NC0047384_Pretreatment_IUP_Ecolab_Renewal_20240509

CITY OF GREENSBORO
WATER RESOURCES DEPARTMENT
INDUSTRIAL WASTE SECTION
SIGNIFICANT INDUSTRIAL USER
WASTEWATER DISCHARGE PERMIT
SIU PERMIT NUMBER P078
ECOLAB, INC.
IS AUTHORIZED TO DISCHARGE WASTEWATER
FROM A FACILITY LOCATED AT
8300 CAPITAL DRIVE
GREENSBORO, NORTH CAROLINA
into the City of Greensboro Sanitary Sewer System
to the T.Z. OSBORNE Water Reclamation Facility
[NPDES PERMIT NUMBER NCO047384]
in accordance with the limitations and conditions set forth in this permit.
This permit shall become effective
SEPTEMBER 1, 2023
This permit and the authorization to discharge shall
expire at midnight on
AUGUST 31, 2028
or upon permit reissuance, whichever comes first.
ljo"� ' 81,1iL23
Amy V inoski Date
Pretreatment Coordinator

Page 2, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
INDUSTRY OFFICIAL RESPONSIBLE FOR PERMIT COMPLIANCE
This signatory official shall be responsible for permit compliance, including monitoring, report
submittals, accidental discharge notification, and permit renewal. Although certain of these
activities may be delegated to other individuals, the Signatory Official is ultimately responsible
for compliance with all permit conditions, limits, activities and terms.
I am aware of my responsibilities as Signatory Official and I am aware of the terms and
conditions set forth in this wastewater discharge permit and the City of Greensboro Sewer Use
and Pretreatment Ordinance.
Signatory Official NAME (PLEASE PRINT)
Signatory Official TITLE (PLEASE PRINT)
Signatory Official Signature
Date:
CHANGE OF SIGNATORY OFFICIAL
If there is a change of the Signatory Official for this facility, the City of Greensboro shall be
notified of such change within thirty (30) days. A new page 2, "INDUSTRY OFFICIAL
RESPONSIBLE FOR PERMIT COMPLIANCE" shall be submitted to the Industrial Waste
Section with the name, title and signature of the new official.
September 1, 2023 Permit Renewal

Page 3, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
SECTION I - PERMIT MODIFICATION HISTORY
DATE MODIFIED REASON & DESCRIPTION OF MODIFICATION OR ACTION
January 1, 2021 PERMIT ISSUANCE
PERMIT MODIFICATION
January 24, 2022 Section II.C. —modified Monitoring Location description. Section III—
reduced 6-month average flow to 100,000 gpd; reduced SIU monitoring
for BOD7& COD from 216 months to 116 months.
September 1, 2023 PERMIT RENEWAL
Section IV.G. —removed, subsequent sections relabled.
September 1, 2023 Permit Renewal

Page 4, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
SECTION II - GENERAL INFORMATION
A. Description of Discharge
Pipe 01 —Process Wastewater from cleaning, equipment use, and facility wash down from soap
and detergent product manufacturing
Pipe 01 does not include domestic waste discharge.
B. Authorization Statement
1. The permittee is hereby authorized to discharge wastewater in accordance with the effluent
limitations, monitoring requirements, and all other conditions set forth in this Industrial User
Pretreatment Permit(IUP) into the sewer collection system and wastewater treatment facility of
the City of Greensboro.
2. The permittee is hereby authorized to continue operation of and discharge wastewater from the
following treatment or pretreatment facilities. These facilities must correspond to the treatment
units listed on both the application and inspection forms.
Solids Removal-Filtration
Flow Equalization Tanks
Spill Protection
3. The permittee is hereby authorized to, if requested by the City of Greensboro and after
receiving Authorization to Construct(A to C) from the City of Greensboro, construct and operate
additional pretreatment units as needed to meet final effluent limitations.
C. Monitoring Location
Bulk Storage 1 room adjacent to the sump tank. All permit compliance and surcharge sampling
will be conducted at this this location. Effluent Flow meter is located in this area.
D. Composite Sampling Technique
Soap &Detergent Categorical regulated parameters shall be taken as composite samples.
A composite sample for the purposes of this permit is:
A Flow Proportional Composite sample taken over the entire work/discharge day by an automatic
sampler interfaced with the effluent flow meter.
September 1, 2023 Permit Renewal

Page 5, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
SECTION III - EFFLUENT LIMITS AND MONITORING REQUIREMENTS
Effluent Limits and Monitoring Requirements for Pipe 01
THIS FACILITY IS REGULATED BY THE FEDERAL CATEGORICAL
PRETREATMENT STANDARDS FOR SOAP and DETERGENT MANUFACTURING
[40 CFR 417.166 Subpart P—Manufacture of Liquid Detergents]
[40 CFR 417.176 Subpart Q—Manufacture of Detergents by Dry Blending]
[40 CFR Part 417.196 Subpart S—Manufacture of Detergent Bars and Cakes]
EFFLUENT LIMITATIONS MONITORING FREQUENCY
EFFLUENT Daily 6- Month Sample CITY OF
CHARACTERISTICS Maximum Average Type PERMITTEE GREENSBORO
Flow (gallons per day) 100,000 # DAILY
BOD7 m /1 See Limits in Special C 1/6 months 1/ ear
COD m 1 Permit Condition A C 1/6 months 1/ ear
H standard units 5.0— 12.0 Grab 1/6 months
BODS++ m /1 M C 1/6 months
Suspended Solids++ M C
1/6 months
(mg/1)
Total Cadmium m /1 M C 1/6 months
Total Chromium m /1) M C 1/6 months
Total Copper m /1 M C 1/6 months
Total Lead m /1 M C 1/6 months
Total Nickel m /1 M C 1/6 months
Total Zinc m /1 M C 1/6 months
Total Silver m /1 M C 1/6 months
Total Selenium m /1 M C 1/6 months
Total Cyanide m /1 M C 1/6 months
#The Greensboro Industrial Waste Section does not consider Flow to be a pollutant and
flow data is not considered to be a report.
++All BOD concentrations over 200 mg/1 and all Total Suspended Solids concentrations
over 200 mg/1 are subject to an Industrial Waste Surcharge.
C - Composite Sample [See Section II Part D for permit-specific definition]
G - Grab Sample
M- Monitoring Only [See Local Pollutant Allocation Document to determine if an
Allocation has been issued for this parameter]
September 1, 2023 Permit Renewal

Page 6, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
SECTION IV - SPECIAL PERMIT CONDITIONS
A. Federal Categorical Pretreatment Standards for Soap and Detergent Manufacturing
40 CFR 417.166 Subpart P - Manufacture of Liquid Detergents
"There shall be no discharge of wastewater streams in which both the COD/BOD7 ratio
exceeds 10.0 and the COD exceeds 1.10 kg/kkg of anhydrous product." [1.10 kg/kkg= 1.10
lbs/1000 lbs]
40 CFR Part 417.176 Subpart Q—Manufacturing of Detergent by Dry Blending
"There shall be no discharge of wastewater streams in which both the COD/BOD7 ratio
exceeds 10.0 and the COD exceeds 0.26 kg/kkg of anhydrous product." [0.26 kg/kkg= 0.26
lbs/1000 lbs]
40 CFR Part 417.196 Subpart S—Manufacture of Detergent Bars and Soaps
"Comply with 40 CFR Part 403" [No additional discharge standards]
Note: The term anhydrous product shall mean the theoretical product that would result if all water
were removed from the actual product.
Compliance Calculations:
- Wastestreams from the 3 subparts are combined prior to discharge.
- A Weighted Alternative COD Anhydrous Standard was calculated.
Ecolab Soap and Detergent Products Applicable Pounds Total Pounds by
Federal Standard CY 2019 Subcategory
All Liquid Product Packaging Lines Subpart P 250,471,688 250,471,688
Dry Packaging, All Fill, Small Subpart Q 10,876,759 10,876,759
Blender
Pressed Solids Subpart S 10,867,906 27 807,398
Extruded Solids 16,939,492
TOTAL DETERGENT POUNDS 289,155,845
COD/BOD7 ratio Standard Calculation
- Take COD value and BOD7 value for same sampling date and calculate ratio
- If the result is <10.0, the wastestream is compliant with this criteria
COD kg/kkg Anhydrous Product Standard Calculation
- Convert COD values to production values in kg/kkg for compliance judgment with Federal
Standard. Take the COD in mg/l divided by 1000.
- Compare value to Weighted Alternative COD Anhydrous Standard below
September 1, 2023 Permit Renewal

Page 7, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
COD Anhydrous Product Standard: The following Production Weighted Alternative Standard was
calculated for each regulated subpart based on CY 2019 weighted annual production.
40 CFR production 40 CFR Part 417 Weighted Alternative
Part Pounds % of Total COD Anhydrous COD Anhydrous
417 (CY2019) Pounds Standard (kg/kkg) Standard
Subpart (kg/kkg)
P 250,471,688 86.62 1.10 .9528
Q 10,876,759 3.762 0.26 0.00978
S 27,807,398 9.617 0.26 (IWS BPJ) 0.025
289,155,845 0.9876
CY 2019 Total Pounds)
Although Subpart S has no discharge limitations, in order to treat it as an unregulated wastestream
rather than a dilution wastestream, it was assigned the same COD Anhydrous Standard as
Subpart Q, based on Best Professional Judgment (BPJ).
This Alternative Categorical standard will be evaluated after one year to determine if separation
of the wastestream into two separate discharges is warranted.
This alternative Categorical standard will also be evaluated and re-assessed when there is a 20%
or more change in the production lines output of either the liquid or dry-blend detergent
processes.
B. FLOW MEASUREMENT
Compliance with the flow limit in this permit shall be documented in the following manner:
1. The Permittee shall provide and maintain a refrigerated composite sampler and primary
flow measurement device for flow proportional sampling and flow measurement of the
permittee's process wastewater discharge.
2. The effluent process flow meter readings shall be recorded daily and the daily effluent flow
calculated in gallons per day. Flow measurement records shall be submitted to the City of
Greensboro Industrial Waste Section monthly. Data is to be submitted by the 15th of each
month for the previous month's flow measurements.
3. The permittee shall maintain permanent flow records and maintenance and calibration
records on-site for a minimum of three years. These records shall be available to the City of
Greensboro Industrial Waste Section during inspections or upon request.
4. Immediate notification, within 24 hours of becoming aware of the problem, shall be provided
to the Pretreatment Coordinator [336-433-7227] or Pretreatment Compliance Specialist [336-
September 1, 2023 Permit Renewal

Page 8, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
373-3285] by phone or e-mail for any periods in which the effluent meter is inoperable with
the exception of periods for maintenance/calibration. This notification shall include the cause
of the malfunction/failure, anticipated repair time and/or plan of action to allow the permittee
to comply with the requirement to record the flow meter readings daily.
5. Malfunction/failure of effluent flow meters that are used for sewer billing purposes shall
also be immediately reported, within 24 hours of becoming aware of the problem,to the
Water Resources Customer Service Division by phone---Assistant Manager [336-373-4108]
or Manager [336-373-2639]. Failure to do so will result in the Industrial Waste Section and
the Water Resources Customer Service Division reverting back to the incoming water meter to
determine compliance and billing.
6. The wastewater meter must have a non-resettable totalizer that reads in cubic feet or
gallons. There shall be no by-pass capability of the wastewater metering devices and
monitoring point(s).
7. If the wastewater meter is being used for billing or compliance, it must have permanent flow
records (i.e. strip chart recordings)that include at minimum the following basic information:
date, time, totalizer reading (with units), interval flow volume(with units), maximum flow
rate (with units), and primary measuring device type. Any interruption in such records with
the exception of periods for maintenance/calibration are a violation of this permit and may
result in a civil penalty each day the interruption is allowed to continue.
8. The wastewater meter shall have a back-up power source (battery or generator)to ensure
uninterrupted measurement of the discharge flow in the event of a power failure unless loss of
power automatically prevents any discharge from the facility. The back-up source shall
provide power to the wastewater meter's sensor and permanent flow records for a minimum of
12 hours.
C. PERMITTEE SAMPLING AND MONITORING REPORT SUBMITTAL DATES
Permittee Sampling for the pollutant limitations in Section III (Effluent Limits and Monitoring
Requirements) of this permit shall be conducted in the following manner:
1. Samples for the January 1-June 30 Reporting Period shall ALL be taken during the
months of January, February and/or March. The compliance report shall be submitted on
or before APRIL 15 of each year.
2. If there are no discharges during months designated for sampling, the April 15 compliance
report shall be submitted with the notation"NO DISCHARGE/NO SAMPLING". If there
is a discharge after March and prior to June 30, self-monitoring is still required to meet the
permit monitoring requirements and that data shall be submitted with the corresponding
monthly flow data.
September 1, 2023 Permit Renewal

Page 9, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
3.Samples for the July 1-December 31 Reporting Period shall ALL be taken during the
months of July, August and/or September. The compliance report shall be submitted on or
before OCTOBER 15 of each year.
4. If there are no discharges during months designated for sampling, the October 15
compliance report shall be submitted with the notation"NO DISCHARGE/NO
SAMPLING". If there is a discharge after September and prior to December 31, self-
monitoring is still required to meet the permit monitoring requirements and that data shall
be submitted with the corresponding monthly flow data.
5. If there are no discharges during an entire semi-annual reporting period, a letter must be
submitted to the Industrial Waste Section by July 15 or January 15 stating there was no
discharge and no sampling for that period. This letter must be signed and certified by the
signatory official.
D. SIGNATORY REQUIREMENTS FOR INDUSTRIAL USER REPORTS
All self-monitoring and re-sampling data submitted for compliance to the City of Greensboro
shall include the certification statement below and shall be signed by the person on-site at the
facility who is authorized to represent the company in an official capacity concerning matters that
involve the City of Greensboro Industrial Waste Section ("Signatory Official").
I certify under penalty of law that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for
knowing violations. [40 CFR Part 403.6]
E. SLUG/SPILL CONTROL PLAN
The permittee shall provide protection from accidental and slug discharges of prohibited materials
and other substances regulated by this permit, which have a reasonable potential to cause
Interference or Pass Through, or in any other way violate the POTW's regulations, local limits or
Permit conditions.
The permittee shall notify the Industrial Waste Section immediately of any changes at its facility
affecting potential for a Slug Discharge.
The permittee shall submit a new or updated slug/spill control plan for approval when so directed
in writing by the City of Greensboro Industrial Waste Section. The plan shall contain, at a
minimum the following elements:
September 1, 2023 Permit Renewal

Page 10, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
■ Description of discharge practices, including non-routine batch discharges;
■ Description of stored chemicals;
■ Procedures for immediately notifying the POTW of slug discharges that would cause a
violation of 40 CFR Part 403.5(b) [EPA Specific Prohibitions included in Greensboro SUO
Article 1I, Section 1. B.], with procedures for follow up written notification within 5 days;
■ If necessary, procedures to prevent adverse impact from accidental spills, including
inspection and maintenance of storage areas, handling and transfer of materials, loading and
unloading operations, control of plant site run-off, worker training,building of containment
structures or equipment, measures for containing toxic organic pollutants(including
solvents) and/or measures and equipment for emergency response.
Any current slug/spill control plan developed by the permittee and approved by the City of
Greensboro is hereby incorporated as a condition of this Significant Industrial User Permit.
F. FLOW METER CALIBRATION/VERIFICATION
Flow meters used for flow monitoring under this permit shall be calibrated in accordance with
manufacturer's recommendation by an independent contractor or a Greensboro Industrial Waste
Section approved in-house technician. Calibration documentation shall be maintained for a
minimum of three (3) years and made available upon request and during on-site inspections.
1. Industries with a highly-accurate (<0.5% variance) flow meter, such as a magnetic or
ultrasonic (Doppler and transit) meter, must have the meter calibrated/verified once every
five years.
2. Industries with effluent wastewater meters that are used for City of Greensboro sewer
billing purposes, must calibrate the meters annually. Permanent records in the form of
electronic data trend sheets, strip or circular chart recordings that have back-up and fail-
safe capabilities are also required to be maintained.
3. Any industry may conduct meter calibration more frequently than required in this permit.
The following flow meters/systems have no calibration requirements:
1. Industries with custom built Memtek0 pretreatment systems have a permanently calibrated
flow measurement system (as long as the plumbing remains intact and the viscosity of the
liquid does not change) and no calibration is required.
2. Industries with a non-discharge closed-loop system are not required to have any meter on
the system calibrated.
3. Industries that record daily flow from a City of Greensboro owned, maintained, and
calibrated incoming potable water meter are not required to have the meters calibrated.
4. The Industrial Waste Section does not require deduct meters to be calibrated.
Industries with an electronic data base with power back-up do not need to maintain redundant
paper recorders.
September 1, 2023 Permit Renewal

Page 11, SIU Permit#P078
ECOLAB, INC.
Effective September 1, 2023
G. BOD7 Analytical Testing
From U. S. Environmental Protection Agency 40 CFR Part 417 Soap and Detergent
Manufacturing Website: ...BODE refers to the oxygen demand as determined by incubation at
20°C for a period of 7 days using an acclimated seed. The parameter BODE is used in subparts
P,O, Q, and R [of the Soap and Detergents Categorical Standard].There is no approved
analytical method for BOD7 in EPA's test procedures regulation at 40 CFR Part 136. There
is a method available in Standard Methods, no. SM 5210C, which is called"Ultimate BOD Test"
that can be run for [up to] 90 days.
The City of Greensboro hereby allows Ecolab to use an unapproved method for the BOD7 test.
September 1, 2023 Permit Renewal