NC0024228_Permit (Modification)_20180302

City of High Point Wir' _-
Public Services Department lirt
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LAB SERVICES DIVISIONlb
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NORTH CAROLINA'S INTERNATIONAL CITY.'"
CERTIFIED MAIL# 7015 0640 0005 9557 4910
RETURN RECEIPT REQUESTED
March 9, 2018
Monti Hassan RECENEDIDENRIDWR
NC DWR PERCS MAR 16 2018
1617 Mail Service Center
Raleigh, NC 27699-1617 Water Resources
Permitting Section
Re: KAO Specialties Americas— IUP#0026 Permit Modification
Dear Mr. Hassan,
Enclosed is a copy of the permit modification for KAO Specialties Americas. The permit limits
were changed from concentration-based limits to mass-based limits to prevent non-compliance
with BOD and TSS while they troubleshoot the cause(s). Allocating additional loading is not an
option until Westside's upgrade and associated Headworks are complete. Additionally, I have
included a copy of the updated allocation table. If you have any questions, please contact me at
[phone].
Sincerely,
1) ,)
Y
Carrie Boyd
/
Pretreatment Supervisor
Enclosures
P.O. 230, High Point, NC 27261 USA
Phone: [phone] Fax: [phone] TDD: 336.883.8517

City of High Point A� ---
Public Services Department
LAB SERVICES DIVISION
L. I W....v.' --Ill
NORTH CAROLINA'S INTERNATIONAL CITYTN
VIA ELECTRONIC MAIL
March 2, 2018 ..
f$
Mr. Pat Simcox
ICAO Specialties Americas LLC
243 Woodbine St
High Point, NC 27261
RE: Industrial User Permit #0026 —Permit Modification
Dear Mr. Simcox,
Enclosed is your modified Industrial User Permit effective March 2, 2018 through June 30,
2021. This permit is issued pursuant to the requirements of North Carolina General Statues
143-215.1 and the City of High Point Sewer Use Ordinance Section 8.
Please review your permit. The permit limits are now expressed as mass-based limits. This
modification is an effort to assist with the facility's investigation into the recent non-compliance
issues and prevent significant non-compliance classification.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. Unless such demand is made, the decision shall
be final and binding. If you have any questions, please call me at [phone].
Sincerely,
I
Came Boyd
Pretreatment Supervisor
cc with attachments:
Monti Hassan, NC DWR PERCS
P.O. 230, High Point, NC 27261 USA
Phone: [phone] Fax: [phone] TDD: 336.883.8517

0 F711.
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yCity of High Point
`` Control Authority and/or Municipality
•
NORTH CAROLINA'S INTERNATIONAL CITY
PERMIT
Industrial User Pretreatment Permit(IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
0026 414.85
IUP Number 40 CFR Category(if Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any applicable
federal categorical pretreatment regulations, all other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and
the Control Authority and/or Municipality Sewer Use Ordinance. The following Industry
hereafter referred to by name or as the permittee:
Industry name,permittee:
KAO Specialties Americas LLC
Facility Located at Street Address
243 Woodbine Street
City
High Point
State,Zip
NC 27261
is hereby authorized to discharge wastewater from the facility located at the above listed address
into the sanitary sewer collection system and the wastewater treatment facility of the Control
Authority and/or Municipality listed below:
IUP Control Authority and/or Municipality VVVVTP name:
City of High Point West Side WWTP
NPDES Number:
NC0024228
VVVVTP Address:
1044 W Burton Rd
City,State,Zip
Thomasville, NC 27360
in accordance with effluent limitations, monitoring requirements, and all other conditions set
forth in Parts I,II, and III of this Industrial User Pretreatment Permit(IUP).
Effective date, this permit and the authorization to discharge shall become
effective at midnight on this date:
March 2, 2018
Expiration date,this permit and the authorization to discharge shall expire at
midnight on this date:
June 30, 2021
10
Date signed Pretreatment Superviso 4

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
IUP, PART I, OUTLINE:
A.) IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
E.) Schematic and Monitoring Locations
F.) Effluent Limits&Monitoring Requirements
G.) Definitions and Limit Page(s)notes
A. IUP Basic Information:
Receiving Control Authority&WWTP name: POTW NPDES#:
City of High Point West Side WWTP NC0024228
IUP Name: IUP Number:
KAO Specialties Americas LLC 0026
IUP Effective date: Pipe Numbers,list all regulated pipes:
March 2,2018 001
IUP Expiration date: IUP 40 CFR#(if applicable),or N/A:
June 30, 2021 414.85
B. IUP History. A Complete Permit History is required):
Effective Date Renewal or Modification Description of changes over previous IUP.
6/30/1994 First Issued Date of initial issuance
6/30/1998 Re-issuance of Permit Re-issuance of permit
7/8/1998 Modification Changed BOD&TSS limits,Part 1; Section B,
Corrected typo in Part III.
12/17/1998 Modification Changed Bis(2-ethylhexyl)phthalate limits,Part
III, Section B
12/23/1998 Modification Corrected BOD typo(limit was incorrect)
4/25/2000 Modification Changed name and address of industry on permit
to reflect recent changes
5/2/2000 Modification Corrected Group A parameter daily limits
7/1/2002 Renewal Permit renewal with revised standard language of
Part IV;add monitor only requirements for total
phosphorus and total nitrogen
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
2

Industrial
User Pretreatment Permit (IUP)
PART I
Specific Conditions
B. IUP History(continued):
Effective Date Renewal or Modification Description of changes over previous IUP.
7/1/2003 Modification Added pretreatment and monitoring description to
Part I;Replaced Part IV with new standard
language.New permit format.Removed historical
Supplement to Permit Cover Sheet
10/28/2005 Modification Increased flow from 300,000 to 400,000 gpd
based on addition of new facility and adjusted
Group A and Group B mass limits proportionally.
Removed monitoring for Cyanide,Lead,
Chromium,Total Nitrogen,and Total Phosphorus
6/30/2006 Renewal Permit renewal.No significant changes.
2/11/2008 Modification Reduced limit for Bis(2-ethylhexyl)phthalate to
correct over-allocation. Added sample type to
Group A Parameters list and modified Part IV per
recommendations from NC DWQ PERCS.
2/16/2008 Modification Changed permit limit for Hexachlorobenzene
from 0.0008/0.000267 kg/day to Below Detection
to reduce apparent headworks allocation
12/1/2009 Modification Lowered TSS and permitted flow due to revised
headworks analysis. Reduced sampling by City to
once per 6 months.Added narrative to address
rain events and planned exceedances. Self-
Monitoring for surcharge billing will be
performed as separately directed. Removed Zinc
parameter since it is not used in process. Changed
header and footer of Part IV.
7/1/2011 Renewal Permit renewal.Daily maximum will serve as
single sample event monthly average.
11/1/2011 Modification Re-issued permit in new format.
7/1/2012 Modification Modified BOD limit due to limited allocation.
Removed Ammonia limit to monitor only,All
limits changed to concentration based limits
instead of flow-based mass limits which increased
COD to an equal concentration equivalent.
7/1/2016 Renewal Permit renewal.Definitions added. Omitted
monthly average limits and applied to daily
maximum.Added zinc as it categorical limit and
although not used in the process,no instances of
non-detect.
3/2/2018 Modification Modification from concentration-based limits to
flow-based mass limits.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
3

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
C.) 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 Control Authority and/or Municipality.
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.
IU Treatment Units
List all Treatment Units: Descriptions:
Flow Equalization Aerated equalization(2.18 MGD total volume)
Activated Sludge 3 sequential batch reactors with a digester for regenerating
waste sludge(0.450 MGD each)
Flocculation Natural Flocculation — 45 minute settle timer following
completion of reaction timers for activated sludge. No
flocculating agents are added to SBRs.
pH adjustment Addition of Sodium hydroxide to adjust pH to neutral-
basic range.
Spill protection Overflows are installed between SBRs and Digester to
prevent overfilling of a basin. Level floats are installed in
each basin to alarm for high and high-high levels and
pause the PLC activity for a particular basin.
Additionally, a diversion basin (0.188 MGD) is kept
available to handle plant spills.
3.) The Permittee is hereby authorized to, if required by the Control Authority
and/or Municipality and after receiving Authorization to Construct (A to C)
from the Control Authority and/or Municipality, construct and operate
additional pretreatment units as needed to meet final effluent limitations.
D.) Description of IUP Discharge(s):
1. Describe the discharge(s) from all regulated pipes.
Pipe# 001 , Description of Discharge:
Process wastewater is generated from specialty chemical manufacturing operation,
vessel washdown,equipment and facility cleaning.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
4

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
E.) Schematic and Monitoring Locations:
The facility schematic and description of monitoring location(s) given below must
show enough detail such that someone unfamiliar with the facility could readily
find and identify the monitoring location(s) and connection to the sewer. Include
and identify all regulated pipes.
Ka9 3
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- _ discharge to High s'
...,_ •—•"•m..Lil ', * A (Westside). I i1
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IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
5

Receiving POTW name=> Westside WWTP IU name=> KAO Specialties Americas
IUP, Part 1 Section F:
Receiving POTW NPDES#_> NC0024228 IUP#_> 0026
Effluent Limits and Monitoring Requirements Effective date for these Limits=> 3/2/2018 Pipe#_> 001
Expiration date for these Limits=> 6/30/2021 40 CFR#=> 414.85
The Permittee may discharge from this specific if not applicable put N/A
Pipe number according to these specific dates, THE LIMITS ON THIS PAGE ARE,(Check one below):
LIMITS for ENTIRE permit period =>
effluent limits, and monitoring requirements INTERIM Limits for period# 1 =>
INTERIM Limits for period#2 =>
FINAL Limits Page => X
Concentration Limits Mass Limits Monitoring Frequency
Sample
Collection
Monthly Monthly Method PQL
Daily Max Average Units Daily Max Average Units By Industry By POTW (C or G) mg/L
1 Flow 0.250* MG D Daily Every Sample Meter
2 BOD 1251.00 lbs/day Monthly Once/6 months C 2.0
3 TSS 625.50 lbs/day Monthly Once/6 months C 1.0
4 Temperature
5 pH 5.0—11.0 N/A SU Daily Every Sample G 0.1 SU
OTHER PARAMETERS;Please List Alphabetically
6 COD Monitor Only N/A Once/6 months C 15.0
The following parameters are based on OCPSF Process flow=0.183 MGD
7 Zinc 1.60 lbs/day N/A Once/6 months C 0.005
8 Acenapthene I 0.029 lbs/day N/A Once/6 months C 0.010
9 Anthracene 0.029 lbs/day N/A Once/6 months C 0.010
10 Benzene 0.087 lbs/day N/A Once/6 months G 0.010
11 Bis(2-ethylhexyl) 0.145 lbs/dayN/A Once/6 months C 0.010
phthalate
12 Carbon Tetrachloride 0.217 lbs/day N/A Once/6 months G 0.010
13 Chlorobenzene 0.217 lbs/day N/A Once/6 months G 0.010
14 Chloroethane 0.168 lbs/day N/A Once/6 months G 0.010
15 Chloroform 0.169 lbs/day N/A Once/6 months G 0.010
16 Di-n-butyl phthalate 0.031 lbs/day N/A Once/6 months C 0.010
17 1,2-Dichlorobenzene 0.299 lbs/day N/A Once/6 months C 0.010
18 1,3 Dichlorobenzene 0.217 lbs/day N/A Once/6 months C 0.010
19 1,4-Dichlorobenzene 0.217 lbs/day N/A Once/6 months G 0.010
20 1,1-Dichloroethane 0.034 lbs/day N/A Once/6 months G 0.010
21 1,2-Dichloroethane 0.275 lbs/day _ N/A Once/6 months G 0.010
•This sae captures and heats rainwater from paved surfaces,roof surfaces and storage tank diked areas.This permit specifically authorizes daily discharges that may exceed 250 000 gallons during documented rain events.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
6

IUP, Part 1 Section F continued:
Sample
Collection
Monthly Monthly Method PQL
Daily Max Average Units Daily Max Average Units By Industry By POTW (C or G) mg/L
22 1,1-Dichloroethylene 0.034 lbs/day N/A Once/6 months G 0.010
23 1 2-Trans- 0.038 lbs/dayN/A Once/6 months G 0.010
Dichloroethylene
24 1,2-Dichloropropane 0.299 lbs/day N/A Once/6 months G 0.010
25 1,3-Dichloropropylene 0.299 lbs/day N/A Once/6 months G 0.010
26 Diethyl phthalate 0.070 lbs/day N/A Once/6 months C 0.010
27 Dimethyl phthalate 0.029 lbs/day N/A Once/6 months C 0.010
28 4,6-Dinitro-o-cresol 0.119 lbs/day N/A Once/6 months C 0.010
29 Ethylbenzene 0.217 lbs/day r N/A Once/6 months G 0.010
30 Fluoroanthene 0.034 lbs/day N/A Once/6 months C 0.010
31 Fluorene 0.029 lbs/day N/A Once/6 months C 0.010
32 Hexachlorobenzene 0299 lbs/day N/A Once/6 months C 0.010
33 Hexachlorobutadiene 0.217 lbs/day N/A Once/6 months C 0.010
34 Hexachloroethane 0.299 lbs/day N/A Once/6 months C 0.010
35 Methyl Chloride 0.168 lbs/day N/A Once/6 months G 0.010
36 Methylene chloride 1 0.055 lbs/day N/A Once/6 months G 0.010
37 Naphthalene 0.029 lbs/day N/A Once/6 months C 0.010
38 Nitrobenzene 3.414 lbs/day N/A Once/6 months C 0.010
39 2-Nitrophenol 0.099 lbs/day N/A Once/6 months C 0.010
40 4-Nitrophenol 0.247 lbs/day N/A Once/6 months C 0.010
41 Phenanthrene 0.029 lbs/day N/A Once/6 months C 0.010
42 Pyrene 0.031 lbs/day N/A Once/6 months G 0.010
43 Tetrachloroethylene 0.079 lbs/day N/A Once/6 months G 0.010
44 Toluene 0.043 lbs/day N/A Once/6 months G 0.010
45 1,2,4-Trichlorobenzene 0.299 lbs/day N/A Once/6 months G 0.010
46 1,1,1-Trichloroethane 0.034 lbs/day N/A Once/6 months G 0.010
47 1,1,2-Trichloroethane 0.049 lbs/day N/A Once/6 months G 0.010
48 Trichloroethylene 0.040 lbs/day N/A Once/6 months G 0.010
49 Vinyl Chloride 0.148 lbs/day N/A Once/6 months C 0.010
'This site captures and treats rainwater hom paved surfaces,root Surfaces end storage tank diked areas.This permit specifically authorizes dally discharges Thal may eacssd 250,000 gallons during documented talo events.
The permittee will request authorization tot planned activities that may exceed 250.000 gpd.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
7

Industrial User Pretreatment Permit (TUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s)notes:
In addition to the definitions in the City of High Point Sewer Use Ordinance the following
defmitions and requirements apply:
1. Composite Sample:
Unless defined differently below, a composite sample for the monitoring requirements of
this IUP is defined as the automatic or manual collection of one grab sample of constant
volume, not less than 100 ml, collected every hour during the entire discharge period on
the sampling day and proportioned for flow. Sampling day shall be a typical
production,and discharge day.
2. Daily Monitoring Frequency
Daily Monitoring Frequency as specified in this IUP shall mean each day of discharge.
3. Continuous/Daily Monitoring Frequency
For flow, "daily" shall mean the permittee shall read the flow meter totalizer every day,
including weekends and holidays, convert this to a daily flow, and report these daily
flows to the control Authority with the report due under Part II,2.
4. "Every Sample"Monitoring Frequency
A monitoring Frequency of"every sample" as specified in this IUP shall mean each time
a composite or grab sample is collected.
5. Grab Sample
Grab sample for the monitoring requirements of this IUP, is defined as a single "dip and
take"sample collected at a representative point in the discharge stream.
6. Instantaneous measurement
An Instantaneous measurement for the monitoring requirements of this IUP is defined as
a single reading,observation,or measurement.
7. "Monthly Average"
The arithmetic average of all samples collected during a calendar month
for a particular parameter. One sample can constitute a monthly average.
I1.P#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
8

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
Outline of PART II,
1. Representative Sampling 16. Federal and/or State Laws
2. Reporting 17. Penalties
3. Test Procedures 18. Need to Halt or Reduce
4. Additional Monitoring by 19. Transferability
Permittee
5. Duty to comply 20. Property Rights
6. Duty to Mitigate 21. Severability
7. Facilities Operation, Bypass 22. Modification, Revocation,
Termination
8. Removed substances 23. Reapplication
9. Upset Conditions 24. Dilution Prohibition
10. Right of Entry 25. Reports of Changed Conditions
11. Availability of Records 26. Construction of pretreatment
facilities
12. Duty to provide information 27. Reopener
13. Signatory Requirements 28. Categorical Reopener
14. Toxic Pollutants 29. General Prohibitive Standards
15. Civil and Criminal Liability 30. Reports of Potential Problems
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume and
nature of the monitored discharge. All samples shall be taken at the monitoring points specified in
this permit and, unless otherwise specified, before the effluent joins or is diluted by any other
wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and approval by,the permit issuing authority.
a) The permittee shall install and maintain a refrigerated automatic composite sampler
capable of interfacing with the effluent flow metering device. Variances may be
permitted on a case by case basis for portable,non-refrigerated samplers.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms specified by the
Control Authority and/or Municipality,postmarked no later than the twentieth day of the
month following the month in which the samples were taken. If no discharge occurs
during a reporting period (herein defined as each calendar month) in which a sampling
event was to have occurred, a form with the phrase "no discharge" shall be submitted.
Copies of these and all other reports required herein shall be submitted to the Control
Authority and/or Municipality and shall be sent to the following address:
Carrie Boyd
Pretreatment Supervisor
City of High Point Industrial Pretreatment Program
P.O.Box 230
High Point,NC 27261
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
9

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
b.) If the sampling performed by the permittee indicates a violation,the permittee shall notify the
Control Authority and/or Municipality within 24 hours of becoming aware of the violation.
The permittee shall also repeat the sampling and analysis and submit the results of the repeat
analysis to the Control Authority and/or Municipality within 30 days after becoming aware of
the violation.
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with the techniques
prescribed in 40 CFR part 136 and amendments thereto unless specified otherwise in the
monitoring conditions of this permit.
4. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more frequently than
required by this permit, using approved analytical methods as specified above, the results of such
monitoring shall be submitted to the Control Authority and/or Municipality. The Control
Authority and/or Municipality may require more frequent monitoring or the monitoring of other
pollutants not required in this permit by written notification.
5. DutyComply
to p Y
The permittee must comply with all conditions of this permit. Any permit noncompliance
constitutes a violation of the Control Authority and/or Municipality Sewer Use Ordinance and is
grounds for possible enforcement action.
6. Duty to Mitigate - Prevention of Adverse Impact
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of
this permit which has a reasonable likelihood of adversely affecting human health,the POTW,the
waters receiving the POTW's discharge,or the environment.
7. Facilities Operation, Bypass
The permittee shall at all times maintain in good working order and operate as efficiently as
possible, all control facilities or systems installed or used by the permittee to achieve compliance
with the terms and conditions of this permit. Bypass of treatment facilities is prohibited except
when approved in advance by the Control Authority and/or Municipality. Bypass approval shall
be given only when such bypass is in compliance with 40 CFR 403.17.
8. Removed Substances
Solids, sludges, filter backwash, 4r other pollutants removed in the course of treatment or control
of wastewaters shall be disposed of in a manner such as to prevent any pollutants from such
materials from entering the sewer system. The permittee is responsible for assuring its compliance
with any requirements regarding die generation,treatment, storage, and/or disposal of"Hazardous
waste"as defined under the Federl Resource Conservation and Recovery Act.
9. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and temporary
noncompliance with the effluent limitations of this permit because of factors beyond the
reasonable control of the permittee. An upset does not include noncompliance to the extent caused
by operational error, improperly designed or inadequate treatment facilities, lack of preventative
maintenance,or careless or improper operations.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
10

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
An upset may constitute an affirmative defense for action brought for the noncompliance. The
permittee has the burden of proof to provide evidence and demonstrate that none of the factors
specifically listed above were responsible for the noncompliance.
10. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of Environment and
Natural Resources, Division of Water Quality, the Regional Administrator of the Environmental
Protection Agency, the Control Authority and/or Municipality, and/or their authorized
representatives,upon the presentation of credentials:
1. To enter upon the permittee's premises where a real or potential discharge is located or
in which records are required to be kept under the terms and conditions of this permit;
and
2. At reasonable times to have access to and copy records required to be kept under the
terms and conditions of this permit;to inspect any monitoring equipment or monitoring
method required in this permit;and to sample any discharge of pollutants.
11. Availability of Records and Reports
The permittee shall retain records of all monitoring information, including all calibration and
maintenance records as well as copies of reports and information used to complete the application
for this permit for at least three years. All records that pertain to matters that are subject to any
type of enforcement action shall be retained and preserved by the permittee until all enforcement
activities have concluded and all periods of limitation with respect to any and all appeals have
expired.
Except for data determined to be confidential under the Sewer Use Ordinance, all reports prepared
in accordance with terms of this permit shall be available for public inspection at the Control
Authority and/or Municipality. As required by the Sewer Use Ordinance, effluent data shall not
be considered confidential.
12. Duty to Provide Information
The permittee shall furnish to the Director of Public Works or his/her designees, within a
reasonable time, any information which the Director, his/her designee, or the Division of Water
Quality may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The permittee shall also
furnish,upon request,copies of records required to be kept by this permit.
13. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit must be signed
and certified by the Authorized Representative as defined under the Sewer Use Ordinance. If the
designation of an Authorized Representative is no longer accurate because a different individual or
position has responsibility for the overall operation of the facility, or overall responsibility for
environmental matters for the company, a new authorization satisfying the requirements of this
section must be submitted to the Director prior to or together with any reports to be signed by an
authorized representative.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
11

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
14. Toxic Pollutants
If a toxic effluent standard or prohibition(including any schedule of compliance specified in such
effluent standard or prohibition) is established under Section 307(a) of the Federal Clean Water
Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more
stringent than any limitation for such pollutant in this permit, this permit may be revised or
modified in accordance with the toxic effluent standard or prohibition and the permittee so
notified.
15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties
for noncompliance.
16. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve
the permittee from any responsibilities, liabilities, or penalties established pursuant to any
applicable Federal and/or State law or regulation.
17. Penalties
The Sewer Use Ordinance of the Control Authority and/or Municipality provides that any person
who violates a permit condition is subject to a civil penalty not to exceed$25,000 dollars per day
of such violation.
Under state law, (NCGS 143-215.6B), under certain circumstances it is a crime to violate terms,
conditions, or requirements of pretreatment permits. It is a crime to knowingly make any false
statement,representation,or certification in any record or other document submitted or required to
be maintained under this permit, including monitoring reports or reports of compliance or
noncompliance. These crimes are enforced at the prosecutorial discretion of the local District
Attorney.
18. Need to Halt or Reduce not a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessary
to halt or reduce the permitted activity to maintain compliance with the conditions of the permit.
19. Transferability
This permit shall not be reassigr ed or transferred or sold to a new owner, new user, different
premises,or a new or changed operation without approval of the Town.
20. Property Rights
This permit does not convey y property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights,nor any infringem nt of Federal, State or local laws or regulations.
21. Severability •
The provisions of this permit are severable and, if any provision of this permit or the application
of any provision of this permit to any circumstance is held invalid, the application of such
provision to other circumstances and the remainder of this permit shall not be affected thereby.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
12

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
22. Permit Modification, Revocation, Termination
This permit may be modified,revoked and reissued or terminated with cause in accordance to the
requirements of the Control Authority and/or Municipality Sewer Use Ordinance and North
Carolina General Statute or implementing regulations.
23. Re-Application for Permit Renewal
The permittee is responsible for filing an application for reissuance of this permit at least 180 days
prior to its expiration date.
24. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any other way attempt to
dilute the discharge as a partial or complete substitute for adequate treatment to achieve
compliance with the limitations contained in this permit.
25. Reports of Changed Conditions
The permittee shall give notice to the Control Authority and/or Municipality of any planned
significant changes to the permittee's operations or system which might alter the nature,quality,or
volume of its wastewater at least 180 days before the change. The permittee shall not begin the
changes until receiving written approval from the Control Authority and/or Municipality. Also
see Part II,30 below for additional reporting requirements for spill/slug issues.
Significant changes may include but are not limited to
(a) increases or decreases to production;
(b) increases in discharge of previously reported pollutants;
(c) discharge of pollutants not previously reported to the Control Authority and/or
Municipality;
(d) new or changed product lines;
(e) new or changed manufacturing processes and/or chemicals; or
(f) new or changed customers.
26. Construction
No construction of pretreatment facilities or additions thereto shall be begun until Final Plans and
Specifications have been submitted to the Control Authority and/or Municipality and written
approval and an Authorization to Construct(A to C)have been issued.
27. Reopener
The permit shall be modified or,alternatively,revoked and reissued to comply with any applicable
effluent standard or limitation for the control of any pollutant shown to contribute to toxicity of
the WWTP effluent or any pollutant that is otherwise limited by the POTW discharge permit. The
permit as modified or reissued under this paragraph may also contain any other requirements of
State or Federal pretreatment regulations then applicable.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
13

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
28. Categorical Reopener
Thisermit shall
p be modified, or alternatively, revoked and reissued, to comply with any
applicable effluent standard or limitation issued or approved under Sections 302(b)(2)(C)and(D),
304(b)(2), and 307(a)(2)of the Clean Water Act, if the effluent standard or limitation so issued or
approved:
1.) contains different conditions or is otherwise more stringent than any effluent
limitation in this permit;or
2.) controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements
of the Act then applicable.
29. General Prohibitive Standards
The permittee shall comply with the general prohibitive discharge standards in 40 CFR 403.5 (a)
and(b)of the Federal pretreatment regulations.
30. Potential Problems
The permittee shall provide protection from accidental and slug discharges of prohibited materials
and other substances regulated by this permit. The permittee shall also notify the POTW
immediately of any changes at its facility affecting the potential for spills and other accidental
discharge, discharge of a non-routine, episodic nature, a non-customary batch discharge, or a slug
load as defined in the Sewer Use Ordinance.
Additionally, the permittee shall notify by telephone the Control Authority and/or Municipality
immediately of all discharges that could cause problems to the POTW including any slug loadings
as defined in the Sewer Use Ordinance. If the permittee experiences such a discharge, they shall
inform the Control Authority and/or Municipality immediately upon the first awareness of the
commencement of the discharge. Notification shall include location of the discharge, type of
waste, concentration and volume if known and corrective actions taken by the permittee. A
written follow-up report thereof shall be filed by the permittee within five (5)days, unless waived
by the Control Authority and/or Municipality.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
14

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
1. Slug/Spill Control Measures
In addition to the requirements in Part II, 30, the Permittee shall complete installation and/or
commence implementation, operation, and/or maintenance of the following specific protection
Measures, Activities, Plans. Etc. (Items without specific completion date(s), or marked as
"Continuous."must be performed for the entire duration of the permit):
Required Completion/
Description of Measure,Activity, Plan, etc. Implementation Date
Implementation of current and updated Slug/Spill Control plan Plan on file
Continuous
The permittee shall provide updates to the Control Authority as required by Part II, 30, of this
IUP. Modifications to the measures shall be approved by the Control Authority prior to
installation/implementation. If a measure fails, the Control Authority shall be notified within 24
hours.
2. Sludge Management Plan
Ninety days prior to the initial disposal of sludge generated by any pretreatment facility, the
permittee shall submit a sludge management plan to the Control Authority.
3. Flow Measurement Requirements
The permittee shall maintain appropriate discharge flow measurement devices and methods consistent
with approved scientific practices to ensure the accuracy and reliability of measurements of the
volume of monitored discharges. Devices installed shall be a continuous recording flow meter
capable of measuring flows with a maximum deviation of less than 10% from true discharge rates
throughout the range of expected discharge volumes. The totalizer shall be non-resetable. The
devices shall be installed, calibrated, and maintained to ensure accuracy. At the time of issuance of
the permit, this method consists of continuous flow measurement at sample point for Pipe 001.
The meter shall be calibrated every year,and the permittee shall include a copy of the calibration
report with the applicable monthly report required under Part II, 2, of this permit.
Modifications to the flow metering equipment shall be approved by the Control Authority prior to
installation. If a required flow measurement device fails, the Control Authority shall be notified
within 24 hours.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Division of Water Quality Certified
Laboratory that is certified in the analysis of the pollutant in wastewater.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
15

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
5. Certified Operator
The permittee shall employ appropriately trained operators capable of properly operating all
pretreatment units.Permittee shall notify the POTW of designated operators, including credentials
if applicable,within 24 hours of any delegated operator changes
6. Total Toxic Organics (TTO) Definition
"TTO", or Total Toxic Organics, is the sum of the concentrations of the toxic organic compounds
listed in 40 CFR 414 that are found in the permittee's process discharge at a concentration greater
than 0.01 mg/1.
7. Total Toxic Organics (TTO) Certification
In lieu of monitoring for TTO, the permittee may, upon submitting to the Control Authority one
sample showing TTO compliance and a toxic organic management plan make the following
certification every six months:
"Based upon my inquiry of the person or persons directly responsible for managing
compliance with the permit limitation for total toxic organics(TTO),I certify that,to the best
of my knowledge, no dumping of concentrated toxic organics into the wastewaters has
occurred since filing of the last monitoring report. I further certify that this facility is
implementing the toxic organic management plan submitted to the Control Authority."
At a minimum,the certification statements are due by June 15'of each year covering the January
through June six month period, and December 15th of each year covering the July through
December six month reporting period. If the certification is not submitted for both periods within
10 days of the respective due dates, the Control Authority shall collect TTO samples before
December 31 {and the permittee may be billed for the cost of the TTO sampling and/or analysis).
8. Toxic Organic Management Plan
Within ninety days of the issuance of this permit, the permittee shall develop and submit to the
Control Authority a toxic organic management plan.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
16

IUP Synopsis
A. IUP Basic Information
Receiving POTW name: POTW NPDES#:
City of High Point Westside WWTP NC0024228
IUP name: IUP Number:
ICAO Specialties Americas LLC 0026
IUP Effective date: Pipe Numbers,list all regulated pipes:
March 2,2018 001
IUP expiration date: IUP 40 CFM,if applicable:
June 30,2021 414.85
B. IUP Survey& Application form
Attach a completed copy of the Industrial User Wastewater Survey&
Application Form(see appendix 6-A)
C. IU Inspection form
Attach a copy of an Industrial User Inspection Form(see chapter 7) completed
by the Control Authority within the past 12 months.
D. RATIONALE FOR LIMITATIONS:
As listed on the IUP Limits Page(s), PART I, Section F of the IUP.
RATIONALE#1:
Review of IU Monitoring Data, with no Over Allocation situation:
The following pollutants were assigned numerical limits in this lOP based
on a review of monitoring data for the permittee to determine what ranges of
concentrations are currently being discharged. To account for sample
variability a factor was applied to the monitoring data to determine the
permit limit. Permit limits assigned by the Local IUP Control Authority
cannot result in an Over Allocation situation for any pollutants.
pH—Local Limit
BOD—NPDES Permit has limits
TSS—NPDES Permit has limits
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
1

IUP Synopsis
RATIONALE#2a:
Categorical Industrial Limits, with no Over Allocation situation:
Check here if Combined Wastestream Formula (CWF) or other categorical
limits calculations were used. If used, Please attach calculations: (see CWF
Spreadsheet, Appendix 6-F)
Were used(attach calculations)
Were not used X
The following pollutants were assigned numerical limits in this IUP based
on the categorical regulations. These limits do not result in over allocations.
Zinc, Toxic Organics
RATIONALE#3a:
Over Allocation Prevention, with IU pollutant reduction:
The following pollutants were assigned numerical limits in this IUP based
on allocating the Maximum Allowable Industrial Loading (MAIL)
determined with the Headworks Analysis (HWA) among all Industrial
Users. The total loading of each pollutant from all permitted discharges
does not exceed the MAIL. These limits do not result on over allocations.
N/A
RATIONALE#3b:
Interim Limits for IU pollutant reduction:
The following pollutants were assigned interim numerical limits in this IUP
to allow time for the i idustry to come compliance with final limits that will
not in over allocations)
N/A
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date: 3/2/2018
2

IUP Synopsis
RATIONALE#4:
4.) Other Rationale for Limitations:
The following rationale was used for developing IUP Limits.
Parameter Rationale
COD No local limit and not an allocated
pollutant. Already measures BOD.
RATIONALE#5a:
Non-Categorical Parameters where No Limit needed or assigned in an IUP:
The following pollutants were not assigned numerical limits in this IUP
because the loadings for these pollutants from this IU were less than 5% of
the MAHL. The loading of these pollutants from this IU is considered
insignificant at this time.
Pollutant Avg SIU mg/1 Avg SIU lbs/day 5%MAHL, lbs/day
Ammonia 0.640 0.688 2.3686
Based on 2012-2017 data
RATIONALE#5b:
Categorical Parameters with Waived Monitoring:
Monitoring is waived for the following categorical parameters (attach
documentation of waiver justification).
Cyanide — Was removed from permit in 10/2005 permit modification.
Historical records show it had not been detected since 2003
Lead—was removed from permit in 10/2005 permit modification. Historical
records show it had not been detected since 2004.
IUP#0026 Renewal Effective Date: 7/1/2016 Modification Effective Date:3/2/2018
3

Workbook Name : WS HWA Working.xlsx, Worksheet Name: AT
Allocation Table
Headworks last approved: 07/26/17
Allocation Table updated: 07/26/17
Permits last modified: 03/02/18
pony— Westside
NPDES#=> NC0024228
FLOW BOD TSS
Industry Type Renewal Modification Date Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit Pipe of Effective Effective Permit Conc. Load Conc. Load
Count (please hal alphabelicly) number number Industry Date Date Expires MGD gal/day lbs/day mg/I lbs/day
1 Cascade Die Casting Group 0128 001 464.16 07/01/16 06/30/21 0.0090 9,000
2 Dairy Fresh 0151 001 Dairy 06/07/16 06/06/21 0.2000 200,000 32_
5337.608 1500.00 2502.00
3 KAO Specialties Americas 0026 001 414.85 07/01/16 03/02/18 06/30/21 0.2500 250,0001••••.---
1251.00 625.50
4 Piedmont Chemicals Industries I 0036 001 414.85 07/01/16 06/30/21 0.1000 100,000 417.00 166.80
•5
► 4
6
7
8 ,
9 ,
10 1 ..4
Column Totals=> 0.5590, 559,000 70061 1 32941
Basis=> NPDES Design Design
MAHL from HWA(lbs/day)=> NPDES Permitted Flow=> 6.2000 15512 10342
Uncontrollable Loading(lbs/day)_> 2.5242 6000 5263
Total Allowable for Industry(MAIL)(lbs/day)_> 3.6758 9513 5079
Total Permitted to Industry(lbs/day)=> 0.5590 7006 3294
MAIL left(lbs/day)_> 3.1168 2507 1784
Percent Allow.Ind.(MAIL)still available(%)=> 84.8% 26.4% 35.1 %
5 Percent MARL(lbs/day)_> 0.3100 776 517
1

1

Workbook Name : WS HWA Working.xlsx, Worksheet Name: AT
Allocation Table
Headworks last approved: 07/26/17
Allocation Table updated: 07/26/17
Permits last modified: 03/02/18
POTW=>Westside
NPDES#=> NC0024228
Ammonia Arsenic Cadmium Chromium Copper Cyanide
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please hstalphabeticly) number number mg/I lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day
1 Cascade Die Casting Group 0128 001 0.0375
2 Dairy Fresh 0151 001
3 KAO Specialties Americas 0026 001
4 Piedmont Chemicals Industries I 0036 001 0.2350 0.1960
5
6 I
7
8
9
_ i m...... ...-..i-.-.
t
10
Column Totals=> 0 0.0000 0.0000 1 0.0000 1 0.0375 t 0.19601
AS/Nit/TF Stream Stream AS/Nit/TF Stream
Basis=> Design inhibition Std Std inhibition Std
MAHL from HWA(lbs/day)_> 568.79 2.3686 0.1653 7.5755 25.2646 0.4399
Uncontrollable Loading(lbs/day)_> 345.25 0.1200 0.0105 0.0821 0.6842 0.1074
Total Allowable for Industry(MAIL)(lbs/day)_> 223.54 2.2486 0.1548 7.4934 24.5805 0.3325
Total Permitted to Industry(lbs/day)_> 0.00 0.0000 0.0000 0.0000 0.0375 0.1960
MAIL left(lbs/day)_> 223.54 2.2486 0.1548 7.4934 24.5430 0.1365
Percent Allow.Ind.(MAIL)still available(%)=> 100.0% 100.0% 100.0% 100.0% 99.8% 41.1 %
5 Percent MAHL(lbs/day)=> 28.44 0.1184 0.0083 0.3788 1.2632 0.0220

,
1
I
1

Workbook Name : WS HWA Working.xlsx, Worksheet Name: AT
Allocation Table _
Headworks last approved: 07/26/17
Allocation Table updated: 07/26/17
Permits last modified: 03/02/18
POTw=> Westside
NPDES#=> NC0024228
Lead Mercury Molybdenum Nickel Selenium
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit PipeConc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please listalphabeticly) number number J mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/I lbs/day mg/1 lbs/day
I Cascade Die Casting Group 0128 001 0.1000
2 Dairy Fresh 0151 001
3 KAO Specialties Americas 0026 001
4 Piedmont Chemicals Industries I 0036 001 0.1790 0.1493
5
6 _
7
4
8
9 _
10
Column Totals=> I 0.24931 I 0.0000001 I 0.00001 0.0000 0.0000
Stream Stream Stream
Basis=> Std N P D ES Std Std
MAHL from HWA(lbs/day)=> 1.7482 0.024932 4.1378 0.2727
Uncontrollable Loading(lbs/day)=> 0.1074 0.005473 0.1158 0.1095
Total Allowable for Industry(MAIL)(lbs/day)_> 1.6408 0.019459 4.0220 0.1632
I Total Permitted to Industry(lbs/day)_> 0.2493 0.000000 0.0000 0.0000 0.0000
MAIL left(lbs/day)_> 1.3915 0.019459 4.0220 0.1632
Percent Allow.Ind.(MAIL)still available(%)_> 84.8% 100.0% #VALUE! 100.0% 100.0%
5 Percent MAHL(lbs/day)_> 0.0874 0.001247 0.2069 0.0136

Workbook Name : WS HWA Working.xlsx, Worksheet Name: AT
Allocation Table
Headworks last approved: 07/26/17
Allocation Table updated: 07/26/17
Permits last modified: 03/02/18
POTW=> Westside
NPDESi)=> NC0024228
Silver Zinc Total Nitrogen Total Phos. COD
Industry Permit Limits Permit Limits Permit Limits Permit Limits Permit Limits
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count 1 (plcasc list alphabeticly) number number mg/I lbs/day mg/I lbs/day mg/1 lbs/day mg/I lbs/day mg/I lbs/day
1 Cascade Die Casting Group 0128 001 1.0000
2 Dairy Fresh 0151 001 10000 16680
3 KAO Specialties Americas 0026 001 1.6000
4 Piedmont Chemicals Industries I 0036 001 0.4900 _
5
6 -
7
8
9
10
Column Totals=> 0.0000 1 3.0900 0.00 0.00 16680
AS/Nit/TF AS/Nit/TF
Basis=> inhibition inhibition NPDES
MARL from HWA(lbs/day)=> 7.4018 30.7605 202.64
Uncontrollable Loading(lbs/day)_> 0.0526 2.6146 575.5675 167.59
Total Allowable for Industry(MAIL)(lbs/day)_> 7.3491 28.1459 35.06
Total Permitted to Industry(lbs/day)_> 0.0000 3.0900 0.00 0.00 16680
MAIL left(lbs/day)_> 7.3491 25.0559 35.06
Percent Allow.Ind.(MAIL)still available(%)_> 100.0% 89.0% #VALUEI 100.0% #VALUEI
5 Percent MAHL(lbs/day)_> 0.3701 1.5380_ 10.1322