2018 SHAMROCK ENVIRONMENTAL II PERMIT

City
6 I North
August 31, 2018
of Greensboro
Carolina Water Resources Department
Steve Davis
SHAMROCK ENVIRONMENTAL t
519 Patton Avenue
Greensboro, North Carolina 27406
Dear Mr. Davis:
Enclosed is the renewal of Significant Industrial User Permit #P068 effective September 1,
2018. Also included is the City of Greensboro Local Pollutant Allocation Document.
The Permittee and the State of North Carolina have 30 days from receipt to comment on this
permit. If you have any comments or objections to the permit, please notify the City of
Greensboro in writing no later than October 01, 2018. If no written objections are received
within 30 days, the permit will be considered final and binding.
Please return a signed copy of the signatory page (Page 2) to the City of Greensboro. The
signature requirement is to make the signatory official aware of his/her responsibilities. In
addition, the signature of a high ranking official on a permit document displayed at a facility
reminds all employees that the company has a legal commitment to comply.
Sincerely,
Frank Skee
Pretreatment Coordinator
Encl: Permit /Standard Conditions/Permit Synopsis/Local Pollutant Allocation Document

City
6 J North
of Greensboro
Carolina
SHAMROCK ENVIRONMENTAL
STA TEMENT OF RECEIPT
For 2018 Industrial User Permit #P068
2018 Permit Received by:
Name of program: Industrial Waste Services
Water Resources Department
City of Greensboro

CITY OF GREENSBORO
WATER RESOURCES DEPARTMENT
INDUSTRIAL WASTE SECTION
SIGNIFICANT INDUSTRIAL USER
WASTEWATER DISCHARGE PERMIT
SIU PERMIT NUMBER P068
SHAMROCK ENVIRONMENTAL II
IS AUTHORIZED TO DISCHARGE WASTEWATER
FROM A FACILITY LOCATED AT
519 PATTON AVENUE
GREENSBORO, NORTH CAROLINA
into the City of Greensboro Sanitary Sewer System
to the T.Z. OSBORNE Water Reclamation Facility
[NPDES PERMIT NUMBER NCO0473841
in accordance with the limitations and conditions set forth in this permit.
This permit shall become effective
SEPTEMBER 1, 201B
This permit and the authorization to discharge shall
expire at midnight on
AUGUST 31, 2023
or upon permit reissuance, whichever comes first.
Frank Skee
Pretreatment Coordinator
September /, 2018 Permit Renewal
Date

Page 2, SIU Permit #P068
SHAMROCK II — PATTON AVENUE
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, 2018 Permit Renewal

Page 3, SIU Permit #P068
SHAMROCK II - PATTON AVENUE
SECTION I - PERMIT MODIFICATION HISTORY
DATE MODIFIED
REASON & DESCRIPTION OF MODIFICATION OR ACTION
February 1, 2003
New SIU Permit - Shamrock Environmental is leasing the facility formerly
known as Four Seasons Environmental
PERMIT RENEWAL
September 1, 2003
Permit Renewal 30-Day Comment Period: Reduced Self -monitoring Requirements
on pages 6 and 7.
October 1, 2004
Change location where flow readings are to be taken and where compliance flows
are to be taken during malfunction/failure of effluent meter [Section IV- C.3 and
C.5]. This change is being made due to problems with the effluent flow meter.
November 19, 2004
Changed expiration date on cover page, typographical error. Expiration date
should be 2008 and not 2003.
Industry has performed sampling weekly for copper and mercury and has not
January 1, 2005
violated their permit limitations. Page 7, changes Permittee monitoring
frequency on copper and mercury from weekly to monthly.
PERMIT RENEWAL
Page 5, Section II.C. - modiflcation of description of monitoring location; Page 6,
Section III - Daily Maximum flow limit changed to Monthly Average limit Of
30,000 gpd; Page 7, Section IV.B.3. - incorporated requirement for flow data
September 1, 2008
submittal by the 15th for the previous month's readings; Section IV.B.4. -
modifled to specify reporting period;
Section IV.B.5. - modified to include additional POTW contact information; Page
9, Section IV.C. - incorporated requirement to notify POTW in writing in the
event of zero discharge for a reporting period.
1) Modified Section II.A. to include boiler and cooling tower feed to discharge per
January 2, 2009
PERCS review letter dated 8128108; 2) Modifled to change monitoring from
monthly to quarterly for copper and mercury
Permit Modification
1) Page 5, Section III - Increased Flow to 35,000 gpd monthly average due to
increased operations; Changed minimum sampling requirement for City to
July 1, 2011
1/year. 2) Page 6, Section IV.B.4. - changed effluent fluent meter calibration
requirement from once per six-month period to once a calendar year; 3) Page 6,
Section IV.B. 5 and 6. - deleted names from permit and included the position
titles only.
PERMIT RENEWAL
September 1, 2013
Section IV. - Added Special Condition F (Slug/Spill Control Plan) per DWQ
guidance; Section III - Modifled self -monitoring requirements, added selenium to
POTW monitoring.
PERMIT RENEWAL
September 1, 2018
Special Condition Changes: Added Flow Measurement Calibration/ Verification
Section, Modifled flow language
September 1, 2018 Permit Renewal

Page 4, SIU Permit #P068
SHAMROCK II-PATTON AVENUE
SECTION II - GENERAL INFORMATION
A. Description of Di
Pipe 01- Process Wastewater from cleaning of transport tankers, storage tanks, tote tanks,
boiler and cooling tower blowdown.
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.
Grit Removal Oil/Water Separator
pH adjustment/Neutralization Spill Protection
Filtration Screening
Sedimentation Solids Removal
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
Manhole on southeast corner of Tank Wash Bay #1 on the north side of and adjacent to
Fieldcrest Drive
D. Composite Sampling Technique
A composite sample for the purposes of this permit is:
A Flow Proportional Composite sample taken over the entire workday by a refrigerated
automatic sampler interfaced with the effluent flow meter.
September I, 2018 Permit Renewal

Page 5, SIU Permit #P068
SHAMROCK II - PATTON AVENUE
Effective September 1, 2018
SECTION III - EFFLUENT LIMITS AND MONITORING REQUIREMENTS PIPE 01
THIS FACILITY IS REGULATED BY THE FEDERAL CATEGORICAL PRETREATMENT STANDARDS
FOR TRANSPORTATION EQUIPMENT CLEANING [40 CFR PART 442.15 - SUBPART A]
EFFLUENT
LIMITATIONS
MONITORING FREQUENCY
EFFLUENT
CHARACTERISTICS
Daily
Maximum
Monthly
Average
6-Month
Average
Sample
Type
PERMITTEE
CITY OF
GREENSBORO
Flow (gallons per day)
35,000
#
DAILY
pH (Standard Units)
5.0 -12.0
Grab
1/year
BOD++ (mg/1)
M
C
2/6 months
1/year
Suspended Solids++ (mg/1)
M
C
2/6 months
1/year
Cadmium (T) (mg/1)
M
C
2/6 months
1/year
Chromium (T) (mg/1)
M
C
2/6 months
1/year
Copper (T) (mg/1)
M
C
2/6 months
1/year
Lead (T) (mg/1)
M
C
2/6 months
1/year
Nickel (T) (mg/1)
M
C
2/6 months
1/year
Zinc (T) (mg/1)
M
C
2/6 months
1/year
Silver (T) (mg/1)
M
C
2/6 months
1/year
Selenium (T) (mg/1)
M
C
1/year
Cyanide (total) (mg/1)
M
Grab
1/6 months
1/year
Mercury (T) (mg/1)
M
C
2/6 months
1/year
Non -Polar Material [SGT-
HEM]^ (mg/1)
M
Grab
2/6 months
1/year
ALL METALS ARE TO BE ANALYZED AS TOTAL [T]
# The Greensboro Industrial Waste Section does not consider Flow to be a pollutant and
flow data is not considered to be a report.
^Silica Gel Treated Hexane Extractable Material (analyzed using EPA Method 1664)
++ 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 1, 2018 Permit Renewal

Page 6, SIU Permit #P068
SHAMROCK II - PATTON AVENUE
SECTION IV - SPECIAL PERMIT CONDITIONS
A. FLOW MEASUREMENT
Compliance with the flow limit in this permit shall be documented in the following manner:
1. The Permittee shall provide and maintain a refrigerated composite sampler and primary
flow measurement device for flow proportional sampling and flow measurement of the
permittee's process wastewater discharge.
2. The effluent process flow meter readings shall be recorded daily and the daily effluent flow
calculated in gallons per day. Flow measurement records shall be submitted to the City of
Greensboro Industrial Waste Section monthly. Data is to be submitted by the 15t' of each
month for the previous month's flow measurements.
3. The permittee shall maintain permanent flow records and maintenance and calibration
records on -site for a minimum of three years. These records shall be available to the City of
Greensboro Industrial Waste Section during inspections or upon request.
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, 2018 Permit Renewal

Page 7, SIU Permit #P068
SHAMROCK II - PATTON AVENUE
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. CENTRALIZED WASTE TREATMENT OPERATIONS
Shamrock shall account for all Centralized Waste Treatment wastestreams processed on -site to
prove that no CWT wastewater is discharged from this facility. Records shall be maintained and
available upon request to the POTW.
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]
D. POLLUTANT MANAGEMENT PLAN
Shamrock Environmental shall implement the current approved Pollutant Management Plan
[required by 40 CFR Part 442.15 (b) (1) and described in 40 CFR Part 442.15 (b)(1-5)] on file with
the City of Greensboro Industrial Waste Section. This Plan and any subsequent Plan
modifications are hereby established as a condition of this Significant Industrial User Permit
and shall be enforceable as such by the POTW.
Failure to implement the Pollutant Management Plan may result in the Federal Categorical
Standards in 40 CFR Part 442.15 (a) being placed in this Significant Industrial User Permit.
September 1, 2018 Permit Renewal

Page 8, SIU Permit #P068
SHAMROCK II - PATTON AVENUE
E. PERMITTEE SAMPLING AND MONITORING REPORT SUBMITTAL DATES
Permittee Sampling for the pollutant limitations in Section III (Effluent Limits and Monitoring
Requirements) of this permit shall be conducted in the following manner:
1. Samples for the January 1 June 30 Reporting Period shall ALL be taken during the
months of January, February and/or March. The compliance report shall be submitted
on or before APRIL 15 of each year.
2. If there are no discharges during months designated for sampling, the April 15
compliance report shall be submitted with the notation "NO DISCHARGE/NO
SAMPLING". If there is a discharge after March and prior to June 30, self -monitoring is
still required to meet the permit monitoring requirements and that data shall be
submitted with the corresponding monthly flow data.
3. Samples for the July 1-December 31 Reporting Period shall ALL be taken during the
months of July, August and/or September. The compliance report shall be submitted on
or before OCTOBER 15 of each year.
4. If there are no discharges during months designated for sampling, the October 15
compliance report shall be submitted with the notation "NO DISCHARGE/NO
SAMPLING". If there is a discharge after September and prior to December 31, self -
monitoring is still required to meet the permit monitoring requirements and that data
shall be submitted with the corresponding monthly flow data.
If there are no discharges during an entire semi-annual reporting period, a letter must be
submitted to the Industrial Waste Section by July 15 or January 15 stating there was no
discharge and no sampling for that period. This letter must be signed and certified by the
signatory official.
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.
1. 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 (either total gallon calculation or deduct) 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.
September 1, 2018 Permit Renewal

Page 9, SIU Permit #P068
SHAMROCK II — PATTON AVENUE
The following flow meters/systems have no calibration requirements:
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.
Industries with a non -discharge closed -loop system are not required to have any meter
on the system calibrated.
Industries that record daily flow from a City of Greensboro owned, maintained, and
calibrated incoming potable water meter or deduct meter are not required to have the
meters calibrated.
Industries with an electronic data base with power back do not need to maintain redundant
paper recorders.
September 1, 2018 Permit Renewal

CITY OF GREENSBORO SIU PERMIT SYNOPSIS pow)
1
Receiving POTW
City of Greensboro T. Z. Osborne POTW
2
POTW NPDES #
NCO047384
3
Facility Name:
Shamrock Environmental II- 519 Patton Ave.
4
SIU Permit Number & Pipe #
P068 Pipe 01
5
Permit Effective Date
September 1, 2018
6
Permit Expiration Date
August 31, 2023
(7)
Subject to Federal Categorical
Pretreatment Standards?
40 CFR 442.15 — Subpart A [Pollutant
Management Plan in lieu of limits
8
Was CWF used?
No [If yes, attach calculations
Rationale for SIU Permit Limits/Allocations
PARAMETER
PERMIT LIMITS
Daily Monthly 6-Month
Maximum Average Average
LOCAL POLLUTANT
ALLOCATION
6-Mo Avg %MAHL
RATIONALE
FOR LIMIT/
ALLOCATION
Flow(gal/day)
35,000
7
H units [ran e]
5.0-12.0
7
BOD
3500 m /I
<5
4
Suspended Solids
1500 m /I
<5
4
Cadmium total
0.03 m /I
<5
4
Chromium total
0.50 m /I
<5
4
Copper* total
2.50 m /I
<5
7 c
Non -polar material
SGT-HEM
26.0 mg/I
N/A
7(c)
Mercury* total
0.001 m /I
<5
7 c
Lead total
0.40 m /I
<5
4
Nickel total
1.0 m /I
<5
4
Zinc total
12.5 m /I
<5
4
Silver total
0.08 m /I
<5
4
Cyanide total
0.02 m /I
<5
4
CODE RATIONALE
1
LIMIT based on Federal Categorical Standard
2
Local LIMIT that is more stringent than Federal Categorical Standards -Established to
prevent over -allocation value based on actual industry data]
3
Local LIMIT due to Loading of >9% MAHL — Limit: BPJ by POTW
4
Loca/PallutantA/location—Loadin <9% MAHL —Allocation: BPJ by POTW
5
Loca/Po//utantA//ocation [allocated at EPA/POTW published domestic values]*
6
No Limit or Allocation Established - <5% MAHL and not considered significant*
7
Other — (a) pH limit from 40 CFR Part 403.5(b)(2) and upper pH local limit of 12.0
(b) Flow limit based on historical data
c Other- Values from 40 CFR Part 442 implemented as an allocation
*No POTW over -allocation of the pollutant and the loading of the pollutant from the IU is considered insignificant at this time.
This synopsis includes an SIU inspection Report and permit application/survey.

PERMIT WRITERS NOTES:
1. The solidification processes were moved from this facility to the Shamrock Brown
Summit facility in 2017.
2. This facility has an effluent meter used for billing and compliance.
3. As per allowed in 40 CFR Part 442, this facility chose to develop a Pollutant Management
Plan (PMP) in lieu of accepting the 3 categorical discharge limits (mercury, copper and
Oil and Grease/SGT-HEM) in the regulation. Greensboro has issued a Local Pollutant
Allocation at the same concentration for all 3 parameters. [NOTE: The other
Greensboro SIU that is subject to 40 CFR Part 442 chose to accept the limits.]
4. Conversations with EPA headquarters confirmed that an SIU that chooses the PMP
option does not have to comply with the limits in the regulation. However, if the
concentrations of the 3 parameters are excessive, the SIU can be cited for ineffective
implementation of their PMP.