NC0004375_More Information (Received)_20010810

NPDES DOCUMENT SCANNING: COVER MEET
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
4
Additional Information Received
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
August 10, 2001
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Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Clariant
August 10, 2001
Mr. David A. Goodrich
NPDES Unit Supervisor
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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Re: NPDES Permit Number NC0004375; Trial Period for Treatment of Solicited
Industrial Wastewater from Selected SIC Customers
Dear Mr. Goodrich;
This is a follow up to my letter of June 14, 2001. Mr. Michael Myers and I have
discussed the proposal of June 14th and have left each other several phone messages relative to
the subject. Mr. Myers left a phone message on August 3rd letting me know that you and he had
discussed Clariant's proposal and that the Division was in agreement that Clariant could proceed,
on a trial basis, with treatment of non -hazardous industrial wastewater from third party sources.
I am writing to confirm our treatment plans for the trials beginning later this month. If
there are any concerns or requirements, please let me know. We have every intention of
complying with interim measures applicable to this plan.
Clariant will begin receiving truckload shipments (4,000 to 5,000 gallon loads) of
targeted and carefully selected OCPSF wastewaters that are similar to our influent. Receipts will
be thoroughly tested and profiled prior to shipment. Shipments will only be accepted Monday
through Friday between 7:00 a.m. and 6:00 p.m.
We will accept wastewater from manufacturing sites in SIC codes 2865 and 2869, and
that is compatible with our existing wastewater treatment plant biology and pretreatment
systems.
Based on discussions with several waste brokerage companies in North Carolina, we
believe the influent volume from outside sources will be in the range of 5,000 — 30,000 gallons
per day. This is roughly 1.75% of current WWTP throughput. We do not anticipate the
relatively small flow or organic loading to have an impact WWTP performance.
We propose to conduct the trials throughout the remainder of this year. We shall keep
thorough records that will include generator name and location, SIC number, shipment date,
shipment volume, time received, waste profile number, and any specific pertinent comments.

Letter of August 10, 2001 to Mr. David Goodrich page 2
I propose sending the Division this data along with a treatment system performance
analysis in early February. This is meant to provide the Division the needed information to
evaluate Clariant's performance and management system. It will also give Clariant valuable
experience in fine-tuning the administrative and operational processes.
Unless there are regulatory prohibitions, which to -date we have not discovered, we wish
proceed with application of a permit revision to include treatment of off -site wastewater.
Probably in the first half 2002. I would like to propose we meet in March with you and members
of your staff. This would allow the Division time to review our February report. It is our hope
that by working closely with the Division we can modify our plans such that permitting
difficulties are minimized.
We appreciate the guidance the Division has provided thus far. It has been very helpful.
If you would like to call and discuss any particulars, my phone number is [phone].
Sincerely;
Gary P. Sanderson, P.E.
ESHA Manager
cc: Michael Myers - DENR
Dan Trueman, Vic Ethridge, Frank Rash, Erin Russell — Clariant

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
Clariant
June 14, 2001
Mr. David A. Goodrich
NPDES Unit Supervisor
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699.-1617
1
CD
CD
CV
Re: NPDES Permit Number NC0004375; Domestic Sewerage & Solicited Industrial
Wastewater Treatment
Dear Mr. Goodrich;
This letter and attached material contain updated information subsequent to the meeting
of April 4, 2001. We have concentrated our efforts on decreasing the categories of solicited
industrial wastewater we propose to treat by considering only those sources having wastewater
similar in nature to our own influent. We have studied the new CentralizedeWaste Treatment
Point Source Category (40 CFR part 437) regulation for applicability. We believe it does. This
is further discussed in the attachment "Centralized Waste Treatment Facility Discussion".
The status of treating domestic sewerage has moved into the stage of attorneys for the
two entities discussing possible contract language. No technical or design work has taken place
since the April 4th meeting.
Regarding solicited third party wastewater, we have narrowed our proposal down to
inclusion of 13 categories from Subchapter N. Details of these are addressed in the attached
"Centralized Waste Treatment Facility Discussion".
We have been treating off -grade Clariant products subject to 40 CFR 414 Subpart H for
several months. The data and records are meticulously kept and we are happy to forward them to
the Division for review and inspection if you so desire.
We realize our request to treat wastewater from non-Clariant 40 CFR 414 Subpart H
sources plus 12 additional categories requires much study on the part of the permit writer. We
also understand our proposal expands our range of wastewater influent and treatment plant
operation into areas which are new and where there is no proven history.
In order to develop some experienceand provide the Division with additional data and
information, we would like to offer a proposal outlined in the attachment titled PROPOSAL. As

June 14, 2001 Letter to Mr. David A. Goodrich page 2
soon as Clariant and CMUD feel a contract is negotiable, we believe we should submit a permit
modification application to the Division. During the interim months, we propose to begin
treating selected third party wastewater to provide operational data to the Division on our
performance.
We propose treating limited quantities of targeted and carefully selected OCPSF
wastewaters that are similar to our influent. For example dyestuff, specialty organic synthesis,
and textile chemical producer wastewaters.
Because the contract work on treatment of domestic sewerage is progressing slowly, we
are unsure of precisely when we will approach the Division with a permit modification package.
Since treatment of third party wastewaters is new and poses a permitting dilemma, we
believe at least one more meeting with you and members of your staff would be beneficial. We
do not know if our proposal causes large or small regulatory or permitting obstacles. It is our
hope that by working closely with the Division we can modify our plans such that permitting
difficulties are minimized.
I would like to follow up with a phone call in July to discuss what course of action the
Division believes is best.
We appreciate the guidance the Division has provided thus far. It has been very helpful.
If you would like to call and discuss any particulars, please call me at [phone].
Sincerely;
'1/al'i ?,ida/)-L'‘tb
Gary P. Sanderson, P.E.
ESHA Manager
cc: Michael Myers - DENR
Dan Trueman, Vic Ethridge, Frank Rash, Erin Russell — Clariant

June 14, 2001 Letter to Mr. David A. Goodrich page 3
PROPOSAL
Clariant proposes to begin immediate solicitation of business from manufacturing sites in
SIC codes 2865 and 2869 for treatment of wastewater. Wastewater treatment from these sources
is regulated under 40 CFR 414 Subpart H, the primary regulation governing the Mt. Holly
Plant's existing NPDES permit.
All proposed wastewater for treatment will undergo the SELF -AUTHORIZATION
PROTOCOL FOR NON-CLARIANT, NON -HAZARDOUS WASTE RECEIPT, copy attached.
Only materials that are compatible with the existing wastewater treatment plant, WWTP, biology
and pretreatment systems will be accepted.
Beginning August 1, 2001 we would begin treatment of solicited third party wastewater.
Clariant will meter the solicited wastewater streams into the pretreatment process at rates of
between 5,000 and 30,000 gallons per day. This influent rate is between 0.4% and 2.5% of
current WWTP throughput. The relatively small flows and organic loading will not negatively
impact WWTP performance.
We would continue treating small quantities of subpart H wastewater throughout the
interim period prior to submission of a permit modification request and issuance of a revised
NPDES permit from the Division. This will give Clariant valuable experience in fine tuning the
administrative and operational processes. The trial period will allow the Division to evaluate
Clariant's performance and management system.
As soon as the city of Charlotte and Clariant reach a tentative agreement regarding
partnership in wastewater treatment, Clariant will submit a permit modification request to the
Division. The permit request will include expansion of treatment of third party wastewater to 12
additional industrial categories. All of the proposed categories produce wastewater similar in
content to those produced by our existing plant operations.
The twelve additional categories are listed below. There are multiple small businesses in
these categories that are relatively close to the Charlotte area where Clariant can provide a cost
effective and superior treatment service.
1. 40 CFR Part 414 Subpart
2. 40 CFR Part 414 Subpart
3. 40 CFR Part 414 Subpart
Treatment
4. 40 CFR Part 414 Subpart
Biological Treatment
5. 40 CFR Part 417 Subpart
6. 40 CFR Part 417 Subpart
7. 40 CFR Part 417 Subpart
8. 40 CFR Part 410 Subpart
9. 40 CFR Part 410 Subpart
D: Thermoplastic Resins
E: Thermosetting Resins
I: Direct Discharge Point Sources that Use End -of -Pipe Biological
J: Direct Discharge Point Sources That Do Not Use End -of -Pipe
F: Manufacture of Soap Flakes and Powders Subcategory
H: Manufacture of Liquid Soaps Subcategory
P: Manufacture of Liquid Detergents Subcategory
D: Woven Fabric Finishing Subcategory
E: Knit Fabric Finishing Category

June 14, 2001 Letter to Mr. David A. Goodrich page 4
PROPOSAL
Continued
10. 40 CFR Part 410 Subpart F: Carpet Finishing Subcategory
11. 40 CFR Part 410 Subpart G: Stock and Yarn Finishing Subcategory
12. 40 CFR Part 410 Subpart H: Nonwoven Manufacturing Subcategory
During the April 4, 2001 meeting, the Division cautioned us that our original proposal to
treat wastewater from a widespread group of industrial sources and types was not advisable. We
have reduced the scope significantly. The types of organic and inorganic chemicals contained in
wastewater from the above manufacturers will not cause upset of biological treatment in the site
WWTP and are compatible with the treatment process at our Mt. Holly Plant.

Centralized Waste Treatment Facility
Discussion Regarding
Clariant Corporation - Mount Holly East Site
In studying the December 22, 2000 Environmental Protection Agency final rule, Effluent
Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the
Centralized Waste Treatment Point Source Category (65 FR 81242 - 81313), we believe it
applies to Clariant's proposal to treat wastes/wastewaters from off -site facilities. As we read it,
the purpose of the rule was to develop limitations, guidelines and standards for wastewater
discharges for sites treating multiple source wastewaters.
Clariant's proposal is to become a Centralized Waste Treatment (`CWT') Facility that can treat
wastes/wastewaters from a limited variety of sources which have wastes and wastewaters that are
compatible with our wastewater treatment system. The new regulation defines a CWT facility as
"any facility that treats (for disposal, recycling, or recovery of materials) or recycles any
hazardous or non -hazardous industrial waste, hazardous or non -hazardous industrial wastewater,
and/or used material from off site." CWT facilities include ones that treat waste received from
off site exclusively, and ones that treat wastes generated on site as well as waste received from
off site. We believe the definition applies to the activities we are proposing to the Division and
therefore the CWT rule applies to our proposed wastewater treatment activities.
Clariant is only interested in treating wastes/wastewaters that are similar in nature to the
wastes/wastewaters we currently generate in our production processes. As a result, we believe
the Organics Subcategory of the 40 CFR 437 is applicable. Organic Wastes (as defined in the
CWT rule) are wastes and/or used materials that contain organic pollutants, but not a significant
quantity of oil and grease (generally less than 100 mg/L) from manufacturing or processing
facilities or other commercial operations.
I. Best Practicable Control Technology (BPT) Limitations
The Best Practicable Control Technology (BPT) limitations for the Organics Subcategory, 40
CFR 437.31, lists 14 specific metals an organic pollutants as well as 3 conventional parameters.
The technology basis for these BPT limitations is Equalization and Biological Treatment.
Clariant's Mount Holly East facility uses this technology currently.
BPT limitations for the 17 pollutant chemicals and parameters are listed in the table on the next
page.

CWT Applicability to Clariant Corp. — Mt. Holly East Site
40 CFR 437.31
Organics Subcategory
BPT Limitations
page 2
Regulated Parameter
Maximum Daily (mg/L)
Maximum Monthly Average
(mg/L)
BOD5
163
53.0
PH
Between 6 and 9
Between 6 and 9
TSS
216
61.3
Antimony
0.928
0.679
Copper
0.865
0.757
Molybdenum
1.01
0.965
Zinc
0.497
0.420
Acetone
30.2
7.97
Acetophenone
0.114
0.0562
Aniline
0.0333
0.0164
2-Butanone
4.81
1.85
o-Cresol
1.92
0.561
p-Cresol
0.698
0.205
2,3-Dichloroaniline
0.0731
0.0361
Phenol
3.65
1.08
Pyridine
0.370
0.182
2,4,6-Trichlorophenol
0.155
0.106
Our existing NPDES permit requires daily monitoring of outfall BOD, Total Suspended Solids,
and pH. Of the 14 metals and specific organics, Clariant only tests for phenol as a part of our
quarterly monitoring requirements.
For the remaining 13 metals and specific organics, Clariant proposes that the Division add them
to the list of quarterly monitoring requirements.
II. Discharge Limitations
Clariant is proposing to treat a much more limited group of effluent types after meeting with the
Division on April 4, 2001. Specific information on this is contained in III. below. We propose
that the site accept waste streams from 13 industry categories listed in Subchapter N. We have
chosen categories that have wastes/wastewater that are similar to and compatible with
wastewater from current operations and that are acceptably treated in biological treatment
systems.

CWT Applicability to Clariant Corp. — Mt. Holly East Site page 3
One of the problems developing effluent limitations for treatment of waste streams from outside
sources is that the various categories have variant effluent limitations. Moreover, for some of the
subcategories, the effluent limitations are based on pounds of product produced (e.g. kilograms
per 1,000 Kg of product produced or pounds per 1000 pounds of product produced, etc.). It
would be virtually impossible to develop effluent limitations for Clariant's Mt. Holly Plant based
on numerous third party (customer's) production rates.
If it were possible to place all of the solicited waste streams under the umbrella of 40 CFR 437
Subpart C, determining effluent limitations would be much less complex. We request that the
Division determine if this can be done. Except for OCPSF wastewaters, 40 CFR 414 Subpart H,
it would certainly be a more reasonable approach in development of effluent limitations for all
other solicited waste streams.
III. Categories From Which Clariant To Solicit Wastes/Wastewater
Listed below are those Subchapter N categories/sub-categories from which Clariant wishes to
solicit business. As discussed above, we propose that all of these categories/sub-categories be
regulated in accordance with 40 CFR 437 Subpart C.
Subchapter N Subparts Clariant Proposes to Include in Its Wastewater Treatment System
40 CFR Part 414 — Organic Chemicals, Plastics and Synthetic Fibers
Subpart D. Thermoplastic Resins
SIC Code 28213. Examples are ABS resins, Acrylic Latex, Acrylic Resins,
Nylon 6 Resin, Cellulose Acetates, Fluorocarbon Polymers, HDPE,
Polystyrene, Silicone Resins, etc.
Effluent limitations are concentration based (mg/L).
Subpart E. Thermosetting Resins
SIC Code 28214. Examples include Polyurethane Resins, Urea
Formaldehyde Resins, Phenolic Resins, Melamine Resins, Epoxy Resins,
etc.
Effluent limitations are concentration based (mg/L).
Subpart H. Specialty Organic Chemicals
Wastewaters from the manufacture of SIC 2865 and 2869 organic
chemicals and organic chemicals groups which are not defined as
commodity or bulk organic chemicals.
Effluent limitations are concentration based (mg/L).

CWT Applicability to Clariant Corp. — Mt. Holly East Site page 4
Subpart I. Direct Discharge Point Sources That Use End -Of -Pipe Biological
Treatment
Process wastewater discharges resulting from the manufacture of the
OCPSF products and product groups defined by 414.11 from any point
source that uses end -of -pipe biological treatment or installs end -of -pipe
biological treatment to comply with BPT effluent limitations
Effluent limitations are concentration based (mg/L).
Subpart J. Direct Discharge Point Sources That Do Not Use End -Of -Pipe Biological
Treatment
Process wastewater discharges resulting from the manufacture of the
OCPSF products and product groups defined by 414.11 from any point
source that uses end -of -pipe biological treatment or installs end -of -pipe
biological treatment to comply with BPT effluent limitations
Effluent limitations are concentration based (mg/L).
40 CFR Part 417 — Soap and Detergent Manufacturing Point Source Category
Subpart F. Manufacture of Soap Flakes and Powders Subcategory
Discharges from the manufacture of soapflakes and powders, commencing
with the drying of the neat soap to and including packaging of the finished
flakes and powders.
Effluent limitations are mass based (kilograms per 1000 kilograms of
anhydrous product.)
Subpart H. Manufacture of Liquid Soaps Subcategory
Discharges from the blending of ingredients employed in the manufacture
of liquid soaps and the packaging of the finished products.
Effluent limitations are mass based (kilograms per 1000 kilograms of
anhydrous product.)
Subpart P. Manufacture of Liquid Detergents Subcategory
Discharges from manufacture of liquid detergents, commencing with the
blending of ingredients, to and including bottling or packaging of finished
products.

CWT Applicability to Clariant Corp. — Mt. Holly East Site page 5
Subpart P continued
Effluent limitations are mass based (kilograms per 1000 kilograms of
anhydrous product.)
40 CFR Part 410 — Textile Mills Point Source Category
Subpart D. Woven Fabric Finishing Subcategory
Desizing, bleaching, mercerizing, dyeing, printing, resin treatment, water
proofing, flame proofing, soil repellency application, special finish
application
Effluent limitations are mass based (kilograms per 1000 pounds of
product.)
Subpart E. Knit Fabric Finishing Subcategory
Desizing, bleaching, mercerizing, dyeing, printing, resin treatment, water
proofing, flame proofing, soil repellency application, special finish
application
Effluent limitations are mass based (kilograms per 1000 pounds of
product.)
Subpart F. Carpet Finishing Subcategory
Bleaching, scouring, carbonizing, fulling, dyeing, printing, resin treatment,
waterproofing, flameproofing, soil repellency, looping, and backing with
foamed and unfoamed latex and jute
Effluent limitations are mass based (kilograms per 1000 pounds of
product.)
Subpart G. Stock and Yarn Finishing Subcategory
Cleaning, scouring, bleaching, mercerizing, dyeing and special finishing
Effluent limitations are mass based (kilograms per 1000 pounds of
product.)

CWT Applicability to Clariant Corp. — Mt. Holly East Site page 6
Subpart H. Nonwoven Manufacturing Subcategory
Discharges from facilities that primarily manufacture nonwoven textile
products of wool, cotton, or synthetics, singly or as blends, by mechanical,
thermal, and/or adhesive bonding procedures.
Effluent limitations are mass based (kilograms per 1000 pounds of
product.)
IV. Wastes Excluded From the Centralized Waste Treatment Category
In accordance with the CWT rule Clariant realizes that there are some wastewater streams which
would not be covered by the regulation.
Wastes that would not be subject to the CWT rules:
• Wastewater that is generated from Mt. Holly East Site operations.
• Solicited wastewater generated off site if the customer demonstrates that the wastewater is
generated at a facility that is subject to 40 CFR 414 Subpart H.
• Clariant Corporation wastes and wastewater from product stewardship activities (treatment or
recovery of unused products, shipping and storage containers with product residues and off -
spec products). This is part of our proposal to treat portions of our corporation's internal
off -specification materials. The site will only accept Clariant Corporation wastes or
wastewater from 40 CFR Part 414 Subpart H sources.

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Clariant
MOUNT HOLLY EAST PLANT
SELF -AUTHORIZATION PROTOCOL FOR
NON-CLARIANT, NON -HAZARDOUS WASTE RECEIPT
Introduction
These procedures provide an outline of the evaluation process Clariant - Mount Holly East will
utilize to accept off -site waste for wastewater treatment. This plan covers the protocol for initial
approval of off -site non-Clariant waste streams and the protocol for quality assurance and
verification for continuing acceptance of those waste streams.
New Wastestream Approval Procedures
1) Once a waste generator expresses interest in utilizing the Clariant - Mount Holly East
facility, the site Customer Service Representative will procure all pertinent information
concerning the composition of the waste under review, the process generating the waste,
any analytical data the generator may possess, all applicable Material Safety Data Sheets
(MSDS), and any relevant knowledge the generator has concerning the waste.
2) The above information will be compiled in a routing file and circulated to the following
members of Clariant - Mount Holly East's staff for their evaluation:
A. Environmental Chemist/Engineer
B. WWTP Analytical Chemist
3) The Environmental Chemist/Engineer will perform an in-depth review of the chemical
nature of the waste and the process from which the waste is generated. This review will
include, but may not be limited to, the following:
A. A complete evaluation of all applicable MSDS's.
i. Determining if waste exhibits hazardous characteristics as per 40 CFR
261:
a. Determining if the material will react in an adverse manner after
exposure to water, air, or any other naturally occurring conditions
per the criteria of 40 CFR 261.23.
Revised March 2001
1

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
b. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 261.21.
c. Determining if the waste could exhibit the characteristic of
corrosivity per 40 CFR 261.22.
d. Determining if heavy metals and organics meet or exceed the
concentrations specified in 40 CFR 261.24
ii. Determining if waste is a "listed" hazardous waste as per 40 CFR 261
based on the process from which the waste is generated and/or the raw
materials which comprise the waste (i.e. discarded commercial chemical
product).
iii. Determining the relative concentrations of any listed hazardous
constituents.
iv. Investigating the toxic effects, using up-to-date references, that may be
associated with any of the listed waste constituents, including threshold
and non -threshold health effects.
v. Determining the potential that may exist for the processing of the waste to
create an objectionable odor, of which the intensity might result in its
detection off -site. (NOTE: Clariant recognizes the subjectivity of an
"objectionable odor", and will employ analytical testing as well as a
"common sense" approach when an odorous waste is involved.)
B. A review of all other information that the generator has provided, including any
analytical data and the first draft of the completed profile sheet.
i. Determining if the chemical composition that the generator has provided
is satisfactory (qualitatively and quantitatively).
H. Determining if the "name of waste" and the "process generating waste"
fully and accurately describes each.
iii. Evaluating any analytical data and determining if it is relevant (e.g., Is the
data current and applicable? Did a qualified laboratory perform the
analysis?).
iv. Identifying what additional information the generator needs to provide, if
any.
Revised March 2001
2

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
C. An assessment of the accuracy of the information the generator has provided
concerning physical characteristics of the waste.
i. Comparing the physical state and consistency of the sample with profiled
information.
ii. Associating the odor of the waste with specific chemical groups (e.g.,
Does the sample exhibit an odor associated with volatile organics?
Halogenated organic compounds? Sulfurous compounds?).
iii. Determining the oil content (e.g., Does a visual inspection of the sample
correlate with the information on the profile?).
iv. Verifying the color and any other characteristics which can be confirmed
visually.
D. A determination of all the analytical tests which must be performed on a
representative sample prior to completing a final profile sheet. (NOTE: Analytical
test methods employed have been approved by the United States Environmental
Protection Agency and are prescribed in the EPA manual SW-846 and Standard
Methods.)
i. Tier I Testing
For all non-Clariant waste materials a standard battery of testing will be
performed for each new material submitted for approval. The Tier I tests
are as follows:
a. Chemical Oxygen Demand (COD)
b. pH
c. Oil and Grease
d. Phenols
e. Respirometry Testing
ii. Tier H Testing
For all non-Clariant waste materials submitted for approval, Clariant may
require testing for parameters other than the Tier I parameters. The Tier II
testing is optional and is only done when the Environmental
Chemist/Engineer believes it is necessary for a waste stream approval.
Any of the following tests may be performed as part of the Tier II testing:
a. Flash Point
b. RCRA Metals along with copper, zinc, and nickel.
c. Volatile compound scan
d. Semi -Volatile compound scan
e. Biological Oxygen Demand (BOD)
Revised March 2001
3

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
E. Coordinating treatability testing with the WWTP Analytical Chemist and WWTP
Supervisor.
4) The Environmental Chemist/Engineer will perform a cursory review of available
information and provide any relevant comments or suggestions.
5) The Environmental Manager may review additional testing requirements identified by
the Environmental Chemist/Engineer and approve the suggested tests and/or provide
recommendations.
6) The Customer Service Representative will procure any additional information the
Environmental Chemist/Engineer has requested. The Customer Service Representative
will route the sample to Clariant - Mount Holly East's laboratory, accompanied by a
request form describing all the analytical data needed.
7) Clariant - Mount Holly East's WWTP analytical laboratory will perform, or contract out,
all the tests deemed essential. The results of these tests will be reported on a standardized
form, and all worksheets and subsequent report forms will be filed via a Mount Holly
Profile Number. (NOTE: Once a profile number is assigned, this information file will be
referenced by profile number.)
8) The laboratory will provide the Environmental Chemist/Engineer with the completed
analytical data. (NOTE: The WWTP Analytical Chemist will review this data and
approve it prior to distribution.)
9) The Environmental Chemist/Engineer will compile the analytical data and all other
required information on a profile sheet and assign the customer a profile number.
10) All of the above information, including the completed profile sheet, will be returned to
the routing file and circulated to each of the following for their final review and approval:
A. The Environmental Chemist/Engineer
B. WWTP Supervisor
C. The Environmental Manager (Optional)
Each of the above persons will approve the final package prior to waste receipt.
11) The Environmental Chemist/Engineer will issue a "Notice of Authorization" for the
approved wastestream to the appropriate Customer Service Representative. This notice
will stipulate any conditional monitoring involved regarding the processing and disposal
of the waste. The approved waste will be added to Clariant - Mount Holly East's "Non -
Hazardous Waste Approval Listing".
Revised March 2001
4

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Ouality ControUOuality Assurance Policy
1) Clariant - Mount Holly East will maintain its stringent quality control program for
incoming wastes. A representative sample will be taken from each containerized waste
and compared to the corresponding profile sheet. The following describes tests and
observations utilized by quality control.
A. Extracting representative core samples from each:
i. Bulk Shipment,
Containerized Waste Shipment (drums).
(NOTE: Samples of containerized wastes are composited according to
"like" physical characteristics. In the event a composite sample fails the
QA/QC evaluation, individual samples are taken from each drum
represented in the composite and tested.)
B. Comparing the physical characteristics of the sample to those listed on the waste
profile sheet (See Attachment
A). This comparison will include evaluating:
i. Color,
ii. Odor,
iii. Physical State,
iv. Viscosity.
C. Analyzing the pH of the waste.
D. Observing any reactions (e.g. fuming, boiling, etc.).
Revised March 2001
5

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
When any discrepancies in the waste are observed, an off -specification notification is
completed, noting the discrepancies. This memo is addressed to the Customer Service
Representative and the Environmental Manager. An amendment to the profile will be
issued to account for the change in the waste when deemed appropriate. (NOTE: The
generator will be advised of this situation. In some instances, the waste may be rejected
because of an off -spec characteristic (e.g. strong odor).
In the event a waste is identified as exhibiting a hazardous characteristic, a non-
conforming/off-specification waste memo will be completed and routed to the
Environmental Manager and the Customer Service Representative. (NOTE: The
Environmental Chemist/Engineer will take the active role in this matter.) Prudent
measures will be taken to isolate and secure the waste.
If a waste exhibits a characteristic potentially outside the parameters for non -hazardous
waste, the waste will be rejected and the material removed from the facility. If the waste
requires additional laboratory analysis to determine if it is a RCRA hazardous waste, the
material will be considered rejected on the day the laboratory analysis is returned
indicating a potential hazardous characteristic, and the material will be removed from the
site.
If the generator chooses to have the waste returned to his facility, the Customer Service
Representative will make arrangements for the generator to use a hazardous material
transporter. Also, Clariant-Mount Holly will indicate the rejection to the generator on the
bill of lading, non -hazardous manifest, etc. This rejection will stipulate the suspected
hazard class.
Clariant - Mount Holly East will offer the generator the choice of having the waste routed
to a TSDF for disposal. Clariant - Mount Holly East will reject the waste on the
discrepancy portion of the non hazardous waste manifest. The generator will complete a
hazardous waste manifest and forward this document to Clariant - Mount Holly East; a
copy of the non -hazardous manifest will be attached. Clariant - Mount Holly East will
assist in having the waste transported via a hazardous waste carrier to the designated
facility.
Revised March 2001
6

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Information Maintained For The NCDENR Division of Water Quality
1) Clariant - Mount Holly East will create and maintain records for all new wastestream
profiles prior to processing the waste.
2) Clariant - Mount Holly East will also maintain an updated Generator Listing. This listing
will include:
A. The generator profile number,
B. The generator name and address,
C. The name of the waste,
D. Any pertinent comments (e.g. watch pH, flash point, need copy of non -hazardous
waste manifest, etc.)
3) Clariant — Mt. Holly East will treat all incoming materials using a "batch method".
Clariant will maintain records of all "batches" of waste material treatments. This batch
record will contain details of the quantities of individual profiled wastes treated.
Revised March 2001
7

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Proposed Effluent Limits: Clariant Corp. Mt. Holly Plant, NPDES Permit Number NC0004375
GPS 03.12.2001
Stream Stream Description
No.
1 Clariant Product Disposal (OCPSF)
2 Solicited OCPSF Wastewaters
3 Solicited Petroleum Containing Water
4. Solicited Textile Mill Wastewaters
Flow
Rate
0.030
0.02
0.012
0.030
-5.}Solcited Soap & Detergent Wastewaters 0.020
" 6 CMUD Domestic Sewage pit") 2.000
7 Groundwater Remediation fkf,. 0.150
8 Dyes Manufacturing .,j, 0.450
9 Specialty Chemical Manufacturing Sam it 0.090
10 Stormwater - Process Areas 4. , 0.087
11 Stormwater - Nonprocess Areas =(trij 0.138
12 Clariant Sanitary i► 0.027
.13 River Filter Plant Backwash .4.. 0.065
Totals (annual daily avg. flow basis) 3.119
BOD TSS N P O&G BOD TSS
Conc. Conc Conc Conc Conc Limit Limit
45 57.0 37.5 2.6 11.26 14.26
45 57.0 37.5 2.6 7.51 9.51
45 30.6 37.5 2.6 38 4.50 3.06
53 61.3 37.5 2.6 13.26 15.34
53 61.3 37.5 2.6 40 8.84 10.22
?( 30 30.0 6.0 1.0 500.40 500.40
45 57.0 37.5 2.6 56.30 71.31
45 57.0 37.5 2.6 168.89 213.92
45 57.0 37.5 2.6 33.78 42.78
45 57.0 37.5 2.6 32.65 41.36
1 30.0 37.5 2.6 1.15 34.53
30 30.0 6.0 1.0 6.76 6.76
0 30.0 37.5 2.6 0.00 16.26
N P
Limit Limit
9.38
6.26
3.75
9.38
6.26
100.08
46.91
140.74
28.15
27.21
43.16
1.35
20.33
0.65
0.43
0.26
0.65
0.43
16.68
3.25
9.76
1.95
1.89
2.99
0.23
1.41
845.28 979.71 442.95 40.58
O&G
Limit
0.00
0.00
3.80
0.00
6.67
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.48
Requested maximum month avg.day
Existing Permit Limits
*mita , CGrASe,
5.000
3.900 max. rr 852.00 976.00 651.00
- ,,,,tid% 4D 10 -/D�'i i '' ,X 5 T r yciu( V. ./ �Cj',r(': • NH3
tt te,
Notes:
Stream Source of Limit Derivation
No.
1 & 2 40 CFR 414.91 & BAT
3 40 CFR 437.21, 414.91 & BAT
4 40 CFR 437.31 & BAT
5 40 CFR 417, 437.31 & BAT
6 & 12 40 CFR 133.102 & Basinwide Plan
BOD TSS N P O&G
Conc. Conc. Conc. Conc. Conc.
45 57.0 37.5 2.6
30 30.6 37.5 2.6 38
53 61.3 37.5 2.6
53 61.3 37.5 2.6 40
30 30.0 6.0 1.0
7,8,9,10 40 CFR 414.91 & BAT 45 57.0 37.5 2.6
11 & 13 Amalgamation & BAT
Stream 5 O&G interpolated from
40 CFR 417
Nitrogen limit to be effective during
summer months, not cold weather
months

Directions to Clariant Corporation — Mt. Holly East Operating Site
Interstate 85
To Gastonia
NC 273 Mt. Holly exit
S
ir
NC 27
Mt. Holly
Moores
Chapel
oad
Sam Wilson
Road exit
Interstate 85
To Charlotte
Catawba
River
Belmeade
Road
Mt. Holly Plant
East Operating
Site
Entrance
NC 27
To Charlotte
Mt. Holly Road

April 4, 2001 Meeting
Subject: Clariant Mt. Holly East Plans and Timing for Waste
Water Treatment Alterations (permit NC0004375)
cle GP4'0-
9:30 a.m.
10:00 a.m.
Coffee and introductions
Status of Clariant and CMUD business plans
' 10:30 a.m. Discussion of Clariant proposal for treatingoff-site wastewater
11:15 a.m. Discussion of proposed permit limits
12:00 p.m. Lunch
12:30 p.m. Tour of Mt. Holly East Operating Site
2:00 p.m. Wrap-up discussions
2:45 p.m. Adjourn

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April 4, 2001 Meeting
Subject: Clariant Mt. Holly East Plans and Timing for Waste
Water Treatment Alterations (permit NC0004375)
9:30 a.m. Coffee and introductions
10:00 a.m. Status of Clariant and CMUD business plans
10:30 a.m. Discussion of Clariant proposal for treatingoff-site wastewater
11:15 a.m. Discussion of proposed permit limits
12:00 p.m. Lunch
12:30 p.m. Tour of Mt. Holly East Operating Site
2:00 p.m. Wrap-up discussions
2:45 p.m. Adjourn

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Visit to Clariant Mt. Holly Plant
Subject: Visit to Clariant Mt. Holly Plant
Date: Mon, 2 Apr 2001 08:45:05 -0400
From: [e-mail]
To: [e-mail]
Dear Mr. Myers,
Attached is a simplistic map showing how to get to the Mt. Holly Plant from
either Interstate 85 or NC 27, Mt. Holly Road. Mt. Holly Rd. is the road
that runs through the middle of Paw Creek.
I'll send an agenda out later this afternoon. If there are specific items
you would like on the agenda, just let me know .
Thank you.
(See attached file: Map to MHE.doc)
Gary Sanderson
DMap to MHE.doc
Name: Map to MHE.doc
Type: Microsoft Word Document (application/msword)
Encoding: base64
Download Status: Not downloaded with message
paw
D I?
1 of 1 4/3/2001 10:58 AM

Agenda for Meeting Between Clariant and DWQ on April 4th
Subject: Agenda for Meeting Between Clariant and DWQ on April 4th
Date: Mon, 2 Apr 2001 14:00:14 -0400
From: [e-mail]
To: [e-mail], [e-mail], [e-mail],
[e-mail], [e-mail], [e-mail]
CC: [e-mail], [e-mail], [e-mail],
[e-mail]
We are planning to meet at the Clariant Mt. Holly Plant between 9:30 and
10:00 a.m. on Wednesday April 4th. The meeting will be held in the site
training room.
The probable attendees are listed below. (If I've incorrectly represented
some9ne's title, please forgive me.)
oRick Carrier Brown & Caldwell Charlotte
Office Manager
✓Vic Ethridge Clariant - Mt. Holly Sr.
Environmental Chemist
✓Ned Fiss Aware Environmental Manager of Process
Group
✓bavid Goodrich NCDENR Supervisor of
Permitting
✓Michael Myers NCDENR Permit Writer
✓Glen Pysell Clariant - Mt. Holly
Environmental Chemist
e/Frank Rash Clariant - Mt. Holly
Supervisor of WWTP
✓ary Sanderson Clariant - Mt. Holly
ESHA/Infrastructure Manager
✓Barry Shearin Charlotte Mecklenburg Utilities Department
Chief Engineer
Peter Schuler Brown & Caldwell Senior
Engineer
''Michael Teague Clariant NAFTA Director of Corp.
ESHA
✓Dan Trueman Clariant - Mt. Holly Plant
Manager
£ t\ 1241-45<11 -
A proposed agenda is below."Changes are no problem. We can easily decide
what is best when we all get together Wednesday morning. If you would like
to change or add anything, feel free to email me at your convenience.
Thank you,
Gary Sanderson
9:30 a.m.
10:00
10:30
wastewater
AGENDA
Gather in the conference room for coffee and introductions
Status of Clariant and CMUD business plans
Discussion of Clariant proposal for treating off -site
11:15 Discussion of proposed permit limits
12:00 p.m. Lunch
12:30 Tour of the Mt. Holly East Operating Site
1 of 2 4/3/2001 10:58 AM

Agenda for Meeting Between Clariant and DWQ on April 4th
2:00 Wrap up discussions
2:45 Adjourn
2 of 2 4/3/2001 10:58 AM

MEMORANDUM
Date: March 13, 2001
To: Meeting Attendees
From: Peter Schuler, Brown and Caldwell
Re: Charlotte Mecklenburg Utilities (CMUD)
CMUD/ Clariant Combined WWTP
Meeting with DWQ, February 15, 2001
19047-001
MAR 1 5 2001
DEYR - WATER QU '! ! rY
POI?;T EC'!RCE
A meeting was held at the NCDENR DWQ offices in Raleigh to discuss the results of the
treatability report and discuss future NPDES permit limits for the Clariant WWTP.
Rick Carrier, Brown and Caldwell
Bill Reid, DWQ Point Source Bureau
Dave Goodrich, DWQ NPDES
Gary Sanderson, Clariant Corporation
Michael Myers, DWQ Point Source Bureau
Peter Schuler, Brown and Caldwell
Jackie Nowell, DWQ NPDES
Barry Shearin, Charlotte -Mecklenburg Utilities
The following items were discussed:
• Barry Shearin gave an overview of where CMUD / Clariant / BC stood on this project in
terms of what had been accomplished to date and where we felt we were headed.
■ Gary Sanderson then gave an overview of Clariant's situation. In summary,
- Current Production is down 30 percent and expected to drop further.
WWTP was built more than 20 years ago when flow was higher than 2.0 MGD.
Clariant is currently looking at CMUD and other potential wastewater sources to provide
food for the microbial population of the WWTP.
• Dave Goodrich explained that Clariant's NPDES permit is in a state of transition and that
nutrient discharges are a concern with or without CMUD. The state is aiming to cap major
dischargers to Lake Wylie and that a TP of 1 ppm should be expected. He also felt that
growth in the Mecklenburg County area is going to continue no matter what and that CMUD
has a good compliance record. He also feels that a separate meeting is warranted just to
discuss Clariant other issues (off -site OCPSF waste treatment.
• Lake Wylie is not hyper-eutrophic like Jordan Lake. Lake Wylie studies have been going on
for 11 years with South Carolina. The 1995 Catawba Basin Plan had very stringent limits of
0.5 ppm for phosphorous. These limits have been revised because the main stem of Lake
Wylie is more like a river than a lake. However, certain areas such as Catawba Creek are
eutrophic. The current objective is to require POTWs to meet BAT limits of 6:1 (TN:TP).
Although South Carolina considers controlling TP more necessary, the Lake Wylie study
UWN OD CALDWVELL
G:\19047 - Clariant Treatability\WP\Meeting Minutes\MM 2-15-01.doc

Meeting Attendees
March 13, 2001
Page 2
demonstrated that both nutrients should be controlled. The Neuse River is moving towards
TN limits of 3.0-3.5 mg/L.
■ NCDENR DWQ is planning to address nutrient concerns when facilities expand -- as with
this project. DWQ is amenable to using the building block approach to determine mass
based limits and that daily monitoring will most likely be required. Although the focus is on
TP, a load for TN must be established. The Aware BAT report stated that the BAT TN
discharge was 4441b/day.
■ DWQ has allowed site specific BAT at Monsanto.
■ Dave wants limits based on Aware BAT report and proposed POTW rules of 6 ppm TN and
1 ppm TP. DWQ supports the concept of constructing a full scale BAT and monitoring and
reporting without limits in return for more defined mass limits in the future.
■ DWQ wants detailed information on Clariant's proposal for treating off -site wastewater, a
process plan for treating CMUD wastewater, a discussion of proposed permit limits and how
they were derived, and a response to the questions posed by DWQ about the treatability
report. This information is to be provided a couple of weeks prior to the next meeting.
■ The next meeting is scheduled for Wednesday, April 4, 2001, at 10:00 am at Clariant
Corporation.
PFS:pfs
8IUYN AND CLII/LL
G:119047 - Clariant Treatability\WP'Meeting Minutes\MM 2-15-01.doc

MEMORANDUM
To: Michael Myers/Jackie Nowell
From: Peter Schuler, Brown and Caldwell
Date: March 13, 2001
Subject: Answers to Questions Regarding Treatability Testing of
Combined Charlotte Mecklenburg Utilities and
Clariant Corporation Wastewaters
NPDES Permit Number NC0004375
19047-01/05
r
DENR - WATER QUALITY
POINT SOURCE BRANCH
The following are Brown and Caldwell's responses to the questions in your memorandum dated
January 17, 2001:
, . 1. Clariant needs to be aware that the permit holder is responsible for compliance with the
NPDES Permit limits. Any limitations for the Long Creek Basin wastewater would have to
be negotiated between Clariant and the Charlotte Mecklenburg Utilities.
Clariant and Charlotte Mecklenburg Utilities (CMUD) are aware of this and negotiations
are scheduled to begin after this meeting.
c.f_ 2. If approved, how will Charlotte Mecklenburg Utilities and/or Clariant address inflow and
infiltration from the Long Creek Basin? I suggest that if approved, a flow limit be placed on
the flow that can be accepted by the facility.
Six (6) million gallons of equalization storage capacity is being constructed as part of the
new Long Creek Pumping Station (PS) to handle inflow and infiltration. The plan is that
all flows in excess of 2 MGD will either be stored or pumped from the Long Creek PS to
the Paw Creek PS with the ultimate treatment point being CMUD's McAlpine Creek
WWTP. The Clariant facility will only accept 2 MG of the Long Creek Basin wastewater
but Clariant and CMUD would request flexibility to treat additional flow in accordance
with the NPDES permit. CMUD is actively working to reduce inflow and infiltration in the
Long Creek basin.
3. What is the Long Creek wastewater composition? (e.g. % industrial, % commercial,
% domestic) For indirect industrial dischargers: Who are they, what is the nature of their
business, what are the characteristics of their wastewater, do they have pretreatment permits?
If so, how is their compliance? Who will regulate pretreatment facilities?
Currently, the Long Creek basin is dominated by domestic wastewater (90%) — with the
exception of Cintas Corporation (a commercial laundry). Cintas currently discharges an
average of 0.1 mgd (5%) under the CMUD industrial pretreatment program. The rest of
the basin's wastewater is made up of office/commercial (5%). Future development within
the basin is projected to be almost exclusively residential and office -type commercial due to
the development of 1-485 and the proximity to the Catawba River. CMUD will continue to
regulate all current and future pretreatment facilities within the Long Creek Basin in
accordance with their pretreatment ordinance and NPDES requirements.
\\CHA-01\PROJECTS\I9047 - ClariantTreatability\Gen\DWQ Comments and Questions Answers to DWQ Qucstions.doc

Michael Myers/Jackie Nowell
March 13, 2001
Page 2
4. Clariant's contribution is projected to equal 1.1 MGD while the Long Creek Basin
contribution is projected to equal 2.0 MGD. The combined 3.1 MGD is equal to 79% of the
permitted flow for the Clariant Corporation. This is very close to the 80/90 rule for
municipalities. This again raises the issue of inflow and infiltration and how it will be
managed. Also, the Division should discuss our position regarding any potential flow
expansion request resulting from increased flow from the Long Creek Basin.
Inflow and infiltration from Long Creek will be handled as discussed in #2 above.
Clariant will continue to handle stormwater flow by diverting it into on -site storage basins
and controlling the flow into the WWTP. Clariant would like to request that the maximum
permitted daily flow be increased to 5-mgd to allow re -treatment of stored wastewater
during periods when the WWTP is performing well: The McAlpine Creek WWTP is not at
80% level yet. Therefore, no planning is require&
5. Based on the actual flow numbers Clariant equals 35.5% while Long Creek would equal
64.5% this is consistent with the synthetic combined wastewater.
Agree&
6. The study reports a Return Activated Sludge (RAS) of 30,000 mg/L. This is extremely high.
What is the reason / basis for using this number?
The RAS was concentrated during the bench scale studies to "wash out" background
contaminants. The concentrated RAS was then diluted to the MLVSS concentration that
is intended to be used in the full-scale facility — 4,000 to 5,000 mg/L.
7. From the study, it appears that in the event of a slug from the acid sewer that peroxide
addition would be used to control the inhibition of nitrification that was evident in the pilot
study.
"Slugs" from the acid sewer were not observed during the study and historically have not
been a problem for operation at this facility. Bench scale treatability tests demonstrated
that peroxide addition appeared to be effective at making certain herbicide wastewater
more amenable to biological treatment. This system could be installed to add peroxide
when necessary to maintain permit limits but the use of peroxide could be prohibitively
expensive.
8. When were the samples gathered for the peroxide experiment? If not collected during the
mid July event, how can the data from the peroxide experiments be correlated to that event?
Under "normal" operation nitrification does not appear to be inhibited, however the mid July
event inhibited nitrification. Discuss the validity of the peroxide results taking this into
consideration.
The samples were collected on August 30, 2000 and the tests were run on August 31 ' and
September 13, 2000. This was during the production of the herbicide that caused the event
that started in mid -July.
11CHA-011PROJECTS119047 - Clariant Treatability\Gen\DWQ Comments and Questions\Answers to DWQ Questions.doc

Michael Myers/Jackie Nowell
March 13, 2001
Page 3
9. How will potential slugs from the alkaline sewer be managed? Results from the peroxide
experiments do not suggest that peroxide addition would control slugs from the alkaline
sewer.
"Slugs" from the alkaline sewer were not observed during the study and historically have
not been a problem for operation at this facility. The addition of peroxide to the alkaline
sewer would also improve the nitrification rates of the alkaline wastewater as
demonstrated in the bench scale study. The combined acid / alkaline wastewater would
have a nitrification rate of approximately 0.03 mg N/mg VSS per day without peroxide
addition. The addition of 375 mg/L peroxide increased the nitrification rate to 0.12 mg
N/mg VSS per day — a four fold increase in nitrification rate. This system could be
installed to add peroxide when necessary to maintain permit limits but the use of peroxide
could be prohibitively expensive.
10. What affect did the mid -July event have on the influent characteristics of the wastewater?
(i.e. Did the process change affect the characteristics of the alkaline or the acid sewer and
how?)
The characteristics of the individual wastewater streams were not monitored —
measurements were taken on the simulated combination of the influent wastewater only.
The mid -July event increased the organic nitrogen, TKN and ammonia concentrations of
the Clariant Wastewater due to the increase in amine compounds present in the discharge
from Building 45. At least one of these compounds appears to inhibit nitrification at the
WWTP.
11. Figure 3-8 indicates that the effluent NO2 and NO3 concentrations significantly decreased in
mid July. This corresponds approximately to the time when DO levels dropped to less than
0.5 mg/L and when nitrification was inhibited. Please discuss the significance of these two
events when interpreting the results of this figure?
This figure is misleading in that it only shows influent and effluent Nitrate and Nitrite
concentrations. A truly accurate representation of what actually occurred can only be
developed by calculatin conversion rates of organic nitrogen, ammonia, nitrate /
nitrate, 0 nitrogen gas. CDuring the times of nitrification inhibition and increased organic
nitrogen / ammonia concentrations in the influent wastewater, the conversion from
ammonia to nitrate /nitrate is the limiting factor in the conversion in the breakdown of
nitrogen compounds Throughout the study, the amount of de -nitrification was fairly
consistent and averaged around 15 mg/L when the anoxic zone D.O. level was maintained
below 0.5 mg/L. If an anoxic zone is required as part of the treatment process, it will be
sized sufficiently to handle anticipated loads of nitrate / nitrite nitrogen while operating at
a conventional re -circulation rate of three times the influent flowrate.
12. Discuss the ability of the treated combined wastewater for meeting TN limits.
The combined wastewater will not be able to meet a consistent limit of 6 mg/L. Clariant
currently discharges TN concentrations that average around 25 mg/L and range from 5 to
55 mg/L. During the pilot study when things were working well, the following
concentrations of nitrogen compounds were observed in the effluent: ammonia
<0.2 mg/L, J nitrate/nitrate = 5 mg/L and 7 mg/L organic nitrogen (most is non-
bioavailable ; therefore, a total nitrogen of approximately 12 mg/L was the best result
�. 6.. T: Tc? L,Z
\\CHA-011PROJECTSU 9Q47 - Clariant Treatability\Gen\DWQ Comments and Questions\Answers to DWQ Questions.doc

Michael Myers/Jackie Nowell
March 13, 2001
Page 4
observed but would not be sustainable on a regular basis. A building block assessment of
each waste stream is needed to set a rational mass based total nitrogen limit.
13. Please discuss the rationale for choosing chemical addition for phosphorus removal instead of
biological phosphorus removal.
In actuality, phosphorous removal should not be an issue on this project Clariant has
decided to continue to add lime for pH adjustment of their acid sewer. The lime addition
will allow precipitation of calcium phosphate. Bypass of the Long Creek wastewater
around the lime addition system will be required to ensure that adequate phosphorous is
available as a macronutrient for BOD removal.
14. Explain the gap in the data for `SBOD out' for the Clariant Only Pilot Unit (Figure 3-12).
Samples from the Clariant Only Pilot Unit were not collected on August 8th and 111*.
15. Please discuss how the acclimation period will be handled during the startup of the combined
wastewater system.
A long acclimation period is not expected, the domestic wastewater should be relatively
easy to treat in comparison to the Clariant wastewater. Additionally the Clariant WWTP
already treats domestic wastewater generated by plant personnel. It is envisioned that the
Long Creek wastewater will be added in step increments over a period of several weeks to
allow Clariant to monitor the effluent and ensure that all permit parameters are being
successfully met.
16. Effluent data for BOD and COD contains only the soluble portion. This assumes that TSS
will be completely removed under full-scale operations. The report points out that the
hydraulic loading rate at 3.1 MGD will be significantly lower than the typical design range.
Discuss the current and/or proposed WWTP and how the plant can be operated to overcome
possible rising sludge due to denitrification in the secondary clarifiers.
The clarifiers will be operated to maintain a sludge blanket of less than 1.5 feet to
minimize the amount of time that solids spend in the clarifier.
17. Please discuss the significance of the pilot unit operating as CSTR, as opposed to a plug flow
reactor when interpreting ammonia removal and NO2/NO3 concentrations. Particularly after
the plant upset in mid -July.
The full-scale plant as well as the pilot plant operate as a series of CSTRs not as a plug
flow reactor. Brown and Caldwell would expect the full-scale plant to operate much the
same as the pilot unit CSTRs are less subject to upset conditions than plug flow reactors.
18. How will the dosing rates for phosphorus removal be controlled?
See the answer to question #13 above.
NCHA-011PROJECTS\I9047 - Clariant Treatability\GennDWQ Comments and Questions\Answers to DWQ Questions.doc

Michael Myers/Jackie Nowell
March 13, 2001
Page 5
19. Discuss the use of a grinder as opposed to a bar screen. Highlighting potential operational
problems with both systems.
Clariant does not have a way to handle municipal primary solids. Their on -site landfill is
not permitted to handle material that would be removed by a bar screen. Additionally,
Clariant seeks to avoid the potential issues with odor and nuisance pests that would arise
from handling these solids. Grinding these solids would allow them to pass through the
treatment system and be removed in the secondary clarifiers after treatment
20. Discuss the impacts of the peroxide addition on downstream treatment units.
Peroxide addition should not impact downstream treatment units — other than to possibly
alter the oxygen demand of the wastewater (it could lessen or increase). Peroxide addition
is viewed as the alternative of last resort Clariant would first send out -of -spec treated
wastewater to the 300 MG on -site storage reservoir for additional treatment at a later date.
Peroxide addition would only be used when other alternatives have been exhausted — due
to the cost of the peroxide.
21. Discuss the optimization of the 300 MG reservoir. In particular, discuss the use of the
reservoir prior to the treatment system versus after the treatment system.
The use of the reservoir in any mode other than how it is currently used would not be
prudent.
22. Schedule has the pump station construction beginning prior to obtaining a modified permit or
ATC for proposed modifications to treatment plant. Discuss the schedule and the risk
associated with proceeding with the pump station prior to approval. Assuming DWQ
approval acceptance of the Long Creek Basin wastewater cannot begin until a modified
permit is issued and construction is completed on the modified plant.
The new Long Creek Pump Station is needed to replace an aging and undersized existing
pump station. The construction of this pump station is needed whether or not Long Creek
Basin sewerage is ever treated at Clariant The wastewater will be conveyed to the Paw
Creek Pump Station and ultimately to the McAlpine Creek WWTP for treatment. The only
provisions currently made in the detailed design package for the new Long Creek Pump
Station is that an area has been reserved in the pump station wet well for installing two
variable speed pumps to convey wastewater to Clariant. If this project receives approval
from NC DENR DWQ, the pumps will be installed and the pipeline will be laid to Clariant.
23. The Long Creek Basin was undoubtedly included in the flow justification used to determine
the flow limit for the McAlpine Creek WWTP. The Division needs to discuss how if at all
this proposal may affect the McAlpine Creek NPDES permit.
The intent of this project is to forestall potential expansion of the McAlpine Creek WWTP.
11CHA-011PROJECTS119047 - Clariant Treatability\GennDWQ Comments and Questions\Answers to DWQ Questions.doc

Michael Myers/Jackie Nowell
March 13, 2001
Page 6
24. Study suggests that UV would not be effective, however UV is being proposed for this
project. The Division agrees that further evaluation is needed before deciding whether UV
disinfection is appropriate for this facility.
Trojan used "typical" municipal UV dosages to evaluate the one sample that was sent to
them during the pilot study. The discharge from Clariant will require higher dosages due
to the relatively low transmissivity of the wastewater. Brown and Caldwell has successfully
designed UV disinfection systems for primary effluent with transmissivities lower than that
observed on this project. Additional evaluations are planned to determine the dosage
requirements to effectively disinfect the combined CMUD/Clariant treated wastewater.
Brown and Caldwell can foresee no reasons why UV disinfection will not be successful at
disinfecting this wastewater. Alternative disinfection methods are not recommended for
the following reasons — chlorine has the potential for forming chlorinated organic
compounds and ozone will make non -biodegradable organic compounds biodegradable
after the point of treatment (Le.: ozone will create BOD in the effluent).
25. Study suggests that a significant portion of the TN would be in a non-bioavailable state since
it could not be degraded by the treatment system and that this nitrogen would not be
bioavailable in the receiving stream. What studies have been done to show this or how have
Brown and Caldwell determined that this statement is accurate?
No formal studies have been conducted by Brown and Caldwell. However, dye compounds
are specially formulated to be non -biodegradable to prevent color loss over time.
26. In Brown and Caldwell's opinion, with the wide variability in the influent loading, would the
use of the 300 MG reservoir as off-line storage prior to the treatment plant be more effective
in protecting the treatment plant and receiving stream than after the treatment plant? If
operated as off-line storage, it would be recommended that the influent be monitored
upstream with a feed forward control loop.
The 300 MG reservoir is more effective as a post -treatment storage basin for "off -spec"
treated wastewater than an off-line storage reservoir. This reservoir is un-lined and the
use of this reservoir to store untreated wastewater from Clariant would not be prudent.
The vast majority of the contaminants have been removed through treatment — even if it is
'toff -spec". It should be noted that the addition of domestic wastewater to this facility will
assist in leveling out the variability of the influent loading. Note that 6 million gallons of
equalization storage is planned at the Long Creek pumping station.
PS
cc: Rick Carrier, Brown and Caldwell
David Goodrich, NC DWQ
Gary Sanderson, Clariant Corporation
Barry Shearin, Charlotte -Mecklenburg Utilities
11CHA-01\PROJECTS119047 - Clariant Treatability\Gen\DWQ Comments and Questions\Answers to DWQ Questions.doc

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
�Clariant
March 12, 2001
Mr. David A. Goodrich
NPDES Unit Supervisor
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: NPDES Permit Number NC0004375; Clariant Corporation - Mt. Holly Plant
Facility Revisions
Dear Mr. Goodrich;
We appreciate very much the time you and your staff spent with us on February 15, 2001
discussing proposed revised wastewater treatment plant operations at the Mt. Holly site of
Clariant Corporation. As discussed in the meeting, Clariant should submit the following
information to DWQ.
1. Detailed information on Clariant's proposal for treating off -site wastewater and Clariant
disposal products
a. Administrative process
b. Origin of materials proposed for treatment
c. Treatment plans and revisions
d. Characterization and quality assurance process
2. Process plan for treating of CMUD domestic sewage
3. Discussion of effluent limits and their derivation (strawman)
The attachments to this letter contain all of the information requested by DWQ at the
meeting. If additional data or supporting material would be helpful, please feel free to call me at
[phone] or email me at [e-mail].
I look forward to meeting with you and others on your staff on April 4th here at the Mt.
Holly Plant for additional discussions. We would be most happy to provide a tour of the site
wastewater treatment plant, WWTP, as well as our manufacturing facilities.
Sincerely;
P.413,LTh
Gary P. Sanderson, P.E.
Plant Services Manager
_�— r_. tj
�S i1 L'= i ;•
PR R 1 5 Z' 0i
pc1c11, f; ^ ,

Clariant Corporation — Mt. Holly Plant March 12, 2001
NPDES Permit NC0004375
Discussion of WWTP Proposed Operations and Effluent Limits
The Mt. Holly Plant proposes to treat wastewater from the following origins in the site
wastewater treatment plant, WWTP. A discussion of each influent stream follows the list.
1. Clariant U.S. products for disposal (OCPSF materials)
2. Solicited OCPSF wastewater
3. Solicited petroleum containing wastewater
4. Solicited textile mill wastewater
5. Solicited soap and detergent wastewater
6. CMUD domestic sewage
7. Mt. Holly site wastewater (existing throughput)
1. Clariant U.S. products for disposal (OCPSF materials)
Materials in this stream are either finished goods that have been discontinued, finished goods
that have deteriorated during storage, or in -process materials that are substandard and cannot be
completed into saleable fmished goods. Two Clariant sites are the primary sources of these
materials; a large warehouse facility in Charlotte and an OCPSF manufacturing plant in the city
of Mt. Holly. Both sites are currently having these chemicals solidified and landfilled.
Clariant owns and operates OCPSF manufacturing and warehousing facilities throughout the
United States. A few of these sites may wish to ship materials to the Mt. Holly Plant for
treatment, but transportation, characterization testing, and administrative costs are too high for
this to be an economical altemative. The Mt. Holly Plant expects materials from these Clariant
facilities to be low volume.
Each material planned for treatment will undergo BOD and COD testing, the MSDS will be
reviewed, and an Environmental Chemist will assess compatibility within the WWTP. If the
material passes these tests/reviews, the site will agree to receive it.
Incoming waste products will be inventoried, weights and containers cross checked with original
proposals, and each container will be checked for flowability and other handling characteristics.
An environmental chemist will prepare a "batch recipe sheet" for mixing of disposal goods with
water and controlled release into the WWTP. Each batch will be a blend of roughly 1000 gallons
of disposal materials and 9000 gallons of water. The 10,000 batch will be released to the WWTP
over 12 — 24 hours. 20 — 40 gallons per minute of dilution water will be mixed with the batch
outlet as it enters the site sewer system.
Materials in this influent category will biodegrade similarly to existing wastewater. BAT is
proposed for nutrient removal and 40 CFR 414.91 limits are proposed for BOD and TSS
concentrations in the effluent.

Mt. Holly Plant: Discussion of WWTP Proposed Operations and Effluent Limits
March 12, 2001 Page 2
During 2000 the Mt. Holly Plant treated small quantities of "off specification" finished goods
from the production plant in the city of Mt. Holly. The WWTP operated quite well and there
was no impact on effluent parameters.
Since the 2000 test runs went successfully, the site wishes to begin treating these materials
routinely. As the materials are OCPSF origin products, Clariant proposes that these materials be
handled with no permit impact. Planned WWTP influent impact is approximately 30,000 gallons
per day
2. Solicited OCPSF Wastewater
The site, through a broker, will solicit treatment business from selected industrial customers.
Verification of sites having OCPSF pretreatment permits will be required. Waste materials
volume will be quantified and each material will receive 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. The source
would be especially useful as replacement BOD during plant turnarounds and other low
manufacturing periods.
The Mt. Holly Plant expects volume from this source to be roughly 5,000,000 pounds annually.
Influent volume to the WWTP is estimated at 20,000 gallons per day. Materials in this influent
category will biodegrade similarly to existing wastewater. BAT is proposed for nutrient removal
and 40 CFR 414.91 limits are proposed for BOD and TSS concentrations in the effluent.
3. Solicited Petroleum Containing Wastewater
The site, through a broker, will solicit treatment business from selected tank farm and transfer
station customers. The site intends to treat only streams with low petroleum contamination, such
as stormwater from tankfarm dikes, tank draw -off water, etc.
Plans are to install a diked feed tank for truck receipts. The feed tank would feed a constant flow
rate to an oil/water separation unit which in -turn would feed into the aerobic aeration process in
the WWTP. Oil collected in the separation unit would be sold into the fuels blending market.
Since these facilities would be new recycling/primary treatment systems at the headworks of the
WWTP, an authorization to construct would be required from the Department.
Expected influent volume from this source is estimated to be 12,000 gallons per day. Materials
in this influent category are expected to have low nutrient loading subsequent to the oil/water
separation process. Nutrient limits are proposed using BAT. TSS and O&G proposed
concentrations in the effluent are based on 40 CFR 437.21. BOD concentration is based on 40
CFR 414.91.

Mt. Holly Plant: Discussion of WWTP Proposed Operations and Effluent Limits
March 12, 2001 Page 3
4. Solicited Textile Mill Wastewater
The site, through a broker, will solicit treatment business from selected industrial customers.
Verification of sites having pretreatment permits under 40 CFR 410 will be required. Waste
materials volume will be quantified and each material will receive 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.
As with OCPSF wastewater from solicited customers, this waste stream is a filler material for the
WWTP. Organic chemicals in this stream are similar to those already being treated in the site
WWTP. Wastewater characterization, operation, and administration will be identical to that for
OCPSF wastewater.
The site expects influent volume from this source to be approximately 30,000 gallons per day.
BAT is proposed for nutrient removal and BOD and TSS concentration proposal is derived from
40 CFR 437.31.
5. Solicited Soap and Detergent Wastewater
The site, through a broker, will solicit treatment business from selected industrial customers.
Verification of sites having pretreatment permits under 40 CFR 417 will be required. Waste
materials volume will be quantified and each material will receive 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 an organic filler material for the WWTP and is an interruptible source. It
will be fed into the WWTP to maintain total plant influent BOD balancing and consistent organic
chemical feedstock for the biological system. Because of the high biodegradability of
wastewater of this type, it will be especially useful as replacement BOD during plant turnarounds
and other low manufacturing periods.
The Mt. Holly Plant expects volume from this source to be roughly 20,000 gallons per day. BAT
is proposed for nutrient removal and BOD and TSS concentration proposal is derived from 40
CFR 437.31.
6. CMUD Domestic Sewage
The proposal from Clariant and Charlotte -Mecklenburg Utilities Department, CMUD, is for
CMUD to deliver a constant 2.0 MGD of domestic sewage to the Clariant head works from its
pump station located on Long Creek. Clariant will install the following WWTP process
improvements to handle wastewater from this source.
a. Grinding and grit removal facilities at the head works.
b. Subsurface mixing equipment in pond Z-03A
c. Return activated sludge recycle to the anoxic zone and expanded flow rate system

Mt. Holly Plant: Discussion of WWTP Proposed Operations and Effluent Limits
March 12, 2001 Page 4
d. Anoxic zone in pond Z-03A
e. Expanded volume polymer feed system for the secondary clarifiers
f. Ultraviolet disinfection system for clarified effluent exiting the secondary clarifiers
The process design for these additions is being done currently. Design details for the additional
facilities will have to be submitted to the Department for authorization to construct.
Nutrient removal is based on the Catawba River Basinwide Water Quality Plan of 1999. BOD
and TSS concentrations in the effluent are based on 40 CFR 133.102.
7. Mt. Holly Site Wastewater (existing throughput)
Other than volume reductions, there are no changes in existing site wastewater. Per Catawba
River Basinwide Water Quality Plan, BAT is proposed for nutrient removal. 40 CFR 414.91
concentration limits are proposed for BOD and TSS.
The following publications and federal regulations were used as guidelines for deriving
requested effluent limits.
1. 40 CFR 133.102
2. 40 CFR 414.91
3. 40 CFR 437.21
4. 40 CFR 437.31
5. Aware's 1999 Report - Evaluation of Best Available Technology Economically Achievable
(BAT) for Control of Nutrient Discharges Clariant Corporation
6. Division of Water Quality's 1999 Catawba River Basinwide Water Quality Plan
The table on the next page indicates proposed effluent limits for each of the 13 streams
contributing influent to the WWTP. The stream volumes are consistent with Clariant drawing
number 790.53.050.01.8342, copy enclosed.
Enclosures:
1. page 39, of Aware BAT Report
2. page 61, DWQ Catawba River Basinwide Water Quality Plan

Proposed Effluent Limits: Clariant Corp. Mt. Holly Plant, NPDES Permit Number NC0004375
GPS 03.12.2001
Stream Stream. nescriotio-
No.
1 Clariant Product Disposal (OCPSF)
2 Solicited OCPSF Wastewaters
3 Solicited Petroleum Containing Water
4 Solicited Textile Mill Wastewaters
5 Solcited Soap & Detergent Wastewaters
6 CMUD Domestic Sewage
7 Groundwater Remediation
Flow BOD TSS N P
Rate Conc. Conc Conc Conc.
0.030 45 57.0 37.5 2.6
0.020 45 57.0 37.5 2.6
0.012 45 30.6 37.5 2.6
0.030 53 61.3 37.5 2.6
0.020 53 61.3 37.5 2.6
2.000 30 30.0 6.0 1.0
0.150 45 57.0 37.5 2.6
O&G BOD TSS N
Conc Limit Limit Limit
11.26 14.26 9.38
7.51 9.51 6.26
38 4.50 3.06 3.75
13.26 15.34 9.38
40 8.84 10.22 6.26
500.40 500.40 100.08
56.30 71.31 46.91
P O&G
Limit Limit
0.65 0.00
0.43 0.00
0.26 3.80
0.65 0.00
0.43 6.67
16,68 0,00
3.25 0.00
00
1.95 0.00
1.89 0.00
2.99 0.00
0.23 0.00
1.41 0.00
8 Dyes Manufacturing
0.450 45 57.0 37.5
2.6 168.89 213.92 140.74
9.76 0.
9 Specialty Chemical Manufacturing
10 Stormwater - Process Areas
11 Stormwater - Nonprocess Areas
12 Clariant Sanitary
13 River Filter Plant Backwash
Totals (annual daily avg. flow basis)
0.090
0.087
0.138
0.027
0.065
3.119
45 57.0
45 57.0
1 30.0
30 30.0
0 30.0
37.5
37.5
37.5
6.0
37.5
2.6
2.6
2.6
1.0
2.6
33.78
32.65
1.15
6.76
0.00
42.78
41.36
34.53
6.76
16.26
28.15
27.21
43.16
1.35
20.33
845.28 979.71 442.95 40.58 10.48
Requested maximum month avg.day
Existing Permit Limits
5.000
3.900 max.
urce o . mit Derivation
1 & 2 40 CFR 414.91 & BAT
3 40 CFR 437.21, 414.91 & BAT
4 40 CFR 437.31 & BAT
5 40 CFR 417, 437.31 & BAT
6 & 12 40 CFR 133.102 & Basinwide Plan
7,8,9,10 40 CFR 414.91 & BAT
11 & 13 Amalgamation & BAT
_ TSS V P O1:
45 57.0 37.5
30 30.6 37.5
53 61.3 37.5
53 61.3 37.5
30 30.0 6.0
45 57.0 37.5
2.6
2.6 38
2.6
2.6 40
1.0
2.6
852.00 976.00 651.00
NH3
Notes:
Stream 5 O&G interpolated from
40 CFR 417
Nitrogen limit to be effective during
summer months, not cold weather
months

i
w
1
Using the US EPA methodology summarized in Section 1.3, AEI evaluated baseline effluent
TN and TP wasteload based on the statistical analysis of the full-scale operating data under
optimized conditions to define appropriate average monthly effluent limits. The TP was based
on the data for the five (5) monthly periods May 5, 1999 through September 30, 1999, which
corresponds to the period during which phosphorus addition was minimized. The TN analysis
is based on the data from April 1, 1999 through September 30, 1999, which corresponds to
summer operating conditions.
The statistical analyses of the TP and TN data presented in Figures 6 and 7, respectively.
1 These data, which are included in Appendix C, indicate 95 percentile concentrations of 2.6
mg/1 TP and 37.5 mg/1 TN. These concentrations represent the baseline concentrations and the
Imonthly average concentration limits that could be met by the existing optimized BAT
treatment plant without incorporation of additional treatment processes. Based on the long
1 term average (LTA) flows previously determined bythe NCDENR for the Clariant discharge
flow of 1.42 MGD, the proposed monthly average mass discharge limits are:
I TP 30.8 lb
s/day
TN 444.1 lbs/day
I. The baseline TN represents 32% p nts a reduction in nitrogen from Clariant's current ammonia
nitrogen (NH3-N) limit of 651 lb/d.
1
r
1
1
1
t
39
FINAL
October, 1999

1995 Recommended Point Source Nutrient Reduction Strategies
• No new discharges allowed on the lake mainstem or its tributaries, unless an evaluation of
engineering alternatives (EAA) shows that it is the most environmentally sound alternative.
For any new or expanding discharges that meet this requirement, it was recommended that
advanced treatment technology be required.
• Any new or expanding facility with a permitted design flow of greater than or equal to 1
MGD was required to meet monthly average limits of 1.0 mg/1 total phosphorus (TP) and 6.0
mg/1 total nitrogen (TN), (TN applies to summer only). For new or expanding facilities with
a permitted design flow of less than 1 MGD but greater than 0.05 MGD (50,000 gallons per
day), a TP limit of 2.0 mg/1 was recommended. No expansion was to be allowed if it
increased the total nutrient load from the facility, unless an EAA shows that it is the most
environmentally sound alternative.
• All industrial discharges were to be handled on a case -by -case basis. DWQ recommended
that industries in the management area control TP and TN to best available technology levels.
• Existing discharges to the lake mainstem and tributaries were encouraged to remove that
discharge when alternatives became available. Programs such as the Charlotte -Mecklenburg
Utility (CMUDD) sewer line extension project were supported.
• Additional recommendations were made for point source discharges to the Catawba Creek
and Crowders Creek watersheds to reduce nutrient enrichment. These recommendations
called for more stringent permit limits for nutrients on all dischargers with permitted design
flow of >_ 0.05 MGD within the Catawba Creek watershed (0.5 mg/1 TP and TN limits of 4
mg/1 in summer and 8 mg/1 in winter) by January 1, 2006. Interim limits of 1.0 mg/1 TP and
6.0 mg/1 TN become effective January 1, 2001. By January 1, 2000, all facilities with
permitted design flow of >_ 1MGD will be required to meet limits of 1.0 mg/1 TP and 6.0 mg/1
TN in summer within the Crowders Creek watershed.
• Incentives should be established to encourage privately -owned facilities to tie on to larger
municipal WWTPs.
1995 Recommendations for Nonpoint Sources
Future study will be conducted to reevaluate the extent of the defined management area.
Nonpoint sources on the South Fork Catawba River upstream of Long Creek will be further
assessed to determine what effect additional control of nutrients in the upper South Fork Catawba
River basin may have upon eutrophication in Lake Wylie. Results of this study will be
considered during the development of the next Catawba River Basin Plan.
All tributaries to Lake Wylie should be targeted by the NC Division of Soil and Water
Conservation for cost share funds for use in implementation of best management practices
(BMPs). When possible, resources should be targeted toward implementation of BMPs in the
Catawba Creek, Crowders Creek and the South Fork Catawba River watersheds. The South Fork
Catawba River watershed should be considered the highest priority for implementation of BMPs.
Status of Progress
The Lake Wylie Management Strategy is still being implemented, and therefore, the full effects
of the strategy are yet to be realized. DWQ has already required marked reductions in point
Section A: Chapter 4 - Water Quality Issues Related to Multiple Watersheds in the Catawba River Basin 61

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Clariant
MOUNT HOLLY EAST PLANT
SELF -AUTHORIZATION PROTOCOL FOR
NON-CLARIANT, NON -HAZARDOUS WASTE RECEIPT
VAR i, LJJi
DE? R
POINS SOLIgE3P.Ab -
Introduction
These procedures provide an outline of the evaluation process Clariant - Mount Holly East will
utilize to accept off -site waste for wastewater treatment. This plan covers the protocol for initial
approval of off -site non-Clariant waste streams and the protocol for quality assurance and
verification for continuing acceptance of those waste streams.
New Wastestream Approval Procedures
1) Once a waste generator expresses interest in utilizing the Clariant - Mount Holly East
facility, the site Customer Service Representative will procure all pertinent information
concerning the composition of the waste under review, the process generating the waste,
any analytical data the generator may possess, all applicable Material Safety Data Sheets
(MSDS), and any relevant knowledge the generator has concerning the waste.
2) The above information will be compiled in a routing file and circulated to the following
members of Clariant - Mount Holly East's staff for their evaluation:
A. Environmental Chemist/Engineer
B. WWTP Analytical Chemist
3) The Environmental Chemist/Engineer will perform an in-depth review of the chemical
nature of the waste and the process from which the waste is generated. This review will
include, but may not be limited to, the following:
A. A complete evaluation of all applicable MSDS's.
i. Determining if waste exhibits hazardous characteristics as per 40 CFR
261:
a. Determining if the material will react in an adverse manner after
exposure to water, air, or any other naturally occurring conditions
per the criteria of 40 CFR 261.23.
Revised March 2001
1

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
b. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 261.21.
c. Determining if the waste could exhibit the characteristic of
corrosivity per 40 CFR 261.22.
d. Determining if heavy metals and organics meet or exceed the
concentrations specified in 40 CFR 261.24
ii. Determining if waste is a "listed" hazardous waste as per 40 CFR 261
based on the process from which the waste is generated and/or the raw
materials which comprise the waste (i.e. discarded commercial chemical
product).
iii. Determining the relative concentrations of any listed hazardous
constituents.
iv. Investigating the toxic effects, using up-to-date references, that may be
associated with any of the listed waste constituents, including threshold
and non -threshold health effects.
v. Determining the potential that may exist for the processing of the waste to
create an objectionable odor, of which the intensity might result in its
detection off -site. (NOTE: Clariant recognizes the subjectivity of an
"objectionable odor", and will employ analytical testing as well as a
"common sense" approach when an odorous waste is involved.)
B. A review of all other information that the generator has provided, including any
analytical data and the first draft of the completed profile sheet.
i. Determining if the chemical composition that the generator has provided
is satisfactory (qualitatively and quantitatively).
ii. Determining if the "name of waste" and the "process generating waste"
fully and accurately describes each.
iii. Evaluating any analytical data and determining if it is relevant (e.g., Is the
data current and applicable? Did a qualified laboratory perform the
analysis?).
iv. Identifying what additional information the generator needs to provide, if
any.
Revised March 2001
2

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
C. An assessment of the accuracy of the information the generator has provided
concerning physical characteristics of the waste.
i. Comparing the physical state and consistency of the sample with profiled
information.
ii. Associating the odor of the waste with specific chemical groups (e.g.,
Does the sample exhibit an odor associated with volatile organics?
Halogenated organic compounds? Sulfurous compounds?).
iii. Determining the oil content (e.g., Does a visual inspection of the sample
correlate with the information on the profile?).
iv. Verifying the color and any other characteristics which can be confirmed
visually.
D. A determination of all the analytical tests which must be performed on a
representative sample prior to completing a final profile sheet. (NOTE: Analytical
test methods employed have been approved by the United States Environmental
Protection Agency and are prescribed in the EPA manual SW-846 and Standard
Methods.)
i. Tier I Testing
For all non-Clariant waste materials a standard battery of testing will be
performed for each new material submitted for approval. The Tier I tests
are as follows:
a. Chemical Oxygen Demand (COD)
b. pH
c. Oil and Grease
d. Phenols
e. Respirometry Testing
ii. Tier H Testing
For all non-Clariant waste materials submitted for approval, Clariant may
require testing for parameters other than the Tier I parameters. The Tier II
testing is optional and is only done when the Environmental
Chemist/Engineer believes it is necessary for a waste stream approval.
Any of the following tests may be performed as part of the Tier II testing:
a. Flash Point
b. RCRA Metals along with copper, zinc, and nickel.
c. Volatile compound scan
d. Semi -Volatile compound scan
e. Biological Oxygen Demand (BOD)
Revised March 2001
3

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
E. Coordinating treatability testing with the WWTP Analytical Chemist and WWTP
Supervisor.
4) The Environmental Chemist/Engineer will perform a cursory review of available
information and provide any relevant comments or suggestions.
5) The Environmental Manager may review additional testing requirements identified by
the Environmental Chemist/Engineer and approve the suggested tests and/or provide
recommendations.
6) The Customer Service Representative will procure any additional information the
Environmental Chemist/Engineer has requested. The Customer Service Representative
will route the sample to Clariant - Mount Holly East's laboratory, accompanied by a
request form describing all the analytical data needed.
7) Clariant - Mount Holly East's WWTP analytical laboratory will perform, or contract out,
all the tests deemed essential. The results of these tests will be reported on a standardized
form, and all worksheets and subsequent report forms will be filed via a Mount Holly
Profile Number. (NOTE: Once a profile number is assigned, this information file will be
referenced by profile number.)
8) The laboratory will provide the Environmental Chemist/Engineer with the completed
analytical data. (NOTE: The WWTP Analytical Chemist will review this data and
approve it prior to distribution.)
9) The Environmental Chemist/Engineer will compile the analytical data and all other
required information on a profile sheet and assign the customer a profile number.
10) All of the above information, including the completed profile sheet, will be returned to
the routing file and circulated to each of the following for their final review and approval:
A. The Environmental Chemist/Engineer
B. WWTP Supervisor
C. The Environmental Manager (Optional)
Each of the above persons will approve the final package prior to waste receipt.
11) The Environmental Chemist/Engineer will issue a `Notice of Authorization" for the
approved wastestream to the appropriate Customer Service Representative. This notice
will stipulate any conditional monitoring involved regarding the processing and disposal
of the waste. The approved waste will be added to Clariant - Mount Holly East's "Non -
Hazardous Waste Approval Listing".
Revised March 2001
4

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Ouality ControllOuality Assurance Policy
1) Clariant - Mount Holly East will maintain its stringent quality control program for
incoming wastes. A representative sample will be taken from each containerized waste
and compared to the corresponding profile sheet. The following describes tests and
observations utilized by quality control.
A. Extracting representative core samples from each:
i. Bulk Shipment,
ii. Containerized Waste Shipment (drums).
(NOTE: Samples of containerized wastes are composited according to
"like" physical characteristics. In the event a composite sample fails the
QA/QC evaluation, individual samples are taken from each drum
represented in the composite and tested.)
B. Comparing the physical characteristics of the sample to those listed on the waste
profile sheet (See Attachment
A). This comparison will include evaluating:
i. Color,
ii. Odor,
iii. Physical State,
iv. Viscosity.
C. Analyzing the pH of the waste.
D. Observing any reactions (e.g. fuming, boiling, etc.).
Revised March 2001
5

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
When any discrepancies in the waste are observed, an off -specification notification is
completed, noting the discrepancies. This memo is addressed to the Customer Service
Representative and the Environmental Manager. An amendment to the profile will be
issued to account for the change in the waste when deemed appropriate. (NOTE: The
generator will be advised of this situation. In some instances, the waste may be rejected
because of an off -spec characteristic (e.g. strong odor).
In the event a waste is identified as exhibiting a hazardous characteristic, a non-
conforming/off-specification waste memo will be completed and routed to the
Environmental Manager and the Customer Service Representative. (NOTE: The
Environmental Chemist/Engineer will take the active role in this matter.) Prudent
measures will be taken to isolate and secure the waste.
If a waste exhibits a characteristic potentially outside the parameters for non -hazardous
waste, the waste will be rejected and the material removed from the facility. If the waste
requires additional laboratory analysis to determine if it is a RCRA hazardous waste, the
material will be considered rejected on the day the laboratory analysis is returned
indicating a potential hazardous characteristic, and the material will be removed from the
site.
If the generator chooses to have the waste returned to his facility, the Customer Service
Representative will make arrangements for the generator to use a hazardous material
transporter. Also, Clariant-Mount Holly will indicate the rejection to the generator on the
bill of lading, non -hazardous manifest, etc. This rejection will stipulate the suspected
hazard class.
Clariant - Mount Holly East will offer the generator the choice of having the waste routed
to a TSDF for disposal. Clariant - Mount Holly East will reject the waste on the
discrepancy portion of the non -hazardous waste manifest. The generator will complete a
hazardous waste manifest and forward this document to Clariant - Mount Holly East; a
copy of the non -hazardous manifest will be attached. Clariant - Mount Holly East will
assist in having the waste transported via a hazardous waste carrier to the designated
facility.
Revised March 2001
6

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Information Maintained For The NCDENR Division of Water Quality
1) Clariant - Mount Holly East will create and maintain records for all new wastestream
profiles prior to processing the waste.
2) Clariant - Mount Holly East will also maintain an updated Generator Listing. This listing
will include:
A. The generator profile number,
B. The generator name and address,
C. The name of the waste,
D. Any pertinent comments (e.g. watch pH, flash point, need copy of non -hazardous
waste manifest, etc.)
3) Clariant — Mt. Holly East will treat all incoming materials using a "batch method".
Clariant will maintain records of all "batches" of waste material treatments. This batch
record will contain details of the quantities of individual profiled wastes treated.
Revised March 2001
7

Clariant Corporation — Mount Holly East Plant
Clariant Internal Waste Acceptance Protocol
Clariant
MOUNT HOLLY EAST PLANT
SELF -AUTHORIZATION PROTOCOL FOR INTERN
CLAMANT NON -HAZARDOUS WASTE RECEIPT
MAR 1 5 2001
l I
DER - WA(ER QUALITY
POI'iT SOURCE BRANCH
Introduction
These procedures provide an outline of the evaluation process Clariant - Mount Holly East will
utilize to accept internal Clariant waste for wastewater treatment. These intemal wastes will
generally be off -specification products from Clariant production facilities and from Clariant
contract warehouse facilities. This plan covers the protocol for initial approval of internal
Clariant waste streams and the protocol for quality assurance and verification for continuing
acceptance of those waste streams. Because Clariant has a thorough knowledge of its products
and processes, the plan for Clariant product acceptance is less comprehensive than for non-
Clariant products.
New Wastestream Approval Procedures
1) Once a Clariant production facility or contract warehouse facility expresses interest in
utilizing the Clariant - Mount Holly East facility, the site Environmental Chemist/Engineer
will procure all pertinent information concerning the composition of the waste under review,
the process generating the waste, any analytical data the generator may possess, all
applicable Material Safety Data Sheets (MSDS), and any relevant knowledge the generator
has concerning the waste.
2) The Environmental Chemist/Engineer will perform an in-depth review of the chemical nature
of the waste and the process from which the waste is generated. This review will include, but
may not be limited to, the following:
A. A complete evaluation of all applicable MSDS's.
i. Determining if waste exhibits hazardous characteristics as per 40 CFR
261:
a. Determining if the material will react in an adverse manner after
exposure to water, air, or any other naturally occurring conditions
per the criteria of 40 CFR 261.23.
b. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 261.21.
Revised March 2001
1

Clariant Corporation — Mount Holly East Plant
Clariant Internal Waste Acceptance Protocol
c. Determining if the waste could exhibit the characteristic of
corrosivity per 40 CFR 261.22.
d. Determining if heavy metals and organics meet or exceed the
concentrations specified in 40 CF'R 261.24
ii. Determining if waste is a "listed" hazardous waste as per 40 CFR 261
based on the process from which the waste is generated and/or the raw
materials which comprise the waste (i.e. discarded commercial chemical
product).
iii. Determining the relative concentrations of any listed hazardous
constituents.
iv. Investigating the toxic effects, using up-to-date references, that may be
associated with any of the listed waste constituents, including threshold
and non -threshold health effects.
v. Determining the potential that may exist for the processing of the waste to
create an objectionable odor, of which the intensity might result in its
detection off -site. (NOTE: Clariant recognizes the subjectivity of an
"objectionable odor", and will employ analytical testing as well as a
"common sense" approach when an odorous waste is involved.)
C. An assessment of the accuracy of the information the generator has provided
concerning physical characteristics of the waste.
i. Comparing the physical state and consistency of the sample with profiled
information.
ii. Verifying the color and any other characteristics which can be confirmed
visually.
D. A determination of all the analytical tests which may need to be performed on a
representative sample will be made prior to accepting the waste. Because Clariant
has a thorough knowledge of its processes and products, there may only be a need
for minimal testing, if any, to ensure compatibility of the waste with the
wastewater treatment system. Testing of Clariant products will be done mainly to
fill data gaps in the treatability of the waste. Therefore the tests which may be
performed on the waste Clariant materials are as follows:
a. Chemical Oxygen Demand (COD)
b. pH
c. Biological Oxygen Demand (BOD)
d. Respirometry Testing
e. Total Phenols
Revised March 2001
2

Clariant Corporation — Mount Holly East Plant
Clariant Internal Waste Acceptance Protocol
The decision to perform testing and well as the testing regimen (if testing is
deemed necessary) for a particular Clariant product or waste material will be
determined by the Environmental Chemist/Engineer and the WWTP Analytical
Chemist.
E. Coordinating treatability testing with the WWTP Analytical Chemist and WWTP
Supervisor.
4) The Environmental Chemist/Engineer will perform a cursory review of available
information and provide any relevant comments or suggestions.
5) The Environmental Manager may review additional testing requirements identified by
the Environmental Chemist/Engineer and approve the suggested tests and/or provide
recommendations.
6) Clariant - Mount Holly East's WWTP analytical laboratory will perform, or contract out,
all the tests deemed essential. The results of these tests will be reported on a standardized
form, and all worksheets and subsequent report forms will be filed via an Clariant-
internal Mount Holly Profile Number. (NOTE: Once this profile number is assigned, this
information file will be referenced by profile number.)
7) The laboratory will provide the Environmental Chemist/Engineer with the completed
analytical data. (NOTE: The WWTP Analytical Chemist will review this data and
approve it prior to distribution.)
9) The Environmental Chemist/Engineer will compile the analytical data and all other
required information and assign the Clariant waste an Clariant-internal Mount Holly
profile number.
Revised March 2001
3

Clariant Corporation — Mount Holly East Plant
Clariant Internal Waste Acceptance Protocol
Quality Control/Quality Assurance Policy
1) As stated earlier, because of Clariant's thorough knowledge of its products and processes,
testing of incoming materials will probably not be necessary. Therefore, for internal
Clariant materials, Clariant - Mount Holly East will primarily use visual observations to
maintain quality assurance.
The operator charging the waste materials will perform the following when charging the
material to the accumulation tank.
A. Comparing the physical characteristics of the sample to those listed on the batch
sheet charging instructions. This comparison will include evaluating:
i. Color,
ii. Odor,
iii. Physical State,
iv. Viscosity.
B. Observing any reactions (e.g. fuming, boiling, etc.).
If any discrepancies are noted while charging, the material transfer of the waste will be
halted, and the material will be removed from the charging area.
The material will then either be returned to the generating Clariant facility, or undergo
identification testing at the Clariant — Mount Holly East facility.
Information Maintained For The NCDENR Division of Water Quality
1) Clariant - Mount Holly East will create and maintain records for all new Clariant-internal
wastestreams.
2) Clariant - Mount Holly East will also maintain an updated Clariant facility/contract
warehouse facility listing. This listing will include:
A. The Clariant-internal profile numbers,
B. The facility name and address,
C. The name of the waste,
D. Any pertinent comments (e.g. watch pH, flash point, need copy of non -hazardous
waste manifest, etc.)
3) Clariant — Mount Holly East will treat all incoming materials using a "batch method".
Clariant will maintain records of all "batches" of waste material treatments. This batch
record will contain details of the quantities of individual profiled wastes treated.
Revised March 2001
4

Proposed Effluent Limits: Clariant Corp. Mt. Holly Plant, NPDES Permit Number NC0004375
GPS 03.12.2001
Stream Stream Description
No.
1/4/1 Clariant Product Disposal (OCPSF)
2 Solicited OCPSF Wastewaters
.i3 Solicited Petroleum Containing Water
4 Solicited Textile Mill Wastewaters
5 Solcited Soap & Detergent Wastewaters
6 CMUD Domestic Sewage
�� r \Groundwater Remediation
Dyes Manufacturing
9 Specialty Chemical Manufacturing
\19 Stormwater - Process Areas
2 ,. N-Stormwater - Nonprocess Areas
12 Clariant Sanitary - 5u% gs
11.RivPr Filter Plant Backwash
Totals (annual daily avg. flow basis)
Requested maximum month avg.day
Existing Permit Limits
Flow BOD TSS N P
Rate Conc. Conc Conc Conc
0.030 45 57.0 7.5- 2.6
0.020 45 57.0 2.6
0.012 45 30.6 37.5 2.6
0.030 53 61.3 `27.5 2.6
0.020 53 61,3 37.5 2.6
2.000 30 30.0 6.0 1.0
0.150 45 57.0 37.5 2.6
0.450 45 57.0 37.5 2.6
0.090 45 57.0 37.5 2.6
0.087 45 57.0 37.5 2.6
0.138 1 30.0 37.5 2.6
0.027 30 30.0 6.0 1.0
0.065 0 30.0 37.5 2.6
3.119
5.000
3.900 max.
O&G BOD TSS
Conc Limit Limit
11.26 14.26
7.51 9.51
38 4.50 3.06
13.26 15.34
40 8.84 10.22
500.40 500.40
56.30 71.31
168.89 213.92
33.78 42.78
32.65 41.36
1.15 34.53
6.76 6.76
0.00 16.26
Stream Source of Limit Derivation
Mc.
1 & 2 40 CFR 414.91 & BAT
3 40 CFR 437.21, 414.91 & BAT
4 40 CFR 437.31 & BAT
5 40 CFR 417, 437.31 & BAT
BOD TSS N P O&G
Conc. Conc. Conc. Conc. Conc.
45 57.0 37.5 2.6
30 30.6 37.5 2.6 38
53 61.3 37.5 2.6
53 61.3 37.5 2.6 40
6 & 12 40 CFR 133.102 & Basinwide Plan
30 30.0 6.0 1.0
7,8,9,10 40 CFR 414.91 & BAT
11 & 13 Amalgamation & BAT
45 57.0 37.5 2.6
845.28 979.71
852.00 976.00
N P
Limit Lirrit
9.38 0.65
6.26 0.43
3.75 0.26
9.38 0.65
6.26 0.43
100.08 16.68
46.91 3.25
140.74 9.76
28.15 1.95
27.21 1.89
43.16 2.99
1.35 0.23
20.33 1.41
442.95 40.58
651.00
NH3
O&G
Limit
0.00
0.00
3.80
0.00
6.67
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.48
Notes:
Stream 5 O&G interpolated from
40 CFR 417
Nitrogen limit to be effective during
summer months, not cold weather
months

Environmental and
Industrial Services
D
Post Office Box484
High Point, NC 27261
Phone: [phone]
Fax: [phone]
March 7, 2001
Mr. Gary P. Sanderson, P.E.
ESHA Leader
Clariant Corporation
Mt. Holly Plant
P.O.Box 669246
Charlotte, North Carolina 28266-9246
Re: Requested Waste Water Information
Dear Gary:
Enclosed you will find the information you have requested regarding estimated volumes
relative to waste types.
The following information is submitted based upon the information provided.
Total annual volumes based upon information provided by Clariant.
• Daily 125,000
• Annual 32,500,000 (based on 5 days per week)
Preliminary annual volumes .
• 437 — Petroleum Waters (include # 464 & 467)
• 414 — OCPSF Waters
• 410 — Textile Waters
• 417 — Soaps & Detergents
• Others .(include #433 and non cat waste)
• 455 — Pesticides (unknown)
When submitting your permit you may consider the following
to reach your desired totals. Keep in mind this is based on a 5
you are basing volumes on 7 days per week you can adjust ac
• 437 — 43% or
• 414-35% or
• 410-16% or
• 417-07% or
• Others — 07% or
• 455-<01% or
7,500,000
6,090,000
2,870,000
1,250,000
1,250,000
120,000
percentages and volumes
day per week schedule. If
cordingly.
13,975,000 gallons
11,375,000 gallons
5,200,000 gallons
2,275,600 gallons
2,275,000 gallons
325,000 gallons
•

March 7, 2001
Mr. Gary P. Sanderson, P.E.
ESHA Leader
Clariant Corporation
Page Two
When reviewing this information please keep in mind that several conditions will allow
fluctuations in the volumes generated.
• Event work (special one time projects)
• Emergency Work.
• Acceptable waters, not listed.
We do recommend that you include Cat. Numbers 464, 467 & 433 to your permit.
Although they may be from the metal industry they do represent a large portion of the
waters that are out there. Additionally, we can be very selective in the acceptance criteria
for waters from these categories.
Mr. Sanderson, A&D is excited about the opportunity to work with you and Clariant
Corporation on this endeavor. With our combined efforts and knowledge we will be
successful and make an impact in the Southeast.
If you have any questions or comments you can reach us by calling 800-434-7750. We
will be happy to assist you however we are able.
Again, thank you and we will be looking forward to speaking with you soon.
Respectfully Submitted,
Michael P. Milchuck
A&D Environmental and Industrial Services, Inc.

Agenda for NC DENR DWQ Meeting
February 15, 2001
I. Introduction / Overview / Purpose
II. Summary of Pilot Study Results
A. BOD/COD
B. Nitrogen
1. TKN
2. Organic Nitrogen
3. Ammonia
4. Nitrate / Nitrite
C. Phosphorous
III. Proposed Treatment Plant Modifications
A. Pump Station
B. Headworks
C. Activated Sludge Process
D. Disinfection
IV. Timetable for Improvements
V. Permit Limits
VI. Action Plan / Schedule
19047/WPMgenda for NC DENR Meeting

Process Water S
1 1/2"
Process Water
Spray nozzle for
container cleaning
n
to �-�a--
v`
Diaphragm Pump
Drums and/or Totes
Existing Drowning Tank
DT-405
D4
1 1/2"
Notes:
1. Bulk shipment handling is not included.
2. Waste material will not have odor problem.
3. CPVC piping is acceptable.
OD 2" 2" ►S Acid Sewer
tl
Process Water—>C1 Alkaline Sewer
1 1/2"
OFF -SITE WASTE HANDLING AT BUILDING 16
D. Shah
Feb 7, 2001

64-004fr
> 1/"o1- L4m113 WiOS INreFep7
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Agenda for NC DENR DWQ Meeting
February 15, 2001
I. Introduction / Overview / Purpose
II. Summary of Pilot Study Results
A. BOD/COD
B. Nitrogen
1. TKN
2. Organic Nitrogen
3. Ammonia
4. Nitrate / Nitrite
C. Phosphorous
III. Proposed Treatment Plant Modifications
A. Pump Station
B. Headworks
C. Activated Sludge Process
D. Disinfection
IV. Timetable for Improvements
V. Permit Limits
VI. Action Plan / Schedule
19047/WPAAgenda for NC DENR Meeting

2000 Clariant TN, NH3/loading w/o Study months
Date Avg. Qw (mgd) Avg. TN (mg/I) Avg. TN Load (#/d) Avg. NH3 Load (#/d) Avg. NH3 (mg/I)
Jan-00 1.3032 10.9 118.5 44.0 4.1
Mar-00 1.4341 13.4 160.3 117.0 9.8
Apr-00 1.461 5.1 62.1 156.4 12.8
May-00 1.3061 36 392.1 195.7 18.0
Sep-00 1.4073 23.8 279.3 323.5 27.6
Oct-00 1.0041 54.9 459.7 153.8 18.4
Nov-00 1.2023 7.2 72.2 12.2 1.2
Dec-00 1.4645 8.4 102.6 14.5 1.2
1.3228 20.0 205.9 127.1 11.6
Prior to Treatability Study
Date Avg. Qw (mgd) Avg. TN (mg/I) Avg. TN Load (#/d) Avg. NH3 Load (#/d) Avg. NH3 (mg/I)
Jan-00 1.3032 10.9 118.5 44.0 4.1
Mar-00 1.4341 13.4 160.3 117.0 9.8
Apr-00 1.461 5.1 62.1 156.4 12.8
May-00 1.3061 36 392.1 195.7 18.0
1.3823 17.8 202.5 167.3 14.4
After Treatability Study
Date Avg. Qw (mgd) Avg. TN (mg/I) Avg. TN Load (#/d) Avg. NH3 Load (#/d) Avg. NH3 (mg/I)
Sep-00 1.4073 23.8 279.3 323.5 27.6
Oct-00 1.0041 54.9 459.7 153.8 18.4
Nov-00 1.2023 7.2 72.2 12.2 1.2
Dec-00 1.4645 8.4 102.6 14.5 1.2
1.3635 13.1 142.3 44.0 4.1
jmn
2/14/01

Total Nitrogen [lb/day]
2500
2000
1500
Total Nitorgen Mass Analysis for Clariant Industries
1000 -
500 -
0
1473.4
Nitrogen Loading
Based on BAT
from AWARE Study
444.1
317.9
Nitrogen Loading using data from the
Brown and Caldwell Treatability Study
extrapolated to 3.9 MGD
1001.8
484.6
513.9
2045.9
1232.7
Actual Clariant
WWTP Loadings for
2000 prior to and
after treatability study
202.5
142.3
JO\G�o \��\��� \��G� \.C\ `��'GC� G>� �'G� `Q�eS oo�o
cfr
Q�,. o bog° o Qoo`
J J
Qc oo
Q

70
Total Nitrogen Concentration Analysis for Clariant Industries
60 -
50 -
J
E. 40 -
w
a)
20 -
10-
Nitrogen concentration
Based on BAT
from AWARE Study
13.7 � e I
9.
err
O\G
G�J
45.3
Nitrogen concentration using data from
the Brown and Caldwell Treatability Study
30.8
14.9
15.8
62.9
37.9
Actual Clariant
WWTP Loadings
for 2000 prior to
and after treatability
study
17.8
13.1
�\-\ JO ��� JO • ��� JO Jai • Jai
G Gym ���co So�G`� Qoco GP (e.. �\Jo�
Qi ,�Q N.
Q

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

140 -
120 -
100 -
60 -
40 -
20 -
0
Combined CMVIU / Clariant Pilot Unit - TKN Removal
6/26/2000
7/10/2000
7/24/2000
Date
8/7/2000
- - + - - TKN-in ■ TKN-out
8/21/2000
9/4/2000
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

Nitrate -Nitrite, mgfL
Combined CMU / Clariant Pilot Unit - Nitrate / Nitrite Removal
Date
- - + - -Nitrate-Nitrite-in Nitrate -Nitrite -out
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

J
H
1000
900 -
800 -
700 -
600 -
500 -
400 -
300 -
200 -
100 -
Combined CMU / Clariant Pilot Unit - TSS Removal
Date
- - + - - TSS-in
Worksheet in G: 19047 - Clariant Treatability WP Reports Chaptcr 3 - Pilot Study Report.doc

200 -
O
cc 150 -
Combined CMU / Clariant Pilot Unit - BOD Removal
4/A
•
•
•
•
•
•
•
• -
.•,
•
•
Date
- - • - - BOD-in ■ SBOD-out

E
Ll
0
U
Combined CMU / Clariant Pilot Unit - COD Removal
8/21/2000
Date
- - + - - COD -in • SCOD-out
9/4/2000
Worksheet in G: 19047 - Clariant Treatability WP Reports Chapter 3 - Pilot Study Report.doc

10
Do
co
SOLICITED
DISPOSAL MATERIAL
(PROPOSED)
CMUD
(PROPOSED)
CLARIANT OFF —SPEC.
MATERIALS
(PROPOSED)
GROUND WATER
REMEDIATION
DYES
MANUFACTURE
SPECIAL CHEM.
MANUFACTURE
NON CONTACT
COOLING
PRODUCTS
82
ALKALINE ACID
SEWER SEWER
90
•
EVAPORATION 45
105
STEAM
GENERATION
75
STORM
WATER
225
•
POTABLE WATER
CITY OF CHARLOTTE
SANITARY WASTE 27
WATER
TREATMENT
FILTER BACKWASH 65
NOTE:
FLOW FROM THE THREE SOURCES AT THE
TOP LEFT ARE PROPOSED. ALL OTHERS. 198
ARE BASED ON EXISTING OPERATIONS EVAPORATION
OR PLANNED SHUTDOWNS.
NEUTRALIZATION
STORM FLOW
NEUTRALIZATION
STORM FLOW
STORAGE
PRIMARY
CLARIFIERS
SLUDGE
FILTRATION
SLUDGE
LANDFILL
ACTIVATED
SLUDGE
STORM FLOW
STORAGE
952 WATER INTAKE
SETTLING
CANAL
STORAGE
65
CATAWBA RIVER
FLOW
THIS OWAWING IS A PRIVATE AND CONRDENDAL CDNIUNICA110N AAO THE PROPERTY OF CLAMANT CORPORATION,
MT. HMV PLANT. IT MUST NOT BE COPED OR LOANED WIDIOUT THE CONSENT OF CLAMANT CONP0RA11cN, AND
MUST BE PROMPTLY RETURNED ON REQUEST OR CCWP TION OF ORDER THIS DRAWING HAS BEEN CREATED MATH
'mow CO NOT MANUALLY DRAFT ON TTIS COPY,
--r AP#O. PROJECT DOWER
1/19/01
DH
ISSUED FOR COMMENTS
Fh�D. MAINTENANCE
10. PRDDUCraN
PATE
AFvo, FA* MAFL/ATISE
BIE
APPROVED EM
DATE
ACTIVATED
SLUDGE
SECONDARY
CLARIFIERS
1
POLISHING
POND
POLISHING
POND
POST
AERATION
EFFLUENT
METERING
3,101
DATE
APP'D. mums
ARP'). SAM./EI imi
DATE
APPROVED 9r
DAZE
WNW(
83420100
ZI.Clariam
Mt. Holly Plant, P.O. Box 089248, Charlotte, North Carolina 28288
1RLz
DEPARTMENT 50
PROCESS FLOW DIAGRAM
WATER FLOW SCHEMATIC - PROPOSED
NPDES PERMIT NC0004375
REV. DATE
PROJECT NO.
DRAWN
CHECKED
APP.D.
REVISION DESCR1PDSOH1
APPMW�D 9r
GATE
APPHOrED 9r
PLOT sc./I—m o
1=1
SCALE
NONE
SHEET HO.
1 OF 1
Dw9. Na
760.53.050.01.8342
REv

CLARIANT
GROUNDWATER
CLARIANT
ALKALINE SEWER
Ume
ACID SEWER-
CMUD
WASTEWATER
PARSHALL FLUME
r____
ACID PRIMARY CLARIFIER NO 1
NEUTRALIZATION
GRINDER
r
GRIT
REMOVAL
FROM 300MG
RESERVOIR
FLOATING AERATORS
JET MIXING
W AEROBIC ZONE ' /
�VVVVV VV V VV\LLV V'LLVV__1LVy%'%
ACTIVATED SLUDGE LAGOON
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.)-i 4
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.
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BELT PRESSES
1
RLTRATE ---
soups
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- -- - LANDFILL
TO CATAWBA
RIVER
TO RESERVOIR
RESERVOIR__�
TRANSFER PUMP
BROWN AND
CALDWELL
LNE IS 2 INCHES
AT FULL SIZE
(F NOT 2.-SCALE AC RVINGLY)
FLE CMUD\19047\CAD
DRAWN J PORTER
DESIGNED P SCHULER
CHECKED P SCHULER
CHECKED R CARRIER
REVISIONS
DESCRIPTION
BY DATE
AP
CLARIANT CORPORATION
CLARIANT
WASTEWATER TREATMENT FACILITY
IMPROVEMENTS
CLARIANT WWTF
PROJECT NUMBER
19047
DRAWING NUMBER
SUBMITTED:
APPROVED:
APPROVED:
Feuer MUNN
DATE
DATE:
DATE
PROPOSED FLOW DIAGRAM
SHEET NUMBER

BASIN SEWER
004,444„-
bANA
6,0
CLARIANT WWIP
CATAWBA RIVER
300 MG STORAGE 1
RESERVOOt
0rj5I I. I
11
•
i� 11
11
11
11
//
4t
�11
11
1\
,11
DOMING CHARLOTTE MECKLENBURG
PAW CREEK ;
PUMP STATION UTILITIES DEPARTMENT
McALPINE CREEK WWTP
LAKE WYUE
BROWN AND
CALDWELL
LAME IS 2 INCHES
ATFULL SIZE
OF NOT r-SCALE *CCOI Nf4Y)
SUBMITTED:
APPROVED:
APPROVED:
MULCT mita=
NMI MOc
DATE
DATE:
DATE
FILE CMUD\19047\CAD
DRAWN J PORTER
DESIGNED P SCHULER
CHECKED P SCHULER
CHECKED R CARRIER
REVISIONS
ZONE REV.
DESCRIPBON
BY
DAIS
APP.
CLARIANT CORPORATION
CLARIANT
WASTEWATER TREATMENT FACILITY
IMPROVEMENTS
CMU / CLARIANT COMBINED WWTF
LONG CREEK BASIN PFD
PROJECT NUMBER
19047
DRAWING NUMBER
SHEET NUMBER

Clariant Corporation
Mt. Rally Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
V46rt
Clariant
February 5, 2001
Charles H. Weaver, Jr.
NPDES Unit
Division of Water Quality
11617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Renewal of NPDES Permit NC0004375
Dear Mr. Weaver;
FEB 1 2 2001
Delft
GNT SOURCE BRA" thi
Thank you very much for taking the time to discuss the information and data Clariant
should provide to the Division. I was concerned a full permit application package would be
required after I received the January 29, 2001 letter. Based on our discussion, I understand that
the Division is in need of detailed materials describing existing and/or proposed site operations
and wastewater treatment processing.
I plan to generate, for the Division, the information listed below. If I have misinterpreted
anything, please let me know. I believe that, at a minimum, items 1 and 2 are also required as a
result of the January 5, 2001 letter of Mr. David Goodrich, NPDES Unit Supervisor.
1. Proposed schematic of wastewater flow
2. Description of proposed facility changes, including those coupled with the reduction in
manufacturing capacity at the site
3. Priority Pollutant Analyses in accordance with 40 CFR 122.21
4. Last three years production data
I was in the process of responding to Mr. Goodrich's letter when I received your notification
of the requirement of an application for permit renewal. I have enclosed a copy of my submittal
to Mr. Goodrich, and information needed to satisfy items 1, 2 and 3. (Please note that the
Priority Pollutant Analysis sample was taken on September 14, 2000. I mistakenly told you the
sample was taken in December 2000. If a more recent sample and analyses are required, we will
be happy to comply.)
I will compile site historical production data and forward it to you as soon as I can. This
may take several days to consolidate and compile.

Letter to Mr. Charles H. Weaver, Jr. — February 5, 2001 page 2
Thank you for the guidance you provided me in our telephone conversation of February
5, 2001. If I have misinterpreted anything from our discussion or if there are additional data or
information requirements, please contact me at [phone]. My email address is
[e-mail].
Sincerely;
Gary P. Sanderson, P.E.
Plant Services Manager
cc: Mr. David A. Goodrich, NCDENR
Mr. Dan Trueman, Clariant
Dr. Michael Teague, Clariant
Ms. Marty Griffin, Clariant

Clariant Corporation
Mt. Holly Plant
P.O. Box 669246
Charlotte, NC 28266
704.827.9651
' Clariant
February 4, 2001
Mr. David A. Goodrich
NPDES Unit Supervisor
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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 that the Division not reduce
the permitted discharge flow and monitoring parameters based on our decreasing manufacturing
volume, but instead allow us sufficient time to submit a permit modification for the planned
operation.
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
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.
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.

Schedule for Clariant / Charlotte -Mecklenburg Combined Treatment Project
Task No.
Task Description
2001
2002
Feb.
March
April
May
June
July
August i Sept.
Oct.
Nov.
Dec.
Jan
Feb.
March
April
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
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
I
_._...
C
111
1
r
_
❑
1
❑
19047/ADM/Proposed Phase II schedule

10
r
N
co
co
SOLICITED
DISPOSAL MATERIAL
(PROPOSED)
CMUD
(PROPOSED)
ALKALINE ACID
SEWER SEWER
82
2000
CLARIANT OFF —SPEC.
MATERIALS
(PROPOSED)
30
GROUND WATER
REMEDIATION
RCRA
120
CERCLA
30
DYES
MANUFACTURE
450
SPECIAL CHEM.
MANUFACTURE
NON CONTACT
COOLING
STEAM
GENERATION
STORM
WATER
90
EVAPORATION 45
105
75
225
POTABLE WATER
CITY OF CHARLOTTE
SANITARY WASTE 27
WATER
TREATMENT
FILTER BACKWASH 65
NOTE:
FLOW_ FROM THE THREE SOURCES AT THE
TOP LEFT ARE PROPOSED. ALL OTHERS
ARE BASED ON EXISTING OPERATIONS
OR PLANNED SHUTDOWNS,
NEUTRALIZATION
STORM FLOW
NEUTRALIZATION
STORM FLOW
STORAGE
PRIMARY
CLARIFIERS
198
EVAPORATION
SLUDGE
FILTRATION
SLUDGE
LANDFILL
STORM FLOW
STORAGE
1/19/01
952 WATER INTAKE
SETTLING
CANAL
CATAWBA RIVER
FLOW
STORAGE
ACTIVATED
SLUDGE
65
ACTIVATED
SLUDGE
SECONDARY
CLARIFIERS
POLISHING
POND
THIS DRAWING 6 A PRIVATE AND CONFIDENTIAL COMMUNICATION AND THE PROPERTY OF C,ARUNT CORPORATION.
MT. HOLLY PUNT. IT MUST NOT BE COPIED OR LOANED WITHOUT THE CONSENT OF CLAMANT CORPORATION, MD
MUST BE PROPPRY RETURNED ON REQUEST OR COMPLERON OF ORDER. THIS DRAWING MS BEEN CREATED WTTH
dlaQr4G. DO NOT MANUALLY DRAFT ON THIS COPY.
- D. PROJECT ENGINEER
POLISHING
POND
J
POST
AERATION
EFFLUENT
METERING
3,101
�'Clariarit
Mt. Holly Plant, P.O. Box 869248, Charlotte, North Carolina 28288
DATE
APP'D. RAW MAnL/HI- E
DATE
APPROVED BY
GTE
- APP 0. WVNTENANCE
DATE
APP'D. URLRIES
GTE
PRODUCTION
GATE
APPTI. SAFEIY/T.NVIR0.
GTE
APPROVED BV
GTE
FILE NAME
83420100
TTU
DEPARTMENT 50
PROCESS FLOW DIAGRAM
WATER FLOW SCHEMATIC - PROPOSED
NPDES PERMIT NC0004375
A
REV.
DATE
OH
PROJECT NO.
DRAWN _ CHECKED APP'D.
ISSUED FOR COMMENTS
REVISION DESCRIPTION
APPROVED BY
GTE
APPROVED BY
GTE
PLOT SCALE PAT*
1=1
SCALE
NONE
SHEET NO.
1 OF 1
79.53.060.01.8342 REYA"

Annual Pollutant Analysis Monitoring Requirement
Reporting Form A
(Revised June 1990)
. Facility Information:
Page 1 of 9
NPDES Permit No: NC 0004375 Discharge (Pipe) No: 001 Year: 2000
Facility Name: Clariant Corporation Class: 4 County: Mecklenburg
Person(s) Collecting Samples: Dwayne Wallace
Status of facility wastewater treatment operation on day of sampling: typical: Yes ✓ No
If no, explain briefly: Last aeration basin in series - down for cleanout.
Analytical Laboratory: Pace Analytical
II. Sampling:
24 hr composite for main sample/grab sample for purgeable fraction
Date Sampled (composite sample):
Sampling begun (date, time):
Sampling finished (date, time):
Date Sampled (grab sample):
09/14/00 06:45
09/15/00 06:45
09/15/00 07:02
Corresponding sample taken for toxicity testing:
✓ Yes
No
Instructions
The purpose of this document and the accompanying memo is to standardize the sampling, analysis and reporting procedures to be used for the
Annual Pollutant Analysis Monitoring (APAM) Requirement as described in the permit.
Sampling
1. Take a 24-hr composite sample from the final effluent during mid -week (Wednesday through Friday). Collect a grab sample for the volatile
organic fraction when collection of the 24-hour composite sample is completed. Follow any other sampling instructions provided by the
laboratory performing the analysis.
2. Indicate in the space provided at the top of this page whether a corresponding sample for toxicity testing was taken.
3. Make note of any unusual wastewater treatment operating conditions occurring on the day of sampling in the space provided on the form.
Analysis
4. Analyze the effluent for pollutants listed on the APAM form, including those to be identified and approximately quantified under the 10
significant peaks rule, using appropriate EPA -approved methods for each of the analytic fractions. Other analytical methods can be substituted
only with prior, written approval of the Director of the Division of Environmental Management (DEM). Read and distribute to the laboratory
performing the analysis the accompanying memo (Tedder, October 1990) clarifying analytical requirements.
5. Identify chemicals to be analyzed for according to the 10 significant peaks rule (as described in item 2 of the Annual Pollutant Analysis
Monitoring Requirement in the permit) using a GC/MS library search. Tentative identification is all that is required; confirmation by standard
injection is not necessary. Estimate the concentration of each based on an internal standard having the closest retention tine.
Reporting
6. Quantitation Limit Targets that should be met are listed on this Revised APAM Reporting Form A. Report the use of any higher quantitation limit
and an explanation as to why the listed quantitation limit target could not be met. Examples of acceptable reasons for not meeting a quantitation
limit target could be high background concentrations in a sample, or the necessity for sample fraction dilution to bring a chemical to within a
quantifiable concentration. List any quantitation limit different (whether higher or lower) from the target in the column provided for this
purpose.
7. If a chemical is found to be below the quantitation limit, report the concentration detected as less than (or<) the quantitation limit in the
appropriate space. Provide a concentration estimate for chemicals detected in concentrations greater than the detection limit and less than the
quantitation limit. Enter the detection limit in parentheses beside the estimate. Chemicals detected in concentrations above the quantitation
limits must be quantified. Quantitation limit and detection limit are defined in the accompanying memo (Tedder, October 1990). Enter the total
number of peaks detected in each analytic fraction in the appropriate space on this Revised APAM Form A. Report all concentrations in units of
micrograms per liter (ug/I) and metals as total recoverable metal If no peaks to be identified under the 10 significant peaks rule are observed,
enter "none" in the space provided for "other" compounds in each appropriate analytic fraction section. Provide the concentration estimate and
retention time for "unknowns" as well as for "significant peaks" for which a structural assignment can be made.
8. If "significant peaks" are found, provide probable molecular weight, library match probability, retention time, identification basis, and MS scan
number for each. In addition, list internal standards and their retention times.
9. In the section labeled "Organic Analytical Information" (p.9), include for each organic fraction the method, extraction technique, GC operating
conditions, and surrogate recovery. Report the size of the GC/MS library being utilized in the appropriate space.
10. Use copies of this Annual Pollutant Analysis Monitoring Revised Form A to report the results of the analysis. Both the analytical laboratory
representative and the facility operator is responsible charge should sign completed forms (last page).
11. Mail two completed copies of the form (and the laboratory report, if submitted to the facility on a different form) to: ATTN: Central Files,
Division of Environmental Management, NC DEHNR, P.O. Box 27687, Raleigh NC 27611. Mail the APAM form separately from Discharge
Monitoring Reports.
MN/APAMCOV,DOC

A. Purgeable (Volatile Organic) Fraction, EPA Method 624 Page 2 of 9
Number of chemicals detected in Fraction 0
Fraction STORET Number 84085
STORET Compound
Number
Quantitation
Limit Target
Quantitation
Limit*
Concentration
Detected
GC/MS
Confirmation?
1. Pollutants to be analyzed for:
(ug/L)
(ug/L)
(ug/L)
Yes
No
34210
Acrolein
100
100
<100
X
34215
Acrylonitrile
100
100
<100
X
34030
Benzene
5
5
<5
X
32101
Bromodichloromethane
5
5
<5
X
32104
Bromoform
5
5
<5
X
34413
Bromomethane
10
10
<10
X
32102
Carbon tetrachloride
5
5
<5
X
34301
Chlorobenzene
6
6
<6
X
34311
Chloroethane
10
10
<10
X
.
34576
2-Chloroethyl vinyl ether
10
10
<10
X
32106
Chloroform
5
5
<5
X
.
34418
Chloromethane
10
10
<10
X
•
32105
Dibromochloromethane
5
5
<5
X
34496
1,1-Dichloroethane
5
5
<5
X
34531
1,2-Dichloroethane
5
5
<5
X
34501
1,1-Dichloroethylene
5
5
<5
X
34546
trans-1,2-Dichloroethylene
5
5
<5
X
34541
1,2-Dichloropropane
6
6
<6
X
34704
cis-1,3-Dichloropropene
5
5
<5
• X
34699
trans-1,3-Dichloropropene
5
5
<5
X
34371
Ethylbenzene
8
8
<8
X
34423
Methylene chloride
5
5
<5
X
34516
1,1,2,2-Tetrachloroethane
7
7
<7
X
34475
Tetrachloroethylene
5
5
<5
X
34010
Toluene
6
6
<6
X
34506
1,1,1-Trichloroethane
5
5
<5
X
34511
1,1,2-Trichloroethane
5
5
<5
X
39180
Trichooroethylene
5
5
<5
X
34488
Trichlorofluoromethane
10
10
<10
X
39175
Vinyl chloride
10
10
<10
X
* If difference from quantitation limit target
NA = Not Analyzed

2. Other purgables (up to 10 highest peaks)
Page 3 $f 9
Compound
Prob
Mole.
Wt.
Est.
Conc.
(uglL)
Lib. Match
Prob.
(%)
Retention
Time (RT)
(Min)
Identification Basis
Scan
Number
Lib.
Match
Manual
Interpret.
RT
None
146
209
97
12.941
X
1730
chlorotrifluoromethylbenzene isomer
180
39
97
16.2
X
2272
trifluoromethylbenzaldehyde isomer
174
18.2
97
18.965
X
2732
trifluoromethylbenzonitrile isomer
171
29.5
97
19.272
X
2783
trifluoromethylacetophenone isomer
188
2150
97
20.702
X
3021
trifluoromethylbenzenamine isomer
161
13.5
94
21.009
X
3072
trifluoromethylphenol isomer
162
13.3
95
21.887
X
3218
Complete only if non -target compounds are present:
Internal Standard
Retention
Time (RT)
(Min)
1,4-difluoronenzene
12.232
chlorobenzene-d5
16.344
1,4-dichlorobenzene-d4
19.765
0
0

4
B. Acid Extractable Fraction, EPA Method 8270 Page 4 of 9
Number of chemicals detected in Fraction 0
Fraction STORET Number 45582
STORET Compound
Number
Quantitation
Limit Target
Quantitation
Limit*
Concentration
Detected
GC/MS
Confirmation?
1. Pollutants to be analyzed for.
(ug/L)
(ug/L)
(ug/L)
Yes
No
34452
4-Chloro-3-methylphenol
10
10
<10
X
34586
2-Chlorophenol
10
10
<10
X
34601
2,4-Dichlorophenol
10
10
<10
X
34606
2,4-Dimethylphenol
10
10
<10
X
_
34616
2,4-Dinitrophenol
50
50
<50
X
34657
2-Methyl-4,6-dinitrophenol
50
50
<50
X
34591
2-Nitrophenol
10
10
<10
X
34646
4-Nitrophenol
50
50
<50
X
39032
Pentachlorophenol
50
50
<50
X
34694
Phenol
10
10
<10
X
34621
2,4,6-Trichlorophenol
10
10
<10
X
' If difference from quantitation limit target

2. Other acid extractables (up to 10 highest peaks)
Page 5°of 9
Compound
Prob
Mole.
Wt.
Est.
Conc.
(ug/L)
Lib. Match
Prob.
(%)
Retention
Time (RT)
(Min)
Identification Basis
Scan
Number
Lib.
Match
Manual
Interpret.
RT
Phenol, 3-(trifluoromethyl)-
162
1300
95
5.963
x
435
(Trifluoromethyl)acetophenone isomer
188
394
95
6.043
x
447
3-(Trifluoromethyl)benzoic acid
190
852
78
7.064
x
599
unknown
769
8.252
c
776
Complete only if non -target compounds are present:
Internal Standard
Retention
Time (RT)
(Min)
1,4-Dichlorobenzene-d4
5.76
Napthalene-d8
7.35
Acenapthene-d8
10.31
Phenanthrene-d10
13.15
Chrysene-d12
18.52
Perylene-d12
21.22

C. Base/Neutral Fraction, EPA Method 8270 Page 6 of 9
Number of chemicals detected in Fraction 0
Fraction STORET Number 45583
STORET Compound
Number
Quantitation
Limit Target
Quantitation
Limit*
Concentration
Detected
GC/MS
Confirmation?
1. Pollutants to be analyzed for:
(ug/L)
(ug/L)
(ug/L)
Yes
No
3405
Acenaphthene
10
10
<10
X
34200
Acenaphthylene
10
10
<10
X
34220
Anthracene
10
10
<10
X
39120
Benzidine
50
50
<50
X
,
34526
Benzo (a) anthracene
. 10
10
<10
X
34247
Benzo (a) pyrene
10
10
<10
X
34230
Benzo(b)fluoranthene
10
10
<10
X
34521
Benzo (ghi) perylene
10
10
<10
X
34242
Benzo(k)fluoranthene
10
10
<10
X
34278
Bis(2-chloroethoxy)methane
10
10
<10
X
34273
Bis(2-chloroethyl)ether
10
10
<10
X
.
34283
Bis(2-chloroisopropyl) ether
10
10
<10
X
39100
Bis(2-ethylhexyl) phthalate
10
10
<10
X
34636
4-Bromophenyl phenyl ether
10
10
<10
X
34292
Butyl benzyl phthalate.
10
10
<10
X
34581
2-Chloronaphthalene
10
10
<10
X
34641
4-Chlorophenyl phenyl ether
10
10
<10
X
34320
Chrysene
10
10
<10
X
34556
Dibenzo (a,h) anthracene
10
10
<10
X
34536
1,2-Dichlorobenzene
10
10
<10
X
34566
1,3-Dichlorobenzene
10
10
<10
X
34571
1,4-Dichlorobenzene
10
10
<10
X
34631
3,3-Dichlorobenzidine
20
20
<20
X
34336
Diethyl phthalate
10
10
<10
X
34341
Dimethyl phthalate
10
10
<10
X
39110
Di-n-butyl phthatate
10
10
<10
X
34611
2,4-Dinitrotoluene
10
10
<10
X
34626
2,6-Dinitrotoluene
10
10
<10
X
34596
Di-n-octyl phthalate
10
10
<10
X
34346
1,2-Diphenylhydrazine
10
10
<10
X
34376
Fluoranthene
10
10
<10
X
34381
Fluorene
10
10
<10
X
39700
Hexachlorobenzene.
10
10
<10
X
34391
Hexachiorobutadiene
10
10
<10
X
34386
Hexachlorocyclopentadiene
10
10
<10
X
34396
Hexachloroethane
10
10
<10
X
34403
Indeno(1,2,3-cd) pyrene
10
10
<10
X
34408
Isophorone
10
10
<10
X
34696
Naphthalene
10
_
10
<10
X
34447
Nitrobenzene
10
10
<10
X
34438
N-nitrosodimethylamine
10
10
<10
X
34428
N-nitroso-di-n-propylamine
10
10
<10
X
34433
N-nitrosodiphenylamine
10
10
<10
X
34461
Phenanthrene
10
10
<10
X
34469
Pyrene
10
10
<10
X
34551
1,2,4-Trichlorobenzene
10
10
<10
* if difference from quantitation limit target

2. Other base/neutrals (up to 10 highest peaks)
Page 7 of 9
Compound
Prob
Mole.
Wt.
Est.
Conc.
(ug/L)
Lib. Match
Prob.
(%)
Retention
Time (RT)
(Min)
Identification Basis
Scan
Number
Lib.
Match
Manual
Interpret.
RT
None
Complete only if non -target compounds are present:
Internal Standard
Retention
Time (RT)
(Min)
1,4-Dichlorobenzene-d4
5.76
Napthalene-d8
7.35
Acenapthene-d8
10.31
Phenanthrene-d10
13.15
Chrysene-d12
18.52
Perylene-d12
21.22

f
D. Organochlorine/Organophosphorus Pesticides and PCBs Page 8 of 9
'Number of chemicals detected in Fraction 0
Fraction STORET Number 00188
STORET Compound
Number
Quantitation
Limit Target
Quantitation
Limit*
Concentration
Detected
Confirmation?
Dual Column GC/MS
1. Pollutants to be analyzed for: (ug/L)
Organochlorine Pesticides/PCBs: EPA Method 8080
(ug/L)
(ug/L)
Yes
No
Yes
No
39330
Aldrin
0.05
0.05
<0.05
X
39337
Alpha-BHC
0.05
0.05
<0.05
X
39338
Beta-BHC
0.05
0.05
<0.05
X
34259
Delta-BHC
0.1
0.1
<0.1
X
39340
Gamma-BHC (Lindane)
0.05
0.05
<0.05
X
39350
Chlordane
0.2
0.2
<0.2
X
39310
4,4'-DDD
0.1
0.1
<0.1
X
39320
4,4'-DDE
0.1
0.1
<0.1
X
39300
4,4'-DDT
0.1
0.1
<0.1
X
39380
Dieldrin -
0.02
0.02
<0.02
X
•
34361
Endosulfan I (alpha)
0.1
0.1
<0.1
X
34356
Endosulfan II (beta)
0.1
0.1
<0.1
X
34351
Endosulfan sulfate
0.7
0.7
<0.7
X
39390
Endrin
0.06
0.06
<0.06
X
34366
Endrin aldehyde
0.2
0.2
<0.2
X
39410
Heptachlor
0.05
0.05
<0.05
X
39420
Heptachlor epoxide
0.8
0.8
<0.8
X
39480
Methoxychlor
0.5
0.5
<0.5
X
39755
Mirex
0.2
0.2
<0.2
X
39400
Toxaphene
2.4
2.4
<2.4
X
34671
PCB 1016
0.5
1.0
<1.0
X
39488
PCB 1221
0.5
1.0
<1.0 '
X
39492
PCB 1232
0.5
1.0
<1.0
X
39496
PCB 1242
0.5
1.0
<1.0
X
39500
PCB 1248
0.5
1.0
<1.0
X
39504
PCB 1254
1
1.0
<1.0
X
.
39508
PCB 1260
1
1.0
<1.0
X
Organophosphorus Pesticides: EPA Method 8140
39560
Demeton
2.5
2.5
<2.5
X
39540
Parathion (ethyl)
0.6
0.6
<0.6
X
•
E. Herbicides, EPA Method 8150
Number of chemicals detected in Fraction 0
Fraction STORET Number 00148
STORET Compound
Number
Quantitation
Limit Target
Quantitation
Limit"
Concentration
Detected
Confirmation?
1. Pollutants to be analyzed for
(ug/L)
(ug/L)
(ug/L)
Yes
No
39730
2,4-D
12
12
<12
X
1
39.045
Silvex
2
2
<2.0
X
39740
2,4,5-T
2
2
<2.0
X
• tf difference from quantltation limit target

0
Organic Analytical Information
m
Page 9 of 9
Organic Fraction
Method
Extraction
GC Operating Conditions
Column Description
Surrogate Spikes
Batch
Continuous
Length X ID, FIIm Thickness,
Column Type, Carrier Gas & Flow
Rate, Temperature Program
Compound
Recovery
Purgeable
624
X
J&W DB-624, 60 m x 0.25 mm ID
DBFM
97%
Helium, 1 mL/min
Toluene-d8
101%
4min a40C,to220Ca8Clmin,4.5min
BFB
101%
Acid Extractable
8270
X
J&W DB5-MS, 30 m x 0.25 mm id
2-FP
070'
Helium,1.0 mt./min. 1.75 min ©40 C. to 130 C
Phenol-d6
0%
a 35 Clmin, to 330 C a 12 C/min, 7 min
'2,4,6-TBP
0%
Base/Neutral Extractable
8270
X
J&W D85-MS, 30 m x 0.25 mm id
NitroBenz-d5
0%
Helium,l.0 mtJmin, 1.75 min a 40 C, to 130 C
2-FBP
0%
a 35 Clmin, to 330 C a 12 C/min, 7 min '
Terphenyl-d14
0%
GC/MS Library size (number of reference spectra): Method 624 - 40,000 Method 625 - 75,000
F. Metals and Other Chemicals
Number of Metals and Other Chemicals (as listed below) detected in Sample 5
Fraction STORET Number 78240
STORET Compound
Number
Quantitatlon
Limit Target
Quantitatlon
Limit*
Concentration
Detected
1. Pollutants to be analyzed for.
(ug/L)
(ug/L)
(ug/L)
1104
Aluminum
50
100
200
1097
Antimony
50
50
<50
1002
Arsenic
10
10
<10
1012
Beryllium
25
25
<25
1027
Cadmium
2
2
<2
1034
Chromium
5
5
<5
1042
Copper
2
2
7.5
1051
Lead
10
10
<10
71900
Mercury
0.2
0.2
<0.2
1067
Nickel
10
10
<10
1147
Selenium
5
5
<5
1077
Silver
5
5
<5
1092
Zinc
10
10
<10
2. Other inorganics:
1077
Barium _
500
500
<500
940
Chloride
1000
1000
470000
720
Cyanide
20
20
26
951
Fluoride
100
100
1200
`
• If difference from quantitation limit target
Analytical Laboratory
Signed:
Facility Operator
I certify that this
Signed:
Representative:
-('f - r L..O
MCkk W . .--v n -es
Date:
WOO 14a( 42
10 -- 1 9 — 0
in Responsible Charge (ORC):
report is accurate and complete to the best of
k� � 12. Ulictittacr..
-6 W 0,1,. ,2_ P ,
my knowledge.
.. Date: l d " 3 6 " 00