NC0020427_Permit (Modification)_20190522

Larry Cobler
Wastewater Plant Operations Director
ROCKINGHAM
A CITY LOOK/NO FORWARD
May 22, 2019
Mr. Monti Hassan
NC Dept. of ENR
Division of Water Resources, PERCS Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
INOI?
Dear Monti,
Enclosed are two copies of Cascades Molded Pulp's IU Permit along with two
copies of the updated allocation table and a copy of the transmittal letter to Cascades
Molded Pulp. The City increased their BOD limits and reduced their flow limits in an
effort to help them stay in compliance with BOD concentrations.
If you have any questions, feel free to call me at 910-895-9434. Thank you.
Sincerely,
rryCobler
Plant Operations Director
City of Rockingham, WWTP
200 Byrd Drive, Rockingham, NC 28379 • Phone [phone] • Fax [phone] • [e-mail]

City of Rockingham
Control Authority and/or Municipality
PERMIT
Industrial User Pretreatment Permit MR)
To Discharge Wastewater Under the
Industrial Pretreatment Program
0012
IUP Number
N/A
40 CFR Category(W Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any
applicable federal categorical pretreatment regulations, all other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Control Authority Sewer Use Ordinance. The following Industry,
hereafter referred to by name or as the ermittee:
Industry name, pennittee:
Cascades Moulded Pulp, A Division of Cascades Holdings US, Inc.
Facility Located at Street Address
112 Cascades Way, PO Box 609 28380
City
Rockingham
State, Zip
North Carolina 28379
is hereby authorized to discharge wastewater from the facility located at the above listed
address into the sanitary sewer collection system and the wastewater treatment facility of
the Control Authority listed below:
UP Control Authority and/or Municipality W WTP name:
City of Rockingham WWTP
NPDES Number.
NCO020427
W WCP Address:
200 B d Drive
City, State, Zip
Rockingham, North Carolina 28379
in accordance with effluent limitations, monitoring requirements, and all other conditions
set forth in Parts I, H, and III of this Industrial User Pretreatment Permit (IUP).
Effective date, this permit and the authorization to discharge shall become
effective at midnight on this date:.
June 1, 2019
Expiration date, this permit and the authorization to discharge sha xpire at
midnight on this date:
June 30.2021
� ,�4 1 . (/ L, = ='
Da igned City

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
A. IUP Basic Information:
Receiving Control Authority & WWTP name :
POTW NPDES # :
City of Rockingham, Rockingham WWTP
NCO020427
IUP Name:
IUP Number:
Cascades Moulded Pulp, A Division of Cascades
0012
Holdings US, Inc.
IUP Effective date:
Pipe Numbers, list all regulated pipes:
June 1, 2019
001
IUP Expiration date:
IUP 40 CFR # (if applicable), or N/A:
June 30, 2021
N/A
B. IUP History. A Complete Permit History is required):
Effective Date
Jan 1, 1997
Renewal or
Modification
Original
Description of changes over previous IUP.
Jul 1, 2001
Renewal w/
Modifications
Modification to BOD and Flow Limits
Jan 17, 2003
Modification
Modification to BOD Limits and included
Requirement for Biocide Certification
Jul 1, 2006
Renewal
Jul 1, 2011
Renewal
Feb 2, 2015
Modification
Modification of Company Name
Jul 1, 2016
Renewal w/
Modification
Added Local Limits for COD, pH, &
Surfactants, Reduced flow
Oct. 1, 2016
Modification
Modification to BOD Limits
June 1, 2019
Modification
Modification to reduce flow limit and increase
BOD limit
IUP 0012 Page 12

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
C.) 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 Control Authority.
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
uid inspection forms.
IU Treatment Units
Dissolved Air Floatation
3.) The Permittee is hereby authorized to, if required by the Control Authority and
after receiving Authorization to Construct from the Control Authority,
construct and operate additional pretreatment units as needed to meet final
effluent limitations.
D.) Description of IUP Discharge(s):
1. Describe the discharge(s) from all regulated pipes.
Pipe #001: Process and domestic wastewater.
E.) Schematic and Monitoring Locations:
The facility sampling point shall be the first manhole outside of plant building.
IUP 0012 Page 13

IUP, Part 1 Section F:
Effluent Limits and Monitoring Requirements
The Permittee may discharge from this specific
Pipe number according to these specific dates,
effluent limits, and monitoring requirements
Receiving POTW name =>
Receiving POTW NPDES # =>
Effective date for these Limits =>
Expiration date for these Limits =>
Rockingham WWTP
NCO020427
06/01/2019
6/30/2021
THELIMITS ON THIS PAGE ARE, (Check one below
LIMITS for ENTIRE permit period => X
INTERIM Limits for period # 1 =>
INTERIM Limits for period # 2 =>
FINAL Limits Page =>
Cascades Moulded Pulp,
IU name =>
A Division of Cascades
Holding US, Inc.
IUP # =>
0012
Pipe # =>
001
40 CFR # =>
N/A
if not applicable put N/A
Concentration Limits
Mass Limits
Monitoring Frequency
Daily Max
Monthly
Average
Units
Daily Max
Monthly
Average
Units
By Industry
By POTW
Sample
Collection
Method
(C or G)
Required
Laboratory
Detection
Level
1
Flow
0.018
0.012
MGD
Continuously
When Sampling
C
2
BOD
3150
2100
m l
Monthly
Monthly
C
2 m I
3
COD
M&R
M&R
mg/l
Monthly
C
2 mg/1
4
TSS
600
400
m 1
Monthly
Monthly
C
2 mg/1
5
pH
6.0-9.0
Eve —Sample
EverySample
G
0.1 SU
OTHER
PARAMETERS; Please List Al habeticall
6
1 Cadmium
M&R
M&R
m 1
Annually
Quarterly
C
0.002 m l
7
Chromium
M&R
M&R
m l
Annually
Quarterly
C
0.005 m l
8
Copper
M&R
M&R
m l
Annually
Quarterly
C
0.002 mg/1
9
Lead
M&R
M&R
m l
Annually
Quarterly
C
0.01 m l
10
Nickel
M&R
M&R
m l
Annually
Quarterly
C
0.01 mgll
11
Surfactant, CTAS
M&R
M&R
m
Monthly
C
2 m 1
12
Surfactant, MBAS
M&R
M&R
m l
Monthly
C
2 mg/1
13
1 Zinc
M&R
M&R
m
Anniudlir
Quarterly
C
0.01 m l
Parameter and prohibitions not included above shall be regulated and limited in compliance with City's Sewer Use Ordinance.
IUP 0012 Page 14

Industrial User Pretreatment Permit (IUP)
PART I
Specific Conditions
G.) Definitions and Limit Page(s) notes:
1.
2.
93
9
5
In addition to the definitions in the City of Rockingham Sewer Use Ordinance the
following definitions and requirements apply:
Composite Sample:
Unless defined differently below, a composite sample for the monitoring
requirements of this IUP, is defined as the automatic or manual collection of
one grab sample of constant volume, not less than 100 ml, collected every
hour during the entire discharge period on the sampling day. Sampling day
shall be a typical production, and discharge day.
Composite Sample, alternative definition:
A composite sample for the monitoring requirements of this IUP is the same
as described above unless specifically defined below as the automatic or
manual collection of constant volume and constant time grab samples
collected and composited according to the following criteria:
specific volume of each grab sample =
specific time interval between samples =
total duration of sample collection period =
Total number of grab samples to be composited =
Daily Monitoring Frequency
Milliliters
Hours
Hours
Samples
Daily Monitoring Frequency as specified in this IUP shall mean each day of
discharge.
Grab Sample
Grab sample for the monitoring requirements of this IUP, is defined as a
single "dip and take" sample collected at a representative point in the
discharge stream.
Instantaneous measurement
An Instantaneous measurement for the monitoring requirements of this IUP is
defined as a single reading, observation, or measurement.
IUP 0012 Page 15

Industrial User Pretreatment Permit (IUP)
PART H
General Conditions
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the
volume and nature of the monitored discharge. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before
the effluent joins or is diluted by any other wastestream, body of water, or
substance. Monitoring points shall not be changed without notification to, and
approval by, the permit issuing authority.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms
specified by the Control Authority, postmarked no later than the twentieth
day of the month following the month in which the samples were taken. If
no discharge occurs during a reporting period (herein defined as each
calendar month) in which a sampling event was to have occurred, a form
with the phrase "no discharge" shall be submitted. Copies of these and all
other reports required herein shall be submitted to the Control Authority and
shall be sent to the following address:
Plant Operations Director
City of Rockingham
514 Rockingham Road
Rockingham, North Carolina 28379
b.) If the sampling performed by the permittee indicates a violation, the
permittee shall notify the Control Authority within 24 hours of becoming
aware of the violation. The permittee shall also repeat the sampling and
analysis and submit the results of the repeat analysis to the Control
Authority within 30 days after becoming aware of the violation.
3. Test Procedures
Test procedures for the analysis of pollutants shall be performed in accordance with
the techniques prescribed in 40 CFR part 136 and amendments thereto unless
specified otherwise in the monitoring conditions of this permit.
4. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this permit, using approved analytical methods as
specified above, the results of such monitoring shall be submitted to the Control
Authority. The Control Authority may require more frequent monitoring or the
monitoring of other pollutants not required in this permit by written notification.
5. Duty to Comply
The permittee must comply with all conditions of this permit. Any permit
noncompliance constitutes a violation of the Control Authority Sewer Use
Ordinance and is grounds for possible enforcement action.
IUP 0012 Page 16

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
6. Duty to Mitigate - Prevention of Adverse Impact
The' permittee shall take all reasonable steps to minimize or prevent any discharge
in violation of this permit which has a reasonable likelihood of adversely affecting
human health, the POTW, the waters receiving the POTW's discharge, or the
environment.
7. Facilities Operation, Bypass
The permittee shall at all times maintain in good working order and operate as
efficiently as possible, all control facilities or systems installed or used by the
permittee to achieve compliance with the terms and conditions of this permit.
Bypass of treatment facilities is prohibited except when approved in advance by the
Control Authority. Bypass approval shall be given only when such bypass is in
compliance with 40 CFR 403.17.
8. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of
treatment or control of wastewaters shall be disposed of in a manner such as to
prevent any pollutants from such materials from entering the sewer system. The
permittee is responsible for assuring its compliance with any requirements regarding
the generation, treatment, storage, and/or disposal of "Hazardous Waste" as defined
under the Federal Resource Conservation and Recovery Act.
9. Upset Conditions
An "upset" means an exceptional incident in which there is an unintentional and
temporary noncompliance with the effluent limitations of this permit because of
factors beyond the reasonable control of the permittee. An upset does not include
noncompliance to the extent caused by operational error, improperly designed or
inadequate treatment facilities, lack of preventative maintenance, or careless or
improper operations.
An upset may constitute an affirmative defense for action brought for the
noncompliance. The permittee has the burden of proof to provide evidence and
demonstrate that none of the factors specifically listed above were responsible for
the noncompliance.
10. Right of Entry
The permittee shall allow the staff of the State of North Carolina Department of
Environment and Natural Resources, Division of Water Quality, the Regional
Administrator of the Environmental Protection Agency, the Control Authority,
and/or their authorized representatives, upon the presentation of credentials:
1. To enter upon the permittee's premises where a real or potential
discharge is located or in which records are required to be kept under the
terms and conditions of this permit; and
IUP 0012 Page 17

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
2. At reasonable times to have access to and copy records required to be
kept under the terms and conditions of this permit; to inspect any
monitoring equipment or monitoring method required in this permit; and
to sample any discharge of pollutants.
11. Availability of Records and Reports
The permittee shall 'retain records of all monitoring information, including all
calibration and maintenance records as well as copies of reports and information
used to complete the application for this permit for at least three years. All records
that pertain to matters that are subject to any type of enforcement action shall be
retained and preserved by the permittee until all enforcement activities have
concluded and all periods of limitation with respect to any and all appeals have
expired.
Except for data determined to be confidential under the Sewer Use Ordinance, all
reports prepared in accordance with terms of this permit shall be available for public
inspection at the Control Authority. As required by the Sewer Use Ordinance,
effluent data shall not be considered confidential.
12. Duty to Provide Information
The permittee shall furnish to the Plant Operations Director or his/her designees,
within a reasonable time, any information which the Director, his/her designee, or
the Division of Water Quality may request to determine whether cause exists for
modifying, revoking and reissuing, or terminating this permit or to determine
compliance with this permit. The permittee shall also furnish, upon request, copies
of records required to be kept by this permit.
13. Signatory Requirements
All reports or information submitted pursuant to the requirements of this permit
must be signed and certified by the Authorized Representative as defined under the
Sewer Use Ordinance. If the designation of an Authorized Representative is no
longer accurate because a different individual or position has responsibility for the
overall operation of the facility, or overall responsibility for environmental matters
for the company, a new authorization satisfying the requirements of this section
must be submitted to the Plant Operations Director prior to or together with any
reports to be signed by an authorized representative.
14. Toxic Pollutants
If a toxic effluent standard or prohibition (including any schedule of compliance
specified in such effluent standard or prohibition) is established under Section
307(a) of the Federal Clean Water Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for
such pollutant in this permit, this permit may be revised or modified in accordance
with the toxic effluent standard or prohibition and the permittee so notified.
IUP 0012 Page 18

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
15. Civil and Criminal Liability
Nothing in this permit shall be construed to relieve the permittee from civil or
criminal penalties for noncompliance.
16. Federal and/or State Laws
Nothing in this permit shall be construed to preclude the institution of any legal
action or relieve the permittee from any responsibilities, liabilities, or penalties
established pursuant to any applicable Federal and/or State law or regulation.
17. Penalties
The Sewer Use Ordinance of the Control Authority provides that any person who
violates a permit condition is subject to a civil penalty not to exceed $25,000 dollars
per day of such violation.
Under state law, (NCGS 143-215.6B), under certain circumstances it is a crime to
violate terms, conditions, or requirements of pretreatment permits. It is a crime to
knowingly make any false statement, representation, or certification in any record or
other document submitted or required to be maintained under this permit, including
monitoring reports or reports of compliance or noncompliance. These crimes are
enforced at the prosecutorial discretion of the local District Attorney.
18. Need to Halt or Reduce not a -Defense
It shall not be a defense for a permittee in an enforcement action that it would have
been necessary to halt or reduce the permitted activity to maintain compliance with
the conditions of the permit.
19. Transferability
This permit shall not be reassigned or transferred or sold to a new owner, new user,
different premises, or a new or changed operation without approval of the City.
20. Property Rights
This permit does not convey any property rights in either real or personal property,
or any exclusive privileges, nor does it authorize any injury to private property or
any invasion of personal rights, nor any infringement of Federal, State or local laws
or regulations.
21. Severability
The provisions of this permit are severable and, if any provision of this permit or
the application of any provision of this permit to any circumstance is held invalid,
the application of such provision to other circumstances and the remainder of this
permit shall not be affected thereby.
IUP 0012 Page 19

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
22. Permit Modification, Revocation, Termination
This permit may be modified, revoked and reissued or terminated with cause in
accordance to the requirements of the Control Authority Sewer Use Ordinance and
North Carolina General Statute or implementing regulations.
23. Re -Application for Permit Renewal
The permittee is responsible for filing an application for reissuance of this permit at
least 180 days prior to its expiration date.
24. Dilution Prohibition
The permittee shall not increase the use of potable or process water or in any other
way attempt to dilute the discharge as a partial or complete substitute for adequate
treatment to achieve compliance with the limitations contained in this permit.
25. Reports of Changed Conditions
The permittee shall give notice to the Control Authority of any planned significant
changes to the permittee's operations or system which might alter the nature,
quality, or volume of its wastewater at least 180 days before the change. The
permittee shall not begin the changes until receiving written approval from the
Control Authority. Also see Part II, 30 below for additional reporting requirements
for spill/slug issues. -
26. Construction
No construction of pretreatment facilities or additions thereto shall be begun until
Final Plans and Specifications have been submitted to the Control Authority and/or
Division of Water Quality and written approval and an Authorization to Construct
have been issued.
27. Reopener
The permit shall be modified or, alternatively, revoked and reissued to comply with
any applicable effluent standard or limitation for the control of any pollutant shown
to contribute to toxicity of the WWTP effluent or any pollutant that is otherwise
limited by the POTW discharge permit. The permit as modified or reissued under
this paragraph may also contain any other requirements of State or Federal
pretreatment regulations then applicable.
28. Categorical Reopener
This permit shall be modified, or alternatively, revoked and reissued, to comply
with any applicable effluent standard or limitation issued or approved under
Sections 302(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if
the effluent standard or limitation so issued or approved:
1.) contains different conditions or is otherwise more stringent than any
effluent limitation in this permit; or
IUP 0012 Page 10

Industrial User Pretreatment Permit (IUP)
PART II
General Conditions
2.) controls any pollutant not limited in this permit.
The permit as modified or reissued under this paragraph shall also contain any other
requirements of the Act then applicable.
29. General Prohibitive Standards
The permittee shall comply with the general prohibitive discharge standards in 40
CFR 403.5 (a) and (b) of the Federal pretreatment regulations.
30. Potential Problems
The permittee shall provide protection from accidental and slug discharges of
prohibited materials and other substances regulated by this permit. The permittee
shall also notify the POTW immediately of any changes at its facility affecting the
potential for spills and other accidental discharge, discharge of a non -routine,
episodic nature, a non -customary batch discharge, or a slug load as defined in the
Sewer Use Ordinance.
Additionally, the permittee shall notify by telephone the Control Authority
immediately of all discharges that could cause problems to the POTW including any
slug loadings as defined in the Sewer Use Ordinance. If the permittee experiences
such a discharge, they shall inform the Control Authority immediately upon the first
awareness of the commencement of the discharge. Notification shall include
location of the discharge, type of waste, concentration and volume if known and
corrective actions taken by the permittee. A written follow-up report thereof shall
be filed by the permittee within five (5) days, unless waived by the Control
Authority.
IUP 0012 Page 111

Industrial User Pretreatment Permit QUP)
PART III
Special Conditions
1. Slug/Spill Control Measures
The permittee shall provide protection from accidental and slug discharges of
prohibited materials and other substances regulated by this permit. The permittee
shall maintain a written slug/spill control plan, which shall include, but is not
limited to:
(a) Description of discharge practices, including non -routine batch discharges
(b) Description of stored chemicals
(c) Procedures for immediately notifying the POTW of slug discharges that
would cause a violation of 40 CFR 403.5(b), with procedures for follow up
notification within 5 days
(d) And 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,
measure for containing toxic organic pollutants (including solvents) and/or
measures and equipment for emergency response.
2. Sludge Management Plan
Ninety days prior to the initial disposal of sludge generated by any pretreatment
facility, the permittee shall submit a sludge management plan 'to the Control
Authority.
3. Flow Measurement Requirements
The permittee shall maintain appropriate discharge flow measurement devices and
methods consistent with approved scientific practices to ensure the accuracy and
reliability of measurements of the volume of monitored discharges. Devices
installed shall be a continuous recording flow meter capable of measuring flows
with a maximum deviation of less than 10% from true discharge rates throughout
the range of expected discharge volumes. The devices shall be installed, calibrated,
and maintained to ensure accuracy. The meter shall be calibrated every six (6)
months. Modifications to the flow metering equipment shall be approved by the
Control Authority prior to installation. If a required flow measurement device fails,
the Control Authority shall be notified within 24 hours.
4. Certified Laboratory Analysis
Pollutant analysis shall be performed by a North Carolina Division of Water Quality
Certified Laboratory that is certified in the analysis of the pollutant in wastewater.
5. Certified Operator
Pursuant to Chapter 90A-44 of North Carolina General Statutes, and upon
classification of the facility by the Certification Commission, the permittee shall
employ a certified wastewater pretreatment plant operator in responsible charge
IUP 0012 Page 112

Industrial User Pretreatment Permit (IUP)
PART III
Special Conditions
(ORC) of the wastewater treatment facilities. Such operator must hold a
certification of the type and grade equivalent to, or greater than the classification
assigned to the wastewater treatment facilities by the Certification Commission.
The permittee must also employ a certified backup operator of the appropriate type
and grade to comply with the conditions of Title 15A, Chapter 8A .0202. The ORC
of the facility must visit the wastewater facility as required; must properly manage
and document daily operation and - maintenance of the facility; and must comply
with all other conditions of Title 15A, Chapter 8A .0202. The permittee shall
submit a letter designating the operator in responsible charge to the Certification
Commission or their designee within thirty days after facility classification.
6. Biocide Certification
Each year the Permittee shall submit to the Issuing Authority certification that the
industry does not use pentachlorophenol or trichlorophenol as a biocide and these
compounds are not present in the discharge.
IUP 0012 Page 113