NC0047384_Pretreatment_IUP_Vertellus_Renewal_20240509

CITY OF GREENSBORO
WATER RESOURCES DEPARTMENT
INDUSTRIAL WASTE SECTION
SIGNIFICANT INDUSTRIAL USER
WASTEWATER DISCHARGE PERMIT
SIU PERMIT NUMBER P002
VERTELLUS LLC
IS AUTHORIZED TO DISCHARGE WASTEWATER
FROM A FACILITY LOCATED AT
2110 W. GATE CITY BOULEVARD
GREENSBORO, NORTH CAROLINA
into the City of Greensboro Sanitary Sewer System
to the T.Z. OSBORNE Water Reclamation Facility
[NPDES PERMIT NUMBER NC0047384]
in accordance with the limitations and conditions set forth in this permit.
This permit shall become effective
SEPTEMBER 1, 2023
This permit and the authorization to discharge shall
expire at midnight on
AUGUST 31, 2028
or upon permit reissuance, whichever comes first.
Ls/1,2.
U h
Amy Var' oski Date
Pretreatment Coordinator

Page 2, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
INDUSTRY OFFICIAL RESPONSIBLE FOR PERMIT COMPLIANCE
This signatory official shall be responsible for permit compliance, including monitoring, report
submittals, accidental discharge notification, and permit renewal. Although certain of these
activities may be delegated to other individuals, the Signatory Official is ultimately responsible for
compliance with all permit conditions, limits, activities and terms.
I am aware of my responsibilities as Signatory Official and I am aware of the terms and conditions
set forth in this wastewater discharge permit and the City of Greensboro Sewer Use and
Pretreatment Ordinance.
Signatory Official NAME (PLEASE PRINT)
Signatory Official TITLE (PLEASE PRINT)
Signatory Official Signature
Date:
CHANGE OF SIGNATORY OFFICIAL
If there is a change of the Signatory Official for this facility, the City of Greensboro shall be
notified of such change within thirty (30) days. A new page 2, "INDUSTRY OFFICIAL
RESPONSIBLE FOR PERMIT COMPLIANCE" shall be submitted to the Industrial Waste
Section with the name, title and signature of the new official.
September 1,2023 Permit Renewal

Page 3, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
SECTION I — PERMIT MODIFICATION HISTORY
DATE MODIFIED REASON & DESCRIPTION OF MODIFICATION OR ACTION
September 1, 1998 PERMIT RENEWAL
October 6, 1998 Increase inflow limit from six month average of 90,000 gpd to six-month
average of 110,000 gpd
January 7, 2000 Page 4A, Changed organic sampling type to allow for laboratory
composite of Volatile Organic Analyses (VOA-EPA 624 parameters)
September 1, 2003 PERMIT RENEWAL
October 1, 2004 Increase in Daily Maximum flow from 110,000 gpd to 120,000 gpd
August 11, 2006 Name change from Morflex Incorporated to Vertellus Performance
Materials, Inc.
PERMIT RENEWAL
1) Section II.A. Modified description of discharge; 2) Section II.C.
included OCPSF sampling location; 3) Flow changed from daily
maximum of 120,000 gpd to monthly average of 100,000 gpd[page 5 &
September 1, 2008 6]; 4) Page 6—monitoring frequency changed from 416 months to 216
months; 5) Section IV. Flow Measurement" changed Item 3 - clarified
reporting period; Item 4- updated e-mail addresses; 6) deleted paragraph
after 49 addressing installation of flow measuring equipment; 7) IV.B.
Self-Monitoring Report Submittal—added requirement for when no
discharge by Permittee
October 1, 2008 Modification of Section ILA. Description of Discharge—removed cooling
tower/boiler water (process)from description of discharge.
1) Page 5 and 6 Section III. Changed minimum sampling requirement for
July 1, 2011 City to 1/year. 2) Page 7 Section IV. 3. Changed meter calibration
requirement to once per calendar year; 3)Page 8, Section IV.B. —Report
Submittal date changed to 151h in lieu of 20th.
PERMIT RENEWAL
September 1, 2013 Section III—City monitoring frequency set to 116 months; Section IV. -
Added Special Condition D (Slug/Spill Control Plan)per DWQ guidance;
Added Special Condition E (Surrogate Process Control Sampling).
July 1, 2015 Permit Modification
Changed address to 2110 W. Gate City Blvd.
Permit Modification
July 1, 2016 Increased flow from 100,000 gpd to 120,000 gpd based on increased
production of DEFT. Increased Federal OCPSF pollutants
proportionally.
Permit Modification
Samples taken from Wastewater Holding Tanks T352 and T353 for EPA
July 25, 2016 Method 624 parameters shall be grab samples. Composited grab samples
may be performed using method at Section 4, F. Changes at Pages 4, 5,
5A, 9 added for clarification.
September 1,2023 Permit Renewal

Page 3A, SIU Permit 0002
VERTELLUSLLC
Effective March 9, 2022
SECTION I— PERMIT MODIFICATION HISTORY
DATE MODIFIED REASON & DESCRIPTION OF MODIFICATION OR ACTION
Permit Modification
September 30, 2016 Transfer SIU Permit P002 from Vertellus Performance Materials, Inc. to
Vertellus LLC. This is a change of ownership with no change of processes
or personnel.
PERMIT RENEWAL
September 1, 2018 Special Condition Changes:Added Flow Measurement Calibration/
Verification Section, Modified flow language;Added Detection Limits and
Matrix Interference Section.
PERMIT MODIFICATION(Due to NCDEQ Comments)
October 1, 2020 Modified flow limit/OCPSF mass limits—Based on Five Year Long-Term
Average calculation ; Sampling Language Clarified
PERMIT MODIFICATION
March 9, 2022 Modified flow limit/OCPSF mass limits based on updated review of
facility's average flow data
September 1, 2023 PERMIT RENEWAL
September 1,2023 Permit Renewal

Page 4, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
SECTION II - GENERAL INFORMATION
A. Description of Discharge
Pipe 01 —Process Wastewater from production process waters [Organic esters, intermediates,
castor oil based materials and derivatives, and DEET insect repellent] Vertellus utilizes batch
chemical manufacturing technology to produce core products and also offers custom
manufacturing and synthesis capabilities. Facility/equipment wash down and industrial storm
water.
Pipe 01 does not include domestic waste discharge.
B. Authorization Statement
1. The permittee is hereby authorized to discharge wastewater in accordance with the effluent
limitations, monitoring requirements, and all other conditions set forth in this Industrial User
Pretreatment Permit(IUP) into the sewer collection system and wastewater treatment facility of
the City of Greensboro
2. The permittee is hereby authorized to continue operation of and discharge wastewater from
the following treatment or pretreatment facilities. These facilities must correspond to the
treatment units listed on both the application and inspection forms.
Air Stripping Oil / Water Separator
Neutralization, pH adjustment Spill Protection
Flow Equalization (non-aerated) Screening
3. The permittee is hereby authorized to, if requested by the City of Greensboro and after
receiving Authorization to Construct (A to C) from the City of Greensboro, construct and operate
additional pretreatment units as needed to meet final effluent limitations.
C. Monitoring Location
Automatic Composite Sampler located adjacent to Wastewater Holding Tanks T352 and T353
near laboratory exit and T352 and T353 sampling taps for Method 624 grab samples
D. Sampling Technique
1. Compliance samples for EPA Method 624.1 OCPSF regulated parameters shall be grab
samples taken from either Wastewater Holding Tanks T352 or T353.
2. Compliance samples for EPA Method 625.1 OCPSF regulated parameters including Lead and
Zinc flow proportional composite samples shall be collected from the automatic sampler.
3. The automatic sampler shall be used to collect flow proportional composite samples for
compliance with Local Pollutant Allocation parameters and for surcharges.
September 1, 2023 Permit Renewal

Page 5, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
SECTION III-EFFLUENT LIMITS AND MONITORING REQUIREMENTS
Effluent Limits and Monitoring Requirements for Pipe 01
THIS FACILITY IS REGULATED BY FEDERAL CATEGORICAL PRETREATMENT
STANDARDS FOR ORGANIC CHEMICALS, PLASTICS AND SYNTHETIC FIBERS
[40 CFR PART 414.110]
EFFLUENT LIMITATIONS MONITORING FREQUENCY
EFFLUENT Daily Monthly Sample CITY OF
CHARACTERISTICS Maximum Average Type PERMITTEE GREENSBORO
Flow (gallons per day) 115,000 # DAILY
H standard units 5.0— 12.0 Grab 1/6 months
Chemical Oxygen Demand Immediately report all
m /1)^ values >10,000 m /l C 1/month
EFFLUENT LIMITATIONS MONITORING FREQUENCY
EFFLUENT Daily 6 Month Sample CITY OF
CHARACTERISTICS Maximum Avera e T e PERMITTEE GREENSBORO
BOD++ m /1 M C 1/6 months
Suspended Solids++ m /1 M C 1/6 months
Cadmium T m /1 M C 1/6 months
Chromium T m /1) M C 1/6 months
Copper T m /1) M C 1/6 months
Lead T m /1 C *Seepage 5A 1/6 months
Nickel T m /1 M C 1/6 months
Zinc T m /1 C *See Pame 5A 1/6 months
Silver T m /1 M C 1/6 months
Cyanide (Total) (mg/1) Grab *See page 5A 1/6 months
ALL METALS ARE TO BE ANAL YZED AS TOTAL[T]
OCPSF Effluent Limits and Monitoring Frequency are listed on Page 5A
# The Greensboro Industrial Waste Section does not consider Flow to be a pollutant and
flow data is not considered to be a report.
^See Special Conditions: SURROGATE PROCESS CONTROL SAMPLING
++ALL BOD CONCENTRATIONS OVER 200 mg/l AND ALL TOTAL SUSPENDED
SOLIDS CONCENTRATIONS OVER 200 mg/l ARE SUBJECT TO AN INDUSTRIAL
WASTE SURCHARGE
C - Composite Sample [See Section II Part D for permit-specific definition]
G - Grab Sample
M- Monitoring Only [See Local Pollutant Allocation Document to determine if an
Allocation has been issued for this parameter]
September I, 2023 Permit Renewal

OCPSF Permit Limits PAGE 5A, SIU Permit P002
(40 CFR Part 414) VERTELLUS GREENSBORO LLC
Effective: September 1, 2023
VERTELLUS
SIU Process Flow Limit(MGD)= 0.115
EFFLUENT LIMITS MONITORING FREQUENCY
EPA DAILY MAXIMUM MONTHLY AVERAGE SAMPLE CITY OF
Method POLLUTANT (pounds) (pounds) TYPE PERMITTEE GREENSBORO
1 624 Methylene chloride 0.1630 0.0345 Grab 1/6 months 1/year
2 624 1,1 Dichloroethylene 0.0575 0.0211 Grab 1/6 months 1/year
3 624 1,1 Dichloroethane 0.0566 0.0211 Grab 1/6 months 1/year
4 624 Chloroform 0.3117 0.1065 Grab 1/6 months 1/year
5 624 Carbon tetrachloride 0.3645 0.1362 Grab 1/6 months 1/year
6 624 1,2 Dichloropropane 0.7615 0.1880 Grab 1/6 months 1/year
7 624 Trichloroethylene 0.0662 0.0249 Grab 1/6 months 1/year
8 624 1,1,2 Trichloroethane 0.1218 0.0307 Grab 1/6 months 1/year
9 624 Tetrachloroethylene 0.1573 0.0499 Grab 1/6 months 1/year
10 624 Chlorobenzene 0.3645 0.1362 Grab 1/6 months 1/year
11 624 1,2 trans Dichloroethylene 0.0633 0.0240 Grab 1/6 months 1/year
12 624 1,2 Dichloroethane 0.5505 0.1726 Grab 1/6 months 1/year
13 624 1,1,1 Trichloroethane 0.0566 0.0211 Grab 1/6 months 1/year
14 624 1,3 Dichloropropylene 0.7615 0.1880 Grab 1/6 months 1/year
15 624 Benzene 0.1285 0.0547 Grab 1/6 months 1/year
16 624 Toluene 0.0710 0.0269 Grab 1/6 months 1/year
17 624 Ethylbenzene 0.3645 0.1362 Grab 1/6 months 1/year
18 624 Methyl chloride 0.2829 0.1055 Grab 1/6 months 1/year
19 624 Vinyl chloride 0.1650 0.0930 Grab 1/6 months 1/year
20 624 Chloroethane 0.2829 0.1055 Grab 1/6 months 1/year
21 625 4,6 Dinitro-o-cresol 0.2657 0.0748 Composite 1/6 months 1/year
22 625 2-Nitrophenol 0.2216 0.0623 Composite 1/6 months 1/year
23 625 4-Nitrophenol 0.5524 0.1554 Composite 1/6 months 1/year
24 625 Acenaphthene 0.0451 0.0182 Composite 1/6 months 1/year
25 625 Anthracene 0.0451 0.0182 Composite 1/6 months 1/year
26 625 Bis(2-ethyl hexyl)phthalate 0.2474 0.0911 Composite 1/6 months 1/year
27 625 1,2 Dichlorobenzene 0.7615 0.1880 Composite 1/6 months 1/year
28 625 1,3-Dichlorobenzene 0.3645 0.1362 Composite 1/6 months 1/year
29 625 1,4-Dichlorobenzene 0.3645 0.1362 Composite 1/6 months 1/year
30 625 Diethyl phthalate 0.1084 0.0441 Composite 1/6 months 1/year
31 625 Dimethyl phthalate 0.0451 0.0182 Composite 1/6 months 1/year
32 625 Di-n-butyl phthalate 0.0412 0.0192 Composite 1/6 months 1/year
33 625 Fluoranthene 0.0518 0.0211 Composite 1/6 months 1/year
34 625 Fluorene 0.0451 0.0182 Composite 1/6 months 1/year
35 625 Hexachlorobenzene 0.7615 0.1880 Composite 1/6 months 1/year
36 625 Hexachlorobutadiene 0.3645 0.1362 Composite 1/6 months 1/year
37 625 Hexachloroethane 0.7615 0.1880 Composite 1/6 months 1/year
38 625 Naphthalene 0.0451 0.0182 Composite 1/6 months 1/year
39 625 Nitrobenzene 6.1402 2.1455 Composite 1/6 months 1/year
40 625 Phenanthrene 0.0451 0.0182 Composite 1/6 months 1/year
41 625 Pyrene 0.0460 0.0192 Composite 1/6 months 1/year
42 625 1,2,4 Trichlorobenzene 0.7615 0.1880 Composite 1/6 months 1/year
43 r:�� Total Lead 0.6618 0.3069 Composite 1/6 months 1/ ear
44 Total Zinc 2.5033 1.0071 Composite 1/6 months 1/ ear
45 1 1 Total Cyanid m /I 0.05 m /I Grab 1/6 months 1/ ear
All sampling must occur during normal operational periods and must be representative of a production day.
Compositing of grab samples for EPA Method 624 parameters is allowed,but must be performed by a laboratory certified by the State of North
Carolina. A "Grab Composite"sample shall consist of a minimum of four grab samples.
Samples for lead,zinc and the EPA Method 625 parameters shall be composited using an automatic sampler.

Page 6, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
SECTION IV - SPECIAL PERMIT CONDITIONS
A. FLOW MEASUREMENT
Compliance with the flow limit in this permit shall be documented in the following manner:
1. The Permittee shall provide and maintain a refrigerated composite sampler and primary
flow measurement device for flow proportional sampling and flow measurement of the
permittee's process wastewater discharge.
2. The effluent process flow meter readings shall be recorded daily and the daily effluent flow
calculated in gallons per day. Flow measurement records shall be submitted to the City of
Greensboro Industrial Waste Section monthly. Data is to be submitted by the 151" of each
month for the previous month's flow measurements.
3. The permittee shall maintain permanent flow records and maintenance and calibration
records on-site for a minimum of three years. These records shall be available to the City of
Greensboro Industrial Waste Section during inspections or upon request.
4. Immediate notification, within 24 hours of becoming aware of the problem, shall be provided
to the Pretreatment Coordinator [336-433-7227] or Pretreatment Compliance Specialist [336-
373-3285] by phone or e-mail for any periods in which the effluent meter is inoperable with
the exception of periods for maintenance/calibration. This notification shall include the
cause of the malfunction/failure, anticipated repair time and/or plan of action to allow the
permittee to comply with the requirement to record the flow meter readings daily.
5. Malfunction/failure of effluent flow meters that are used for sewer billing purposes shall also
be immediately reported, within 24 hours of becoming aware of the problem, to the Water
Resources Customer Service Division by phone---Assistant Manager [336-373-4108] or
Manager [336-373-2639]. Failure to do so will result in the Industrial Waste Section and the
Water Resources Customer Service Division reverting back to the incoming water meter to
determine compliance and billing.
6. The wastewater meter must have a non-resettable totalizer that reads in cubic feet or gallons.
There shall be no by-pass capability of the wastewater metering devices and monitoring
point(s).
7. If the wastewater meter is being used for billing or compliance, it must have permanent flow
records (i.e. strip chart recordings) that include at minimum the following basic information:
date, time, totalizer reading (with units), interval flow volume(with units),maximum flow
rate (with units), and primary measuring device type. Any interruption in such records with
the exception of periods for maintenance/calibration are a violation of this permit and may
result in a civil penalty each day the interruption is allowed to continue.
September 1, 2023 Permit Renewal

Page 7, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
8. The wastewater meter shall have a back-up power source (battery or generator) to ensure
uninterrupted measurement of the discharge flow in the event of a power failure unless loss
of power automatically prevents any discharge from the facility. The back-up source shall
provide power to the wastewater meter's sensor and permanent flow records for a minimum
of 12 hours.
B. PERMITTEE SAMPLING AND MONITORING REPORT SUBMITTAL DATES
Permittee Sampling for the pollutant limitations in Section III (Effluent Limits and Monitoring
Requirements) of this permit shall be conducted in the following manner:
1. Samples for the January I-June 30 Reporting Period shall ALL be taken during the
months of January, February and/or March. The compliance report shall be submitted on
or before APRIL 15 of each year.
2. If there are no discharges during months designated for sampling, the April 15
compliance report shall be submitted with the notation "NO DISCHARGE/NO
SAMPLING". If there is a discharge after March and prior to June 30, self-monitoring is
still required to meet the permit monitoring requirements and that data shall be submitted
with the corresponding monthly flow data.
3. Samples for the July 1-December 31 Reporting Period shall ALL be taken during the
months of July, August and/or September. The compliance report shall be submitted on
or before OCTOBER 15 of each year.
4. If there are no discharges during months designated for sampling, the October 15
compliance report shall be submitted with the notation"NO DISCHARGE/NO
SAMPLING". If there is a discharge after September and prior to December 31, self-
monitoring is still required to meet the permit monitoring requirements and that data shall
be submitted with the corresponding monthly flow data.
If there are no discharges during an entire semi-annual reporting period, a letter must be
submitted to the Industrial Waste Section by July 15 or January 15 stating there was no discharge
and no sampling for that period. This letter must be signed and certified by the signatory official.
C. SIGNATORY REQUIREMENTS FOR INDUSTRIAL USER REPORTS
All self-monitoring and re-sampling data submitted for compliance to the City of Greensboro
shall include the certification statement below and shall be signed by the person on-site at the
facility who is authorized to represent the company in an official capacity concerning matters
that involve the City of Greensboro Industrial Waste Section ("Signatory Official").
I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations. [40 CFR Part 403.6]
September 1, 2023 Permit Renewal

Page 8, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
D. SLUG/SPILL CONTROL PLAN
The permittee shall provide protection from accidental and slug discharges of prohibited
materials and other substances regulated by this permit, which have a reasonable potential to
cause Interference or Pass Through, or in any other way violate the POTW's regulations, local
limits or Permit conditions.
The permittee shall notify the Industrial Waste Section immediately of any changes at its facility
affecting potential for a Slug Discharge.
The permittee shall submit a new or updated slug/spill control plan for approval when so directed
in writing by the City of Greensboro Industrial Waste Section. The plan shall contain, at a
minimum the following elements:
■ Description of discharge practices, including non-routine batch discharges;
■ Description of stored chemicals;
■ Procedures for immediately notifying the POTW of slug discharges that would cause a
violation of 40 CFR Part 403.5(b) [EPA Specific Prohibitions included in Greensboro SUO
Article II, Section 1. B.], with procedures for follow up written notification within 5 days;
■ If necessary, procedures to prevent adverse impact from accidental spills, including
inspection and maintenance of storage areas, handling and transfer of materials, loading
and unloading operations, control of plant site run-off, worker training, building of
containment structures or equipment, measures for containing toxic organic pollutants
(including solvents) and/or measures and equipment for emergency response.
Any current slug/spill control plan developed by the permittee and approved by the City of
Greensboro is hereby incorporated as a condition of this Significant Industrial User Permit.
E. SURROGATE PROCESS CONTROL SAMPLING
Chemical Oxygen Demand (COD) sampling shall be performed at least monthly for process
control and POTW loading estimations. COD analyses may be performed in-house or by a
commercial laboratory. If more than one COD analysis is performed in a calendar month, only
the highest COD value need be reported. The six monthly process control COD values shall be
submitted to the Industrial Waste Section by July 15 (for January through June) and by January
15 (for July through December). All COD analyses shall be made available during inspections
and upon request by the IWS.
Any COD value greater than 10,000 mg/1 shall be immediately reported(within 24 hours of
becoming aware of the result) to the City of Greensboro Industrial Waste Section. The
notification shall be made by telephone or email to the Pretreatment Coordinator, Pretreatment
Compliance Specialist and/or the Laboratory and Industrial Waste Section Supervisor.
September 1, 2023 Permit Renewal

Page 9, SIU Permit#P002
VERTELLUSLLC
Effective September 1, 2023
F. FLOW METER CALIBRATION/VERIFICATION
Flow meters used for flow monitoring under this permit shall be calibrated in accordance with
manufacturer's recommendation by an independent contractor or a Greensboro Industrial Waste
Section approved in-house technician. Calibration documentation shall be maintained for a
minimum of three (3) years and made available upon request and during on-site inspections.
I. Industries with a highly-accurate (<0.5% variance) flow meter, such as a magnetic or
ultrasonic (doppler and transit) meter, must have the meter calibrated/verified once every five
years.
2. Industries with effluent wastewater meters that are used for City of Greensboro sewer billing
purposes, must calibrate the meters annually. Permanent records in the form of electronic
data trend sheets, strip or circular chart recordings that have back-up and fail-safe capabilities
are also required to be maintained.
3. Any industry may conduct meter calibration more frequently than required in this permit.
The following flow meters/systems have no calibration requirements:
4. Industries with custom built Memtek©pretreatment systems have a permanently calibrated
flow measurement system (as long as the plumbing remains intact and the viscosity of the
liquid does not change) and no calibration is required.
5. Industries with a non-discharge closed-loop system are not required to have any meter on the
system calibrated.
6. Industries that record daily flow from a City of Greensboro owned, maintained, and
calibrated incoming potable water meter are not required to have the meters calibrated.
7. The Industrial Waste Section does not require deduct meters to be calibrated.
Industries with an electronic data base with power back-up do not need to maintain redundant
paper recorders.
G. DETECTION LIMITS AND MATRIX INTERFERENCES
Proof of efforts to resolve effluent sample detection limits reported higher than permit limits
issued herein [due to matrix interference] shall consist of the information included in"Chapter 1-
Checklist of Laboratory Data Required to Support a Claim that the Permittee was Unable to
Measure Pollutants Due to Matrix Problems" of EPA Guidance on Evaluation, Resolution and
Documentation of Analytical Problems Associated with Compliance Monitoring [EPA
Publication 821-13-93-001 June 1993]. All costs associated with the proof of matrix
interferences, included any third party review of the analytical data and supporting
documentation, shall be the responsibility of the permittee. This shall also include the costs for
any additional procedures, analyses or data review of samples collected by the City of
Greensboro to determine compliance with the permit limits issued herein.
September 1, 2023 Permit Renewal