Acuity Specialty Products Group Inc.

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II10. The R.M. Clayton Reclamation Center POTW is located on Plant Road,Atlanta, Georgia, and is operated by the City of Atlanta Department of WatershedManagement ("City of Atlanta"). The City of Atlanta is authorized to operate theR.M. Clayton Reclamation Center POTW pursuant to a NPDES permit issued by theGeorgia Environmental Protection Division, which authorizes the discharge of treatedwastewater from the R.M. Clayton Reclamation Center POTW to the ChattahoocheeRiver.11. Under its NPDES permit, the City of Atlanta must require all industrialusers that discharge to the R.M. Clayton Reclamation Center POTW to comply withthe CWA, the General Pretreatment Regulations, and the City of Atlanta's State-Approved Pretreatment Program.The City of Atlanta's Pretreatment Programincorporates, inter alia, a Sewer Use Ordinance, and allows the City of Atlanta to issueIndustrial Wastewater Discharge Permits to Industrial Users.12. At all times relevant to the Information, phosphorus and pH fell withinthe definition of a pollutant pursuant to the Clean Water Act. 33 U.S.C. § 1362(6).THE SEABOARD FACILITY'SINDUSTRIAL WASTEWATER DISCHARGE PERMIT13. Wastewater resulting from the manufacturing processes at the Seaboardfacility contains several pollutants, including phosphorus, a common waste constituent4
for a chemical blending facility that manufactures detergent and cleaning products.14. Wastewater resulting from the manufacturing processes at the ASPfacility also included water with a highly acidic or basic composition. The acidic orbasic composition is referred to in the Permit as "pH." The scale for measuring pHranges from 0 to 14. Wastewater with a low pH is highly acidic, and wastewatercontaining high pH is considered to be basic. A pH of 7 is considered to be neutral.15. At all times relevant to the Information, the Seaboard facility was subjectto Industrial Wastewater Discharge Permit No. C128 (the "Permit"), which had beenissued to Zep Manufacturing, <strong>Inc</strong>. by the City of Atlanta. At all times relevant to theInformation, Permit No. C128 incorporated the City of Atlanta's Sewer UseOrdinance ("Sewer Use Ordinance") by reference.16. Permit No. C 128 allowed the Seaboard facility to discharge industrialwastewater effluent to the R.M. Clayton Reclamation Center POTW, from thefacility's Wastewater Pre-Treatment Plant, in accordance with effluent limitations setby the Permit.17. The Permit prohibited the discharge of wastewater containing aconcentration of phosphorous greater than 10 mg/L if the facility discharged 25,000gallons or more of wastewater per day. The Permit provided for an alternative massbasedphosphorus limit of 2.0 pounds of phosphorus per day if the facility discharged5
Page 2 and 3: GUILTY PLEA and PLEA AGREEMENTr!:ed
Page 4 and 5: 1'1.up and the facts of this case,
Page 6 and 7: the prov1s10ns set out mthe Complia
Page 8 and 9: this Plea Agreement, the Government
Page 10 and 11: CERTIFICATION OF ATTORNEY AND DEFEN
Page 12 and 13: ATTACHMENT A
Page 14 and 15: company, ASP. ASP is a Delaware cor
Page 18 and 19: IIless than 25,000 gallons of waste
Page 20 and 21: discharged to the R.M. Clayton Recl
Page 22 and 23: IIDateOctober 30, 200 1November 6,
Page 24 and 25: ATTACHMENT B
Page 26 and 27: purchased from other companies to m
Page 28 and 29: eceiving a representative sample of
Page 30 and 31: IHIconstruction on improvements to
Page 32 and 33: X. Acuity represents to EPA that AS
Page 39 and 40: allegations of Acuity's corporate i
Page 41 and 42: (v). Schedule.After submission of t
Page 43 and 44: (b) Vice President of Compliance/Du
Page 45 and 46: ....12. Training.(a) Environmental
Page 47 and 48: 5. that the training requirements d
Page 49 and 50: I IG6. Freedom of InformationRespon
Page 51 and 52: "during the term of this Agreement
Page 53 and 54: 1111submissions to SOD through thei
Page 55 and 56: ATTACHMENT C
Page 57 and 58: EXHIBIT ARESOLUTIONSOFTHE BOARD OF
Page 59 and 60: 2) WAIVER OF RIGHTS(a)The Governmen
Page 61 and 62: 4) LIMITATION OF CHARGESThe United
Page 63 and 64: 7) WAIVER OF APPEALIf the Court acc
Page 65 and 66: In Open Court thisday of June, 2007
Page 67:
Ii iINFORMATION BELOW MUST BE TYPED
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Acuity Specialty Products Group Inc.

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