NC0047384_Pretreatment_IUP_PGBrown02_Renewal_20240509

CITY OF GREENSBORO
WATER RESOURCES DEPARTMENT
INDUSTRIAL WASTE SECTION
SIGNIFICANT INDUSTRIAL USER
WASTEWATER DISCHARGE PERMIT
SIU PERMIT NUMBER P031-02
PROCTER AND GAMBLE SKIN CARE
IS AUTHORIZED TO DISCHARGE WASTEWATER
FROM A FACILITY LOCATED AT
6200 BRYAN PARK ROAD
BROWN SUMMIT, 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.
4'N' Oat
Amy V 'noski Date
Pretreatment Coordinator

Page 2, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
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.

Page 3, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
SECTION I—PERMIT MODIFICATION HISTORY
DATE MODIFIED REASON & DESCRIPTION OF MODIFICATION OR ACTION
May 1, 2016 PERMIT ISSUED
PERMIT RENEWAL
Transferred 100,000gpd of flow from Pipe 02 to Pipe 01 (Pipe 02 now
limited to 100,000gpd and Pipe 01 now limited to 550,000gpd); Special
September 1, 2018 Conditions Changes:Added Flow Measurement Calibration/ Verification
Section; Modified Flow Language; Added Combined Limitation
Calculations Section; Modified Cyanide Certification language; Modified
Annual Chemical Reconfirmation Analyses language.
September 1, 2023 PERMIT RENEWAL

Page 4, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
SECTION II - GENERAL INFORMATION
A. Description of Discharge
Pipe 02—Process Wastewater from mixing, compounding, and packaging of consumer products.
Pipe 02 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.
Flow Equalization
Dissolved Air Floatation [DAF]
Flocculation
Neutralization, pH adjustment
Solids Removal—Centrifuge
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
Samples shall be taken from the automatic ISCO 6712 FR Refrigerated Sampler located at the
Used Water Treatment Plant and connected to the final equalization tank.
D. Composite Sampling Technique
Pharmaceutical Categorical regulated parameters shall be taken as grab samples.
The automatic sampler shall be used to collect flow-proportional Composite samples for
compliance. The City of Greensboro performs all routine compliance sampling for Local
Pollutant Allocations for this facility.

Page 5, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
SECTION III - EFFLUENT LIMITS AND MONITORING REQUIREMENTS
Effluent Limits and Monitoring Requirements- Pipe 02
THIS FACILITY IS REGULATED BY THE FEDERAL CATEGORICAL
PRETREATMENT STANDARDS FOR PHARMACEUTICAL MANUFACTURING
[40 CFR 439.36 Subpart C - Chemical Synthesis]
40 CFR 439.46 Subpart D—Mixing and Compounding]
EFFLUENT EFFLUENT LIMITATIONS MONITORING FREQUENCY
CHARACTERISTICS Daily 6-Month Sample PERMITTEE CITY OF
Maximum Average Type GREENSBORO
Flow (gallons per day) 100,000 # DAILY
H standard units 5.0— 12.0 Grab 1/6 months
BOD++ m /1 M C 1/6 months
Suspended Solids++(m /1) M C 2/6 months 1/6 months
Cadmium T m /1 M C 1/6 months
Chromium T m /1 M C 1/6 months
Copper T m /1 M C 1/6 months
Lead T m /1 M C 1/6 months
Nickel T m /1 M C 1/6 months
Zinc T m /1 M C 2/6 months 1/6 months
Silver T m /1 M C 1/6 months
Selenium T m /1 M C 1/6 months
Cyanide (total) (mg/1) M Grab 1/6 months
Acetone (mg/1) 20.7 8.2 Grab 1/6 months 1/year
Ethyl acetate (mg/1) 20.7 8.2 Grab 1/6 months 1/year
n-Amyl acetate (mg/1) M Grab 1/year***
Isopropyl acetate (mg/1) M Grab 1/year***
Methylene Chloride (mg/1) M Grab 1/year***
ALL METALS ARE TO BE ANAL YZED AS TOTAL[TJ
#The Greensboro Industrial Waste Section does not consider flow to be a pollutant and
flow data is not considered 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
***See Section IV -Special Permit Conditions: Annual Chemical Analysis Reconfirmation
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]

Page 6, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
SECTION IV - SPECIAL PERMIT CONDITIONS
A. FLOW MEASUREMENT
Compliance with the flow limit in this permit shall be documented in the following manner:
1. The Permittee shall provide and maintain a refrigerated composite sampler and primary flow
measurement device for flow proportional sampling and flow measurement of the permittee's
process wastewater discharge.
2. The effluent process flovv 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-
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.

Page 7, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
8. The wastewater meter shall have a back-up power source (battery or generator) to ensure
uninterrupted measurement of the discharge flow in the event of a power failure unless loss
of power automatically prevents any discharge from the facility. The back-up source shall
provide power to the wastewater meter's sensor and permanent flow records for a minimum
of 12 hours.
B. PIPE 01 AND PIPE 02 COMBINED LIMITATION COMPLAINCE CALCULATIONS
Compliance with Flow limitations, BOD allocations, TSS allocations, and Zinc allocations will
be calculated using combined data from Pipe 01 and Pipe 02. Total effluent flow is not to
exceed the combined total flow limit for both pipes. Total BOD,total TSS, and Total Zinc
loading is not to exceed combined total allocation for both pipes.
C. ANNUAL CHEMICAL ANALYSIS RECONFIRMATION
An annual chemical analysis [for all 5 pollutants regulated under 40 CFR Part 439.46] of
wastewater from the effluent sample location must be performed yearly to reconfirm the absence
of a pollutant. In order to reconfirm the absence of a pollutant, the chemical analysis must show
that the pollutant is less than the detectable value of the certified lab. In the event that a certified
parameter is detected in the annual chemical analyses reconfirmation or is expected to be
present based on changes that occur in the permittee's operations, the permittee shall
immediately notify the Control Authority.
D. TEST METHODS
On September 21, 1998 in conjunction with the promulgation of the Federal Categorical
Pretreatment Standards for the Pharmaceutical Manufacturing Category [40 CFR Part 439], EPA
amended 40 CFR Part 136 [Approved Test Methods for Wastewater Analysis] to include Table
IF-List of Approved Methods for Pharmaceutical Pollutants.
EPA recommends that some of the organic pollutants regulated under 40 CFR Part 439 be
analyzed using EPA Method 1666. However, as of the issuance date of this permit, the State of
North Carolina Division of Water Resources does not certify wastewater laboratories for Method
1666. [The North Carolina Pretreatment Regulations require that all pretreatment compliance
samples be analyzed by a laboratory certified by the State of North Carolina to conduct the
analysis.] Therefore, the permittee is hereby granted permission to use the following test
methods to comply with 40 CFR Part 439.

Page 8, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
1. Pharmaceutical Organics Parameter Sampling and Test Procedures:
Sampling by the permittee may consist of one single grab sample for compliance judgment.
Test procedures for the analysis of pollutants shall conform to regulations published by the
United States Environmental Protection Agency (US EPA) pursuant to 40 CFR Part 136 under
which such procedures may be required. The categorical regulated parameters must be analyzed
using appropriate test methods listed in Table IF of 40 CFR 136.3. Alternate methods [i.e.
Method 624 and 625 or 524.2] may be used as long as the method meets the QA/QC
requirements of the applicable Table IF method (see 40 CFR 136.4), and the lab has approval
from NC DWR Laboratory Certification Unit to use the alternative method for the applicable
parameter [copy of approval letter is required]. Detection levels generated by the chosen method
must be low enough to judge compliance with limits contained within Section II of this permit.
E. PHARMACEUTICAL ORGANIC PARAMETERS NOT USED OR GENERATED
The permittee has submitted documentation under 40 CFR 439.2 that the following parameters
are neither used nor generated at the facility.
Federal Categorical Standards
PARAMETER 40 CFR 439.46 (mg/1)
Daily Maximum Monthly Average
n-Amyl acetate 20.7 8.2
Isopropyl acetate 20.7 8.2
Methylene chloride 3.0 0.7
The following statement shall be submitted along with the reconfirmation data to the City of
Greensboro Industrial Waste Section annually:
"The Annual Chemical Reconfirmation Analyses ivere performed on[insert date]and based
upon my inquiry of the person or persons directly responsible for managing compliance with
Pretreatment Standards for 40 CFR Part 439, I certify that, to the best of my knowledge and
belief, there have been no changes in the processes at our facility that would result in the use
or generation of the parameters listed in this Special Condition since filing of the last
certification. "
The Chemical Reconfirmation Analyses must be conducted once each calendar year. The data
and certification statement must be signed and certified and shall be submitted to the City IWS
by the end of the calendar year. Any parameter detected in the Reconfirmation Analyses can
result in reopening this SIUpermit to include limits and additional monitoring for that
parameter.

Page 9, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
F. PERMITTEE SAMPLING AND MONITORING REPORT SUBMITTAL DATES
Permittee Sampling for the pollutant limitations in Section III (Effluent Limits and Monitoring
Requirements) of this permit shall be conducted in the following manner:
1. Samples for the January 1-June 30 Reporting Period shall ALL be taken during the
months of January, February and/or March. The compliance report shall be submitted on
or before APRIL 15 of each year.
2. If there are no discharges during months designated for sampling, the April 15
compliance report shall be submitted with the notation"NO DISCHARGE/NO
SAMPLING". If there is a discharge after March and prior to June 30, self-monitoring is
still required to meet the permit monitoring requirements and that data shall be submitted
with the corresponding monthly flow data.
3. Samples for the July 1-December 31 Reporting Period shall ALL be taken during the
months of July, August and/or September. The compliance report shall be submitted on
or before OCTOBER 15 of each year.
4. If there are no discharges during months designated for sampling, the October 15
compliance report shall be submitted with the notation "NO DISCHARGE/NO
SAMPLING". If there is a discharge after September and prior to December 31, self-
monitoring is still required to meet the permit monitoring requirements and that data shall
be submitted with the corresponding monthly flow data.
If there are no discharges during an entire semi-annual reporting period, a letter must be
submitted to the Industrial Waste Section by July 15 or January 15 stating there was no discharge
and no sampling for that period. This letter must be signed and certified by the signatory official.
G. 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 knoiving violations.

Page 10, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
H. 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 may 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 the 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 include, but is not
limited to:
■ 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 II, 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.
1. 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.

Page 11, SIU Permit#P031-2
PROCTER AND GAMBLE SKIN CARE
Effective September 1, 2023
The following flow meters/systems have no calibration requirements:
1. Industries with custom built Memtek©pretreatment systems have a permanently
calibrated flow measurement system (as long as the plumbing remains intact and the
viscosity of the liquid does not change) and no calibration is required.
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.