NC0004375_More Information (Received)_20010204

NPDES DOCUMENT SCANNING COVER !;I1EET
NPDES Permit:
NC0004375
Clariant Corporation
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Additional Information Received
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 4, 2001
This document is printed on reuse paper - ignore arty
Content on the reYerse side

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Clariant
February 4, 2001
Mr. David A. Goodrich
NPDESnit- Supervisor
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
li r_ -LT tg,___u ‘,ri
FEB 122001
PO NT SOURCE
Re: NPDES Permit Number NC0004375; Clariant Corporation - Mt. Holly Plant
Facility Revisions
Dear Mr. Goodrich;
As mentioned in my September 5, 2001 letter, the Mt. Holly Plant is in the process of
reducing manufacturing operations significantly. The shutdown and decommissioning of
chemical processes is almost complete. This work is expected to be finished by the end of April.
The reduction in dyestuff and organic chemical synthesis operations will ultimately idle
65% of our reaction equipment. Finishing operations reductions will idle 50% of the equipment
in that service.
Revisions and capacity reductions in steam generation and compressed air systems are
currently under construction. The smaller size utilities units are planned for start up by May 1,
2001.
The scale back in site operations will reduce OCPSF contribution to the wastewater
treatment plant, WWTP. We estimate a BOD loading_reduction of approximately 47% and an
OCPSF flow rate drop of roughly 42%.
After careful study, we have elected not to make modifications in the WWTP. This is
because we wish to replace the decommissioned manufacturing loads with other loads. There
are three sources of raw wastewater we wish to introduce into the WWTP.
1. Off -specification Clariant OCPSF products and intermediates destined for
disposal from other Clariant sites
2. Charlotte Mecklenburg Utility Department, CMUD, domestic wastewater
3. OCPSF wastes and wastewater from other industrial sites in the southeast and
possibly wastewater from oils treatment and recovery operations from the area

Mt. Holly Plant Facility Revisions Letter of February 4, 2001 page 2
By replacing wastewater loading with these other materials and sources we can operate
the WWTP near its designed economic capacity. This will greatly help us to competitively
operate our remaining manufacturing operations, by recovering a significant portion of the
WWTP operating costs.
Because it will take time to perform treatability work to assess WWTP performance and
operating parameters with each additional influent stream, and because modifications to the
NPDES permit are part of the process, full implementation of our plan at the operational level is
expected to take many months. We therefore respectfully request thatthe Division not reduce
the ann_j_t_teddiapharge flow and monitoring teeters based on our decreasing_manufacturng
volume, but instead allow us sufficient time to submit a permit_modif cation for the planned
operation.
"'4.
,c , should not trigger a modification to the NPDES permit. Some of the details of the proposed
operation are enclosed. More detailed information will be forwarded to the Division in March.
We wish to begin introducing off -specification products and materials from other
Clariant OCPSF locations as soon as possible. We believe this addition is a minor one that does
not pose a measurable operating impact. Other Clariant sites currently send these materials to
disposal companies for solidification and landfilling. We believe the alternative of thorough
treatment in a well operated biological treatment system represents significant improvement in
good environmental stewardship. We propose to begin this work as soon as possible without
modification of the NPDES permit. The planned disposal process will simply be "in -kind"
replacement of wastewater volume from scaled back operations. We believe the minor change
Treating CMUD domestic wastewater and additional industrial source wastes are larger
initiatives. We believe a modified NPDES permit is likely to be needed for CMUD wastewater
inclusion in Clariant's WWTP. Treatment of additional industrial source OCPSF wastewater is
planned as in_kind"replacement of volume from scaled back manufacturing. We do not believe
they should require a permit modification, but request interpretation from the Division.
( We are also investigating treatment of oil treatment and recovery wastewater from
sources in North Carolina and South Carolina. We believe influent from these sources would
possibly require permit modification in accordance with 40 CFR part 437.42. We also believe
treatment of these materials will require new primary treatment processing in accordance with 40
�CFR part 136.VIII.A.4 and part 136.VIII.A.2.
Clariant continues to work with CMUD regarding treatment of 2.0 MGD of their
domestic wastewater. Treatability work done by Brown and Caldwell this past summer,
indicates that the WWTP will perform extremely well on the combined wastewater. Clariant and
CMUD will be visiting the Division in mid February to discuss permitting issues this will trigger.
Finally, with respect to treating wastewater and off -specification chemicals from other
industrial entities in the southeastern region of the United States, we plan to do marketing

Mt. Holly Plant Facility Revisions Letter of February 4, 2001 page 3
research and treatability studies during the next six months and present the Division with a
thorough plan by August 2001.
We have enclosed a proposed water balance diagram of the WWTP based on inclusion of
all three new streams. A brief description of each planned waste stream is also enclosed.
If you have any questions, comments, or need additional information please feel free to
call me at [phone]. My email address is [e-mail]. If a meeting
would be beneficial, we are at your service. Thank you for your help and advice.
Sincerely;
Gary P. Sanderson, P.E.
Plant Services Manager

Description of Planned Additional Waste Steams Treatment
1. Clariant off -specification products and materials (only OCPSF chemicals)
The site will review Clariant data and MSDS of each off-spec./surplus chemical material for
biodegradability and compatibility in the WWTP. Once the site approves a material, we will
notify the other Clariant site of quantities and packaging requirements for shipment. At receipt,
each incoming shipment will be checked against the approved quantity and product name. Any
nonconformance will result in return of the shipment to the sender.
Every two days, a prescribed amount of waste material will be mixed with water in our dye
manufacturing plant to produce a 10,000 gallon batch with known BOD quantity. The batch will
be sewered at a calculated rate so as to maintain a constant BOD influent rate to the WWTP. As
the material exits the tank it will be mixed with a constant 50 gal/min water stream and
introduced into the site sewer.
The anticipated volume of surplus materials is 600,000 pounds annually. Influent volume to the
WWTP is estimated to be 0.03 MGD.
2. Charlotte Mecklenburg Utility Department, CMUD, domestic sewage
CMUD will pump a constant 2.0 MGD of domestic sewage to the Clariant head works from its
pump station located on Long Creek. Clariant will install grinding and grit removal facilities for
the wastewater. All flow will be mixed with Clariant wastewater and introduced into pond Z-
03A for biological treatment.
After discharge from the secondary clarifiers, all site effluent will be disinfected using UV
technology.
2. Wastes and wastewater from other industrial sites in the southeast
A. OCPSF wastes and wastewater
Clariant will solicit treatment business from selected industrial customers. Waste materials
volume will be quantified and each material will go through a battery of tests to assess
biodegradability, pH, and other specific characteristics. Administration of inventory, batch
dilution system, feed rate into the WWTP, etc. will be identical to Clariant only waste.
This waste stream is a filler material for the WWTP; not a major contributor or continuous
un-interruptable source. It will be fed into the WWTP to maintain total plant influent BOD
balancing and consistent organic chemical feedstock for the biological system. We will also
use it as BOD source during low manufacturing volume periods.
The anticipated volume from this source is estimated at 5,000,000 pounds annually.
Influent volume to the WWTP from this source is estimated at 0.08 MGD.
B. Oil recovery and treatment wastewater
Clariant will solicit wastewater treatment business from petroleum transfer stations and
other petroleum handling businesses. We do not plan to enter the petroleum recovery
business, only to treat wastewater from entities engaged in petroleum handling.

Description of Planned Additional Waste Steams Treatment page 2
As with OCPSF wastewater from customers, this waste stream is a filler material for our
WWTP. Waste materials volume will be quantified and each material will go through a
battery of tests. Administration of inventory, feed rate into the WWTP, etc. will be identical
to that discussed in 3.A.
This waste stream is a filler material for the WWTP; not a major contributor or continuous
un-interruptable source. Depending on availability and profitability of this influent material
versus OCPSF influent material, the Mt. Holly Plant will treat this material or OCPSF
material.
The two influent streams will be handled in parallel, but managed such that total influent
volume of the combined sources is maintained at or below 0.08 MGD, as discussed in 3.A.

LJ
A
REv.
10
co
co
SOLICITED
DISPOSAL MATERIAL
(PROPOSED)
CMUD
(PROPOSED)
PRODUCTS
(88)
ALKALINE ACID
SEWER SEWER
20001
CLARIANT OFF —SPEC.
MATERIALS
(PROPOSED)
30A
GROUND WATER
REMEDIATION
RCRA 120
CERCLA 30
DYES
MANUFACTURE
45(1_.
SPECIAL CHEM.
MANUFACTURE
90
NON CONTACT
COOLING
^— EVAPORATION 45
105
STEAM
GENERATION
75
STORM
WATER
225
SANITARY WASTE 27
CITY OF CHARLOTTE
POTABLE WATER
WATER
TREATMENT
FILTER BACKWASH 65
NOTE:
FLOW FROM THE THREE SOURCFS AT THE
TOP LEFT ARE PROPOSED. ALL OTHERS
ARE BASED ON EXISTING OPERATIONa
OR PLANNED SHUTDOWNS.
NEUTRALIZATION
STORM FLOW
NEUTRALIZATION
STORM FLOW
STORAGE
PRIMARY
CLARIFIERS
SLUDGE
FILTRATION
SLUDGE
LANDFILL
STORM FLOW
STORAGE
1/19/01
DATE
952 WATER INTAKE
PROJECT NO.
DH
DRAWN
CHECKED
APP.D.
SETTLING
CANAL
STORAGE
65
198
EVAPORATION
ACTIVATED
SLUDGE
ACTIVATED
SLUDGE
1
T
CATAWBA RIVER
7 .d1 3'f i)
7
[ISSUED FOR COMMENTS
FLOW
THIS DRAWING IS A PRNATE AND CONFlDENNL COMMUNICATION AND THE PROPERTY OF CLARIAM CORPORATOR;
MT. HOLLY PLANT. R MUST NOT BE COPED OR LOANED WITHOUT THE CONSENT OF CLARNNT CORPORATION. MO
MUST BE PROMPTLY RETURNED ON REQUEST OR COMPLETION OF ORDER. TIS DRAWING HAS SEEN CREATED WITH
6111.4Ca% CO NOT MANUALLY DRAFT ON THIS COPY.
D. - CT ENGINEER
APP'D. AMMTENANCE
P
ROVED BY
DATE
DATE
RATE
DA
AA' D. RAN NAT'LI SE
APP'D. UTIJITES
4.0pRav133 BY
DATE
DATE
APPROVED BY
FEE ,MAIL
83420100
PLOT SCALE RATIO
1=1
DA
DATE
SECONDARY
CLARIFIERS
POLISHING
POND
POLISHING
POND
POST
AERATION
EFFLU ENT
METERING
3,101
116'Clariant
Mt. Holly Plant, P.O. Box 889248, Charlotte. North Carolina 28268
TALE
DEPARTMENT 50
PROCESS FLOW DIAGRAM
WATER FLOW SCHEMATIC — PROPOSED
NPDES PERMIT NC0004375
NONE
SHEET NO.
1 OF 1
Ve0.53.050.01.8342
REv` Ne.

Nitrate -Nitrite, mg/L
Combined CMU / Clariant Pilot Unit - Nitrate / Nitrite Removal
7/10/2000
Date
F - • - - Nitrate -Nitrite -in ■ Nitrate -Nitrite -out
8/21 /2000 9/4/2000
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

CiAr)
E
Combined CMU / Clariant Pilot Unit - TKN Removal
Date
- - + - - TKN-in —•— TKN-out
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

{_P6
140
120 -
100
t 80
60
40 -
20 -
•
0
6/26/2000
Combined CIVIU / Clariant Pilot Unit - Ammonia Removal
7/10/2000 7/24/2000
Date
8/7/2000
1
I
1
I
I 1
- - + - - NH3-in ■ NH3-out — A- - TKN-in
•
8/21/2000 9/4/2000
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

Combined CMMMU / Clariant Pilot Unit - TSS Removal
Date
- - + - - TSS-in —•--- TSS-out
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

1200 -
1000 -
O
800 -
Combined CiVIU / Clariant Pilot unit - COD Removal
7/10/2000
ft
-ffrk\<
7/24/2000
Date
8/7/2000
- - COD -in —• SCOD-out
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc
8/21/2000
9/4/2000

•
Combined CMU / Clariant Pilot Unit - BOD Removal
350 -
300 -
250 -
200 -
0
150 -
•
100 -
50 -
•
♦'
•
i
♦
•
0
6/26/2000 7/10/2000
9
s
•
•
•
1
7/24/2000 8/7/2000 8/21/2000 9/4/2000
Date
- - • - - BOD-in ■ SBOD-out

Schedule for Clariant / Charlotte -Mecklenburg Combined Treatment Project
Task No.
Task Description
2001
2002
Feb.
March
April
May
June
July
August
Sept.
Oct.
Nov.
Dec.
Jan
Feb.
March
April
1
1.1
1.1.1
1.1.2
1.1.3
1.1.4
1.1.5
1.1.6
1.1.7
1.1.8
1.1.9
1.1.10
1.2
1.3
1.4
2
2.1
2.2
2.3
2.4
2.5
2.6
3
3.1
3.2
3.3
3.4
3.5
4
4.1
4.2
4.3
5
5.1
5.2
5.3
5.4
Permits
NPDES Permit Modifications
Meeting with NC DENR
NPDES Permit Negotiations
Clariant Files Permit Modifications
Public Hearing
ND DENR DWQ Permit Review
Draft NPDES Permit Issued
Clariant Comment Period
Clariant Comments Issued
NC DENR Reviews Comments
NPDES Permit Modifications Issued
EA - FONSI Ruling
Authorization to Construct
Building Standards
Design of Modifications
Disinfection - UV Tests
Preliminary Design (Procurement Grade)
Preliminary Design Report Issued
Review of Preliminary Design Report
Final Design (Including Long Creek Design Modifications)
50% Review
90% Review
Final Design Complete
Clariant / Utilities Contract Negotiations
Negotiations
Draft Contract
Review / Comment Period
Sign / Execute Contract
Signed Contract
Pre -Purchase of Disinfection Equipment
Specify Equipment
Bid / Purchase Equipment
Equipment Fabrication
Construction
Bid
Review / Award of Bid
Construction
Start -Up
1
_
C
❑
[.
❑
MIMI
19047/ADM/Proposed Phase II schedule

•
LONG CREEK
BASIN SEWER
CLARIANT WWTP i--al
300 MC STORAGE \
RESERVOIR
CATAWBA RIVER
CHARLOTTE MECKLENBURG
UTILITIES DEPARTMENT
—1111 McALPINE CREEK WWTP
E70STrrIC
PAW CREEK
PUMP STATION
f
LAKE WYLIE
BROWN AND
CALDWELL
LIE IS 2 INCHES
AT FULL SIZE
OF NOT Y-SCALE ACCORDINGLY)
SUBMITTED:
APPROVED:
APPROVED:
NMMO GLOOM
DATE
DAZE:
DATE:
FTIE CMUD\19047\CAD
DRAWN J PORTER
DESIGNED P SCHULER
CHECKED P SCHULER
cHEcKED _ R CARRIER
REVISIONS
ZONE REV.
DESCRIPTION BY DATE APP.
CLARIANT CORPORATION
CLARIANT
WASTEWATER TREATMENT FACILITY
IMPROVEMENTS
CMU / CLARIANT COMBINED WWTF
LONG CREEK BASIN PFD
PROJECT NUMBER
19047
CRANING NUMBER
SHEET NUMBER

State of North Carolina
Department of Environment,
and Natural Resources
Division of Water Quality
Michael Easley., Governor
William Ross, Jr., Secretary
Kerr T. Stevens, Director
MEMO
To: Mike Parker
Mooresville l gional Office
From: Bill Mills
Stormwaterneral Permits Unit
A7:5‘A
•41f011
DE N R
Subject: Clariant Corporation
Proposed Diversion of Stormwater to NCS000037
Mount Holly Plant
Mecklenburg County
eTO'n Oti
Clariant has proposed to eliminate some of the industrial activities at the Subject plant and render
some areas no subject to Stormwater NPDES. Other areas of the facility are presently draining
their storm runoff into the wastewater treatment plant and the stormwater from these areas are
proposed to be diverted to the surface waters directly and included in the existing NPDES
stormwater permit NCS000037. The details of their plans are shown on the attached submittal.
I would appreciate your regional office perspective on this proposed modification to their permit
and drainage regime. Given the travel restrictions we are faced with, I would not expect to make a
trip down to Clariant but if you plan a site visit please let me know of the date so that I can
consider it should I be in the area on other matters.
Thanks for your help. (I am keeping the original of the narrative but the drawings are the only set
they provided, I will need them back).
Attachments
Dave Goodrich
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

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Clariant
January 5, 2001
N.C. Deparment of Environment and Natural Resources
Division of Water Quality
Stormwater Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Certified Mail
Z 176 553 628
JAN 1 1 2001
RE: Conversion of Combined Sewer Lines (Process Sewer/Storm Sewer) To
Stormwater Only Sewer Lines
Clariant Corporation — Mount Holly East Plant
Stormwater Discharge Permit Number NCS000037
Dear Mr. Mills:
Clariant Corporation's Mount Holly East plant has an individual stormwater discharge permit
(NCS000037), which allows it to discharge stormwater to two surface water bodies, Long Creek
and the Catawba River. The stormwater outfalls covered in Clariant's stormwater discharge
permit flow to both of these two surface water bodies.
However, for a majority of the developed portion of the site (particularly where industrial
activity occurs), stormwater does not enter catch basins or drainage features which lead to
surface waters. Rather, the stormwater flows to Clariant's on -site wastewater treatment system
where it is aerobically treated and eventually discharged to the Catawba River. Most of the
storm sewer lines in the developed portion of the site are actually combined sewers which carry
process/sanitary wastewaters and stormwater. All of these combined -flow lines lead to the
plant's on -site wastewater treatment system. Consequently, most of the stormwater runoff from
the site is actually treated in an aerobic wastewater treatment system instead of flowing directly
to a surface water body.
Currently, Clariant has plans to downsize the Mount Holly East manufacturing site, and this
includes a plan to downsize the on -site wastewater treatment system. Because of this, Clariant
will need to reduce the volume of stormwater entering the treatment system. The downsized
wastewater treatment will not be able to adequately handle to hydraulic loading contributed by
the current volume of stormwater.
Therefore, Clariant will need to divert some of the stormwater currently entering its wastewater
treatment system to Long Creek and to the Catawba River.

Essentially, Clariant plans on accomplishing the diversion by converting the combined sewers
described above to "stormwater only" sewers. After the mothballing of affected manufacturing
buildings and, in some cases, the demolition of some manufacturing buildings, there will no
longer be process wastewater flow in the combined sewer lines. The only flow through these
lines would be stormwater runoff
Clariant would investigate the lines to assure that there are no illicit discharges in the lines slated
for conversion to storm sewers. We would not expect there to be any of these types of
discharges since the mothballing of the buildings would involve actually disconnecting water
supply and power supply from the buildings. We would then begin the cleaning of the diverted
sewer lines.
Because these combined sewers formerly handled process waste, Clariant has proposed a
rigorous cleaning protocol before the conversion takes place. Furthermore, part of this cleaning
protocol is also verification of cleanliness for sewer piping and junction boxes. This verification
is essentially a sampling of the rinsate from the cleaning operations. The cleaning protocol
requires that the concentration of constituents in the rinsate be below the site's RCRA permit
groundwater protection standards. Attached is a comparison of Clariant's groundwater
protection standards to the Safe Drinking Water Act's Maximum Contaminant Levels (MCL's).
As you can see, Clariant's groundwater protection standard concentrations are less than or equal
to the MCL's (with the exception of p-dichlorobenzene). A copy of the sewer cleaning protocol
is also attached as a separate document.
For the purpose of simplicity, there will basically be two (2) main diversions: one on the eastern
side of the site and one on the northwestern area of the site. The enclosed drawing. shows the
details of the diversions. The Eastern diversion will involve the most linear feet of sewer line
conversion. These sewer lines now serve as combined sewers to carry process waste and ..
stormwater to the on -site wastewater treatment system. The Northwestern diversion will involve
substantially less sewer conversion. These sewer lines now serve mainly to carry stormwater
and boiler blowdown water to the on -site wastewater treatment system.
As shown on the attached drawing (Area 2 — Drawing Number 38081102), the Eastern diversion
calls for breaking the combined sewer lines coming from the former production buildings 39, 40,
and 46. These broken lines would be tied in to newly added junction boxes and ultimately re-
routed to the current stormwater Outfall 3F. Outfall 3F discharges stormwater to Long Creek.
After this diversion has been made, Clariant plans to re -sample Outfall 3F and analyze the
stormwater run-off for those parameters analyzed for in the original sampling of this outfall. The
results of this sampling will be submitted to the Stormwater Section with the appropriate
documentation when it becomes available. The Outfall 3F sampling will be done after all of the
demolition and sewer re-routing have been completed. The estimated time schedule for the re -
sampling is late 3" Quarter 2001.

Essentially, the eastern portion of the plant site will become inactive. The production buildings
and warehouses in this portion of the plant will be either "mothballed" or razed. Since industrial
activity will no longer be occurring in this area of the plant, three (3) currently permitted
stormwater outfalls (Outfalls 3A, 3B, and 3C) will need to be removed from the permit. Outfalls
3D and 3F will need to remain a part of the permit because industrial activity will continue to
occur in areas draining to these outfalls.
The Northwestern diversion (Area 1— Drawing Number 38081101) calls for re-routing all
sanitary and boiler blowdown flow to a different alkaline process sewer line to the south of
Building 1. After the re-routing of the sanitary/boiler blowdown flow, the only thing remaining
in the sewer lines north of Building 1 will be stormwater flow. Therefore, this line will be
broken and diverted to the Catawba River as shown in the attached drawing. This will create a
new stormwater outfall which discharges to the culvert system in the northwest corner of the site.
Although the Boiler Room and Fuel Tank in this area will still be operational, all of the
stormwater drainage from these areas will flow to the site's wastewater treatment system. The
fuel truck unloading area and the fuel tank containment dike both drain to the site's wastewater
treatment system.
Since there will be no industrial activity in the area draining to the newly created outfall, Clariant
does not intend to include it as part of the stormwater permit modification. Therefore, no
sampling of this outfall is planned.
The demolition work will probablytake place in late spring 2001. The sewer diversion project
will take place after the demolition/mothballing described above has been completed.
Clariant would like to make these changes to its Stormwater Discharge Permit after all of the
proposed storm sewer modifications have been made. We would also like to know if the
Stormwater Section has any problems or suggestions with the proposed actions described above.
We are available to meet with you to discuss these proposed modifications at your convenience.
The Section is also welcome to visit the site to take a look at the proposed modifications
described above.
Should you have any questions or need any additional information, please call me at (704) 822-
4485.
Sincerely,
Victor B. Ethridge
Senior Environmental Chemist

Process Sewer System Cleaning Protocol
The purpose of sewer clean -out procedures is to remove residual materials which could be
sources of releases to soil, groundwater or surface water if left in place. Because the sewers are
gravity drained, low points where large volumes of raw wastewater could be held are not
anticipated. Water rinsing will be used to remove water-soluble residuals. Non -water soluble
residuals will be removed by rinsing at a sufficient velocity to mobilize solid depositions out of
the sewer segment being converted to stormwater sewers.
The diversity of sewer materials of construction, piping configurations and length/slope of sewer
runs requires a variety of sewer component clean -out procedures. Clariant reserves the right to
substitute equally effective procedures for sewer cleaning. Selection of cleaning methods will be
made based on the methods ability to meet criteria presented below.
Sewer components will be cleaned from junction box to junction box working from upstream to
downstream.
Clean -out procedures must meet the following criteria:
Criterion 1: The entire length and cross-section of a line must be rinsed at least once;
Criterion 2: Accumulated solids must be removed;
Criterion 3:
Criterion 4:
Junction boxes must be emptied of liquids and solids and triple -rinsed
with fresh water, preferably under high pressure: and
Clean -out will be complete when the above criteria have been met and the
concentrations of VOCs (Method 8260), SVOCs (Method 8270) and
metals (Table 1-3) in a grab sample of wash water and junction box rinsate
are below GWPS listed in Table VI-1 of the RCRA permit.
For the purposes of cleaning, an empty junction box will be a box which has had free liquids
removed to the extent possible by pumping. An empty sewer section is a sewer line which has
been gravity drained of liquid.
I
JAN 1 1 2001

Comparison of Clariant's HWM Permit Groundwater Protection Standard Contaminant
Concentration Limits to the Safe Drinking Water Act's Maximum Contaminant Levels
Clariant HWM
Permit
SDWA
Groundwater
Maximum
Protection
Contaminant
Standard
Levels
Contaminant Name
(ug/L)
(ug/L)
o-Dichlorobenzene
600
600
m-Dichlorobenzene
600
N/A
p-Dichlorobenzene
600
75
Chlorobenzene
50
100
Ethylbenzene
700
700
Toluene
1000
1000
Xylene
10000
10000
Benzene
5
5
Acetone
100
N/A
Tetrachloroethene
5
5
p-Benzoquinone
10
N/A
4-Nitrophenol
50
N/A
Aniline
10
N/A
Chloroaniline
10
N/A
Cadmium
5
5
Chromium
100
100
Cobalt
70
N/A
Lead
15
15
Nickel
100
N/A
Vanadium
20
N/A
Cyanide
200
200
Copper
100
1300
Iron
300
N/A
Manganese
50
N/A

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
January 5, 2001
Mr. Gary P. Sanderson
Clariant Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
A7A
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit NC0004375
Clariant Corporation/Mount Holly Plant
Mecklenburg County
Dear Mr. Sanderson:
The Division has reviewed the letter describing the future activities at the Clariant Corporation's Mount
Holly Facility. The Division agrees that a NPDES permit modification and Authorization to Construct is required.
The Division suggests a modification to the existing NPDES permit rather than applying for a new NPDES
permit. Based on the information provided, the Division could not determine if a major or minor modification is
appropriate. As long as the activity will not result in an increase in flow or a change in the wastewater characteristics,
a minor permit modification is appropriate.
For a minor permit modification, a letter detailing the proposed activities and the requested changes to the
permit should be submitted to the NPDES Unit at the address listed below.
The Authorization to Construct required for the modifications to the treatment system requires that detailed
plans and specifications (stamped by a PE registered in North Carolina), along with design calculations be submitted
in triplicate. In addition, 3 copies of the following are required: a letter describing the project, flow schematic and
construction sequence. The information listed above should be submitted to the NPDES Unit at the address listed
below.
If you have any questions concerning, please contact Michael Myers at telephone number [phone],
extension 508.
Sincerely,
David A. Goodrich
NPDES Unit Supervisor
cc: Central Files
Mooresville Regional Office/Water Quality Section
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer
VISIT US ON THE INTERNET CAP http://h2o.enr.state.nc.us/NPDES

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Clariant
September 5, 2000
wR'
r. Kerr T. Stevens
Director
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ti
.SEP 1 + 2000
DIV. OF WATER QUALITY
DIRECTOR'S OFFICE
Re: NPDES Permit Number 0004375; Clariant Corporation - Mt. Holly Plant Facility
Revisions
Dear Mr. Stevens;
This is to notify the Division that Clariant Corporation is reducing certain manufacturing
operations at the Mt. Holly Plant this year. Operations shutdowns are occurring in a staged fashion
between late August through year end. Roughly 50% of the site's organic synthesis and dyes
finishing capacity will be decommissioned. By early 2001, the site will have reduced infrastructure
size and capacity as well.
Engineering, construction/decommissioning, and operating details are currently underway.
Cessation of manufacturing operations will occur more quickly than associated shrinkage of
infrastructure facilities.
Preliminary engineering studies indicate that 40 — 53% of the BOD loading of the site
wastewater treatment plant, (WWTP), will be eliminated. Production and infrastructure related
wastewater flow is estimated to decrease between 42% and 50%. Storrnwater, RCRA, CERCLA
and other non -production related flows will not be affected.
The WWTP primary and secondary treatment systems are currently larger than will be
necessary for the anticipated future load. We therefore wish to make several modifications in the
primary and secondary treatment systems to improve WWTP operating efficiency and decrease
operating costs. Engineering design and operating details of the revisions are underway and will be
completed within the next 30 days.
While modifications will not be large in scope or cost, we believe that an Application for
Authorizations to Construct may be required; 15 NCAC 2H.0138(b). oi•
We also believe the changes in manufacturing and infrastructure operations may require
Clariant to submit a new NPDES permit application to the Division, 40 CFR 122.62 (a)(1).
459

Mt. Holly Plant Facility Revisions Letter of September 5, 2000 page 2
Realizing that the foregoing information is general in nature, we would appreciate a
determination by the Division as to whether such submittals are required. If the Division agrees that
a NPDES permit application and Application for Authorizations to Construct are required, would
you please forward the appropriate forms to the following address.
Gary P. Sanderson, P.E.
Clariant Corporation — Mt. Holly Plant
P.O. Box 669246
Charlotte, North Carolina 28266-9246
If you have any questions or comments, please feel free to call me at [phone]. If a
meeting would be beneficial, we are at your service. Thank you for your help and advice.
Sincerely;
4)ty
Gary P. Sanderson, P.E.
Plant Services Manager
cc: Mr. David A. Goodrich, NCDENR
Mr. Edward Pyles, Director — TLP Operation
Mr. Daniel Trueman, Mt. Holly Plant Manager