediately reported, within 24 hours of becoming aware of the problem, to the Water
Resources Customer Service Division by phone ---Assistant Manager [336-373-4108] or
Manager [336-373-2639]. Failure to do so will result in the Industrial Waste Section and the Water
Resources Customer Service Division reverting back to the incoming water meter to determine
compliance and billing.
6. The wastewater meter must have a non-resettable totalizer that reads in cubic feet or gallons.
There shall be no by-pass capability of the wastewater metering devices and monitoring
point(s).
7. If the wastewater meter is being used for billing or compliance, it must have permanent flow
records (i.e. strip chart recordings) that include at minimum the following basic information:
date, time, totalizer reading (with units), interval flow volume (with units), maximum flow
rate (with units), and primary measuring device type. Any interruption in such records with
the exception of periods for maintenance/calibration are a violation of this permit and may
result in a civil penalty each day the interruption is allowed to continue.
September 1, 2018 Permit Renewal

Page 7, SIU Permit #P065
SHAMROCK BROWN SUMMIT
8. The wastewater meter shall have a back-up power source (battery or generator) to ensure
uninterrupted measurement of the discharge flow in the event of a power failure unless loss
of power automatically prevents any discharge from the facility. The back-up source shall
provide power to the wastewater meter's sensor and permanent flow records for a minimum
of 12 hours.
B. PERMITTEE SAMPLING AND MONITORING REPORT SUBMITTAL DATES
Permittee Sampling for the pollutant limitations in Section III (Effluent Limits and Monitoring
Requirements) of this permit shall be conducted in the following manner:
1. Samples for the January 1-June 30 Reporting Period shall ALL be taken during the months
of January, February and/or March. The compliance report shall be submitted on or
before APRIL 15 of each year.
2. If there are no discharges during months designated for sampling, the April 15 compliance
report shall be submitted with the notation "NO DISCHARGE/NO SAMPLING". If there is a
discharge after March and prior to June 30, self -monitoring is still required to meet the
permit monitoring requirements and that data shall be submitted with the corresponding
monthly flow data.
3. Samples for the July 1-December 31 Reporting Period shall ALL be taken during the
months of July, August and/or September. The compliance report shall be submitted on
or before OCTOBER 15 of each year.
4. If there are no discharges during months designated for sampling, the October 15
compliance report shall be submitted with the notation "NO DISCHARGE/NO SAMPLING".
If there is a discharge after September and prior to December 31, self -monitoring is still
required to meet the permit monitoring requirements and that data shall be submitted
with the corresponding monthly flow data.
If there are no discharges during an entire semi-annual reporting period, a letter must be
submitted to the Industrial Waste Section by July 15 or January 15 stating there was no discharge
and no sampling for that period. This letter must be signed and certified by the signatory official.
C. WASTE/WASTEWATER RECORDS
Shamrock Environmental shall keep records on all wastes/wastewaters brought on -site for
pretreatment and discharge. These records shall include:
1. A profile of each waste stream to include laboratory data from either the industry or
Shamrock. This profile shall be completed before any waste stream is discharged to the
City of Greensboro POTW.
2. Source of the waste including company name and address
3. Identity of the waste/wastewater constituents. This information should be verifiable
through laboratory data and documentation from contracted company.
4. Dates of: arrival, storage, treatment and discharge
5. Storage and treatment locations and all pretreatment processes employed by Shamrock
Environmental before discharge.
September 1, 2018 Permit Renewal

Page 8, SIU Permit #P065
SHAMROCK BROWN SUMMIT
6. Any laboratory analyses conducted on the waste/wastewater before and/or after
treatment.
7. ALL Subpart C waste streams shall be profiled for Ammonia. Any current Ammonia
Discharge SOP developed by the permittee and approved by the City of Greensboro is
hereby incorporated as a condition of this Significant Industrial User Permit.
D. TANKER WASH RECORDS
Should the tanker wash facility at Shamrock Environmental be used, Shamrock shall maintain
records of all "outside" tankers washed at the truck wash facility. These records shall include:
date and time of washout, product transported/washed from tanker and the initials of the
Shamrock employee who verified the information.
E. SIGNATORY REQUIREMENTS FOR INDUSTRIAL USER REPORTS
All self -monitoring and re -sampling data submitted for compliance to the City of Greensboro
shall include the certification statement below and shall be signed by the person on -site at the
facility who is authorized to represent the company in an official capacity concerning matters
that involve the City of Greensboro Industrial Waste Section ("Signatory Official").
1 certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible forgathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations. [40 CFR Part 403.6]
F. SLUG/SPILL CONTROL PLAN
The permittee shall provide protection from accidental and slug discharges of prohibited
materials and other substances regulated by this permit, which have a reasonable potential to
cause Interference or Pass Through, or in any other way violate the POTW's regulations, local
limits or Permit conditions.
The permittee shall notify the Industrial Waste Section immediately of any changes at its facility
affecting potential for a Slug Discharge.
The permittee shall submit a new or updated slug/spill control plan for approval when so
directed in writing by the City of Greensboro Industrial Waste Section. The plan shall contain, at
a minimum the following elements:
Description of discharge practices, including non -routine batch discharges;
Description of stored chemicals;
Procedures for immediately notifying the POTW of slug discharges that would cause a
violation of 40 CFR Part 403.5(b) [EPA Specific Prohibitions included in Greensboro SUO
Article II, Section 1. B.], with procedures for follow up written notification within 5 days;
September 1, 2018 Permit Renewal

Page 9, SIU Permit #P065
SHAMROCK BROWN SUMMIT
If necessary, procedures to prevent adverse impact from accidental spills, including
inspection and maintenance of storage areas, handling and transfer of materials, loading
and unloading operations, control of plant site run-off, worker training, building of
containment structures or equipment, measures for containing toxic organic pollutants
(including solvents) and/or measures and equipment for emergency response.
Any current slug/spill control plan developed by the permittee and approved by the City of
Greensboro is hereby incorporated as a condition of this Significant Industrial User Permit.
G. (1) WASTE/WASTEWATER RECEIPT CATEGORIZATION
When collecting, transporting, storing, treating and discharging wastewater, the Permittee shall
categorize wastewater according to the criteria in this section:
Metals Subcategory
Oils Subcategory
Organics Subcategory
Spent Electroplating Baths
Used Oils
Landfill leachate
Spent Electroplating Sludges
Oil -water emulsions or mixtures
Solvent -bearing wastes
Metal Finishing Rinse Water
Lubricants
Still bottoms
Metal Finishing Sludges
Coolants
Byproduct waste glycols
Chromate Wastes
Contaminated Groundwater clean-up
Contaminated Groundwater clean-up
from petroleum sources
from by non -petroleum sources
Air Pollution Control Blowdown
Used petroleum products
Off Specification Organic products
Water
Air Pollution Control System
Sludges
Oil spill clean-up
Wastewater from paint washes
Spent Anodizing Solutions
Wastewater from oil-bearing paint
Wastewater from adhesive or epoxy
wastes
formulations
Incineration Wastewater
Interceptor wastes
Wastewater from organic chemical
product operations
Cyanide Containing Wastes
Off -specification fuels
Tank clean out from organic, non-
>136 mg/1
petroleum sources
Waste Acids and Bases [with
Non -contact used glycols
metals]
Waste Acids and Bases [without
Tank clean -out from petroleum or oily
metals]
sources
Vibratory deburring wastewater
Aqueous and oil mixtures from parts
cleaning operations
Alkaline and acid solutions used
Rinse or wash water from petroleum
to clean metal parts or
equipment
sources
Cleaning, rinsing and surface
preparation solutions from
Underground storage tank remediation
electroplating or phosphating
wastes
operations
Waste Liquid Mercury
Bilge water
September 1, 2018 Permit Renewal

Page 10, SIU Permit #P065
SHAMROCK BROWN SUMMIT
G. (2) If wastewater is from a source that is not listed in the table above, then the following
criteria apply:
(a) If a wastewater contains oil and grease equal to or greater than 100 mg/l, then the
wastewater is in the Oils Subcategory
(b) If the wastewater contains less than 100 mg/1 of oil and grease and has any of the
following pollutants in the concentrations greater than the listed concentration in the
table below, then the wastewater is in the Metals subcategory:
Metal
Concentration
Cadmium
0.2 mg/l
Chromium
8.9 mg/l
Copper
4.9 mg/l
Nickel
37.5 mg/1
(c) If the waste receipt contains oil and grease less than 100 mg/l, and does not have
concentrations of cadmium, chromium, copper or nickel above any of the values listed
above, the waste receipt should be classified in the Organics subcategory.
(d) The criteria and information on subcategory determination are provided as guidance
in proper classification of wastes by subcategory. Where a waste is clearly described
as a specific subcategory waste in Section F. 1), it should be classified as such. If the
waste is not explicitly listed in Section F1, then Section F. (2) should be utilized to
subcategorize unless common sense and best professional judgment by the permittee
warrant classification in another more appropriate subcategory.
(e) For every wastewater shipment discharged by the Permittee, the Permittee shall
maintain records showing the basis for subcategorization.
H. PROHIBITED WASTEWATER
The Permittee may not discharge any wastewater that had a total cyanide concentration greater
than 5.0 mg/1 at the time of collection from the source, unless the Permittee segregates this
wastewater during collection and transportation and then removes and/or destroys the cyanide
before mixing with any other wastewater discharged to the POTW.
I. SEGREGATION OF WASTEWATERS
Throughout collection, transportation, storage, treatment and discharge the Permittee shall
completely segregate the Subpart C-Organic waste streams from the Multiple waste streams
wastewater [Subparts A & B - Metals Wastes and Oily Wastes].
September I, 2018 Permit Renewal

Page 11, SIU Permit #P065
SHAMROCK BROWN SUMMIT
J. DETECTION LIMITS AND MATRIX INTERFERENCES
Proof of efforts to resolve effluent sample detection limits reported higher than permit limits
issued herein [due to matrix interference] shall consist of the information included in "Chapter 1-
Checklist of Laboratory Data Required to Support a Claim that the Permittee was Unable to
Measure Pollutants Due to Matrix Problems" of EPA Guidance on Evaluation, Resolution and
Documentation of Analytical Problems Associated with Compliance Monitoring [EPA Publication 821-B-
93-001 June 1993]. All costs associated with the proof of matrix interferences, included any third
party review of the analytical data and supporting documentation, shall be the responsibility of
the permittee. This shall also include the costs for any additional procedures, analyses or data
review of samples collected by the City of Greensboro to determine compliance with the permit
limits issued herein.
K. SURROGATE PROCESS CONTROL SAMPLING
Chemical Oxygen Demand (COD) sampling shall be performed at least monthly for process control
and POTW loading estimations. COD analyses may be performed in-house or by a commercial
laboratory. If more than one COD analysis is performed in a calendar month, only the highest
COD value need be reported. The six monthly process control COD values shall be submitted to
the Industrial Waste Section by July 15 (for January through June) and by January 15 (for July
through December). All COD analyses shall be made available during inspections and upon
request by the IWS. Any COD value greater than 10,000 mg/l shall be immediately reported (within 24
hours of becoming aware of the result) to the City of Greensboro Industrial Waste Section. The notification
shall be made by telephone or email to the Pretreatment Coordinator, the Pretreatment
Compliance Specialist and/or the Laboratory and Industrial Waste Section Supervisor.
September 1, 2018 Permit Renewal

CITY OF GREENSBORO SIU PERMIT SYNOPSIS pats)
1
Receiving POTW
City of Greensboro T. Z. Osborne POTW
2
POTW NPDES #
NCO047384
3
Facility Name:
Shamrock Environmental -Brown Summit
4
SIU Permit Number & Pipe #
P065 Pipe 01
5
Permit Effective Date
September 1, 2018
6
Permit Expiration Date
August 31 2023
(7)
Subject to Federal Categorical
Pretreatment Standards?
40 CFR Part 437.46(c) Subpart D — Multiple
Wastestreams A & B -
8
Was CWF used?
No If yes, attach calculations
Rationale for SIU Permit Limits/Allocations
PARAMETER
PERMIT LIMITS
Daily Monthly 6-Month
Maximum Average Average
LOCAL POLLUTANT
ALLOCATION
6-Mo Avg %MAHL
RATIONALE
FOR LIMIT/
ALLOCATION
Flow(gal/day)
125,000
7
H units ran e
5.0-12.0
7
BOD
2000 m /I
<5
4
Suspended Solids
1000 m /I
<5
4
Cadmium total
0.10 m /I
0.050 m /I
<5
2
Chromium total
0.947 m /I
0.487 m /I
<5
1
Copper total
0.405 m /I
0.301 m /I
<5
1
Lead total
0.222 m /I
0.172 m /I
<5
1
Nickel total
3.95 m /I
1.45 m /I
<5
1
Zinc total
2.87 m /I
0.641 m /I
<5
1
Silver total
0.120 m /I
0.0350 m /I
<5
1
Cyanide total
0.50 m I
>10
2,3
CODE RATIONALE
1
LIMIT based on Federal Categorical Standard
2
Local LIMIT that is more stringent than Federal Categorical Standards -Established to
prevent over -allocation value based on actual industry data
3
Local LIMIT due to Loading of >9% MAHL — Limit: BPJ by POTW
4
Loca/Po//utantA//ocation—Loadin <9% MAHL — Allocation: BPJ by POTW
5
Loca/Po//utantA//ocation allocated at EPA/POTW published domestic values]*
6
No Limit or Allocation Established - <5% MAHL and not considered significant*
7
Other — (a) pH limit from 40 CFR Part 403.5(b)(2) and upper pH local limit of 12.0
(b) Flow limit based on historical data
c Other
*No POTW over -allocation of the pollutant and the loading of the pollutant from the IU is considered insignificant at this time.
This synopsis includes an SIU inspection Report and permit application/survey.

CITY OF GREENSBORO SIU PERMIT SYNOPSIS (Page z)
Shamrock Environmental P065 Brown Summit
Pipe 01-Effective September 1, 2018
Rationale for SIU Permit Limits/Allocations
PARAMETER
PERMIT LIMITS
Daily Monthly 6-Month
Maximum Average Avera e
LOCAL POLLUTANT
ALLOCATION
6-Mo Avg %MAHL
RATIONALE
FOR LIMIT/
ALLOCATION
Arsenic Total
0.162 m /I
0.104 m /I
N/A
1
Cobalt Total
0.192 m /I
0.124 m /I
N/A
1
Mercury Total
0.00234 mg/1
0.000739 mg/1
N/A
1
Antimony Total
0.249 m /I
0.206 m /I
N/A
1
Titanium Total
0.0947 m /I
0.0618 m /I
N/A
1
Tin Total
0.409 mg/1
0.120 mg/1
N/A
1
Vanadium
(Total)
0.218 mg/I
0.0662 mg/1
N/A
1
Bis(2-ethylhexyl)
phthalate
0.267 mg/I
0.158 mg/I
N/A
1
Carbazole
0.392 m /I
0.233 m /I
N/A
1
n-Decane
5.79 m /I
3.31 mg/1
N/A
1
Fluoranthene
0.787 mg/1
0.393 m /I
N/A
1
n-Octadecane
1.22 m /I
0.925 m /I
N/A
1

CITY OF GREENSBORO SIU PERMIT SYNOPSIS (2azs)
1
Receiving POTW
City of Greensboro T. Z. Osborne POTW
2
POTW N PDES #
NCO047384
3
Facility Name:
Shamrock Environmental Brown Summit
4
SIU Permit Number & Pipe #
P065 Pipe 02
5
Permit Effective Date
September 1 2018
6
Permit Expiration Date
August 31 2023
(7)
Subject to Federal Categorical
Pretreatment Standards?
40 CFR Part 437.35 Subpart C- Organics
8
Was CWF used?
No [If yes, attach calculations
Rationale for SIU Permit Limits/Allocations
PARAMETER
PERMIT LIMITS
Daily Monthly 6-Month
Maximum Average Average
LOCAL POLLUTANT
ALLOCATION
6-Mo Avg %MAHL
RATIONALE
FOR LIMIT/
ALLOCATION
Flow(gal/day)
150,000
7
H units ran e
5.0-12.0
7
BOD
2000 m /I
<5
4
Suspended Solids
1000 mg/1
<5
4
Cadmium total
0.01 m /I
<5
4
Chromium total
0.40 m /I
<5
4
Copper total
0.85 m /I
<5
4
Nickel total
0.40 mg/1
<5
4
Lead total
0.40 m /I
<5
4
Zinc total
2.9 m /I
<5
4
Silver total
0.40 mg/1
<5
4
Cyanide total
0.1 m 1
<5
4
Ammonia
70 mg/1
<5
4
Total Phosphorus
19.71 m /l
<5
4
CODE RATIONALE
1
I LIMIT based on Federal Categorical Standard 40 CFR Part 437.35
2
Local LIMIT that is more stringent than Federal Categorical Standards -Established to
prevent over -allocation value based on actual industry data
3
Local LIMIT due to Loading of >9% MAHL — Limit: BPI by POTW
4
Local Po//utantA//ocation—Loadin <9% MAHL — Allocation: BPI by POTW
5
Local Po//utantA//ocation allocated at EPA/POTW published domestic values]*
6
No Limit or Allocation Established - <5% MAHL and not considered significant*
7
Other — (a) pH limit from 40 CFR Part 403.5(b)(2) and upper pH local limit of 12.0
(b) Flow limit based on historical data
c Other
*No POTW over -allocation of the pollutant and the loading of the pollutant from the IU is considered insignificant at this time.
This synopsis includes an SIU inspection Report and permit application/survey.

CITY OF GREENSBORO SIU PERMIT SYNOPSIS (Paget)
Shamrock Environmental Brown Summit P065 Pipe 02-
Effective September 1, 2018
PARAMETER
PERMIT LIMITS
Daily Monthly 6-Month
Maximum Average Average
LOCAL POLLUTANT
ALLOCATION
6-Mo Avg %MAHL
RATIONALE
FOR LIMIT/
ALLOCATION
o-Cresol
1.92 mg/I
0.561 mg/I
N/A
1
-Cresol
0.698 mg/1
0.205 mg/1
N/A
1
2,4,6-Trichloro henol
0.155 mg/I
0.106 mg/I
N/A
1

PERMIT WRITERS NOTES: FOR PIPE 01 AND PIPE 02
1. This facility combines Subpart A and Subpart B wastestreams for
pretreatment and discharges the combined treated wastestreams through
Pipe 01. Thus the discharge standards are taken from Subpart D Multiple
Wastewaters in 40 CFR Part 437.
2. Pipe 02 discharge standards come from Subpart C: Organics Treatment &
Recovery
3. Although Greensboro has issued several bubble permits, this facility can
never be bubbled due to the different Categorical standards for each pipe.
4. The solidification process was moved from the Shamrock II -Patton Avenue
facility to this location in 2017.
5. This facility has an effluent meter that is used for billing and compliance.
Although Greensboro does not encourage the use of effluent metering, it is
imperative for this facility to have one since most of their flow volume has
been brought on -site and would not be measured through the incoming
potable water meter.
6. Due to the nature of this type of facility, the permit contains several unique
site -specific special conditions (ammonia profiles, wastestream profiles, in -
plant wastestream tracking, etc.)
7. Currently each pipe has a dedicated sludge press and return wastewater from
each pipe is segregated. The facility is considering installing one larger
sludge press and the permit will be modified accordingly at that time to
specify the treatment train for that single wastestream.
8. North Carolina has only a few Centralized Waste Treatment plants and there
is a benefit to the pretreatment program and POTWs to have a CWT locally
available to treat the most difficult to treat wastestreams. This facility also
provides emergency response to spills, operational staff for pretreatment
processes, and conducts waste solidification processes.