NC0004375_Permit (Issuance)_20100909

NPDES DOCIMENT !;CANNING COVER SHEET
NPDES Permit:
NC0004375
Clariant Corporation
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Approval
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 9, 2010
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 9, 2010
Bill Archer, Facility Manager
Clariant Corporation
P.O. Box 669246
Charlotte, North Carolina 28266
Subject: Issuance of NPDES Permit NC0004375
Clariant Corporation
Mecklenburg County
Dear Mr. Archer:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
This final permit includes following major changes from the draft sent to you on June 8, 2010:
• The permit limits have been recalculated to include the contaminated groundwater flow that was
incorrectly identified in the renewal application.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable
to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt
of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh,
North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
None Cazolina
7%7aturaI/ji

Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements
to obtain other permits which may be required by the Division of Water Quality or permits required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit
that may be required. If you have any questions concerning this permit, please contact Sergei Chernikov at
telephone number [phone].
Sincerely,
leen H. Sullins
cc: NPDES Files
Central Files
Mooresville Regional Office -Surface Water Protection
EPA Region IV (e-copy)
Aquatic Toxicology Unit (e-copy)
Meredith Moore (e-copy: [e-mail])
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www,ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
North Carolina
Naturally

Permit NC0004375
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
•
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina 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 the
•
Mt. Holly East Facility
NC Highway 27 northwest of Charlotte
Mecklenburg County
to receiving waters designated as the Catawba River in the Catawba River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective October 1, 2010.
This permit and authorization to discharge shall expire at midnight on June 30, 2015.
Signed this day September 9, 2010.
631 g €en H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
1

SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit
issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate
and discharge from this facility.arises under the permit conditions, requirements, terms, and provisions included herein.
Clariant Corporation is hereby authorized to:
1. Continue operation of a 3.9 MGD wastewater treatment plant consisting of the
following treatment units:
• Two stormwater equalization basins for non -alkaline wastewater;
• Two stormwater equal1zation basins for alkaline wastewater;
• Two acid neutralization tanks;
• One lime slurry tank;
• Two primary clarifiers;
• One wastewater equalization basin;
• One aeration basin with mechanical aeration;
• Two secondary clarifiers;
• Two polishing ponds;
• Staged discharge facility including effluent holding basin and post aeration;
• Two sludge holding tanks; and
• Two sludge dewatering belt presses.
This facility is located at the Mt. Holly East facility off NC Highway 27 northwest of
Charlotte in Mecklenburg County.
2. Discharge treated centralized waste treatment (CWT) and non -categorical industrial
process wastewaters from said facility at the location specified on the attached map
through outfall 001 into the Catawba River, classified WS-IV CA waters in the
Catawba River Basin.
2

Latitude:
Longitude:
Ouad #:
Stream Class: •
Receiving Stream:
Permitted Flow:
35°16'46"
81°00'32"
FI5SW
WS-IV CA
Catawba River
3.9 MOD
Clariant Corporation
NC0004375
Mecklenburg County

' A. (1) FFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until the addition of future wastewater sources or
expiration, the Permittee is authorized to discharge treated CWT and non -categorical industrial process wastewater from outfall
001. Such discharges shall be limited and monitored by the Permittee as secif ed below:
EFFLUENT
CHARACTERISTICS
EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
Monthly Average
Daily Maximum
Measurement
Sample .
Sample Locatio$
Frequency
Type
Flow
3.9 MGD
Continuous
• Recording
Influent or Effluent
•
BOD, 5-day, 20°C4
300.1 pounds/day
888.5 pounds/day
Daily
Composite
Effluent
Total Suspended Solids
395.4 pounds/day
1,245.2 pounds/day
Daily
Composite
Effluent
Oil and Grease
102.9 pounds/day
344.2 pounds/day
Monthly
Grab
Effluent
Dissolved Oxygen
Daily
Grab
Effluent, U' & D1
Fecal Coliforrn
(geometric mean)
Monthly
Grab
Effluent
pH2
Daily
Grab
Effluent, U' & D1
NH3 as N4
574.5 pounds/day
861.8 pounds/day
Daily
Composite
Effluent
T emperrure °C
•
Daily
• Grab
Effluent, U' & D?....
Conductivity "
Daily • •
Grab
Effluent, U' & D1
COD
Monthly
Grab
•
Effluent
Total Nitrogen5
(NO2+NO3+TKN)
See below for Annual Average
Monthly
Composite
Effluent
Total Phosphorus5 .
See below for Annual Average
Monthly
Composite
Effluent
Total Mercury
12 ng/L
12 ng/L
Monthly
Grab
Effluent
Total Phenols
Monthly
Grab
Effluent
MBAS
Quarterly
Composite
Effluent
Total Iron
,
Quarterly
Composite
Effluent
Sulfates
Quarterly
Composite
Effluent. .
Chlorides
Quarterly
Composite
Effluent
Total Manganese
Quarterly
Composite
Effluent
Chronic Toxicity3
Quarterly
Composite
Effluent
Total Chromium
Monthly
Composite
Effluent
Total Antimony
310 pg/L
310 pg/L
Monthly
Composite
Effluent
Total Arsenic
2,771 pg/L
2,771 pg/L
Monthly
Composite
Effluent
Total Copper
3.97 pounds/day
4.5 pounds/day
Monthly
Composite
Effluent
Total Zinc
2.2 pounds/day
2.6 pounds/day
Monthly
Composite
Effluent
Notes:
1. U= upstream at NC Highway 27. D = downstream at I-85. Upstream and downstream samples for dissolved oxygen,
temperature, conductivity and pH shall be collected three times per week during June, July, August and September and once
per week during the remaining months of the year.
2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
3. Chronic Toxicity, refer to Section A. (3).
4. Staging requirements (applicable April 1-October 31) — Refer to Section A. (5).
5. The Total Nitrogen limitation is 318.5 pounds/day and Total Phosphorus limitation is 40.0 pounds/day based on a 12-
month rolling average. Refer to Section A. (4).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
3

When an approved analytical protocol with the appropriate minimum detection level is followed and a result of "non -detectable"
or "below quantitation limit" is obtained, the permittee will be considered to be in compliance with the numerical permit limit for
that pollutant.
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
CWT Parameters
Effluent Characteristic
4
Daily Maximum
pounds/day
Monthly Average
pounds/day
Measurement
Frequency
Sample
Type
Sample
Location
Acetone
158.6
41.8
Annually
Grab
Effluent
Acetophenone
0.6
0.29
Annually
Grab
Effluent
2-Butanone
25.3
9.7
Annually
Grab
Effluent
o-Cresol
10.1
2.9
Annually
Grab
Effluent
p-Cresol
3.7
1.1
Annually
Grab
Effluent
Phenol
19.2
5.7
Annually
Grab
Effluent
Pyridine
1.9
0.96
Annually
Grab
Effluent
2,4,6-Trichlorophenol
0.81
0.56
Annually
Grab
Effluent
Notes for CWT Parameters.
S13ould any annual monitoringresult in detection of a C . T parameter contained in.40 CFR 437 Subpart D, then
quarterly monitoring will_b „ unediately for the detected parameter(s) After four consecutive quarterly samples
resulting in non -detection are achieved, the monitoring frequency will revert to annually.
When an approved analytical protocol with the appropriate minimum detection level is followed and a result of "non -
detectable" or "below quantitation limit" is obtained, the permittee will be considered to be in compliance with the
numerical permit limit for that pollutant.
A. (3) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 1.8%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II 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 NPDES 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 Chronic 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
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR.-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
4

Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall 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
permittee 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 Section 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.
If the Permittee monitors any pollutant more frequently then required by this permit, the results of such monitoring
shall be included in the calculation & reporting of the data submitted on the DMR & all AT Forms submitted.
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.
A. (4) TOTAL PHOSPHORUS AND TOTAL NITROGEN MONITORING
The Permittee shall calculate a 12-month rolling average mass loading as the sum of monthly loadings, according to
the following equations:
(1) Monthly Average (pounds/day) = TP x Qw x 8.34
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 =conversion factor, from (mg/L 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:
5

12
(2) 12-Month Average Mass Loading (pounds/day)= ETPma =12 (inclusive of reporting month)
Where:
TPma = the total phosphorus monthly average mass loading (calculated above).
Total Nitrogen is to be calculated using the 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 worksheet is Sue with the discharge • •
monitoring report, 12 months from the effective date of the total phosphorus and total nitrogen limits. In the interim
period between the effective date and the requirement to submit the attached worksheet, 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. (5) STAGING REQUIREMENTS (APPLICABLE APRIL 1— OCTOBER 31)
The operating day runs from 7:00 am to 7:00 am. Each day,, the petmittee will calculate a running daily average seam..:.
flow -as determined by turbine operation at Mountain Island. Dam, leakage at the dam (80 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: BOD5 + 0.54(NH3-N) <=566.4 pounds/day
(2) When daily average river flow is calculated to be >175 cfs but < or = 250 cfs: BOD5 + 0.54(NH3-N) <=1044
pounds/day
The attached additional DMR sheet (see next page) shall be used to monitor compliance with BOD and NH3 staging
requirements during the summer (April 1— October 31)
6

A. (6) Effluent Pollutant Scan
The permittee shall perform an annual pollutant scan of its treated
Ammonia (as N) Trans-1,2-dichlorocthylene
Chlorine (total residual, TRC) 1,1-dichloroethylene
Dissolved oxygen 1,2-dichloropropane
Nitrate/Nitrite 1,3-dichloropropylene
Kjeldahl nitrogen Ethylbenzene
Oil and grease • Methyl bromide
Phosphorus Methyl chloride
Total dissolved solids Methylene chloride
Hardness
Antimony
1,1,2,2-tetrachloroethane
Tetrachloroethylene
Arsenic Toluene
Beryllium 1,1,1-trichloroethane
Cadmium 1,1,2-trichloroethane
Chromium Trichloroethylene
Copper Vinyl chloride
Lead Acid-ex$rartabk compomdr:•
Mercury
Nickel
• Selenium
Silver •
Thallium
Zinc
Cyanide
Total phenolic compounds
Volalik owsric covirmdc
Acrolein
Acrylon itrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-chloroethylvinyl ether
Chloroform
Dichlorobromomethane
1,1-dichloroethane
1,2-dichloroethane
P-chloro-m-cresol
2-chlorophenol
2,4-dichlorophenol
2,4-dimethylphenol
4,6-dinitro-o-cresol
2,4-dinitrophenol
2-nitrophenol
4-nitrophenol
Pentachlorophcnol .
Phenol
2,4,6-trichlorophenol
Base -neutral compound,::
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
3,4 benzofluoranthene
Benzo(glu)perylene
Benzo(k)fluoranthene
Bis (2-chloroethoxy) methane
effluent for the following parameters:
Bis (2-chloroethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-bromophenyl phenyl ether
Butyl benzyl phthalate
• 2-chloronaphthalene-
4-chlorophcnyl phenyl ether
Chrysene
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzo(a,h)anthracene
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
3,3-dichlorobcnzidine
Diethyl phthalate
Dimethyl phthalate
2,4-dinitrotoluene •
2,6-dinitrotoluene -
1,2-diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclo-pentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Naphthalene
Nitrobenzene
N-nitrosodi-n-propylamine
N-nitros odimethylamine
N-nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-trichlorobenzene
•
➢ 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 CFR Part
136.
➢ Unless indicated otherwise, metals must be analyzed and reported as total recoverable.
➢ Test results shall be reported to the Division on DWQ Form- DMR-PPA1 or in a form approved by the
Director, within 90 days of sampling. Two copies of the report shall be submitted along with the DMR forms
to the following address: NC DENR / DWQ/ Central Files, 1617 Mail Service Center, Raleigh, North
Carolina 27699-1617.
8

Additional DMR Sheet for Clariant-Mt.` Holly East
EFFLUENT
NPDES Permit NC0004375 Discharge Month Year
Clariant Class 4 Mecklenburg County
Operator in Responsible Charge (ORC): •
Certified Laboratory:
Person(s) Collecting Samples:
• Check if ORC has changed •
I certify that this report is accurate and complete to the best of my
knowledge.
X
River • Allowable Actual
Qw Flow BOD5 NH3 BOD+.54NH3 BOD+.54NH3 Comp?
Date Tirne (MGD) (cfs) (pounds/day) (pounds/day) (pounds/day) (pounds/day) Case (Y/N)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Average
Case 1: River Flow <= 175 cfs, BOD5 + 0.54NH3 <= 566.4 pounds/day
Case 2:175 cfs < River Flow <= 250 cfs, BODs + 0.54NH3 <= 1044 pounds/day
•

A. (7) NOTIFICATION OF NEW WASTE SOURCE
Clariant Corporation will notify the Division of Water Quality's Mooresville Regional Office and the Point Source
Compliance/Enforcement Unit at least fourteen (14) days prior to the addition of any new waste source to the
treatment facility. The addition of any new waste source will trigger Clariant's compliance with Tier 2 effluent
limitations and monitoring requirements.
a
9

Department of Environment and Natural Resources
Division of Water Quality
Fact Sheet For NPDES Permit NC0004375
Facility Information
Applicant/Facility Name:
Clariant Corporation — Mt. Holly
Applicant Address:
P.O. Box 669246, Charlotte, NC 28266
Facility Address:
11701 Mount Holly Rd., Charlotte, NC28214
Permitted Flow:
3.9 MGD (Grade IV — Biological)
Type of Waste:
Industrial, Stormwater, and Sanitary Wastewater
Facility/Permit Status:
Renewal
County:
Mecklenburg County
Miscellaneous
Receiving Stream:
Catawba River
Stream Classification:
WS-IV-CA
303(d) Listed?:
No
Subbasin:
03-08-34
Drainage Area (mi2):
calculated
40.8 mi2
Summer 7Q10 (cfs):
329 cfs
Winter 7Q10 (cfs):
NA
Average Flow (cfs):
3,016 cfs
IWC (%):
1.8 %
Primary SIC Code:
2865
Regional Office:
Mooresville
USGS Topo Quad:
Mountain Island Lake & Mount Holly
Permit Writer:
Sergei Chernikov
Date:
May 10, 2010
Summary
Clariant operated a specialty chemical manufacturing facility in Mount Holly from 1936 until 2005
when it ceased all organic chemical manufacturing and processing. The facility also treated OCPSF
and CWT (centralized waste treatment) wastes from customers located off -site. Wastewater from
the facility is treated in an on -site WWTP. The existing permit is based on the OCPSF and CWT
effluent guidelines. The proposed permit will be based on the CWT guidelines only since all the
OCPSF manufacturing has been discontinued. The facility also discontinued treatment of oily
water in 2005.
The facility has been a specialty chemical and dye -manufacturing site since 1937. As a result of
historical operations, the facility is included on the National Priorities List due to organic contained
in surface water and groundwater from the site. Stormwater from the facility is therefore treated in
the on -site WWTP in addition to the CWT process wastewater, and domestic wastewater from
current on -site manufacturing operations. The WWTP also receives groundwater from a
groundwater pump and treat system and leachate from an active on -site landfill cell. As portions of
Fact Sheet
NPDES Renewal (NC0004375)
Page 1

the facility become inactive, Clariant is developing the facility as an industrial park. The following
two tenant operations are currently located at the facility with the treatment of the resulting process
wastewaters in the on -site WWTP:
• SCR -Tech — A non -categorical operation that regenerates NOx air pollution control catalyst
• Monark Industrial Services, Inc. — A non -categorical operation that solidifies liquid and
semi -solid wastes.
Since Clariant is developing the facility as an industrial park, future wastewater sources will occur.
In the past, in order to account for these future wastewater sources in the permit effluent limits, a
tiered approach to developing the limits was used. The proposed limits for both conventional and
non -conventional parameters were presented in two tiers, Tier 1, and Tier 2. The Tier 1 limits were
based on wastewater flow from existing and planned wastewater sources. The Tier 2 limits were
based on wastewater flow not only from existing and planned wastewater sources, but also from
future wastewater sources. The facility is in transition period and is on track to be sold. Therefore,
expansion is not planned and Tier 2 will be eliminated from the proposed permit.
Facility has no fecal coliform limit due to the very minor contribution of sanitary wastewater flow.
Technology Based Effluent Limit Development
Conventional parameters have been calculated based on the guidelines specified in the Table 3-1
(attached). Flow numbers for calculation were taken from the Table 2-2 (attached). The following
effluent guidelines were used to calculate permit limits:
• CWT parameters — 40 CFR part 437 (subpart B) (flow=0.325 MGD)
The results of these calculations are•generally more stringent than the limits in the current permit.
All the calculations are attached.
Limits for Total Nitrogen and Total Phosphorus have been established based on the results
of the BAT study. Monthly average limit for NH3-N was established as the 95th percentile
effluent load during the renewal in 2003, daily maximum limit was calculated using 1.5
multiplier.
Toxicity Testing
Current Requirement: Quarterly Chronic Toxicity @ 1.8% MAR, JUN, SEP, DEC
Recommended Requirement: Quarterly Chronic Toxicity @ 1.8% MAR, JUN, SEP, DEC
The facility has been consistently passing its WET tests during previous permit cycle.
Compliance Summary
DMRs have been reviewed for the period from January 2006 through April 2010. Facility has a
good compliance record. During the review period, no NOVs (notices of violation) have been
issued. A compliance evaluation inspection conducted on June 4, 2008 determined that facility is
in compliance.
Reasonable Potential Analyses (RPA)
RPA were conducted for As, Ba, Cd, Cr, Cu, CN, Sb, Pb, Hg, Mo, Ni, Phenols, Se, Ag, Zn (please
see attached). A separate RPA for acute standards for CN and Ni was also calculated (please see
attached). The "acute" RPA was based on 1Q10 dilution in accordance with the EPA guidance.
Fact Sheet
NPDES Renewal (NC0004375)
Page 2

Instream Monitoring
Instream monitoring is required DO, pH, temperature and conductivity. Facility has a very small
influence on the water quality due to the high dilution ratio.
Proposed Changes
Monitoring Frequencies: Monitoring for Oil and Grease were reduced from weekly to
monthly due to the removal of the limit.
Limits:
• Limits for CWT and conventional parameters have been recalculated based on the
reevaluation of projected flows.
• The OCPSF parameters have been eliminated from the permit due to discontinued
manufacturing of specialized chemicals in 2005.
• Limits for Arsenic, Antimony, and Mercury have been added to the permit based on
the results of the reasonable potential analyses.
• Limit for Oil and Grease was eliminated from the permit since the facility no longer
accepts oily water for treatment.
Tiers: Tier 2 has been eliminated at the request of the permittee.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone].
CHANGES IN THE FINAL PERMIT:
AFTER CONSULTATIONS WITH THE EPA, THE CONTAMINATED GROUNDWATER WAS INCLUDED IN THE
CWT CATEGORY FOR THE PURPOSES OF LIMIT CALCULATIONS. THE DECISION WAS MADE BECAUSE THE
GROUNDWATER IS BEING TREATED BY THE WASTEWATER TREATMENT PLANT ALONG WITH THE OTHER
WASTE STREAMS FROM THE OUTSIDE CLIENTS.
THE PERMIT LIMITS WERE RECALCULATED BASED IN THE INCLUSION OF THE GROUNDWATER IN THE
CWT CATEGORY.
Fact Sheet
NPDES Renewal (NC0004375)
Page 3

Chernikov, Sergei
From: [e-mail]
Sent: Friday, September 03, 2010 11:17 AM
To: Chernikov, Sergei
Subject: RE: finally got an answer from HQ
based on the groundwater being contaminated from both CWT activities and historic production,
I have no comments.
1

Chernikov, Sergei
From: [e-mail]
Sent: Monday, August 02, 2010 7:27 AM
To: Chernikov, Sergei
Subject: finally got an answer from HQ
does this help? need anything else?
Forwarded by Marshall Hyatt/R4/USEPA/US on 08/02/2010 07:26 AM
From:
>
>
>
>
Jan Matuszko/DC/USEPA/US
1
To:
>
>
>
1
IMarshall Hyatt/R4/USEPA/US@EPA
>
>
Date: I
>
>
108/02/2010 07:06 AM
>
Subject:
>
>
1
>
IRe: would like your help re question from NC
>
Hi Marshall,
1

The first question that needs to be asked is whether or not the groundwater is subject to t%e
CWT ELGs.
From the reg,
Sec. 437.1 General applicability.
(a) Except as provided in paragraphs (b), (c), or (d) of this section, this part applies
to that portion of wastewater discharges from a centralized waste treatment (CWT) facility
that results from any of the following activities:
(1) Treatment and recovery of hazardous or non -hazardous industrial metal -bearing wastes,
oily wastes and organic -bearing wastes received from off -site; and
(2) The treatment of CWT wastewater.
(b) This part does not apply to the following discharges of wastewater from a CWT
facility:
(1) Wastewater from the treatment of wastes that are generated on- site when the wastes
generated on -site are otherwise subject to another part of subchapter N.
"CENTRALIZED WASTE TREATMENT WASTEWATER --Any wastewater generated as a result of CWT
activities. CWT wastewater sources may include, but are not limited to: liquid waste
receipts, solubilization water, used oil emulsion -breaking wastewater, tanker
truck/drum/roll-off box washes, equipment washes, air pollution control scrubber blow- down,
laboratory -derived wastewater, on -site landfill wastewaters, and contaminated storm water.
T.-
So, what is the source of the contaminated GW?_ Is it from CWT activities or something else?
For example, if it also a manufacturing site and that's what caused the groundwater
contamination, then it would likely be subject to another ELG rather than CWT.
Assuming you determine the GW is subject to the CWT regulation, then you look at the
pollutants in the groundwater. Typically, non -petroleum contaminated GW would be placed in
the organics subcategory. However, if it is contaminated groundwater from petroleum sources,
then it should be placed in the oils subcategory. (See Waste Receipt Classification Table).
I hope this helps. Feel free to contact me further if you have additional questions.
Jan
++++++++++++++++++++
Jan Matuszko
Senior Environmental Engineer
Technology and Statistics Branch
Engineering and Analysis Division (4303T) U.S. EPA 1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
[phone]
I From:
(Marshall Hyatt/R4/USEPA/US
I To:
2

>
Jan Matuszko/DC/USEPA/US@EPA
Date:
107/30/2010 09:54 AM
Subject:
(would like your help re question from NC
thanks for your assistance and thoughts.
Forwarded by Marshall Hyatt/R4/USEPA/US on 07/30/2010 09:54 AM
1 From:
1"Chernikov, Sergei" <sergei.chernikov®ncdenr.gov>
To:
IMarshall Hyatt/R4/USEPA/US@EPA
Date:
3

107/19/2010 08:43 AM
1 Subject:
IFW: Additional NPDES Comments
Marshall,
The Clariant (NC0004375) wants us to include the groundwater, which is being treated, in the
CWT organics category for the purposes of limits calculation. Please see the explanation
below. Previously, we have not included groundwater in the calculation because it comes from
- .the site itself, not from . one of the clients they have.
Can we include the groundwater in the limit calculations?
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
From: [e-mail][mailto:[e-mail]]
Sent: Wednesday, July 07, 2010 1:53 PM
To: Chernikov, Sergei
Cc: [e-mail]
Subject: RE: Additional NPDES Comments
Hello Sergei,
I did not include groundwater data with my previous email because I have only limited data
that's directly relevant to the groundwater we are recovering for treatment. For the
4

Chernikov, Sergei
From:
Sent:
To:
Subject:
Attachments:
Thank you Sergei.
[e-mail]
Friday, July 23, 2010 9:56 AM
Chernikov, Sergei
RE: Additional NPDES Comments
pic19884.gif
5Chernikov, Sergei" <[e-mail]>
"Chernikov, Sergei"
<sergei.chernikov®ncdenr.gov>
07/23/2010 09:32
AM
To"[e-mail]"
<[e-mail]>
cc"Belnick, Tom" <[e-mail]>
SubjectRE: Additional NPDES Comments
I have looked at your comments and forwarded them to EPA. One issue can be easily fixed: TSS based on
CWT. I will recalculate the limit using a different section of CWT effluent guidelines.
The rest of the questions are very difficult to solve. I am not sure is we can use CWT guidelines for
groundwater remediation flows. our Region VI contact is still investigating this issue. We have not done it in
the past and need EPA approval to do it.
As soon as I have a response from EPA, we will have an internal discussion to decide on how to address your
questions.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: [e-mail][mailto:Bill.ArcherCa�clariant.com]
Sent: Wednesday, July 07, 2010 1:53 PM
To: Chernikov, Sergei
1

Cc: [e-mail]
Subject: RE: Additional NPDES Comments
Hello Sergei,
r,^
I did not include groundwater data with my previous email because I have only limited data that's directly relevant to the groundwater
we are recovering for treatment. For the remediation water we only measure selected indicator organic compounds (dichlorobenzene,
chlorobenzene, etc.) but no metals or conventional parameters. We do have a lot of monitoring wells both in our RCRA area and in
our CERCLA area which we sample. The CERCLA wells are regularly tested only for the indicator organic parameters. The
groundwater recovered from the CERCLA area accounts for approximately 2/3 of the remediation groundwater flow. The RCRA
monitoring wells are analyzed for more compounds but show a wide range of contaminant levels across the area. The RCRA
remediation water accounts for about 1/3 of our groundwater flow. I am attaching two files that give summaries of recent monitoring
data.
After receiving your email yesterday, I went back through the CWT rules to review how they address contaminated groundwater. In
40CFR437.2(r) the definition of "Organic wastes" includes the following passage:
"Examples of these wastes are landfill leachate, contaminated groundwater clean-up from non -petroleum sources, solvent bearing
wastes..."
The rules also include in the definition of Centralized Waste Treatment Facility in 40CFR437.2 (c) the following:
"'CWT facility' includes both a facility that treats waste received from off -site and a facility that treats wastes generated on -site as well
as waste received off -site."
Thus, when we dropped out of the OCPSF cate ory, our on -site contaminated groundwater should have been includednthe _CWT-.
organics ca egory instead o e non -categorical group in our application. CWT ' ' are-based-on_treatin� wastes from many_
—afferent sources wi averse characteristics. a CWT al ollcations should a applied to the contaminated groundwater which is
commingled with the other CWT wastes. - T -
I am attaching revised copies of Tables 3-3 and 3-4 of the Support Document which was submitted with our application which shows
the calculated permit limits for the facility with the groundwater flow included in the CWT category.
Please contact me if you would like to discuss this in more detail.
Thanks and regards,
Bill Archer
(See attached file: 2009-03-01_Table 3 RCRA GW Results Feb 09_CLR-022.xls)(See attached file: Nat Att
Table.xls)(See attached f le: Updated Tables.pdf)
"Chemikov, Sergei" <[e-mail]>
"Chernikov, Sergei" To
<sergei.chernikov®ncdenr.gov> "[e-mail]
07/06/2010 <[e-mail]
02:15 PM cc
Subject
RE: Additional NPDES
Comments
Bill,
Thank you for your e-mail! Pease send me groundwater sampling results at your earliest convenience.
2

Serge!
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex Permitting Unit
Phone: [phone], fax [phone]
1617 Mail Service Center
Raleigh, NC 27699-1617
Express mail: 512 North Salisbury St.
Raleigh, NC 27606
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
From: [e-mail][mailto:[e-mail]]
Sent: Friday, July 02, 2010 2:48 PM
To: Chernikov, Sergei
Cc: Belnick, Tom; [e-mail]
Subject: Additional NPDES Comments
Hello Sergei,
Thanks for faxing your calculations for the draft NPDES Permit and for your input during our phone
conversation yesterday. As we discussed, I noticed a few differences between our calculated limits for several
parameters and yours. In further review of the calculations after our phone conversation, I also found one
additional discrepancy related to TSS limits calculated for the Centralized Waste Treatment flow. Following is a
discussion of each of the differences I've noted and our basis for the proposed limits Clariant calculated in our
application submittal.
Groundwater Flow — For conventional parameter limits, Clariant included contaminated groundwater in non -
categorical wastewater for our calculation of permit limits. We have an expanding network of remediation wells
that contribute contaminated water containing both conventional parameters and individual components. (Most
TSS comes from oxidation of high levels of iron in the water.) We included 0.305 MGD of this groundwater in
the 0.384 MGD flow shown in the non -categorical grouping at the top of Table 3-3 of our support document
with allocation limits of 30/45 mg/1 for avg/max BOD & TSS. In our 2005 renewal application this groundwater
A
ha SF cate o total in Table 3-3 as ex lained on page 12 of the 2005 Support
Document). With cessation of OCPSF production for the 2010 renewal, this water was inc u e wit other
contaminated non -categorical wastewater in our application. The 0.305 MGD of flow shown would translate
into additional BOD & TSS allocations of 76.3 lbs monthly average and 114.5 lbs daily max.
Additional Cu & Zn allocations from non -categorical sources — The non -categorical wastewater category
discussed above includes sanitary wastewater, process wastewater from our tenant, and the contaminated
groundwater. In addition to adding Cu & Zn loading, these sources add significantly to the combined flow that
must be treated. Since the typical BAT treatment method for metals is precipitation (an equilibrium reaction),
the achievable mass discharge is significantly influenced by the total flow treated. We believe that the CWT
allocation for Cu & Zn applicable to mixed stream wastewaters should also be applied to this non -categorical
water since it is commingle and treated with the CWT water. This would result in an additional allocation of
2.42 lbs Cu monthly average, 2.77 lbs Cu daily max, and 1.35 lbs Zn monthly average, 1.59 lbs Zn daily max to
the draft mass limits.
TSS based on CWT - After our phone conversation I also noticed a discrepancy in the TSS limits calculated
3

for the Centralized Waste Treatment flow. Your calculations used a TSS BPT value of 30.6 mg/1 average and'
74.1 mg/1 max, which appear to be the BPT limits for the Oils Treatment and Recovery category rather than the
BPT limits for Organics Treatment and Recovery. The Organics category TSS values in 40CFR437.31 are 61.3
mg/1 average and 216 mg/1 max.
One last comment — it would be nice if we could find a way to simplify the staging requirement in the permit if
we can't delete it altogether, particularly since we can no longer get real time river flow data and always use the
minimum river flow to comply with the staging requirements. Maybe something like a requirement to control
discharge such that daily discharge for projected (BOD + 0.54 NH3-N) is < or = 566.4 lbs. (The 566.4 lbs is the
current staging limit for the lowest river flow condition.)
I appreciate your help with this and willingness to consider our proposal. I will be in next week after July 4 and
will be available to discuss this in more detail.
Kind regards and Happy Fourth of July,
Bill Archer
4

Chernikov, Sergei
From: Belnick, Tom
Sent: Tuesday, July 06, 2010 9:31 AM
To: Krebs, Rob
Cc: Allocco, Marcia; Chernikov, Sergei
Subject: RE: Permit NC0004375 Clariant Mt. Holly East
Rob- looks like Comment 1 is valid, but the other comments appear incorrect. There is a Footnote 5 for TN and TP. For
Hg and Phenols, there is no Footnote for Hg and Phenols (looks like they are comparing old permit to NEW Draft, and
NEW draft does away with Footnote relating to OCPSF, since that process is no longer in operation). Sergei will review
comments before we go with Final.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Krebs, Rob
Sent: Friday, July 02, 2010 12:56 PM
To: Belnick, Tom
Cc: Allocco, Marcia
Subject: Permit NC0004375 Clariant Mt. Holly East
Tom,
The Riverkeeper just pointed out some things in the June draft permit. Namely:
On the Effluent limits page
1) BOD note 4 does not correspond to BOD
2) Total Nitrogen Note 5 Does not exist
3) Total Phosphorus Note 5 Does not exist
4) Total Mercury Note 6 — Does not exist.
5) Total Phenols Note 7 — Does not exist
Rob
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
Rob Krebs - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
1

MEMORANDUM
To:
From:
Subject:
June 22, 2010
Britt Setzer, Regional Engineer
NC DENR / DEH / Public Water Supply Section
Mooresville Regional Office
Sergei Chernikov, Environmental Engineer II, Complex NPDES Unit,
Division of Water Quality (fax-919-807-6495)
Review of the discharge locations for the following:
Review of Draft NPDES Permit-NC0004375
Clariant Corporation
Mecklenburg County
Please indicate below by July 26, 2010 your agency's position or viewpoint on the facility
listed above. We cannot issue the permit without your concurrence. Please return this form
at your earliest convenience.
RESPONSE:
This agency has reviewed the draft permit and determined that the proposed
discharge will not be sufficiently close to any existing or known proposed
public water supply intake so as to create an adverse effect on water quality.
We concur with the issuance of this permit provided the facility is operated
and maintained properly, the stated effluent limits are met prior to discharge,
and the discharge does not contravene the designated water quality standards.
Concurs with issuance of the above permit, provided the following conditions
are met:
Opposes the issuance of the above permit, based on reasons stated below, or
attached:

North Carolina ) ss
Mecklenburg County)
The Charlotte Observer Publishing Co.
Charlotte, NC
Affidavit of Publication
THE CHARLOTTE OBSERVER
DINA SPRINKLE
NCDENR/DWQ/POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH NC 27699
REFERENCE: 30063432
6475084 permit-mt. holly e.
Before the undersigned, a Notary Public of said
County and State, duty authorized to administer
oaths affirmations, etc., personally appeared,
being duly sworn or affirmed according to law,
doth depose and say that he/she is a
representative of The Charlotte Observer
Publishing Company, a corporation organized and
doing business under the laws of the State of
Delaware, and publishing a newspaper known as The
Charlotte Observer in the city of Charlotte,
County of Mecklenburg, and State of North Carolina
and that as such he/she is familiar with the
books, records, files, and business of said
Corporation and by reference to the files of said
publication, the attached advertisement was
inserted. The following is correctly copied from
the books and files of the aforesaid Corporation
and Publication.
PUBLISHED ON: 06/12
AD SPACE:
FILED ON:
NAME:
56 LINE
TITLE:
DATE: 1 f i ' / In Testimony Whereof I have hereunto set my hand� fa.' nd a seal, the
day and year aforesaid. My Commission Expires May 17, 2011
Not • 11 Ifs . / ,� �y�arrmi ssi on Expires: _/_/_
Publlq Notice
North Carolina Environmental Management Commission!
NPDES Unit
1617 Mall Service Center
Raleigh, NC 27699-1617
Notice of Intent to Issue a NPDES Wastewater Permit
The North Carolina Environmental Management Commission pro-
poses to issue a NPDES wastewater discharge permit to the per-
son(s) listed below.
Written continents regarding the proposed permit will be accepl-
eti until 30 days after the publish date of this notice. The Director
of the NC Division of Water Quality (DWQ) may hold a public hear-
ing should (here be a signilicanl degree of public interest. Please
mail comments and/or information requests to DWQ at the above
address. Interested persons may visit the DWQ at 512 N.
Salisbury Street, Raleigh, NC to review information on file.
Additional Information on NPDES permits and this notice may be
found on our website: www.ncwaterquallty.org, or by calling (919)
807-6304.
Clarlanl Corporation requested renewal of permit NO3004375 for
Mount Holly East facility In Mecklenburg County: this facility dis-
charge is treated industrial wastewater to Catawba River, Catawba
River Basin.
LP6475084

REASONABLE POTENTIAL ANALYSIS
Clariant
NC0004375
Time Period 2007-2010
Cow (MGD) 3.9
7Q10S (cis) 329
7Q10W (cfs) 0
3002 (cfs) 0
Avg. Stream Flow, OA (cfs) 3016
Recbing Stream Catawba River
WWTP Class IV
IWC (%) © 7Q10S 1.8042
© 7010W NIA
3002 N/A
@QA 0.2
Stream Class WS-IV CA
Outfall 001
Qw=3.9 MGD
PARAMETER
TYPE
(1)
STANDARDS &
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
Pic WQSr SSFAY /
Chronk Acute
n SW. Mar Prod Cw AllowahhCw
Acute: N/A
Arsenic
NC
50
ug/L
5 5
Nolo: n<12
5897.4
_ -_ _
Chronic: 2,771 --
add a Omit------_—•—• •—.—_ —•—
—_— — — —
Limited data set
Acute: N/A
Barium
NC
1000.0
ug/I.
3 1
Note: n<12
96.6
_ _
Chronic: 55,425--•—
no limit -----_---.—.—.—•---------.
Limited data set
�2
Acute: 15
Cadmium
NC
15
ug/L
5 0
0.5
nolimit
n<12
Note: n<12
--•---
Limited data set
Acute: 1.022
no limit
Chromium
NC
50 1,022
ug/L
5 1
75.0
_ _—
-----_-- •—•—_—_—_---.-----
—
Note: n<12
Chronic 2,771
Umited data set
Acute: 7
no Emit
Copper
NC
7 At. 7.3
ug/L
5 4
4430.2
_ ----__--------•—•-------_—_---
—i—
Note: n<12
Chronic 388
Umited data set
action level standard
Cyanide
NC
5 N 22
10
ug/L
5 2
68.3
Acute: 22
___
no chronic Emit ,
•— _ __-___ _.—__ _•—_—.—_—
Note: n<12
Chronic: 277
Umited data set
Acute: N/A
add a limit
Antimony
NC
6
ug/L
5 3
1,082.2
-_ _--•---•-----------------------
Note: n<12
Chronic 310
Limited data set
Acute: 34
no limit
Lead
NC
25 N 33.8
ug/L
5 0
2.5
_ _•_ _ _-------.—•—.—.—_—_—_—_—_—.—•—
Note: n<12
Chronic: 1,386
Umited data sot
Acute: N/A
add a Limit
Mercury
NC
0.012
0.0002
ug/L
40 40
2.1421
___—__---_—_—•—•---_—_---_—_—•—•--
Chronic 1
— —
Acute: N/A
no Emit
Molybdenum
A
3.500
ug/L
5 3
Note: n<12
212,546.4
_ _ _—_—
Chro lc 1,749,737
— — -----_—_—_—_—.—_—.—•—
Limited data set
Acute: 261
no chronic Emit
Nickel
NC
88 261
ug/L
5 5
3,220.1
_ —
--------_ _--•—•-------_-----
Note: n<12
Chronic: 4,877
Limited data set
Acute: N/A
no Emit
Phenols
A
1 N
ug/L
5 3
128.5
___ __----------.—_—•—_—_—_—_—.—_—_—
Note: n<12
Chronic: 500
Limited data set
Acute: 56
no limit
Selenium
NC
5.0 56
ug/L
5 3
51.1
_ _ _.__----
—---- ----•----- -- --- -----•
Note: n<12
Chronic: 277
Limited data sot
Acute: 1
no limit
Silver
NC
0.06 AL 1.23
ug/L
5 0
2.5
_.—__---_—_—_—_—•—_—_—_—_—_—_—_—_—_—.
Note: n<12
Chronic: 3
•
Limited data set
action level standard
Acute: 67
no Limit
Zinc
NC
50 Al. 67
uglL
5 5
315.8
---------•—,—_—_—_—_—_—_—_—_—
Note: n<12
Chronic: 2.771
Limited data set
action level standard
'Uwe
C = Carcinogenic
NC = Notrcarcinogenic
A = Aesthetic
•• Freshwater Discharge
4375- rpa-2010.xis, rpa
526/2010

4
REASONABLE POTENTIAL ANALYSIS
Clariant
NC0004375
Time Period 2007-2010
Qw (MGD) 3.9
7Q10S (cfs) 266
7Q1OW (cfs) 0
30Q2 (cfs) 0
Avg. Stream Flow, QA (cfs) 3016
Rec'ving Stream Catawba River
WWTP Class IV
/WC (%) @ 7Q10S 2.2221
7Q1OW N/A
@ 3002 N/A
@ QA 0.2
Stream Class WS-IV CA
Outfall 001
Qw=3.9MGD
PARAMETER
TYPE
(1)
STANDARDS &
CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC WQS/ %FAVI
Chronic Acute
n # Got. Max Pred Cw Allowable Cw
Cyanide
NC
22 N 22
10
ug/L
5 2
Note: n<12
Limited data
68.3
set
- _ _ _ _ _ _ ---------no
Acute: 990
acute limit
-----------------------
Nickel
NC
261 261
ug/L
5 5
Note: n412
Limited data
3,220.1
set
_ _ ___ _ _
Acute: 11,746
_ _ _ ______________ ______
no acute limit
* Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
"Freshwater Discharge
4375- rpa for 1Q10-2010.xis, rpa
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Arsenic
Barium
Date Data
BDL=1/2DL
Results
Date
Data
BDL=1/2DL
Results
1
19.0
19.0
Std Dev.
183.8793
1
9.7 9.7
Std Dev.
4.1569
2
26.0
26.0
Mean
143.9600
2
<
5 2.5
Mean
4.9000
3
92.8
92.8
C.V.
1.2773
3
<
5 2.5
C.V.
0.8484
4
464.0
464.0
n
5
4
n
3
5
118.0
118.0
5
6
MuIt Factor=
12.7100
6
Mult Factor=
9.9600
7
Max. Value
464.0 uglL
7
Max. Value
9.7 ug/L
8
.r
Max. Pred Cw
5897.4 ug/L
8
Max. Pred Cw
96.6 ug/L
9
9
10
;aP
10
11
Hi
11
12
pr,,:
12
13
13
14
'
14
15
15
16
16
17
17
18
y:
18
19
a;
19
20
:-.
20
21
r
21
22
,,
22
23
23
24
24
25
25
26
26
27
27
28
t"`
28
29;°
29
30
rt
30
31
31
32
32
33
33
34
t''
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
-,
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
59
59
60
60
199
199
200
200
-1-
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Cadmium
Chromium
Date Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
<'
1 0.5
Std Dev.
0.0000
1
<
5 2.5
Std Dev.
3.6224
2
<.'
1 0.5
Mean
0.5000
2
<
5 2.5
Mean
4.1200
3
<
1 0.5
C.V.
0.0000
3
<
5 2.5
C.V.
0.8792
4
1 0.5
n
5
4
10.6 10.6
n
5
5
1 0.5
5
• <
5 2.5
6
MuIt Factor =
1.0000
6
Mult Factor =
7.0800
7
Max. Value
0.5 uglL
7
Max. Value
10.6 ug/L
8
Max. Pred Cw
0.5 ug/L
8
Max. Pred Cw
75.0 uglL
9
9
107.
10
11
11
12
.1
12
13
13
14
14
15
•'
15
16
16
17
17
18
18
19
19
20
20
21
4
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
-`'
33
34
34
35
35
36
36
37
37
' '•
38
38
F;.; ;
39
39
40
40
41
41
42
42
43
;
43
44
44
45
'
45
46
46
47
47
48
48
49
49
50
50
51
`.. y
51
52
52
53
53
54
54
55
55
56
56
57
57;,',
58
58
y;
59
59
60
60
199
199
200
200
-2-
4375- rpa-2010.xis, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Copper
Cyanide
Date
Data
BDL=1/2DL
Results
Date Data
BDL=112DL
Results
1
340
340.0
Std Dev.
138.8110
1 6
5.0
Std Dev.
4.4721
2
120
120.0
Mean
106.9800
2 < 5
5.0
Mean
7.0000
3
65.1
65.1
C.V.
1.2975
3 15
15.0
C.V.
0.6389
4
7.3
7.3
n
5
4 <5
5.0
n
5
5
<
5
2.5
5 < 5
5.0
6
Mult Factor =
13.0300
6
Mult Factor =
4.5500
7
Max. Value
340.0 ug/L
7
Max. Value
15.0 ug/L
8
Max. Pred Cw
4430.2 ug/L
8
Max. Pred Cw
68.3 ug/L
9
9
10
10
11
11
12
12
13
13
14
14
15
.
15 i
16
16
17
17
18
t.
18
19
19
20
20
21
t
21
Y3
22
}`
22
:d•
23
23
24
'
,
24 24
25
„:
25
26
26
27
=
27
28
28
:;
29
29
°
30
30
31
31
32
32
33
33
34
34 P'"::
35
35
36
36
37
37
38
38
39
39
40
•'; a
40
t=-
41
41
42
42
43
,,
43
44
:!
44 ;+ ,
45
t :
45
46
L •s
46
47
?,:
47
48
`;
48
49
49
50
50
51
51
52
52 ,/
53
53
54
�
54
55
55 `
56
56
57
57 ;�i
58
58 t'-,;
59
59 =Y
60
60 i' ,°'.
199
199 I;s,a
200
200
-3-
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Antimony
Lead
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
: <
<
;
5
5
115
87.7
33.4
BDL=1/2DL
2.5
2.5
115.0
87.7
33.4
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
51.0355
48.2200
1.0584
5
9.4100
115.0 ug/L
1082.2 ug/L
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45-
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
< 5
< 5
, < 5
< 5
F <• 5
..•'
ai
1a22
'1,,
}"
NC
-
BDL=1/2DL
2.5
2.5
2.5
2.5
2.5
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
0.0000
2.5000
0.0000
5
1.0000
2.5 ug/L
2.5 ug/L
-4-
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Mercury
Molybdenum
Date
BDL=112DL
Results
Date Data
BDL=1/2DL
Results
Data
1
0.3100
Std Dev.
0.0486
1
<
0.2
0.1
Std Dev.
3933.8192
2
0.SSo8
0.0008
Mean
0.0104
2
<
0.2
0.1
Mean
2130.6400
3
0.0` 0�3
_ 0.0031
C.V.
4.6608
3
560
560.0
C.V.
1.8463
4
0
0.0021
n
40
4
9130
9130.0
n
5
5
0.0019
0.0019
5
963
963.0
6
0.0030
Mult Factor =
6.9100
6
Mult Factor =
23.2800
7
0.0012
0.0012
Max. Value
0.3 ug/L
7
Max. Value
9130.0 ug/L
8
0.0012
0.0012
Max. Pred Cw
2.1 ug/L
8
Max. Pred Cw
212546.4 uglL
9
0.0010
0.0010
9
10
0.0009
0.0009
10
11
0.0010
0.0010
11
12
0.0009
0.0009
12
13
0.0014
0.0014
13
4
14
0.0008
0.0008
14
15
0.0011
0.0011
15
16
0.0009
0.0009
16
17
0.0019
0.0019
17
6v
18
0.0020
0.0020
18
19
0.0023
0.0023
19
20
0.0014
0.0014
20
21
0.0013
0.0013
21
22
0.0052
0.0052
22
is;
23
0.0023
0.0023
23
24
0.0020
0.0020
24
;• •• •
25
0.0037
0.0037
25
26
0.0026
0.0026
26
27
0.0020
0.0020
27
28
0.0061
0.0061
28
29
Dec-2007
0.0113
0.0113
29.
30
0.0003
0.0003
30
.
31
0.0014
0.0014
31
{k.
32
0.0008
0.0008
32
33
0.0024
0.0024
33
34
0.0065
0.0065
34
35
0.0086
0.0086
35
i=
36
0.0025
0.0025
36
37
0.0033
0.0033
37
38
0.0007
0.0007
38
, ;,+•
39
0.0059
0.0059
39
40
0.0097
0.0097
40
41
41
42
42
43
• .
43
44
44
45
45
46
46
47
47
48
48
49
50
49
50
iT.
51
51.•
52
52
53
53
54
54
fit?
55
55
r
56
56
57
57
5: 1
58
58
59
59
60
60
199
199
200
200
-5-
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Nickel
Phenols
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44 .
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
•
',
1.
."
;c,
-
,I
yy��
..,
J
;'.y
�!
L. ='''
:'
`
i° ;
.;a
ii':1
'- i
I '
13
.7.6
117
333
143
•
BDL=1/2DL
13.0
7.6
117.0
333.0
143.0
Results
Std Dev.
Mean
C.V.
n
MuIt Factor =
Max. Value
Max. Pred Cw
132.2429
122.7200
1.0776
5
9.6700
333.0 ug/L
3220.1 ug/L
1
2
3
. 4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37.
38
39
40
41
42
43
44
45
46
47
48,
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
25
< 10
27
< 10
18
,
`''
'
.`
;"•;:.
•'�'
:xs.
""''
,�
,,
µ,
w
y
BDL=1/2DL
25.0
5.0
27.0
5.0
18.0
.
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
10.5830
16.0000
0.6614
5
4.7600
27.0 ug/L
128.5 ug/L
- 6 -
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Selenium
Silver
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
<
<
f:
1
.
BDL=1/2DL
5.4 5.4
10 5.0
14.2 14.2
10 5.0
11.4 11.4
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
4.3174
8.2000
0.5265
5
3.6000
14.2 ug/L
51.1 ug/L
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date
Data
<
<
<
<
<
r
-
i a -1
..;.
BDL=1l2DL
5 2.5
5 2.5
5 2.5
5 2.5
5 2.5
Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Pred Cw
0.0000
2.5000
0.0000
5
1.0000
2.5 ug/L
2.5 ug/L
-7-
4375- rpa-2010.xls, data
5/26/2010

REASONABLE POTENTIAL ANALYSIS
Zinc
Date
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Data BDL=112DL Results
33 33.0 Std Dev. 25.7068
96 96.0 Mean 52.9800
50.8 50.8 C.V. 0.4852
33.3 33.3 n 5
51.8 51.8
Mult Factor = 3.2900
Max. Value 96.0 ug/L
Max. Pred Cw 315.8 ug1L
-8-
4375- rpa-2010.xls, data
5/26/2010

Table 1. Project Information
Facility Name
WWTP Grade
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
Time Period
Data Source(s)
Clariant
IV
NC0004375
001
3.9
Catawba River
WS-IV CA
329.0
3016
2007-201.0
application and DMRs
1 Q10 = 266 cfs
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
. Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Name
Type Chronic Modifier Acute PQL Units
Arsenic
NC
50
ug/L
Barium
NC
1000
•
ug/L
Cadmium
NC
2
15
ug/L
Chromium
NC
50
1022
ug/L
Copper
NC
. 7
AL
7.3
ug/L
Cyanide
NC
5
N
22
10
ug/L
Antimony
NC
5.6
ug/L
Lead
NC
25
N
33.8
ug/L
Mercury
NC
0.012
0.0002
ug/L
Molybdenum
A
3500
ug/L
Nickel
NC
88
261
ug/L
Phenols
A
1
N
ug/L
Selenium
NC
5
56
ug/L
Silver
NC
0.06
AL
1.23
ug/L
Zinc
NC
50
AL
67
ug/L
4375- rpa-2010.xls, input
5/26/2010

Roo- cAA,)4_
Cox- ve,k\' i
Cw j -zed CFP- !laid
I U„
(A---1, 11 6/v- T1-)
04 0 + o. 040 — 0). og /
r—ejeit,z.
0.02 7,1.,3`f = 20.2 ie/d
x 0,68 X 8,3y- 33.02
/ SS = /i
le/1
30. ° J/)
"/� x
SS -
//
dV 0, — ryto
,NU) o• i7 `f t 0. 035 = 0, 2t 3
,i- lL >c 0, 2 / S = 78 /i/d
60 0= /1, S j x o, 2 9 3 x S, 3 y- 2,61 /8//
7S 3 Yj0,2-43 x y .C3.3 /e/d
rj /c, ,-213 y 75. 5 /e/c/
./cyj
Flo,v = 0,o6 lLtGi
SS = 3J It x 0,001x g.SY = o.2S //d rt•av ,
J
TSS = 2.IS /L x 0.004 3..sY 0.3R /e/) dry/
GWl
Flo-v - 0,32S /460 4- 0,30c /fcn qri-v--A-1Uv4_ n) _0,63
ADP s.(3 rJ JG x 0,63 3y = 21s, S iv'. a_
%SS - 6 3 M L p. 6 x . 3 y - 324. si
216, 0 • ,(g . -3? = ///,(3 H ,
D = 32 �& x(),x LTa, /55,sr
G = T27- ,6S x 8,3'1 ,8
Isla
1Od
v
/e/ IAA a-vi
RI) d, yn
/113

, !S (P + = D. 6 3
CAA. = o, S ,�-� �G x c�, 3 3 , 3 Ie16/
`� _ l
0,`120 r� /�. 9•3y / D.6�� 2,2 felot
A- ce-4 b A- 5 :7-1 s. 3 y , S 161)
ArQ,7'0 1.,2-n,ac,t = 0,0s62 x 8,3V 0.63= 0,2g 1�1�
2_ r�d- �,W ,�� 1 S x 8.3 y >co3 9, /40
p— C °1 = 0,50 %G X 8.Ti x 0,43 — 2,3 ig/oi
C J) - 0,2-Os /IA x 8,3y X
ri\-5LA--) r-ciG V3y xo.‘3 /�f
PuH(Li-) il'2L:1 //, y 0.4,3 = o,s4 lei)
2 �I b - I(A-19 e) = 0.10 6 y $ • 31/ p, S 6 AVd
tiLn
/4 y r4U4
S �, Y 1_ i, 5
� �J �L x g. 3 x v. 6 IV)
r),»57 ,�9)�, �� 31.( X a�3= 2.� k/d
cizi' el-c--t1/°11-c- - x't OrL
2- rs-t-71c,,,c,0A = V gi 7/Z- xS.3`1 2-C,1 /c/
- Cvu so) = -tq 2 i k x 3y x v, 63 = 10,1 I Vd
//d
Cr.-lo f = D, 658 7 %L A. 3 y x o, ‘2=- 3,7
h-t-A_A)) = 3,t1G R3 63-/id
L' , , �,� o)G x q.3y a- s3 = 1,3 hold
ieid
2 1-1 6 `]�-,�Gl+�uvuo ���� = o, 1 S S r� �� i8. 3�! x D, 63 = 0,3/

9 0 ± 2, + g SS _egg ,» )e l4'
10r4_) p._ r 1,\c- h
2_0 131 4(2-73 300.,i 10)
fisS — 20 S'b,3 `52'f, g itiaP
A SS = 0 t qj • 9 t o. 3s + /f/ — /I/ 2 \1 , 2 /67d
ez4(...7 ,
�,�
04 G 402 g /0q/
oa G )40 otx

SOC PRIORITY PROJECT: NO
To: Western NPDES Program Unit
Surface Water Protection Section
Attention: Sergei Chernikov
February 12, 2010
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Mecklenburg
NPDES Permit No.: NC0004375
PART I - GENERAL INFORMATION
1. Facility and address: Clariant Corporation
Post Office Box 669246
. Charlotte, NC 28266
2. Date of investigation: February 10, 2010
3. Report prepared by: Samar Bou-Ghazale, Environmental Engineer II
4. Person contacted and telephone number: Bill Archer, [phone]
5. Directions to site: From the jct. of NC Hwy. 27 and Hwy. 273 just east of the Town of
Mount Holly, travel east on Hwy. 27 N 0.6 mile. The entrance to the Clariant facility will
be on the right (south) side of Hwy. 27 on the east side of the Catawba River.
6. Discharge point(s), List for all discharge points: -
Latitude: 35° 16' 55" Longitude: 81° 00' 30"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: F 14 SE
7. Site size and expansion area consistent with application: Yes. There is additional area
available for expansion, if necessary.
8. Topography (relationship to flood plain included): The site has gently rolling topography,
which slopes towards the Catawba River at a rate of 2 - 4%. All existing WWT facilities
are protected from flooding by an earthen dike.
9. Location of nearest dwelling: None within 1000 feet of the WWTP site.

Page Two
10. Receiving stream or affected surface waters: Catawba River (Lake Wylie)
a. Classification: WS-IV, B CA
b. River Basin and Subbasin No.: Catawba 030833
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is the headwaters of Lake Wylie, a large reservoir created to generate
hydroelectric power. The reservoir is also used for primary and secondary
recreation with frequent bodily contact. There is a municipal water intake 4
miles downstream of the discharge point.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater: 3.9 MGD (Design Capacity)
b. What is the current permitted capacity: 3.9 MGD
c. Actual treatment capacity of current facility (current design capacity) : 3.9 MGD
d. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: There have been no ATCs issued in the past two years.
e. Description of existing or substantially constructed WWT facilities: The existing
WWT facilities consist of two separate sewer systems, and alkaline system and an
acid system. Both systems transport SW to the treatment system as well as
wastewater from on -site buildings. The existing treatment facilities consist of two
SW basins for both the alkaline and acid wastewater streams followed by two acid
neutralization tanks, a lime slurry tank, two primary clarifiers, a wastewater
equalization basin, an aeration basin (mechanical), two secondary clarifiers, two
polishing ponds, staged effluent holding facilities including a holding basin and
post aeration, two sludge holding tanks, and two sludge dewatering belt presses.
f. Description of proposed WWT facilities: There are no WWT facilities proposed at
this time.
g. Possible toxic impacts to surface waters: This facility has passed all but two
toxicity tests since 2006. Please note that their IWC is 1.8%.
2. Residual handling and utilization/disposal scheme: Residuals that are generated in the
wastewater treatment process are dewatered by the belt presses and then disposed of in a
lined on -site landfill (Permit Number WQ0000537).
3. Treatment plant classification: Class IV (no change from previous rating).
4. SIC Code(s): 4953 Wastewater Code(s): 02, 66,72,73,78
5. MTU Code(s): 01502

• Page Three
PART III - OTHER PERTINENT INFORMATION
I. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No public monies were used in the construction of this
facility.
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: N/A
4. Alternative analysis evaluation: There is no known alternative to the existing discharge.
PART IV - EVALUATION AND RECOMMENDATIONS
The permittee, Clariant Corporation, is requesting renewal of the subject permit. Clariant
WWTP currently treats process and domestic wastewater generated on site, nonhazardous
wastewater trucked to the site from industrial customers, contaminated groundwater pumped from
site remediations wells, leachate from onsite permitted sludge landfill and stormwater from the
site. A site investigation revealed that the wastewater treatment facilities were in good
operational conditions.
Clariant Corporation was formerly a specialty chemical and dye manufacturing site from
1936 until mid 2005. Prior to 2005, the primary products by the Clariant were sulfur -based dyes
and specialty organic chemicals. All organic chemical manufacturing and processing ceased in
2005. At this time there are two tenants in this facility generating wastewater that is treated in
Clariant WWTP. These facilities are:
A) SCR -Tech. —A non -categorical operation that regenerates NOx catalyst used for air
pollution control in the fossil fuel burning electrical power generation industry.
According to applicant SCR -Tech activities involve physical and chemical cleaning of
the catalyst modules that are trucked to the site. Possible constituent in their
wastewater include organic acids, iron, arsenic, molybdenum, vanadium and tungsten.
B) Monark Industrial Services, Inc. —A non categorical operation that solidified liquid
and semi -solid wastes. Monark stores equipment on the site and conducts
nonhazardous waste stabilization in a covered concrete pit. (Discharge from this
facility is domestic wastewater and stormwater run-off)
Since the facility discontinued the on -site dye and specialty chemical manufacturing and
the inclusion of the wastewaters that does not contain Organics Chemical, Plastic, or Synthetic
Fibers (OCPSF), Clariant is requesting permit modifications which include the removal of
(OCPSF) from the permit effluent discharge. Currently, the facility is only accepting wastes that
fall into the CWT (Centralized Waste Treatment) organics category. This office recommends
approval of Clariant Corporation request.

Pending review and approval by the Western NPDES Program Unit, It is recommended
that the NPDES permit be renewed as requested.
Cam'
Signature of Report re er
Water Quality Regional Supervisor
—r2—ra
Date
--z_pz../ 0
Date

Clariant
Clariant Corporation
Mt. Holly Plant
December 22, 2009
P.O. Box 669246
Charlotte, NC 28266
Mrs. Dina Sprinkle
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Permit Renewal Application
NPDES Permit No. NC0004375
Clariant Corporation - Mt. Holly East Plant
Dear Mrs. Sprinkle:
We are submitting one original and two copies of the attached permit application and permit
documents for renewal of the subject NPDES permit for the Clariant-Mt. Holly East facility.
It is our understanding that no fee is required by the Division since the documents being
submitted are for renewal of the permit.
BACKGROUND
Clariant operates an industrial facility in Mecklenburg County near Mount Holly, North
Carolina (Clariant-Mt. Holly East Plant). This facility produced dyes and specialty chemicals
from 1936 until mid 2005, when it ceased all organic chemical manufacturing and processing.
The existing NPDES permit is based on OCPSF and CWT effluent guidelines. Based on
current operations the facility should no longer be covered by the OCPSF guidelines, but only
the Centralized Waste Treatment (CWT) Organics Treatment and Recovery guidelines.
Clariant's Wastewater Treatment Plant currently treats process and sanitary wastewater
generated onsite, nonhazardous wastewater trucked to the site from third party industrial

customers, contaminated groundwater pumped from site remediation wells, leachate from an
onsite permitted sludge landfill and stormwater from active portions of the site. Each of these
sources is described in more detail below.
The following two (2) tenant operations are currently located at the facility with the treatment
of the resulting wastewaters in the on -site WWTP:
• SCR -Tech - A non -categorical operation that regenerates air pollution control
catalyst; and
• Monark Industrial Services, Inc. - A non -categorical operation that solidifies liquid
and semi -solid nonhazardous wastes.
The largest tenant, SCR Tech, regenerates catalyst modules for pollution control systems at
power plants. SCR Tech leases Buildings 21, 32, 48, 49 and 51. SCR Tech's activities
involve physically and chemically cleaning catalyst modules that are trucked to the site.
Chemical cleaning and regeneration of the modules is conducted in Bldg 48. SCR Tech
generates wastewater which can contain fly ash particulates, organic cleaning agents (primarily
organic acids), flue gas constituents and metals used as catalysts in the modules. SCR Tech's
primary process wastewater is collected and pretreated within Building 48 to precipitate and
remove the vast majority of the metals present in the raw waste prior to discharge to
Clariant's sewer. Possible constituen is in their wastewater include organic acids, iron,
arsenic, molybdenum, vanadium and tungsten.
The second tenant at the Mount Holly East Plant is Monark Industrial Services. Monark stores
equipment on the site and conducts nonhazardous waste stabilization in a covered concrete pit.
Any runoff from Monark's operations area between buildings 39 & 46 is captured by the
onsite wastewater sewer.
2

The Third Party waste makes up the overwhelming contribution of BOD and suspended solids
to the plant influent. CODs over 100,000 mg/I are not uncommon in third party wastes.
Clariant has in place a system for evaluating and approving waste streams prior to acceptance.
Prospective customers must fill out a waste profile for each new waste stream and, except in
unusual situations, must provide a pre -shipment sample for Clariant to evaluate. Samples of
each incoming shipment are also collected and checked for consistency with the profile using
specific gravity, pH and appearance. Clariant currently only accepts third party wastes that fall
into the CWT organics category. Clariant's current permit also allows oily water treatment
and recovery, but acceptance of oily wastes was discontinued in 2005.
Clariant has an extensive network of remediation wells that pump contaminated groundwater
for treatment in the wastewater plant. Currently there are 21 individual pumping wells in
CERCLA areas around the property and a well point system of 110 wells in the RCRA area
near the WWTP. The CERCLA wells discharge directly to the sewer system. The RCRA
wells pump to an air stripper prior to discharging to the WWTP. We anticipate that the RCRA
requirement to pre -strip this RCRA water will be dropped in the near future. The predominant
contaminants in the pumped groundwater are 1,2-dichlorobenzene and chlorobenzene at low
mg/1 concentrations. The recovered groundwater may contain much lower levels of other
contaminates such as xylenes, toluene, ethyl benzene, and 1,4-dichlorobenzene.
Stormwater from most of the active portion of the site is collected and directed to the WWTP.
The areas around the facilities leased by our tenants are captured by the plant sewers, including
areas where SCR Tech loads & unloads their catalyst modules. Because of recent building
shutdowns and demolitions, Clariant modified its stormwater system about two years ago to
redirect run-off from two areas of the site to stormwater discharge outfalls instead of the
wastewater treatment plant. This has reduced the amount of stormwater being treated in the
WWTP.
3

With the cessation of OCPSF manufacturing, the requested permit renewal will result in a net
reduction in the currently allowed wasteload discharge of BOD and TSS from the Clariant-Mt.
Holly East facility. While there may be future tenants and new development at the site in the
future, the potential impact on wastewater generation can not be predicted at this time, and thus,
there are no provisions for expansion included in this application.
Application Package
The application package for the permit renewal and modification includes the following
documents:
• Sludge Management Plan;
• EPA Form 1— General Information;
• EPA Form 2C NPDES — Existing Manufacturing, Commercial, Mining and
Silvicultural Operations;
• Application Support Document; and
• Suggested Draft permit.
We are also emailing an electronic copy of the suggested draft permit to your attention.
We appreciate the Division's cooperation and assistance with this matter. We would appreciate
the opportunity to meet with you to discuss the application documents and our plans for the
Clariant-Mt. Holly East facility. We will call your office within the next few weeks to
4

schedule a mutually convenient meeting date. In the meantime, please feel free to call either
Ned Fiss with Fiss Environmental Solutions, Inc. at [phone] or myself at (704) 822-
2702 if you have any questions or need additional information.
Sincerely,
Clariant Corporation
Bill Archer
Facility Manager
Attachments
cc: N. Fiss, FES
5

Clariant Mount Holly East
Wastewater Treatment Sludge Management
Both primary and secondary sludge generated by the Mt. Holly East Wastewater
Treatment Plant is dewatered and landfilled onsite in a dedicated permitted Residuals
Disposal Unit (Permit Number WQ0000537). Sludge from both the primary and
secondary clarifiers are periodically pumped into one of two sludge holding/ thickening
tanks. These tanks feed two pressure belt filters. The sludge filter cake drops from the
filters directly into a dedicated dump truck. When full, the truck transports the sludge to
the on -site landfill cell and deposits the sludge into the cell. Currently Cell is the only
active landfill cell; however, a fourth cell is prepared and permitted for operation.
Leachate from the cell is returned to the wastewater treatment system.
/Z /
Bill Archer, Facility Manager Date

APPLICATION SUPPORT DOCUMENT
PERMIT RENEWAL
NPDES PERMIT NO. NC004375
CLARIANT CORPORATION -MT. HOLLY EAST PLANT
^
Ask Prepared for:
Clariant Corporation
PO Box 669246
Charlotte, NC 28266-9244
Prepared by:
.�, FISS Environmental Solutions, Inc.
9331 Tillot Drive
Matthews, NC 28105
ask FISS Job No. N130-33
FISS Document No. 13033r001
^
4014 December, 2009
Ask
� FISS
ENVIRONMENTAL

4161
eat1
elee
SECTION 1.0
BACKGROUND
Aft, 1.1 GENERAL
A'°' Clariant operates an industrial park facility (formerly a chemical production facility) and
centralized waste treatment (CWT) plant near Mount Holly, North Carolina (Clariant-Mt. Holly
East Plant). Wastewater from the facility and from off -site locations are treated in an on -site
wastewater treatment plant (WWTP) and the treated wastewaters are discharged to the Catawba
River under NPDES Permit No. NC0004375. The current NPDES permit became effective on
July 1, 2005. This permit was issued by the North Carolina Department of Environment and
Natural Resources (NCDENR).
This Application Support Document has been prepared by FISS Environmental Solutions, Inc.
(FISS). The purpose of this document is to present information required for development of
appropriate discharge limitations for the Clariant-Mt. Holly NPDES permit in accordance with
NCDENR regulations and US EPA effluent guidelines for Organic Chemical, Plastics, and
Synthetic Fibers (OCPSF) Manufacturing and Centralized Waste Treatment (CWT). The
methodologies utilized in development of the proposed limitations are the same methodologies
used by NC DENR in development of the July 2005 NPDES permit.
The Clariant-Mt. Holly East facility was formerly a specialty chemical and dye manufacturing
site from 1936 until mid 2005. Prior to 2005, the primary products produced by the Clariant-Mt.
Holly East facility were sulfur -based dyes and specialty organic chemicals. However, all organic
ea) chemical manufacturing and processing ceased in 2005. The facility continues operation of an
industrial park facility and a centralized waste treatment (CWT) system as authorized by the
latest NPDES permit. According to the OCPSF regulations as written in 40 CFR Part 414 and
efts
confirmed by Jan Matuszko at the U.S. E.P.A., OCPSF regulations apply only to process
wastewater discharges resulting from the manufacture of OCPSF products, and as such, these
regulations no longer apply to the Clariant facility since all OCPSF production has been
discontinued. However, the CWT system will continue to operate to treat additional waste
streams from other on -site and 31.d party sources.
MEN
1

AN1
fits The treated wastewaters include:
1. CWT wastewaters from off -site manufacturing operations, hauled to the Clariant facility;
2. Impacted Stormwater from the facility;
/fi'', 3. Process wastewater and domestic wastewater from current on -site, non-OCPSF
operations; and
4. The impacted groundwater from a groundwater pump and treat system and leachate from
an active on -site landfill cell.
elms
In addition to treating hauled -in wastes in the centralized waste treatment operations, Clariant
ow\ has developed the facility as an industrial park for compatible industrial operations. To date, two
(2) tenants have operations at the facility with treatment of resulting process wastewaters in the
on -site WWTP.
'at` As a result of historical OCPSF operations, the facility is included on the National Priorities List
due to organic contaminants contained in soil and groundwater at the site. The WWTP receives
groundwater from a groundwater pump and treat system and leachate from an active on -site
landfill cell. Stormwater from active portions of the facility are treated in the on -site WWTP in
addition to the wastewater from current on -site industrial operations. Treatment in the on -site
WWTP of leachate, groundwater and stormwater from the facility are continuing. Since 2003,
,at, the Clariant facility has been permitted to accept centralized waste from off -site sources.
As dye manufacturing portions of the facility have become inactive, Clariant has worked to
'''vN develop the facility as an industrial park for compatible industrial operations. The following
tenant operations are located at the facility with the treatment of the resulting process
wastewaters in the on -site WWTP:
,.►, • SCR -Tech — A non -categorical operation that regenerates NO„ air pollution control catalyst.
• Monark Industrial Services, Inc. — A non -categorical operation that solidifies liquid and
semi -solid wastes.
raltS
2
elms

rioN
Aits
With the discontinuation of on -site dye and specialty chemical manufacturing and inclusion of
the wastewaters described above, Clariant is requesting permit modifications which include the
talk
tee, removal of OCPSF effluent discharge limitations from the NPDES permit for the Clariant-Mt.
Aq Holly East facility.
PAIN 1.2 EXISTING WASTEWATER SYSTEM
The Clariant Mt. Holly East site has two separate sewer systems, an alkaline and an acid. Both
evAN
rilLN
carry impacted 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 partially neutralized
water into two impoundments for storage. The storage impoundments have a capacity of 2.5
MG. The acid sewer system has a capacity of 500,000 gallons per day. There are currently no
processes at the site that produce acidic wastewater requiring neutralization.
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. Any wastewater over the
capacity of the lift station can be diverted into a storage impoundment. The alkaline sewer
system has a capacity of 4,500,000 gallons per day.
•
The combined and neutralized sewer streams flow into two primary clarifiers that operate in
parallel. Primary solids settle out and are pumped to two sludge holding tanks. Clarified
wastewater flows by gravity from the primary clarifiers to a 4.5 MG equalization/biological
treatment basin. The two clarifiers are designed to handle a total wastewater flow of 5,200,000
gallons per day.
The 4.5 MG equalization/biological treatment basin is equipped with several mixers and aerators.
This basin is typically operated as a first stage activated sludge unit. Wastewater flows from it
by gravity to a second stage 2.5 MG activated sludge aeration basin. The aeration basin has jet
3

Albs
mixers that maintain a homogeneous mixture of sludge and water. Aerators provide dissolved
oxygen for the mixed liquor bacterial population as needed.
eft, Mixed liquor from the aeration basin flows by gravity into two secondary clarifiers. Settled
biological sludge is returned to the biological system. Waste activated sludge is pumped either
'ft, to the sludge holding tank or 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
5,000,000 gallons per day of flow.
egAN
The primary and secondary treatment process includes two neutralization tanks. Lime slurry is
pumped into each neutralization tank in a continuous manner for neutralization of acidic
,t,, wastewater. The neutralization process can accept up to 750,000 gallons per day of acidic
en)p, wastewater at pH 0.5. Because there is currently no generation of highly acidic wastewater, this
neutralization facility is not currently needed or used.
ea" Treated effluent exiting the secondary clarifiers flows through a polishing pond and canal
paralleling the WWTP. The canal flows to a second polishing pond. This pond has an effluent
lift station and an exit valve that can shut off flow to the river. The gravity flow exiting the
second pond passes through a flow measurement flume prior to entering another canal that
conveys the water to a discharge point in the Catawba River.
est, The effluent lift station can deliver the entire flow of the exiting effluent to a 360 MG effluent
eviN holding basin for storage and re -treatment through the WWTP. If any of the permitted effluent
parameters are expected to be impacted by a process upset or spill in the complex, the WWTP
throughput is pumped into the effluent holding basin. Water that is diverted into the effluent
`we\ holding basin is eventually released back to the WWTP and re -treated through the activated
sludge system prior to discharge.
AIRN
1.3 FACILITY CHANGES
ANN
41t, Clariant has no plans to modify any of the on -site WWTP processes or components since the
wastewater they receive is compatible with existing WWTP design. Clariant is utilizing
4

available portions of the Clariant-Mt. Holly East facility as an industrial park and is continuing to
pursue additional tenants for the industrial park; however this application does not include
,N, provisions for potential expansion. A brief discussion of the current site utilization is presented
below.
1.3.1 Shutdown of Dye and Specialty Chemical Manufacturing
Clariant no longer operates the textile chemical and dyestuff plant within the complex.
This plant was shut down in October 2002. All specialty chemical manufacturing and
processing was ceased in mid 2005. Both operations were subsequently cleaned and
mothballed.
1.3.2 SCR -Tech
SCR -Tech regenerates NO,, catalyst used for air pollution control in the fossil fuel
burning electrical power generation industry. SCR -Tech occupies Building 48 within the
'4.1` Clariant facility (one of the mothballed production plants) for their catalyst regeneration
tutN
process and has been operating since 2002. SCR -Tech also occupies warehouse,
laboratory, and office space at the site.
1.3.3 Monark Industrial Services, Inc.
AirN
Monark Industrial Services, Inc. (MIS) provides remediation, waste management, and
transportation services. MIS leases space at the Clariant facility for use in the
consolidation and solidification of non -hazardous waste materials for landfilling off -site.
ent, Except for stormwater runoff from the leased space, MIS's operation contributes no
elle' process wastewater for treatment in the on -site WWTP.
eloN
5
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rilbt
SECTION 2.0
WASTEWATER CHARACTERISTICS AND SOURCES
Ask
2.1 DISCHARGE CHARACTERISTICS
Effluent data from the Clariant-Mt. Holly East facility discharge monitoring reports (DMR)
submitted to NCDWQ for the period of January 2008 through August 2009 are summarized in
Appendix A. Average daily flows for the latest 12 months of available data are also presented in
Table 2-1. As shown in Table 2-1, the average effluent flow for the 12-month period of
September 2008 through August 2009 is 0.44 MGD. Flows during this period have been
affected by a more than 30% reduction in 3`1 Party waste receipts in 2009 versus 2008.
ros
As required by the current NPDES permit, Clariant has collected one (1) effluent sample per
month and analyzed for total nitrogen (TN) and total phosphorus (TP). For the period of
September 2008 through August 2009, TN and TP effluent monitoring results are shown
respectively on Figures 1 and 2.
est
A summaryof priority pollutant analytical testingperformed over thepast 5 years is included in
P � tYYt�
Appendix B.
2.2 WASTEWATER SOURCES
2.2.1 General
A water flow schematic for the Clariant-Mt. Holly East facility is presented in Figure 3.
Wastewater present or planned for immediate inclusion are from the following industrial
categories of the US EPA Effluent Guidelines and Standards:
• Centralized Waste Treatment Point Source (40 CFR Part 437); and
• Non -categorical industrial wastewaters.
The current NPDES permit includes OCPSF wastewater sources. However, according to
EPA regulations, 40 CFR Part 414 only applies to establishments that manufacture
,ot, OCPSF products. Clariant has terminated all on -site chemical and dye manufacturing, so
OCPSF regulations no longer apply. The facility continues to treat stormwater and
groundwater that was contaminated as a result of historical OCPSF manufacturing in the
6

on -site WWTP, and also accepts 3rd party OCPSF wastewaters trucked to the Clariant-
Mt. Holly East facility under the CWT organic waste regulations. OCPSF effluent
standards include a number of compounds that, as a result of the change in OCPSF status,
will no longer require monitoring. As shown in Appendix B, no OCPSF parameters have
been detected in the Clariant WWTP effluent in over 5 years. Clariant is therefore
requesting that OCPSF effluent limitations and monitoring requirements be removed
from the 2010 Clariant-Mt. Holly NPDES permit.
7

AIN
tAIN
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tiat
rots
tok
rit
PPILN
Mrs
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TABLE 2-1
EFFLUENT FLOW DATA SUMMARY
,y tip
Year
r
r Month• ,,
t z'''
AveragelDaily E_ low -, G )
2008
September
0.55
October
0.42
November
0.44
December
0.40
2009
January
0.29
February
0.37
March
0.53
April
0.53
May
-
0.52
June
0.43
July
0.38
August
0.37
12-month Average Flow (MGD) 0.44
8

) ) ) ) ) ) ) ) ) ) ) 19 19 )i))))))))))))))))))))))))))))
Concentration (mg/L)
100.0
90.0
80.0
70.0
60.0
50.0
40.0
30.0
20.0
10.0
0.0
Figure 1. Average Effluent Total Nitrogen (Sept. 2008-Aug. 2009)
Sep-08 Oct-08 Nov-08 Dec-08 Jan-09 Feb-09 Mar-09 Apr-09 May-09 Jun-09 JuI-09 Aug-09
9
—♦—TN mg/L

Concentration (mg/L)
10.00
9.00
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
Figure 2. Average Effluent Total Phosphorus (Sept. 2008-Aug. 2009)
Sep-08 Oct-08 Nov-08 Dec-08 Jan-09 Feb-09 Mar-09 Apr-09 May-09 Jun-09 Jul-09 Aug-09
10
—*—TP mg/L

)))).))))))))))))))))))))J)))))))))))1)
TRUCKS 32
150
THIRD PARTY
CWT
182
ALKALINE
SEWER
SCR TECH
0
[...... EVAPORATION 2
4
UTILITIES
(STEAM GENERATION)
POTABLE WATER
CITY OF CHARLOTTE
46
48 21
27
GENERAL NOTES:
1. ALL FLOWS ARE IN 1,000 gpd AND ARE AVERAGE DAILY FLOWS.
2. FLOWS ARE BASED ON EXISTING OPERATIONS.
3. NEGLIGIBLE LOSS OF WATER TO PRODUCT OCCURS DURING MANUFACTURING.
4. STORMWATER IS BASED ON A 0.118—INCH RAIN.
SCR PRETREATED
ACID
SEWER
SANITARY WASTE 7
GROUND WATER
REMEDIATION
RCRA 77
CERCLA 133
FUTURE
TENANT EXPANSION
0
STORM WATER
188
WATER
TREATMENT
(STAND—BY)
NEUTRALIZATION
STORM FLOW
STORAGE
STORM FLOW
STORAGE
PRIMARY
CLARIFIERS
H
SLUDGE
FILTRATION
SLUDGE
LANDFILL
EQUALIZATION/
BIOLOGICAL TREATMENT
73
EVAPORATION
ACTIVATED
SLUDGE
FILTER PLANT BACKWASH
STORM FLOW
STORAGE
154 WATER INTAKE
SETTLING
CANAL
STORAGE
SECONDARY
CLARIFIERS
POLISHING
POND
POLISHING
POND
POST
AERATION
CATAWBA RIVER
FLOW —�
6
12/17/09
0H
REVISED STREAM FLOW RATES
5
12/6/04
K.S.
AWARE ENVIRONMENTAL INC. - OOC No. 13020p02.0WG
4
8/20/02
K.S.
AWARE ENVIRONMENTAL INC. - DOC No. 13020p02.DWG
3
7/30/02
K.S.
AWARE ENVIRONMENTAL INC. - DOC No. 13020p02.OWG
2
7/18/02
0H
REVISED STREAM FLOW RATES. ADDED SEMIWORKS ET WAREHOUSING
1
6/21/02
DH
REVISED STREAM FLOW RATES
0
1/19/01
OH
ISSUED FOR RECORD
raoutcT N0. I DRNMM I GR.1= I open. 1
0tv190/4 orscre 00N
EFFLUENT
METERING
564
INS COMM 6 0 MA I en ODMoosne coarerCATON YO re menu. a wean CCIupI4m7M.
WT. ICILY PLAIT. R IAST NOT EC COPIED 011 LOWED ael101R TIC CONSO4 11 000017 CAIf01W10 0 AMD
KM o PROMPTLY GERM= ON RDUF 1 70 COIPILDCN Or Moot no ORIRP0 INS OEM IXIA1 a0N
73Q•. 00 NOT YWWLY OM IN 110 Oar.
Mro. 900011 Diane
Our
• 01.11
0ATL
MANNCO 57
Clariant
Mt. Holy Plant. P.O. Box 669246. Charlotte. North Carolina 28266
sorb. avomect
wr a 1.111
WIN INCONCLON
• sercavo wa1.
Prat wet
83420102
FIGURE 3
DEPARTMENT 50
PROCESS FLOW DIAGRAM
WATER FLOW SCHEMATIC
NPDES PERMIT NC0004375
elleiNCO
Meao 11 a
ROT yea Oleo
1-1
No I 1 07 �' I790.53 050.01.8342

Ashs
elq
rah
efts
ellek
A breakdown of the flows from each source, by industrial category is shown in Table 2-2.
Flow components included in each category are discussed in the following subsections.
2.2.2 Centralized Waste Treatment (CWT) Category
Clariant receives organic -bearing wastes from both on -site and off -site sources, which are
included under the Centralized Waste Treatment category. CWT organic wastewaters
include any wastewaters at a CWT facility associated with the treatment of organic
wastes. Clariant will not receive metal -bearing wastewaters included under Subpart A —
Metals Treatment and Recovery (40 CFR Part 437.10) or oily wastes included under
Subpart B- Oils Treatment and Recovery (40 CFR Part 437.20) of the CWT Effluent
Guidelines and Standards.
eat, CWT wastes received by Clariant are described below:
• 3rd Party Organic -Bearing Wastes (32,000 gpd)- Clariant has been receiving
organic -bearing wastewaters from off -site sources since 2001. The solicited 3rd party
,b•r, wastewaters include only wastewaters compatible with the on -site WWTP. As oily
est, wastewaters are no longer received by the facility, it is requested that CWT oily
wastewater monitoring requirements be removed from the permit.
est.• Stormwater (42,000 gpd) — Since the WWTP is a CWT operation, all stormwater
generated from the WWTP area and landfill are classified as CWT wastes.
Stormwater generated elsewhere on -site does not fall into the CWT category.
• Other CWT Wastes (150,000 gpd)- During treatment of centralized wastes, the
following wastewaters are generated and treated in the on -site WWTP:
emeN
• Equipment washwater; and
• Primary and biological solids processing.
Anis
2.2.3 Non -Categorical Wastewaters
tots Clariant continues to treat the following existing non -categorical wastewaters in the on-
e."' site WWTP:
edik
• Sanitary Wastewater (7,000 gpd);
12

• Filter Plant Backwash (1,000 gpd);
• Process and Non -Process Area Stormwater (147,000 gpd)- As discussed above,
the Clariant-Mt. Holly East site is included on the NPL due to organic contaminants
contained in groundwater and surface water. These contaminants resulted from
historical OCPSF activities previously performed at the facility. These contaminated
stormwaters, which are treated in the on -site WWTP for removal of contaminants
prior to discharge, are generated from the following areas on -site:
• Effluent holding basin;
• Production buildings area; and
• non -process areas.
• Groundwater (210,000 gpd) — The Clariant-Mt. Holly East site is included on the
National Priority List (NPL) due to organic contaminants contained in groundwater
and surface water. Groundwater is extracted from the site, treated and discharged to
the on -site WWTP for further treatment.
• SCR Tech Air filter regeneration wastewater (48,000 gpd)- SCR -Tech regenerates
NO„ reduction catalyst used for air pollution control in the fossil fuel burning
electrical power generation industry. SCR -Tech occupies Building 48 within the
Clariant facility (one of our mothballed production plants) for their catalyst
regeneration process and has been operating since late 2002. SCR -Tech also
occupies warehouse, laboratory, and office space at the site, and uses steam produced
by the Clariant facility.
SCR operates under SIC 3564. SCR's regeneration process is not covered by any of
the categorical standards in the US EPA Subchapter N Effluent Guidelines and
Standards.
The catalyst regeneration process removes metallic and fly ash contaminants from the
ceramic substrate and re -deposits new catalyst on the substrate. Water baths
containing various cleaning agents are used to dissolve contaminants, and clean
deposits from the substrate.
13

The company's regeneration process includes pretreatment of the spent regeneration
solutions by addition of iron and lime slurry to the regeneration solution for
precipitation of metals. The precipitated solids and metals are then removed from the
spent solutions through filtration along with fly ash contained in the solutions. The
filtered solutions are discharged as process wastewater to the Clariant WWTP for
further treatment. Possible constituents in this wastewater include organic acids, iron,
arsenic, molybdenum, vanadium and tungsten. To improve the efficiency of metal
precipitation, Clariant is will begin providing further treatment of the SCR
wastewater for removal of metals through segregated sedimentation in one of the
WWTP's existing primary settling tanks. Current flows resulting from SCR-Tech's
operation are approximately 48,000 gpd.
The sludge from the SCR regeneration operations will be collected in roll -off
containers and hauled to the Republic Services landfill in Concord, North Carolina
for disposal. Sludge removed from the Clariant primary clarifier receiving SCR
wastewater will be dewatered separately through the Clariant WWTP beltpress
equipment and also hauled to the Republic Services landfill for disposal. Repeated
TCLP testing of SCR Tech's sludge has been shown to be non -hazardous.
14

Ink
sink
ifask
Adak
aft
TABLE 2-2
WASTEWATER FLOWS
Wastewater Source
......,.M , . i
Existing and Planned Flows
Average
Daily Flow
(MGD )
Category
Average Day Flow
(MCD)
Category
Max Monthly
(�IGD) «)
Centralized Waste Treatment
3rd Party Organic WW
0.032
0.046
CWT Stormwater
0.042
0.061
Primary & Biological Solids Processing
0.070
0.102
Other Equipment & Unloading Area Washwater
0.080
0.116
0.224
0.325 —
Non -categorical
Sanitary
0.007
0.010
—
Filter Plant Backwash
0.001
0.001
—
Groundwater
0.210
0.305 -1
Process Area Stormwater
0.120
0.174
Non -Process Area Stormwater
0.027
0.039
Air Filter Regeneration WW (SCR -Tech)
0.048
0.070 — --
0.413
0.599
Total Average Daily Flow (I)
0.564
Notes:
(1) Total Average Daily Flow adjusted to account for loss in wastewater volume prior to discharge due to
evaporation.
Ask (2) Based on historical data (January 2008-August 2008), max monthly flow is 1.45 times greater than the
,401, average daily flow.
ANIL
AMA
Ask
Ink
Ask
oak
15
.01
Anlik

SECTION 3.0
EFFLUENT GUIDELINES AND STANDARDS
3.1 GENERAL
There have been changes in facility production and wastewater flows at the facility over the past
several years. These changes in wastewater sources, flows, and character affect the current
NPDES effluent limits. As discussed in Section 2.2.1, there are two (2) industrial categories of
wastewater to be considered: Centralized Waste Treatment (CWT) and Non -Categorical. The
US EPA has developed the Effluent Guidelines and Standards for both industrial categories. The
proposed limits for conventional and non -conventional parameters based on these guidelines are
presented in the following sections. Because Clariant is no longer an OCPSF facility, the tiered
effluent limits as contained by the current permit are no longer necessary.
3.2 CONVENTIONAL PARAMETERS
The US EPA Effluent Standards and Guidelines for conventional parameters for the two
industrial categories are summarized in Table 3-1 along with the previous allocations allowed
permitted by NCDENR for the specific non -categorical discharges. Ammonia -nitrogen (NH3-N)
is included in the current Clariant NPDES permit and is part of the staging requirements. The
EPA effluent guidelines do not include limitations for NH3-N. The 2004 Catawba River
Basinwide Water Quality Plan (Catawba Plan), prepared by NCDENR, indicates that no water
quality problems have been identified in the Catawba River at Monitoring Station No. 02142938
(near S. Belmont), downstream of the Clariant discharge. Continuation of the staging
requirements is not being requested for the renewed permit. Given that Total Nitrogen is already
limited in the permit at levels significantly lower than the existing ammonia -nitrogen limit,
Clariant requests that the ammonia limit be dropped from the new permit.
16

Albk
ink
r.d
..,
Ink
TABLE 3-1
US EPA EFFLUENT GUIDELINES AND STANDARDS
''
Industrial Category and Parameters
Monthly Avg.
Effluent Limit
(mg/L)
Max Day
Effluent Limit
(mg/L)
Non -categorical: Sanitary, Air Filter
Regeneration, Utilities, Process Stormwater
BOD5
30
45
TSS
30
45
Non -categorical: Non -Process Stormwater (1)
BOD5
1
1
TSS
30
45
Non -categorical: Filter Plant Backwash(1)
BOD5
0
0
TSS
30
45
Non -categorical: Utilities(1)
BOD5
0
0
TSS
0
0
Centralized Waste Treatment
BOD5
53
163
TSS
61.3
216
Notes:
imok (1) Based on previous allocations allowed by NCDENR for the Clariant facility.
Anik
01164
0114
•r►
17

•
ems
Oil and grease (O&G) is included in the current permit, but is requested by Clariant to be
4.4
removed since oily wastewater no longer is delivered to the centralized waste treatment
operation.
Proposed limits for conventional parameters were determined based on the past 12 months
(September 2008 — August 2009) of groundwater flow data, 2008 flow data for 3`d party
wastewaters and CWT process water, in conjunction with the EPA limitations. Due to the
general economic downturn during 2009, 2008 data is more indicative of normal trucked and
CWT process wastestream flows and has therefore been used for development of CWT effluent
limitations. A summary of the existing limits for the current permit and proposed limits for the
eft,
new permit are presented in Table 3-2. Breakdowns of the BOD5 and TSS allocations by
,1111 industrial category are presented in Table 3-3. The maximum monthly flow was used to
AMIN calculate the proposed limits. The maximum monthly flow was determined based on the
tees historical ratio of average daily flow to maximum monthly flow, as noted in Table 3-3.
Allts
Ants
Oats
OWN
4114
efitS
effi
tfites
OAS
AWN
Albs
At, 18
tot

Ilk
ak
TABLE 3-2
CURRENT AND PROPOSED LIMITS — CONVENTIONAL PARAMETERS
Parameter
ilak
Current Limits Tier 1
Proposed Limits
Monthly Avg.
Daily Max
Monthly Avg.
Daily Max
Flow
BOD5
TSS
NH3-N (2)
Total Nitrogen(3)
Total Phosphorus(3)
3.9 MGD
341 lb/d
362 lb/d
574.5 lb/d
318.5 lb/d
40.0 lb/d
none
913 lb/d
994 lb/d
861.8 lb/d
none
none
3.9 MGD
241 lb/d
315 lb/d
none
318.5 lb/d
40.0 lb/d
none
588 lb/d
8091b/d
none
none
none
..n Notes:
(1) Proposed limits based on max flow as shown in Table 2-2.
(2) NH3-N limits deleted based on lower Total Nitrogen limits.
Ask (3) Total Phosphorus and Total Nitrogen limits based on a 12-year rolling average beginning after 12
months of data collection under the 2003 permit.
Ilk
Ilk
Ilk
Illk
aft
•a►
Al k
Ilk
19
Ink

erats
rat,
est
TABLE 3-3
WASTE LOAD ALLOCATIONS — INCLUDES FUTURE FLOWS
CONVENTIONAL PARAMETERS BY INDUSTRIAL CATEGORY
BASED ON US EPA EFFLUENT GUIDELINES AND I ITATIQNS
�
la. Non -categorical, Max Monthly Flow = 0.384 M 1 ('' ' s.
Includes: Sanitary(0.010 MGD),Groundwater 0.305 anti Air Filter Regeneration(0.070 MGD)
g
Month Avg. . • Day (mg/L1 Month Avg. Max Day
(mg/L) (lb/d) (lb/d)
BOD5 30 45 96.1 144.2
TSS 30 45 96.1 144.2
ib. Non -categorical, Max Monthly Flow = 0.214 MGD (2)
Includes: Non -Process Stormwater
Month Avg. Max Day (mg/L) Month Avg. Max Day
(mg/L) (lb/d) flb/d)
BOD5 1 1.5 2.0 3.0
TSS 30 45 53.3 80.0
lc. Non -categorical, Max Monthly Flow = 0.001 MGD (2)
Includes: Filter Plant Backwash
Month Avg. Max Day (mg/L) Month Avg. Max Day
(mg/L) (lb/d) (lb/d)
BOD5 0 0 0 0
TSS 30 45 0.4 0.6
2. Centralized Waste Treatment, Max Monthly Flow = 0.325 MGD (2)
Includes: Current and All Future Flows (3rd Party Organic WW, WWTP Stormwater, Primary &
Biological Solids Processing, and Equipment & Unloading Area Wash Water).
Month Avg. Max Day (mg/L) Month Avg. Max Day
m L (lb/d) (lb/d)
BOD5 53 163 143.4 441.0
TSS 61.3 216 165.8 584.4
TOTAL ALLOCATIONS:
Month Avg. Max Day
(lb/d) (lb/d)
BOD5 241 588
TSS 316 809
Notes:
(1) Max monthly flow was calculated based on ratio of Max Monthly Flow to Average Daily Flow for
elk) January 2008 — August 2009. Ratio of max monthly flow to Average Daily Flow is 1.45.
eAte, (2) No BOD or TSS allocation for Utilities (0.0002 MGD steam generation).
20

AgIN
'ab` 3.3 NON -CONVENTIONAL PARAMETERS
The EPA guidelines also include non -conventional parameters for wastewater discharged from
oft,
OCPSF and CWT categorical operations. The current NPDES permit includes limits for OCPSF
and CWT non -conventional parameters. However, since Clariant has the terminated on -site
ANON organic chemical production and no longer accepts 3rd party oily wastewater, the current effluent
permit limits need to be modified to only include CWT organic waste parameters. A summary
of the current and proposed limits for non -conventional parameters is presented in Table 3-4.
The CWT organic wastewater parameters were calculated using the max monthly flow (see
esP` Table 3-4).
3.3.1 Copper and Zinc
As a result of current tenant operations and naturally occurring sources in groundwater
and surface water, copper and zinc may be present in the non -categorical wastewater
streams being treated by the Clariant WWTP, and as such, the non -categorical flows
should receive an allocation for both constituents. The CWT organic wastewater
eft, standards represent BAT treatment levels for copper and zinc in mixed stream
wastewaters such as the WW present at Clariant, and these standards should also be
`st, utilized for non-CWT waste streams. Furthermore, according to the Catawba River
Basinwide Assessment Report from December 2008, there have been zero water quality
exceedences for zinc or copper from 2003 to present at the station directly downstream of
the Clariant discharge (Station #: C3900000), which indicates that there is additional
assimilation capacity in the Catawba River. The monthly average limits, if determined
oak,by using the combined CWT and non -categorical wastewater flows, would be
,qb, approximately 30% lower for copper and 50% lower for zinc than the limits contained in
the current NPDES permit. Clariant requests that the combined CWT and non -
categorical wastewater flows be used for copper and zinc limits in the new permit.
tabs
en' 3.4 TOTAL NITROGEN AND TOTAL PHOSPHORUS
In October, 1999, a study was performed by AWARE Environmental Inc. (AEI) at the request of
Clariant and submitted to the NCDENR to evaluate the Best Available Technology
Economically Achievable (BAT) for control of total nitrogen (TN) and total phosphorus (TP) in
the effluent discharge. The results of the 1999 BAT study were used by NCDENR as the basis
21

for the annual average effluent limits of 444.1 lbs TN/day and 32.5 lbs TP/day included in the
2003 NPDES permit for Clariant.
At, In accordance with the 2003 NPDES Permit, a follow-up June 2004 BAT study was performed
AllaN by AEI and submitted to NCDENR for update of the BAT. The permit required that the study be
''al based on the first twelve (12) months of effluent monitoring data following issuance of the
eat' March 1, 2003 NPDES permit. The results of the June 2004 BAT Update Study indicate that the
rse,` revised BAT effluent limits for TN and TP should be annual average limits of 318.5 lbs TN/day
and 40 lbs TP/day. We are requesting that these limits remain unchanged in the new permit.
esit
3.5 RIVER STAGING REQUIREMENTS
The 2005 NPDES permit contains a provision which requires Clariant to reduce mass -loadings
of BOD5 and NH3-N during periods when the Catawaba River flow is less than 250 cfs due to
interruption of upstream Mountain Island hydroelectric dam operations. In light of the
significantly reduced BOD5 limits being requested by Clariant in the new NPDES permit upon
renewal, Clariant is requesting that the River Staging Requirements be removed in the new
NPDES permit.
tiBt
OIRS
441
astN
ellEN
eiltN
41k,
/fit

4116
eligN
elizs
egt
etur
TABLE 3-4
CWT LIMITS - NON -CONVENTIONAL PARAMETERS
WASTE LOAD ALLOCATIONS
Proposed Max Monthly Flow = 0.325 MGD
'
Effluent Characteristic
- Proposed I flits 0.325MGD •t
Month` Avg: _
, - Z- . Max Day= �.
k t
Copper (1)
5.37
6.14
Zinc (1)
2.99
3.53
Acetone
21.60
81.86
Acetophenone
0.15
0.31
2-Butanone
5.01
13.04
o-cresol
1.52
5.20
p-cresol
0.56
1.89
phenol
2.93
9.89
pyridine
0.49
1.00
2,4,6-trichlorophenol
0.29
0.42
Notes:
(1) Copper and zinc limits calculated using combined CWT and non -categorical wastewater
flows.
23

APPENDIX A
SEPTEMBER 2008 - AUGUST 2009 EFFLUENT DATA
CLARIANT WWTP

) ))))))))) ))))))) )))))) ))))))) ) )) ) ) )) )) ) ) ) )
Appendix A
Parameter
DMR Units
► Summary
12-month
Average
Max 30-day
Average
Max Day
Total No.
Analyses
Effluent Flow
MGD
0.44
0.54
0.70
363
Temperature
deg C
16.87
26.30
29.00
363
pH
SU
7.83
7.95
8.30
363
Min pH
SU
7.83
7.70
7.30
363
Fecal Coliform
#/100 ml
1115.67
6000.00
6000.00
- 12
12-month
Average
(mg/I)
12-month
Average
(1b/d)
Max 30-day
Average
(mg/I)
Max 30-day
Average
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
Total No.
Analyses
BOD
Ibs/d
17.29
62.93
39.95
135.82
65.00
264.50
351
Ammonia
lbs/d
1.50
5.58
1.66
6.80
1.96
9.20
351
TSS
Ibs/d
8.30
31.35
9.45
39.97
19.00
92.64
351
TN
mg/L
51.26
181.36
NA
NA
84.20
423.94
12
TP
mg/L
4.66
16.78
NA
NA
8.10
45.99
12
Total Phenols
Ibs/d
0.02
0.06
NA
NA
0.12
0.27
12
Total Sulfate
_
mg/1:
1602.85
5777.05
2310.00
8366.05
2310.00
11719.18
5
COD
mg/L
225.15
839.01
238.15
1013.65
289.00
1323.35
351
MBAS
mg/L
0.20
0.65
NA
NA
0.27
1.57
4
Manganese
mg/L j
2.12
6.05
NA
NA
2.55
10.96
4
Iron
mg/L
0.66 l
1.90
NA
NA
1.61
8.17
4
Chlorides
mg/L
184.50
587.08
NA
NA
235.00
2965.82
7
Mercury
ng/L
3.62
NA
24.50
12
Mercury
Ibs/d
0.01
NA
0.13
12
Nitrate-N
mg/L
7.92
30.05
NA
NA
38.20
195.17
12
Nitrite-N
mg/L
0.00
0.00
NA
NA
0.01
0.04
12
NO2+NO3 - N
mg/L
7.92
30.05
NA
NA
38.20
195.17
12
TKN
mg/L
43.34
151.31
NA
NA
82.30
2965.82
8
Total Zinc
mg/L
0.15
0.51
0.44
1.56
0.44
1.91
12

)))))))))))))))))))))))))))))))))) ) ))) )) ) )
Appendix A
Parameter
DMR
Units
Sep-08
Oct-08
Nov-08
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Effluent Flow
MGD
0.54
0.68
30
0.41
0.56
31
0.45
0.62
30
Temperature
deg C
22.60
26.00
30
16.47
22.00
31
10.17
17.00
30
pH
SU
7.85
8.10
30
7.89
8.10
31
7.89
8.10
30
Min pH
SU
7.85
7.60
30
7.89
7.80
31
7.89
7.70
30
Fecal Coliform
4/100 ml
430.00
430.00
1
100.00
100.00
1
21.00
21.00
1
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
BOD
Ibs/d
8.90
40.78
19.00
86.04
29.00
10.50
38
30.00
101.23
30.00
15.61
60.75
30.00
134.86
28.00
Ammonia
Ibs/d
1.45
6.63
1.77
9.20
29
1.55
6
1.82
7.53
30
1.66
6.31
1.96
9.10
28
TSS
Ibs/d
8.14
37.69
11.00
56.80
29
8.50
31
11.00
48.76
30
8.67
33.02
14.00
57.25
28
TN
mglL
38.50
161.73
38.50
202.97
1
66.80
231
66.80
312.04
1
46.90
199.17
46.90
273.31
1
TP
mg/L
4.00
16.80
4.00
21.09
1
8.10
28
8.10
37.84
1
6.50
27.60
6.50
37.88
1
Total Phenols
Ibs/d
0.02
0.07
0.02
0.08
1
0.01
0
0.01
0.05
1
0.01
0.05
0.01
0.06
1
Total Sulfate
mg/L
0
0
1970.00
8366.05
1970.00
11480.23
1
COD
mg/L
215.00
983.55
248.00
1289.61
29
228.09
815
248.00
1109.65
30
234.78
901.49
271.00
1298.72
28
MBAS
mg/L
0
0
0.27
1.15
0.27
1.57
1
Manganese
mg/L
0
0
1.39
5.90
1.39
8.10
1
Iron
mg/L
0
0
0.14
0.59
0.14
0.80
1
Chlorides
mglL
0
0
235.00
997.98
235.00
11.12
1
Mercury
ng/L
24.50
24.50
1
5.19
5.19
1
1.25
1.25
1
Mercury
Ibs/d
0.1029
0.1292
1
0
0.0242
1
0.0053
0.0073
1
Nitrate-N
mg/L
13.90
58.39
13.90
73.28
1
3.20
11
3.20
14.95
1
0.10
0.42
0.10
0.58
1
Nitrite-N
mg/L
0.00
0.00
0.00
0.00
1
0.00
0
0.00
0.00
1
0.00
0.00
0.00
0.00
1
NO2+NO3 - N
mg/L
13.90
58.39
13.90
73.28
1
3.20
11
3.20
14.95
1
0.10
0.42
0.10
0.58
1
TKN
mg/L
24.60
103.34
24.60
0.00
0
63.60
220
63.60
14.85
1
46.80
198.75
46.80
11.12
1
Total Zinc
mg/L
0.09
0.40
0.09
0.50
1
0.05
0
0.05
0.21
1
0.22
0.94
0.22
1.29
1

) ) ) ))) ) ) ) ) ) )) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
Appendix A
Parameter
DMR
Units
Dec-08
Jan-09
Feb-09
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Effluent Flow
MGD
0.40
0.60
31
0.30
0.57
30
0.39
0.70
28
Temperature
deg C
9.37
15.00
31
6.67
13.00
30
8.37
12.00
28
pH
SU
7.83
8.00
31
7.95
8.30
30
7.88
8.10
28
Min pH
SU
7.83
7.60
31
7.95
7.70
30
7.88
7.50
28
Fecal Coliform
#/100 ml
5.00
5.00
1
245.00
245.00
1
540.00
540.00
1
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/i)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
BOD
Ibs/d
20.70
71.48
35.00
140.19
28.00
22.81
57.80
38.00
124.70
29.00
39.95
135.82
65.00
264.50
30.00
Ammonia
Ibs/d
1.50
5.38
1.74
8.14
28
1.49
3.87
1.88
8.30
29
1.50
4.97
1.74
7.73
30
TSS
Ibs/d
9.25
34.72
17.00
85.18
28
7.95
20.90
12.00
49.88
29
9.14
30.06
13.00
53.31
30
TN
mg/1.
63.00
212.69
63.00
321.88
1
26.30
121.87
26.30
234.84
1
51.90
65.75
51.90
118.92
1
TP
mg/L
7.00
23.63
7.00
35.76
1
0.95
4.40
0.95
8.48
1
5.10
6.46
5.10
11.69
1
Total Phenols
ibs/d
0.01
0.04
0.01
0.06
1
0.01
0.06
0.01
0.11
1
0.12
0.15
0.12
0.27
1
Total Sulfate
mg/L
0
0
1.38
1.75
1.38
3.16
1
COD
mg/L
215.78
797.79
250.00
1169.69
28
238.15
601.16
285.00
1257.86
29
232.00
770.39
276.00
1226.19
30
MBAS
mg/L
0
0
0.11
0.14
0.11
0.25
1
Manganese
mg/L
0
0
2.55
3.23
2.55
5.84
1
Iron
mg/L
0
0
0.59
0.75
0.59
1.35
1
Chlorides
mg/L
0
0
155.00
196.36
155.00
0.03
1
Mercury
nglL
1.35
1.35
1
2.27
2.27
1
2.01
2.01
1
Mercury
Ibs/d
0.0046
0.0069
1
0.01
0.0203
1
0.0025
0.0046
1
Nitrate-N
mg/L
38.20
128.96
38.20
195.17
1
7.90
36.61
7.90
70.54
1
1.50
1.90
1.50
3.44
1
Nitrite-N
mg/L
0.00
0.00
0.00
0.00
1
0.00
0.00
0.00
0.00
1
0.00
0.00
0.00
0.00
1
NO2+NO3 - N
mg/L
38.20
128.96
38.20
195.17
1
7.90
36.61
7.90
70.54
1
1.50
1.90
1.50
3.44
1
TKN
mg/L
24.80
83.73
24.80
0.00
0
18.40
85.26
18.40
0.00
0
50.40
63.85
50.40
0.03
1
Total Zinc
mg/L
0.133
0.449012
0.13
0.68
1
0.11
0.4865389
0.11
0.94
1
0.27
0.3395147
0.27
0.61
1

) j) j i)))) ) ) ) )) ) ) ) ) ) )) )))) )) ) ) ) ) ) ) ) ) ) ) ) )
w
Appendix A
Parameter
DMR
Units
Mar-09
Apr-09
May-09
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Effluent Flow
MGD
0.53
0.70
31
0.53
0.65
30
0.52
0.64
30
Temperature
deg C
12.30
17.00
31
16.87
22.00
30
21.70
25.00
30
pH
SU
7.72
7.90
31
7.74
8.10
30
7.70
7.90
30
Min pH
SU
7.72
7.50
31
7.74
7.30
30
7.70
7.50
30
Fecal Coliform
4/100 ml
21.00
21.00
1
17.00
17.00
1
4.00
4.00
1
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
I Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
BOD
Ibs/d
27.71
117.96
45.00
235.02
30.00
11.48
51.99
23.00
116.88
29.00
14.65
62.07
32.00
156.79
29.00
Ammonia
Ibs/d
1.46
6.35
1.68
8.46
30
1.55
6.80
1.85
8.89
29
1.50
6.26
1.71
8.16
29
TSS
Ibs/d
8.57
37.86
15.00
72.08
30
8.05
35.57
11.00
47.75
29
9.45
39.97
19.00
92.64
29
TN
mg/L
36.20
177.67
36.20
237.85
1
66.20
236.47
66.20
290.19
1
40.26
134.78
40.26
164.30
1
TP
mg/L
7.00
34.36
7.00
45.99
1
3.80
13.57
3.80
16.66
1
4.45
14.90
4.45
18.16
1
Total Phenols
Ibs/d
0.02
0.08
0.02
0.11
1
0.02
0.05
0.02
0.07
1
0.01
0.05
0.01
0.06
1
Total Sulfate
mg/L
0
0
2130.00
7130.55
2130.00
8692.65
1
COD
mg/L
217.76
944.29
289.00
1284.63
30
229.67
1013.65
262.00
1323.35
29
237.40
995.47
267.00
1273.50
29
MBAS
mg/L
0
0
0.21
0.70
0.21
0.86
1
Manganese
mg/L
0
0
2.37
7.93
2.37
9.67
1
Iron
mg/L
0
0
0.29
0.98
0.29
1.20
1
Chlorides
mg/L
0.00
0.01
1
0.00
0.00
0
142.00
475.37
142.00
302.33
1
Mercury
ng1L
1.85
1.85
1
0.85
0.85
1
1.10 _
1.10
1
Mercury
Ibs/d
0.0091
0.0122
1
0.0030
0.0037
1
0.0037
1
Nitrate-N
mg/L
7.00
34.36
7.00
45.99
1
3.50
12.50
3.50
15.34
1
0.85
2.85
0.85
3.47
1
Nitrite-N
mg/L
0.00
0.00
0.00
0.00
1
0.00
0.00
0.00
0.00
1
0.01
0.03
0.01
0.04
1
NO2+NO3 - N
mg/L
7.00
34.36
7.00
45.99
1
3.50
12.50
3.50
15.34
1
0.86
2.88
0.86
3.51
1
TKN
mg/L
29.20
143.32
29.20
0.01
1
62.70
223.97
62.70
0.00
0
39.40
131.90
39.40
302.33
1
Total Zinc
mg/L
0.14
0.6675002
0.136
0.893594
1.00
0.44
1.56
0.44
1.9112389
1
0.05
0.16
0.05
0.2007881
1
•
•

)) ) ))) )) ) )))))) ) ))) ) ) )) )) ))))))) ) ) ) ) ) ) )) ) ) )
Appendix A
Parameter
DMR
Units
Jun-09
Jul-09
Aug-09
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Month
Avg.
Max Day
No.
Analyses
Effluent Flow
MGD
0.43
0.61
30
0.38
0.58
31
0.36
0.56
31
Temperature
deg C
25.90
27.00
30
25.77
28.00
31
26.30
29.00
31
pH
SU
7.72
8.04
30
7.87
8.10
31
7.86
8.10
31
Min pH
SU
7.72
7.50
30
7.87
7.60
31
7.86
7.70
31
Fecal Coliform
8/100 ml
5.00
5.00
1
6000.00
6000.00
1
6000.00
6000.00
1
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
Month
Avg.
(mg/I)
Month
Avg.
(Ib/d)
Max Day
(mg/I)
Max Day
(Ib/d)
No.
Analyses
BOD
Ibs/d
12.09
44.46
19.00
67.90
30.00
13.38
44.97
21.00
71.32
29.00
9.65
29.44
18.00
63.93
30
Ammonia
Ibs/d
1.41
5.29
1.57
7.14
30
1.46
5.07
1.65
7.18
29
1.48
4.47
1.71
6.37
30
TSS
Ibs/d
7.95
30.21
10.00
46.25
30
7.48
25.86
17.00
59.07
29
6.50
19.79
9.00
34.09
30
TN
mglL
56.70
227.64
56.70
321.84
1
84.20
281.59
84.20
423.94
1
38.20
125.84
38.20
193.80
1
TP
mglL
2.60
10.44
2.60
14.76
1
2.70
9.03
2.70
13.59
1
3.70
12.19
3.70
18.77
1
Total Phenols
Ibs/d
0.02
0.07
0.02
0.10
1
0.02
0.07
0.02
0.11
1
0.01
0.03
0.01
0.05
1
Total Sulfate
mg/L
0.00
350.62
1
0
2310.00
7609.83
2310.00
11719.18
1
COD
mg/L
201.64
762.73
239.00
1105.46
30
224.76
789.39
271.00
1204.79
29
226.75
693.40
257.00
1008.95
30
MBAS
mg/L
0
0
0.19
0.63
0.19
0.96
1
Manganese
mg/L
0
0
2.16
7.12
2.16
10.96
1
Iron
mg/L
0
0
1.61
5.30
1.61
8.17
1
Chlorides
mg/L
0.00
350.62
1
0.00
2965.82
1
206.00
678.63
206.00
385.00
1
Mercury
ng/L
0.76
0.76
1
1.39
1.39
1
0.94
0.94
1
Mercury
Ibs/d
0.0030
0.0045
1
0.0028
0.0043
1
0.0031
0.0042
1
Nitrate-N
mg/L
15.50
62.23
15.50
87.98
1
1.90
6.35
1.90
9.57
1
1.50
4.94
1.50
7.61
1
Nitrite-N
mg/L
0.00
0.00
0.00
0.00
1
0.00
0.00
0.00
0.00
1
0.00
0.00
0.00
0.00
1
NO2+NO3 - N
mg/L
15.50
62.23
15.50
87.98
1
1.90
6.35
1.90
9.57
1
1.50
4.94
1.50
7.61
1
TKN
mg/L
41.20
165.41
41.20
350.62
1
82.30
275.24
82.30
2965.82
1
36.70
120.90
36.70
385.00
1
Total Zinc
mg/L
0.04
0.16
0.04
0.2196677
1
0.191
0.64
0.19
0.96
1
0.039
0.13
0.04
0.20
1
•

APPENDIX C
CWT STORMWATER DISCHARGES DRAINED TO WWTP —
BASIS FOR CATEGORY
A portion of the stormwater from the Clariant property is treated with process wastewater in the
on -site WWTP. The total stormwater area drained to the WWTP is 3,794,076 ft2. The average
precipitation in Charlotte, NC as provided by NOAA is 43.09 inches/yr. This is equivalent to
approximately 0.118 inches/day. Based on the average annual rainfall, the various areas of
drainage and the degree of imperviousness in each area, the average daily stormwater runoff was
calculated to be 195,414 gpd. Of the total stormwater runoff, 168,885 gallons is considered to be
CWT and 26,529 gallons is considered to be non -categorical. Stormwater drainage areas and
associated runoff are summarized in Table C-1. Stormwater drainage areas are shown on the
stormwater site plan included with the permit application.
The CWT stormwater sources include the following:
• Effluent Holding Basin
• Landfill Ce11 3
• Production Buildings Area
• Former Dinitrophenol Production Area
• WWTP Area
These sources are discussed below.
Effluent Holding Basin
The effluent holding basin is typically not used during the summer when the WWTP is operating
most effectively. The basin captures precipitation and some stormwater which comes into
contact with the basin walls, process wastewater sludges and settled material contained in the
basin, which is then treated in the WWTP.
Landfill Cell 3
All stormwater that falls on the landfill is collected as leachate and treated in the WWTP. The
landfill is designed so that none of the stormwater runs off and none of the stormwater infiltrates
the groundwater.
Production Building Area
This area comprises the chemical and dye manufacturing production area.
Former Dinitrophenol Production Area
Dinitrophenol (DNP) was formerly produced in an area near the Production Building Area. The
DNP production facility was shut -down and demolished and replaced with lawn. However, the
soil in this location is visibly contaminated with DNP which leaches to the surface of the ground
from subsurface sources. All stormwater drainage from this area is considered to be
contaminated with dinitrophenol.
WWTP Area
The area of the WWTP captures precipitation and stormwater from the immediate surrounding
impervious area, which combines with the process wastewater and is treated in the WWTP.

))) )) )) 1 ) *))))))) ))) :)) ))) )) ) )) )) )
TABLE C-1
SUMMARY OF STORMWATER DRAINAGE TO WWTP
Clariant Corporation - Mt. Holly East Plant
NPDES Permit No. NC0004375
Category
Stormwater Drainage Area
Description
Surface Area
Impervious
Area
Pervious Area
Stormwater
Runoff
(91301)
Stormwater
Infiltration
(gpd)(1
acres
ft2
%
Run-off
Coefficient
(C)
%
Run-off
Coefficient
(C)
Non-
Wastewater Impoundment (Eff. Holding
32.0
1,393,920
35%
1.00
65(3/0
0.35
49,213
53,314
Categorical
Basin)
Production Buildings Area
21.0
914,760
100%
0.90
0%
60,555
6,728
All other areas that drain to WWTP
18.0
784,080
20%
0.90
80%
0.35
26,529
31,143
Total Non-Catagorical =
71.0
3,092,760
146,294
81,189
CWT
WWTP Area
9.9
431,244
100%
0.90
0%
.
28,547
3,172
Landfill Cell 3
4.1
178,596
100%
1.00
0%
13,136
Total CWT=
14.0
609,840
41,684
3,172
Total Stormwater Drainage =
85.0
3,702,600
187,978
84,360
Notes:
(1) Stormwater flow is based on NOAA Average Charlotte, NC rainfall of 43.09" per year.
Average daily rainfall based on 365 days is 0.118".

2008 — 2009 Monthly Summary
3r`I Party Wastewater Treatment (Organic -Bearing Wastewater)
Month
No. of Loads
Total Gallons
January 2008
233
1,099,516
February 2008
195
873,019
March 2008
222
1,034,293
April 2008
196
915,937
May 2008
187
874,346
June 2008
204
947,867
July 2008
214
1,010,524
August 2008
262
1,273,487
September 2008
215
1,048,533
October 2008
234
1,087,838
November 2008
143
649,806
December 2008
159
736,479
January 2009
146
649,625
February 2009
131
568,305
March 2009
163
779,759
April 2009
200
944,060
May 2009
173
777,873
Total
2,849
13,298,731
Month Avg. (Jun. 08-
May 09)
187
872,846
Month Avg. (Jan. 08-
Dec 08)
204
957,911

1144411
1' / CIAO �al W/ v' ` CorOg l /' I f !� r WI C K-h e t C.1,4 444 A/.4r4T—t 6,1109 / t�l h a ►?,
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Relnick, Tom
•
From:
Sent:
To:
Subject:
Attachments:
Tom,
Michael Wicker [MWicker© ithersravenel.com
Monday, November 30, 200 '57 AM
Belnick, Tom
RE: Clariant- NC0004375
NPDES Permit.pdf
e,,ttpot ww7►'_
yuutiewvvi ciam;.4.1-
This is the permit I would like to discuss with you to see if there might be any proposed changes that you foresee when
they come in for renewal based on CWT or OCPSF requirements or Basin wide requirements that have occurred in the
last permit cycle.
From: Belnick, Tom [mailto:[e-mail]]
Sent: Monda . vep•• . 3, 2009 1:57 PM
To: Mich. icker
Cc: Po .art, Jeff
Subj ct: Clariant- NC0004375
Micha
beginnin
further.
I- I saw your email r
mt
•
rding Clariant. I'd like to get some more clarification from you. I'll be out of the office
back next Monday. If you could call me next week at 919-807-6390, I'd be glad to discuss
Tom Belnick
Supervisor, NPDES West Program
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
r-11(u�M�C
E-mail correspondence to and frgr ' his address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties. / CO - Lo ^ s`L)
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Department of Environment and Natural Resources
Division of Water Quality
Fact Sheet For NPDES Permit NC0004375
444111W
Facility Information
Applicant/Facility Name:
Clariant Corporation — Mt. Holly
Applicant Address:
P.O. Box 669246, Charlotte, NC 28266
Facility Address:
11701 Mount Holly Rd., Charlotte, NC28214
Permitted Flow:
3.9 MGD (Grade IV — Biological)
Type of Waste:
Industrial, Stormwater, and Sanitary Wastewater
Facility/Permit Status:
Renewal
County:
Mecklenburg County
Miscellaneous
Receiving Stream:
Catawba River
Stream Classification:
WS-IV-CA
303(d) Listed?:
No
Subbasin:
03-08-34
Drainage Area (mi2):
calculated
40.8 mi2
Summer 7Q10 (cfs):
329 cfs
Winter 7Q10 (cfs):
NA
Average Flow (cfs):
3,016 cfs
IWC (%):
1.8 %
Primary SIC Code:
2865
Regional Office: .
Mooresville
USGS Topo Quad:
Mountain Island Lake & Mount Holly
Permit Writer:
Sergei Chernikov
Date:
May 10, 2010
Summary
Clariant operated a specialty chemical manufacturing facility in Mount Holly from 1936 until 2005
when it ceased all organic chemical manufacturing and processing. The facility also treated OCPSF
and CWT (centralized waste treatment) wastes from customers located off -site. Wastewater from
the facility is treated in an on -site WWTP. The existing permit is based on the OCPSF and CWT
effluent guidelines. The proposed permit will be based on the CWT guidelines only since all the
OCPSF manufacturing has been discontinued. The facility also discontinued treatment of oily
water in 2005.
The facility has been a specialty chemical and dye -manufacturing site since 1937. As a result of
historical operations, the facility is included on the National Priorities List due to organic contained
in surface water and groundwater from the site. Stormwater from the facility is therefore treated in
the on -site WWTP in addition to the OCPSF process wastewater, CWT process wastewater, and
domestic wastewater from current on -site manufacturing operations. The WWTP also receives
groundwater from a groundwater pump and treat system and leachate from an active on -site landfill
Fact Sheet
NPDES Renewal (NC0082295)
Page 1

cell. As portions of the facility become inactive, Clariant is developing the facility as an industrial
park. The following two tenant operations are currently located at the facility with the treatment of
the resulting process wastewaters in the on -site WWTP:
• SCR -Tech — A non -categorical operation that regenerates NOx air pollution control catalyst
• Monark Industrial Services, Inc. — A non -categorical operation that solidifies liquid and
semi -solid wastes.
Since Clariant is developing the facility as an industrial park, future wastewater sources will occur.
In the past, in order to account for these future wastewater sources in the permit effluent limits, a
tiered approach to developing the limits was used. The proposed limits for both conventional and
non -conventional parameters were presented in two tiers, Tier 1, and Tier 2. The Tier 1 limits were
based on wastewater flow from existing and planned wastewater sources. The Tier 2 limits were
based on wastewater flow not only from existing and planned wastewater sources, but also from
future wastewater sources. The facility is in transition period and is on rack to be sold. Therefore,
expansion is not planned and Tier 2 will be eliminated from the proposed permit.
Facility has no fecal coliform limit due to the very minor contribution of sanitary wastewater flow.
Technology Based Effluent Limit Development
Conventional parameters have been calculated based on the guidelines specified in the Table 3-1
(attached). Flow numbers for calculation were taken from the Table 2-2 (attached). The following
effluent guidelines were used to calculate permit limits:
• CWT parameters — 40 CFR part 437 (subpart B) (flow=0.325 MGD)
The results of these calculations are generally more stringent than the limits in the current permit.
All the calculations are attached.
Limits for Total Nitrogen and Total Phosphorus have been established based on the results
of the BAT study. Monthly average limit for NH3-N was established as the 95th percentile
effluent load, daily maximum limit was calculated using 1.5 multiplier.
Toxicity Testing
Current Requirement: Quarterly Chronic Toxicity @ 1.8% MAR, JUN, SEP, DEC
Recommended Requirement: Quarterly Chronic Toxicity ® 1.8% MAR, JUN, SEP, DEC
The facility has been consistently passing its WET tests during previous permit cycle.
Compliance Summary
DMRs have been reviewed for the period from January 2006 through April 2010. Facility has a
good compliance record. During the review period, no NOVs (notices of violation) have been
issued. A compliance evaluation inspection conducted on June 4, 2008 determined that facility is
in compliance.
Reasonable Potential Analyses (RPA)
RPA were conducted for As, Ba, Cd, Cr, Cu, CN, Sb, Pb, Hg, Mo, Ni, Phenols, Se, Ag, Zn (please
see attached). A separate RPA for acute standards for CN and Ni was also calculated (please see
attached). The "acute" RPA was based on 1Q10 dilution, which is based on EPA guidance.
Fact Sheet
NPDES Renewal (NC0082295)
Page 2

Instream Monitoring
Instream monitoring is required DO, pH, temperature and conductivity. Facility has a very small
influence on the water quality due to the high dilution ratio.
Proposed Changes
Monitoring Frequencies: Monitoring for Oil and Grease were reduced from weekly to
monthly due to the removal of the limit.
Limits:
• Limits for CWT and conventional parameters have been recalculated based on the
reevaluation of projected flows.
• The OCPSF parameters have been eliminated from the permit due to discontinued
manufacturing of specialized chemicals in 2005.
• Limits for Arsenic, Antimony, and Mercury have been added to the permit based on
the results of the reasonable potential analyses.
• Limit for Oil and Grease was eliminated from the permit since the facility no longer
accepts oily water for treatment.
Tiers: Tier 2 has been eliminated at the request of the permittee.
State Contact
If you have any questions on any of the above information or on the attached permit, please contact
Sergei Chernikov at [phone].
REGIONAL OFFICE COMMENTS:
NAME: DATE:
Fact Sheet
NPDES Renewal (NC0082295)
Page 3