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HomeMy WebLinkAbout2016June2 FROsitevisitEnvironmental Date: June 2, 2016 To. ® NPDES Unit ❑ Non -Discharge Unit Attn: Teresa Rodriquez From: Mark Brantley Fayetteville Regional Office State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report Application No.: NC0003573 Facility name: Chemours Fayetteville Works Works Note: This form has been adapted from the non-dischar e facili staff report to document'the review of both non discharge and NPDES permit applications and/or renewals Please complete all sections as they are applicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ®Yes or ❑ No Date of site visit: May 20, 2016 Site visit conducted by: Mark Brantley Inspection report attached? ® Yes or ❑ No RECEIVE®INCC�E�IDWR JUN 0 7 2016 Water Quality Perrnitting Section Person contacted: Jamie Lewis and their contact information: �) 678 -1219 e. Driving directions: This facility is located at the Bladen -Cumberland County line between Highway 87 and the Cape Fear River. 2. Discharge Point(s): Latitude: Longitude: Latitude: Longitude: 3. Receiving stream or affected surface waters: Classification: Class C River Basin and Subbasin No.: Cape Fear River Basin 03-06-17 Describe receiving stream features and pertinent downstream uses: The effluent pipe discharges into the Cape Fear River just upstream of Lock and Dam #3 That section of River is used for boating fishing and wildlife propagation The Bladen Bluff Water Treatment Plant's intake is about 10 miles downstream. II. PROPOSED FACILITIES: NEW APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit) Proposed flow: Current permitted flow: 2. Are the new treatment facilities adequate for the type of waste and disposal system? ElYes or ElNo If no, explain: 3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? El Yes ❑ No ❑ N/A If no, please explain: FORM: WQROSSR 04-14 Page 1 of 5 4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A If no, please explain: 5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A If no, please explain: 6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A If no, please explain: 7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No If yes, attach a map showing conflict areas. 8. Is the proposed or existing groundwater monitoring program adequate? ❑Yes ❑ No ❑ N/A If no, explain and recommend any changes to the groundwater monitoring program: 9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites with restrictions (Certification B) Describe the residuals handling and utilization scheme: 10. Possible toxic impacts to surface waters: 11. Pretreatment Program (POTWs only): III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ®Yes ❑ No ❑ N/A ORC: Jamie Lewis Cert ificate #: 994529 Backup ORC: Russel Rotan Certificate #21886 Backup ORC: Ray Beard Certificate # 28791 Backup ORC: Ken Locklear Certificate # 990070 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste an d disposal system? ®Yes or ❑ No If no, please explain: Description of existing facilities: Please see description of facilities that is attached to the permit application Proposed flow: Current permitted flow: 2.0 mad Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc.) 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? ®Yes or ❑ No If no, please explain: Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? ® Yes or ❑ No If yes, please explain: • An A to C (ATC # 003573A02) has been completed for the relocation of Outfall 002 to the Cape Fear River at a location upstream of Lock and Dam No 3 • Please see applicant's application for a complete review of their wastewater treatment process 4. Is the residuals management plan adequate? ® Yes or ❑ No If no, please explain: 5. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? E] Yes or ❑ No If no, please explain: FORM: WQROSSR 04-14 Page 2 of 5 6. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A If no, explain and recommend any changes to the groundwater monitoring program: 7. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No If yes, attach a map showing conflict areas. 8. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No If no, please explain: 9. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no, please explain: 10. Are the monitoring well coordinates correct in BIMS? ❑Yes ❑ No ®N/A If no, please complete the following (expand table if necessarv): Monitoring Well Latitude Longitude O / // O 1 // O / It O 1 11 O / it O / If O / 11 O I If O l 11 O / it 11. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ®Yes or ❑ No Please summarize any findings resulting from this review: • In October 2014 this facility had 2 daily BOD violations and a monthly Bod violations that resulted in a NOD. Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. 12. Are there any permit changes needed in order to address ongoing BIMS violations? F1 es or ®No If yes, please explain: 13. Check all that apply: ®No compliance issues ❑ Notice(s) of violation El Current enforcement action(s) ❑ Currently under SOC E] Currently under JOC ❑ C Please explain and attach any documents that may help clarify answer/comm urrently under moratoriuments (i.e., NOV, NOD, etc.) If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been working with the Permittee? Is a solution underway or in place? Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A If no, please explain: 14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ❑ No ®N/A If yes, please explain: 15. Possible toxic impacts to surface waters: 16. Pretreatment Program (POTWs only): FORM: WQROSSR 04-14 Page 3 of 5 IV. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No If yes, please explain: 2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an additional information request: 3 �7 D Item Reason List specific permit conditions recommended to be removed from the permit when issued: Condition Reason List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason Recommendation: El Hold, pending receipt and review of additional information by regional office ❑ Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ® Issue ❑ Deny (Please state reasons: ) Signature of report preparer: Signature of regional supervisor: Date: G • �- / (, FORM: WQROSSR 04-14 Page 4 of 5 V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS An A to C (ATC IT 003573A02) has been completed for the relocation of Outfall 002 to the Cape Fear River at a location upstream of Lock and Dam No 3 • Please see applicant's application for a complete review of their wastewater treatment process • Also in the application packa a is a good description of how this facility is no longer owned by DuPont but is more like an industrial park owned by The Chemours Company with several tenants The manufacturing process is the same however there are new owners of the processes FORM: WQROSSR 04-14 Page 5 of 5 V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS_ • An A to C (ATC # 003573A021 has been completed for the relocation of Outfall 002 to the Cape Fear River at a location upstream of Lock and Dam No. 3 • Please see applicant's application for a complete review of their wastewater treatment process • Also in the application packa a is a good description of how this facy is no longer owned by DuPont but is more like an industrial park owned by The Chemours Company with several tenants The manufacturing process is the same, however there are new owners of the processes FORM: WQROSSR 04-14 Page 5 of 5 Water Resources ENVIRONMENTAL DUALITY May 27, 2016 Michael E Johnson The Chemours Company Fc LLC 22828 NC Highway 87 West Fayetteville, NC 28306 SUBJECT: 5/20/2016 Compliance Evaluation Inspection The Chemours Company Fc LLC Chemotars Company -Fayetteville Works Permit No: NC0003573 Bladen County Dear Mr. Johnson: PAT MCCRORY Governor DONALD R. VAN DER VAART Secretary S. JAY ZIMMERMAN Director Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on 5/20/2016. The Compliance Evaluation Inspection was conducted by Mark Brantley, Environmental Program Consultant, of the Fayetteville Regional Office. The facility was found to be in Compliance with permit NC0003573. The cooperation of Mr. Jamie Lewis, facility ORC, was greatly appreciated. As a reminder, preservation of the Waters of the State can only be achieved through consistent NPDES Permit compliance. Comments • Facility was clean and neat in appearance at the time of the inspection. • Log books and maintenance records are up to date. Maintenance records are kept on a work order system. • Laboratory records were compared to the November 2015 eDMR and notranscription-errors were noted. • Facility has submitted a NPDES permit renewal application since the current permit expires on October 31, 2016. Please continue to use the current permit until a new NPDES permit is issued. Fayetteville Regional Office 225 Green Street, Suite 714, Fayetteville, North Carolina 28301-5095 Main Phone: 910-433-3300 1 Internet: http:/hruww.ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer— Made in part by Recycled Paper Or. Johnson Page 2 May 27, 2016 Please referto the enclosed inspection report for additional observations and comments. If you oryour staff have any questions, please call me at 910-433-3327. Sincerely, /n W A640 Mark Brantley Environmental Program Consultant Division of Water Resources Water Quality Regional Operations Section cc: Jamie Ray Lewis, ORC EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# United States Environmental Protection Agency Form Approved, EPA Washington, D.C. 20460 OMB No, 2040-0057 Water Compliance inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 u 2 15 1 3 1 NC0003573 111 12 16/05/20 17 18 11 19 1 G I 201 21LLI I I I I I I I I I I I I I I I I. 1 1 1 1. I I I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA — -Reserved — 67 70 LJ h I 71 I n, itI 72 I N JData I_J 73 I I 174 180 751 III 1 11 Section B: Facility Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 08:30AM 16/05!20 12/03/01 Chemours Company-Fayetteville Works 22828 NC Highway 87 West Exit Time/Date Permit Expiration Date Fayetteville NC 283067332 11:45AM 16/05/20 16/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Jamie Ray Lewis/ORC/910-678-1219/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Michael E Johnson,22828 NC Highway 87 West Fayetteville NC 283067332//910-678-1155/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) ® Permit ® Flow Measurement ® Operations & Maintenance Records/Reports ® Self-Monitoring Program Sludge Handling Disposal Facility Site Review ■ Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Mark Brantley FRO WQ//910-433-3300 Ext.727/ ,kJ 4,4 S w .� F7 el% Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date li a S FKnson 0 WQ//910-433-3300 Ext.72E EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type 1 3 NC0003573 I11 12 16/05/20 j 17 18 i c I Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Comments Facility was clean and neat in appearance at the time of the inspection. Log books and maintenance records are up to date. Maintenance records are kept on a work order system. Laboratory records were compared to the November 2015 eDMR and no transcription errors were noted. Facility has submitted a NPDES permit renewal application since the current permit expires on October 31, 2016. Please continue to use the current permit until a new NPDES permit is issued. Page# 2 Permit: NC0003573 Owner -Facility: Chemours Company -Fayetteville Works Inspection Date: 05/20/2016 Inspection Type: Compliance Evaluaiion Operations � Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? #Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? Comment: Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical. results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete:. do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Yes No NA NE � ❑ ❑ ❑ ❑ ❑ Yes No NA NE ® ❑ ❑ ❑ ® ❑ ❑ ❑ ❑ ❑ ® ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ � ❑ ❑ ❑ ❑ ❑ ❑ � ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ � ❑ � ❑ ❑ ❑ ■ ❑ ❑ ❑ � ❑ ❑ ❑ ® ❑ ❑ ❑ Page# 3 Permit: NC0003573 Owner - Facility: Chemours Company -Fayetteville Works Inspection Date: 05/20/2016 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ N ❑ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? N ❑ ❑ ❑ Comment: Flow Measurement -Effluent Yes No NA NE # Is flow meter used for reporting? ■ El ❑ ❑ Is flow meter calibrated annually? ® ❑ ❑ ❑ Is the flow meter operational? N ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ 0 Comment: Solids Handling Equipment Yes iVo NA NE Is the equipment operational? M ❑ ❑ ❑ Is the chemical feed equipment operational? M ❑ ❑ ❑ Is storage adequate? N ' ❑ ❑ ❑ Is the site free of high level of solids in filtrate from filter presses or vacuum filters? 0 ❑ ❑ ❑ Is the site free of sludge buildup on belts and/or rollers of filter press? ■ ❑ ❑ ❑ Is the site free of excessive moisture in belt filter press sludge cake? ! ❑ ❑ ❑ The facility has an approved sludge management plan? 0 ❑ ❑ ❑ Comment: Chemical Feed Yes No NA NE Is containment adequate? 0 ❑ ❑ ❑ Is storage adequate? 0 ❑ El ❑ Are backup pumps available? 0 ❑ ❑ ❑ Is the site free of excessive leaking? M ❑ ❑ ❑ Comment: Page# 4 Permit: NC0003573 Owner - Facility: Chemours Company -Fayetteville Works Inspection Date: 05/20/2016 Inspection Type: Compliance Evaluation Puma Station - Influent Yes No NA .NE Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ Is the wet well free of excessive grease? ❑ ❑ ❑ Are all pumps present? El El ❑ Are all pumps operable? ❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Is SCADA telemetry available and operational? ❑ ❑ ❑ Is audible and visual alarm available and operational? ® ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? e ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? N ❑ ❑ Are weirs level? ■ ❑ ❑ ❑ Is the site free of weir blockage? N ❑ ❑ El Is the site free of evidence of short-circuiting? ❑ ❑ Is scum removal adequate? El ❑ ❑ Is the site free of excessive floating sludge? ❑ ❑ El Is the drive unit operational? N ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ Is the overflow clear of excessive solids/pin floc? M❑ El EJ Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) ❑ ❑ ❑ Comment: Aeration Basins Mode of operation Type of aeration system WW Is the basin dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Yes No NA NE Ext. Air Diffused ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ® ❑ ❑ ❑ Page# 6 Permit: N00003573 Owner -Facility. Chemours Company -Fayetteville Works Inspection Date: 05/20/2016 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Comment: Pumps -RAS -WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ❑ N ❑ Is sample collected above side streams? N ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ■ ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is sampling perf ormed according to the permit? Comment: Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Commen t: Upstream /Downstream Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling locatiori)? Comment: Facility is a member of the Middle Cape Fear River Basin Association. Yes No NA NE 0 0 El El ❑ ❑ ❑ . ❑ ❑ ❑ ■ ❑ ❑ ❑ . ❑ ❑ ❑ Yes No NA NE ❑ N ❑ ❑ Page# 6