NCS000041_COMPLIANCE_20190603

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
Uc�SOOD0 4l
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
>c COMPLIANCE
❑ OTHER
DOC DATE
❑ 2-o fck O U O 3
YYYYM MDD

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V C� p 3 O b C0 3
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑
YYYYMMDD

,c,\�Fo STg14
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
° Q ATLANTA FEDERAL CENTER
61 FORSYTH STREET
�� Qc �pOj��°2 ATLANTA, GEORGIA 30303-8960
MAY 2 9 2019
CERTIFIED MAIL .7017 1450 0000 7973 2809
RETURNED RECEIPT REQUESTED
Mr. Daniel C. Grieneisen
Environmental Safety and Health Affairs
Clariant Corporation
P.O. Box 866
Mount Holly, North Carolina 28120
Re: Compliance Evaluation Inspections
Clariant Corporation — Mount Holly West Facility
NPDES Permit No. NCS000041
Dear Mr. Grieneisen:
JUN 0 3 2019
DENR-LAND QUALITY
STORMWATER PcRitiliT i'ING
On March 19, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the Clariant Corporation — Mount Holly West Facility located at 625 East Catawba Avenue in Mount
Holly, NC. The purpose of the CEI was to evaluate Clariant Corporation — Mount Holly West Facility's
compliance with the requirements of Sections 301 and 402(p) of the Clean Water Act (CWA), 33 U.S.C.
§§ 1311 and 1342(p); the regulations promulgated thereunder at 40 C.F.R. § 122.26; and, the State of
North Carolina's NPDES Stormwater Permit NCS000041.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren.garcia ancclenr.gov.
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Kenneth Kwan, P.E., at the above address, by email at
[e-mail], or at [phone].
Sincerely,
t
Daniel 7.O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Enclosures
cc: Ms.,Annette Lucas
NCDEQ
Internet Address (URL) • http./Avww.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (NI161mum 30% Postconsumer)

U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
F*o Water Compliance Inspection Report
NPDES ID: NCS000041 Effective Date: 11/01/2009 Ex iration Date: 10/31/14 admin continued
Facility Name: Clariant, Corporation — Mount Holly SIC Code. 2821
Address: 625'East Catawba Ave, Mount Holly, NC 28120
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Daniel C. Grieneisen Fernando Henrique Colombo
Environmental Safety and Health Affairs VP of Operations North America
P.O. Box 866 625 East Catawba Ave
Mount Holly, NC 28120 Mount Holly, NC 28120
704-822-2137 1 704-822-2101
INSPECTION ENTRY DATES/TINIES
Entry Date/Time: 03/19/19, 2:30 pm Exit Date/Time: 03/19/19, 6:00 pm
EPA Inspectors: Ahmad Dromgoole, Kenneth Kwan
NCDENR Inspectors: Tarnera Eplin, Tom Poe, Thad Valentine, Lauren Garcia, Alaina Morman
X Permit Self -Compliance Program I Pretreatment
X Records Compliance Schedule
Pollution Prevention
X FacilijX Site Review Laborat9a
X
Storm Water
X Effluent / Receiving Waters XOperations & Maintenance
Combined Sewer Overflow
Flow Measurement Slud a Handling Disjg2sal Sani1gy Sewer Overflow
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
19, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon arrival at the facility, EPA inspectors presented credentials and facilitated an opening conference. The CEI included both a
records review portion and a facility walk through. Upon completion, an exit conference was held with facility personnel in which
they were informed of EPA's preliminary findings and told that an actual inspection report will be sent to the facility by EPA.
Inspe o Si a e Office/Phone Number Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
og-a3111
Ahmad E romgoole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
�-/
USEPA Region 4/WPD-CWEB-SIZESz�
404-562-9434
Daniel J. O'Lone, ief
Stormwater and Residuals Enforcement Section
Page 1 of 6

GPS
Coordinates
Latitude 35017'45.45"N Longitude
81 ° 0'28.80"W
Receiving
Site
Weather
Water(s) or
Catawba River
Acreage
43
Condition' :
CIear skies, Low 50s
MS4
Date of
-
Does the site
Permit
-Discharge to 303(d) :.. '
discharge pollutants
Coverage
04/02/2014
SIC
2821
�. or TMDL
Yes
--contributing
to the°listed
Yes
Renewal
�Code (s)
waters
receiving stream
Application
impairment.
Form
SPPP TOPICS (Part.11) YES NO
NIE
SPPP on -site (obtain a copy of the plan) & signed Section A
X
A complete SPPP dated Oct. 2107 was provided by the facility via e-mail. However, this SPPP was not signed or
dated with the proper management approval.
Site Description Section A(l)(b)
X
(storage practices, loading/unloading activities, outdoor processes, dust generating processes, and waste
processes)
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
X
(include inventory of materials handled at the site, information pertaining to any pollutant sources, information
pertaining to the storage and application of pest control chemicals)
Site Maps (general location map and site specific map) Sections A(1)(a & c)
X
(include identification of receiving waters and/or MS4s, identification of impaired waters, latliong of discharge
points, drainage areas to each discharge point, site boundaries, site topography, drainage features and flow
directions, impervious areas, industrial activities, and site best management practices (BMPs)
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
X
The SPPP stated that the facility has not experienced a reportable spill incident in the past 3 years. However, it is
uncleared as to the timeframe since the SPPP was dated 10/17 and have not been updated recently. The permit
requires a list of current spills or leaks for the previous 3 years.
SPPP Certification Section A(1)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
An annual non-stormwater certification for 2018 was sent in via e-mail. However, this certification did not state
the day that the test was performed, the outfall that was evaluated, the type of test conducted, the actual result of
these tests, and the name of the person conducting the test. Also, the Annual Non-stormwater Discharge
Certification Form in Appendix C-6 of the SPPP was not in the 2018 certification submitted in the e-mail.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis of control options like eliminating exposure or controlling runoff)
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
(Should include a table or summary clearly inventorying the sources and procedure for making visual observations
of accumulated liquid and how to dispose of it).
Appendix B of the SPPP contains a table of all storage tanks volume and stored materials. However, their
associated secondary containment capacities were not listed.
Page 2 of 6

gSPPP TQ4PICS(PartIIj� " Y t sjX x 77
YES:I NO
,N/E
t.-
Stormwater BMP Summary Section A(2)(c)
X
(Include all structural and non-structural BMPs at the site)
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
(Stormwater specific plan identifying the various responsible officials and their signatures)
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
(address maintenance and cleaning schedules of control systems, outfWls, adjacent waters, handling of industrial
activities, drainage structures, and BMPs- Include a Iist of the areas incorporated in the program)
The SPPP did not address preventative maintenance and,good housekeeping practices on storm drains, retention
basins, and catch basin.
Employee Training Section A(5)
X
(minimal annual training of spill response and cleanup/prevention and potential areas of industrial stormwater)
Identify the Responsible Party Section (A)(6)
X
SPPP Modified or Update to Current Conditions Section (A)(7)
X
(review and update at least annually, recertify, and include the review of most recent benchmarks samples)
The latest annual review and update of the SPPP was conducted in October 2017. The SPPP Plan Amendments
and Review Log in Table 1-1 of the SPPP show no records of annual review in 2018.
Schedule and Procedures for Routine Inspections (minimum of semiannually) . Section A(8)
X
The SPPP provided by the facility states that the routine system inspections will be performed twice per year.
These inspections required the completion of a checklist which is maintained in a file. In addition to the
semiannual inspections, facility operators are required to perform checks every shift of the stormwater outfalls
and the stormwater containment areas.
Clariant Corporation operates a specialty chemical manufacturing facility in Mount Holly, NC. There are currently approximately 164
employees at the roughly 43-acre Mount Holly facility. The facility processes operate 24 hours a day/7 day a week. The facility
manufactures a variety of personal -care products, as well as chemicals for biocides, detergents, surfactants, deicers, and metalworking,
crop -protection, and textiles. There are currently four batch processing plants at the Mount Holly facility: three plants are active while
the forth is idle. Except for a few raw materials and a product that are shipped by rail, most of the materials used and/or produced at the
site are transported by truck. The chemical processes at this plant are closed batch processes which are housed either indoors or within
covered area.
The areas around the Mount Holly plant were primarily impervious/paved. Runoff from the site would typically flow towards one of the
drainage systems at the site. There facility currently holds two NPDES permits: NCS000041 (industrial stormwater) and NCS000047
(industrial wastewater). Depending on the operations in a drainage area, the drain inlets were tied into either the wastewater treatment
plant or the stormwater treatment system. The drain inlets were color coordinated allowing for a determination of where runoff in the
area would be direct.
For this inspection, the focus was on the facility's NPDES stormwater permit (NCS000041). The facility operated 6 stormwater outfalls
associated with this permit. These outfalls are all tied to either the two retention basins or one of the four small basins_ The stormwater
discharges from these retention basins are controlled by manual valves that are normally closed. Before releasing any stormwater, facility
personnel conduct a visual observation of the characteristic of stormwater prior to batch release to receiving water.
Page 3 of 6

ord Review
7RRepresentative
YES:
NO
N/E
on-site
X
ords of the Implementation of the SPPP Part 11 Section A(9), Part III Section 1)(6)
X
Records from 2017 and 2018 of implementation of the SPPP were spot checked during the inspection and
appeared to have been maintained in accordance with the permit,
Records of Maintenance and Housekeeping Programs Part 11, Section A(9)
X
The facility maintains records of its maintenance and housekeeping activities in an electronic database. Samples
of these records were made available during the inspection.
Records of Routine Inspections Part 11, Section A(9)
X
The inspection records for 2018 were provided for review during the inspection. During the 11/3/18 semi-annual
inspection, three issues noted. No records were available during the inspection on how and when these issues
were addressed. This information was later provided to EPA via email. However, the timeframe on when these
issues were addressed are still missing.
Records of Employee Training Part 11, Section A(9)
X
Records of employee training were provided and reviewed for 2018.
Records for the Approval of Representative Outfalls Part III Section D(5)
No request was made for the approval of a representative outfall.
X
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(1)
X
The records of benchmark monitoring were reviewed for 2017-2018. According to facility personnel, a contract
lab is used for the analysis of all benchmark parameters except for pH which is run on site. From the review of
the available records, the appropriate lab methods, holding times, and preservatives were used for the benchmark
monitoring. A more expansive review of the benchmark history was later performed on data provided. by the
state. This review showed that for 2017 and 2018, Clariant only performed annual benchmark monitoring instead
of semiannual as required by the permit.
Records of Qualitative Monitoring Part 11 Section C, Part III Section D
X
(minimum of 60 days between periodic sampling)
Qualitative monitoring is performed at the various outfall prior to the releasing of the stormwater at the outfalls.
These records from 2018 were available and reviewed.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
X
From the review of the 2018 benchmark monitoring records, there were benchmark exceedances for BOD, COD
and TSS at various time and at different outfalls. A Tier One response was submitted to EPA via email for
review. However, these responses need to be filled out utilized the form in Appendix C-7 of the SPPP.
Records of Bypasses Part HI Sections E(7)
According the facility, there had been no reportable bypasses since 2017.
X
Records of 24 hr Reporting Part Ill Sections E(8 &9)
According the facility, there had been no events at the facility since 2017 requiring 24 hr reporting.
X
Nate :location; quantitative, description, design issue,. O&M=deficiencies th::the.:nature acid -
Pollutant Sources _ _ _ E cludia' g,�
eztent), and pollutants off site
A few raw materials and products at the facility are shipped by rail. The railcar unloading area near plant 3 can
1oadiwx nlaadiu be seen in photo DSCN 1871. In this unloading area, the observed storm drains were red meaning that runoff
from this area would be directed to the wastewater treatment system. The loading/unloading area near
Area warehouse # 1 has sediment deposit along the storm drain area.
Page 4 of 6

l ��. ,ajar"- A'
_ a'�'
6-'hi-,S.' ;4 ;y„_.. '.k9 tl,9 '.: u r..a�. F -.µ Y..R^ '1.3
7, a ! s #Ta.
Note�locat�oniiantEtattvedescr�ptton,destgn�ssufie,� O&Mde#iciencies;(�neludmg the
;.PolliitantSciareesc?
'¢i� t ' ) 2
nature and
t .aa'a r �v :�h c ` a ._ ..+rY r.�, r T.h� ^r
ez#ent), and poil©tapts off site
, t ±�
a..+.,2^A fM �� f: �'ee •k,x �� �i�� X`'��,n. 54
•,Raw'Material� j4 � �,' ."r
sn•, F
'Storage )Facilities;,",',,:
No issue noted during the inspection.
'•OuWoor Process���
.
jy
Opera'hons x• .
No issue noted during the inspection.
;,.•:}
Product- torage E
" Areas, ,` *°
No issue noted during the inspection'
g p
Two storm drain systems were in place at the Clariant facility: the green painted storm drains were associated
°"' ' r
with stormwater manage while red storm drains were tied into the facility's wastewater treatment system. The
' Storm drains.,,, ; ., ,'' ;
impervious areas around the facility drained to various storm drain inlets which, depending on the area, would
direct water to the appropriate treatment area. An example of these catchments can be seen in photo
'.
DSCN 1870.
,Housekeeping-, ''
No issue noted during the inspection.
,
Liquid: Storage f #
•
yTanks:
No issue noted during the inspection.
s' a
= .' ` • `
Most of the stormwater outfalls at the Clariant site have some form of holding/retention capacity prior to
,
.Best=Management.' ' °°
discharging. Two outfalls were associated with larger retention ponds. This included the retention ponds for
`_Practices (B_MPs),.-
Outfall 1 (see photo DSCN 1 872) and Outfall 6 (see photo DSCN 1878). Out outfalls have smaller retention
areas We the retention area for Outfall 3 (seen in photo DSCN1875).
Sgills/deaks Handing,
No issue noted during the inspection.
Disposal/Waste"e _
.:
'• '
:No issue noted during the inspection.
Handling Areas'
°Vehicle,Maintena'nce .
Areas~
No outdoor vehicle maintenance actives were observed.
Outfall; Stormwater
„t
Discharge;&'
YES.,.'.'
NO
:Receivin Water
A
Describe: According the facility's SPPP, 6 stormwater outfalls are operated at this site. The
Number & location'',
large retention pond near the northeast comer of the site discharges to Outfall 1 (seen in photo
of stgrmwatei `.
DSCN 1873). South of Outfall 1 along the east side of the site there are Outfalls 3 (seen in photo
discharges}/outfall(s)
X
DSCN 1874), Outfall 4 (seen in photo DSCN 1876), Outfall 5 (seen in photo DSCN 1877), and
cgasistent;with,the
SPPP •r
Outfall 6 (seen in photo DSCN1879). Outfall 7, seen in photos DSCN1868-DSCN1869),
received runoff from the area along the west side of the site near the truck scale.
Page 5 of 6

Outfal'S#ormwater
Discharges*...
Receivin ;;Water
Evidence of off -site
accumulatiowof
X
Describe: During the inspection, no evidence of pollutant accumulation was observed in the
pollutants observed
receiving water.
"in receiving.water
-Other potential.
discharges off -site
Describe: During the inspection, no stormwater outfalls were observed aside from those
(through outfalls not
X
identified in the facility's SPPP.
included is the
SPPP
The facility has a permit and treatment system for both stormwater and wastewater.
Non-stDescribe:
X
During the inspection, no discharges of non-stormwater were observed at the stormwater
observed
discharge observed
discharge
outfalls.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area as
necessary:
An exit conference was held with Shawn Moye, Clay Dunn, Daniel Grieneisen, and Fernando Colombo were the following
observations were relayed:
1. The loading/unloading area near warehouse # 1 has sediment deposit along the storm drain area.
2. A punch list of records to be submitted to EPA was provided to facility personnel
a. SPPP
b. Non-Stormwater Discharge Certification Form
c. Documentation of the three issues noted during the 11/3/18 semi-annual inspection was addressed
d. Records of Tier One response for benchmark exceedances
Page 6 of 6

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DSCN1869.,lpG
Attributes
File Name
DSCN1S69 JRG r'
Description
: Photograph;of Outfall 7 This'outfall &ains'the area,.ofthe site=near the-truck,scaie:
Latitude: ti
N 35* 1.7' 42 30" h
.,
SW-NCS000041-031919. Page 3 of 13

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I N
A Q-�
DO. . . . . . . . . . . .
Iv— WN
w.;
e -t-
54
4ft.
'-41PL
. . . . . . . . . . . . .

DSCN 1872JPG I .
Attributes
Ale: Nim, a
:D5CN1872:JPG
Description`*
=
. Photograph'of the °retention oasin'-.Which discharges'to Outfall 1 .There were two -outlet 'structures.:
,near, the;corner.of the pond. One outletatructure led to the stream The`other led to the
wastewater treatment system. The co iditions of the.accumulated water. would determine.
whether-it'was'sent-to-the,stream'.or_to the treatment plant:
Latitude
-N 35' 1T 44.45" _
Longitude
W-81* 00' 21.39"
SW-NCS000041-031919 Page 6 of 13

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DSCN1979JPG
Attributes
File Name
'OSCN187UPG
Description,
. Photpgraph�of Outf611•6 which was not -discharge -during the inspection:
Latitode.` '
4`350 17' 34 97"; °; 3
-
Longitude
W 810 00' 27.29"
SW-NCS000041-031919 Page 13 of 23