NC0024147_Pretreatment Annual Report_20220224

RECEIVED
r L. 2 4 2022
NCDEQIDWRINPDES
CITY OF SANFORD
2021 PRETREATMENT ANNUAL REPORT
Protecting Our Waters
it II MI iit a
• ,► 4
4
•
•
* , Ifir •,„,.„ i
„r e -k ,
„, .,
_ tz *
__ _. , :ek,l i
ik r......, ..,
40 . i
L'Icri ,T,1
v.:....i-- •
, ff i
0,41 .
11 .
4
" , °"4IPTERE11 ��
'' a . . it • urs

P.0.Box 3729 PHONE[phone]
Sanford,NC 27330 Fax [phone]
eitp of ianforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
February 18, 2022
Michael Montebello
Division of Water Quality, PERCS
1617 Mail Service Center
Raleigh,N.C. 27699-1617
RECEIVED
-rt 2 4 2022
RE: 2021 Pretreatment Annual Report
NCDEC�IDW�NPDES
Dear Mr. Montebello
The City of Sanford is submitting two(2)copies of the Big Buffalo Creek WWTP's Pretreatment Annual Report(PAR).
The following describes our pretreatment activities for the calendar year of.202&.The report is believed to be accurate and
complete. 3cial
The PAR is being submitted in accordance with the terms and conditions of the NPDES permit NC 0024147 and with
15A NCAC 2H .0908(b).
If there are questions or comments please feel free to contact me at(919)777-1783.
Sincerely,
C�J
Sarah Jordan
Pretreatment Coordinator
City of Sanford
Enclosures

(", nw
CITY OF SANFORD
ANNUAL PRETREATMENT PROGRAM REPORT
Report Date: 2/18/2022
Period Covered by This Report: from January 1, 2021 to December 31, 2021
Period Covered by Previous Report: from January 1, 2020 to December 31, 2020
Name of Wastewater Treatment Plant(s) NPDES Permit Number
Big Buffalo Creek NC0024147
Non-Discharge Permit Number
WO 0020248
Person to contact concerning information contained in this report:
Name: Scott A. Siletzky
Title: Water Reclamation Facility Administrator
Mailing Address: City of Sanford
P.O. Box 3729
Sanford,N.C. 27331-3729
Telephone # [phone]
I have personally examined and am familiar with the information submitted in
this document and attachments. Based upon my inquiry of those individuals
immediately responsible for obtaining the information reported herein, I believe
that the submitted information is true, accurate and complete. I am aware that
there are significant penalties for submitting false information.
February 18,2022 ` r,
Date Signature of 0 ►,6'a0"----

NARRATIVE
1. General Information:
A. Program Information
a) The Allocation Table (AT), Enforcement Response Pla
n (ERP), Head-
work's Analysis (HWA), Industrial User Permits (IUP), Industrial
Waste Survey (IWS), Long Term Monitoring Plan (LTMP), and Sewer
Use Ordinance (SUO) are all up to date.
AT -- The City of Sanford's Allocation Table was last approved on
2/22/2018 and last updated on 12/10/2021. The updated copy is in-
cluded in this PAR.
ERP -- The ERP was revised and submitted to the Division February
15, 2015. The plan has been implemented as required by Section IV,
C, 9 of NPDES Permit number NC0024147. Documentation of the
Division's approval was included in the 2009 PAR. A copy of the
ERP has been submitted to all the significant industrial users.
HWA— The most recent headworks analysis was approved February
22, 2018. A new headworks analysis will be submitted to the Division
by May 1, 2022.
IUP —There are 11 SIUs discharging to the POTW, 9 of which are
deemed as Categorical Industrial Users (CIUs). The permit cycle ends
September 30, 2024.
IWS —Division approval of the IWS was received on August 10, 2018.
The next IWS will be conducted by August 1, 2023.
LTMP— The LTMP received Division approval on March 12, 2015.
SUO -- The City of Sanford revised and submitted the local ordinance
and PERCS check list to the Division on December 20, 2011. The SUO

was revised to incorporate changes that the State had made to the
NCAC 15A 02H .0900 - Local Pretreatment Programs regulations.
The City received approval of the revisions on January 25, 2012. The
Attorney's Statement, Documentation of Council adoption, and the
adopted SUO were submitted to complete the SUO requirements on
February 4, 2013.
The 2021 PAR was received February 2, 2021 (letter dated July
29, 2021). Additional information was submitted July 8th 2021.
The City received approval for the 2021 PAR July 29th 2021 from
Ms. Vanessa Manuel of the Raleigh Regional Office.
The last pretreatment audit was conducted on September 17, 2021
by Cheng Zhang of the Raleigh Regional Office. The findings and
this report are included in this PAR.
B. Permit Information
1. All permits expire September 30, 2024.
Magneti Marelli was officially shutdown in December of 2021.
Magneti Marelli halted production in July 2021. The approved
drop request, dated January 14th 2022. is included in this PAR.

SIU Information
A. SIU'S in SNC
There was one industry, Arauco, in SNC for the period ending Jan-
uary-June 2021
There was one industry, Charah, in SNC ending July-December
2021.
B. Reason for and period of SNC
1. Arauco was judged as SNC on July 23, 2021.They violated sev-
eral parameters that had a monthly average limit. Further infor-
limit violations, late reporting, and invalid samples during the Ju-
ly-December 2021 period. Discussion about their status as SNC
and violations are ongoing.
C. Permit requirement Violations
January thru June
1/21- Hydro Tube had a low pH violation
2/25-2/27- Caterpillar, Womack site, had 3 flow overages.
3/1-Low pH during City sampling at Magneti Marelli
3/5-High pH during City sampling at Magneti Marelli
5/18- Caterpillar(Womack) had 5 high flow readings
6/22- Caterpillar(Womack) had 3 high flow readings
Arauco judged SNC for this period. See above information.
July thru December
7/15- STI had a flow overage
9/13- Caterpillar(Womack) flow overage
9/21- Arauco had overages for zinc and copper
9/21- Hydro Tube didn't submit August flow data on time
10/1- Coty had 2 flow overages

10/6- Caterpillar(Womack) had a flow overage
11/3-11/11- Caterpillar (Boone Trail) power outage, no notice
11/17-Charah had a molybdenum overage and didn't submit a hard copy
of September flows
Charah judged as SNC during this period. See above information.

D. AtoC
There were two Authorizations to Construct submitted in the 2021 cal-
endar year.
3/12/2021- Wyeth replaced a flow meter for pipe 02. A response letter
wasn't submitted as it was more of a repair vs. construction. All infor-
mation pertaining to this A to C is included in this PAR.
12/8/21- Caterpillar(Womack) installing a new metering pump to dis-
pense an anti-foaming solution to prevent future NOVs from false high
readings. This A to C is included in this PAR.
Orders and Schedule Information
There were no Orders or Schedules submitted or issued during the January
thru June reporting period.
There were no Orders or Schedules submitted or issued during the July thru
December reporting period.

Public Notice
1. There were ONE industry in SNC for the period ending Janu-
ary-June 2021. (Information included in this PAR).
2. There was ONE industry in SNC for the period ending July-
December 2021. (Information included in this PAR).

hist
yo _ _ 6 REPORT
Sanford
2014 2015 2016 2017 2018 2019 2020
1st half 12nd half 1st half I 2nd half 1st half I 2nd half 1st half I 2nd half 1st half 12nd half 1st half 12nd half 1st half 12nd half
Magneti Marelli Powertrain USA, Inc. PreviousNames:
IUP# 0007 Pipe# 001,002 SIU Word Description:
433+463+464
IUP_Status:IUP# 0007
Reporting I I I I I I XI
ASC/Trion PreviousNames: Trion,Inc.
IUP# 0013 Pipe# 1 SIU Word Description:
metals
IUP_Status:IUP# 0013
Reporting I I I I I IX XI
STI Polymer PreviousNames: Salden Technologies
IUP# 0032 Pipe# 01 SIU Word Description:
chemicals,OCPSF,Plaatics
IUP_Status: IUP# 0032
Cyanide I XI I I I I I
Caterpillar Paint& Plating Operations PreviousNames:
IUP# 0033 Pipe# 01 SIU Word Description:
Metals,Finishing
IUP_Status:IUP# 0033
Cyanide I I XI I I I I
Hydro Tube Enterprises Inc. PreviousNames:
IUP# 0034 Pipe# 01 SIU Word Description:
metals
IUP_Status:IUP# 0034
Reporting I I I I IX IX I
ASC/Trion PreviousNames: Trion,Inc.
IUP# 0013 Pipe# 02 SIU Word Description:
metals
IUP_Status: IUP# 0013
Reporting I I I I I IX XI
An'X'In a semi-annual period Indicates snc for the period for the respective parameter.
PRINTED ON:12/7/2021 This information is compiled from many sources,and has not been verified. PAGE 59
Contact the local pretreatment coordinator or state pretreatment staff if errors are noted.

hist�
- _ at
s REPORT
Charah, Incorporated PreviousNames:
IUP# 0035 Pipe# 01 SIU Word Description:
Combustion Residual Leachate
IUP_Status:IUP# 0035
Reporting I I X I I I I I
Caterpillar Inc. PreviousNames:
IUP# 000040 Pipe# 001,002 SIU Word Description:
IUP_Status:IUP# 000040
Reporting I I I I IX I I
Tyson Foods Inc. Mexican Original PreviousNames:
IUP# 0041 Pipe# 01 SIU Word Description:
Food
IUP_Status:IUP# 0041
Reporting I I I I I I XI
Hydro Tube Enterprises Inc. PreviousNames:
IUP# 0034 Pipe# 02 SIU Word Description:
metals
IUP_Status:IUP# 0034
Reporting I I I I I IX I
An'X'In a semi-annual period Indicates snc for the period for the respective parameter.
PRINTED ON: 12/7/2021 This information is compiled from many sources,and has not been verified. PAGE 60
Contact the local pretreatment coordinator or state pretreatment staff if errors are noted.

l
Pretreatment Program Info Database printed on: 1/18/2022
for Program Name Sanford 1
WWTP Name Big Buffalo Stream Information IWc%at 7Q10 51.92
Program Approval Date 06/10/1983 7Q10 Flow cfs/mgd 17.2 / 11.11
1010 Flow cfs/mgd 14.21 / 9.19
Pretreatment Status Full
Re ion Stream Classification C
9 RRO
Basin Number CPF11
County Lee Receiving Stream Name DEEP RIVER
NPDES Number NC0024147 \. i
NPDES Effective Date 05/01/2018 Last PAR Rec 02/02/2021 PAR Due Date03/01/2022 mercury
1631
Current Fiscal quir
NPDES Expire Date 09/30/2022 06/28/2019 required
Year PCI Done
POTW is Primary WTP TRUE Last Audit on 09/17/2021 Audit Year Next25/26 'yes W
Design Flow mgd 12.0000 %Design mgd is SIU permitted ( 19.15 ( Permitted SIU flow(mgd)[Pt_SIU) 2.29774
WWTP SIU's 12 Program SIUs 12
WWTP CIU's 9 Program ClUs HWA LTMP MS SUO ERP
date Inactive Date Next Due 05/01/2022 08/01/2023
Date Received by DWR 05/25/2017 12/22/2014 07/30/2018 12/20/2011 04/20/2009
Date Approved 02/22/2018 03/12/2015 08/10/2018 01/25/2012 07/17/2009
Adopt Date Required
Date Adopted 01/15/2013
r
Info in this Box from Pt Contacts
Date Date Date
PT Pro Attended Attended Attended
Formal Name g.Prime Phonel ext Fax HWA Wksp IUP Wksp PAR Wksp
Mr.Scott Sitetzky I II(919)777-1781 J I(919)776-5037 II I 11/9/2004
[e-mail] Superintendent PO Box 3729
27331
1r.Dale Deaton I 11919-777-1782 ) 1.919-776-5037 0 2/9/2012 1 4/16/2014 1 2/7/2014 I
Lab Supervisor
Ms.Sarah Jordan IPrim 11(919)777-1783 J I 11 3/27/2014 1 4/16/2014 12/7/2014 I
[e-mail] Pretreatment Coordinator PO Box 3729 27331
J
Pretreatment Related NOVs from DWQ
J DWR Central Office Contact!McGee&Miller
09/14/2016 NOV-2016-PC-0454 Failure to enforce ERP
DWR Regional Contact Cheng Zhang

DocuSign Envelope ID:73C0D794-1C74-422B-BF1E-258E286F6262
75
t/I
ROY COOPER i41:,'~ �
Governor
LIZABETH S.BISER
.cretary ;•aq�0".
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
January 18,2022
Subject: End of 2021 Pretreatment Mailing
Dear Pretreatment Professionals:
After another complex pretreatment year,we wanted to provide you an update on some issues,
inform you on this year's upcoming workshops and distribute the Pretreatment Program Info
Database sheets.
I. Manufacturers Register: The Division now has access to an online Manufacturers Register
that can be downloaded and emailed. POTWs can request a copy of the register at any time.
2. Rules Updates: This is a reminder that the State Pretreatment rules (.0900)were updated
effective on July 1,2019. Per 15A NCAC 02H.0917(a),each control authority shall
transmit to the Division copies of all significant industrial user pretreatment permits 30
days prior to the effective date.Please note that approved permit writers can submit the
IUPs at the time of issuance. More details on how to become an approved permit writer can
be found on the Permit Writing Guidance page.
3. E-reporting: EPA postponed the deadline for E-reporting to December 21, 2025. An in-house
program is in development for potential Pretreatment Annual Report(PAR) submission
along with the other required Pretreatment ICIS data elements due in 2025.
4. Municipal Permitting Reorganization: Pretreatment and collection system have moved under
the Municipal Permitting Unit.Advantages of this is to combine the NPDES permit limit
development with the Headworks analysis,to jointly improve NPDES direct discharger and
POTW/SIU disclosure of emerging compounds, and to include Pretreatment staff input when
reviewing limit violations at POTWs.
INPDES Branch)
Compliance&
Expediated Permitting Industrial Permitting Municipal Permitting
Supervisor:John Hennessy Supervisor:Doug Dowden Supervisor:Michael Montebello
NPDES Municipal Pretreatment Collection
Permitting systems
5 NorthNorth Carolina DepartmentStreet1 of1617 EnvironmentalMailServiceCenter I Quality Raiei Divisihon of Water
NorthCarolina Resou27rces
512 Salisbury 699-1617
919.7079000

DocuSign Envelope ID:73C0D794-1C74-422B-BF1E-258E286F6262
5. Staff Assignments: Our goals for project review are 30 days for IUPs and SIU drops and 90
days for ERP, HWA, IWS, LIMP and SUO. This year,we have filled both previously
vacant pretreatment coordinator positions.
a. Keyes McGee: Keyes.Mcgee(wncdenr.gov,Office Phone: [phone]
b. Charlie Miller: Charlie.Miller(incdenr.gov,Office Phone: [phone]
Please also feel free to contact Michael Montebello [[e-mail]] or
alternatively Kristin Litzenberger[[e-mail]].
6. Workshops: The following workshops are projected for 2022. The invitations and directions
for these workshops will be posted on the"I`ra i n i n page once the dates are finalized.
We will send links to register for the events once scheduled.Please register early as
space is typically limited.
a. NCMA Water Quality Compliance Workshop—February 15,2022
b. Pretreatment Annual Report(PAR)-Projected 4th quarter of 2022
c. Headworks Analysis (HWA)-Projected 4th quarter of 2022
d. Industrial User Permit Writing(IUP) - Projected 4th quarter of 2022
All subject to current COVID-19 situation and staffing.
7. Pretreatment Program Info Database Sheets: Please review your attached program info
sheet(s)and historical SNC sheet(s), if applicable, and make necessary updates to any of the
information presented. Send the corrected sheets back with your PAR, due March 1,2022,
for calendar year 2021. If all of the information was correct,please indicate that in your
PAR. Especially note the due dates as this may be the only reminder you get. Please note:
a. All pretreatment programs (full and modified)must submit a PPS form with their PAR
per an EPA requirement of the State.
b. Historical SNC sheets only list currently Active SIUs that had SNCs from 2014-2020.
c. PAR forms are available for download on our website.
8. Email Addresses: The Municipal Permitting Unit often uses email to send out mass
mailings. To make this an effective and cost saving tool,we ask that you keep the Municipal
Unit updated on your current email address as well as which staff member is the"primary"
contact for your POTW-see"prim" field next to staff names on Program Info sheet,and
email field below names. For programs with more staff than the printed sheet can show,a
separate contacts page has been included. Please make any staff changes on that sheet and
return to the Municipal Unit with the PAR.
As always,please contact your pretreatment staff member(as listed above)with any questions or
comments.
Sincerely,
—DocuSigned by:
ksl/EOY 2021 kdL githi&Widlil
Attachments:Program Info Sheet(s) `—C464531431644FE...
Historical SNC Sheet(s),if applicable Michael Montebello, Supervisor
Ec: Municipal Permitting Pretreatment Staff Municipal Permitting Unit
Regional Office Pretreatment Staff
Pretreatment Consultants
U.S.EPA,Region 4
D,.,----- . /}l. North inmt of om Quality ieu
512 NorthCarol SalisburyaDepart Street
en 1617 Mail n Serviceental Center i RaleighDvision.Northof CarolinaWaterRso
2769rces9 1617
919.707.9000

Chapter 9, PAR Guidance
Pretreatment Performance Summary (PPS)
1. Pretreatment Town Name: City of Sanford
2. "Primary"NPDES Number NCOO ## 24147
or Non Discharge Permit#if applicable=>
3. PAR begin Date, please enter O l/01/yy or 07/0 l/yy 3.=> 1/1/2021
4. PAR end Date, please enter 06/30/yy or 12/3 l/yy 4.=> 12/31/2021
5. Total number of SIUs, includes CIUs 5.=> 11
6. Number of ClUs 6.=> 9
7. Enter the Higher Number, either (7a) or(7b)here=> 0
7a. Number of SIUs not sampled by POTW 7a._> 0
7b. Number of SIUs not inspected by POTW 7b.=> 0
8. Number of SIUs with no IUP,or with an expired IUP 8.=> 0
9. Total Number of SIUs in SNC due to either IU Reporting violations or
IUP Limit violations. To avoid double counting some SIUs
Enter (9a+ 9b ) - 9c here=> 2
Enter the Number of SIUs in SNC for :
9a. IU Reporting violations 9a.=> 0
9b. IUP Limit violations 9b.=> 2
9c. Both IU Reporting& Limit violations 9c._> 0
10. Number of Sills in SNC due to IU Reporting violations
that were not sampled or inspected by POTW 10.=> 0
11. Number of SIUs in SNC due to violation of 11.=> 0
Compliance Schedule due dates
12. Number NOVs,NNCs,AOs, or similar assesed to SIUs 12.=> 7
13. Number Civil or Criminal Penalties assessed to SIUs 13.=> 0
14. Number of SIUs included in public notice 14.=> 2
15. Number of SIUs from which penalties collected 15.=> 15
16. Total Amount of Civil Penalties Collected 16._> $ 1430
17. Total Number of SIUs on a compliance schedule 17.=> 0
Foot Notes: AO Administrative Order NOV Notice of Violation
CIU Categorical Industrial User PAR Pretreatment Annual Report
CO Consent Order POTW Public Operated Treatment Works
IUP Industrial User Pretreatment Permit SIU Significant Industrial User
NNC Notice of Non-Compliance SNC Significant Non-Compliance,formerly RNC
Chapter name: PAR Guidance File name: PAR_PP33derfleotis atbrillegb3lrpptb®991, Section B, Page 5 Blank PPS Form,Copy and use in your PAR

Pretreatment Annual Report (PAR) PAR covers this calendar year=> 2021
Significant Non-Compliance Report (SNCR) Control Authority=Program=Town Name => Sanford
WWTP = Wastewater Treatment Plant, use separate form for each WWTP. WWTP Name => Big Buffalo WWTP
SIU= Significant Industrial User NPDES # _> 24147
SNC = Significant Non-Compliance
A SNCR Form must be submitted with every PAR, please write "None" if you had No SIUs in SNC during calendar year
SNC ? (Yes/No )
IUP Pipe Industry Name Parameter for each 6-month period.
# # or "Reporting" Jan. - June July- Dec.
42 1 Arauco USA, LLC Overages on Zinc and Copper Yes No
35 1 Charah, LLC Overages on Molybdenum No Yes
Attach a copy of the Division's "SIUs in SNC Historical Report" for your POTW's SIUs behind this page .
Is the database correct ? Notify the Division of any errors ! Database indicates SNC history for previous years.
EVERY SNC MUST be explained in the Narrative, How was, is, or will it be resolved?
REPEAT SNCs are serious matters that MUST be explained in the Narrative.
Form name: PAR,SNCR,2001
Date Revised: 1/4/2001

1
1

Re: Question
From: Sarah Jordan<sa ah [e-mail]>
Ann McMillan<[e-mail]>
Date: 1/27/2021 10:01 AM
Hi Ann,
Since it's products that are already in the collection system,that's fine.No need for a letter,Pll just print and stick this email in the file for
informational purposes.Thanks for letting me know!
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Ann McMillan<[e-mail]>
To: Sarah Jordan<sarah [e-mail]>
Sent: 1/27/2021 9:56 AM
f. et:Question

Hi Sarah,
We have are no longer cleaning magna drums due to a change in our business.
We will start washing out totes with hot water no soap or cleaning products will be used. These are only our products so it will
t be a change in any materials or addition of any cleaning products.
Do I just need to send you a letter concerning this change?
I want to make sure you are aware of this change.
Have a great day,
Ann
Ann McMillan
EHS/ISO Manager
r4111 Wi DRIVE.
fL4V4{M'1ii.
POLYMER
5618 Clyde Rhyne Drive
Sanford, NC 27330
919-777-5995 ext. 209

Re: March Monthly Flow sheets
From: Sarah Jordan<sarah [e-mail]>
Savannah Carroll<[e-mail]>
Date: 4/21/2021 1:22 PM
Savannah,
I appreciate you and your team working to get this done in an expeditious fashion.In light of the newness of this process,we may allow
calibration records to be submitted at the end with the final report in the future.This is definitely a learning process and editing needs to be
done.
This email can serve as approval for the use of Carotek,Inc.It is still required to submit the signed documentation(by both parties)and
calibration records(email is fine)as soon as possible.I realize that the precise equipment hasn't been determined yet,but as soon as it is please
get the calibration information to me as soon as possible.Email is fine for that also.As far as documentation,you could use the sheets you
attached,with a cover page saying something along the lines of"the process detailed by the attached quote has been examined and is in
agreement with both Arauco and Carotek,Inc"(it doesn't have to be that exact quotation,but something similar)and have an Arauco
representative and Carotek representative sign.Again,in the interest of time,a scanned emailed copy will suffice.After the receipt of that
information,I'll draft the official approval and sign,scan,and email it to you,with a hard copy to follow.Hard copies of the documents detailed
above from your side,mailed as soon as possible, would be helpful for clarity and documentation purposes.Please let me know if you run into a
timing issue,so we can retain compliance.Hope that sounds agreeable?
I haven't heard from DENR yet.I'll circle back with them on Friday if I still haven't heard anything.The information from them may be helpful
if you decide to request a larger copper allocation.Arauco's zinc limit is the same as all of our industrial users,so I doubt there's much room or
appropriate reasoning to allow for a larger adjustment there. As it stands right now permit changes(without any request from your end on a
1 Change)will most likely consist of removing the April/October time constraint on verification,daily maximum values on constituents
iunlcad of monthly averages(still thinking on that and waiting for the State's input),the monthly flow average will stay in place,and some
finetuning to the mag meter verification process(dates,documents,etc)that have come to light while trying to complete and organize this
procedure.
Additionally,Arauco's CBOD average from the City sampling event is 3,435 mg/l,and the TSS average is 15,600 mg/l.The surcharge is due to
our billing office by the 25th or each month,so I'm sending it in on Friday(4/23)but Pm working on getting you an estimate of the monthly
cost.Oil and Grease readings also carry a surcharge.I noticed on the February data,Oil and Grease was submitted at 6.9 mg/1 but it was dated as
2/23/2020 as opposed to 2/23/2021?Is this a typo?If so please look over those results as well as March's and resubmit with corrected dates if
necessary.I see in the dates sampled column it states"sampled for semi-annual in March"in most columns but not cyanide,flow,and oil and
grease.Then in March,they show dates of 3/25/2020 and 3/26/2020,is this correct? What are the oil and grease values you've submitted to the
WWTP in 2021?Thanks for any clarification.Let me know if I can help further in any way.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Savannah Carroll<[e-mail]>
To: Sarah Jordan<sarah [e-mail]>
Sent:4/21/2021 8:30 AM
Subject:RE:March Monthly Flow sheets

Sarah,
I will plan on sending all of the results in at the end of the semi-annual period (June)to simplify things on both ends!Thank you
for the clarity. We will also proceed with certification for TTO for the semi-annual period as well, as you mentioned below.Also,
please let me know about any changes to copper/zinc resampling based on responses you receive from DENR.
Our electrical engineer informed me that a straight stretch of pipe is require for clamp-on calibration both upstream and
downstream of the actual meters, and we currently do not have access points in these places on the pipe. We are planning on
digging and adding permanent access in the future to allow for easy clamp on verification, but for the sake of time this semi-
annual period,we will be digging in on the stretches of pipe required for clamp on verification of the meters in the next 9 days. I
have attached the service agreement from our intended vendor, Carotek.They are still working on the calibration records for
their equipment,since they don't know which equipment will be coming out and usually provide that information at the end
(with the report) not prior to the service,for that reason.Apparently they have 17 different clamp on meters, so knowing which
is going to be here on that day is hard to predict.
Thank you so much for the coordination,
Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C):843-544-3025
From:Sarah Jordan<[e-mail]>
Sent:Thursday,April 15, 2021 2:53 PM
To:Savannah Carroll<[e-mail]>
)jest: Re: March Monthly Flow sheets
Adverter Este es un correo externo.No abra/descargue archivos desconocidos;no haga clic en enlaces sin antes verificar la procedencia de los
correos.
Savannah,
Yes,semi-annual periods are from January to June and then from July to December. Whenever modifications or renewals come
up again, I'm going to remove the April and October time constraint because I reallydo
n't on t see any significance in those
particular months for the verification.Then calibrations/verifications could be done any time between January through June
then once again during July-December. I just wouldn't have them on back-to-back months like June and then again in July, or
December and again in January.
Sending them piecemeal is fine, as long as they're representative of a typical day, it's just unusual. Usually, I get them all
together as industries pick a week for sampling and do it consequently.You can continue to send them in monthly,that way if
an issue is spotted we could take care of it sooner rather than later. It's not stated in the permit that it can't be done this way, so
it's fine with me now that I understand. I do need the bench sheets from the lab doing the sampling. It also would be handy
near the end of the six-month period to put all your data on a summary sheet or table. My other industries do this,and it makes
judging compliance for the six-month period easier.
3r as the TTO, look at page 15 of your permit and read numbers 6 and 7. Since the TTO was done recently and all was fine,
)kay with you all certifying instead of running the TTO again. You'd need to put the statement that's quoted (which basically
says there are no changes in conditions,the process, or wastestream to the best of your knowledge that has occurred during
the six months)on Arauco letterhead and sign it.The permit specifies the due dates for these.
Also, looking at your permit, as your limits are monthly averages,the violations of zinc and copper are a little more complicated

111111FoRimalreleil
700 SAM NEWELL ROAD- . P.O.. Box 1395 MATTHEWS, NC 28106
QUOTATION
Company: Arauco Pages: 2
Attn: this Molinet Date: 04/15/21
Phone: [phone] Quote4: KP20210415
Fax:
E-mail: [e-mail] Mail/Fax Order To: Carotek,Inc.
Street Address: 985 Corinth Road 700 Sam Newell Road
City,State: Moncure, NC Matthews,NC 28106
PH: [phone]
Zip Code: 27559 FX:[phone]
Terms:
Validity: 30 days Quote Contact: Kim Price
Freight Terms: Phone: [phone] X 1148
FOB: Account Manager: Pete Tollens
Delivery:
Reference: Qnty 2)Clamp On Verifications
*Any orders originating from this quote,please reference Quote#shown above
One trip to Arauco,985 Corinth Road,Moncure,NC to perform Qnty 2)Clamp On Verifications Onsite.
On site 8 hours @$165.00/Hour
Travel Time 2.5 hours Overtime $ 1320.00
@$24750/Hour... $ 618.75
Travel Mileage Approx.250 Miles Round Trip @ 0.58/mile
Travel Time 2.5 hours @$165.00/Hour
Hotel Expense&Per Diem $ 412.50
S 150.00
Total(Actual time on site will be charged) $ 2646.25
Prepared By: Kim Price
Carotek Field Service
04/15/21 THANK YOU i•OP.THE OPPORTUM T Y TO SLSC WT T 5 QUO?ATiON
Page

CAROTEK,INC
ATTACHMENT*1
TERMS
L The terms of this quotation constitute the entire contract between the buyer and the seller and no change or waiver of any
such terms shall be effective unless express and in writing signed by an officer of the seller.
2. Unless otherwise requested and previously agreed,all shipments will be made F.O.B seller's plant,freight collect or prepay
and added to invoice.Parcel post shipments will be postage paid,insured at the option of the buyer,postage and fees added
to the invoice. Risk of loss is on buyer from time of shipment
3. Seller shall have no liability for loss or damage resulting from a delay in scheduled delivery whether caused by war,riots,
strikes,labor disputes,fires,lack of transportation facilities,serious accidents,delays in receipt of parts or materials from
suppliers or sub-contractors,Government recommendation,errors or rejection of supplier's or subcontractor's parts,natural
disasters,unusually severe weather,acts of God,or any other circumstance.Overtimes which may be requested by the
buyer in order to maintain or improve schedules delayed by causes beyond the seller's control will be added to the quoted
cost at rates prevailing at the time.Seller will make every reasonable effort to maintain delivery estimates quoted induding
the use of overtime and premium payments at seller's discretion.
4. The seller accepts no responsibility for the installation of the equipment unless installation and/or installation supervision
forms a separate part of the purchase contract.Seller will advise buyer with regard to the installation of auxiliary equipment
and similar items,but accepts no responsibility for the work and equipment supplied by the buyer or third parties.
5. Sales,use,excise,property or similar taxes arising out of or relating to this order or the goods delivered are not induded in
the price,except as otherwise specifically stated in the invoice.Al such taxes are the responsibility of the buyer,and the
seller shall have the right at any time to bill separately to the buyer any such tax,which the seller may be called upon to pay.
6. Seller warrants to the original buyer of all products manufactured by it that such products are free from defects in materials
or workmanship for a period of one year from the date of shipment from seller's plant,such warranty to remain in effect if
and only if such products are used in accordance with instructions of the seller,and such defects have not been contributed
to by any other cause such as improper care or unreasonable use.Seller further warrants that such products,to the extent
they do not represent designs and specifications of the Buyer,do not infringe any United States Patents.Seller will pass onto
the buyer the same terms and warranties as granted by the manufacturers of component parts contained in seller's
equipment.
7. Seller's liability under the warranty provided herein(and under any other warranty,express or implied,statutory or
otherwise)is limited to,at seller's option,repair or replacement of all parts which are shown to have been defective when
shipped,and then only if seller is notified of such defects within such warranty period.
8. For any performance guarantee to be effective seller shall have access to the equipment for the purpose of performing tests
and to make such field changes and modifications to the equipment as it may deem necessary.For such tests,buyer will
furnish at no cost to seller utilities as required,material of specified quality,and such tabor and materials as are required to
perform the tests properly.In the event the seller determines after such tests,that the equipment is not of suitable design
and is incapable of operation when served with material of the same quality and characteristics as described to seller or as
tested by seller,seller will endeavor to make necessary modification or replacement of parts and equipment at its option on
the basis of labor and material being supplied at straight time rates,seller's liability being limited to the refund of the
purchase price upon return of the equipment in as-is condition.Seller shall not be liable for any labor,material,supplies,
utilities or similar items expended by buyer during the course of installation or start-up,nor shall seller be liable for any loss
of pi ofits or production,and seller's liability for incidental and consequential damages is hereby excluded to the full extent
permitted by applicable law.Seller's liability as stated herein cannot be altered or enlarged except in writing and signed by
an officer of seller.
9. Seller shall furnish buyer upon his request,assembly drawings of the specific equipment,electrical and hydraulic circuit
diagrams and other information reasonably required for the proper installation,maintenance and operation of the
equipment Such drawings or information provided by the seller are for information purposes only and will not he binding
upon the seller except as noted on the face of the drawings.Seller reserves the right to make at any time such changes in
detail of design or construction as shall,in the seller's sole judgment,constitute an improvement Detail and shop drawings
comprise proprietary information of the seller and do not form a part of normal information to be supplied to the buyer.
10. Any proposals,prints,drawings or other information furnished to the original buyer by the seller is intended for the
confidential use of the buyer,shall remain the property of the self,and shall not be used in any manner detrimental to the
seller's interests.
11. The office of the seller in North Carolina shall be the place of performance where title passes to the buyer and payment
becomes due.This agreement shall be a North Carolina contract and shall be interpreted and administered for all purposes
under the laws of North Carolina_
12. Buyer agrees to indemnify,defend and hold harmless Seller from and against any claims,costs,liabilities or expenses,
inducting reasonable attorneys fees and costs,arising out of any claims for personal injury(including death),property
damage,lost profit or other damage caused or alleged to be caused by the equipment or system that is the subject of this
order,or its manufacture,installation or operation.
THANK YOU FOR THE OPPORTUNITY TO SUBMIT TH6 QUOTATION_

Re: March Monthly Flow sheets
From: Sarah Jordan<[e-mail]>
Savannah Carroll<[e-mail]>
4/15/2021 2:53 PM
Savannah,
Yes,semi-annual periods are from January to June and then from July to December.Whenever modifications or renewals come up again,,Pm
going to remove the April and October time constraint because I really don't see any significance in those particular months for the verification.
Then calibrations/verifications could be done any time between January through June then once again during July-December. I just wouldn't
have them on back-to-back months like June and then again in July,or December and again in January.
Sending them piecemeal is fine,as long as they're representative of a typical day,it's just unusual.Usually,I get them all together as industries
pick a week for sampling and do it consequently.You can continue to send them in monthly,that way if an issue is spotted we could take care of
it sooner rather than later.It's not stated in the permit that it can't be done this way,so it's fine with me now that I understand.I do need the
bench sheets from the lab doing the sampling.It also would be handy near the end of the six-month period to put all your data on a summary
sheet or table.My other industries do this,and it makes judging compliance for the six-month period easier.
As far as the TTO,look at page 15 of your permit and read numbers 6 and 7.Since the TTO was done recently and all was fine,Pm okay with
you all certifying instead of running the TTO again. You'd need to put the statement that's quoted(which basically says there are no changes in
conditions,the process,or wastestream to the best of your knowledge that has occurred during the six months)on Arauco letterhead and sign it.
The permit specifies the due dates for these.
looking at your permit,as your limits are monthly averages,the violations of zinc and copper are a little more complicated as far as the
piing,the fines,the number of violations,etc.Most industries'limits are daily mazes,not monthly averages.I'm getting DENR to weigh in
to decide the best way to deal with this for both sides.So just sit tight and I'll let you know when I hear.
Concerning copper,you can request a permit modification.State the reason you need a higher limit in a letter.You can request a certain limit,
just know the City may counter with a different limit.We have some allocation,so Pm fairly certain we could give Arauco a higher limit based
on our other industrial users'limits. However,SNCs/violations aren't sufficient reasons that lead to looser limits.In the coming years,we may
have to impose stricter limits on all of our industries,since Sanford is growing! It may be worth considering keeping your flow as a monthly
average and giving other parameters a daily maximum.It would make sampling,resampling,compliance judgments,and reporting more
straightforward.
No worries,I'm not in the office Monday either,but I'll keep you informed.Let me know if there are more questions.I appreciate your continued
cooperation and patience.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Savannah Carroll<[e-mail]>
To: Sarah Jordan<[e-mail]>
Sent:4/15/2021 11:08 AM

Sarah—my apologies for the confusion. I have been sending the results in piecemeal because we didn't plan on doing all of our
semi-annual sampling at once (in one week, per se, like the city does when you all come onsite).We have been breaking up the
sampling by month in order to spread it out over a semi-annual period.Would you like me to wait to send any results until the
end of the 6 months and send them all together? (For instance we just took another sample in April to continue towards the
total permit required amount of samples). If it would be easier, I would be happy to wait until the end of the semi-annual
riod, and send all the results at once!
Also,we had not discussed the TTO requirements yet,and I was curious if you could shed some light on certification as apposed
to sampling for that! I know you all had completed a TTO sample in November. In order to opt into a certification statement as
opposed to sampling,would we need to take one ourselves and then, assuming it is compliant, pursue the certification route
next semi-annual period? In our permit it mentions a semi-annual period from November to April for flow meter calibration.Am
I to understand from below that the semi-annual period is actually from January to June for sampling purposes, and November
to April for flow meter calibration purposes?
Thank you so much for any clarification!
Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C): 843-544-3025
From:Sarah Jordan<[e-mail]>
Sent:Thursday,April 15, 2021 10:50 AM
To:Savannah Carroll<[e-mail]>
Subject: Re: March Monthly Flow sheets
r,cia:Este es un correo externo.No abraidescargue archivos desconocidos;no haga clic en enlaces sin antes verificar la procedencia de los
correos.
Savannah,
Looking over the semi-annual results.There are a few issues I noticed.
1. On pipe 01,we require 4 cyanide samples
2. On pipe 01, we require 2 mercury samples
3. Check your dates on page 3- I think the 2020s need to be changed to 2021
4. Did we discuss the TTO requirements as far as certification as opposed to sampling?
5. On pipe 02 4 oil and grease samples are required
6. Bench sheets for all these results from the certified lab you used are required
Let me know if there are questions or concerns or if more sampling needs to be done prior to June 30th.There should be
enough time to get your lab to take missing samples if need be.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)

From:Savannah Carroll<savannah.carrollParauco.com>
To:Sarah Jordan<sarah.jordant sanfordnc.net>
Sent:4/15/2021 10:36 AM
Subject: RE: March Monthly Flow sheets
Sarah—great,thank you I appreciate it! Sounds good, and likewise, I will let you know the mag meter calibration information
as soon as I have it.Also, I am out tomorrow and Monday, so my response to anything in the time frame might be slightly
delayed.
Thanks,
Savannah Carroll
Environmental Manager
(0):919-545-5848
(C): 843-544-3025
From:Sarah Jordan<sarah.jordanc sanfordnc.net>
Sent:Thursday,April 15,2021 10:33 AM
To:Savannah Carroll<savannah.carrollParauco.com>
Subject: Re: March Monthly Flow sheets
Advert-n;: =:Este es un correo externo.No abra/descargue archivos desconocidos;no haga clic en enlaces sin antes verificar la procedencia de los
coffees.
No need to send a corrected hard copy.The email copy is fine.Also, in your previous email,you asked about who would
onduct the additional sampling. It's the industry's responsibility to collect the resamples. Scott and I are taking your
..oncerns about copper under advisement and are looking at our allocation table, and headworks. I'll be in touch about that
issue soon. Thanks.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Savannah Carroll <savannah.carrollParauco.com>
To:Sarah Jordan <sarah.jordannsanfordnc.net>
Sent:4/15/20219:56 AM
Subject: March Monthly Flow sheets
Sarah,
Please see attached for the March industry sampling and daily flow sheets for Arauco-Moncure. Please note I have
submitted this as a hard copy to the city a day or two ago but realized I had actually included some stormwater results on
the second analysis page(the last page in the copy, we collected two samples in March).The copy attached to this email
shows the correct values. I can send a hard copy of the last page corrected to the city as well if you would like. My
apologies for the mix up on the hard copy. Please let me know of any questions or concerns.
Thank you,

Re: Waste Water Line Meter Calibration
From: Sarah Jordan<sarakjordan@sanfordncnet>
Savannah Carroll<[e-mail]>
.,..e: 4/5/2021 1:52 PM
Savannah,
4%was specified and confirmed by the State and by other pretreatment colleagues I have spoken to during this process.If the E&H meter
onboard verification is used,could it get within 4%?We don't have a problem with using this method,but we have to have some reliable way to
verify the mag meters are reading and reporting correctly.Please let me know so we can get this resolved as soon as possible.Thanks.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From: Savannah Carroll<[e-mail]>
To:Sarah Jordan<sarah [e-mail]>
4/1/2021 2:33 PM
_ect:FW:Waste Water Line Meter Calibration

Hi Sarah,
We are working with a third party that we typically use for flow meter calibrations to quote for the April wastewater flow meter
calibrations.The company is Carotek which is a local subsidiary of the well known entity Endress-Hauser. It appears that he has
some hesitation (detailed below)as to the 4%error due to variables related to installation processes. He will not issue a factory
ibration certificate due to this. Do you have any insight as to the accuracy of this method at your other facilities and why 4%
is the allowable threshold?He mentions 10%as the window due to variable outside of Endess-Hauser's control.
Any help is appreciated.Thank you!
Savannah Carroll
Environmental Manager
(0): 919-545-5848
(C):843-544-3025
From:Tollens, Pete<[e-mail]>
Sent:Thursday,April 1, 2021 11:57 AM
To: Luis Molinet<[e-mail]>
Cc:Savannah Carroll<[e-mail]>;Timothy Lewis<[e-mail]>;Johnny Smith
<[e-mail]>
Subject: RE:Waste Water Line Meter Calibration
~P-;-rerci a•Este es un correo externo.No abra/descargue archivos desconocidos;no haga clic en enlaces sin antes verificar la procedencia de los
correos.
comments below from Bill Burton, Carotek Field Service Manager.
Pete
E&H flow meters have onboard verification that is traceable to a recognized standard (I have attached one of these reports for
review).This would be the preferred method for verifying the meters in question. We can perform the mentioned test below
using a clamp on flow meter, but I have to question the 4%and a certificate of calibration on a clamp on.A clamp on flow
meter is only as good as the installation based on all relative data in regards to that install.This includes pipe data, material,
temperature, pipe liner.... Etc.These are accurate devices, but a calibration cert on this device would only pertain to the
installation factors during the factory calibration and listed installation requirements.This means that the uncertainty of the
measurement would almost double with any variance from the factory requirements for installation.We routinely test our
portable clamp on at our PTU against a Coriolis meter to verify it is working correctly,we know all the info needed to promise a
good install, but I would never generate a calibration report for it. If I use a clamp on in the field I would have to expand the
percent error to 10% basically due to the uncertainty budget around the installation factors.
We can provide the verification as spelled out below with an expanded MPE, but I cannot issue a factory calibration certificate
on the 93T portable as I deem it misleading. I would however recommend using the traceable factory onboard calibration tool
provided by Endress. I have attached one of these reports for reference and the backing for the technology.
Let me know we can also follow up with a conversation if needed.
From:Luis Molinet<luis.molinetParauco.com>
Sent:Tuesday, March 30, 2021 10:52 AM
To:Tollens, Pete<pete.tollensPcarotek.com>
Cc:Savannah Carroll <savannah.carroliParauco.com>;Timothy Lewis<timothy.lewis_Parauco.com>;Johnny Smith

<johnny.smithna arauco.com>
Subject:Waste Water Line Meter Calibration
Pete;
you are aware we need to do the first waste water flow meter verification by April 30th 2021 for the 2 E&H mag flowmeters
installed last year.
I know you are working to give us a proposal for the service.At the same time there are some requirements from the City of
Sanford. 1 quote those requirements from what we've received the City:
"If a magnetic flow meter is being employed for flow measurement it must be verified. Verification does not eliminate the
need of calibration but indicates when/if calibration needs to be performed. Verification is more feasible as clamp-on
equipment can check the accuracy and precision of the magnetic flow meter as it stays in operation whereas traditional
calibration would require a complete removal of the magnetic meter.
Regulated pipes 01 and 02 magnetic flow meters shall be verified semiannually(by the 30th of April and October)by a non-
affiliated third party that must be approved by the Control Authority. Verification will consist of clamp-on ultrasonic flow
measurement equipment.Documentation is required for the ultrasonic equipment, namely a factory calibration report and
should be filed as a baseline reference. it is also recommended to have an ultrasonic configuration data sheet.
Baseline measurement of magnetic field strength are established at the time of magnetic meter installation. These baseline
measurements are compared to readings of the ultrasonic meter. Comparing the readings of the ultrasonic meter to the
readings of the magnetic flow meter provide a basis to evaluate the magnetic flow meter's accuracy and ability to report a
verifiable result. By assessing these values,it can be determined if the magnetic flow meter's calibration has shifted and if
corrective action needs to be taken.
If these values deviate by more than 4%,a complete full calibration of the magnetic flow meter will be required."
Ldrotek has to be approved by the City of Sandford to perform the job,so Savannah needs to submit a request that includes:
• An agreed upon outline of the verification event that is signed by both an Arauco employee and the verifying third party
(I'm assuming a quote/proposal of services will suffice)
• Documentation from the vendor that any and all verification equipment is certified as accurate.
Can you help us with the needed documentation?
Please let us know.
Thanks.
Luis Molinet
raU 985 Corinth Road,Moncure NC 27559
Phone:[phone] Mobile:[phone]
www.arauco-na.com
www.arauco-na.com

Sarah,
During the City of Sanford January- June sampling event, we experienced a pH reading of 5.8 on pipe
01, putting us in violation of our permit.
This occurred only one day out of the four testing days. Nothing in our process changed on any of the
fnur days. In our investigation it was found that the
coming fresh water from the City of Sanford is very inconsistent on its pH levels. We began
monitoring the incoming freshwater on January 12th. Results are below:
1/12/2021 pH 7.1
1/13/2021 pH 7.2
1/14/2021 pH 6.86
1/15/2021 pH 6.1
1/18/2021 pH 6.1
1/19/2021 pH 6.47
1/20/2021 pH 7.26
1/21/2021 pH 7.67
On Jan.26th we had a third party come in to test and verify our readings. Both ours and theirs
registered a pH 6.1
Both instruments used were calibrated to buffer solutions of 4, 7, and 10 to insure credible readings.
With this variable of incoming water from the city, it will be impossible to meet our permit limits based
on the water source.
I have reached out to Scott Christiansen with the City of Sanford. He says we should not be seeing pH
readings this low as they shoot for pH 7.8
I have asked him to look into it further and even to have someone come out to review. I am waiting to
hear back.
I feel we are being penalized for something we have no control over. Your thoughts on this situation
would be welcomed.
Thanks,
Tim Althaus
VP Operations / Sales
Hydro Tube Enterprises Inc.
Office 919-258-3070 ext. 204
Cell - 919-625-9816
www.hydrotube.com
Integrity is doing what's right even when no one is watching.

Re: NOV Response
From: Sarah Jordan<sarah [e-mail]>
Tim Althaus<[e-mail]>
Cc: Scott Siletzky<[e-mail]>
Date: 2/5/2021 11:46 AM
Tim,
I understand the situation, however, I cannot rescind the notice of violation.
All of our industries have the same pH limits and receive their incoming water from the City of Sanford, as does our plant. We have
pH limits for our NPDES permit, which led us to change industrial pH ranges back in 2014 to coordinate with our pH limits.
The fluctuation in pH values of the influent water can be the reasoning or justification for the violation submittal that the POTW
requires as part of NOV conditions.
Hydro Tube's pH limit(6.0-10.5 s.u.) is established and enforced by the IUP, the ERP, and the NC pretreatment program (managed
by NCDEQ). These documents dictate that when there is an IUP infraction, a notice of violation must be issued by the POTW. I
recognize your consternation regarding the pH fluctuations of the incoming water, but the POTW can't impose limits on influent water.
It's the industry's duty to manage and uphold its permit limits on industrial effluent discharge despite any deviation(s) of the
influent water. For clarification, please see your IUP Part II General Conditions, specifically number five(Duty to Comply) and number
six (Duty to Mitigate).
I appreciate your consideration in this matter. If you would like to talk with someone from the NC PERCs (Pretreatment, Emergency
Response and Collection Systems) Unit you can contact:
ael Montebello (Supervisor)
pnone: 919-707-3624
email: [e-mail]
- Christyn Fertenbaugh (Environmental Engineer)
phone: [phone]
email: [e-mail]
- Kristen Litzenberger (Environmental Specialist)
phone: [phone]
email: [e-mail]
There's some staffing changeover taking place at the municipal level and their responsiveness has been hindered due to these
transitions as well as COVID-19. Kristen tends to be fairly responsive via email. It's always the POTW's goal to keep our permittees in
compliance and to sustain and maintain amicable working relationships. Have a good weekend.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Tim Althaus<[e-mail]>
To: Sarah Jordan<[e-mail]>
Cc: Randy Buchanan<[e-mail]>

Hi Sarah,
We have are no longer cleaning magna drums due to a change in our business.
We will start washing out totes with hot water no soap or cleaning products will be used. These are only our products so it will
t be a change in any materials or addition of any cleaning products.
Do I just need to send you a letter concerning this change?
I want to make sure you are aware of this change.
Have a great day,
Ann
Ann McMillan
EHS/ISO Manager
MIII YOU DRI
VE.
WI tt1Ue Mx AI 7
POLY MER
5618 Clyde Rhyne Drive
Sanford, NC 27330
919-777-5995 ext. 209

Re: Question
From: Sarah Jordan<sarah jordan®sanfordnc.net>
Ann McMillan<[e-mail]>
Date: 1/27/2021 10:01 AM
Hi Ann,
Since it's products that are already in the collection system,that's fine.No need for a letter,Pll just print and stick this email in the file for
informational purposes.Thanks for letting me know!
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Ann McMillan<amcmillan@stipolymercom>
To: Sarah Jordan<[e-mail]>
Sent: 1/27/2021 9:56 AM
! !et:Question

P.O.Box 3729
SANFORD,NC 27330 PHONE[phone]
FAN [phone]
Qt;itp of 'anforb
Sarah Jordan
WASTEWATER MANAGEMENT FACILITY PRETREATMENT COORDINATOR
February 10,2021
Cody Butcher
EHS Associate
Caterpillar Inc.
P.O.Box 3667
Sanford,NC 27331-3667
Subject Pipe 02 Flowmeter Malfunction
Dear Mr.Butcher:
In reference to the email I received yesterday about the pipe 02 flow meter malfunction at
Caterpillar(Boone Trail site IUP#000040),it was discussed with Scott Siletzky(the
Water Reclamation Facility Administrator).It was agreed upon that during the interim
period(while the 02 meter is malfunctioning and giving off erroneous readings)that pipe 02
flow will be estimated by observing 01 flow and past 02 flow data Pipe 02 tracks process
and domestic flows_The interim period is not to exceed 90 days past the receipt of this
letter without prior approval of the wastewater management facility.It was confirmed that
a modified authorization to construct detailing a new flow measurement device is
forthcoming.I have attached emails discussing this for reference as well.
Thank you for your help in promoting a healthy environment for our community. If there are
questions concerning the above information please feel free to contact me at(919)777-1783
or via email.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Re: Pipe 02 Flow Meter: Boone Trail
From: Sarah Jordan<sarah_jordan@san fordnc_net>
To: Cody Butcher<Butcher Cody
fb: Kevin Staubus<staubus kevin@cat_com>
Date: 2/102021 9:40 AM
Cody,
On the flow sheet please mark when the estimate starts and why etc just so we have that in addition to this email that I'm going to put in the file.
Also PLEASE let me know when the letter agreeing to the 02 solution is received as it's important to calcnlatP the 90-day timeline.Thanks!
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Cody Butcher<Butcher Cody H@cat_com>
To:Sarah Jordan<sarah jordan@sanfonlncnet>
Cc:Kevin Staubus<Staubus Kevin@cat,com>
2/10/2021 8:46 AM
Su ject:RE:Pipe 02 Flow Meter:Boone Trail
•

Re: Pipe 02 Flow Meter: Boone Trail
From: Sarah Jordan<sarah jordan@sanfondncatet>
Cody Butcher<Butcher
Codyf1@catcom>
2/10/2021 8:51 AM
Cody,
Excellent!If it so happens that 90 days isn't a sufficient amount of time,please let us know as soon as possible_I'll work on this letter and will
hopefully get it out this week.Thanks!
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From:Cody Butcher<Butcher CodyH@catcom>
To:Sarah Jordan<[e-mail]>
Cc:Kevin Staubus<Staubus Kevin@a cat.com>
Sent:2/10/2021 8:46 AM
ct RE:Pipe 02 Flow Meter.Boone Trail

Sarah,
We can absolutely estimate Pipe 02 flow.Pipe 02 is essentially Pipe 01, (paint process wastewater),but it includes the
bathrooms/domestic water use throughout the facility.There are no other processes at that facility that would contribute to
nverages or violations.
I believe 90 days should be plenty of time for us to get everything ordered, delivered,and installed.With COVID there is no way
for me to know if there will be shipping issues, but I will do my best to get it done ASAP,and we can address any of those issues
if they come up.
As for an ATC, I will draft a revision from the previously submitted one sometime in the next week and send that out to you.
Please let me know if there is anything else I can/need to do!
Thank you,
Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford,NC 27330
Office:[phone]
Cell:[phone]
butcher cody hPcat.com
rpillar:Confidential Green
From:Sarah Jordan<[e-mail]>
Sent:Wednesday, February 10,2021 8:25 AM
To:Cody Butcher<[e-mail]>
Cc:Kevin Staubus<[e-mail]>
Subject:Re: Pipe 02 Flow Meter: Boone Trail
CAUTION: EXTERNAL EMAIL
This is a message from [e-mail].
Use caution when opening unexpected emails and do not click on links or attachments from unknown
senders.
For more resources, visit security.cat.com/phishing.
Hey Cody,
Can't complain about 2021 yet,fingers crossed for everyone that it's better than 2020. Moving forward in regards to the flow
meter issue,is it feasible to estimate 02 flow(based on 01 flow and/or historical flow data)during the interim? If so,that is
probably the best solution. If that sounds doable, I'll draft a letter and put a time limit on the new and accurate flow numbers
I the new meter,say 90 days? Let me know your thoughts.Thanks.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)

am:Cody Butcher<Butcher__Cody._Hkcat.com>
:Sarah Jordan<sarah.jordanftsanfordnc.net>
Cc: Kevin Staubus<Staubus KevinPcat.com>
Sent:2/9/2021 12:14 PM
Subject: Pipe 02 Flow Meter: Boone Trail
Hi Sarah!
I hope you have had a safe and wonderful start to 2021.
I wanted to reach out to you to let you know that our flow meter at Boone Trail has started to malfunction and return
ridiculous flow measurements. It was just calibrated in December and has seemingly been fully operational until we pulled
the numbers for January flow data. I believe we have no choice but to call it non-operational at this point
Last year,we began the process of upgrading the flow meter,as well as installing a flume in the pipe,but we were later told
by the contractors after the ATC was sent that the application would not work in that pipe.So we went back to the drawing
board,and I have just received a quote for a new laser flow meter to be installed.The project has been approved and now we
are just waiting for the formalities to go through,and the flow meter to be ordered/installed.
Since our flow meter is no longer operational,what are the next best steps for us to ensure that we remain in compliance
during the interim?Is there a grace period that can be granted to allow us time to order the new flow meter and install it
rhile not monitoring pipe 02?I expect the lead time to be roughly 5-7 weeks according to the company.
Thank you!
Cody Butcher
EHS Associate
Building Construction Products Division
5000 Womack Road Sanford,NC 27330
Office:[phone]
Cell:[phone]
butcher cody hPcat.com
Caterpillar:Confidential Green

PO Box 3729 ^'
Sanford,NC 27331-3729 Fax [phone]
Phone [phone]
(Cite of fianforb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
April 28,2021
Ms. Savannah Carroll
Environmental Manager
Arauco Panels USA,LLC
985 Corinth Road
Moncure,NC 27559
Subject Vendor Approval
Dear Ms. Carroll:
Based on submittal of Arauco's request dated April 22, 2021 signed by Bill Burton from
Carotek and yourself with the quote document serving as an agreement,your request has
been approved pending the submittal of equipment verification documents.Equipment
documentation and results of the verification process are to be submitted within 30 days of
the service date to be judged as compliant of IUP000042. Please submit hard copies of all
relevant documents in the mailing containing the final results and the equipment
documentation.
If you have questions concerning the above information,please feel free to contact me at
[phone] or via email.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

CITERPI
ITERPILLAR
Cater Inc.
Building Construction Products Division
5000 Womack Road
Sanford,North Carolina 27330 USA
April 28,2021
Mrs. Sarah Jordan
Pretreatment Coordinator
Wastewater Management
City of Sanford
P.O.Box 3729
Sanford,NC 27331
Mrs.Jordan:
In reference to Industrial User Pretreatment Permit Number 000040,this letter is in response
to the letter received on February 1e,2021 in regard to the pipe 02 flowmeter at Boone
Trial.
It was agreed upon that for 90 days,pipe 02 flow would be estimated based on pipe 01 due to
erroneous readings from the pipe 02 flow meter.As soon as the agreement was made,the
flow meter was ordered,and a target date was established.Due to lengthy shipping/delivery
time,the flow meters will not be here for install by the agreed 90-day grace period.
The latest shipping information states that the flow meters will be shipped on May 7,2021
and delivered 3-5 business days later. We have already scheduled a tentative installation date
of May 19, 2021 and expect to be fully operational by May 21,2021.
In order to avoid another extension,we would like to extend the grace period to May 31,
2021 to prepare for any unexpected issues that may arise. If the flow meter is operational
prior to May 31,2021 as expected, we will begin to record flow data at pipe 02 rather than
estimate.
Regards,
Kevin Staubus,CSP
Sanford Environmental,Health and Safety Manager
Caterpillar,Inc., Sanford Site
Caterpillar:Confidential Green
-_J

P.O.Box 3729
SANFORD,NC 27330 PHONE[phone]
FAX [phone]
satimmimaiamismommaisiumaimismininiaga (Ntp of 'anforb
WASTEWATER MANAGEMENT FACILITY SarE Nordan
PRETREATMMENT COORDINATOR
April 29,2021
Kevin Staubus&Cody Butcher
Caterpillar Inc.
P.O.Box 3667
Sanford,NC 27331-3667
Subject:Pipe 02 Boone Trail(IUP 000040)Interim Period Extension
Dear Mr. Staubus&Mr.Butcher:
In reference to the letter from Caterpillar dated April 28,2021, an extension of no more than
30 days from the original interim period of May 13t,2021 is granted. This extension is in
response to long shipping and delivery times. The new deadline is Friday Jane 25th
2021.This date should ensure proper and accurate flow meter readings after the installation.
Caterpillar is expected to continue to record flows during the entirety of this time.After the
completion of the installation and recording of normalized flows,please send a timeline
detailed and
letter of the ongoings at the Boone Trail site during the 02-flowmeter malfunction,
as previously discussed. It is also imperative to schedule the City of Sanford's January-June
2021 sampling event Please call or email our lab supervisor,Dale Deaton,to coordinate. His
phone number is 919-777-1782 and his email is [e-mail]
Thank you for your help in promoting a healthy environment for our community. If there are
questions concerning the above information,please feel free to contact me at(919)777-1783
or via email.
Sincerely,
54j441-
Sarah Jordan
Pretreatment Coordinator
City of Sanford

� sr.
P4 Box 3729 F
Sanford,NC 27331-3729 Fax [phone]Q37
Phone [phone]
City of 'anf orb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
May 11,2021
Kyle Hoover _
Charah,Inc.
1271 Moncure-Flatwood Road
Moncure,NC 27559
Subject: Vendor Approval
Dear Mr. Hoover:
Based on submittal of Charah's request dated May 7th 2021 along with the dually signed
agreement and instrument verification documents,your request has been approved.
Results of the verification process are to be submitted within 30 days of the service date to
be judged as compliant of IUP000035. Please submit hard copies of all relevant documents
in the mailing containing the final results.
If you have questions concerning the above information,please feel free to contact me at
[phone] or via email.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

PO Box 3729
Sanford,NC 27331-3729 �•�:�' (91 r 77 5 3:
Phone (919) 7-1783
City of *oinforb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
May 18, 2021
Ms. Savannah Carroll
Environmental Manager
Arauco Panels USA,LLC
985 Corinth Road
Moncure,NC 27559
Subject: May TSS and CBOD Resamples
Dear Ms. Carroll:
During the January through June City of Sanford sampling event,higher than usual TSS and
CBOD values were recorded and resulted in a prohibited surcharge value($134,214.48). It
was decided by the City of Sanford to conduct resamples. These results are detailed below
and on the included sheets.
Date Flow(GPM) TSS(mg/1) CBOD(mg/1)
5/4/2021 2,057.37 1,280 768
5/5/2021 1.756.00 2,160 897
5/6/2021 3,079.13 2.000 966
Average(mg/1) 17813333 877
Arauco will be surcharged on an averaged CBOD value of 877 mg/1(surcharge limit is 250
mg/1),an averaged TSS value of 1,813.333 mg/1 (surcharge limit is 200 mg/1),and an
averaged Oil and Grease reading of 349.9 mg/1(surcharge limit is 40 mg/1)on the next water
and sewer statement. The Oil and Grease readings were derived from industry supplied
sampling.These averages have mitigated and reduced surcharge costs. The approximate
surcharge value is$17,421.20 monthly. For an exact cost,please contact the City of Sanford
finance office.
Samples were collected in accordance with the Industrial Permit,Pretreatment Regulations,
and the City of Sanford Sewer Use Ordinance. Samples were analyzed in a Certified
Laboratory using approved methodology.

If you have questions concerning the above or enclosed information,please feel free to
contact me at(919)777-1783 or via email at [e-mail]
Sincerely,
82241_
Sarah Jordan
Pretreatment Coordinator
City of Sanford
Enclosures

INDUSTRY---Arauco Panels
Composite Date TSS CBOD
I 5/4/2021 I 1280 768
I 5/5/2021 ' 2160 897 I
5/6/2021 2000 966
All values reported in mg/I
Notes for week The GGA's and Blanks were out of range for the 5/4/2021 CBOD analysis.
The Blanks were out of range for the 5/5 and 5/6 CBOD analysis.

•
134
11 •e, : sin WW1?
F��
rac 2�0 .A1aucO Panels
0 '''' ES mormig.-.
0 Floss
D rime S t
1
IIIIIMIM
a i. u rlrIIIIII
® 5142oz,!i 10 16 i ti
! 1y
f NO.iIiL / Me4 fob_
T 5
54/2021
IIIIIIIIIIIIIIIII
NOM&
1 ilall siarlozi re)t.- J rearli-;,-
wariormi
6,,-,.
NOTES
11111111111.111111.1
��11111 51412021 ii # WMmaperstare Blank. Industry am Arriving mran
11 3W51202I f='IL s/snm,G�}'�
'� saran �S ' .. ��a�rn,4ag,nd�.ayd,S,r;y�mlab �L LS.(,
�� T �[Itare�lade�ymd�mv*blab " 23.9 .l2.S
MIIMINEMINIEll'11i�:== TmHeaab 7�rm61n'�Su77Q+61usiviog�Iab
IIIIIIIIIIIIIIIIII■:-!__
I7a na4 _._ _---_
Ca.,,,,1 Y4/2621 Dans 1
raaeLeg SampSog Srtc miiill M *Wok IL NOM
unimimmill
Time Arrived Laboratory:
r1.,
Sammie('Rehm Went Weer
MilMa
e .
611..=almlaki.mann SIM 61X FAM411 ali
If rMalaY eil sae of Moat / M
What ccasposate
)Qgreb a7 are ecilemed,thY emplaced on lee.A tospeormre blank accompanies the composite sample(s)re the grabs s)daring the n m en back to Me laboratory.

Re: Meter Verification
From: Sarah Jordan<[e-mail]>
Kyle Hoover,P.E.,P.G.,PMP<[e-mail]>
6/10/2021 1:56 PM
Kyle,
Thanks for sending this.Based on this,Charah will be considered compliant of the permit-required mag meter verification.I appreciate Charah's
dedication to making this new stipulation run smoothly.You can print this email for proof of compliance.Thanks and let me know if you need
anything.Have a good weekend.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)
From: "Kyle Hoover,P.E.,P.G.,PMP"<[e-mail]>
To: Sarah Jordan<sarah [e-mail]>
`"-- "Chris Long,CES,PQM,CPESC-IT"<[e-mail]>,Norman Divers<[e-mail]>
6/10/2021 1:41 PM
Subject:RE:Meter Verification

Please see attached for the flow meter verification for our facility in Moncure.
Please let me know if you have any questions or concerns.
Kyle Hoover,P.E.,P.6.,PMP
Director of Engineering,Environmental&Quality I Charah Solutions,Inc.
Mobile:[phone] I Office:502-245-1353
[e-mail] J https://www.charah.com
Charah- Service Above AII.
Solutions
From:Kyle Hoover, P.E.,P.G., PMP
Sent:Thursday,June 3,2021 1:59 PM
To:Sarah Jordan<[e-mail]>
Cc:Chris Long,CES, PQM, CPESC-IT<[e-mail]>; Norman Divers<[e-mail]>
Subject: RE:Meter Verification
Sarah,
I will be sending this out to you today—sorry for the delay.
From:Sarah Jordan<sarah.jordan aOsanfordnc.net>
Sent:Thursday,June 3, 2021 1:58 PM
To: Kyle Hoover, P.E., P.G., PMP<khooverPcharah.com>
Cc:Chris Long,CES, PQM, CPESC-IT<[e-mail]>; Norman Divers<[e-mail]>
Subject: Meter Verification
CAUTION:This email originated from outside of the organization.Do not click links or open attachments unless you recognize the sender
and know the content is safe.
Kyle,
Hope the mag meter verification went well. I'm just checking in because in the last letter I sent I needed all the information and
results pertaining to the event within 30 days. Please let me know if I can assist you in any way.Thanks and have a good
weekend.
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
''') 353-6802 (Emergencies Only)

f-----
_-Y
QEitp of 'anforb
WASTEWATER MANAGEMENT FACILITY
Sarah Jordan
Pretreatment Coordinator
sarah.jordan ansanfordnc.net
March 25,2021 Phone:[phone]
Ms.Kristin Litzenberger
Department of Water Quality,PERCS
1617 Mail Service Center
Raleigh,N. C. 27699-1617
Subject:Modified IUP 000035 and IUP 000042
Dear Ms.Litzenberger:
he City of Sanford is submitting modified IUP 000035 and modified IUP 000042. These modifications came
_lout due to industrial,POTW, and DWQ concerns about the accuracy of magnetic meters being employed at
these sites to measure daily flow.Through collaboration with industry representatives,pretreatment colleagues,
draft copies,and cooperation from the division,it was decided these meters will be verified semi-annually by
comparing readings of an ultra-sonic meter to the magnetic flow meter readings in opposition to a full
recalibration. These values are not to deviate more than 4%of one another,if so, a full recalibration is required.
In this mailing,I have included the modified parts of both permits and copies of the transmittal letters that were
mailed to the industry representatives.Both modified permits include a new signed cover page,an updated IUP
history,and magnetic meter verification specifications and requirements under Part III, Special Conditions.
If there are questions or comments please feel free to contact me at(919) 777-1783.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford
Enclosures

Ift
P.O.Box 3729
Sanford,NC 273su PHONE(919)77i 1-1783
Fax [phone]
,at ' o 'anfnrb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILE T Y
March 25,2021
Norman Divers
Charah,Inc.
1036 Belmont Village Drive
Belmont,NC 28012
Subject: Transmittal Letter Industrial of Modified User Permit(IUP)Number 000035
Dear Mr.Divers:
Enclosed is your modified Industrial User Pretreatment Permit(IUP Number 000035). The amended
permit includes:a new signed cover page, an updated IUP history on page 2,and magnetic flows titer
verification guidelines on page l 4_ Carefully look over these changes..This modification is the result of
calibration concerns referencing the use magnetic flowmeters.
Please note that IUP 000035 states the third-party verifyingthe magnetic meter must be approved
by the City of Sanford prior to conducting the verification event_Approval requests are to be su ' i a
by the industrial user and must contain: bnii led
an agreed upon outline of the verification event that is signed by BOTH a representative of
the industrial user and a representative of the verifying third-party
documentation that(any and all)verification equipment is certified as accurate
If the above conditions are met and are satisfactory, the City of Sanford will send an approval of the
verification event and the third-party in hardcopy. In the interest of time,the City of Sanford can
verbally give approval by phone or email, with the hardcopy to follow.These verification events must
be performed on or before April 30th(for the January through June reporting period)and on or before
October 30th(for the July through December reporting period)each year.

Approval requests must be submitted at least 30 days prior to the verification event.Due to the timing
of this permit change,the April 2021 30-day timeframe has been waived.However,an approval
request for the April 2021 verification event is still required.Please submit this to the City of
Sanford for review as soon as possible.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
local Sewer Use Ordinance.Please read this permit carefully.If any parts,measurements frequencies,or
sampling requirements contained in this permit are unacceptable to you,you have the right to an
adjudicatory hearing upon written request within thirty(30)days following the receipt of this letter. A
copy of this permit must be submitted to the Pretreatment Section of the Department of Environmental
Management(the Division)for comments and approval. Once approval has been obtained from the
Division and/or there is no demand for a hearing from the Industry,this decision shall be final and
binding.
Sincerely,
&kJ__
Sarah Jordan
Pretreatment Coordinator
City of Sanford

6:14-74-
P.O.Box 37294;;
Sanford,t C 27330 PHONE(919)7=f-1783
Fax [phone]
CitP of ttlnrb
SARAN ORDAr
Pretreatment Coordinator
saran:[e-mail]
WASTEWATER MANAGEMENT FACILITY
March 25.2021
Chris Long
Charah,Inc.
1271 Moncure-Flatwood Road
Moncure,NC 27559
Subject Transmittal Letter Industrial of Modified User Permit(IUP)Number 000035
Dear Mr.Long:
Enclosed is your modified Industrial User Pretreatment Permit(IUP Number 000035).The amended
permit includes:a new signed cover page, an updated IUP historyon
� page 2,and magnetic flowmeter
verification guidelines on
page 14. Carefully look over these changes. This modification is the result of
calibration concerns referencing the use m gnetic flowmeters.
Please note that IEIP 000035 states the third-party verifying the magnetic meter must be approved
by the City of Sanford p��ea�
prior to conducting the verification event. Approval requests are to be submitted
by the industrial user and must contain:
an agreed upon outline of the verification event that is signed by BOTH a representative of
the industrial user and a representative of the verifying third-party
-documentation that(any and all)verification equipment is certified as accurate
If the above conditions are met and are satisfactory,the City of Sanford will send an approval of the
Verification event and the third-party in nrdcopy.In the interest of time,the City of Sanford can
verbally give approval by phone or email,with the hardcopy to follow. These verification events must
be performed on or before April 30th(for the January through June reporting period)and on or before
October 30th(for the July through December reporting period)each year.

Approval requests must be submitted at least 30 days prior to the verification event. Due to the timing
of this permit change, the April 2021 30-day timeframe has been waived.However,an approval
request for the April 2021 verification event is still required.Please submit this to the City of
Sanford for review as soon as possible.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
local Sewer Use Ordinance. Please read this permit carefully. If any parts, measurements frequencies, or
sampling requirements contained in this permit are unacceptable to you,you have the right to an
adjudicatory hearing upon written request within thirty (30)days following the receipt of this letter. A
copy of this permit must be submitted to the Pretreatment Section of the Department of Environmental
Management(the Division)for comments and approval. Once approval has been obtained from the
Division and/or there is no demand for a hearing from the Industry,this decision shall be final and
binding.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

CITY OF SANFORD
C«ttmI Aut v y and/or likinieineEtv
PERMIT
Industrial User Pretreatment Permit(IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
IUP# 000035
In compliance with the provisions of North Carolina General Statute 143-215_1, any
applicable federal categorical pretreatment regulations, all other Iawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Control Authority and/or Municipality Sewer Use Ordinance. The
following Industry hereafter referred to by name or as the permittee:
tridusay e,perm
CHARM,LLC
Facility Lora/eclat Street Address
1271 Moncure-Flatwood Road
city
Moncure,NC 27559
is hereby authorised 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 and/or Municipality listed below:
IUP CtxtfrolAudhordyoYutiar Municipality vvvvrPrune
City of Sanford,Big Buffalo Creek WWTP
NPDES?ember
NC 0024147
trWflP Address
5327 Iron Furnace Road
Cdy,State,ZP
Sanford,North Carolina 27331-3729
in accordance with effluent limitations,monitoring requirements,and all other conditions
set forth in Parts I,II,and III of this Industrial User Pretreatment Permit(IUP).
Effective date,this pen&and the actrisembp to 1:Sachems shall became
effective at ii.:.L ikit d a,this date
March 24, 2021
Expaaaon to,this petmd and the authorize=to crmnharge shall ewe at
Midnighton this data
September 30, 2024
Ze4.-zf
signed
Director of PuhJic Works

IUP,PART I, OUTLINE:
A.) IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
E.) Schematic and Monitoring Locations
F.) Effluent Limits&Monitoring Requirements
G.) Definitions and Limit Page(s)notes
A. IUP Basic Information:
Receiving Control Authority&WWTP nay POTW NPDES#: t
City of Sanford Big Buffalo WWTP NC 0024147
IUP Name:
RIP Number:�.�.0
000035 -
RIP Effective date: Pipe Numbers,list all regulated pipes
March 24,2021 Pipe 01
IIIP E iration date: HIP 40(tit#(if applicable),or N!A t
September 30,2024 N/A
B. IUP History.
Effective Date Renewal or Description of changes over previous RT.
Modification
22,2015 New Permit Permit issued to regulate the dischargefleachate from coal ash
mining sites
August 4,2015 Modification Fixed effective dates on Part I A,B,and F to list effective date as
July 22,2015.
November 17,2015 Modification Fixed typographical errors in detection limits(iron,bromide,zinc,
and aluminum)
September 8,2016 Modification Changed Molybdenum limit from 0.048 to 0.08
December 14,2016 Modification Changed Molybdenum limit from 0.08 to_134
September 30,2029 Renewal Renewed permit Changed effective dates_
December 3,2020 Modification Detection levels changed on Aluminum,Iron,Zinc,Bromide,
Strontium,and Molybdenum to reachable laboratory limits.
March 24,2021 Modification
Magnetic flow meter verification requirements added.
I
2

Industrial User Pretreatment Permit(IUP)
PART III
Special Conditions
If a magnetic flow meter is being employed for flow measurement it must be verified.
Verification does not eliminate the need of calibration but indicates whenfif calibration needs
to be performed.Verification is more feasible as clamp-on equipment can check the accuracy
and precision of the magnetic flow meter as it stays in operation whereas traditional
calibration requires complete removal of the magnetic meter.
Regulated pipe 01's magnetic flow meter shall be verified semiannually(by the 30th of April
and October)by a non-affiliated third party that must be approved by the Control Authority.
Verification will consist of clamp-on ultrasonic flow measurement equipment.
Documentation is required for the ultrasonic equipment,namely a factory calibration report
and should be filed as a baseline reference. It is also recommended to have an ultrasonic
configuration data sheet.
Baseline measurement of magnetic field strength are established at the time of magnetic meter
installation. These baseline measurements are compared to readings of the ultrasonic meter.
Comparing the readings of the ultrasonic meter to the readings of the magnetic flow meter
provide a basis to evaluate the magnetic flow meter's accuracy and ability to report a
verifiable result By assessing these values,it can be determined if the magnetic flow meter's
calibration has shifted and if cohcc;tive action needs to be taken.
If these values deviate by more than 4%, a complete full calibration of the magnetic flow
meter will be required.
14

P.0.Box 3729
Sanford,NC 27330 PHONE(919)7—r rr-1 i83
Fax [phone]
City of 11n forb
SARAHJORDAN
Pretreatment Coordinator
sar ah_jordan@sanfor dnc.net
WASTEWATER MANAGEMENT FACILITY
March 25,2021
Ms. Savannah Carroll
Arauco Panels USA,LI,C
985 Corinth Road
Moncure,NC 27559
Subject: Transmattal Letter Industrial of Modified User Permit OUP)Nrm;ber 000042
Dear Ms. Carroll:
Enclosed is your modified Industrial User Pretreatment Permit(IUP Number 000042). The amended
permit includes: a new signed cover page,an updated IUP history on page 2, and magnetic flow meter
verification guidelines on page 14. Carefully look over these changes.This modification is the result of
calibration concerns referencing the use magnetic flowmeters.
Please note that TUP 000042 states the third-party verifying the magnetic meter must be approved
by the City of Sanford prior to conducting the verification event Approval requests are to be submitted
by the industrial user and must contain:
an agreed upon outline of the verification event that is signed by BOTH a representative of
the industrial user and a representative of the verifying third-party
documentation that(any and all)verification equipment is certified as accurate
If-the above conditions are met and are satisfactory,the City of Sanford will send an approval of the
verification event and the third-party in hardcopy. In the interest of time,the City of Sanford can
verbally give approval by phone or email, with the hardcopy to follow.These verification events must
be performed on or before April 30th(for the January through June reporting period)and on or before
October 30(for the July through December reporting period) each year.

n � C U cr fl ! 1t1U
4- rpDt a C E' 5' R. E N [ g it° i P., >
W w N 0 op • 5
P p g di\ p 2 ci, ~ r
2 '-g, 3 rl. w :: i t 5f 'J.
0
, 0 a
r ,r2..... F. 5. A 1 1 k l' I. I" 1
8 F 1 2- 1 6 i ' 11
R Et = .5-. I. 2 OA ..c:, B 4 2 5. t m g
oi... P' 4". .-* i IS Xi
ot•
La
El „, Iii
.. ,, B ,
Ed R cil s i :i. 09.-- IT -,
4. ,vi'.6 '2. gfiP 6'7 : .1f44 ir !
g. c E. o o iv ,.Th i 4 pti
8 IF b ' C 4 �
uc' G g m, erg A.U.
5' r cp r 1 '" 1: :I q
w tp i C
g' R. ti-T1 „.+,0 i. ap ,e4.71: V ell =
2.2. r 4' 5 2 i7, ep 1 ;
(0 i ri rt. P. I/
og

@ I I g � d� p GI
., 0
a.) .U
1 g 0
b it
li M �'/ Q
.
t I .... r, L
i :I i 51 -c) ti
-0 g -
a-- 4 0 1 g ci
, i i i .v1.9 c', d 11 al 0
-.‘‘t
U• I0 co q L) � o Ei a 2
l 0 1 .....2 z ,Cr. c� S1 -8 IL?' A"CT (-I
a) •1A ri4 4 0 ° e 4 1
AO $� '�' may,. CI ? E g Q .g "1
-a . .°1 .13 1 4ii "p5., (,)
g '2 4 g i . .. 'g 4 t '-'' . b -0 ct . q.., 0 cu
4 Acad O .1 O s = 8 r-N6 1
0, co .a) 24 I
, adI 0 ' 1 f g P k g .g, 40 d' G1., a
a, d' 'b jII
U U ' osLo . - o cu
j .e. 2 •Dlt) Qc)"2 ° cli -g
4 t
. 0
c� w
e "§ '.g A I ..., 0\ , z ,. , 1 0 ,z z
.5g';' 2U4° .4 73 •ytg

Industrial User Pretreatment Permit(II P)
PART I
Specific Conditions
IUP, PART I, OUTLINE:
IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
B.) Schematic and Monitoring Locations
F.) Effluent Limits&Monitoring Requirements
G.) Definitions and i.imit Page(s)notes
A. IUP Basic Information:
Receiving Control Avtlmrity&W WTP name: POTW NPDES g:
City of Sanford Big Buffalo WWTP NC 0024141
IUP Name:
IUP Number
1 Arauco Panels USA, LLC 000042
IUP Effective Gate: Pipe Numbers,list all iceutated pipes:
March 24,2021 01&02
1Wrn Expiration date:
UN 40 CH(41(if applicable),or Ni
September 30,2024 40CFR 429
B. IUP History
• Effective Date Renewal or Description of changes over previous MP.
MuMication
11/5/2020 New Permit New IUP Permit,Transition from a general permit
3/24/2021 Modification Magnetic flow meter verification requirements added.
2

Industrial User Pretreatment Permit (IUP)
PART ilI
Special Conditions
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 ofineasurements of the volume of monitored discharges. Devices installed
shall be a 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 totalizer shall be non-resemble.At the time of issuance of the permit,
this method consists of continuous recording totalizing flow meters.
Pipe 01 and Pipe 02 flow meters shall be calibrated semiannually by the 30th of each
of the following months by a non-affiliated third party that must be approved by the
Control Authority:April and October. 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.
If a magnetic flow meter is being employed for flow measurement it must be verified.
Verification does not eliminate the need of calibration but indicates when/if
calibration needs to be performed_ Verification is more feasible as clamp-on
equipment can check the accuracy and precision of the magnetic flow meter as it
stays in operation whereas traditional calibration would require a complete removal
of the magnetic meter.
Regulated pipes 01 and 02 magnetic flow meters shall be verified semiannually(by
the 30thof April and October) by a non-affiliated third party that must be approved
by the Control Authority. Verification will consist of clamp-on ultrasonic flow
measurement equipment.
Documentation is required for the ultrasonic equipment,namely a factory calibration
report and should be filed as a baseline reference. It is also recommended to have an
ultrasonic configuration data sheet
Baseline measurement of magnetic field strength arc established at the time of
magnetic meter installation.These baseline measurements are compared to readings
of the ultrasonic meter.Comparing the readings of the ultrasonic meter to the readings
of the magnetic flow meter provide a basis to evaluate the magnetic flow meter's
accuracy and ability to report a verifiable result.By assessing these values, it can be
determined if the magnetic flow meter's calibration has shifted and if corrective
action needs to be taken.
If these values deviate by more than 4%,a complete full calibration of the magnetic
flow meter will be required.
14

0.8ox 3729 PHONE[phone]
anford,NC 27330 Fax [phone]
fit' of 'anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 21,2021
Mr.Norman Divers
Vice President,Environmental,Health,and Safety
Charah,Inc.
1036 Belmont Village Drive
Belmont,NC 28012
Subject:Transmittal Letter for Industrial User Permit#000035
Dear Mr.Divers:
Enclosed is modified Industrial User Permit 000035 (CHARAH,LLC).Changes are as follows:
1. Industrial self-sampling frequency was decreased from"twice per week"to"quarterly"
2. The magnetic flow meter verification process was clarified.
3. Changed the limits to a daily maximum of mg/1 from a lbs/day monthly average.
The modified pages are 1 through 6,and 15.Please add these modified pages to your current l UP.
Remove the former pages and place them in a separate"historical"file and retain for future reference.
Please read this permit carefully,paying special attention to the changes referenced above.If any parts
(sampling frequencies/requirements,limits,and/or magnetic meter verification language)contained in
this permit are iinaeceptable to you,you have the right to an adjudicatory hearing upon written request
within thirty(30)days following the receipt of this letter.Unless such demand is made,this decision
shall be final and binding.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

D 0.Box 3729 PHONE[phone]
nford,NC 27330 Fax [phone]
Qitp of 6anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 21,2021
Mr.Kyle Hoover
Director of Engineering,Environmental,and Quality
Charah Solutions,Inc.
12601 Plantside Drive
Louisville,Kentucky 40299
Subject:Transmittal Letter for Industrial User Permit#000035
Dear Mr.Hoover:
Enclosed is modified Industrial User Permit 000035 (CHARAH,LLC). Changes are as follows:
l_ Industrial self-sampling frequency was decreased from"twice per week"to"quarterly".
2. The magnetic flow meter verification process was clarified_
3. Changed the limits to a daily maximum of mg/1 from a lbs/day monthly average.
The modified pages are 1 through 6,and 15.Please add these modified pages to your current IUP.
Remove the former pages and place them in a separate"historical"file and retain for future reference.
Please read this permit carefully,paying special attention to the changes referenced above.If any parts
(sampling frequencies/requirements,limits,and/or magnetic meter verification language)contained in
this permit are unacceptable to you,you have the right to an adjudicatory hearing upon written request
within thirty(30)days following the receipt of this letter. Unless such demand is made,this decision
shall be final and binding.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

O.Box 3729 PHONE[phone]
anford,NC 27330 Fax [phone]
t ttp of 6anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 21,2021
Mr. Chris Long
Quality&Compliance Specialist
Charah Solutions,Inc.
1271 Moncure-Flatwood Road
Moncure,NC 27559
Subject Transmittal Letter for Industrial User Permit#000035
Dear Mr. Long:
Enclosed is modified Industrial User Permit 000035 (CHARAH,LLC). Changes are as follows:
1. Industrial self-sampling frequency was decreased from"twice per week"to"quarterly".
2. The magnetic flow meter verification process was clarified.
3. Changed the limits to a daily maximum of mg/1 from a lbs/day monthly average.
The modified pages are 1 through 6,and 15.Please add these modified pages to your current IUP.
Remove the former pages and place them in a separate"historical"file and retain for future reference.
Please read this permit carefully,paying special attention to the changes referenced above.If any parts
(sampling frequencies/requirements,limits,and/or magnetic meter verification language)contained in
this permit are unacceptable to you,you have the right to an adjudicatory hearing upon written request
within thirty(30)days following the receipt of this letter_ Unless such demand is made,this decision
shall be final and binding.
Sincerely,
ortj—
Sarah Jordan
Pretreatment Coordinator
City of Sanford

CITY OF SANFORD
Control AuManly ardkr Limo PINY
PERMIT
Industrial User Pretreatment Permit(IUP)
To Discharge Wastewater Under the
Industrial Pitient Program
IUP# 000035
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 and/or Municipality Sewer Use Ordinance. The
following Industry hereafter referred to by name or as the permittee:
Industry name.permktee:
CHARAH,LLC
Feoay Located at Street Address
1271 Moncure-Flatwood Road
city
Moncure,NC 27559
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 and/or Municipality listed below:
IUP control Authonly and/arNtaticpaay VYWTP name:
City of Sanford,Big Buffalo Creek WWTP
NPDES Number:
NC 0024147
VNNTP Address
5327 Iron Furnace Road
city.State,TIP
Sanford,North Carolina 27331-3729
in accordance with effluent limitations,monitoring requirements,and all other conditions
set forth in Parts I,II,and III of this Industrial User Pretreatment Permit(IUP).
Effective date,this penno and the authorization to discharge shall become
effective at midnight on uricdma
August 1, 2021
Expiration date,this wok and the authorization m discharge shy expire at
midnight on this dam
September 30, 2024
Date Signed of Public Wailes

IUP, PART I, OUTLINE:
A.) IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
E.) Schematic and Monitoring Locations
F.) Effluent Limits& Monitoring Requirements
G.) Definitions and Limit Page(s)notes
A. IUP Basic Information:
Receiving Control Authority&WWTP name: POTW NPDES#:
City of Sanford Big Buffalo WWTP NC 0024147
IUP Name: IUP Number.
Charah,LLC 000035
IUP Effective date: Pipe Numbers,list all regulated pipes:
August 1,2021 Pipe 01
IUP Expiration date: IUP 40 CFR#(if applicable),or N/A:
September 30,2024 N/A
B. IUP History.
l ;five Date Renewal or Description of changes over previous IUP.
Modification
July 22, 2015 New Permit Permit issued to regulate the discharge/leachate from coal ash
p p mining sites
August 4,2015 Modification Fixed effective dates on Part 1 A, B,and F to list effective date as
July 22, 2015.
November 17,2015 Modification Fixed typographical errors in detection limits (iron,bromide,zinc,
and aluminum)
September 8, 2016 ,Modification . Changed Molybdenum limit from 0.048 to 0.08
December 14,2016 Modification Changed Molybdenum limit from 0.08 to .134
September 30,2019 Renewal Renewed permit. Changed effective dates.
December 3,2020 Modification Detection levels changed on Aluminum,Iron,Zinc,Bromide,
Strontium, and Molybdenum to reachable laboratory limits.
March 24, 2021 .Modification ,Magnetic flow meter verification requirements added
August 1,2021 Modification Reduced industrial monitoring frequencies to quarterly. Removed
"April& October"as related to magnetic meter verification.
I ' Changed limits from lbs./day to mg/I to make comparisons
between differing IUP's limits more seamless.
2

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 and/or
Municipality.
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.
IU Treatment Units
List an Treatment ttr s Descriptions:
2 grit chambers 2 grit chambers with potential flocculent
Spill Protection addition for TSS control and pH control
1 million gallon storage tank and control
valve to monitor flow and head off any
spillage
3.) The Permittee is hereby authorized to, if required by the Control Authority
and/or Municipality and after receiving Authorization to Construct (A to C)
from the Control Authority and/or Municipality, 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#01,Description of Discharge:Discharge consists of coal combustion by-products,
including run-off via rainfall,from two sites.Leachate from one site will be trucked to
the second site and discharged to 1-million-gallon storage tank prior to pumping to
collection system_
E.) Monitoring Locations and Schematic:
The sampling point for Pipe 01 shall be in the discharge pipe at the triple pump
station,closest to the public sewer.
3

Receiving POTW name => Big Buffalo WWTP IU name=> Charah,LLC
IUP, Part 1 Section F: Receiving POTW NPDES#_> NC 0024147 IUP#_> 000035
Effluent Limits and Monitoring Requirements Effective date for these Limits=> August 1,2021 Pipe#_> of
Expiration date for these Limits=> September 30,2024 40 CFR#=> N/A
The Permittee may discharge from this specific THE LIMITS ON THIS PAGE ARE,(Check one below): if not applicable put N/A
Pipe number according to these specific dates, LIMITS for ENTIRE permit period=> X
effluent limits, and monitoring requirements INTERIM Limits for period# 1 =>
INTERIM Limits for period#2=>
FINAL Limits Page=>
Required
Sample Laboratory
Collection Detection
Monthly By City of Method Level in
Daily Max Units Average By Industry Sanford mg/L
1 Flow 0.288 MGD 0.144 MGD Daily &Each Each Metered
Composite Composite
Sampling Sampling
Event Event
2 pH(Range
Min./Max.) 6.0-10.5 Std. Units Quarterly 2 per six Grab Std. Units
months
3
Ammonia M&R mg/L Quarterly Once/year Composite 0.1
4
TSS M&R mg/L Quarterly Once/year Composite 2.5
5
Temperature 66 °C Quarterly Once/year Instantaneous °C
6
Aluminum M&R mg/L Quarterly Once/year Composite 0.01
4

J
7
Arsenic ! 0.099 mg/L Quarterly Once/year Composite 0.005
8
Cadmium i M&R mg/L Quarterly Once/year Composite 0.002
9
Chromium 0.0129 mg/L Quarterly Once/year Composite 0.005
10
Copper M&R mg/L Quarterly Once/year Composite 0.005
11
Cyanide M&R mg/L Quarterly Once/year Grab 0.01
12
Lead M&R mg/L Quarterly Once/year Composite 0.001
13 Low Level
Mercury 0.00083 mg/L 2 per Quarter Once/year Grab 0.000001
14
Molybdenum 0.056 mg/L 4 per Quarter Once/year Composite 0.005
15
Selenium 0.099 mg/L Quarterly Once/year Composite 0.002
16
Zinc 0.04288 mg/L Quarterly Once/year Composite 0.005
17
Silver M&R mg/L Quarterly Once/year Composite 0.005
18
Nickel 0.022 mg/L Quarterly Once/year Composite 0,005
19
Barium M&R Quarterly Once/year Composite 0,002
5

20
Beryllium M&R Quarterly Once/year Composite 0.001
21
Bromide M&R Quarterly Once/year Composite 0.1
22
Iron M&R Quarterly Once/year Composite 0,05
*Charah, LLC will be responsible for any additional monitoring cost incurred by Big Buffalo WWTP as it relates to this project. This will include any
monitoring done at Big Buffalo WWTP to determine interference and/or pass through,
**M&R is defined as Monitor and Report
***Quarterly is defined as specified below:
First Quarter: January 1st-March 3 l st
Second Quarter: April 1st-June 30th
Third Quarter: July 1st-September 30th
Fourth Quarter: October 1 St-December 31 st
6

Industrial User Pretreatment Permit(IUP)
PART III
Special Conditions
If a magnetic flow meter is being employed for flow measurement it must be verified.
Verification does not eliminate the need of calibration but indicates when/if calibration needs
to be performed.Verification is a more feasible process as clamp-on equipment can check the
accuracy and precision of the magnetic flow meter as it stays in operation whereas traditional
calibration requires complete removal of the magnetic meter.
Regulated pipe 01's magnetic flow meter shall be verified semiannually by a non-affiliated
third party that must be approved by the Control Authority. Semiannual periods defined as
such that the first verification event take place between January 1'to June 314 and the second
verification event occurring between July 1st-December 31st. The verification events must be
separated by at least 30 business days(i.e.,nonconsecutive months).Verification will consist
of clamp-on ultrasonic flow measurement equipment, unless there is a deemed acceptable
substitution approved by the Control Authority.
Documentation is required for the ultrasonic equipment, namely a factory calibration report
and should be filed as a baseline reference. It is also recommended to have an ultrasonic
configuration data sheet Reporting information gathered from the verification event is to be
postmarked by no more than 20 days after completion of the verification process.Additional
reporting specifications are listed on pages 8&9 under Part II of the General Conditions#2a-
c.
Baseline measurement of magnetic field strength are established at the time of magnetic meter
installation. These baseline measurements are compared to readings of the ultrasonic meter.
Comparing the readings of the ultrasonic meter to the readings of the magnetic flow meter
provide a basis to evaluate the magnetic flow meter's accuracy and ability to report a
verifiable result By assessing these values,it can be determined if the magnetic flow meter's
calibration has shifted and if corrective action needs to be taken.
If these values deviate by more than 5%, a complete full calibration of the magnetic flow
meter will be required.
15

Box 3729 PHONE[phone]
ord,NC 27330 Fax [phone]
itp of fs.anf orb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 21,2021
Ms. Savannah Carroll
985 Corinth Road
Moncure,NC 27559
Subject:Transmittal Letter for Industrial User Permit#000042
Dear Ms_Carroll:
Enclosed is modified Industrial User Permit 000042(Arauco Panels USA,LLC).Changes are as
follows:
1. Limits were changed from monthly averages to daily maximums(with the exception of flow)to
allow for resampling flexibility in respect of compliance determination.
2. Sampling recommendations were made to page 8. See the second paragraph under
"Representative Sampling".
3. The magnetic flow meter verification process was clarified.
The modified pages included are 1,2,5,6,8,14,and 15.Please add these modified pages to your current
IUP.Remove the former pages and place them in a separate"historical"file and retain them for future
reference.
Please read this permit caref
ully,paying special attention to the changes referenced above. If any parts
(measurement frequencies,sampling requirements,limits,and/or magnetic meter verification language)
contained in this permit are unacceptable to you,you have the right to an adjudicatory hearing upon
written request within thirty(30)days following the receipt of this letter.Unless such demand is made,
this decision shall be final and binding.
Sincerely,
qtta —
Sarah Jordan
Pretreatment Coordinator
City of Sanford

CITY OF SANFORD
Control Authority and/or illunicipaRy
PERMIT
Industrial User Pretreatment Permit(IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
000042 429
KIP Nu nber dD CFR Cate9ay(f AppicabIe)
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 and/or Municipality Sewer Use Ordinance. The
following Industry hereafter referred to by name or as the permittee:
Industry crane,permitee:
Arauco Panels USA,LLC
Fealty Located at Street Address
985 Corinth Road
City
Moncure
State,Tv)
North Carolina 27559
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 and/or Municipality listed below:
IUP Control Authority artdfor Municipality WWTP name:
City of Sanford Big Buffalo Creek WWTP
NPDES Number:
NC 0024147
W WrP Address
5327 Iron Furnace Road
City,State,Zip
Sanford,North Carolina 27331-3729
in accordance with effluent limitations,monitoring requirements,and all other conditions
set forth in Parts I,II,and III of this Industrial User Pretreatment Permit(IUP).
Effective date.this permit and the ailhorizatiNI to discharge shall become
effective at midnight on this date
August 1, 2021
apiration date,this permit and the aulhorizaffort to dhsdarge sham expire at
midnight on this date:
September 30, 2024
Date signed c works Director

Industrial User Pretreatment Permit(IUP)
PART I
Specific Conditions
IUP, PART I, OUTLINE:
A.) IUP Basic Information
B.) IUP Modification History
C.) Authorization Statement
D.) Description of Discharges
E.) Schematic and Monitoring Locations
F.) Effluent Limits&Monitoring Requirements
G.) Definitions and Limit Page(s)notes
A. IUP Basic Information:
Receiving Control Authority&WWTP name: POTW NPDES#:
City of Sanford Big Buffalo WWTP NC 0024147
IUP Name: IUP Number:
Arauco Panels USA,LLC 000042
IUP Effective date: Pipe Numbers,list all regulated pipes:
August 1,2021 01&02
IUP Expiration date: IUP 40 CFR#(if applicable),or N/A
September 30,2024 40CFR 429
B. IUP History
Effective Date Renewal or Description of changes over previous MP.
Modification
11/5/2020 New Permit New IUP. Transitioned from a general permit.
3/29/2021 Modification Magnetic flow meter verification requirements added.
8/1/2021 Modification Limits changed to daily maximums with the exception of flow
which was left as a monthly average. Sampling specifications
added and magnetic meter verification practices were clarified_
2

ReceivingPOTW name=> IUP Name ARAUCO PANELS
Big Buffalo WWTP=> USA,LLC
IUP, Part 1 Section F: Receiving POTW NPDES#_> NC 0024147 IUP#_> 000042
Effluent Limits and Monitoring Requirements Effective date for these Limits=> August 1,2021 Pipe#=> 01
Expiration date for these Limits=> September 30,2024 40 CFR#=>429
The Permittee may discharge from this specific if not applicable put N/A
THE LIMITS ON THIS PAGE ARE,(Check one below):
Pipe number according to these specific dates, LIMITS for ENTIRE permit period => X
effluent limits, and monitoring requirements INTERIM Limits for period# 1 =>
INTERIM Limits for period#2 =>
FINAL Limits Page =>
Monitoring Frequency Monitoring Frequency
Recommended
Daily Sample Collection Method Laboratory
Units Maximum By Industry By Ci Detection Level
Y tY (C Or G) in mail
1 Flow MGD Daily&Each Composite Each Composite Sampling Metered
Sampling Event Event
2 Arsenic mg/1 1 per six months Composite 0.002
3 Cadmium mg/1 0.01 1 per six months 4 per six months Composite 0.0005
4 Chromium mg/I 1.5 4 per six months Composite 0.005
5 Copper mg/1 0.4 4 per six months Composite 0.002
6 Cyanide mg/1 0.15 4 per six months 1 per six months Grab 0.01
7 Lead mg/1 0.3 4 per six months Composite 0.005
8 Mercury mg/1 2 per six months Composite 0.0002
9 Nickel mg/1 1.0 4 per six months Composite 0.005
10 pH(Range Std. 6.0-10.5* 4 per six months Grab Std. Units
Min./Max.) * Units
11 Silver mg/1 0.24 4 per six months Composite 0.001
12 Temperature * °C 66* 4 per six months Instantaneous
13 TTO mg/I 1 per six months providing the I per year providing the Grab 0.01
certification is not submitted certification is not submitted
14 Zinc mg/1 1.24 4 per six months Composite 0.01
15 Xylene mg/1 1 per six months Grab 0.01
16 Toluene mg/1 1 per six months Grab 0.01
17 Chloride mg/1 1 per six months Grab 0.5 _
5
' _ __use be advised pH and temperature will not be monthly averages.pH cannot be averaged and temperature has a numeric maximum.1

ReceivingPOTW name=> LW 1Yg111V!11\AV V V 1 n1\L'LU vues,
Big Buffalo WWTP=> LLC
Receiving POTW NPDES#_> NC 0024147 IUP#_> 000042
Effective date for these Limits=> August 1,2021 Pipe#_> 02
Expiration date for these Limits=> September 30,2024 40 CFR#=>429
if not applicable put N/A
THE LIMITS ON THIS PAGE ARE,(Check one below):
IUP, Part 1 Section F:
Effluent Limits and Monitoring Requirements LIMITS for ENTIRE permit period => X
INTERIM Limits for period# 1 =>
The Permittee may discharge from this specific INTERIM Limits for period#2 =>
Pipe number according to these specific dates, FINAL Limits Page => X
effluent limits, and monitoring requirements
Monitoring
Monitoring Frequency Frequency
Monthly
Average Sample
Collection Recommended
Daily Method Laboratory Detection
Units Maximum By Industry By City (C or G) Level in mg/1
1 Flow MGD .150 ' Daily&Each Composite Sampling Each Composite ' Metered
Event Sampling Event
2 Ammonia mg/1 1 per six months Composite 0.1
3 CBOD-5 mg/1 4 per six months Grab V 2.0
4 Molybdenum mg/1 1 per six months Grab 0.01
5 Oil&Grease mg/1 4 per six months Grab 5.0
6 pH(Range Std. 6.0-10.5* 4 per six months Grab
min/max)* Units
7 Selenium mg/1 1 per six months Composite 0.005
8 Temperature* °C 66* 4 per six months Instantaneous
9 Total Nitrogen mg/I ! ! 1 per six months ' Composite 0.5
(NO2+NO3+TKN)
10 Total Phosphorus mg/I l per six months Composite 0,1
11 TSS mg/1 4 per six months Composite 2.5
*Please be advised pH and temperature will not be monthly averages. pH cannot be averaged and temperature has a numeric maximum.
6

Industrial User Pretreatment Permit OUP)
PART II
General Conditions
Outline of PART II,
1. Representative Sampling 16. Federal and/or State Laws
2. Reporting 17. Penalties
3. Test Procedures 18. Need to Halt or Reduce
4. Additional Monitoring by Permittee 19. Transferability
5. Duty to comply 20. Property Rights
6. Duty to Mitigate 21. Severability
7. Facilities Operation,Bypass 22. Modification,Revocation,
Termination
8. Removed substances 23. Reapplication
9. Upset Conditions 24. Dilution Prohibition
10. Right of Entry 25. Reports of Changed Conditions
11. Availability of Records 26. Construction of pretreatment
facilities
12. Duty to provide information 27. Reopener
13. Signatory Requirements 28. Categorical Reopener
14. Toxic Pollutants 29. General Prohibitive Standards
15. Civil and Criminal Liability 30. Reports of Potential Problems
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.
The objective of industrial self-sampling is to obtain quantitative data that is representative of
normal/routine industrial operation.For this reason, it is strongly recommended that all sampling
parameters be drawn simultaneously and collected consecutively over the course of one week
(running from Sunday to Saturday) occurring under standard operational conditions. If an issue
arises concerning this matter,please notify the POTW within 24 hours of its discovery.
2. Reporting
a.) Monitoring results obtained by the permittee shall be reported on forms specified by the
Control Authority and/or Municipality post marked no later than 20 days following the
month in which the data was received from the Certified Lab. If no disrharge 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 ofthese
and all other reports required herein shall be submitted to the Control Authority and/or
Municipality and shall be sent to the following addtess.
Sarah Jordan
- Pretreatment Coordinator
City of Sanford Wastewater Management Facility
P.O.Box 3729
Sanford,North Carolina 2733 i-3729
8

Industrial User Pretreatment Permit OUP)
PART III
Special Conditions
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 flow meter capable of measuring flows with a maximum deviation of less
than 5% from true discharge rates throughout the range of expected discharge
volumes. The devices shall be installed, calibrated, and maintained to ensure
accuracy.The totalizer shall be non-resettable.At the time of issuance of the permit,
this method consists of continuous recording totalizing flow meters.
If a magnetic flow meter is being employed for flow measurement it must be verified.
Verification does not eliminate the need of calibration but indicates when/if calibration
needs to be performed_ Verification is a more feasible process as clamp-on equipment
can check the accuracy and precision of the magnetic flow meter as it stays in
operation whereas traditional calibration requires complete removal of the magnetic
meter.
Regulated pipe 01 and 02's magnetic flow meters shall be verified semiannually by a
non-affiliated third party that must be approved by the Control Authority. Semiannual
periods defined as such that the first verification event take place between January
to June 31'and the second verification event occurring between July 1st-December
31 g. The verification events must be separated by at least 30 business days(i.e.,
nonconsecutive months). Verification will consist of clamp-on ultrasonic flow
measurement equipment,unless there is a deemed acceptable substitution approved by
the Control Authority.
Documentation is required for the ultrasonic equipment,namely a factory calibration
report and should be filed as a baseline reference. It is also recommended to have an
ultrasonic configuration data sheet.Reporting information gathered from the
verification event is to be postmarked by no more than 20 days after completion of the
verification process.Additional reporting specifications are listed on pages 8&9
under Part II of the General Conditions#2a c.
Baseline measurement of magnetic field strength are established at the time of
magnetic meter installation.These baseline measurements are compared to readings of
the ultrasonic meter_ Comparing the readings of the ultrasonic meter to the readings of
the magnetic flow meter provide a basis to evaluate the magnetic flow meter's
accuracy and ability to report a verifiable result.By assessing these values,it can be
determined if the magnetic flow meter's calibration has shifted and if corrective action
needs to be taken.
14

Industrial User Pretreatment Permit(IUP)
PART III
Special Conditions
If these values deviate by more than 5%,a complete full calibration of the magnetic flow
meter will be required_
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
(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 SA .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_
5. Total Toxic Organics (TTO)Definition
"TTO", or Total Toxic Organics, is the sum of the concentrations of the toxic
organic compounds listed in 40 CFR 429pmt that are found in the permittee's
process discharge at a concentration greater than 0.01 mg/1.
7. Total Toxic Organics(TTO) Certification
In lieu of monitoring for TTO,the permittee may, upon submitting to the Control
Authority one sample showing TTO compliance and a toxic organic management
plan,make the following certification every six months:
"Based upon my inquiry of the person or persons directly responsible for
managing compliance with the permit limitation for total toxic organics(TTO),
I certify that, to the best of my knowledge, no dumping of concentrated toxic
organics into the wastewaters has occurred since filing of the last monitoring
report. I further certify that this facility is implementing the toxic organic
management plan submitted to the Control Authority."
15

r
City of 'anforb
WASTEWATER MANAGEMENT FACILITY
Sarah Jordan
Pretreatment Coordinator
sarah.iordanno.sanfordnc.net
November 12,2021 Phone:[phone]
Mr.Keyes McGee
Department of Water Quality,PERCS
1617 Mail Service Center
Raleigh,N. C. 27699-1617
Subject:Modified IUP 000040
tar Mr. McGee:
The City of Sanford is submitting modified IUP 000040 with a flow limit increase on pipe 01.This flow limit
modification came about due to the facility adding a shift and having increased production.
In this mailing,I have included the modified part of the permit and a copy of the transmittal letters that was
mailed to the industry representatives.The modified permit includes a new signed cover page,and an updated
IUP history. I also have included an updated allocation table accounting for this flow increase.
If there are questions or comments,please feel free to contact me at(919)777-1783.
Sincerely,
dcj *-&
Sarah Jordan
Pretreatment Coordinator
City of Sanford
Enclosures

I
'�

DocuSign Envelope ID:3CD6FB72-4CDB-49C0-8ABD-8496417FBF1B
prar :
ROY COOPER ., ` {
Governor b� `' ,�;, ''
La
TONNE DELLI-GATTI
rcretary ,�
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
4/20/2021
Via Electronic Mail(sarah [e-mail])
Ms. Sarah Jordan
Pretreatment Coordinator
City of Sanford
P.O.Box 3729
Sanford,NC 27331
Subject: Pretreatment Review of Industrial User Pretreatment Permit Modifications
Program:City of Sanford
WWTP:Big Buffalo WWTP,NPDES#:NC0024147
Lee County
Dear Ms.Jordan:
The Municipal Unit of the Division of Water Resources has reviewed the Industrial User Pretreatment Permit
(IUP)modifications submitted by the City of Sanford for the following Significant Industrial Users(SIUs).The
IUPs were received by the Division on March 26,2021.
SIU# SIU NAME
000035 Charah,LLC
000042 Arauco Panels USA,LLC
The review indicates that the IUPs are adequate and meets the minimum requirements of 15A NCAC 2H.0905
and.0916 and 40 CFR 403.8(f)(1)(iii).The allocation table,maintained in the Division's database,has been
updated accordingly.
Regardless of this approval action today,within 180 days of the effective date of any reissued NPDES permit(or
any subsequent NPDES permit modification)the Permittee would be required to submit to the Division a written
technical evaluation of the need to revise local limits (i.e., an updated IWS, or documentation of why one is not
needed).This action may include revising,updating or adding to the list of Significant Industrial Users(SIU's).
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW.It is the
POTW's responsibility to ensure that these objectives are consistently met. 1
If you have any questions or comments,please contact Michael Montebello at(919)707-3624[email:
[e-mail]].Thank you for your continued support of the Pretreatment Program.
Sincerely,
nnAAD,ocuSigned byy:A``t,�y ',..''''``
, im ►rWV��dlt
ksl/sanford_ U
iup 056 C464531431644FE...
Ec: Municipal nit File
Cheng pal RRo for S.Daniel Smith,Director
Central Files(Laserfische) Division of Water Resources
North Carolina Department of Environmental Quality Division of Water Resources
t. 47...E / 512 North Salisbury Street ! 1617 Mail Service Center I Raleigh,North Carolina 27699-1617
919.707.9000

' yA
0.Box 3729
anford,NC 27330 PHONE[phone]
Fax [phone]
(;itp of anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 21,2021
Mr.Keyes McGee
Department of Water Quality,PERCS
1617 Mail Service Center
Raleigh,NC 27699-1617
Subject:Modifications to IUP 000035&IUP 000042
Dear Mr.McGee:
The City of Sanford is submitting modifications for IUP 000035 and IUP 000042.
The modifications for IUP 000035(CHARM-I,LLC)are as follows:
• Industrial self-sampling frequency was decreased from"twice per week"to"quarterly"due to
the slowing of leachate production.From the establishment of IUP 000035 in 2015 we've
gathered numerous data points and analytical data. Quarterly sampling is more frequent than the
majority of the City of Sanford's IUPs.
• The magnetic flow meter verification process was clarified and the date stipulations of this
verification having to arbitrarily take place during April and October.
• The limits were also changed from a pound's monthly averages to daily maximum calculated in
mg/Ito align with our other pretreatment program IUPs and to make comparisons between
differing IUP limits more seamless. This was done by back calculating pound per day limits to
mg/1 using the pounds formula.
The modifications for IUP 000042(Arauco Panels USA,LLC)are as follows:
• Limits were changed from monthly averaged from monthly averages to daily maximums(with
the exception of flow)to clarify and allow flexibility of any needed resampling with respect to
compliance determinations.
• Sampling recommendations were added to Part II of the General Conditions under 1.
Representative Sampling.This was added due to Arauco's sporadic self-sampling during the
January June 202I reporting period_Though it's not an official IUP condition,a sampling event
of one week solidifies and simplifies one result due date,post marked no later than 20 days
following the month in which the data was received from the Certified Lab. Sporadic sampling
made it difficult to ensure the correct results were received within the required timeframe.

▪ The magnetic flow meter verification process was clarified and the date stipulations of this
verification having to arbitrarily take place during April and October.
The enclosures I've included are:
• Three transmittal letters relating to the modifications of IUP 000035 because of the multiple
factions and locations of Charah leads.
• The modified pages of IUP 000035.
• One transmittal letter to Arauco's Savannah Carroll detailing the modifications of IUP000042.
• The modified pages of RIP 000042.
• The modified allocation table using Charah's new mg/1 limits opposed to their pound's limits. I
will also send this electronically as I believe it's easier to read that way.
If there are questions or comments,please don't hesitate to contact me via email or by phone.
qr./a--
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Workbook Name : Allocation Table for State with IUP ModsJul2021, Worksheeil iiiiiY 4:38 PM
age 2of4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 07/21/21
Permits last modified: 07/21/21
POTW.> City of Sanford
NPDES#=> NC0024147
kmmonia I Arsenic Cadmium Chromium 1 Copper
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load I Conc. Load Conc. Load Conc. Load Conc. Load
Count (please list alphabetiely) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day
1 Arauco 0026 01 &02 0.01 0.01251 1.5 1.8765 0.4 0.50041
2 Caterpillar Boone Trail 0040 01 &02 0.0500 0.0156 1.5000 0.4666 1.4200 0.4417
3 Caterpillar Womack 0033 01 &02 0.0500 0.0156 1.5000 0.4666, 1.4200 0.4417
4 Charah 0035 0001 0.0990 0.2378 0.0129 0.0310
5 Coty 0010 0001
6 Hydro Tube 0034 01 &02 _ 0.0500 0.0031 1.5000 0.0938 1.4200 0.0888
7 Magneti Marelli 0007 01 &02 0.05000.0167 1.7000 0.5671 1.4200 0.4737
8 Moen 0008 01 &02 1.5000 3.6779 �4 0 3.4818
9 Pfizer 0022 01 &02T 61.00 225.17 0.0500h 0.1846 1.5000 5.5371
10 STI Polymer 0032 01 &02
11 Trion 0013 01 &02 0.0118 1.5000 0.3547 1.4200 0.3357
12 Tyson 0041 0001
13
1...... .........1.
Column Totals=> I 2251 , 0.23781 1 0.2318 1 10.72821 1 4.8218!
Sludge Sludge AS/NitITF
Basis=> Design Ceiling Ceiling inhibition Sludge Ceiling
MAHL from HWA(lbs/day)=> 2421.94 0.3918 0.2983 12.8527 11.2336
Uncontrollable Loading(lbs/day)_> 765.82 0.0636 0.0058 0.3381 3.7857
Total Allowable for Industry(MAIL)(lbs/day)=> 1656.12 0.3282 0.2925 12.5146 7.4478
Total Permitted to Industry(lbs/day)_> 225.17 0.2378 0.2318 10.7282 4.8218
MAIL left(lbs/day)_> 1430.95 0.0905 0.0607 1.7864 2.6261
Percent Allow.Ind.(MAIL)still available(%)_> 86.4% 27.6% 20.8% 14.3 % 35.3 %
Percent MARL still available(%)=> 59.1 % 23.1 % 20.4% 13.9% 23.4%
5 Percent MARL(lbs/day)_> 121.10 0.0196 0.0149 0.6426 0.5617

Workbook Name : Allocation Table for State with IUP ModsJul2021, Workshe 'ilirii?/ , 4:38 PM
age 3 of 4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 07/21/21
Permits last modified: 07/21/21
Pores=> City of Sanford
NPDES#=> NC0024147
I (Cyanide I Lead 'Mercury Molybdenum I Nickel '
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please list alphabeticly) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day
1 Arauco 0026 1.01 &02 0.15 0.18765 0.3 0.3753 1 1.2510
2 Caterpillar Boone Trail 0040 01 &02 0.1500 0.0467 0.3000 0.0933 0.3111_
3 Caterpillar Womack 0033 01 &02� 0.1500 0.0467 0.3000 0.0933 1.0000 0.3111
4 Charah 0035 0001 0.1500 0.3603 0.00083 0.00199 0.0560 0.1345 0.0220 0.0528
5 Coty 0010 0001 _
6 Hydro Tube 0034 +01 &02 0.1500 0.0094 0.0188 -_ 0.5000 0.0313
7 Magneti Marelli 0007 01 &02 0.1500 0.0500 0.3000 0.1001 0.5000 0.1668
8 Moen 0008 01 &02 0.1500 0.3678 0.3000 0.7356 0.5000 1.2260
9 Pfizer 0022 01 &02 0.1000 0.3691 0.3000 1.1074
10 STI Polymer 0032 01 &02 0.1500 0.0313 0.1000 0.0209
I
11 Trion 0013 01 &02 0.1500 0.0355 0.3000 0.0709 0.5000 0.1182
4 I
12 Tyson 0041 0001 -�
i 4 I . --4
13
Column Totals=> I 1.27001 1 2.14691 0.0019941 0.1345] 1 1.9062
Sludge
Stream Sludge Sludge Ceiling
Basis=> Std Ceiling NPDES Ceiling HASL
MAHL from HWA(lbs/day)_> 2.4820 3.2374 0.097863 0.3287 4.2244
Uncontrollable Loading(lbs/day)_> 0.0694 0.1792 0.008670 0.1792, 0.2254
Total Allowable for Industry(MAIL)(lbs/day)_> 2.4127 3.0582 0.089194 0.1495 3.9990
Total Permitted to Industry(lbs/day)_> 1.2700 2.1469 0.001994 0.1345 1.9062
MAIL left(lbs/day)_> 1.1426 0.9113, 0.087200 0.0150 2.0928
Percent Allow. Ind. (MAIL)still available(%)_> 47.4% 29.8% 97.8% 10.0% 52.3 %
Percent MAHL still available(%)_> 46.0% 28.1 % 89.1 % 4.6% 49.5%
5 Percent MAHL(lbs/day)_> _ 0.1241 0.1619 0.004893 0.0164 0.2112

Workbook Name : Allocation Table for State with IUP ModsJul2021, Workshei'iliriia/ntl, 4:38 PM
"' Page 4 of 4
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 07/21/21
Permits last modified: 07/21/21
Porw=> City of Sanford
NPDES#=> NC0024147
Selenium I Silver I Zinc Total Nitrogen Total Phos. I
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load t Conc. Load Conc. Load Conc. Load
Count (please list alphabeticly) number number mg/1 i lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day
1 Arauco 0026 01 &02 0.24 0.30024 1.24 1.5512 I
2 Caterpillar Boone Trail _ 0040 01 &02 0.2400 0.0747 1.2400 0.3857
3 Caterpillar Womack 0033 01 &02 0.2400 0.0747 1.2400 0.3857
4 Charah 0035 0001 0.0990 0.2378 0.0429 0.1030
5 Coty , 0010 0001 1..........
6 Hydro Tube 0034 01 &02 0.2400 0.0150 ' 1.2400 0.0776
7 Magneti Marelli 0007 01 &02 0.2400 0.0801 1.4800 0.4937 _
8 Moen 0008 01 &02 ' 0.2400 0.5885 1.2400 3.0404
9 Pfizer 0022 01 _ _0.8859 ��
10 STI Polymer 0032 01 &02 0.0209
11 Trion 0013 01 &02 0.2400 0.0567 1.2400 0.2932
12 Tyson 0041 0001 --.4 0.2400
5.1708
13
/
' Column Totals=> I 0.2378 1.7009 1 9.5853J ( 0.001 1 0.00
Sludge AS/Nit/TF Sludge
Basis=> Ceiling inhibition Ceiling Design Design
MAHL from HWA(lbs/day)_> 0.4702 8.1553 22.3192 ####### 2081.66
Uncontrollable Loading(lbs/day)_> 0.0433 0.0173 5.8693
Total Allowable for Industry(MAIL)(lbs/day)_> 0.4268 8.1379, 16.4498 ####### #######
Total Permitted to Industry(lbs/day)=> 0.2378. 1.7009 9.5853 0.00 0.00
MAIL left(lbs/day)=> 0.1891 6.4371 6.8646 ####### #######
Percent Allow.Ind. (MAIL)still available(%)=> 44.3 % 79.1 % 41.7% ####### #######
Percent MAHL still available(%)_> 40.2% 78.9% 30.8% ####### #######
5 Percent MAHL(lbs/day)_> 0.0235 _ 0.4078 1.1160 227.18 104.0832

Workbook Name : Allocation Table for State with IUP ModsJul2021, Workshearil nnia/il, 4:38 PM
�'page 1 of 4
Allocation Table Spreadsheet Instructions:
Headworks last approved: 02/22/18 1)Applicable Values should be entered in the Heavy Bordered cells. Rest of worksheet is protected,password is
Allocation Table updated: 07/21/21 2)Formulas are discussed in the Comprehensive Guidance,Chapter 6,Section C.
Permits last modified: 07/21/21 3)HWA and AT worksheets in this workbook are linked. Pollutant Names,MAHLs,Basis,and Uncontrollable load
in this AT worksheet are automatically entered from the HWA spreadsheet. This includes pollutant names in
columns AT through BK.
POTW=> City of Sanford
NPDES#=> NC0024147
FLOW I BOD I TSS E
Industry Type Renewal Modification Date 'ermit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe of Effective Effective Permit Conc. Load I Conc. Load
Count (please list alphabeticly) number number Industry Date Date Expires MGD gal/day mg/1 lbs/day mg/1 lbs/day
1 Arauco 0026 01 &02 I 429 I 11/5/2020 I I 9/30/2024 0.15 150000 - I
2 Caterpillar Boone Trail 0040 01 &02 433 09/30/19 09/30/24 0.0373 37,300
3 Caterpillar Womack 0033 01 &02 433 09/30/19 09/30/24 0.0373 37,300
_
4 Charah 0035 0001 coal ash 09/30/19 09/30/24 288,000
5 Coty 0010 0001 cosmetics 09/30/19 _ 09/30/24 0.0661 66,098
6 Hydro Tube 0034 01 &02 433 09/30/19 09/30/24 0.0075 7,500
w
7 Magneti Marelli 0007 01 &02 433 &464 09/30/19 09/30/24 I 0.0400 40,000 885.00 295.24
8 Moen 0008 01 &02 433 09/30/19 09/30/24 0.2940 294,000
9 Pfizer 0022 01 &02 433 09/30/19 _ 09/30/24 0• .4426v 442,610
10 STI Polymer 0032 01 &02 433 09/30/19 09/30/24 0.0250 25,000
11 Trion 0013 01 &02 433 09/30/19 09/30/24 0.0284 28,350 .....,
12 Tyson 0041 0001 09/30/19 09/30/24 0.5000' 50,000
13 '
Column Totals=> 1.72891 1,278,858 1 2951 0
Basis=> NPDES Design Design
MAHL from HWA(lbs/day)=> NPDES Permitted Flow=> 12.0000 23419 40032
Uncontrollable Loading(lbs/day)_> 3.4651 5577 8641
Total Allowable for Industry(MAIL)(lbs/day)_> 8.5349 17841 31391
Total Permitted to Industry(lbs/day)_> 1.7289 295 0
MAIL left(lbs/day)_> 6.8061 17546 31391
Percent Allow. Ind. (MAIL)still available(%)=> 79.7% 98.3% 100.0%
Percent MAHL still available(%)_> 56.7% 74.9% 78.4%
5 Percent MAHL(lbs/day)=> 0.6000 1171 2002

DocuSign Envelope ID:7DCE5A45-3850-4F3D-SEEC-827955CD69F5
cos STATE q,
it:..!; 4:
ROY COOPER. i 1I'—
Governor lei j'.
LIZABETH S.BISER
'
cretary �Quw *
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
11/15/2021
Via Electronic Mail(sarah [e-mail])
Ms. Sarah Jordan
Pretreatment Coordinator
City of Sanford
P.O.Box 3729
Sanford,NC 27331
Subject: Pretreatment Review of Industrial User Pretreatment Permit Modifications
Program:City of Sanford
WWTP: Big Buffalo WWTP,NPDES#NC0024147,Lee County
Dear Ms.Jordan:
The Municipal Unit of the Division of Water Resources has reviewed the Industrial User Pretreatment Permit
(IUP)modifications submitted by City of Sanford for the following Significant Industrial Users(SIUs).The IUPs
were received by the Division on 07/26/2021.
SIU# SIU NAME
000035 Charah,LLC
000042 Arauco Panels USA,LLC
The review indicates that the IUPs are adequate and meets the minimum requirements of 15A NCAC 2H.0905
and.0916 and 40 CFR 403.8(f)(1)(iii).The allocation table,maintained in the Division's database,has been
updated accordingly.
Regardless of this approval action today, within 180 days of the effective date of any reissued NPDES permit(or
any subsequent NPDES permit modification)the Permittee would be required to submit to the Division a written
technical evaluation of the need to revise local limits (i.e., an updated IWS, or documentation of why one is not
needed).This action may include revising,updating or adding to the list of Significant Industrial Users(SIU's).
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW.It is the
POTW's responsibility to ensure that these objectives are consistently met.
If you have any questions or comments,please contact Keyes McGee at(919)707-3626 [email:
[e-mail]].Thank you for your continued support of the Pretreatment Program.
Sincerely,
p—DocuSigned by:
tkm/Sanford iup_057 it(,i(,iutd, t/fat.
Ec: Municipal Unit File '—C464531431644FE...
Cheng Zhang,RRO for S.Daniel Smith,Director
Central Files(Laserfische) Division of Water Resources
North Carolina Department of Environmental Quality I Division of Water Resources
D_E 512 North Salisbury Street 11617 Matl Service Center I Raleigh.North Carolina 27699 1617
NA,,PTU:JC INA
0.1"'""1"6."°mt41O"a\ 919.707.9000

DocuSign Envelope ID:7D786E92-1 F55-4384-A4F1-1201 DE294DE9
tot STATE,*
ROY COOPER
Governor
LIZABETH S.BISER " !3
rcretary '��auw .
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
12/6/2021
Via Electronic Mail([e-mail])
Ms.Sarah Jordan
Pretreatment Coordinator
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Subject: Pretreatment Review of Industrial User Pretreatment Permit Modification
Program:City of Sanford
WWTP:Big Buffalo WWTP,NPDES#NC0024147,Lee County
Dear Ms.Jordan:
The Municipal Unit of the Division of Water Resources has reviewed the Industrial User Pretreatment Permit
(IUP)modification submitted by City of Sanford for the following Significant Industrial Users(SIU).The IUP
was received by the Division on I I/16/2021.
SIU# SIU NAME
000040 CATERPILLAR INC.
The review indicates that the RIP is adequate and meets the minimum requirements of 15A NCAC 2H.0905 and
.0916 and 40 CFR 403.8(f)(1)(iii).The allocation table,maintained in the Division's database,has been updated
accordingly.
Regardless of this approval action today,within 180 days of the effective date of any reissued NPDES permit(or
any subsequent NPDES permit modification)the Pernuttee would be required to submit to the Division a written
technical evaluation of the need to revise local limits (i.e., an updated IWS, or documentation of why one is not
needed).This action may include revising,updating or adding to the list of Significant Industrial Users(SIU's).
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW.It is the
POTW's responsibility to ensure that these objectives are consistently met.
If you have any questions or comments,please contact Keyes McGee at(919)707-3626[email:
[e-mail]].Thank you for your continued support of the Pretreatment Program
Sincerely,
r—DocuSigned by:
tkm/Sanford_iup_058 l d 4 , kbtkidiJL
Ec: Municipal Unit File _C464531431644FE...
Cheng Zhang, RRO for S.Daniel Smith,Director
Central Files(Laserfische) Division of Water Resources
No of Enmt Quality Di We Reu
Sitrth NorthCarolina SalisburyDepartment Street ( 1617 Mailviron Serviceenal Center I I Raleigh.vision Northofat
Carolinar so
2769rces9-1617
919.707.9000

PG Box 3729 µy~� Phone (919)//l-1783
Sanford,NC 27331
ry Fax [phone]
City of 3a11f o rb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
December 10,2021
Mr. Keyes McGee
Division of Water Quality,PERCS
1617 Mail Service Center
Raleigh,N. C. 27699-1617
Subject: Recension of IUP 000007
Dear Mr. McGee:
Upon request dated November 23,2021 and an inspection of the Magneti Marelli site on
November 19,2021 permit 000007 is officially rescinded, effective immediately.All
production and accompanying process waste ceased discharge to the City of Sanford WWTP
by October 1,2021. The discharge pipe has been closed and production tanks have been
pumped and cleaned.
I have included a copy of their request,a copy of the transmittal letter of notification from the
City of Sanford,and an updated allocation table with regard to their voided permit. Let me
know if there are questions regarding this information.
Sincerely,
52A
Sarah Jordan
Pretreatment Coordinator
City of Sanford

PO Box 3729 Phone [phone]
919
Sanford,NC 27331 � -� Fax [phone]
City of 6mnforb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
December 10,2021
James Suer
Magneti Marelli Powertrain USA LLC
2101 Nash Street
Sanford,NC 27331-0548
Subject: Recension of IUP 000007
Dear Mr.Siler:
Upon inspection of Magneti Marelli on November 19,2021 and recension request,permit
000007 is officially rescinded,effective immediately. It has been a pleasure working with you
and the entire staff at Magneti Marelli.Please let me know if you have questions.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

TARED$
November 23, 2021
Sarah Jordan
Pretreatment Coordination
City of Sanford Wastewater Management Facility
P.O. Box 3729
Sanford,NC 27331
Subject: Notification to Rescind Industrial User Pretreatment Permit Number 000007
Dear Ms.Jordan:
Marelli North Carolina USA LLC, located at 2101 Nash Street, Sanford, NC 27330,has ceased all production
operations at its facility.
II wastewater treatment tanks have been pumped and cleaned. The discharge pipe has been closed to
prevent any discharge of water into the city sewer system. Effective immediately, please rescind Industrial
User Pretreatment Permit Number 000007.
If you have any questions,or require additional information, please contact me at 919-775-6463. I have
enjoyed working with you,the City of Sanford, and the Pretreatment staff.
Sincerely,
James D.Siler
WWTPO/ORC
Margin North Carolina t1C
grail„
1 Nash Street
ford,NC 27330
• 919.776-4111

Page 1 Allocation Table for State Modified December 2021.xlsx
Allocation Table Spreadsheet Instructions:
Headworks last approved: 02/22/18 1)Applicable Values should be entered in the Heavy Bordered cells. Rest of worksheet Is protected, password is
2
Allocation Table updated: 12/10/21
p 2)Formulas are discussed in the Comprehensive Guidance,Chapter 8,Section C.
Permits last modified: 11/12/21 3)HWA and AT worksheets in this workbook are linked, Pollutant Names,MAHLs,Basis,and Uncontrollable load
In this AT worksheet are automatically entered from the HWA spreadsheet. This Includes pollutant names In
columns AT through BK.
pow City of Sanford
NPDES#=> NC0024147
FLOW I BOD I TSS )
Industry Type Renewal Modification Date 'ermit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe of Effective Effective Permit Conc. Load Conc. Load
Count (pleat list elphabedely) number number Indus Date Date Ex sires MGD l al/da m l 1 lbs/da m. 1 lbs/da
1 Arauco 0042 01 &02 429 11/5/2020 9/30/2024 0.15 150000
2 Caterpillar Boone Trail 0040 01 &02 433 09/30/19 11/12/21 09/30/24 0.0270 27,000
3 Caterpillar Womack 0033 01 &02 433 09/30/19 09/30/24 0.0373 37,300
4 Charah 0035 0001 coal ash 09/30/19 09/30/24 0.2880 288,000 ........
5 Coty 0010 0001 cosmetics 09/30/19 09/30/24 0.0661 66,098 . _ ��
r
6 Hydro Tube 0034 01 &02 433 09/30/19 09/30/24 0,0075 7,500
7 Moen 0008 01 &02 433 09/30/19 09/30/24 0.2940 294,000
8 Pfizer 0022 01 &02 433 09/30/19 09/30/24 0.4426 442,610
9 STI Polymer 0032 01 &02 433 09/30/19 09/30/24 0,0250 25,000 .a...a.a....
10 Trion 0013 01 &02_ 433 09/30/19 09/30/24 0.0284 28,350 ' ��
11 son ' 0041 0001 09/30/19 09/30/24 0.5000 50,000
12 IMIIIIIMIIIIIIIIIIIIIOIIIIII
Column Totals=> 1.6889 1,238,858 0 0
Basis=> NPDES Design Design
MAHL from HWA(1bs/day)=> NPDES Permitted Flow=> 12.0000 23419 40032
Uncontrollable Loading(lbs/day)_> 3.4651 5577, 8641
Total Allowable for Industry(MAIL)(lbs/day)_> 8.5349, 17841 31391
Total Permitted to Industry(lbs/day)_> 1.6889 0, 0
MAIL left(ibs/day)_> 6.8461 17841 31391
Percent Allow.Ind.(MAIL)still available(%)_> 80.2% 100.0% 100.0%
Percent MAHL still available(%)=> 57.1 % 76.2 % 78.4%
5 Percent MAHL(lbs/day)=> 0.6000 1171 2002

Page 2 Allocation Table for State Modified December 2021.xlsx
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 12/10/21
Permits last modified: =EMI
porw6> City of Sanford
NPOES#=> NC0024147
kmmonia I Arsenic Cadmium Chromium I Copper I
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load Conc. Load Conc. Load Conc. Load
Count (please liit alphabeticly) number number mg/1 lbs/day mg/I lbs/day mg/I lbs/day mg/1 ibs/ me.... lbs/day
1 Arauco 0042 01 &02 0.01�0.01251 1.5a 1.8765 0.4 0.50041
2 Caterpillar Boone Trail 0040 01 &02 0.0500 0.0113 1.5000 0.3378 1.4200 0.3198
3 Caterpillar Womack 0033 01 &02 _ 0.0500 0-0 6 1.5000 0.4666 t 1.4200 0.4417
4 Charah 0035 0001 0.0990 0.2378 0.0129 0.0310
5 Coty 0010 0001
6 Hydro Tube 0034 " 01 &02 4-_ -I. 0 0500 0.0031 1.5000 0.0938 ' 1.4200 0.0888
7 Moen 0008 01 &02 ��~ 1.5000 3.6779 1.4200 3.4818
8 Pfizer 0022 01 &02 61.00 225.17 0.0500 0.1846 1.5000 5.5371
9 STI Polymer 0032 01 &02 _
10 Trion 0013 01 &02 -.4.---. 0.0500 0.0118�1.50000 0.3547 1.4200 0.3357
11 Tyson 0041 0001
12
Column Totals=> 225 0.2378 L 0.2151 1 10.16111 r 4.3481
Sludge Sludge AS/NIVtF
Basis=> Design Calling Ceiling Inhibition Sludge Ceiling
MAHL from HWA(ibs/day)_> _ 2421.94 0.3918 0.2983 12.8527 11.2336
Uncontrollable Loading(lbs/day)_> 765.82 0.0636 0.0058 0.3381 3.7857
Total Allowable for Industry(MAIL)(lbs/day)_> 1656.12 0.3282 0.2925 12.5146 7.4478
Total Permitted to Industry(ibs/day)_> 225.17 0.2378 0.2151 10.1611 4.3481
MAIL left(lbs/day)_> - 1430.95 0.0905 0.0774 2.3535 3.0998
Percent Allow.Ind.(MAIL)still available(%)_> 86.4% 27.6% 26.5 % 18.8% 41.6%
Percent MARL still available(%)_> 59.1 % 23.1 % 26.0% 18.3% 27.6%
5 Percent MAHL(lbs/day)_> 121.10 0.0196 0.0149 0.6426 0.5617

Page 3 Allocation Table for State Modified December 2021.xlsx
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 12/10/21
Permits last modified: 11/12/21
POTw=> City of Sanford
NPDES#=> NC0024147
Cyanide I Lead 'Mercury Molybdenum I Nickel I
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load I Conc. Load l Conc. Load Conc. Load
Count t (plane liatalphabaicly) number number mg/1 lbs/day mg/1 lbs/day mg/I lbs/day mg/1 lbs/d y_ mg/I lbs/day
1 Arauco 0042 01 &02 0.15 0.18765 0.3 0.3753 1 1.2510
2 Caterpillar Boone Trail 0040 01 &02 0.1500 0.0338 ' 0.3000 0.0676 1.0000 0.2252
3 'Caterpillar Womack 0033 01 &02 0 1500 0.0467 0.3000 0.0933 1.0000 0.3111
4 bharah 0035 0001 0.1500 0.3603 0.000083` 0.00199 0.0560 0.1345 0.0220 0.0528
5 Cot), 0010 0001
6 Hydro Tube 0034 01 &02 0.1500 0.0094 0.3000 a��.. 0 5000 0.0313
7 Moen 0008 01 &02 0.1500 0.3678, 0.3000 0.7356 0.5000 1.2260
8 Pfizer 0022 01 &02 0.1000 0.3691 0.3000 1.1074
9 STI Pol er 0032 01 &02 0.1500 0.0313 0.1000 0.0209
10 Trion 0013 01 &02 0.1500 0.0355 0.3000 0.0709 0.5000 0.1182
11 son 0041 0001
12
Column Totals->
1.2200 2.0469 0.001994 0.1345 r 1.7394
Sludge
Stream Sludge Sludge Ceiling
Basis=> Std Ceiling NPDES Ceiling HASL
MAHL from HWA(lbs/day)=> 2.4820 3.2374! 0.097863 0.3287 4.2244
Uncontrollable Loading(lbs/day)_> 0.0694 0.1792 0.008670 0.1792 0.2254
Total Allowable for Industry(MAIL)(lbs/day)_> 2.4127 3.0582 0.089194 0.1495 3.9990
Total Permitted to Industry(lbs/day)_> 1.2200 2.0469 0.001994 0.1345 1.7394
MAIL left(Ibs/day)_> 1.1927 1.0113 _0.087200 0.0150 2.2596
Percent Allow. Ind. (MAIL)still available(%)_> 49.4% 33.1 % 97.8% 10.0% 56.5 %
Percent MAHL still available(%)_> 48.1 % 31.2% 89.1 % 4.6% 53.5 %
5 Percent MAHL(lbs/day)_> - 0.1241 0.1619 0.004893 0.0164 0.2112

Page 4 Allocation Table for State Modified December 2O21.xlsx
Allocation Table
Headworks last approved: 02/22/18
Allocation Table updated: 12/10/21
Permits last modified: 11/12/21
Porw=> City of Sanford
NPDES#=> NCOO24147 _
Selenium I Silver I Zinc Total Nitrogen Total Phos.
Industry ermit Limits Permit Limits Permit Limits Permit Limits Permit Limits P
IUP INDUSTRY NAMES Permit Pipe Conc. Load Conc. Load I Conc. Load Conc. Load I Conc. Load
Count (please lin ilphabettcIy) number number mg/1 lbs/day mg/1 lbs/day mg/1 lbs/day mg/1 lbs/d y mg/1 lbs/day
1 Arauco 0042 01 &02 0.24 0.30024 1.24 1.5512
2 Caterpillar Boone Trail 0040 01 &02 0.2400 0.054011 1.2400 0.2792
3 Caterpillar Womack 0033 01 &02 0.2 00 0.0747 1.2400 0.3857 .
4 Charah 0035 0001 0.0990 0.2378 0.0429 0.1030 .._ .. ®
5 Coty 0010 0001 ram` e
6 Hydro Tube 0034 01 &02 0.2400 0.0150 1.2400 0.0776 m......
7 Moen 0008 01 &02 0.2400 0.5885 1.2400 3.0404
8 Pfizer 0022 01 &02 0.2400 0.8859
9 STI Polymer 0032 01 &02 0.1000 0,0209
10 Trion 0013 01 &02 0.2400 0.0567 1.2400 0.2932
11 Tyson 0041 0001 �..e.., .............
1.2400 5.1708
12 E
AIRMUColumn Totals=> � 0.2378 1.62081 9.09167 0.00 0.00
Sludge AS/Nlt/TF Sludge
Basis=> Ceiling Inhibition Ceiling Design Design
MARL from HWA(lbs/day)=> 0.4702 8.1553; 22.3192 ####### 2081.66
Uncontrollable Loading(lbs/day)=> 0.0433 0.0173 5,8693
Total Allowable for Industry(MAIL)(ibs/day)_> 0.4268 8.1379 16.4498 ####### #######
Total Permitted to Industry(lbs/day)=> 0.2378 1.6208 9.0916 0.00 0.00
MAIL left(lbs/day)_> 0.1891 6.5171 7.3583 ####### #######
Percent Allow. Ind.(MAIL)still available(%)_> 44.3 % 80.1 % 44.7°/a #######', #######
Percent MARL still available(%)_> 40.2% 79.9% 33.0% ####### #######
5 Percent MARL(lbs/day)_> _ 0.0235 0.4078 1,1160 227.18 104.0832

DocuSign Envelope ID:D9A95B6A-F6BD-41 BC-A428-5DCA49E8B09E
ROY COOPER ` to '
Governor .1 4
'I IZABETH S.BISER
1 ecretary 4r4 v0;:r
J.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
December 28,2021
Mr. Scott Siletzky
Water Reclamation Administrator
City of Sanford
P.O. Box 3729
Sanford,NC 27331-3729
Subject: Pretreatment Audit
City of Sanford
Big Buffalo WWTP-NPDES Permit No.NC0024147
Lee County
Dear Mr. Siletzky:
On September 17,2021, Cheng Zhang of the Raleigh Regional Office conducted an audit of City
of Sanford's pretreatment program. The assistance given by Ms. Sarah Jordan,the pretreatment
coordinator,was greatly appreciated. The inspection report is attached.Findings during the
inspection were as follows:
1. There are 11 Significant Industrial Users (SIUs)discharging to the POTW,9 of which are
also Categorical Industrial Users (CIUs). It was noted that Arauco Panels was in
Significant Non-Compliance(SNC)for zinc violations during the most recent semi-
annual period.
2. The pretreatment inspection file review included Arauco Panels(Permit No. 000042),
STI Polymer(Permit No. 000032)and Caterpillar(Permit No. 000033). The files needed
for review were available for inspection,contained all the required elements and were in
excellent condition. In the first half of 2021, STI Polymer was in compliance; Caterpillar
had four flow violations;Arauco Panels had multiple violations for zinc and cadmium
and was in SNC for zinc violations. The POTW took enforcement against these violations
as required by the Enforcement Response Plan.
3. A review of the files containing the pretreatment program elements was conducted. All
files were available and well organized. Please contact the Division about whether the
Long Term Monitoring Plan(LTMP)needs to be updated.
."2...,.:......,..,
DE�.,_ North Carolina Department of Environmental Quality f Division of Water Resources
-� Raleigh Regional Office 13800 Barrett Drive 1 Raleigh.North Carolina 27609
°..i�'aa"�"..,.., 919191.4200

DocuSign Envelope ID:D9A95B6A-F6BD-41 BC-A428-5DCA49E8B09E
4. LTMP data since the last inspection were reviewed, it was noted that all parameters were
sampled at required locations and analyzed with required detection levels. LIMP data
was well organized and maintained.
5. As part of the audit,the inspector watched Ms. Jordan conduct an inspection of one of the
City's SIUs, Caterpillar. The inspection was very thorough. It was evident that Ms.
Jordan has good relationship with the industry representative and broad knowledge of the
SIU's pretreatment operation.
Cityof Sanford's pretreatment Program is verywell managed. Thank you for your continued
support of the Pretreatment Program. If you have any questions or comments,please call Cheng
Zhang at(919) 791-4200 (or email: [e-mail]).
Sincerely,
—DocuSigned by:
UtIA t,SSa f. Nl.aru ,i
`—B2916E6AB32144 F...
Vanessa E. Manuel,Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
Attachments: PT Audit Form
Cc: Central Files w/attachment(Laserfiche)
Raleigh Regional Office w/attachment
Sarah Jordan,City of Sanford(electronic copy only)
D .,_ North Carolina Department of Environmental Quality I Division of Water Resources
�Jly� Raleigh Regional Office 13800 Barrett Drive I Raleigh.North Carolina 27609
NORTH CARc%INA ` —'
°'D"°M11a161N""'�"�*\ 919.791.4200

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
IC NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT AUDIT REPORT
Water Resour.c>
Background Information[Complete prior to audit;review Program Info Database Sheet(s)]
1. Control Authority(POTW)Name: City of Sanford
2. Control Authority Representative(s): Sarah Jordan
3. Title(s): Pretreatment Coordinator
4. Address of POTW:
Mailing PO Box 3729
City Sanford Zip Code 27331
Phone Number [phone] Fax Number [phone] E-Mail sarah.lordanAsanfordnc.net
5. Audit Date 09/17/2021
6. Last Inspection Date: 06/28/2019 Inspection Type: ®PCI ❑Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ®Yes ❑ No
If No,Explain.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ❑Yes ® No
If Yes,Explain.
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑Yes ❑ No ® NA
Parameters Covered Under Order
ICIS Coding
Main Program Permit Number MM/DD/YY
INICIO1012 14 I1 14 17 1 1091171211
10. Current Number of Significant Industrial Users(SIUs)? 11
11. Number of SIUs with No RIP,or with an Expired IUP? 0
12. Number of SIUs Not Inspected by POTW in Last Calendar Year? 0
13. Number of SIUs Not Sampled by POTW in Last Calendar Year? 0
14. Number of SIUs in SNC for Limits Violations During.Either of Last 2 Semi-Annual Periods? 1
15. Number of SIUs in SNC for Reporting During Either of Last 2 Semi-Annual Periods? Y 0
16. Number of SIUs in SNC with Pretreatment Schedule? 0
17. Number of SIUs on Schedules? 0
18. Current Number of Categorical Industrial UserlICIUs)? _ Y 9
19. Number of CIUs in SNC? 0
NC DWR Pretreatment Audit Form Revised: December 2016 Page 1

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
20. PRETREATMENT PROGRAM ELEMENTS REVIEW-Review POTW files,verify POTW has copy of each Program Element
in their File,complete with all supporting documents and PERCS Approval Letter,and dates consistent with Program Info:
Program Element Last Submittal Last Approval Date Next Due,
Date In file? Date In file If Applicable
Headworks Analysis(HWA) 9/8/2017 Z Yes❑ No 2/22/2018 ®Yes❑ No 5/1/2022
Industrial Waste Survey(IWS) 6/30/2018 ®Yes❑ No 8/10/2018 ®Yes❑ No 8/1/2023
Sewer Use Ordinance(SUO) 12/20/2011 ®Yes❑ No 1/25/2012 ®Yes❑ No
Enforcement Response Plan(ERP) 4/20/2009 ®Yes❑ No 7/17/2009 ®Yes❑ No
Long Term Monitoring Plan(LIMP) 12/22/2014 ®Yes❑ No 3/12/2015 ®Yes❑ No
Legal Authority(Sewer Use Ordinance-SUO)
21. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
Yes❑ No If yes,Please list these towns and/or areas.Arauco Panels and Charah(two SIUs)from Chatham County
22. If yes to#21,Do you have current Interjurisdictional Agreements(IJAs)or other Contracts? ❑Yes❑ No ®NA
A copy,if not already submitted,should be sent to Division.
23. If yes to#21,Have you had any trouble working with these towns or districts? ❑Yes❑ No ®NA
If yes,Explain.
24. Date of Last SUO Adoption by Local Council 1/15/2013
25. Have you had any problems interpreting or enforcing any part of the SUO? ❑Yes® No
If yes,Explain.
Enforcement(Enforcement Response Plan-ERP)
26. Did you send a copy of the ERP to your industries? ® Yes❑ No
If no,POTW must send copy within 30 days.
27. Have you had any problems interpreting or enforcing any part of the ERP(i.e.any adjudication,improper enforcement,etc?
❑Yes® No If yes,Explain.
28. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
29. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating Explanation,if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program ®S❑M❑U
Access to POTW Vehicles for
Sampling,Inspections,and ®S❑M❑U
Emergencies
Access to Operable Sampling
Equipment ZS❑M❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis ZS❑M❑U
Reference Materials
ZS❑M❑U
Staff Training(i.e.Annual and
Regional Workshops,Etc.) ®S❑M❑U
Computer Equipment(Hardware and
Software) ®S❑M❑U
NC DWR Pretreatment Audit Form Revised: December 2016 Page 2

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
30. Does the POTW have an adequate data management system to run the pretreatment program? ®Yes❑ No
Explain Yes or No.Microsoft Excel and Work.
31. How does the POTW recover the cost of the Pretreatment Program from their industries?Explain.
Surcharge(for BOD,TSS,and O&G),fines,and additional sampling charge.
Public Perception/Participation
32. Are there any local issues affecting the pretreatment program(e.g..odor,plant closing,new or proposed plants)?
❑Yes® No If yes,Explain.
33. Has any one from the public ever requested to review pretreatment program files? ®Yes❑ No
If yes,Explain procedure.If no,how would the request be addressed?Charah's file was requested,which was provided
34. Has any industry ever requested that certain information remain confidential from the public? ®Yes❑ No If yes,Explain
procedure for determining whether information qualified for confidential status,as well as procedure for keeping files confidential
from public. If no how would the request be addressed?POTW has a locked files area kept apart from the rest of the program
files where confidential information
35. In addition to annual inspection,does the POTW periodically meet with industries to discuss pretreatment? ®Yes❑ No
36. Is the public notified about changes in the SUO or Local Limits? ®Yes❑ No
37. Were all industries in SNC published in the last notice? ®Yes❑ No
Permitting(Industrial Waste Survey-MS)
38. How does the POTW become aware of new or changed Users?City and County has the short form for anyone
connecting to water/sewer to fill out. Forms are sent to the POTW.
39. Once the POTW becomes aware of new or changed Users,how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?)Those meeting any SIU criteria,or with any chemicals that may cause problems with the collection system or
WWTP.
40. Does the POTW receive waste from any groundwater remediation projects(petroleum,CERCLA)or landfill leachate?
EYes❑No If Yes,How many are there?One
Please list each site and how it is permitted,if applicable. Charah was issued an IUP.
41. Does the POTW accept waste by(mark if applicable) ®Truck ['Dedicated Pipe ❑NA
42. If the POTW accepts trucked waste,what controls are placed on this waste? (example.designated point,samples drawn,
manifests required)Designated discharge point at the influent box. Operators are present. Haulers are required to
sign in and note where the load originated. Domestic septage charged the domestic rate. Industrial septage
charged a higher rate and samples are drawn and tested for all LTMP POCs.
43. How does the POTW allocate its loading to industries?Mark all that apply
❑Uniform Limits ® Historical Industry Need ®By Surcharge ®Categorical Limits ❑Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑Yes® No
If yes,what parameters are over allocated?
45. If yes to#44,What is being done to address the over allocations?(short-term IUPs,HWA to be revised,pollutant study,etc.)
N/A
46. Does the POTW keep pollutant loading in reserve for future growth/safety? ®Yes❑ No
If yes,what percentage of each parameter 15%
7. Has the POTW experienced any difficulty in allocation?(for example:adjudication by an industry) ❑Yes® No
If yes,Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 3

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
48. How does the POTW decide on which pollutants to limit in the permits?Monitor for? (for example:were only those pollutants
listed on the application limited;categorical parameters;NPDES Pollutants of Concern)
Categorical requirements,surcharge parameters,LTMP parameters,NPDES permit POCs
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits? Explain.
Semi-annual sampling,more frequent for new SIUs
Permit Compliance
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑Yes® No
If yes,which industries? What was(will be)the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance.This should include compliance judgment on all violations of limits,reporting
requirements,and permit conditions,as well as for SNC. Excel spreadsheet shows the%violations,are run at the end of 6
months for SNC determination. Flow reports are due the 20th day of the following month,and received dates are tracked.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes❑ No
If no,does the POTW form include all Division data? ❑Yes❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ®Yes❑ No
If no,Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs are required to hold a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
EPA Guidance.
56. How does the POTW decide where the sample point for an SIU should be located?
On SIU property. Sample point 01 is process only waste. Sample point 02 is combined.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example:correct location;proper programming of sampler; clean equipment;swirling the sample bucket uniformly)
POTW: ®Yes❑ No SIU: ®Yes❑ No If yes,Explain. POTW staff are trained and only lab and
pretreatment staff perform industrial sampling. SIUs are required to have a certified lab perform their sampling.
58. Who performs sample analysis for the POTW for Metals Environment l
Conventional Parameters POTW lab
Organics Environment 1
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Chain of custody time shown when left sampling site,and arrived at the lab. Initials of staff performing sampling.
Temperature blank showing samples transported on ice. COC for POTW and commercial lab to sign when they pick
samples up.
Long/Short Term Monitoring Plan(L/STMP)and Headworks Analysis(HWA)
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES ❑NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ®YES ❑NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®YES ❑NO Is Table Adequate? ®YES ❑NO
60d. All LTMP/STMP effluent data on Discharge Monitoring Report(DMR)?®YES❑NO Division Inspector,verify yourself!
60e. If NO to any above,list violations
60f. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ®NO
If yes,which ones? Eliminated: Added:
61. Do you complete your own headworks analysis(HWA)? ❑Yes® No
If no,who completes your HWA?Hazen&Sawyer Phone[phone]
,2. Do you have plans to revise your HWA in the near future? ®Yes❑ No
If yes,what is the reason for the revision?(mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available ❑Resolve over allocation ®5 year expiration ❑Other
Explain.
NC DWR Pretreatment Audit Form Revised: December 2016 Page 4

DocuSign Envelope ID:D9A95B6A-F6BD-41 BC-A428-5DCA49E8B09E
63. In general,what is the most limiting criteria of your HWA? ❑Inhibition ❑Pass Through ®Sludge Quality
64. Do you see any way to increase your loading in the future(Example:obtaining more land for sludge disposal)? ❑Yes® No
Explain.No plan to obtain more land at this time.
Summary
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
None
NC DWR Pretreatment Audit Form Revised: December 2016 Page 5

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
INDUSTRIAL USER PERMIT(IUP)FILE REVIEW(3 IUP FILE REVIEWS AND 1 IU INSPECTION)
66. User Name 1.Arauco Panels 2.STI Polymer 3.Caterpillar
67. IUP Number 000042 000032 000033
58. Does File Contain Current Permit? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
i9. Permit Expiration Date 9/30/2024 9/30/2024 9/30/2024
70. Categorical Standard Applied(I.E.40 CFR,Etc.)Or N/A 429 414 433
71. Does File Contain Permit Application Completed Within One Year Prior ®Yes El No ®Yes ❑ No ®Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year? ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
73. a.Does File Contain Slug/Spill Control Plan? a. ®Yes❑No a. ®Yes❑No a. ®Yes❑No
b.If No,is One Needed?(See Inspection Form from POTW) b.❑Yes❑No b.❑Yes❑No b. ❑Yes❑No
74. For 40 CFR 413 and 433 TTO Certification,Does File Contain a Toxic ❑Yes❑NoNN/A ❑Yes❑NoNN/A ®Yes❑No❑N/A
Organic Management Plan(TOMP)?
75. a.Does File Contain Original Permit Review Letter from Division? a. ❑Yes❑No a. ❑Yes❑No a. ❑Yes❑No
b.All Issues Resolved? b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A b.❑Yes❑No❑N/A
76. During Most Recent Semi-Annual Period,Did POTW Complete its ®Yes ❑ No ®Yes ❑ No ®Yes ❑ No
Sampling as Required by IUP,including Flow?
77. Does File Contain POTW Sampling Chain-Of-Custody Forms? ®Yes ❑ No ®Yes El No ®Yes ❑ No
78. During Most Recent Semi-Annual Period,Did SIU Complete its ®Yes❑No❑N/A ®Yes❑No❑N/A ®Yes❑No❑N/A
Sampling as Required by IUP,including Flow?
79. During Most Recent Semi-Annual Period,Did SIU submit all reports on ®Yes❑No❑N/A ®Yes❑No❑N/A NYes❑No❑N/A
time?
80a.For categorical Ws with Combined Wastestream Formula(CWF),does ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
file include process/dilution flows as Required by IUP?
80b.For categorical Ws with Production based limits,does file include ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi-Annual Period,Did POTW Identify All ®Yes ❑ No ❑Yes❑NoNN/A ®Yes ❑ No
Limits Non-Compliance from Both POTW and SIU Sampling?
12. During Most Recent Semi-Annual Period,Did POTW Identify All ❑Yes❑NoNN/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
Reporting Non-Compliance from SIU Sampling?
83. a.Was POTW Notified by SIU(Within 24 Hours)of All Self- a.❑Yes❑No®N/A a.❑Yes❑No®N/A a.®Yes❑NooN/A
Monitoring Violations?
b.Did Industry Resample and submit results to POTW within 30 Days? b.❑Yes❑No®N/A b.❑Yes❑NoNN/A b.®Yes❑No❑N/A
c.If applicable,did POTW resample and obtain results within 30 days of c.❑Yes®No❑N/A
becoming aware of SIU limit violations in the POTW's sampling of SIU? c.❑Yes❑No®N/A c.❑Yes❑No®N/A
84. During Most Recent Semi-Annual Period,Was SIU in SNC? ®Yes El No El Yes ® No El Yes ® No
85. During Most Recent Semi-Annual Period,Was Enforcement Taken as ®Yes❑No❑N/A ❑Yes❑NoNN/A NYes❑No❑N/A
Specified in POTW's ERP(NOVs,Penalties,timing,etc.)?
86. Does File Contain Penalty Assessment Notices? N Yes❑No❑N/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
87. Does File Contain Proof Of Penalty Collection? NYes❑No❑N/A ❑Yes❑NoNN/A ❑Yes❑NoNN/A
88. a.Does File Contain Any Current Enforcement Orders? a.❑Yes❑NotaN/A a.❑Yes❑NotaN/A a.Plies❑NotaN/A
b.Is SIU in Compliance with Order? b.❑Yes❑NotaN/A b.❑Yes❑No®N/A b.DYes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested El Yes ® No El Yes ® No El Yes ® No
Information For You?
FILE REVIEW COMMENTS:
81-Arauco Panels had zinc,copper and cadmium violations in March and April 2021.Caterpillar had four flow violations in April 2021.
84-Arauco Panels was in SNC for zinc violations.
85-NOVs were issued to Arauco Panels and Capterpillar.
86-Arauco Panels was assessed two civil penalties($250 and$500).
NC DWR Pretreatment Audit Form Revised: December 2016 Page 6

DocuSign Envelope ID:D9A95B6A-F6BD-41BC-A428-5DCA49E8B09E
INDUSTRY INSPECTION ICIS CODING:
Main Program Permit Number MM/DD/YY
INICI0 to 12 14 1114171 109I17 I21 I
1.Industry Inspected: Carterpillar
2.Industry Address: 5000 Warmack Road,Sanford,NC 27330
3.Type of Industry/Product: Metal finisher/Contractors Equipment
4.Industry Contact: Kevin Staubus Title: EHS Manager Phone: Fax:
5.Does the POTW Use the Division Model Inspection Form or Equivalent? ❑Yes ❑ No
6.Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview ®Yes El No
B. Plant Tour ®Yes ❑ No
C. Pretreatment Tour ®Yes ❑ No
D. Sampling Review ®Yes El No
E. Exit Interview ®Yes ❑ No
Industrial Inspection Comments:
POTW representative conducted a thorough inspection.
Audit SUMMARY AND COMMENTS:
Audit Comments: The program is well managed
Requirements: None
Recommendations: Contact DWR about LTMP update
NOD: ❑Yes ® No
NOV: ❑Yes ® No
QNCR: ❑Yes ® No
POTW Rating:
Satisfactory ® Marginal ❑ Unsatisfactory❑
Audit COMPLETED BY:Cheng Zhang,Raleigh Regional Office DATE:9/17/2021
NC DWR Pretreatment Audit Form Revised: December 2016 Page 7

DocuSign Envelope ID:534466D9-B8B2-4C21-9BC6-B34055196AAE
ass ONE*
ROY COOPER
Governor ` A{ r�
,LIZABETH S.B1SER
rcretary } aiwcr +
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Qualit
y
1/14/2022
Via Electronic Mail(sarah [e-mail])
Ms_Sarah Jordan
Pretreatment Coordinator
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Subject: Pretreatment Review of Industrial User Pretreatment Permit Drop Request
Program:City of Sanford
WWTP: Big Buffalo WWTP-NPDES#:NC0024147,Lee County
Dear Ms.Jordan:
The Municipal Unit of the Division of Water Resources has reviewed the request to drop the following industry
from the list of significant industrial users (SIUs) for the City of Sanford's Big Buffalo WWTP (NPDES #:
NC0024147).The SIU drop request was received by the Division on 12/10/2021:
SIU# SIU NAME
000007 Magneti Marelli Powertrain USA,LLC
The review indicates that the facility no longer discharges process wastewater and thus no longer meets the
definition of a SIU. Therefore, the SIU drop request is approved based on compliance with 15A NCAC 2H
.0907(b).The SIU list which is part of your approved pretreatment program is hereby modified.
Regardless of this approval action today,within 180 days of the effective date of any reissued NPDES permit (or
any subsequent NPDES permit modification)the Permittee would be required to submit to the Division a written
technical evaluation of the need to revise local limits (i.e., an updated IWS, or documentation of why one is not
needed).This action may include revising,updating or adding to the list of Significant Industrial Users(SIU's).
Federal and State pretreatment regulations require the local delegated pretreatment program to effectively control
and document the discharge of wastewater from Significant/Categorical Industrial Users to the POTW. It is the
POTW's responsibility to ensure that these objectives are consistently met.
If you have any questions or comments, please contact Keyes McGee at (919) 707-3626 [email:
[e-mail]].Thank you for your continued support of the Pretreatment Program.
Sincerely,
tkm/Sanford_iup_drop_059 DocuSignea by:
Ec: Municipal Unit File I k cL __ A, L�.
Cheng Zhang, RRO uuu-y ��u�
C464531431644FE...
Central Files(Laserfische)
for S.Daniel Smith,Director
Division of Water Resources
DE .,, North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh.North Carolina 27699-1617
°i•"""af^'""^°'1mos je, 919.707.9000

C&TERPILLAR
Caterpillar,Inc.
Building Construction Products Division
5000 Womack Road
Sanford,North Carolina 27330 USA
December 8, 2021
Mrs. Sarah Jordan
Pretreatment Coordinator
Wastewater Management
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Re: Authorization to Construct Request—Wastewater PLC, Chemical Pumps, Filter Press
Mrs. Jordan:
Per our Industrial User Pretreatment Permit Number 000033 requirement, Caterpillar is
requesting an Authorization to Construct to install a new Walchem metering pump to
intermittently dispense Southeastern Laboratories Antifoam 615 into the system. The pump
will activate as a batch of wastewater is run through the system to prevent foam buildup in
the system and allow our flow meter to accurately record flow through the system. Please
refer to the attached documents for specs on the items to be installed.
The current plans are to install the metering pump as soon as possible to prevent any future
NOVs from excess foam buildup.
Regards,
Cody Butcher
EHS Associate
Caterpillar, Inc., Sanford Site
Caterpillar:Confidential Green

Metering Pumps
EZ Series
EZ Series electronic metering pumps offer precise chemical
injection at a low cost. The compact size and simple control
make them ideal for water treatment and OEM applications.
EZ Series have outputs to 6.3 GPH (24 I/h) and a maximum a :
pressure of 150 PSI ( 10 bar).Advanced microprocessor
control and a turndown ratio of 360:1 make this series an
exceptional value. The pumps are simple to operate with
only three pushbutton keys and the unmatched turndown
ratio provides both versatility and high resolution chemical
feed which eliminates slug-feeding effects.
Summary of Key Benefits
High Speed Performance
E-Series pumps operate at 360 strokes-per-minute, providing high resolution chemical feed. Most com-
petitive products operate at slower speeds, resulting in slug feeding, accelerated diaphragm wear and
poor feed control.
Engineered Longevity
All E-Series pumps feature dual bearing support. The armature and shaft are supported with a
bearing on each end, which ensures proper axial movement, enabling the E-Series to operate at
360 SPM while extending the life of the diaphragm.
Superior Check Valve Performance
Dual Check Valve Assemblies in both suction and discharge fittings feature precision ball guides and
tapered seats. Precise machining and molding of parts limit valve ball travel, ensuring that balls fully
seat and seal with every stroke. This superior check valve design guarantees fast priming and reliable
performance.
High Compression Ratio
The compression ratio of a metering pump is important because it affects the pump's ability to prime
and vent. The compression ratio is raised when you reduce the dead volume of the pump head during
operation. All E-Series pumps feature a very high compression ratio that ensures proper feed espe-
cially with off-gassing products (i.e. Sodium Hypochlorite).
Innovative Timer Control
The EZ-Timer module integrates Walchem's EZB pump technology with a versatile programmable timer.
Timed feed control can be programmed in daily or weekly cycles.
WALCHEM
IWAKI America Inc.

Specifications
Al
ectrical Specifications Safety Certifications
EZ EZB EZC The EZ series metering pumps* tt
50/60 Hz, singlephase 20 Watt avg. 22 Watt avg. are WQA tested and certified � Qa�v
9 9
1 ±10% to NSF/ANSI Standard 50 and , oo-
15 VAC 0.8 Amp max. 1.2 Amp max. Standard 61.
230 VAC ±10% 0.4 Amp max. 0.6 Amp max. *See www.wga.org for specific chemicals
and certification parameters.
Shipping Weight 8 lbs. (3.6 kg) 10 lbs. (4.5 kg) The EZ series metering pumps
(approximate) (approximate) are tested by Intertek to UL
and CSA standards.
Operating Conditions azr3.0
s
Ambient Temperature: 32 to 122°F (0 to 50°C)
Relative Humidity: 30%to 90% non-condensing Intertek
Liquid Temperature: PVC liquid ends: 32 to 104°F (0 to 40°C)
PR PVDF, SS liquid ends: 32 to 140°F (0 to 60°C)
Below 32°F (0°C), pump is limited to 70% of maximum pressure. Liquid cannot freeze.
Pumps should always be shielded from direct exposure to the elements.
L
Dimensions
Z 1 I
1111
IIII
p 11iimimumi _ _ I.a`rN
, 4.a,__ __
�1 `�J I OUT AIR -��\ J--
! II
IIIIIiIIIIIIIIIIIIIrim Ii _ n'i 1 G
IIII I III
—---- IIIIIIIII IIII 1� * �0��0� H
!!!!1h1hI1h1IIIIIII,I,I,III1+1.1-h1-1.1 I.1.11 ,� ..
X
�Y �ILI
Ii"11
D
ft I I... I I ll I I
lIIiII .I
` t
R Ill 'III Mounting Dimensions (see Instruction Manual for FC dimensions)
_w X
_X :CAM Model R S T X V Z
S Z EZB 3.46" 0.28" 0.63" 0.24" 0.39" 1.26"
V EZC 3.94" 0.59" 1.18" 0.28" 0.59" 1.18"
Model A B E D G2a4 H364 L' W IN/OUT/AIR
EZB 3.21" 0.98" 3.54" 6.10" 7.47" 7.95" 3.94" 0 Y ID x 0 3/80D
1.85"
FZC 4.13" 1.06" 3.94" 6.46" 7.83" 8.66" 4.57" 0%ID x 0 Y2 OD
ites:
1. Addition of a Multifunction valve increases overall length by 0.10".
2. Addition of a Multifunction Valve increases discharge height by 2.62".The Auto Degassing Valve increases discharge height by 1.82"
3. Addition of a Multifunction Valve increases overall liquid end height by 1.25".The Auto Degassing Valve increases overall height by 1.82"
4. Dimensions shown are for 11-21 sizes.Add 0.5" for 31-36 sizes.

SAFETY DATA SHEET
Section 1. Identification
Product Identifier: Antifoam 615
Other Identification: AJ C 15
Recommended Use&Use Restrictions: Defoamer/Antifoam
In Case of Emergency:
Supplier Southeastern Laboratories, Inc. CHEMTREC(transportation): 800-424-9300
Manufacturer: PO Box 10189 Goldsboro,NC 27532-0189 General Information: 919-751-1001
511 North Oak Forest Road Goldsboro,NC 27534
Section 2. Hazard(s)Identification
GHS Classification: This product is not considered hazardous under the OSHA Hazard Communication Standard(Hazcom 2012)
Health: Not Applicable.
Environmental: Not Classified.
Physical: Not Applicable.
GHS Labeling:
Pictogram: Not Applicable.
Signal Word: Not Applicable.
Hazard Statement:
Not Applicable.
Precautionary Statement-Prevention:
Not Applicable.
Precautionary Statement-Response:
Not Applicable.
Precautionary Statement-Storage:
Not Applicable.
Precautionary Statement-Disposal:
Not Applicable.
Section 3. Composition/Information of Ingredients
Component: Proprietary silicon emulsion Formaldehyde Methanol
Weight%: Not Available <0.1 % <0.5%
Alternate Name: Not Available Methanal Methyl alcohol
CAS Number: Not Available 50-00-0 67-56-1
Amounts of hazardous substances specified are typical and do not represent specifications.Remaining component substances are proprietary,non-hazardous and/or
present in amounts below reportable limits. Exact percentages of hazardous listed substances and other proprietary substances will be available to appropriate
personnel as outlined by 29CFR 1910.1200(i)Trade secrets.
Section 4. First-Aid Measures
General Advice: Consult a physician if you feel unwell. Show this safety data sheet to the doctor in attendance. Rescue
personnel must assess the exposure site and don appropriate PPE.
Inhalation: If breathed in, move person into fresh air. If breathing difficulty or discomfort occurs and persists
immediately seek medical attention.
Skin Contact: Wash thoroughly for at least 15 minutes.Wash contaminated clothing before reuse.
Eye Contact: Immediately flush with large amounts of water for at least 15 minutes, lifting upper and lower eyelids.
Remove contact lenses, if worn,while flushing. Continue rinsing. Seek medical attention if any effects or
irritation occurs.
SDS(GHS)—Antifoam 615 Page 1 of 5

Engineering Local exhaust ventilation is generally recommended.
Controls:
Work & Hygienic Provide readily accessible eyewash stations and safety showers.Wash at end of each work shift and before
Practices: eating,smoking or using the toilet.Promptly remove clothing that becomes contaminated.Launder or discard
contaminated clothing.
Personal Protective Equipment(PPE)
Eye Protection: Wear safety glasses with side shields when working with liquids.Use equipment for eye protection tested
and approved under appropriate government standard such as NIOSH.
Skin Protection: Wear impervious gloves. Wear body covering clothing, as appropriate,to prevent skin contact.
Respiratory None is required if adequate ventilation conditions exist.If aerosol or mist potential exists use an
Protection: approved respirator.Respirators should only be used if the employer has implemented a written program
that takes into account workplace conditions,requirements for worker training,respirator fit testing,
medical exams,as described in the OSHA Respiratory Protection Standard(29 CFR 1910.134).
Section 9. Physical and Chemical Properties
Appearance: White liquid emulsion Upper Flammability Limit: Not Available
Odor: Slight sweet mild Lower Flammability Limit: Not Available
Odor Threshold: Not Available Vapor Pressure @ 68°F: — 17 mm Hg
pH: 6-9 Relative Vapor Density: (air=1) Not Available
Freezing Point(°F): —32 Relative Density@ 68°F: —0.98— 1.02
Initial Boiling Point(°F): >212 Solubility: Dispersible(in water)
Boiling Range(°F): >212+ Log Partition Coefficient: Not Established
n-octanol/water
Flash Point(°F)(oc): >300 Auto-ignition Temp.(°F): Not Established
Evaporation Rate:(n-Butyl < 1 Decomposition Temp(°F): Not Established
Acetate=1) Viscosity@ 68°F: 1000—2000 cPs
Section 10. Stability and Reactivity
Stability and Reactivity: Stable under recommended storage conditions.
Possibility of Hazardous Incompatible with oxidizers.Hazardous polymerization will not occur.
Reactions:
Hazardous Decomposition Thermal decomposition products include fumes of oxides of silicon,nitrogen and carbon.
Products:
Incompatible Materials: Strong oxidizing agents.
Conditions to Avoid: Incompatible materials.Do not expose product to elevated temperatures for extended periods of time.
Section 11. Toxicological Information
Signs and Symptoms of Exposure:
Acute Effects:
Eye Contact: Mild eye irritation is possible. Corneal injury is unlikely.
Skin Contact: Minor skin irritation is possible,depending on the frequency and duration of exposure.
Inhalation: Product does not readily form vapors.No adverse effects anticipated with proper handling.Inhalation exposure is
likely to occur as an aerosol or mist when product is heated or as result of mixing with water or other products.
Ingestion: Ingestion of small amounts of this product is not likely to cause any harmful effects.Ingestion of large amounts
may result in symptoms including gastrointestinal irritation,vomiting,diarrhea and nausea.
Medical Conditions None identified.
Aggravated By Exposure:
Acute Toxicity Values
Component: Antifoam 615(mixture calculation)
Oral LD50(rat)= >5,000 mg/kg(estimate)
SDS(GHS)—Antifoam 615 Page 3 of 5

Section 15. Regulatory Information
U.S.Federal Regulations
Superfund Amendments and Reauthorization Act(SARA)Title HI Information:
Comprehensive Environmental Response and Liability Act of 1980(CERCLA):
SARA Title IH/EPCRA(Sec 304): Product does contain specific CERCLA listed hazardous substance(s)above
the de minimis concentrations for which emergency release notification may
be required.Methanol.
SARA Title III/EPCRA(Sec 302)EHS: Product does not contain applicable toxic chemical(s) for which routine
annual release report may be required.
SARA Title HI/EPCRA (Sec 313): Product does not contain applicable toxic chemical(s)above the de minimis
concentrations for which routine annual report may be required.
SARA Title 111/EPCRA(Sec 311/312): Acute
Toxic Substances Control Act(TSCA): Components Listed or Exempt
Clean Water Act(40CFR 423)Priority Pollutants: Components not listed
Clean Air Act(Sec 112(r))Hazard Air Pollutants: Formaldehyde.
Section 16. Other Information
Hazardous Material Health ME0 Personal Protective Equipment(PPE)designation provided as a guideline
Information System Flammability 0 only.User shall make final PPE decision based upon use in specific
(U.S.A.) ..Physical Hazard 0 situation.
Personal Protection B
Physical Hazards: Not Applicable
Personal Protection:
Fir' 1
Safety Glasses and Appropriate Gloves.
National Fire O
Protection 1 O
Association(U.S.A.)
Validation Date: 09-11-2015 Validated By: R.Gates
Previous Validation: 09-04-2015
Comments: Revised Sections 2,3,4,7,8,11,15. Phone Number: 919-751-1001
Notice to Reader
The information contained herein is based on data considered accurate. However,no warranty is expressed or implied regarding the accuracy of these data or the results
to be obtained from the use thereof. Under no circumstances shall Southeastern Laboratories,Inc.be liable for incidental,consequential or other damages from alleged
negligence,breach of warranty,strict liability or any other theory,arising out of the use or handling of this product. The sole liability of Southeastern Laboratories,Inc.
for any claims arising out of the manufacture,use or sale of its products shall be for the buyer's purchase price. All risks associated with the use of the material shall be
assumed by the user and not assumed by Southeastern Laboratories,Inc.
SDS(GHS)—Antifoam 615 Page 5 of 5

PO Box 3729
Sanford,NC 27331 Phone:(919}777-1783
City 0f banf 0r Faz:(919}7765037
WASTEWATER MANAGEMENT FACILITY
Sarah Jordan
PRETREATMENT COORDINATOR
December 10,2021
Mr. Cody Butcher
EHS Associate
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27330
Subject: Authorization to Construct-Metering Pump for Antifoam-IUP 000033
The City of Sanford received a letter dated December 8,2021 requesting an Authorization to Construct
from Caterpillar Inc's Womack Road Facility(IUP 000033)to add a metering pump to dispense an
antifoaming agent(already in use)to prevent foam build-up in an attempt to obtain accurate flow data.
The specifications for the subject project have been reviewed and found to be satisfactory.
Authorization is hereby granted for the construction of:
■ Walchem Metering Pump
The Authorization to Construct is issued in accordance with Part U, Paragraph 26 of Industrial User
Permit Number 000033,and shall be subject to revocation unless the structure(s)is constructed in
accordance with the conditions and limitations specified in IUP Number 00033,and in accordance with
the final specifications submitted for review. A copy of the specification data shall be maintained on file
at the Pretreatment facility and by the permittee for the use of the pump.
Caterpillar Inc_,must notify the City of Sanford WWTP at least forty-eight(48)hours in advance of
operation of the subject project Such notification shall be made during normal office hours(8:00 a.m.
until 5:00 p.m. Monday through Friday,excluding City holidays).
Any sludge generated must be disposed of in accordance with G.S. 143-215.1 and in a manner approved
by the North Carolina Division of Environmental Management The issuance of this permit does not
preclude the permittee from complying with any and all statutes,rules regulations,or ordinances of the
City,the State,or the Federal Government.Failure to abide by the requirements contained in this
Authorization to Construct may subject the permittee to an enforcement action by the City,the State,or
the Federal Government in accordance with the City's Sewer Use Ordinance,North Carolina General
States 143-215.6A to 143-215.6C,and Federal Regulations.

2
In the event that the unit(s)fail to perform satisfactorily,including the creation of nuisance conditions,
the permittee shall take immediate corrective actions and notify the City. Construction of additional
or replacement pretreatment facilities requires another Authorization to Construct. Contact me if there
are any questions. Thank you for your help in promoting a safe and healthy environment for our
community.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Connor W.Jarvis
(�j� Senior EHS Associate
Pfizer Pfizer
4300 Oak Park
Sanford,NC 27330
919-566-5210
March 12t", 2021
Ms. Sarah Jordan
Pretreatment Coordinator
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Subject Wyeth LLC,Industrial User Permit(IUP)#00022;
Authorization to Construct(ATC) Request Letter
Ms. Jordan,
Wyeth LLC, a subsidiary of Pfizer(Wyeth)owns and operates a pH neutralization system for
pretreatment of process wastewater prior to discharging to the City of Sanford's collection system
under its industrial user permit(IUP)#000022. To support site operations and ensure permit
compliance, Wyeth utilizes multiple flow meters to continuously monitor wastewater effluent
flows from both sanitary and process waste lines.
The ISCO 4230 Bubbler Flow Meter, located at the Pipe 02 sampling point, is approaching the
equipment end-of life. For business continuity purposes, Wyeth desires to replace this unit with
the vendor recommended, functionally equivalent,Teledyne ISCO Signature Bubbler.
The technical brochure for the proposed replacement wastewater flow meter is enclosed to
provide further details on this unit.
We appreciate your consideration with this ATC request. If you should have any questions,
please feel free to contact me at(919) 566-5210.
Sincerely,
e,,,,9„.
Connor W. Jarvis
Senior EHS Associate and IUP Technical Contact
cc: Robert Garceau- Wyeth LLC, Asset Reliability Engineer

i'*iiiiik' ::*64*4... i. ....-6::,,,. illt, „..Ly-,.„-,---,-.y- ...- . .
-6--a' 6 00 ..-.6.,:z ,„..,„le'----.-,--..,.:: - ._,
U AU at, , ,:::::zi: ,
0 U - „.
r
l,i,-4,,,.,,,...,„. ,.-,
0,-
d,,...,7\JQ ro,u �� y
i =
,.-, ' , - A .,.,,g,.....-14‘'......,,,A','
jt.,,„,....1/4,„,-;-,,,,,,„„.,,,,,,,,,,,,,,,, ,
II 1 2 3
5
31c>7 t
t ) I
1 1644545 gal A 6
r,vt aat"-!1: li°9Uo 8 e 4
7 9
LevvJ
. 300 Refer Er:ce Hierwxl v: i:, ,
300 Case Hun illy. d •>;, • 0 -F-
. A
n R r , 'N ► q
A 1 1
Ise°
1
„A...,
, .:
„.....,,,
.:,
0
Applications
• Industrial Pretreatment Compliance
10
• Permit Enforcement
• Wastewater Treatment Plant
Discharge Monitoring
• Outfall Monitoring
• Shallow Flow Measurement in
Small and Large Channels

IIIi !BChN -
r 0
c o 0 =
S _r.
, , \% k
4 ? \\\\ .
� ts3
ca
.n
NIli
la T..
rn
•
r \\\\
t
3i>,
.1t. lealb
S
1.*: ' 4 km *.
s: n

Configurab ;
The Teledyne Isco Environmental Network TIENet®—is key to the Signature flow meter's flexibility.The Signature supports
multiple TIENet devices to monitor one or more channels with multiple,redundant,or alternate technologies,without
hardware or firmware changes.This network's intelligent design minimizes cabling and conduit costs through the use of TIENet
expansion boxes,common connectors,and efficient cable configurations.
In addition to TIENet devices,the Signature also accepts SDI-12 and Modbus ASCII/RTU inputs.
a
Simplified Pan 01li-4-+,0
Acting as a system hub,the Signature records and transmits data,generates reports,and takes intelligent action in response
to multiple simultaneous inputs,communicating with SCADA systems using RS-485 Modbus ASCII or RTU,or optional 4-20 mA
Analog.With a diverse array of possible inputs and an industry-standard output,the Signature is a one-stop access point for process
monitoring and control.
Cellular
Communication
Ethernet
SIGNATURE 1 [:1111
1 < ti
>
FLOW METER II
Modbus In rli or SDI-12In
—Modbus RTU/ASCII
—4-20 mA Out
Bubble Line 330 Expansion
•
Boxes(3)
LaserFlow // [3UsS
�� Q3
360 WA&, `J
Sampler r
—1/
Interface �7
306(2)
zji,o)
PH
Interface
301 (2)
Area Velocity
d 350

j414 '
,,s, Flow Techn
Designed with a variety of flow measurement options,the Signature
has
' 4 the flexibility to meet challenging site requirements head-on.Choose
sti , from four established flow measurement technologies.
•�- ,, :1, '�''— The Signature flow meter can employ any combination of these
•._ ..;.' :,.'-.
technologies simultaneously,even at great distances.
Non-contact LaserFlow1"Velocity Sensor Continuous-wave Doppler
:ram` The LaserFlow sensor remotely Teledyne Isco'sTIENet""350 Area
„ : measures flow in open channels with Velocity Sensor continuously
6.01
non-contact Laser Doppler Velocity transmits an ultrasonic signal into the
iotechnology and non contact ultrasonic flow stream.The signals are reflected
c level technology. The sensor uses off bubbles and particles,and then
,1:11t t;e.` r; , advanced technology to measure return to the sensor with a frequency
velocity with a laser beam at single shift(Doppler effect)which is proportional to velocity.A
or multiple points below the surface of the water.A non- differential pressure transducer in the sensor measures liquid
contacting ultrasonic transmitter measures the liquid head depth in order to determine the wetted area.Flow rate is then
height to determine the wetted area.Multiplying the wetted calculated by multiplying the wetted area of the flow stream by
area by the average velocity yields the flow rate.Flow during its average velocity.
surcharge conditions can be measured with an optional,
integrally-mounted continuous-wave Doppler area velocity
sensor.
Non-contact Bubbler Module
Ultrasonic Teledyne Isco'sTIENetn"330 Bubbler
With the Teledyne IscoTlENef' 310 • Module technology is ideal in flow
;mo w w-_xa u;zt.ws;,,w Ultrasonic Level Sensor mounted fa , streams affected by harsh weather,
above the flow stream,transmitted 4t �:; `a-4 �- b debris,or corrosive chemicals.Since
soundpulses are reflected off the liquid '1 '�'A
q - the depth of flow is determined by
surface.The elapsed time between measuring the pressure needed to
Itransmitted and returned signals determines liquid level.Flow force bubbles out of the line,you are able to calculate flow rate
rate is then calculated using one of the meter's built-in flow using one of the meter's built-in flow conversions,or a user-
conversions,or a user-defined level-to-flow relationship. defined level-to-flow relationship.

Signatur- gyp'
i Senso:. ; 330 Bubbler
loppliii._ ., ..
••
Weirs and flumes Excellent' Excellent Excellent Good'
Channels less than 6 in.(150 mm) Good 2 Excellent Good Good 2
Small round pipes,6 to 8 in.(150 to 200mm) Good 2 Excellent Good Excellent
Medium round pipes,10 to 15 in.(250 to 375 mm) Good 2 Excellent Excellent Excellent
Large round pipes,15 to 96 in.(375 to 2500 mm) Excellent 2 Excellent Excellent Excellent
Irrigation channels and small streams Excellent 2 Excellent Good Excellent
Rivers and large streams Excellent 2 Excellent Good Excellent
Organic Solvents Compatible Compatible Not recommended Compatible
Organic Acids Compatible Compatible Not recommended Compatible
Alcohols Compatible Compatible Not recommended Compatible
Esters Compatible Compatible Not recommended Compatible
Inorganic acids Compatible Compatible Compatible Compatible
Inorganic bases Compatible Compatible Compatible Compatible
Inorganic salts Compatible Compatible Compatible Compatible
Strong wind Not recommended Excellent Excellent Not recommended
Air temperature fluctuations Good' Very good' Excellent Good'
Steam above liquid Not recommended° Excellent Excellent Not recommended°
Foam on liquid Not recommended° Excellent Excellent Not recommended°
Flow stream turbulence Not recommended° Excellent Excellent Not recommended°
Floating debris Not recommended° Excellent Excellent Not recommended°
Floating oil or grease Not recommended' Excellent Excellent Not recommended°
Suspended solids Excellent Good Very good Excellent
Suspended grease Excellent Good Very good Excellent
Silting Excellent Good Very good Excellent
Liquid temperature fluctuations Very good Excellent Good' Very good
Submerged flow Not recommended Not recommended Excellent Excellent
Full pipe flow Not recommended Not recommended Excellent Excellent
Surcharged flow Not recommended Not recommended Excellent Excellent
Reverse flow Not recommended Not recommended Excellent Excellent
Maintenance Requirements Caused by Adverse Conditions
Silting None Occasional Occasional None
Suspended solids None Occasional Occasional None
High grease concentration None Occasional Occasional None
1. Use with caution on small flumes 4. Conditions that limit access to the water level may adversely affect
2.There must be adequate space above for mounting sensor measurement
I. Large air temperature fluctuations will affect accuracy 5. Non free flow conditions may require programming adjustments

Inputs
Flow monitoring combines with a variety of inputs to produce an in-depth
representation of the measurement site.All input data can be recorded and
Bubbler used for reporting,output or control.
Level Sensor
v
Flow Technologies T f
• Ultrasonic
two
• Bubbler
Ultrasonic � • Continuous wave Doppler ,� + {
Level Sensor j
• Laser and Doppler
t .
•
tM
pH � 0.
5D1-12 43- 1
Device The TIENet 301 pH/temperature sensing
• device provides acidity/alkalinity ,- {
measurements to the Signature. � ��
4
bi.c.
SDI-12
Area Velocity Two SDI-12 inputs accept data ranging from single-parameter sensors to
Sensor
P P 9 9
multi-parameter sondes and other SDI-12 output devices.
Modbus Input
Modbus The Signature accepts up to two writable modbus registers to request
Input
• updated readings from other measurement devices,totaling up to 40
• parameters.
TIENet M Devices
LaserFlow • TIENet input and output device utilize a common,proprietary
Velocity Sensory interface protocol.
�� • Low system integration cost with multiple measurement technologies,
Input/Outputs,protocols and communication options.
• Configurable and upgradable
without hardware or firmware ► Mir '�'r ,
changes ``
in Signature Flow Meter.
t� h �".
pH Sensor i
Interface • Quick set-up with an \'
'101identifiable,unique address T i.
for each device. .-s
• Easy trouble shooting with built j
in device diagnostics. '

• ! \ i• l \,., .ri t1 , itrP; om`T ,v
)utputs and Communication
The Signature can export selected data in the industry format of choice to
associated equipment for remote data acquisition and/or process control.
The Signature's ability to communicate over great distances using a number of 4-20 mA
Analog
protocols makes it a powerful tool for smart triggering,alarming,reporting,and
data infrastructure.
Modbus Output ii
Simplified Plant Integration-The Signature communicates with SCADA systems l��/ Ethernet
Network
using RS-485 Modbus ASCII/RTU output.
4-20 mA Current Loop 3 Cellular
Modem
Optional dual Analog Output cards support up to six independent 4-20 mA Communication
current loops for external control.Additional outputs are possible with an
Expansion Box.
Modbus/
SCADA
Sampler Interface V�
The TIENet 306 Sampler Interface connects the Signature to an automatic
0
wastewater sampler.The Signature can then enable the sampler based on user- i 1°wi'nk
Software
oecified conditions,(threshold,logic and equation)pace the sampling routine
based on flow,and receive sample and bottle information from the Teledyne Isco
sampler.
OAlarms
USB Connectivity
USB connectivity allows easy retrieval of report files via the front panel USB port O\! Ice pace
with a flash drive,or a direct Windows®PC connection.Report files may be viewed
as a text file or imported into Teledyne Isco's Flowlink®software.USB connectivity
can also be used to save or load program settings and update firmware. % 0
%L4
USB
Ethernet Interface
An Ethernet card provides remote retrieval of data and summary reports,remote
programming,and alarming via SMS text messaging or email.
Cellular i41,, Internet
��11/1 Accessible
An internal CDMA or GSM cellular modem enables long distance,remote ��■!� Data
programming,data retrieval,and alarms.Data can be automatically sent to server
at set time intervals.
-CADA
he Signature provides a Modbus output for exporting site data to an external
control system.

te�r+'p� i' () () r
e w v'2•r�dt ( (( ,
a A. ` , , ,
L _i. PA ,,\ f I
If,t.L`+, .a,,,w O. / 1 n l 5 , I `
55 /�.-•44, U l- 1 '� J
Intelligents Comsliant
• P F
The Signature responds intelligently to multiple concurrent inputs, The Signature secures the integrity of your site data
with preprogrammed actions. through verifiable reports with data authentication for
regulatory agencies.
Actions
•Trigger and pace an automatic water sampler based on site Reports
conditions,with the optional TIENet 306 Sampler Interface Digital reports are accessible through the many
•Log or push data at more frequent intervals during critical events communication options,eliminating the expense of hard
to capture higher-resolution data,returning to the primary rate copy report storage and paper roll/ribbon servicing.
during normal operating conditions Report types include:
•Switch from one flow measurement technology to another based •Summary—Includes the daily minimum,maximum,
on site conditions and average for selected data types
•Send alarm notifications via SMS text messaging or email •Diagnostic—Tracks all diagnostic tests and results
to ensure data quality.This can be useful in
•Humidity alarms for preventive maintenance analyzing site or application issues
•Program—Contains the current configuration and
tracks any changes
•History—Contains all user and meter events
such as data transfers,program changes,and
level adjustments.This information can be used
to confirm equipment operation and detect
-P0111 tampering
Sgnature Meter tteport'_201310170800-No_ " 'I 23 -.
Report 1 Signature Meter '• --
Interval:2013-10-16T08:00:00 to 2013-10-17T08:0' _ - - '-
301 pH: 1 -,_
Ave:6.62 pH •a•a _ _
Max:9.19 pH 2O13-10-16722:42:45 ___--�rl..:•-•0'•
Min:3.50 pH 201 3-1 0-1 770 2:59:00 - -;-:
301 Temperature: „aw as a«* - „,.,•
'Ave:39.6•C
Max:58.2°C 2013-10-16T23:54:00 M...••�' . "�`- ma
Min:27.7•C 2 01 3-1 0-1 671 9:10:00 '•"`• "°"'"•'m — —-
-
350
Aver 8199in w•�- - ",o,., Fmt evie,v 711:1'8
. Rage _ .--_Mae:10.265 in 2013-10-17703:07:00 =J5 Min: 1.897 m 2013-10-1 7703:52:00tv.ea''vary0120I27'iFlow Rate-A: i i '- Ever Ave:493.05 gpm x Y • IYEverx8 _Max:1819.51 gpm 2013-10-16720A6:00 � �`I *iNgnosook
Min:25.16 gpm 2013-10-17T04:24:15 wI �' 2/1040 -
, 0/2014e�350:40.3•ature: yS� • • Q ✓ 1_N201
Ave:40.3•C -
Max:57.2•C 2013-10-1672_3:55:00li \ \
i �2i1I2ate_
i Min:28.8•C 2 01 3-1 0-1 671 9:10:00 r1 •V i_ i 1' 2i9201212190g °Y°^I
Total Flow: 1 1 I II � /^ Y L812012121$12 eve,lTotal: 2197017 gal - 1 ; ,,,interval: 710279 gal _ . •
rmHistO.• rYRe
Summary Report Dia9nOstic Report

A F-
r
,j ,\t I r ,.
$_Vo ),Nepotl.I Ile X
Original and Authentic—Verified! Fie m„,,. e: F4300 Coq:ince Meter109SEP11V95TORY.bt Browse.,,
Use the free Report Verification tool installed alongside
wtlrtiketio,le: RADOamots and settinsVdeweVM Dame Bra!fe... J
Flowlink on your computer to verify data integrity.All
downloaded Signature data is accompanied by a singular
key calculated with a hash-based message authentication
code(HMAC).Even the slightest change to your data will
result in a drastically different key.
USB Connectivity ,
With a USB flash drive attached,you can quickly download (j�
Diagnostic,Program,History,and Summary reports,update 0
11111 firmware in the Signature flow meter and connected TIENet °". '
devices,and download data files for use with '
Flowlink software.
In addition,the USB port provides direct serial connection .
with a computer running Flowlink.
000 1 ''
6 4 :,s,
y f ;
`/'n' "Illift
�ti^y-vim.
Ala - T,:fit-777 --7 , .-„ . ,. 4.,,,_ '! .t
... _ _ _ =a._ s'r�ry' g r.
ii.,*-7----- ,
la 4• 1
�
Q. j

(\O/ )ASAP c,Un,_Jp,U L/ )/\ r
(7s ��J/` io �.,J_�o+ t�J, o
oo0o f '_l,A -_�/0__i n 00( 0 . o o
U o/ � o � 4
o t o/�o r/lJ .J J �_)/� ,.J O o o
0 o0oC)o�, y.�/vo, 0�L.�, oAC
ro, 0000000 L �
0 0 #r .
a A.
( � � 0 0 0, 0 \<\ 00) 1 0 .6
t
0 �o vo t\ /,�is_U/\o o 0 0A
o ff, 0 0 Li o U,, U / o o M
0 / 000�O \o � o o o
o •o �oipil o( �' , o Y
o \o o,/\ j �o ` )f\o o
C1 U 0, ��:,�,,o>/v
TELEDYNE ISCO
Everywhereyoulookv
4700 Superior Street,Lincoln,NE 68504 USA•Tel:[phone] •USA&Canada:[phone]
Fax:[phone]•Email:[e-mail]
N
Teledyne Isco reserves the right to change specifications without notice.
©2016 Teledyne Technologies Incorporated

p1o3aeS Jo Amp
loieuquooD IuamPa.Ra1J
UPJof liamS
—7-7172fi--Ne-ng
`ApaiaauN
'.iaiiem stq.i ui uoiimadooa moA ioj noA 3Iuegy-pu'3up.zojaus Juep gums
le Hem ein 10 £8LI-LLL(6t6)le auz iaeiuoa of aag toad aseald`uogeuuojui aeoge aqi
&urpieSai suoisonb ale abagiB •aa1ou sigi&I!Apslaijo sAup Of uigi'J% 'yawl()Adoa
PSI Aq pallullgns aq
isnw ua3e}aq of(s)uoRau 3AR321.103 aqi pug uoiietoin Nun 2u[uoseaI aqi ucm tdxa ivauuaieis uaiiuni.V
T9 SEM Hd 2119.111821 MR puu`IZII uo piosueSjo AID alp Aq p0i0npu03 sera ajdtaesai V'OH)uEtd asuodsal AauaRiaura mil Aq paa.ioJua pun pawls se Hui lamas pue laienk Aietugad moA of pappu aq"p.m
aug 00'0S$v Vigil sV 119 Jo lItuIl iIniad pagtaads aqi Jo Tiagap a saw3Ipu!sA1, Z t Ague f pawP t0
did uo 8•g Jo Hd n paauauadxa agni oipAH`Juana&ugduius IZOZ aunf-Aiunuuf plo3ueS jo AID aqi TuunQ
:snegity'rye Jeau
Hd 2utpie23-11(AON)uoRulo!A3o aaRoN 43*Cgns
Z££LZ ON`pioJueS
puooi ga1►g3 gpsid.11AI Sto9Z
'auq sasudiaiug agns oipAH
ivapisa1J331A
stmITIV w:L
IZOZ`IZ AlenuRr
AJJ113d31N31/1139VNVvN ti31dM31SVM
!au oupJojues@n uepio(•gBJes
Joaeuipioo3luau eaJaWd
uep1or Lien
L£O -9 (6l6) xe3 0££LZ ON'pop
£8L1.-/I/(6L6)3N0Hd 6ZL£x08'0 a
s'

Sarah,
Below is email stating cause of NOV. I have added some verbiage for corrective action.
Let me know if you need anything else.
Tf s,
Tim Althaus
VP Operations / Sales
Hydro Tube Enterprises Inc.
Office 919-258-3070 ext. 204
Cell - 919-625-9816
www.hydrotube.com
Integrity is doing what's right even when no one is watching.
From: Tim Althaus
Sent: Thursday, February 4, 2021 1:17 PM
To: 'Sarah Jordan'
Cc: Randy Buchanan
Subject: NOV Response
Sarah,
Di g the City of Sanford January- June sampling event, we experienced a pH reading of 5.8 on pipe
01, putting us in violation of our permit.
This occurred only one day out of the four testing days. Nothing in our process changed on any of the
four days. In our investigation it was found that the
incoming fresh water from the City of Sanford is very inconsistent on its pH levels. We began
monitoring the incoming freshwater on January 12th. Results are below:
1/12/2021 pH 7.1
1/13/2021 pH 7.2
1/14/2021 pH 6.86
1/15/2021 pH 6.1
1/18/2021 pH 6.1
1/19/2021 pH 6.47
1/20/2021 pH 7.26
1/21/2021 pH 7.67
On Jan.26th we had a third party come in to test and verify our readings. Both ours and theirs
registered a pH 6.1
Both instruments used were calibrated to buffer solutions of 4, 7, and 10 to insure credible readings.
With this variable of incoming water from the city, it will be impossible to meet our permit limits based
on the water source.
I have reached out to Scott Christiansen with the City of Sanford. He says we should not be seeing pH
re--'=-igs this low as they shoot for pH 7.8
I I ?. asked him to look into it further and even to have someone come out to review. I am waiting to
hear back.
I feel we are being penalized for something we have no control over. Your thoughts on this situation
would be welcomed.

Sarah,
We have concerns about the incoming freshwater. We have been testing for PH each day.
We have seen large swings in the incoming water that affects the outgoing water.
The Ph one day this week was 6.1 coming in. if we rinse any parts at all, we can be below 6 on the outgoing.
Other days when the Ph is up around 7 on the incoming, the outgoing is fine.
What is the "standard" for the incoming fresh water from the city?
Thanks,
Tim Althaus
VP Operations / Sales
Hydro Tube Enterprises Inc.
Dffice 919-258-3070 ext. 204
ell - 919-625-9816
Nww.hydrotube.com
Integrity is doing what's right even when no one is watching.
From: Sarah Jordan [mailto:[e-mail]]
Sent: Thursday, January 21, 2021 1:55 PM
ro: Tim Althaus
:c: Randy Buchanan
Subject: NOV Receipt Date
rim,
:'m putting the NOV for the low pH event on January 12th in the mail today. Please let me know when you receive it. The lab staff told me the resample they
onducted today was in the acceptable range. Thank you.
iarah Jordan
?retreatment Coordinator
2ity of Sanford
919)777-1783
919) 353-6802 ( ;rgencies Only)

Starting February 8th we are now taking daily pH readings for our incoming water. If we have readings
lower than expected on the incoming side, we
will contact the city and they will sample and measure. When we see a drop we will test the outflow and
if close to our limits, will take action to rectify.
Tim Althaus
VP Operations / Sales
Hydro Tube Enterprises Inc.
Office 919-258-3070 ext. 204
Cell - 919-625-9816
www.hydrotube.com
Integrity is doing what's right even when no one is watching.

0.Box 3729 v«s� PHONE[phone]
inford,NC 27330 Fax [phone]
Qrttp of 'anforb
Sarah Jordan
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
March 5,2021
Mr.James Siler
EH&S Manager
Magneti Marelli,U.S.A.,Inc.
PO Box 548
Sanford,NC 27331-0548
Subject Notice of Violation(NOV)Regarding pH
Dear Mr. Siler.
During the City of Sanford sampling event,conducted 3/1-3/5,Magneti Marelli experienced two pH
readings out of compliance with permit limits(6.0-10.5 s.u.).A pH reading of 5.8 on pipe 01 dated March
1st and a pH reading 109 on pipe 01 dated March 5th.As result,a$50.00 f ne will be added to your next
water and sewer bill as stated and enforced by the emergency response plan(ERP).
A written statement explaining the reasoning of the violation and the corrective action(s)to be taken must
be submitted as well as two resamples conducted by Magneti Marelli within 30 days of receiving this
notice. If there are questions regarding the above information,please feel free to contact me at(919)777-
1783 or via email at [e-mail]. Thank you for your cooperation in this matter.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

pH NOV
From: Sarah Jordan<[e-mail]>
To: SILER James(M)<james.sile marellicom>
E 3/5/2021 10:00 AM
James,
Dale told me there were 2 pH readings that were out of the limits of your IUP.fun sending out your NOV today Please let me know when you
receive it(via email or phone is fine)as you are to submit 2 pH resamples,the cause of the pH abnormalities,and the corrective actions to
be taken within 30 days_If you have questions let me know.Thanks and have a good weekend
Sarah Jordan
Pretreatment Coordinator
City of Sanford
[phone]
[phone] (Emergencies Only)

MAREal
March 18, 2021
Mrs. Sarah Jordan
Wastewater Management Facility
P.O. Box 3729
Sanford, North Carolina 27331-3729
Re: NOV request for two PH readings:
Dear Mrs. Jordan
I have looked at the plant operation and PH dosing on our first day we had a low PH reading
which wa`due to low flow and the plant being down for an extended period.Dosing was
increased and during the testing week,we also had an air pump which went down causing
dosing product not to have proper mixing short circuiting the system and later causing an
increase in dosing product to increase PH above limits.We have corrected the pump issue and
the system is online and operating properly.
PH reading on 3/18/2021 was 8.04 with a flow of.004912 MGD
PH Reading on 3/19/2021 was 6.91 with a flow of.001247 MGD
For any questions that you might have, you can reach me at 919-775-6463
Sincerely,
puie.4 see,
James D. Sher
Chemical Management
TPOtOperations
Powertrain
919-7754483
Magneti Maceili Powertrain USA LLC
2101 Nash Street
Sanford, NC 27330 Namel Headquarters R&D
__
www.mareili_com 21
Sheet 37483 rebut:ha/1ga Drive
Po8 548 Farmington HAs..Pal 48335
Sanford.NC 27330 Tel [phone]
Tel [phone] Fax[phone]
Fax[phone]

amstataftvpacipaiptd
peatiawtv loam aseauft
'pal
00Ps
wogs 0u eq lot mem swops Ickuald not jo esn mum eR wag uoselotA
10 33§011 Ala se suss xej spa (q`Z 11 Ind 0olgutoo muued qwa Pe1dwoo eAeR DOA'sow%
711493(u1l RWigUO3 90t81LL( j 1183 sinful ►P st xel M
-aouendatea aRo.td o 8dwes wJ x a }yea]le Reigns Ismu
'TaEEU sl 3111. P0a 0 sPittwq3 eoueldukoo-u!eg01peunbea
Seichmes ellx0 10f % 31 % mie0 ana
e00 1%&cep4£ugqyA peatuq0s q Him suope de Atom fly X
waives!auioo 1R00 siejeumed uotuips X
0M2au03 X uotialoiA uost a WatueMs ueV X
:peAle3ei
e8u i 30yto&mew Hd
:equossa MOD
S`9b°fl'9 159 Pule WO Nd 1Z16l P0s 17./811£
Nun WIN uoMe100 0!(s)1ed PaiduleS
"PUBS ss2ggiuesai PePerannY GAILL0J.aumsai Hd cue uowneichazi alp=s"seam ' '
z0 E 10 X N mod tij0011e10,A 60P040 - s ;es
£9*S1L-615 LiaclumN 000114 11 3N`P 10S
:Jequinti l d 1d11Z` :ssalPIN
10111OON*wed
WAN neuBew AtisnPul :waif
L£oc`9LL-616:Xg dnoi J 100mean0ad piques#o :01
aat1oN.rrrop-kZ do ?uuopauo-fpaS'ofu ,o Jo da cempg-
_
- _� n z. Fs-. r vi s=. _ - . —gY a g,.? �?.�7--3s n �* �.�..� »�i' '--•'�Lr.-�'."'acre e ice ':" � •
H➢ZL E LZ 31%1cc `J"'SS
6 E Irog OJ
Smillaz,i uau�inema;srem
p 0Jus

AGNETI
AREL
a
March 18, 2021
Mrs. Sarah Jordan
Wastewater Management Facility
P.O. Box 3729
Sanford, North Carolina 27331-3729
Re: NOV request for two PH readings:
Dear Mrs. Jordan
I have looked at the plant operation and PH dosing on our first day we had a low PH reading
which was due to low flow and the plant being down for an extended period. Dosing was
increased and during the testing week,we also had an air pump which went down causing
dosing product not to have proper mixing short circuiting the system and later causing an
increase in dosing product to increase PH above limits. We have corrected the pump issue and
the system is online and operating properly.
PH reading on 3/18/2021 was 8.04 with a flow of.004912 MGD
PH Reading on 3/19/2021 was 6.91 with a flow of.001247 MGD
For any questions that you might have, you can reach me at 919-775-6463
Sincerely,
PaAleutD. Sam
James D. Siler
Chemical Management
WWTPO/Operations
Powertrain
919-775-6463
Magneti Marelli Powertrain USA LLC
2101 Nash Street
Sanford, NC 27330 Magneti Marelli U.S.A.Inc.
Headquarters R&D
www.marelli.com 2101 Nash Street 37483 Interchange Drive
POB 548 Farmington Hills,MI 48335
Sanford,NC 27330 Tel [phone]
Tel [phone] Fax[phone]
Fax[phone]

of-',,'
P.O.• Box 3729 1 t PHONE[phone]
e—rord,NC 27330 Fax [phone]
Cap of a` attforh
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
March 30.2021
Cody Bute: -
Caterpillar inc_
5000 Womack Road
Sanford,NC 27331-3667
Subject Notice of Violation(NOV)Regarding Flow
Dear Mr.Butcher:
The industry-supplied flow sheet indicated three flow overages on pipe 02 February 25`b,26th,and 27th a0
which exceeded the permit daily maximum limit of 0.0373 MGD.The ERP required action is a$50.00 fine
per violation,per day added to your next water and sewer bill. Totaling$150.00 for the recorded February
flows.Please let me know the reasoning and corrective action with in 30 days of receipt of this mailing.
If there axe questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
Sarah Jordan
Present Coordinator
City of Sanford

CATERPftLAR
Caterpillar,Inc.
Building Construction Products Division
5000 Womack Road
Sanford,North Carolina 27330 USA
April 21,2021
Mrs. Sarah Jordan
Pretreatment Coordinator
Wastewater Management
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Mrs. Jordan:
In reference to Industrial User Pretreatment Permit Number 000033,this letter is in response
to the Notice of Violation, (NOV), received on April 15,2021 for overages at Pipe 02 on
February 25t, 26th, and 27m.
In November 2020,the original flow meters to the facility were replaced due to outdated
equipment and periodic outages. The new flow meters were installed and calibrated on
November 13th, 2020 at Pipes 01 and 02. Since their installation,the meters have been
providing inaccurate and elevated flow measurements.
We have been diligently working with the contractors who installed the meters and other
wastewater contractors to calibrate the meters to pinpoint accuracy. The contractors have
been on site at least once per month since installation of the meters and have told us the
issues have been resolved each time.
As of April 21,2021,the Pipe 01 flow meter is providing accurate flow measurements. The
Pipe 02 flow meter also seems to be providing accurate readings, aside from occasional
spikes, which we are working on remedying with a separate contractor.
Per our earlier conversation in March 2021, we have agreed to accept NOV fines until the
issues are resolved,rather than taking on a compliance schedule.
Regards,
Kevin Staubus, CSP
Sanford Environmental, Health and Safety Manager
Caterpillar, Inc., Sanford Site
Caterpillar: Confidential Green

4.*17)--
D.Box 3729 PHONE(919)I!/-1783
iford,NC 27330 _ Fax [phone]
City of 'aiiforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
April 16,2021
Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27331-3667
Subject:Notice of Violation(NOV)Regarding Flow
Dear Mr.Butcher:
The industry-supplied flow sheet indicated one flow overage dated 3/2 on pipe 02 of 39,940 gallons at the
Caterpillar-Womack site.This value exceeded the permit daily maximum flow limit of 0.0373 MGD. The
ERP required action is a$50.00 fine added to your next water and sewer bill.The reasoning and corrective
action was documented on the flowsheet in the comments section.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
5"2"
Sarah Jordan
Pretreatment Coordinator
City of Sanford

CITERPILLAR
Caterpillar,Inc.
Building Construction Products Division
5000 Womack Road
Sanford,North Carolina 27330 USA
April 21,2021
Mrs. Sarah Jordan
Pretreatment Coordinator
Wastewater Management
City of Sanford
P.O. Box 3729
Sanford,NC 27331
Mrs. Jordan:
In reference to Industrial User Pretreatment Permit Number 000033,this letter is in response
to the Notice of Violation, (NOV), received on April 15, 2021 for overages at Pipe 02 on
February 25t,26t, and 27m.
In November 2020,the original flow meters to the facility were replaced due to outdated
equipment and periodic outages. The new flow meters were installed and calibrated on
November 13th, 2020 at Pipes 01 and 02. Since their installation,the meters have been
providing inaccurate and elevated flow measurements.
We have been diligently working with the contractors who installed the meters and other
wastewater contractors to calibrate the meters to pinpoint accuracy.The contractors have
been on site at least once per month since installation of the meters and have told us the
issues have been resolved each time.
As of April 21, 2021,the Pipe 01 flow meter is providing accurate flow measurements. The
Pipe 02 flow meter also seems to be providing accurate readings, aside from occasional
spikes,which we are working on remedying with a separate contractor.
Per our earlier conversation in March 2021,we have agreed to accept NOV fines until the
issues are resolved,rather than taking on a compliance schedule.
Regards,
Kevin Staubus, CSP
Sanford Environmental,Health and Safety Manager
Cate
rpillar, Inc., Sanford Site
Caterpillar: Confidential Green

D.Box 3729 PHONE[phone]
oford,NC 27330 Fax [phone]
QCitp of 'anforb '
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
May 18,2021
Kevin Staubus&Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27330
Subject:Notice of Violation(NOV)Regarding April Flow
Dear Mr. Staubus and Mr.Butcher:
The industry-supplied April flowsheet indicated five flow overages at the Caterpillar-Womack site as
detailed below:
Pipe 01 (Date-value) Pipe 02(Date-value)
4/6-0.09260 MOD 4/7-0.04376 MGD
4/19- 0.04262 MOD
4/27-0.04643 MGD
4/30-0.04170 MGD
These values exceed the permit daily maximum flow limit of 0.0373 MGD.The ERP required action is a
$50.00 fine per violation(5* $50.0(=$250.00 total)added to your next water and sewer bill. The reasoning
and corrective action was documented on the flowsheet in the comments section.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Industrial Self-Monitoring Report Form
Industry Name:Caterpillar Inc. Address:5000 Womack Rd.Sanford NC,27330
Date of Last Calibration:11/10/2020 Permit No:000033 Month:April 1021
Units:Thousand Gallons Per Day(TGD)
Date: I Pipe 01 I Pipe 02 , Date: Pipe C1 I Pipe 02 I Date: Pipe 01 I Pipe 02
1 0 13.29 12 19.33 29.06 23 12.42 20.95
2 0 5.6 13 13.96 27.07 24 0 4.65
3 0 4.45 14 9.95 26.55 25 0 5.6
_ r
4 2.13 6.25 15 27.65 32 26 13.17 29.63
5 8.76 29.26 16 16.18 23.59 27 46.43 28.53
6 92.6 27.19 17 0 7.89 28 11.75 26.1
7 6.51 43.76 18 0 4.7 29 19.4 26.45
8 15.1 2559 19 42.62 28 30 4L7 25.98
9 34 4.69 20 3161 35.91
10 0 _ 25.59 21 16.47 28.5
11 0 4.69 22 32.6 305
TOTALS:Units,Thousand Gallons,(TG)
i
Pipe 01 Total/Month 514.34 Thousand Gallons Pip_01 Daily Average 1 Month 17.14
Pipe 02 Tot l/Month 632.02 Thousand Gallons Pipe 02 Daily Average/Month 21.07
Still seeing solids buildup in Pipe 02 flume causing occasionally high readings.Pipe 01 also
Comments: has increased values due to foam buildup in end stage tank.Working to:mediate both
issues.
I certify that these figures are true and accurate readings of this industry's flow.
Name: u t-, 6i-C‘LAIk--t.5-- Title: 1( ri r-. _e
Signature: ,~ `", Date: 5-G t -- f L i m,,'s <
Caterpillar:Confidential Green

.
P O.Box 3729 PHONE(91%777-1783
nfad,NC 27330 Fax [phone]
Cap of 'anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
June 22,2021
Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27330
Subject:Notice of Violation(NOV)Regarding April Flow
Dear Mr.Butcher:
The industry-supplied May flowsheet indicated three flow overages at the Caterpillar-Womack site as
detailed below:
Pipe 01(Date-value) Pipe 02(Date-value)
5/18-0_04017 MGD 5/13-0_03751 MOD
, 5/19-0.07834 MGD
These values exceed the permit daily maximum flow limit of 0.0373 MGD.The ERP required action is a
$50.00 fine per violation(3* $50.00=$150.00 total)added to your next water and sewer bill_ The reasoning
and corrective action was documented on the flowsheet in the comments section.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783_
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

i.Box 3729 PHONE[phone]
ford,NC 27330 Fax [phone]
City of Oanforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
July 15,2021
Ann McMillan
Environmental Compliance&
Quality Assurance Manager
5618 Clyde Rhyne Drive
Sanford,NC 27330
Subject:Notice of Violation(NOV)Regarding Email
Dear Ms.McMillan:
The email you submitted on July 13,2021 indicated a flow overage at STI Polymer of 108,600 gallons.
This value exceeds the permit daily maximum flow limit of 0.025 MGD.The ERP required action is a
$50.00 fine added to your next water and sewer bill. The reasoning was documented in the email.Please
submit the corrective action within 30 days of the receipt of this letter.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
oszILL-41‘
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Good afternoon Sarah,
I am responding to your letter dated July 15, 2021 concerning the flow overage on July 13th
TP curred due to the excess rain that occurred on the 13th resulting in water backing up into STI Polymer's manway from
dc,......tream. This has happened one other time in the 20 years that STI Polymer has been monitoring flow. We are considering
this a natural occurrence that we cannot put a corrective action in place.
We can confirm that no untreated water came out of the manway resulting in a waste spill.
Please do not hesitate to contact me to contact me with any questions.
Have a great day,
Ann
Ann McMillan I EH&S/ISO Manager
5618 Clyde Rhyne Drive I Sanford, NC 27330
office: 919.777.5995 ext. 209
www.stipolymer.com I amcmillan(astipolymer.com

0.Box 3729 PHONE[phone]
_Iniord,NC 27330 Fax [phone]
eft p of Zlanforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
September 21, 2021
Tyler Althaus
Hydro Tube Enterprises Inc.
2645 Mt. Pisgah Church Road
Sanford,NC 27332
Subject:Notice of Violation(NOV)Missing August Flow Data
Dear Mr. Althaus:
The required August 2021 was not submitted on time.As stated in IUP 000034 flow reports must be
submitted by the 20th of the following month. Furthermore,the Division of Water Resources requests
that flow sheets be submitted via hard copy and postmarked no later than the 20th of each month.
The ERP required action is a$50.00 fine added to your next water and sewer bill. Please submit this
information as soon as possible.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783
or via email.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

01%.
y
Box 3729 . � Fax [phone]
tford,NC 27331-3729 Phone [phone]
tritp of sii'ltiforb
WASTEWATER MANAGEMENT FACILITY Sarah Jordan
PRETREATMENT COORDINATOR
September 21, 2021
Ms. Savannah Carroll
Environmental Manager
Arauco Panels USA,LLC
985 Corinth Road
Moncure,NC 27559
Subject: July-December 2021Wastewater Monitoring Report/NOV
Dear Ms. Carroll:
During the City of Sanford sampling event conducted 8/30-9/2,Arauco experienced high
zinc and copper readings. See tables below.
Date Zinc Result Zinc Permit Limit (mg/I)
(mg/1) Daily Maximum
8/30/21 1.389 1.24
Date Copper Result Copper Permit Limit (mg/I)
(mg/1) Daily Maximum
8/30/21 1.389 0.40
8/31/21 0.419 0.40
These overages carry a$50.00 fine per violation,totaling$150.00. Additionally,you will be
surcharged on an averaged CBOD value of 530.5 mg/1 (surcharge limit is 250 mg/1) and an
averaged TSS value of 1,180 mg/1 (surcharge limit is 200 mg/1). All fines and surcharges
will be applied to your next water and sewer bill.
Please resample copper until compliance is achieved. Compliance is achieved when less than
25%of your samples are below the permit limit. Please submit these resamples as soon as
possible.

A written statement explaining the reasoning for the violations and the corrective action(s)to
be taken must be submitted within 30 days of receiving this notice.
Samples were collected in accordance with the Industrial Permit,Pretreatment Regulations,
and the City of Sanford Sewer Use Ordinance. Samples were analyzed in a Certified
Laboratory using approved methodology. The results are recorded on the Laboratory
service sheet.
If you have questions concerning the enclosed information,please feel free to contact me at
[phone] or via email.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford
Enclosures

985 Corinth Road
a is U Moncure,North Carolina 27559
Tel:[phone]
Toll Free:855-427-2826
Fax:[phone]
October 18, 2021
Sarah Jordan, Pretreatment Coordinator
City of Sanford, Wastewater Management Facility
PO Box 3729
Sanford, NC 27331
Subject: NOV Response/Monthly Report for Industrial User Pretreatment Permit 00042
Dear Ms.Jordan,
The facility was issued a Notice of Violation on September 21, 2021 regarding high copper and
zinc readings taken by the City of Sanford during semi-annual wastewater sampling on August
30th and 30st, 2021. As required by the NOV, the facility would like to address the reasons for
these violations and the corrective actions resulting.
Reasons for Violations
In the past, the permitted facility operated both Particleboard and Medium Density Fiberboard
(MDF) facilities and equipment simultaneously onsite, including wastewater treatment
equipment that was shared by both operations.The Particleboard operation,which permanently
ceased in April 2020, included air pollution control equipment (an Electrostatic Precipitator, or
ESP) that incinerated atomized air pollution and particulate matter and separated out this ash
for collection and disposal. This unit was a "Wet ESP" meaning the waste stream was treated
with water for collection. Consequently,the wastewater from this control device was high in ash
content, which included metals. Over time, the metals content of the sludge in the wastewater
pretreatment lagoons built up. While the use of the Wet ESP ceased in 2020,the sludge from the
system remains. As temperatures changes at the turning of the season, and pond turnover
occurs,the sludge in the bottom of the pretreatment lagoons can be stirred up and indicate high
levels of metals, including copper and zinc. While there are some metals that remain in the MDF
manufacturing process, these are very small compared to the historic production of these
contaminants in the Particleboard wastewater process. Bayoxide Filters, which have specific
media and technology for metals removal, were commissioned in spring 2020 to remove and
treat metals, especially zinc, in the MDF process. Temperature changes and lagoon turnover in
water and sludge movement are strongly believed to be the root cause of the zinc and copper
exceedances.
Corrective Actions
The site has scheduled Clean Harbors, LLC. to complete dredging in the pretreatment lagoons in
November 2021. The company will utilize a suction and boat system to remove sludge from the
bottom of the pretreatment lagoons and dispose of it. This will not only add depth back to the

ponds, increasing settling and pretreatment time in the ponds, but will also remove the historic
sludge that contains metals and other contaminants that are no longer a part of operations on
site. With removal of contaminant laden sludge from the ponds and an increase in wastewater
retention time, the site believes that the root causes of violations for copper and zinc will be
corrected. Resampling to bring the site into compliance is taking place mid though late October
for both copper and zinc.
Also,as required by the Industrial User Pretreatment Permit 000042 issued on November 6, 2020,
Arauco North America, Inc. located at 985 Corinth Rd., Moncure, NC is submitting this September
2021 monthly report.The report includes a summary of the daily flow rates for Pipe 01 and Pipe
02. The daily average was 64,360 gallons total for both pipes.
It you have any questions or concerns, please contact Savannah Carroll, Regional Environmental
Manager, at [e-mail] or [phone].
Sincerely,
/47 (
4 � 6, (1j7
Savannah Carroll for Jeff McMillian (Plant Manager, offsite currently)
Regional Environmental Manager

� �s
T.144.0fr-
0.Box 3729 PHONE[phone]
__nford,NC 27330 Fax [phone]
Qttty_ of *anforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
October 26, 2021
Mr. Wallie Tyler
HSE Manager
Coty US LLC
1400 Broadway Road
Sanford,NC 27332
Subject:Notice of Violation(NOV) Regarding September Flowsheet Overages
Dear Mr. Tyler:
Coty's September flowsheet you submitted indicated two flow overages. One on 9/22 of 71,920 gallons and
another on 9/30 of 78,970 gallons.
Both of these exceed the permit daily maximum flow limit of 66,098 gallons per day. The ERP required
action is a$50.00 fine per violation. Consequently, $100.00 will be added to your water and sewer bill.
Please submit the reasoning and corrective action within 30 days of the receipt of this letter.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
8FL"12---
Sarah Jordan
Pretreatment Coordinator
City of Sanford

P.O.Box 3729
Sanford,NC 27330 PHONE[phone]
Fax F9am
99)776-5D37
i 1p of gl,artfortt
SARAH JORDAN
f retreatment Coordinator
sarah
WASTEWATER MANAGEMENT FACILITY [e-mail]
L
October 28,2021
Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27330
Subject Notice of Violation(NOV)Regarding September Flow
Dear Mr.Butcher
The industry-supplied September flowsheet indicated a flow overage at the Caterpillar-Womack site as
detailed below_
Pipe 02(Datc�valae)
9/13-0.0410'7 MGD
This value exceeds the permitted daily maximum flow limit of 0.0373 MGD. The ERP
$50.00 fine(per violation)added to our next water andrequired action is a
to be submitted y sewer bill. The reasoning and corrective action are
within 30 days of receiving this notice.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
6"-4L-
Sarah Jordan
Pietreahnent Coordinator
City of Sanford

Industrial Self-Monitoring Report Form
Industry Name:Caterpillar Inc. Address:5000 Womack Rd.Sanford NC, 27330
Date of Last Calibration:06/30/2021 Permit No:000033 Month:September 2021
Units:Thousand Gallons Per Day(TGD)
Date: Pipe 01 Pie 02 Date: Pins 01 Pin a 0; Date: fir.;9 02:
1 12.32 25.48 12 0.28 2.96 23 15.44 32.81
2 14.56 28.83 13 20.83 41.07 24 8.75 17.72
3 8.6 14.78 14 10.3 27.13 25 0 2.7
4 3.1 2.36 15 16.2 25.06 26 0 3.87
5 3.08 4.57 16 14.52 31.01 27 21.71 28.25
6 3.01 2.26 17 13.25 13.8 28 12.5 28.15
7 7.35 12.5 18 0 3.18 29 16.4 30.24
8 14.35 27.08 19 0 3.19 30 18.95 29.9
9 23.27 34.68 20 20.69 33.25
10 20.6 35.75 21 25.09 30.65
11 0 3.42 22 15.93 22.32
TOTALS:Units,Thousand Gallons,(TG)
__ Total/Month 341.08 Thousand Gallons Pips.01 Daily Average/Month 11.37
Pipe 02 Total/Month 598.97 Thousand Gallons Pipe 02 Daily Average/Month 19.97
Comments:
l certify that these figures a-e � r accurate
:e readingsof i .ter' s
.t «ii true ca.t�. i,LS •.a.�.�.ei�.� this s3'S zt.,.tJ��� 1,,.t ua%
Name: i%nci r 0, \d O „� Title: 0 er-
� � r i
Signature: Date: LO ( 121 &ôaj
....)
Caterpillar:Confidential Green

G.Box 3729 PHONE[phone]
lord,NC 27330 Fax [phone]
;ttp of 6alnforb
SARAH MCNEILL
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
November 19,2021
Norman Divers
Charah,Inc.
1036 Belmont Village Drive
Belmont,NC 28012
Subject July-December 2021 Wastewater Monitoring Report,Notice of Violation(NOV)
Dear Mr.Divers:
The July-December 2021 sampling event conducted October 18th and 19th indicated that Charah Incorporated exceeded
the permitted limited of molybdenum.The violation as described:
Violations:
Pipe Date Parameter Result Permit Limit TRC Limit
10/19/21 Molybdenum 0.195 mg/I 0.056 mg/I 0.0672 mg/1
A written statement explaining the reason for the violation(s)and corrective actions to be taken must be submitted within
30 days of receiving this notice.Charah must collect at least 3 resamples at or below their permitted limit to fall below the
33%threshold to avoid significant non-compliance.These resamples are to be separate from the quarterly 4 required self-
monitoring samples. Also,the molybdenum overage incurs a$50.00 fine
Additionally,Charah failed to submit the September flow sheet in hard copy as required. Hard copies of flow sheets are to
be postmarked no later than the 20th of the following month.Please send this as soon as possible.This reporting violation
carries a$50.00 fine.The$100.00 accumulated fine will be attached to your next water and sewer statement.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
C5A,1,_4.1----
arah Jordan
retreatment Coordinator
ity of Sanford
nclosures:Chain of Custody
Laboratory Service Report
Metals

i
r-)
°.0.Box 3729
;anford,NC 27330 PHONE[phone]
Fax [phone]
1i ttp of ititforbf
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
November 19, 2021
Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27330
Subject:Notice of Violation(NOV) Regarding October Flow
Dear Mr. Butcher:
The industry-supplied October flowsheet indicated a flow overage at the Caterpillar-Womack site as
detailed below:
Pipe 02(Date-value)
10/6/21-0.03857 MGD
This value exceeds the permitted daily maximum flow limit of 0.0373 MGD. The ERP required action is a
$50.00 fine which will appear on your next water and sewer bill. The reasoning and corrective action are to
be submitted within 30 days of receiving this notice.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
aZ"--12-- L--
Sarah Jordan
Pretreatment Coordinator
City of Sanford

°.0.Box 3729 �� PHONE[phone]
Sanford,NC 27330 Fax [phone]
Cttp of aanforb
SARAH JORDAN
Pretreatment Coordinator
[e-mail]
WASTEWATER MANAGEMENT FACILITY
December 22,2021
Cody Butcher
Caterpillar Inc.
5000 Womack Road
Sanford,NC 27331-3667
Subject:Notice of Violation(NOV)Regarding Flow Meter Power Outage
Dear Mr.Butcher.
The industry-supplied flow sheet(Boone Trail site)indicated apower ra ch
outage on pipe 02 November 3 -11 .
While a power outage is an acceptable reason for no flow data,the system is to be checked daily. Due to
this, Caterpillar will incur a$50.00 on their next water and sewer bill.
If there are questions regarding the above information,please feel free to contact me at(919)777-1783.
Sincerely,
Sarah Jordan
Pretreatment Coordinator
City of Sanford

Inaustr al Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Coty,Inc.
Use separate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000010
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
IFlow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1 1 1 1 1
*Maximum (mg/I►=> 0.045 5.425 68 47 219 197 66 33
*or Maximum (lb/d)=>
*or Average(mg/I)=> 3.184 0.073 68 47.0 219 197 66 33
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
0&G NH3 TKN N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1
*Maximum (mg/I)=> 13.7 41.7 0.50 0.7
*or Maximum (lb/d)=>
*or Average(mg/I)=> 13.7 42 0.50 0.7
*or Average Loading(Ib/d)=>
violations,(chronic SNC is>=66%)=> 0% 0% 0% 0%
To TRC violations,(SNC is>=33%)=> 0% 0% 0% 0%
P Mo Se Diethyl phthalate
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1 1 1
*Maximum (mg/I)=> 3.40000 1.30000 0.02500 0.00250 0.00025 0.00250 0.00128 0.00130
*or Maximum (lb/d)=>
*or Average(mg/I)=> 3.40000 1.30000 0.02500 0.00250 0.00025 0.00250 0.00128 0.00130
*or Average Loading(Ib/d)_>
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)=> 0°/a 0% 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreat Innual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Coty,Inc.
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000010
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CD CR CU )
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 2 2 1 1 1 1
*Maximum (mg/1)_> 0.045 5.425 0.0026250 0.0075000 0.001000 0.001000 0.470000 0.030000 I
*or Maximum (lb/d)=>
*or Average(mg/I)=> 3.184 0.073 0.0026250 0.0075000 0.001000 0.470000 0.030000
*or Average Loading(Ib/d)=> 0.001000
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB Sulfide
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 1 1 1 1
*Maximum (mg/I)=> 0.001000 0.000100 0.003000 0.004000 0.001000 0.001000
*or Maximum (Ib/d)=>
*or Average(mg/I)=> 0.001000 0.001000 0.003000 0.004000 0.001000
*or Average Loading(lb/d)=> 0.001000
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0%
TRC violations,(SNC is>=33%)=> 0% 0% 0% 0% 0% 0%
AS MBAS CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/I)=> 0.00500 0.00500 0.00250 0.00250 0.00050 0.00050
*or Maximum (Ib/d)=>
*or Average(mg/I)_> 0.00500 0.00500 0.00250 0.00250 0.00050
*or Average Loading(lb/d)=> 0.00050
%violations,(chronic SNC is>=66%1=> 0% 0% 0% 0% 0% 0%
TRC violations,(SNC is>=33%)=> 0% 0% 0% 0°/a 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

II rial Data Summary Form(IDSF) Control Authorit Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Moen,Incorporated
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000008
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:Combined Wastestream
1st 6 months,dates: 1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/I)_> 289 287 131 366 255 913 66 110
*or Maximum (Ib/d)=> —
*or Average(mg/I)=> 0.210 0.233 82 220 178 517 43 79
*or Average Loading (Ib/d)_>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
O&G NH3 TKN N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1 1 1 1 1
*Maximum (mg/I)=> 16.87 39.82 71.4 46.70 83.2 78.3 0.2 1.55
*or Maximum (Ib/d)=>
*or Average (mg/I)=> 14 26 71.4 46.70 83.2 78.3 0.2 1.55
*or Average Loading (lb/d)_>
violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)=> 0% 0% 0% 0% 0% 0% 0% 0%
P Mo1 Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/I)=> 9.11 10.4 0.21900 0.14200 0.00025 0.01250
*or Maximum (Ib/d)=>
*or Average(mg/I)=> 9.11 10.40 0.21900 0.14200 0.00025 0.01250
*or Average Loading (Ib/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0 0 0 0
%TRC violations,(SNC is>=33 %)_> 0% 0% 0 0 0 0
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit Ibid=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than In)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

P atment Annual Report(PAR) Co authority, Industry,
Industrial Data Summary Form (IDSF) Town Name;City of Sanford Name:Moen, Incorporated
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000008
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates: 1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd1 Chloroform Di-n-butyl ahathalate Phenol
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1 1 1 1 1
*Maximum (mg/I)=> 0 0.035 0.006 0.0076 0.005 0.005 0.025 0.0025
*or Maximum (lb/d)=>
*or Average (mg/I)=> 0.000 0.004 0.006 0.0076 0.005 0.005 0.025 0.0025
*or Average Loading (Ib/d)=> _
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
TRC violations,(SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
11st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/I)_>
*or Maximum (Ib/d)=>
*or Average (mg/I)_>
*or Average Loading(lb/d)_>
%violations,(chronic SNC is>=66%)_>
TRC violations,(SNC is>=33 %)_>
' AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/I)_>
*or Maximum (Ib/d)=>
*or Average (mg/I►=>
*or Average Loading (lb/d1=>
%violations,(chronic SNC is>=66%)_>
%TRC violations,(SNC is>=33 %)=>
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit Ib/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

rF atment Annual Report(PAR) ( I Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Moen,Incorporated
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000008
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates: 1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CD CR CU J
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/I)=> 0 0.035 0.000025 0.000250 0.19100 0.17100 0.06700 0.12100
*or Maximum (Ib/d)=>
*or Average (mg/I)=> 0.168 0.182 0.000025 0.000250 0.07250 0.04925 0.03600 0.04750
*or Average Loading(Ib/d)_>
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months I2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 4 4 4 4 4 4
*Maximum (mg/I)=> 0.00100 0.00100 0.16900 0.09400 0.00100 0.00200 0.24300 0.12000
*or Maximum (Ib/d)_>
*or Average (mg/I)=> 0.00100 0.00100 0.07800 0.03400 0.00100 0.00125 0.15825 0.04900
*or Average Loading(Ib/d)_>
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
TRC violations,(SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 5 5 4 4
*Maximum (mg/I)=> 0.00150 0.00050 0.00500 0.00500 0.00030 0.00050
*or Maximum (Ib/d)=>
*or Average(mg/I)=> 0.00150 0.00050 _ 0.00450 0.00450 0.00015 0.00050
*or Average Loading (Ib/d)=>
%violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)_> 0% 0% certified certified 0% 0% 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
" POTW must enter at least one of these IUP=>Industrial User Permit Ib/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Indu Data Summary Form (IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Pfizer
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000022
Enter BDL values as <values NPDES#:NC 0024147
1st 6 months,dates: 2021 to 1 1 2021 6 30 Pipe Combined
/ / / /
2nd 6 months,dates:7/1/2021 to 12/31/2021 Pipe Combined
Flow,mgd 02 CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples => 184 184 4 4 4 4 4 8
*Maximum (mg/1) _> 200 134 449 370 103.0 41
*or Maximum (lb/d)_> 314
*or Average(mg/1) _> 164 102 396 314 65.5 38
*or Average Loading(lb/d)_>
violations,(chronic SNC is>=66%)=> 0% 0% N/A N/A N/A N/A N/A N/A
% — _ 0%
TRC violations, (SNC is>—33 %) —> 0% N/A N/A N/A N/A N/A N/A
O&G NH3 TKN ' N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1 1 1 1 1
*Maximum (mg/1) => 4.3 6.18 39 27.00 45 32 0.049 0.02
*or Maximum (lb/d) _>
*or Average(mg/1) _> 2.3 3 39 27.00 45.0 32.0 0.049 0.02
*or Average Loading(lb/d) _>
% violations, (chronic SNC is>=66%) => N/A N/A 0% 0% N/A N/A N/A N/A
% TRC violations,(SNC is>=33 %) => N/A N/A 0% 0% N/A N/A N/A N/A
P Hg AS Mo
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 2 2 1 1 1 1
*Maximum (mg/1) => 32 25.00 0.0001 0.0001 0.000235 0.000325 0.01 0.06
*or Maximum (lb/d)=>
*or Average(mg/1) _> 32 25.00 0.0001 0.0001 0.000235 0.000325 0.01 0.06
*or Average Loading(lb/d)_>
% violations, (chronic SNC is>=66%)=> N/A N/A N/A N/A 0% 0% N/A N/A
% TRC violations, (SNC is>=33 %) => N/A N/A N/A N/A 0% 0% N/A N/A
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretr ent Annual Report(PAR) Contro irity, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Pfizer
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000022
Enter BDL values as <values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates: 1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CN Carbon Tetrachloride
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5 2 2
*Maximum (mg/1) _> 0.00031 0.003 0.00017 0.0085
*or Maximum (lb/d) =>
*or Average(mg/1) => 0.002 0.003 0.00 0.01
*or Average Loading(lb/d)_>
% violations, (chronic SNC is>=66%) => 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% 0% 0%
Acenaphthene Nitrobenzene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1
*Maximum (mg/1) => 0.0015 0.0015 0.0016 0.002
*or Maximum (lb/d) =>
*or Average(mg/1) _> 0.0015 0.0015 0.0016 0.002
*or Average Loading(lb/d) =>
% violations,(chronic SNC is>=66%) => 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %) => 0% 0% 0% 0%
I I
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1)_>
*or Maximum (lb/d) =>
*or Average(mg/1) =>
*or Average Loading(lb/d) =>
% violations, (chronic SNC is>=66%)=>
% TRC violations, (SNC is>=33 %)=>
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Indu Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Pfizer
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000022
Enter BDL values as<values NPDES#:NC 0024147
1st 6 months,dates:1/1/2021 to 6/30/2021 Pipe Combined
2nd 6 months,dates:7/1/2021 to 12/31/2021 Pipe Combined
Flow,mgd 02 Se Pb Ni
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1 4 4 4 4
*Maximum (mg/1) _> 0.00046 0.00046 0.001 0.001 0.030 0.04
*or Maximum (lb/d)=>
*or Average(mg/1) => 0.000 0.00046 0.001 0.001 0.028 0.020
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1) _>
*or Maximum (lb/d)=>
*or Average(mg/1)=>
*or Average Loading(lb/d) _>
% violations,(chronic SNC is>=66%) =>
% TRC violations, (SNC is>=33 %) _>
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1) _>
*or Maximum (lb/d)=>
*or Average(mg/1) =>
*or Average Loading(lb/d) =>
% violations,(chronic SNC is>=66%) =>
% TRC violations, (SNC is>=33 %)=>
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretr ent Annual Report(PAR) Control Authori Industry,
Industrial Data Summary Form (IDSF) Town Name:City of Sanford Name:Pfizer
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000022
Enter BDL values as<values NPDES#:NC 0024147
1st 6 months,dates:1/1/2021 to 6/30/2021 Pipe 01
2nd 6 months,dates:7/1/2021 to 12/31/2021 Pipe 01
Flow,mgd 02 CD MBAS CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5 0 0 4 4
*Maximum (mg/1)_> 0.0003 0.000 0 0 0.056 0.037
*or Maximum (lb/d) =>
*or Average(mg/1) => 0.0003 0.0003 0.042 0.03
*or Average Loading(lb/d) =>
violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% N/A N/A 0% 0%
% TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% N/A N/A 0% 0%
HG NH3 Acetone Chloroform
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 1 1 1 1 1 1
*Maximum (mg/1) _> 0.000085 0.000085 63 27 0.4 0.21 0.003 0.0025
*or Maximum (lb/d) =>
*or Average(mg/1) _> 0.00009 0.0001 63 27 0.36 0.210 0.00 1.25
*or Average Loading(lb/d) _>
% violations,(chronic SNC is>=66%) _> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
AS 40CFR-439-16 CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 5 5 4 4
*Maximum (mg/I) _> 0.000235 0.007 0.30 0.81 0.003 0.005 0.005 0.005
*or Maximum (lb/d)=>
*or Average(mg/1) _> 0.000235 0.007 0.30 0.810 0.003 0.004 0.0050 0.005
*or Average Loading(lb/d) =>
% violations, (chronic SNC is>=66%)_> 0% 0% N/A N/A 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %) => 0% 0% N/A N/A 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control tority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Nanse:STI Polymer,Inc.Technologies
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 181 184 4 4* 4 4 4 4
*Maximum (mg/1) _> 196 203 507 859 54 347
*or Maximum (lb/d)=>
*or Average(mg/1) _> 147 169 412 603.5000 29 142
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%) _> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
- _ ,
O&G NH3 TKN N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1
*Maximum (mg/1)=> 21.8 30.4 7 6.5
*or Maximum (lb/d)=>
*or_ Average(mg/1)=> 14 11 7 6.5
*or Average Loading(lb/d) _> 0
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %) _> 0% 0% 0% 0%
P CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 5 5 4 4 4 4
*Maximum (mg/I) => 2.9 1.3 0.00050 0.00025 0.003 0.008 0.111 0.004
*or Maximum (lb/d) =>
*or Average(mg/1) => 2.9 1 0.00044 0.0003 0.003 0.003 0.087 0.00300
*or Average Loading(lb/d)_>
%violations,(chronic SNC is >=66%)_> 0% 0% N/A N/A 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %) _> 0% 0% N/A N/A 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:STI Polymer,Inc.Technologies
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd Cyanide Lead Zinc
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 2 1 2 1 2
*Maximum (mg/1) _> 0.013 0.017 0.00245 0.00800 0.001380 0.00013 0.04570 0.01340
*or Maximum (lb/d) _>
*or Average(mg/1)=> 0.007 0.00245 0.0052 0.001380 0.000005 0.045700 0.011700
*or Average Loading(ib/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
Acenaphthene Anthracene Benzene Bis(2-etju;jexyl)phthalate
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1) _> 0.0060 0.0035 0.0060 0.0040 0.00355 0.00075 0.07000 0.0043
*or Maximum (lb/d)=>
*or Average(mg/1)_> 0.0060 0.0035 0.0060 0.0040 0.00355 0.00075 0.07000 0.0043
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)=> 0% 0% 0% 0% 0% 0% 0% 0%
Carbon Tetrachloride Chlorobenzene Chloroethane Chloroform
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1) => 0.00470 0.00001 0.00355 0.00009 0.00490 0.00012 0.00400 0.00085
*or Maximum (lb/d) _>
*or Average(mg/1)_> 0.00470 0.00470 0.00355 0.00009 0.00490 0.00012 0.00400 0.00085
*or Average Loading(lb/d) _>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Contro: tority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:STI Polymer,Inc.Technologies
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
4,6-Dinitro-o-cresol Ethylbenzene Fluoranthene Fluorene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)_> 0.0012 0.0007 0.00345 0.00007 0.0080 0.0005 0.0060 0.0043
*or Maximum (lb/d) _>
*or Average(mg/1)_> 0.0012 0.0007 0.00345 0.00007 0.0080 0.0005 0.0060 0.0043
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%) _> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
Hexachlorobenazene Hexachlorobutadiene Hexachloroethane Methyl Chloride
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)=> 0.0075 0.000 0.0075 0.0003 0.0600 0.0003 0.00410 0.00007
*or Maximum (lb/d) _>
*or Average(mg/1) _> 0.0075 0.0003 0.0075 0.0003 0.0600 0.0003 0.00410 0.00007
*or Average Loading(lb/d) _>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
Methlene Chloride Naphthalene Nitrobenzene 2-Nitrophenol
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1) => 0.00850 0.00425 0.0700 0.0175 0.0065 0.0016 0.0130 0.0028
*or Maximum (lb/d)=>
*or Average(mg/1)=> 0.00850 0.00012 0.0700 0.0009 0.0065 0.0003 0.0130 0.0028
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%) => 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:STI Polymer,Inc.Techno:_o___
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
CN AG MBAS CTAS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 4 4
*Maximum (mg/1) => 0.00245 0.033 0.0005 0.0005
*or Maximum (lb/d) _>
*or Average(mg/1)_> 0.00245 0.018 0.0005 0.0005
*or Average Loading(lb/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 4 4
*Maximum (mg/1) _> 0.000075 0.0000750 0.0010 0.003 0.001 0.001 0.211 0.065
*or Maximum (lb/d)_>
*or Average(mg/1)_> 0.000075 0.00008 0.0010 0.002 0.002 0.002 0.14 0.03
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
Mo Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 . 1
*Maximum (mg/1)_> 0.510 0.845 0.0031 8.2
*or Maximum (lb/d) _>
*or Average(mg/1)=> 0.510 0.8450 0.0031 5.2000
*or Average Loading(lb/d)_>
%violations, (chronic SNC is>=66%)_> 0% 0% N/A N/A
%TRC violations, (SNC is>=33 %)_> 0% 0% N/A N/A
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:STI Polymer,Inc.Technologies
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Di-n-butyl phathalate 1,2-Dichlorobenzene 1,3;Dichlorobenzene 1,4-Dichlorobenzene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)_> 0.0065 0.00350 0.00365 0.00095 0.00385 0.00385 0.00500 0.00500
*or Maximum (lb/d)=>
*or Average(mg/1)_> 0.0065 0.00350 0.00365 0.00095 0.00385 0.00385 0.00500 0.00500
*or Average Loading(lb/d)_>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
0
1,1-Dichloroethane 1,2-Dichloroethane 1,1-Dichloroethylene 1,2-trans-Dichloroethylene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)_> 0.00105 0.00011 0.00210 0.00210 0.000210 0.00210 0.00001 0.00011
*or Maximum (lb/d)_>
*or Average(mg/1)_> 0.00021 0.00011 0.00210 0.00210 0.000210 0.00210 0.00001 0.00011
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %)_> _ 0% 0% 0% 0% 0% 0% 0% 0%
1,2-Dichloropropane 1,3-Dichloropropylene Diethyl phthalate Dimethyl phthalate
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1) => 0.0005 0.00005 0.0002 0.00008 0.0005 0.0005 0.0004 0.0004
*or Maximum (lb/d)=>
*or Average(mg/1)=> 0.0005 0.0001 0.0002 0.00008 0.0005 0.0005 0.0004 0.0004
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)=> 0% 0% 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:STI Polymer,Inc.Technologies
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000032
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
4-Nitrophenol Phenanthrene Pyrene Tetrachloroethylene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)_> 0.020 0.005 0.0070 0.0004 0.0100 0.0011 0.00195 0.00090
*or Maximum (lb/d) _>
*or Average(mg/1)_> 0.0200 0.0050 0.0070 0.0004 0.0100 0.0011 0.00195 0.00090
*or Average Loading(lb/d) =>
% violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
Toluene 1,2,4-Trichlorobenzene 1,1,1-Trichloroethane 1,1,2-Trichloroethane I
II
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2 1 2 1 2
*Maximum (mg/1)=> 0.00285 0.00500 0.0080 0.0050 0.00280 0.01250 0.00190 0.01250
*or Maximum (lb/d)_>
*or Average(mg/1)_> 0.00285 0.00393 0.0080 0.0065 0.00280 0.00140 0.00190 0.00720
*or Average Loading(lb/d)_>
% violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
Trichloroethylene Vinyl Chloride
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 2 1 2
*Maximum (mg/1)=> 0.00370 0.01250 0.00165 0.02500
*or Maximum (1b/d) =>
*or Average(mg/1)=> 0.00370 0.00810 0.00165 0.01333
*or Average Loading(lb/d)=>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %) _> 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Magneti Marelli(Main Plant)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000007
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
Plant shut down in second six months
Flow,mgd CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total# of samples=> 184 4 4 4
*Maximum (mg/1)=> 0.015 0.00250 0.00340 0.09400
*or Maximum (lb/d) => 0.00033 0.00026 0.00082
*or Average(mg/1)=> 0.000 0.00250 0.00340 0.09400
*or Average Loading(lb/d)=> 0.00018 0.00018 0.00049
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 25%
% TRC violations,(SNC is>=33 %)=> 0% 0% 0% 25%
FIG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 4 4 4
*Maximum (mg/1) => 0.00008 0.00500 0.00100 0.42100
*or Maximum (lb/d) => 0.00016 0.00092 0.00033 0.01730
*or Average(mg/1)_> 0.00008 0.00500 0.00100 0.28425
*or Average Loading(lb/d) _> 0.00009 0.00053 0.00018 0.00950
% violations,(chronic SNC is>=66%) => N/A 0% 0% 0%
% TRC violations, (SNC is>=33 %)_> N/A 0% 0% 0%
AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 0 1 4
*Maximum (mg/1) => 0.00380 0.00000 0.00250 0.00500
*or Maximum (lb/d) => 0.00009 0.00000 0.00104 0.00033
*or Average(mg/1)=> 0.00380 0.02010 0.00500
*or Average Loading(lb/d) _> 0.00009 0.00056 0.00026
% violations,(chronic SNC is>=66%)=> N/A Certified 0% 0%
% TRC violations,(SNC is>=33 %)=> N/A Certified 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter

* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plan
Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Magneti Marelli(Main Plant)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000007
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
Plant shut down in second six months
Flow,MGD Phenol Al
1st 6 months 2nd 6 months 1st 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 1 1
*Maximum (mg/1)_> 0.014534 0.11 17.2
*or Maximum (lb/d) _> 0.065 0.422
*or Average(mg/1) _> 0.0010 0.110 17.200
*or Average Loading(lb/d)_> 0.065 0.422
% violations,(chronic SNC is>=66%)_> 0% 0% 0%
% TRC violations,(SNC is>=33 %)=> 0% 0% 0%
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1) =>
*or Maximum (lb/d) =>
*or Average(mg/1)_>
*or Average Loading(lb/d) _>
% violations, (chronic SNC is>=66%)_>
% TRC violations, (SNC is>=33 %)=>
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1) =>
*or Maximum (Ib/d) _>

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Magneti Marelli(Main Plant)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000007
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021 I
Plant shut down in second six months
Flow, MGD CBOD COD TSS I
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 4 4 4
*Maximum (mg/1) _> 0.0176 521 1520 464
*or Maximum (lb/d)_> 19.1 453 36
*or Average(mg/1) _> 0.0045 307 948 208
*or Average Loading(lb/d)=> 41 137 18
% violations,(chronic SNC is>=66%) _> 0% 0% N/A 0%
% TRC violations, (SNC is>=33 %)=> 0% 0% N/A 0%
O&G NH3 TKN N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 1 1 1
*Maximum (mg/1) _> 33.40 75.20 91.40 0.45
*or Maximum (lb/d) => 12.22 5.39 6.55 0.03
*or Average(mg/1) _> 22.70 75.20 91.40 0.45
*or Average Loading(lb/d)_> 3.81 5.39 6.55 0.03
% violations, (chronic SNC is>=66%)_> N/A N/A N/A N/A
% TRC violations, (SNC is>=33 %) _> N/A N/A N/A N/A
P Mo Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 0
*Maximum (mg/1)=> 18.00 0.25000 0.25000
*or Maximum (lb/d) => 0.66 0.01790 0.01790
*or Average(mg/1) _> 18.00 0.25000 0.25000
*or Average Loading(lb/d)_> 0.66 0.01790 0.01790
% violations, (chronic SNC is>=66%) _> N/A N/A N/A
% TRC violations,(SNC is>=33 %) _> N/A N/A N/A
BDL=>Below Detection Limit mg/1=>milligrams per liter

rU
tment Annual Report(PAR) Co ithonty, Industry,
dustrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Trion,Incorporated
see seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000013
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,m9d CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5 4 4 4 4
*Maximum (mg/I)_> 0.03600 0.0025 0.001 0.001 0.0019 0.122
*or Maximum (Ib/d)_>
*or Average(mg/I)_> 0.00752 0.0021 0.001 0.001 0.002 0.04
*or Average Loading(Ib/d)=>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 4 4
*Maximum (mg/I)=> 0.075 0.000075 0.001 0.001 0.001 0.006 0.27 1.15
*or Maximum (lb/d)=>
*or Average(mg/I)_> 0.3750 0.000 0.001 0.001 0.001 0.0018 0.25 0.400
*or Average Loading(Ib/d)_>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 0 0 5 5 4 4
*Maximum (mg/I)_> 0.2350 0.00047 0.000 0.000 0.045000 0.002450 0.000500 0.001000
*or Maximum (lb/d)=> 0.000 0.000
*or Average(mg/I)_> 0.2350 0.00047 0.011880 0.002460 0.000500 0.000625
*or Average Loading(Ib/d)=>
%violations,(chronic SNC is>=66%)_> 0% 0% certified certified 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)_> 0% 0% certified certified 0% 0% 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
' POTW must enter at least one of these IUP=>Industrial User Permit Ib/d=>pounds per day
All averages are based on six month periods, SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)Is calculated as half of detection, TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Inditmentustrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Trion,Incorporated
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000013
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow, m9d Toluene
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1
*Maximum (mg/I)_> 0.000360 0.000285
*or Maximum (lb/d)=>
*or Average(mg/I)=> 0.000360 0.000285
*or Average Loading(lb/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)_> 0% 0% 0% 0%
o-XYlene - I
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1
*Maximum (mg/I)=> 0.0001200 0.0002200
*or Maximum (lb/d)=>
*or Average(mg/I)=> 0.0001200 0.0002200
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)_> 0% 0%
%TRC violations,(SNC is>=33%)_> 0% 0%
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/I)=>
*or Maximum (lb/d)=>
*or Average(mg/I)_>
*or Average Loading(Ib/d)=>
%violations, (chronic SNC is>=66%)_>
%TRC violations,(SNC is>=33%)_>
BDL=>Below Detection Limit mg/I=>milligrams per liter
' POTW must enter at least one of these IUP=>Industrial User Permit ib/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(()Is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Ir !al Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR)
Pretreatment Name:City of Sanford Name:Trion,Incorporated
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000013
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow, m9d CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/I)_> 56.0000 51.0000 350.0000 144.0000 70.8000 50.0000
*or Maximum (Ib/d)_>
*or Average(mg/I)=> 38,0000 40.0000 205.2500 144.0000 42.0000 37.0000
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)_> 0% 0% N/A N/A N/A N/A N/A N/A
%TRC violations,(SNC is>=33%)_> 0% 0% N/A N/A N/A N/A N/A N/A
O&G NH3 TKN N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1 1 1 1 1
*Maximum (mg/I)_> 15.500 8.470 14.000 5.700 20.000 10.000 0.430 0.420
*or Maximum (Ib/d)=>
*or Average(mg/I)_> 5.985 2.998 14.000 5.700 20.000 10.000 0.430 0.420
*or Average Loading(lb/d)_>
%violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
P Mo Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/I)_> 7.3000 5.2000 0.2320, 0.2190 0.0031 0.0031
*or Maximum (Ib/d)_>
*or Average(mg/I)_> 7.3000 5.2000 0.2320 0.2190 0.0031 0.0031
*or Average Loading(Ib/d)_>
%violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)=> 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/l=>milligrams per liter
" POTW must enter at least one of these IUP=>Industrial User Permit Ib/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Caterpillar Paint&Plating Operations
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000033
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 0 4 4
*Maximum (mg/1)_> 1041.00 882.00 2900.00 1990.00 422.00 240.00
*or Maximum (lb/d) =>
*or Average(mg/1)=> 550.75 547.00 1561.00 1990.00 271.00 201.00
*or Average Loading(lb/d)_>
violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
O&G NH3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1
*Maximum (mg/1)_> 61.000 2.500 58.500 8.700
*or Maximum (lb/d)_>
*or Average(mg/1)_> 35.875 2.500 58.500 8.700
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0%
P Molybdenum Selenium
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/1)_> 17.20 73.400 0.03600 0.00700 0.00500 0.00050
*or Maximum (lb/d)=>
*or Average(mg/1)_> 17.20 73.400 0.03600 0.00700 0.00500 0.00050
*or Average Loading(lb/d)=>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Caterpillar Paint&Plating Operations
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000033
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd XYLENE PHENOL
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1 1 1
*Maximum (mg/1)_> 0.001500 0.001500 0.009 0.00500
*or Maximum (lb/d) _>
*or Average(mg/1)_> 0.001500 0.001500 0.00890 0.00500
*or Average Loading(lb/d)=>
violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %) _> 0% 0% 0% 0%
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1)_>
*or Maximum (lb/d) _>
*or Average(mg/1)_>
*or Average Loading(lb/d)_>
% violations, (chronic SNC is>=66%)_>
%TRC violations,(SNC is>=33 %)=>
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1)_>
*or Maximum (lb/d)_>
*or Average(mg/1)=>
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_>
% TRC violations, (SNC is>=33 %) _>
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Caterpillar Paint&Plating Operations
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000033
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5 4 4 4 4
*Maximum (mg/1)_> 0.0316 0.00100 0.002500 0.001 0.001 0.334 0.095000
*or Maximum (lb/d) =>
*or Average(mg/1)=> 0.00040 0.002020 0.001 0.001 0.133 0.055750
*or Average Loading(lb/d)=>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33 %)=> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 4 4
*Maximum (mg/1)_> 0.010000 0.0001 0.075 0.03200 0.001000 0.001000 0.018 0.0090
*or Maximum (lb/d) =>
*or Average(mg/1)=> 0.010000 0.0001 0.03625 0.02275 0.001000 0.001000 0.0145 0.00725
*or Average Loading(lb/d) =>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)=> 0% 0% 0% 0% 0% 0% 0% 0%°AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 5 5 4 4
*Maximum (mg/1) => 0.01200 0.0070 0.00400 0.01400 0.00050 0.00500
*or Maximum (lb/d)=>
*or Average(mg/1)=> 0.01200 0.0070 0.00370 0.00710 0.00050 0.00500
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% certified certified 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Caterpillar Inc(Boone Trail)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000040
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/1) => 143.00 60.00 267.00 382.00 150.00 400.00
*or Maximum (lb/d) =>
*or Average(mg/1)_> 105.00 38.00 214.50 233.50 81.00 269.00
*or Average Loading(Ib/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
O&G NH3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1
*Maximum (mg/1)_> 2.850 2.500 7.800 8.700
*or Maximum (lb/d)_>
*or Average(mg/1)_> 2.638 2.500 7.800 8.700
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0%
P Molybdenum Selenium
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/1)=> 90.90 73.400 0.01100 0.00700 0.00500 0.00050
*or Maximum (lb/d) =>
*or Average(mg/1)_> 90.90 73.400 0.01100 0.00700 0.00500 0.00050
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Industrial Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Caterpillar Inc(Boone Trail)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000040
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd XYLENE PHENOL
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 1 1 1 1
*Maximum (mg/1) _> 0.001500 0.001500 0.01300 0.00500
*or Maximum (lb/d)=>
*or Average(mg/1)_> 0.001500 0.001500 0.01300 0.00500
*or Average Loading(lb/d)_>
violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0%
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1)=>
*or Maximum (lb/d)=>
*or Average(mg/1)=>
*or Average Loading(lb/d)=>
% violations,(chronic SNC is>=66%)_> _
% TRC violations,(SNC is>=33 %)_>
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=>
*Maximum (mg/1) =>
*or Maximum (ib/d)_>
*or Average(mg/1)=>
*or Average Loading(1b/d)_>
% violations,(chronic SNC is>=66%)_>
% TRC violations,(SNC is>=33 %)_>
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Caterpillar Inc(Boone Trail)
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP 000040
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5 4 4 4 4
*Maximum (mg/1)_> 0.00025 0.000250 0.01400000 0.035000 0.029000 0.049000
*or Maximum (lb/d)=>
*or Average(rng/1)_> 0.00067 0.000220 0.00650000 0.016500 0.014750 0.035250
*or Average Loading(lb/d)=>
violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %) _> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 4 4
*Maximum (mg/1)=> 0.000100 0.0001 0.03500 0.03600 0.001000 0.001000 0.04700 0.27000
*or Maximum (lb/d) =>
*or Average(mg/1)=> 0.000100 0.0001 8.77400 0.02275 0.001000 0.001000 0.02975 0.10025
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
AS TTO CN AG
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 5 5 4 4
*Maximum (mg/1)=> 0.0130 0.007 0.01800 0.01400 0.00050 0.00500
*or Maximum (lb/d)=>
*or Average(mg/1)_> 0.0130 0.007 0.00890 0.00930 0.00050 0.00500
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)=> 0% 0% 0% 0% 0% #REF!
N/A mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half the value. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

rU
ial Data Summary Form(IDSF) Control Authority, Industry,
retreatment Annual Report(PAR) Town Name:City of Sanford Name:Hydro Tube Enterprises
see seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000034
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:02
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow, m9d CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/I)=> 138.00 145 258.00 393 68.00 98
*or Maximum (lb/d)_>
*or Average(mg/I)_> 92.00 112 191.25 281 41.00 55.25
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
O&G NH3 TKN1 N2-N3
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1 1 1 1 1
*Maximum (mg/I)=> 69.60 24.40 23.00 100.00 44.00 160.00 0.73 0.12
*or Maximum (lb/d)=>
*or Average(mg/I)=> 36.08 10.45 23.00 100.00 44,00 160.00 0.73 0.12
*or Average Loading(Ib/d)_>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
P Mo Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/I)=> 8.30 20.00 0.00125 0.00333 0.003 0.0031
*or Maximum (lb/d)_>
*or Average(mg/I)_> 8.30 20.00 0.00125 0.00333 0.0031 0.0031
*or Average Loading(lb/d)=>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)_> 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Pretreatment Annual Report(PAR) Control Authority, Industry,
Industrial Data Summary Form(IDSF) Town Name:City of Sanford Name:Hydro Tube Enterprises
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000034
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow, m9d CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 4 4 4 4 4 4
*Maximum (mg/I)=> 0.00025 0.00025 0.004 0.011000 0.03 0,041
*or Maximum (Ib/d)=>
*or Average(mg/I)_> 0,00025 0.00025 0.00275 0.00525 0.02825 0.0305
*or Average Loading(Ib/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)_> 0% 0% 0% 0% 0% 0% 0% 0%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 4 4
*Maximum (mg/I)=> 0.00075 0.00075 0.0140 0.016 0.001 0.001 0.058 0.089
*or Maximum (Ib/d)=>
*or Average(mg/1)_> 0.00075 0.00075 0.0115 0.01225 0,001 0.001 0.0535 0.06475
*or Average Loading(lb/d)_>
%violations, (chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0% 0% 0%
%TRC violations, (SNC is>=33%)=> 0% 0% 0% 0% 0% 0% 0% 0%
AS TTO CN AG I
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 5 5 4 4
*Maximum (mg/I)_> 0.00047 0.00144 0.0025 0.0025 0.0005 0.0005
*or Maximum (Ib/d)_>
*or Average(mg/I)_> 0.00047 0.00144 0.00246 0.00246 0.0005 0.0005
*or Average Loading(Ib/d)_>
%violations,(chronic SNC is>=66%)_> 0% 0% 0% 0% 0% 0%
%TRC violations,(SNC is>=33%)=> 0% 0% certified certified 0% 0% 0% 0%
BDL=>Below Detection Limit mg/I=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit Ib/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Indut_____Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Tyson Foods
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000025
Enter BDL values as <values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CBOD COD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 2 2 2 2 2 2
*Maximum (mg/1) => 956 463 1190 1220 380 438
*or Maximum (lb/d) _> j
*or Average(mg/1) => 945.0 339.5 979 1000 289 308
*or Average Loading(lb/d) _>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
O&G ( NH3 H Zn
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 1 1 1 1 2 2
*Maximum (mg/1)=> 5 128 9.4 16 0 0.0002 0.138 0.13
*or Maximum (lb/d)=>
*or Average(mg/1) => 4 103 9.4 16.20 0.0 0.0002 0.105 0.11
*or Average Loading(lb/d) _>
% violations, (chronic SNC is>=66%) => 0% 0% 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 0% 0%
P TN Cn
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 2 2
*Maximum (mg/1) _> 2.70 4.00 19.6' 30.5 0.286 0.011
*or Maximum (lb/d) =>
*or Average(mg/1) => 2.70 4.00 19.6 30.5 0.151 0.0085
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%) _> 0% 0% 0% 0% 0% 0%
% TRC violations,(SNC is>=33 %) => 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

Charah
Solutions
Quarterly Leachate Sampling Data Sheet
Project: Brickhaven Structural Fill
Sample Point: LT-02
Reporting Period: Q4 2021
Notes:
M&R-Monitor and Report N/A=Not Applicable
N/E-Not Established ROL=Below Quantitation Limits
Daily Doily Required
Monitoring Maximum Maximum Laboratory Laboratory
Sampling 1- Concentration Limit Detection Detection Level
Constituent Frequency Sample Date Analytical Result Value? (mg/Il (lbs./day) Level(mg/7) (mg/11
Aluminum 1 per quarter 10/26/21 < 0.001 mg/I M&R N/E 0.001 0.01
Arsenic 1per quarter 10/26/21 0.00566 mg/1 N/E N/E 0.001 0.005
Barium I per quarter 10/26/21 0.0513 mg/I N/E N/E 0.00001 0.002
Beryllium I per quarter 10/26/21 0.00016 mg/I M&R N/E 0.000001 0.01
Bromide Iper quarter 10/26/21 1.4 mg/I M&R N/E 0.03 0.1
Cadmium I per quarter 10/26/21 < 0.001 mg/I M&R N/E 0.001 0.002
Chromium Iper quarter 10/26/21 < 0.001 mg/I N/E N/E 0.001 0.005
Copper 1 per quarter 10/26/21 0.001 mg/I M&R N/E 0.001 0.005
Cyanide 1 per quarter 10/26/21 < 0.0049 mg/I M&R N/E 0.005 0.01
Iron I per quarter 10/26/21 < 0.1 mg/I M&R N/E 0.1 0.05
Lead 1per quarter 10/26/21 < 0.001 mg/I M&R N/E 0.001 0.001
Low Level Mercury 2 per quarter 10/27/21 0.00000116 mg/1 N/E N/E 0.0000005 0.000001
10/29/21 0.00000057 mg/I
10/26/21 0.282 mg/1
Molybdenum 4 per quarter 10/27/21 0.279 mg/1 N/E N/E 0.001 0.005
10/28/21 < 0.001 mg/I
10/29/21 0.218 mg/I
Nickel i per quarter 10/26/21 < 0.001 mg/I N/E N/E 0.001 0.005
Selenium 1 per quarter 10/26/21 < 0.001 mg/I N/E N/E 0.001 0.002
Silver Iper quarter 10/26/21 < 0-001 mg/I M&R N/E 0.001 0.001
Zinc I per quarter 10/26/21 < 0.001 mg/I N/E N/E 0.001 0.005
pH 1 per quarter 10/26/21 7.8 Std.Units 6.0-10.5 N/E N/A Std.Units
Ammonia I per quarter 10/26/21 < 0.1 mg/I MAR N/E 0.1 0.1
Total Suspended Solids(TSS) I per quarter 10/26/21 14.3 mg/I MAR N/E 2.5 2.5
Extra Sampling Request
- 12/1/2021 0.238 mg/I
Molybdenum - 12/3/2021 0.24 mg/I N/E N/E 0.001 0.005
- 12/7/2021 0.239 mg/I
1/17/2022
Charah Solutions,Inc.

Charah.
Solutions
Monthly Leachate Monitoring Summary Report
Project:8rickhaven Structural Fill Site
Sample Point:LT-01
Certified or Approved By:
Date
July V Monthly Average Flow: 17,342 GPO
0.0173 MGD
2021 Monthly Peak Daily Flow: 38,400 GPD
0.0384 MGD
, Monthly Average Permitted Monthly
Dolly Maximum Constituent Monthly Average Constituent r Compliant Average Allowable
Constituent Concentration(nigh) Concentration (mg/1) Discharge?' Mass Based Limit
(Ibs./day)
Aluminum 0,200 0.200 a a Yes N/E
Antimony 0.010 0,0100 s s• Yes N/E
I Arsenic 0.011 0,010 s s' Yes 0.24
Barium 0.050 0.045 s a s• Yes 7.21
Beryllium 0.0010 0,0010 • a s Yes N/E
Bromide 1,200 1.163 s Yes ��
Cadmium 0.0020 0,0020 • *0. Yes
Chromium 0.010 0.0100 0 'a • Yes
0.031
Copper 0.020 0,0200 0 a Yes
Cyanide 0.010 0.010 a s 0 Yes
Iron 0,500 0.500 $ a Yes
' Lead 0,01000 0.01000 0 as Yes
0,0000100 0.0000030 0.0000004 Yes 0.002
Molybdenum 0.242 0.229 s0.134
a Yes
Nickel 0.010 0,010 ass Yes r
53
Selenium 0.020 0.020 0,0029 Yes
0.240
Silver 0.0040 0.0040 0,0006 Yes N/E
Strontium 7.880 7,433 1.0750 Yes N/E
Zinc 0,100 0.100 0.0145 Yes 0.103
Total Dissolved Solids(TDS) 1400 1363 197.06 Yes N/E
pH* 7.117.72 7.72"* Yes N/E
Ammonia 0.100 0.100 0.0145 Yes N/E
Total Suspended Solids(TSS) 21.30 6.86
0.9925 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'' Consituent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
r
5 Day BOD 2.00 2.00 0.29 Yes N/R
Total Phosphorous 0.050 0.050 0.01 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
Charah Solutions,Inc
1/8/2022

Charah'
Solutions
Monthly Leachate Monitoring Summary Report
Project: Brickhaven Structural Fill Site Dgltalty elpned by Norman Dwain
DN.C.US,
[e-mail],
Sample Point: LT-Ol 0,Charan Solution.,Inc:',
i i DU=EMS,CN=Norman Divers
Certified or Approved By: Norman Divers,7/20/2021 Dale:2021,07.2012 4442-04'00'
Date
lune V Monthly Average Flow: 14,720 GPD
2021 0,0147 MGD
Monthly Peak Daily Flow: 32,000 GPD
0.0320 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/I) Concentration (mg/1) actual flow' Discharge?' Mass Based Limit
(lbs./day) (lbs,/day)
Aluminum 0.385 0.219 0.0268 Yes N/E
Antimony 0.010 0.0100 0.0012 Yes N/E
Arsenic 0.010 0.010 0.0012 Yes 0.24
Barium 1.010 0.144 0.0177 Yes 7.21
Beryllium 0.0010 0.0010 0,0001 Yes N/E
Bromide 1.100 1.100 0,1350 Yes N/E
Cadmium 0.2060 0.0224 0.0027 Yes N/E
Chromium 0.043 0.0133 0.0016 Yes 0.031
Copper 0.020 0.0200 0.0025 Yes N/E
Cyanide 0.010 0.009 0.0010 Yes N/E
Iron 1.270 0.577 0.0708 Yes N/E
Lead 0.01000 0.01000 0.0012 Yes N/E
Low Level Mercury 0.0000025 0.0000014 0.0000002 Yes 0.002
Molybdenum 0.257 0.222 0.0273 Yes 0.134
Nickel 0.581 0.067 0.0082 Yes 0.053
Selenium 0.469 0.065 0.0080 Yes 0.240
Silver 0.0040 0.0040 0.0005 Yes N/E
Strontium 31.000 9.624 1.1815 Yes N/E
Zinc 1.860 0.276 0.0339 Yes 0.103
Total Dissolved Solids(TDS) 1570 1434 176.04 Yes N/E
pH* 7.317.78 7.78** N/A Yes N/E
Ammonia 0.100 0.100 0.0123 Yes N/E
Total Suspended Solids(TSS) 15.90 5.97 0.7329 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'' Consltuent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
5 Day 130D 2.00 2.00 0.25 Yes N/R
Total Phosphorous 0.050 0.050 0.01 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
7/20/2021 Charah Solutions,Inc.

Charah.
Solutions
Monthly Leachate Monitoring Summary Report
Project: Brickhaven Structural Fill Site
Sample Point: LT•01 'a
Certified or Approved By: Norman Divers,6/21/2021 t= 1 '1
Date
May V Monthly Average Flow: 6,606 GPD
0.0066 MGD
2021
Monthly Peak Daily Flow: 25,600 GPD
0.0256 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/I) Concentration (mg/I) actual flow' Discharge?' Mass Based Limit
(lbs./day) (lbs./day)
Aluminum 0.200 0.178 0.0098 Yes N/E
Antimony 0.010 0.0091 0.0005 Yes N/E
Arsenic 0.010 0.010 0.0005 Yes 0.24
Barium 0.053 0.050 0.0027 Yes 7.21
Beryllium 0.0010 0,0009 0.0000 Yes N/E
Bromide 1.200 1.100 0.0606 Yes N/E
Cadmium 0,0020 0.0018 0.0001 Yes N/E
Chromium 0.010 0.0089 0.0005 Yes 0.031
Copper 0.020 0.0178 0.0010 Yes N/E
Cyanide 0.008 0.008 0.0004 Yes N/E
Iron 0.500 0.451 0.0249 Yes N/E
Lead 0.01000 0.00888 0.0005 Yes N/E
Low Level Mercury 0.0000031 0.0000010 0.0000001 Yes 0.002
Molybdenum 0.243 0.205 0.0113 Yes 0.134
Nickel 0.010 0.009 0.0005 Yes 0.053
Selenium 0.020 0.018 0.0010 Yes 0.240
Sliver 0.0040 0.0036 0.0002 Yes N/E
Strontium 8.040 7.584 0.4178 Yes N/E
Zinc 0.100 0.089 0.0049 Yes 0.103
Total Dissolved Solids(TDS) 1430 1388 76.45 Yes N/E
pH* 7.4/7.6 7.6** N/A Yes N/E
Ammonia 0.100 0.100 0.0055 Yes N/E
Total Suspended Solids(TSS) 13.60 6.11 0.3368 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'' Consttuent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
S Day BOO 2.00 2.00 0.11 Yes N/R
Total Phosphorous 0.120 0.059 0.00 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
6/21/2021 Charah Solutions,Inc.

Charah.
Solutions
Monthly Leachate Monitoring Summary Report
Project: Brickhaven Structural Fill Site
Sample Point: LT-01 ryr++w Nam.,Dr,.
ON +96wieam..
Certified or Approved By: Norman Divers,5/18/2021 a " ,41,..00400.
Date
April V Monthly Average Flow: 6,827 GPD
2021 0.0068 MGD
Monthly Peak Daily Flow: 25,600 GPD
0.0256 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/i) Concentration (mg/l) actual flow' Discharge?' Mass Based Limit
(lbs./day) (lbs./day)
Aluminum 0.200 0.146 0.0083 Yes N/E
Antimony 0.010 0.0075 0.0004 Yes N/E
Arsenic 0.013 0.011 0.0006 Yes 0.24
Barium 0.058 0.056 0.0032 Yes 7.21
Beryllium 0.0010 0.0007 0.0000 Yes N/E
Bromide 1.200 1.113 0.0633 Yes N/E
Cadmium 0.0020 0.0014 0.0001 Yes N/E
Chromium 0.010 0.0071 0.0004 Yes 0.031
Copper 0.020 0.0148 0.0008 Yes N/E
Cyanide 0.008 0.008 0.0005 Yes N/E
iron 0.500 0.394 0.0224 Yes N/E
Lead 0.01000 0.00713 0.0004 Yes N/E
Low Level Mercury 0.0000102 0.0000027 0.0000002 Yes 0.002
Molybdenum 0.251 0.233 0.0133 Yes 0.134
Nickel 0.010 0.008 0.0004 Yes 0.053
Selenium 0.020 0.014 0.0008 Yes 0.240
Silver 0.0050 0.0036 0.0002 Yes N/E
Strontium 8.170 7.685 0.4375 Yes N/E
Zinc 0.100 0.071 0,0041 Yes 0.103
Total Dissolved Solids(TDS) 1470 1385 78.85 Yes N/E
pH* 7.3/7.7 7.7** N/A Yes N/E
Ammonia 0.120 0.103 0.0058 Yes N/E
Total Suspended Solids(TSS) 7.60 3,85 0.2192 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'- Consituent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
5 Day B0D 2.00 2.00 0.11 Yes N/R
Total Phosphorous 0.050 0.050 0.00 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
5/18/2021 Charah Solutions,Inc.

Charah'
Solutions
Monthly Leachate Monitoring Summary Report
Project: Brickhaven Structural Fill Site
co.,*8 40 w No,m,n Diva,.
ON.CWE,
Sample Point: LT-01 E.c__.$o 10CCT
0q.C .tumor..
Certified or Approved By: Norman Divers,4/20/2021 Os*2021.04.20 00,311A7-0Ottl
Date
March V Monthly Average Flow: 8,258 GPD
2021 0.0083 MGD
Monthly Peak Daily Flow: 25,600 GPD
0.0256 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/I) Concentration (mg/I) actual flow' Discharge' Mass Based Limit
(lbs./day) (lbs./day)
Aluminum 0.100 0.076 0.0052 Yes N/E
Antimony 0.005 0.0042 0.0003 Yes N/E
Arsenic 0.026 0.016 0.0011 Yes 0.24
Barium 0.097 0.063 0.0043 Yes 7.21
Beryllium 0.0005 0.0004 0.0000 Yes N/E
Bromide 1.100 0.953 0.0656 Yes N/E
Cadmium 0.0010 0.0008 0.0001 Yes N/E
Chromium 0.005 0.0038 0.0003 Yes 0.031
Copper 0.010 0.0076 0.0005 Yes N/E
Cyanide 0.008 0.008 0.0006 Yes N/E
Iron 0.824 0.442 _ 0.0304 Yes N/E
Lead 0.00500 0.00380 0.0003 Yes N/E
Low Level Mercury 0.0000052 0,0000017 0.0000001 Yes 0.002
Molybdenum 0.340 0.250 0.0172 Yes 0.134
Nickel 0.008 0.005 0.0003 Yes 0.053
Selenium 0.020 0.009 0.0006 Yes 0.240
Silver 0.0025 0.0019 0.0001 Yes N/E
Strontium 8.360 7.829 0.5392 Yes N/E
Zinc 0.050 0.038 0.0026 Yes 0.103
Total Dissolved Solids(TDS) 1510 1470 101.24 Yes N/E
pH* 7.418.28 8.28** N/A Yes N/E
Ammonia 0.100 0.100 0,0069 Yes N/E
Total Suspended Solids(TSS) 5,50 3.89 0.2679 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'' Consituent mass based limit calculated on average daily flow derived from total monthly flow data,
Non Permit Required Constituents
5 Day BOO 2.00 2.00 0.14 Yes N/R
Total Phosphorous 0.050 0.050 0.003 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
4/20/2021 Charah Solutions,Inc.

Charah.
Solutions
Monthly Leach ate Monitoring Summary Report
Project: Brickhaven Structural Fill Site
Dlgilally nIgned by Norman Divers
DN,C=U9,E=naNere(Qjcharah.com,
Sample Point: LT-01 On-Chereh Solutions.Inc.',
OU=EHS,CN=Norman Divers
Certified or Approved By: Norman Divers,3/19/2021 Dols,2021.03.1919:09:04.04'00'
Date
February V Monthly Average Flow: 8,457 GPD
2021 0.0085 MGD
Monthly Peak Daily Flow: 25,600 GPD
0,0256 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/I) Concentration (mg/I) actual flow' Discharge?' Mass Based Limit
(lbs./day) (lbs./day)
Aluminum 0.100 0.047 0.0033 Yes N/E
Antimony 0.005 0.0027 0.0002 Yes N/E
Arsenic 0.030 0.019 0.0014 Yes 0.24
Barium 0.066 0.056 0.0040 Yes 7.21
Beryllium 0.0020 0.0004 0.0000 Yes N/f
Bromide 1.500 1.111 0.0784 Yes N/f
Cadmium 0.0008 0.0003 0.0000 Yes N/E
Chromium 0.005 0.0016 0.0001 Yes 0.031
Copper 0.017 0.0035 0.0002 Yes N/E
Cyanide 0.008 0.008 0.0006 Yes N/E
Iron 1.020 0.600 0.0423 Yes N/E
Lead 0.01760 0.00269 0.0002 Yes N/E
Low Level Mercury 0.0000014 0.0000008 0.0000001 Yes 0.002
Molybdenum 0.359 0.227 0.0160 Yes 0.134
Nickel 0.006 0.005 0.0003 Yes 0.053
Selenium 0.005 0.002 0.0002 Yes 0.240
Silver 0.0100 0.0022 0.0002 Yes N/f
Strontium 8.150 7.814 0.5511 Yes N/E
Zinc 0.050 0.019 0.0013 Yes 0.103
Total Dissolved Solids(TDS) 1600 1520 107.21 Yes N/E
pH*- 7.218.31 8.31** N/A Yes N/E
Ammonia 0.100 0.100 0.0071 Yes N/E
Total Suspended Solids(TSS) 8.30 4.58 0.3227 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
' Consituent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
S Day B0D 3,20 2.15 0.15 Yes N/R
Total Phosphorous 0.050 0.050 0.00 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
3/19/2021 Charah Solutions,Inc.

Charah-
Solutions
Monthly Leachate Monitoring Summary Report
Project: Br!ckhaven Structural Fill Site a°,e„ye,°.„,,Noonan
a.en
Sample Point: LT-01 ".E•nc°.�
��nn®termwm.
1 BV•EHB,Clr•Notm°n 04.
Certified or Approved By: Norman Divers,2/19/2021 9,.a;a.0eod'°
Date
,January V Monthly Average Flow: 11,768 GPD
2021 0.0118 MGD
Monthly Peak Daily Flow: 19,200 GPD
0.0192 MGD
Monthly Average Permitted Monthly
Constituent Daily Maximum Constituent Monthly Average Constituent Mass Based Limit on Compliant Average Allowable
Concentration(mg/I) Concentration (mg/I) actual flow 1 Discharger 1 Mass Based Limit
(lbs./day) (lbs./day)
Aluminum 0.030 0.018 0.0017 Yes N/E
Antimony 0.003 0.0025 0.0002 Yes N/E
Arsenic 0.030 0.020 0.0020 Yes 0.24
Barium 0.063 0.059 0.0058 Yes 7.21
Beryllium 0.0010 0.0002 0.0000 Yes N/E
Bromide 1.700 1.055 0.1035 Yes N/E
Cadmium 0.0001 0.0001 0.0000 Yes N/E
Chromium 0.001 0.0005 0.0000 Yes 0.031
Copper 0.001 0.0005 0.0000 Yes N/E
Cyanide 0.008 0.008 0.0008 Yes N/E
Iron 0.785 0.506 0.0496 Yes N/E
Lead 0,00010 0.00010 0.0000 Yes N/E
Low Level Mercury 0.0000022 0.0000012 0.0000001. Yes 0.002
Molybdenum 0.263 0.232 0.0227 Yes 0.134
Nickel 0.005 0.004 0.0004 Yes 0.053
Selenium 0.002 0.002 0.0002 Yes 0.240
Silver 0.0004 0.0004 0.0000 Yes N/E
Strontium 8.370 7.944 0.7796 Yes N/E
Zinc 0.009 0.006 0,0006 Yes 0.103
Total Dissolved Solids(TDS) 1550 1500 147.21 Yes N/E
pH* 7.418.02 8.02** N/A Yes N/E
Ammonia 0.100 0.100 0.0098 Yes N/E
Total Suspended Solids(TSS) 6.60 4.54 0.4453 Yes N/E
*Minimum and Maximum pH values shown
**Monthly maximum pH value shown
'' Consituent mass based limit calculated on average daily flow derived from total monthly flow data.
Non Permit Required Constituents
5 Day BOD 13.60 4.66 0.46 Yes N/R
Total Phosphorous 0.090 0.061 0.01 Yes N/R
Sulfide 0.10 0.10 0.01 Yes N/R
2/19/2021 Charah Solutions,Inc.

PretrL ent Annual Report(PAR) Contrc______,ority, Industry,
Industrial Data Summary Form (IDSF) Town Name:City of Sanford Name:Arauco Panels USA,LLC
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000042
Enter BDL values as <values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd l CD CR CU
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 7 5 4 4 12 8
*Maximum (mg/1)_> 0.011 0.003 0.057 0.595 0.940 1.389
*or Maximum (lb/d)=>
*or Average(mg/1) => 0.005185 0.002376 0.042 0.266 0.285 0.24
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)_> 0% 0% 29% 0% 0% 0% 42% 17%
% TRC violations, (SNC is>=33 %)=> _ 0% 0% 0% 0% 0% 0% 25% 13%
HG NI PB ZN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 2 2 4 4 4 4 12 8
*Maximum (mg/1)=> 0.000375 0.000075 0.067 0.203 0.083 0.08 2.58 3.146
*or Maximum (lb/d) =>
*or Average(mg/1) => 0.000375 0.000071 0.059 0.08625 0.0625 0.046 1.01 0.90
*or Average Loading(lb/d)_>
% violations, (chronic SNC is>=66%)=> 0% 0% 0% 0% 0% 0% 42% 13%
% TRC violations, (SNC is>=33 %)_> 0% 0% 0% 0% 0% 0% 25% 13%
AG AS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 4 4 1 1
*Maximum (mg/1) _> 0.007 0.002 0.00978 0.00502
*or Maximum (lb/d)_>
*or Average(mg/1)=> 0.00475 0.002 0.00978 0.00502
*or Average Loading(lb/d)=>
% violations,(chronic SNC is>=66%)=> 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)=> - 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods. SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant

tary Form(IDSF) Control Authority, Industry,
Report(PAR) Town Name:City of Sanford Name:Arauco Panels USA,LLC
ch industry/pipe WWTP Name:Big Buffalo Creek IUP#: 000042
<values NPDES#:NC 0024147 Pipe#: 02
1st 6 months,dates: 1/1/2021 to 6/30/2021
2nd 6 months,dates: 7/1/2021 to 12/31/2021
Flow,mgd CBOD TSS
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
184 184 6 4 7 4
5730 599 48700 1280
=>
/1) => 2352 530.5 9691.4286 1180
lb/d)=>
;NC is>=66%)=> 0% 0% 0% 0%
Cis>=33 %)_> 0% 0% 0% 0%
O&G NH3 TN
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
4 4 1 1 1 1
471.000 82.7 14 20 18 18
=>
/1)=> 133.383 52.575 14 20 18 18
lb/d)=>
3NC is>=66%)_> 0% 0% 0% 0% 0% 0%
Cis>=33 %)_> 0% 0% 0% 0% 0% 0%
TP Mo Se
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months Ind 6 months
1 1 1 1 1 1
1.7000 4.4 0.0025 0.00125 0.00182 0.00091
=>
VD=> 1.7000 4.4 0.0025 0.00125 0.00182 0.00091
lb/d)_>
3NC is>=66%)_> 0% 0% 0% 0% 0% 0%
C is>=33 %) _> 0% 0% 0% 0% 0% 0%
BDL=>Below Detection Limit mg/1=>milligrams per liter
at least one of these IUP=> Industrial User Permit lb/d=>pounds per day

Data Summary Form(IDSF) Control Authority, Industry,
Pretreatment Annual Report(PAR) Town Name:City of Sanford Name:Arauco Panels USA,LLC
Use seperate forms each industry/pipe WWTP Name:Big Buffalo Creek IUP#:000042
Enter BDL values as<values NPDES#:NC 0024147 Pipe#:01
1st 6 months,dates:1/1/2021 to 6/30/2021
2nd 6 months,dates:7/1/2021 to 12/31/2021
Flow,mgd CN TTO
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 184 184 5 5
*Maximum (mg/1) _> 0.026 0.0076
*or Maximum (lb/d)=>
*or Average(mg/1) => 0.0159 0.00349
*or Average Loading(lb/d)_>
% violations,(chronic SNC is>=66%)=> 0% 0% certified certified
% TRC violations, (SNC is>=33 %) _> 0% 0% certified certified
Toluene ( Xylene Chloride
1st 6 months 2nd 6 months 1st 6 months 2nd 6 months 1st 6 months 2nd 6 months
Total#of samples=> 1 1 1 1 1 1
*Maximum (mg/1) _> 0.0014 0.014 0.0045 0.045 17 190
*or Maximum (lb/d)_>
*or Average(mg/I)=> 0.0014 0.014 0.0045 0.045 17.0 190.0
*or Average Loading(lb/d) =>
% violations,(chronic SNC is>=66%) _> 0% 0% 0% 0% 0% 0%
% TRC violations, (SNC is>=33 %)=> 0% 0% 0% 0% 0% 0%
Total#of samples=>
*Maximum (mg/1) =>
*or Maximum (lb/d) _>
*or Average(mg/1) =>
*or Average Loading(lb/d)=>
% violations, (chronic SNC is>=66%)=>
% TRC violations,(SNC is>=33 %)=>
BDL=>Below Detection Limit mg/1=>milligrams per liter
* POTW must enter at least one of these IUP=>Industrial User Permit lb/d=>pounds per day
All averages are based on six month periods SNC=>Significant Non-Compliance mgd=>million gallons per day
Less than(<)is calculated as half of detection. TRC=>Technical Review Criteria WWTP=>wastewater treatment plant