NC0004375_Regional Office Historical File Pre 2018 (4)

A74LA..
NCDENR
NorthCarolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman -
Governor Director Secretary
October 21, 2009 �
r. Ken Golder
Clariant Corporation
PO Box 18278
Charlotte, NC 28218
Subject: Renewal Note
NPDES Permit NCO004375
Mount Dolly East (1\4I1E) Facility
Mecklenburg County
Dear Permittee:
Your NPDES permit expires on June 30, 2010. Federal (40 CFR 122.41) and North Carolina (15A
NCAC 211.010 (e)) regulations state that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit.. If you have already mailed your renewal application, you may
disregard this notice.
Your renewal package must be sent to the Division postmarked no later than January 1, 2010.
Failure to request renewal by this date may result in a civil penalty assessment. larger penalties may be
assessed depending upon the delinquency of the request.
f any wastewater discharge will occur after Jane 30, 2010, the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-21.1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $2 ,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
e at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items ;you
must submit with the permit renewal application. if you have any questions, please contact me' at the
telephone number or e-mail address listed below.
Sincerely,
�7
Charles H. Weaver, Jr.
NPDES Unit
cc Central File
liES FZIe r ,:��e;
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 tine
512 North Salisbury Street,N
Raleigh, North Carolina 27604 oft ohn
Phone: [phone] FAX [phone] charies,[e-mail] vVaturally
An Equal Opportunity/Affirmative Action Employer;- 50% Recycled110% Post Consumer Paper

NPDES PERMIT 'CSC 004375
MOUNT HOLLY EAST (MHE) FACILITY
MECKLENBURG COUNTY
The following items are REQUIRED for all renewal packages:
A cover letter requesting renewal of the permit and ocum tinting; any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
The completed application form (copy attached), signed by the perinittee or an Authorized
Representative. Submit one signed original and two copies.
If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part II.B. 1 Lb of the existing NPDES perinit).
A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The followin,L, items most be submitted by any Municipal or Industrial facilities diaghAMiag
nrocess wastewater:
industrial facilities classified as Primary Industries {sec Appendices A.-D to Tide 40 of the Code of Federal
4Lt- "') all" "'u"I" ""' '' � F"t" " :-- J-U IVX%-Jl/ X114&OL 0""Xl"L a
Priority PollutantAnalysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non -process wastewater (coofing
water, filter backwash., etc.)
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

Nj A % Michael l . Easley, Gave t
William U. Ross Jr., Secretary
7 North Carolina Department of Environment and "1<atural Resources
C oleen Sullins, Director
Division of rater Quality
Mr. Ken Golder, President
Clariant Corporation
PO Box 18278
Charlotte, NC 28218
Subject. Compliance Evaluation Inspection
Mount Holly East facility
NPDES Permit No. NCO004 7
Mecklenburg; County, North Carolina
Lear Mr. Golder:
Enclosed please finda copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on June 4, 2008 by Ms. Donna flood and Ms. Marcia Allocco of this
Office. Please inform the facility's Operator -in -Responsible Charge: of our findings by forwarding a
copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms Hood or me at (7 4) 63-16
Sincerely, i
Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Enclosure
cc: Mecklenburg County llealth Department
Rusty Rozzelle, MC WQP
DlJ
N. C. Division of Water Quality, vlooresville Regional office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

United States Environmental Protection Agency Form Approved,
EPA Washington, D,C, 20460 OMB No. 2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i,e, PCS)
Transaction Code PDES yr/mo/day Inspection Type Inspector Fac Type
I LN1 2 1 1 L 1 -1 31 NC 0004375 Ill 121 08/06/04 117 18U 19L 20u 91
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 J_LU66
Inspection Work Days Facility Self -Monitoring Evaluation Rating el QA ---------------------------Reserved---_---- .____--- ___
671 3,0 j 69 70141 71U 72LNI 7374 751 111 111180
Section B. Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Mount Holly East (MHE) Facility 10:45 Am 08/06/04 05/07/01
PO Box 669246 Exit Time/Date Permit Expiration Date
Charlotte NC 28266 02:45 PM 08/06/04 10/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Dwayne R Wallacey'ORC/704-822-2768/
Frank Rash//704-822-2768 /
Name, Address of Responsible Official[Title/Phone and Fax Number
Nick Altman,PO Box 669246 Charlotte NC 28266//704-822-2743/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summa[y of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and gnature(s) of Inspector(s) ¢ Agency/Office/Phone and Fax Numbers Date
Donr d MR0 WQ//704-663-1699 Ext.2193/
A
L)
Signature Y a anagement Q A Reviewer Agency/Office/Phone and Fax Numbers D 0 M ia Allocco MRO WQ//704-663-1699 Ext,2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit. NCO004375 Owner - Facility: Mount Holly East (MHE)
Facility
Inspection Date: 06/04/2008 Inspection Type, Compliance Evaluation-
Permit
Yes No
NA
NE
(if the present permit expires in 6 months or less). Has the permittee submitted a new application"?
00U0
Is the facility as described in the permit?
is ono
o
Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
0
Is the inspector granted access to all areas for inspection?
D
13
0
Comment:
CPeratit►ri Maeiltenane
Yes No
NA
NE
Is the plant generally clean with acceptable housekeeping?
a 0
00
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH„ DO, Sludge 11 0
00
Judge, and other that are applicable?
Comment: The facility appeared to he well maintained at the time of the inspection.
Record Kee itt
Yes o
NA
NE
Are records kept and maintained as required by the permit?
w0
D
0
Is all required information readily available, Complete and current?
Are all records maintained for 3 years (lab, reg, required 5 years)?
Are analytical results Consistent with data reported can DMRs?
Is the chain -of -custody complete?
in 0
0
0
Dates, times and location of sampling
is
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
11 0
0
0
Has the facility submitted its annual Compliance report to users and DWQ?
(if the facility is - or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
0 0
ra
i t
Is the ORC visitation log available and current?
11 0
0
Is the ORC certified at grade equal to or higher than the facility classification?
l
Is the backup operator certified at one grade less or greater than the facility classification?
a 0
0
Is a copy of the current NPDS permit available on site?
a 0
0
Page f# 3

Permit: NCO004375 Owner - Facility: Mount Holly East (MHE)
Facility
Inspection Date: 06/0412008 Inspection Type: Compliance Evaluation
Record g Keqf *
�p I n_
Yes
No
NA
NE
Facility has copy of previous year's Annual Report on file for review?
no
o
in
o
Comment, DMRs for January 2007-December 2007 were reviewed for the inspection.
No conductivity was performed on the effluent on 8,18.2007 due to operator error. No
other violations were reported for the review period.
Labqrato
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
in
o
n-
o
Are all other parameters(excluding field parameters) performed by a certified tab?
0
0
0
# Is the facility using a contract tab?
0
0
0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
0
0
0
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0,2 degrees?
o
o
n-
Incubator (130D) set to 20,0 degrees Celsius +/- I . 0 degrees?
0
0
0
Comment: The facility performs on site analyses under laboratory certification #217.
Both Pace Analytical (#12) and Mt, Holly (#215) Labs are used to perform analyses on
the effluent. Expired lab reagents were present at the time of the inspection. Please
remove all expired reagents.
Aerobic lei ester
Yes
No
NA
WE
Is the capacity adequate?
in
C-)
00
Is the mixing adequate?
NO
00
Is the site free of excessive foaming in the tank?
a
0
0
0
# Is the odor acceptable?
0
0
0
# Is tankage available for property waste sludge?
0
0
0
Comment: Slugdge is disposed of in the permitted on site monofill in cell #3.
Standby Power
.__j_
Yes
No
_NA
NE
Is automatically activated standby power available?
0
00
0
Is the generator tested by interrupting primary power source?
is
0
0
0
Is the generator tested under load?
is
D
0
C3
Was generator tested & operational during the inspection?
0
D
0
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
D
0
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
is
0
0
0
Is the generator fuel level monitored?
in
0
0
0
Comments Standby power operates the tab only.
Solids Ha ment
_qq!p
Yes -No-
NA
NE
Page # 4

} Permit: NCU004375 Owner - Facility: Mount Holly East (MHE) Facility
Inspection Date: 06/04/2003 Inspection Type: Compliance Evaluation
Solids Handiin ui rIt I1t
Yes o NA
E
Is the equipment operational
O
O
Is the chemical feed equipment operational?
n it
0
Is storage adequate?
0
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
0 N 0
0
Is the site free of sludge buildup on belts and/or rollers of filter press?
N 0 D
0
Is the site free of excessive moisture in belt filter press sludge cake?
0 is 0
11
The facility has an approved sludge management plan?
in 0 0
0
Comment;: Both belt presses were, operational can the day of the inspection. At the
time of the inspection one belt press was net removing adequate amounts of water from
the sludge, thereby producing substandard sludge cake.
Prima iarifier
Yes No NA
NE
Is the clarifier free of black and odorous wastewater?
D 0
l
Is the site free of excessive buildup of solids in center well of circular clarifier?
0 0
Are weirs level?
0
n_
Is the site free of weir blockage?
W 0
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
0 11 0
("i
Is the site free of excessive floating sludge?
a 0 0
0
Is the drive unit operational?
Is the sludge blanket level acceptable?
0 0
Is the sludge blanket level acceptable? {Approximately % of the sidewall depth}
0 0
0
Comment:
Aeration Basins
Yes No NA
PIE
Mode of operation
Ext. Air
Type of aeration system
,let
Is the basin free of dead spots?
in 0 D
Are surface aerators and mixers operational?
in 0 00
Are the diffusers operational?
Is the foam the proper color for the treatment process?
a 0 00
Does the foam cover less than 25% of the basin's surface?
Page;#

Permit: NCO004375 Owner - Facility: Mount Holly East (MHE)
Facility
Inspection Date: 06/04/2008 Inspection Type: Compliance Evaluation
Aeration Basins
Yes No
NA
NE
Is the DO level acceptable?
D 0
0
Is the DO level acceptable?(1.0 to 3.0 mg/1)
000a
Comment;
Sec9nqary_Clar!fier
Yes- No
NANE
Is the clarifier free of black and odorous wastewater?
WOO
0
Is the site free of excessive buildup of solids in center well of circular clarifier?
■ 0
0
0
Are weirs level?
0
0
0
Is the site free of weir blockage?
n-
o
o
Is the site free of evidence of short-circuiting?
■0
0
0
Is scum removal adequate?
W 0
0
0
Is the site free of excessive floating sludge?
IN 0
0
0
Is the drive unit operational?
■ 0
0
0
Is the return rate acceptable (low turbulence)?
0
0
0
Is the overflow clear of excessive solids/pin floc?
■ 0
0
0
Is the sludge blanket level acceptable? (Approximately Y4of the sidewall depth)
0 0
0
Comment:
Chemical Feed
Yes No
NA
NE
Is containment adequate?
a 0
13
0
Is storage adequate?
a 0
00
Are backup pumps available?
0
D
0
Is the site free of excessive leaking?
0
00
Comment: Lime slurry is added to enhance the treatment process. Housekeeping
around the lime slurry area needs to be improved,
gqyalizqtioij asins
Yes No
NA
NE
Is the basin aerated?
0 0
NO
Is the basin free of bypass lines or structures to the natural environment?
a 0
0
0
Is the basin free of excessive grease?
0 0
0
Are all pumps present?
n_ 0
■
0
Are all pumps operable?
0 0
■0
Are float controls operable?
0 0
0
0
Page # 6

Permit: NCO004375 Owner - Facility. Mount Holly East (MHE)
Facility
Inspection Date: 06/04/2008 Inspection Type. Compliance Evaluation
Equalization Basins
Yes
No NA�NE
Are audible and visual alarms operable?
0000
# Is basin size/volume adequate?
O
O
Comment;
Flow Measurement - Effluent
Yes
No NA
NE
Is flow meter used for reporting?
a
0 00
Is flow meter calibrated annually?
0 0
Is the flow meter operational?
0 0
0
(If units are separated) Does the chart recorder match the flow meter?
Q
0 ■
o rnent The flaw meter was last calibrated on 4.20.2008.
Effluent Pie
Yes
No NA
NE
Is right of way to the outfall properly maintained?
■
O 0
0
Are the receiving water free of foam other than trace amounts and other debris?
ISO
0
0
If effluent (diffuser pipes are required) are they operating properly?
0
Comment.
Effluent SAT_p jiriq
Yes
No NA
NE
Is composite sampling flow proportional?
in
0 ! l
0
Is sample collected below all treatment units?
Is proper volume collected
i �1
Is the tubing clean?
in
0 0
Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
a
0 0
0
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
in
0 0
0
Comment.
lipstream I Downstream am ling
Yes
No NA
PILE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? 0
0
Commend
Page #

Aft
sr, UNITED STATESENVIRONMENTAL PROTECTION
REGION 4
a ATL.ANTA FEDERAL CENTER
61 FOR YTH STREET
ATL NTA, GEORGIA 3030 -6 60
MAR
Matt Matthews
Point Source Branch
Surface "dater Protection Section
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 2799-1 17
RE: PAI Inspection Report
Clariant Corporation -- Mt. Holly :East Facility V WTP
NPDES Permit No. NCO004375
Dear Mr. ;Matthews:
Enclosed is a copy of the report for the January 29- 0,'2007 performance audit inspection
that was conducted at the Clariant Corporation -- Mt. Holly East Facility Wastewater Treatment
Plant in Charlotte, North Carolina,
If you have any questions, please feel free to contact me at (404) 5 -9460.
Sincerely,
David Parker, Chief
Eastern Enforcement Section
Water Programs Enforcement Branch
Water Management Division
Enclosure
Internet Address (URL) http,://www,epa,gov
Aocyct dlrtecyci ble < Printed with Vegetable tail Based Inks on Recycled Paper (Minimum 30% Postconsumer)

united States Environmental Protection Agency
Science and Ecosystem Support Division
Region
Tq r
c
0
PRO~
Final Report
Performance audit Inspection
lariant Corporation - Mt. Holly East Facility
Charlotte, North Carolina
Requestor; 'Water Management Division SESD Project Leader: Liza M ntalvo
US EPA Region 4 980 College Station Rd.
1 Forsyth St. Athens, Georgia 30605
.Atlanta, GA 30303 SESD Project # 07-0233
Page 1 of 1

Performance Audit Inspection
Clariant Corporation - It Holly East Facility
Charlotte, North Carolina
NPDES Permit NCO004375
Introduction
The following personnel participated in the inspection:
Name
Organization
Phone Number
Liza Montalvo
EPA
[phone]
Ron Phelps
EPA
[phone]
Marcia Allocco
NCDENR
[phone]
Chet Whiting
NCDENR
[phone]
Gary Francis
NCDENR
[phone]
Frank Rash
Clariant Corp.
[phone]
Dwayne Wallace
Clariant Corp.
[phone]
William M. Archer
Clariant Corp.
[phone]
Samuel FEll, Jr.
Clariant Corp.
[phone]
SumMaEl
nitoring reports.
Page 2 of 10

FIELD EVALUATION
1. Facility Site Review
The Clariant Corporation Mt. Holly East Facility consists of a 3.9 mgd (permitted) activated
;Mudge wastewater treatment process. Clariant Corporation n discontinued its chemical
manufacturing operation at the Mt. Holly East Facility. The facility continues to treat on -site
groundwater, storm water, and leachate from its active on -site landfill cells. Other sources
include industrial wastewater from outside customers. Truckloads of wastewater are
discharged into one of two sumps at the facility. The wastewater treatment process consists
of one storm water equalization basin for non -alkaline wastewater, one equalization basin for
alkaline wastewater, two primary clarifiers, two aeration basins operated in series, two
secondary clarifiers, and two polishing ponds. Treated wastewater is discharged into the
Catawba River via c utfall 001. Sludge from the primary and secondary clarifiers is stabilized
and thickened in two sludge holding tanks and dewatered in a belt press. dewatered sludge
is disposed of at the permitted on -site landfill.
All treatment units appeared to be working; properly.
Rating: Satisfactory.
2. Permit
The NPDES permit became effective on July 1, 2005 and will expire on June 30, 2010. The
inspection observations verified the permit information regarding time name and description
f the facility, the location of the permitted outfall, and the name and location of the
receiving waters.
Rating. Satisfactory.
3, Records and Re o f
The facility's records consisted of discharge monitoring reports (D s), daily logs,
calibration records, laboratory bench sheets, laboratory reports, and chain of custody
records. Records and reports for July 2006 were checked for agreement with NPDES
self -monitoring requirements regarding spling documentation, equipment calibration,
and reporting of parameter concentrations and loadings. Records were maintained for
minimum of five years. The following deficiencies were noted;
• Corrections to records were written over.
Recommendation: Corrections to records should be remade using a single line
out, the correction,; and the date and signature or initials of the analyst making the
corrections:
Page 3 of 10

Dissolved Oxygen (DO), pH, and temperature were collected once during i
dayshift and once during the nightshift which is more frequently than requi
the permit. However, only the nightshift data was reported on the DMR.
I -
Permit NCO004375, Part 11, Section E, 5b).
4tisfactory.
ient
P
tecommendation:
tion check conducted by the operator exceeded the accepted range of
)rrective actions be properly documented.
g: Satisfactory.
ling
The facility performed the analysis for BODS, TSS, COD, inorganic phenols, ammonia
nitrogen, conductivity, DO, pH, and temperature. Fecal coliform bacteria samples were
analyzed by the City of Mount Holly WWTP. All other parameters were analyzed by PAC
Analytical Services in Asheville, NC.
Page 4 of 10

The overall sampling procedures were consistent with NPDES requirements regarding
sampling locations, sample documentation, containers, and holding times. However, the
following deficiencies were noted:
• An aliquot check conducted indicated that the sampler was collecting a volume of
approximately 40 TnI.
Regulaj2ar R ui a ent: NPDES Permit NCO004375 defines a composite sample
as a sample collected over a 24-hour period by continuous sampling or combining
grab samples of at least 100 ml in such a manner as to result in a total sample
representative of the wastewater discharge during the sample period.
• The effluent sampler intake line was coated on the inside with a black residue.
Recommendation: The sample tubing should be changed or cleaned on a r gul r
basis.
Rating. Marginal.
6. Effluent/ReceivingStrearns
The final effluent was of alight brown color. There were no floating solids nor any visible
foam observed.
Rating: Satisfactory.
Page 5 of 10

Basec
were
defici
The d
paran
0
'Iel
LABORATORY EVALUATION
rogen, Total Phosphorus, Total Mercu
SUMMARY
Dings, the laboratory data was rated as Satisfactory. Minor deficiencie!
d TSS. Deficiencies were also noted for BOD5 and FC. Once the
,ted for BOD5 and FC, the data for these parameters should be satisfactl
onductivity and DO adversely impacted data reliability for these
Clariant laboratory was provided by:
alytical Chemist
City of Mount Holly Laboratory was provided by:
,story Supervisor
(NPDES) analyses,
2. Facilities and EQuipment
The Clariant laboratory facility was adequate. Sufficient analytical equipment and bench
space were available for processing samples. Most of the laboratory equipment appeared I
be in adequate working condition except for the conductivity meter. The Hanna HI 8633
meter could not be properly calibrated, and it is reconunended that this meter be repaired c
replaced.
Page 6 of 10

. Sample Handling and Preservation
The WWTP laboratory followed the NPDES requirements for sample containers and holding
times. '
4. Nlethodolo
Table L-1 reflects the tests required by-Clariant's NTDES'pen-nit (NC ?004375), the status of
the laboratory methods used for the NPDES self -monitoring program and a data quality
assessment. The following observations were made during the evaluation:
a H''
• The off meter/electrode system was calibrated daily against three buffers (4, 7, and 10
.U.) No duality control checks were used to verify the instrument response.
Re ulatvry Requirement: At least one of the pH standards must be analyzed as a
sample after calibration. Immerse the electrode in the buffer and the result must
agree within ± 0.1 pH units of the true value. If the meter response shows a
difference greater than 0.1 pH units from the expected value, look for trouble with the
electrode or the potentiometer. The meter may have to be recalibrated. Refer to
Standard Methods' '4500- +E.4.a.
b. Conductivity
• Three calibration standards were available at the time of the inspection; 9.64, 101.1,
and 104,033 umho/cm. A review of the plant's records indicated that conductivity in
the plant effluent was -3000 urmo/c ` . The lab technician stated that the 104,033
umho/cm was delivered to the laboratory in error. The conductivity meter could not
be calibrated to the high standard. The records of daily calibration were not
adequately documented.
eLul torn R.ec mire ent: As stated earlier in the report, the Manna meter may
require repair or replacement to be calibrated correctly. The facility needs to
purchase calibration standards of the proper range that bracket the expected values in
their effluent: It is recommended that the meter be calibrated with the 1412 umho/crn
standard, and then checked against the 500 and 5000 a ho/cm standards. Refer to
Standard Methods' 2510.
TSS
• The laboratory balance displayed a sticker indicating that it was due for service in
April 2006. The lab analyst stated that the balance had been serviced but could not
locate the paperwork.
Page 7 of 10

BOD
I
Holly laboratory used de -ionized water from a squeeze bottle to ri
if the filter' assemblies.
ient: It is recomrnen�
Standard Methods' 9030B.
L DO
• The bench sheets used to document the field DO meter calibration indicated that
manufacturer's calibration procedures, Generally the calibration procedure uses a
saturated air environment. See Standard Methods' 4500-0 G.
Page 8 of 10

References
. Standard Methods for the Examination of Water and Wastewater, 1 `h Edition (1992).
. NPDES Perniit No.NCO00 37 .
Page 9 of 1

TABLE L-1
MFTWODq NTNT1 JS
{
PARAMETER
LABORATORY NCll D
40 CFR
I�r�TA
METHOD
APPROVED
L► FiCH;i+lCit '
Qt�Ai � `
PH
4500-H' B a
YES
M1NOR
S
DO
4500-0 G `
YES
MAJOR
U
Conductivity;
2510132
YES
MAJOR
U
BODr
5210B z
YES
MINOR
C
TSS
2540D x
YES
MINOR
S
PC
922,2D'
YES
MINOR
C
NH3-N
4500-NH, E
YES
NONE r
S
Temperature
55013 '
YES
NONE
S
Inorganic Phenols
510 A, C'
YES
NONE
Oil and Grease
1664 n,s
YES
NONE
S
COD
5220 D" 6
YES
NONE
C
Fe
200.7 4 j
YES
NONE
Cr
200,7 a.s
YES
NONE
S
Zn
200.7 a,s
YES
NONE
5
Mn
200,7 4.1
YES
NONE
S
Phosphorus
365.2 4,1
YES
NONE
S
F+ TEN
>5 `„' °
`Y':F"
l�'..,N"-
Total Nitrogen
353.2 41
YES
NONE
S
Hg
1631 E 0
YES
NONE
S
MBAS
5540c'''
YES
NONE
S
Sulfates
375.4 `
YES
NONE
S
Chlorides
325,3 a.s
YES
NONE
S
Marginal I1 = Unsatisfactory
2. Standard Methods for the Examination of Water and Wastewater, 1 `s Edition (1992),
3. Standard Methods _for the Examination of Water and Waste yatq, 14th Edition (1975).
4. Analyzed by the contract laboratory, PACE Analytical Services, Inc. in Asheville, NC. Contract data was given a cursory review to assess if a
methodologies were used to generate the data.
5. Methods for Chemical Analysis of Wat r and W istes> EPA-600l4.79-020, and all current revisions,
6. Due to problems with the spectrophotometer, the facility will be contracting out the COD analysis.
Page 10 of 10

C1tC32and Pollutant Scan
PNCO004iJAnnual
Month:PF-
:Nt.:
ItfjNovember$
O001
Year: 2007
Facility Name, Clariant Corporation
ORC: Dwayne Wallace
Date of sampling: 11/07/2007
Phone:
704.822,2768
alytical Laboratory: Pace Analytical Services, Inc.
,'I MR
Ammonia (as N)
Composite
350,1
0.1
2.5
mg/1
Dissolved oxygen
Composite
SM 450 J-0 G
0.1
3.6
g/1
Nitrate/Nitrite
Composite
353.2
3
110
mg/1
Total Kleldahl nitrogen
Composite
351.2
3 5
49.8
mg/1
Total Phosphorus
Composite
365.1
0.5
6.5
mg/1
Total dissolved solids
Composite
SM 2540C
10
3090
g/1
Hardness
Composite
SM 2340D
O,65
757
g/1
Chlorine (total residual, TRC)
Grab
Orion Kle
Oil.
<0.1
g/1
Oil and grease
Crab
1664A
5
8.9
mg/l
:10
6 "y3
Antimony
Composite
2 00 .7
0.005
0.115
mg/l
Arsenic
Composite
200.7
0.005
0.0928
mg/l
Barium
Composite
200.7
0«005
0.0097
g/l
Beryllium
Composite
2003
0.001
<0..001
g/l
Cadmium
Composite
200.7
0.001
<0.001
zMg/l
Chromium
Composite
200.7
0.005
<0 ©©5
g/1
Cobalt
Composite
200.7
0.005
0.0152
g/l
Copper
Composite
200.7
0.005
0.0651
g/l
Cyanide
Grab
SM 4500-CN-E
0.005
0.014
g/l
Lead
Composite
200.7
0.005
<0.005
ixag/l
Mercury
Composite
4.1
0.0002
©«ClQQ31
mg/1
Molybdenum
Composite
200.7
0.005
0.56
amg/l
Nickel
Composite
00.7
0.005
4..17
mg/1
Phenol
Grab
420.4
0.001
ci.Q27
mg/l
Selenium
Composite
200.7
0.01
0.0142
mg/1
Silver
Composite
200.7
0.005
Cl.00
mg/1
Thallium
Composite
200.7
0.01
<0.01
g/l
Tina
Composite
200.7
0.005
<0.005
g/l
Titanium
Composite
200.7
0.005
<0.005
mg/1
Vanadium
Composite
200 7
0.005
0.168
mg/1
Zinc
Composite
2007
0.01
Q.C15t18
ring/l
y 4 y I I.
. , „,,.,„ts.,,. ..... ......, ,. .,...,.. c .. u.' 1as lI
y
Acetone
Grab
624
25
<25
ug/1
Acrolein
Crab
624
100
<100
ug/l
Acrylonitrile
Crab
624
100
<100
ug/
Benzene
Crab
624
5
<5
/l
romoform
Crab
624
5
<5
ug/l
-But none
Grab
624
5
<5
ug/1
Carbon tetrachloride
Grab
624
5
<5
ug/1
hlorobenzene
Crab
624
5
<5
ug/l
Chlorodibromomethane
Grab
624
5
Form - DMR- PPA-1 Page 1 of 4

ppl-
Annual Monitoring and Pilo Scan rermit o.: Nt�00075 Month: November
tall: 001 Year: 2007
g }
Chloroethane
Grab
624
10
<10
ug/I
2-chloroethylvinyl ether
Grab
624
10
<10
ug/I
Chloroform
Grab
624
<5
ug/I
Dichlorobrom ameth e
Grab
624
5
<5
ug/I
71-dichloroethane
Grab
624
5
<5
Ug/I
1,2-dichloroethane
Grab
624
5
<5
g/I
Trans-1,2-dichloroethylene
Grab
624
5
<5
ug/1 ,
1, 1 -dichloroethylene
Grab
624
5
<5
ug/I
1,2-dichloropropane
Grab
624
5
<5
g/I
1,-dichloropropylene
Grab
624
5
<5
Ug/I
;thylbenzene
Grab
624
5
<5
ttg/1
Methyl bromide
Grab
624
1?
<5
tg/I
Methyl chloride
Grab
624
5
<5
ttg/I
Methylene chloride
Grab
624
5
<S
bg/I
1,1,2,-tetrach oroethane
Grab
624
5
<6
ug/I
Tetrachloroethylene
Grab
624
5
<5
Ug/I
Toluene
Grab
624
5
<5
Ug/I
1, 1, 1 -trichloroethane
Grab
624
5
<5
g/I
1,1,2-trichloroethane
Grab
624
5
<5
ug/I
'T`richloroethylene
Grab
624
5
<5
Ug/1
Vinyl chloride
Grab
624
5
<5
Ug/l
`.wNO qY.^.
MR
P-chloro-m creso
Grab
8270
20
<20
ug/I
2-chlorophenol
Grata
8270
10
<10
ug/I
2,4-dichlorophenol
Grab
8270
10
<10
ug/I
2,4-dimethylphenol
Grab
8270
10
<10
ug/1
4,6-dinitro-o-cresol
Grab
8270
20
<20
ug/I
2,4-dinitrophenol
Grab
8270
50
<50
ug/I
2-nitrophenol
Grab
8270
10
<10
ug/I
4-nitrophenol'
Grab
8270
50
<50
ug/l
Pentachlorophenol
Grab
8270
50
<50
ug/I
Phenol'
Grab
8270
10
<10
g/I
2,4,6-trichlorophenol
Grab
8270
10
<10
g/I
Acenaphthene
Grab
8270
10
<10
ug/I
Acenaphthylene
Grab
8270
10
<10
ug/I
Acetophenone
Grab
8270
10
<10
ug/l
Aniline
Grab
8270
10
<10
ug/I
Anthracene
Grab
8270
10
<10
ug/I
Benzidine
Grab
8270
50
<50
ug/I
Benzo(a)anthracene
Grab
8270
10
<10
ug/I
Peno(a)pyrene
Grab
8270
10
<10
ug/I
3,4 benzopuoranthene
Grab
8270
10 1
<10
ug/I
Be zo(ght)perylene
Grata
8270
10 F
<1®
tT.g/I
Form - DMR- PA-1 Page 2 of

Annual Monitoring ing and Pollutant Scan
NCC 0043 7 Month: November
er
01 Year: 2007
I*
•
q
� ru
L
�
.*u
Ulm
IM
Hai
HIM
y
For - L MR- PPA-1 _ Page 3 of

Annual Monitoring and Pollutant Scan Permit o.: NtJO4S75 Month: November
Outfall: 00 i Year: 2007
I certify under penalty of law that this document and all attachments were prepared under my direction
and supervision in accordance with a system to design to assure that qualified perdonnel properly
gather and evaluat the information submitted. used on my inquiry of the person or persons that
manage the'system, or those personas directly responsibel 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 fines and imprisonment for knowing violations.
Authorized Representative name
Signature
Date
Farm - DMR- PPA-1 ` Page 4 of

Annual Monitoring and Pollutant Sean
t No., NCO004 75
Month. November
ll: 001
PFarcility
Year: 2007
: Clari t Corporation
CRC: Dwayne Wallace
Late of sampling: 11/07/2 7
Phone:
704.822,2753
alytical Laboratory Pace Analytical Services, Inc.
Ammonia (as N)
Composite
350.1
0.1
2.5
g/l
issolved oxygen
Composite
SM 4500-0 G
0A
3.6
fl
Nitrate/Nitrite
Composite
3.2
3
110
m/l
Total Kjeldahl nitrogen
Composite
351.2
3,5
49.8
m /l
Total Phosphorus
Composite
365.1
0.5
6.5
m /l
Total dissolved solids
Composite
SM 2540C
10
3 990
mg/1
Hardness
Composite
SM 3340B
0.65
757
m /l
Chlorine (total residual, TRC)
Grab
Orion Ele
1
_<0.1
mg/1
Oil and grease
Grab
1Ca i4A5
8.9
mg/1
n
5
)
ui
n
U e �
Antimony
Composite
200.7
0.0 05
0.115
t .
m/I
g/l
Arsenic
Composite
200.7
0.005
0.0928
g/1
Barium
Composite
2003
0.005
0.0097
g/1
Beryllium
Composite
200.7
0.001
<0.001
/l
Cadixiu
Corposite
200.7
0.0010001
mg/1
Chromium
Composite
200.7
0.005
0.005
g/1
Cobalt
Composite
200.7
0.005
0.0152
rmg/1
Copper
Composite
200.7
0.005
0.0651
g/1
Cyanide
Grab
SM 45O - N-
0.005
0.014
mg/1
Lead
Composite
200.7
0,005
<0.005
g/1
Mercury
Composite
245.1
0.0002
0.0 0031
g/l
Molybdenum
Composite
200.7
0.005
0.56
g/1
Nickel
Composite
200.7
0055
0.117
g/1
Phenol
Grab
420.4
0.001
0.027
g/1
Selenium
Composite
200.7
0.01
0.0142
g/1
Silver
Composite
200.7
0.O05
<0 005
g/l
Thallium
Composite
200.7
0.01
0.01
mg/1
Tin
Composite
2003
0.005
<0.005
g/1
Titanium
Composite
2003
0.005
<0.005
mg/l
Vanadium
Composite
200.7
0.005
0.168
mg/1
Zinc
Composite
200.7
0,01
p,
$iu 500
g/
? (..... ,. , .,:.,, ,.: , w, .,,. `�'3�,^Y;. 3'�"'� � •,"fin? '�i�� ���� $�'s"� � ��
tiss
j &c t i '9 .. �v t; 7r:1.r.� ., ., ,..�, � ,a { :.
Acetone
Grab
624
25
¢ \ au4
<25
v
ug/l
Aerolein
Grab
624
100
< 00
ug/l
crylonitrile
Grata
224
000
<100
ug/1
Benzene
Grab
624
5
<5
ug/1
Brornoform
Grab
224
5
<5
ug/1
-But one
Grab
624
5
<5
ug/1
Carbon tetrachloride
Grab
524
55
ug/1
hlorobe e e
Grab
224
5
g/1
Chlorodibromometh e
Grab
624
Form - DM - PPA-1
Wage 1 of

Annual Monitoring Pouat Scan
t No0: NCO004375
Month: November
utfall 001
Year: 2007
y,
Chloroeth e
Grab
624
10
<10
ug/1
2-c:hloroethylvinyl ether
Grab
624
10
<10
ug/1
Chloroform
Grab
624
5
<5
ug/l
Dichlorobromomethane
Grab
624
5
<5
ug/1
1,1-dchloroeth e
Grab
624
5
5
ug/1
1,-dichloroeth e
Grab
624
5
<5
/1
Trans-1,2-dichloroethylene
Grab
624
5
<5
ug/1
1,1-dichloroethylene
Grab
64
5
<5
g/
1,2-dichloroprop e
Grab
224
5
<5
ug/1
1,-dichloropropylene
Grab
624
5
<5
ug/l
Ethylbenze e
Grab
624
5
<5
ug/1
Methyl bromide
Grab
624
10
<5
ug/1
Methyl chloride
Grab
224
5
<5
ug/1
Methylene chloride
Grab
624
5
<5
ug/1
1,1,2,2-tetrachloroethane
Grab
624
5
<5
ug/1
Tetrachl roethylene
Grab
624
5
<5
g/1
Toluene
Grab
64
5
`*5
ttg/1
1, 1, 1 -trichloroethane
Grab
624
5
<5
g/1
1,1,2-trichloroeth e
Grab
224
<5
ug/l
Trichloroetthy ene
Grab
624
5
<5
ug/1
Vinyl chloride;
Grab
624
5
<5
ugJl
i t+
P-chloro-m-creso
Grab
8270
20
<20
S
des+
ug/l
2-chlorophenol
Grab
8270
10
<10
ug/1
2,4-dichlorophenol
Grab
8270
10
<10
g/1
,4-dimethylphenol
Grab
8270
10
<10
ug/1
4,6-dinitro-o-cresol
Grab
8270
20
<20
ug/1
2,4-dinitrophenol
Grab
8270
5
<50
ug/1
2-nitrophenol
Grab
8270
10
<10
ug/1
-nitrophenol
Grab
27C}
o
<50
u f 1
Pentachlorophenol
Grab
8270
50
<50
ug/l
Phenol
Grab
8270
10
<10
ug/1
2,4,6 trichlorophenol
Grab
8270
10
<10
ug/1
.�;
Acenaphthene
Grab
8270
10
<10
ug/l
Acenaphthylene
Grab
8270
10
<10
ug/1
Acetophenone
Grab
8270
10
<10
ug/1
Aniline
Grab
8270
10
<10
ug/1
thracene
Grab
8270
10
<10
ug/l
Benzidine
Grab
8270
50
<50
ug/1
8enzo(a)anthracene
Grab
82 0
10
<10
ug/1
Benzo(a)pyrene
Grab
8270
10
<10
ug/l
3,4 benzofluoranthene
Grab
8270
10
<10
ug/l
enzo(ghi)perylene
Grab
820
10
<10
ug/l
For - LAMP'- PPA-1
Page 2 of 4

No.: NC 004375
+:. ! s . i i " , I . * • I
Month. November
Year: 2007
, rtyl,l ki I��ES,�y�a 3Rys5%'; I�p,:ft°t
Benzc (k)fluoranthene
13is (2-chloroethoxy) methane
Bis (-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
-chloronaphthalene
4-chlorophenyl phenyl ether
1,,4,-trichlorobe ene
1,2-dichlorobenzene
1, 2-dphenylhydrazin
1,3-dichlorobenzene
1,4-dichlorobenzen
2,3-Dichloroaniline
2,4-dinitrotoluene
2,6-dinitrotoluene
3,3-dichlorobenzidine
Carbazale
Chrysene
Dibenzo(a,h)anthracene
Diethyl phthalate
Dimethyl phthalate
lz-n-butyl phthalate
Di- -octyl phthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
H exachlorocyelo-pentadiene
Hexacloroethan
Indeno(I,2,3-ed)pyrene
Isophorone
Naphthalene
n-lecane
Nitrobenzene
N-nitrosodimethyl ine
N-nitrosodi--propyl ine
ICI-nitrosodiphenyl ine
n-Octadecane
o-Cresol
p-Cresol
Phena �threne
Pyrene
Pyridine
Form - DMR_ F'PA_ 1
11, pl
! II M
a q
iIII. IA1 •
�i
I.
I" I
ie N141tl1 IIVI
I, Ip
III I�
Ui.. II`I
a #
#
#
s 4
li � II111 ICI
1F
1
#
I lul
p
Iwl I IIIII I
uw uJ alrl I�
a ;pi
o I�
a I
� Ild Ipulll �
1I
�
R�i■II
�
II I
#
1�1 IIIfi111
I
III
Page 3 of 4

and Pollutant Scan Month: November
•■NCO004375 Annual Monitoring
Year: 2007
I certify under penalty of law that this document and all attachments were ;prepare under my direction
d supervision in accordance with a system to design to assure that qualified perdonnel properly
gather and evaluat the information submitted. Based on my inquiry of the person or persons that
manage the system., or those persons directly reponsiel for gathering the information,' the
information submitted is, to the best of my knowledge and belief, true, accurate and complete. I a
aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations.
Authorized Representative name
Signature
Date
Form - L MR- PPA-1
Page 4 of 4

Vill l EL) TATCZA MPIVIKUNMtriT.AL rMV I ECG lVV4 AlAr %o T
REGION 4
a�Swv 0ATLANTA FEDERAL GETTER
cap 61 FOR YTH STREET
ATLANTA,, G ORGIA 30303-8960
WAR 1 3 Z007
. Matt Matthews
Point Source Branch
Surface Water Protection Section
Division of Water (duality
North Carolina Department of Environment
and Natural Resources
1617 Mal Service Center
Raleigh, NC 27699-117
RE: PAI Inspection Deport
Clariant Corporation -. Mt. Dolly East Facility WWTP
DES Permit No. NCO004375
Dear Mr.`Matthews:
Enclosed is a copy of the report for the January 2 - 0, 2007 perfonnance audit inspection
that was conducted at the Clariant Corporation — Mt. Holly East Facility Wastewater Treatment
Plant in Charlotte, North Carolina.
If you have any questions, please feel free to contact me at [phone]
Sincerely,
David Parker, Chief
Eastern Enforcement Section
Water Programs Enforcement Branch
Water Management Division
Enclosure
Internet Address (UR.);+ http://www,spa.gov
Recycled/Racyciabls Printed with Vegetable Oil used Inks on Recyded Paper (Minimum 30% Ptastconsumer)

United ,Mates Environmental Protection Agency
Science and Ecosystem ,Support Division
Region
ieD ro
da
PR
Final Report
Performance Audit Inspection
Clariant Corporation - Mt. Holly East Facility
Charlotte, North Carolina
R questor: Water Management Division S1ESD Project Leader: Liza Montalvo
US SPA Region 4 980 College Station Rd.
61 Forsyth St. Athens, Georgia 30665
Atlanta„ GA 30303 SESD Project # 07-0233
Page 1 of 10

PP, ppppp
FIELD EVALUATION
. Facility Site Review
The Cl ariant Corporation Mt. Holly East Facility consists of a 3.9 mgd (permitted) activated
sludge wastewater treatment process. Cl an ant Corporation discontinued its chemical
manufacturing operation at the Mt. Holly Fast Facility. The facility continues to treat on -site
groundwater, storm water, and leachate from its active on -site landfill ells. ether sources
include industrial wastewater from outside customers. Truckloads of wastewater are
discharged into one of two sumps at the facility. The wastewater treatment process consists
of one storm water equalization basin for non -alkaline wastewater, one equalization basin for
alkaline wastewater, two primary clarifiers, two aeration basins operated in series, two
secondary clarifiers, and two polishing ponds. Treated wastewater is discharged into the
Catawba River via outfall 001. Sludge from the primary and secondary clarifiers is stabilized
and thickened in two sludge holding tanks and dewatered in a belt press. l ewatered sludge
is disposed of at the permitted on -site landfill.
All treatment units appeared to be working properly.
Rating: Satisfactory*.
2* Permit
The NPDES pennit became effective on Julys 1, 2005 and will expire on June 30,2010. The
inspection observations verified the pen -nit information regarding the name and description
of the facility, the location of the permitted outfall, and the name and location of the
' receiving waters.
Rating. Satisfactory.
3. Records and Re arts
The facility's records consisted of discharge monitoring reports (DMRs), daily logs,
calibration records, laboratory bench sheets, laboratory reports, and chain of custody
records. Records and reports for July 2006 were checked for agreement with NPDES
self -monitoring requirements regarding sampling documentation, equipment calibration,,
and reporting of parameter concentrations and loadings. Records were maintained for a
minimum of five years. The following deficiencies were noted:
Corrections to rewords were written river.
Recommendation: Corrections to records should be made using a single line
out, the correction, and the date and signature or initials of the analyst making the
corrections,
Page 3 of 10;

The overall sampling procedures were consistent with NPDES requirements regarding
sampling locations, sample documentation, containers, and holding times. However, the
following deficiencies were noted:
• An aliquot check conducted indicated that the sampler was collecting a volume of
approximately 40 ml.
ReggIgLM,Requirement: NPDES Permit NCO004375 defines a composite sample
as a sample collected over a 4-hour period by continuous sampling or combining
grab samples of at least 100 ml in such a manner as to result in a total sample
representative of the wastewater discharge during the sample period.
• The effluent sampler intake line was coated on the inside with a black residue.
Recommendation: The sample tubing should be changed or cleaned on a regulq-r
basis.
Rating: Marginal.
S, Effluent/ReceivingEffluent/Receiving Streams
e final effluent was of a light brown color. There were no floating solids nor any visible
foam observed.
Rating: Satisfactory.
Page 5 of 10

LABORATORY EVALUATION
On January 2 -30, 2006a Performance Audit Inspection (PAI) was conducted at the Clariant
Corporation's Wastewater Treatment facility in Mt. Holly, North Carolina by EPA employees
Liza Montalvo and Ron Phelps. The self -monitoring analyses conducted on -site at the facility's
laboratory were pH, Dissolved Oxygen (DO), Biochemical Q) et, Demand (BODs), Chemical
Oxygen Demand (COD), Conductivity, Total Suspended Solids (TSS), Inorganic Phenols,
Ammonia Nitrogen ( 3-N) and Temperature. The analysis for Fecal Coliform Bacteria (FC)
bacteria was conducted at the City of Mount Elolly's laboratory for Clariant Corp.
EPA -approved test procedures were referenced for all analyses.
The analyses for Oil and Grease, Total Nitrogen, Total Phosphorus, Total Mercury,, Methylene
Blue Active Substances ( A), Total Iron., Sulfates, Chlorides, Total Manganese, Total
Chromium, and Total Zinc were under contract with PACE Analytical Services in Asheville,
NC. The contract laboratory was not visited but a review of the laboratory record s.,indicated that
approved methods were being used for all contracted analyses.
SUMMARY
Based on the total findings, the laboratory data was rated as Satisfactory. Minor deficiencies
were noted for, PIS and TSS. Deficiencies were also noted for BOD5 and FC. Once the
deficiencies are corrected for BODs and FC, the data for these parameters should be satisfactory.
The deficiencies for conductivity and. DO adversely impacted data reliability for these
parameters,
1. Personnel
Information about the Clariant laboratory was provided y:
- Samuel hill, Jr., Analytical Chemist
Information about the City of Mount HollyLaboratory was provided by:
• Mike Moretz, Laboratory Supervisor
The analysts were trained to conduct the National Pollutant Discharge Eli ration System
( DES) analyses.
. Facilities and E ui ent
The Clariant laboratory facility was adequate: Sufficient analytical equipment and bench
space were available for processing samples. Most of the laboratory equipment appeared to
be in adequate working condition except for the conductivity meter. The Hanna M 8633
meter could not be properly calibrated, and it is recommended that this meter be repaired or
replaced.
:Page 6 of 10

3. Sarngle Handling and P eservation
The WWTP laboratory followed the NPDES requirements for sample containers and holding
times
4. Methodoloey`
Table'L-1 reflects the tests required. by Cl °ants NPDES permit (NCO0 437 , the status of
the laboratory methods used for the NPDES self -monitoring program and a data quality
assessment, The following observations were made during the evaluation:
a. pH
• The pH meter/electrode system was calibrated daily against three buffers (4, 7, and 10
S.U.) No quality control checks were used to verify the instrument response.
Regulatory Requirement: At least one of the pH standards trust be analyzed as a
sample after calibration. >Inthrerse the electrode in the buffer and the result must
agree within ± 0.1 pH units of the true value. If the meter response shows a
difference greater than 0. 1 pH units from the expected value, loop for trouble with the
electrode or the potentiometer. The meter may have to be recalibrated. Refer to
Standard Methods' 4500-H+ B . .a.
b. Conductivity
• Three calibration standards were available at the time of the inspection; 9,64,101.1,-
and 104,033 a o/c . A review of the plant's records indicated that conductivity in
the plant effluent was -3000 a o/cm. The lab technician stated that the 104,033
u o/cm was delivered to the laboratory in error. The conductivity meter could not
be calibrated to the high standard. The records of daily calibration were not
adequately documented.
Reaulatory ReQuire exits As stated earlier in the report, the Hanna meter may
require repair or replacement to be calibrated correctly, The facility needs to
purchase calibration standards of the proper range that bracket the expected values in
their effluent. It is recommended that the meter be calibrated with the 1412 a o/cm
standard, and then checked against the 500 and 5000 urnh /crn standards. Refer to
Standard Methods' 2510 .
c. TS
• The laboratory balance displayed a sticker indicating that it was due for service in
April 2006. The lab analyst stated that the balance had been serviced but could not
locate the paperwork.
Page 7 of 10

Regulatog Reguirement: The balance should be checked and serviced at least
annually.
d. BOD
A review of the bench sheets indicated that the laboratory was ctieckin g the pH of
samples but not adjusting the pH of samples to the required range of 6.5 to 7,5 s.u.
Reaulater y Reauirement: The BOD samples should be adjusted to the required
range with either sulfuric acid or sodium hydroxide. Refer to Standard Methods
5210B.
e. FC
• The Mt. Holly laboratory used de -ionized water from a squeeze bottle to rinse dov
the side of the filter assemblies.
Regglatory Requirement. After the appropriate volume of sample has been filtei
rinse the funnel with three 20- to 30-mL portions of sterile dilution water. The
dilution/rinse water is prepared by adding 1.25 mL of stock phosphate buffer solut
and 5 mL of magnesium chloride solution (81.4 g of MgC12.61120 or 38.0 g of
anhydrous MgC12/L distilled water) to I liter distilled water to provide the workint
solution. Mix well, sterilize in an autoclave and dispense, See Standard Methods)
9050 C. 1. a.
• The fecal coliform collection container was sterilized at 103 to 105 0 C in an over
overnight.
Reaulatory Reauirement. It is recommended that the sterilization of the collecti
Standard Methods' 9030B.
L DO
• The bench sheets used to document the field DO meter calibration indicated that the
meter was not consistently calibrated using the saturated environment method. The
bench sheets documented the pre -calibration saturation levels which indicated that
the readings dropped from 60 to 2 % during October to Novembe:r 2006. The
manufacturer's calibration procedures stated that the meter could be calibrated in air,
but didnot list any quality control criteria for the operator.
Regulate rv,Reguirement- The meter must be calibrated each day by following the
manufacturer's calibration procedures. Generally the calibration I>rocedure uses a
saturated air environment. See Standard Methods' 4500-0 G.
Page 8 of 10

References
1. Standard Methods for the E an- nation of dater and Wastewater, 1 th Edition `(1 .
. NPDES Permit No.NCO00437:
Page 9 of 10

TABLE L-I
METHODS STATUS
CLARIANT CORPORATION WWTP
PERMIT NO. NCO004375
1. S =Satisfactory C = Conditional (data is conditionally satisfactory once deficiencies are corrected)
M = Marginal U = Unsatisfactory
2. Standard Methods for the Examination of Water and Wastewater, 18" Edition (1992).
3, Standard Methods for the Examination of )YajttrAnd Wastewater, 14th Edition (1975).
4. Analyzed by the contract laboratory, PACE Analytical Services, Inc. in Asheville, NC. Contract data was given a cursory review to assess if approved
methodologies were used to generate the data,
5. Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020, and all current revisions.
6. Due to problems with the spectrophotometet, the facility will be contracting out the COD analysis.
Page 10 of 10

A Michael r Easley. Governor
0, William C Ross 1r., Secretary
North Carolina Department of Environment and Natural Resources
C3 Alan W Klimek, P E Director
Division or Witter Quality
I! •
21
1r, Sara Hill
C lariant Corp - Mount Molly Plant
P,O, Pox 669246
Charlotte, NC 6266- 246
SUBJECT., Wastewater/Groundwater Laboratory'Certification renewal
Dear Mr: Mill;
The [department of Environment and Natural Resources, In accordance with the provisions of NC G
143-215-3 (a) (10), 16 NCAC 2M C 800, is pleased to renew certification for your laboratory to perform
specified environmental analyses required by EMC monitoring and reporting regulations 16 NCAC 2.
.0500, 2M 0900 and 2L 0100, D200, ,0300, and 2N .0100 through .660C1,
Enclosed for your use is e certificate describing the requirements and limits of your certification Please
review this certificate to insure that your laboratory is certified for all parameters required to properly meet
your certification needs.
Please contact your assigned inspector, Chet Whiting, at 704-235-2201 if you have questions or need
additional information.
Sincerely,
Pat Donnelly
Branch Manager
Enclosure
cc: Chet Whiting
Mooresville Regional Office
rtiiO h arriiina
Laboratory Section 1623 Phil! Service Center Raleigh, NC 27699-1623 Pbane [phone] Customer Service
Internet: � iv4v,c e4a liit .crrl L ocnt on: 4405 Reedy Creek Rd Raleigh, NC 27607 tax [phone] 1-877-623-6748
An Equal opportunity/Affirmative Action Employer— 5604 Recycled110°ta Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
DVVISIO'N OF WATER QUALITY
LABORATORY CERTIFICATION PROGRAM
In accordance with the provisions ofMaG- . 143-21&3 (a) (1), 143x21a.3 (a)(10) and NCAC 2 .d800
'lop i .
",,r acx
`- 'rssr tinc`_
CLARIANT CORP. . _ MOUNT HOLY PLANT
Is hereby certified to perform environmental analysts as listed on Attachment l and report monitoring data to DWO for
compliance with NPDES effluent, surface water; groundwater; and pretreatment regulations.
By reference f 5A NCAC 2N .08Qtl is made apart of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology: equipment, quality control procedures,
records, and proficiency of the laboratmy have been examined and found to be acceptable.
This certificate shall be valid until December 31, 200
Certificate No. 217
Pat Connelly

Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lob Name: Clarlant Corp i Mount Holly Plant Certificate Number: 217
Address: P.0 Box 669246 Effective Date: 01/01t2007
Charlotte, NC 28266-9246 Expiration Date: 1213112007
Date of Last Amendment:
The above named laboratory, having duty met the requirements of I SA NCAC 2H 0800, Is hereby certified for the measurement of the parameters listed below
IED PARAMETERS
INORGANICS
BOO
Sid Method 5210B
COD
Sid Method 5220D
CONDUCTIVITY
Sid Method 2610B
DISSOLVED OXYGEN
Sid Method 4500 0 G
AMMONIA NITROGEN
Sid Method 4500 NH3 E
pH
Std Method 4500 H B
INORGANIC PHENOLS
Std Method 51 0A - 14th Ed
RESIDUE SUSPENDED
Std Method 25400
TEMPERATURE
Sid Method 25508
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples Laboratories are
subject to civil penalties and/or deoertification for Infractions as set forth In I SA NCAC 2t 0807

0 \\VNN4 A
�4'19 Michael F Easley, Govern
- William G Ross Jr , Secretary
_ North Carolina Department of Environment and Natural Resources
C Man W. Klimek, P.E. Director
Division of Water Quality
February 23, 2006
Mr. William M. Archer, Plant Services Manager
Clariant Corporation
Post Office :Box 669246
Charlotte, North Carolina 2826
Subject Results of Effluent Sampling Analyses
Clariant Corporation WWTP
NI DPS Permit No. NCO00437
Mecklenburg County, N.C.
Dear l\/'Ir. Archer:
Enclosed please find the results from the laboratory analyses performed on the effluent samples
from the Clariant Corporation Wastewater Treatment Plant ( ' W"TP). The samples analyzed were
composite (split) and grab samples collected during; the Compliance Sampling Inspection performed by
Mr. Wes Bell on December 14, 200 .
The results of the effluent sampling analyses show compliance with the effluent permit limits.
Please attach this later to the inspections report dated December 21, 2005 to complete your records on the
inspection.
The report should be self-explanatory.- however, should you have any questions concerning the
report, please do not hesitate to contact Mr. Tell or me at (704) a 3-1699.
Sincerely,
t
' . D. Rey Gleason, P.E.
Surface eater Protection Regional Supervisor
Enclosure
cc. Rusty R.ozzelle, MC'W QP
WI3
. ` Isle" 1tCarolina
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet, ww ncwatq rtality r 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]- 23-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recyciedf10% Past Consumer Paper

ANALYTICAL RESULTS SHEET
NAME OF FACILITY: Clariant Corporation WWTP
Grab: X Composite:
Sample Date(s): 12/14/05
NPDES Permit No, NCO004 375
Sample Location: Effluent
Counter. Mecklenburg
BOD5, mg/l, ibs/day
43, 125,9
Phenols, ug/l, ibsrdav
57, 0.17
COD: High, mg/l
Sulfate,mg/l
660
CAD: Low, mg/I ;
240
sulfide, nig/l
Cc liform: Fecal, f#/100 nil
3
Biomass: Drys Weight
Cc liform:'Total, /100 nil
Biomass: Peri Ash Free
Cc liform:>Tube Fecal, MPN
Nll,-N, nig/l, lbs/day
0.63, I;8
Cohform. Tube Total, MPN
TKN, mg/l, lbs/day
15, 43,9
Residue, Total, mg/l
NO, +NO,, mg/1, ibs/day
20, 58.5
Volatile, mg/I
POO mg/1
Fixed, mg/1
P: 'Total, mg/l, ibs/day
6.6, 19.3
Residue: -Suspended, mg/l, lbs/day
46, 134.7
P: Dissolved, mg/l
Volatile, mg/l ;
Ag-Silver, ug/I
<5.0
Fixed, mg/l
Al -Aluminum, ug,/I
230
Settleable Solids, ml/i
Be -Beryllium, ug/I
PH, S.U.
8.10
a -Calcium, ug/I
TOC, mg/l
Cd-Cadmium; ug/l, lbs/day
<2,0, <0.01
Turbidity, NTU
Co -Cobalt, a /I
Chloride, ng/I
550
Cr-Chromium: Total, ug/l, lbs/da
<25, <0.07
Oil and Grease, mg/l, ibs/day
<10, =29.3
Cu-Cropper, ug/l, lbs/day
170, 0.5
Arsenic, rig/l, lbs/day
31, OJ 09
Fe -Irian, ug/l
450
Fluoride, mg/l
Pb-Lead, ug/l, lbs/dayy
<I0, <0,03
Manganese, ug/i
1500
Hg-Mercury, ug/1, lbs/day
<0.2, <0.0006
MBAS, mg/1
0.3
Ni-Nickel, ug/l, lbs/day
17, 0.05
Conductivity, uml os/cm
1412
Zn-Zinc, ug/l, ibs/day
72, 0.21
Dissolved Oxygen, mg/l
Voc
Temperature, °C;
4.9
Note: 0.351 MGD was utilized In the lbs/day calculation

0 A 7-Michael F. Easley„ Governor
! .
William G. Ross Jr., Secretary
„
North Carolina department of Environment and Natural Resources
C3 `C Alan W. Klimek, P.E. director
Division of Water duality
January 30 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7003 2260 00013492 7983
Mr.l~ rank Rash
Clariant Corporation
Post Office Box 66 246
Charlotte, North Carolina 28266
Subject: Notice of Violation - Effluent Limitations
Tracking #.: NOV-2006-L'V-004
Clariant MHE WWTP
NPDES Permit No NCO004375
Mecklenburg County
Dear Mr. Rash.
A review of the October 2005 self -monitoring report for the subject facility revealed a violation
of the following parameter.
Pie Parameter Re orted Value Permit Limit
001 Oil and Grease 92.3 lbsdday (monthly average) 88 lbslday (monthly average)
Remedial actions, -i not already implemented, should be taken to correct any problems. The
Division of Water Quality may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operation and/or' maintenance problems, and you
anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent. You may contact Mr. John Lesley of this Office for additional information.
If you have questions coneermng this matter, please do not hesitate to contact Mr. Lesley or me
at 704f663-1699:
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
cc: Point Source Branch
MCWQP
JL
Ot
Ici-�tyhCaprrgollina
AMA
lly
North Carolina Division of Water Quality 610 East Center Ave., Suite 3t11 Mooresville, NC 8115 Phone [phone] FAX 704-6
gy
ENF
Customer Service Phone: [phone] Internet: h o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycledl10% Post Consumer Paper

Michael F Easley, Governor
William G. Ross it,, Secretary
North Carolina Department of Environment and Natural Resources
{ Man W Klimek, Y. E , Director
Division of Water Quality
December 21, 2005
Mr. William M. Archer, Plant Services Manager
Clariant Corporation
Post Office Box 669246
Charlotte, North Carolina 28266
Subject: Compliance Sampling Inspection
Clariant Corporation WWTP
NPDES Permit No. NCO004375
Mecklenburg County, N.C.
Lear Mr. Archer:
Enclosed please find a copy of the Compliance Sampling Inspection Report fo • the
inspection conducted at the subject facility on December 14, 2005, by Mr. Wes Bell of this
Office. Please inform the facility's Operator -in -Responsible Charge of our findings by
forwarding a copy of the enclosed* report. The results of the effluent sampling will be forwarded
to you under separate letter.
The report should be self-explanatory; however, should you have any question
concerning the report, please do not hesitate to contact Mr. Bell or me at (704) a -1 99.
Sincerely;
a
. I . Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Enclosure
cc: Rusty Rozzelle, MCWQP
p B.:.
Norrth Carcl i na pAV
ia
N E
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115'[phone] Customer Service
1-I 77-62.3-6748

United States Environmental Protection Agency Form Approved,A Washington, D,C. 20460
E Pt"k OMB No. 2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A: National Data System Coding (i,e,, JPCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fee Type
I UN 2 US 31 NCO004375 ill 12 05/12/14 I 17 18 3 19 us 20U
a I -
Remarks U
211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Jill 1111 Jill 6E
Inspection Work Days Facility Self -Monitoring Evaluation Rating Bl QA --------------_____________Reserved---- ----------
671 1.5 119 70141 71 UN 72 UN 731 1 174 75
I 1 180
L-JI
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number)
Mount Holly East (MHE) Facility 09�45 AM 05/12/14 05/07/01.
PO Box 669246 Exit Time/Date Permit Expiration Date
Charlotte NC 28266 01:45 PM 05/12/14 10/06/30
Name(s) of Onsite Representative(s)[Tittes(s)/Phone and Fax Number(s) Other Facility Data
Dwayne R Wallace/ORC/704-822-2768/
Frank Gamble Rash//704-822-2727 /
Name, Address of Responsible OfficialfritelPhone and Fax Number
Nick Altman,PO Box 669246 Charlotte NC 28266//704-822-2743/ Contacted
No
Section C. Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: SummaEy of Findinq/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wesley N Bell MRO WQ//704-663-1,699 Ext,231/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Richard M Bridgeman MRO WQ//704-663--1699 Ext.264/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete,
Page # I

PPPFPF,
NPDES yrl o/day Inspection Type (cont.
1
3 "C0004 7S Ill 12 05/12/14 17 18t µ'
Section D� Summary of Finding/Comments {Attach additional sheets of narrative and checklists as necessary}'
RECORD RC KEEPING SECTION cont'd
DMRs were reviewed from October 04 through September 05, The 1 -month rolling average for effluent
total phosphorus was violated for April 05, May 05, and June 05. The Division may separately issue either
an NOV or NOV/civil penalty assessment. All monitoring frequencies were correct.
The facility staff mint insure the facility is visited by either the CRC or the designated Backup CORC on a
daily basis excluding weekends and legal holidays. The facility staff are intheprocess of designating
additionalBackup ORCs. The river staging report form was not attached to the October 04 DMR; however,
the inspection verified that the discrepancy was a transcription error. An amended DMR will be submitted.
The facility staff must insure all "less than" values are appropriately calculated <(arithmetic and/or
geometric' means) for the monthly average values. Overall, the facility staff incorporate a commendable
record keeping system.
FACILITY SITE REVIEW:
The facility continues to abide by the Tier I Permit sampling requirements. No additional new sources
have been introduced Into the system following the reissuance of the current Permit (effective 711/0 ).
Currently, only stormwater enters the acid neutralization system. This storrnwater is combined with the
process wastewater prior to the primaries.
Page # 2

Permit: NCO004375 Owner - Facility: Mount Holly East (MHE) Facility
Inspection Date: 12/14/2005 Inspection Type: Compliance Sampling
Ppft ra�tion& Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? WOOO
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge W 0 0 0
Judge, and other that are applicable?
Comment., The facility staff incorporate;a comprehensive process control program.
The facility appeared to be property operated and well maintained at the time of the
inspection.
Permit Yes No NA NE
(if the present permit expires in 6 months or less). Has the permittee submitted a new application? 0 13 VA 0
Is the facility as described in the permit? a D 0 0
# Are there any special conditions for the permit? in 0 0 0
Is access to the plant site restricted to the general public? 0 0 0
Is the inspector granted access to all areas for inspection? 0 0 0
Comment: Overall, the facility description appeared adequate; however, the facility
has only one stormwater equalization basin for alkaline wastewater and the wastewater
equalization basin has been converted to an aeration basin.
Record Kee "in Yes No NA NE
Are records kept and maintained as required by the permit? 0 0 0
Is all required information readily available, complete and current? 0 0 0
Are all records maintained for 3 years (lab, reg. required 5 years)? 0 0 0
Are analytical results consistent with data reported on DMRs? 0 0 0
Is the chain -of -custody complete? 0 0 0
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration ■
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters? 000
Has the facility submitted its annual compliance report to users and DWQ? 0 0 NO
(if the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? 0 0 NO
Is the ORC visitation log available and current? a 0 0 0
Is the ORC certified at grade equal to or higher than the facility classification? in 0 it 0
Page # 3

pprp
Permit: NCO004375 Owner - Facility: Mount Nally East (MHE) Facility
Inspection Date: 12/141 o05 Inspection Type: Compliance Sampling
Rec rd Kee&q Yes No NA NE
Is the backup operator certified at one grade less or greater than the facility classification? a 0 0
Is a copy of the current NPCIFS permit available on site?
Facility has copy of previous year's Annual Report on file for review? 00NO
Comment: nt: See "Summary" Section for additional comments.
Effluent Pipe Yes No NA NE
Is right of way to the outfali properly maintained? 11000
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly? 00110
Comment: The effluent appeared a brownish color with no floatable solids or foam.
Flow Measurement - Effluent Yes No NA N
Is flow meter used for reporting? U000
Is flow meter calibrated annually? 12000
Is the flow meter operational? 11000
(If units are separated) Does the chart recorder match the flow meter? OOOK
Comment: The flow meter is calibrated/verified twice per month. The flaw meter was
last calibrated/verified on `I 1/15/05.
Salida Handlin ui merit Yes No NA NE
Is the equipment operational? N 0 Q
Is the chemical feed equipment operational?
Is storage adequate? a 0 0 0
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts anchor rollers of filter press? 0 0
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment: The facility utilizes two belt presses. One of the belt presses was not
operational. The operational belt press was not in -use at the time of the inspection.
Ear Screens
Type of bar screen
a.Manual
b.Mechanicai
Are the bars adequately screening debris?
U000
Yes
No
NA
NE
8000
Page # 4

Permit: NC0004375 Owner - Facility: Mount Holly East (MHE) Facility
Inspection Date: 12/14/2005 Inspection Type: Compliance Sampling
Bar Screens Yes No. NA NE
Is the screen free of excessive debris? MOOO
Is disposal of screening in compliance? 000
Is the unit in good condition? 0 0 0
Comment:
gvelletlrl Gaalrt Yes No NA NE
Is the basin aerated? 0 0 a 0
Is the basin free of bypass lines or structures to the natural environment? 0 0 0 0
Is the basin free of excessive grease? n 0 D 0
Are all pumps present? 0 0 0
Are all pumps operable? 0 0 0
Are float controls operable? 0 0 0
Are audible and visual alarms operable? 0 0 in 0
# Is basin size/volume adequate? in 0 0 0
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 0 0
Are weirs level? 0 0 0
Is the site free of weir blockage? 0 0 0
Is the site free of evidence of short-circuiting? 0 0 0
Is scum ,removal adequate? 0 0' 0
Is the site free of excessive floating sludge? 0 0 0
Is the drive unit operational? 0 0 0
Is the sludge blanket level acceptable? 11 0 0 =
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 0 0 in
Comment: Both of the facility's primaries were operational; however, only one of the
clarifiers were in -use due to low influent flows.
Secqq#a_ �Clar�ffier YesNo _NA NE
Is the clarifier free of black and odorous wastewater? a 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 0 0
Page # 5

pppr"
Permit: NCO004375 Owner - Facility. Mount Holly Fast (MHE) Facility
Inspection date: 12/14/2005 Inspection Type: Compliance Sampling
Secgrida {clarifier Yes No NA N
Are weirs level? 0
Is the site free of weir blockage? in 0 l
Is the site free of evidence of short-circuiting?
Is scum removal adequate? 0 0 Q
Is the site free of excessive floating sludge? 21 0 0 Q
Is the drive unit operational? inno
Is the return rate acceptable (low turbulence)
Is the overflow clear of excessive solids/pin floc? 0 L
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0
Comment: Both of the facility's secondaries were operational; however, only one of
the clarifiers was in -use due to low influent flows.
Aeration ;Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots?
Are surface aerators and mixers operational? Q 0
Are the diffusers operational? Q 0, 0
Is the foam the proper color for the treatment process?
Goes the foam cover less than 5% of the basin'ssurface? 0 a 0 0
Is the DO level acceptable? a 0
Is the DO level acceptable?(1.0 to 3.0 mgll) 0 0 a 0
Comment: The facility utilizes two aeration basins in series. The initial aeration basin
was equipped with surface aeration and mixers. The final aeration basin was equipped
with surface and diffused aeration. Foaming was observed throughout both aeration
basins that was attributed to the cold weather and process wastewater from one of the
outside clients:
Star F!gvyer Yes No NA N
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source? 0 0 a 0
Is the generator tested under load? 130100
Was generator tested & operational during the inspection? 0000
Page

Permit. NCO004375 Owner - Facility: Mount Holly East (MHE) Facility
Inspection Date: 1211412005 Inspection Type: Compliance Sampling
Staq#§y Power Yes. No NA NE
Do the generator(s) have adequate capacity to operate the entire wastewater site? ON00
Is there an emergency agreement with a fuel vendor for extended run on back-up power? N 110 0
Is the generator fuel level monitored? IN000
Comment: The two on -site generators are tested weekly (not under load). During
power outages, the ORC indicated that the effluent gate valve is closed with all effuent
pumped to the 350 MG holding pond (all powered by one of the generators).
Pu!qps�S-W�A$ Yes No NA NE
Are pumps in place? U000
Are pumps operational? in 0 0 0
Are there adequate spare parts and supplies on site? DOOM
Comment:
Labqr4" Yes No NA NE
Are field parameters performed by certified personnel or laboratory? U000
Are all other parameters(excluding field parameters) performed by a certified lab? is 0 0 0
# Is the facility using a contract lab? 0 13 0
Is proper temperature set for sample storage (kept at I .O to 4A degrees Celsius)? 0 0 0
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? 0 0 0
Incubator (BOD) set to 20,0 degrees Celsius +/- 1.0 degrees? 0 0 0
Comment: On -site analyses are performed under laboratory certification #217. Please
refer to Mr. Chet Whiting's (Division's Laboratory Certification Unit) inspection report
regarding the facility's laboratory practices,
Eff"luqt _Sam_p "n Yes No NA NE
Is composite sampling flow proportional? ■ 0 0 0
Is sample collected below all treatment units? 0 0 0
Is proper volume collected? 0 in 0 0
Is the tubing clean? 0 0 is 0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? is 0 0 0
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? 0 0 0
Comment: Approximately 60 - 70 ml. aliquots were being collected during the
composite sampling event. The ORC increased the aliquot amount to comply with the
permit requirement.
Pp treatyl_/ I?qwnstrqaT Saim Ing Yes No NA NE
pT
Page # 7

W7
Permit: NCO004375 Owner - Facility: Mount Molly East (MNE) Facility
Inspection Date: 12/1412005 Inspection Type: Compliance Sampling
ypstream / Downstream §am EIn Yes No NA NIA
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? U 0 0
Comment,
Page # 8

Michael F. Easley, Governor
William G. Ross Jr., Secretary
r North Carolina Depar went of Environment and Natural Resources
`i
Alan W. Klimek„ P. E. Director
Division of Water {duality
Date: December 6, 2005
Nick Altman
PO Box 669246
Charlotte, NC 28266
Subject: Notice of Incomplete Discharge Monitoring Report NC0004375 .
Dear Pe ittee:
The purpose of this letter is to call your attention to problems With the recent submittal of the Discharge
Monitoring' Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems With your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DR's deficiency.
Incomplete or illegible DMRs affect our staffs ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with, your NPDES permit and 15A NCAC 02I .0506, and you may subject to further
enforcement action. Please tape the necessary steps to correct the problems and submit two copies of the
amended DMR within.. fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central files
1617 Mail Service Center
Raleigh, North Carolina 7699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs, please contact Michele Phillips at 919-733-5083 Ext. 534. Thank
you for your assistance in this matter:
wkMEms
Sincerely, t,iiiE y
"" tOFFICE.
Michele Phillips
C 0 8 200"
cc: '
Central Files
.,,.. 17,
O
NorthCartrtina
;Vatur-1141
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: hfp;l#h2o.enr.state.ne.us 512 N. Salisbury St. Raleigh, NC 27604 Fax. [phone]
An Equal Opportunity/Affirmative Action Employer

a s
�oiice o Pico plete D ge lk oxu�o . ' g Report
ptrmit Number
Facility:
County:'1
DNIR Month and Year -
The
Division of Water Quality deemsd=ms the aforementioned DMR as incomplete due to the
following on(s): (Please see the highlighted areas on the attached DMRjor .details.)
e written values are illegible.
tl
E
The Averagee, dlor the paints have been o d.
Ll e Brits of Measure have been omitted or are inco t"
The DNS '=m ter Codes have been omittcd.
other -
fa
v
w,
,

P.O. Box 669246
Charlotte N.Q*AWC EN a�
AND NATURAL RESOURCES
S
KCXMSV1LLF"""',-"^4ALr* dilmit
tea , e
November 10, 2005 NOV `I 7 200
NC DENRI [division of WaterQuality/
Water Quality Section
A N: Central Files 2
s a ,
1617 Mail Service Center
a � _$
Raleigh N.C. 27689-1617 rr n
Attached is the October, 2005 CMR for the Glariant Corporation, Mt. Holly East facility, NPl3ES, Permit
numberNC 0004375.
For October 2005, this facility exceeded its monthly average limitation for Oil & Grease. This facility
discharged a monthly,average of 92.3 lbs/day Oil & Grease compared to our permitted limit of 88.0
lbslda , The high average is primarily attributable to an unusually high daily discharge on October 12,
2005 that resulted from a combination of high flaw and a higher than nonnal tail & Grease
concentration, ' The facility had received approximately 5.8 inches of rain in the week prior to Oct. 12
and the discharge flow was over 40% higher than average. The Oil & Grease concentration for the
sample 'collected that day was unexpectedly high too, resulting in a total discharge that day much
higher than we had previously experienced. We know of no unusual Oil & Grease discharges into the
system influent and no system upsets that could have caused the higher Oil & Grease level. We
speculate that the source of the higher Oil & Grease may have been from to runoff after a
protracted period of dry weather.
If you have any questions regarding this report, please contact me at (704) 822- 768 or my supervisor,
Frank Rash, at [phone].
Dwayne R. Wallace
O C, Mount Holly East Plant
Clariant Corporation
cc. Mr. John Leslie, Mooresville Regional Office

Michael F. Easley, Governor
William G. Ross Jr., Secretary
T North Carolina Department of Environment and Natural Resources
'C Alan W. Klimek, P. E, Director
L*PT. k y`
Date. November 9, 2005 ry
Gary Sanderson
P Q Box 18278 n
Charlotte, NC 2818
Subject: Notice of Incomplete Discharge Monitoring Report NCO004375
Dear Pe ittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the D R's deficiency.
Incomplete or illegible D Rs affect our staff s ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES pen -nit and 15A NCAC 02 .0501 , and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
ended DMR within fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service tenter
Raleigh, North Carolina ''-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs please contact Michele Phillips at 19-7 -5083 Ext. 534. Thank
you for your assistance in this matter.
Sincerely,
Alan W. Klimek, P.E.
cc:
Central :Piles
one
Nor Carolina
%`rall#
N. C. division of water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: http:lVo.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax: [phone]
An Equal OpportunitytAffirmatve Action Employer

l 0- fke of I�Complete Discharge Monitoring Report
r
f
�LL
,Permit Number l
ility.
County. . lt.
DMR :Month and Year.�.
e Division of Water Quality deems they aforementioned DMR as incomplete due to the
following on(s). (Please see the hzghlibhted areas can the attached D R for details.)
e wfittan values art illegible.
r
r
e Average, Maximum, and/or the Minimum data paints have been omitted.
LI The Emits of Measure have been omitted or are incorrect
The DYIR Parameter Codes have been omitted.

Michael F. Easley, Governor
3 William G. Ross Jr., Secretary
T" t North Carolina Department of :Environment and Natural Resources
CO
.i
Alan W. Klimek, P. E. Director
Division, 0A atpr Quality
"t
d a" M.l x
Date: July 25, 2005 f l��
Frank Rash
PO Box 669246
Charlotte, NC 222
Subject: Notice of Incomplete Discharge Monitoring Report 01
Dear Pe ttee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database, Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staffs ability to provide a timely;and effective evaluation of DR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
amended DMR within fifteen (15) days of the date of this letter to the following address.
Attention: Michele Phillips
Division of Water Quality;
Central Files
1617 Mail Service Center'
Raleigh, North Carolina 27699-161
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs please contact staff with the Division's NPDES Program at 919-
73 -5083. Thank you for your assistance in this hatter,
Sincerely,
Alan W. Klimek, P.E.
cc:
Central Files
one NCarolina
Witrall j
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: 'httpJ/h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax: [phone]
An Equal Opportunity/Affirmative Action Employer

Notice of Incomplete Discharge Monitoring Report
Permit Number: d 4-,3 7J-
Facility:
County:
DMR Month and Yean, J14A&
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
following reason(s): (Please seethe highlighted areas on the attached DMR for details.)
Ll The written values are illegible.
all" The Average, Maximum, and/or the Minimum data points have been omitted.
* 7 64 P-3B
Ll The Units of Measure have been omitted or are incorrect.
Ll The DMR Parameter Codes have been omitted.
U Other:

Michael F. Easley, Crovernx>r
QWilliam U. Ross Jr., Secretary
��t North Carolina Department of Environment and Natural Resource,
i Alan W. Klimek„ R E. Director
Division of Water Quality
April 8, 2005
Ducharme, McMillen & Associates, Inc.
Mr. Tony Franco, CMI
200 Tray Hall .Road., 2nd Floor
Windsor, CT 06095
SUBJECT: Tax Certification
Clariant Corporation, Mount Holly East
Mecklenburg County, North Carolina
Dear Mr. Franco:
The 'subject facility had already been issued a Tax Certification by this Office, therefore,
there is no need for another certification.
Please note that maintenance items such as repairs and replacement equipment are
covered under the original certification.
Enclosed is the Tax Certification application submitted to this office.
f you have any questions concerning this natter, please do not hesitate to contact Mr.
Samar Bou-Ghazale or me.
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Supervisor
One
otbCarolina
°�rCLlvt��
N Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 [phone] Customer Service
1-87'7-623.6748

QMA
DUCHARME, MCMILLEN ASSOCiATES, INC
A"
February 24, 2005
Mr. Rex Gleason
NCDENR
Mooresville Regional Office
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
RE: 2005 Tax Certification Request
Clariant Corporation, Mount Holly East
Mecklenburg County, Charlotte
Dear Mr. Gleason:
0010EPT. 07
7 ANI) 70URCES
1 2,005
On January 20, 2003 Clariant Corporation received a property tax certification Ao.
TCS-MV-111 for assets associated with NPDES Permit NCO004375. We request
that an additional certification be granted for the additional assets that have since
been added to the site, and are used in accordance with the aforementioned permit.
The table on the second page contains a list of assets we request to be added to
the previously approved tax certification.
If you should have any questions you may reach me at 860-683-1900 ext. 2204 or
you can contact Bill Archer, at the Mount Holly East facility at 704-822-2702. As
proof of receipt, please sign and date this letter at the bottom and fax a copy to my
attention at [phone].
Sincerely,
. . .. .... .
Tony raric"o', CMl
Tax Manager
cc: Russ Panetta
Stacey Williams
Signature Date
200 Day Hill Rd., 2nd Ftoor - Windsor, CT 06095 - 86M83-1900 # Fax: [phone] - wwwAnwinc.cont
TO .7;i[IN

._ Gleason
February
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00 PEW A
7�- y Michael F. Easley, Governor
} ✓ William C. Ross Jr,, Secretary
North Carolina department of Environment and Natural Resources
:.
t Alan W. Klimek, P.F, director
Division of Water Quality
December 10, 2004
217
Mr. Gary P. Sanderson 1)i"'C 1 4 20V"""
Clariant Corp. - Mount Holly Plant
P, . Box 6 924
Charlotte, NC 28266- 246
I
10
SUBJECT: LaboratoryCertification Maintenance Inspection
Dear Mr. Sanderson.
Enclosed is a report for the inspection performed on October 22, 2004 by Mr. Chet Whiting.
Where deficiencies are cited in this report, a response is required as well as for all lettered comments
and/or recommendations. Within thirty days of receipt, please supply this office with a written item for
item description of how these deficiencies, comments and/or recommendations were corrected.
We are concerned about the CITED PREVIOUSLY L. deficiency (s) found during the inspection.
If the deficiencies cited in the enclosed report are not corrected, enforcement actions will be
recommended. You are reminded that it is not legal to analyze environmental samples required
by the N.C. Division of Water Quality without our certification. For certification maintenance, your
laboratory must continue to carry out the requirements set forth in 15A NCC 2fi .0800.
Copies of the checklists completed during the inspection may be requested from this office.
Thank you for your cooperation during the inspection. Thank you for your cooperation during the
inspection. If you wish to obtain an electronic copy of this report by email, or if you have questions or
need additional information please contact us at 919-733- 90 .
Sincerely,
dames W. Meyer
Laboratory Section
Enclosure
CC' Chet Whiting
Mooresville Regional Office
NPCarolina
Laboratory Section 1623 Mail Service Center; Raleigh, NC 27699-1623
4405 Reedy Greek. Road; Raleigh, NC 27607
Phone [phone] FAX [phone]I Internet: www.dwqlab,org
An Equal Opportunity/Affirmative Action Employer— 50% Recycle 1110% host Consumer Paper

ON -SITE INSPECTION REPORT
Laboratory Name: Clariant Mount Holy
Laboratory Address: P.O. Box 6 246 Charlotte, NC 26266
Laboratory Cert, Number: 217
Inspection Type: Maintenance
Inspection DateOctober 22, 2664
Inspectors: {whet Whiting
Local Contact Persons): Mr. Sam Hill
1. INTRODUCTION:
The above named laboratory was inspected to verify compliance with 1 6A NACU 2H .066 for
the analysis of environmental samples.
II. OVERVIEW:
The laboratory was neat and well organized. Laboratory personnel provided the inspector(s) with
all materials, and information requested for examination. Some improvements were noted in
laboratory documentation related to standard source materials and consumable items.
III [DEFICIENCIES, REQUIREMENTS, COMMENTS, NTS, AND RECOMMENDATIONS:
GENERAL O OTORY:
TEMPERATURE AND DISSOLVED ECD OXYGEN:
1. DEFICIENCY (previously cited): The facility is not currently certified to perform these
parameters.
REQUIREMENT: Please submit the appropriate documentation requesting certification for
temperature and dissolved oxygen analyses. The form to amend a certification application is
available at the Laboratory web site. j j / DwQ . o r
Please resolve this issue immediately.
CHEMICAL AL OXYGEN
DEMAND-
COMMENT: Identification of process control samples from compliance samples is still less
than clear.
REQUIREMENT: Clearly identify compliance and process control samples on laboratory
worksheets:

PPP
7Pa__go 2
Note: As discussed process control samples do not have to meet the same stringent criteria as
compliance samples. It is therefore in the laboratory's best interest to clearly identify compliance
samples.
NOTE: The laboratory has an annual five -point curve for COD and is checking three points and
an LCS with each series. The requirement is to check the mid -range of the curve and analyze an
L_CS for each analytical series. Theserequirements are for compliance samples only. On days
when only process control samples are being analyzed'a mid -range and L.CE are not required.
Non-compliance samples comprise the majority of COD samples analyzed. The effort and
expense of this analysis could be significantly reduced on days when only process control is
analyzed. This is why it is very important to clearly identify the samples,
BIOCHEMICAL OXYGEN DEMAND:
B. COMMENT: The laboratory is using the seed correction value from the control with depletion
nearest 0%. This is an outdated criterion and no longer approved.
REQUIREMENT: All control values that meet the 2 mg D.O. depletion; 1 mg D.O. remaining
criteria applied to samples must be used. If multiple controls are within these acceptance criteria
an average control value is used:
2. DEFICIENCY: The laboratory did not qualifying results that failed to meet Q.C. criteria on
the DMR report forms. 8/8/04, 8/5/04, 8f6/04, 8/9/04, 8/17/04 '[use 2 leave one criteria],
7/12/04 [seed control out).
REQUIREMENT: A notation must be made on the DMR report form in the comment section
when any required sample quality does not meet specified criteria, and another sample can not
be obtained. The most common occurrences will probably involve BOD and Fecal Coliform MF).
Items may include bit not be limited to: (BOA) seed corrections, G, or blanks, (Fecal Coliform)
Insufficient dilutions to obtain 20'- 60` blue colonies per filter.
NOTE: Sample dilution ranges were changed in September 04 effectively correcting depletion
problems. A copy of when to qualify BOD results will be sent under separate cover.
CONDUCTIVITY
C.COMMENT: The conductivity meter is calibrated at 10, 100, and 1000 pmh ; however
samples' routinely are analyzed in the 5- 6000 pmho/cm range.
REQUIREMENT: A standard needs to be analyzed that is above the highest sample
concentration:
RECOMMENDATION: Since no samples were observed below 100 pmhos it is our
recommendation that the calibration sequence include 100, 10, and. 10,000 pmho
standards.

FF� -
Pagt
REQUIREMENT: pH buffer cheeks mint be within ± 0.1 pH units or corrective action must be
taken, the meter realibrated and checked.
SOLIDS TS p
RECOMMENDATION:The T S worksheet was somewhat crowded this made review slightly
confusing. It was recommended that the sheet be expanded to include an additional column
for data currently recorded in the margin.
GENERAL QIALITY CONTROL
Note: Duplicate evaluation criteria were discussed and information will be sent under separate
cover,
DATA REVIEW:
General laboratory records and documentation was reviewed. Data and DMRs from June, July
and August 2004 were reviewed. No items other than those specified in the above report were
observed.
V CONCLUSION
Correcting the above cited deficiencies and/or comments and implementing , the
recommendations will help this lab to produce quality data and meet certification requirements.
Please respond to all numbered deficiencies and lettered comments.
Report prepared by Chet Whiting Date: November 10, 2004

Qualifying Versus Rejecting E3OD Data
The lab is not qualifying the data when quality control requirements are not met.
The following information is provided to enable compliance. Please note that no
major problems were noted in the B D area:
It is the desire of the State of North Carolina that all data generated for any
permitted location under NPDES requirements is to be reported. "Every person
subject to [1 5A NCAC 2S .0506] shall file certified monitoring reports setting
forth the results of tests and measurements conducted pursuant to NPDES
permit monitoring requirements." Reference; 1 A NCAC 2B . 5 a 1 .
Additionally, "the results of all tests of the characteristics of the effluent, including
but not limited to NPDES Permit Monitoring Requirements; shall be reported on
monthly report forms." Reference: 15A NCAC 2S .g566 3
The NPDES Permit itself states in Part ll, Section D; Monitoring and
Records, Number 7 - Recording Results; "for each measurement or
sample taken pursuant to the requirements of this permit, the permittee
shall record the following information... the results of such analyses.
This means all data are reported and none are rejected. If all quality
control requirements are not met, it is recommended that the data be
flagged and the qualification appear on the back of the Discharge
Monitoring Report (DMR). Any rejection of data from the storets will be
issued by the agency which receives the data,
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than
0.2 mg/1.
2. The seed controls must deplete at least 2.0 mg/I DO and have at feast
1.0 mg/I DO remaining,
. The samples must also deplete at lust 2.0 mg/I DO and have at least
1.0 mg/I DO remaining.
4. No evidence of toxicity should be present. This can only be evident
when at least three dilutions are analyzed. This is characterized by an
increasing BOD value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of
193 /I + 30. mg/l.
6. The seed correction, calculated from the seed controls, must be
between 6.6 and 1.0 mg/I.
Anytime any of the above quality control requirements are not met, the
data must be flagged. The qualifying statement should indicate that all QC
requirements were not meta But the data must Shwa s be reported.

Clariant Corporation
P.C. Box 669246
Claulotte, N.C. 182E 6- 246 4 �t
Nov. 15, 2004 � Nam..
N. C. Dept. of Environment, Health and Natural Resources
NPDES Permit Group
610 East Center Ave.
Mooresville, N.C. 28115
This letter follows up my verbal telephone report made to the Mooresville Regional Office on
Nov.: 12 2004.
On Sept. 21, 2004, Clariant Corporation's Mount Holly Plant, East Facility, permit 4 NC
0004375, exceeded its permitted discharge limits on the annual OCP Fj'CW`f parameters.
The limits exceeded are as follows:
Arsenic: .263 lbs. discharged. (permitted limit:.231 lbs., monthly ave.
Vanadium: .195 lbs. discharged. (permitted limit: .147 lbs., monthly ave.)
Molybdenum: 19.5 tbs. discharged. (permitted limit: 2.141 tbs., monthly ave.), (2.241 lbs.,
daily max.).
This facility became aware of this discrepancy on Nov. 1 t, 2004, when we received
confirmation from Pace Laboratories ofthe analytical results:
This facility will initiate quarterly sampling for these parameters begiraiing in Dec. 2004, as
required by our NPDES permit, All other parameters were within permitted limits.
I have enclosed With this letter, two corrected copies of Septa 2004 DMR's, and two copies of
our CP F/ CWT report for 2004
If you have any questions, please cull my supervisor, Mike Rash at [phone], or myself at
(704) 22-276 .
Dw a ne Wallace, ORC
Clariant Corporation
Mount Holly East Platt

ppppp-
Facility Name: Clanant Corporation
Date of sampling: 0 121/04
Analytical laboratory: Pace Analytical Services, Inc.
CRC: Dwayne R, Wallace
Phone: [phone]

#C'1 tL7 ti t[7 C La Cd t k iC (a SiZ CL' C[;} C7 (a f. CCU A"' !.Q #i7 (a C.t� .L� - iC� .C� i.C7 CQ .f� CCU
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Ci! �

I. certify under penalty of law that this document and all attachments were prepared under my direction
and supervision in accordance with a system to design to assure that qualified perdonnel properly
gather and ev luat the information submitted. Based on my inquiry of the person or persons that
manage the system, or those persons directly responsibel forgathering the information, the
information submitted is , to the best of my knowledge and belief, true, accurate and complete. I a
aware that there are significant penalties for submitting false information, including the
passibility of fines and imprisonment for Knowing violations.
Authorized Representative name
Signature
Date

Supplemental CWT Monitoring
Permit No. NCO004 7 Month: Sept
Outfall: 001 Year. 2004
Facility Name: Clariant Corporation RC: Dwayne Wallace
Late of Sampling. 0 /21/04 Phone: [phone]
Analytical Laboratory: Pace Analytical Services, Inc
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Michael F. Easley
0 governor
AMA N ISE I William G. Ross, Jr,, Secretary
North Carolina Department of Environment and Natural Resources
"t Alan W. Klimek, P.E.; Director
Division of Water (Quality
September 9, 2004
Ken Golder
Clanant Corporation
PO Box 18278
Charlotte, NC: 28218
Subject: Renewal Notice
TIES Permit NC O004375
Mount HollyEast ) Facility
Mecklenburg County
Dear Ike 'tree:
Your NPDES permit expires on June 30, 2005. Federal (40 C:1 ^ 122. 1 d North Carolina (1 A NCAC 2E-1. 105(e))
regulations require that permit renewal applications must be filed at least 180 days prier to expiration of the current permit. If
you have already mailed your renewal application, you may disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than January 1,
2005. Failure to request renewal by this date may result in a civil assessment of at least $500.00. Larger penalties may be assessed.'
depending upon the delinquency of the request.
If any wastewater discharge will <occur after Jane 30, 2005, the current permit must be renewed. Discharge of wastewater
without a valid permit would violate North Carolina General Statute 143-215.1; unpertnitted discharges of wastewater may be
assessed civil penalties of up to $5,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact me at the telephone
number or address listed below. You may also contact the Mooresville Regional Office at [phone] to begin the rescission
process._
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please contact me at the telephone number or e-mail address listed
below.
Sincerely,
Charles I I. Weaver, Jr:
DES Unit
cc: Central Files
I�iPT1ES File....
1617 bail Service Center„ Raleigh, North Carolina 27699-1617 919 733-5083, extension 511 (lax) 919 33-0719
Vrsrr us ON THE INTE Nr T @ http.fth o.enr.state,nc,us/NPDES e-mail: [e-mail]

NPDE S permit NCO004375
Mount Holly East (MHE) Facility
Mecklenburg Cunty
The following items are REOIARED for all renewal packages..
• A cover letter requesting renewal of the pen -nit and documenting any changes at the facility sine
issuance of the last permit. Submit one signed original and two copies.
• The completed application form (copy attached), signed by the permittee ' or an Authorized
Representative. Submit one signed original and two copies.
• If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
M
water, f lterbackw ,sh, etc.)
PLEASE NCB
.chic to a c rout ,c ut ices cts.cc>tavc j aa.tt. aly 1, 1777, uacic z no icur-wad icc icquucu widi yuLu
application package.
Send the completed renewal package to:
Mr. Charles H. Weaver, Jr.
NC; DENR'/ Water Quality NPDES Unit
1617 Mail Service Center
Raleigh, NC . 7699-1 1

■
J
of
F.
Dixisim o"Ovattr QualttN
May 1, 2004
Mr. Gary Sanderson
Cl `'ant Corporation _MBE Facility`
Post Office Box 66924E
Charlotte, North Carolina 2266
Subject: Compliance Bic► onitoring Inspection
Clariant Corporation WWTP
DES Permit No. NCO004375
Mecklenburg County, ty, NC
Lear Mr. Sanderson:
Enclosed is a copy of the Compliance Bionionitoring Inspection Report for the inspection
conducted at the subject facility on May 7, 2004 by John Lesley of this Office. Please inform the
facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed.
report.
Samples were collected of the facility's effluent dischge on May - , 2004 and May 6-7,
2004 for use in a chronic Ce iodap ni dubia pass/fail'toxicity test. Toxicity test results will be
forwarded under separate cover when available.
The report should be self-explanatory; however, should you have any questions once g
this report; please do not hesitate to contact Mr. Lesley or me at 704-663-1699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc. Central Files
Mecklenburg County Health Department
!*3 -ixxa
NCDENR
N. C. Division ofWatm Quality, Moo !e Office, 919 North Main s Mors I e N 29115 [phone] Cuswn=
1- 77-623-6 4

Unded States Environmental Protemon Agency
Washington, D.C. 20460 Form Approved,
EPA (FMB No. 2040-0057
:Approval :expire7sS-31-98
Section A: National Data System Coding (Le,, PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fee Type
I L 2 W 31 NCO004375 11 121 04/05/07 1 17 18 L.j 19 � 20 Lj
Remarks
211 1 1 1 1 1 -1 1 1 1 1 1 1 L' IJ66
Inspection Work Days Facility Self -Monitoring Evaluation Rating E1 QA Reserved
671 3 � 0 169 70 Lj 71 LEJ 72 L�j 73 L 74 751 JJ'j 111 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date
PO TW name and NPDES permit Number)
Mount Holly East (MHE) Facility 10:00 AM 04/05/07 03/03/01
PO Box 669246 Exit Time/Date Permit Expiration Date
Charlotte NC 28266 11:40 AM 04/05/07 05/06/30
Narne(s) of Onsite Representative(s)/Tities(s)lPhone and Fax Number(s) Other Facility Data
Dwayne R Wallace/ORC/704-822-2768/
111
Name, Address of Responsible Official[ Title/Phone and Fax Number
Gary Sanderson,PO Box 669246 Charlotte NC 28266//704-822-2743/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N Facility Site Review EffluentlReceiving Waters N Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachmeht summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
John E Lesley MRO WQ//704-663-1699/704-663-6040
z
Signature of Management 0 A Reviewer Agency/Office/Phone and Fax Numbers Date
Richard M Bridgeman 704-663-1699/704-663-6040
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete,

03
NPDES yrirmo/day Inspection Type ( .cant , ) 1
g NCO004375 i11 1 04105/t]? g1T 1$
us
t erection D: umma of Finding/Comments f ttach additional sheets of narrative and checklists as n ce s 3
Odor complaints from residents near the facility have been frequent. Sludge removal operations by Bionomics,
Inc. have been can -going at the WWTP, which have led to the odor complaints The company is stepping up the
time table for the sludge removal to minimize the duration of the odor problems.
Monthly monitoring reports were reviewed for the period of September 2003 through March 2004, In December 2003
the monthly BOO limit was violated (NOV sent), and the 'facility failed the chronic toxicity test (NOV :sent) .
The facility also reported a failure for the Chronic Toxicity; test in February 2003 ( a review of the spilt
test results by the ATU found that the test was a Pass).
The facility began treating Oily Wastewater on January 22, 2004. The oily wastewater facility consists of a
series of tanks for chemical addition (112So4, Caustic, or Polymers) to improve oil/water separation. oil is
removed by an oil/water separator, placed in storage, and checked for chlorides and PCBs prior to being taken
by a contractor for recycling. Water is discharged to the biological WWTP.
The BAT study required by the NPDES Permit has been completed.
All wastewaters shipped to the WWTP must be profiled prior to being accepted. Samples are sent to Clariant
of the wastewater. The samples are tested for pH, specific gravity, oil, COD, phenols, respirometry, BONS,
chlorine, and PCB. Other tests which may be conducted are flash point, metals scan., volatiles scan„ and
semi-uolatiles scan. Physical characteristics such as color, odors,appearance, viscosity, and oil
separation are also noted on the Pre -Shipment Sample Analysis; Form. :If acceptable, the wastewater is
assigned a MHE Profile Number which is used for identification of the wastewater. There is also a Third
Party Wastewater Shipment Log that is used when the wastewater is delivered.

J l
C000000000000
0000000
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in
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ONONNOD
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osso
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Permit: NCO004375 Owner - Facility: Clariant Corporation - Mount Holly East (MHE) Facility
Inspection mate: 05/07/04 Inspection Type. Bioassay Compliance
Yea b1c
NA
19E
Are field parameters performed by certified personnel or laboratory?
19 0
0
0
Are all other parameters(excluding field parameters) performed by a certified tab?
a Q
0
J
Is the facility using a contract tab?
Is 0
Q
0
Are analytical results consistent with data reported on DMRs?
In 0
0
0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
in 0
Q
0
Incubator (Fecal Conform) set to 44.5 degrees Celsius+l- 0.2 degrees?
0 0
a
0
Incubator (BOO) set to 20,0 degrees Celsius +l- 1.0 degrees?
it 0
Cornment:See Laboratory Certification Maintenance Inspection dated 1012212003.
yes
„IMU m2a2UMIMP.121 - EffluaiA
Is flow meter used for reporting?
Na—BA—NE
a 0
0
0
Is flaw meter calibrated annually?
a 0
0
0
Is flow meter operating properly?
■ C
(If units are separated) Does the chart recorder match the flaw meter?
0 0
a
Comment:Meter is calibrated as needed by Instru entlControls Dept, Last calibrated on 2/1012004.
Yes Nn
NA
NF
a=QULE===,
Are records keptand maintained as required byfhe permit?
If a
0
C
Is all required information readily available, complete and Current?
a 0
Q
Q
Are all records maintained for 3;year (tab. reg. required 5 years)?
■ 0
0
0
Are analytical results consistent with data reported on DMRs?
Is 0
0
Are sampling and analysis data adequate and include:
IN 0
0
0
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and Calibration
Dates of analysis
Name of person performing analyses
Transported COCs'
Plant records are adequate, available and include
19 000
O&M Manual
As built Engineering drawings
Schedules and dates of equipment maintenance and repairs
0
Are DMRs complete: do they include all permit parameters?
Is 0
Has the facility submitted its annual compliance report to users?
0 0
,
0
(if the facility is =car > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
0 0
a
0
Is the ORC visitation log available and current?
a Q
Q
(� i
Is the ORC certified at grade equal to or higher than the facility classification?
in 0
®
0
Is the backup operator certified at one grade less or greater than the facility classification?
Is p
0
0
Is a copy of the currentNPDES+ permit available on site?
a [..
]
0
Is the facility description verified as contained in the NPDES permit?
W 0
0 ;
0
Does the facility analyze process control parameters, for example: MLSS, MC T, Settleable Solids„ DO, Sludge
It 13
0
Judge, pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
0 0
Is
0
Comment:
Fff It sent amnlinc
Yes : No
NA:
NF
Is composite sampling flow proportional?
Igo
00
Is sample collected below all treatment units?
a 000

F.111LIS211L QUIQW1111i
is proper volume collected?
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)'
Comment:
Comment:

Michael F. Easley, Governor
V41fk7 William C. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
} Coleen H. Sullins, Deputy Director
{ Division of Water Quality
April 28, 2004
vZEISOURCES
sg rfi
Mr. Frank Rash 1,A .SAL OFFId
Clariant Corporations
Mount Holly Plant
P.O. Box 669246 APR 2 9 2004
Charlotte, North Carolina 2826 -924 i
Subject: January 7,2004-Toxicity Test
Clariant Corporation i TY SECTION
NPI E No NC 004 7
Mecklenburg County
r. Rash,
Thank you for submitting the supporting information requested for the January 7, 2004 effluent
toxicity test result for the Clariant Corporation.. All relevant information has been reviewed by .Aquatic
Toxicology Unit staff. The result of the January 7, 2004 test has been recorded with a chronic value of
2.5%.
To investigate the apparent difference in results obtained from the tests, we examined documentation
concerning sampling, testing, and lab procedures. Water quality parameters of the control waters for the
tests were similar. All quality assurance documentation from both labs was in order. However, your
facility's split sampling procedure should be modified. As Mr. Ferrell, a member of our staff, explained
to Mr. Dwayne Wallace on /9/04, the procedure should be modified so that a small amount (i.e.
approximately one quarter of container volume or less) be poured into each laboratory's shipping
container m_gkina certain the s lg is mixed between each 12ggring. This pouring procedure should be
repeated for each laboratory's container until all are full leaving no airspace. Using this split sampling
method avoids the possibility of one laboratory receiving a sample containing a greater concentration of
any stratified toxic constituents. Enclosed is a handout that demonstrates the split method described
above.
Also, the chain -of -custody form mailed to our office from lace Analytical, Inc. lacked a sample
collection signature, a relinquished by signature, and a date/time for each. The chain -of -custody form
mailed from your office contained both those signatures with the date/times. When Mr. Ferrell inquired
about this discrepancy with Mr. Dwayne Wallace, he informed him that the facility copy had been lost
so lie requested the laboratory return the original so he could have a copy on file. Mr. Ferrell was told
after the original was returned is when the missing signatures with the date/times were filled. in.
Zo�hR
Customer Service Environmental Sciences Branch 1621 Mail Service: Center Raleigh, NC 27699-1621 (919) 7 3-9960
1800 62 -7746

,Iq
In the future, if information is inadvertently left off of a chain -of -custody sheet, the correct procedure
would be to make a copy, fill in the missing information, and write amended cgpy at the top of the
page. An amended copy should be kept at the facility, and a copy should be sent to the laboratory for
their records.
We have not determined that any of the labs involved violated any defined protocols. Each laboratory
produced appropriate quality assurance documentation. Effluent water quality parameters measured at
each laboratory were reasonably similar.
form should have "CORRECTED COPY" written or typed at the top.
Sincerely,
Matt Matthews, Supervisor
Aquatic Toxicology Unit
c1!Sledge
11
Jennifer Jones -PACE Analytical, Inc.
Jim Sumner-Enviromnental Testing Solutions, Inc.
Central Files
Lance Ferrell
Enclosure

12
.,,� � ate.. ,. •,a .:
�'°' � �^��� r+ ., ao i� �O• �.. `,�'u =,ass ; ����� h.. „�h"")� s b t �* y�.s" s �� °�s ':a'' �^.';,
,,���: 4`., ��;:�`•.„...
� ����,�*.�z..a : � ,.fix �.3,�. k���, • � � ���� � < � �`
j I /4 sample l /4 sample l /4 sample
C �b 2111,
MAN
r� Wake certain sample is mixed between pours
1 0% Composite Sample

C %N A 7*4�� MichWel F Easley. Govern r
Williams G. Ross Jr.. Senterary
North Carolina Department of Environment and Natural Resources
Alan W, Klimek, P E. Director
Division of Water Quality
"C Coleco H" Sullins, Deputy Director
Division of Water Quality,
May 24 2004
r. Gary Sanderson
Clariant Corporation MEE Facility
Past Office Box 669246
Charlotte, Worth. Carolina 28266
Subject: Toxicity Test Results
Clariant Corporation W WTP
DES Permit NCO00437
Mecklenburg County, ty, N
Dear Mr. Sanderson:
Enclosed is a copy of the toxicity test results relative to the inspection conducted at the
subject facility on May 7, 2004 by John Lesley of this Office. Effluent samples were collected. on
May 4 and 7, ` 004 by Division staff for use in a chronic toxicity test. The test utilizing these
samples resulted in a Mass.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Mr. Lesley or me at [phone].
Sincerely,
Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Central Files
Aquatic Toxicology Unit
Mecklenburg County Dept. of Water Quality
#!"Elt—Al
N. C" Division ofWater ity, Mooresville Regional Office, 919 North Main Street, Moo e NC 2Sr r 5 [phone] Customer service
1-977-6 3- 74

Clariant (corporation WWTP
DES Permit No. NC 0 4375
Page 2
Whole effluent samples were collected on May 4 and 7, 2004 by Division staff for use in a
chronic Ceri da hnia dui is pass/fail toxicity teat. Clariant Corporation WWTP has an effluent
discharg
ge permitted at 3.9 NICK entering the Catawba River (7QIO of 329 CFS) The test using
these samples resulted in a pass. Toxicity test information follows:
Test Type 3-Brood C riodaphnia dubia pass/fail
Test Concentration 1. % sample
Test Result Pass
Control Survival 100%
Control Mean Reproduction 4."7 neonates
Test Treatment Survival 100%
Treatment Mean Reproduction 24.2 neonates
First Sample ply 7.91 SiJ
First Sample Conductivity 6530 micro os/cm
First Sample Total Residual Chlorine 0. 052 n 'l
Second Sample pH T70 SCi
Second Sample Conductivity 6574 crd os/m
Second Sample Total :Residual Chlorine <0. } 52 mgil
Test results for these samples indicate that the effluent would not be predicted to have
water duality impacts on the receiving stye

r
grit Corporation .Nit. Holly bast Plant Clariant
w,
P.O. Box 669246
Charlotte, NC 26266
Phone: 704,827.9651
April 23, 200
NC DEN ivision of Water Quality/Water Quality Section
Attention. Central Files
1617 Mail Service Center
Raleigh, North. Carolina 27699-1617
NPDES Permit Number N4CO004375 R Updates Which Include Data Collected
During BAT Study
e have been collecting additional data to update a site BAT stud} and report as required
by the NPDES permit. In reviewing the data collected during study, it was noted that portions o
the data should be included in the DMRs. Therefore, we have updated the DMRs with the
applicable data.
The updated DMRs are enclosed. Ifthere are any questions regarding this submission,
please feel free to contact me. My phone number is 74-822-2787. My email address is
sanderson clariant.co .
Sincerely;
Gary P. Sanderson, P.E.
Plant Services Manager t: DEPT. OF ENVIRONMENT
AND NATURALKSOURr.E8
MAY i 3 2004
cc Mooresville Regional Office
WAIyy "Is �

'Aichato F. EaMey, Gove� tT�t
C William G. Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
:Alan W, Kl - P.'E. Di or
-! Division ofWater Quality
Cohn H. Sullins Deputy Director
Division of Water Quality
February 19, 2004
CERTIFIED MAIL
RETURNCREQUESTED
7003 2260 0001 3491 1906
Mr. Gary P Sanderson, Plant Services Manager
Clariant Corporation
P.O. Box 669246'
Charlotte, NC 28266
Subject: Notice of Violation) - Effluent Limitations
Clariant Corporation —Nit. Holly East Facility
LIES Permit No. NCO004375`
N }V-2004-L,V-0077
Mecklenburg County
Dear Mr. Sanderson:
review of the December 2003 self -monitoring report for the subject facility revealed a violation of
the following parameter:
i i ` a Parameter Re orted Value Limit
it
001 Biochemical Oxygen Demand 822 lbs/day 810lbs/day FIN
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water Quality may pursue enforcement actions for this and any additional violations. if the
violations are of acontinuing nature, not related to operationand/or maintenance problems, and you
anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent. You may contact Richard Bridgeman of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Mr. BridgeBridgeman or me
at 704/663-1699.
Sincerely;
D. Rex Gleason, P.E.
Waster Quality Regional Supervisor
cc. Paint Source CompliancefEnforcement Unit
RMB
EN
orth arolana 13
,f [1i`1111!% i?ivision of y, 4ttxs iie ReBio 9i9 lvi ' i Iviao la 8215 (?U4} 663-i9 Service
l 7 ti2-6748

\klA�
Michael F, Easl , Governor
William G. Ross Jr.,Seorerary
North Carolina Departatent ofEnvironment and Natural Resourcea
i Alas W. Klimek, P. E. Director
� Division of Water Quality
Coleco H. SullinsDeputy Di or
Division of Water Quality`
January 13, 2004
Mr. Gary '. Sanderson, Plant Services Manager
Clariant Corporation
Post Office Sox 669246
Charlotte, North Carolina 28266
Subject: Results from Effluent Sampling Analyses
Clariant Corporation WWTP
P 1 � Permit No. NCO004375
Mecklenburg County, N.C.
Dear Mr. Sanderson:
Enclosed please find the results from the laboratory analyses performed on the effluent
samples from the Clariant Corporation wastewater treatment plant ( P). The samples
analyzed were composite and grab samples collected. during the. Compliance Sampling Inspection
performed by Mr. Wes Bell on November;'12, 2003.
e results of the sampling analyses show compliance with all permit effluent limits.
Please attach this letter to the inspection report dated November 18, 2003 to complete your
records on the inspection.
If you have any further questions regarding this matter, please do not hesitate to contact
Dell or me a [phone].
Sincerely;
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Dusty Rozzelle, MCWQP
2s t
,a NCDENR
N.C. Division of Water Quality, Mooresville Regional Offic 919 Nosih in tr Mooresville NC 2811 (704) E+63-1599 Customer Service
1-77-23-748

240
110
2.5, 14
7."74

Clariant Corporation Mt. Holly East Plant C1 a rl* a -n t
P.O. Box 669246
Charlotte, NC 28266
�"T,'PVr MF "01K
Phone: 704,827,9651 ESOURCES
111,440NAL OFFICE
January 7, 2004 Vr JAN 13 2W4
Ms. Jacquelyn M. Nowell Mr, D. Rex Gleason, PE
Division of Water Quality Division of Water Qualit$ATERQUAL =11-0
1617 Mail Service Center 919 North Main Street
Raleigh, North Carolina 27699-1617 Mooresville, North Carolina 28115
Re-. NPDES Permit Number NCO004375; Addition of New Waste Source t© the Site
Wastewater Treatment Plant
Dear Ms. Nowell and Mr. Gleason;
As required by,Section A. (7) of our NPDES permit, I wish to inform you that an
additional oastt6 wa�iewater source will begin operations on January 22, 2004. The new source
is an o water s n process that will be operated by Clariant. It is located in an operating
area of one of the old manufacturing units.
Clariant had originally contractedwith Remedial Services Incorporated, RSL of Satsuma,
Alabama for this work. Because of management problems and construction cost issues, RSI
withdrew from the contract. As a result, Clariant has decided to run the process itself
Mari will begin reporting effluent data in compliance with Tier 2 effluent limitations
and monitoring requirements effective January 26, 2004.
if there is any additional information that is needed by the Division, please let me know.
My phone number is 704-822-2787. My email address is &Yar y,sandersorj@c1ajLWnt,com-
Sincerely-,
Gary,P,' Sanderson, RE
Plant Se rvices'Manager
cc: David Goodrich-DENR, Nick Altman, Frank Rash, Erin Russell — Clariant

A Michael F. Easley, G v mar
C William G: Ross Jr. Secrete
p North Carolina Department of Environment and Natural Resources
Alan W, Klimek, P. E_, Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
December 2, 2003
Gary Sanderson
Clariant Corporation
P.O. Box. 669246
Charlotte, NC 28266
Subject. Notice of Violation Rescission
NOV- 003-L -02 7
Clariant Corporation — Mt. Holly East WWTP
NP DES Permit No. NC000437
Mecklenburg County, IBC
Dear Mr. Sanderson:
A Notice ofViolation (NOV) dated November 7, 2003 was issued for perceived.. effluent
Total Mercury limitation violations occurring during June 2003 at the subject facility.
Appropriate staff have reviewed your NOV rescission request and amended Discharge
Monitoring Report (D ) for June 2003. The amended DMR indicates that the subject
violation did not occur; therefore, the NOVis hereby rescinded. By copy ofthi letter, this
Office is requesting that our Raleigh Office remove the subject NOVfrom your tile.
Should you have any questions on this matter, please do not hesitate to contact Mr. .
Richard Bridge 'an or me at 704/663-169.
Sincerely,
D. Rex Gleason,'P.E.
Water Quality Regional Supervisor
Cc: Point Source Compliance/Enforcement Unit
RMB
NC EN
Mooresville Regional Office, 919 North Main Street, Mooresville, North Carolina 28115
Phone [phone] Customer Service
Fax [phone]

R0. Box 669246
ColariantCWPOMfion Charlotte N.C. 28266-9246
N&Allc Dke'-7r)"- OF
A
N,
e-w-
November 21, 2003
DEC,
Mr, Richard Bridgeman
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
This facility has recently received a Notice of Violation for exceeding our effluent limitation on
mercury, during June 2003. We have reviewed our paperwork and noticed that the mercury testing
results, for June 2003, were none -detected, (.0002 mg/L). This should have been reported as less -than
(<) .0002 mg/L, but were reported as .0002 mg/L, also our monthly average should have been reported
as less -than (<) .0021 tbs. instead of .0021 It I have mailed two corrected copies of the June DMR to
Central Files/ NC DENRI Water Quality Section. We are currently reviewing our mercury testing
procedures with Pace Analytical to see if we can get a test result with a lower detection limit.
I have enclosed a corrected DMR for June 2003, and a copy of our testing results for mercury from
Pace Analytical with this letter.
If you have any questions regarding this report, please contact my supervisor, Mike Rash or myself at
[phone] or [phone],
I 6L4 n (2 - U3 Lat-91,
Dwayne R.Pallace
ORC, Mount Holly East Plant
Clariant Corporation

% Michael E. Easicy, tez,
William G. Ross Jr,,
( North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
t Division of Water Quality
t "C Coleco H. Sullins, Deputy Director
Division of Water Quality
November 18, 2003
CERTIFIED IL 7003 2260 000134910701
RETURNCEIREQUESTED
Mr. Gary P. Sanderson, Plant Services Manager
Clariant Corporation
Post Office Box 669246
Charlotte, North Carolina 28266
Subject: Notice of Violation
Compliance Sampling Inspection
Clariant Corporation WWTP
DES Permit No. NC 004375
Mecklenburg County, N.C.
Dear Mr. Sanderson:
Enclosed please find a copy of the Compliance Sampling Inspection Report for the
inspection iconducted at the subject facility on November 12, 2003, by Mr. Wes Bell of this
Office. Please inform the facility's Operator -in -Responsible Charge of our. findings by forwarding
a coyly of the enclosed report. The results of the effluent sampling will be forwarded to you under
separate letter.
This report is being issued as a Notice of Violation (NOV)because ofthe limit violations
(not previously addressed by the Division) and the monitoring'violations of the sub eet NPDES
Pe " °t and North Carolina neral`Statute (G.S.) 143-215.1 as detailed in the Self -Monitoring
Section of the attached report. Pursuant to G.S. 143-21 .6 , a civil penalty of not more than
stay -five thousand doll 25,000.00) per violation, per day may be assessed against any
person n who violates or fails t ► act in accordance with the terms, conditions, or requirements of
y permit issued pursuant to G.S. 143-21 .1.
It is requested that a written response be submitted to this Office by December 9. 2 O3
addressing the deficiencies noted in the Facility Site Review/Operations & Maintenance and
Self -Monitoring Sections of the report. In responding, please address your comments to the
attention of Mr. Richard Brid em
7hCarolin
N, C. Envision of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer Service
-877-623-6748

r. fury Sanderson
Paige Two
November 18, 2003
The report should be self-explanatory; however, should you have any questions
concerning the report, please do not hesitate to contact'Mr. Bell or me at (04) 663-1 99.
Sincerely,
I. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc. Rusty Rozzelle, M WQP

United States Environmental Protection Agency Form Approved.
EPA Washington, D.C. 20460" OMB No. 204 57
Approval expires 8-31- 8
Section A; National Data §Ystem Coding i.e., PCS
Transaction Code NPDES yrtmolday Inspection Type Inspector Fac Type
"I 2 L5j 31 NCO004375 111 121 03/11/1Z 17 18U 19U5 20 LJ
Remarks
21
Inspection Work Days Facility Self -Monitoring Evaluation Muting B1 QA
67 69 70 71 U 72 U 73 74 _ 751 1 1 1 1 1 1 180
Section : FacilityData
Name and Location of Facility Inspected (For Industrial Users discharging to PO , also include Entry Ti ate Permit Effective Date
POTVV name and NPDES permit Number)
09:5C C3/iiJ'12 03/03/01
Mount Holly Rash (h?ia;E) Facility
PC Box 669246 Exit Time/Date Permit Expiration Date
^narlotte AFC 2826 C2:CC Pt� tC6/3G
C5
Names) of Onsite Representative(s)>Tkttes(s)lPhone and Fax Number(s) Other Facility Data
Dway e a WallacelCEC/704-822-4302✓
=rank gash/ t.11ltle:s Supervisor/704_822-2768i
Name, Address of Responsible l ThlelPhone and Fax Number
Contacted
Cam Saersc�n.,PU ux 66924E Charlotte NC-282661 7ii4-82-2743f` No
Section C> Areas Evaluated During inspection (Check only those areas evaluated)
permit Flow Measurement Operation, & AFai to :anc>e Records/Reports
Sell-Mo: sir ng Prngra¢n Sludge F7andl-Lag Dispersal Facility site Review Efflue=/Rece-ving waters
Section D: umma of Finding/Comments (Attach additional sheets of narrative and checklists as ne
SEE ATTA ED PAGE t S
Na (s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wesley N Bell KRO WC,'//704-563-1699'704-663-6C40 C
Signature of Management 0 A'Reviewer Agency/OffiosiPtione and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

The permit description appears to adequately describe the facility. The facility is currently
operating under the Tier 1 Permit requirements.
RECORDSCIFX
Records and reports consisting of monthly monitoring reports (DMR's), chain of custody
forms, sample analysis reports, flaw charts, sludge records, process control data,Operator-in-
Responsible Charge (ORC)/daily operation and maintenance bags, and calibration logs are
maintained in accordance to permit requirements. The facility's records were in-depth and well
organized/maintained.
A primary clarifier was off-line clue to routine maintenance and one of the secondary
clarifiers was off-line due to low flows. One of the aeration basins is utilized for flaw equalization.
The majority of the influent flow originates from third -party discharges. According to the Utilities
Supervisor, the facility is in the process of installing/constructing a system to receive oil/water
mixtures (wastewater from oil/water separators, tank farms, etc).
The facility appeared to be operating properly and surrounding grounds were well
maintained. A section of the operational primary cl 'flier's effluent trough was in need of repair.
The scum railing in secondary clarifier had missing belts at the joints and the squeegees for both
skimmer arms needed adjustment/replacement. Untreated groundwater had been discharged
behind the pump building for the groundwater treatment system during a maintenance activity.
The untreated water appeared to have migrated into the stormwater drainage system which ,
eventually discharges into the effluent canal prior to past aeration. The appropriate corrective
actions should be incorporated for the above -noted discrepancies. In addition, the Permit requires
that the facility be properly operated!and maintained at all times.
Screenings appropriately disposed. The mixed liquor appeared to be well mixed and
adequately oxygenated. The comprehensive ;process control program includes DO, pH,
settleability tests, COD,; settleable solids, MLVSS, MLS , Fratios, MCRT, and oxygen uptake
rates. Sludge wasting is based on F ratios and MCRT calculations. The facility"s records were
in-depth and well organized.
Although the facility is staffed with, appropriately certified operators, the back-up CRC
has visited the facility in 2003 in excess of twenty percent (based on a calender year). Please be
advised that the CRC and back-up OR.0 roust comply with the responsibilities/requirements listed.
in 1 A NCAC 8G.0204 and.0205(l)(a).
LABORAIQRY.-
The on -site laboratory (Certification #217) and the contracted services of Face Analytical
(Certification t 2) in Huntersville, N.C. provide analytical support. The laboratories were not
evaluated during this inspection. All laboratory field equipment appeared to be properly
calibrated d maintained. The ORC> and staff must insure that all calibration times are
documented and the pH meter readings (following standardization) are documented to verify the
meter's adjustment to the appropriate buffer.

EFFLUENIMXEIVI
.t R y.:
The effluent discharge appeared brown with trace suspendedsolids and no foam. The
receiving stream did not appear to be negatively impacted. The discharge outfall was accessible at
the time of the inspection. The results of the effluent samples collected at the time of the
inspection will be sent under separate cover.
The effluent was analyzed for the following:
pH 7.74 s.u. - DO 7.45 rng/l - temp. 17.4°E
Self - monitoring reports were reviewed for the period September 202 through august
2003, inclusive. A chronic toxicity failure was reported for December* 2002. The two follow-up
chronic toxicity tests were compliant. Monthly average effluent total mercury violations were
reported. for March, April, and June*2003 Daily maximum effluent total mercury violations
were reported on March 4 and June 3*, 2003. A monthly average effluent TSR violation was
reported for April* 2003. Note: * denotes that the violations have been separately addressed by
the Division.
No effluent total nitrogen, total phosphorus, MBAS, total manganese, total iron,
chlorides, and total mercury were reported for the month of October 2002. No effluent TSR was
reported on February 18 and 1, 2003,
The facility has not converted the sample collection and analysis for effluent total mercury
according to EPA Method 1631 effective September 1, 2003. This requirement was stipulated in
the permit cover letter dated January 27, 2003.
The noncompliance box was not checked for March 203 (noncompliant due to effluent
total mercury violations). The effluent total zinc and total chromium columns on the March 2003
DMR were listed as mgll (should be lbsida ). The effluent conductivity and total mercury were
listed as composite samples on the March h 2003 through August 2003 DMRs. The ORC indicated
that both analyses were grab samples (as required by the Permit). No effluent total mercury limit
was listed on the DMRs from March 2003 through August 2003. The same upstream d
downstream times were listed on August 21, 2003. Please be advised that the permittee and ORC
must insure that all DMRs are accurate and complete prior to sub
e ORC and staff must insure that the collection/analysis times for effluent DO and
temperature (one time if performed in effluent wastestre ) are appropriately documented.
On ten weekday occasions throughout the DMR review period, a " " was documented in
the "ORC; on -site" column. The ORC indicated that neither the designated back-up ORC" or
himself were present during those weekdays. Please be advised that the facility must insure that
either the ORC or designated Back-up ORC visit the facility as required in the Permit and 15A,
NCAC 08G ,0200.
Composite samples are collected flow proportionately. All reviewed sample analyses
(including COCs, etc.) appeared to be properly preserved and sheet the required holding times.

E QMEASUREMEINM
Effluent flaw is measured continuously by an ultrasonic flaw meter with totalizer and chart
recording. The flaw meter is calibrated 2/month by tin -site instrument calibration personnel.
The flow meter was last calibrated on 11 / 3.
SLUDGE 'DISPOSAL:
Sludge is dewalered and disused pan -site in a lined landfill cell in accordance with Permit
WQ000 )53"7. Two cells have been closed and capped. The facility is currently disposing sludge
into a lined third cell.

DEC '03 2003 16: 42 FR CLAR I ANT CORP ENGINEE 8226529 TO ?46636040 P, 1 /04
Clariant Corporation lit. Holly East Plant
P'0. Box 669246 11701 Nit. Holly Road
Charlotte, North Carolina 28 C6-9246 Charlotte, NC 29214
Plant Services Telefax Number- (704) 822-6S29
TELEFAX TRANSMITTAL
To- Richard laid
Location/Company., N P,M -- Division of'Water Oualitv
Telefax Number: 704 6t53
Number of Pages (including Cover Sheet)-
Subject Attachments to a Letter of Dec, 1 2003
From: QgMSanderson
Date: December 3 2003 Phone Number: ,(04) 8 787
Notes- Attached are three clo that were gMdv er h
sent to vou early on D "� 1 0 " e for the oversight. if there ue i
items that you wish to discus& plMto call ore ` me,
Sincerely- ....... Gary SLmAtm& flAftt-Stml er
Email. M,sandcrsonAclariant.com

DEC 03 2003 16:42 FR CLARIANT CORP ENGINES 8226529 TO ?046636040 P,02/04
Cl
+- P.U. BOX 860246 adant Charlotte N.C. 2A266
March 15, 2003
Attention, Central :Ales
Division of Water Quality
1617 Mall Service Center
Raleigh N.C. 76 1617
Attached are the February 2003 monitoring results for the Clanant Corporation, ML 'Holly facility.
NPD S Permit number NC 0004375,
During the month of February, this facility moved the location of our Ste- ter laboratory to the
effluent plant area. We were unable to sample the final discharge for Total Suspended Solids, as
reqaired by our permit, for February 18 and 19, 2003, due to the laboratory equipment not being
available. All other parameters were within required limits,
if you have any questions regarding this report, please contact my supervisor, Mike Rash or myself at
[phone] or (704) 822-422 .
D yne Wallace
ORC, Mount Holly Plant East
Clanant Corporation
r .,

DEC`03 2003 16: 2
FR CLARIANT CORP ENGINES
8226529 TO 7046636040 P.03/04
Clariant Chernical Corporation
Up/ Down Stream
Chain of
Custody
Date 4f Sampling:
21—
UPSTREAM
DOWNSTREAM
Sampled by:
a i . f UCt
..( ,q
Sampled by, -
Sample Time;
Sample Time:
Analysis Time:
C t7` f a
..
Analysis Time:
PH
pN
, C ;
Temp.
Temp.
(C)
©O:
ID ko
DO:
Conductivity:
/ r
J
'
Conductivity:
Analysis Performed by:
- - •
w
�.
r
a

03 2003 1 »42 FR.CL.ARIANT CORP EN INEE 8226529 TO "?046636040 P 04/04
Oadaft s i'.a. &X889246
N.C.Z8266
November 18, 002
Attent Cenkal Files
Division of Water Quality
1617 Mail Service Center
Raleigh N.G. 276 117
Attached are the October 2002 monitoring, results for the Clariant Co to Mt. Holly facility,
NPC) , Permit number G 0004375. t ,
Due to an operatore r, this facility did not complete monthly sari pli g fr�rOct 2002. � h`
discrepancy s uncovered Nov, 14. 2( }2 at which time this officei
e are implementing adrninistraWe 2, al b notified John L ley, N D N .
future. and will conduct additional sampling for them the likelihood of Similar n � the
If you have any questions regarding this repo
yne R, ally
ORC, Mount Nally .East Plant
Clamant Corporation
}
oath of November 2002;
Please contact my supervisor, Mike Rash or myself at
TOTAL PAG .04 ��

s.C1 ari ant
Clariant Corporation
Mt. Hotly East Plant
P.O. Box 669246
Charlotte, NC 28266
Phone: [phone]
December 1, 2003
Mr. Richard Bridgeman
Division of Water Quality
919 North Main Street
Mooresville, North Carolina 28115
PermitRe: NPDES r Dated November
Dear Mr, Bridgeman;
As requested in Mr. Gleason's letter of November 18, 2003, Clariant is submitting a
written response to the noted deficiencies in the Facility Site Review/Operations & Maintenance
and SelllMrmitormg Sections,
REVIEW/OPERATIONS& MAINTENANCE
notedThe deficiencies in this paragraph detail what are normal and routine maintenance items
disagreesthat are addressed every day in an operating facility. Clariant oes not consi er any to e
significant and vehemently
improperconsidered
paragraph. We take pride in the maintenance of our facility and contest this portion of the
1. "A section of the operational primary clarifier's e flarerrI trcrrrgh was in ncXed of repair. „
"The scum railing in secondary)) clarifier had missing bolh.v at the pints and the squeegees
v or both skimmer arms needed adjustment replacement. "
Major pieces of equipment are scheduled drawn at intervals such that all small and routine
maintenance work is done in a planned and efficient fashion. The items outlined in the
NOV are not ones that rendered the operating clarifiers dangerous or incapable of
performing the process operations they were designed for. The items are on the list of
maintenance activities to be performed at the next planned outage.
"(Intreatedgroundwater had been discharged behind the pump bitilcding,liar the
groundwater treatment syy=stone during maintenance activity. The untreated tinter
appeared to have emigrated into the stormwater drainage system which eventually
discharges into the qffluent canal pricer to past aeration.'fi

' Letter to Mt. Richard Brid eanan datedDecember 1, 2003 page
At the time of the inspection, the groundwater pumping system down: One of our
maintenance mechanics had en using clean process water to flush a vacuum d
during routine maintenance of the process equipment. Clean n water was what the inspector
saw on the ground outside the pump house. The statement that untreated ground water
was allowedto run to a stormwater`outfall is false.
Paragraph 4;
To address the requirement stated in this paragraph, we are changing working schedule of
the wastewater treatment operators is being changed effective January 1, 2004. Mr. Dwayne
Wallace, ORC, will begin working five;days s week, Monday -- Friday. This arrangement'
should satisfy the requirements of 15A, NCAC 8G .0204 and .0205(l) .
SELF-MONITORMG;
P a r l 2, 1'sentence: "No effluent total narwo en, total phosphorus, MRAS, total
manganeve, total iron, chlorides, and total mercury were reportedfor the month of October
is "
Clariant discovered this oversight in November 2002 and reported it to the Division at that time.
A. copy of the notification letter is attached, . Cl "ant installed revised t operating
procedures at that time to preclude future events.
Paragraph h , 2,d sentence: "No effluent TSR was reported on Rebruaty 18 and 19, 2003. "
This event was reported to the Division on March 15, 2003. A copy of the notification letter i
attached. The site relocated its wastewater laboratory and the equipment was out -of -service for
the two days stud to construction work,
Paragraph 3 ;
Conversion of mercury sample collection and analysis was an oversight. Both C lariant and our
contract laboratory dropped the ball: Beginning with the December 2003 sampling event,
Clariant will sample and have analyses dame in accordance with EPAhod 163 1.
Paragraph 4:
Clariant has addressed all of the items detailed in this paragraph, Each deficiency was reviewed
with the Utilities Supervisor `and ORC and administrative procedures were revised so that novae
will recur. The only item with which Clariant takes exception is Sentence . It is addressed
below.
Paragraph , sentence . a " e same upstrewn and downstream times were listed oil Augitst 21,
2003. #*
Attached is the WVV`TP log form for the two samples, Please note that the samples were taken by
two separate individuals. The fact that two persons took the samples at the same time should not
be a deficiency or violation.` Clariant does not understand this citing.

�t

Letter to Mr. Richard Bridgeman dated December 1, 2003 page
Paragraph
The' deficiencies noted in this paragraph were not ones ,ofperformance of work but of notations
on Clariant log sheets. Cl ant has always performed DO and temperature measurements in the
effluent waste stream. The time of the measurements is identical. Temperature measurements
have always been. in Celsius. The log sheets have been revised to document time and that
temperature measurements are in Celsius.
Paragraph
The ORC and back f3. C work schedules are being changed to be Monday -- Friday.
Beginning in January 20e will be fully compliant with the requirements of 15A NCAC
08G.0200
e began addressing ;deficiencies the day following the DWQ inspector's visit. Those
items dealing with deficiencies and mercury sampling and analysis were addressed with
revised administrative procedures and meetings with all of the WWTP operators. The necessary`
corrective actions were in place on November 19, 2003
The WWTP personnel work schedules are being completely revised as of January1, 2004
in order to address the deficiency of percentage of the weekdays that the ORC and backup ORC
will eon -site, This will address the deficiency of 10 flays during the last year that neither the
OC or back-up ORC was on site.
s notedin the previous pages, Clariant wishes the Division to revisit several deficiency
items listed in the inspection coon eport, We would greatly appreciate the opportunity to discuss
theseitems as we believe they are not warranted.
Sincerely,
Gary P. Sanderson, P.E.
Plant Services Manager

Annual Pollutant Analysis Monitoring Requirement
Reporting Form A
(Revised Jane 1990)
1, Facillty Information. rage 1 of 9
NPDES Permit No: Discharge (Pipe) No: 06 1 Year. 2003
Facility Name. CL t t'lass: L4 County.
Persons) Collecting Samples:
Status of facility wastewater treatment operation on day of sampling: typical: Yes No
If no, explain briefly;
Analytical Laboratory, Pace Analytical Services
11. Sampling
24 hr composite for main sample/grab sample for purgeable fraction
Date Sampled (composite sample): Corresponding sample taken for toxicity testing:
Sampling begun (date, time): (0 5 . 'es
Sampling finished (date, time); o
Bate Sampled (grab sample):
Instructions
The purpose of this document and the accompanying memo is to standardize the sampling, analysis and reporting procedures to be used for the Annual
Pollutant Analysis Monitoring (APAM) Requirement as described in the perrrut,
Sampling
1. Take a 24- r composite sample from the final effluent during mid -week (Wednesday through Friday). Collect a grab sample for the volatile organic
fraction when collection of the 24-hour composite sample is completed, Follow any other sampling instructions provided by the laboratory
perfornring'the analysis.
Z. Indicate in the space provided at the top of this page whether a corresponding sample for toxicity testing was taken.
. Make note of any unusual wastewater treatment operating conditions occurring on the day of sampling in the space provided, on the forma
Analysis
4, Analyze the effluent for pollutants listed on the APAM form, including those to be identified and: approximately quantified under the 10 significant
peaks rule, using appropriate EPA -approved methods for each of the analytic fractions, Other analytical methods can be substituted only with
prior, written approval of the Director of the Division of Environmental Management (D]E;M). Read and distribute to the laboratory performing the
analysis the accompanying memo (Tedder, October 19 0) clarifying analytical requirements.
5, identify chenucals to be analyzed for according to the 10 significant peaks rule (as described in item 2 of the Annual Pollutant Analysis Monitoring
Requirement in the permit) using a GC/MS library search. Tentative identification is all that is required, confirmation by standard injection is not
necessary. Estimate the concentration of each based on an internal standard having the closest retention time.
Reporting
6. Qtantitation Limit Targets that should be met are listed on this Revised APAM Reporting Form A. Report the use of any higher quantitation limit
and an explanation as to why the listed quantitation limit target could not be met. Examples of acceptable reasons for not meeting a quantitation
limit target could be high background concentrations in a ssrnple,, or the necessity for sample fraction dilution to bring a chemical to within a
quantifiable concentration. List any quantitation limit different (whether higher or lower) from the target in the column provided for this purpose,
7. If a chemical is found to be below the quantitation limit, report the concentration detected as less than (or<) the quantitation limit in the appropriate
space. Provide a concentration estimate for chemicals detected in concentrations greater than the detection limit and less than the quantitation h"mit.
Enter the detection limit in parentheses beside the estimate, Chemicals detected in concentrations above the quantitation limits must be quantified.
Quantitation limit and detection limit are defined in the accompanying memo (Tedder, October 1990). Enter the total number of peaks detected in
each analytic fraction in the appropriate space on this Revised APAM Forma A. Report all concentrations in units of micrograms per liter (ug/1) and
metals as total recoverable metal. If no peaks to be identified under the 10 significant peaks rule are observed, enter "none" in the space provided
for "other" compounds in each appropriate analytic fraction section. Provide the concentration estimate and retention time for "unknowns" as well
as for "significant peaks" for which a structural assignment can be made.
5. If "significant peaks" are found, provide probable molecular weight library match probability, retention time, identification basis, and MS scan
number for each, In addition, list internal standards and their retention times,
9° In the section labeled "Organic Analytical information" (p.9), include for each organic fraction the method, extraction technique, GC operating
conditions, and surrogate recovery. Report the size of the GC/MS library being utilized in the appropriate space.
10. Use copies of this :Annual Pollutant Analysis Monitoring Revised Form A to report the results of the analysis, Both the analytical laboratory
representative and the facility operator is responsible charge should sign completed forms (last page).
11. Mail two completed copies of the form (and the laboratory report, if submitted to the facility on a different form) to: AT`TN: Central Files, Division
of 'Environmental Management, NC DEHNR, P.O. Box 29535 Raleigh. NC 27626. Mail the APAM form separately from Discharge Monitoring
Renorts.

NOV 0 4 21
CENTRALF1

,..... ". r°
I
w i' 1010011
+per
• r«
OEM
W01=31
I
,u
d x i
M w w w -p
MOM;
r
r
* if difference from quantitation limit target
ILIA = Not Analyzed

2. tither purgable (up to 10 highest peaks) Page 3 of
r b tm Lib. Match Retention Identification Basis
Compound Mole® Cone. Prob. Time (RT) Lib. Manual Scan
(ug/L) (0) (Min Match Interpret. RT Number
None
Complete only if non -target compounds are present;
Retention
Internal Standard Time IRT
in)
Bro ochloromethane
1,4-Difluorobenzen
hlorobenzenewd5
0 Q

V U 4ZW

'8270 Page 4 of
0
�r
i • �Ga w'
M •t _ w
S!
M
- w
* If difference from quantltation limit target

CENTRALFILES

2. Other acid extractable (up to 10 highest peaks)
Page a of 9
Prob
E
Retention Identificattion Basis
Copouncf
Bole.
Corac.
NUb.atch
b Time (RT C.ib Manual
scan
(u '11_)
Min Math Interpret. RT
Number
Trifluorometl laniline isomer
16
90 5.509 x
327
Unknown
107
8.39
716
Complete only if non -target compounds are present:
Retention
Internal Standard
Time (RT)
in
1,4-Dichlorobenzene-d4
5 1
Na thlene-d6
6.67
cena thene-d10
9e221
Phenanthrene-d10
11.677
Chrysene-d12
16.
P lene-d1
1 &67

r,ENTRAL FILM

2m Other base/neutrals (p to 10 highest peaks)
Page 7 of
Prob Est. Lib. Match Retention Identification Basis
Compound
Mole. Conc.
Probe
Time (Ri)
Lib.
Manual ±
Scan
wt. (o IL)
N
(Min)
Match
Interpret. RT
Number ;
None
Complete only if non -target compounds are present,
Retention
Internal standard
Time (RT)
(Min)
1,4-®iehloroben ene$d4
5.31
Na thalenemd8
6.67$
Acena thene-dlt7
9.221
Phenanthreneadl9
11.67
Ch ene-dl2
16.32
Pe len-d12
18.672

C,F
.grRAL FILeS

Organic Analytical Information
Rage
9 of 9
Organic Fraction
Extraction
GC Operating Conditions
Surrogate Spikes
Method
Column Description
i3atrh Continuous
length X ID, Film Thickness,
Compound Recovery
Column Type, Carrier Gas & Flow
%
Rate, Tam aratura iro ram
Purgeable 624
X
, &W DS-624, 60 m x 0.26 mm 10
DBFM
98%
Nahum, 1 mUmm
Toluene-d8
97%
4 min @ 40 C, to 220 C @ 6 Clmin, 4.6 min
BFB
102%r
Acid Extractable 8270
X
Aw D86 , 30 m x 0.26 mm id
-FIB
%
Nellum,l.0 mUmin, 1.75 min !!j 40 C, to 130 C
Phenol-d6
2%
* 35 Cfmin, to 330 C L412 Clmin, 7 min
2,4,6-TBP
6%
BasaiNeutral Extractable 8270
X
AW D85-MS, 30 m x 0.26 mm id
NitroBen -d8
40%
Heliu ,1,0 mUmin,175 min a 40 C, to 130 C
-FBP
4%
36 c1t in, to 330 c @ 12 Cfmin, 7 min
Te hen l-d14
23%
GUMS Library size number of referencespectra): Method 624.40,000 Method 625 - 75,000
F. Metals and Other Chemicals
Number of Metals and tither Chemicals as listed below detected In Sample
4
Fraction STORET Number 78240
STORET Compound
Quantitetion Quantitation
Concentration
Number
Limit Target Umit*
Detected
1. Pollutants to be anal `ed for,
u fl u !L
a JL
1104 Aluminum
50
100
<100
1097 Antimony
50
50
<50
1002 Arsenic
10
10
<10
1012 Be Iium
25
25
<25
1027 Cadmium
2
2
c2
1034 Chromium
5
5
<5
1042 Copper
2
2
19
1051 Lead
10
10
<10
71900 Meru
0.2
0.2
<0.2
1067 Nickel
10
10
15
1147 Selenium
5
5
<5
1077 ISilver
5
5
<5
1092 lZinc
10
10
<0
2. Other inorganics:
1077 Barium
500
500
<500
40 Chloride
1000
1000
310000
720 C anide
20
20
<0
951 Fluoride
100
100
670
" If difference from quantitation limit target
Analytical Laboratory Representative:,
Signed:
Date:
r o
"
9
Facility Operator in Responsible Charge (CRC):
I cerfify that this report is accurate and complet
o e best of my knowledge,
Signed. '.
Date:le '

iNA-rMichael F. Easl
C; William G. Ross 3a
j North Carolina Department of Environment and Natur
Alan W. Klimek-, R
Division of W
Coleen H. Sullins, Dep
Division of W
November 7, 2003
CERTIFIED MAIL
RETURN RECEIPT D 70012510 0004 8286 4934
Mr Gary Sanderson
Clariant Corporation
P.O. Box 669246
Charlotte, NC 2266
Subject: .Notice ofViolation - Effluent Limitations
Clariant Corporate — Mt. Holly East Facility
DES Permit No. NCO0 43 5
NOV-2003-LV-0257
Mecklenburg Coty
Dear Mr.Sanderson:
A review of the June 2003 self -monitoring report for the subject facility revealed violations of the
following eter-
11' a Pa meter Re acted Value Limit
001 Total Mercury 0.0421 lbs/day U.0016 lbs/day FIN
001 Total Mercury 0.0021 lbs/day 0.0005 lbs/day FIN
rated should be taken to correct any problems. The
nt actions for this and any additional violations. If the
o operationand/or maintenance problems, and you
Consent. You may contact Richard Bridgeman of this Office for additional info - tion.
If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgeman or me
at 704/663-1699.
Sincerely,
3" 0
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc: Point Source Compliance/Enforcement Unit
Wi3rNR
Mooresville Regional Office, 919 North Main Street; Mooresville, North Carolina 28115
Phone [phone] Customer Service
Fax [phone]Q 1-877-623- 748

Ciariant Corporation
August 13, 2003
s. Jacquelyn M. Nowell Mr. D. Rex Gleason P.E.
Division of Water Quality Division of Water Quality
1617 Mail Service Center 919 North Main Street
Raleigh, North Carolina 27699-1617 Mooresville, North Carolina 2811
Re: NPDES Permit Number NGU004375; Addition of.New Waste Source to the Site
Wastewater Treatment Plant
Dear Ms. Nowell and Mr. Gleason;
s required by Section A. (7) of our NPDES permit, I wish to inform you that an
additional on -site wastewater source will begin operations on or about September 4, 2003. The
new source is an oily water separation process that will be operated by Remedial Services,
Incorporated of Satsuma, Alabama.
Accordingly, Clariant will begin reporting effluent data in compliance with Tier 2
effluent limitations and monitoring requirements in the permit.
If there is any additional information that is needed by the Division, please let me know.
M phone number is 704- 2-2787. My email address is gar sig rsoti &1L1!iria �.���n1.
Sincerely;
/ 1 OA P
'Z�z
Gary P. Sanderson, P.E.
Plant Services Manager
David Goodrich-DENR, Nick Altman, prank Rash, Erin Russell — Clariant

EFFLUENT
RMIT NO. NCOOO-4375 DISCHARGE NO. 001 MONTH J NE YEAR 2003
4AME CLARIANT COR QRATION CLASS IV COUNTY MECI LENBURG
R IN RESPONSIBLE CHARGE ( RC) DWAYNE R. WALLACE GRADE IV PHONE [phone]
CS ANALYTICAL SERVICES
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NPDe
FACIL
3 NO. _NC0004375 DISCHARGE NO. 001 MONTH JUNE YEAR 2003
STREAM
LOCATIO
CLARIA T -CORPORATION COUNTY MECKLENBURG
IBA _RIVER STREAM -CATAWBA RIVER
[WAY _27BRIDGE LOCATION HIGHWAY 74 -BRIDGE
Upstream Downstream
EWA
on
KOWN
WIN
0M
ANN
LEW
WE

EFFLUENT
NP# ES PERMIT NO, NC0004375 DISCHARGE NO, 001 MONTH JUNE YEAR 2003
FACILITY NAME CLARIANT CORPORATION CLASS IV COUNTY MECKLENBURG
OPERATOR IN RESPONSIBLE CHARGE (ORC) DWAYNE R. WALLACE GRADE IV PHONE. [phone]
CERTIFIED LABORATORIES (1) CLARIANT
CHECK BOX IF ORC HAS CHANGED PERSONS) COLLECTING SAMPLES CLARIANT WWTP OPERATORS
Mail ORIGINAL and ONE COPY to:
NC DENRI DIVISION OF WATER QUALITY/ X
WATER QUALITY SECTION (SIGNATUR F ORC) DATE
ATTN: CENTRAL FILES BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
1617 MAIL SERVICE CENTER ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE
RALEIGH, NC. 27699-1617
M
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Case 1: River Flaw < 175 cfs
8005 + 0.54 NH3 < 566.4 lblday
Case 2. River Flow 17 -2 0 cfs
8005 + 0.54 NH3 < 1044 lb/day
Case 3: River Flow > 250 cfs
B005 + 0.54 NH3 = not applicable

Pace Analytical Services, Inc.
JJ. 9800 Kincey Avenue, Suite 100
aneAnalyticale
Huntersville, NC 28078
Phone: [phone]
www.pacelabs.com Fax:[phone]
June 17, 2003
Mr. Mike Rash
Clariant Corporation
PO Box 669246
Charlotte, NC 28266
RE. Lab Project Number: 9244960
Client Project Ill: Monthly Effluent
Dear Mr. Rash.
Enclosed are the analytical results for sample(s)'received by the laboratory June 3, 2003through June 6, 2003
Results reported herein conform to the most current NELAC standards„ where applicable, unless otherwise narrated
in the body of the report.
If you have any questions concerning this report, please feel free to contact me.
Sincerely.
Brenda Pathammavong
[e-mail]
Project Manager
Enclosures
f
Laboratory Certification I s REPORT OF LABORATORY ANALYSIS Ubgr3tory Certifikation IQa
C Wastewater 12 LA Wastewater 04034
NC Drinking Water 377C This report shall not be reproduced, except in fold, VA Drinking Water 21
Sc 99006 without the written consent of Pace Analytical Services; Inc. FL NELAP E87627
y y A,4

Pace Analytical Services, Inc.
9800 incey Avenue, Suite100
j 1,
ci 14"n Vic a
unfersvrlle, NC 28078
Phone. [phone]
www.pacelahs.rom
Fax: [phone]
Lab Project Number:
9244960
Client Project ID:
Monthly Effluent
Lab Sample No 923013999
Project Sample Number: 9244960.001 Date Collected: 06/03103 06:55
Client Sample ID: FINAL COMPOSITE
Matrix: Water
Date Received: 06/03/03 11:00
Parameters
Results
' !!nits Re Tort Limit Analyzed By
CAS No. 01 RgALmt
Metal s
Trace ICP Metals
Prep/Method:
/ EPA 200.7
Chromium
ND
mg/l 0.0020- 06/1 /03 07:31 LBG
7440-4 -
Zinc
0.040
g/l 0.010 06/13/03 07:31 LBO
7440-6 -6
Date Digested
06106/03
06/06/03
Wet Chemistry
Total Kjeldahl Nitrogen
Method: EPA
351.2
Nitrogen, Kjeldahl, Total
4.3
g/l 0.10 06/06103 ALA
Nitrogen, Nitrate/Nitrite
Method: EPA
353.2
Nitrite as N
0,36
g/1 0.050 06/03/03 ALA
Nitrate as N
27.
mg/l 0.050 06/03/03 ALA
Phosphorus, Total
Method: EPA
365.2
Phosphorus
0.120
mg/1 0.0200 06/06/03 WWB
7723-14-0
Date: 061I 103
Paqe. i or 1
r
� � �.
t borate ertif loon Ili
NC Wastewater 1
LA Wastewater 0404
SIC Drinking Water 370
This report shall not be reproduced, except in fuli,
VA Drinking Water 1
99006ytical
without
Services, Inc.
the written consent of Pace AnalSc
L NELAP E6767

Dace Analytical Services, Inc.
9800 Kfncey Avenue, Suite 100
r� j untersilie, �l 28978
A11 a U Gil Phone- 704,875.9092
www.paeelabs.com Fax:[phone]
Lab Project Number. 9244960
Client Project ID: Monthly Effluent
Lab Sample No: 923014005 Project Sample Number: 9244960-002 Date Collected: 06/03/03 07:10
Client Sample ID: FINAL GRAB Matrix: Water Date Received: 06/03/03 11:00
Parameters Results Units e art Ltmit Anal Zgo ByCAS o. QUal Re Lmt
Metals
Mercury. CVAA , in Water Method: EPA 245.1
Mercury ND mg/l 0,00020 06/10/03 LRG 7439-97.6
Date: 06/17/03 Page: 2 of 11
LoArAVU Cer l i ation !D REPORT F LABORATORY ANALYSIS #motion !
C Wastewater 12 This report sh!l not be reproduced, except in full,LA Wastewater 04034
A Drinking Water 21
NC Drinking Water 37706g
C 06 without the written consent of Pace Analytical' Services, Inc, FL NELAP E87627

✓ Ana Vic
ale
to w acalo, cvm QUALITY CUNT
Pace Analyt;
9800 Kincey
Hun
Phi
Lab Project Number: 9244960
Client Project ID: Monthly Effluent
QC Batch: 75455
Analysis Method: EPA 245.1
QC Batch Method: EPA 245.1
Analysis Description. Mercury, CVAAS, in Water
Associated Lab Samples:
923114005
METHOD BLANK: 923025761
Associated Lab Samples:
92301405
Blank Reporting
Parameter
Units
Result Limit Footnotes
Mercury
mg/l
NO 0.0002'
LABORATORY CONTROL SAMPLE: 923025779
Spike LCS LS
Parameter
Emits
Conc. Result Rec Footnotes
Mercury
mg/l
0.0050 0.0052 103'
MATRIX SPIKE & MATRIX SPIKE
DUPLICATE:
923025787 923025795
93157231 Spike MS MSD MS MS
Parameter
Units
Result Conc. Result Result Rc X Rec
RPD Footnotes
Mercury
mg/l
0' 0.0050 0.0061 0.0058 121 116
5
SAMPLE DUPLICATE: 923025803
931578157 OUP
Parameter
Units
Result Result RPD Footnotes
Mercury
mg/1
NO NO NC
Data: 06/ 7103
Page: 6 of 11
CertificationLgboratory IDs
REPORT O LABORATORY ANALYSIS
Laboratory ertct �� � iDs
C Wastewater 12
LA Wastewater 04034
NC Drinking Water 37706
This report shalt not be reproduced, except in full,
VA Drinkin Water 13
SC 9900
without the written consent of face Analytical Services, Inc.
FL NELAP E87627
4y aceny�

Pace Analytical Services, Inc.
9800 Kinsey Avenue, Suite 100
f /�
l�luntersvrlle, 28978
aneA/
naw.pacelabs.co(
Phone:
QUALITY CONTROL DATA
04,875.909
Fax. 7t?4.875.9119i
Lab Project number:
9244960
Client Project ID:
Monthly Effluent
QC Batch: 75356
Analysis Method: EPA 200.7
QC Batch Method:
Analysis Description: Trace ICP Metals
Associated Lab Samples:
923013999
METHOD BLANK: 923018162
Associated Lab Samples:
93013999
Blank Reporting
Parameter
Units
Result Limit Footnotes
Chromium
mg/l
NO 0.0020
Zinc
mg/l
ND 0.010
LABORATORY CONTROL SAMPLE: 923018170
Spike LCS LCS
Parameter
Units
_ Conc. Result X Rec Footnotes
Chromium
mg/l
0,2500 0.2600 104
Zinc
mgll
0.2500 0.2620 105'
MATRIX SPIKE & MATRIX SPIKE
DUPLICATE:
923018188 923018196
92301546 Spike MS MSD
MS MSD
Parameter
Units
Result Cone. Result Result
Rec Rec RPD Footnotes
Chromium
mg/l
U.00074 0,2500 0.2600 0.2630
104 105 1
Zinc
mg/l
0.1860 0.2500 0.4390 0.4460
101 104 2'
SAMPLE DUPLICATE: 9230180
923012553- DUP
Parameter
Units
Result Result RPD Footnotes
Chromium
mg/l
NO n1 NC
Zinc '
mg/l
0.3000 0.3000 : 0
hate. 06/17/03
Page: 7 of 11
Labors L.Certification
REPORT O LABORATORY ANAL
CWastatory ertifleat�0
NC Wastewater 12
This report shall not be reproduced, except in full,
34
LA Wastewater 04034
VA Drinking Water 1
NC Drinking Water 3770
37706
without the written consent of Pace Analytical Services, Inc,
FL NELAP E87627
C
N s�

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
anaifllcal
neA
Huntersville, NC 28078
www.paeelabs.com
QUALITY CONTROL DATA
704.875
PhoneFax.,: ,9092 704.875.9091
Lab Project Number:
9244960
Client Project ID:
Monthly Effluent
QC Batch: 75335
Analysis Method: EPA 365.2
QC Batch Method: EPA 365.2
Analysis Description: Phosphorus, Total
Associated Lab Samples:
923013999
METHOD BLANK: 923016786
Associated Lab Samples:
923013999
Blank Reporting
Parameter
Units
Result Limit Footnotes
Phosphorus
mg/l
NO 0.0200
LABORATORY CONTROL SAMPLE &
LCSD: 923016794 923016802
Spike LCS LCSD LCS LCSD
Parameter
Units
Conc, Result Result Rec Rec
RPD Footnotes
Phosphorus
mg
O,5000 0.5300 0.5300 106 106
0
MATRIX SPIKE: 923016810
923008114 Spike MS MS
Parameter
Units
Result Conc. Result V Rec Footnotes
—
Phosphorus
mg/1
2.000 5.000 2.300 6 1
SAMPLE DUPLICATE: 923016828
923008122 DUP
Parameter
Units
Result Result RPD Footnotes
Phosphorus
mg/1
0.4700 1.180 86 1
Oate: 06/17/03
page: 8 of 11
Laboratory Certiftaf1Qg_IQ5
REPORT OF LABORATORY ANALYSIS
LakrqWMQ grtiftion �ID
NC Wastewater 12
LA Wastewater 04034
NC Drinking Water 37706
This report shall not be reproduced, except in full,
VA Drinking Water 213
SC 99006
without the written consent of Pace Analytical Services, Inc.
FL NELAP E87627

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
Huntersville, RUC 28078
aceAnaj yficaj
w . pacelabs. cam
QUALITY CONTROL DATA
l�l�v:7o4.8 .9 z
Fax: [phone]
Lab Project Number: 9244960
Client Project ID: Monthly
Effluent
QC Batch: 75313
Analysis Method: EPA 353.2s
QC Batch Method: EPA 353.2
Analysis Description: Nitrogen, Nitrate/Nitrite
Associated Lab Samples:
923013999
METHOD BLANK: 923016158
Associated Lab Samples:
923013999
Blank Reporting
Parameter
Units
Result Limit Footnotes
Nitrite as N
mgll
NO 0.050
Nitrate as N
mgll
ND 0.050
SAMPLE DUPLICATE: 923016190
923006506 DUP
Parameter
Units
Result Result RPD Footnotes
Nitrite as N
mgll
8.300 0
Nitrate as N
mgll
NO NC
Date: 06/17/03
Page: 9 of ii
Ubo r rtif tion l a
R LABORATORY ANALYSIS
� aboratory Certificati I
NC Wastewater 1
This report shall not be reproduced, except in full,
LA Wastewater 04034
VA Drinking Water 213
NBC Drinking Water 37706
without the written consent of Pace Analytical: Services, Inc.
FL NELAP E87627
Sc 9 0006
,x nor.°ao

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
xneAnaHuntersville,
ycal
N 2807`8
I
.pacelabs.com
QUALITY CONTROL. DATA
Phoax.704.87 .9091
Fax., it74.8.9(79f
Lab Project Number: 9244960
Client Project ID: Monthly Effluent
QC Batch: 75551
Analysis Method: EPA 351.2
QC Batch Method: EPA 351.2
Analysis Description: Total Kjeldahl Nitrogen
Associated Lab Samples:
923013999
METHODBLANK.:' 923029201
Associated Lab Samples:
923013999
Blank Reporting
Parameter
Units
Result Limit Footnotes
Nitrogen, Kjeldahl, Total
mgfl
NO 0.10
LABORATORY CONTROL SAMPLE: 923029219
Spike LCS LCS
Parameter
Units
Conc. Result % Red Footnotes
Nitrogen, Kjeldahl, Total
mg/l
10,00 9.570 96
MATRIX SPIKE & MATRIX SPIKE DUPLICATE:
923029680 92309698
9230144 Spike Ms MSD- MS MSD
Parameter
Units
Result Conc. Result Result R c Rec
RPD Footnotes
Nitrogen, Kjeldahl, Total
mg/l
1950 10.00 1910 1920 0 0
1 2,2
SAMPLE DUPLICATE: 92302970
923013999 DUP
Parameter
Units
Result Result RPD Footnotes
Nitrogen, Kjeldahl, Total
mg/l
4.300' 4.400 2
Date: 06/17/03
Page: 10 or 11
labor tort' Certification IN
REPORT OF LABORATORY ANALYSIS
Labor t4rY ertification IC?s
NC Wastewater 12
LA Wastewater 04034
NC Drinking Water 3770
This report shot[ not a reproduced, except in foil,
VA Drinking Water 213
Sc 9900fi
without the written consent of Pace Analytical Services, Inc.
FL NELAP E137627
lktl ABC

Pace Analytical Services, Inc.
} / / 9800 cey Avenue, Suite 10
G 1 I unter Dille, NC 28078
Phone. [phone]
www.pacelabs.com Fax; 704.875,9091
-Lab Project Numbers 9244960
Client Project ID: Monthly Effluent
QUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with CPA guidelines, unrounded concentrations are displayed and have been used to calculate Rec and RPD values,
LCS(D) Laboratory Control Sample (Duplicate)
MS(D) Matrix Spike (Duplicate)
DP Sample Duplicate
ND Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL' Adjusted Method Detection Limit
RPD Relative Percent Difference
Ell A matrix effect was present.
L2I The spike recovery was outside acceptance limits for the MS and /or MS due t matrix interference. The LES
and/or LCSD were within acceptance limits showing that the laboratory is in control and the data i
acceptable.
[fate: 06/17103 Page. 11 of 11
."aboratry Certification IN LABORATORYlb_oratory.Certification Is
C Wastewater 12 REPORT OF LA Wastewater 04034
NC Drinking Water 37706 This report shall not be reproduced, except in full, VA prinking Water 213
Se 99006 without the written consent of Pace Analytical Services, Inc. FL NELAP E87627
� x aeco7
a

Pace Analytical Services, Inc.
9800 Kincey Avenue, Suite 100
acienai1 ! ytica# Huntersv111e, SIC 8078
/� Phone: [phone]
www.pacelabs.conr Fax. 704.875,9091
Lab Project Number. 9244960'
Client Project ID- Monthly Effluent
PARAMETER FOOTNOTES
Inorganic Wet Chemistry Analyses were performed at our Pace Asheville laboratory and Organic and Metals
testing was performed at our Pace Charlotte laboratory unless otherwise footnoted.
NO Not detected at or above adjusted reporting limit
NC Not Calculable
J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit
MDL Adjusted Method Detection Limit
pate: 06/17/03 Page. 5 of 11
boa story Certification IE"►�1' I TIC AI� Laboratory eriification 1D5
NC Wastewater 12 LA Wastewater 04034
NC Drinking Water 3770
This report shall not be reproduced, except in full, VA DrinkingWater 213
c 99006 without the written consent of Pace Analytical Services, Inc. FL NELAP E87627

[ nal ica - the Chain -of -Custody is a LEGAL DOCUMENT Ali relevant fields must be completed accurately.
w.pacelabs.com Re ulred Client Information: Section B. 71,9291
Report $: /
Required Client Information: Section ,t { � �) '� Qx � i, of To Be Completed by Pace Analytical and Client Section
Com pY/ r Copy To: Quote Reference:
Client Information Check cote/contract):
Add { Invoice T :. p } Requested Due Date: TAT: Project Manager;
RO,
Turn around Mimes less than 14 days subject to Project #:
laboratory and contractual obligations and may result in a
Project Na j/ Rush Turnaround Surcharge, Profile is
Ile • / ,�� Turn Around Time (TAT) in calendar days.
fiJeo Project Namber:Requested Analysis:
Section Required Client Information_ Va1ld Matrix Codes — cs, Ct Preservatives }
IlkATRIX gOPE __ w w #xt
WATER WT w w ul
p gyp py ff
S A M P L E SOIL St `� w w * i
/
WIPE wp 0 0 -6 r'
iPiE character per box. AIR AR c as c s#
III {A-, 0-9 TISSUE Tissue T°� t °}
Sample ICES MUST BE UNIQUE orb (�R _ or mm tdd t yy hh:mm alp X � � z z c� , Remarks I Lab l
! i It r f tf FW ` rr i 7° t
i A3 6
— — — — — — — — — — — +
P
y .
•.. I�RP t ►JIIME AND EGNAT t

Michael F. Easley, Governor
{ William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. F., Director
a,. { Division of W ater Quality
Ir
rJ
Coleen H. Sullins, Deputy Director
Division of Water Quality
November 7 2003 j
CERTIMED MAIL
RETURNCE TED N
OV
Mr. Gary Sanderson
Cl Pant Corporation
P.O. Box 669246 _ ... .
Charlotte, NC 2826
Subject: Notice of Violation - Effluent nt Limitations
Clar ant Corporation — Mt. Holly East Facility
DES Permit No. NCO004375
NOV"-2003-LV-0257
Mecklenburg County
Dear Mr. Sanderson:
A review of the .tune 2003 self -monitoring report for the subject facility revealed violations of the
following parameter:
Pie Parameter Reported Value Limit
001 Total Mercury 0.001 lbs/day 0.0016 lbs/day FIN
001 Total Mercury 0.0021 lbs/day 0.0005 lbs/day FIN
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water {duality may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operationand/or maintenance problems, and you
anticipate remedial construction activities, then you may Wish to consider applying for a Special Order by
Consent. You may contact Richard Bridgeman of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Mr. Bri geman or me
at 704/6634699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc; Point Source Compliance/Enforcement Unit
RMB
t�O ERR
Mooresville Regional Office, 919 North Main Street, Mooresville, North Carolina 28115 Customer Service
rnn ­i c-?AQ

Michael F. Easley, Governor
{ William Cr. Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
C3 Coleen H. Sullins, Deputy Director
Division of Water Quality
October 22, 2003
21
Mr. Cary P. Sanderson
Clariant 'Corp. - Mount Holly Plant
P.O. Sox 66924
Charlotte, NC 8288-9248
SUBJECT: Laboratory Certification Maintenance inspection
Dear Mr. Sanderson.
Enclosed is a report for the inspection performed on August 29, 203 by Mr. Chester
E. Whiting. Where deficiencies are cited in this report, a response is required as well as for
all lettered comments and/or recommendations. Within thirty days of receipt, please supply
this office with a written item for item description of hew these deficiencies, comments
and/tar recommendations were corrected. if the deficiencies cited in the enclosed report are
not corrected, enforcement actions will be recommended. For certification maintenance,
your laboratory mint continue to carry out the requirementsset forth in 1 aA NCA H
.0800.
Copies of the checklists completed during the inspection, may be requested from this
office. Thank you for your cooperation during the inspection. if you wish to obtain an
electronic coov of this re ort bv email, or if you have questions or 'need 'additional
information please contact us at 919-733-3908.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
Chester E. Whiting'
Mooresville Regional Office
N. C. Division of Water Quality Laboratory Section 1623 Mail Service Center Raleigh; North Carolina 27699-16 3 [phone]
FAX: [phone]

ON -SITE INSPECTION REPORT
Laboratory Name. Clariant Mount Holy
Laboratory; Address; P.O. Box 669246 Charlotte, NC 28266
Laboratory Cert. Number: 21
InspectionType:: Fallow U
Inspection Date: August 29, 2003
Inspector(s): Chet Whiting
Local Contact rsons). Mr. Sam Hill
1. INTRODUCTION:
CTIONA
The above named laboratory was inspected to verify compliance with 15A N AC 2 .0800 for
the analysis of environmental samples:
11. OVERVIEW:
The laboratory was neat and well organized. Laboratory personnel provided the inspector(s) with
all materials, and information requested for examination. Some improvements were noted in
laboratory documentation. However there were areas that will, require improvement as well. One
area is observing the nature of the samples and adjusting analytical technique accordingly. A
specific instance can be observed in TSS analysis section` below. Sample volume must be
adjusted.
Ill. DEFICIENCIES, REQUIREMENTS, COMMENTS, AND RECOMMENDATIONS:
GENERAL Btu OTO:
A. COMMENT: Some cross out and overwriting corrections were observed on laboratory data.
REQUIREMENT: Overwriting, cross out, correction fluid, and pencil entries are unacceptable for
laboratory documentation. All entries are to be made in permanent ink.
Corrections are to be made as follows:
1) Draw a single line through the error:
) Make the correction near the error, or in a corresponding margin.
3) Initial the correction. .
B. COMMENT: The laboratory needs additional documentation regarding the preparation of
standards and reagents. We recommend the creation of a reagent / standard prep. log book.
This should include but not be limited to the following information.

Page
Clarlant Mt. Holly
a) The date, the analysts initials, the chemical vendor, the analysis, the lot # standard
certification I.D. (if pertinent), date received, expiration date (if pertinent), preparation
information.
) All standard information, BOO G A, Chlorine standards, Ammonia standards, TSS check
standards for example, and any other chemical reagent prep. information needs to be
centralized in a single location.
) Purchased reagents such as pH buffers should be logged in when received and when
opened. In the past this information was recorded on reagent bottles. wince bottles are not
retained for to period of five years (document retention requirement) this is not adequate:
AMMONIA NITROGEN:
COMMENT: Dilution factors are recorded in the final answer column on the laboratory bench
sheet. This crowds the data entries. There is a blank column on the beach sheet that can be
used to record dilution factors (recommendation).
TEMPERATURE AND DISSOLVED OXYCENW
C. COMMENT: The facility is not currently certified to perform these parameters. Please submit
the appropriate documentation requesting certification for temperature and dissolved oxygen
analyses. The farm to amend a certification application is available at the Laboratory web site,
htt-pil>w L . LD
D. COMMENT: ENT: DO and temperature samples are returned to the lab for analysis.
Temperature and dissolved oxygen (DO) readings are to be taken instantaneously.
Temperature and DO do not posses the limited stability of pH and Total Residual (chlorine. If
the sample is not easily accessible, for example as from a well or from a bridge, a container
may be used to procure a sample and then the measurements are to be taken immediately.
SOLIDS JaS
1. DEFICIENCY: In some instances the sample volume was not adjusted in order to obtain a
I mg weight difference and the reported value was not adjusted to reflect a less than value.
REQUIREMENT: Adjust the filtration volume (where necessary), or adjust the reported value to
indicate that insufficient volume was filtered to achieve a 1 mg weight change.
In some cases additional volume must be filtered for this analysis In order to obtain at least 1
mg of solids on the filter. The accepted sensitivity of the balance is 1 mg, based on this criteria
less than a 1mg weight change for 100 mis of sample filtered the value reported would be less
than 10 mg/L. When sample volumes are changed, the analytical reporting limit` must be
changed to reflect the detection limit achieved. For example if 1 liter of sample was filtered and 1
mg was not obtained the result would be reported as c 1 mg/L, if 500 mis was filtered the result
would be < 2mg/L. It appears that the character of the effluent has changed so that less solids
are present. If the amount of sample filtered does not produce 1 mg weight change be sure that
the reported value reflects the volume filtered as stated in the examples above. As with other

Page
Clarint Mt: Holly
analyses observation of the sample should provide: a fairly accurate indication of the volume to
be filtered. Remember to be flexible and adjust filtration volume to reflect the sample condition,
REQUIREMENT: The laboratory must revieTSS data from at least June 2003 and adjust the
values to accurately reflect analytical results. Amended DMRs will then need to be submitted.
COMMENT: The laboratory stated that slow filtration was a problem, even though ;insufficient
weight change was being obtained. There are larger filtration apparatus available to replace the
gooch crucible system used in the laboratory at this time.
CHEMICAL OXYGEN DEMAND:'
E. COMMENT: COD values reported on the DMR'seem to come from both grab and composite
samples. The conditions of the permit specify which values are to be reported. It is most likely
the composite value. grab samples collected at the permit designated sample site must be
reported on the DMR in space provided elsewhere on the document. If grab samples are used
for process controls make sure they are not collected at the permit designated sample location.
Process control samples not taken from the permit designated sample location do not have to be
reported on the DMR.
BIOCHEMICAL OXYGEN DEMAND:
COMMENT: The chlorine testis performed monthly. The effluent is not chlorinated/de-
chlorinated. However, since the waste is complex' industrial waste with variable characteristics,
we feel that it would be advisable to conduct this test; daily. (Recommendation) Deference:
Standard Methods 181 Edition 5210 B 4 (d) (3).
DATA REVIEW:
General laboratory records and documentation was reviewed. Data and DMRs from may, June
and July 2003 were reviewed. No items other than those specified in the above report were
observed.
IV. CONCLUSION:
Correcting the above cited deficiencies and/or comments and implementing the
recommendations will help this lab to produce quality data and meet certification requirements.
Please respond to all numbered deficiencies and lettered comments.
Report prepared by. Chet Whiting Date: October 6, 2003

Subject: NCO004375
Date: Mon, 22 Sep 2003 1 :04: - 4 0
From:` Charles Weaver <[e-mail]
Organization: NCB DENt DWQ
o: Richard Bridge to Rich rd rid erla @, elrl ilmn t
Mercury limit of 0.000 lbs/day would not display correctly in BIMS.
Recreated paragmeter using daily max only with g"Manual review" footnote
to capture monthly average.
V
1 of 1 9/22/0310: 7 M

_�375/Mccklenburg Co.)
PFFF
Subject: . Clariant 3 Co.
Date: Tue, 16 Sep 2003 07:5 :I J -t 400
CharlesWeaver <[e-mail]
Organization: NC DENR DWQ
o: Richard Bridgeman <Richard.Bridgeman@ncmaiInet>
The monthly average mercury limit has been added. Thanks for catching
this one.
HW

PFFp"'75/MecklenburgCo.)
Subject: Clariant (TWO004,Y751TYlecMenburg Co.j
Date: Mon, lib Sep 2003 14:44: 6 -04 0
From: Richard Brid er ian, <[e-mail]
Organization: NC DENR - Mooresville Regional Office
To: Charles Weaver <[e-mail]
RIMS Permit Monitoring/Limits folder does not reflect bath Monthly'
Average and Daily Maximum limits for Mercury; the Monthly Average limit
5s missing.
Richard Bridgemah - [e-mail]
%TITLE%
North Carolina Dept. of Environment & Natural Resources
Div. of Grater Quality
919 N. Main St.
Mooresville NC 28115
Ph: ('704) 663-16 9 Fax: [phone]
Richard Brill entan <Richard.13nidgeman ng nail et
Enviromnental Chemist TI
NC l l - Mooresville
Div. of Water'Quality
1 oft 9/16/03 :06 AM

Michael F. Easicy. Govem,.
` William G. Ross Jr., Socretary d
..IDLL
" Notts Carolina DeNrtnien, ofEnvironmcnt a d Natural Resources
" Alan Al. Klimek, P. E.. Director
- ~ ' Division of Water Quality
Col' n H, Sullins, Deputy Director
Division of Water
August 8, 2003
CERTIFIED MAIL
RETURNCEI 17ESTED
Mr. Gary Sanderson 7001 2510 0004 8286 6617
Clariant Corporation
P.C. Box 669246
Charlotte, NC 2266
Subject: t. Notice of Violation - Effluent Limitations
Clariant Corporation -- Mt. Holly East Facility
NPDES Permit No. NCO00437
Mecklenburg County
Dear Mr. Sanderson:
A review of the April 2003 self -monitoring report for the subject facility revealed a violation ofthe
following parameter:
Pi
.jm Parameter Reoorted Value Limit
001 Total Suspended. Solids 418.8 lbs/day 410.0 lbs/day FIN
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of "hater Quality may pursue enforcement actions for this and any additional violations. if the
violations e of a continuing nature, not related to operationand/or maintenance problems, d you
anticipate remedial construction activities, then you may wish to consider applying for a Special Girder by
Consent. You may contact Richard Bridgeman of this Office for additional information.
f you have questions concerning this after, please do not hesitate to contact Mr. Bridgeman or me
at 7041663.1699:
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Point Source Cornpli nforcm t Unit
RMB
Mooresville Regional Office, 919 North Main street, Mooresville, North Carolioa 28115
Pinme; 704- 6a -1 99
Fax [phone]ti 1-8 i -62 5748

State of North Carolina
Department of Environment and Natural. Resources
Division of Warr Quality
19 North Main Street Mooresville, North Carolina 28115
February 2, 2003
CERTIFIED MAIL
MTURN RECEIPTO STED
70012510 0004 8287 8061
sanderson
orporation-Mount Holly East
i9246
North Carolina 28266
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Te
NPI ES Permit No. NCO00437
Mount Holly East WWTP
Mecklenburg County
Dear Mr. Sanderson:
This is to inform you that a reviewof your toxicity
You should take whatever remedial action
sting
elf -monitoring report form for the month of
n specified in your NPDES Permit.
tes provide for assessment of civil
1699.
Sincerely,
D. Rex. Gleason, P.E.
Regional Water Quality Supervisor
cc: Aquatic Toxicology Unit'
Central Files

,E EFFLUENT TOXICITY MONITORING AND RE.
rutted to:
North Carolina Division of W
Central Files
1617 Mail Service Cer
Raleigh, NC 27699-1,
IN ADDITION
city test data (original "AT" form) must be submitted to th(
Environmental
1621 Mail Se:
Raleigh, North Ca;

7"
Michael F. Easley
Governor
jWITtarn G. Ross, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Kfirnek, P.., Director
Division of Water Quality
January 30, 2003
Tony Franco
Consultant
DuCharme, McMillen & Associates, Inc.
2 C?',I ay Dill Read., 2nd floor
Windsor, CT 06095
SUBJECT: Tax Certification
No. TCS-VIV-1 I I
Wastewater Treatment Facilities
Clariant Corporation, Mount :Molly
East
)ES No.NC 00 3"75
Mecklenburg County, North Carolina
Dear Mr. Franco:
Attached are two, (2) copies of Tax Certification Number TCS- -I 11 covering the
operation of wastewater treatment facilities as specified in the subject NPDES Permit issued by
the North Carolina Environmental Management'Commission.
d Company may use this Certification; to obtain benefits in keeping with the
appropriate Statutes.

Petoskey
,is for
M19
North Carolina 28236-6819
INrLjrlzi 11
Mecklent
Certification to obta
)n of these treatmeni
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
NMENR
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 PHONE [phone]
1800 623-7748 FAX [phone]

FFV
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
LEIGII
TAX CERTIFICATION
(Franchise/privilege; Amortization; Property)
1n accordance with the provisions of'the General Statutes of North Carolina (. S. 105-122(d,
1t 5-130.10, 105-`14"7(13), 105-2'75($)}, this is to certify that:
Clariant Corporation
Mount Holly East
Mecklenburg County
HAS BEEN ISSUED
NP1 ES Permit No. NCO0043 '5 for the discharge from and the operation of wastewater
treatment facilities consisting of the Following:
1- Two stormwater equalization basins for non -alkaline w tewater(total volume 2.51 G);
- Two storrnwater equalization basins for alkaline wastewat r(total volume 3.5 MG);
- Two pH neutralization tanks and one slurry tank,
4- Two primary clarifiers;
5- 4.5 MG wastewater equalization :basin;
6- 2.5 MG aeration basin;
7- Two secondary clarifiers,
4- effluent polishing al;
9- Staged discharge facility, including 360 MG effluent holding basin with post aeration;
10-'Two sludge bolding tanks;
11- Two sludge dewatering belt presses, and
12- Pumps, piping and controls pertinent to the listed facilities.
The wastewater treatment facilities are located at the Cl t-Mt. Holly facility, NC Highway
27, :Northwest of Charlotte, Mecklenburg County. Treated effluent is dischargedinto the
Catawba River.
The Environmental Management Commission and the Department of Environment and Natural
Resources have found that the treatment facilities:
Page Two

a. Have been constructed or installed;
b. Comply with the requirements of the Commission;
C. Are being effectively operated in accordance with the terms and conditions of the
Permit, Certification of
Approval, or other document of approval issued by the
Commission; and
d. Have as their primary rather than incidental purpose the reduction of water
pollution resulting from the discharge of wastewater.
Issued at Mooresville, No Carolina this the 30'h day of January, 2003 by the directive of the
No Carolina Enviromnental Management Commission and the No Carolina Department of
Environment and Natural Resources.
D. Rex Gleasag/,-P.E.
Water Quality Regional Supervisor
Mooresville Regional Office

December 23, 2002
to cry OF awwwaff
Mr. Rex Gleason
NCDENR
Mooresville Regional Office
Division of Water Quality
919 North Main Street
Mooresville, NC 2811
RE: Tax Certification
Clariant Corporation, Mount Holly East
Mecklenburg County, Charlotte
Clear Mr. Gleason:
I have attached a copy of the NPDES Permit NCO004375 and a list of the assets
associated with this permit. We request tax certification for the assets on the
attached list.
If you should have any questions you may reach me at 860-683-1900 or you can
contact Gary Sanderson, P.E., at the Mount Holly East facility at 704-822-2787.
Sincerely,
on ranco
Consultant
cc Russ Panetta
Cary Sanderson
Dave Meinika
Bart Burger
200 Day 11111Road, nd Floor * Windsor, CT 6095 860-68 -1900 Fay:: 860-683,018 s + ran ew.ctmainc.com

State of North Carolina
Department of Environment
and Natural ResourcesMilo
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
y*
Alan. W. Klimek, P.E., Director i
September 11, 2002
r. Gary Sanderson SEPi
Clariant Corporation }
PO Box 669246
Charlotte, NC 28266
Subject: NPDES Draft Permit
NPDES Permit NCO00437
Clariant Corporation -Mt. Holly East Plant
Mecklenburg County
Dear Mr. Sanderson:
The Division received Clariant Corporation an addendum to the application for a new National
Pollutant Discharge Elimination System (NPDES) permit on August 21, 2002. The Division of
Water Quality has prepared a draft permit for your review.
Please review the draft permit carefully. Check to insure that the facility information is correct,
including address and location.
The following modifications have been made to the draft permit:
• Effluentlimitations for BQD, S day and Total Suspended Solids have been modified based
on the revision of waste flows used for development of the allocations for OCPSF, non
categorical and centralized waste treatment waste streams. Effluent limitations have been
reduced due to a smaller flow (neat design capacity) being used for allocation development.
The application support document submitted by Clariant describes the allocation process.
• Tiered limitations have been placed in the permit. Tier 1 limits- are effective for existing
wastewater sources„ Tier 2 limits become effective when any addition wastewater sources
are added.
The effluent limitation for NH3 as N has been revised slightly downward to a mass based
limit of 618 lb/day (monthly average) and 927 lb/day (daily maximum). In the past, the
NH3 limit has been allocated based on secondary treatment of the effluent discharge;
• Monthly monitoring for manganese, sulfates, chlorides, MBAs and iron has been reduced
to quarterly monitoring based on the results of a reasonable potential analysis that
indicated that the NC water quality standard would not be violated by the effluent
discharge. A limitation is not required but due to the nature of the discharge, effluent
monitoring is still required.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1 C1 7 -TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr,state,nc.us/NPDES

Permit Nu: ber: N OC1C74 iS
• Monthly monitoring for chromium and zinc have been added to the permit based on new
wastewater streams from Seaboard Container Cleaning and. SCR -Tech that indicate their
presence:
• Effluent limitations for total nitrogen and total phosphorus have added to the permit based
on the Catawba River Basin Management Plan for nutrient protection in the Lake Wylie
watershed, These are interim limits based on current information from the facility.
• A special condition has been added to the permit that will require that Clariant will conduct
a BAT study for the development of more accurate nutrient limits in 2003.
• Mercury continues to be a water quality concern throughout North Carolina. Holders of NPDES
permits have worked with the state to reduce potential risks from this pollutant, including tasks
associated with collecting and reporting more accurate data. The most commonly used laboratory
analysis (EPA Method 24.1) has a detection limit of 0.2 ug/L while the current water quality
standard an order of inagnit de dower at 0,012 ug1L.,. A more recently approved analytical cast .
(E "A Method 1 31) should produce a detection limit below the level of the standard. This will allow
the Division to assess potential w'atef'qu�ility impacts=from discharges more accurately. Therefore.
be innin on or, before e tember 1,;2',003, you will be're aired to e n usm EPA Method 1631
when analyzing :fors mercury.:.
• Lnstrearn monitoring for BOID,5, and NH3 have been deleted based on review of data,
showing no impact on water quality in the CatawbamRiver.
The Division -will hold the comment period -'open for 30 days: During this time the Division
wiU
accept comments from you or your representative, the public and other agencies. This is your
opportunity to comment on the provisions of the permit.
Please provide comments you have regarding this draft permit to DENR - DWQ NPDES Unit no
later than October 11, 2002, Concurrent with this transmittal, the Division is also publishing
a notice in the newspapers having general circulation in the Mecklenburg County, soliciting
public comment on the draft permit:
Following the 0-day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuance of the final permit:
Parts The "boilerplate" language is considered standard conditions and cannot be changed to
represent individual facilities. The requirement to include standard permit conditions verbatim
or by reference is stipulated in 40 CFR 122.43. Language is interpreted appropriately for each
facility.

` Permit Number: NCO004375
if you have any questions concerning the draft permit for your facility, please call me at (919)
733-5033, extension 512:
Sincerely,
Ja elyn N well
NP S`Unit
cc: Mooresville Regional Office/Water Quality Section
EPA Region,FV/Attn. Roosevelt -Childress
Neel Piss--./ Aware Environmental Inc. 9305 J" Monroe Road,; Charlotte NC 70- i 490-
DEH
Aquatic Toxicology',
Central Files=
NPDES File

Permit Number: NC 004375
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIC)'NAL POLLUTANT DISCHARGE ELIMINATICiN SYSTEM
In compliance with the provision of North. Carolina General Statute 143-21 .1, ether lawful
standards and regulations promulgated and adopted by the North Caroling. Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Clariant Corporation
is hereby authorized to discharge wastewater from a facility located at
Clariant-Mt. Holly East
NC Highway 2
Northwest of Charlotte
Mecklenburg County
to receiving waters designatedas the Catawba. River in the Catawba River Basin in accordance "
with effluent limitations„ monitoring requirements, and other conditions set forth in Parts I, Il,
III and IV hereof,
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on :Tune 30, 2005.
Signed this day
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the
Environmental Management Commission
1

J
rll j x t_y
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«� �,`i"` a�g"�':� *.., r�x .*ri �` aa�`" 't y �( � #. P '..; - A t rf +� e� •t P ����..��
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r ��,,,,,.. �- .,.,. 1 y I rt # ? _ t ...•.;;, r ,{...,+. �i,, tt ., f : {.:.
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�.ta t ~
5{ rav'"`�.w,.�,„,4 r `"�'^c t.t` .�.. .✓ ti .is °"'iy v r"' JFrT"" 0:
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Facilit-
Facility Information
s
Location
t.acitttcle: 36"16'46"` Sib-Sasiw 03.08-<31 �
Lougqude; 81000' 2"
Quad # F15SCV
i react Class. S-Iti } Clariant Corporation
17., l', ICt}t1 13i
R�-,r•n:.=rnn:. fit rc':F rn •:. �.tt; 4U}«t �i tG'cY. . '. `"

Permit Number: NCO004 75
SUPPLEMENT TO PERMIT COVER SHEET
Cl ri nt Corporation
is hereby authorized to:
1. Continue operation of a 3.9 MGD wastewater treatment plant with a discharge through
outfall 091 consisting of the following treatment units
• 2.5 MG star ester equalization basins for non -alkaline wastewater;
15 MG stormwater equalization basins for alkaline wastewater;
pH neutralization tanks; -1 , ONE IeE 7 rj
two primary clarifiers; .%
• 45 MG wastewater equalization basin,
25• MG aeration basin;
two secondary clarifiers, v
effluent polishing canal,
ii staged discharge fa ility'in luding 360 MG effluent holding basin and post aeration;
sludge holding tanks; and
« sludge dewatering belt presses.'
The facility is located- at�the lariant-Mt. Holly East facility, NC highway 27, Northwest
of Charlotte, Mecklenburg County, and;
2. Discharge treated. OC;P F, centralized waste treatment (CWT) and non -categorical
irldustr al process wastewaters frOrri said facility at th'e location specified on the
attached reap through outfall 001 into the Catawba River, which is classified W -1V CA
waters, in the Catawba River Basin.
13020iraftPermit
2

Permit Number: N O004375
•
li«�
� k
« • -
V
lw
• �
we +
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w
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81ao 1
w • •.w .w •
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115.0 lb/day
M
w. ;,
• ..
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ll .
•
I
divi
w w
Monthly
{
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winosite
« -
13
w« w
®Composite
ample locations: E- Effluent, I- Influent, U-upstream at NC Highway 27, D-downstream at I-85. Upstream and
wnstrearn samples for dissolved oxygen, temperature, conductivity and pH shall be collected three times per
eels during June, July, August and September and once per week during the remaining months of the year.
7e pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
hronic Toxicity, refer to Section A(3).
taging requirements (applicable April 1-October 31) — Refer to Section A(5).
e Total Nitrogen limitation is 444A lb/d and Total Phosphorus limitation is_32.5 lb/d based on a 12-month
riling average. Refer to Section A(4),
ee Sections A(2)b and A(2)e.
ee Sections A( )c and A(2)f
shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit Number; NCO004375
.) . TIER 2 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
•ing the period beginning upon addition of future wastewater sources and lasting until
irat on, the Permittee is authorized to discharge treated OCPSF, CWT and non -categorical
trial process wastewater from outfall 001. Such discharges shall DC h tied and
ed b the Peritte ass ecified below:
EFFLUENT LII'I'ATIC7NS MONITORING UIREMENTS
•ND
4-
REQ
PM
�,
485.0 lb/day
Saw
II
IYI
V
•
f s ..
' • •
1.
• r•
Conductivity
•
MI
M
• . M , e . _
- •below for4nhu A Vk� a
I�' II���
• ..
•
�•�
Y be _ ; g
i�'*
.Mercu
art ...
M . •������Quarterly
RIMBRIMEM ME
mple locations: E4 Effluent, I- Influent, U-upstream at NC Highway 27, D-downstream at I-85. Upstream and
wnstream samples for dissolved oxygen, temperature, conductivity and pH shall be collected three times per
rek during Junk:, July; August and September and once per week during the remaining months of the year.
.e pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
ironic Toxicity, refer to Section A(3).
aging requirements (applicable April I -October 31) -• Refer to Section A(S).
ie Total Nitrogen limitation is 444A lb/d and Total Phosphorus limitation is 32.5 lb/d based on a 12-month
Iling average. Refer to Section A(4).
se Sections A(2)b and. A(2)e:
^e Sections A(2)c and A(2)f,
shall be no discharge of floating solids or visible foam in other than trace amounts.
4

t Permit Number: NCO0043i
When an approved analytical protocol with the appropriate minimum detection level is followed and a result of "non -
detectable" or "below quantitation 't" is obtained, the permittee will be considered to be in compliance with the
numerical permit limit for that pollutant.

Permit Number: NCO0043 r
EN'TS
TION A( ). EFFLUENT LIMITATIONS AN IJ MONIT© NG Q I
ing the period beginning on the effective date of the permit and lasting until expiration, the
nittee is authorized to discharge OCPSF and Centralized Waste Treatment (C T) related
Tess wastewater from outfall serial number 001. Such discharges shall be limited and
Litored by the Perittee as specified below.
i.TION A( )aw Tier I OCPSF parameters
t 6t .• i3 i if
6# f i 9 '
.. 3 i#tl'
ii t
4
e'
a
e
m
19'�i�lil
up r i�I
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•
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it
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6

Permit Number: NCO004375
SECTION A(2)c. Tier I Combined OCPSF and CWT Parameters
Bis(2-ethythexyl) primaiate
I.:)z
V.-�o
---j
----
-
To—tal Chromium
—
14.15
5.69
Monthly
-;Eo—mposite
E
Total Copper
16.98
7.30
Annually
E
Tlu®rant—hene
—0.
—37 (i.14
Annually
Grab
E
Total Lead
3.64
1.69
Annually
Composite
E
-- - -
T-ot-TN--ic�kel.,
22-35
9-33
Annually
CompositeComPosite—
E
T,oitl —Phenol
—
268
0-83
Monthly
----�Z—nthly
Grab
-To—mposite
E
—E
Total — —Zinc —
13-19
1-46
8

Permit Number: N O004;3
'Pier 2 OCPSF Parameters
I
i e a pe p•'
w s a s • _
± - eo ♦
t
pa a s
®w i� i •
1 `
iml W.{.. IF }
fyly4.
f i f . , � ..
� : •
� it it
'1
1 I`
i ii
661I
' f
yr
r
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Ire f i
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'i q Si�l�
f
i
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�� 4
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i f ifmli tl
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1
0

Permit Number: NCO004375
SECTION A(2)f. Tier 2 Combined O PSF and CWT Parameters
Bis(2-ethylhexyl) phthalate 2.08 U2 Annually Grab
Total Chromium 17.60 T I O Monthly composite
Total Copper 24.6 8.88 Annually Composite E
Fluorantliene 0.51 0.20 Annually Grab E
Total Lead 4.75 2.26 Annually Composite E
Total Ni kel 31 7 12.9 Annually Composite E
Total Phenol 8.25 2.48 Monthly Grab E
Total Zinc 16.12 6.97 1 Monthly composite I E
Motes ­feir_ 0C F,and CW" 1 "Poi- m &tern.
1' Should- any annual mo4itorin result in detection of an QCPSF' paraxrseter contained in 40 CF°R 414
Subpart 1( xctudin metals) or C T parameter contained in 40 CFR 437 Subpart fi, then quarterly monitoring
wilt be in immediately for � the detected pararrieter(s). ,After fo i.consecutive quarterly samples resulting in'non-
detection are achieved, the monitorin frequency will revert to, annually.
Wh en an approved analyticat protocol w, ith the appropriate minimum detection level Is fcilto ed and a result of
"nova -detectable" or "below quantitation limit" is obtained: the..permittee will be considered to be in compliance
with the numerical permit; limit for that pollutant.
11

a Permit leer; NCO004375
A(3). CHRONIC TOXICITY PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
C"eriodaphnia dubia at an effluent concentration of 1.9%.
The permit holder shall perform at a minimum, ug artery monitoring using test procedures outlined in the "North
Carolina Ceriodaphnira Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent
versions. The tests will be performed during the months of March June September and December. Effluent
sampling for this testing shall be performed at the N DES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as
described in "North Carolina Phase II Chromic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions.''
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
io
concentration aving,no detectable inmpairmenC of reproduction or survival and'the lowest concentration that does
have detectable -impairment of reproduction or survival. The definition of "detectable iiripairmen , collecticri
methods', exposure regimes, and further statistical methods are specified in the "North Carolina Phase 11 Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February I998 or, subsequent versions.uent
All toxicity testing results: required as part ofthis permit condition will be entered on the Effluent Discharge
Monitoring Farm (MR-1), for the months in which tests were performed, using the parameter code TGPaB forthe
passlfail results and T P3B for the Chronic'Value. Additionally; DWQ Form AT-3 (original) is to be sent to the
follovn address.
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic "Toxicity Test Farms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shalt be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
pernmittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow"
in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include
alternate monitoring requirements or limits:
NOTE. Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction; and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
_12

Permit Number: NCO004375
A(4). TOTAL PHOSPHORUS AND TOTAL NITROGEN MONITORING
The Per ittee shall calculate a 2-month rolling average mass loading as the sung of monthly loadings, according
to the following equations:
(1) Monthly Average (lbs.fday) = TP x, Qw x 8.34
where:
TP = the arithmetic average of total phosphorus concentrations (mglL) obtained via composite samples (either daily,
weekly, or monthly average values) collected during the month
w = the average daily waste flow (MGD) for the month
8.34 = conversion factor, from; (mg1L x MGD) to pounds
The 12-month rolling average mass loading is defined as the sum of the monthly average loadings for the previous
12 months inclusive of the reporting month:
12
(2) 12=Month Mass Loading'(Ilbs.ld y TPma 1` (inclusive ofreportin month)
Where fit.
TPma is defined as the total phosphorus monthly averagepass loading (calculated above).
Total Nitro en is to be calculated-usingthe same method.
The monthly average and 12-month average mass loadings;shall-be-reported on the attached worksheet and
submitted with the discharge monitoring report for Clariant Corporation. The first workshdet is due with the
discharge monitoring report, 12 months from the effective date of the total`phosphorus and total nitrogen limits. In
the interim pdriod betwden the.", effective data and the requirement to subit_the attachedvorkshddt, the total
phosphorus and total nitrogen monthly average mass loadings should be reported on the discharge monitoring report
for the respective facility.
The Permittee shall report the total phosphorus and total nitrogen concentrations for each sample on the discharge
monitoring report. Reporting of and compliance with the phosphorus and nitrogen limits shall be done on a monthly
basis.
A( ). COMPLETION OF BEST AVAILABLE TECHNOLOGY STUDY
The pennittee shall be required to perform a study which determines monthly average limits for total phosphorus
(TP) and total nitrogen (TN) which can be met through the application of best available technology (BAT) that is
economically achievable. The study shall be based on 12 months of effluent monitoring data collected from January
1, 2003 to December 31, 2003. The BAT study report shall be submitted to the NCDWQ for approval by July 1,
2004 and the division will apply BAT limits for TPandTN to the ermittee's discharge based on the results of this
study and the performance of other similar plants. The TP and TN limitations shown in A(I) are interim limits
which shall remain in effect until the BAT study is completed and BAT limits for TP and TN are established by the
Division.
A( ). STAGING REQUIREMENTS (APPLICABLE APRIL I - OCTOBER 31)
The operating day runs from 7:00 am to 7:00 am. Each day, the permitted will calculate a running daily average
stream flow as: determined by turbine operation at Mt. Island Lam, leakage at the dam (0 cfs), and the 7Q10 flow
of Dutchman's Creek (15 cfs). Effluent release is to be controlled such that projected release of BOD and ammonia,
using the most recent analytical values for these parameters, will not exceed the value given in the following
formulas:
(1) When the daily river flow is calculated to be < or = 175 cfs: BUDS + 0.54( H3-N) <- .4
(2) When daily average river flow is calculated to be > 175 cfs but < or = 250 cfs: BUDS
O 54(NH3-N) <= 1044 lb/day
3

Permit Number: NCO004375
tached additional DMR sheet shall be used to monitor compliance with BOO and NH3
g requirements during the summer (April 1 - October 31)
Additional DMR Sheet for Clariant-Mt. Holly East
EFFLUENT
S Permit No. NCO004375 Discharge Month Year
nt Class 4 Mecklenburg County
for in Responsible Charge (C RC):
.ed Laboratory:
Person(s) Collecting Samples.
Check if ORC; his changed
l certify that this report is accurate and complete
to the best of my knowledge.
Actual: ._
)D+.54NH3 Camp?
lb d Case DUM
d (dly max)
dly max)

Permit Number: N O004:375
SECTION A.(7.) Effluent Pollutant Scan '
The permittee shall perform
n annual pollutant
scan of its treated effluent for the
following parameters:
Ammonia (s N)
Trans-1,2-dic lomethylene
Bis (2-chloroethyl) ether
Chlorine (tonal residual, TRC)
1,1-dichloroethylene
Bis (2•chtoroi opropyl) ether
Dissolved oxygen
1,2-dichloropropane
Bis (2-ethythexyl) phthalate
Nitrate/Nitrite
1.-dichlompmpylene
4-bromophenyl phenyl ether
Kietdahl nitrogen
Ethylbenzene
Butyl benzyl phthalate
Oil and grease
Methyl bromide
2-chloronaphthalene
Phosphorus
Methyl chloride
4 chlorophenyl phenyl ether
Total dissolved solids
Methylene chloride
Chrysene
Hardness
1,1,2,2-tetrachtoroethane
Di-n-butyl phthalate
Antimony
Tetrachloroethylene
Di-n l phthalate
>
Arsenic
__ :�. , Toluene
cen
C3rirh)anthrae
zo(a
Beryllium
1,1;1-trichloroethane
1.24ch robenzene
Cadmturn
10;2-trichloroethane
1,3 d chioroben ene
Chromium
Tdchloroethylene.
1,4-dlchlorobenzene
Copper
Vinyl chloride
3,374chl6robenzidine
1 ead
: ,Acid-exfracfabie compounds.
Diethyl phthalate
Mercury
P-chloro-m-ereso
Dimethyl phthalate
Nickel
2 chlorophenot
2,4-dinitrotoluene
Selenium :.
2,4-dichlor6phenol
2,6-dinitrotoluene
Silver
2A4=dl p0ylphenol
1,2-diphenythydrazine
Thallium
4;6-dinitro-0-cresol
Fluoranthene
Zinc
2;4-dinitrophenot
Fluorene
Cyanide
2-nitrophenot
Hexachlorobenzene
Total phenolic compounds
4•nitrophenol
Hexachlorobutadiene
Volatile Wank ggWunds.
Pentachlorophenol
Hex chlorocyclo-pentad ene
Acrolein
Phenol
Hexachlomethane
Acrylonitrile
2,4,6-trichlorophenol
Indeno(1,2.3-cd)pyrene
Benzene
Base-neufrai compounds.'
Isophorone
Bromoforrn
Acenaphthene
Naphthalene
"
Carbon tetrachloride
Acenaphthylene
Nitrobenzene
Chlorobenzene
Anthracene
N-nitrosodi-n-propylamine
Chlorodibromomethane
Benzidine
N-nitrosodimethylamine
Chloroethane
Benzo(a)anthracene
N-nitrosodiphenylamine
2-chloroethylv'rnyt ether
Benzo(a)pyrene
Phenanthrene
Chloroform
34 benzofluoranthene
Pyrene
Dichlorobromomethane
Benzo(ghQperylene
1,2;4-trichlorobenzene
1,1-dichloroethane
Benzo(k)fluoranthene
1,2-dichloroethane
Bis (2-chloroethoxy) methane
The total set of samples analyzed during the current term of the permit must be
representative of seasonal
variations.
Samples shall be collected and analyzed in accordance with analytical methods approved
under 40 CFRPart 13.
?
Unless indicated otherwise, metals roust be analyzed and reported as total recoverable.
>
Test results shall be reported to the Division in D Q Form- DMR-PPA l or in a form
approved by the Director,
within 90 days of sampling.
A copy of the report shall be
submitted to each the NPDES Unit and the Compliance
and Enforcement Unit to the
15

` Permit Number: NCO004375
following address: Division of Water Quality, Water Quality Section, , 1617 Mail Service
Center, Raleigh, North Carolina 7699-1617.
Clariant W WT P Nutrient Worksheet
DES .Permit NCO00437
Reporting Month:
Beginning Month.: (Month 1
Ending Month: (Month 12)
Monthly Average Monthly Average
Total Nitrogen Total Phosphorus
ibslday lbslday
Month 1
..... H
Month ._ _ .. , v
Month 3
Month 4'
Month 5i
Month £>'
1vlont T
Month g
Month ....
Month .10 _.. _... .
Month 11
Month 1
-Month Mass
Loading;
E=
Note: The TN and TPmass loadings for the current reporting month
should be entered for Month 1.
1

PART I
(Continued)
3 Schedule of Qompliance
)ermittee shalt comply with Final Effluent Limitations specified for discharges in accordance with
tllo . g schedule:
iittee shall; comply with. Final Effluent Limitations by the effective date of the permit
;s specified below.
ittee shall Pat all times provide the operation and maintenance necessary* to operate the existing
ies at op 'mum efficiency.
ater than 14 calendar days following a date identified in the above schedule of compliance, the
ittee'shall submit either a report of progress or, in the case of specific actions being required by
ified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall
e the cause of noncompliance, anv remedial actions taken, and the probability of meeting the next
Jule requirements.

Part II
Page ? of 11
fa. b. "Mize "average weekly concentration," other than for fecal coliform bacteria, is the stun; of the concentrations
of all daily ;discharges sampled and/or measured during a calendar week (Sunday/Saturday) on which dairy
discharges are sampled and measured' divided by the number of daily- discharges sampled and/or measured
during such week'(arithmetic mean of the daily concentration values). The daily concentration value is equal
to the concentration of a composite sample or in the case of grab samples is the ari etic mean (weighted
by flow value) of all the samples collected during that calendar day, The average weekly count for fecal
This
coliform bacteria is the geometric mean of the counts for samples collected during a calendar week.
limitation is identified as "Meekly Average" under "Other Limits" in fart I of the perrnit.
c. The "maximum daily concentration" is the concentration of a pollutant discharge during a calendar day. Y
only one sample is taken during any calendar day the concentration of pollutant calculated from it is the
Itma. ' u Dails, Concentration". It is identified as "Daily hLasi um" under "Other its"" in Part I of the
permit.
d. The "average annual concentration," ether than for fecal coliform.. bacteria, is the sum of the concentrations
of all daily discharges sampled and/or measured during a calendar year on which daily discharges are
sampled and measured divided by the number of daily discharges sampled anal/or measured du6ng such
year (arithmetic mean of the daily concentration values). The daily concentration value is equal to the
concentration of a composite sample or in the case of grab samples is the arithmetic mean (weighted by flow
value) of all the samples collected during that calendar day. The average yearly count for fecal coliform
bacteria is the geometric mean of the counts for samples collected during a calendar year. This limitation is
identified as "Annual Average" under "Other Limits'" in Part I of the permit.
e. The "daily average concentration" (for dissolved oxygen) is the minimum allowably amount of dissolved
oxygen required to be available in the effluent prior to discharge averaged over a calm day, If only one
dissolved oxygen sample is taken over a calendarday, the sample is considered to be the "daily average
concentration" for the discharge. It is identified as "daily average in the text of Part I.
f. The "quarterly average concentration" is the average of all samples taken over a calendar quarter. It is
identified as "Quarterly Average Limitation" in the teat of Part I of the permit.
g, A calendar quarter is defined as one of the following distinct periods: January through Nlarch, April through
Julie, July through September, and October through December.
7. Other 11leasu e-menu
a. Flow, (MCiD): The flow limit expressed in this peinzit is the 24 hours average flow, averaged monthly. It is
deterniined as the arithmetic mean of the total daily flows recorded during the calendar month.
b. can "instantaneous flow measurement" is a measure of flow taken at the time of sampling, when both the
sample and flow will be representative of the total discharge.
c, A "continuous flow measurement" is a measure of discharge flow from the facility, which occurs continually
without interruption throughout the operating hours of the facility. Flow shall be monitored continually
except for the infrequent times when there may be no flow or for infrequent maintenance activities on the
flow device.
. Tyt>es of Samples
a. Composite Sample: A composite sample shall consist of:
(1) a series of grab samples collected at equal time intervals over a 24 hour period of discharge and
combined proportional to the rate of flow measured at the time of individual sample collection, or

Part II
Page 4of11
1. b. 'I1ae Clean Water Act provides that any person who violates a permit condition is subject to a civil penalty
not to exceed $25,000 per dal- for each violation. Any person who negligently violates any permit condition
is subject to criminal penalties of $2,500 to $25,000 per day- of violation, or imprisonment for not more than
1 year, or both. Any person who knowingly violates pernuit conditions is subject to crizz taal penalties of
$5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or bath. Also, anv
person who violates a permit condition may be assessed an administrative penalty not to exceed $10,000 per
violation with the maximum amount not to exceed $125,000. [Ref. Section 309 of the Federal Act 33 U.S.C.
1319 and 40 CFR 122.41 (a)]
c. Under state law, a civil penalty of not more than ten thousand do ($10,000) per violation may be assessed
against any, person who violatesor fails to act in accordance with the terms, conditions, or requirements of a
pe 't, [Ref: North Carolina General Statute's § 143-215.6A]
d. Any person may be assessed an administrative penaltyby the Administrator for violating section 301, 302,
306 307, 308, 31 , or 405 of the .act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of the act. Administrative penalties for Class I violations are
not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to
exceed $25,000. Penalties for Class II violations are not to exceed $16,000 per day for each day during
which the violation continues, with the maximum amount of any Class II penalty not to exceed $125,000.
I7utt' to l�Iitit�ate
e pennittee shall take all reasonable steps to mirrimize or prevent any discharge or sludge use or disposal in
violation of this perrriits which has a reasonable likelihood of adversely affecting human health or the
environment.
3. t iv aLid Cri al LiaWlitc
Except as provided in pernift conditions on "Bypassing" (Part II, C-4) and "Power Failures" (fart II, C-7),
nodiing in this permit shall be construed to relieve the pertnittee from any responsibilities, liabilities, or penalties
for noncompliance pursuant to NCGS 1 3-?153, 14 - 15.6 or Section 309 of the Federal Act, 33 USC 1319.
Furthermore, the pertnittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. (ail and Hazardous Substance IdabIty
Nothing in diis permit shall be construed to preclude the institution of any legal action or relieve the e ttee
from anv responsibilities, liabilities, or penalties to which the pernitittee is or may be subject to under N GS 1 3-
215.75 et seq, or Section 311 of the Federal Act; 33 USG 1321. Furthermore, the permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Pro e t, Rights
e issuance of this pen -nit does not convey any property rights in either real or personal property, or any
exclusive privileges, near does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations.
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
7. eve a i1i
e provisions of this permit are severable, and if any provision of this permit, or the application of any
provision of this pen -nit to any circumstances, is held invalid, the application of such provision to other
circumstances, and the remainder of this permit, shall not be affected thereby~;

Part H
Page 6 of 11
12. Pe t_-coons
This pen -nit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
permittee for a permit modification, revocation and reissuance, or termination, ation,or a notification of planned
changes or anticipated noncompliance does not stay any permit condition.
13. permit _10 'f :ati n Revocation and Reissuance or jerMjD3,dgn
The issuance of this pe `t does not prohibit the permit issuing authority from reopening and 'modify ng the
pe t, revoking and reissuing the permit, or terminating the pennit as allowed by the laws, rules, and regulations
contained in Title 40, Code of )Federal Regulations, farts' 122 and 123; Title 15A of die North Carolina
Administrative Code, Subchapter 2H .0100, and North Carolina General Statute 143-21 .1 et. al.
14. previous PeMt
1 previous National Pollutant Discharge Elimination System Pe its issued to this facility, whether for
operation or discharge, are hereby revoked by issuance of permit. [Me exclusive authority to operate this
facility arises under permit. `t. e authority' to operate the .facility under previously issued permits 'ts beating this
number is no longer'; effective. ] Tlie conditions; requirements, terms, and provisions of this permit aud-iorizing
discharge under the National Pollutant Discharge Elimination System govern discharges from this facility..
SECTI N C. PE TIO D MAINTENA E (7F CAL LTTIC3 C) TR4L
1. CUdfird C21 ator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon classification of the facilirr by the
Certification Commission, the permittee shall employ a certified wastewater treatment plant operator in
responsible charge (ORC) of the wastewater treatment` facilities. Such operator must hold a certification of the
grade equivalent to or greater than the classification assigned to the wastewater treatment facilities by the
Certification Co ssion. The pe tree must also employ- a certified back-up operator of the appropriate type
and any grade to comply with the conditions of Title l5A NCAC Chapter 8G.0202. The ORC of the facility
must visit each Class I facility at least weekly :and each Class II, III, and Al facility at least' daily, excluding
weekends and'holidays, and must properly manage and document daily operation and maintenance of the facility
and must comply with all other conditions of Title 15A, NCAC Chapter 8G.0203. Once s the facility is classified,
the permittee shall submit a- letter to the Certification Conunission, which designates the operator in responsible
charge within thim, dads after the wastewater treatment facilities are 50% complete.
2. Proner Oneration and ijlaintenance
The pennittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the permittee to achieve compliance with the
conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the operation of back-up or au ' ' . facilities
or similar systems installed by a perr ittee only when the operation is necessary- to achieve compliance with the
conditions of the penruit.
. Need to l Ialt or Reduce no£ a Defense
It shall not be a defense for a permittee in an enforcement action that it would have been necessarytohalt or
reduce the permitted activity in order to maintain compliance with the condition of this pen -nit.
4. Bi, assing of Treatment Faclties
a. Definitions
(l) "Bypass"` means the known diversion of waste streams from anyportion of a treatment facility~ including
the collection system, which is not a designed or established or operating mode for the facility.
(2) "Severe property damage" means substantial physical damage to property, damage to the treatment
facilities which causes them to become inoperable, or substantial and permanent loss of natural resources
which can reasonably be expected to occur in the absence of a bypass. Severe property d age does
not mean economic loss caused by delays in production:

Part II
Page 9 of 11
. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering; waters of the State or navigable waters of the United States.The pertnittee
shall comply with all existing .federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, ant: permit issued by the Permit Issuing Authority for the utilization/disposal of -sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR fart 503.
The permittee shall comply~ with applicable 40 CFR Part 503 Standards for the Use and Disposal of Sewage
Sludge (when promulgated) within the time provided in the regulation, even if the permit is not modified to
incorporate the requirement. The perinittee shall notify the Permit Issuing Authority of any significant change in
its sludge use or disposal practices.
7. Power Failures
The pennittee is, responsible for maintaining adequate safeguards as - required by DEM Regulation, `isle 15 A,
North Carolina Administrative Code, Subchapter 2H, 0124 Reliability, to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures either by means of alternate power sources, standbc`
generators or retention of inadequately treated effluent.
SECTIUN i}. NIT©RIN!a I) REQORI)S
1. Renresentarive Samtalini�
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the pe "tted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period which the sample represents. All samples shall be taken at
the monitoring points specified in this pen -nit and, unless otherwise specified, before the effluent joins or is
diluted by anv other`wastestream, both of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Pen -nit Issuing Authority.
2. e or `
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on
a monthly Discharge Monitoring Report (DMR) Form PENI No. 2 R 1, 1.1 2, 3) or alternative forms approved
y the Director, DEM, postmarked no later than the 30th dad, following the completed reporting period.
e first DMR is due on the last day- of the month following the issuance of the permit or in the case of a new
facilits- on the last clay of the month followingthe commencement of charge. Duplicate signed copies of
these, and all other reports required herein., shall be submitted to the following address;
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. F1ow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. Tlie
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements are consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flews with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Chace -through condenser cooling water flow which is monitored by pump logs, or pump hour meters
as specified in Part 'I of this permit and based on the manufacturer's pump curves shall not be subject to this
requirement:

Part Il
Page 10 of i 1
E QTIDN E REI'0?RT-1—Nt- RE ,UI R E MEMENIS
1. L hange in Discharge
U discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the pe `t.
?. l'la ed :hams
e puttee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for determining whether a
facility is a new source in 40 CFR Tart 122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants which are subject neither to effluent limitations in the
permit, nor to notification requirements under 40 CFR Part 1212.42 (a) (I).
c. The alteration or addition results in a significant change in the permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of pen -nit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. m cipated Ncrncomtkliance
e pertnittee shall give advance notice to the Director of any planned changes in the permitted facility or activity
which may result in noncompliance with permit requirements.
4. TransThifers
s permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the per ittee and incorporate such other requirements as may be
necessary under the Clean Water Act.
5.onitciri —Re-Varts
Monitoring results shall be reported at the intervals specified elsewhere in this pe t.
a. Monitoring results must be reported on a Discharge 'Monitoring Report (Di1�IR) (See fart- II. D. 3 of
this
permit) or forms provided by the Director for reporting results of monitoring of sludge use or disposal
practices.
b. If the pennittee monitors any pollutant more frequently than required by the permit, using test procedures
specified in Dart II, D. 4. o£ this permit or in the case of sludge use or disposal, approved under 40 C
FR
503, or as specified in this permit, the results of this monitoring shall be included in the calculation and
reporting of the data submitted in the DINER.
c. Calculations for all limitations which require averaging of measurements shall utilize an arithmetic mean unless
otherwise specified by the Director in the permit.
. Twent)--four Hour Rel ortng
a. The pennittee shall report to the central office or the appropriate regional office any noncompliance which
may endanger health or the environment. y information shall be provided orally i 24 hours from the
time theperrnittee became aware of the circumstances. iA written submission shall also be provided within 5
days of the time the permittee becomes aware of the circumstances. The written submission shall contains a
description of the noncompliance,; and its cause; the period of noncompliance, inclu g exact dates and
times, and if the noncompliance has not been corrected, the anticipated time it is expected to continue; and
steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance.

PART III
OTHER REQUIREMENTS
A. (o struction
No construction of wastewater treatment facilities or additions to ;add to the planes treatment capacity or ;to
change the type of process utilized at the; treatment plant shall be begun until Final Plans and Specifications have
been submitted to the Division of Water Quality and written approval and Authorization to Construct has been
issued.
B. Crroundwater Lfonitorin
The p ttee shall, upon written notice from the Director of the ]division of Water Quality, conduct
groundwater monitoring as'may be required to determine the compliance of this NPDES pe 'tted facility with
the current groundwater standards:
C. Changg§ in Discharges, of Toxic ubstancs
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the pe t, if that discharge will exceed the highest of the
following"notification levels";
(1) One 'hundred micrograms per liter 000 4g/L);
(2) Two hundred micrograms per liter (200 µg/L.) for acrolein and acrylonitrile; five hundred micrograms
per liter (50 µg/L) for 2.4- ` 'trophenol and for " -methyl-4.Ci-' ' 'trophenol and one milligrarn per
liter (l mg/L) for antimony;
(.3) Five (5) times the maximum concentration value reported for that pollutant in the pen -nit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1 Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter 0 g/L) for antimony;
(3) Ten 00) times the maximum concentration value reported for that pollutant in the permit application.
D. Re us to Wa
irement to Continuail =Evaluate Alternativestewater Dischar es
e permittee shall continually evaluate all wastewater disposal alternatives and pursue the most environmentally
sound alternative of the reasonably cost effective alternatives. If the facility is in substantial nova -compliance with
the terms and conditions of the NPDES permit or governing rules, regulations or laws, the permittee shall
submit a report in such farm and detail as required by the Division evaluating these alternatives and a plan of
action within sixty (60) days of notification by the Division.
PART IV
ANNUAL ADMINISTERING AND COMPLIANCE MONITORING FEE
REQUIREMENTS
A. The pernuittee must pay the annual administering 'sterin.g and compliance monitoring fee within 30 (thirty)
days after being billed by the Division. Failure to pay the fee in a timely mariner in accordance with
15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the permit.

. .
kloriburg County
r1lotte, NC
VDIES Permit NC007
sset
Asset #
Cap. Date
Description
Ac . Value
_�ategory
I
41
2000
WASTEWATER TREATEMENT PLANT
508,786
IP
10
2000
Instrumentation
24,72
& E
1012411
2000
MIXER„ ASHBROOK H M, FOR Z-04 AERATION BA
27,337
& E
1012549
2000
Pump 154C, Circulation & Transfer
30,009
& E
1012548
2000
Pump 154E, Brine Circulation
30,009
& E
1000124
1999
AGITATOR - SPARE FOR AG-402
18,438
& E
1010845
1999
AGITATOR -ALUM. SULFATE SO. BICARBONATE M-
5,903
& E
1010844
1999
AGITATOR -MIX TANK COPPER SULFATE T154B {At
5,903
& E
1000182
1998
LIME SILO AREA CONTROL SYSTEM
5,746
& E
1000184
_1998
LIME SILO AREA ELECT SYSTEM
18,158
& E
1000183
1998
LIME SILO AREA MOTOR CONTR CEN
2,093
& E
1000300
1997
FLOATING MIXER
5,688
& E
1000301
1997
FLOATING MIXER
5,688
& E
1000251
1997
SEWAGE SUMP PUMP -PILOT PLANT
1,058
& E
1000310
1997
SSH STORAGE TANK
95,000
& E
1000308
1997
SSH STORAGE TANK SUMP PUMP
3,000
& E
1000309
1997
SSH STORAGE TANK TRANSFER PUMP
5,000
& E
1000400
1996
AGITATOR A1301 FOR SOL KETT K27
20,000
& E
1000402
1996
AGITATOR AG01 FOR SOL KET K25
20,000
& E
1000404
1996
AGITATOR AG01 FOR SOL KET.K23
20,000
& E
1000398
1996
AGITATOR AG01 FOR SOL KETT K29
20,000
& E
1000393
1996
FLOATING AERATOR #1
4,830
& E
100092
1996
FLOATING AERATOR #2
4,830
& E
1000391
1996
FLOATING AERATOR #3
4,830
& E
1000390
1996
FLOATING AERATOR #4
4,30
& E
1000389
196
FLOATING AERATOR #5
4,830
& E
1000388
1996
FLOATING AERATOR #6
4,830
& E
1000606
1995
EFF.PLANT SEC. CLAR.FLOW METER
1,246
& E
1000503
1995
ZO-4 FLOATING AERATOR
7,716
& E
100004
1995
ZO-4 FLOATING AERATOR
7,716
& E
1000883
1992
AQUA JET AGITATOR
1,332
VI & E ;
1000884
1992
AQUA JET AGITATOR
1,33
& E
1000885
1992
AQUA JET AGITATOR
1,332
& E
1000854
1992
BRINE TANK
1,428
& E
100 862
1992
CERCLA GROUNDWATER PUMP.WELL
45,053
& E
1000861
1992
CERCLA GROU NDWTR.MONITOR WELLS
4,053
& E
1000931
1991
CLARIFICATION PRESS #1 -16N
38,300
& E
1000929
1991
CLARIFICATION PRESS #2 -1N
38,294
& E
101169
1990
AGITATOR {@ K-0
8,000
& E
1001167
1990
AGITATOR @ K-22
8,000
& E
1001165
1990
AGITATOR @ K-24
8,000
& E
1001163
1990
AGITATOR @ K-26
8,000
& E
1001161
1990
AGITATOR a K-28
8,000
M& E
1001159
1990
AGITATOR @ K-30
8,000
& E
1001157
1990
AGITATOR @ K-32
12,000
M & E
1001154
1990
AGITATOR @ K-34
12,000
M & E
1001186
1990
AGITATOR @ T-02
10,000
M & E
1001183
1990
AGITATOR @ T-03
10,000
M & E
1001181
1990
AGITATOR @ T-04
10,000
M & E
1001178
1990
AGITATOR a T-05
10,000

s • s s •
e6kIenb6rg County
e rl i
~ i Permit
I
ate
Asset #
Cap. Date
Description
& E
1001001
1990
BRINE SUPPLY PUMP
100105
1990
CLAR. PRESS PAN PUMP,ILDEN
& E
1001088
1990
CLARIFIACATION PRESS, CP-1
& E
1001087
1990
CLARIFIACATION PRESS, CP-
E
1001287
1990
EFFLUENT EQUIP -INSTRUMENTATION
& E
1001288
1990
EFFLUENT EQUIPMENT -ELECTRICAL
& E
100189
1990
EFFLUENT EQUIPMENT -MECHANICAL
& E
100190
1990
EFFLUENT EQUIPMENT -PIPING
& E
1001370
1989
ACID WASTEWATER PUMP P-213
& E
1001369
1989
ACID WASTEWATER PUMP P-2C
& E
1001395
1989
LIME CIRCULATION PUMP - P16A
& E
1001394
1989
LIME CIRCULATION PUMP - P16B
& E
1001396
1989
LIME HOLDING TANK-T-16
& E
1001393
1989
LIME TRANSFER PUMP - P-17A
& E
1001392
1989
LIME TRANSFER PUMP - P-17B
E
100184
1989
MIXER - A-10
E
1001383
1989
MIXER - A-11
& E
100132
1989
MIXER - A-14
E
1001381
1989
MIXER - A-15
& E
100180
1989
MIXER - A-16
& E
1001379
1989
MIXER - A-17A
E
100178
1989
MIXER - A-17C
& E
100188
1989
MIXER - A-3A
& E
1001387
1989
MIXER - A-313
& E
1001386
1989
MIXER - A-5
& E
100185
1989
MIXER - A-6
& E
1001411
1989
SECOND STAGE NEUT. TANK - T-5
& E
1001410
1989
SECOND STAGE NEUT. TANK -T-6
E
1001451
1988
BRINE SYSTEM PIPING AND VALVIN
& E
1001506
1988
ELECT ACTUATORS - WASTE TREAT,
E
1001705
1986
SSH STORAGE TANK
E
100061
1983
#1 WATER FILTER ROBERTS BOZE IN
& E
100200
1983
#2 WATER FILTER
& E
1002069
1983
#3 WATER FILTER
& E
1002060
1983
#4 WATER FILTER
& E
1002059
1983
#5 WATER FILTER
& E
100102
1983
AGITATOR
& E
1002103
1983
AGITATOR 3NTNA-7
& E
1002131
1983
BRINE STORAGE TANK
& E
1002093
1983
CENTRIFUGAL WASTE PUMP CROWN
& E
1002094
1983
CLARIFIER MECHANISM ESD TYPE ZURN
& E
1002095
1983
CLARIFIER MECHANISM ESD TYPE ZURN
& E
100091
183
CONCRETE CHLORINE CONTACT BASIN
& E
1002017
1983
SS MIXED ACID STORAGE TANK
& E
1002098
1983
VERTICAL WET PIT SUMP PUMP
& E
1002099
1983
VERTICAL WET PIT SUMP PUMP
& E
1002100
1983
VERTICAL WET PIT SUMP PUMP
& E
1002101
1983
VERTICAL WET PIT SUMP PUMP

A� W A r49 Mich2lasley
Q Governor
Witham G. Ross, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
ONE p `CAlan W. Klimek, Director
Division of Water Quality
DIVISION OF WATER QUALITY
December 3, 2002
Tony Franco, Consultant
DMA, Inc.
200 Day Hill Road, 2' Floor
Windsor, CT O60
Subject: Clariant Corporation
Tax Certification of Water
Pollution abatement
Equipment
Mecklenburg County
Dear Mr. Franco:
This Office is unable to provide the requested Tax Certification as the information you
provided on November 14, 2002, lacks the following:
1- A copy of your permits.
- A list/description of items related to wastewater treatment (as listed in the permit). The
list should also include appropriate appurtenances such as pumps, piping, etc. associated
with the wastewater treatment facilities.
Upon receipt of the above noted information, this Office will be able to prepare an
appropriate response to your request. Please submit the information by December 24, 2002, or
the application will be returned to you as incomplete.
If you have any questions concerning this matter, please do not hesitate to contact
Samar Bou-Ghazale or me.
Sincerely,
; / )r'!�
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
[ %
er Service Mooresville Regional ice, 919 North Main Street, Mooresville, 28115 F8 1699
1623-7748 FAXAX (704) {34) 040

Li P
JUL 2
WATERt
UPDATE OF THE EVALUATION
OF BEST AVAILABLE TECHNOLOGY
ECONOMICALLY ACHIEVABLE (BAT) FOR
CONTROL
OF NUTRIENT DISCHARGES
LARIANT CORPORATION
Prepared for;
Clariant Corporation
11701 Mt. Holly Rd.
Charlotte, NC 2214
Prepared by;
AWARE Environmental* Inc.
30 -J Munroe Road
Charlotte, NC 2 270-1 9C3
AEI Job No. N130-30
AEI Document No, 1`3030r001
June 200

TABLE OF CONTENTS
Section No.
Description
Pa No.
TABLE OF CONTENTS, ...................:......: : . .... . . . : . . . ........
. : .
LIST OF TABLES. . .....:......:.... , ..':........... , .::... , , ... .
LIST OF FIGURES ...........................:............::...
LIST OF APPENDICES .......`......::.... .:....:..........:...........
. ... ii
1.0
INTRODUCTION ... . ..... . ....'....................::... .
1.1
GENERAL. .. - —
1
L 2
EXISTING WASTEWATER SYSTEM ...... ...... . ..... . .
.
L3
BAT STUDY ... .............:.............. .......... .....
L4
CONDUCT OF BAT STUDY .................: . .....: . . .....:. , ...:.
, . .
2.0
TREATMENT PLANT OPERATIONAL REVIEW .. , . . ............
. . .... 6
2A
BACKGROUND.. .... ... -- ......... ........ ,,..
2.2
TREATMENT PLANT PERFORMANCE.. , .....: : ... . .:......
. .:...
.0
DEVELOPMENT OF BAT EFFLUENT QUALITY . ..:........ . ......14
3 A
BAT DATA AND DEVELOPMENT OF BAT ......:.... . ........:..14
3.2
ANNUAL EFFLUENT FLOW FOR TN AND TP ......:......
, ; .:..14
3.3
TOTAL NITROGEN BAT....14
3A
TOTAL PHOSPHORUS BAT.
18
3.4.1
Phosphorus Treatability ........ . .. . ..:....:..... . ....................1
S
3.4.2
Effluent Phosphorus.. . ... .......
.21
3.4.3
Phosphorus BAT Development ......:.......:.. . .. . . . ......:.....
. . . : .21
3.5
BAT SUMMARY..
..26
LIST OF TABLES
Table No.
Di Lion
a e N.
1
Summary of Summer and Winter Operating Data
10
2
Summary of Removal Efficiencies
11
3
Total Phosphorus/Total Nitrogen - Effluent Data:
1.
4
Summary of Phosphorus Surcharges from Public Owned Treatment
Works {POTW's}
24
i

LIST OF; FIGURES
Figure No. Description Paae No.
1 FlowlTemp raturelAmmonia-N (200 -2004)
2 Comparison of Effluent Flow and Treated Flow Through
the Biological System 12
2 Statistical Analysis of Biological Treatment 17
4 ;Statistical Analysis of Total Nitrogen Winter 19
5 Statistical Analysis of Total Nitrogen - Summer 2
Correlation of Ferric Chloride Addition and Phosphorus Removal 22
7 Statistical Analysis of Effluent Total Phosphorus 2
Correlation of Ferric Chloride Addition and Phosphorus Removal
Costs 2
LAST OF APPENDICES
A BAT Test Data
B Jar Test Data
i

SECTION 1.0
tNTRODUCTION
1.1 GENERAL
Clariant operates a chemicals production facility and centralized waste treatment (CWT) plant
near Mount Holly, North Carolina (Clan t-Mt. Holly East Plant). Wastewater from the
facility and from off -site locations are treated in an can -site wastewater ater treatment plant
(WWTP) and the treated wastewaters are discharged to the Catawba River under NPDES
Permit No. NCO004375. The current NPDES permit became effective on March 1, 2003.
This permit was issued by the North Carolina Department of Environment and Natural
Resources (NCDENR)
The facility had been a specialty chemical and dye manufacturing site since 1937. In recent
years a number of the production units have shut down and the latest NPDES permit authorizes
operation of a centralized waste treatment system.
The treated wastewaters include:
I. CWT wastewaters from off -site manufacturing operations, hauled to the Clariant
facility; ,
1 Stormwater from the facility;
. Process wastewater and domestic wastewater from current on -site manufacturing
operations; and
4. The groundwater from a groundwater pump and treat system and leachate from an
active on -site landfill cell.
In addition to treating hauled -in wastes in the centralized waste treatment operations; Clariant
has developed the facility as an industrial park for compatible industrial operations. To date,
one (1) new tenant has operations at the facility with treatment of resulting process wastewaters
in the on -site WWTP,
1

1.2EXISTING WASTEWATER SYSTEIVI
The Clariant Mt Holly East site has two ;separate sewer systems, an alkaline and an acid.
Both carry stormwater to the on -site WWTP for treatment in addition to carrying wastewater
from site buildings.
The acid sewer is a gravity system that terminates in a lift station at the WWTP. The lift
station pumps acidic wastewater to "a primary treatment process. It can also pump water into
two lined impoundments for storage. The lined storage impoundments have a capacity of 2.5
MG The acid sewer system has a capacity of 500,000 gallons per day.
The primary treatment process includes two neutralization tanks that operate in series. Lime
slurry is pumped into each neutralization tank in a continuous manner for neutralization of
acidic wastewater. The neutralization process can accept up to 750,000 gallons per day of
acidic wastewater at pH 0.5.
The alkaline sewer is a gravity system that terminates in a lift station at the WWTP. - The lift
station pumps alkaline wastewater to a mixing chamber downstream of the two neutralization
tanks where the acid and alkaline sewer streams are mixed together. The lift station can also
pump water into two impoundments. These storage impoundments have a capacity of 3.5 MG:
The alkaline sewer system has a capacity of 4,500,000 gallons per day.
The combined and neutralized sewer streams flaw into two primary clarifiers that operate in
parallel. Primary and secondary solids and calcium sulfate, from the neutralization process,
settle out and are pumped to two sludge holding tanks. Clarified wastewater Bows by gravity
from the primary clarifiers to a 4.5 MG equalization basin. The two clarifiers are designed to
handle a total wastewater flow of 5,200,000 gallons per day.
The sludge is pumped from the sludge holding tanks to one of two continuous belt filter presses
for dewatering. ;Dewatered sludge is accumulated in dump trucks and is hauled to a lined
landfill on the site.
2

The 4.5 MG equalization (EQ) basin has several mixers and aerators. Wastewater flows from
the EQ basin by gravity to a 2.5 MG activated sludge aeration basin. The activated sludge
aeration basin has jet mixers that maintain a homogeneous mixture of sludge and water, Five
(5) aerators provide dissolved oxygen for the bacterial population in the mixed liquor. The
separate aeration/mixing controls allow adjustments to optimize nitrificationldenitrification
Mixed liquor from the aeration basin flows by gravity into two secondary clarifiers. Settled
biological sludge is returned to the aeration basin, Waste activated sludge is pumped to the
primary clarifiers where it mixes with primary sludge and is settled out for dewatering and
landfilling The secondary clarifiers are ;designed to handle up to 5,000000 gallons per clay of
flow.
Treated effluent exiting the secondary clarifiers flows through an exit canal paralleling the
WTP. The canal flows to a small final exit pond that has an aerator to provide a positive
dissolved oxygen prior to release into the Catawba River, The exit pond has an effluent lift
station and an exit valve that can shut off flow to the river.
The effluent lift station can divert the entire effluent flow to a 360 MG holding basin for
storage and re -treatment through the WTP. if any of the permitted effluent parameters are
expected to be exceeded due to WTP upset or poor treatment process performance, the
WWTP throughput can be pumped into the holding basin. Treated wastewater that is diverted
into the effluent holding basin is eventually released back to the WWTP equalization basin and
re -treated through the activated sludge system prior to discharge,
1.3 BAT STUDY
During 1995 and 1999, the Clariant Corporation conducted an evaluation of best available
technology economically achievable (BAT) for control of the nutrient discharges. The conduct
of the BAT study was based on the requirements in a draft permit issued by NCDENR which
specifically noted.
3

"It has been determined by the Division of Water Quality, through intensive water
quality studies, that discharges upstream of Lake Wylie, including this discharge, steed
to control nutrients through the application of best available technology (BAT) that is
economically achievable. ,The permittee shall provide the Division with a study which
fully investigates the feasibility of meeting a monthly average TP limit of 1.0 mg/l and
a summertime TN limit of 6 mg/l. If it is determined to be beyond reasonable BAT to
reach such concentrations of nutrients, the Division will apply BAT limits based on the
results of this study and the performance of other similar plants. The nutrient study
should be completed by November 1, 1999."
Based on this requirement, AWARE Environmental Inc. (AEI) conducted a study for Clariant
Corporation to evaluate the applicable BAT nutrient criteria. A report on BAT was submitted
to the North Carolina Department of Environment and Natural Resources in 1999. This report
was entitled "Evaluation of Best Available Technology Economically Achievable (BAT) for
Control of Nutrient Discharges-Ciari ant Corporation", October, 1999. _
Following the report submittal, the NCDENR included nutrient limits in the recent renewal of
the NPDES permit. Specifically, the nutrient criteria was based on a 12 month rolling average
for total nitrogen and total phosphorus. The specific limits whichare based on the results of
the October 1999 BAT study, included a total nitrogen (TN limit of 444.1 lbs/day and a total
phosphorus (TP) limit of 32.5 ibs/day. Compliance is to be based on the results of the first 12
months of effluent testing and will continue on a rolling annual average basis following the
initial 12 months. The monthly average lbs/day was to be based on the arithmetic average of
the concentrations monitored for composite samples collected during the month and the
average daily waste flow for the month;
In addition to a specific limit, based on the changes in the facility, the NCDER required the
perittee to perform a study which updates the limits for total nitrogen and total phosphorus
which can be met through BAT. The study is to based on twelve 12) months of effluent
monitoring data with the 12 months being utilized in the study as being the first 12 months
4

following the issuance of the new NPDES permit on March 1, 2003. A report on the BAT
update study will need to be submitted to NCDWQ for approval by July 1, 2004.
1.4 CONDUCT OF BAT STUDY
Based on the requirements in the NPDES permit, Clariant conducted a BAT study to determine
the best available treatment technology. The study was designed as an update of the October
1999 study utilizing the data from the 003-2004 operations. This report presents the results
of that study.
5

SECTION 2.0
TREATMENT PLANT OPERATIONAL REVIEW
2.1 BACKGROUND
The 1999 report analyzed, in detail, the wastewater treatment facilities at the Clariant facility.
The results of that analysis indicated that Clariant's treatment facility represented an industrial
BAT facility. The study found that them were elevated levels of nitrogen in the discharge
because of the nature of the wastewater (the majority of the discharge nitrogen was a refractory
organic nitrogen which could not be degraded using conventional nitrification or
denitrification). The addition of phosphorus was found to be a key criteria for maintaining
proper biological treatment.
The operation of the facility as a centralized waste treatment (CWT) facility began with the
revision of the NPDES permit in March 2003. Clariant initiated a program, based o
requirements of the NPDES permit, to update the BAT performance. AEI initiated a detailed
review of the treatment plant operations as part of the BAT evaluation.
2.2 TREATMENT PLANT PERFORMANCE
The operation of the treatment plant is complex because of the nature of the NPDES permit
limits. The treatmentplant must meet, on a monthly basis, BOD5 TSS and ammonia nitrogen
criteria along with criteria for OCPSF and CWT parameters, In addition, the BOD5 and
ammonia nitrogen discharges are limited based, on the river flow during the period of April 1
through October 31. Therefore, the plant must be able to discharge, to the available capacity,
on a year round basis since the storage of excessive quantities of wastewater could result in the
inability to discharge the stored wastewater. AEI conducted a detailed review of the treatment
plant performance in order to update the BAT for TN and TIP.
Initially, it was planned to use the routine performance monitoring data for the system as the
basis to establish BAT. However, based on a review of the initial months of data, it appeared
that a more detailed program would be required. Therefore, in August 2003, AEI revised the

monitoring program and also established controls to optimize nitrification/denitrification.
These changes included.
I . Laboratory QC confirmation;
2. A minimum of 2 per week influent and effluent total nitrogen and total phosphorus
analysis;
1 Use of rapid test kits to provide daily aeration basin NH3-d NO3-
4. Operation with a minimum MLSS of 5,000 mg/l;
5. Weekly review of system monitoring data to adjust operation;
. Modification of aeration basin controls to operate the complete mix basin with a
minimum DO which allows both nitrification and denitrification to occur in a single
basin using its rapid test kit data to adjust system operation; and
7. Jar testing for phosphorus removal.
The results of this program showed that the nitrification process is temperature dependent.
Following the implementation of the nitrification/denitrification program, the effluent ammonia ,
nitrogen and nitrate nitrogen averaged less than 2 mg/I each during the periods of biological
nitrification. Aeration basin temperature appears to be the primary factor which limits the
biological nitrification. It appears that when aeration basin temperatures are approximately
20"C or higher the system provides complete biological nitrification. However, when the
temperature drops to less than 15°C, the biological nitrification is lost and the BOI s removal
is reduced.
Figure I presents a summary of the discharge flows, aeration basin temperature, and effluent
ammonia nitrogen for the period January 1, 2003 through February 29, 2004. These data
show that once the temperature for nitrification was achieved (approximately 20'C), the
system achieved almost complete nitrification, and when colder temperatures occurred
(approximately ;15"C), the system lost the ability to nitrify. The lower discharge flow rates
during the colder months are based on the need: to store a portion of the flow (in the Sot} MG
basin) for retreatment. This storage capability allows the facility to comply with effluent I ODD
d' ammonia nitrogen criteria during winter operating conditions.
7

A summary of the summer and winter operating parameters is presented in Table I. These
data show that the system is achieving a high level of BOD5 removal both in the summer and
winter.
Under summer operating conditions the effluent B0135 is normally less than 10 mg/l. Under
winter operating conditions there is an increase in the BOD5and approximately 50 percent of
the treated wastewater flow is held in the effluent storage basin and recycled back to the
WWTP for re -treatment during warmer operating conditions. The system is operated at an
organic loading (food to mass ratio) of approximately 0.02 to 0.03 lbs BOD5 applied/lb
MLSS/day both in the summer and winter. This is a very low loading and should allow the,
system to achieve maximum levels of BOD5 removal and nitrification. These data indicate that
the system is impacted by cold temperature conditions.
The need to store a portion of the wastewater in the winter means that the flow through the
treatment plant is not equal to the effluent discharge flow. Figure 2 shows that the plant holds
back a portion of the flow during the winter. Therefore, the flow which is discharged is not
the total flow treated through the wastewater treatment plant, This has an impact on the
development of nutrient BAT levels. In looking at annual averages of nitrogen and
phosphorus, the data needs to be evaluated both in terms of the wastewater which is treated and
the wastewater which is actually discharged during the operating periods.
In August 2003, the revised program to optimize the performance of the treatment, system was
implemented.. This included an increase in the MLSS level to be maintained in excess of 5,000
mg/l, maintaining aeration DO level at the I to 2 mg/I level, and using the daily amnionia and
nitrate readings to adjust DO. Ammonia and nitrate test strips were utilized to provide the
daily operating data. Split samples were sent to several laboratories to verify the quality of the
laboratory data.
The full-scale performance data indicated that this program was helpful in optimizing system
nitrification/denitfification performance. Table 2 summarizes the winter and summer effluent
quality following the August 2003 modification of the operating protocol. The test data
9

TABLE
SUMMARY OF SUMMER AND WINTER OPERATING DATA
lnfient
Flow (Iv1C;GD)
0.8
O.6
BOD (m /1)
688-
1416
NH3- (mg/1)
10.8
71.7
Aeration Basin
F/M (Ibs BOD A/lb ML,SS-day)
0.02
0.03
ML.SS (mg/1)
6125
5998
SVI (mg/gm)
53.4
7 ; 9
D.O. (m/1)
3.2
14
Temperature (" C)
22.6
1
Secondary Clarifier
BOD (mg/1)
11
216
Final Effluent
Flow (M 1D)
0.9
0.2
BOD (m/1)
8
19
(l s/day)
49
307
Nil-N ( II)
1.8
46
10

T BLE ,
SUMMARY OF REMOVAL EFFICIENCIES
R (August 1-November 18
4
BQb 688
TKN 66 14.
NIL-N T3 1.
Organic N 5&8 13.4
NO2/NO3-N 1.6 L 8
TN 64;6 16.6
T]P T4 6.1
SIN (November 2-rFelbru ry )
BU 1416 193
TKN 97A 116.3
3-N 46.8 46.
Organic N 50.6 6 .6
NO2/NO -N 19 0.
TN 101:7 104.8
TP 4,3 &4
Notes:
A. Total nitrogen includes the sum of TKN (ammonia + organic nitrogen), nitrite, and
nitrate nitrogen. The data for all components of TN were not monitoring at the
same frequency. Outliers were not used in Tabu 2. Therefore, there may not be
balance of all parameters.
B. Total phosphorus and total nitrogen There was more effluent than influent data.
The individual data is shown in Appendix A.
11

indicate that there continues to be a refractory nitrogen component. This appears to be related
to the organic nitrogen and may result from the types of materials that are being hauled in from
textile wastes similar to that which had previously been treated on -site and to the treatment of
contaminated groundwater and stormwater at the Clariant site. Higher levels of nitrogen
occurred in winter because of the colder aeration basin temperatures.
There was no phosphorus addition to the treatment plant during these studies. However, it
appears that there is some phosphorus in the wastewater. The change in phosphorus in the
wastewater appears to be a significant change due to the centralized waste treatment (CWT)
operations.
13

E TIO 3.t1
DEVELOPMENT OF BAT EFFLUENT QUALITY
3.1 BAT DATA AND DEVELOPMENT OF RAT
The effluent monitoring data from the Clariant treatment system were utilized to define BAT
for TN and TP. Appendix A presents a summary of all the influent and effluent TN and TP
data which was collected as part of this study.
There was a difference between the flow processed throughthe wastewater treatment plant and
the effluent discharge flow since a portion of the treated wastewater can be diverted to the
effluent holding basin. Therefore, daily effluent waste loads were calculated using two
different approaches. One used the actual effluent discharge flow and the other used the actual
flow through the biological system. A summary of the actual discharge total nitrogen and total
phosphorus and the total nitrogen and total phosphorus which were calculated based on the
flows through the biological system is presented in Table 3.
The procedure for developing BAT was similar to that used in the 1999 report and is based on
U.S. EPA methodology. A statistical analysis of flow, TN and TP concentrations was
developed. The BAT levels for the annual average TN and TP were developed based on these
parameters.
3.2 ANNUAL EFFLUENT FLOW FOR TN AND TP
The actual 12 months of flows through the biological system were evaluated to define a BAT
flow basis. A summary of the treated flow levels is presented in Figure 3. This indicates that
the 50 percentile flow which would be used to determine the annual waste load is 0.92 MGD.
3.3 TOTAL NITROGEN BAT
The results of the previous BAT report showed that there was no cost effective procedure to
further reduce the total nitrogen beyond the current ntrificationldenitrification process.
Therefore, BAT was developed based on an optimized treatment plant utilizing
14

TABLE .3
TOTAL PHOSPHORUS / TOTAL NlrfROGEN - EFFLUENT DATA
MARCH 2O03 - FEBRUARY 2004
o+IT� ,
4-Mar-03 0.28 i 11 95.3 25.69 222.5449.5 429"
r
0.79 5.5 02 36.24 528.4136.0 525.2
5 13 19.17 8.13 119.91 5.8 86.2
1.28 012 31.7 1.28 33&40 15 399.1
1.49 .2 30. 39.77 37777 33.5 3186
_ 1.50 3 19.9 37.53 24&95 27.3 180.9
18-Aug-03 1.09 5.3 44.5 48.18 404.53 48.2 404.6
_ �____� a
20-Aug-03 OA2 ' 3:6 40.3 I 12.61 141.16 11.0 123.3
25-Aug-03 0.38 0.85 27.9 1 2.69 88.42 3.1 ; 103.2
r...__e.
27-Aug-03;- 0.84 0.403 17.27 2.82 120.99 3.1 14.7
3-Sep-03 1.09 4.9 10.75 44.54 97.72 49.6 1 108.8
5-Sep-03 1.54 j 097 9 00 12.46 I 115.59 7.3 $ _67.7
8-Sep-03 1,41 0.88 12.33 103144.99 8.2 115.1
10-Sep-03�� 1.26 1.7 1.18 17.86 127.99 19,9 1423
15-Sep-03 0.84 0.72 4.80 5.04' 33.63 6.1 40.6
17-;Sep-03 1,21 3.51 7.14 35.4 72.0 33.4 68.0
2 -Sep-03 1.20 ,6 18.34 56.04 183.55 59.1 193.7
24-Sep-03 0.87 3.36 0.99 24.38 7.18 17.8 5.2
29-Sep-03 ' 0.61 5a38 8.75 27.37 44.51" 4,5 39.8
1-Oct-03 1.11 18 11.26 166.63 104.24 156.8 1 98.1
6-Oct-03 0.40 10.6 1030 35.36 34.36 36.3 35.3
8-Oct-03 0.69 9.15 10.89 52.34 62.27 41.6 49,5
13-Oct-03 0.86 13.7 . 7 9 9 98 26 71, 51 105.3 76.6
15-Oct-03 .86 9.8 15.22 70.27 109.13 68.8
20-Oct-03 0.62 14 21.00 72.39 108.59 66.1 99.2
22-Oct-03 0.40 5.6 14.84 18.68 49.51 20.0 53.1
27-Oct-03 0.92 6.04 21.62 46.34 165.89 38.8 138.8
29-Oct-03 1.12 4.4 22.44 41.10 209.61 20.1 102.3
3-Nov-03 0.35 6,56 1617 1 19.15 4T49 20:6 51.1
5-Nov-03 0.57 8,24 18.15 39.25 86A2 36.8 ' 81.0
15

Try RI N I (enntinirarll
a
i
a
a
e
0.53
9.24•
' *s463
e
I�� IIII
IIII IVIIII
f
f
M
�.
* .10 0
3. F
7.7
ta.
•
!...
86.07
L
"gyp
�
♦�
1,
�..
4 •
*
F
F
s
♦.
1.
215
•
11.41
* 92
j
i
*.
Note A _ Based on measured flow through the biological system and final effluent
TN and TF concentrations.
t

W.
3
�.,
d
i t
3
#€
` "
33f
}
... ...., ..�..-.....T� ..... .,., ,.
.,. ...
?.
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� }
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�
3
i
a
} �
}
s..A}t...«
......z.�.f
R
rips�
..m... w..i w..,,w�„xe�w�.,..
� �..s«»w�.....��....,..:,...w.x�....
�,„>
,99
June 30, 2004 1C1:11:46 a,en.
// !!!R
Drawing: 13030CHARTI DWG.DWC
9305-1 MONROE RD. CHARLOTTE, NC-28270

nitrification/denitrification which produced an effluent ammonia-N and nitrate-N of less than 2
mg/I each under summer operations. In developing the total nitrogen BAT, the performance of
the system was divided between summer and winter operations. A summary of the winter total
nitrogen is presented in Figure 4. This shows that the 50 percentile nitrogen concentration in
the winter is 115 mg/l. A summary of the summer total nitrogen is presented in Figure 5.
This shows that the 50 percentile summer total nitrogen concentration is 17 mg/l.
There is a need to divert a portion of the winter flow to storage. Therefore, the proposed
approach for defining BAT is to separate summer (May through October) and winter
(November through April) conditions. During the summer, the flow to be used for BAT
would be 1.5 x the average flow or 1.38 MGD while for the winter the flow would be 0.5 x
the average flow or.46 MGD, Based on 1.38 MGD and 17 mg/l TN, this would result in a
TN limit of 196 lbs TN/day in the surnmer. Based on 0.46 MGD and 115 mg/I TN in the
winter, this would result in a TN limit of 441 lbs TN/day. The resulting annual average TN
would therefore be 318.5 lbs TN/day. This is a reduction of approximately 30% in the annual
average total nitrogen limitation as compared to present annual average limit of 444.1 lbs/day.
.4 TOTAL PHOSPHORUS BAT
The approach for developing the total phosphorus BAT limits was based: on a combination of
the total phosphorus in the optimized effluent from the treatment plant and the results of the jar
testing program which was conducted as part of the study for precipitation of the phosphorus.
A precipitation process was used for definition of BAT levels since this treatment plant is not
designed for biological phosphorus removal and biological removal would require a major
change in the treatment plant, Jar tests were performed to determine if precipitation techniques
could be used for additional phosphorus removal,
.4.1 Phosphorus Treatability
A series of precipitation jar tests were performed on the influent samples and mixed
liquid samples using ferric chloride, alum and lime. The results of these tests indicated
that ferric chloride was most effective in removing significant levels of the total
18

phosphorus. A summary of these data is presented in Appendix B. It appeared that the
ferric chloride precipitation could achieve up to 60 percent phosphorus removal. A`
summary of the ferric chloride data is presented in Figure 6. The effluent phosphorus
did not appear to be temperature dependent. Therefore the analysis of effluent total
phosphorus was based on all of the data.
3.4.2 :Effluent Phosphorus
A statical summary of the effluent phosphorus is presented in Figure 7. This shows
that the 50 percentile effluent total phosphorus is i mg/l. Based on the 50 percentile
flow of 0.92 MGD, the effluent total phosphorus from the facility would average 53
lbs/day on an annual basis:
3..3 Phosphorus BAT Development
It appears that the nature of the total phosphorus for the CT treatment plant operation
is different than that found in the previous study since phosphorus is no longer added to
the treatment plant. Therefore, a cost analysis was prepared to define the cost to
achieve additional phosphorus removal beyond the 53 lbs/day effluent total phosphorus.
As a first step in the analysis, the costs for municipal phosphorus removal was updated
from the 1999 study. These updated costs are presented in Table 4 and showed a
typical phosphorus removal cost of $2/lb phosphorus. These costs were then used as a
basis for defining BAT.
The approach for phosphorus removal is based on ferric chloride precipitation. The
cost for ferric chloride is 1.25 cents/lb. The cost analysis is based solely on the
chemical cost and does not include costs related to additional sludge generation,
chemical feed and sludge disposal, therefore this analysis is conservative. Phosphorus
removal would be achieved by adding ferric chloride to the secondary clarifier so that
additional clarification facilities would not be required. A summary of the percent
removals with the ferric chloride addition is presented in Figure 8. Based on the
POTW costs, the
21

6
c 40
•
0
•
0
50 100 150 200
FERRIC CHLORIDE ADDITION G L
CU K LATICN OF FERRIC CHLORIDE ADDITION
AND PHOSPHORUS REMOVAL'
LARIANT CORPORATION
MOUNT HOLLY, NORTH CAR©LINA
SCALr NUT :,TO SCALE rt r�� E» a l3r Tf)AVWlSAl MAY U{J4DESICNf f) d3 VfSE i) `
t PROJECT NUM£3ER 141119A iivw sHAWING Nt).
N 1 0-30 9365— j MONROf I<G <'fiARLt)fTf. N :h:�+r�r1'' Ik.)'ULR 6
__

TABLE .4
SUMMARY OF PHOSPHORUS SURCHARGES FROM
PUBLIC OWNED TREATMENTWORKS ( TWs)
}R
Gastonia, NC
84.701")
Norfolk, VA (Hampton Roads Sanitation District)
167�00('))
Birmingham,
III
200 0
Iu�
I p
B Nuti4eui Surcharge from Surveyed
excess of 8 mg/L
excess of 250 mg/L
excess of 4 g/L
24

z
W
5
<
40—
CY_
PROPOSED
BAT REMOVAL
Q
2
--* AVERAGE COST MUNICIPAL
0
PHOSPHORUS REMOVAL
CL
2 4
8 10 1
COST PER POUND OF
PHOSPHORUS ($, Ib.
CORRELATION OF FERRIC CHLORIDE ADDITION
AND PHOSPHORUS REMOVAL COST
LARIANT CORPORATION
MOUNT HOLLY, NORTH CAROLINA
cA E NOT TO SCALE ar��eov c� BY :FDRIAWN BY:
MAY 04 J)rscNrr� BY ; s ec
WING
PROJECT NUMBER �#it M1R!""L�NC
N }-w��,, 7-
9 i0l,, J MONR( A` mi, CCHARt O�:ILIFIGUURE

Summary of TreatmentPlant
Total Nitrogen and Total Phosphorus
Date !
Influent
effluent
TN (m 1)
I TP (m /1)
Tlv (m 1)
Tt' (rrsg/1)
953)
5.5
-NIw, -t
19,17
1.3
31.7
0.1?
2-JUI-03
3 .4 _
19.9
3.0
-Aug-O3
11.93
0.8 1
#.
�
5.3
20-Aug-03
28
40.3
2 i- Aug-O j
8,5
0.4
2T9
3.6
j 0.85
2 7-Atug-O3
10.75
4,9
5-Sep-03
.
r -
8-Sep-03
_.......�.
_
0,97 `
-
I
12,33
OM
10-Sep-03
1800
12.18
� 1.
115-Sep-03
12.17
6.77
t.8
0.72
17 Sep-03
150
7.14
I22-Sep-03
----I
31,21
8,7
18.31
_11
5.6
2ZSep-O3
_
_
..
'9-Sep 03
_
O.156
^s
5.38
1-Cct-(?3
21
11.E
18
6-Oct-0
9.65
0488 j
10.E
10,6
9.15
1-Clct-(}
45,25
6 1
9.97
13.7
15-Oct-).a
_
6
13.22
9.8
20-Oct-03
35M
29
21
' 22-C7ct-03
170
_._
14.84
14
! 5.6
27-tact-03
28.1
j 5.95
21,62
6.04
29-tact-03
21
22.44
{ 4.4
3-Nov-0-3- !
330.46
I 23.2
16.27
C 6.5
5-Nov-03
72
;
18,145
E 8,24
10-Nov-03
89.62
0.21
17,62
9.?4
1--Nov-03
�
170
I
�w
22.1.3
F
1o.1
1- plc v'O
22,3
2
5.26
18.17
15.4
15621
14,1
1-17ec-oa
174. 2
4._6
2
-
1?O.1
_ _ _ . -
10.
C
130.17
9.31
I3-Dec- 3
144.86
0,34 .
i 10.13
`_`_
T 71
j 1;0-Dec-03
97
_
_W
15U4
6.23
Summary or Treatment Plant TP/TN
PI 1307 1 0-30 WWTPtSummary orTP
1
Clarlant Corp.:
June 2004

(cantinud)
Date � ueut
Muent
TN (m /1)
TP (mg/1)
TN (m /1)
TP (m lt)
' 1;-Dec-03 0.19
5M E
8.1
I 0.945
17-Dec-03 70
.._ _.._
f9.27
937
140:09
.75 - '
?9-CJec 0 16.2 _
8.31
190.24 _
12,2
Al
_ _
—
f _.
6.43
6-Jan-0 t
�._
14t -
�._.
� 1.54 1
163
I2-Jan-04 104.95
0.$ 1
93.15
2.$
14-Jan-04 i
�
86.17
.57
19-.tan-04 � 9�.28
3, 7 �
110.29
-2 8
'7l-3an-O�i � 5�
j`
9?.39
i 2.8
26_Jan-04 5.1
_
11.3
9,-'
1 7.43
915
4-Feb-04
_ _ _
9-Feb-04 �
1
-,
89.E 15
7:96
�9.87
5
86.2?
115.9
11-Feb-04 89
24U3
9. 44
18®Feb-010
110.3 _
11.8
23-Feb-0 3
i
x
Summary of Treatment Plant TP/TNI
Clariant Corp.
Pt130\130-10 \VWTP\Summaj-y of TP
2
Junc: 2004

PHOSPHORUS REMOVAL JAR TESTING
CLARIAN
AEI JN 130-30A
Jar Tests performed on Mixed lr.iquor samples
Ferric Chloride (as FeCL3)
Dosage Final pH
Fllt. Phos
Init. Phos
Reduction
mg/L su
mg/L
mg/L
50 7.88
6.31
10.06
37
100 7.28
4.75
10.06
5
200 6.77
4.13
10.06
59
Alum (as AI04)
Dosage Final pH
Fitt. Phos
init. Phos,
Reduction
mg/L su
mg/L
m /L
%
0 7.42
8.03
10.06
20
100 7.19
4.56
10.06
55
00 6,81
8.03
10.06
20
Jar Tests performed on Influent samples
Lime (as CaO)
Dosage Final pH
Tot. Phos
Init. Phos
Reduction
mg/L su
mg1L
mg/L`%
200 8,5
5.61
6.68
16
300 9.65
5.06
6.68
24
450 10.5
3.98
6.68
40

`CClariant
Clariant Corporation
October 28, 2002
GAI-02-1
Mr. John Leslie
NC Department of Environment and Natural Resources
919 North Main Street
Mooresville, NC 2 115
Subject: NPDES Pernut Exceedance — Oil & Grease
Clariant Corporation — Mount Holly West
eiie ;ia 'Pei-tait No. 7CG50000
Certificate of Coverage No. NCG500047
Dear Mr. Leslie'
ANID
1 ..
4ICE
y
OCT
29
,
This letter follows tip on my verbal telephone report made to you at the Moorseville Regional
office on October 23.
Clariant Corporation's Mount Holly West Plant exceeded a permit discharge limit on October 16,
2002, We became aware of the exceedance on October 231.: 001
A sample taken at Ouffrll 001 oil October 16 had a reported Oil & Grease level of 290 mg/1 .
Our permit specifies Oil & Grease limits of 15 mg/L (monthly average) and 20 mg/L (daily
maximum).
We believe the cause of this exceedance is known and has been corrected. The sttrmwater valve
at Outfall 001 had recently developed a small leak. We suspect that a small amount of surfactant
product was spilled and leaked through the valve. At the time the sample was taken, the water
flowing through the pipe may have picked up some remaining residue in the pipe. Many
surfactant raw materials and products are hexane extractable and thus show up as Oil & Grease
when ana ly zecd by 1_';PA "N/Iethod 166 ^
Outfall valve 001 has been completely replaced and no current leaks are detected, For this
reason, we believe that there is no reason to expect of recurrence of this permit exceedance.
If You have any questions, please call me at 704- 2 -22I .
Si►tcerely,
Call Insley, P
Environmental Leader
Clariant Corporation -- Mount Holly West

GC: ;
Q urgent rux Review0 t 0 " Reply Ci ' rwe Recyrk
r {, akx w ?b • • • > r • m
°lease. call if you have any trouble receiving or reading this fax. Tbanks
r!S'Jil�t
fRi a t r 'it du r,' w+ u
d YRYJ%tf Ef
fr+it a r t 4f rf at ayrt ++
1 i 5 py, r a t t t t t
�t�t�(��§y��.
,_3#rnilfSi.,.
a44"
var a
�.AS",
Jl'�
i
. .
� st t tra+ra 2xt, ( !'j d rxk txts nx rvn t
. ., . . . .
. . . . .
n
tj t r t y i ry r�ii €i41�7�i Z�Oi���ftf t�Y: � , tk � e� + r•�aat + �'i ���#+vYfkf ++63?xh ,� � r e 4 � , h` € � �, ��R�i
,,.. �,., � r , N`t r.: ..�{, tYkln#,n `: , r{•kht�,�.. + ` d, 4!F j ;.,t ,
t

NCDENR-DOJO Fax:[phone] Oct 9 '02 9.03 P.02/31
'State of North' Carolina
.Department of Environment i.
and :Natural Resources ►
Division of Water QualityMIL M
a� �
Michael F. Easley,. Governor NCDEM6`R
,William G. boss, Jr., SecretarY
Alan W. Klimek, PE., Director
September 11., 2002
Mr. Gary Sanderson�
IClariant Corporation
P© Box 669246
Charlotte, NC 28266
subject: NPDES Draft Permit
NPDES Permit NCO004375
filar -ant Corporation -Mt- Holly East Plant
Mecklenburg County
Dear Mr. S ` demon':
;'The,Divisi.on received Clariant Corporation "an addendum to the application for a new National
'Pollutant Discharge Elimination System (NPDES),permit on August 21, 2002. The Division of
Water Quality has pirep red a draft pecrruit for your review.
Please review the draft permit carefully. Check to insure that the facility information is correct,
including address and location.
The following moth%cations have been made to the draft permit:
Effluent limita iasns for BOO, 5 day and Total Suspended Solids have been modified based
on the revision of waste flows used for development of the allocations for OCPSF, non'
categorical and centralized wastetreatment waste streams. Effluent limitations have been
reduced due to aa< smaller flow (not design capacity) being used for allocation development.
The application support document submitted by Cl 'ant describes the allocation procese.
Tiered limitations have been placed in the permit. Tier 1 limits are effective for existing
wastewater sources. Tier 2 limits become effective when any addition wastewater sources
are added.
The effluent limitation for NH3 as N has been revised slightly downward to a mess based
limit of 618 lb/day (monthly average) and 927 lb/day (daily maximum), in the past, the
H3 limit has been allocated based on secondary treatment of the effluent discharge.
• Monthly monitoring for manganese, sulfates, chlorides, MBAS and iron has been reduced
to quarterly monitoring based on the results of a reasonable potential analysis that
indicated that the NC water quality standard would ,not be violated by the effluent
discharge. A limitation is not required but due to the nature of the discharge, effluent
monitoring is still required
F, -
1 17 Mott SERVICE CENTER, RAtEv4, NORTH CARotiran 27699-t 617 - TELEPHONE [phone]/FAx [phone]
AN EQUAL OPPORTUNITY AFFIRMATIvE AcnoN EMPLOYER - 5 RECYCLED/ 10% POST -CONSUMER PAPER
vlsrT ors ON YHEJNTERwET 0 http://h2o.enr.state.nc.us/NPDES
s
a

NCDENR-DWO Fax:[phone] Oct 9 '02 9:03 P.03/31
Permit Number: NCO004375
a Monthly monitoring for chromium and zinc have been added to the permit based on new
wastewater str6ams from Seaboard Container Cleaning and SCR -Tech that indicate their
presence.
0 Effluent limitations for to nitrogen and total phosphorus have added to the permit based
on the Catawba River Basin Management Plan for nutrient iprotection in the Lake Wylie
watershed. The ! se are interim limits based on current information from the facility.
0 A special condition has been added to the permit that will require that Clariant will conduct
a BAT study for' the development of more accurate nutrient limits in 2003.
a Mercury continues to be a water quality concern throughout North Carolina. Holders of NPDES
permits have worked, with the state to reduce potential risks from this pollutant, including tasks
associated with collecting and reporting more accurate data. The most commonly used laboratory
analysis (EPA Mthud 245.1) has a detection limit of 0.2 ug/L while the current water quality
tandardis gnjWde r at 0,012 ug/L., t alyt
-4n order of rna jcrWe .'� more rec tally approved. an icAl lest
;PAMetIhoa"1,043 I) S 6uldp i�dvtection Ii � lev7l of the standa�'& This will allow
produce n�,it below the
the blivision'to a's' t tial wal y impa ts,'�o` discharges more accurately: - iVe reepre,
ess efjiva�it
e innin on oi. before Se tembe- EPA. Method 1 631
hen analyzingi, e, metcury.
h
'0' '
ion ess �P�
s to a7
on
in oi b ore tt
e g n n I yz �'S , r, me,
ana inj
*
• Stream moni�odng ior'bb' NH3 have been -deleted bI Med on ' taut of data,
ho I wing no irnpa�t on at qualit�, in th C etawba-i2iver.
The ivision will hold the Cmment period6peh for 30 days uring this time the Dividior� wilt
accept comments from you or your representative, the public and other agencies. This is your
opportunity to comment on the provisions of the permit.
Please provide comments you have regarding this draft permit to DENR — DWQ NPI)ES Unit no
later than October 11, 2002. Concurrent with this transmittal, the Division is also publishing
a notice in the newspapers having general circulation in the Mecklenburg County, soliciting
public comment on,Ahe draft permit.
Following the 30-day public comment period, the Division will review all pertinent comments
and take appropriate action prior to issuance of the final permit.
Parts The *boilerplarc* language is considered standard conditions and cannot be changed to
represent individual facilities. The requirement to include standard permit conditions verbatim
or by reference is st , ipulated in 40 CPR 122.43. Language is interpreted appropriately for each
facility.

NCDENR-DWO Fax:[phone]
Oct 9 '02 :04 P.04/31
Permit Number: NC O0043 `5
you have any questions concerning the draft permit for your facility, please call me at (9 f 9)
33-5083, extension 512.
Sincerely,
r
Ja ' Glyn . N well
NP S Unit
Mooresville Regional Office/Water Quality Section
EPA °Region,NjAtm. R s'e Gbildress
Ned fis ..JAveare E4vi n ery lric. 9305 d A ae Road, Charlotte NO2€2 �-m 49 i
DERV
Aquatic Toxf' 6fogy
Central Files,
i 'F'F Fate
r
G
;; r

NCDENR-DWO Fax :[phone]
STATE OF NORTH
DIVISION OF V
p
PEI
F TO DISCHARGE WAS'.
Oct 9 ' 02 9 - U4 P. O5/31
Permit Number: NCOOO437
;CAROLI A
AND NATURAL RESOURCES
:R QUALITY
1TER UNDER THE
{
"3E ELIMINATION SYSTEM
ince with; the provision of North Carolina General Statute 143- 15.1, other lawful
and regulations promulgated and adopted by the North Carolina Environmental
mt Commission, and the Federal 'Water Pollution Control Act, as amended,
Clariant Corporation
authorized to discharge wastewater from a facility located at
Cl t- t. Holly East
NC Highway 27
Northwest of Charlotte
Mecklenburg County
III and IV hereof.
'"This permit shall become effective
this permit and authorization to discharge shell expire at midnight on June 30, 2005.
ry
`Signed this day
Alan V Klimek, P.E., Director
Division of Water Quality
By Authority of the
Environmental Management Commission
1
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NCDENP-DW Fax [phone] Oct 9 '02 9 06 P.07/31
Permit Number: NCO00437
SUPPLEMENT TO PERMIT COVER SHEET
Clarlant Corporation
rereby authorized to.
Continue operation of a 3.9 MGD wastewater treatment plant with a discharge through;
outfall 001, consisting of the following treatment units
• 2.5 MG atormwatcr equalization basins for non -alkaline wastewater;
f N .5 MG star water equalization basins for alkaline wastewater;
• pH neutralization tanks-,
• two prunalyclarifiers;
• .5 MG Wastewater equalization sin, �):...
• 2.5 MG aerations basin; Ale
a„ 4
• o second clarifiers,

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�R-DWQ Fax:[phone] Oct 9 '02 9:07 P.10/31
Permit Number: NCO004375
numerical permit bmt fear that poUutant.
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NCD N -DWO FaxW919-733-0719 Oct 9 '02 9:08 P.1 >31
Perm. it Number: NCO004375
SECTION A(2)e. -Tier I OCPSJr ftrasnaters - Continued
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NCDENR-DWO Fax [phone]
SECTION A( )c. 'Ties I Combined OCPSF and CIA
Oct 9 '02 9:09 P.13/31
Penrut Number: NCO00437
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)ENR-DWO Fax:[phone] Oct 9 '02 9:09 P.14/31
Permit Number: NCO004375

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DE -DWO Fax :919•-733-0 19
ION A(2)c ''filer 2 Combinad OCPSF`and CWT
act `'9 '02 9:10 F.16/31
Perrait 'sb r NCO00437
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NCDENR-DWO Fax :919-?33-0719 Oct 9 '02 9:11 P.18/31
Permit Number: NCO004375
A(4). TOTAL PHOSPHORUS AND TOTAL rontoraN MONITORING
The Pennittee shall calculate a 12-moutb tolling average massIoading, as the sum of monthly loadings, according
to the following equatio'ns:
(1) Monthly Avetage(lbs./dsy)=TPxQw.x 9,34
where:
TP - the arithmetic average of total phosphorus concentrations (mg/l.) obtained via composite samples (either daily,
weekly, or monthly average values) collected during the -month
Qw - the average daily waste flow (MGD) for the month
8.34 = convenitin factor, from (mg/L x MGD) to pounds
The 12-mooth rolling average mass loading is defined as the sum of the monthly average loadings for the previous
12 months inclusive ofthe reporting mouth:
12
1 (2) rna in .... 12:Mcmth, Mass Lo�V
lgdiht'obsay)-, TP 12 clusiveo
Where,
rIpma is dpfla ed a thtotal phosplho s mouth livleri* ss to inj (calculated above).
D!!a,N�itro ern Is to tlike'i'a'me totthod!
-- - -------
ed 0 thir attached worksheet and
The monthly average, 12-monih avcra� mn�ss load gs.9hall-be.r, Olt
I
Corporan P. ":�be ;rse worksheet is due with t submitted with the 4ist ge inorntoring rep for Cl:jqt I YJ
discharge monitorig report, 10 months from �e ii(feoivi date of the total pho plibrus and total nitrogen 1: mi In
Art the in im �, pchad won sheet the totot
inter _perWbi;�veen thi, e5ective date and thebequiremeni
,phosphorus and total nitrogen monthly average mass loadings should be reported on the discharge monitoring report
for the respective facility.
ThePerminee shall report: the total phosphorus and total nitrogen concentrations for each sample on the discharge
...................
Q­j ­_ .., I ........ _!" — ­.. ­.­ F­­ .— .. ­.4e ."s.—awlao aPuv­& AAs 1s%a/ —
which shall remain in effect until the BAT study is completed and BAT limits for TP and TN are established by the
Division.
A(6), STAGING RF�QUIREMXNTS (APPLICABLE APRIL I — OCTOBER 31)
The operating day runs from TOO imi to 7.00 arri Each day, the permittee will calculate a -running daily average
stream flow as determined by turbine operation at Mt. Island Dam, leakage at the dam (80 cfs), and the 7Q 10 flow
of Dutchrnan's Creek (1cfs). Muent release is to be controlled such that projected release of BOD and ammonia,
using the most recent analytical values for these parameters, will not exceed the value given in the following
formulas:
(1) When the daily river flow is calculated to be < or 175 cfs: 13ODS + 0,54(NH3-N) <-5664
,(2) When daily average river flow is calculated to be > 175 cfs but < or 250 cfs: BOO S +
0.54(NH3-N) <-'J044 lb/day
13

NCDENR-0 0 Fax.91 -?33-0 19
e ;attached additional DMR sheet shall be us;
staging requirements during the summer (April
4
Additional DMR Sheet ft
f EFF1
hi'pnp-q poesy yit Met r�Ct"'YM417 niar%cararr
Oct 9 '02 9:11 P.,19/31
Permit Number. NCO0043' 5
►onitor compliance with BOO and NH3
:tober 31
t-Mt. Holly East
Month Year
i certify that this report is accurate and complete
to the best of my knowledge.
X
ver
_A Allowable -ActualI
:Time
o B
i fs �
NH3r i D+,54 H B©D+.5�4NH3 Comp?
lb � � lb d N
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NCI NR- WO
Fax.[phone]
Oct ' 9 '02 9:12 P. 20/31
ti
Permit Number: NC0004 '7
SEcTION A.(7.) Effluent PcsoutatntSea*
The permittee shall perform annual pollutant scan of its treated effluent for the
following parameters:
Ammonia (try N)
Trans-t2
Bis (2 thyl) atheir
ChbMeftoolmidiiiiii, TRG)
11,14fteovViroam
On (2.ch y
Dissolved oxygen
1,24ne
Bin (2 ) phthalass
NitratelNrtn(a
1,3 yferiephano
e
tttetdaht nitrogen
E
Bu
Of and greats
pi
Uh
Phosphorus
Mato dilonde
44 anyl pharryl erw
Total dinolved, solos',
Methyfeft chbrtde
Chrywo
Hardness
1,12,240"clibmathans
n-trutylphthalate
Antimony
t
pb�
i%{ rc [ phowate
Tolume
dradmxrm t
1�1,2tn�aUranOl3brpkaenxene
t
t
1,
chromiumr j
t
rl Tnroa#hyM! / `
t 1.lchbrserse
#35 copper f I
„ r'Viny#chlon, l
--33; roo.I rs eide.
j Lea
..t
t: ttthyt pnttuNate
i
i Mercury
P4k)m4n-c%sQ,.._._...._ _
\
: [hrneltryt phthalate
Nickel #ir �
`
` 2ttFt
1
2,4 rtrototu �
Selenium- 1
.4drr1nrd nol
i 2,6-dinkrotoluoris
Silver 1.
yt of
1,2�t t
Thallium
4,6ai6tloo- t
Fkrorenthene
Zinc
2,4 It opherfol
Fluowe
Cyanide
2 of
Haxachlorobstizena
Total phemokc oompm�ds
4-ftophandl
HeXadilDrObUtIldlene
V i#eoroantcC rrountte
Pentachlorophariol
Haxedilarocyclo-peaWfiene
Acrolsin;
Phanat
H (
Atrylonttr4e
2,4,&inch w
l i 2,
Senaene
8esaaa lords
t
Brorsftorm
Aostisphthene
Naphrutiene
Carbon tetrachionde
AcensphthyleneNitrobenzene
Chiombenzene
Anduszone
N-oltrosode•n ' e
Chtorortlttro thaneBenzIdine
Wahmsodirnothyfamow
Chwoetl+ana
ro(a)an
N-ro e y mra
2-chlo 'thylvinyl ether,zu(a
Phensinthrerie
Chloroform3,4
bens Mane
Pyrafte
NhIorobrorromethane
xts(ghi)perytene
124a b one
8
1,2-d roethane
a (2-ch oxy) methane
> The total set of sim ples
analyzed during the current term of the permit must be
representative of seasonal
variations,
Samples shall be collected and analyzed in accordance
with analytical methods approved
under 40 CFR Part 136.
Unless indicated'otherwise, metals must be analyzed and reported as total recoverable.
Test results shall be reported to the Division in l7WQ Form- D R-PPAl or in a form
approved by the "Director, within 90 days of sampling.
A copy of the report shall be
submitted to each the NPDE a Unit and the Compliance and Enforcement Unit to the
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NCDENP-DWO Fax:[phone] Oct `'9 '02 9 12 P.21/31
Permit Number.
ber: NCO0 4 7'
following address: Division of Water Quality, Water Quality Section, , 1617 Mail Service
Center, Raleigh; North Carolina 27699-1617.
Clarriaarl Nutrient 'Workshleet
NIPOES Permit NCO004375
G
Reporting Month:
Beginning Month: (Month 1)
Ending Month: (Month 12)
I
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dote: The TN and TP mass loadings for the current reporting month
should be enrered for Mconth i .
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NCDENR-DWO F x4919- 33-0 19 Oct 9 '02 9 12
P. 2/31
Depastment ofEnviroumcnt and Natural Resources
Division ofwater;Q"Iurality
Fact Sheet For Permit SCO004375
i• a i �„ �
Facility Information'
Applicant/Facility Name"
Clariarit Corporation - Mt. Holly
Applicant Address?:
P.O. Box 669246, Charlotte, NC 28266
Facility Address':
11701 Mount Molly Road, Charlotte, NC 28214'
Permitted Flow 1:
3.9 MGD (Grade IV _ Biological)
Type of"'W'tastel::
industrial
Facility/]Permit Status':
Renewal
County':
Mecklenburg
t
Miscellaneous
a.
Receiving Stream I,,
Catawba River
Stream Classification:
WSW -CA
303(d) Listed??:
No
Subbasin2. '
03-08- 4
Drainage Area (rm2l: (calculated)
40.8 mx2
Summer 7Q 10 (cfs):
329 efs
3Q2 (cfs):
716 cfs
Average ]Flow (cfs(:'
3016 chi
IWC (°/a(: N
1.8°l
Primary SIG Code:.
286
Regional Office:
Mooresville
USES Topo Quad: G
Mountain Island Lake & fount Holly
Permit it Writer
Jackie Nowell
Elate:
September 4; 2002
i
Summary
and other pertioent data in developing this permit, This fact sheet summarizes the rationale
used to determine permit limits and conditions.
Wastewater from the Ci riant Corporation facility is treated in the on -site WWTP. The
treatment plant is comprised of the following, treatment units:
* o separate sewer systems, acid sewer and alkaline suer.
* Acid sewer lift station pumps.
* Alkaline sewer lift station pumps.
* 2.5 MG; lined equalization basins for non -alkaline wastewater.
* 3.5 MG limed equalization basins for alkaline sewer wastewater.
•Two p14neutralization tanks with lime slurry addition.
*Two primary clarifiers.
* One 4.5 MG equalization basin with mixers and aerators.
* One 2,5 MG activated sludge aeration basin with jet mixing and aerators.
* Two secondary clarifiers.
Fast Shettc
" NPDES R-onewai
h Pagc
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«• •
•
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Oct9 '02 9:13 P.23/31
.ondary sludge.
final exit pond that has an aerator in it
!lease' into the Catawba River.
,ient lift station can deliver the entire
affluent holding basin for storage and
nce that time, there have been changes
Lion,
used limits for ammonia,'
,nzotlor tene,
..: ` !. : !: • : 'e , a !. ! . . " - r: .. s . � .. _ _ _... _. _. _
• !
i
f • • « • • • , •.. • • ! ! : : • « • • 1. !
! is , • . : , « •. • . - ..: • : • f ..: .. �:: « •. • � •..
x a
! •... ,. 1. ' • • •....
industrial categories of the US EPA Effluent Guidelines and Standards:
• Organic Chemicals, Mastics and Synthetic Fibers ( CJPSIF) (40 CFR Part 41.4);
• Centralized Waste Treatment (CWT) Point Source (40 CFR Part 437); and
• lion -categorical industrial wastewaters.
Discharge Monitoring Report Data Review
According to the self -monitoring data, the facility is achieving compliance with the current
permit limits.
Current Stream Conditions
The Catawba River flows from western North Carolina into Lake�Vylic. The Catawba Rimer is in
the Catawba River! kArainage area. The Catawba, River i classified as a class WS- V CA water in
the Catawba River�Basin (North Carolina's classification system), which means it is a protected
water supply and i;s designated for drinking water.
The Catawba Diver is not listed as an impaired water according to North Carolina's draft 2000
303(d) list:
FaitI$]heet
NPOEs Rrnewal

NCDENi -DWO Fax 919- 33-D719 Oct 9 '02 9:13 P. 2Af31
jv*tream Monitoring
Cla.riant conducts monitoring of the Catawba liver, bath upstream and downstream of the
WWTP discharge. Analysis of approximately 3 years of instream, data (1989 -- 2002), shows no
violations of North Carolina's dissolved oxygen standard.
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NPJXS Renewal
Page 3

NCDENR-DWO Fax:[phone] Oct 9 '02 9:13 P.25/31
compliance Summary
Staff Reports indicate that the facility is well maintained and operated. The Clariant
Corporation WWTP: has a very good compliance record. Over the past three years, the facility
had no violations of monthly average limits.
Toxicity Testing
Current Requirement: Chronic toxicity limit monitored quarterly
The facility has a good toxicity compliance record over the past six years.
Recommended Requirement: Chronic toxicity limit monitored quarterly 1. 8%,
i.
Toxicant Analysis,
Using the self monitoring data required per the NP)DES permit and the approved Long Term
Monitoring Plan, reasonable potential analysis' were conducted on the following toxicants:
iron, manganese, chloride, mercury, total phenols and total sulfate, The standards used for the
analysis are consistent with the standards for a class WS-1V stream.
Refer to the proposed changes section to sea results,
PROPOSED WATER ' QUALITY BAGED LIMITS
This permit contains water quality based limits for ammonia, dissolved oxygen,
MIZEMM,
c-wr-o;wl-u-m--,-toted ,copper, -flu-o-ranthene, total lead, total nickel, total phenol and total zinc,
NMES kcnewal
Pagc 4

(b) Notice of Public Meeting
(1) Notice of public meeting on any NPDES permit application shall be circulated in the
geographical areas of the proposed discharge by the Director at least 30 days prior to
the date of the meeting:
(A) by publishing the notice one time in a newspaper having general circulation
in said county-
(B) by mailing the notice to all persons and government agencies which, received
a copy of the notice or the fact sheet for the NPDES application; and
(C) by mailing the notice to any person or group upon request.
(2) The notice of any public meeting shall include at least the following:
(A) name, address, and phone number of agency holding the public meeting;
(B) name and address of each applicant whose application will be considered
it the meeting;
(Q) name of waterway to which each discharge is made and a short
description of the location of each discharge on the water ay;
(b) a brief reference to the public notice issued for each NPDES application
including identification number and date of issuance;
(E) infor.mation regarding; the time and location for the meeting;
(F) the purpose of the meeting-,
(G) address and phone number of premises at which interested persons may
obtain further information, request a copy of each draft NPDES permit,
request a copy of each fact sheet, and inspect and copy NPDES forms and
related documents; and
Fact Sheet
NPDES Penewal
Page 6

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tAC 02H .0111 MEETINGS AND HF ROS
?ublic Meetings.
(1) The Direkor shall provide an opportunity for the applicant, any affected.. state; any
or group of persons to request or _ ,,. __
l P P + petition for a public meeting with respect to NPDES
permit applications, Any person who desires a public meeting on any NPDES permit
application *.hall so request in writing to the Director within 30 days following the
publication date of the notice of application. Any such request or petition for public
muting sha).l indicate the interest of the party filing ;such request and the reasons why
a meeting is warranted,
(2) The Director is delegated authority to determine if a public meeting shall be held in
accordance with G.S. 143-21 .1(c)(3) and to issue public notice and conduct such
sleeting for the Commission,
() All commlents received within 30 days following the publication date of the notice of
NPDIES permit application shall be made part of the application file and shall be
considered by the Director prior to taking final action on the at,
(4) Any meeting brought pursuant to this Subsection shall be held in the geographical
area of the proposed discharge or other appropriate area, in the discretion of the
Director, and, may, as appropriate, consider related groups of permit applications.
(b) Adjudicatory Hearings and appeals shall be conducted in accordance with Article 3 of
Chapter 150E of the General - Statutes.
History Note: Authority G.S. 143-215.3(a)(1); 1 3-215.1(c)(1); 143-215.3(a)(3); 143-215.3(a)(4)
143-215.5, 143-215.1(e); Eff, February 1, 1976;
Amended l ff. Mardi 1, 1993; November 1 19 7,
15A NCAC 02H .01 12 FINAL ACTION ON PERMIT A1PPUCA.TIONS
t Fact Siaaoi
t NP )lES Rencwid
Page 7

NCI N -S7WO Fax m919-733-0 19 Oct 9 '0 :15 P. / 1
(a) The Director shaall take finial action can all NPD S applications not later than 60 days
following notice of intent to issue or deny, or, if a public meeting is held, within 90 days
following the closing of the record of the meeting or in the case of an Authorization to Construct
permit 90 days after the receipt of a complete application or, if a public meeting is held
concerning the Authorization to Construct, within 90 days following the closing of the record of
the meeting.
(b) The Director is authorized to.
(1) issue a permit containing such conditions as are necessary to effectuate the
purposes of G.S. 14 -215.1 and . � 143-2 1567,
(2) issue a permit containing time schedules for achieving compliance with applicable
effluent standards and limitations, water quality standards, and other legally applicable
re uirements;
(3) modify or revoke any permit upon living 50 days notice to the person affected
pursuant to Rule .0114(a) of this Section;
(4)'suspen.d a permit pursuant to Rule .01,14(a) of thisSection;
(5) rescind a permit upon request by the perrrzittee;
( a); decay a permit application:
() where necessary to effectuate the purposes of Article 21 Chapter 143
(H) for a discharge prohibited by G.S. 143-214.2(a),
(C) where the Secretary of the Army finds the discharge would substantially
impair anchorage and navigation,
(D) for a discharge to which the regional administrator of EPA has objected
as provided in Section 402(d) of the Clean Water Act as amended, 33 U&C,
Section 1251 et seq,
(F) for any point discharge which conflicts with a plan approved pursuant to
Section 208(b) of the Clean 'Water Act as amended, 33 U. S.C. Section 1251 et
seq, effective February 4, 1987.
(c) The permit applicant has the burden of providing sufficient evidence to reasonably ensure
that the proposed system will comply with all applicable water duality standards and
requirements. No permit may; be issued when the imposition of conditions cannot; reasonably
ensure compliance. with applicable water quality standards and regulations of all affected
states. a
(d) Permits shall be issued or renewed for a period of time deemed reasonable by the Director
except in no case shall permits be issued for a period to exceed five years.
f
History Note: Authority G.S. 143-215.3(a)(l); 143-215.1(c)(4); 143-215, l(b); 143-215.3(a)(3),
143.215.3(a)(4), 143-21 .1(c)( ), 1 3-214.2(a), 143-215; 14-215.2(a), Eff. February 1, 1 ' b,
Amended ;off. March 1, 1993; October 1, 1987; September 1, 1986; December 1, I9 4.
Proposed sched l6`for Permit Issuance
Draft Permit to Pu6lac Notice- September 11, 2002
Permit Scheduled to Issue: October 25, 200
References,
L 2002. NPDES Permit Application Form 11 Clarisnt Corporation,
. 2000. 30 mast of North Carolina Impaired W rs - Draft. ; North Carolina Division of
Water Quality, Water Quality Section. Copies obtained through Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
Pao shctt
NPDES Rcticwa]
Page
4

NCD NR-DW Fax :919-Z33-0719 Clot 9 '02 9`:15 P. 30/31
State Contact
if you have any questions on any of the above information or on the attached permit, please
contact cide Noi�cll t (91 ) i -5038 ext. 512
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IMAM .
NP SU R'VISCiR
NAME: DATE.
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NCDENR-DWO Fax:919-?33-0719 Oct 9 '02 9:lei P.31/31
Regional Office Comment
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Michael F. Eash
William G. Ross J
North Carolina Department of Environment and Natur,
::4 Alan W. Klimek, F
5 Division of V
'14
June 3, 2002
Mr. Gary Sanderson, Plant Services Manager
Clariant Corporation
Post Office Box 669246
Charlotte, North Carolina 28266
Subject: Cotripliance Evaluation Inspection
Clariant Corporation WWTP
NPDES Permit No. NCO004375
Mecklenburg County, NC
Dear Mr. Sanderson:
condi
and i
Respi
this r
I - -
cc of the facility are commendable. Please inform the facility's Op(
iarge of our findings by forwarding a copy of the enclosed report.
)ort, please do not hesitate to contact Mr. Lesley or me at [phone].
Sincerely,
<
D. Rex Gleason, P.E.
N Water Quality Regional Supervisor
;ure
Central Files
Mecklenburg County Department of Environmental Protection
Janet Boyer, Division of Air Quality, MRO
JL
4CIEWNR
N. C. Division of Water Quality 919 North MainStreet, Mooresville NC 28115 Phone [phone]
FAX [phone]

t
Name and Address of Responsibh
"ermit No. YR/MO/DAY It
1375 0/05130
Self -Monitoring Evaluation Rating
4
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Exit
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1Dat
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_-Title(s)_-- -- -Phone No(s
Ccial;
Permit Z plow l
Records/Reports 0 Self M
Facility Site Review El Compl
Effluent/ReceivingEffluent/Receiving Waters � j L.aborz
Sea
See Attached Sheet(s) for Summary
Signature(s) of tnspector(s):
John Lesley
?jp— , 6t
Signature of Reviewer:
MR
tion Type Inspector Facility
C S 2
QA ..Reserved...
September 1, 1991
e:
Permit Expiration Date:
August 31, 1996
7
Un Multimedia
] Other:
Date.
[phone] May 30, 2002
3'ency/office Date:
Schedules] Pretre
ri Storrs
q/Office/Telephone;
neguiarory viuce use c.vmy
Action Taken Date.
i
EPA Form 3560- (Revised -85) Previous Editions are Obsolete

Clar ant Corpartat on VIWTP
NPUES Permit No. NCO00 375
'age
Linda Love last inspected the facility on May 3, 2001.
Permit:
The permit expired on August 31, 1996. The renewed permit (expiration date of August
31, 2001) is under adjudication by the pe ittee; therefore, the permit that expired on August 31,
1996 is currently active.
The facility accepts trucked waste from outside sources. Be advised that all relevant facts
(including the fact that trucked waste is taken for treatment and a listing of the types of the
wastes) must be included in the permit application (see 1. A NCAC 2H .0114 (a)(2) and. 40 CFR
122.62) or the permit may be modified or revoked.. The facility permit that is in affect currently
allows for the treatment of both domestic estic d industrialwastewater, including categorical
sources of wastewater. As long as the wastewater being trucked in is of the same types of
wastewater the company historically treats, the activity may continue.
The permitted facility is a 3.9 MGD wastewater treatment plant consisting of bar screens,
acid'and alkaline pump stations, stormwater basins, air stripper -groundwater remediation system,
acid. neutralization — lime addition, two primary clarifiers, two sludge holding tanks, two belt
filter presses with polymer addition, two aeration basins with mechanical aeration, two
secondary clarifiers, chlorine contact chamber (not in use), two polishing ponds with mechanical
aeration, pal adjustment, effluent flow measurement, effluent storage lagoons, and an on -site
sludge landfill.
Facility Site Review/Operations and Maintenance:
The facility appeared to be well operated and maintained. One oft e primary clarifiers
and the sludge storage tanks were out of service for painting and general maintenance. One o
the aeration basins serves as a flow equalization basin. One of the secondary clarifiers is out of
service due to low flow in the facility. Ajet-purnp recirculation system has been added to the
aeration basin to improve mixing.
The plant' is staffed 24-hoursper day, seven days per week in two 2-hourshifts. The
CARC has a Grade TV certification and the designated backup has a Oracle frl Certification.
The facility accepts trucked waste (see Permit Section) from outside sources. On April
27, 2002 a'tanker of "MOT Brine" was accepted into the WWTP from the Clariant :facility in
Elgin, South Carolina. The addition of the waste caused an odor nuisance condition to occur in
the Mount Dolly area for several days. Ms. Janet Boyer, Division of Air Quality, investigated
the complaint. The complaint investigation confirmed the cause of the nuisance odor condition.
The WWTP staff took immediate actions to abate the nuisance; however, the odors persisted for
several days. No non -characteristic odors were noticeable during this inspection.
A comprehensive process control program consists of dissolved oxygen, pH, settleable
solids, MLSS, l L. SS d sludge blanket depth measurements. Sludge wasting is based on
Mean Cell Residence Time.

Clariant Corportation VVWTP
NPDES Permit No. NCO004375
Page 3
Self -Monitoring Program:
Monthly Self -Monitoring Reports were reviewed for the period April 2001 through
March 2002. No violations were reported for the period.
Samples are collected and maintained at 4'C during collection and storage. All sampling
events are well documented.
Laboratory:
The on -site lab is certified (Certification No. 217 expires December
BET, COD, TSS, ammonia as nitrogen, COD, and phenols analyses. Pace
all other required testing and analyses.
Sludge Disposal:
Sludge is dewatered and disposed of on site in a lined landfill cell ireI
Permit No. WQ0000537. Two of the nine cells have been capped. A new I
under construction. Landfill leachate is conveyed to the wastewater storag(
is removed by means of pumps and discharged to the 'TP.
Flow Measurement:
Flow is measured by means of an ultra -sonic flow meter equipped and chart recorder. On -site technicians calibrate the flow meter twice montl
was last calibrated on May 26, 2002.
Records and Reports:
Records and reports consist of monthly monitoring reports, chain of
sample analysis reports, flow charts, sludge records, process control data,
and maintenance reports, and tanker sampling data. The records and report
kept in accordance with permit requirements.
Effluent/R'w
aters:
aters:
The facility discharges into the Catawba River (WS4V, CTB34,
m an
ith a flow totalizer
ly. The flow meter
custody forms,
IRC log, operation
were up-to-date and
17Q10 = 95.0 CAS).
The receiving
stream did not appear to be impacted by the discharge.

Clariant Corporation — Mount Holly last Plant
Off -Site Waste Acceptance Protocol
clananil
MOUNT HOLLY EAST PLANT
SELF -AUTHORIZATION PROTOCOL FOR
N fN-CLA NT, NON -HAZARDOUS WASTE RECEIPT
Introduction
Theseprocedures provide an outlineof the evaluation process Clariant - Mount Holly; East will
utilize to accept off -site waste for wastewater treatment. This plan covers the protocol for initial
approval of off -site non-Clariant waste streams and the protocol for quality assurance and
verification for continuing acceptance of these waste streams.
New Wastestrearn Avoroval Procedures
1) Once a waste generator expresses interest in utilizing the Clariant - Mount Holly East
facility, the site Customer Service Representative will procure all ;pertinent information
concerning the composition of the waste under review, the process generating the waste,
any analytical data the generator may possess, all applicable' Material Safety Data Sheets
( MS S), and any relevant knowledge the generator has concerning the waste.
2 The above information will be compiled in a routing file and circulated to the following
members of Clariant - Mount holly East's staff for their evaluation;
A. Environmental Chemist/Engineer
B. WWTP Analytical Chemist
3 The Environmental Chemist/Engineer will perform an in-depth review of the chemical
nature of the waste and the process from which the waste is generated. This review will
include, but maynot be limited to, the following:
A. A complete evaluation of all. applicable MSIS's,
i. Determining ifwaste exhibits hazardous characteristics' as per 40 CFR
261:
a Determining if the material will react in an adverse manner after
exposure to water, air, or any other naturally occurring conditions
per the criteria of 40 CER 261.23.
Revised March 2001
1

Clariant Corporation — Mount Holly Fast Plant
Of Site Waste Acceptance Protocol
b. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 26121.
C. Determining if the waste could exhibit the characteristic of
corrosivity per 40 CFR 261.22.
d. Determining if heavy metals and organics meet or exceed the
concentrations specified in 40 CFR 261.24
ii. Determining if waste is a "listed" hazardous waste as per 40 CFR 261
based on the process from which the waste is generated and/or the raw
materials which comprise the waste (i.e. discarded commercial chemical
product).
iii. Determining the relative concentrations of any listed hazardous
constituents.
iv. Investigating the toxic effects, using up-to-date references, that may be
associated with any of the listed waste constituents, including threshold
and non -threshold health effects.
v. Determining the potential that may exist for the processing of the waste to
create an objectionable odor, of which the intensity might result in its
detection off: site. (NOTE: Clariant recognizes the subjectivity of an
"objectionable odor", and will employ analytical testing as well as a
"common sense" approach when an odorous waste is involved.)
B. A review of all other information that the generator has provided, including any
analytical data and the first draft of the completed profile sheet.
i. Determining if the chemical composition that the generator has provided
is satisfactory (qualitatively and quantitatively).
ii, Determining if the "name of waste" and the "process generating waste"
fully and accurately describes each.
iii. Evaluating any analytical data and determining if it is relevant (e.g., Is the
data current and applicable? Did a qualified laboratory perform the
analysis?).
iv. Identifying what additional information the generator needs to provide, if
any.
Revised March <2001
2

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

'Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
E. Coordinating treatability testing with the WWTP Analytical Chemist and WWTP
Supervisor.
4) The Environmental Chemist/Engineer will perform a cursory review of available
information and provide any relevant comments or suggestions.
5) The Environmental Manager may review additional testing requirements identified by
the Environmental Chemist/Engineer and approve the suggested tests and/or provide
recommendations.
6) The Customer Service Representative will procure any additional information the
Environmental Chemist/Engineer has requested. The Customer Service Representative
will route the sample to Clariant - Mount Holly East's laboratory, accompanied by a
request form describing all the analytical data needed.
7) Clariant - Mount Hotly East's WWTP analytical laboratory will perform, or contract out,
all the tests deemed essential. The results of these tests will be reported on a standardized
form, and all worksheets and subsequent report forms will be filed via a Mount Holly
Profile Number. (NOTE: Once a profile number is assigned, this information file will be
referenced by profile number.)
8) The laboratory will provide the Environmental Chemist/Engineer with the completed
analytical data. (NOTE: The WWT? Analytical Chemist will review this data and
approve it prior to distribution.)
9) The Environmental ChernistlEngineer will compile the analytical data and all other
required information on a profile sheet and assign the customer a profile number.
10) All of the above information, including the completed profile sheet, will be returned to
the routing file and circulated to each of the following for their final review and approval:
A. The Environmental Cher nist/Engineer
B. WWTP Supervisor
C. The Environmental Manager (Optional)
Each of the above persons will approve the final package prior to waste receipt.
11) The Environmental Chemist/Engineer will issue a Notice of Amhorization7 for the
approved vast trey to the appropriate Customer Service Representative. This notice
will stipulate any conditional monitoring involved regarding the processing and disposal
of the waste. The approved waste will be added to Clariant - Mount Holly East's "Non -
Hazardous to Approval Listine'.
Revised March 2001
4

'Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Qua4tj,ControVOualitv Assurance tolicy
1) Clariant - Mount Holly East will maintain its stringent quality control program for
incoming wastes. A representative sample will be taken from each containerized waste
and compared to the corresponding profile sheet. The following describes tests and
observations utilized by quality control.
A. Extracting representative core samples from each:
i. Bulk Shipment,
R. Containerized Waste Shipment (drums).
(NOTE: Samples of containerized wastes are composited according to
"like" physical characteristics. In the event a composite sample fails the
QAIQC evaluation, individual samples are taken from each drum
represented in the composite and tested.)
B. Comparing the physical characteristics of the sample to those listed on the waste
profile sheet (See Attachment
A). This comparison will include evaluating:
i. Color,
ii. Odor,
in. Physical State,
iv. Viscosity.
C, Analyzing the pH of the waste.
D. Observing any reactions (eg. fuming, boiling, etc.).
Revised March 2001
5

Clariant Corporation -- Mount doily East Punt
Off -Site Waste Acceptance Protocol
When any discrepancies in the waste are observed, an off -specification notification is
completed, noting the discrepancies. This memo is addressed to the Customer Service
Representative and the Environmental Manager. An amendment to the profile will be
issued to account for the change in the waste when deemed appropriate. (NOTE. The
generator will be advised of this situation. In some instances, the waste may be rejected
because of an cuff -spec characteristic (e.g. strong odor).
In the evert a waste is identified as exhibiting a hazardous characteristic, a non-
conforming/off-specification waste memo will be completedand ; routed to the
Environmental Manager and the tamer 'Service Representative, (NOTE: The
Environmental Chemist/Engineer will take the active role in thismatter.) Prudent
measures will be taken to isolate and secure the waste.
If a waste exhibits a characteristic potentially outside the parameters for non -hazardous
waste, the waste will be rejected and the material removed from the facility. If the waste
requires additional laboratory analysis to determine if it is a RCRA hazardous waste, the
material will be considered rejected on the day the laboratory analysis is returned
indicating a potential hazardous us characteristic, and the material will be removed from the
site.
If the generator chooses to have the waste returned to his facility, the Customer Service
Representative will make arrangements for the generator to use a hazardous material
transporter. Also, Clariant-Mount Holler will indicate the rejection to the generator on the
bill of lading, non -hazardous manifest, etc. This rejection will stipulate the suspected
hazard class.
Clariant - Mount Holly East will offer the generator the choice of having the waste routed
to a TSDF for disposal, Clariant' - Mount Dolly East will reject the waste on the
discrepancy portion of the non -hazardous waste manifest. The generator will complete a
hazardous waste manifest and forward this document to Clariant - Mount Molly East, a
copy of the non -hazardous manifest will be attached. Clariant - Rio t :Dolly East will
list in having the waste transported via a hazardous waste carrier to the designated
facility.
Revised March 2001
6

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

P,�Yis 2002 13:34 FR C.AR IANT-EHSA 704+622+22 41 TO 97046637579 P.01/0e
P
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Clariant Corporation
F.U. box
Charlotte, North C=Iina 669246-9246
ESHA Telefax Number (704) 822_=41
TELEFAX TRANsw=,AL
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E. Director
May 15, 2002
Mr. Don Price
Utilities Director
City of Mt. Holly
P.O. Box 406
Mt. Holly, NC 28120
Subject: Complaint Investigation
Odors
Clariant Corporation
11701 Mt. Holly Road, Charlotte
Mecklenburg County, NC
03/60/00687
Air Permit No. 08542R14
Dear Mr. Price:
Reference is made to your complaint which was received in this Office on April 29, 2002 with
spy of the complaint investigation report.
to contact Ms. Boyer or me at [phone].
Sincerely,
Tamara
Regional Compliance Supervisor
JSB:wjp
Enclosure
G:\DEM\AQ\WPDATA',,COLJNTIES\MECKLENB00687\020515.LET
Mooresville Regional Office � 919 North Main Street Mooresville, North Carolina 28115
Phone: [phone] \ Fax: [phone] \ Internet: http://daq.state,nc.us/
An Equal Opportunity 1 Affirmative Acton Employer — 50% Recycled k 10% Post Consumer Paper

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AQ-16 Revised 9119/95 G:\DEM\AQ\WPDATA\COUNTIES\MECKLENB\00687\02043 LCI 6
NORTH CAROLINA DIVISION OF AIR QUALITY
Vi
Air unlit Action Ito ort
Name Location Reg/Co./Prem.No.
Clariant Corporation Mount Holly, Mecklenburg/Gaston County 03/60/00687
Contact Telephone
Mr. Don Rierson 704/822-2165
A -11 t-Ir V WV 17' V t-kA.­
A By: Address/Phone Ree'd Date
ratkins/Garrett 4/29/02 - 4/30/02
Action Date 4/30/02 Next Insp. Date
U4 Issued 1/24/02 Expires 5/31/04
0 ITS ❑ TOXLB 0 COMPLAIN 0 I -STEPS Action Number:
ins: Signature: Date:
►utility Janet S. Boyer
Is
travel 1-77 South to the Mt. Holly/Huntersville Rd. exit. Follow Mt. Holly/Huntersville Rd. into Mt. Holly.
ited on the left, just inside the Mt. Holly city limits.
!IIIIIII I I III mill I I
over the weekend. Mr. Price stated that he had checked the city sewers and found nothing unusual. He ibelieved the odors
were coming from Clariant.
On April 29,2002, at approximately 9:45 am., this office received a phone complaint from Ms. Tina Starries, a Mount Holly
resident. She stated that there had been odors over the weekend, and that the odor that occurred at approximately 8:00 p.m.
Saturday was especially bad. She described the odor as "Weed and Feed mixed with something dead". She had already
contacted Mr. Gary Sanderson at Clariant to complain.
On April 29, 2002, at approximately 1000 a.m., this office received a phone complaint from Ms. Rachel Watkins. Ms.
Watkins stated that she drove along Highway 27 near Clariant at about 8:00 p.m. Saturday. There was a "dead, rotten odor".
She stated that everyone in the car became nauseous, and one child vomited.
On April 30,2002, at approximately 8:30 a.m., this office received a phone complaint from Ms. Kelly Garrett. Ms. Garrett
had a similar complaint, and described the odor as "rotten eggs, sewage". She stated that she and her husband began noticing
the odors last year, but it was getting worse. She had just been outside her house that morning and smelled the same odor.
She believed it was coming from Clariant.
I arrived at the site at approximately 10:45 a.m. on April 30, 2002. The weather was clear and sunny with wind E-Sly 5 to
10 mph. I noticed a slight, unpleasant odor in the parking lot. I called Mr. Don Rierson, Sr. Environmental Engineer, upon
arrival at the Clariant property. Mr. Rierson met me in the lobby, and shared with me what he had learned about the odors.

Clartant Corporation
April 30, 2002
'age No. 2
(see Clariant Incident
WWTP.
on stated that the odor seemed to
and shipment dates). He also stated that they were now refusing to accept wastewater from the Elgin facility, The Clariant
WWTP began accepting wastewater from other companies, "about Labor Day last year," to help offset operating costs at the
plant, according to Mr. Sanderson (see attached marketing material).
We toured the wastewater treatment facility. There was a strong odor downwind of the equalization pond, (Z03A). Aerators
had been started in Z03A at approximately 7:00 pm. Saturday. The aerators were removed Monday afternoon and replaced
with mixers. There was a slight odor downwind of the activated sludge treatment pond (Z04), and from the "staging lake".
The effluent from the treatment system was dark brown.
Mr. Sanderson stated that river water was being brought by way of the backwash canal to increase the flow from
approximately 250,000 gpd to approximately I mgd. Since Z03A has about 4 million gallons of capacity, it should take about
4 days to clear the odor causing chemical from the system. However, the "staging lake" contains 150-200 million gallons
of wastewater with unknown quantities of the odor causing chemical.
Recommend that the issue be referred to Division of Water Quality.
JSB:wjp

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Complaint Form 02 (Revised 9/01 )
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County: Date:
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Repeat Caller: El Yes S"NO
Responsible Party:
Street Address:
Phone:
City/ State/ 7jp:
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Phone:
None [E]�Call Back Letter
Phone
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:':TDLate
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Complaint Record Number: I -STEPS Acton Number Personal Log

Division of Air Quality Complaint Form
County:
CA 0
Date:
Time; r
RepeatCaller: Yes Eh6
Responsible Party:
Street Address:
Phone;
City/ State/ Zip:
Phone:
Nature o
Complaints [
F
Note. Document duration, any health effects, and any damage to property. Get as much detail as possible.
J�Direc " o
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Note; Verify these
directions by repeating them to the caller..
Ask Complainant: "Do you wish to provide your name for the public record?"
Is this complaint: 2Public Record Anonymous
Follow-up requested; !None Call Sack Letter
Nate: Only two attempts will be made to contact the complainant by phone. If the complaint is followed up by phone, a letter will
not be sent.
Complainant Name:
Street Address:
Phone: '.,j
City/ State/ dip:'
Phone:
Call Received by:
Complain�Investlgated ; by: &d
Dates Investigated:
Date Letter Sent:
(or) Dates Called:
Comments:
Data Tracking: Q Complaint Record !Number: 1-STEPS Action Number: F] Personal Leg
Complaint Form 02 (Revised 9101 )
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Division of Air Quality Complaint Form
Date:
V­N]
Responsible Party:
C-1
Street Address:
Phone:
City/ State/ lip:
Phone:
Nature of
Note: Document duration, any health effects, and any damage to property. Get as much detail as possible.
Directions to
Note: Verify these directions by repeating them to the caller.
Ask Complainant 'Do you wish to provide your name for the public record?"
Is this complaint EY-P-ublic Record 0 Anonymous
Follow-up requested: Ej None E�rcall sack E] Letter
Note: Only two attempts will be made to contact the complainant byphone. if the complaint is followed up by phone, a, letter will
not be sent
Complainant Name:
Street Address:
City/ Statel Zip:
Phone:
Call Received by:
Complaint Investigated by:
Dates Investigated:
Date Letter Sent: (or) Dates Called:
DataTracking: El Complaint Record Number: E] I -STEPS Action Number: Personal Log
'
'
�
Complaint Form 02 (Revised
^

PRINT
Clariant Incident Management System
Incident Investigation Report
t. Hmliv Incident 20020044 Status: 0 en it"ltiafedbv: Daniel Grieneisen
on Sectil: First Deport
rs
Title: Odor Complaint 4-27-02' Date/Time of Incident: 04/27/2002 08:30:00
PM
Date Reported 04/27/2002
Location Information
co
mpany= µ Clariant Corporation _ Organization:,
Country: USA Dept. where incident
_ :. .. occurred:. '..
Site: Mt, Holly
Town: Mt. Holly, N. onsite Area, Offsite
E
Location:
Details and Classification
Incident Description:
Initial Report:
Numerous odor complaints were received from on -site sources and the neighboring area during the evening hours (note: the
wind direction was primarily from the south and slightly SSE at times. The wind speed was estimated at 0-10 mph).
At approximately 7:00 PM, the MHE security officer reported a "sewage" odor at the MHE gate house that appeared to
dissipate after a short time.
At approximately 8.20 PM, MHW security notified Dan Grieneisen of a sulphur -like odor at the MHW gatehouse. D Grieneisen
reported to the gatehouse.
At :30 PM,' Darren Honeycutt (8 7-4998) called the MHW gatehouse to complain of an odor that he would describe only as "it
Riverbend.°"
Type of Incident:
Ctassiflcation:
�[
0 Allegation
Near Miss (injury/illness)
Environmental
L Excursion
Near Miss (Property)
0 Process Safety (CMA)
Fire/Expiosion
❑ Near Miss (Spill/Release)
L7 Process Safety (EPA RMP)-
1 Injury/Illness
1:1 Property Damage
EJ Process Safety (General)
Near Miss (Excursion)
El Spill/Release
Q Process Safety (OSHA)
Near Miss (Fire Explosion)
Safety
[� Transportation/Distribution
Page: 1
Printed on 04/28/2002 at 08:05:40 AM

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0,�/27/2001 14:59 8034987750 CLARIANT PACE 04
Clarlant Corporation
Mount Holly Last
Wastewater Treatment FAdlItY
[phone]
VII. Other Components
Does the waste stream contain any of the following components?
COM onent Yes No Actual Concentration
PCBs
C anides
Sulfides
Pesticides
Pheaolics
Dioxins
VITL Shipping Information
M*77 -1,_ 1). 6 L) t)
X CWT Contaminants
Does the waste contain any of the following contaminants aboveAdtfoit leveh described
below?
C000m, Alit
Present Above Action
Acita Cooeo*oo�
•
3 of 4

0171001 14.58 8034387750 GLARIANT PAGE 05
Clariant Corporation
Mount Rolly East
Wastewater reatrnent Facility
(10) 27- 651
a Certification
.-A ni�prvtmmn
complete. I aware' that there are significant pen
fine and irnprisozunent for knowing violations.
Date;
Signatures ---
t Narn o
Title: V 0dM
ii
4 of4

Clara
Mr
Wastewater Tre
Clarlan-L
nt Corporation
[phone]
y
uy m
« 1! •
i r►/
IT. Billi ty Information
•
i
• •
•
Characteristics
•
_Multilayer
•
I of 4

Clariant Corporation
y` Mount Hotly East
Wastewater Treatment Facility
(704) 27-96 1
V. Chemical Composition
Constituent Ran ` e Units
k
.!
q
♦ ®.
#
f
®.
Above TCLP Based on (] ActualTesting Generator Knowledge E] Both
Is this waste a listed waste pursuantto 40 CFR Pert 26 ? Yes No
Is this waste a deeharaeterized CRA D002 corrosive waste? Yes No
2 of
Above TCLP Based on (] ActualTesting Generator Knowledge E] Both
Is this waste a listed waste pursuantto 40 CFR Pert 26 ? Yes No
Is this waste a deeharaeterized CRA D002 corrosive waste? Yes No
2 of

VIL Other Components
Does the waste stream contain any of the following components?
Clarlant Corporation
Mount Holly East
Wastewater Treatment Facility
[phone]
Com oent
Yes No
Actual Concentration
PCBs
C anides
Sulfides
El T
Pesticides
❑
Phenolics
d
o `
Dioxins
i
Halogens
0
VIII. Shipping Information
7!t
•MEN
tegorical Standard Determination
ess generating the waste listed in the 0 Yes No
al" standards pursuant to 40 CFR
r'N7
veered yes to the previous question,
tegorical" standard is the waste
r`
VT Contaminants
waste eantain any of the following contaminants above action levels described
below?
Contaminant
Action Level
Present Above Action Actual Concentration
Level?
Oils and Grease
100 m /L
[ ] Yes '
No
Co er
4.9 m /L
Yes '
No
Chromium
Cadmium
5.0 mg/L
0: m /L
Yes
Yes /
No
, No
Nickel
37.5 m,
� Yes
No
3 of 4

Clariant Corporation
Mount Holly East
Wastewater "Treatment Facility
[phone]
L Certification
fine and imprisonment for knowing violations.
Signature. Date;
i
MAN _ �a�5st`1i�onV%AP LJ,

3rd Party Wastewater Treatment: Business Volumes by Broker
Broker. larint-Mt. Holly East
Generator Profile No. Date
Shipment
Size(gal)
Glariant-Elgin S.G. Plant MHE-2001- 033 01.09.02
4594
01.10.02
4624
01.11.02
4548
01.21.02
4531
MH-2001-0004 01.28.02
4461
01.2902
3918
01.3002
4441
02.1102
4791
02.11 r02
4696"
02.1202
4435
02.132
4668
02.1302
4645
02.1802
4741
02.19.02
4720:
04.1502
4263
04.18.02
4353
4583
04.2302
04.2402
4930
aj..i
04.25.02
04,2602
4313
2695
i-R

3rd Party Wastewater Treatment: Business Volumes by Broker
Catawba Charlab Totals
204,339
Broker: Clariant-Mt. Holly East
Generator Profile No.
Date
Shipment
Size(gal)
Clariant-Elgin S.C. Plant MHE-2001-0002
09.06-01
4221
09.07.01
4315
0911.01
4357
09.13.01
4108
MHE-2001-0004
09.17.01
3548
09.19.01
3866
09.21.01
4212
09.25.01
4791
0926.01
3952

Clan*ant
Mt. Holly East Plant
P.O. Box 669246 11701 Mt Holly Road
Charlotte, North Carolina 28266-9246 Charlotte, North Carolina 28214
[phone]
ieck Mr. Gaj
-2743 (704)82
aIariantcom Lamsanc
oral Services:
anderson
787
Ln, ,Lv-elariant com
Offered:
n
County. The site's EP. identification number is NCD 001810 3-65.
The East Plant wastewater treatment facility employs a tertiary treatment process capable of
handling complex organic molecules, widely variant pH ranges, high COD materials, and
materials of varying contents of dissolved and suspended solids.
Mt. Holly East Plant Environmental Permits and Information
The site's various environmental permits are all approved and administered by the North
Carolina Department of Environment and Natural Resources, DENR, Names and phone
numbers of DENR personnel knowledgeable in site compliance are available, but are not
included in this package of information. The site is happy provide this information. Just
call or email us.
Revised October 2001

t. Dolly East Plant -- Wastewater Treatment and Disposal Services Information Package
Page
The site operates under the following specific environmental permits:
Direct DischargeWastewater- NPDES Nt O004375
Sludge Residuals Landfill: WQ0000537
Sto water: NCS000037
RCRA Part B: NCDOO 1810365
Air Emissions: 08542RO5
Revised October 2001
2

Clariant
Mt Holly East Plant Phone: [phone]
P.O. Box 669246 Fax: [phone]
Charlotte, N.C. 28266-9246
L General FacHily, Information
A. Facility name, mailing address, and telephone number:
Clariant Corporation — Mt. Holly East Plant
P.O. Box 669246
Charlotte, North Carolina 28266-9246
[phone]
R Physical Site Location:
11701 Mt. Holly Road
Charlotte, North Carolina 28214
C. Principal contact(s), title(s), and telephone number(s):
Gary P. Sanderson, P.E. Bob Heck
ESHA/Engineering Manager Safety/Environmental Supervisor
704.822.2787 704.822.2743
customers and external customers.
Thew treatment plant unit operations are listed below
Blending and Chemical Pretreatment
pH Neutralization (pH 3 — 12)
Primary Settling and Clarification
Biological Oxidation
Secondary Clarification
E. The site is owned and operated by Clariant Corporation, a publicly owned Swiss
specialty chemical manufacturer. The U.S. operations are headquartered in
Charlotte, North Carolina. The company has manufacturing operations located in
10 states.

Clariant Corporation — Mr. Holly East Plant
Company and Site Information
F. U.S. Headquarters:
Clariant Corporation
4000 Monroe Road
Charlotte, North Carolina 28205
. Kenneth Golder, President
704.331.7 00
G. Corporate Headquarters:
Clariant Ltd'
Rotha ` stra se 61
CH4132 Muttenz 1
Switzerland
Phone: [phone]
H. Site Administrative Information
The facility manager is Mr. Nickolas H. Altman. Altman is a de reed chemical
engineer. He h 2 years of experience with Cl . t.
ec at t-,Idi aru, an of It: Ut Luc ivu. nv].iy r 141ic. ,Lv-tl . Flv u:sv'"L ;5uFv1 v i�c� u"; z"
testing laboratory, in -process testing personnel, and wastewater treatment plant
ersonnel.
Dry Information
A. The facility's EPA Identification Number: iCDOO1810365
B. The site's environmental operating permits are listed on the next page. Copies of
the permits are not included in this package. The RCRA Part B permit and the air
permit occupy several hundred pages of typed material. "

Clariant Corporation — Mt. Holly East Plant
Company and Site Information
B. Permit Listing
Expiration Permit Permit —Issuing Permit Issue
Date I32e Agency Number Date
8/31/96 NPDES, NCDENR NCO004375 9/1/91
10/31/99 Stormwater NCDENR NCO00037 8/31/94
4/30/02 Landfill NCDENR WQ0000537 5/30/00
1/2/07 RCRAPartB NCDENR NCDO01810365 1/2/97
5/31/04 Air NCDENR 08542RO5 6/4/99
C. Listed below are names and telephone numbers of the environmental regulatory
officials with whom the facility's management deals:
NPICES Point Source Discharge: Mr. Michael Myers [phone]
Stormwater Discharge: [phone]
Landfill Cell: Ms. Shannon Thornburg [phone]
RC RA Part B: Mr. Karim Pathan, P.E. [phone]
Air Permit: [phone]
D. Descriptions of notices of violation received during the last five years are listed
below. None have resulted in fines or follow up by NCDENR.
September 2001: RCRA NOV for not having a means of remote communication at
a satellite accumulation point
May 200 1: Landfill Cell NOV for late submittal of annual monitoring report
May 1998: NPDES NOV for exceeding a maximum discharge quantity for
ammonia on a single day
E. Status of any regulatory actions relative to the site.
There are no actions for non-compliance at the Mt. Holly site. The site has ongoing
groundwater remediation and monitoring requirements and the site is on the
National Priority List. All requirements of the EPA' s record of decision relative to
CERCLA have been met.
The site has multiple SWMUs and has pending confirmatory sampling plans on
file with NCDENR. Quite a few SWMUs have been retnediated in the past and
others are planned for remedial activities over the next few years.
The groundwater under portions of the site is being pumped and treated at the
wastewater treatment plant. There are RCRA and CERCLA pumping systems in
place. The site samples and analyzes groundwater from multiple wells on a semi-
annual basis. Reports of the results are forwarded to DE NR once a year.

-I a m a i- Nei
CtaTiant Corporation — Mt. Holly East Plant
Company and Site Information
-1 1"T," 1"T A 'hqxn-
ter Treatment Information
- . ! I I
I lit; b1W lb U;;11%1V1U ailu avvw�a u, vw-
hours a day. , All vehicles are logged in. Visitors are met at the gatehouse by a
Clariant employee and escorted during their stay on site.
B. Receiving Information for Shipments of Wastewater
Truck load wastewater shipments are logged in at the gatehouse and weighed upon
receipt. A Clariant operator accompanies the truck to an unloading point within the
WWTP complex. Either the driver or the Clariant operator samples the shipment.
The operator gives the truck driver approval to unload the truckload. The truck
returns to the gatehouse and is weighed out.

Clartant Corporation — I. I
Wastewater Acceptaw
Revision Date: 09.19.2
East Plant
- *ter*
t ia
one or more limits will be studied and may be accepted.
Arsenic
5.0 mg/l
Barium
100.0
Cadmium
0.2
Chrome
5.0
Copper
4.9
Lead
5.0
Mercury
0.2
Nickel
37.5
Selenium
1.0
Silver
5.0
Zinc
50.0
Oil & Grease
100.0 mg/l
NH3-N
8,000 mg/l
TSS
30% by weight
Phenol
250 mg/l
COD
500,000 mg/l
pH
Between 2 and 12 (pH outside this range will not be accepted)
Color
Upon approval (determined upon testing of sample)
Odor
Pungent or noxious materials not accepted
Certain other parameters may cause a wastewater to be turned down for treatment. Examples are
high levels of chlorinated cyclic compounds, certain cresols or phenolics, and certain pyrene or
anthracene derivatives.
If there are questions, please call 704-822-2787 or 704-822-2743 for information.

lariant Corporation
Mount Holly East
Waste Treatment
Pre -Shipment a
Analysis
MHE Profile Number
MHE-2000-0139
Waste Name
Extremely Bad Wastewater
Analysis
Perform Test
Results
H
Yes No
4.81
Specific Gravity
'Yes No
1.000
COIF
Yes No
85,900
Phenols
Yes No
2.4
Respirometry
Yes No
Non Topic
BOD, 5-lea
Yes No
37,228
Plash Point
Yes No
Metals Scan
"Yes No
olatiles Scan
Yes No
e ni- ©ladles Scan —Yes
No
Color Description Dark amber liquid
Odor Description Smells like mone
Lkppearance
iscosi
Other Observations "TSS = 3410 l

Clariant Corporation
Mount Holly Cast
Wastewater Treatment Facility
[phone]
clan,ant
Profile Number
L Generator Information
Generator Name
Ehysical Address
City, State, Zip Code
Mailing Address
City, State, Code
Phone Number
Fax Number
EPA ID Number
Primary Contact
Site Business Description
SIC Codes f Faci!jty
IL Billing Information
Customer
Address
City, State, Zip Code
Contact Name
Phone Number
Fax Number
M. Waste Description
Waste Name
Description of Process
Generating Waste
SIC Code(s) Associated
with the Generation of this
Waste Stream
EPA Waste Codes�
. Waste Characteristics
Physical State Solid
Liquid Sludge
1,aycring None
Bilayer El Multilayer
Viscosity Low
Medium
Specific Gravi!X
Flash Point El None
El < 140 F > 140 F
Ilan e To
Odor
Color
I of 4

IMI�
41
IT
lot W#=
01 On raw"Opuffm­y
0
r%.11vw,tuug-, Ju til
-Yes No
es
2 of 4

Clariant Corporation
Mount HOW Last
Wastewater Treatment Fadlity
[phone]
er Components
aste stream contain any of the following components?
t Yes No Actual Concentration
ELL -
)ping Information
J1 lYearlv erlv F
A II Concentration
Mwrl
FUJI
3 of 4

Clariant Corporation
Mount Holly East
Wastewater Treatment Facility
[phone]
rication
I am aware that there are significant penalties for submitting false information, including the possibility of
mprisonment for knowing violations.
Date:
fte: Title-
4 of 4

lan*aint
MOUNT HOLLY EAST PLANT
SELF -AUTHORIZATION PROTOCOL FOR
NON-CLARIANT, NON -HAZARDOUS WASTE RECEIPT
ion
cedures provide an outline of the evaluation process Clariant - Mount Holly East
accept off -site waste for wastewater treatment. This plan covers the protocol for initial
A off -site non -Clan ant waste streams and the protocol for quality assurance and
a for continuing acceptance of those waste streams.
'estream Anoroval Procedures
ce a waste generator expresses interest in utilizing the Clariant - Mount Holly East
--------------
Environmental Chemist/Engineer
WWTP Analytical Chemist
includes, but is not be limited to, the following:
A. A complete evaluation of all applicable MSDS's.
i, Determining if waste exhibits hazardous characteristics as per 40 CFR
261:
a. Determining if the material will react in an adverse manner after
exposure to water, air, or any other naturally occurring conditions
per the criteria of 40 CFR 261.23.
b. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 61.21.
Revised March 2001

Clariant Corporation — Mount lolly Fast Plant
Off -Site Waste Acceptance Protocol
C. Determining if the material could be expected to exhibit the
characteristic of ignitability as specified in 40 CFR 26 1.21.
d. Determining if the waste could exhibit the characteristic of
corrosivity per 40 CFR 26112.
e. Determining if heavy metals and organics meet or exceed the
concentrations specified in 40 CFR 261.24
ii. Determining if waste is a "listed" hazardous waste as per 40 CFR 261
based on the process from which the waste is generated and/or the raw
materials which comprise the waste (i.e. discarded commercial chemical
product).
iiii. Determining the relative concentrations of any listed hazardous
constituents.
iv. Investigating the toxic effects, using up-to-date references, that may be
associated with any of the listed waste constituents, including threshold
and non. -threshold health effects.
V. Determining the potential that may exist for the processing of the waste to
create an objectionable odor, of which the intensity might result in its
detection off -site. (NOTE. Cl ant recognizes the subjectivity of an
"objectionable odor'-", and will employ analytical testing as well as a
"common sense" approach when an odorous waste is involved.)
1 . A review of all other information that the generator has provided, including any
analytical data and the first draft of the completed profile sheet.
i. Determining if the chemical composition that the generator has provided
is satisfactory (qualitatively and quantitatively).
ii, Determining if the "name of waste" and the "process generating waste"
fully and accurately describes each.
iii. Evaluating any analytical data and determining if it is relevant (e.g., Is the
data current and applicable? Did a qualified laboratory perform the
analysis?).
iv.Identifying what additional information the generator needs to provide, if
any.
Revised March 2001
2

C;lariant Corporation - Mount Holly East Plant
Off -Site Waste Acceptance Protocol
C. An assessment :of the accuracy of the information the generator has provided
concerning physical characteristics of the waste.
i. Comparing the physical state and consistency of the sample with profiled
information.
ii. Associating the odor of the waste with specific chemical groups (e.g.,
Does the sample exhibit an odor associated with volatile organics?
Halogenated organiccompounds? Sulfurous compounds?).
iii. Determining the oil content (e.g. Does a visual inspection of the sample
correlate with the information on the profile?).;
iv. , Verifying the color and any ether characteristics which can be confirmed
vi±sually.
D. A determination of all the analytical tests which must be performed on a
representative sample prior to completing a final profile sheet. (NOTE: Analytical
test methods employed have been approved by the United Mates Environmental
Protection Agency and are prescribed in the EPA.. manual S-46 and Standard
Methods.)
i. Tier I "Testing
For all non-Clariant waste materials a standard battery of testing will be
performed for each new material submitted for approval. The Tier 1 tests
are as follows:
a. Chemical Oxygen Demand (COD)
b. pH
c. Oil and Grease
d. Phenols
e. Respirometry Testing
ii. Tier II 'Testing
For all non-Clariant-waste materials submitted for approval, Clariant may
require testing for parameters other than the Tier I parameters. The Tier H
testing is optional and is only done when the Environmental
Chemist/Engineer believes it is necessary for a waste stream approval.
Any of the following tests may be performed as part of the 'Tier 11 testing,:
a. Flash Point
b. RCA Metals along with capper, zinc, and nickel.
. Volatile compound scan..
d Semi -Volatile compound scan
e Biological Oxygen Demand (BC D)
Revised March 2001
3

Clariant Corporation — Mount Holly East Pla
Of Site Waste Acceptance Protocol
E. Coordinating treatability testing v
h the WWTP Analytical Chemist and WWTP
stir,
mtnl ('hPmict1Pncrin,-Pr nPrfArMZ n (nimnry ri-view of ivniinhie information
provides any relevant comments or suggestions.
Environmental Manager may review additional testing requirements identified by
Environmental Chemist/Engineer and approve the suggested tests and/or provide
immendations.
Customer Service Representative will procure any additional information the
ironmental Chemist/Engineer has requested. The Customer Service Representative
route the sample to Cl 'ant - Mount Holly East's laboratory, accompanied by a
test form describing all the analytical data needed.
iant - Mount Holly East's WWTP analytical laboratory will perform, or contract out,
I. +­+� A ----A -.­44�1 'rl.- ^f fl­a fr oto A17;11 ka r�tArwftsA nn q et"And"Mi'70d
Environmental Chemist/Engineer will compile the analytical data and all other
All of the above information, including the completed profile sheet, will be returned to
the routing file and circulated to each of the following for their final review and approval.
A. The Environmental Chemist/Engineer
B. WWTP Supervisor
C. The Environmental Manager (Optional)
Each of the above persons will approve the final package prior to waste receipt.
`environmental Chemist/Engineer will issue a "Notice of Authorization" for the
,ved wastestream, to the appropriate Customer Service Representative. This notice
tipulate any conditional monitoring involved regarding the processing and disposal
waste, The approved waste will be added to Cl ant - Mount Holly East's "Non-
-dour Waste Approval Listing".
Revised March 2001
4

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
QualiLy Control/QualiLy Assurance Polio`l
quality control program for
,n from each containerized waste
is utilized by quality control.
-acting renresentative core samples from each:
Bulk Shipment,
iL Containerized Waste Shipment (drums).
(NOTE: Samples of containerized wastes are co posited according to
"like" physical characteristics. In the event a composite sample fails the
QA/QC evaluation, individual samples are taken from each drum
represented in the composite and tested.)
B. Comparing the physical characteristics of the sample to those listed on the waste
profile sheet (See Attachment
A). This comparison will include evaluating:
i. Color,
ii, Odor,
iii. Physical State,
iv. viscosity.
C. Analyzing the pH of the waste.
D� Observing any reactions (e.g. fuming, boiling, etc.).
Revised March 2001,
5

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

Clariant Corporation — Mount Holly East Plant
Off -Site Waste Acceptance Protocol
Information Maintained For The NCDENR Division of Water Quality
1) Cl "ant - Mount Holly East will create and maintain records for all new wastestrearn
profiles prior to processing the waste,
2) Cl ant - Mount Holly East will also maintain an updated Generator Listing. This listing
will include:
A. The generator profile number,
B. The generator name and address,
C. The name of the waste,
D. Anv nertinent cornment.,z h-, a wnh+ nU flnzh nn;nt ^,F
waste manifest, etc.)
nt — Mt. Holly East will treat all incoming materials using a "batch metho
record will contain details of the quantities of individual profiled wastes treated.
Revised March 2001
7

Mount Holly Bast 3'taU
Wastewater Treatment Plant
Monthly Summary
F January 200
FLOWS (total) FINAL DISCHARGE (average)
Jan. YTD Jan. YTQ
Final (MG) 42.4 42.4 BCD (mg/L) 4 4
-02C (MG); 0.0 0.0 COD (mg/L) 51 51
Groundwater (MG) 2.0 2.0 TSS (mg/L)' 8 8
Process Water (MG) 36.6 36.6 Ammonia (mg/L) 33
Phenol (mgCL) _ 0.05 0.05
EFFICIENCY (average) AIR STRIPPER
Jan. YTD Jars. YTD
BCD Removed 97.1 97.1 Hours Run 667 667
COD Removed 78.5 78.5
OD removed (lb/day) 1494 1494
CAD Removed (lb/day) 2114 2114
SLUDGE
Jan. YTD
Wasted Sludge Flow (average MGD) 0.032 0.032
Sludge Landfilled (total dry tons) 113 113
1_3 Sludge Cake (% dry) 27.1 27.1
APR 2 4 22

Mount Nally East
Wastewater Treatment Plant
Monthly Summary
February 2001
FLOWS (total)
FINAL DISCHARGE (average)
Feb. YTD
Feb.
YTD
Final (MCA)
38.5 80.9
BOD (rng/L)
-02C (MSS)'
1.6 1.6
COD (mg/L)
96
63
Groundwater (MCA)
2.1 4.1
TSS (mg/L)
8
8
Process Water (M)
32.1 68.7"
Ammonia (mg/L) ,
1
2
Phenol (mg/L)
0.06
0.06
EFFICIENCY (average)
AIR STRIPPER
Feb. YTD
Feb.
YTD
BCD Removed ()
98.9 ' 98.3
Hours Run
618
1300
COD Removed
74.8 76.7
BOD Removed (lb/day)
3729 2606
COD Removed (lb/day)'
1902 2009
SLUDGE
Feb.
YTD
Wasted Sludge Flow (average MD)
0.09
0.035
Sludge Lndilld (total dry tons)
122
23
Sludge Cake ( dry)
26.8
26.9

Mount Molly East
Wastewater Treatment Plant
Monthly Summary
March 2001
FLOWS (total) FINAL DISCHARGE (average)
March YTD
March
YTQ
Final (MG)
48.8 129.5 BCD (mg/L)
11
6
-02C (MG)
0.4 2.O COD (mg/L)
70
59
Groundwater (MG)
2.6 3:7 TSS ( g/L)
8
Process Water (MG)
32.3 101.0 Ammonia (mg/L)
2
Phenol (mg/L)
0.05
0.05
EFFICIENCY (average) AIR STRIPPER
March YTD
March
YTD
BCD Removed (°)
90.8 95:7 Hours Run
715
2038
COD Removed (%)
72.2 75.0
BCD Removed (lb/day)
1378; 2174
COD Removed (lb/day)
2376 2131
SLUDGE
March
YTD
Wasted Sludge Flow (average M D)
0.044
0.038
Sludge Landfilled (total dry tons)
92
326
Sludge Cake (% dry)
24.2
26.1

Mount Holly East
Wastewater Treatment Plant
Monthly Summary
Aprll2001 `
FLOWS (total) FINAL DISCHARGE (average)
April YTD
A rllYTD
Final (MG) 34.8 154.3 B D (mg/L)
5'
Z-02C (MG) 0.0 2.0 COD (m /L)
44
55
Groundwater (MG) 2.2 8.9 T(mg/L)
10
8
Process Water (MG) 26.1 127.1 Ammonia (mg/L)
5
3
Phenol (mg L)
0.08
U
•- AIR STkIPPtR.
April YTD
April
YTQ
SOD Removed
99.5 97.4 Hours 'Run
569
2528
COD Removed (°l)
82.5 77.0
OD Removed (lb/day)
2061 2154
COD Removed (lb/day)
' 2035 2123
LUGS
April
YTD
Wasted Sludge Flow (average MGD)
0.951
0.04
Sludge Landfille (total dry tons)
58
395
Mudge Cale (% dry)
25.0 25.9

Mount Holly East
Wastewater Treatment Plant
Monthly Summary
May 2001
FLOWS (total)
May
Final (MG)
34.9
199.2
-0 C (MC)
0.0
2.0
Groundwater (MG)
3.0
11.9
Process Water (MG)
28.4
155.4
EFFICIENCY (average)
AIR STRIPPER
May YTD
BQD Removed () 9.1 97.7
May YTD
Hours Run 690 3343
COD Removed (°l) 81.7 78.1
BOD Removed (lb/day) 1285 1945
COD Removed (lb/day) 2298 2172

Mount Nally East
Wastewater Treatment Pleat
Monthly Summary
June 2001
FLOWS (total) FINAL DISCHARGE (average)
June YTD
June
YTQ
Final (MG)
27.8 227.0 BOD (mg/L)
1
4
Z-02C (MG)
0.0 2.0 COD (mg/L)
38
53
Groundwater (MCA)
3.8 15.7 TSS (mg1L)
1
6
Process Water (MG)
21.8 177.3 Ammonia (rng/L)
1
2
Phenol (m /L)
0.05
0.06
EFFICIENCY (average) AIR STRIPPER
June YTD
June
YTD
BCD Removed ()
00.2 07.0 Fours Run
677
4045
COD Removed
84.5 70.1
BOD Removed (lb/day)
1175 1820
COD Removed (lb/day)
1604 20831
SLUDGE
June
YTD
Wasted Mudge Flow (average MGD)
0.082
0.054
Sludge Landfilled (total dry tons)
66
610
Sludge Cake (% dry)
23.4
263

Mount Holly last
Wastewater Treatment Plant
Monthly Summary
July 2001
FLOWS (total) FINAL DISCHARGE: (average)
jqlj YTD
lyly
YTQ
Final (MG)
23.8 250.8 BOD (mg/L)
e
4
-02C (MG)
0.0 2.0 COD (mg/L)
72
55
Groundwater (M)
1.6 17.4 TSS (g/L)
2
Process Water (MG)
18.4 1957 Ammonia (mg/L)
73
Phenol (mg/L)
0.4
0.07
EFFICIENCY (average) AIR STRIPPER
July YTCt
July
YTQ
BCD Removed
96.8 .- 97.7 Hours Run
71
757
OD Removed
89.8 : 81.
BQD Removed (lb/day)
1262 1740
OD Removed (lb/day)
4091 2431
SLUDGE
July
YTD'
Wasted Sludge Flew (average MGD)
0.082
0.058
Sludge Lnfilled (total dry tens)
61
671'
Sludge Cake (% dry)
20.7
25.

Mount Holly East
Wastewater Treatment Plant
Monthly Summary
August 2001
FLOWS (total) -
FINAL DISCHARGE (average)
&gg YTD
&uq
YTD
Final (MG)
24.2 275.1
BOD (mg/L)
8
5
- 2C (MG)
9.0 2.0
COD (mg/L)
121
64
Groundwater (MG)
1.9 19.2
TSS (mg/L)
11
6'
Process Water (MG)
25,9 221.6
Ammonia (mg/L)
4
3
Phenol (mg/L)
0.24
0.09
EFFICIENCY (average)
AIR STRIPPER
6ug YTD
AugD
BOD Removed (°1)
97.0 97.6
HoursRun
600
5357
COD Removed
83.4 82.2
BCD removed (lb/day)
1594 1763
COD Removed (lb/day)
3936 2806
SLUDGE
AugD
Wasted Sludge Flow (average MGD)
0.067
0.059
Sludge Landfilled (total dry tons)
65
735
Sludge Calve (% dry)
21.5
25.3,

Mount Holly East
Wastewater Treatment Plant
Monthly Summary
Sept 2001
FLOWS (total)
Set
YTQ
Final (MG)
19.0
294.1
-02C (MG)
4.5
6.6
Groundwater (MG)
2.5
21.7
Process Water (MG)
1.7
241.
EFFICIENCY (average) AIR STRIPPER
Set YTQ
Set
YTD
BOD Removed (%)
97.1 97.5
Hours Run
655
6012
COD Removed
82.7 82.3
BOD Removed (lb/day)
2568 1969
COD Removed (lb/day)
3741 3032
SLUDGE
Set
YTD
Wasted Sludge Flow (average MUD)
0.078
0.061
Sludge Lndfllled (total dry tons)
40
775
Sludge Cake ( dry)
2.8
25.1

Mount Holly Bast
Wastewater Treatment Plant
Monthly Summary
Oct 200
FLOWS (total)
FINAL DISCHARGE (average)
Oct
YTD
Oct
YTD
Final (MG)
12.6
306.7
B(D (mg/L) '
31
8
-02C (MG)
10.4
17.0
COD (mg/L)
177
84
Groundwater (MG)
2.2
23.9
TSS (mg/L)
13
8
Process Water (MG)
1.9
260.2
Ammonia (mg/L)
62
9
Phenol (mg/L)
1.16
0.2"
EFFICIENCY (average)
AIR STRIPPER
Oct
YTD
Oct
YTD
BOD Removed (%)
96.1
97.0
Noun Run
697
6709
COD Removed (f)
67.4
80.4
BQD Removed (lb/day)
2613
229
COD Removed (Ike/day)
144
2883
SLUDGE
Masted Sludge Flow (average MGD)
Mudge Lndfilled (total dry tons)
Mudge Cake ( dry)
Oct
YTQ
0.068
0.062
382
1157
31.5 26.

Mount Holly East
Wastewater Treatment Plant
Monthly
Summary
Nov. 2001
FLOWS (total)
FINALDISCHARGE (average)
Nov
YTD
Nov
YTD
Find (MG)
19.2
325.9
BQD (mg/L)
11'
9
-02C (MG)
0.0
17.0
COD (m /L)
176
9
Groundwater (MG)
2,0
25.8
TSS (mg/L)
11
8
Process Water (MG)
18.9
279.1
Ammonia (mg/L)
75
15
Phenol (m /L)
0.09
9.25
EFFICIENCY (average)
AIR. STRIPPER
Nov
YTD
Nov
YTD
BCD Removed (°l)
95.3
96.8
Hours Run
624
7333
COD Removed
51.7
77.9
Bt D Removed (lb/day)
1204
2099`
COD Removed (lb/day)
1003
2624

Mount Holly East
Wastewater Treatment Plant
Monthly Summary
Dec. 2001
FLOWS (total) FINAL DISCHARGE (average)
Dec `fTD
Dec
YTD
Final (MG)
18.3 344.2
SOD (mg/L)
15
9
;
-02C (MG)
1.9 18.9
COD (mg/L)
153
95
Groundwater (MG)
1.9 27.7
TS (mg/L)
10
Process Water (MG)
17.4 296.5
Ammonia (mg/L)
108
22
Phenol (mg/L)
0.07
0.24
EFFICIENCY (average)
AIR STRIPPER
Dec YTD
Dec
YTD
BOD Removed
95.2 96.7
Hours Run
559
7892
COD Removed (%,)
4�5.5 75.
BOD Removed (lb/day)
1480 2117
COD Removed (lb/day)
630 23 3
SLUDGE
Dec
YTD
Wasted SludgeFlow (average MGD)
0.041
0.060
Mudge Lndfilld (total dry tons)
645
2512
Sludge Cake (% dry)
36.5
31.1

NORTH CARt LINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCE
DIVISION OF WATER 'QUALITY
MOORESVILLE REGIONAL OFFICE:
1EE
April 14, 2000
1. HUNT JRMr. Gary P. Sanderson, Plant Services Manager
Oft Clariant Corporation
Post Office Box 669246
Charlotte, North Carolina 28266
)LMAN Subject: Response to comments regarding
ARY Compliance Evaluation Inspection
Clariant Corporation WTP
NPDES Permit No. NCO004375
STEVENSMecklenburg County, NC
Dear Mr. Sanderson:
This Office has reviewed your comments dated April 3, 2000 regarding the
deficiencies noted in the compliance evaluation inspection. ICED report dated March 24,
2000. The comments adequately addressed all deficiencies noted in the CEI report. Our
records, pertinent to the missing reports, have been corrected. however, the delegation
of signature authority needs further discussion.
The January 14, 1998 letter does not comply with the North Carolina
Administrative Code requirements regarding the delegation of signature authority to a
duly authorized representative. The June 11 1998 letter is compliant with the NCAC
requirements with one exception. The ORC is required to sign the front of the DMR
o certify the report's accuracy and completeness. The owner or an individual in a
named position (delegated from: the pe ittee) should sign the hack of the DMR, not
the ORC. This allows oversight on how the facility is operated and maintained from
an individual besides the ORC.
The CEI report still qualifies as a Notice of Deficiency due to the additional
deficiencies noted in the report. It was brought to my' attention that Mr. Wes Bell
• • r ! . • a •