NC0047384_Pretreatment_CROMERR_Application_20240304

r
City of Greensboro
64�,J North Carolina
March 4, 2024
Mr. Michael Montebello, Branch Chief
NC DEQ DWR NPDES Permitting
1617 Mail Service Center
Ralegih, NC 27699-1617
Mr. Montebello,
Water Resources Department
EMAIL TRANSMITTAL [[e-mail]]
The City of Greensboro Industrial Waste Section is requesting an Industrial Pretreatment Program modification
authorizing the City to received reports electronically for its Industrial Waste Pretreatment Program. We will be
using SwiftComply's pretreatment software as a CROMMER COTS solution that meets technical CROMERR
requirements predominantly through use of the EPA's Shared CROMERR Services.
As prescribed by the EPA guidance for POTW Pretreatment Program CROMERR applications, the CROMERR
Checklist has been completed and the EPA Office of Environmental Information CROMERR team has been
copied. They should provide feedback over the content and completeness of the package.
In preparing the application materials, other programs' approaches were reviewed and their models for
CROMERR approval were followed for the City's Industrial Waste Pretreatment Program. Included for your
review are the following attachments:
• CROMERR System Checklist — GreensboroNC
• CROMERR Application
o CROMERR Application Cover Sheet
a Legal Authority
o Electronic Signature Agreement (ESA)
o Registration Process Workflow
o Signature Submission Process Workflow
o System Overview
a Screen Images
o Confirmation Receipt
If you have any questions or need any additional information to approve this request, please contact the
undersigned.
Sinc rely,
Amy Va oski
Pretreatment Coordinator
[phone]
[e-mail]
Alicia Goots
Superintendent of Laboratory & Pretreatment Services
[phone]
[e-mail]
cc: EPA Office of Environmental Information [[e-mail]]
PO Box 3136 Greensboro, NC 27402-3136 > www.greensboro-nc.gov 336-373-CITY (2489) , TTY # 333-6930
640

CROMERR Application Cover Sheet
Agency type: M Local Government Agency — Publicly Owned Treatment Works
Please do not use arrnnvms when rmmnlefina this fnrm
Primary Application Contact
First Name:
Last Name:
Position:
Agency:
Amy
Varinoski
Utilities Pretreatment
Coordinator
City of Greensboro Water
Resources
Mailing Address:
E-mail:
Primary Work Phone:
City of Greensboro Water Resources
2350 Huffine Mill Road
McLeansville, NC 27301
amy.varinoski(a�greensboro
336-580-8247
-nc.gov
Fax:
Secondary Work Phone:
336-433-7227
Secondary Application Contact
First Name:
Last Name:
Position:
Agency:
Alicia
Goots
Superintendent of
Laboratory and
Pretreatment Services
City of Greensboro Water
Resources
Mailing Address:
E-mail:
Primary Work Phone:
City of Greensboro Water Resources
2350 Huffine Mill Road
McLeansville, NC 27301
alicia.goots(a)greensboro-
336-373-3284
nc.gov
Fax:
Secondary Work Phone:
May we share any components of your application for instructive/informative purposes?
❑ Yes ❑ Yes, with limitations M No
If you selected `yes, with limitations EPA will contact you to discuss those limitations
This application includes (Check all that apply):
M CROMERR System Checklist (02-CROMERR System Checklist— GreensboroNC)
❑ No system checklist, but description of how this system complies with relevant CROMERR requirements
❑ Schedule of planned upgrades or changes to this system
M Other attachments (Please list here or in a separate document):
• 03-Attachment 1 Legal Authority
• 04-Attachment 2 Electronic Signature Agreement (ESA)
• 05-Attachment 3 Registration Process Workflow
• 06-Attachment 4 Signature Submission Process Workflow
• 07-Attachment 5 System Overview
• 08-Attachment 6 Screen Images
• 09-Attachment 7 Confirmation Receipt
01-CROMERR Application Cover Sheet GreensboroNC 1 of 3 Updated: 9/1/2023

For states, tribes and local governments (must select one of the following):8
® Signed legal certification is attached er ferthGGMiRg by moil
❑ Approved CROMERR legal certification already on file with EPA
Brief overview of system
System name: SwiftComply Pretreatment IU Portal
City of Greensboro Water Resources (Greensboro) manages the industrial pretreatment program and is implementing
SwiftComply's Pretreatment Compliance Solution which includes an IU Portal providing ability for permitted industrial
users to sign and electronically submit self -monitoring reports permit applications and other program related
communications.
CROMMER approval is required for Greensboro's program in order to fully implement the SwiftComply IU portal portion
of the solution.
The system will connect to Shared CROMERR Services developer APIs to provide all technical CROMERR
requirements though using existing Shared CROMERR Services technology including authentication, user management,
signature and Copy of Record (COR) and messaging.
All systems (check all that apply):
® Collects CROMERR priority report(s)
® Collects report(s) requiring signature
® Uses an electronic signature
EPA -authorized program systems only (check all that apply):
® Uses an off -the -shelf product*
® Uses all Shared CROMERR Services ❑ with minor customizations or ® with no customizations*
❑ Uses some Shared CROMERR Services
*Note: SwiftComply is a new off -the -shelf product and uses Shared CROMERR Services for Messaging,
Authentication, Signature and COR and User Management. Identity Proofing will be performed manually using the
attached ESA and will mirror our existing (physical) process to obtaining official facility signatories.
EPA systems only (check all that apply):
❑ Uses only out -of -the -box CDX CROMERR components ❑ with minor customizations or ❑ with no
customizations
❑ Uses significantly customized CDX CROMERR functionality
Number of systems addressed in this application: 1 We do not recommend more than one system per application unless
those systems work together to provide a complete CROMERR solution
01-CROMERR Application Cover Sheet GreensboroNC 2 of 3 Updated: 9/1/2023

For States, Tribes and Local Governments Only
This application requests modification/revision of the following authorized program(s) under 40 CFR: Detailed regulatory
report lists are not required Requesting CROMERR approval for reporting does not obligate a program or agency to collect
electronically under that program.
If the system's initial reporting may be expanded, we recommend selecting all possible authorized programs from the list below.
Unless otherwise requested, applicants are approved for all possible reporting under an authorized program.
Air
❑ 52: Approval and Promulgation of Implementation Plans (SIP/Clean Air Act Title II) Reporting under CFR 50-52
❑ 60: Standards of Performance for New Stationary Sources (NSPS/CAR/Clean Air Act Title III) Reporting under CFR 60 & 65
❑ 62: Approval and Promulgation of State Plans for Designated Facilities and Pollutants (NSPS/Clean Air Act Title III -
Hospital/Medical) Reporting under CFR 62
❑ 63: National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAP MACT/Clean Air Act Title III)
Reporting under CFR 61, 63 & 65
❑ 70: State Operating Permit Programs (Clean Air Act Title V) Reporting under CFR 64 & 70
❑ 71: Federal Operating Permit Programs (Clean Air Act Title V) Reporting under CFR 64 & 71
Water
❑ 123: EPA -Administered Permit Programs: the National Pollutant Discharge Elimination System (NPDES) Reporting under CFR
122 & 125
❑ 142: National Primary Drinking Water Regulations Implementation (NPDWR) Reporting under CFR 141
❑ 145: State Underground Injection Control Programs (UIC) Reporting under CRF 144 & 146
❑ 233: "404" State Program Regulations (Ocean Dumping) Reporting under CFR 233
® 403: General Pretreatment Regulations for Existing and New Sources of Pollution Reporting under CFR 403-471
❑ 501: State Sludge Management Program Regulations Reporting under CFR 501 & 503
Waste
❑ 239: Requirements for State Permit Program Determination of Adequacy (RCRA Subtitle C) Reporting under CFR 240-259
❑ 271: Requirements for Authorization of State Hazardous Waste Programs (RCRA Subtitle C) Reporting under CFR 260-270,
272-279
❑ 281: Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST)
Reporting under CFR 280
Chemicals
❑ 745: Lead -based Paint Poisoning Prevention in Certain Residential Structures (FLPP/RRP) Reporting under CFR 745
❑ 763: Asbestos Reporting under CFR 763
Special Cases
❑ 65: Consolidated Federal Air Rule (CAR/Clean Air Act Title III) Reporting under CFR 65
❑ 69: Special Exemptions from Requirements of the Clean Air Act (Clean Air Act Title V) Reporting under CFR 70
❑ 132: Great Lakes Water Quality Standards (WQS) Reporting under CFR 130-132
❑ 162: State Registration of Pesticide Products Reporting under CFR 162-169
❑ Emergency Planning and Community Right -to -Know Act (SARA Title III/CRTK) Reporting under EPCRA Sections 302-304,
311-313
❑ Other:
01-CROMERR Application Cover Sheet GreensboroNC 3 of 3 Updated: 9/1/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Item
SwiftComply Pretreatment IU Portal for City of Greensboro, NC Water Resources using
Shared CROMERR Services development APIs for some functionality
CROMERR System Checklist
Registration (e-signature cases only)
1. Identity -proofing of registrant
Business Practices:
City of Greensboro, NC Water Resources (Greensboro) requires all registrants to complete an
electronic signature agreement (ESA) as part of the account creation process. Only signatories will
be able to sign and submit reports, there will be no other CROMERR related user levels. The
registrant requests an account verbally or is notified by Greensboro as part of their Permit
Application or during a physical Site Inspection. The registrant will sign the ESA, witnessed by a
facility (industry) officer and be validated by Greensboro Staff by confirming signature against a
State ID card, driver's license or US Passport. The registrant may fill out the paperwork at
Greensboro's utility office or during a physical site inspection, the wet -ink signature ESA will be
hand delivered. If the account is satisfactory, the registrant will then be provided access to
complete CROMERR registration, linking to the Shared CROMERR Services (SCS) User
Management through the SwiftComply Pretreatment IU Portal. The registrant will already have a
SwiftComply IU portal account which is administered by Greensboro. This local application user
(LAU), the SwiftComply software user, is apart from the CROMERR Registration and subsequent
credentials required for the signatory. The signatory will connect to SCS User Registration through
their SwiftComply LAU. The account setup process (password, challenge questions, and contact
information) relies on SCS APIs. Once the CROMERR credentials are set up and approved by
Greensboro, a signatory user will have access to features that allow signing, report submission and
repudiation.
1. A "Subscriber Agreement" and physical validation process.
Greensboro will expand its existing practice of managing valid industrial user (facility)
signatories for physical paper submission to help satisfy identity -proofing of registrants for
use with the SwiftComply Pretreatment IU Portal. Prior to being provided an option for
online signatory registration within the system, the user must physically register as a
signatory, the user is required to provide a handwritten, wet -ink signature on a paper -based
Electronic Signature Agreement (ESA) to designated Greensboro staff to be able to certify
and submit any application in the SwiftComply IU Portal. This registration must be
presented in person and validated by Greensboro either at Greensboro or at the SIU's
facility while being inspected by Greensboro. The Subscriber Agreement must be
witnessed and signed by an officer of the facility or be accompanied by a letter certifying
that the applicant is a valid employee or legal representative of the facility. A physical copy
of the witnessed ESA and any accompanying certification of employment will be
maintained on file by Greensboro. During periodic inspections, minimally one per year,
Greensboro staff will confirm the continued status of the authorized facility representative
who signed the ESA. Should the signatory reside out of town and cannot be physically
present, a notarized witness to the signature shall be required.
2. SCS Registration: After Greensboro receives the completed ESA, a Greensboro Admin
user will enable the signatory's SwiftComply LAU to have access to register for their
signatory credentials. This will allow the signatory to complete their CROMERR signatory
credentials. After completion of the registration process, the signatory and the Greensboro
Admin will receive a notice. Greensboro Admin will connect to CROMERR User
02-CROMERR System Checklist-GreensboroNC 1 of 22 Updated: 1/10/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Registration (e-signature cases only)
Management to update the signatory's user status to approved. This status may be
maintained and changed by the Greensboro Admin.
To clarify further, there are two options planned for collecting wet signature ESA's. In cases where
the industry has delegated signatory authority as described in 40 CFR 403.12(I), there is already a
delegation letter on file for each industrial user signatory designee certifying them as the signatory
for said industrial user. Greensboro will collect ESAs for each of these existing signatories to
supplement their records and support CROMERR requirements. Two options are proposed, if a
letter is not on file or the signatory is new or changes, a new letter will be required.
1. Physical (in -person) validation option for the Electronic Signature Agreement (ESA). The
ESA, on Greensboro letterhead, will be physically presented to the signatory during a site
inspection or other site visit by Greensboro staff. As outlined in the above response:
"...the user must physically register as a signatory, the user is required to provide a
handwritten, wet -ink signature on a paper -based Electronic Signature Agreement (ESA) to
a designated Greensboro staff member." This registration must be presented in person
and validated by Greensboro either at Greensboro or at the industry's facility while being
inspected by Greensboro. The Subscriber Agreement must be signed by an officer of the
facility or be accompanied by a letter certifying that the applicant is a delegated signatory or
legal representative of the facility.
2. Notarized Company Letter (remote) validation. In cases where an in -person meeting is not
possible, the ESA, on Greensboro letterhead, will be signed by the industry signatory and
must also be notarized. The original hard copy, notarized ESA with wet ink signature shall
be delivered to Greensboro prior to the industry being allowed to register to use the
SwiftComply portal and SCS. In cases where the signatory does not meet the authority
requirements of 40 CFR 403.12(I), a letter delegating authority to the signatory shall also
be required. Other actions/steps may be taken by Greensboro staff to validate these
individuals as official representatives of an industry as outlined in narratives below
(sections 1 b, 2, 3 and 4)
System Functions:
1. a link to connect to Shared CROMERR Services User Management utility for Registration:
a. enter challenge questions/answers and provide password
b. follow-up actions after registration and approval of signatory user status by
Greensboro Admin
Supporting Documentation (list attachments):
• 04-Attachment 2 Electronic Signature Agreement (ESA)
• 05-Attachment 3 Registration Process Workflow
la. (priority reports only) Identity -proofing before accepting e-signatures
Business Practices:
Login credentials are required by a signatory for both the Local Application Users (LAU) to the
SwiftComply Solution and to the SCS Signature and Copy of Record (COR) Service before
signatory can enter or submit data. Registrants are not provided access to SCS registration prior to
a completed ESA being received and validated by Greensboro.
02-CROMERR System Checklist-GreensboroNC 2 of 22 Updated: 1/10/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Registration (e-signature cases only)
System Functions:
None.
Supporting Documentation (list attachments):
• 05-Attachment 3 Registration Process Workflow
1 b. (priority reports only) Identity -proofing method (See 1 bi, 1 bii, and 1 b-alt)
1 bi. (priority reports only) Verification by attestation of disinterested individuals
Business Practices:
SCS maintains authorized signatory credentials, they are not stored in the local application user's
(LAU) account in SwiftComply. A signatory must also have secure account access to the
SwiftComply Pretreatment IU Portal. Only Permitted Industrial Users or facilities approved by
Greensboro have access to the SwiftComply application. ESA receipt and system admin approval
is required before access is created to register to SCS and subsequent subscriber user status must
be updated by a Greensboro Admin to sign and submit an electronic report. The only method to
create and receive an approved ESA for identity proofing is on paper with witnessed wet -ink
signature.
Wet -ink signature:
Greensboro staff will be present during the completion of the ESA and signature process. The
completion of these documents will also be witnessed by an industrial facility officer or properly
delegated representative. In cases where an in -person meeting is not possible, the ESA, on
Greensboro letterhead, will be signed by the industry signatory and must also be notarized. Other
due diligence may include performing actions such as verification phone calls or emails to both the
industry and/or other industrial facility staff as well as periodic physical confirmation of the
signatory's continued employment during facility inspections performed by Greensboro.
System Functions:
None
Supporting Documentation (list attachments):
• 05-Attachment 3 Registration Process Workflow
1 bii. (priority reports only) Information or objects of independent origin
Business Practices:
Please see 1 bi.
System Functions:
Please see 1 bi.
Supporting Documentation (list attachments):
Please see 1 bi.
lb-alt. (priority reports only) Subscriber agreement alternative
02-CROMERR System Checklist-GreensboroNC 3 of 22 Updated: 1/10/2023

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Water Resources
CROMERR System Checklist
Registration (e-signature cases only)
Business Practices:
Please see 1 bi.
System Functions:
Please see 1 bi.
Supporting Documentation (list attachments):
Please see 1 bi.
2. Determination of registrant's signing authority
Business Practices:
Greensboro's existing Sewer Use Ordinance for their pretreatment program provides for use of a
legal Permit Document and identification of valid facility/industrial user signatories. This is currently
performed to document, validate and keep on file, proof of a valid facility signatory for priority 1
reports (self -monitoring reports) which are currently physically submitted to Greensboro by
industries.
The existing process is being expanded to include adoption of the ESA for each signatory. The
ESA must be physically signed by an officer or delegated representative of the facility in the
presence of a Greensboro staff member who can witness the signing and request confirming
identification. The ESA contains rule and statutory citations providing authority for Greensboro to
accept digital signatures. In addition, the certification language will be presented to the signatory
during the signature process for any report signed and submitted.
The Permit to Discharge Wastewater and periodic compliance inspections provide the ability and
opportunity to continually verify a signatory's credentials. If findings indicate the customer's account
isn't appropriately maintained or valid, access to the SwiftComply Pretreatment IU Portal will be
locked until identified deficiencies are addressed.
System Functions:
Signatory must certify acceptance and validity of the electronic signature process each time they
sign and submit a report during the signature and submit process, through the IU Portal using SCS.
Supporting Documentation (list attachments):
• 04-Attachment 2 Electronic Signature Agreement (ESA)
• 05-Attachment 3 Registration Process Workflow
3. Issuance (or registration) of a signing credential in a way that protects it from compromise
Business Practices:
Greensboro's approach allows access to their SwiftComply Pretreatment IU Portal only to
Permitted Industrial Users or validated facilities as allowed by their Sewer Use Ordinance. A
signatory is only granted access to the registration process after being validated through the ESA
process and being allowed access to register to SCS by a Greensboro admin user. After
completing the SCS registration which provides the signatory with credentials to sign and submit a
report electronically, they must also have their system status changed to approved by a
Greensboro admin user, so there are five layers of protection 1 Permitted Industrial User 2
02-CROMERR System Checklist-GreensboroNC 4 of 22 Updated: 1/10/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Registration (e-signature cases only)
Access to SwiftComply Pretreatment IU Portal, 3) ESA validation, 4) Access to Register as a SCS
Signatory, 5) Approval by system admin to sign/submit.
The SwiftComply application "user/pwd" is separate from SCS and is not used for SCS API
registration service or signatory service. The SwiftComply application's user/credential
management does not meet the requirements of CROMERR. However, an IU user must have a
SwiftComply account to access a link to register with SCS or sign/submit a report which can be
done after they have fully registered through the SCS CROMERR registration process.
Greensboro admin user will be able to enable/disable access to registration and subsequently
enable/disable access to sign/submit reports through the SwiftComply application user
management (settings). The user registration process and the signature process will rely on the
SCS APIs. The CROMERR signatory credentials, security and process are completely separate
from SwiftComply application credentials process. Users simply will have access to a url/link to
either register or sign/submit through SwiftComply. SwiftComply is used to create the SMR report
(COR) that is to be reviewed, signed, and submitted.
High Level Order of process:
User Setup
1) Greensboro creates a SwiftComply IU User
2) SwiftComply IU User establishes SwiftComply user credentials
3) ESA is completed by IU and confirmed by Greensboro.
4) Greensboro enables SCS registration link inside SwiftComply application for ESA IU user
5) SwiftComply IU User, clicks registration and goes through SCS registration process
6) Signatory is now registered with unique, separate credentials for SCS
7) Greensboro enables report submission link for Signatory in SwiftComply application
Recurring Process
8) SwiftComply IU User prepares SMR report for Sign/Submit
9) Signatory can begin report submission process, click link, signs into SCS
10) Signatory reviews SMR Report, chooses to sign, presented with certifications
11) Signatory goes through Signatory process in SCS
The SwiftComply application logon credentials are not used in the signature process. However,
users must be logged into SwiftComply Pretreatment IU Portal and be granted access to begin any
SCS processes.
System Functions:
1. Signatory must be a Permitted User and be provided access credentials to SwiftComply
solution
2. Signatory must be provided access by system admin to register through SCS for signatory
credentials
3. Signatory must complete registration process through SCS (relies on SCS APIs):
a. Must follow all rules for username/password security required by SCS
b. Must fill out knowledge base challenge questions and present answers as outlined
by SCS
System Admin must approve status change for signatory
Supporting Documentation (list attachments):
• 05-Attachment 3 Registration Process Workflow
02-CROMERR System Checklist-GreensboroNC 5 of 22 Updated: 1/10/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Registration (e-signature cases only)
4. Electronic signature agreement
Business Practices:
Greensboro will complete the verification process in person for an employee of a permitted
industrial user or facility connected to the city sewer. The registrant cannot initiate credential setup
for the CROMERR Sign/Submit process until they have completed the ESA process and been
enabled to allow access to the SCS registration by a City Admin user.
Greensboro is required to perform at a minimum, one inspection annually at each permitted
industrial user but may make additional site visits if necessary. During the facility inspection
process the employment and signatory status of the ESA/Signatory will be audited and confirmed.
All records related to the ESA and any documents indicating the authority of the user to sign
documents will be stored in a locked vault in the administration office at Greensboro. All records
related to the ESA and signature authority will be stored for a minimum of five years after the
deactivation of the signature device.
System Functions:
No access to register as a signatory is granted without an ESA.
Supporting Documentation (list attachments):
• 04-Attachment 2 Electronic Signature Agreement (ESA) Updated
CROMERR System Checklist
Signature Process (e-signature cases only)
5. Binding of signatures to document content
Business Practices:
SwiftComply's Pretreatment Solution IU Portal will use the Shared CROMERR Services for
Signature and Copy of Record (COR). The IU Portal combines and zips all files and supplies a
single record to be included as COR. Username, password, challenge question, challenge
question answer, and date/time of submittal (relies on SCS APIs) will be combined to create the
validation key by SCS. After the COR has been signed and submitted, the IU Portal will
subsequently retrieve the key file and link to validate, retrieve or repudiate the COR from the
shared service and email confirmation to both to the signatory and the Greensboro Admin.
Greensboro will maintain a log of the COR submission within SwiftComply's Pretreatment Solution
and in addition provide a link to the SCS for COR access (Download COR service). All submitted
reports/documents will remain accessible to the signatory in the IU portal and by download as
COR through SCS.
Greensboro will utilize the repudiation shared service in the event a stored document is repudiated
by a customer, this is system configurable but is established to allow for timely processing of
electronically received compliance data.
System Functions:
Each report/document submitted will use this same process flow:
• The signatory signs into the SwiftComply Pretreatment IU Portal.
• The signatory selects report to submit and clicks the submit button.
02-CROMERR System Checklist-GreensboroNC 6 of 22 Updated: 1/10/2023

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Water Resources
CROMERR System Checklist
Signature Process (e-signature cases only)
• The signatory is presented summary data view of the data they are about to sign and list of
attachments/files and given an opportunity to go backwards or link to make corrections.
• The signatory clicks the Next button
• The signatory reads the certification statement for the e-signature process
• The signatory selects the checkbox next to the certification statement indicating they agree.
• The signatory then will answer one randomly selected challenge question.
• The signatory then is prompted for password and clicks the continue button.
• The IU Portal will verify all signature credentials
• If signatory answers the challenge question incorrectly,
• The 1st failure is logged
• Signatory may try again (a new question/answers) until account is locked
• If the number of failed answers hits 3x, the account is changed to locked status
• The IU Portal will submit, to the shared CROMERR service, the COR file and signature
credentials.
• The IU Portal will retrieve the hash and COR from the SCS service for storage in SCS.
• The IU Portal will retain all submitted reports in a human readable format as it was
submitted.
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve,
validate or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with a link and validation
key for the submitted COR.
Human Readable Copy of Record (COR)
• The COR will consist of a zip file of all data and attachment files submitted. Data will be
in either a pdf or csv format. All attached documents shall be retained in their native
format.
o All data submitted, e.g., analytical results of sampling activities, effluent flow meter
data, pdf files, As files will be accessible in the SwiftComply IU portal in their
submitted form but locked from editing.
• The entirety of the zip/COR file will also be available to the Signatory user.
• Included in the document is:
o Any data given to the agency as part of the report submittal
Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Signature Credential
• Username and password used
• Challenge question asked and answered
• Date and Time of the submittal
Email Confirmation Upon Submittal
• Upon a successful submittal, an email is sent to the Signatory that, at a minimum, will
contain:
o A brief acknowledgement that the agency received the submittal
o Link(s) to download a copy of the COR, validate or repudiate the submitted report.
02-CROMERR System Checklist-GreensboroNC 7 of 22 Updated: 1/10/2023

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Water Resources
CROMERR System Checklist
Signature Process (e-signature cases only)
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
6. Opportunity to review document content
Business Practices:
The signatory or other local application user of the IU Portal may prepare the report and data for
the sign/submit process, however, only the signatory has access to proceed and complete the
process.
1. Review of the report package, data and files to be submitted is available throughout the
data entry or report draft process. For Pretreatment, submission of a reporting package
typically contains one or more data sets of analytical sampling results, effluent flow
readings, required documents and certification statements. This is considered a single
`report package' and is signed/submitted together at one time. The system may also be
used to sign and submit a single file or other required form (e.g., Permit renewal
application form)
2. When clicking the link to continue to sign/submit process a review screen is presented
with a summary of all data and a list of attached files. The user may click and review
details of any item or go back and see all the data still in edit mode prior to continuing. The
goal here is to summarize the content of the report for quick or optionally further detailed
review before signing and submitting the report package.
System Functions:
Each report/document submitted will use this same process flow:
• The signatory selects the report (package) to submit and clicks the submit button.
• The signatory is presented with a summary data view of the data they are about to sign
and a list of attachments/files and given an opportunity to go backwards or link to make
corrections.
• The signatory clicks the Next button or Cancel to return and make edits
• If continuing, the signatory reads the certification statement for the e-signature process
• The signatory selects the checkbox next to the certification statement indicating they
agree confirming that this report may no longer be edited in the future (without going thru
repudiation).
• The signatory then will answer one randomly selected challenge question.
• The signatory then is prompted for password and clicks the continue button.
• The IU Portal will verify all signature credentials
• If signatory answers the challenge question incorrectly,
• The 1st failure is logged
• Signatory may try again (a new question/answers) until account is locked
• If the number of failed answers hits 3x, the account is changed to locked status
• The IU Portal will submit, to the shared CROMERR service, the COR file and signature
credentials.
• The IU Portal will retrieve the hash and COR from the SCS service for storage in SCS.
• The IU Portal will retain all submitted reports in a human readable format as it was
submitted.
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve,
validate or repudiate the COR.
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Signature Process (e-signature cases only)
Human Readable Copy of Record (COR)
• The COR will consist of a zip file of all data and attachment files submitted. Data will be in
either a pdf or csv format. All documents attached shall be retained in their native format.
o All data submitted, e.g., analytical results of sampling activities, effluent flow meter
data, pdf files, As files will be accessible in the SwiftComply IU portal in their
submitted form but locked from editing
o The entirety of the zip/COR file will also be available to the Signatory user.
• Included in the document is:
o Any data given to the agency as part of the report submittal
• Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
7. Opportunity to review certification statements and warnings
Business Practices:
The IU Portal provides the e-signature certification statement prior to signature. Each file type or
report type to be submitted can have additional certifications configured to be presented and
electronically signed. These will appear on the same screen. Some certifications can be optional,
but if required, the check box must be selected before the signature process can continue. The
certification statement is included on the COR.
Each business process implemented (priority and non- priority reports alike) will have the ability to
have their own system admin configured certification statement and be changeable over time.
The "08-Attachment 6 Screen Images" is an example of the screens and process, which can be
configured to display any (required) statements including multiple statements that the signatory
must attest to and (e-sign) sign before proceeding.
The two certification statements currently planned are as follows (these can be edited or added to
as required):
(1) 1 agree that the use of my electronic signature device (Username and Challenge
Question/Answer) shall serve as a legally enforceable signature in the same manner as an original
signature on a paper document pursuant to the provisions of the State's relevant regulations and
requirements. I will be held legally bound, obligated, and responsible for my use of my electronic
signature as I would be by using my hand-written signature in submitting an electronic document
to the SwiftComply Pretreatment Solution.
(2) 1 certify under penalty of law that I have personally examined and am familiar with the
information submitted to the Greensboro and I believe that the information is true, accurate and
complete. I am aware that there are significant penalties for submitting false information, including
the possibility of fine and imprisonment.
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Signature Process (e-signature cases only)
System Functions:
Certification statements are managed through code tables so that what is seen on the screen is
always in sync with what gets presented on the signature page during preview of the data for the
COR.
Supporting Documentation (list attachments):
• 04-Attachment 2 Electronic Signature Agreement (ESA) Updated
• 08-Attachment 6 Screen Images
CROMERR System Checklist
Submission Process
8. Transmission error checking and documentation
Business Practices:
All sessions (transmissions) use the latest Secure Sockets Protocol (SSL) protecting the process
from data loss or attacks during transmission. SwiftComply's solution is SOC2-Typell certified.
https://secureframe.com/blog/soc-2-type-ii
For transmission errors that can happen during the submission process, the user is presented with
an instant response error report that displays the system couldn't process the report submission,
the status is returned to pending and remains unsigned/unsubmitted and can still be edited. An
email notice will also be sent to the signatory user.
The user will be prompted to attempt the submission again and if continued transmission errors
occur to contacts stem support for diagnosis.
System Functions:
Each report/document submitted will use this same process flow:
• The signatory then is prompted for password and clicks the continue button.
• The IU Portal will verify all signature credentials
• If signatory answers the challenge question incorrectly,
• The 1st failure is logged
• Signatory may try again (a new question/answers) until account is locked
• If the number of failed answers hits 3x, the account is changed to locked status
• The IU Portal will submit, to the shared CROMERR service, the COR file and signature
credentials.
• The IU Portal will retrieve the hash and COR from the SCS service for storage in SCS.
• The IU Portal will retain all submitted reports in a human readable format as it was
submitted.
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve, validate
or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with a link and validation
key for the submitted COR.
Failure: SCS API times out, does not return a response or is rejected, an error message will
appear on screen and email notice is sent to the signatory user and system admin with the error
message information.
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Submission Process
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
9. Opportunity to review copy of record (See 9a through 9c)
9a. Notification that copy of record is available
Business Practices:
After the user receives (successful) confirmation of submission,
1. An email notice will be received with validation key and links to download COR, validate or
repudiate
2. The submitted report remains (locked from edit/delete) in the original system used to
gather and submit the report. Its status will be Submitted but remains fully viewable.
3. The Greensboro System Admin will also receive an email notice and be provided the
opportunity to download the COR.
System Functions:
Submission Receipt
• The IU Portal will retain all submitted reports in a human readable format as it was
submitted.
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve, validate
or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with a link and validation
key for the submitted COR.
Human Readable Copy of Record (COR)
• The COR will consist of a zip file of all data and attachment files submitted. Data will be in
either a pdf or csv format. All documents attached shall be retained in their native format.
• All data submitted, e.g., analytical results of sampling activities, effluent flow meter
data, pdf files, As files will be accessible in the SwiftComply IU portal in their
submitted form but locked from editing
o The entirety of the zip/COR file will also be available to the Signatory user.
• Included in the document is:
o Any data given to the agency as part of the report submittal
Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Supporting Documentation (list attachments):
None.
9b. Creation of copy of record in a human -readable format
Business Practices:
See 9a.
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Submission Process
System Functions:
See 9a.
Supporting Documentation (list attachments):
• 10-COR Example
9c. Providing the copy of record
Business Practices:
See 9a.
System Functions:
See 9a.
Supporting Documentation (list attachments):
• 10-COR Example.
10. Procedures to address submitter/signatory repudiation of a copy of record
Business Practices:
The IU Portal will have an option to initiate repudiation of a submitted report (COR). The submitter
may initiate this from their confirmation email link or from a link on the report record in the IU
Portal.
The COR will remain in SCS with a status updated to Repudiated and that status is also reflected
on the original data record within the IU Portal Application. The repudiated record will remain
locked, however, if the submitter desires to edit and resubmit the information, it may be copied into
a new report record for edit, review to be signed and submitted. This does not reflect itself as the
same record that was repudiated, however, as a new record.
Repudiation does not require Greensboro system admin review; however, the Greensboro Admin
user will be notified via email receipt that the previous submitted report was repudiated.
Greensboro will provide for repudiation in compliance with CROMERR. This shall not limit
Greensboro's ability or authority to take enforcement against any user as outlined in an industrial
user's permit or as allowed by applicable laws and/or regulations.
System Functions:
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve,
validate or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with link and validation
key for the submitted COR.
• Should the user initiate the repudiation, they will proceed through the signatory process,
confirm desire to complete the repudiation and securely sign the confirmation to initiate the
process.
• The submitter and Greensboro System Admin will both receive notice of repudiation.
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Submission Process
The original record status will change from submitted to repudiated. It will remain locked from
edit/delete and may not be resubmitted. It may be copied, edited and resubmitted as a new report.
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
11. Procedures to flag accidental submissions
Business Practices:
The submission of reports is a multi -step approach minimizing the risk for accidental submittals.
The signatory must check the certification box, type in a challenge question answer, and click on a
submit button for the submittal to move forward. Accidental submittal becomes the responsibility of
the signatory who is incumbent to repudiate the report and contact Greensboro to determine any
outlying business or regulatory consequences.
System Functions:
Accidental submittals are handled thru the same process as repudiation. There is no functionality
designed to allow for Greensboro Admin users to change the status of a Submitted Report. The
only report status exposed to Greensboro will be Submitted or Repudiated.
• The IU Portal will also send a confirmation receipt email to the signatory's email address
about the success (or failure) of the process. The email will contain links to retrieve, validate
or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with a link and validation
key for the submitted COR.
• Should the user initiate the repudiation, they will proceed through the signatory process,
confirm desire to complete the repudiation and securely sign the confirmation to initiate the
process.
• The submitter and Greensboro System Admin will both receive notice of repudiation.
• The original record status will change from submitted to repudiated. It will remain locked from
edit/delete and may not be resubmitted. It may be copied, edited and resubmitted as a new
report.
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
12. (e-signature cases only) Automatic acknowledgment of submission
Business Practices:
After each submittal, there is an onscreen confirmation and an email is sent to the signatory user
and to the Greensboro Admin user that contains an acknowledgement of submittal, validation key
and links to take further action should they be needed for repudiation, validation or download of
COR.
Should the submission fail, the confirmation notice on screen and automated email will reflect that
status and direct the user to attempt resubmission if due to transmission error.
System Functions:
The IU Portal will also send a confirmation receipt email to the signatory's email address about the
success (or failure) of the process. The email will contain links to retrieve, validate or repudiate the
COR.
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Submission Process
• The IU Portal will send an email notice to the Greensboro Admin with a link and validation key
for the submitted COR.
• Should the user initiate the repudiation, they will proceed through the signatory process,
confirm desire to complete the repudiation and securely sign the confirmation to initiate the
process.
• The submitter and Greensboro System Admin will both receive notice of repudiation.
• The original record status will change from submitted to repudiated. It will remain locked from
edit/delete and may not be resubmitted. It may be copied, edited and resubmitted as a new
report.
The automatic acknowledgement of receipt message will be sent to the signatory's (the registrants)
email. It will include the submitter's name, title of report (SMR package and compliance period)
submitted, date and time of submission, attached zip file of the COR and instructions on how to
validate or get a copy of the COR. A url/link to validate or download the COR will be provided.
The receipt message will also contain the COR validation key. Instructions for questions, contact
information to report spurious activity or a compromise, and for repudiation will also be provided.
Supporting Documentation (list attachments):
• 09-Attachment 7 Confirmation Receipt
CROMERR System Checklist
Signature Validation (e-signature cases only)
13. Credential validation (See 13a through 13c)
13a. Determination that credential is authentic
Business Practices:
A signatory user must have user/pwd credentials that will be validated on login to the
SwiftComply Pretreatment IU portal and subsequently pass password + knowledge base
questions to connect to the signature process and to confirm/sign/submit a report. Final
validation will be through user input and submitted to the SCS service for user validation.
System Functions:
• The signatory signs into the SwiftComply Pretreatment IU Portal.
• The signatory selects the report to submit and clicks the submit button.
• The signatory is presented with a summary data view of the data they are about to sign
and list of attachments/files and given an opportunity to go backwards or link to make
corrections.
• The signatory clicks the Next button
• The signatory reads the certification statement for the e-signature process
• The signatory selects the checkbox next to the certification statement indicating they
agree.
• The signatory then will answer one randomly selected challenge question.
• The signatory then is prompted for password and clicks the continue button.
• The IU Portal will verify all signature credentials
o If signatory answers the challenge question incorrectly,
The 1st failure is logged
Signatory may try again (a new question/answers) until account is
locked
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Signature Validation (e-signature cases only)
• If the number of failed answers hits 3x, the account is changed to
locked status
The IU Portal will submit, to the shared CROMERR service, the COR file and signature
credentials.
The SwiftComply Pretreatment IU Portal application logon credentials are not used in the
registration or signature process. However, users must be logged into the IU Portal and be
granted access to begin any SCS processes. The SCS registration and signatory credentials
are maintained through use of the SCS process and are not directly tied in any way to the
SwiftComply Pretreatment IU Portal Credentials. Greensboro admin users can enable/disable
access to the SCS Registration and Signatory process url/link to a SwiftComply user.
Supporting Documentation (list attachments):
None.
13b. Determination of credential ownership
Business Practices:
After validation of the signatory through the ESA process and registration of the signatory using
the SCS services, (relies on SCS APIs) the user is required to maintain the signature device as
username, password, challenge questions/answers. This is combined with the user being
required to maintain their username/password to the SwiftComply Pretreatment IU Portal.
No other devices are used. Should a disinterested party gain access, Greensboro will lock the
account and proceed with revalidation of the signatory user.
When knowledge base questions are provided, the user will have 3 attempts, each a new
question to complete the process. The system will not provide additional attempts nor a 2-2-1
process (first question twice, second question twice, third question once) for the challenge
questions.
System Functions:
IU Portal Login:
1. User is presented with two fields
a. Username: plain text not masked
b. Password: masked
2. When the user clicks the login button, the system passes the information to the identity
server (IS) to confirm or reject. If rejected, the user is presented with an error message
and given an opportunity to retry. After 3 failed attempts, the system is locked and the
user must contact the Greensboro Admin user or SwiftComply support for password
reset (after lock).
The SwiftComply application logon credentials, its lockout and reset process are not used in the
SCS processes. These are separate credentials. SwiftComply only provides links to
access/login/call SCS processes.
Account locking for SCS access is managed through use of the SCS API services. Greensboro
admin users will be provided a link to the SCS services to view account security
questions/answers and to unlock an account. Greensboro will not have any access to view
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Signature Validation (e-signature cases only)
login or signatory challenge questions/answers. These will be provided through use of SCS API
services.
Signature/Submittal:
1. User is presented with a checkbox and a field
a. Checkbox: associated with the certification statement(s)
b. These may be required or optional, all required checkboxes must be checked to
proceed.
2. When the user selects submit, the application checks:
a. It will then pass the question number and answer provided to the IS service to
determine if the question -and -answer match. If the answer is not correct, the
user is presented with an error message and allowed to retry with another
randomly selected challenge question. After 3 failed attempts, the account is
placed in locked status.
Supporting Documentation (list attachments):
None.
13c. Determination that credential is not compromised
Business Practices:
All login attempts are logged. If repeated single attempt failed login attempts are made a notice
is issued to the Greensboro Admin User as suspected spurious activity.
Greensboro Inspectors will include signatory validation review as part of their periodic onsite
inspection process when visiting facility/industrial user locations throughout the year.
System Functions:
Provide log of all attempted logins, I address, date/time and reason for failure
Supporting Documentation (list attachments):
None
14. Signatory authorization
Business Practices:
The subscriber agreement explicitly authorizes the individual to submit legally binding reports by
the facility/industry official. It is the responsibility of the authorizing facility/industry official to
assign the correct individual to submit reports and notify Greensboro of any change in
relationship of the individual with the entity. Greensboro will also verify the registrant's signing
authority during ongoing on -site inspections. The appropriate industry official as described in 40
CFR 403.12 may revoke the delegated authority and the ESA at any time by submitting a wet
ink signed hard copy request letter on company letter head to Greensboro.
System Functions:
Relies on SCS APIs.
Should there be a request to revoke a signatory user's access or privileges
1) Greensboro will change the status of the user to deny system access
2) Greensboro will contact the source of the request to confirm validity
3) An email notice will be issued to the signatory user's email address
regarding the change in status.
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Signature Validation (e-signature cases only)
Supporting Documentation (list attachments):
None
15. Procedures to flag spurious credential use
Business Practices:
The Greensboro Admin user will periodically review the results of the logged connection
attempts and filter for failed attempts, to perform fraud analysis and determine if an account has
been compromised. If it is determined that a compromise has occurred, the affected account will
be locked, preventing the user from system access. The user will be contacted to address the
situation.
System Functions:
The IU Portal logs details and transaction events at standard syslog levels (such as alert,
warning, normal, debug, etc) to assist researching or troubleshooting technical and process
issues (including fraud analysis as needed). All IP address, user, date/time and connection
status are logged for login attempts.
System log files are read only and may not be edited or deleted.
Greensboro Admin users can flag a user account is locked to prevent spurious use while
researching the issue.
Supporting Documentation (list attachments):
None
16. Procedures to revoke/reject compromised credentials
Business Practices:
Greensboro Admin users have the ability to lock any user account that is requested, suspected,
or determined to be compromised. Immediately when placed in locked status, the user account
cannot be accessed. This lock is permanent in the sense the account will remain locked until
such time as Greensboro manually unlocks the account.
The person with the account will receive direct communication from Greensboro staff, either
before, during, or immediately after locking as part of the research and review process.
Greensboro will work with the signatory user to determine which submittals look to be spurious
and which are not. Those suspected to be spurious will follow the report specific process for
flagging the records as inactive and not to be used with compliance data until the situation is
resolved. This status will also reflect in the IU Portal for all Local Application Users of the IU
portal. This status can only be changed or updated by Greensboro.
All COR that are marked as spurious will still be available to the customer in IU portal, however,
the status change will also be reflected.
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Signature Validation (e-signature cases only)
System Functions:
• Greensboro Admin User will inactivate account access (lock account)
• Notice will be submitted via email to the locked user
• Other steps require manual communication and interaction to proceed
Supporting Documentation (list attachments):
none
17. Confirmation of signature binding to document content
Business Practices:
Signatory users will receive email notification of each report submission including confirmation
of signature binding to document content including validation key.
System Functions:
Each report/document submitted will use this same process flow:
• The signatory signs into the SwiftComply Pretreatment IU Portal.
• The signatory selects the report to submit and clicks the submit button.
• The signatory is presented with a summary data view of the data they are about to sign
and list of attachments/files and given an opportunity to go backwards or link to make
corrections.
• The signatory clicks the Next button
• The signatory reads the certification statement for the e-signature process
• The signatory selects the checkbox next to the certification statement indicating they
agree.
• The signatory then will answer one randomly selected challenge question.
• The signatory then is prompted for password and clicks the continue button.
o Any data given to the agency as part of the report submittal
Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Username, password, challenge question, challenge question answer, and date/time of
submittal will be combined to create the validation key by SCS.
Supporting Documentation (list attachments):
• 06-Attachment 4 Signature —Submission Process Workflow
CROMERR System Checklist
Copy of Record
18. Creation of copy of record (See 18a through 18e)
18a. True and correct copy of document received
Business Practices:
All successful submissions that are signed and not repudiated will indicate that a true and
correct copy of the document has been submitted. This will be provided in an email
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Copy of Record
confirmation to the signatory user with options to validate, repudiate and download the COR for
confirmation.
System Functions:
Submission Receipt
• The IU Portal will retain all submitted reports in a human readable format as it was
submitted.
• The IU Portal will also send a confirmation receipt email to the signatory's email
address about the success (or failure) of the process. The email will contain links to
retrieve, validate or repudiate the COR.
• The IU Portal will send an email notice to the Greensboro Admin with a link and
validation key for the submitted COR.
Human Readable Copy of Record (COR)
• The COR will consist of a zip file of all data and attachment files submitted. Data will be
in either a pdf of csv format. All documents attached shall be retained in their native
format.
o All data submitted, e.g., analytical results of sampling activities, effluent flow
meter data, pdf files, As files will be accessible in the SwiftComply IU portal in
their submitted form but locked from editing.
o The entirety of the zip/COR file will also be available to the Signatory user.
• Included in the document is:
o Any data given to the agency as part of the report submittal
Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Supporting Documentation (list attachments):
None
18b. Inclusion of electronic signatures
Business Practices:
SwiftComply's Pretreatment Solution IU Portal will use the Shared CROMERR Services for
Signature and Copy of Record (COR). The IU Portal combines and zip all files and supplies a
single record to be included as COR. Username, password, challenge question, challenge
question answer, and date/time of submission will be combined to create the validation key by
SCS. After the COR has been signed and submitted, the IU Portal will subsequently retrieve
the key file and link to validate, retrieve or repudiate the COR from the shared service and email
confirmation to both the signatory and the Greensboro Admin including the validation key.
System Functions:
Signature Credential
• Username and password used
• Challenge question asked and answered
• Date and Time of the submittal
Email Confirmation Upon Submittal
• Upon a successful submittal, an email is sent to the Signatory that, at a minimum, will
contain:
o A brief acknowledgement that the agency received the submittal
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Copy of Record
o Link(s) to download a copy of the COR, validate or repudiate the submitted
report.
Supporting Documentation (list attachments):
None
18c. Inclusion of date and time of receipt
Business Practices:
SwiftComply's Pretreatment Solution IU Portal will use the Shared CROMERR Services for
Signature and Copy of Record (COR). The IU Portal combines and zip all files and supplies a
single record to be included as COR. Username, password, challenge question, challenge
question answer, and date/time of submittal will be combined to create the validation key by
SCS. After the COR has been signed and submitted, the IU Portal will subsequently retrieve
the key file and link to validate, retrieve or repudiate the COR from the shared service and email
confirmation to both the signatory and the Greensboro Admin including the validation key.
System Functions:
Signature Credential
• Username and password used
• Challenge question asked and answered
• Date and Time of the submittal
Email Confirmation Upon Submittal
Upon a successful submittal, an email is sent to the Signatory that, at a minimum, will
contain:
• A brief acknowledgement that the agency received the submittal
• Link(s) to download a copy of the COR, validate or repudiate the submitted
report.
Supporting Documentation (list attachments):
None
18d. Inclusion of other information necessary to record meaning of document
Business Practices:
SwifitComply's Pretreatment IU Portal is designed to provide compliance data, inspections
permitting data, requirements, notices and communications for permitted industrial users of
Greensboro's Pretreatment Program. The context, instructions, permit, training videos and
general reason for submitting a "document" is about understanding what the information is that
is required to be submitted. It is not expected to approve a signatory user who does not
understand the meaning of data and documents required to be submitted.
System Functions:
Does not apply
Supporting Documentation (list attachments):
None
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Copy of Record
18e. Ability to be viewed in human -readable format
Business Practices:
SwiftComply's Pretreatment Solution IU Portal will use the Shared CROMERR Services for
Signature and Copy of Record (COR). The IU Portal combines and zip all files and supplies a
single record to be included as COR. Username, password, challenge question, challenge
question answer, and date/time of submittal will be combined to create the validation key by
SCS. After the COR has been signed and submitted, the IU Portal will subsequently retrieve
the key file and link to validate, retrieve or repudiate the COR from the shared service and email
confirmation to both the signatory and the Greensboro Admin including the validation key.
System Functions:
Human Readable Copy of Record (COR)
• The COR will consist of a zip file of all data and attachment files submitted. Data will be
in either a pdf of csv format. All documents attached shall be retained in their native
format.
o All data submitted, e.g., analytical results of sampling activities, effluent flow
meter data, pdf files, As files will be accessible in the SwiftComply IU portal in
their submitted form but locked from editing
o The entirety of the zip/COR file will also be available to the Signatory user.
• Included in the document is:
o Any data given to the agency as part of the report submittal
Including any system configured electronic certifications that may be
added in addition to certifying/agreeing to the e-signature process.
o The username of the person that submitted
o The date and time of submittal
Supporting Documentation (list attachments):
• 10-COR Example.
19. Timely availability of copy of record as needed
Business Practices:
All successful submissions that are signed and not repudiated will indicate that a true and
correct copy of the document has been submitted. This will be provided in an email confirmation
to the signatory user with options to validate, repudiate and download the COR for confirmation.
All COR files may be obtained by link through email or the IU Portal application. If SCS are
operating the timely availability of the record is instantaneous.
System Functions:
Relies on SCS APIs
Supporting Documentation (list attachments):
None
02-CROMERR System Checklist-GreensboroNC 21 of 22 Updated: 1/10/2023

Agency: City of Greensboro, NC System: SwiftComply Pretreatment Date: 1/10/2024
Water Resources
CROMERR System Checklist
Copy of Record
20. Maintenance of copy of record
Business Practices:
All successful submissions that are signed and not repudiated will indicate that a true and
correct copy of record has been submitted. This will be provided in an email confirmation to the
signatory user with options to validate, repudiate and download the COR for confirmation.
All COR files are maintained in the SCS platform space. SCS will store the official CORs.
System Functions:
Relies on SCS APIs
Supporting Documentation (list attachments):
None
02-CROMERR System Checklist-GreensboroNC 22 of 22 Updated: 1/10/2023

GREENSBORO
NORTH CAROLINA
OFFICE OF THE CITY ATTORNEY
January 10, 2024
Mr. Michael Montebello
NC Division of Water Resources
Water Quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC. 27699-1617
Re: Local Legal Certification for eSignature and eReporting for Greensboro, NC
To Whom It May Concern,
I, Tony Baker, am the Chief Deputy City Attorney for the City of Greensboro. I possess the authority to
represent Greensboro Water Resources, a department of the City of Greensboro, through this certification
document.
The City of Greensboro Rules and Regulations for the Operation of the Water and Water System, Section
K: Sewer User and Pretreatment Ordinance, Article I, Section 4 (by definition of Pretreatment Program
and Pretreatment Requirement) authorizes Greensboro Water Resources to develop procedures for receipt
of electronic reports in compliance with 40 CFR Part 3.
I hereby certify that Greensboro Water Resources has no lawfully enacted or promulgated statutes,
ordinances or regulations that impede the implementation of the electronic reporting component of its
authorized programs consistent with 40 Code of Federal Regulations § 3.2000 and with this application.
Chief D puty City Attorney
t'. B 3136
ensboro, NC 27402-3136
(desk) 336-373-7797
(cell) 336-701-2289

SUBSCRIBER AGREEMENT FOR SUBMITTING DATA ELECTRONICALLY
Provided for acceptance of the electronic signature credential issued by the City of Greensboro Water
GREEN580R0 Services Department (Greensboro) to sign electronic reports submitted to Greensboro's SwiftComply
WATER RESOURCES Pretreatment Solution.
Permit #: Permittee:
Located:
(1) understand and agree to submit self -monitoring data required by Permit To
Discharge Wastewater Under The Industrial Pretreatment Program, referenced above, through
electronic format, and I agree that the use of my electronic signature device (Username and Challenge
Question/Answer) shall serve as a legally enforceable signature in the some manner as an original
signature on a paper document pursuant to the provisions of the State's relevant regulations and
requirements. I will be held legally bound, obligated, and responsible for my use of my electronic
signature as I would be by using my hand-written signature in submitting an electronic document to
the SwiftComply Pretreatment Solution.
(2) agree to protect my Online electronic signature credential, consisting of my password and answers
to my security questions, from use by anyone except me and to change them if they become known to
anyone but me. Specifically, I agree to maintain the secrecy of my electronic signature credential; I will
not divulge or delegate my electronic signature credential to any other individual; I will not store my
electronic signature credential in an unprotected location; and I will not allow my electronic signature
credential to be written into computer scripts to achieve automated login.
(3) Agree not to attempt to use or create automated log -in scripts using my e-signature credentials.
(4) Agree to report to Greensboro within 24 hours of discovery, any evidence of loss, theft or other
compromise of my electronic signature.
(5) Agree to notify Greensboro if I cease to represent the regulated entity specified above as signatory
of that organization's electronic submissions to the SwiftComply solution as soon as this change in
relationship occurs and to sign a surrender certification at that time.
(6) 1 certify under penalty of law that I have personally examined and am familiar with the information
submitted to the Greensboro and I believe that the information is true, accurate and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fine and imprisonment.
Signatory Name:
Title:
Email:
Signature:
Date:
Authorization by immediate supervisor or witnessing official: I
individual named above works at/for
company's behalf.
Witness Name:
acknowledge that the
and is authorized to submit documents on the
Signature:
Title: Date:

ATTACHMENT 3 - Registration
SwiftComply IU Portal
Process Workflow
Provides facility signatory with
ESA
Signatory, fills out agreement,
witnessed by Facility Officer
and confirmed by
Pretreatment Staff
LAU Pretreatment Admin securely files ESA and
enables signatory's LAU access to CROMERR
Registration Process
LAU Signatory clicks CROMERR Registration
Button to initiate Process
if
SwiftComply calls SCS
UserManagmentService, Authenticate
(service)
Signatory is walked through SCS process: I
CreateBaseUser
GetEligibleQuestions
CreateUser
i
Authenticate User I
UpdateUserinformation
CreateActivity
SenclMessage
LAU — Facility Signatory, LAU — Pretreatment
Admin Receive Confirmation Notice of
Registration
Legend
OFacility Signatory User
OSwiftComply IU Portal / Local
Application User (LAU)
i Shared CROMERR Services (SCS)
OPretreatment Admin User
LAU — Pretreatment Admin Connects to SCS
UserManagmentService
Authenticate (service)
AuthenticateUser
f- - - ` - - - - - - - - - - - - - I
Update Status of Registered Facility Signatory to
Approved
ChangeUserStatus
LAU — Facility Signatory, LAU — Pretreatment
Admin Receive Confirmation Notice of Approval
LAU Signatory may now manage
CROMERR Knowledge Base
Answers and PWD
LAU — Pretreatment may now force password
reset of LAU Signatory and change that user's
CROMERR Registration Status
END
05-Attachment 3 Registration Process Workflow 1 of 1 Updated: 09/06/2023

ATTACHMENT 5 - Signature
SwiftComply IU Portal
Process Workflow
Report is Ready to Sign/Submit
Signatory Logs into IU Portal and
select Report to Submit
Signatory confirms data for
submission, agrees to e-signature
certification clicks continue
SwiftComply presents a read only
verification page of the Reports
selected for signing
i--———————---——————————
i
Signatory answers the randomly
selected challenge question on file
' Yes
Correctly `�
No
answered?
No
Display Error
Message
' Failed after
3x?
Yes
Account is Locked and
Administrator and Submitter
are notified via email
END
Legend
•
Facility Signatory User
OSwiftComply
IU Portal / Local
Application User (LAU)
Shared CROMERR Services (SCS)
OPretreatment
Admin User
IU Portal generates a Copy of Record (COR)
calls SCS Service
SCS generates hashed values binding
the signature to COR passes back i
response/validation key
SignAndStoreCor
----------------------
IU Portal displays success/failure and
Human Readable Format of submitted
data to user
IU Portal emails notice to the
signatory and System Admin of COR
creation with submission validation
and links to download/validate/
repudiate
--——— — — — —
li
Optional:
ValidateCor
DownloadCor
i
RepudiateCor i
i
---------------------
I
END
06-Attachment 4 Signature Process Workflow 1 of 1 Updated: 09/06/2023

Pretreatment
Why SwiftComply?
Our team focuses on providing efficient business tools for all stakeholders who interact with our regulatory agencies. It is your
data and your responsibility to provide interaction and interact to meet your local requirements so you should have the right tools
to do the job.
Q Industrial User Portal
Industrial users are asked to provide
a signficant investment to meet local
regulatory requirements for sewer use.
Permits, inspections and self -monitoring
are critical to maintain compliance.
Having access to data supporting these
ativities promotes good stewardship and
compliance with your permit.
Utilize dashboard driven technology allowing
users to import, enter and submit sampling
analysis and report files online. Receive
notices and be ability to view inspection
results, permit requirements & your agency's
sampling data for your industry.
Q Modern, user-friendly
software
We designed SwiftComply to put hours back
in your day. Automate reports, reminders, and
notifications, and set up CROMERR compliant
electronic self -monitoring data submission
and permit management to make the best
use of your time and resources.
hello aoswiftcomply.com

Attachment 6 Screen Images
SwiftComply IU Portal
Preparing an SMR Report for Submittal (3 screens)
lu Pofr al
.. } U Do,ral
0 Topps Metal Finishing - New Record
Which record type would you create?
MonitoringlReporting lm Othercompliancedocumenl
Do you want to complete a form or upload a document?
BComplete a Form
D Topps Metal Finishing - SMR
OR Im Upload Uocumenl
Please attach all needed docurnentsto the form
Q SELF -MONITORING REPORT IRpproved excel or .csv format)
A Lab Report
A Chain of Custody
Typo File 14e
08-Attachment 6 Screen Images 1 of 5 Updated: 11/14/2022

`x ty > lu Portal
0 * I Alfred Souza ® v
0 Topps Metal Finishing - 5MR
Please attach all needed documents to the form
Q SELF -MONITORING REPORT (Only .csv forrnatl
Q Lap Report
IS Chain of Custody
Tg. File N—
5MRjDAIA M S.Pnia csr
0
Lao weport 7. I,"Tepplpdt
rya
Ckein yr Cualody l.up Topps LoLpM
"M
Preparing an Permit Application for Submittal (6 screens)
t, tY ) lu Portal
0 Topps Metal Finishing - New Record
Which record type would you create?
aMorntoring f Reporting
0 * I Alfred u9IRa ® v
10Or heir compllamedocumenl
Do you want to complete a form or Upload a docurnerit?
Complete aform QR 11M uploadoocurnenl
Which template would you like to use?
Permit Rene* 1 AppGcai ion w
08-Attachment 6 Screen Images 2 of 5 Updated: 11/14/2022

.f.1::1 r % IIJ Portal
A ilk „f• p
> IIJ Portal
D Topps Metal Finishing - Permit Renewal Application
v 3 4
e—.— SW o —nt
Permit Explratioo Date: Permit number:
09123/2022 C 1458
Official Name of Applicant: Facility Name:
IF Ben Topps Metal Finishing
Facility Address:
6391 Elgin St. Celina, Delaware 10299
® t)se this same address For Mailing
Mailing Address:
6391 Elgin St. Cenne, Delaware 10299
Aulhorl=e0 Signatory Alternative Aulhorlled Signatory:
,e Jerome Bell .47 Darrell Steward
CEO President of Sales
• 1 122131 555 -0109 •1 (2191 555-011 i
D Topps Metal Finishing - Permit Renewal Application
0 * I Alfred Souza ® v
3 4
Have the treatment or gi5posal methods employed, as Indicated in previous discharge permit applications,
been altered In any way since [he last permit applications was submitted?
Q Yes
O No
Have the uantity or qual of wastes discharged as indicated in Prevlous discharge permit applications,
be@n Signi}iGantly Ghan9 in Since the 1a5t @pplicdti9n aws SV4mtll@p5
C) Yes
O No
Gescrlptlon of current or ptanneo activitles that may require permit changes:
tcneck all that appro
Gpnslru4[ign• inslalldlign qr m4piftg9tgn 4f wagt@ C4�I@Ctign, tie@Im@nt qr plgpgg@I faCllitlgg
operaiian Of ngw waste "lrection, Treatment & disposal faciliies
New smxels) of wastewaler to he discharged la the putilic 5CW2r
Other:
Back
08-Attachment 6 Screen Images 3 of 5 Updated: 11/14/2022

OOM PLY ) IU Porlal
�
0 * I Alfred Souza Q -
SOCWLY IU Porlal
0 Topps Metal Finishing - Permit Renewal Application
+L
nuxn oxume i Lr av end
Please attach an explanation or proposal for any changes in operations or waste quantity or
quality below
F ft Marne
0 * I AI}100 Sov.7A a -
0 Topps Metal Finishing - Permit Renewal Application
IWO _0 4
Please attach an explanation or proposal for any changes in operations or waste quantity or
quality below
file roam.
! Frplanarign pM
f, Prop osel.pa!
LosJnp Cakwa�ions:is
08-Attachment 6 Screen Images 4 of 5 Updated: 11/14/2022

a Topps Metal Finishing - Permil Renewal AppliCstlon
Wg if y %m data a mered drA tip Me dotvnem
4uW1111 Info
WA
vrrr �ae�h
j* Wr F 50
Psmmirado—
eml EVnSL[dffNk balayme IMO
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ab
+1 12M b5s. Ma
rota a.rvrr nw.i cF�p*
14s
0-d" r 4-If -1 ---m dii-M-40
ei n
i 4 1 ,w„d kum ■
+e-nrtWrmmCWf
OA1#SJ#Q##
rsafr f�
TOM KANJI F-thAg
laerAM—:
6391 Elyn 5t Caima, Diiim f 1G204
airy rrf—bod a�rrs
WiM1Yr }Fin0
Pmak arrt al !!Lmm
*1121M) S•bt14
CW"WM pe—m A"OMr-W mgw%p— W
•OmiAru~. mLmlw6m or rnodH cabm aP xasty oote[C-on, troWmant or il,MmeM Oecilibn
* Qi;WVM4n0'FM1Yr'wNWCiwSW.ngoo 4nriX6%, W44dri44
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r
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141
iD
1 humW catrfx Chat the r�onnatm contmi ed M Iris opp4catms is Info- end co-ect to the Ue71 of rrM
6 end ID"
nark
08-Attachment 6 Screen Images 5 of 5 Updated: 11/14/2022

CONFIRMATION RECEIPT Greensboro Water Resources
SwiftComply Demo
Greensboro Water Resources<[e-mail] >
To Frank Johnson <[e-mail]>
Frank Johnson, have been identified by the Greensboro Water Resources pretreatment
program as the official signatory for the Permitted Industry who signed and submitted the
following compliance report.
Qtrly SMR Jan 1 — March 31, 2023 confirmed received: March 2, 2023 10:53:03
a.m. Validation key: 83074f4a276d716112a5cfc3ee84eada
Please keep a copy of this email receipt as proof of confirmation of your report
submission. A copy of the submitted report is attached to this email for your records.
You may also use the link provided below to download a copy of the submitted report or
to validate the submission.
If you have submitted this report in error or would like to retract the submission, please
use the link below to recall (repudiate) the submitted report.
rnCity of Greensboro Water Resources
2350 Huffine Mill Road, McLeansville, NC 27301
Office: [phone]
GREENSBORO www.greensboro-nc.gov
WATER RESOURCES
You are receiving this message because you signed and submitted pretreatment compliance report through your
IU Portal entered into the greensboronc.swiftcomply. com software by the Greensboro pretreatment program for a
Permitted Industrial User you are affiliated with. Please note that if this message was received in error or you
suspect suspicious activity or you did not send then report please contact the Greensboro representative
immediately. pretreatment(a-)greensboro-NC.gov

City of Greensboro, NC COPY OF RECORD
SemiAnnual SMR Local Pollutant Allocation (LPAD)
Period: 07/01/2023—12/31/2023
Company Name: Procter & Gamble
Submitted Date: January 8, 202411:23:00
Permit Number: P031
Submitted By: Michael McCleary
Address: 6200 Bryan Park Road, Brown Summit, NC 27214
Title: Plant Manager
Samples
Sample Point P031-01
Analyte
Result
Unit
Collection
Start
Collection
End
Collect
Method
Analysis
Method
Analysis
Date
MDL
TSS
280
mg/L
10/30/23 09:00
10/31/23 09:40
Comp
1
SM 2540D
11/7/23
2.5
Zn, T
1.41
mg/L
10/30/23 09:00
10/31/23 09:40
Comp
200.7
11/8/23
0.010
Sample Point P031-02
Analyte
Result
Unit
Collection
Start
Collection
End
Collect
Method
Analysis
Method
Analysis
Date
MDL
TSS
20
mg/L
10/30/23 09:00
10/31/23 10:00
Comp
1
SM 2540D
11/7/23
2.5
Zn, T
8.97
mg/L
10/30/23 09:00
10/31/23 10:00
Comp
200.7
11/9/23
0.010
Compliance Certifications
None
Signatory Certifications
(1) 1 agree that the use of my electronic signature device shall serve as a legally enforceable signature in the
same manner as an original signature on a paper document pursuant to the provisions of the State's relevant
regulations and requirements. I will be held legally bound, obligated, and responsible for my use of my
electronic signature as I would be by using my hand-written signature in submitting an electronic document
to the SwiftComply Pretreatment Solution.
(2) 1 certify under penalty of law that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system,
or those persons directly responsible for gathering the information, the information submitted is, to the best
of my knowledge and belief, accurate and complete. I am an authorized representative of the user and am
authorized to execute this certification on behalf of the user. I am aware that there are significant penalties
for submitting false information in violations of this certification, including the possibility of fines and/or
imprisonment.
Michael McCleary 1/8/2024
Attachments
LaKertification.pdf
FieldCOCRecord.pdf
Procter & Gamble 1 of 3 Submission: January 8, 2024 11:23:00

City of Greensboro, NC
COPY OF RECORD
Meritech, Inc.
Environmental Laboratory
Laboratory certiflration No-165
RECEIVED
JAN 0 8 2024
IN DUSTR!-A L WA ATE
CITY OF { -� 7- -: N5 F30R0
Contact: April Haley Report Date-, 11/10/23
Client: Procter & Gamble Project: 4Q Zn/1'SS
6200 Cryan Park Road P.0 #- 80046 12 5.4 1
Brown Summit, NC 27214 Date Sam p]e Rtvd; 111212023
MeritechWork Order # 110223150 Sample: P031•01Composite 10130-31/23
purameter ResiulS Analyd l} 13eporLineIjinil M902d
Torn] Suspended Solids 2t30 MR j L 11 17 j23 Z-S mg/ L S%11 2 540 D
zinc-, total 1.41 mg/L 11/13/23 0.010 FnWL EPA 200.7
Meriterh Work0rder# 110223151 Sample; P031.02 Composite 10/M-31123
Total Suspended Stshds
20 mg/L
11/7/23
Z.5 mg{L
SM 25+40 D
Zinc,taral
0,97 rig/l.
11/9/23
L1.0111 Mg/L
EPANO-7
l hereby rer ajty that ! have reviewed and approve these doCa-
Labor arary RepresentaUw
64Z Tarnca Road. Reidsville, North Carnlltia 27320
to l , (33 b) 3 4 2 -4748 lax, (3 36)342.15 22
Procter & Gamble 2 of 3 Submission: January 8, 2024 11:23:00

City of Greensboro, NC
COPY OF RECORD
Chain of Custody Record (COC)
+fir NPDES#:
Client: l hr -Y•h�� --- Phone: r�� ,T4 �tf 6191
Address: &r �c.,_LArk Fax:
N I � Email: Mkt4,'Ae Z - y (7 l�,m
Project: `I& -2., / TSS``
P O•#= N 9 6 )2531
A� t)e� Turn Around Time'
Attention: 7 'RUSH work needs pnarapproval,
How would you like your re art sent? F
�� - Std (lo d3v5) � s 74 48 Hr.,
Circle all that apply: Entail (prrterrtdj Fax, Mail r
ER I TE H f INC.
ENVIRONMENTAL LABORATORIES
542 Tamco Rd. Phone: [phone]
Reidsville NC .273z4 Fax: [phone]
4i��cAv,f
Email: info }meritec�tlabs.com
www.meritechiabs.com
Sample Location and/or ID #
Sampling Dates & Times
Person Taking Sample (SignfPrinq:
Lab Use Only
Start
End
°�'° ?
Grab?
Ji of
cant,
Test(s)
Required
Un Ice?
Yes !Flo
pH OK?
Cl00
Date
Time
date
Time
t
S
Tful
ill r61
040o
Erg/3l 23
000
[.
21
'TS5 4 ; C
Temperature Upon
Re-ceipt ,
Method of
Shipment:
p
"* Dechlorination c0.5 nt of Ammonia Cyanide, Phenol and TKN samples
must he done in the field Erior to reservation-
Comments: fl s.0A, ice.
�b �Glr �f
Compositor#
Ijus #
UPS
U Fed Ex
Are these results for regulatory purposes? Yes N, _
Report results in: mglL & -ZAg ugf L
36 Hand Delivery
Relinquished by. , t Dateli_2-£3 throe-16 ") -
Received by. Date: Time:
1
«� Other
Relinquished by Date: Time.,
Recrived by Date_ Time:
Receiv a t S ifr
Relinquished by Date; Titre
Procter & Gamble 3 of 3 Submission: January 8, 2024 11:23:00