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
� ❑ ❑ ❑
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Yes No NA NE
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❑ ❑ ® ❑
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❑ ❑ ❑
Yes No NA NE
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❑ ❑ � ❑
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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
❑ ❑ ❑
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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
❑ ❑ ❑
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■ ❑ ❑ ❑
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Yes No NA NE
❑ N ❑ ❑
Page# 6