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Home My WebLink AboutNC0004685_Regional Office Historical File Pre 2018 (5)o�o� W aT �9p� r 0 1 Mr. Richard M. Young Senior Environmental Engineering Associate PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Dear Mr. Young: Michael F. Easley, Go ,norij1� William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen Sullins., Director Division of Water Quality April 16, 2008 Subject: Compliance Evaluation Inspection Shelby Facility W WTP NPDES Permit No. NC0004685 Cleveland County, North Carolina Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on April 11, 2008 by Ms. Donna Hood of this Office. Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report; please do not hesitate to contact Ms. Hood or me at (704) 663-1699. Sincerely, -` Robert B. Krebs Surface Water Protection Regional Supervisor Enclosure cc: Cleveland County Health Department DH N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 71 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 IN[ 2 15I 31 NC0004685 Ill 121 08/04/11 117 18I CI 19I SI 20I I i Remarks 21IIIIIIIIIIII'IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA --------------------------- Reserved ---------------------- 67 I 169 70 14 I 71 UI 72 I N I 73I I 174 751 1 I I I I I 180 I_I_I Section B: Facility Data 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) 10:10 AM 08/04/11 05/12/01 -PPG - Shelby facility Exit Time/Date Permit Expiration Date -940 Washburn Switch Rd Shelby NC 28150 01:00 PM 08/04/11 08/08/31 Name(s) of Onsite Re presentative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Billy Lee McFarland/ORC/704-434-2261/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Richard Maxwell Young,158 Emma Dr Ellenboro NC 28040//864-585-4051/ Yes 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 Laboratory Section D: Summary of rindin /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 Donna Hood MRO WQ//704-663-1699 Ext.2193/ Of Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date +cc� Ma cia occo MRO WQ//704-663-1699 Ext.2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 Permit: NC0004685 Inspection Date: 04/11/2008 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation (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: PPG's permit expires on 8/31/2008 and the facility submitted a renewal package. The facility is currently exploring the possibility of connecting onto the City of Shelby's collection system. No decision has been made about the connection at this time. Operations & Maintenance ■nnn ■nnn Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: The facility appeared well maintained and operated at the time of the inspection. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ n n n Is all required information readily available, complete and current? ■ ❑ n ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n Are analytical results consistent with data reported on DMRs? ❑ ■ n n Is the chain -of -custody complete? ■ n n n 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? ■ n n n Has the facility submitted its annual compliance report to users and DWQ? n ❑ ■ n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ■ n Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n Page # 3 Permit: NC0004685 Inspection Date: 04/11/2008 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation ,14 Record Keeping Yes No NA NE 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? ■ n n n Facility has copy of previous year's Annual Report on file for review? n ❑ ■ fl Comment: DMRs for the months of January 2007-December 2007 were reviewed for the inspection. One TRC violation was reported for outfall 002 during July 2007. This violation was handled by NOV. No other violations were reported for the review period. It was noted during the inspection that ammonia nitrogen was reported incorrectly for the month of December 2007. Please submit an amended DMR for December 2007 to reflect the correct ammonia nitrogen values. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ n n n Are all other parameters(excluding field parameters) performed by a certified lab? ■ n n n # Is the facility using a contract lab? ■ ❑ rl Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ n n n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? n n ■ n Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Cl ❑ ■ ❑ Comment: PPG performs field lab analyses under lab certification #223. Pace Analytical (#12) performs all other necessary analyses. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ n n n Is the mixing adequate. ■n00 Is the site free of excessive foaming in the tank? ■ n n n # Is the odor acceptable? ■ n n n # Is tankage available for properly waste sludge? ■ n ❑ n Comment: Sludge is processed through the belt press on site and then the cake disposed of at the county landfill. V.. IJn MA NF= Is containment adequate? ■ n n n Is storage adequate? ■ n n n Are backup pumps available? ■ n n n Is the site free of excessive leaking? ■ n n n Comment: Flow Measurement - Influent Yes No NA NE Page # 4 Permit: NC0004685 Inspection Date: 04/11/2008 Flow Measurement - Influent Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Bar Screens Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Comment: Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Comment: Primary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Yes No NA NE ■nnn ■nnn ■ n n n ■nnn ■nnn Page # 5 Permit: NC0004685 Inspection Date: 04/11/2008 Primary Clarifier Is scum removal adequate? Is the site free of excessive floating sludge? Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Is the drive unit operational? Is the sludge blanket level acceptable? Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) Comment: Aeration Basins Mode of operation Type of aeration system Is the basin free of 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) Comment: Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately''% of the sidewall depth) Yes No NA NE ■ n n n MOOD ■DOD DOOM nnn■ Ext. Air Diffused ■nnn OD■D ■ n n n ■nnn ■nnn nnn■ nnn■ Page # 6 ,Iq Permit: NC0004685 Inspection Date: 04/11/2008 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Comment: Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Down flow Is the filter media present? ■ n n n Is the filter surface free of clogging? ■ Is the filter free of growth? ■ ❑ ❑ ❑ Is the air scour operational? ■ ❑ ❑ ❑ Is the scouring acceptable? ■ n n n Is the clear well free of excessive solids and filter media? ■ n n n Comment: Solids Handling Equipment Yes No NA NE Is the equipment operational? ■ n In n Is the chemical feed equipment operational? ■ n n ❑ Is storage adequate? ■ n n n Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ■ n n n Is the site free of sludge buildup on belts and/or rollers of filter press? ■ n n n Is the site free of excessive moisture in belt filter press sludge cake? ■ n n n The facility has an approved sludge management plan? ■ In n n Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? ■ n n n Are pumps operational? ■ ❑ ❑ Are there adequate spare parts and supplies on site? ■ n n n Comment: Standby Power Yes No NA NE Is automatically activated standby power available? ■ ❑ ❑ n Is the generator tested by interrupting primary power source? ■ n n n Is the generator tested under load? n n n ■ Was generator tested & operational during the inspection? n n ■ n Do the generator(s) have adequate capacity to operate the entire wastewater site? ■ ❑ n n Page # 7 Permit: NC0004685 Inspection Date: 04/11/2008 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is there an emergency agreement with a fuel vendor for extended run on back-up power? ■ n n n Is the generator fuel level monitored? ■ n n n Comment: Pump Station -Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? ■ n n n Are all pumps present? ■ n n n Are all pumps operable? ■ ❑ n Are float controls operable? ■ n n n Is SCADA telemetry available and operational? ■ n n n Is audible and visual alarm available and operational? ■ n n n Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ n n n Is flow meter calibrated annually? ■ n n n Is the flow meter operational? ■ n n n (If units are separated) Does the chart recorder match the flow meter? ■ n n n Comment: The Foxboro Company calibrates the flow meter quarterly. The last calibration was performed on 4.8.2008. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ■ n n n Is sample collected below all treatment units? ■ ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ Is the tubing clean? ■ ❑ ❑ n Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ n n n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n n Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? n n n ■ Are the receiving water free of foam other than trace amounts and other debris? n n n ■ If effluent (diffuser pipes are required) are they operating properly? n n ■ n Page # 8 Permit: NC0004685 Inspection Date: 04/11/2008 Effluent Pipe Comment: Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Yes No NA NE Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ ❑ ❑ 0 Comment: Page # 9 PPG Industries Fiber Glass Products, Inc Timothy G. Mathis Manufacturing Manager Fiber Glass Products August 26, 2009 Division of Water Quality Donna Hood 610 East Center Ave., Suite 301 Mooresville, NC 28115 Technical Assistance and Certification Unit Jerry Rimmer Supervisor 1618 Mail Service Center Raleigh, NC 27699-1618 SENT VIA CERTIFIED MAIL Subject: Temporary ORC Request NPDES Permit: NC0004685 940 Washburn Switch Road Shelby, NC 28150 704-434-2261 Extension 206 mathis@ppg.com ,s Rom_ ;l`,1.''' r:; •..••.r �� AUG 2 8 2009 This letter is being sent to each of you following a letter submitted to you on April 30, 2009 which notified you that Billy McFarland the ORC for PPG Industries Fiber Glass Products, Inc. (PPG) would vacate the ORC position due to his retirement effective 5/1/09. Today's letter notifies each of you that (PPG) has not been able to obtain or employee a Certified "Operator in Responsible Charge" for our WW Grade 3, PC Grade 2 wastewater facility. PPG requests that a "Temporary ORC Certification" be issued to Russle Bernard Carson who will be acting as the "ORC" until he is certified as a WW Grade 3 operator making him elgible to be the facility's permanent waste water "ORC"; he is presently a certified PC Grade 2 operator, WW 2 operator and one of our Back -Up ORCs. The temporary certification is needed because we have approached 120 days without being able to obtain a certified "ORC" for our WW3 — PC2 Grade facility. Efforts were made by way of Job Advertisements in the Shelby NC, Gastonia NC, and Gaffney SC papers to recruit a Certified "ORC". None of the applicants which responded were completely certified in both Wastewater 3 and Physical Chemical 2 treatment. Three applicants were interviewed who qualified with WW3 although they lacked PC experience. One applicant was interviewed who had WW3 and PC1, this applicant was not interested due to the pay rate and benefits in his consulting job were more advantageous to him than the PPG advertised rate of $20.04/hr. In addition to the newspaper advertisements the job vacancy was announced at a local training event for WW Operators at Isothermal Community College and the Regional NCDWQ TACU Consultant was communicated with regularly about the opening in efforts to locate someone who was qualified within the region. There was no response to these efforts. • Russle Bernard Carson is presently one of our Back -Up ORCs and he will be designated as the system permanent ORC for WW 3 upon passing the WW 3 exam. He attended the WW 3 School during July 2009 and has registered for the September exam in Morganton. An ORC Designation Form is enclosed with this letter designating him as the permanent PC 2 ORC. • In the event that Mr. Carson does not pass the exam during the Temporary Certification Period Richard M. Young the facility environmental engineer will be designated as our ORC, he maintains the following active certifications WW 3, cert.# 992348, PC 2, cert.#991181. Also other options include that we will obtain another certified ORC through in-house training or outside recruitment. • Find enclosed two completed "Water Pollution Control System ORC Designation Forms". These forms detail information where we would like to now instate Bernard Carson as the Temporary "ORC WW-3" and the permanent ORC PC 2 for our water pollution control system. Also enclosed is a completed Examination Application requesting the WW 3 ORC Temporary Certification for Bernard Carson and a $200 check as indicated for this process if approved? (Original check to WPCSOCC Jerry Rimmer) Please provide us with written notification to the acceptance of Mr. Carson as Temporary ORC for our facility if this request meets your approval. If you have any questions concerning these matters, please contact Richard Young, Sr. Engineer Associate Environmental, at (704) 434- 2261 ext. 359. Sincerely, �10�,�� Timothy G. Mathis Manufacturing Manager cc: file Richard Young Water Pollution Control System Operator Designation Form WPCSOCC NCAC 15A 8G .0201 Permittee Owner/Officer Name: PPG ItST'�ric�S��w �RSScC �•� r��, Mailing Address:9 40 City: Signature: M l State: me- Zip: -S ISO Phone #: +3 + —0) C Date: .� .......................g�.........................................`................................................................................. Facility Name: I I G 1464AS R` %, O�I'�n�1� S elX��,Permit #: AX1 +(0`V County: ll ! SUBMIT A SEPARATE FORM FOR EACH TYPE OF SYSTEM! Facility Type & Grade: Type Grade Type Grade Biological WWTP Surface Irrigation N/A Physical/Chemical Land Application N/A Collection System Operator in Responsible Charge (ORC) Print Full Name: 11(AS5162 uc trp7of V ct k-olvl" o j Certificate Typ / Grad ./ Number: �✓ C — q 0,7 ()5Work Phone #: 7VT) 'T'- 4 ZZ& Si nature: V�-� ` Date: — v< L — II "I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." .............................................................................................................................................., Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Work Phone #: ( ) Signature: Date: "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." ..............................................................................................................................................., Mail or Fax to: WPCSOCC 1618 Mail Service Center Raleigh, NC 27699-1618 Fax:919/733-1338 (See next page for designation of additional back-up operators. Designation of more than one back-up operator is optional.) Revised 8-2007 Water Pollution Control System Operator Designation Form WPCSOCC NCAC 15A 8G .0201 Permittee Owner/Officer Name: U� A l« Mailing Address: 940 �le,,CMy&.00 5'— 46 god City: S40 4State: 1W_ Zip: 2V SO- Phone #: (RA 4-3*-C) 2- Signature: le-� % i/ 9 Date: ............................................... .................................................................................................. Facility Name: i)� � C�+S .. It r rK FA4- 6 e+SS ?►� &Ck , _4� ' Permit #: � 4,69- G County: ! SUBMIT A SEPARATE rORML FOR EACH TYPE OF SYSTEM! Facility Type & Grade: Type Grade Type Grade Biological WWTP Surface Irrigation N/A Physical/Chemical Land Application N/A Collection System ............................................................................................................................................. Operator in Responsible Charge (ORC) I Qo^6?° Print Full Name: Certificate TypeA Grade / Number: 9153 8 V Work Phone #: (7o4) 4-3 4 - 22-b Signature: 6 Date: &,:q -zb _0 R "I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: Certificate Type / Grade / Number: Signature: Work Phone #: ( ) Date: "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." ................................................................................................................................................ Mail or Fax to: WPCSOCC 1618 Mail Service Center Raleigh, NC 27699-1618 Fax: 919/733-1338 (See next page for designation of additional back-up operators. Designation of more than one back-up operator is optional.) Revised 8-2007 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality . Michael F. Easley, Governor William G. Ross, Jr., Secretary Coleen H. Sullins, Director November 21, 2007 Timothy Mathis PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Rd Shelby, NC 28150 Subject: Renewal Notice ' NPDES Permit NCO004685 PPG - Shelby facility Cleveland County Dear Permittee: Your NPDES permit expires on August 31, 2008. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.O105(e)) regulations require that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If you have already mailed your renewal application, you may disregard this notice. To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than March 4, 2008. Failure to request renewal by this date may result in a civil assessment of at least $500.00..Larger penalties may be assessed depending upon the delinquency of the request. If any wastewater discharge will occur after August 31, 2008, the current permit must be renewed. Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1; unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day. If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact me at the telephone number or address listed below. Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with the permit renewal application. If you have any questions, please contact me at the telephone number or e-mail address listed below. Sincerely, Charles H. Weaver, Jr. NPDES Unit 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 512 North Salisbury Street, Raleigh, North Carolina 27604 NorthCarohna Phone: 919 733-5083, extension 511 / FAX 919 733-0719 / charles.weaver@ncmail.net NaturallyAn Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper NPDES PERMIT NC0004685 PPG - SHELBY FACILITY CLEVELAND COUNTY The following items are REQUIRED for all renewal packages: O A cover letter requesting renewal of the permit and documenting any changes at the facility since issuance of the last permit. Submit one signed original and two copies. 0 The completed application form (copy attached), signed by the permittee or an Authorized Representative. Submit one signed original and two copies. O If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares the renewal package, written documentation must be provided showing the authority delegated to any such Authorized Representative (see Part II.B.1 Lb of the existing NPDES permit). 0 A narrative description of the sludge management plan for the facility. Describe how sludge (or other solids) generated during wastewater .treatment are handled and disposed. If your facility has no such plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed original and two copies. The following items must be submitted by agy Municipal or Industrial facilities discharging process wastewater: Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122:21. The above requirement does NOT apply to privately, owned facilities treating 100% domestic wastewater, or facilities which discharge non process wastewater (cooling water, filter backwash, etc.) PLEASE NOTE: Due to a change in fees effective January 1, 1999, there is no renewal fee required with your application package. Send the completed renewal package to: Mrs. Dina Sprinkle NC DENR / DWQ / Point.Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 PPG Industries Fiber Glass Products, Inc. Richard M. Young Senior Engineer Associate Environmental September 7, 2010 Ms. Donna Hood Surface Water Protection Section NCDENR — Division of Water Quality 610 East Center Avenue, Suite 301 Mooresville, NC 28115 940 Washburn Switch Road Shelby, N.C. 28150 SENT VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED Re: PPG Shelby WWTP-BYPASS/UPSET Report Ms. Hood: 704-434-2261 Extension 359 richardyoung@ppg.co RECEIVED DIVISION OF WATER QUALITY SEP a 9 2010 SWP SECTION MOORESVILLE REGIONAL OFFICE Find attached a WWTP bypass report. This information is being sent to you after our phone conversation on 9/7/10 in which we discussed the Wastewater Bypass that occurred on Saturday 9/4/10 at the PPG Shelby WWTP. The bypass was initially reported by phone to Mr. Web with NC Emergency Management at approximately 3:00 PM on 9/4/10. The release did not reach surface waters and the plant's influent was temporarily diverted to the waste treatment holding pond until the process problem was solved. The spill residue was cleaned up promptly and a root cause investigation began immediately. If you have any questions regarding the information presented, please contact me at (704) 434- 2261 extension 359. Sinc ely, Richard M. Yount Senior Engineer Associate Cc: File IV OF WATER Form WWTP-BYPASS/UPSET Treatment Plant (WWTP) Bypass/Upset RejM9f t fNr'A9ktFA@R4rt � r o Y SEP - 9 2010 SWP SECTION MOORESVILLE REGIONAL OFFICE This form shall be submitted to the appropriate DWQ Regional Office within five days of the first knowledge of the unanticipated bypass or upset. Permittee: r lodL.S 45 Fi�F44- 0b 55 IO-° Permit Number: Facility Name: PF-11(0 - 5��o County: jj Incident Started: Date: �A/10Time: l 6" 5.7 4 A'"! Incident Ended: Date: 9AZLO Time: 1 2-2,� Pm p�P Weather Conditions during Bypass/Upset event: 019alV' �6t1i5 /"G f �► `'' 0 Level of Treatment: _None Zprimary Treatment _Secondary Treatment _Chlorination/Disinfection Only Estimated Volume of Spill/Bypass: ' v-4-S0 ' P- /cmS (must be given even if it is a rough estimate) Describe how the volume was determined: A1/4-&q't%d pmc"""S OL41-7 & VaA d ;,— 3cc,,7eoj LA- v r Vv Did the Spill/Bypass reach the Surface Waters? _Yes /No If yes, please list the following: Volume Reaching Surface Waters: , PV'C Surface Water Name: 11114 Did the Spill/Bypass result in a Fish Kill? Yes _ZNo Was WWTP compliant with permit requirements? /Yes No Were samples taken during event? Yes L/'No Source of the Upset/Spill/By//p�.ass (Location or Treatment Unit): y� l v _Jo Form WWTP-BYPASS/UPSET Page 2 Cause or reason for the Upset/Spill/Bypass: tr�l�r' /� �r� �"�! '`�'� �� + O�v-r r$ h 1 �'1 c� C�� r"� �j �Ut.✓� �Cl o��+).. 4-,e. Cn.Qv"4<<oC'7 4�7ti 4< Oa►r/f/QJ- 41 A % Describe the repairs m��agqiide or actions taken: LCr/l L 1 l ,K" Gti r %�� Gl 0 J Action taken to contain, lessen the impact, clean up, and remediate the! site (if applicable) due to the bypass: `�� C j r 1 7` YID ® { � J9 0'r'/� `i�`P )(I V"I 0 C� Action taken or proposed to be taken to prevent occurrences: Ccx�p(,%N (:�� A(� SI /�1�1r��'IIFY�r�'�rC�� ©t j d nza—,tQ.t-vs, hOMv(+1�11If- Were adequate equipment and resources available to fix the probbm? Yes ❑ No cs%4 �m cJcv— cvcaS cyci Caml r," ��ftid ax�tg 1V-3� �P,j/ Cvi(J �d lei Additional comments about the event: " 24-Hour Report Made To Form WWTP-BYPASS/UPSET /Page 3 Division of Water Quality Emergency Management to Contact Name:Date: �A CNpo I ®- O-W `14-110 Time: Other Agencies Notified (Health Dept, etc): D Person Reporting Event: I`CI��,V (��2-� Phone Number: -;L74-' 59 Did DWQ request an additional written report? _Yes '114 If Yes, what additional information is needed: A/ As a representative for the responsible party, I certify that the information contained in this report is true and accurate to the best of my knowledge. Person Submittina Claim: "Rlfc4clra 114• yo-11 Signature: Title: ✓r. Date: Telephone Number: "' 4W— ZzO C 3 Gl:� Any additional information to be submitted should be sent to the appropriate Division Regional Office within five days of first knowledge of the Bypass with reference to the incident number (the incident number is only generated when electronic entry of this form is completed, if used). Beverly Eaves Perdue Governor ATA •1 C North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary December 1, 2009 5489 Mr. Richard Young. PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150- SUBJECT: Wastewater/Groundwater Laboratory. Certification Renewal FIELD PARAMETERS ONLY Dear Mr. Young: The Department of Environment and Natural'Resources, in accordance with the provisions of NC GS 143-215- .3 (a) (10), 15 . NCAC 2H .0800, is pleased to renew certification for your laboratory to perform specified environmental analyses required by EMC monitoring and reporting regulations 15 NCAC 2B .0500, 2H .0900 and 2L .0100, .0200, .0300, and 2N .0100 through .0800. Enclosed for your use is a certificate describing the requirements and limits of your certification. Please review this certificate to insure that your laboratory is certified for all parameters required to properly meet your certification needs. Please contact us at 919-733-3908 if you have questions or need additional information. Sincerely, �at Pat Donnelly Certification Branch Manager Laboratory Section Enclosure CC' Chet Whiting, Gary Francies Mooresville Regional Office DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-39081 FAX: 919-733-6241 Internet: www.dwqlab.org Nne orthCarolina Natyrally An Equal Opportunity t Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org STATE OF NORTH CAROLINA DEPARTMENT OF THE ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY LABORATORY CERTIFICATION PROGRAM In accordance with the provisions ofN.C.G.S. 143-215.3 (a) (1), 143-215.3 (a)(10) and NCAC 2H.0800: PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. Is hereby certified to perform environmental analysis as listed on Attachment I and report monitoring data to DWQ for compliance with NPDES effluent, surface water, groundwater, and pretreatment regulations. By reference 15A NCAC 2H .0800 is made a part of this certificate. This certificate does not guarantee validity of data generated, but indicates the methodology, equipment, quality control procedures, records, and proficiency of the laboratory have been examined and found to be acceptable. This certificate shall be valid until December 31, 2010 Certificate N 5489 C/ Pat Donnelly Attachment] North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Lab Name: PPG Industries Fiber Glass Products, Inc. Address: .940 Washburn Switch Road Shelby, NC 28150- Certificate Number: 5489 Effective Date: 01/01/2010 Expiration Date: 12/31/2010 Date of Last Amendment: The above named laboratory, having duly met the requirements of 15A NCAC 21-1.0800, is hereby certified for the measurement of the parameters listed below. CERTIFIED PARAMETERS INORGANICS RESIDUAL CHLORINE Std Method 4500 Cl E CONDUCTIVITY Std Method 2510B DISSOLVED OXYGEN Std Method 4500 O C pH Std Method 4500 H B TEMPERATURE Std Method 2550B This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807. DR8168 95 PPG INDUSTRIES, INC. 848 SOUTHERN AVENUE D-&B CHILLICOTHE, OH 45601 Return Service Requested 000048 RKDKlSTA WPCSOCC 1618 MAIL SERVICE CENTER RALEIGH NC 27699-1618 0012297296 Page 1 of 1 Check Date: 08/19/2009 Vendor Number: Invoice Invoice Voucher PPG Contact Phone Number Gross Adjustment Net Number Date Number Audit No. Amount Amount Amount I RI 08/17/09 08/17/09 0352-V63324 740 774-7684 CHILLICOTHE $200.00 $210911 q: AU 1% 2 8 2009 $200.00 $0.00 $200.00 SHADED AREA MUST GRADUALLY CHANGE FROM BLUE AT TOP TO GREEN AT BOTTOM 46-Ehorfz . ..... .. .... 11100 12 297 29611, 1:05310156 0: 2079900 1 113 4 1 G no WATER POLLUTION CONTROL SYSTEM OPERATORS CERTIFICATION COMMISSION EXAMINATION APPLICATION Please complete all sections of this application legibly. Please read the instructions and the eligibility requirements carefully. PRINT (or TYPE) all of your responses in BLACK INK EXAMINATION SELECTION Please check only one: 1 2 3 4 OF Temp Temp Renewal Cond Collections Ph sical Chemical Land A lication S ra Irn ation Subsurface AT Conversion $20 T e and Grade leci rocit Certification 1 $100 IType and Grade PERSONAL INFORMATION Have you previously held a certificate with the WPCSOCC that was revoked, suspended, or relinquished? (Circle one) Yi Please select the month & location at which you prefer to take the examination (circle one) Kenansville Morganton Raleigh Salisbury Williamston March June September November Please note: The WPCSOCC reserves the right to use or not use the noted examination locations as it deems necessary. Social Security Number: 15 �/ / 20 11 Date of Birth: �Z / 17 / �'o Applicant's Name /1I / Mrs / Ms (As you wish it to appear do. certificate) Applicant's Applicant's Address: 17C'n. (First) C, (Middle) (Mailing addressor PO Box) (Last) (Jr., Sr., III etc.) •vie (state) (Zip Code) (County) Work Telephone: jo+ l AW — zz cs I Home Telephone: 204- / 4-5 —'-, 7 Email Page 1 Revised 01/2006 WPCSOCC Exam App EMPLOYER INFORMATION ( Employer's name: PPG ,�.�4 ] ,19 E41sll_ 6� DWO( .1 L-A Employer's telephone: ')0 4 / A7� "Z % Employer's permit number: Ata7c 4(9 Employer's mailing address —"4vw4S444 544 d 1 c. 2_g1 cAp ,&kid (City) I r(State) (Zip code) (County) "Applicants presently working at a water pollution control system must complete the following information: System Name: I I V Lmr� F-j F (Sg ?wJ,4 I ystem permit number: AIC- Type of system (circle one) AW�A AWB �C��S1 CS2% CS3 CS4 LA P/CI P/C2 SI SS WWI WW2 *&3 WW4 Physical address of Facility: -(/ �'�'Gr l t ,,, 5,, 4 City: v State• �� Zip: f D Immediate Supervisor's name and title: ��(((%%%((( r� P �� ei, rr ril 1,1�i4J Immediate Supervisor's work telephone #:� EDUCATION High School: Did you graduate? Yes No If Yes, give school name, address, phone number and date of graduation: G If NO, Do you have a (GED) diploma? Yes No If Yes, give school name, address, phone number and date of issuance: College(s) attended: CI"°lit° Cot, 4 1 k4 aCity/State/Zip �4�C Dates of attendance: From —�-/ /3 To 9C) Years completed 1 &/3 4 Did you receive a degree? es No If yes,date received: Type of degree: (e.gAg, BA, MS) Major: _Wc Minor: rSIA4055 ��, �Ll bi, (Note: Copies of official transcripts must be included for all post -high school education if eligibility to take the examination is based on that education.) COMMISSIONAPPROVED-TRAINING SCHOOL INFORMATION * NOTE: A Certificate of Completion from the school must be included with this application School Title Location where taught (community college etc.) Dates of School From To C 3 P7 205DI j V� 13 _ Un. Completion of this.section.does not eliminate the requirement to attach a Certificate of Completion from the school! Page 2 Revised 01/2006 WPCSOCC Exam App OPERATIONAL EXPERIENCE Please list all of your work experience that demonstrates hands-on experience in the operation of the type and grade system for which you are seeking certification. Include the position's title and be very specific in describing the actual duties you performed while in the position. List your most recent experience first. Attach additional sheers if necessam Dates of Employment Name, address and phone # of employer 'type & grade facility # Hours worked per week Give your position title and a detailed description of your duties when you were in that position. From Month/Year To Month/Yeaz ww3 7. x+ dR4ZV �►� LC'76 5y 6LC05� C%W1C1V � �f ACL'L.1(.ANT ,S NJUNAT'URE I hereby certify that the information given in this application is correct to the best of my knowledge. I understand that providing false information on this application may lead to the revocation of any and all certificates issued to me by the Water Pollution Control System Operators Certification Commission (WPCSOCC). I have read the eligibility requirements for the type and grade certification that I am seeking and believe that I am eligible to sit for the examination for that certification. Applicant's Signature (,�t Date Y 12—b Page 3 Revised 01/2006 WPCSOCC Exam App RECOMMENDATIONBYAPPLICANT'S SUPERVISOR I have reviewed this application and hereby verify that all of the information and statements provided by the applicant are true and correct to the best of my knowledge. I recommend that the Water Pollution Control System Operators Certification Commission (WPCSOCC) consider this applicant for certification. I understand that I am responsible for verifvins the experience information provided on this application and that any false information provided by the applicant may lead to the revocation of any and all certificates issued to me by the Water Pollution Control System Operators Certification Commission (WPCSOCC). _ i i Supervisor's name (please Supervisor's Supervisor's Supervisor's Certifications held by Supervisor with the WPCSOCC Typed Grade CertificateNumber5234-1:0j, Type �Grade Certificate Number "Type ( Signature of Before mailing tnis application, please insure that: • you have provided all required or requested information, documentation, and necessary signatures; • a Certificate of Completion for the required school is included with this application; • a copy of an official transcript is included for all post -high school education if your eligibility for the examination is based on that education; • the application is legible (applications that cannot be read will not be reviewed); • all operational experience is indicated in detail with duties and dates of employment clearly indicated; • you have signed and dated your application in the appropriate location; • your supervisor has signed and dated the application in the appropriate location, if applicable; and you have enclosed the appropriate application fee. *In order for this application to be processed, it must be accompanied by appropriate fees and be postmarked at least 30 days prior to the date of the examination. Please consult our website at http://h2o.enr.state.nc.us/tacu/examapp.html for deadline dates. *Make all checks payable to the WPCSOCC (Water Pollution Control System Operators Certification Commission) *PLEASE NOTE THAT A $25 PROCESSING FEE WILL BE CHARGED FOR ALL RETURNED CHECKS. *Mail the completed application to: WPCSOCC 1618 Mail Service Center Raleigh NC 27699-1618 Page 4 Revised 01/2006 WPCSOCC Exam App PPG Industries Fiber Glass Products, Inc. Timothy G. Mathis Manufacturing Manager Fiber Glass Products April 30, 2009 Division of Water Quality Donna Hood 610 East Center Ave., Suite 301 Mooresville, NC 28115 Technical Assistance and Certification Unit Jerry Rimmer Supervisor 1618 Mail Service Center Raleigh, NC 27699-1618 SENT VIA CERTIFIED MAIL 940 Washburn Switch Road Shelby, NC 28150 Subject: ORC Vacancy and Back — Up ORC Change NPDES Permit: NC0004685 704-434-2261 Extension 206 mathis@ppg.com 14AY 4 2009 DN-Saf0ce Water This letter is being sent to the Regional Division of Water Quality and Commission per 15 NCAC 08G .0202 (2). This letter notify's each of you that Billy McFarland the ORC for PPG Industries Fiber Glass Products, Inc. (PPG), is vacating the ORC position due to his retirement. effective 5/l/09. In addition find enclosed two completed "Water Pollution Control System ORC Designation Forms". These forms detail information where we would like to now instate Billy McFarland as a back up ORC for our water pollution control system. Also I would like to notify you that Michael Humphries and Kellie Hendrick are no longer backup ORCs for our facility effective 5/l/09. In summary these changes will maintain our facility with three backup ORCs - Russle Carson, Richard Young and Billy McFarland. PPG has began interviewing candidates for the vacant ORC position and I will notify each of you within 120 days of a newly designated ORC. If you have any questions concerning these matters, please contact Richard Young, Sr. Engineer Associate Environmental, at (704) 434-2261 ext. 359. Sincerely, Timothy G. Mathis Manufacturing Manager cc: file Richard Young Water Pollution Control System Operator Designation Form WPCSOCC NCAC 15A 8G .0201 Permittee Owner/Officer Name: T P% aJi Y-,�S r. &v 61,6; �i��ittTS j.,e- -P-1 �.,1111.S Mailing Address: 940 &L',,k4 6�d e City: S40&j Stater Zip: 2.g�- Phone #: ( 434 ~ 2Z % ) Signature: -d` Date: 3 d ..................................�..................................................-J.................................................................. .J. Facility Name: P% J, A6 F6 W 0455 ��/S J;,C., Permit #: /IC v0046' !R County: C-10VC, C,�rC1P ! SUBMIT A SEPARATE FORM FOR EACH TYPE OF SYSTEM! Facility Type & Grade: Tye Grade Type Grade Biological WWTP X-3 Surface Irrigation N/A Physical/Chemical Land Application N/A Collection System Operator in Responsible Charge (ORC) Print Full Name: Certificate Type / Grade / Number: Signature: Work Phone #: Date: "I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Back -Up Operator in %Resp))onsible Charge (BU% ORC) Print Full Name: B,'11 �/ Le. Certificate Type / Grade / Number: ►�► v/-:k/ 24649 Work Phone #: ( 7�) 4-'34 - Z26 �� Signature: �'c/ �d�oc�e�c/ Date: "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Mail or Fax to: WPCSOCC 1618 Mail Service Center Raleigh, NC 27699-1618 Fax: 919/733-1338 (See next page for designation of additional back-up operators. Designation of more than one back-up operator is optional.) Revised 8-2007 Water Pollution Control System Operator Designation Form WPCSOCC NCAC 15A 8G .0201 Permittee Owner/Officer Name: M TZdU5S ,lc'S FAQ OC45 RYAd."A/ 1,e-1. Mailing Address: 9 4c 5ct, 'kti M e City: S11P l tJ ' State:NC- Zip: n f 5�0 - Phone #: Py ) 4- 2Z Signature: Date: Z-'ra 'I'a '0Z ......................`................-.)............................................................................................................ . Facility Name: f P6 -l.yr(� 5t V.r?CS Ft &1,, 0045 U&A . , Permit #: Aczcy4- a! ! SUBMIT A SEPARATE FORM FOR EACII TYPE OF SYSTEM! Facility Type & Grade: Type Grade Biological WWTP Physical/Chemical X Collection System Surface Irrigation a Land Application Operator in Responsible Charge (ORC) Print Full Name: Certificate Type / Grade / Number: Signature: County: clef-ya loti d Type Grade N/A N/A Work Phone #: Date: "I certify that I agree to my designation as the Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." Back -Up Operator in Responsible Charge (BU ORC) Print Full Name: R //v Lee MC? Fet, i Certificate Type / Grade / Number: PC 12C /2 � 3 0'1 Work Phone #: ( 1434- — 2Z6 j Signature: //, %��r.P�� Date: 4 07 "I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by the rules and regulations pertaining to the responsibilities of the BU ORC as set forth in 15A NCAC 08G .0205 and failing to do so can result in Disciplinary Actions by the Water Pollution Control System Operators Certification Commission." .................................................................................................................................................. Mail or Fax to: WPCSOCC 1618 Mail Service Center Raleigh, NC 27699-1618 Fax: 919/733-1338 (See next page for designation of additional back-up operators. Designation of more than one back-up operator is optional.) Revised 8-2007 Todd Humphries . 2001 Holly Hill Road Shelby, NC 28152 INOMM Grade 4 Certification #992728 PPG Industries Permit # NC0004685 This letter is to let you know that I am no longer a Back-up ORC effective this day April 29t, 2009 at the PPG Industries Wastewater treatment plant in Shelby NC due to a change in my employment. Todd Humphries �� '"fin ,vl �( t_t.-�_� �-2-7-v 7 Lf0n Beverly Eaves Perdue Governor NCDENR North Carolina Department of Environment and Natural Division of Water Quality Coleen H. Sullins Director April 15, 2009 Mr. Tim Mathis, Manufacturing Manager PPG Industries Fiberglass Products, Inc. 940 Washburnswitch Road Shelby, NC 28150 Resources Subject: Compliance Evaluation Inspection PPG -Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County, North Carolina Dear Mr. Mathis: Dee Freeman Secretary Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on April 4, 2009 by Ms. Donna Hood of this Office. The ORC should be commended for exceptional environmental responsibility in the operation of the wastewater treatment plant. This report should be self-explanatory; however, should you have any questions concerning the report, please do not hesitate to contact Ms. Hood or me at (704) 663-1699. Sincerely, Robert B. Krebs Regional Supervisor Surface Water Protection Enclosure cc: Cleveland County Health Dept DH Mooresville Regional Office One Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 NortllCarolina Phone: (704) 663-1699 \ Fax: (704) 663-6040 \ Customer Service: 1-877-623-6748 9/ Internet: www.ncwaterquality.org Amitrally 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 I NI 2 15I 31 NC0004685 111 121 09/04/03 117 181 CI 19I SI 201 I Remarks 2111IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------ —------------------- Reserved ---------------------- 67I 169 701 I 711 I 721 N I 73 I I w 174 751 I I I I I I 180 Section B: Facility Data 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) PPG - Shelby facility 10:00 AM 09/04/03 08/11/01 Exit Time/Date Permit Expiration Date 940 Washburn Switch Rd Shelby NC 28150 12:30 PM 09/04/03 13/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Billy Lee McFarland/ORC/704-434-2261/ Name, Address of Responsible Official/Title/Phone and Fax Number Grady Gowan,940 Washburn Switch Rd Shelby NC Contacted 28150//704-434-2261/7044347011 Yes 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 Laboratory Storm Water 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 Donna o d ✓� MRO WQ//704-663-1699 Ext.2193/ of Managemmentt Q A eview r Agency/Office/Phone and Fax Numbers D tl J,�ignature rc' Allocco MRO WQ//704-663-1699 Ext.2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day 31 NC0004685 111 121 09/04/03 1 17 Inspection Type 18ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page # 2 Permit: NC0004685 Inspection Date: 04/03/2009 Owner -Facility: PPG -Shelby facility Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ n M n Is the facility as described in the permit? 13 n n n # Are there any special conditions for the permit? n ■ n n Is access to the plant site restricted to the general public? ® n n n Is the inspector granted access to all areas for inspection? ® n n n Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n Judge, and other that are applicable? Comment: The facility appeared well maintained and operated at the time of the inspection. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ n n n Is all required information readily available, complete and current? ® n n n Are all records maintained for 3 years (lab. reg. required 5 years)? ❑ n n Are analytical results consistent with data reported on DMRs? ■ o n o Is the chain -of -custody complete? ® n n n 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? ® n n n Has the facility submitted its annual compliance report to users and DWQ? ® o n n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ■ n Is the ORC visitation log available and current? ® ❑ n n Is the ORC certified at grade equal to or higher than the facility classification? ■ o n n Is the backup operator certified at one grade less or greater than the facility classification? ® n n o Page # 3 Permit: NC0004685 Owner - Facility: PPG - Shelby facility Inspection Date: 04/03/2009 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? ® n n n Facility has copy of previous year's Annual Report on file for review? ❑ n ® ❑ Comment: DMRs for February 2008-January 2009 were reviewed for the inspection. The following violations were reported during the review period: 04/08- Daily maximum violation for Oil and Grease 05/08- Daily maximum violation for Oil and Grease 10/08- Daily maximum violation for Oil and Grease All violations have been handled under prior cover. No other violations were reported for the review period. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ n n n Are all other parameters(excluding field parameters) performed by a certified lab? ■ n n n # Is the facility using a contract lab? ■ n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? n n ■ n Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? n n ■ Comment: PPG performs field lab analyses under lab certification #223. Pace Analytical (#12) performs all other necessary analyses. A laboratory inspection was performed concurrently with the NPDES inspection. Please refer to the report by Mr. Chet Whiting, of this Office, for any lab recommendations. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ n n n Is the mixing adequate? ® n n n Is the site free of excessive foaming in the tank? ■ n n # Is the odor acceptable? ■ n n n # Is tankage available for properly waste sludge? ® n n n Comment: Sludge is processed through the belt press on site and then the cake disposed of at the county landfill. Solids Handling Equipment Yes No NA NE Is the equipment operational? ■ n n n Is the chemical feed equipment operational? ® n n n Is storage adequate? ® n n n Is the site free of high level of solids in filtrate from filter presses or vacuum filters? n n n 1 Page # 4 Permit: NCO004685 Inspection Date: 04/03/2009 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Solids Handling Equipment Yes No NA NE Is the site free of sludge buildup on belts and/or rollers of filter press? ■ n n n Is the site free of excessive moisture in belt filter press sludge cake? ® n n n The facility has an approved sludge management plan? ® n ❑ ❑ Comment: Chemical Feed Yes No NA NE Is containment adequate? ■ ❑ ❑ ❑ Is storage adequate? ■ ❑ n ❑ Are backup pumps available? ■ n n n Is the site free of excessive leaking? ■ ❑ ❑ ❑ Comment: Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? n ■ n n Is flow meter calibrated annually? ■ n n n Is the flow meter operational? ■ ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ■ n n n Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ❑ ® ❑ Is sample collected above side streams? ® ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ ❑ Is the tubing clean? ® n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ® n n n Is sampling performed according to the permit? ❑ ❑ ® ❑ Comment: Influent sampling is performed for process control and is not required by the permit. Equalization Basins Yes No NA NE Is the basin aerated? nn®n Is the basin free of bypass lines or structures to the natural environment? ® n n n Is the basin free of excessive grease? ■ ❑ n ❑ Are all pumps present? ■ n n n Page # 5 Permit: NC0004685 owner -Facility: PPG -Shelby facility Inspection Date: 04/03/2009 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE ® n n n Are all pumps operable? Are float controls operable? ® n n n Are audible and visual alarms operable? ® ❑ ❑ ❑ # Is basin size/volume adequate? ® ❑ ❑ ❑ Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b.Mechanical Are the bars adequately screening debris? ■ n n n Is the screen free of excessive debris? ■ n n n Is disposal of screening in compliance? ■ n n n Is the unit in good condition? ■ n n n Comment: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? ■ n n n Is the site free of excessive buildup of solids in center well of circular clarifier? ® ❑ ❑ ❑ Are weirs level? ® C) n n Is the site free of weir blockage? ■ n n n Is the site free of evidence of short-circuiting? ■ n n n ■ n n n Is scum removal adequate? Is the site free of excessive floating sludge? ® n n n Is the drive unit operational? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? ■ n n n Is the sludge blanket level acceptable? (Approximately %4 of the sidewall depth) ® n n n Comment: One clarifier was being repaired at the time of the inspection. Aeration Basins Yes No NA NE Mode of operation Ext. Air Diffused Type of aeration system Is the basin free of dead spots? ■ n n n Page # 6 Permit: NC0004685 Inspection Date: 04/03/2009 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Are surface aerators and mixers operational? ® n n n Are the diffusers operational? ■ ❑ n ❑ Is the foam the proper color for the treatment process? ® n n n Does the foam cover less than 25% of the basin's surface? ®n n n Is the DO level acceptable? ®n n n Is the DO level acceptable?(1.0 to 3.0 mg/1) ■ n n n Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? ■ n n n Is the site free of excessive buildup of solids in center well of circular clarifier? ■ n n n Are weirs level? ■ n n n Is the site free of weir blockage? ■ n n n Is the site free of evidence of short-circuiting? ® n n n Is scum removal adequate? ■ n n n. Is the site free of excessive floating sludge? ■ n n n Is the drive unit operational? ® n n n Is the return rate acceptable (low turbulence)? ■ ❑ n Is the overflow clear of excessive solids/pin floc? ■ n n n Is the sludge blanket level acceptable? (Approximately '/4 of the sidewall depth) ® n n n Comment: Secondary clarifiers were very clear on the day of the inspection. Pumps-RAS-WAS Yes No NA NE Are pumps in place? ® n n n Are pumps operational? ® n n n Are there adequate spare parts and supplies on site? ® n n n Comment: Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Down flow Is the filter media present? M ❑ ❑ ❑ Is the filter surface free of clogging? ® n n n Is the filter free of growth? ■ n n n Page # 7 Permit: NC0004685 Inspection Date: 04/03/2009 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Filtration (High Rate Tertiary) Yes No NA NE Is the air scour operational? ® n n Is the scouring acceptable? ■ n n n Is the clear well free of excessive solids and filter media? ■ n n o Comment Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ n n n Is flow meter calibrated annually? ■ n n n Is the flow meter operational? ■ n n n (If units are separated) Does the chart recorder match the flow. meter? ■ n n n Comment: The Foxboro Company calibrates the flow meter quarterly. The last calibration was performed on 9.12.2008. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ■ n n M Is sample collected below all treatment units? ■ n n n Is proper volume collected? ®n M M Is the tubing clean? ■ n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n F1 Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ■ n n n 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 ❑ ■ Cl Comment: The receiving stream appeared unaffected by the discharge at the time of the inspection. Upstream / Downstream Samplinq Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? M n n n Comment. - Standby Power Yes No NA NE Is automatically activated standby power available? ■ n n n Is the generator tested by interrupting primary power source? M n n n Page # 8 Permit: NC0004685 Inspection Date: 04/03/2009 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Standby Power Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: Yes No NA NE 13 n n n ®nnn ®nnn ® n n n ®nnn Page # 9 1 Billy Lee McFarland PO Box 443 Bostic, NC 28018 Phone (828) 245-7250 Aprii 29, 2009 Technical Assistance and Certification Unit Jerry Rimmer Supervisor 1618 Mail Service Center Raleigh, NC 27699-1618 Division of Water Quality Donna Hood 610 East Center Ave., Suite 301 Mooresville, NC 28115 SENT VIA CERTIFIED MAIL Subject: Vacating ORC Position NPDES Permit: NC0004685 NC Certifications WW Grade 3 24649 PCC Grade 2 29309 v ol Gt�� • `��• °tiE d ff��eu€rd6 This letter is being sent to the Commission and the Regional Division of Water Quality per 15 NCAC 08G .0204 (9). Due to my retirement I will be vacating my position as ORC for PPG Industries Fiber Glass Products, Inc. effective 05/l/09. Please contact me if there are any questions. Sincerely, Billy McFarland cc: Richard Young PPG file W PPG Industries Fiber Glass Products, Inc. Timothy G. Mathis Manufacturing Manager Fiber Glass Products March 9, 2009 Mr. Robert B. Krebs Surface Water Protection Regional Supervisor 940 Washburn Switch Road Shelby, N.C. 28150 704-434-2261 Extension 206 PRT& F IV "�, ,a:, 4 MAR 1 1 2009 Division of Water Quality, NC DENR -.+.ateLJ -6`d�$v Mooresville Regional Office 610 East Center Avenue, Suite 301 ®��-��6]C� c��r Pl�b�i:i3n Mooresville, NC 28115 SENT VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED Re: Notice of Violation — Effluent Limitations Tracking #: NOV-2009-LV-0049 PPG Industries Fiber Glass Products, Inc. - WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Krebs: This letter is in response to the Notice of Violation issued on February 16, 2009 by the Division of Water Quality ("DWQ") to PPG Industries Fiber Glass Products, Inc. ("PPG"). The Notice of Violation alleged that PPG's October 2008 self -monitoring report described an oil and grease effluent limit excursion of the permitted daily maximum value. PPG immediately investigated the matter upon receiving the sample report from Pace Analytical Labs. No upsets or abnormalities were found relating to the wastewater influent, PPG wastewater operations, .or testing procedures performed by the lab. A "Root Cause Analysis" was conducted by a team of PPG technicians and engineers. Based on the results of our investigation of the sample result, PPG has taken the following actions. We have increased monitoring of the wastewater influent for oil and grease. Should an abnormal indication occur the daily addition of Bentonite Clay mixed into the treatment process is increased from the normal 300 lbs. /day to 400 lbs. /day. This addition increases the efficiency of oil and grease removal from the wastewater due to inadvertent exposure of oil and grease containing materials. Also after an abnormal indication multiple wastewater outfalls are sampled at the production facility to assist in identifying the contaminate source. Additionally as part of jPF7ewastewater management system -weekly and monthly oil and grease audits are being ucted throughout the collection system by wastewater technicians. To date, all subsequent sampling results for oil and grease have been within permitted limits. In summary, PPG believes that the excursion experienced on October 22, 2008 was attributable to an isolated instance of a wastewater contaminate and did not represent the effluent or any upset with the wastewater process. PPG promptly investigated and corrected the conditions thought to have contributed to this contamination. Subsequent sampling results have been compliant, and PPG believes that this issue has been adequately corrected. PPG requests that the DWQ consider this matter resolved and not pursue further actions. If you have any questions or concerns, please contact Richard Young at (704) 434-2261 extension 359. Sincerely, Timothy G. Mathis Manufacturing Manager Cc: Richard Young A. • &Viral NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director February 16, 2009 CERTIFIED MAIL 7007 1490 0004 4510 1735 RETURN RECEIPT REQUESTED Mr. Richard M. Young Senior Environmental Engineering Associate PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Notice of Violation - Effluent Limitations Tracking #: NOV-2009-LV-0049 Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Young: Dee Freeman Secretary A review of the October 2008 self -monitoring report for the subject facility revealed a violation of the following parameter: Outfall Date 001 10/22/08 Parameter Reported Value Permit Limit Oil & Grease 17.1 mg/L (Daily average) 15.0 mg/L (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at 704/663-1699. Sinc rely, Robert B. Krebs Regional Supervisor Surface Water Protection cc: Point Source Branch Cleveland County Health Department Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 NorthCarolina Internet: vnvw.ncwaterquality.org 'J�� ¢r An Equal Opportunity 1 Affirmative Action Employer— 50% Recycledil0% Post Consumer paper N/ y ` `�rq��/ff William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Ii Coleen H. Sullins, Director Division of Water Quality September 10, 2008 CERTIFIED MAIL 7007 1490 0004 4510 0431 RETURN RECEIPT REQUESTED Mr. Richard M. Young Senior Environmental Engineering Associate PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Notice of Violation - Effluent Limitations Tracking #: NOV-2008-LV-0433 Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Young: A review of the May 2008 self -monitoring report for the subject facility revealed a violation of the following parameter: Outfall Date Parameter 001 5/7/08 Oil & Grease Reported Value Permit Limit 25.2 mg/L 15.0 mg/L (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at 704/663-1699. cc: Point Source Branch Cleveland County Health Department Sincerely, Robert B. Krebs Regional Supervisor Surface Water Protection Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Internet: www.newaterquahty.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper NorthCarolina Natura!!il Customer Service 1-877-623-6748 pppppp,- PPG Industries Fiber Glass Products, Inc. Timothy G. Mathis Manufacturing Manager Fiber Glass Products September 4, 2008 940 Washburn Switch Road Shelby, M.C. 28150 704-434-2261 Extension 206 mathis@ppg.com R LW Mr. Robert B. Krebs SEP - j ?�08 Surface Water Protection Regional Supervisor Division of Water Quality, NC DENR Mooresville Regional Office 610 East Center Avenue, Suite 301 4 Mooresville, NC 28115 M-Surface 4 vlcat''011 h"OteCtion SENT VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED Re: Notice of Violation — Effluent Limitations Tracking #: NOV-2008-LV-0376 PPG Industries Fiber Glass Products, Inc. - WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Krebs: This letter is in response to the Notice of Violation issued on August 6, 2008 by the Division of Water Quality ("DWQ") to PPG Industries Fiber Glass Products, Inc. ("PPG"). The Notice of Violation alleged that PPG's April 2008 self -monitoring report described an oil and grease effluent limit excursion of the permitted daily maximum value. PPG immediately investigated the matter upon receiving the sample report from Pace Analytical Labs. No upsets or abnormalities were found relating to the wastewater influent, PPG wastewater operations, or testing procedures performed by the lab. A "Root Cause Analysis" was conducted by a team of PPG technicians and engineers. Based on the results of our investigation of the oil and grease sample result, PPG has taken the following actions. The daily addition of Bentonite Clay in the waste water treatment process has been increased from 200 lbs. to 300 lbs. This change increases the efficiency of oil and grease removal from the wastewater due to inadvertent exposure of oil and grease containing materials. Also manufacturing and maintenance procedures have been revised to reduce the possibility of materials containing oil to enter into the wastewater collection system. To date, all subsequent sampling results for oil and grease have been within permitted limits excluding a similar excursion which occurred during the investigation period on May 7, 2008. In summary, PPG believes that the excursion experienced on April 9, 2008 and May 7, 2008 were most likely attributable to isolated instances of wastewater contamination and did not represent the effluent or any upset with the wastewater process. PPG promptly investigated and corrected the conditions thought to have contributed to this contamination. Subsequent sampling results have been compliant, and PPG believes that this issue has been adequately corrected. PPG requests that the DWQ consider this matter resolved and not pursue further actions. If you have any questions or concerns, please contact Richard Young at (704) 434-2261 extension 359. Sincerely, Timothy G. Mathis Manufacturing Manager Cc: Richard Young OF W ATF9 Michael F. Easley, Governor i i A William G. Ross Jr., Secretary rNorth Carolina Department of Environment and Natural Resources r Coleen H. Sullins, Director Division of Water Quality August 6, 2008 CERTIFIED MAIL 7007 1490 0004 4509 5980 RETURN RECEIPT REQUESTED Mr. Richard M. Young Senior Environmental Engineering Associate PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Notice of Violation - Effluent Limitations Tracking #: NOV-2008-LV-0376 Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Young: A review of the April 2008 self -monitoring report for the subject facility revealed a violation of the following parameter: Outfall Date Parameter Reported Value Permit Limit 001 4/9/08 Oil & Grease 33.4 mg/L 15.0 mg/L (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at 704/663-1699. Sincerely, oo Robert B. Krebs Regional Supervisor Surface Water Protection cc: Point Source Branch Cleveland County Health Department ®"AMA Novi t hCarolina NCDENR (Naturally Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: www.ncwaterguality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper PPG Industries Fiber Glass Products, Inc. Timothy G. Mathis Manufacturing Manager Fiber Glass Products February 5, 2008 Mr. Robert B. Krebs Surface Water Protection Regional Supervisor Division of Water Quality, NC DENR Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 940 Wash ok"C'>. C I . , •.z, AID e. j F E B 7 2008 SENT VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED M-Surf ce Water Protection Re: Notice of Violation — Effluent Limitations Tracking #: NOV-2008-LV-0033 PPG Industries Fiber Glass Products, Inc. - WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Krebs: This letter is in response to the Notice of Violation issued on January 17, 2008 by the Division of Water Quality ("DWQ") to PPG Industries Fiber Glass Products, Inc. ("PPG") Shelby, North Carolina facility. The Notice of Violation was for a reported value of total residual chlorine from outfall 002 on July 5, 2007 in excess of the daily maximum permit limit. PPG's permit requires semi-annual monitoring of outfall 002, including the total residual chlorine parameter. On July 5, 2007, a sample was collected and transported to a contract laboratory for analysis. The total residual chlorine parameter was inadvertently not measured in the field at the time of sampling, rather was measured after it was transported to the laboratory. The sampling results for the total residual chlorine parameter are invalid for this sampling event because the sample was not processed within the 15-minute hold time specified in EPA Method 330.5. Sampling was repeated on October 19, 2007 which included field measurement of total residual chlorine within the prescribed 15-minute hold time. Amended results for total residual chlorine were submitted along with the October 2007 Discharge Monitoring Report (see attachment). Results from the re -sampling were within permitted limits for total residual chlorine. Procedures have been developed to ensure that future sampling events for total residual chlorine will be conducted on site by a certified technician in the presence of a certified NPDES operator, to ensure that sampling and hold -time requirements per Method 330.5 are fully met. Procedures have also been revised to prevent chlorine contamination of sampling equipment from city water or other sources. In summary, the initial sampling event for total residual chlorine was invalid because it was not measured in the field to meet the analytical method's 15-minute hold time requirement. The subsequent sampling event, conducted properly in the field within the 15-minute requirement was compliant with the permit limit. Measures have been implemented to ensure proper field analysis for future sampling events. PPG requests that DWQ consider this matter resolved. If you have any questions or concerns, please contact Richard Young at (704) 434-2261 extension 359. Sincerely, G��e,:Z AI Timothy G. Mathis Manufacturing Manager Cc: Richard Young L9 PPG Industries Fiber Glass Products 940 Washburn Switch Road Shelby, North Carolina 28150 Tim Maoris Manufacturing Manager Fiber Glass Products 704-434-2261 ext. 206 Attention: Central Files Division of Water Quality 1617 Dail Service Center Raleigh, NC 27699-1617 Sent Via Certified Mail Return Receipt Requested Fax 704-434-5851 November 29, 2007 In. compliance with our NPDES permit, #NC0004685, find attached the original and one photocopy of the Discharge Monitoring Report for the month of October, 2007. Both include a copy of the required quarterly whole effluent toxicity testing results. Please note that the original toxicity report was sent to the Aquatic Toxicity Unit. Also included is an AMENDED copy along with a photocopy of the July 2007 Discharge Monitoring Report. If there are any questions regarding this report, please contact Rita Haynes at (704) 434-2261 extension 493. Sincerely; Tim Mathis cc: WWT? ®RC Bob Stein File NPDES PERMIT NO. NC0004685 EFFLUENT DISCHARGE NO. -001 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS OPERATOR IN RESPONSIBLE CHARGE (ORC) Billy McFarland CERTIFIED LABORATORIES (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, INC MONTH COUNTY October YEAR 2007 CLEVELAND GRADE III PHONE (2) PACE LABORATORIES, INC 704-434-2261 CHECK BOX IF ORC HAS CHANGED Mail ORIGINAL and ONE COPY to: ATTN: CENTRAL FILES DIVISION OF WATER QUALITY 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617 PERSON(S) COLLECTING SAMPLES OPERATORS ,/� X //:. "'-' e'L,, (SIGNATURIf OF OPERATOR IN RESPONSIBLE CHARGE) DATE BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. Q E -E co AN 0 o E P 5 0 y o` ° 50050 00010 OD400 00310 00610 31616 00300 1 00530 01042 01092 01051 00940 00951 00556 FLOW �� w � n v w = c. o N � ❑ ❑ m ? 2 Z 0 0 JO o c� 5 Q o �� w u - w X o w 3 (nn En o w ww w o wy �� ° d O. O V z 1V Q W J Lu ❑_ O = U p O lL U) Q C7 J O EFF INF O�? HRS HRS Y/BM MGD °C UNITS mg/L Ibs/day mg/L Ibs/day #/100mL mg/L mg/L mgl mgl mgl mg/L mg/L mg/L 0 64' • 42 0700 8.5 B 0.67 6.1 6.6 00; 8 `5 ' B L233.3 65 . <2'.0 ;<8 8 . <0;10 <44':2 5.0?. 6 5';' ,.<3.3'G; -:0 0058.. 0:01`4, c5 0. 1'40 +0' 59 4 0700 8.5 B 0.54 6.3 6.5 -Z 55 _-:6 6 0655 4.0 B 0.61 7 `:0655 4 0 B 0 51 8 0700 8.5 B 0.49 25.01 6.4 5.8 „ . B$ 0 58 _ 23 9 6 5 ,.. _ ... 10 _ 0700 8.5 B 0.51 24.5 6.5 <2.0 <8.5 <0.10 <42.5 1.0 6.1 <1.1 0.46 5.7 ``-11 ;'•0600, , 9 5 B .:�0 50 '; `23 6 `.,.6 6 12 0700 8.5 B 0.52 22.0 6.6 6.6 13 ;;0600 4 0" B ,,1 0 53 14 0700 4.0 B 0.46 �15 0700 85% BR'`049 ,-2 5. `64 16 0700 8.5 B 0.49 22.3 6.6 6.5 17, Q700 .8.5„- B : ,!: 0 54='' `22'9 ;`6 7•, z2 0 ,<9, 0 , <0: I'0 <45 0 .r2.0': 6:3',. <11.7 z =0 0068 ."0;0.43 266 :041 18 0700 8.5 B 0.49 23.6 6.5 6.3 1 '4700 8.5;? B' °'0 41.:=. ' 23 5: :6 5 20 0700 4.0 B 0.59 " s0555 22 0700 8.5 B 0.67 23.4 7.0 7.1 245 -12 8 B -°A°55 ..23 4_ ' °6 4 " 7:4,'`. ` 24 0700 10.5 B 0.59 23.2 6.1 <2.0 <9.8 <0.10 <49.2 1.0 7.4 <1.0 0.62 <5.0 25 :-0.700 :8.5" B . '-.0 64, , =.22.7 ' :6 3 26 0700 8.5 B 0.53 21.7 6.3 7.4 -B 0:52 28 0655 4.0 B 0.42 29' ' 0700. 8.5; B ; '0 41 , 20 4'' Sc4 - 30 0700 8.5 B 0.48 20.2 6.1 8.1 31-';.0700' ,:8:5-` :B.' :0.48 ::.20:0;'6:3' •<2:0 <80' <010. <40:0 -:.30.0 7:8` <1:Or";. 0.53 -<5.0 AVERAGE 0.53 23.0 0 0 0 0 3 6.7 0 0.0063 0.029 0 203 0.52 1.1 MAXIMUMI =: ,- '.0.6.T 25.1 ` :.7 0 ; ; <2'0 <9.8 • <0 10 • <49.2 : .30 0 8.4„ . • <3.3 , : 0:0068' ; `0.043 ' <5.0, 266 `0.62 ' S.7 MINIMUM 0.41 20.0 6.1 <2.0 <8.0 <0.10 <40.0 1.0 5.7 <1.0 0.0058 0.014 <5.0 140 0.41 <5.0 Comp.'(C) Grab (G) _.a' ' . G G -,:C , ;..5: C `C ;:, .. G Monthly Avg. Limit 20 217 6 65 20 10 Weekly Avg.,Limit- Daily Maximum Limit 1.3 6-9 30 325.5 9 1 97.5 >- 146 5.4 15 DEM Form MR-1 (01100) EFFLUENT (QUARTERLY) NPDES PERMIT NO. NC0004685 DISCHARGE NO. 001 MONTH October YEAR 2007 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS III COUNTY CLEVELAND OPERATOR IN RESPONSIBLE CHARGE (ORC) Billy McFarland GRADE 111 PHONE 704-434-2261 CERTIFIED LABORATORIES (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, INC (2) PACE LABORATORIES, INC (3). R&A Labs CHECK BOX IF ORC HAS CHANGED F__] PERSON(S) COLLECTING SAMPLES OPERATORS Mail ORIGINAL and ONE COPY to: ATTN: CENTRAL FILES /% c r,• 7 /�7 _ DIVISION OF WATER QUALITYc� pt' c�t�t Cf�ic ��Y�-�' 1617 MAIL SERVICE CENTER (SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE RALEIGH, NC 27699-1617 BY THIS SIGNITURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. 50050 00600 00665 TGP38 FLOW E w w 0-FM , m 0 p Q W F Y m u > o O E �, 0 J a 0 INF � R c o F o` Z a Q mN R �W a ~0 0 o O a m 0 0 a~ O HRS HRS Y/B/N MGD mg/L mg/L P/F 2 0700 8.6 B 0.67 ' 4 0700 8.5 B 0.54 � �0 �' `�'P, � „_� y.:�, � � � `_-•.,w,s �f ^; L �' � � ' ` 4 ��.5 0700 v E8 5,, �' Bt k` 55, s, r � '� r. ,.s ;'� w-�f ,.� ,.� :i. ,. 0 B 0.61 i,7 777 77777 8 0700 8.5 B 0.49 4 10 0700 8.5 B 0.51 12 0700 8.5 B 0.52 }� / "�".," j..�;`; s '; �:...'�.,��..'•�' �,y' ?.. {`tt.N $ I,,kts �Ot00t}'�40� r`Brx', Q'3., `' ,.r ,`,v� �'.`, .�.r`I .':,��".`. rz 14 0700 4.0 B 0.46 _ ' t r 16 0700 8.6 B 0.49 17 0700 � jg 5`� g D 0`54 ! ; ' I . , ' ° .,�: * " ; ° . , . y .. A 3 x r: 18 0700 8.5 B 0.49 ^.:,;.a""�; r r.`rr.' 'r rA � i i, ILL F,... - :-,s t..9 . yr , , .�d Y _ 20 0700 4.0 B 0.59 22 0700 8.5 B 0.57 �tlOYiSi ' ✓ a� t !� ' t 23 1F.:$ B! ,G. r 0�55 �r _ n;:, r 24 0700 10.5 B 0.59 26 0700 8.5 B 0.53 28 0655 4.0 B 0.42 �29 07,DO 85 B z_ 30 0700 8.5 B 0.48 31 ''0700 85 a 0 4.8 4` AVERAGE 0.53 7.5 0.16 , MAXIMUM 0:67 .; 7.:5, 016" MINIMUM 0.41 7.5 0.16 Comp (C)�Grab,(G)„k% £• C., ',<C ;_C, <, w - , � s �_ Monthly Avg. Limit WeeklylAvg'' ON s ; Daily Maximum Limit 1.3 ucwN rorm NvIK-I tu-uuu) EFFLUENT (STORMWATER - ®UTFALL 4 002) NPDES PERMIT NO. NC0004665 DISCHARGE NO. 002 MONTH October YEAR 2007 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS III COUNTY CLEVELAND , OPERATOR IN RESPONSIBLE CHARGE (ORC) Billy McFarland GRADE III PHONE 704-434-2261 CERTIFIED LABORATORIES (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, IP (2) PACE LABORATORIES, INC (3) R&A Labs CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES OPERATORS Mail ORIGINAL and ONE COPY to: ATT: CENTRAL FILES _ DIVISION OF WATER QUALITY %4✓ �f °� 1617 MAIL SERVICE CENTER (SIGNATUR19 OF OPERATOR IN RESPONSIBLE CHARGE) DATE RALEIGH, NC 27699-1617 BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. MEMO mmo = M77. im m mm� mm�.=■■ =��mmmm� m =�mmmom mmmemomm, --mm _ -;--� ES� 0 ------------------------- . _ OEM Foy MR-1 (01/00) Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 10/11/07 Facility: PPG, INDUSTRIES NPDES#: NC0004685 Pipe#: 001 County: CLEVELAND Laboratory Performing Test:., R & A LABORATORIES, INC. Comments: Final Effluent Sig afro e erator in Responsible charge An AWARE Environmental Project c X - gnat re of-'LaQboratory Supervisor * PASSED: 3.57% Reduction Work Order: 600704/60100 Environmental Sciences Branch MAIL ORIGINAL TO: Div. of Environmental Management N.C. Dept. of EHNR 1621 Mail Service r-tr Raleigh, North Carolina 27699-1621 I forth Carolina cerioaapnnia Chronic Pass/Fail Reproduction Toxicity Test 1 2 3 4 5 6 7 8 9 10 11 12 # Young Produced 25 21 23 25 24 22 23 23 22 24 25 23 Adult (L) ive (D) ead L L L L L L L L L L L IL Chronic Test Results Calculated t = 1.307 Tarul:a-- t - 2 . 5;08 Reduction = 3.57 Mortality Avg.Reprod. 0.00 23.33 Control Control 0.00 22.50 Treatment 2 Treatment 2 'REATMENTV2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV 5.5836 PASS FAIL # Young Produced 20 22 23 25 21 25 21 24 23 24 20 22 % control orgs X producing 3rd brood Check90ne Adult (L) ive (D) ead L L L L L IL L L L L L L 11 100 1st sample lst sample 2nd sample Complete This For Either Test PH Test Start Date: 10/03/07 Control 6.94 7.01 6.93 7.03 6.94 6.99 Collection (Start) Date Sample 1: 10/01/07 Sample 2: 10/04/07 Treatment 2 6.83 6.92 6.82 6.93 6.89 6.93 Sample Type/Duration 2nd s s s Grab Comp. Duration D t e t e t e I S S a n a n a n Sample 1 X 24 hrs L A A r d r d r d U M M t t t Sample 2 X 24 hrs T P P 1st sample 1st sample 2nd sample D O Hardness (mg/ 1) 4 8 Control 8.5 8.4 8.6 8.3 8.6 8.4 . Treatment 2 8.1 8.0 8.6 8.3 8.6 8.4 Spec. Cond.(µmhos) 182 604 659 Chlorine (mg/1) ........ 0 . 07 0 . 03 LC50/Acute Toxicity Test Sample temp. at receipt(°C) ,,...... 3.0 3.2 (Mortality expressed as combining replicates) Note: Please Concentration Complete This Section Also % - - - - Mortality start/end start/end LC50 = % Method of Determination 95% Con i ence Limits Moving Average Probit % -- % Spearman Karber _ Other Control High PH Organism Tested: Ceriodaphnia dubia Duration(hrs): D.O. Copied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32) NPOEGNo NCD004885 DISCHARGE NO 001 MONTH October YEAR 200 GLASS ''~^'-'' --- PPG INDUST-FIBER STREAM BRUSHY CREEK STREAM BRUSHY CREEK LOCATION NCSR-1323 LOCATION NCSR-1305 Upstream Downstream UMMMMMMOMMMM MMMMMMEMMMMM MMMMMMEMMMM mE Im DEM Form MR-3 (01/00) LL tw 21-4 10 01 Facility Status: (Please check one of the following) All monitoring data and sampling frequencies meet permit requirements Compliant All monitoring data and sampling frequencies do NOT meet permit requirements Noncompliant If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc., and a time table for improvements to be made. "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Tim Mathis Permittee (Please print or type) Signature of Permittee** Date (Required) 940 WASHBURN SWITCH ROAD 704-434-2261 Permit # NC0004685 Permittee Address Phone Number SHELBY, NORTH CAROLINA 28150 Expiration date: 8/31/2008 PARAMETER CODES 00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver 00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc 00082 Color (ADMII) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum Nitrogen 00095 Conductivity 00630 Nitrates/Nitrites 01032 Hexavalent Chromium 01147 Total Selenium 00300 Dissolved Oxygen 00310 BOD5 00340 COD 00400 pH 00530 Total Suspended Residue 00545 Settleable Matter 00665 Total Phosphorous 00720 Cyanide 00745 Total Sulfide 00927 Total Magnesium 00929 Total Sodium 00940 Total Chloride 01034 Chromium 01307 Total Cobalt 01042 Copper 01045 Iron 01051 Lead 01062 Molybdenum 31616 Fecal Coliform 32730 Total Phenolics 34235 Benzene 34481 Toluene 38260 MBAS 39516 PCBs 50050 Flow Total Residual Chlorine 50060 Formaldehyde 71880 Mercury 71900 Xylene 81551 Parameter Code assistance may be obtained by calling the Point Source Compliance/Enforcement Unit at (919) 733-5083 or by visiting the water Quality Section's web site at h2o.enr.state.nc.us/wqs and linking to the Unit's information pages. Use only units designated in the reporting facility's permit for reporting data. x ORC must visit facility and document visitation of facility as required per 15 A NCAC 8G .0204. — If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506. (b) (2) (D)• EFFLUENT -NPDES PERMIT NO. NC0004685 DISCHARGE NO. 001 MONTH July YEAR 2007 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS III COUNTY CLEVELAND OPERATOR IN RESPONSIBLE CHARGE (BORC) Billy McFarland GRADE III PHONE CERTIFIED LABORATORIES (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, INC (2) PACE LABORATORIES, INC CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES OPERATORS Mail ORIGINAL and ONE COPY to: ATTN: CENTRAL FILES®� DIVISION OF WATER QUALITY X6i�u�i 1617 MAIL SERVICE CENTER (SIGNATU OF OPERATOR IN RESPONSIBLE CHARGE) RALEIGH, NC 27699-1617 BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. 704-434-2261 DATE 50050 00010 00400 00310 00610 31616 00300 00530 01042 01092 01051 00940 00951 00556 FLOW ;) o Z 0 z p p W Q EFF N N a J o 0: Q EW o Qj3 o O ui gi a. Z O = C7 N N N d CC G U O E Q O Q III Q /O� U rq J J� a o O m w C7 In U LL J_ HRS HRS YIBIN MGD c UNITS mg/L Ibs/day mg/L Ibs/day #I100mL mg/L mg/L mg] mgl mgl mg/L mg/L mg/L ::::':::�:::::::::::::::::: :::::::::::::::::::::::::::':;:;:: 2 1 0700 8.5 B 1 0.42 26.8 1 6.5 7.5 ... :::D7Q0.::..$:.:8.54:2�v; ....... .... ;63[:` .......... 7>5 ['I€€ ....... ..................... . 4 0600 9.5 B 0.54 26.0 6.4 7.9 -::.: :5:::C36(fQ:::::8:5:s� 441 ..............>0.......7................ .s8'. .. 1�7.....p,(iz. ................ Qp.i$ ....5.......1$ ........ . .. ...1,1..........E .. 6 0700 8.5 B 0.53 27.5 6.8 7.4 :::q QQ .4 I IN ...a�....... ............ .............. 8 0700 4.0 N 0.47 :9:::f#7t3Q$5iBi 7;t3::6 1 o 0700 8.5 B 0.54 27.1 6.6 8.1 :::8,:5: 4 8.5 B 0.49 27.0 6.0 7.4 r12 ::::8:......... j .9.5 B 0.50 95 is€N.fl 4 ................... ............. . 16 0700 8.5 B 0.44 25.3 6.9 7.5 18 0700 8.5 B 0.53 26.6 6.9 <2.0 <8.8 <0.10 <0.44 1.0 7.4 <2.0 0.012 0.039 190 0.81 <5.0 20 0700 8.5 B 0.61 25.6 6.6 7.5 21: ':Ofi(TO i . ..: it. i ' :4ff i f. ............................... ............... .............. 22 0600 4.0 N 0.53 p23 :::i}70 €i$5::is.:€:il;p::::: E:21:;3.::::.6•.;�� :::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::....... .4 ....... ............................... [ ................ . 241 0700 8.5 B 0.52 25.0 1 6.7 7.0 . ......... ... DOE,5.2:::: '60::::::7>2::..:.:.:3�3 .:..:.:.:.:.:.:.:.:..:................................................... �........... 261 0700 11.5 B 0.62 22.7 6.6 7.3 281 0555 4.1 B 0.58 30 0700 8.5 B 0.54 26.3 6.4 7.0 .•.:::.:(#7(3p:::::85::::::8:::::::.Q.s�5:::::::26� 1:::: � �4:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::...:.:.: <...:..:.:...:...:....:.,.:.........:................................................................... . AVERAGE 0.51 25.9 0 0 0 0 2 7.5 0.58 0.012 0.029 0 190 1 0.77 0 <0�52:: MINIMUM 0.41 21.3 6.0 <2.0 <8.8 <0.10 <0.44 1.0 7.0 <1.7 0.012 0.018 <5.0 190 0.53 <5.0 �. �5.:.:.::.:.:�:.:..:.....C............�.........G :...................................:.:...:.:.::.:.:..:.:.::....:.:..:.:.:c:.:.:..:.:.:.c:::.::::::::c:.::::::::::c::::::::::::::::::::::::......::.....:.:. ........................... Monthly Avg. Limit 20 217 6 65 20 10 v . k y: �iii[ i`:� Daily Maximum Limit 1.3 6-9 30 325.5 9 97.5 >- - 146 5.4 15 DEM Form MR-1 (01100) EFFLUENT (QUARTERLY) NPDES PERMIT NO. NC0004685 DISCHARGE NO, 001 MONTH July YEAR 2007 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS III COUNTY CLEVELAND OPERATOR IN RESPONSIBLE CHARGE (ORC) Billy McFarland GRADE 111 PHONE 704-434-2261 CERTIFIED LABORATORIES (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, INC (2) PACE LABORATORIES, INC (3) R&A Labs CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES OPERATORS Mail ORIGINAL and ONE COPY to: �j ATTN: CENTRAL FILES DIVISION OF WATER QUALITY Xv�'' ✓ ��- "� �j�� 1617 MAIL SERVICE CENTER (SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE RALEIGH, NC 27699-1617 BY THIS SIGNITURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. 11111111111 • • u MKIT mil 1 11 m��_______-______ 0 1 11 ' NPOESNO NCO004685 DISCHARGE NO 001 MONTH July YEAR 2007 FACILITY NAME PPG INDUSTRIES FIBER GLASS PRODUCTS, INC. COUNTY CLEVELAND STREAM BRUSHY CREEK LOCATION NCSR-1323 Upstream STREAM _ LOCATION 2 L 10 121 141 ri, , 18 1125,2 81 8.41 53.1 r4. 22 24 26 281 �� BRUSHY CREEK Downstream ��l�% ream PA 8.0 77.7 Facility Status: (Please check one of the following). All monitoring data and sampling frequencies meet permit requirements Compliant All monitoring data and sampling frequencies do NOT meet permit requirements Noncompliant If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc., and a time table for improvements to be made. "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Tim Mathis Permittee (Please print or type) Signature of Permittee** (Required) Date 940 WASHBURN SWITCH ROAD 704-434-2261 Permit # NC0004685 Permittee Address Phone Number SHELBY, NORTH CAROLINA 28150 Expiration date: 8/31/2008 PARAMETER CODES 00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver 00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc 00082 Color (ADMIT) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum Nitrogen 00095 Conductivity 00630 Nitrates/Nitrites 01032 Hexavalent Chromium 01147 Total Selenium 00300 Dissolved Oxygen 00310 BODS 00340 COD 00400 pH 00530 Total Suspended Residue 00545 Settleable Matter 00665 Total Phosphorous 00720 Cyanide 00745 Total Sulfide 00927 Total Magnesium 00929 Total Sodium 00940 Total Chloride 01034 Chromium 01307 Total Cobalt 01042 Copper 01045 Iron 01051 Lead 01062 Molybdenum 31616 Fecal Coliform 32730 Total Phenolics 34235 Benzene 34481 Toluene 38260 MBAS 39516 PCBs 50050 Flow Total Residual Chlorine 50060 Formaldehyde 71880 Mercury 71900 Xylene 81551 Parameter Code assistance may be obtained by calling the Point Source Compliance/Enforcement Unit at (919) 733-5083 or by visiting the water Quality Section's web site at h2o.enr.state.nc.us/wqs and linking to the Unit's information pages. Use only units designated in the reporting facility's permit for reporting data. * ORC must visit facility and document visitation of facility as required per 15 A NCAC 8G .0204. '* If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b) (2) (D). Michael F_ Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen Sullins_ Director Division of Water Quality January 17, 2008 CERTIFIED MAIL 7006 2760 00018497 6339 RETURN RECEIPT REQUESTED Mr. Tim Mathis Manufacturing Manager, PPG Industries 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Notice of Violation - Effluent Limitations Traclldng #: NOV-2008-LV-0033 PPG Industries WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Mathis: A review of the July 2007 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter Reported Value 002 total residual chlorine 950 ug/l (daily maximum) Permit Limit 28 ug/l (daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699. cc: No Carolina Ntura!!y Point Source Branch Cleveland County Health Dept. Sincerely, Robert B. Krebs Surface Water Protection Regional Supervisor N_ C_ Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Richard Young Sr. Engineer Associate, Environmental Fiber Glass Products 704-434-2261 ext. 359 Fax 704-434-0792 richardyoung@ppg.com OFF August 31, 2007 REGIONAL E1VED Ms. Donna Parker NC Department of Environment and Natural Resources SEP 0 42007 Division of Water Quality 610 East Center Ave. Mooresville, NC 28115` SENT VIA CERTIFIED MAIL Subject: Industrial Wastewater Spill Response Evaluation — 08/27/07 NPDES Permit: NC0004685 On 08/27/07, the PPG Industries Fiber Glass Products Inc., Works 52, ("PPG") spilled approximately 255 gallons of untreated process wastewater when a containment around a wastewater settling tank located beside the manufacturing plant overflowed at rate of approximately .5 gallons per minute for 8.5 hours. The spillage migrated across an outdoor concreted area into a Stormwater catch basin. From that point the flow continued through the underground storm water system where it merged with recent storm water and non -contact cooling water. After approximately 3,000 feet of travel the stormwater pipe drained into an unnamed tributary of Beaverdam Creek. Approximately 300' below this merger the tributary flowed through a 24" valve station then onward approximately 70' where it flowed off -site through PPG Stormwater Outfall #002 and downstream to Beaverdam Creek. The low volume overflow began at approximately 1:00 AM and remained undetected until 9:30 AM when the Waste Water Treatment Plant (WWTP) "Operator in Responsible Charge" and I found the overflow. We immediately diverted the upper section of the storm water line to the pre -designated WWTP holding pond and closed the 24" valve station near Outfall #002 ending the spill. We inspected the spill area, the storm water system and Beaverdam Creek where some cloudiness was found. Continuing the investigation a determination was made that the wastewater spill was a non -hazardous substance and the volume discharged into Beaverdam Creek was approximately 200 gallons. "ll At approximately 5:30 PM a Spill Recovery Contractor arrived on -site and transferred the spill contaminated water above Outfall #002 to the WWTP holding pond and the 24" valve station was reopened. The noncompliance has been corrected; the spill residual was cleaned up, the surface water was monitored for 24 hours and is still being monitored during rainfall events. Presently there have been no odors, or visual impact to the stream including vegetation and aquatic life. The cause was determined to be a restricted drain line from the wastewater settling tank along with a failure of the tank's high level electronic sensor that activates a visual alarm inside the manufacturing plant in an operator manned area. The sensor did not operate due to residual build up. Steps have been taken and are planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. They include the following; 1- The separator tank has been cleaned and drain line cleared. 2- The electronic sensor has been replaced with a mechanical float switch. 3- PPG is conducting an evaluation of the wastewater drain process and plans to make modifications if improvements are deemed possible. If you have any questions regarding this incident, please feel free to contact me at (704) 434- 2261 x 359. Sincerely, Richard Young Environmental Engineer cc: G. Mcinnis S. Franklin J. Patel B. McFarland P. Pride T. Mathis File PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Richard Young 704-434-2261 ext. 359 Sr. Engineer Associate, Environmental Fax 704-434-0792 Fiber Glass Products richardyoung@ppg.com July 11, 2007 �� 6�AT0;-,F`L F,-7CCk1RCE:3 Ms. Donna Parker NC Department of Environment and Natural Resources f JUL 1 200? Division of Water Quality 610 East Center Ave. Mooresville, NC 28115 E RATER QUALRY SE00 P SENT VIA CERTIFIED MAIL Subject: Post Oil Spill Analytical Soil Sample Results NPDES Permit: NC0004685 On the afternoon of May 16, 2007 at approximately 3PM an oil spill incident occurred at the PPG Industries Fiber Glass Products Facility (PPG) in Shelby NC. An old transformer / regulator labeled "Contains No PCB's" was being removed from the site by contractors when they accidentally rupture a hole in one of the cooling veins with their heavy equipment. Approximately 165 gallons spilled puddling into a depression where the transformer had been resting. The free liquid was immediately recovered. Visually the oil did not spread out or make contact with water nor was it near any surface water points. Oil samples were sent out to verify there was no detectible prescience of PCB. Test results were received back the following day 5/17/07 indicating that the oil contained 6 ppm 1260 PCB; therefore the spill did not trigger a Hazardous Waste or PCB Reportable Spill. It was determined the spill required Notice per "NC General Statutes - Chapter 143 Article 2 1 A 143-215.85" at that point on May 18 at approximately 4 PM the spill was reported to the NC Emergency Management Communication Center by phone and immediately thereafter yourself. Upon our conversation you requested that I send you the results of soil analysis from the spill point after clean up. Enclosed find a complete copy of these results as received from PACE Analytical Services. Under supervision of a Senior PPG Engineer a full service environmental contractor "HEPACO" removed the contaminated soil down to a level one foot below the last visual observation where contaminated soil was present. The contaminated soils were appropriately disposed of at a permitted landfill. These actions were followed as recommended by Tetra Tech an environmental consulting firm who assisted PPG with direction for the clean up. The returned analytical report indicates "No Detection" of PCB, Oil or Grease. Because of this no detection report and nothing further visually was detected we believe we adequately have cleaned up the discharge. If you have any questions regarding this incident, please contact me at (704) 434-2261 x 359. Uncrely, Richard oung cc: file aceAnalytical® www.pacelabs.com June 12, 2007 Mr. Richard Young PPG Industries 940 Washburn Switch Rd Shelby, NC 28150 RE: Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Dear Mr. Young: Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 704.875.9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax: 828.252.4618 Enclosed are the analytical results for sample(s) received by the laboratory on May 30, 2007. Results reported herein conform to the most current NELAC standards, where applicable, unless otherwise narrated in the body of the report. Inorganic Wet Chemistry and Metals Analyses were performed at our Pace Asheville laboratory and Organic testing was performed at our Pace Charlotte laboratory unless otherwise footnoted. The results relate only to samples in this report. If you have any questions concerning this report please feel free to contact me. Sincerely, Annette Scott annette.scott@pacelabs.com (704) 875-9092 ext. 233 Project Manager Enclosures Asheville Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC 37712 without the written consent of Pace Analytical Services, Inc. 99030 N ACCOR FL NELAP E87648 mphr t Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 Sc 99006 FL NELAP E87627 aceAnalytical ° www.pacelabs.com Solid results are reported on a dry weight basis Lab Sample No: 928446103 Client Sample ID: SOIL TEST Parameters Wet Chemistry Percent Moisture Percent Moisture GC Semivolatiles Organochlorine PCBs PCB-1016 (Aroclor 1016) PCB-1221 (Aroclor 1221) PCB-1232 (Aroclor 1232) PCB-1242 (Aroclor 1242) PCB-1248 (Aroclor 1248) PCB-1254 (Aroclor 1254) PCB-1260 (Aroclor 1260) Decachlorobiphenyl (S) Date Extracted Oil & Grease in Soil Oil and Grease Date: 06/12/07 Asheville Certification IDs NC Wastewater 40 NC Drinking Water 37712 SC 99030 FL NELAP E87648 Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 704.875.9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax., 828.252.4618 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Project Sample Number: 92145508-001 Date Collected: 05/25/07 14:30 Matrix: Soil Date Received: 05/30/07 11:20 Results Units Report Limit DF Analyzed By CAS No. Qual RegLmt Method: % Moisture 9.0 % Prep/Method: EPA 3545 / EPA 8082 ND ug/kg 36. NO ug/kg 36. NO ug/kg 36. ND ug/kg 36. NO ug/kg 36. ND ug/kg 36. ND ug/kg 36. 66 % 05/30/07 Method: EPA 9071E 2500 mg/kg 180 1.0 05/30/07 14:21 KDF 1.1 05/31/07 10:38 JEM 12674-11-2 1.1 05/31/07 10:38 JEM 11104-28-2 1.1 05/31/07 10:38 JEM 11141-16-5 1.1 05/31/07 10:38 JEM 53469-21-9 1.1 05/31/07 10:38 JEM 12672-29-6 1.1 05/31/07 10:38 JEM 11097-69-1 1.1 05/31/07 10:38 JEM 11096-82-5 1.0 05/31/07 10:38 JEM 2051-24-3 05/30/07 1.1 06/11/07 15:18 DVS REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. O N 0.C�pgO Page: 1 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 �lacieAnalyticalo www.pacelabs.com PARAMETER FOOTNOTES Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 704.875.9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax: 828.252.4618 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Dilution factor shown represents the factor applied to the reported result and reporting limit due to changes in sample preparation, dilution of the extract, or moisture content Method 9071B modified to use ASE. All pH. Free Chlorine, Total Chlorine and Ferrous Iron analyses conducted outside of EPA recommended immediate hold time. Depending on the moisture content the PRLs can be elevated for all soil samples reported on a dry weight basis. 2-Chloroethyl vinyl ether has been shown to degrade in the presence of acid. ND Not detected at or above adjusted reporting limit NC Not Calculable J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit MDL Adjusted.Method Detection Limit (S) Surrogate Date: 06/12/07 Asheville Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC 37712 without the written consent of Pace Analytical Services, Inc. 99030 FL NELAP E87648 AC�pq . \a'vyC Page: 2 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 Pace Analytical Services, Inc. Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 2225 Riverside Drive Huntersville, NC 28078 Asheville, NC 28804 Analytical ® Phone: 704.875.9092 Phone: 828.254.7176 ,, Fax: 704.875.9091 Fax: 828.252.4618 www.pacelabs.com QUALITY CONTROL DATA QC Batch: 190156 QC Batch Method: EPA 3545 Associated Lab Samples: 928446103 METHOD BLANK: 928446939 Associated Lab Samples: 928446103 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Analysis Method: EPA 8082 Analysis Description: Organochlorine PCBs Blank Reporting Parameter Units Result Limit Footnotes PCB-1016 (Aroclor 1016) ug/kg NO 33. PCB-1221 (Aroclor 1221) ug/kg NO 33. PCB-1232 (Aroclor 1232) ug/kg ND 33. PCB-1242 (Aroclor 1242) ug/kg NO 33. PCB-1248 (Aroclor 1248) ug/kg NO 33. PCB-1254 (Aroclor 1254) ug/kg NO 33. PCB-1260 (Aroclor 1260) ug/kg NO 33. Decachlorobiphenyl (S) % 74 LABORATORY CONTROL SAMPLE: 928446947 Spike LCS Parameter Units Conc. Result PCB-1016 (Aroclor 1016) ug/kg 166.70 159.7 PCB-1260 (Aroclor 1260) ug/kg 166.70 163.4 Decachlorobiphenyl (S) MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 928446954 928446962 928446103 Spike Parameter Units Result Conc. PCB-1016 (Aroclor 1016) ug/kg 0 183.20 PCB-1260 (Aroclor 1260) ug/kg 22.33 183.20 Decachlorobiphenyl (S) Date: 06/12/07 Asheville Certification IDs NC Wastewater 40 NC Drinking Water 37712 Sc 99030 FL NELAP E87648 LCS % Rec Footnotes 96 98 86 MS MSD MS MSD Result Result % Rec % Rec 102.6 117.1 56 64 138.5 156.1 63 73 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. `N ACCpRO 69 61 RPD Footnotes 13 12 Page: 3 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 Sc 99006 FL NELAP E87627 Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Analytical' Phone: 704.875.909 fax.' 704.875.9091 www.pacelabs.com QUALITY CONTROL DATA QC Batch: 190998 QC Batch Method: EPA 9071B Associated Lab Samples: 928446103 METHOD BLANK: 928487180 Associated Lab Samples: 928446103 Parameter Units Oil and Grease mg/kg LABORATORY CONTROL SAMPLE: 928487198 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax: 828.252.4618 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Analysis Method: EPA 9071B Analysis Description: Oil & Grease in Soil Blank Reporting Result Limit Footnotes NO 170 Spike LCS LCS Parameter Units Conc. Result Rec Footnotes Oil and Grease mg/kg 1333.00 1230 92 MATRIX SPIKE & MATRIX SPIKE DUPLICATE: 928487206 928487214 928483239 Spike MS MSD MS MSD Parameter Units Result Conc. Result Result % Rec % Rec RPD Footnotes Oil and Grease mg/kg 55.28 1474.00 1389 1400 90 91 1 Date: 06/12/07 Asheville Certification IN NC Wastewater 40 NC Drinking Water 37712 SC 99030 FL NELAP E87648 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. JN AC COR a, a Page: 4 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Analytical o Phone: 704.875.909 � fax: 704.875.9091 www.pacelabs.com QUALITY CONTROL DATA QC Batch: 190145 QC Batch Method: Associated Lab Samples: 928446103 SAMPLE DUPLICATE: 928446418 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax: 828.252.4618 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Analysis Method: % Moisture Analysis Description: Percent Moisture 928446103 Parameter Units Result Percent Moisture % 9.000 Date: 06/12/07 DUP Result RPD Footnotes 9.800 9 Asheville Certification IDs REPORT OF LABORATORY ANALYSIS NC Wastewater 40 NC Drinking Water 37712 This report shall not be reproduced, except in full, SC 37712 without the written consent of Pace Analytical Services, Inc. 99030 FL NELAP E87648 H ACCpR Page: 5 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 Sc 99006 FL NELAP E87627 ace Analytical ° www.pacolabs.com QUALITY CONTROL DATA PARAMETER FOOTNOTES Pace Analytical Services, Inc. 9800 Kincey Avenue, Suite 100 Huntersville, NC 28078 Phone: 704.875, 9092 Fax: 704.875.9091 Pace Analytical Services, Inc. 2225 Riverside Drive Asheville, NC 28804 Phone: 828.254.7176 Fax., 828.252.4618 Lab Project Number: 92145508 Client Project ID: Soil Testing 5/25 Consistent with EPA guidelines, unrounded concentrations are displayed and have been used to calculate % Rec and RPD values. LCS(D) Laboratory Control Sample (Duplicate) MS(D) Matrix Spike (Duplicate) DUP Sample Duplicate ND Not detected at or above adjusted reporting limit NC Not Calculable J Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit MDL Adjusted Method Detection Limit RPD Relative Percent Difference (S) Surrogate Date: 06/12/07 Asheville Certification IDs NC Wastewater 40 NC Drinking Water 37712 SC 99030 FL NELAP E87648 REPORT OF LABORATORY ANALYSIS This report shall not be reproduced, except in full, without the written consent of Pace Analytical Services, Inc. µ ACCOA c .Page: 6 of 6 Charlotte Certification IDs NC Wastewater 12 NC Drinking Water 37706 SC 99006 FL NELAP E87627 aneAnalXical' www.pacelahs.com CHAIN -OF -CUSTODY / Analytical Request Document The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately. Section A Section B Section C Page: of Required Client Information: Required Project Information: Invoice Information: I r) 7 Company: r 1r, Report To: Attention: Address- U1 Copy To: Company Name: AEGULAtORYAGENCY.. Address: - I NIPDES r GROUND WATER r DRINKING WATER Email To: Purchase Order No.: Pecs Quote Phone: Fax: .Reference: LIST r RCRA r OTHER Project Name: > Requested Due pall Project manager: A site l DateiTAT: ber: Project Num ]Pace Profile #: 'Locati?n STAT E: Requested Anzflysis:Filte d.(Y/N)- Section D Valid Matrix Codes Required Client Information MATRIX z CODE - 9 0 COLLECTED Preservatives DRINKING WATER DW WT z WATER WW P WASTE WATER SL COMPOSITE COMPOSITE PRODUCT OL S o IUSOLID WP START END/GRAB w 111 OIL AR SAMPLE ID WIPE OT (9 11 0 U) 0 AIR TS (A-Z, 0-9 1,) OTHER LIJ of of U) Q) 0 Sample IDS MUST BE UNIQUE TISSUE 0 w z LU 0 a) 0 ->, 0 Of -I C-) EL 0) C� C TO isn " < < LL < 0 to 0 :E- a) - a) DATE TIME DATE TIME z z :0 E 0 'Pace',Pirojiqct No./ Lab I.D. J 7 2 — — — 1 — —FT- — — — — -- --- — — — — — — 3 — — — — 4- — 5 — — — — — — — — — — — — 7 8 9 10 11 12 ADDITIONAL COMMENTS: RELINQUISHED 1AFFILIATION', E :,'JlME:,, ACCEPTED �FFI]Llkfl6k - d E, TIMt",-• SAMPLE CONDITIONS J3. ti SAMPLER NAME 3 0 o o Z PRINT Name of SAMPLER: E SIGNATURE of SAMPLER: DATE Signed .2 C) Note: By signing this form you are acceolino Par.,', NFT an d. nemte (MMIDDIYY): Cr) 9 w -i— - — P,, n-1161 iui any invoices not para within 3u days. F-ALL-Q-020rev.06, 2-Feb-2007 \o�0F vv r F9QG Michael F. Easley, Governor I William G. Ross Jr., Secret North Carolina Department of Environment and Natural Resources CERTIFIED .MAIL RETURN RECEIPT REQUESTED Mr. Timothy Mathis Manufacturing Manager PPG Industries Fiber Glass Products, Inc. 940 Washburn Road Shelby, NC 28150 Subject: Dear Mr. Mathis: Alan W. Klimek, P.E. Director Division of Water Quality May 17, 2007 70067296(iQ810PR441�jJ42624 Notice of Violation - Effluent Limitation Tracking #: NOV-2007-LV-0264 PPG Industries WWTP" NPDES Permit No. NC0004685 Cleveland County This letter is being reissued because the letter issued on May 16, 2007, contained the wrong Tracking # (NOV-2007-LV-0156); the Tracking # above is correct. A review of the December 2006 self -monitoring report for the subject facility revealed a violation of the following parameters for Outfall 001: Date Parameter Reported Value Permit Limit 12/20/06 Oil & Grease 17 mg/l 15 mg/l (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. Since the comments section on the reverse of the relevant Discharge Monitoring Report provided an explanation for the noted effluent limit violation, it is not requested that a response be submitted; however, should you have additional information concerning the violations or comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. NC®ENR N'co `hCarolina Iaturally Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: wwNv.ncwaterqualiie.or-- 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal OpportunitylAffirmative Action Employer-50% Recycled110% Post Consumer Paper Mr. Tim Mathis NOV-2007-LV-0264 Page 2 If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at (704) 663-1699. Sincerely, Robert B. Krebs Regional Supervisor Surface Water Protection cc: Point Source Branch Cleveland County Health Department MA CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Timothy Mathis Manufacturing Manager PPG Industries Fiber Glass Products, Inc. 940 Washburn Road Shelby, NC 28150 Dear Mr. Mathis: Michael F. Easley, Governor; I�( William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality May 16, 2007 7006 2760 0001 8493 7941 Subject: Notice of Violation - Effluent Limitation Tracking #: NOV-2007-LV-OT-56 0 PPG Industries WWTP NPDES Permit No. NC0004685 Cleveland County A review of the December 2006 self -monitoring report for the subject facility revealed a violation of the following parameters for Outfall 001: Date Parameter Reported Value Permit Limit 12/20/06 Oil & Grease 17 mg/l 15 mg/l (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems Since the comments section on the reverse of the relevant Discharge Monitoring Report provided an explanation for the noted effluent limit violation, it is not requested that a response be submitted; however, should you have additional information concerning the violations or comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. ANA NCDENR Noce ithCarolina Naturally Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service Internet: www.newatergtiality.ora 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal OpportunitylAffirmative Action Employer— 50% Recycled110% Post Consumer Paper Mr. Tim Mathis NOV-2007-LV-0264 Page 2 If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at (704) 663-1699. Sincerely, i Robert B. Krebs Regional Supervisor Surface Water Protection cc: Point Source Branch Cleveland County Health Department Bud Blackwell NC Certifications 573 Henry Jenkins Rd WW Grade 4 195145 Mooresboro, NC 28150 PCC Grade 2 27415 Phone (828) 657-5579 March 30, 2007 Technical Assistance and Certification Unit Jerry Rimmer Supervisor 1618 Mail Service Center Raleigh, NC 27699-1618 Division of Water Quality Donna Hood 610 East Center Ave., Suite 301 Mooresville, NC 28115 SENT VIA CERTIFIED MAIL Subject: Vacating ORC Position NPDES Permit: NC0004685 This letter is being sent to the Commission and the Regional Division of Water Quality per 15 NCAC 08G .0204 (9). Due to my retirement I will be vacating my position as ORC for PPG Industries Fiber Glass Products, Inc. effective 03/31/07. Please contact me if there are any questions. Sine rely, Bud Blackwell cc: Richard Young PPG file Subject: Compliance Evaluation Inspection Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County, North Carolina Dear Mr. Winn: Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on September 15, 2006 by Ms. Donna Hood of this Office. Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ms. Hood or me at (704) 663-1699. Sincerely, . Rex Gleason, P.E. Surface Water Protection Regional Supervisor Enclosure cc: Cleveland County Health Department . DH N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 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 U Si _; 31 . - NC0004685 111 .12I 06/09/15 117 �--� 18I CI 191 cl 201 U !__! Remarks 21111111111.111 11111111111111111111111111111111 1116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA - - --------------------------Reserved--------------------- 67I 1.5 169 701 4 I 71 I I 721 NJ 73I I 174 761 I I I I I I 180 LL Section B: Facility Data - 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) PPG - Shelby facility 09:50 AM 06/09/15 05/12/01 Exit Time/Date Permit Expiration Date 940 Washburn Switch Rd Shelby NC 28150 11:50 AM 06/09/15 08/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Henry F Blackwell/ORC/704-434-2261/ Name, Address of Responsible Official/Title/Phone and Fax Number Todd Winn,940 Washburn Switch Rd Shelby NC 28150/Env Contacted Engineer/704-434-2261/7044340792 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 Laboratory Section D: Summary of Find in/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 Donnas Hood A MRO WQ/// 5 'J / � §ignature of Management Q A Review r Agency/Office/Phone and Fax Numbers Date yo Marcil occ� MRO WQ//704-235-2204/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 Permit: NC0004685 Owner - Facility: PPG - Shelby facility Inspection Date: 09/15/2006 Inspection Type: Compliance Evaluation Permit Yes No NA NE (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? 0110 ❑ Is the inspector granted access to all areas for inspection? ■ ❑ Cl ❑ Comment: PPG has received their new permit. It is effective from 12/1 /2005-8/31 /2008. Operations & Maintenance Yes No NA NE 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: The facility appeared to be well maintained and operated at the time of the inspection. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ ❑ Cl ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ■ Cl ❑ ❑ # Is the facility using a contract lab? ■ ❑ ❑ ❑ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ ❑ ❑ ❑ Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ■ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ■ ❑ Comment: Pace Labs (#12 ) currently performs all necessary analyses. PPG holds lab certification #223 and performs only field analyses on site. Please refer to the report by Mr. Chet Whiting, Laboratory Auditor, for any additional comments. Record Keeping Yes No NA NE 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 ■ Page # 3 Permit: NC0004685 Owner - Facility: PPG - Shelby facility Inspection Date: 09/15/2006 Inspection Type: Compliance Evaluation Record Keeping Yes No NA N 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 2417 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? ■ ❑ Cl ❑ 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? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑ Comment: DMRs for March 2005-February 2006 were reviewed for the inspection. It was noted during the inspection that a BOD analysis was performed on 10/31/2005 but not reported. Please submit an amended DMR for 10/2005 to maintain permit compliance. It was also noted during the inspection that the wrong 'less than' values were being reported on the DMRs. Please report all 'less than' values on the DMR as reported on the laboratory results. Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? ❑ ■ Cl ❑ Is flow meter calibrated annually? ■ ❑ ❑ ❑ Is the flow meter operational? ■ ❑ Cl ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ Cl ■ Comment: Type of bar screen a.Manual ■ b.Mechanical ❑ Are the bars adequately screening debris? ■ ❑ ❑ ❑ Is the screen free of excessive debris? ■ ❑ Cl ❑ Is disposal of screening in compliance? ■ ❑ ❑ Cl Is the unit in good condition? ■ ❑ ❑ ❑ Page # 4 Permit: NC0004685 Inspection Date: 09/15/2006 Owner - Facility: PPG - Shelby facility Inspection Type: Compliance Evaluation Bar Screens Comment: Primary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the sludge blanket level acceptable? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Comment: Aeration Basins Mode of operation Type of aeration system Is the basin free of 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) Comment: Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Yes No NA NE ■❑❑❑ ■❑❑❑ ■ Cl ❑ ❑ ■n❑n ■❑❑❑ ■ ❑ ❑ ❑ ■❑❑❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑❑❑■ Ext. Air Diffused 00011 ■n❑❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑❑❑■ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page # 5 v (n CD II ,Wry CD n S CD 3 N m CD n CD C 3 CD O CD N O N •J y o C) O S Q CD N CD at CD m a 7 3 0 to m tD C O 7 N CD rt �t m CO) in m u, N w n D D D D y N N on O v, m m m (o s Ep w O s � s CD m m m m m p' m w m m m m m m m m cn O _� O— O 3 cn c n o Q Q O _ N �,3 (n O n to c 3 0 Q. O N (��D 0 7 (D 7 Q v U C U C tll N' N o m o 3 3 3' Z Z (o a m O C 3 m 1 = _m N N 'O � -w N O 7 (D O 3 C m 3 (O = m a, m rt m 7 O N N m (D Q N. 7 m O 0 0 m o m °' g �. < n o0 o m m v m o m " o m sv o m °' o m o o m m v m m (o y 3 a m m a 55' O m � O m rt N m 6 7 m X 6 N c0i m C m .. w CD O m J 0 'D N O_ m d O 7 N ID cr J N 0 Q. < m O VOi N N ,� C ..j �D N (D to to (Q n 6 N • (p . J 3 J CD J CD _ J (n S1 N O m (7D n cn •� O ccO J (n C: Q- m 'O O co . O (o m (D w O (Q w m J v m N (D v O Er .J CDaC - (n (D C G C •J O y rL c O D -0 �. CD 'D O v m .J O a 0 O (D X n- 7' p E�- .J .. CD N �« O N CD o CD (D < N .. .. C (CD)- 3 CD •J (D n CD 3 N (D O O 3 O (D y o CD W ■ ■ ■ ■ ■ ■ ■ ❑ m ^ y ❑ ❑ o ❑ ❑ ❑ ❑ ❑ ❑ o ❑ ❑ ❑ ❑ ❑ ❑ o ❑ o o ❑ ❑ ❑. ❑ ❑ o ❑ ❑ D 0 ❑ ❑ ❑ ❑ ❑ * D ❑ 0 ❑ 0 ❑ ❑ ❑ ■ n ❑ ❑ ❑ ❑ ❑ 0 D ❑. ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Z z z ❑ ❑ ❑ ❑ ❑ ❑ z m m m m Permit: NC0004685 . Owner - Facility:' PPG - Shelby facility Inspection Date: 09/15/2006 Inspection Tvoe: Compliance Evaluation" Solids Handling Equipment " Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? 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? Comment: -.Aerobic Digester Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Comment: Solids are stored in the dumpster and then taken to the county landfill. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? =1s proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? _ Comment: , The Foxboro Company calibrates the flow meter every quarter. The last meter calibration was performed on 5/30/2006. Standby Power '' Is automatically activated standby power available? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ '■❑❑❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Cl ❑ ❑ .■❑❑❑ ■ ❑ ❑ ❑ Yes No NA NE ■❑❑❑ ■ ❑ ❑ Cl ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑% ❑ ,. ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Permit: NC0004685 owner - Facility: PPG - Shelby facility Inspection Date: 09/15/2006 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is the generator tested by interrupting primary power source? ■ Cl ❑ ❑ Is the generator tested under load? ■ ❑ ❑ ❑ Was generator tested & operational during the inspection? ❑ ❑ ❑ ■ Do the generator(s) have adequate capacity to operate the entire wastewater site? ■ ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? ■ ❑ -❑ ❑ Is the generator fuel level monitored? ■ ❑ ❑ ❑ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ■ ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ . ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑ Comment: The outfall 001 was not inspected. However, outfall 002 was well maintained and the receiving stream appeared unaffected by the discharge. Page # 8 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources October 11, 2006 CERTIFIED MAIL 7003 0500 0002 6814 3694 RETURN RECEIPT REQUESTED Mr. Todd Winn PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Drive Shelby, NC 28150 SUBJECT: Final Notice - Delinquent Annual Fee PPG - Shelby Facility WWTP NPDES Permit NC0004685 Cleveland County Dear Mr. Winn: Alan W. Klimek, P.E. Director Division of Water Quality — �6�C1 WATURAL RESOURCE,` MOORE:SNJP, ,?.r „�z k310HAL 0is F' : ()Cj 1 2 200( All NPDES permittees must pay an Annual Compliance Monitoring Fee. The fee requirement is documented in your current permit at Part II. B. 14. Your annual fee for the period July 1, 2006 — June 30, 2007 has not been paid. The amount owed is $2,865.00; a copy of the invoice previously sent by the Division's Budget Office is attached. Failure to pay the annual fee is grounds for revocation of your permit, as documented in part II. B. 13 and II. B. 14. This matter must be promptly resolved. This letter serves as final notice that the Division will refer the fee[s] noted above to the North Carolina Attorney General's Office for collection through the courts unless payment in the amount of $2,865.00 is received by November 1, 2006. Make checks payable to NC DENR; include the permit number[s] for which you are submitting payment on the check. If you have evidence that the fee has already been paid, please contact me by phone at (919) 733-5083, extension 547 or via e-mail at bob.sledge@ncmai1.net. Sincerely, moc- Robert L. Sledge Western NPDES Unit cc: Central Files NPDES File ©Qres� R eegocal-0_fTice=_SWP-Section DWQ Budget Office - Fran McPherson North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Internet: www.ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-2496 Non hCarolina Naturallif Customer Service 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer —50% Recycled/10% Post Consumer Paper NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES INVOICE 2 0 0 6 P R 0 0 7 9 3 7 Annual Permit Fee Overdue This annual fee is required by the North Carolina Administrative Code. It covers the administrative costs associated with your permit. It is required of any person holding a permit for any time during the annual fee period, regardless of the facility's operating status. Failure to pay the fee by the due date will subject the permit to revocation. Operating without a valid permit is a violation and is subject to a $10,000 per day fine. If the permit is revoked and you later decide a permit is needed, you must reapply, with the understanding the permit request may be denied due to changes in environmental, regulatory, or modeling conditions. Permit Number: NC0004685 Cleveland County PPG - Shelby facility Todd Winn PPG Industries Fiber Glass Products Inc 940 Washburn Switch Rd Shelby, NC 28150 Annual Fee Period: 2006-07-01 to 2007-06-30 Invoice Date: 08/16/06 Due Date: 09/15/06 Annual Fee: $2,865.00 Notes: 1. A $25.00 processing fee will be charged for returned checks in accordance with the North Carolina General Statute 25-3-512. 2. Non -Payment of this fee by the payment due date will initiate the permit revocation process. 3. Remit payment to: NCDENR - Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 4. Should you have any questions regarding this invoice, please comtact the Annual Administering and Compliance Fee Coordinator at 919-733-5083 extension 210 - - - - - - - - (Return This Portion With Check) ANNUAL PERMIT INVOICE Permit Number: NC0004685 Cleveland County PPG - Shelby facility Todd Winn PPG Industries Fiber Glass Products Inc 940 Washburn Switch Rd Shelby, NC 28150 1111111111111111111111111111; Overdue Annual Fee Period: 2000-07-01 to 2007-06-30 Invoice Date: 08/16/06 Due Date: 09/15/06 Annual Fee: $2,865.00 Check Number: ��F Vd A TF9Q Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources CO r >_ _{ Paul E. Rawls, Chairman Water Pollution Control System Operators Certification Commission November 15 2006 Atlir) Nove rF-=ECG O - I . RICHARD YOUNG PPG INDUSTRIES FIBER GLASS PRODUCTS INC 940 WASHBURN SWITCH ROAD Nov 1 6 2M SHELBY NC 28150 Re: NC0004685 ORC/Back-up ORC Designation Dear Mr. Young: �a 'l. 4:`y4.J'oV,u This letter is to acknowledge receipt of your letter and ORC designation form for PPG Industries, Shelby Facility, Permit # NC 0004685. Kellie Hedrick and Russle Carson have been added to your designated operator list as Back-up Operators in Responsible Charge for your facility along with Billy McFarlund. Henry Blackwell remains your designated Operator in Responsible Charge (ORC). Bill Schenck and John Cook have been removed as Back-up ORC's for your facility per your request. Your facility is currently classified in our BIMS database as a Physical/Chemical Grade 2 facility. According to our paper file the. facility was previously classified as Wastewater Grade 3 in a letter dated October 27, 2000. The Technical Assistance & Certification.Unit staff will check with the regional staff to determine if this facility should have dual classification as WW-3 & PC-2. We will let you know our findings. Your facility is currently only classified in our database as PC-2 and that is what we accept at this time. If it is determined that an omission was made in our database and your facility truly should be classified as Wastewater Grade 3 and Physical/Chemical Grade 2, you will be informed and given ample opportunity to get designated operators certified in Biological Wastewater to be eligible to serve as Backup `ORC - Thank you for your prompt attention to the designation changes at your facility. I apologize for the confusion and will determine the proper classification on a timely basis. This is to confirm that you have completed your designation responsibilities per the current rules listed in NCAC 15A 08G .0200. If you have any further questions please contact me at (919) 733-0026 ext. 309. Sincerely, JerF.immer, Supervisor cc: ooresui a es?io[O NorthCarohna jai MMY Technical Assistance & Certification Unit Internet: http://h2O.enr.state.nc.us/tacu �n�n ��_:1 _ /�_-a__ r\-_:�� •1/\ n�nM II�n T__--��._ //\�/\\_�n�\_nnnn r_.._ /n1I\\ -snn �nnn .-_- _ _ _ __ _ CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Timothy Mathis Manufacturing Manager PPG Industries Fiber Glass Products, Inc. 940 Washburn Road Shelby, NC 28150 Subject: Dear Mr. Mathis: Michael F. Easley, Governor William G. Ross Jr., Secretary Dy3%y}/7�i North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality March 22, 2007 7006 2760 00018493 7309 Notice of Violation - Effluent Limitation Tracking #: NOV-2007-LV-0156 PPG Industries WWTP NPDES Permit No. NC0004685 Clevelpd County A review of the November 2006 self -monitoring report for the subject facility revealed a violation of the following parameters for Outfall 001: Date Parameter Reported Value Permit Limit 11/6/06 pH 5.9 SU 6.0 SU (Daily minimum) 11/8/06 Oil & Grease 23 mg/l 15 mg/1 (Daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. Since the comments section on the reverse of the relevant Discharge Monitoring Report provided an explanation. for the noted effluent limit violation, it is not requested that a response be submitted; however, should you have additional information concerning the violations or comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office for additional information. N�onhCarolina NCDENR Naturally Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Customer Service . Internet: www.ncwateMualitv.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Mr. Tim Mathis NOV-2007-LV-0156 Page 2 If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at (704) 663-1699. Sincerely, Samar Bou-Ghazale Acting Regional Supervisor Surface Water Protection cc: Point Source Branch Cleveland County Health Department [UT" l Michael F. Easley, Governor i Y William G. Ross Jr., Secretary i North Carolina Department of Environment and Natural Resources vbj' 3 • Alan W' K1imekJ]?� BI rector o�.%M— Dualit y June 19, 2006''` r Me�4,1 1 . Tim Mathis PPG Industries Fiber Glass Products, Inc. 40 Washburn Switch Rd Helby, NC 28150 Subject: Notice of Incomplete Discharge Monitoring Report NC0004685 Dear Permittee: JUN 2 C 260,: The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge Monitoring Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed into the Division's database. Our. data entry staff has informed me of problems with your recent DMR submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency. Incomplete or illegible DMRs affect our staff s ability to provide a timely and effective evaluation of DMR submittals. Please be aware that until the Division receives a corrected DMR, you may be considered noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further enforcement action. Please take the necessary steps to correct the problems and submit two copies of the amended DMR within fifteen (15) days of the date of this letter to the following address: Attention: Michele Phillips Division of Water Quality Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions about the proper completion of DMRs, please contact Michele Phillips at 919-73375083 Ext, 534. Thank you for your assistance in this matter Sincerely, Michele Phillips cc: gores .ille Regional-Of_f_ice Central Files Nne orthCarolina Naturally N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: (919) 733-7015 Customer Service Internet: http://h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax: (919) 733-0719 1-877-623-6748 An Equal Opportunity/Affirmative Action. Employer 1 Notice of Incomplete Discharge Monitoring Report Permit Number: Facility: C� �Cu e,41r1 e5 [':5S County: CI 2Je-lG�'y.� DMR Month and Year:r' CS6 The Division of Water Quality deems the aforementioned DMR as incomplete due to the following reason(s): (Please see the highlighted areas on the attached DMR for details.) ❑ The written values are illegible. ❑ The Average, Maximum, and/or the Minimum data points have been omitted. ❑ The Units of Measure have been omitted or are incorrect. ❑ The DMR Parameter Codes have been omitted. 9lJ Other: EFFLUENT (QUARTERLY) No. NC0004685 DISCHARGE NO. 001 MONTH April YEAR 2006 VIE FPPG INDUSTRIES FIBER GLASS PRODUCTS, INC. CLASS III COUNTY CLEVELAND IN RESPONSIBLE CHARGE (ORC) HENRY F. BLACKWELL GRADE IV PHONE 704-434-2261 IR 1 IED LABORATORIES _ (1) PPG INDUSTRIES FIBER GLASS PRODUCTS, INC (2) PACE LABORATORIES, INC (3) R&A Labs c nAr NAS CHANGED I I PERSON(S) COLLECTING SAMPLES OPERATORS ORIGINAL and ONE COPY to: N: CENTRAL FILES %{ _ SION OF WATER QUALITY x l-v"vl ! r—` 'MAIL SERVICE CENTER (SIGNATURE-bF OPERATOR IN RESPONSIBLE CHARGE) DATE EIGH, NC 27699-1617 BY THIS SIGN(TURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. Facility Status: (Please check one of the following) onitoring data and sampling frequencies meet permit requirements All monitoring data and sampling frequencies do NOT meet permit requirements Compliant Noncompliant ie facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, intenance, etc., and a time table for improvements to be made. certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance th a system designed to asure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry the person or persons who manage the system, or those persons directly responsible for gathering the information, the information to the best of my knowledge and belief, true, accurate, and complete. I.am aware that there are significant penalties for submitting lse information, including the possibility of fines and imprisonment for knowing violations." Tim Mathis Permittee (Please print or type) ' 5 �s LAI Signature of Permittee`• D to (Required) WrrP .J D n A n 704434-2261 Permit # NC0004685 ermittee Address Phohe Number Expiration date: 8/31/2008 HELBY, NORTH CAROLINA 28150 . PARAMETER CODES 00010 Temperature 00556 Oil & Grease 00951 Total Fluoride 01067 Nickel 00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver 00080 Color (Pt -Co) 00610 Ammonia Nitrogen 01092 Zinc 00082 Color (ADMII) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum Nitrogen 00095 Conductivity 00630 Nitrates/Nitrites 01032 Hexavalent Chromium 01147 Total Selenium 00300 Dissolved Oxygen 00310 BOD5 00340 COD 00400 pH 00530 Total Suspended Residue 00545- Settleable Matter 00665 Total Phosphorous 00720 Cyanide 00745 Total Sulfide 00927 Total Magnesium 00929 Total Sodium 00940 Total Chloride 01034 Chromium 01307 Total Cobalt 01042 Copper 01045 Iron 01051 Lead 01062 Molybdenum 31616 Fecal Coliform 32730 Total Phenolics 34235 Benzene 34481 Toluene 38260 MBAS 39516 PCBs 50050 Flow Total Residual Chlorine 50060 Formaldehyde 71880 Mercury 71900 Xylene 81551 'arameter Code assistance may be obtained by calling the Point Source Compliance/Enforcement Unit at (919) 733-5083 or by visiting ne water Quality Section's web site at hZo enr.state.nc.us/wos and linking to the Unit's information pages. Jse only units designated in the reporting facility's permit for reporting data. ORC must visit facility and document visitation of facility as required per 15 A NCAC 8G .0204. If signed by other than the permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B .0506 (b) 2) (D). PPG Industries Fiber Glass Products, Inc. W 940 Washburn Switch Road Timothy G. Mathis rh Manufacturing Manager Fiber Glass Products May 10, 2006 MAY 1 a 2001'; Mr. D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor Division of Water Quality, NC DENR Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 SENT VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED Re: Notice of Violation — Effluent Limitations Tracking #: NOV-2006-LV-0167 PPG Industries Fiber Glass Products, Inc. - WWTP NPDES Permit No. NC0004685 Cleveland County Dear Mr. Gleason: Shelby, N.C. 28150 704-434-2261 Extension 206 mathis@ppg.com This letter is is in response to the Notice of Violation issued on April 24, 2006 by the Division of Water Quality ("DWQ") to PPG Industries Fiber Glass Products, Inc. ("PPG"). The Notice of Violation alleged that PPG's February 2006 self -monitoring report described an oil and grease effluent limit excursion of the permitted daily maximum value. PPG immediately investigated the matter upon receiving the sample report from Pace Analytical Labs. No upsets or abnormalities were found relating to the wastewater influent, PPG wastewater operations, or testing procedures performed by the lab. However, inspection of the grab sampling location and sample -handling methods detected possible causes for the elevated oil and grease value. The sampling point was located at an open -topped, wall -mounted reservoir into which final effluent is fed by a small pipe. The reservoir is partitioned into two compartments; one for grab sampling and one for composite sampling. Effluent may be diverted to either side as needed by the operator. Grab samples are drawn from the bottom of the reservoir into the sampling container. Inspection of the grab sample side of the reservoir revealed a dirty residue of unknown origin. The reservoir is located in very close proximity to equipment, pumps, and maintenance activities that use oils and greases. Their presence in this area provides the likely source of the oil - containing residues observed on the sample reservoir.. The residue detected in the grab sampling reservoir very likely contaminated the grab sample. Based on the results of our investigation of the oil and grease sample results, PPG has taken the following corrective actions. The grab sampling point has been relocated to a manual valve tapped directly into the effluent sample line. This change eliminates the possibility that contamination from the former open -topped reservoir will influence our sampling results. In addition, clean sampling techniques and procedures have been reinforced, and operators are required to wear clean gloves while collecting samples, to prevent contamination. To date, all subsequent sampling results for oil and grease have been within permitted limits. In summary, PPG believes that the excursion experienced on February 1, 2006 was most likely attributable to an isolated instance of sample contamination and did not represent the effluent or any upset with the wastewater process. PPG promptly investigated and corrected the conditions thought to have contributed to this contamination. Subsequent sampling results have been compliant, and PPG believes that this issue has been adequately corrected. PPG requests that the DWQ consider this matter resolved and not pursue further actions. If you have any questions or concerns, please contact Richard Young at (704) 434-2261 extension 359. Sincerely, Timothy G. Mathis Manufacturing Manager Cc: Richard Young A • � ' -.,r ter•,;... ��a.'_aus:..( CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Tim Mathis, Manufacturing Manager PPG Industries Fiber Glass Products, Inc. 940 Washburn Road Shelby, North Carolina 28150 Subject: Dear Mr. Mathis: Ok Michael F. Easley, Govero~j/ William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality April 24, 2006 7003 2260 0001 3493 8958 Notice of Violation - Effluent Limitations Tracking #: NOV-2006-LV-0167 PPG Industries WWTP NPDES Permit No. NC0004685 Cleveland County A review of the February 2006 self -monitoring report for the subject facility revealed a violation of the following parameter: Pipe Parameter 001 Oil and Grease Reported Value 25 mg/l (daily maximum) Permit Limit 15 mg/l (daily maximum) Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699. cc: Point Source Branch Cleveland County Health Dept. JL AFL, MCDENR Sincerely, D. Rex Gleason, P.E.- Surface Water Protection Regional Supervisor Mooresville Regional Office Division of Water Quality Phone 704-663-1699 Internet: www.ncwaterqualitv_.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax 704-663-6040 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper None rthCarolina Customer Service 1-877-623-6748 PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 281 David W. Weber Senior EHS Engineer Fiber Glass Products Fax November 30 2005 Certified Mail - Return Receipt Requested xND NAT ,= RESVlL Ms. Donna Hood �r N.C. Division of Water Quality I , Mooresville Regional Office 610 East Center Ave Suite 301 Mooresville, NC 28115 Subject: Update on Oil & Grease Testing Results from October 24, 2005 WATER NPDES Permit NC0004685 Dear Ms. Hood: ext. 359 pg.com R,1.`�tESOIiRCE� . r%. ,,!0N1ALOFFICE p . 200' mc �10 This letter is written as a follow-up to my letter on this subject dated November 10, 20 5 and our subsequent telephone conversation on November 28, 2005. As we discussed, PPG ha originally submitted a split sample for Oil & Grease analysis to our contract lab (Pace) from our final effluent on October 24. The contract lab originally misplaced one of the split samples, so PPG had to •eport these results based on one sample which indicated an exceedance of the Daily Maximum limi ation. On November 11, the lab located the missing split sample and analyzed it for Oil & Grease. 11 QA/QC criteria for the second sample were within required limits. The result of the second sam le was Not Detected at the reporting limit (ND), as is typical for PPG's effluent. PPG's consultant, Mr. Bob Stein of Aware Environmental, consulted with Chet Whiting Office) and Jim Meyer (Section Head — DWQ Laboratory Section) for advice on how to pr these results. Both stated that, under the circumstances, the results should be averaged with t considered as "0". Based on this, PPG's final result for Oil & Grease on October 24 was 11 does not exceed the Daily Maximum requirement. PPG's DMR for October reported the 1 and indicated "Compliance" with all permit conditions. Should you have any questions or concerns, please contact me at 704-434-2261 extension 35 Sincerely, 1414&111Z�� David W. Weber Senior EHS Engineer ✓looresville )erly report ND result rig/I, which mg/1 result i PPG Industries, Inc. David W. Weber Senior EHS Engineer Fiber Glass Products November 10, 2005 940 Washbrn Switch Road .C\ Certified Mail - Return Receipt Requested Ms. Donna Hood N.C. Division of Water Quality Mooresville Regional Office 610 East Center Ave Suite 301 Mooresville, NC 28115 Subject: Daily Maximum Exceedance Oil & Grease — October 24, 2005 NPDES Permit NC0004685 Dear Ms. Hood: Shelby, North Carolina 281 Fax This letter is written as a follow-up to our telephone conversation on Monday, November 7, discussed, PPG received laboratory results for Oil & Grease from final effluent sampled on 2005 of 22 mg/l. This result exceeds the Daily Maximum limitation of 15 mg/l for Oil & Gre NPDES Permit. PPG has undertaken a full investigation to determine the cause of the elevated result. investigated conditions at the Wastewater Treatment Plant and checked the quality assuranc our contract laboratory (PACE Labs, Huntersville, NC) that performed the analysis. As of t are unable to explain the reason for the elevated result. No unusual conditions occurred at the Treatment plant and all contract lab quality assurance data are in order. PPG expects to re Grease results from the next week in the very near future. We plan to compare these results 1 if further investigation is needed. Should you have any questions or concerns, please contact me at 704-434-2261 extension 359. Sincerely, David W. Weber Senior EHS Engineer ext. 359 com i. As we tober 24, from our We have data from is date, we Wastewater eive Oil & determine PLATU DW SVILLE RESOURCES ,GfOro`!� OFFICIr NOV 1 4 200:, FFV PPG Industries, 940 Washburn Switch Road, Shelby, NC 28150 Via Certified Mail - Return Receipt Requested June 17, 2005 Mr. Michael Parker NC Department of Environment and Natural Resources Division of Water Quality 610 East Center Ave. Mooresville, NC 28115 RE: Non -Characteristic Effluent NPDES Permit No. NC0004685 Dear Mr. Parker: J'UN 2 i 2,86-'s As per our initial phone call on June 14, 2005' concerning the upset caused by a raw material spill inside of our facility, -the following is a summary of the event to satisfy the five-day written report in letterform requirement. On Monday June 13, 2005 at —1030 hours a valve failed on a binder tank resulting in the loss of —3475 gallons of binder. The tank is located inside the facility and is set inside a concrete basin that is equipped with drains that lead to the WWTP. Upon notification of the spill, influent flow was redirected to the lined emergency holding basin. It has since been estimated that somewhere between 500-750 gallons flowed to the WWTP prior to the flow being redirected to the emergency holding basin. Throughout the remainder of the day, there was no evidence at the WWTP that the portion of material that had entered the WWTP had caused any upset condition. The following morning around 0600 hours the ORC arrived to the WWTP and noticed that the water in the secondary clarifiers had a white tint to it. Immediately, the ORC diverted all influent into the emergency holding basin and contacted me via cell phone. arrived shortly thereafter and we pulled a grab sample of the effluent. The sample was cloudy versus normally being completely transparement. We then proceeded to the discharge point at the creek. The treated water coming from the end of the discharge pipe had the same slight white tint. From the end of the pipe we could see visual evidence of the white tint in the creek in the form of an —3' wide plume that became FFV harder and harder to see until it completely disappeared at —20 yards downstream of the discharge pipe. With all influent now being directed to our emergency holding basin, we started to treat the water that was in the system over and over again with all discharge coming back to the head of the plant for re -treatment. Due to the rising level in the emergency holding basin, at —2230 hours we were forced to redirect influent back to the WWTP and likewise return discharging to the creek. Effluent grab samples, at this time, appeared much better but still had a slight white tint/haze to them. The following morning, we went to the discharge point at the creek and could still see a faint white tint around the discharge point but the tint quickly disappeared shortly downstream of the pipe. TSS samples taken during the episode were above normal but below the daily maximum permit limit. pH, dissolved oxygen and conductivity samples were all in their normal ranges. Analysis from other samples collected (e.g. BOD, NH3, etc) are not completed but will, of course, be reported on the June DMR. The system has improved much but is not 100% back to normal. As of today, the effluent is not yet completely transparent, as is normal. There still remains a slight cloudiness to the water. As with any system upset, it may take a full week or so for the system to fully return back to normal. As follow up from the incident investigation, valves will be added to the drains in the concrete basin and be locked in the "closed" position. In the event of a future spill, the entire volume of the tank will be held in the containment basin. The material can then either be pumped out by vacuum truck or diverted to the emergency holding basin after all influent valves have been closed and the emergency holding basin valves fully opened. If you have any questions regarding this incident, please feel free to contact me at (704) 434-2261 x 359. Please note that a copy of this letter is also being faxed to your attention at (704) 663-6040. Sincerely, jo�� Todd Winn Environmental Engineer cc: B. Blackwell file Michael F. _•. Governor William G. Ross Jr.. Secretary IJ North Carolina Department of Environment and Natural Resources _co 1 Alan W. Klimek. P. E. Director Division of Water Quality Coleen H. Sullins. Deputy Director Division of Water Qualin April 22, 2004 CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. Todd Winn, Staff Engineer PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Dear Mr. Winn: 70012510 0004 8286 3692 Notice of Violation/Notice of Recommendation for Enforcement Compliance Evaluation Inspection PPG Industries WWTP NPDES Permit No. NC0004685 NOV#: 2004-PC-0029 Cleveland County, NC Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on April 16, 2004 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding dcopy of the enclosed report. This report is being issued as a Notice of Violation (NOV) and Notice of Recommendation for Enforcement (NRE) because of the monitoring violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Upstream/Downstream Sampling Section of the attached report. Pursuant to G.S. 143- 215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) per violation, per day may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. It is requested that a written response be submitted to this Office by MU 1120042004. addressing the deficiencies noted in the Upstream/Downstream Sampling Section of the report. Mr. Chet Whiting (Division's Laboratory Certification Unit) will separately address all issues pertaining to the facility's on -site laboratory practices. In responding, please address your comments to the attention of Mr. Richard Bridgeman. NortbCarolina {� JVlrtuz'a!!iJ NCDENR N. C. Division of Water Quality, Mooresville Regional Office, 919 North Main Street; Mooresville NC 28115 (704) 663-1699 Customer Service 1-977-623-6748 Mr. Todd Winn Page Two Apri122, 2004 This letter is also to advise you that this Office is considering sending a recommendation for enforcement action to the Director of the Division of Water Quality for the monitoring violations of G.S. 143.215.1(a) and the NPDES Permit No. NC0004685. If you have an explanation for the violations that you wish to present, please include it in the requested response. Your explanation will be reviewed and if an enforcement action is still deemed appropriate, your explanation will be forwarded to the Director along with the enforcement package for his consideration. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Mr. Bell or me at (704) 663-1699. Sincerely, D. Rex Gleason, P.E. Water Quality Regional Supervisor Enclosure cc: Cleveland County Health Department ,/: United States Em unmental Protection Agency Form Approved. EPA Washington, D.C. 2o4s0 OMB No. 204OM57 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 31 NCO004685 1 11 121 04/04/16 1 17 1819igi 20 U u ,r L_I u Remarks 166 Inspection Work Days Facility Sell -Monitoring Evaluation Rating 131 QA — Reserved — 671 1.5 1 69 70 L.J 71 U 72 U 73 W 74 7,91 I I I 1 I I Section B: Facility Data 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) 10:00 AM 04/04/16 99/05/01 PPG Industries Fiber Glass Products Inc - Shelby Exit Time/Date Permit Expiration Date 940 Washburn Switch Road Shelby NC 2,8150 01:00 PM 04/04/16 03/08/31 Name(s) of Onsite Representative(s)/Tities(s)/Phone and Fax Numbers) Other Facility Data Henry F Blackwell/ORC/704-434-2261/ Todd Winn/Engineering Associate/704-434-2261 ext 359/ Name, Address of Responsible Official/Tftie/Phone and Fax Number (� Todd Winn, Engineering, Associate,940 Washburn Switch Road Shelby kntacted Yes 28150/Engineering Associate/7044342261359/ Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Repotts Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Laboratory 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(Agency/Office/Phone and Fax Numbers Data es) A N Bell g � Y / MRO WQ//704-663-1699/704-663-6040 9 /z /d y Signature of Management Q A Reviewer Agency/OfficelPhone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. CA N N N N N N N N y D N y O m N y y N y D N N O > s> y s E 3 � y� m Er a 3 a m EF 3 w co of N O m N C.L. (q 3 y COm y A N d y 3 N N W y o 3 c y m m N O 3 m N 3 m m (p 3 3 m o m> m m m v m a e m m m m °1 a'<<' m m m m °/ _'—. m m m c o m T� y l n• 3 m 3 m r. m 3 m m M _. m v oz$ d m w 2w ac T�° m w mS• m m �c m m 61 m F Z v v ® (NA c m v gCD w m �/ c m v_ y a K m o m y, X O m a 7C 03 �j .� 8 N t0 C a O� �' t0 C a •v 3CID Q `5. y f!J y m E O `� c o `a c v m = w w m o g N w EF o co ? v o o cc ? v o >> n v o d ° 3 N �. a y �. a ((�� N m y 7 O S ° y a a d y y a d y y 2 a O• ' V 2 N w _ m .O-. •p m (O (o EOA• cr S •O a N S C N m (D O -i O R 2 m 7 m 1 a a 8 a z g f y enA) S m EF � a a m ° m w ° C C u nT -u `� 3 n. G) a d a:3 m a 3 N d m 7 O CD C m 71 C1 — Q CD G) x g ° v a t�• . 0 m N Ci •J 1 Y/ C Q. ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ■ ❑ ■ ■ ■ MOORE 5 ❑❑1300013❑13171313 ❑❑❑❑❑❑❑❑❑ ❑❑❑❑ ❑D ❑❑■❑❑ w ❑ ❑ ❑ ❑ ❑ ❑ ❑ 13 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 21 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ O a) W y Permit: NC0004685 Owner - Facility: PPG Industries Fiber Glass Products Inc - PPG Industries Fiber Glass Products Inc - Shelby Inspection Date: 04/16/04 Inspection Tvpe: Compliance Evaluation Comment:Large dumps of vegetation were observed adjacent to the clarifier weirs; however, no short-curcuiting was observed. The vegetation has been scheduled to be removed. Aeration Basins Mode of operation Yes No NA NE Ext. Air Type of aeration system Diffused Is the basin free of dead spots? M ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ ❑ Are the diffusers operational? M ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? M ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Are settleometer results acceptable? ❑ ❑ ❑ Comment: Filtration (High Rate Tertiary) Type of operation: Yes No NA NE Down flow Is the filter media present? ❑ ❑ ❑ Is the filter surface free of clogging? ❑ ❑ ❑ Is the filter free of growth? ❑ ❑ ❑ Is the air scour operational? ❑ ❑ 0 ❑ Is the scouring acceptable? ❑ ❑ 0 ❑ Is the clear well free of excessive solids and filter media? 0 ❑ ❑ ❑ Does backwashing frequency appear adequate? ❑ ❑ ❑ Comment: Laboratory Are field parameters performed by certified personnel or laboratory? Yes No NA NE M ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ❑ ❑ ❑ Is the facility using a contract lab? ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? a ❑ ❑ ❑ Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? ❑ ❑ ❑ Comment:The DO meter calibrations were not always documented for all effluent and instream field analyses. The TRC calibration/verification data was not kept on -site for the effluent analyses performed on Outfall 002. Flow Measurement- Effluent Is flow meter used for reporting? Yes No NA E ❑ ❑ NE ❑ Is flow meter calibrated annually? 00013 Is flow meter operating properly? M ❑ ❑ ❑ (if units are separated) Does the chart recorder match the flow meter? 0000 Comment:The magnetic flow meter is calibrated quarterly by The Foxboro Company. The flow meter was last calibrated on 3/04. Record Keening Are records kept and maintained as required by the permit? Yes No NA NE ❑ ❑ ❑ 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? ❑ ❑ ❑ Are sampling and analysis data adequate and include: 0 13 0 13 Permit: NC0004685 Owner - Facility: PPG Industries Fiber Glass Products Inc - PPG Industries Fiber Glass Products Inc - Shelby Inspection Date: 04/16/04 Inspection Type: Compliance Evaluation Record Keeoina Dates, times and location of sampling ,Yes No NA NE Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Plant records are adequate, available and include ❑ ❑ ❑ O&M Manual As built Engineering drawings Schedules and dates of equipment maintenance and repairs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users? ❑ ❑ ❑ (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? ❑ ❑ ❑ Is the facility description verified as contained in the NPDES permit? 1 ❑ ❑ ❑ Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO, Sludge ❑ ❑ ❑ Judge, pH, and others that are applicable? Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment:DMRs were reviewed fmm February 2003 through January 2004. No limit violations were reported. Oil & grease analyses were not property calculated and reported. The ORC and staff must Insure that the effluent pH and TRC collection and analysis times for Outfall 002 are documented. Fffl�mplina Is composite sampling flow proportional? Yes No NA ❑ ❑ NE ❑ Is sample collected below all treatment units? ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ ❑ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ❑ ❑ ❑ Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ❑ ❑ ❑ Comment:The ORC and staff must insure that 100 mis. per aliquot is collected during the composite sampling period. Yes No NA NE ,Uoatr .am / Down'Strearn Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ❑ n ❑ ❑ Comment:lnstream fecal coliform was not collected 3/wk during the months of June through September (68 total violations). Yes No NA NE Solids Handling Failuipm .nt Is the equipment operational? ❑ ❑ ❑ 0 Is the chemical feed equipment operational? ❑ ❑ ❑ E Is storage adequate? 0 ❑ ❑ ❑ Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ❑ ❑ ❑ 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? ❑ ❑ ❑ Comment:The fitter belt press was operational; however, the treatment unit was not in -use at the time of the inspection Is right of way to the outfall properly maintained? 0 1313 Permit: NC0004685 Owner - Facility: PPG Industries Fiber Glass Products Inc - PPG Industries Fiber Glass Products Inc - Shelby Inspection Date: 04/16/04 Inspection Type: Compliance Evaluation Effluent Pipe Are receiving water free of solids and floatable wastewater materials? Are the receiving waters free of solids / debris? Are the receiving waters free of foam other than a trace? Are the receiving waters free of sludge worms? If effluent (diffuser pipes are required) are they operating properly? Comment:The effluent appeared clear with no suspended solids or foam. Yea No NA N ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 011011 Michael Easit . Crn Qom, ,Wiliiam G. Ross J%. S �L North Carolina Dix anent oftnvironmenr and Natrrrai Resources / Alan W-Klimek. P. Director v/ Division orWamr Qualin Colvin H. SuIiu>s Depuny Dire`ior Division olRW=- Qualiry May 12, 2004 Mr. Todd Winn, Staff Engineer PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Subject: Rescission of Notice of Recommendation for Enforcement PPG Industries WWTP NPDES Permit No. NC0004685 Cleveland County, N.0 Dear Mr. Winn: A Notice of Violation and Recommendation for Enforcement dated April 22, 2004 was issued for the monitoring violations of the subject NPDES Permit. Through that Notice your company was notified that this Office was considering sending a recommendation for enforcement action to the Director of this Division. Appropriate staff has reviewed your response to the subject Notice. Based on your response, this Office has decided not to prepare an enforcement recommendation at this time. A request for enforcement from our Raleigh Office could change the situation; however, we do not anticipate such a request at this time. Should you have any questions on this matter, please do not hesitate to contact Mr. Wes Bell or me at (704) 663-1699. Sincerely, D. Rex Gleason, P.E. Water Quality Regional Supervisor AMA NMENR K C Dr-�Sim of W Qin.-e, 919 North Main Str4 Moores Ue NC 28115 (744) 663-1699 Crssto= Service 1-97"/-623-6748 MEMO August 22, 2001 To: Wess Bell From: Chet Whiting Subject: Request to rescind NOV from PPG Industries I reviewed the data packet you gave me related to differences in analytical results by method 413.1 and 1664 for oil and grease samples from PPG Industries Shelby. The data is not conclusive to substantiate PPG's contention that the 1664 HEM results are due to interference. By definition the tests are for Hexane Extractable Materials and Freon Extractable Materials. It is almost certain that there will be compounds that are miscible in one solvent and not the other. The fact that the Silicon Gel Treated option of method 1664 removes the substance is not an indication of interference. This option is for non -polar compounds and would remove polar compounds included in the standard HEM extraction. Insufficient information is included to draw a correlation for two of the interferences stated in section 4.5 of method 1664 (detergent and particulates). Section 3.1 of Method 1664 states: "HEM and SGT-HEM are method -defined analytes; i.e., the definitions of both HEM and SGT-HEM are dependent on the procedure used. The nature of the oils and greases, and the presence of extractable non -oily matter in the sample will influence the material measured and the interpretation of the results". It may be that the random high results are due to interference, however there is an equal chance that the results are due to the presence of a Hexane Extractable Material and therefore must be reported. By definition if the substances is extracted by hexane even if it is a non -oily material it must be included in the results. At this point PPG must make a stronger argument for their contention that the results are due to interference. We would recommend a Base/neutral Acid analysis that includes tentatively identified compounds, to determine if the compound detected is organic in nature. If this test were to indicate that no organic compounds were present it would certainly strengthen PPG's argument that the results may be due to interference. Although it is unlikely, PPG might also consider examining the solids and conductivity results for the days in question to rule out interference from dissolved materials. While further investigation may reveal that the values in question are due to interference we feel that it is premature to draw that conclusion at this time. cc: Steve Tedder James Meyer Rex Gleason \ � 0 PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products July 9, 2001 Mr. Richard Bridgeman Division of Water Quality NC DENR 919 North Main Street Mooresville, NC 28115 Re: Notice of Violation, June 22, 2001 PPG Industries, Shelby, NPDES No. NC0004685 Dear Mr. Bridgeman: 704-434-2261 Extension 544 Iballard@ppg.com All JUL 1 2 2001 This letter and the attachments are PPG Industries Fiber Glass Products, Inc. (PPG's) response to the Notice of Violation issued June 22, 2001 for oil and grease limit violations on March 22 and August 23, 2000. PPG is requesting that the state rescind this Notice of Violoation because excursions of oil and grease have not occurred, as detailed in this letter and supporting documents. Oil and grease test results have been an issue with the PPG effluent since the required test procedure changed from EPA Method 413.1 to EPA Method 1664, which use freon and hexane respectively as their extracting solvents. PPG's permit limits were established based on the freon extraction, EPA Method 413.1. Method 1664 is known to extract interfering compounds such as surfactants, in addition to oil and grease, and may cause false -high results. Such results have been experienced in tests of PPG effluent and PPG has been working with the state to resolve this problem through modification of the test to eliminate interferences. PPG conducted two studies demonstrating that the change from test Method 413.1 to Method 1664 causes an occasional high value in the wastewater effluent because hexane extracts different compounds than freon. Split samples analyzed by each method have confirmed that effluent quality remains in compliance when using the original method (EPA 413.1). PPG has taken appropriate action based on the studies and has followed the suggestions from the Division of Water Quality Laboratory Section, EPA Office of Water Quality, and the Region IV EPA in addressing the situation. PPG has kept the state agency informed of activities and progress (see attached June 5, 2000 letter). After a prolonged and expensive study, PPG presented data to the agency to support a request for a permit modification that would eliminate the issue and provide meaningful data as to effluent quality (see attached March 5, 2001 letter). PPG's March 5, 2001 permit modification request proposed: (1) oil and grease monitoring be reduced to one event every two months and (2) approval to analyze oil and grease samples using Page 2 both Method 413.1 and 1664 with silica gel treatment to prevent surfactant interference. Method 413.1 would be used for reporting purposes and Method 1664 with silica gel treatment would be used to establish a baseline with which to establish future oil and grease limits. Receipt of the permit modification request has been confirmed by the Raleigh agency, but resolution of the issue is pending action by the agency. PPG believes that this is a technical issue involving test methods and that no effluent violation has occurred. It is unfortunate that the issuance of this NOV will cloud an otherwise good compliance record. PPG has been responsible, proactive, and technically accurate in addressing this issue and feels that any enforcement action is unwarranted. PPG requests that this Notice of Violation be rescinded. If additional information is needed, please give me a call. If a meeting between the agency, PPG, and its consultant Aware Environmental, would be helpful, please let me know. Sincerely, Ago Lacy Ba lard Attachments: Letter of 6-5-00 Letter of 3-5-01 cc: J. Scruggs P. Pride J. Osheka T. Winn Cleveland County Health Department PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products June 5, 2000 Mr. Dave Goodrich NCDENR Permitting Division 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Effluent Oil and Grease Method Study/Permit Modification Request PPG Industries Fiber Glass Products, Inc. — Shelby, NC NPDES No. NC0004685 Dear Mr. Goodrich: 704-434-2261 Extension 544 Iballard@ppg.com PPG Industries Fiber Glass Products, Inc. (PPG), a manufacturer of fiber glass for the reinforced plastics industry, is located in Shelby, NC. Wastewater from our production units is treated in an on -site WWTP before being discharged to Brushy Creek. The NPDES discharge permit limits effluent oil and grease to 10 mg/L maximum daily and 15 mg/l average. Historically, the oil and grease effluent concentrations have been below PPG's 10 mg/L permitted discharge limit. Approximately one and a half years ago, the analyzing laboratory (Pace Analytical Labs, Huntersville, NC) switched from the old EPA Method 413.1, which uses CFC-113 (freon) as the extracting solvent, to the new EPA Method 1664, which uses n-hexane (hexane) as the extracting solvent. As a result of this switch, PPG effluent oil and grease concentrations have been periodically higher than normal and have exceeded the 10 mg/L discharge criteria. Freon is no longer being imported or produced in the U.S. as of January 1, 2000. Additionally, analytical laboratories will no longer be allowed to use any existing freon after the year 2005. Therefore, future oil and grease analysis will be performed using Method 1664 once freon is permanently phased out. Both EPA Methods 413.1 and 1664 were developed for the determination of relatively non- volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials. Under EPA Method 4111, the freon extracted constituents were referred to as "oil and grease" Under EPA Method 1664, the hexane -extracted constituents are referred to as "hexane extractable material". Method 1664 measures not only oil and grease, but any material that can be extracted using hexane. Oil and grease is a method -defined parameter; therefore, any change in method protocol, such as use of another solvent, has the potential to affect results. The EPA Guidance Document, Analytical Method Guidance for EPA Method 1664A Implementation and Use (40 CFR part 136), indicates that there may be differences in results obtained using Method 1664 compared to Method 413.1. This Guidance Document outlines recommendations for performing side -by -side testing between Method 413.1 and Method 1664. Based on the EPA method of side -by -side testing, a conversion factor is developed. This conversion factor can be applied to oil and grease results obtained by Method 1664 (hexane extraction) in order to determine the expected result that would be obtained by Method 413.1 (freon extraction). In order to investigate potential causes for the higher than normal effluent oil and grease concentrations, Mr. Jim Meyer (NCDENR), Mr. Wayne Turnbull (EPA — Region 4), Mr. William Telliard (EPA, Office of Water) and Ms. Marta Jordan (EPA, Office of Water) were contacted by our wastewater consultant Lili Gellner of Aware Environmental, Inc.. Based on discussions with these individuals, several key issues were identified. They are as follows: 1. Hexane has a higher affinity for extracting petroleum products, compared to freon which has a higher affinity for extracting natural fats and oils. Z. Surfactants appear to be more readily extracted by hexane than freon, which can cause higher results in Method 1664 compared to Method 413.1. Hexane extracted material treated with silica gel may reduce interference from materials such as surfactants but does not interfere with the measurement of petroleum products. Hexane versus Freon Hexane has a higher affinity for petroleum products than freon. Higher oil and grease results under Method 1664 as compared to Method 413.1 would suggest that more of the hydrocarbon products are being extracted with hexane than with freon. Based on the operation and performance of the waste treatment system, it is not expected that higher than normal oil and grease levels are associated with hydrocarbons. The PPG wastewater treatment process is a unique and highly effective system that uses a variety of treatment chemicals, along with physical, chemical and biological processes in order to provide optimum treatment and maintain high effluent quality. The treatment system includes primary treatment with the addition of lime, an aluminum - based coagulant and a polymer. In the secondary biological treatment system, sodium bentonite (clay) is added to the mixed liquor to remove refractory organic compounds and ferric chloride is added prior to the secondary clarifiers to improve settling and turbidity. It is expected that these processes would significantly reduce hydrocarbon oil and grease to very low or non -detectable levels. This corresponds to our historical oil and grease data. Surfactants Based on EPA testing of laundering facilities, surfactants can cause a positive result for oil and grease. PPG uses a significant a mount of surfactants in the production process. In order to reduce the interference from surfactants, it was recommended that hydrocarbon oil and grease be analyzed instead of total oil and grease. Method 1664 measures total oil and grease. In order to measure the hydrocarbon portion of oil and grease, the hexane -extracted material in Method 1664 is treated with silica gel, which removes polar organic material and should remove most surfactants. Since hydrocarbon oil and grease is nonpolar, it should not be affected by the silica gel treatment. In order to determine if PPG's higher than normal effluent oil and grease concentrations were a result of the change in the analytical method, split samples were analyzed using EPA Methods 413.1 and 1664. This testing was performed on several effluent samples from PPG's WWTP. The results of this initial testing showed that Method 413.1 consistently resulted in lower oil and grease concentrations than Method 1664. However, these results suggested that there was not a consistent correlation between the two methods. PPG initiated a program to perform additional testing. PPG routinely collects split samples for effluent oil and grease. The first effluent sample is analyzed using the new Method 1664. If Method 1664 results in a concentration greater than 10 mg/L, the second sample is analyzed using Method 413.1. Method 413.1 has consistently resulted in an effluent oil and grease concentration lower than Method 1664. Effluent oil and grease data collected from December 1999 through April 2000 is presented in Table 1. Based on this data, Method 1664 results in a higher oil and grease concentration. Furthermore, there is not a consistent correlation between Methods 413.1 and 1664 when determining oil and grease in PPG's wastewater. This data shows that Method 1664 can result in an oil and grease concentration from 1.5 to 27 times as high as Method 413.1. Since there is not a good correlation between these results, a conversion factor obtained by side - by -side testing would need to account for the high ratio results. Additional oil and grease data was obtained from Pace Analytical Labs. These data are summarized in Tables 2 and 3 and includes the quality control (QC) analyses for the PPG samples. Table 2 includes a summary of the oil and grease matrix spike results obtained by Method 1664. Table 3 includes of summary of the oil and grease DI water control spike results obtained by both Method 1664 and Method 413.1. This spike recovery results in Table 3 show that DI water spiked with oil and grease provides fairly consistent results for both Method 1664 and Method 413.1. The spike recovery results in Table 2 show that oil and grease recovery from typical samples is highly variable under Method 1664. This type of variability is consistent with the variability in the PPG effluent oil and grease data obtained by Method 1664. Based on the data presented in Table 1, it appears that PPG will be subjected to a greater risk of noncompliance for effluent oil and grease under Method 1664. In order to address this issue while freon is still available, PPG is expanding their testing program. This testing program was initiated the week of May 29, 2000. Each week, approximately six (6) split effluent samples will be collected for oil and grease analysis. Sample No. 1 will be analyzed for oil and grease by Method 1664 and Sample No. 2 will serve as the QC matrix spike for Method 1664. If the oil and grease result by Method 1664 is greater than 10 mg/L, additional analyses will be performed as follows. Sample No. 3 will be analyzed for oil and grease by Method 1664 with the addition of 3 a silica gel treatment and Sample No. 4 will serve as the QC matrix spike. Sample No. 5 will be analyzed for oil and grease by Method 4 13. 1 and Sample No. 6 will serve as the QC matrix spike. It is expected that this testing will help to clarify some of the issues associated with the new analytical Method 1664 and will help to determine a more appropriate oil and grease limit for PPG's effluent. This testing program will continue until a total of eight (8) full sets of oil and grease data are obtained, which is the number of samples required for EPA's method of side -by - side testing. Because Method 1664 does not consistently result in an oil and grease result greater than 10 mg/L, it is expected that testing will take longer than eight weeks to complete. We appreciate NCDENR's cooperation with this testing program. During this testing program, we would like to request that PPG's NPDES permit be temporarily modified from an oil and grease limit of 10 mg/L to a "monitor only" status. PPG will continue to maintain optimum performance of the treatment system throughout this testing program. Sincerely, Lacy allard Attachment cc: Rex Gleason, NCDENR-Mooresville Chet Whiting, NCDENR- Mooresville Bob Stein, AWARE Environmental Inc. Lill Gellner, AWARE Environmental Inc. M. LeCroy R. Daman J. Buchanan 259011001 7 TABLE 1 SUMMARY OF PPG EFFLUENT OIL AND GREASE RESULTS (12/1/99 — 4/12/00) Date Sample Collected PPG Effluent Oil and Grease (mg/L) Ratio of Oil and Grease (Hexane Extraction/Freon Extraction) Hexane Extraction (EPA Method 1664) Freon Extraction (EPA Method 413.1) 12/01/99 <5.0 12/07/99 <5.0 12/15/99 <5.0 12/21/99 11.0 2.6 4.2 12/28/00 <5.0 01/05/00 7.8 _ 01/12/00 9.1 _ 01/19/00 49.0 1.8 27.2 01/26/00 <5.0 02/02/00 6.1 _ 02/09/00 <5.0 02/16/00 11.0 7.3 1.5 02/23 /00 10.0 03 /01 /00 <5.0 03/08/00 <5.0 03/15/00 <5.0 03/22/00 28.0 3.5 8.0 03/29/00 <5.0 04/05/00 5.8 04/ 12/00 15.0 Notes: Split sample not analyzed by Method 413.1 unless result from Method 1664 is greater than 10 mg/L. NA = Not Analyzed 5 TABLE 2 SUMMARY OF LABORATORY MATRIX SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease Matrix Spike EPA Method 1664 - Hexane Extraction Date Background O&G Concentration of Sample (mg/L) Spike O&G Concentration (mg/L) Result (mg/L) % Spike Recovery (mg/L) 12/01/99 11.0 42.1 67.5 134.0 % 12/07/99 0.0 40.0 41.3 103.0 % 12/15/99 6.8 42.1 28.7 52.2 % 12/21/99 14.0 42.1 28.0 33.3 % 12/28/00 11.2 42.1 46.2 83.1 % O1/05/00 7.8 40.0 13.8 15.0 % 01/12/00 13.3 40.0 86.2 182.0 % 0 l/ 19/00 0.0 40.0 19.0 47. 5% O1/26/00 53.1 40.0 165.1 280.0 % 02/02/00 24.3 40.0 38.6 60.0 % 02/09/00 10.6 40.8 65.2 134.0 % 02/16/00 43.8 48.8 65.7 44.9 % 02/23/00 19.3 40.0 51.2 79.8 % 03/01/00 7.2 40.0 31.4 60.5 % 03/08/00 0.0 40.0 29.3 73.3 % 03/15/00 2.9 40.0 17.3 36.0 % 03/22/00 8.8 40.0 37.1 70.8 % 03/29/00 0.1 40.0 34.7 86.5 % 04/05/00 0.0 40.0 52.9 132.0 % 04/ 12/00 10.5 40.0 39.8 73.3 % Maximum Spike Recovery 15.0 % Minimum Spike Recovery 280.0 % TABLE 3 SUMMARY OF LABORATORY DI WATER CONTROL SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease DI Water Control Spike Hexane Extraction EPA Method 1664 Freon Extraction EPA Method 413.1) Date Spike O&G Concentration m Result (mg/L) Percent Spike Recovery m Spike O&G Concentration m Result (mg/L) Percent Spike Recovery (mg/L) 12/01/99 40.0 34.4 86.0 % 12/07/99 40.0 36.1 90.3 % 12/ 15/99 40.0 36.1 90.3 % 12/21/99 40.0 37.9 94.8 % 520.0 477.0 91.7 % 12/28/00 40.0 39.1 97.8 % 01/05/00 40.0 36.6 91.5 % 01/12/00 40.0 38.9 97.3 % 01/19/00 40.0 40.1 100.0 % 501.0 513.0 102.0 % 01/26/00 40.0 44.8 112.0 % 02/02/00 40.0 38.6 96.5 % 02/09/00 40.0 36.2 90.5 % 02/16/00 40.0 37.0 92.5 % 267.0 241.0 90.3 % 02/23/00 40.0 38.2 95.5 % 03/01/00 40.0 36.2 90.5 % 03/08/00 40.0 41.5 104.0 % 03/15/00 40.0 42.4 106.0 % 03/22/00 40.0 47.9 120.0 % 200.0 182.0 91.0 % 03/29/00 40.0 48.3 121.0 % 04/05/00 40.0 53.8 135.0 % 04/ 12/00 40.0 44.4 111.0 % Maximum Spike Recovery 135.0 % 102.0 % (Minimum Spike Recovery 86.0 % 90.3 % PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products March 5, 2001 Mr. Dave Goodrich NCDENR, DWQ Permitting Division 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Request for NPDES Permit Modification for Oil and Grease PPG Industries - Shelby, NC - NPDES No. NC0004685 Dear Mr. Goodrich: i �61r__ �;- 704-434-2261 Extension 544 Iballard@ppg.com The purpose of this letter is to provide an update of the testing described in PPG Industries' (PPG) June 5, 2000 letter sent to NCDENR, and to request a modification to PPG's NPDES permit limits. The June 5' testing program was designed to investigate the differences in methods for determining oil and grease in the PPG wastewater treatment plant final effluent. This letter summarizes the recent inconsistency in oil and grease results in the PPG final effluent and the inadequacy of the new hexane oil and grease method for measuring oil and grease in the PPG final effluent. Furthermore, PPG requests a permit modification for oil and grease analysis, which is more appropriate for this type of wastewater. Background PPG is a fiberglass manufacturer located in Shelby, NC. Process wastewater from our production units is treated in an on -site WWTP before being discharged to Brushy Creek. The waste treatment system is a highly effective system that provides optimum treatment and maintains high effluent quality. It includes primary treatment with the addition of lime, an aluminum -based coagulant and a polymer. In the secondary biological treatment system, sodium bentonite (clay) is added to the mixed liquor to remove refractory organic compounds and ferric chloride is added prior to the secondary clarifiers to improve settling. It is expected that these processes would significantly reduce hydrocarbon oil and grease to very low or non -detectable levels. This has been shown in our historical effluent oil and grease data. The NPDES discharge permit limits effluent oil and grease to a daily maximum of 15 mg/L and a maximum monthly average of 10 mg/L. Historically, the oil and grease effluent concentrations have been well below PPG's permitted discharge limits. Page 2 As of January 1, 2000, CFC-113 (Freon) is no longer being imported into or produced in the United States. Additionally, analytical laboratories will no longer be allowed to use any existing Freon after the year 2005. In April 1998, the analyzing laboratory (Pace Analytical Labs, Huntersville, NC) switched from the EPA Method 413.1, which uses freon as the extracting solvent, to the new EPA Method 1664, which uses n- hexane (hexane) as the extracting solvent in anticipation of this action. Since the switch, PPG effluent oil and grease concentrations have occasionally been higher than ZD normal. Historical effluent oil and grease data is presented in Table 1. Both EPA Methods 413.1 and 1664 were developed for the determination of relatively non-volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials, commonly referred to as total oil and grease. Under EPA Method 413.1, the freon extracted constituents were referred to as "oil and grease". Under EPA Method 1664, the hexane -extracted constituents are referred to as "hexane extractable material," implying that Method 1664 measures not only oil and grease, but any material that can be extracted using hexane. This is problematic for two reasons. ZD First, hexane has a higher affinity for extracting petroleum products, compared to Freon which has a higher affinity for extracting natural fats and oils. Second, surfactants appear to be more readily extracted by hexane than Freon, which can cause higher results in Method 1664 compared to Method 413.1. This was discussed in PPG's letter to you dated June 5, 2000. PPG uses a significant amount of surfactants in the production process. Hexane extracted material treated with silica gel may reduce interference from materials such as surfactants but does not interfere with the measurement of petroleum products. In order to reduce the interference from surfactants, it was recommended in phone conversations with the EPA that hydrocarbon oil and grease be analyzed instead of total oil and grease. Method 1664 measures total oil and grease. In order to measure the hydrocarbon portion of oil and grease, the hexane -extracted material in Method 1664 is treated with silica gel, which removes polar organic material and is expected to remove surfactants. Since hydrocarbon oil and grease is nonpolar, it should not be affected by the silica gel treatment. Oil and grease is a method -defined parameter; therefore, any change in method protocol, such as use of another solvent, has the potential to affect results. The EPA Guidance Document, Analytical Method Guidance for EPA Method 1664A Implementation and Use (40 CFR part 136), indicates that there may be differences in results obtained using Method 1664 compared to Method 413.1. This Guidance Document outlines recommendations for performing side -by -side testing between Method 413.1 and Method 1664. Based on the EPA method of side -by -side testing, a conversion factor is developed. This conversion factor can be applied to oil and grease results obtained by Method 1664 (hexane extraction) in order to determine the expected result that would be obtained by Method 413.1 (Freon extraction). Page 3 Initial Testing and Results In order to determine if PPG's higher than normal effluent oil and grease concentrations were a result of the change in the analytical method, split samples were analyzed using EPA Methods 413.1 and 1664. This testing was performed on several final effluent samples from PPG's WWTP. The results of this initial testing showed that Method 413.1 consistently resulted in lower oil and grease concentrations than Method 1664. However, these results suggested that there was not a consistent correlation between the two methods and that a representative correlation factor could not be developed. PPG then initiated a program to perform additional testing. PPG began collecting split samples for effluent oil and grease. The first effluent sample was analyzed using Method 1664. If Method 1664 resulted in a concentration greater than 10 mg/L, the second sample was analyzed using Method 413.1. Effluent oil and grease data collected from December 1999 through April 2000 is presented in Table 2. Based on this data, it can be seen that Method 1664 typically results in a higher oil and grease concentration. Furthermore, there is not a consistent correlation between Methods 413.1 and 1664 when determining oil -and grease in PPG's wastewater. This data shows that Method 1664 can result in an oil and grease concentration from 1.5 to 27 times as high as Method 413.1. Since there is not a good correlation between these results, a conversion factor obtained by side -by -side testing would need to account for the variation and inconsistency between methods. Additional oil and grease data was obtained from Pace Analytical Labs. These data are summarized in Tables 3 and 4 and include the quality control (QC) analyses for the PPG samples analyzed from December 1999 to April 2000. Table 3 is a summary of the oil and grease matrix spike results obtained by Method 1664. Table 4 is a summary of the oil and grease DI water control spike results obtained by both Method 1664 and Method 413.1. This spike recovery results in Table 4 show that DI water spiked with oil and grease provides fairly consistent results for both Method 1664 and Method 413.1. The spike recovery results in Table 3 show that oil and grease recovery from typical samples is highly variable under Method 1664. This type of variability is consistent with the variability in the PPG effluent oil and grease data obtained by Method 1664. Expanded Testing Program and Results Based on the data presented in Tables 1 and 2, it appears that PPG will be subjected to a greater risk of noncompliance for effluent oil and grease under Method 1664. In order to address this issue while Freon was still available, PPG expanded their testing program. This testing program was initiated the week of May 29, 2000 and is the program described in PPG's June 5' letter. Each week, approximately six (6) split effluent samples were collected for oil and grease analysis. Sample No. 1 was analyzed for oil and grease by Method 1664 and Sample No. 2 served as the QC matrix spike for Method 1664. If the oil and grease result by Method 1664 was greater than 10 mg/L, additional analyses were performed as follows: Sample No. 3 was to be analyzed for oil and grease by Method 1664 with the addition of a silica gel treatment and Sample No. 4 was to serve as the QC matrix spike. Page 4 Sample No. 5 was to be analyzed for oil and grease by Method 413.1 and Sample No. 6 was to serve as the QC matrix spike. The purpose of this testing was to help clarify some of the issues associated with the new analytical Method 1664 and determine a more appropriate oil and grease limit for PPG's effluent. This testing program was originally designed for a total of eight (8) full sets of oil and grease data, which is the number of samples required for EPA's method of side -by -side testing. However, after a five (5) month period, only one (1) sample exceeded an oil and grease concentration of 10 mg/L by Method 1664. Further analysis of this sample using the Freon extraction and the silica gel treated hexane extraction showed that no detectable quantity of oil and grease was present, as shown in Zn Table 5. Although there is only one data set, this information is very important. It shows that although Method 1664 indicated that oil and grease was present at 23.9 mg/L, the material that resulted in the high reading was neither a hydrocarbon nor a natural oil or grease. Method 413.1 resulted in no detectable oil and grease, which indicates that there was no natural oils or greases in the sample. Method 1664 with a silica gel treatment resulted in no detectable oil and grease, which indicates that there was no petroleum hydrocarbons in the sample. Therefore, the high oil and grease measurements are likely caused by a surfactant or other constituent that is neither hydrocarbon nor natural oil or fat. The program has been suspended due to the time, expense and effort required for sample collection. Because the treatment facility operates very effectively, there is no outward indication of when a high oil and grease measurement may occur. The data show that even with hexane, the frequency of high oil and grease measurements is low. Although Method 1664 does not consistently result in high effluent oil and grease levels, the method does put PPG at risk for non-compliance. Guidance Document Summary As outlined in USEPA's Interim Guidance for Performance -Based Reductions of NPDES Permit Monitoring Frequencies, it is within the power of the NPDES authorities to grant relief to regulated facilities that have established a history of both compliance and an ability to consistently reduce the pollutants in their discharge below the levels needed to meet their permit requirements. This relief can come in the form of reduced reporting and monitoring requirements when a facility has demonstrated long term compliance for a given parameter. The following steps are to be taken when determining if a facility is eligible for reductions: 1) Evaluation of the facility's enforcement history. The history includes any environmentally related criminal actions, and any NPDES/Clean Water Act related civil judicial or administrative actions. Page 5 2) Evaluation of the facility's parameter -by -parameter compliance history. In order to be considered, a facility may not have had any Significant Noncompliance violations in the last two (2) years, and no selected (permit - specific) violations within the last year. 3) Application of the parameter -by -parameter performance history. This uses a two year monthly average of effluent data to establish a long term discharge rate. This rate can be used to correlate the monitoring frequency required. 4) The performance levels used to establish the monitoring reductions must be maintained in order to remain eligible for these reductions. Request for Permit Modification PPG has demonstrated both a history of compliance and a genuine interest in compliance with environmental regulations. Data shows that prior to the change in methodology, PPG's effluent oil and grease levels were low to non -detectable. Based on this information, PPG Shelby would like to request that the monitoring frequency of oil and grease be reduced to one event every two months. Prior to the change in laboratory methodology, PPG had a monthly average oil and grease level of approximately 1.8 mg/L (Table 5). This level is only 18 % of their NPDES maximum monthly average limit of 10 mg/L. According to the guidelines established in the interim report, a monthly average (for a weekly sample) that is less than 25 % of the permit limit only needs to be monitored on a bimonthly basis. Also, through parallel sample analysis with freon, PPG has established that the current hexane extraction method can result in false discharge violations. The data generated using the hexane method have shown no correlation to those produced by freon extraction. Therefore, PPG would like to use Method 413.1 for bimonthly, reportable oil and grease measurements. However, due to the pending depletion of Freon. PPG would like to begin analyzing the oil and grease samples using Method 1664 with silica gel. These samples would be monitor -only and used to establish a baseline value for this method. After the baseline has been established, PPG would like to review the data with NCDENR to establish a new oil and grease limit using Method 1664 with silica gel. We feel that the use of Method 1664 with silica gel will provide a more effective and adequate means of monitoring the PPG effluent than the current hexane method. We also feel that the use of silica gel in the oil and grease method will allow us to maintain compliance without altering the intention of the test parameter, which is to determine the quantity of non-volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials. Page 6 Conclusions PPG has demonstrated long-term compliance with environmental regulations. The recent decline in the supply of freon has forced laboratories to use the hexane extraction for the oil and grease analysis. Since the change in methodology, PPG has experienced seemingly random spikes in oil and grease concentration. Further analysis of these samples with freon has shown that the oil and grease levels in PPG's wastewater have not changed. This is further supported by the consistency of both our production and wastewater treatment operations. PPG would like to request that the oil and grease monitoring be reduced to one (1) event every two (2) months. We would also like to analyze oil and grease samples using both Method 413.1 and 1664 with silica gel treatment to prevent surfactant interference. Method 413.1 would be used for reporting purposes. Method 1664 with silica gel treatment would be used to establish a baseline with which to establish future oil and grease limits. We are available to discuss the proposed permit changes with you after you have had a chance to review this information. Please call me at the above number or contact our consultant Lili Gellner of Aware Environmental at 704-845-1697. Sincerely, Lacy 7allard Attachment cc: M. LeCroy R. Daman B. Blackwell J. Buchanan Rex Gleason, NCDENR-Mooresville Bob Stein, AWARE Environmental Inc. Lili Gellner, AWARE Environmental Inc. 259011003 TABLE 1 PPG HISTORICAL EFFLUENT OIL AND GREASE VALUES 1997 Effluent Data 1998 Effluent Data 1999 Effluent Data 2000 Effluent Data Date O&G Monthly Date O&G Monthly Date O&G Monthly Date O&G Monthly (mg/L) Avg. (mg/L) Avg. (mg/L) Avg. (mg/L) Avg. (mg/L) (mglL) (mg/L) (mg/L) 01 /07/1997 ..............3........ .......01 1 3.0 ........................01 01 /05/1998 3 2.0 .........................01 01 /05/1999 22 9.3 01 /05/2000 7.8 7.3 /14/1997 ..................................................................................................................................................................................................................................................................................................................................... /13/1998........................ /12/1999...........<5...... ................. ......01 /12/2000............9.......... ...-.__........ ...01 /21 /1997 ....................................................................................................................................................................................................................................................................................... 1 01 /20/1998 2 01 /19/1999 <5 01 /19/2000 49 1.8 ........(.......... ........ 01/28/1997 .............2................3.0 7 .............02/03/1998.............2...............1..5 01/28/1998 2 ............02/01 01/26/1999 <5 01/26/2000 <5 - ... ......... 02/04/1997 ....................................... .................... ....................... ...................................... .............. ..... ....................... /1999...........<5............................. ..................................... ...... 02/02/2000.............6.1....... ............ 7.0 ......... 02/11 /1997 ........................................................................................................................................................................................................................................................................................................................_.-........ 4 02/10/1998 . 2 02/09/1999 ........ ............ <5 ......... .............. ....................................... 02/09/2000 .................... <5 .............. ----... 02/18/1997 ........................................................................................................... 2 02/17/1998 <1 ........................................................................................................................................................................(.....................-_........ 02/16/1999 <5 02/16/2000 117.3) 02/25/1997 ............................................................ 4 ............................................................................................................................................................................................................................................-.._........... 02/24/1998 <1 02/23/1999 <5 02/23/2000 10 03/04/1997 ..................................................................................................................................................................................................................................................................................................................................... 3 3.0 03/03/1998 <1 1.0 03/02/1999 5 5.9 03/01 /2000 <5 5.0 03/11/1997 3 03/10/1998 1 03/09/1999 7.6 03/08/2000 <5 ................................................................................................. 03/18/1997 3 ............................................................................................................................................................................................................................ 03/17/1998 .................................................................................. <1 03/16/1999 <5 03/15/2000 <5 ....................................... 03/25/1997 .................... .3.......................... ....................... -03/24/1998_ <1 ..................... .............................03/30/1999........._6.7 ..................................... 03/23/1999 .................... <5 ..................................03/29/2000 ....................... ....................................... 03/22/2000 ............<5............................. ........ _........... 28�3.5) ........ -_........... 04/01 /1997 2 1.4 03/31 /1998 .................................................................................. 04/08/1997 ....................................... 1 .................... ....................... 04/07/1998 ...................................... <5 .................... 6.3 ..................................... 04/06/1999 .................... 6.8 ...................... ........................................ 5.5 04/05/2000 .................... 5.8 ............ ....... ... 7.7 04/15/1997 ................................... .... 2 .................... ....................... 04/14/1998 ...................................... <5 ....................... ..................................... 04/13/1999 .................... <5 ....................... ....................................... 04/12/2000 .................... 15 ............. -........ 04/22/1997 ........................................................................................................................................................................................................................................................................................................................_.__..... <1 04/21 /1998 .................... <5 ....................... ..................................... 04/20/1999 .................... <5 ....................... ....................................... 04/19/2000 .................... <5 ............. ......... 04/29/1997 ....................................... <1 04/28/1998 10 04/27/1999 <5 04/26/2000 <5 05/06/1997 ................................................................................................................................................................................................................................................................................................................................... .................... 1 ....................... 1.5 ...................................... 05/05/1998 .................... 49 ....................... 16.5 ..................................... 05/04/1999 .................... <5 ....................... 5.6 ....................................... 05/03/2000 .................... <5 ........... -.......... 6.3 05/13/1997 .......................................................................................................................................................................................................................................................................................... 2 05/12/1998 <5 05/11 /1999 <5 05/10/2000 <5 05/20/1997 .............1........ 2 ................. ... 05/19/1998 7 05/18/1999 <5 05/17/2000 .................... 7.1 .......... -........... 05/27/1997 ........................................ ... .............................. ......05/26/ 1998 ............<5 .................. ...... ... .. ................. ......05/26/1999..........7.4 ..... ................. ... ... ......05/24/2000 ...........7.9 ..................... ... ... 06/03/1997 ...................................................................................................................................................................................................................................................................................................................................... 0.095 1.3 . 06/03/1998 .................... <5 ....................... 5.0 ..................................... 06/01/1999 .................... <5 ....................... 5.9 ....................................... 06/07/2000 .................... <5 ....................... 7.5 06/10/1997 ..............3....`.. 1 .. ... ................. 06/09/1998 ......06/16/1998............<5...... <5 06/08/1999 <5 06/14/2000 10 06/18/1997 ....................................... .................... ....................... ...................................... .. .........................06/15/1999.........-5.3............................._......06/21/2000............8.1....... ... ... .......-.. 06/24/1997 ..................................................................................................................................................................................................................................................................................................................................... <1 06/23/1998 .................... <5 ....................... ..................................... 06/23/1999 .................... <5 ....................... ....................................... 06/28/2000 ..................... 7 ...... _............... _07/01/1997 ....... ..<.1 ....... . 1.0.............06/30/1998.............<..5.................................._06/30/1999...........9:4..................................07/05/2000............9:4..............�:0....... 07/08/1997 ................................................................................................................................................................................................................................................................................................... <1 07/07/1998 <5 20.5 07/06/1999 <5 9.9 07/12/2000 5 07/15/1997 ....................................... <1 .................... 07/14/1998 <5 07/13/1999 23 07/19/2000 8 07/22/1997 ....................................... <1 ..................................................................................................... ....................... ...................................... 07/21 /1998 ... ................ <5 ....................... ..................................... 07/20/1999 .................... 6.4 ....................... ....................................... 07/26/2000 .... ................ 5.5 ......... .--........ 07/29/1997 ....................... ..................................... 07/27/1999 ........ ........... <5 ....................... ....................................... 08/02/2000 .................... <5 ....................... 8.8 08J05/1997 ............................................................................................................................................................................................................._........................................................................................-........................... .<1' 1 1.3 .07/28/1998 ......... 08/04/1998 .67 ................................................................................................................................................................................................. <5 18.5 08/03/1999 <5 5.9 08/09/2000 <5 08/12/1997 ......................................................................................................................................................................................................................................................................................................................_.............. 2 08/11/1998 32 08/10/1999 <5 08/16/2000 <5 08/19/1997 ................................................................................................................................................................................................................................................................................................... <1 08/18/1998 32 08/17/1999 8.7 08/23/2000 24 08/26/1997 .......................... <1 .....................................................................................................................................-....................................................................................................................... 08/25/1998 <5 08/24/1999 <5 08/30/2000 <5 09/02/1997 ...................................................................................................................................................................................................................................................................................................................................... <1 2.2 09/01/1998 <5 27.5 09/07/1999 <5 5.3 09/07/2000 <5 6.3 09/09/1997 ...................................... <1 .................... ....................... 09/08/1998 ...................................... <5 09/15/1999 <5 09/14/2000 8 09/16/1997 ...................................................................................................................................................................................................................................................................................................................................... 6 09/15/1998 .................... 2.4 ....................... ..................................... 09/21/1999 .................... 6.3 ....................... ....................................... 09/20/2000 .................... 5.4 ............ .......... 09/23/1997 ............................................................................................................................................................................................................................................................................................................................_...... <1 09/22/1998 <5 09/28/1999 <5 C9/27/2000 6.8 09/30/1997 ...................................................................................................................................................................................................................................................................................................................................... 2 09/28/1998 120 10/05/1999 <5 13.0 10/04/2000 <5 5.4 10/07/1997 ...................................................................................................................................................................................................................................................................................................................................... 3 1.8 10/06/1998 6 5.3 10/12/1999 <5 10/11/2000 <5 10/14/1997 .......................................................................................................................................................................................................................................................................................................-............................ 2 10/13/1998 <5 10/19/1999 25 10/18/2000 6.6 10/21/1997 ...................................................................................................................................................................................................................................................................................................................................... <1 10/20/1998 5 10/26/1999 17 10/25/2000 <5 10/28/1997 <1 ... ......1..0....... 10/28/1998 ......11103/1998..........-<5..... <5 11/02/1999 <5 15.2 11/01/2000 <5 <5.0 11 /04/1997.........._<�...... ..................................................................................................................................................................................................................................................................................................................................... .... ......5.0..... ......11 /09/1999.........-56 ..... .... ................. ... ......1..1 /08/2000............<5...... ..... ................ ... 11 /11 /1997 ..................................................................................................................................................................................................................................................................................................................................... 1 11 /10/1998 <5 11 /16/1999 <5 11 /15/2000 <5 11 /18/1997 .......................................................................................................................................................................................................................................................................................... <1 11 /17/1998 <5 11 /23/1999 <5 11 /22/2000 <5 11/25/1997 ..................................................................................................................................................................................................................................................................................................................................... 1 11/24/1998 <5 11/30/1999 <5 11/29/2000 - .................. <5 12/02/1997 ..................................................................................................................................................................................................................................................................................................................................... <1 1.6 12/01 /1998 46 22.2 12/07/1999 <5 5.0 12/06/2000 <5 <5.6 12/09/1997 1 12/08/1998 <5 12/14/1999 <5 12/13/2000 <5 ......................................................................................................................................................................................................-...................................................................................................................... 12/16/199................ .........2 .......... �....................................12/15/1998............ 50...................................12/21 /1.999............�2 6)...............................12/20/2000.........._7:4............................. 12/24/1997 .................... ............................................................................................................................................................................................... ANNUAL AVG. 1.8 1.8 11.2 10.9 7.8 1 7.6 6.6 6.6 Notes: All analyses performed four 1/7/97 through 3/31/98 performed using freon extraction. Laboratory switched to hexane extraction starting with 4/77/98 data. Values in parentheses indicate freon results from split samples. 25901 s008.x1s 7 TABLE 2 SUMMARY OF PPG EFFLUENT OIL AND GREASE RESULTS (12/1/99 - 4/12/00) Date Sample Collected PPG Effluent Oil and Grease (mg/L) Ratio of Oil and Grease (Hexane Extraction/Freon Extraction) Hexane Extraction (EPA Method 1664 Freon Extraction (EPA Method 413.1) 12/01 /99 < 5.0 -- 12/07/99 < 5.0 -- 12/15/99 <5.0 -- 12/21 /99 11.0 2.6 4.2 12/28/00 < 5.0 -- i I 01/05/00 7.8 -- 01 / 12 /00 9.1 -- 01 / 19/00 49.0 1.8 27.2 01 /26/00 < 5.0 -- 02/02/00 6.1 -- 02/09/00 < 5.0 -- 02/16/00 11.0 7.3 1.5, 02/23/00 10.0 -- 03 /01 /00 < 5.0 -- 03/08/00 < 5.0 -- 03/ 15/00 < 5.0 -- 03/22/00 28.0 3.5 8.0 03/29/00 < 5.0 -- 04/05/00 5.8 -- 04/12/00 15.0 -- Notes: Split sample not analyzed by Method 413.1 unless result from Method 1664 is greater than 10 mg/L. TABLE 3 SUMMARY OF LABORATORY MATRIX SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease Matrix Spike (EPA Method 1664 - Hexane Extraction) Date Background O&G Concentration of Sample (mg/L) Spike O&G Concentration (mg/L) Result (mg/L) % Spike Recovery (mg/L) y 12/01/99 11.0 42.1 67.5 134.0 % 12/07/99 0.0 40.0 41.3 103.0 % 12/15/99 6.8 42.1 28.7 52.2 % 12/21/99 14.0 42.1 28.0 33.3 12/28/00 11.2 42.1 46.2 83.1 % 01/05/00 7.8 40.0 13.8 15.0 % j 01/12/00 13.3 40.0 86.2 182.0 % 01 / 19/00 0.0 40.0 19.0 47.5 % 01/26W 53.1 40.0 165.1 280.0 % 02/02/00 24.3 40.0 38.6 60.0 % 02/09/00 10.6 40.8 65.2 134.0 % 02/16/00 43.8 48.8 65.7 44.9 % 02/23/00 19.3 40.0 51.2 79.8 % 03/01/00 7.2 40.0 31.4 60.5 % 03/08/00 0.0 40.0 29.3 73.3 % 03/15/00 2.9 40.0 17.3 36.0 % 03/22/00 8.8 40.0 37.1 70.8 % 03/29/00 0.1 40.0 34.7 86.5 % 04/05/00 0.0 40.0 52.9 132.0 % 04/12/00 10.5 40.0 39.8 73.3 % Minimum F- Spike Recover l 15.0 % Maximum S ike Recoveryl 280.0 % TABLE 4 SUMMARY OF LABORATORY DI WATER CONTROL SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease DI Water Control Spike I-lexane Extraction (EPA Method 1664) Freon Extraction (EPA Method 413.1) Date Spike O&G Concentration (m /L) Result (mg/L) percent Spike Recovery (mg/L) Spike O&G Concentration (m /L) Result (mg/L) Percent Spike Recovery (mg/L) 12/01/99 40.0 34.4 86.0 % 12/07/99 40.0 36.1 90.3 % 12/15/99 40.0 36.1 90.3 % 12/21/99 40.0 37.9 94.8 % 520.0 477.0 91.7 % 12/28/00 40.0 39.1 97.8 % 01/05/00 40.0 36.6 91.5 % 01/12/00 40.0 38.9 97.3 % 01/19/00 40.0 40.1 100.0 % 501.0 513.0 102.0 % 01 /26/00 40.0 44.8 112.0 % 02/02/00 40.0 38.6 96.5 % 02/09/00 40.0 36.2 90.5 % 02/ 16/00 40.0 37.0 92.5 % 267.0 241.0 90.3 % 02/23/00 40.0 38.2 95.5 % . 03/01/00 40.0 36.2 90.5 % 03/08/00 40.0 41.5 104.0 % 03/15/00 40.0 42.4 106.0 % 03/22/00 40.0 47.9 120.0 % 200.0 182.0 91.0 % 03/29/00 40.0 48.3 121.0 % 04/05/00 40.0 53.8 _ 135.0 % 04/12/00 40.0 44.4 111.0 Maximum Spike Recovery 135.0 % 102.0 % Minimum Spike Recover 86.0 % 90.3 % TABLE 5 SUMMARY OF PPG EFFLUENT OIL AND GREASE RESULTS (5/24/00-9/20/00) Date Sample Collected PPG Effluent Oil and Grease (mg/L) Ratio of Hexane Extraction/Freon Extraction Total Petroleum Hydrocarbons - Freon Extraction (mg/L) Hexane Extraction Silica Gel Treated Hexane Extraction Freon Extraction 05/24/00 7.9 05/31/00 <5 (0.1) 06/07/00 <5 (2.0) 06/ 14/00 10.0 06/21/00 8.1 06/28/00 7.0 07/05/00 9.4 07/12/00 8.6 07/ 19/00 8.0 07/26/00 5.5 08/02/00 <5 (0.0) 08/09/00 < 5 (4.2) 08/16/00 <5 (3.0) 08/23/00 23.9 < 1 > 23.9 0.161 08/30/00 < 5 (1.9) -<5 09/07/00 < 5 (1.7) 09/13/00 8.0 09/20/00 5.4 11 1 PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 Lacy Ballard, R. E. M. 704-434-2261 Staff Engineer, Environmental Extension 544 Fiber Glass Products Iballard@ppg.com March 5, 2001�S4T Vi- Mr. Dave Goodrich NCDENR, DWQ Permitting Division MAR 07 2001 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Request for NPDES Permit Modification for Oil and GreaWATER el PPG Industries - Shelby, NC - NPDES No. NC0004685 Dear Mr. Goodrich: The purpose of this letter is to provide an update of the testing described in PPG Industries' (PPG) June 5, 2000 letter sent to NCDENR, and to request a modification to PPG's NPDES permit limits. The June 5`' testing program was designed to investigate the differences in methods for determining oil and.grease in the PPG wastewater treatment plant final effluent. This letter summarizes the recent inconsistency in oil and grease results in the PPG final effluent and the inadequacy of the new hexane oil and grease method for measuring oil and grease in the PPG final effluent. Furthermore, PPG requests a permit modification for oil and grease analysis, which is more appropriate for this type of wastewater. Background PPG is a fiberglass manufacturer located in Shelby, NC. Process wastewater from our production units is treated in an on -site WWTP before being discharged to Brushy Creek. The waste treatment system is a highly effective system that provides optimum treatment and maintains high effluent quality. It includes primary treatment with the addition of lime, an aluminum -based coagulant and a polymer. In the secondary biological treatment system, sodium bentonite (clay) is added to the mixed liquor to remove refractory organic compounds and ferric chloride is added prior to the secondary clarifiers to improve settling. It is expected that these processes would significantly reduce hydrocarbon oil and grease to very low or non -detectable levels. This has been shown in our historical effluent oil and grease data. The NPDES discharge permit limits effluent oil and grease to a daily maximum of 15 mg/L and a maximum monthly average of 10 mg/L. Historically, the oil and grease effluent concentrations have been well below PPG's permitted discharge limits. Page 2 As of January 1, 2000, CFC-113 (Freon) is no longer being imported into or produced in the United States. Additionally, analytical laboratories will no longer be allowed to use any existing Freon after the year 2005. In April 1998, the analyzing laboratory (Pace Analytical Labs, Huntersville, NC) switched from the EPA Method 413.1, which uses freon as the extracting solvent, to the new EPA Method 1664, which uses n- hexane (hexane) as the extracting solvent in anticipation of this action. Since the switch, PPG effluent oil and grease concentrations have occasionally been higher than normal. Historical effluent oil and grease data is presented in Table 1. Both EPA Methods 413.1 and 1664 were developed for the determination of relatively non-volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials, commonly referred to as total oil and grease. Under EPA Method 413.1, the freon extracted constituents were referred to as "oil and grease". Under EPA Method 1664, the hexane -extracted constituents are referred to as "hexane extractable material," implying that Method 1664 measures not only oil and grease, but any material that can be extracted using hexane. This is problematic for two reasons. First, hexane has a higher affinity for. extracting petroleum products, compared to Freon which has a higher affinity for extracting natural fats and oils. Second, surfactants appear to be more readily extracted by hexane than Freon, which can cause higher results in Method 1664 compared to Method 413.1. This was discussed in PPG's letter to you dated June 5, 2000. PPG uses a significant amount of surfactants in the production process. Hexane extracted material treated with silica gel may reduce interference from materials such as surfactants but does not interfere with the measurement of petroleum products. In order to reduce the interference from surfactants, it was recommended in phone conversations with the EPA that hydrocarbon oil and grease be analyzed instead of total oil and grease. Method 1664 measures total oil and grease. In order to measure the hydrocarbon portion of oil and grease, the hexane -extracted material in Method 1664 is treated with silica gel, which removes polar organic material and is expected to remove surfactants. Since hydrocarbon oil and grease is nonpolar, it should not be affected by the silica gel treatment. Oil and grease is a method -defined parameter; therefore, any change in method protocol, such as use of another solvent, has the potential to affect results. The EPA Guidance Document, Analytical Method Guidance for EPA Method 1664A Implementation and Use (40 CFR part 136), indicates that there may be differences in results obtained using Method 1664 compared to Method 413.1. This Guidance Document outlines recommendations for performing side -by -side testing between Method 413.1 and Method 1664. Based on the EPA method of side -by -side testing, a conversion factor is developed. This conversion factor can be applied to oil and grease results obtained by Method 1664 (hexane extraction) in order to determine the expected result that would be obtained by Method 413.1 (Freon extraction). Page 3 Initial Testing and Results In order to determine if PPG's higher than normal effluent oil and grease concentrations were a result of the change in the analytical method, split samples were analyzed using EPA Methods 413.1 and 1664. This testing was performed on several final effluent samples from PPG's VV VTP. The results of this initial testing showed that Method 413.1 consistently resulted in lower oil and grease concentrations than Method 1664. However, these results suggested that there was not a consistent correlation between the two methods and that a representative correlation factor could not be developed. PPG then initiated a program to perform additional testing. PPG began collecting split samples for effluent oil and grease. The first effluent sample was analyzed using Method 1664. If Method 1664 resulted in a concentration greater than 10 mg/L, the second sample was analyzed using Method 413.1. Effluent oil and grease data collected from December 1999 through April 2000 is presented in Table 2. Based on this data, it can be seen that Method 1664 typically results in a higher oil and grease concentration. Furthermore, there is not a consistent correlation between Methods 413.1 and 1664 when determining oil and grease in PPG's wastewater. This data shows that Method 1664 can result in an oil and grease concentration from 1.5 to 27 times as high as Method 413.1. Since there is not a good correlation between these results, a conversion factor obtained by side -by -side testing would need to account for the variation and inconsistency between methods. Additional oil and grease data was obtained from Pace Analytical Labs. These data are summarized in Tables 3 and 4 and include the quality control (QC) analyses for the PPG samples analyzed from December 1999 to April 2000. Table 3 is a summary of the oil and grease matrix spike results obtained by Method 1664. Table 4 is a summary of the oil and grease DI water control spike results obtained by both Method 1664 and Method 413.1. This spike recovery results in Table 4 show that DI water spiked with oil and grease provides fairly consistent results for both Method 1664 and Method 413.1. The spike recovery results in Table 3 show that oil and grease recovery from typical samples is highly variable under Method 1664. This type of variability is consistent with the variability in the PPG effluent oil and grease data obtained by Method 1664. Expanded Testing Program and Results Based on the data presented in Tables 1 and 2, it appears that PPG will be subjected to a greater risk of noncompliance for effluent oil and grease under Method 1664. In order to address this issue while Freon was still available, PPG expanded their testing program. This testing program was initiated the week of May 29, 2000 and is the program described in PPG's June 5' letter. Each week, approximately six (6) split effluent samples were collected for oil and grease analysis. Sample No. 1 was analyzed for oil and grease by Method 1664 and Sample No. 2 served as the QC matrix spike for Method 1664. If the oil and grease result by Method 1664 was greater than 10 mg/L, additional analyses were performed as follows: Sample No. 3 was to be analyzed for oil and grease by Method 1664 with the addition of a silica gel treatment and Sample No. 4 was to serve as the QC matrix spike. Page 4 Sample No. 5 was to be analyzed for oil and grease by Method 413.1 and Sample No. 6 was to serve as the QC matrix spike. The purpose of this testing was to help clarify some of the issues associated with the new analytical Method 1664 and determine a more appropriate oil and grease limit for PPG's effluent. This testing program was originally designed for a total of eight (8) full sets of oil and grease data, which is the number of samples required for EPA's method of side -by -side testing. However, after a five (5) month period, only one (1) sample exceeded an oil and grease concentration of 10 mg/L by Method 1664. Further analysis of this sample using the Freon extraction and the silica gel treated hexane extraction showed that no detectable quantity of oil and grease was present, as shown in Table 5. Although there is only one data set, this information is very important. It shows that although Method 1664 indicated that oil and grease was present at 23.9 mg/L, the material that resulted in the high reading was neither a hydrocarbon nor a natural oil or grease. Method 413.1 resulted in no detectable oil and grease, which indicates that there was no natural oils or greases in the sample. Method 1664 with a silica gel treatment resulted in no detectable oil and grease, which indicates that there was no petroleum hydrocarbons in the sample. Therefore, the high oil and grease measurements are likely caused by a surfactant or other constituent that is neither hydrocarbon nor natural oil or fat. The program has been suspended due to the time, expense and effort required for sample collection. Because the treatment facility operates very effectively, there is no outward indication of when a high oil and grease measurement may occur. The data show that even with hexane, the frequency of high oil and grease measurements is low. Although Method 1664 does not consistently result in high effluent oil and grease levels, the method does put PPG at risk for non-compliance. Guidance Document Summary As outlined in USEPA's Interim Guidance for Performance -Based Reductions of NPDES Permit Monitoring Frequencies, it is within the power of the NPDES authorities to grant relief to regulated facilities that have established a history of both compliance and an ability to consistently reduce the pollutants in their discharge below the levels needed to meet their permit requirements. This relief can come in the form of reduced reporting and monitoring requirements when a facility has demonstrated long term compliance for a given parameter. The following steps are to be taken when determining if a facility is eligible for reductions: 1) Evaluation of the facility's enforcement history. The history includes any environmentally related criminal actions, and any NPDES/Clean Water Act related civil judicial or administrative actions. Page 5 2) Evaluation of the facility's parameter -by -parameter compliance history. In order to be considered, a facility may not have had any Significant Noncompliance violations in the last two (2) years, and no selected (permit - specific) violations within the last year. 3) Application of the parameter -by -parameter performance history. This uses a two year monthly average of effluent data to establish a long term discharge rate. This rate can be used to correlate the monitoring frequency required. 4) The performance levels used to establish the monitoring reductions must be maintained in order to remain eligible for these reductions. Request for Permit Modification PPG has demonstrated both a history of compliance and a genuine interest in compliance with environmental regulations. Data shows that prior to the change in methodology, PPG's effluent oil and grease levels were low to non -detectable. Based on this information, PPG Shelby would like to request that the monitoring frequency of oil and grease be reduced to one event every two months. Prior to the change in laboratory methodology, PPG had a monthly average oil and grease level of approximately 1.8 mg/L (Table 5). This level is only 18 % of their NPDES maximum monthly average limit of 10 mg/L. According to the guidelines established in the interim report, a monthly average (for a weekly sample) that is less than 25 % of the permit limit only needs to be monitored on a bimonthly basis. Also, through parallel sample analysis with freon, PPG has established that the current hexane extraction method can result in false discharge violations. The data generated using the hexane method have shown no correlation to those produced by freon extraction. Therefore, PPG would like to use Method 413.1 for bimonthly, reportable oil and grease measurements. However, due to the pending depletion of Freon, PPG would like to begin analyzing the oil and grease samples using Method 1664 with silica gel. These samples would be monitor -only and used to establish a baseline value for this method. After the baseline has been established, PPG would like to review the data with NCDENR to establish a new oil and grease limit using Method 1664 with silica gel. We feel that the use of Method 1664 with silica gel will provide a more effective and adequate means of monitoring the PPG effluent than the current hexane method. We also feel that the use of silica gel in the oil and grease method will allow us to maintain compliance without altering the intention of the test parameter, which is to determine the quantity of non-volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials. Page 6 Conclusions PPG has demonstrated long-term compliance with environmental regulations. The recent decline in the supply of freon has forced laboratories to use the hexane extraction for the oil and grease analysis. Since the change in methodology, PPG has experienced seemingly random spikes in oil and grease concentration. Further analysis of these samples with freon has shown that the oil and grease levels in PPG's wastewater have not changed. This is further supported by the consistency of both our production and wastewater treatment operations. PPG would like to request that the oil and grease monitoring be reduced to one (1) event every two (2) months. We would also like to analyze oil and grease samples using both Method 413.1 and 1664 with silica gel treatment to prevent surfactant interference. Method 413.1 would be used for reporting purposes. Method 1664 with silica gel treatment would be used to establish a baseline with which to establish future oil and grease limits. We are available to discuss the proposed permit changes with you after you have had a chance to review this information. Please call me at the above number or contact our consultant Lili Gellner of Aware Environmental at 704-845-1697. Sincerely, Attachment cc: M. LeCroy R. Daman B. Blackwell J. Buchanan Rex Gleason, NCDENR-Mooresville Bob Stein, AWARE Environmental Inc. Lili Gellner, AWARE Environmental Inc. 259011003 TABLE 1 PPG HISTORICAL EFFLUENT OIL AND GREASE VALUES 1997 Effluent Data 1998 Effluent Data _ 1999 Effluent Data 2000 Effluent Data Date O&G Monthly Date O&G Monthly Date O&G Monthly Date O&G Monthly (mg/L) Avg. (mg/L) Avg. (mg/L) Avg. (mg/L) Avg. (mg/L) (mg/L) (mg/L) (mg/L) 01 /07/1997 1 3.0 01 /05/1998 3 2.0 01 /05/1999 22 9.3 01 /05/2000 7.8 7.3 .................................................................................................................................................................................................................................................................................................................... 01 /14/1997 3 01 /13/1998 1 01 /12/1999 <5 01 /12/2000 9.1 .................................................................................................................................................................................................................................................................................................................... ................. . 01 /21 /1997 /20/1.998..............2.....................................01 /19/1999............<.5...................................01 /19/2000........49.0.:$)......................... ....................................................01 01 /28/1997 7 01 /28/1998 2 01 /26/1999 <5 01 /26/2000 <5 .02/04/1997..............2................3.0.............02/03/1998..............2.................1..5............02/01 /1999.........._<5..............5.0.............02/02/2000.............6.1...............7.0....... .................................................................................................................................................................................................................................................................................................................. 02/11 /1997 4 02/10/1998 2 02/09/1999 <5 02/09/2000 <5 ..................................................................................................................................................................................................................................................................................................................... 02/18/1997 2 02/17/1998 ........................................................................................................................ 02/25/1997 4 02/24/1998 ........<..�....................................02/16/1999............<.5...................................02/16/2000........1.�..��3!......................... �.............................. 03/04/1997 3 3.0 03/03/1998 ..<......................................02/23/1.999............<.5.................................._02/23/2000..............1 <1 1.0 03/02/1999 5 5.9 03/01 /2000 <5 5.0 ...................................................................................................................................................................................................................................................................................................................................... 03/11 /1997 3 03/10/1998 1 03/09/1999 7.6 03/08/2000 <5 ...................................................................................................................................................................................................................................................................................................................................... 03/18/1997 3 03/17/1998 <1 03/16/1999 <5 03/15/2000 <5 ........................... ....................................... 03/25/1997 .................... 3 ............................................................. 03/24/1998 ........................................... <1 ..................................... 03/23/1999 .................... <5 .......................... ..................................................... 03/22/2000 28 3.5 ......................... .......................................................................................................................................................................................................................................................................................... 04/01 /1997 2 1.4 03/31 /1998 <1 03/30/1999 6.7 03/29/2000 <5 .................................................................................. 04/07/1998 <5 6.3 ................................................................................................................................................................... 04/06/1999 6.8 5.5 04/05/2000 5.8 7.7 .04/08/1.997..............1.......................... 04/15/1997 2 04/14/1998 ........................................................................................................................................................................................................... <5 04l13/1999 <5 04/12/2000 15 ..............................................................................................................................� 04/22/1997 <1 04/21/1998 ............................................................................�5...................................04/19/2000..............�5.............................. 5 04/20/1999 ...................................................................................................................................................................................................................................................................................................................................... 04/29/1997 <1 04/28/1998 10 04/27/1999 <5 .............05/03/2000 04/26/2000 .......................... <5 ........6.3....... 05/06/1997..............1.......:.........1..5 .............05/05/1998............49..............16.5..........05/04/1999...........<5..............5.6 .................................................................................................................................................................................................................................................................................................................. 05/13/1997 2 05/12/1998 <5 05/11 /1999 <5 05/10/2000 <5 .................................................................................................................................................................................................................................................................................................................... 05/20/1997 2 05/19/1998 7 05l18/1999 <5 05/17/2000 7.1 .................................................................................................................................................................................................................................................................................................................... 05/27/1997 1 05/26/1998 <5 05/26/1999 7.4 05/24/2000 7.9 ............................ 06/03/1997 0.095 ............................................................................................................................................................................................................................................................... 1.3 06/03/1998 <5 5.0 06/01/1999 <5 5.9 06/07/2000 <5 7.5 .................................................................................................................................................................................................................................................................................................................... 06/10/1997 1 06/09/1998 <5 06/08/1999 <5 06/14/2000 10 .................................................................................................................................................................................................................................................................................................................... 06/18/1997 3 06/16/1998 <5 06/15/1999 5.3 O6/21l2000 8.1 ...................................................................................................................................................................................................................................................................................................................................... 06/24/1997 <1 06/23/1998 <5 06/23/1999 <5 06/28/2000 7 ...... .07/01/1997.......................... ........1..0.............06/30/1998............<5 ...... ........................06/30/1999......... 9.4....................... ......07/05/2000.............9.4...............7.0 ...................................................................................................................................................................................................................................................................................................................................... 07/08/1997 <1 07/07/1998 <5 20.5 07/06/1999 <5 9.9 07/12/2000 5 ...................................................................................................................................................................................................................................................................................................................................... 07/15/1997 <1 07/14/1998 <5 07/13/1999 23 07/19/2000 8 ...................................................................................................................................................................................................................4................................................................................................................ 07/22/1997 <1 07/21/1998 <5 07/20/1999 6.4 07/26/2000 5.5 ...................................................................................................................................................................................................................................................................................................................................... 07/29/1997 <1 07/28/1998 67 07/27/1999 <5 08/02/2000 <5 8.8 ....... ... ................................................................................................................................................................................................................................................................................................................. 08/05/1997 1 1.3 08/04/1998 <5 18.5 08/03/1999 <5 5.9 08/09/2000 <5 ...................................................................................................................................................................................................................................................................................................................................... 08/12/1997 2 08/11 /1998 32 08/10/1999 <5 08/16/2000 <5 ................................................................................................................................................................................................................................................................................................................. 08/19/1997 <1 08/18/1998 32 08/17/1999 8.7 08/23/2000 24 ..............................................�.................................................................................................................................................................................................................................................................................... 08/26/1997 1 08/25/1998 <5 08/24/1999 <5 08/30/2000 <5 ........<5............................. 09/02/1997..........._<1 ...............2.2.............09/01 /1998............<5.............27.5...........09/07/1999.......... <5............................. ...................................09/ ....................................... ....................... 09/09/1997 ...................................................................................................................................................................... <1 09/08/1998 <5 09/15/1999 <5 14/2000........................... .................................................................................................................................................................................................................................................................................................................... 09/16/1997 6 09/15/1.998 2.4 09/21 /1999 6.3 09/20/2000 5.4 ........................................ 09/23/1997 <1 09/22/1998 ................................................................................................................................................................................................. <5 09/28/1999 <5 09/27/2000 ............................................... ................ 6.8 ....................................................................................................................................................................................................................................................................... 09/30/1997 2 09/28/1998 120 10/05/1999 <5 13.0 10/04/2000 <5 5.4 .......10/07/1997...................................:8.............10/06/1998............. S.................5.3 ............10l12/1999...........<5...................................10/1.. /2000..............e5.............................. ................................................................................... ............................................................................................................................................................................................................................. 10/14/1997 2 10/13/1998 <5 10/19/1999 25 ............................................................... 10/18/2000 6.6 ... ................................. 10/21 /1997 <1 ................................................................ 10/20/1998 5 .............................................................. 10/26/1999 17 10/25/2000 <5 ...................................................................................................................................................................................................................................................................................................................................... 10/28/1997 <1 10/28/1998 <5 11 /02/1999 <5 ..... 15.2 ................. 11 /01 /2000 ......11 <5 ......<5...... <5.0 ................. 11 /04/1997..... ...................................................................................................................................................................................................................................................................................................................................... ......<1..... ......1..0..... ......11 /03/1998...........<5..... ......5.0..... ......11 /09/1999..........5s /08/2000..... 11 /11 /1997 1 11 /10/1998 <5 11 /16/1999 <5 11 /15/2000 <5 ................................................................................................. 11 /18/1997 <1 ............................................................................................................................................................................................................................ 11 /17/1998 <5 11 /23/1999 <5 11 /22/2000 <5 ...................................................................................................................................................................................................................................................................................................................................... 11 /25/1997 1 11/24/1998 <5 11 /30/1999 <5 11 /29/2000 <5 ......<5.............<5.6..... 12/0211997.........._<�...... ......1..fi..... ......12/01 /1998...........46 ...........22.2...........12/07/1999........._<5 .............5.0..... ....................................... .......................................................................................... 12/09/1997 1 .............................................................................................................................................................................................................................. 12/08/1998 <5 12/14/1999 <5 12/13/2000 <5 12/16/1997 2........ 12/15/1998 ................................................................................................................................................................................................... 50 12/21 /1999 11(2.6) 12/20/2000 7.4 .................................................................................................. 12/24/1997 2 12/22/1998 <5 .......................................................................................................................................................... 12/28/1999 <5 12/27/2000 <5 ...................................................................................................................................................................................................................................................................................................................................... 12/31 /1997 2 12/29/1998 <5 [ANNUAL AVG. 1.8 1 1.8 11.2 1 10.9 7.8 7.6 6.6 6.6 Notes: All analyses performed four 1(7/97 through 3/31/98 performed using freon extraction. Laboratory switched to hexane extraction starting with 417/98 data. Values in parentheses indicate freon results from split samples. 25901 s008.xls 7 TABLE 2 SUMMARY OF PPG EFFLUENT OIL AND GREASE RESULTS (12/1/99 — 4/12/00) Date Sample Collected PPG Effluent Oil and Grease (mg/L) Ratio of Oil and Grease (Hexane Extraction/Freon Extraction) Hexane Extraction (EPA Method 1664) Freon Extraction (EPA Method 413.1) 12/01 /99 < 5.0 -- 12/07/99 < 5.0 -- 12/15/99 <5.0 -- 12/21 /99 11.0 2.6 4.2 12/28/00 < 5.0 -- 01 /05/00 7.8 -- 01 / 12/00 9.1 -- 01 / 19/00 49.0 1.8 27.2 01 /26/00 < 5.0 -- 02/02/00 6.1 -- 02/09/00 < 5.0 -- 02/16/00 11.0 7.3 1.5 02/23/00 10.0 -- 03 /01 /00 < 5.0 -- 03/08/00 < 5.0 -- 03/ 15/00 < 5.0 -- 03/22/00 28.0 3.5 8.0 03/29/00 < 5.0 -- 04/05/00 5.8 -- 04/12/00 15.0 -- Notes: Split sample not analyzed by Method 413.1 unless result from Method 1664 is greater than 10 mg/L. TABLE 3 SUMMARY OF LABORATORY MATRIX SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease Matrix Spike (EPA Method 1664 - hexane Extraction) Date Background O&G Concentration of Sample (mg/L) Spike O&G Concentration (mg/L) Result (mg/L) % Spike Recovery (mg/L) 12/01/99 11.0 42.1 67.5 134.0 % 12/07/99 0.0 40.0 41.3 103.0 % 12/15/99 6.8 42.1 28.7 52.2 % 12/21/99 14.0 42.1 28.0 33.3 % 12/28/00 11.2 42.1 46.2 83.1 % 01/05/00 7.8 40.0 13.8 15.0 % 01/12/00 13.3 40.0 86.2 182.0 % 01/19/00 0.0 40.0 19.0 47.5 % 01/26/00 53.1 40.0 165.1 280.0 % 02/02/00 24.3 40.0 38.6 60.0 % 02/09/00 10.6 40.8 65.2 134.0 % 02/ 16/00 43.8 48.8 65.7 44.9 % 02/23/00 19.3 40.0 51.2 79.8 % 03/01/00 7.2 40.0 31.4 60.5 % 03/08/00 0.0 40.0 29.3 73.3 % 03/15/00 2.9 40.0 17.3 36.0 % 03/22/00 8.8 40.0 37.1 70.8 % 03/29/00 0.1 40.0 34.7 86.5 % 04/05/00 0.0 40.0 52.9 132.0 04/12/00 10.5 40.0 39.8 73.3 % Minimum Spike Recover 15.0 % m S i Maximuke Recover 280.0 TABLE 4 SUMMARY OF LABORATORY DI WATER CONTROL SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease DI Water Control Spike Hexane Extraction (EPA Method 1664) Freon Extraction (EPA Method 413.1) Date - Spike O�iG Concentration (m /L) Result (mg/L) percent Spike Recovery (mg/L) Spike O&G Concentration (m /L) Result (mg/L) percent Spike Recovery (mg/L) 12/01 /99 40.0 34.4 86.0 % 12/07/99 40.0 36.1 90.3 % 12/15/99 40.0 36.1 90.3 % 12/21 /99 40.0 37.9 94.8 % 520.0 477.0 91.7 12/28/00 40.0 39.1 97.8 % 01/05/00 40.0 36.6 91.5 % 01/12/00 40.0 38.9 97.3 % 01 / 19/00 40.0 40.1 100.0 % 501.0 513.0 102.0 % 01 /26/00 40.0 44.8 112.0 % 02/02/00 40.0 38.6 96.5 % 02/09/00 40.0 36.2 90.5 % 02/16/00 40.0 37.0 92.5 % 267.0 241.0 90.3 % 02/23/00 40.0 38.2 95.5 % 03/01/00 40.0 36.2 90.5 % 03/08/00 40.0 41.5 104.0 % 03/15/00 40.0 42.4 106.0 % 03/22/00 40.0 47.9 120.0 % 200.0 182.0 91.0 % 03/29/00 40.0 48.3 121.0 % 04/05/00 40.0 53.8 135.0 % 04/12/00 40.0 44.4 111.0 % Maximum Spike Recover 135.0 % 102.0 % Minimum S ike Recovery 1 86.0 % 90.3 % 1 , PPG Industries, 940 Washburn Switch Road, Shelby, NC 28150 Via Certified Mail - Return Receipt Requested " Gs I"'919Cffi _ CFRQE May 25, 2005 Mr. Barry Love NC Department of Environment and Natural Resources Division of Water Quality 610 East Center Ave. Mooresville, NC 28115 RE: Industrial Wastewater Overflow Response Evaluation — 5/24/2005 NPDES Permit No. NC0004685 Dear Mr. Love: CAR 2 7 200.E Enclosed is a completed Sewage Spill Response Evaluation Form for the incident reported to you initially by phone on May 24, 2065. If you have any questions regarding this incident, please feel free to contact me at (704) 434-2261 x 359. Sincerely, odd Winn Environmental Engineer cc: B. Blackwell file Sewage Spill Response Evaluation: (Page 1 of 3) Permittee PPG Industries Fiber Glass Products Inc Permit Number: NC0004685 County: Cleveland Incident Ended: (Date/Time) Sometime between 1800 hrs on May 23 and 0600 hrs on May 24. Estimated Duration (Time) between 2 & 2.5 hours — based on volume and average daily flows. First knowledge of incident: (Date/Time) 5/24/2005 / 0800 hrs. Estimated volume of spill/bypass 65800 gallons. Show rational for volume: Entire volume flowed to and was retained in spill containment Inside dimensions of spill containment = 120' x 110' x 5 75' Depth of wastewater in the containment area was —8". 120' x 110' x 8" = 8800 ft3 8800 ft3 x 7.48 gallons/ ft3 = — 65800 gallons if spill is ongoing, please notify Regional Office on a daily basis until spill can be stopped. Reported to: Barry Love Mooresville Regional Office (Date/time) 5/24/2005 / 1540 hrs. Name of person Weather conditions: Clear Skies No Precipitiation Temperature: 60 to 70F. Source of spill/bypass (check one) to WWTP) Level of treatment (check one): Did spill/bypass reach surface waters? Volume reaching surface waters? Name of surface water N/A Sanitary Sewer Pump Station X WWTP (piping X None Primary Treatment Secondary Treatment Chlorination Only Yes X No (if Yes, please list the following) 0 gallons (best estimate based on experience) Did spill/bypass result in a fish kill? Yes, _X_No If Yes, what is the estimated number of fish killed? Please provide the following information: 1. Location of spill/bypass: PPG Industries Fiber Glass Products Inc Waste Water Treatment Plant Site 2. Cause of spill/bypass: After a prompt investigation it was determined that a sump had clogged sometime during the night and overflowed to the nearby fuel unloading area spill containment sump which drains into the east 500,000 gallon fuel oil tank containment area At sometime during the night the clog broke loose and flow resumed as normal. It appears that all the untreated industrial water flowed onto the pavement and directly downgrade into the nearby fuel unloading spill sump which discharges into the east 500,000 gallon tank spill containment area There was no evidence of any industrial effluent reaching any storm sewer, or nearby grounds. A piece of a large thick plastic bag/packaging material was found in the sump. With no way of being certain it appears that this thick plastic bag/packaging material may have caused a tempgM blockage in the line resulting in the overflow. 3. Did you have personnel available to perform initial assessment 24 hours/day (including weekends and holidays)? Yes x No Revision #1 6/11/99 Sewage Spill Response Evaluation: (Page 3 of 3) Permittee PPG Industries Fiber Glass Products Inc Permit Number 0004685County Cleveland 10. Comments: Other agencies notified: Non Person reporting spill/bypass: Todd Winn Phone Number: (704) 434-2261 x 359 Signature 7 �' ��'^ Date:O Z OS For DWQ Use Only: DWQ requested additional written report? If yes, what additional information is needed? Requested by Yes No Revision #1 6/11/99 PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 April 13, 2005 Via Certified Mail — Return Receipt Requested Ms. Valery Stephens NC DENR / Water Quality / Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Permit Signing Official Name Change — NPDES Permit: # NC0004685 PPG Industries Fiber Glass Products, Inc. — Shelby, NC Ms. Stephens: During a recent wastewater inspection of our facility by Ms. Donna Hood, DWQ-Mooresville, it was pointed out that our permit's signing official has changed. Ms. Hood requested that we submit complete and submit a "Water Quality Section Permit Name/Ownership Change Form" to your department noting this change. The only change being requested by this form is the change of the permit's signing official from J.T. Scruggs to Timothy Mathis. Please note that this personnel change was also submitted in our comments on our draft NPDES permit submitted to DWQ on July 1, 2004. Signature authority for monthly monitoring reports as a "Duly Authorized Representative" per 15A NCAC 2B.0506(b)(2)(D), remains unchanged and is still delegated to the person holding the title of Environmental Engineer. Please feel free to contact Mr. Todd Winn, Associate Engineer -Environmental, of my staff if you have any questions or require additional information on this matter. Sincerely, Timothy Mathis Manufacturing Manager Cc; {PUIs7IDonna7B6o Division of Water Quality Mooresville Regional Office 610 East Center Avenue, Suite 301 Mooresville, NC 28115 file C}Fi'I.lir, L�,,JBifUi�lkllail NATU"Z RESOtlRCE� _?FIAL OFFICE AVR 1 4 {fp � a��®®pyxxyy�o ayN� ke��t' f4tW h�c, �O� 06 W Appp T �9Q7 PERMIT Michael F. Easley Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources WATER QUALITY SECTION I. CURRENT PERMIT INFORMATION: Permit Number: N/C/ 0 / 0 / 0 / 4 / 6 / 8 / 5 / -or Certificate of Coverage Number: N/C/G/ / 1. Permit holder's name: PPG Industries Fiber Glass Products, Inc. Alan W. Klimek, P.E. Director, Division of Water Quality 2. Permit's signing official's name and title: From J.T. Scruggs to Timothy Mathis (Person legally responsible for permit) Manufacturing Manager (Title) 3. Mailing address: 940 Washburn Switch Road City: Shelby State: NC I Zip Code: 28150 Phone:( 704 ) 434-2261 H. NEW OWNER/NAME INFORMATION: 1. This request for change is a result of Change in ownership of company _ Name change for company _ Change in ownership of property/facility _ Name change for property/facility X Other (please explain): Permit's signing official's name change (SEE COVER LETTER) 2. Owner Information Company or Owner Name: PPG Industries Fiber Glass Products, Inc. (name to be put on permit / certificate of coverage) Owner's/operator's or signing official's name: Timothy Mathis Title: Manufacturing Manger Company Contact: Todd Winn Title: Engineering Associate, Environmental Owner Mailing address: 940 Washburn Switch Road City: Shelby State: NC Zip Code: 28150 Phone: ( 704) 4340-2261 x) 359 E-mail address: twinnADDLY.com 3. Facility Information Facility Name: PPG Industries Fiber Glass Products, Inc. Facility Contact: Todd Winn Title: Engineering Associate, Environmental Facility Mailing address: 940 Washburn Switch Road City: Shelby State: NC Zip Code: 28150 Phone: (704) 4340-2261 x) 359 E-mail address: twinn(tng.com SWU-239-102501 PPPPFF" PERMIT NAME / OWNERSHIP CHANGE FORM THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL. REQUIRED ITEMS: 1. This completed application 2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of incorporation) Certification must be completed and signed by both the current permit holder and the new applicant in the case of change of ownership. For name change only, complete and sign the application certification. Current Permittee's Certification: I, Timothy Mathis attest that this application for name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information and attachments are not included, this application package will be returned as incomplete. Date: Z3, G � Applicant's Certification: I, N/A , attest that this application for a name/ownership change has been reviewed and is accurate and complete. to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information and attachments are not included, this application package will be returned as incomplete. Signature: N/A Date: 'i/A THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS: NC DENR / DWQ / Point Source Branch Attn: Valery Stephens 1617 Mail Service Center Raleigh, North Carolina 27699-1617 S WU-239-102501 IPV North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor CERTIFIED MAIL RETURN RECEIPT REQUESTED October 18, 2004 7003 2260 00013550 3056 Mr. M. Todd Winn, Associate Engineer, Environmental PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Dear Mr. Winn: William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director Subject: Notice of Violation - Effluent Limitations Traclung #: NOV-2004-LV-0517 PPG Industries — Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County, NC A review of the June 2004 self -monitoring report for the subject facility revealed a violation of the following parameter: Pine Parameter Reported Value Limit 001 Oil and Grease 23.0 mg/L 15.0 mg/I, FIN Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Richard Bridgeman of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgeman or me at 704/663-1699. Sincerely, D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor cc: Point Source Branch Mooresville Regional Office 7�TOne�1�,. 610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 1�f Ol hCarolina Phone: 704-663-1699 / Fax: 704-663-6040 / Internet: h2o.enr.state.nc.us Aahmally ��Xv/ Michael F. Easlc� ovcrnor 7 William G. Ross Jr.. Secretary North Carolina Department ofEnvironmcnt and Natural Resources Alan W. Klimek. P. E. Director Division of Water Quality August 12, 2004 CERTIFIED MAIL 7003 2260 00013550 2615 RETURN RECEIPT REQUESTED Mr. M. Todd Winn, Associate Engineer, Environmental PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Subject: Notice of Violation - Effluent Limitations Tracldng #: NOV-2004-LV-0391 PPG Industries = Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Winn: A review of the May 2004 self -monitoring report for the subject facility revealed a violation of the following parameter: Pine Parameter Reported Value Limit 001 Oil and Grease 39.0 mg/L 15.0 mg1L FIN Remedial actions, if not already implemented, should be taken to correct any problems. The Division of Water Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. You may contact Richard Bridgeman of this Office for additional information. If you have questions concerning this matter, please do not hesitate to contact Mr. Bridgeman or me at 704/663-1699. Sincerely, D. Rex Gleason, P.E. Water Quality Regional Supervisor cc: Point Source Compliance/Enforcement Unit N"o�lrCarolina Naturally N. C. Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 PP-PPPP W AMichael F. Easley, Governor \O�Q Rp�i William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P. E. Director > Division of Water Quality p Coleen H. Sullins, Deputy Director Division of Water Quality May 18, 2004 223 Mr. Todd Winn PPG Industries Fiber Glass Products, Inc. WAY 1 9 2004 940 Washburn Switch Road Shelby, NC 28150 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Winn: Enclosed is a report for the inspection performed on April 16, 2004 by Mr. Chet Whiting. Where deficiencies are cited in this report, a response is required as well as for all lettered comments and/or recommendations. Within thirty days of receipt, please supply this office with a written item for item description of how these deficiencies, comments and/or recommendations were corrected. If the deficiencies cited in the enclosed report are not corrected, enforcement actions will be recommended. For certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copV of this report by email, or if- you have questions or need additional information please contact us at 919-733-3908. Sincerely, 1vo�' ?James W. Meyerrl oratory Section Enclosure cc: Chet Whiting Mooresville Regional Office P RCDEN1R N. C. Division of Water Quality Laboratory Section 1623 Mail Service Center . Raleigh, North Carolina 27699-1623 (919) 733-7015 FAX: (919) 733-6241 On-Site Inspection Report LABORATORY NAME: ADDRESS: CERTIFICATE NO: DATE OF INSPECTION: TYPE OF INSPECTION: EVALUATOR: LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: PPG Industries Works 52, Route 4 Shelby, NC 28150 223 April 16, 2004 Maintenance Chet Whiting Mr. Bill Shenck, Mr. Todd Winn This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory continues to do a good job overall. All items requested for examination were provided. Laboratory personnel were courteous and cooperative throughout the inspection. III. DEFICIENCIES, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: SOLIDS SUSPENDED: A. COMMENT: The time in and out of the drying oven(s) are not recorded. REQUIREMENT: Record the time in and out of the drying oven. ref: 15A NCAC 2H .8085 (7), & (7) (A). REQUIREMENT: The laboratory must document all relevant information. If the information ,is not recorded, the laboratory has no means with which to prove that the procedure was actually performed. REQUIREMENT: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. The following are requirements for certification and must be included in each certified laboratory's quality control program. Ref: 15A NCAC 2H .0805 (a) (7). COMMENT: The laboratory performs an annual drying cycle verification. By exercising this option a laboratory must record time in and out of the drying oven in order to document that the samples were dried for the time specified by the drying cycle verification. DISSOLVED OXYGEN: B. COMMENT: The D.O. meter is calibrated only on the two days BOD is analyzed. Dissolved Oxygen is reported 5 days a week. The meter must be calibrated and the calibration documented each day it is used to analyze compliance monitoring samples. A review of manufacturer's instruction for similar meters indicates that the meter must be calibrated prior to making D.O. measurements. pppppp- Page 2 FECAL COLIFORM MF: COMMENT: The laboratory is adding dilution water to the filter funnel prior to adding 1 ml of sample. This procedure is acceptable for a 1 ml sample volume. There are occasions that lower dilutions may be necessary such as stream samples during a rain event. If a volume below 1 ml is used them serial dilutions must be performed using sterile dilution bottles. C. COMMENT: The incubator used for the fecal coliform test does not operate in the specified temperature range of 44.5 ± 0.2°C. The external digital thermometer indicated this temperature, however when verified against an NIST thermometer the actual temperature was 43.9 C. An attempt was made to raise the temperature however no adjustment above the temperature indicated on the external digital was possible. At that time we instructed the laboratory to return to using the water bath until this situation can be resolved. ABOVE COMMENT DOES NOT REQUIRE RESPONSE D. COMMENT: Required supporting information not documented '(pH meter calibration). REQUIREMENT: Document the calibration of the field pH meter. Ref: 15a NCAC 2H .0805 (a) (7) & (7) REQUIREMENT: The laboratory must document all relevant calibration information. If the information is not recorded, the laboratory has no means with which to prove that the calibration was actually performed. REQUIREMENT: Each laboratory shall develop and maintain a document outlining the analytical quality control practices. used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. The following are requirements for certification and must be included in each certified laboratory's quality control program. Ref: 15A NCAC 2H .0805 (a) (7). IV. PAPER TRAIL INVESTIGATION: Data and supporting documentation from January, March and April of 2004 was examined. No items others than those specified in the report above were observed. V. CONCLUSIONS: Correcting the above cited comments and implementing the recommendations will help this lab to produce quality data and meet certification requirements. Please respond to all lettered comments. Report prepared by: Chet Whiting Date: April 26, 2004 PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Todd Winn 704-434-2261 ext. 359 Associate Engineer, Environmental Fax 704-434-0792 Fiber Glass Products Nu DEPT. 01 EWViRO14Cd1EW twinn@ppg.com AZ40 NekTl Us AL RESOURCES May 12, 2004 Via Telecopier and Certified Mail - Return Receipt Requested Mr. Richard Bridgeman N.C. Division of Water Quality Mooresville Regional Office 919 North Main Street Mooresville, NC 28115 MAY 1 3 2004 WATER !�, UAL" 01 Subject:. Response to Notice of Violation/Notice of Recommendation for Enforcement Compliance Evaluation Inspection PPG Industries WWTP — NPDES Permit No. NC0004685 NOV#: 2004-PC-0029 Cleveland County, NC Dear Mr. Bridgeman: This letter is in response to a Notice of Violation (NOV) from the Mooresville Division of Water Quality (DWQ) office dated April 22, 2004. Based on an inspection by Mr. Wes Bell on April 16, 2004, the NOV alleges monitoring violations of the subject NPDES Permit and North Carolina General Statute (G.S,) 143-215. The inspection report indicates that the instream fecal coliform was not collected three times per week during the months. of June through September, for a total of 68 instances since issuance of the permit. PPG believes that there has been no monitoring violation and that the facility's NPDES discharge has had no adverse impact on any applicable water quality standard or permitted limit for the reasons outlined below. Sampling FrequencX The NOV alleges that PPG should have conducted 3/week sampling frequency for fecal coliform during the months of June through September, instead of only weekly as was performed year-round. Attached Table A.(1) of the NPDES permit specifies effluent limitations and monitoring requirements. For fecal coliform, the table states "weekly" for the measurement frequency and "B,U,D" for the effluent, upstream and downstream sampling locations. PPG has consistently performed the fecal coliform testing weekly from the effluent, upstream, and downstream locations. All other upstream/downstream samples are collected daily or at a 3/week frequency where clearly designated in the table and/or its footnote. There is no clear statement in the table or footnote to indicate that any other test frequency should be performed for fecal coliform. Since this is the only upstream/downstream parameter specifically identified in the table for "weekly" measurement frequency, PPG believes that its current practice of collecting weekly fecal coliform samples fully complies with the permit requirement. Prior inspections and reviews by DWQ have not indicated any concerns with PPG's performance of weekly fecal coliform sampling. PPP70Adverse Impact PPG believes that there is no adverse impact from the alleged fecal coliform sampling violation as follows: 1. No limit: The current permit has no limit for fecal -coliform, and therefore there was no potential to have exceeded a limit even if more samples had been collected. 2. Low effluent concentration: Ongoing sampling of the effluent, before discharge into the receiving stream, has been consistently low in fecal coliform concentration and therefore has had no impact on the receiving stream. The weekly effluent geometric mean for the previous 24 months (April 2002 through March 2004) is 4 cfu/100 ml. Low upstream/downstream concentrations: There has been no adverse impact on the receiving stream, as the fecal coliform tested at the effluent is substantially less than that present in the stream. In addition, the upstream fecal coliform concentration is greater than the downstream concentration. The weekly upstream geometric mean from April 2002 through March 2004 is 801 cfu/100 ml, whereas the weekly downstream geometric mean, during the same time period, is 758 cfu/100 ml. PPG's effluent contribution to fecal coliform in the stream is negligible and it is therefore unlikely that more frequent sampling would have shown otherwise. In summary, PPG believes the information presented herein demonstrates a diligent intent to fully meet the NPDES sampling requirements.. Further, PPG believes that no violation occurred with the fecal coliform sampling frequency as stated in the current permit and that the alleged violation has no impact on any permit limit or water standard. However, to resolve this issue, PPG is willing to include 3/week June through September fecal coliform testing to future sampling events beginning in June 2004, until a renewed permit is received. Therefore, PPG is requesting that the issues raised in this NOV be considered resolved and that DWQ recommend no further enforcement action based on the enclosed information. Should you have any further questions, please contact me at 704-434-2261 extension 359. Sincerely, � Todd Winn w/ attachment cc: Pat Pride — Lexington FGEC Shelby WWTP operations T. Mathis File A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NC000468.5 During the period beginning on the effective date of the permit and lasting until permit expiration, the Permittee is authorized to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REQUIRE MENTS Monthly Average. lb/day Daily Maximum lb/day Monthly Average Concentration Daily Maximum Concentration Measurement Frequency Sample Type Sample Location' I"lowContinuous ecor ing I or 5-day, 200C _ mg mg ee y Composite Total Suspended est ue 20.0 mg mg Daily Composite ,- mg mg Weekly ompostte Dissolved Oxygen' Daily Grab, pH3 Daily Grab Temperature °C at y Grab, Fecal o t orm geometric mean Weekly Grab, -F— Total Nitrogen + 2+ , Quarterly ompostte Total Phosphorus uarter y Composite on uctivity See Note Grab U, Oil and Urease 10.0 mg mg Weekly Grab Lead 2/Month Composite Fluoride 5.4 mg ee- y Composite Zinc ont t Composite Copper2/Month Composite Chloride2/Month Composite ronlc oxicrty Quarterly ompostte Notes: t Sample Locations: E - Effluent, I — Influent, U — Upstream at NCSR 1323, D — Downstream at NCSR 1305; upstream and downstream samples shall be grab samples. Stream samples shall be collected three times per week during June, July, August, and September and once per week during the remaining months of the year. 2 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. 3 The pl-i shall not be less than 6.0 standard units nor greater than 9.0 standard units. 4 Chronic Toxicity (Ceriodaphnia) P/F a 33 %; January, April, July, October; See A(3) of the Supplement to Effluent Limitations page; collection of the composite toxicity sample shall coincide with composite samples for lead, fluoride, zinc, copper, and chloride. There shall be no discharge of floating solids or visible foam in other than trace amounts. -12-2004 WED 07:44 AM PPG MFG ENGR SHELBY N 0 FAX NO, 7044342261++267 P. 01 PPG INDUSTRIES FIBER 940 WASHBURN SWITCH ROAD SHELBY', NC 28150 CLASS PRODUCTS, INC. W FAX To: .Richard Hridi eman Phone: Fax: 704-663-6040 CC: bate: 5/1.2/04 _ Number�f pages including cover sheet: 4 From: Todd Winn Phone: 704-434-2261 x359 Fax: 704-434-0792 REMARKS: Urgent a For your revie,.v D Reply ASAP El Please comment Response to NOV #2004-PC-0029 WES Permit #: NCO004685 The original signed letter is being sent via overnight certified marl. If you have any questions, please contact me at the phone number listed above. Todd Winn THE MATFRIAL OP THIS TRANSMISSION CONTAINS CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE ADDRESSEE. IF YOU ARE NOT THE ADDRESSEE, ANY DISCLOSURE OR USE OF THIS INFORMATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS FACSIMILE IN ERROR, PLEASE NOTIFY US BY TELEPHONE IMMEDIATELY -12-2004 WED 07:44 AM PPG MFG ENGR SHELBY N 0 FAX PPG Industries, Inc. 940 Washburn Switch Road Todd Winn Associate Engineer, Environmental Fiber Glass Products May 12, 2004 Via Teleeopier and Certified Mail - Return Receipt Requested Mr. Richard Bridgeman N.C. Division of Water Quality Mooresville regional Office 919 North Main Street Mooresville, NC 28115 i N0, 70443422614267 P. 02 Shelby, North Carolina 28150 704-434-2261 ext. 359 Fax 704-434-0792 twinn@ppg.com Subject_ Response to Notice of Violation/Notice of Recommendation for Enforcement Compliance Evaluation •Inspection PPG Industries'WWTP—NPDES Permit No. NC0004685 . NOV#: 2004-PC-0029 Cleveland County, NC Dear Mr. Bridgeman: This Ietter is in -response to a Notice of Violation (NOV) from the Mooresville Division of Water Quality (DWQ) office dated April 22, 2004. Based on an inspection by Mr. Wes Bell) on April 16, 2004, the NOV alleges monitoring violations of the subject NPDES Permit and North Carolina General Statute (G. A.) 143-215.- -The inspection report indicates that the instream fecal coliform was not collected three times per week during the months. of June. through September, for a total of 68 instances since issuance of the permit. PPG believes that there has been no monitoring violation and that the facility's NPDES discharge has had no adverse impaevon any'applicable water quality standard or permitted limit for the reasons outlined below.. Sampling Frequencx The NOV alleges that PPG should have'conducted. 3/week sampling frequency for fecal coliform during the months of June through September, 'instdad of only weekly as was performed year-round. Attached Table A.(1) of the NPDES permit specifies "ffluent limitations and monitoring requirements. For fecal coliform, the table states -"weekly" for the measurement frequency and "E,U,D" for the effluent, upstream and downstream sampling locations. PPG has consistently -performed the fecal coliform testing weekly from the effluent, upstream, and downstream 'locations. All other upstream/downstream samples are collected daily or at a 3/week frequency where clearly designated in the table and/or its footnote. There is no clear statement in the table or footnote to indicate that any other test frequency should be performed for fecal coliform. Since this is the only upstream/downstream parameter specifically identified in the table for "weekly" measurement frequency, :PPG believes that its current practice of collecting weekly fecal coliform samples fully complies with the permit requirement. Prior inspections and reviews by DWQ have not indicated any concerns with PPG's performance of weekly fecal coliform sampling. F-12-2004 WED 07:45 AM PPG MFG ENGR SHELBY N 0 FAX NO. 70443422,61++267 P. 03 No Adverse Tmpact PPG believes that there is no adverse impact from the alleged fecal coliform sampling violation as follows: 1. No limit: The current permit has no limit for fecal coliform, and therefore there was no potential to have exceeded a limit even if more samples had been collected. 2. Low effluent concentration: Ongoing sampling of the effluent, before discharge into the receiving stream, has been consistently low in .fecal coliform concentration and therefore has had no impact on the receiving stream. The weekly effluent geometric mean for the previous 24 months (April 2002 through March 2004) is 4 cfu/100 ml. 3. Low upstream/downstream concentrations: There has been no adverse impact on the receiving stream, as the fecal coliform tested at the effluent is substantially less than that present in the stream, in addition, the upstream fecal coliform concentration is greater than the downstream concentration. The weekly upstream geometric mean from April 2002 through March 2004 is 801 cfu/100 ml, whereas the weekly downstream geometric mean, during the same time period, is 758 cfu/100 mi. PPG's effluent contribution to fecal coliform in the stream is negligible and it is therefore unlikely that more frequent sampling would have shown otherwise. In summary, PPG believes the information presented herein demonstrates a diligent intent to fully meet the NPDES sampling requirements. Further, PPG believes that no violation occurred with the fecal coliform sampling frequency as stated in the current permit and that the alleged violation has no impact on any permit limit or water standard. However, to resolve this issue, PPG is willing to include 3/week June through September fecal coliform testing to future sampling events beginning in June 2004, until a renewed permit is received. Therefore, PPG is requesting that the issues raised in ;this NOV be considered resolved and that DWQ recommend no further enforcement action based on the enclosed information. Should you have any further questions, please contact me at 704-434-2261 extension 359. Sincerely, I ow Todd Winn w/ attachment cc: Pat Pride — Lexington FGEC Shelby WWTP operations T. Mathis File A. (1) EFFLUENT LIM[TATIONS AND MON[TORING REQUIREMENTS- FINAI, Permit No. NCO004685 During the period beginning on the effective slate of the permit and lasting; until permit expiration, the Permittee is authorized to discharge from oulfall(s) serial number 001. Such discharges shall be limited and monitored by the Permiltee as specified below; Monthly u2ily on yDaily Average Maximum Average Maximum Measurement SaropEe Sample IbIday lbfelay Concentration Concentration Frequency Type Location' °�v MGM - ,- = ay. - --- — -- - — - ---- - - - -- - 1.3 - -_ -- - _ onttTtuous eco ing-- - -or Total Suspended Residue m mg 0.0 mgtL rnglL Weekly Daily Composite Composite Dissolved xygen m Tn Weekly omposTte PH; Daily Grab, Temperature ° Daily Grab Daily— ra Fecala t orrn e-omelrtc mean Weekly ra , eta Nitrogenzf , eta Phosphorus Quarterly Composite onus Conductivity Quarterly mpMite See N Urab Oil and rease mg m Weekly Grab ea uan e 21Mouthompasrte Tnc � ml; Weekly Composite opper not omposite uIllorT a 2IMonth Composite Chronic oxici yQuarterly 2/MonthComposite ampastteEA Notes: Sample Locations. E - Effluent, I —Influent, U — Upstream at NCSR 1323, D — Downstream al NCSR 1305; upstream. and downstream samples shall be grab samples_ Stream samples shall be collected three times per week during June, July, August, and Seplember and once per week during The remaining months of the year. 2 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L. - 3 The pH shall not be less than 6.0 standard units nor greater than 9.O standard un its. 4 Chronic Toxicity (Ccriodaphnia) PIP O 33 %, January April, July, October; Sce A(3) of the Supp lemeni to Effluent Limitations page; collection of the composite toxicity sample shall coincide wlth composite samples for lead, fluoride, zinc, copper, and chloride. There shall be no discharge of floating solids or visible fearn in other lb an trace amounts. —c PIO :ro 0 0 .A o 0 3 t� i z V2 �c i-- [• o0 I� z c--3 0 .r, .A w ry ry rn rV W Mi haa: ^. sieti. Gnvemor William G. Ross Jr.. Secretary North Carolina Department of Environmeni and Natural Resources Alan W. Klimek. P. E. Director Division of Water Quality Coleen H. Sullins. Denury Director Division of Water Quality March 18, 2004 Mr. J. L. Zamboldi PPG Industries, Inc. One PPG Place Pittsburgh, Pennsylvania, 15272 SUBJECT: Tax Certification No. TCS-MV-114 Wastewater Treatment Abatement Facilities PPG Industries Fiber Glass Products, Inc. Shelby Facility NPDES No. NC0004685 Cleveland County, North Carolina Dear Mr. Zamboldi: Attached are two (2) copies of Tax Certification Number TCS-MV-114 covering the operation of wastewater treatment facilities as specified in the subject NPDES Permit issued by the North Carolina Environmental Management Commission. The Company may use this Certification to obtain tax benefits in keeping with the appropriate North Carolina Statutes. Sincerely, D. Rex Gleason Water Quality Regional Supervisor Attachment cc: Cleveland County Health Department NorlhCaroIina A7'?JA7""//r" — - - NCDENR Customer Service 1-877-623-6748 - 7 N. C. Division of Water Quality, Mooresville Regonal Office, 919 North Main Street, Mooresville NC 28115 (704) 663-1699 Michaci F. Easin. Governor �� ^r William G. Ross Jr.. Secretary QG North CarolinaD-partrnent of Environment and Natural Resources Alan W. Klimek. P. E. Director > I 1 Division of Water Quality Coleen H. Sullins_ Deouty Director Division of Water Quality Mr. Chris Greene Tax Assessor Cleveland County P.O. Box 370 Shelby, North Carolina 28151 Dear Mr. Greene: March 18, 2004 Subject: Tax Certification No. TCS-MV-114 Wastewater Treatment/ Abatement Facilities PPG Industries Fiber Glass Products, Inc. Shelby Facility NPDES No. NC0004685 Cleveland County, NC Attached is Tax Certification No. TCS-MV-114 covering the operation of wastewater treatment facilities as specified in the subject NPDES Permit issued by the North Carolina Environmental Management Commission. PPG Industries Fiber Glass Products, Inc. may use this Certification to obtain tax benefits in keeping with the appropriate North Carolina Statutes. A detailed description of these treatment facilities is available in the files of North Carolina Division of Water Quality. Sincerely, D. Rex Gleason, P.E. Water Quality Regional Supervisor d dz(M1 �1na I C ENR N. C. Division of Water Quality, Mooresville Regonal Office, 919 North Main Strom Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH TAX CERTIFICATION (Franchise/privilege; Amortization; Property) In accordance with the provisions of the General Statutes of North Carolina (G. S. 105-122(d), 105-130.10, 105-147(13), 105-275(8)), this is to certify that: PPG Industries Fiber Glass Products, Inc. Shelby Facility Cleveland County HAS BEEN ISSUED NPDES Permit No. NC0004685 for the discharge from and the operation of wastewater treatment facilities consisting of the following: 1- Overflow/storage basin; 2- Bar screen and grinder; 3- Influent wet well with lime addition and pumps; 4- Surge tank, equalization tank, a flash mix tank with aluminum chloride addition, coagulant and polymer addition; 5- Two primary clarifiers; 6- Two aeration basins with bentonite clay addition, a splitter box and floc tank; 7- One sand, filter;_ 8- One chlorine contact basin; 9- One sludge thickener tank and a sludge belt press. The wastewater treatment facilities are located at PPG Industries Fiber Glass Products, Inc.'s plant on SR1313 west of Shelby, Cleveland County. Treated effluent is discharged into the Broad River Basin. The Environmental Management Commission and the Department of Environment and Natural Resources have found that the treatment facilities: Page Two PPG Industries Fiber Glass Products, Inc. Tax Certification 1 a. Have been constructed or installed; b. Comply with the requirements of the Commission; C. Are being effectively operated in accordance with the terms and conditions of the Permit, Certification of Approval, or other document of approval issued by the Commission; and d. Have as their primary rather than incidental purpose the reduction of water pollution resulting from the discharge of wastewater. Issued at Mooresville, North Carolina this the 18'' day of March, 2004 by the directive of the North Carolina Environmental Management Commission and the North Carolina Department of Environment and Natural Resources. D. Rex Glean n, P.E. Water Quality Regional Supervisor Mooresville Regional Office TCS-MV-114 V_ r ..fit ° Tlt ®FFB PPG Industries, Inc. February 2, 2004 One PPG Place Pittsburgh, Pennsylvania 15272 USA North Carolina Department of Environmental and Natural Resources Division of Water Quality i4 ATTN: Samar Bou-Ghazale,9r 919 North Main Street Mooresville, North Carolina 28115 Subject: PPG Industries Fiber Glass Products, Inc. — Shelby, North Carolina Tax Certification — Pollution Abatement Equipment Dear Mr. Bou-Ghazale: PPG Industries Fiber Glass Products, Inc. ("PPG") respectfully requests certification for special tax treatment for the wastewater treatment equipment located in the PPG Shelby, North Carolina facility. PPG's Shelby, North Carolina plant produces continuous strand fiber glass. The facility also operates an on -site wastewater treatment facility. Enclosed is a schedule detailing the equipment associated with the wastewater treatment plant under Water Permit No. NC0004685. The list includes the following wastewater treatment plant components, along with one item associated with stormwater pollution prevention, which are the basis for PPG's tax certification request: 1. Wastewater treatment equipment associated with the primary, secondary, and tertiary wastewater treatment processes. 2. Handling and storage equipment for lime used in the wastewater treatment processes. 3. Dewatering equipment for final processing of the wastewater treatment plant sludge. 4. Covers for waste dumpsters to prevent rainwater runoff contamination of stormwater. Pursuant to N.C. Gen. Stat. § 105-275(8)(a)',, an exemption is provided for "real or personal property that is used, or if under construction, is to be exclusively used for air cleaning or waste disposal or to abate, reduce, or prevent the pollution of air or water....". Such property is exempted from being listed, appraised assessed or taxed by state or local governments after approved certification. In addition, N.C.,' Gen. Stat. § 105-275(8)(a)1-4, states that the Department of Environment and Natural Resources shall furnish a certificate to the county tax supervisor once it has found that the installed property is in compliance and effectively operating under the plans of the Environmental Management Commission and that the equipment's primary purpose is the reduction of water pollution resulting from the discharge of industrial wastes and other contaminating materials. As PPG's equipment meets the above -referenced statutory requirements for tax certification, PPG respectfully requests that equipment exclusively associated with the wastewater treatment plant and stormwater pollution prevention as identified on the attached be approved for tax certification. V- We appreciate your assistance with this matter. Should you have any questions regarding this request or to schedule a site visit, please contact me at (412) 434-2454 or Kelly Lenart with Ernst & Young at (412) 804-7687. Enclosure cc: Todd Winn, PPG Industries, Inc. Bruce Putnam, PPG Industries, Inc. Kelly Lenart, Ernst & Young, LLP Charlie Long, Ernst & Young, LLP -toW/ Very truly ours J. L. Zamboldi PPG Industries Fiber Glass Products, Inc. Shelby, North Carolina Plant Division of Water Quality Tax Certification Application Year of Acquisition Property Card Number Asset Description Asset Description 2 Original Historical Cost DENR Permit Number Description of Asset Function % of Time Used for PC 1990 03520894004200 REVISE CARD 0894004199 52.189 SLUDGE DEWATERING SYSTEM 57,756.30 NC0004685 wastewater treatment 100% 1994 03520944005041 SECONDARY TREATMENT - AERATION BASIN 52.498 WWTP UPGRADE 399,335.81 NC0004685 wastewater treatment 100% 1994 03520944005042 TERTIARY TREATMENT - EFFLUENT FILTER 52.498 WWTP UPGRADE 236,031.17 NC0004685 wastewater treatment 100% 1994 03520944005043 LIME HANDLING/STORAGE SYSTEM 52.498 WWTP UPGRADE 54,707.81 NC0004685 wastewater treatment 100% 1995 03520954001010 INFLUENT SYSTEM UPGRADE 52-613 1994 WWTP UPGRADE 98,653.88 NC0004685 wastewater treatment 100% 1995 03520954010010 SECONDARY CLARIFIER SYSTEM UPGRADE 52-613 1994 WWTP UPGRADE 98,653.88 NC0004685 wastewater treatment 100% 1995 03520954011010 AERATION SYSTEM UPGRADE 52-613 1994 WWTP UPGRADE 303,117.76 NC0004685 wastewater treatment 100% 1996 03520964004010 IWWTP LIME SYS UPGRADE 52-742 ALSO SEE 0960201020 77,461.16 NC0004685 wastewater treatment 100% LLShelby Attachments_rev.xls, Water PC Q � 9 PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Todd Winn.. 704-434-2261 ext. 359 Associate Engineer, Environmental Fax 79,44'-''0792 Fiber -Glass Products twinppg;coin November 7, 2002 Mr. Michael Parker Division of Water Quality NC DENR 919 North Main Street Mooresville, NC 28115 Dear Mr. Parker: On August 6th, 2002 we were granted by your department the permission to conduct a "pilot - study" to reuse treated effluent as non -potable, process water. The results of this study were favorable showing up to a 1/3rd decrease in city water usage. Although the results of this pilot study were favorable, we have determined that we yield fewer cycles in the cooling towers using recycled water vs. city water. This is due primarily to the higher -level s'of dissolved solids in the recycled effluent. Fewer cycles result in increased process water treatment chemical usage and cost. Therefore, we are currently in the process of conducting a cost vs. benefit analysis on the installation of membrane/RO technology to treat only the portion of effluent used for process water. If cost effective, this could prove to be the most viable option for conserving the use of city water. Our NPDES permit (NC0004685) expires August 31, 2003. Therefore, in February of 2003 we will be submitting a renewal application. With this renewal we will include a request to include in our new permit the following three options: 1. Use of up to 100% of our treated effluent as process water (as is). 2. Use of up to 100% of our treated effluent as process water using membrane/RO technology only on the portion of effluent used for recycle 3. Retain the option to discharge 100% of all treated effluent without recycling. The "pilot study" expires December 31, 2002. Since we will be submitting an application for permit renewal in February 2003, we are requesting permission to continue using recycled effluent as process water "as is" under this "pilot study" until the permit is 'issued. If you have any questions concerning this request, please contact me at (704) 434-2261 extenstion 359. Sincerely, / - C�b av-t M. Todd Winn cc: file �J ;r V 12 PPG Industries, Inc. 940 Washburn Switch Road Shelby, North Carolina 28150 Todd Winn 704-434-2261 ext. 359 Fax 704-434-0792 Associate Engineer, Environmental Fiber Glass Products MC DPP` . OF �ia�40,406,4r twinn@ppg.com ',MD NAT! ipAL RE989 on L OFFICE March 24, 2003 Mr. Michael Parker Division of Water Quality NC DENR 919 North Main Street Mooresville, NC 28115 Dear Mr. Parker: MAR 2 6 2%0 As per our phone conversation on March 24, 2003, we are submitting this letter to your department confirming the status of our treated effluent recycle program. In February of this year, we submitted our NPDES permit (NC0004685) renewal application. This application included a request to include in our new permit the following three options: 1. Use of up to 100% of our treated effluent as process water (as is). 2. Use of up to 100% of our treated effluent as process water using membrane/RO technology only on the portion of effluent used for recycle. 3. Retain the option to discharge 100% of all treated effluent without recycling. As stated in the letter sent to your office on November 7, 2002, it is worth re -noting that this project continues to be successful. We continue to see an approximate 1/3 decline of total city water consumption. The original pilot study was effective from August 6 through December 31, 2002. As per your department's guidance in November of 2002, and again in March of 2003, we will continue to 1ccycle eu ea �ff!ue::r ,n�lar +be oriaina? 1JllOt Study, issued by your department, until our NPDES permit is issued. I would also like to take this opportunity to thank your department for its continued support of this recycle project. If you have any questions, please contact me at (704) 434-2261 extension 359. Sincerely, �, J 4/ c3� M. Todd -Winn cc: file Michael F. Easley Governor William G � . ,... Pir.OFSWef9*' IWEW North Carolina Department of Environment P1�a�ti��ilRAMMIDES 3VILLE REGIONAL Op- RCr- Alan YY. Klim ivision ater'Q I t January 3, 2003 VAN 2 2 2005 Lacy Ballard PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Subject: Renewal Notice NPDES Permit NC0004695 Shelby facility Cleveland County Dear Permittee: The subject permit expires on August 31, 2003. North Carolina Administrative Code (15A NCAC 2H.0105(e)) requires that an application for permit renewal be filed at least 180 days prior to expiration of the current permit. If you have already mailed your renewal application, you may disregard this notice. To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than March 4, 2003. Failure to request renewal of the permit by this date may result in a civil assessment of at least $500.00. Larger penalties may be assessed depending upon the delinquency of the request. If any wastewater discharge will occur after August 31, 2003 (or if continuation of the permit is desired), the current permit must be renewed. Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1 and could result in assessment of civil penalties of up to $25,000 per day. If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact Bob Sledge of the Division's Compliance Enforcement Unit at (919) 733-5083, extension 547. You may also contact the Mooresville Regional Office at (704) 663-1699 to begin the rescission process. Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with the permit renewal application. If you have any questions, please contact Valery Stephens at (919) 733-5083, extension 520. Sincerely, �1 07 Charles H. Weaver, Jr. NPDES Unit cc: Central Files Mooresville Regional Office,1X i er Qualit}-SEctio�n. NPDES File 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 520 (fax) 919 733-0719 VISIT us ONTHEINTEaNET@http:/lh2o.enr.state.nc.us/NPDES e-mail: valery.stephens@ncmail.net NPDES Permit NC0004685 Shelby facility Cleveland County The following items are REQUIRED for all renewal packages: ❑ . A cov�ri;letter requesting renewal of the permit and documenting any changes at the facility since issuance of the last permit. Submit one signed original and two copies. ❑ The completed application form (copy attached), signed by the permittee or an Authorized Representative. Submit one signed original and two copies. ❑ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares the renewal package, written documentation must be provided showing the authority delegated to any such Authorized Representative (see Part II.B.11.b of the existing NPDES permit). ❑ A narrative description of the sludge management plan for the facility. Describe how sludge (or other solids) generated during wastewater treatment are handled and disposed. If your facility has no such plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed original and two copies. The following items must be submitted by any Municipal or Industrial facilities discharging process wastewater: Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal Regulations, Part 122) and ALL Municipal facilities with a permitted flow ? 1.0 MGD must submit a Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21. The above requirement does NOT apply to privately owned faciU es treating 1000o domestic wastewater, or facilities which discharge non process wastewater (cooling water, filter backwash, etc.) PLEASE NOTE: Due to a change in fees effective January 1, 1999, there is no renewal fee required with your application package. Send the completed renewal package to: Mrs. Valery Stephens NC DENR / Water Quality / Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 r2 PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products June 5, 2000 Mr. Dave Goodrich NCDENR Permitting Division 1617 Mail Service Center Raleigh, NC 27699-1617 704-434-2261 Extension 544 Iballard@ppg.com Re: Effluent Oil and Grease Method Study/Permit Modification Request PPG Industries Fiber Glass Products, Inc. — Shelby, NC NPDES No. NC0004685 Dear Mr. Goodrich: PPG Industries Fiber Glass Products, Inc. (PPG), a manufacturer of fiber glass for the reinforced plastics industry, is located in Shelby, NC. Wastewater from our production units is treated in an on -site WWTP before being discharged to Brushy Creek. The NPDES discharge permit limits effluent oil and grease to 10 mg/L maximum daily and 15 mg/1 average. Historically, the oil and grease effluent concentrations have been below PPG's 10 mg/L permitted discharge limit. Approximately one and a half years ago, the analyzing laboratory (Pace Analytical Labs, Huntersville, NC) switched from the old EPA Method 413.1, which uses CFC-113 (freon) as the extracting solvent, to the new EPA Method 1664, which uses n-hexane (hexane) as the extracting solvent. As a result of this switch, PPG effluent oil and grease concentrations have been periodically higher than normal and have exceeded the 10 mg/L discharge criteria. Freon is no longer being imported or produced in the U.S. as of January 1, 2000. Additionally, analytical laboratories will no longer be allowed to use any existing freon after the year 2005. Therefore, future oil and grease analysis will be performed using Method 1664 once freon is permanently phased out. Both EPA Methods 413.1 and 1664 were developed for the determination of relatively non- volatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials. Under EPA Method 413.1, the freon extracted constituents were referred to as "oil and grease" Under EPA Method 1664, the hexane -extracted constituents are referred to as "hexane extractable material". Method 1664 measures not only oil and grease, but any material that can be extracted using hexane. Oil and grease is a method -defined parameter; therefore, any change in method protocol, such as use of another solvent, has the potential to affect results. The EPA Guidance Document, Analytical Method Guidance for EPA Method 1664A Implementation and Use (40 CFR part 136), indicates that there may be differences in results obtained using Method 1664 compared to Method 413.1. This Guidance Document outlines recommendations for performing side -by -side testing between Method 413.1 and Method 1664. Based on the EPA method of side -by -side testing, a conversion factor is developed. This conversion factor can be applied to oil and grease results obtained by Method 1664 (hexane extraction) in order to determine the expected result that would be obtained by Method 413.1 (freon extraction). In order to investigate potential causes for the higher than normal effluent oil and grease concentrations, Mr. Jim Meyer (NCDENR), Mr. Wayne Turnbull (EPA — Region 4), Mr. William Telliard (EPA, Office of Water) and Ms. Marta Jordan (EPA, Office of Water) were contacted by our wastewater consultant Lili Gellner of Aware Environmental, Inc.. Based on discussions with these individuals, several key issues were identified. They are as follows: 1. Hexane has a higher affinity for extracting petroleum products, compared to freon which has a higher affinity for extracting natural fats and oils. 2. Surfactants appear to be more readily extracted by hexane than freon, which can cause higher results in Method 1664 compared to Method 413.1. Hexane extracted material treated with silica gel may reduce interference from materials such as surfactants but does not interfere with the measurement of petroleum products. Hexane versus Freon Hexane has a higher affinity for petroleum products than freon. Higher oil and grease results under Method 1664 as compared to Method 413.1 would suggest that more of the hydrocarbon products are being extracted with hexane than with freon. Based on the operation and performance of the waste treatment system, it is not expected that higher than normal oil and grease levels are associated with hydrocarbons. The PPG wastewater treatment process is a unique and highly effective system that uses a variety of treatment chemicals, along with physical, chemical and biological processes in order to provide optimum treatment and maintain high effluent quality. The treatment system includes primary treatment with the addition of lime, an aluminum - based coagulant and a polymer. In the secondary biological treatment system, sodium bentonite (clay) is added to the mixed liquor to remove refractory organic compounds and ferric chloride is added prior to the secondary clarifiers to improve settling and turbidity. It is expected that these processes would significantly reduce hydrocarbon oil and grease to very low or non -detectable levels. This corresponds to our historical oil and grease data. Surfactants Based on EPA testing of laundering facilities, surfactants can cause a positive result for oil and grease. PPG uses a significant a 2 mount of surfactants in the production process. In order to reduce the interference from surfactants, it was recommended that hydrocarbon oil and grease be analyzed instead of total oil and grease. Method 1664 measures total oil and grease. In order to measure the hydrocarbon portion of oil and grease, the hexane -extracted material in Method 1664 is treated with silica gel, which removes polar organic material and should remove most surfactants. Since hydrocarbon oil and grease is nonpolar, it should not be affected by the silica gel treatment. In order to determine if PPG's higher than normal effluent oil and grease concentrations were a result of the change in the analytical method, split samples were analyzed using EPA Methods 413.1 and 1664. This testing was performed on several effluent samples from PPG's WWTP. The results of this initial testing showed that Method 413.1 consistently resulted in lower oil and grease concentrations than Method 1664. However, these results suggested that there was not a consistent correlation between the two methods. PPG initiated a program to perform additional testing. PPG routinely collects split samples for effluent oil and grease. The first effluent sample is analyzed using the new Method 1664. If Method 1664 results in a concentration greater than 10 mg/L, the second sample is analyzed using Method 413.1. Method 413.1 has consistently resulted in an effluent oil and grease concentration lower than Method 1664. Effluent oil and grease data collected from December 1999 through April 2000 is presented in Table 1. Based on this data, Method 1664 results in a higher oil and grease concentration. Furthermore, there is not a consistent correlation between Methods 413.1 and 1664 when determining oil and grease in PPG's wastewater. This data shows that Method 1664 can result in an oil and grease concentration from 1.5 to 27 times as high as Method 413.1. Since there is not a good correlation between these results, a conversion factor obtained by side - by -side testing would need to account for the high ratio results. Additional oil and grease data was obtained from Pace Analytical Labs. These data are summarized in Tables 2 and 3 and includes the quality control (QC) analyses for the PPG samples. Table 2 includes a summary of the oil and grease matrix spike results obtained by Method 1664. Table 3 includes of summary of the oil and grease DI water control spike results obtained by both Method 1664 and Method 413.1. This spike recovery results in Table 3 show that DI water spiked with oil and grease provides fairly consistent results for both Method 1664 and Method 413.1. The spike recovery results in Table 2 show that oil and grease recovery from typical samples is highly variable under Method 1664. This type of variability is consistent with the variability in the PPG effluent oil and grease data obtained by Method 1664. Based on the data presented in Table 1, it appears that PPG will be subjected to a greater risk of noncompliance for effluent oil and grease under Method 1664. In order to address this issue while freon is still available, PPG is expanding their testing program. This testing program was initiated the week of May 29, 2000. Each week, approximately six (6) split effluent samples will be collected for oil and grease analysis. Sample No. 1 will be analyzed for oil and grease by Method 1664 and Sample No. 2 will serve as the QC matrix spike for Method 1664. If the oil and grease result by Method 1664 is greater than 10 mg/L, additional analyses will be performed as follows. Sample No. 3 will be analyzed for oil and grease by Method 1664 with the addition of 3 a silica gel treatment and Sample No. 4 will serve as the QC matrix spike. Sample No. 5 will be analyzed for oil and grease by Method 413.1 and Sample No. 6 will serve as the QC matrix spike. It is expected that this testing will help to clarify some of the issues associated with the new analytical Method 1664 and will help to determine a more appropriate oil and grease limit for PPG's effluent. This testing program will continue until a total of eight (8) full sets of oil and grease data are obtained, which is the number of samples required for EPA's method of side -by - side testing. Because Method 1664 does not consistently result in an oil and grease result greater than 10 mg/L, it is expected that testing will take longer than eight weeks to complete. We appreciate NCDENR's cooperation with this testing program. During this testing program, we would like to request that PPG's NPDES permit be temporarily modified from an oil and grease limit of 10 mg/L to a "monitor only" status. PPG will continue to maintain optimum performance of the treatment system throughout this testing program. Sincerely, Lacy allard Attachment cc: V<ex Gleason, NCDENR-Mooresville Chet Whiting, NCDENR- Mooresville Bob Stein, AWARE Environmental Inc. Lili Gellner, AWARE Environmental Inc. M. LeCroy R. Daman J. Buchanan 259011001 7 TABLE 1 SUMMARY OF PPG EFFLUENT OIL AND GREASE RESULTS (12/1/99 — 4/12/00) Date Sample Collected PPG Effluent Oil and Grease (mg/L) Ratio of Oil and Grease (Hexane Extraction/Freon Extraction) Hexane Extraction (EPA Method 1664) Freon Extraction (EPA Method 413.1) 12/01/99 <5.0 12/07/99 <5.0 12/15/99 <5.0 12/21 /99 11.0 2.6 4.2 12/28/00 <5.0 01105100 7.8 _ 01 / 12/00 9.1 _ 01 / 19/00 49.0 1.8 27.2 O1/26/00 <5.0 02/02/00 6.1 _ 02/09/00 <5.0 02/16/00 11.0 7.3 1.5 02/23/00 10.0 03/01/00 <5.0 03/08/00 <5.0 03 / 15/00 <5.0 03/22/00 28.0 3.5 8.0 03/29/00 <5.0 04/05/00 5.8 _ 04/ 12/00 15.0 Notes: Split sample not analyzed by Method 413.1 unless result from Method 1664 is greater than 10 mg/L. NA = Not Analyzed 5 TABLE 2 SUMMARY OF LABORATORY MATRIX SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease Matrix Spike EPA Method 1664 - Hexane Extraction) Date Background O&G Concentration of Sample (mg/L) Spike O&G Concentration (mg/L) Result (mg/L) %Spike Recovery (mg/L) 12/01/99 11.0 42.1 67.5 134.0 % 12/07/99 0.0 40.0 41.3 103.0 % 12/15/99 6.8 42.1 28.7 52.2 % 12/21/99 14.0 42.1 28.0 313 % 12/28/00 11.2 42.1 46.2 83.1 % 01/05/00 7.8 40.0 13.8 15.0 % 01/12/00 13.3 40.0 86.2 182.0 % 01/19/00 0.0 40.0 19.0 47.5 % 01/26/00 53.1 40.0 165.1 280.0 % 02/02/00 24.3 40.0 38.6 60.0 % 02/09/00 10.6 40.8 65.2 134.0 % 02/16/00 43.8 48.8 65.7 44.9 % 02/23/00 19.3 40.0 51.2 79.8 % 03/01/00 7.2 40.0 31.4 60.5 % 03/08/00 0.0 40.0 29.3 73.3 % 03/15/00 2.9 40.0 17.3 36.0 % 03/22/00 8.8 40.0 37.1 70.8 % 03/29/00 0.1 40.0 34.7 86.5 % 04/05/00 0.0 40.0 52.9 132.0 % 04/ 12/00 10.5 40.0 39.8 73.3 % Maximum Spike Recovery 15.0 % Minimum Spike Recovery 280.0 % TABLE 3 SUMMARY OF LABORATORY DI WATER CONTROL SPIKE RESULTS (NON PPG SAMPLES) Oil and Grease DI Water Control Spike Hexane Extraction EPA Method 1664 Freon Extraction EPA Method 413.1 Date Spike O&G Concentration m /L Result (mg�) Percent Spike Recovery m /L Spike O&G Concentration m /L) Result (mg/L) Percent Spike Recovery (mglL) 12/01/99 40.0 34.4 86.0 % 12/07/99 40.0 36.1 90.3 % 12/15/99 40.0 36.1 90.3 % 12/21/99 40.0 37.9 94.8 % 520.0 477.0 91.7 % 12/28/00 40.0 39.1 97.8 % 01/05/00 40.0 36.6 91.5 % 01/12/00 40.0 38.9 97.3 % 01/19/00 40.0 40.1 100.0 % 501.0 513.0 102.0 % 01 /26/00 40.0 44.8 112.0 % 02/02/00 40.0 38.6 96.5 % 02/09/00 40.0 36.2 90.5 % 02/16/00 40.0 37.0 92.5 % 267.0 241.0 90.3 % 02/23/00 40.0 38.2 95.5 % 03/01/00 40.0 36.2 90.5 % 03/08/00 40.0 41.5 104.0 % 03/15/00 40.0 42.4 106.0 % 03/22/00 40.0 47.9 120.0 % 200.0 182.0 91.0 % 03/29/00 40.0 48.3 121.0 % 04/05/00 40.0 53.8 135.0 % 04/12/00 40.0 44.4 111.0 % Nlaximum Spike Recovery 135.0 % 102.0 % Minimum Spike Recovery 86.0 % 90.3 % PRI PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA April 13, 1998 Mr. D. Rex Gleason, P.E. North Carolina Department of Environment and Natural Resources Division of Water Quality 919 North Main Street Mooresville, NC 28115 Subject: Quarterly Progress Report Special Order by Consent EMC WQ No. 96-24 PPG Industries NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Gleason: N.C. DWr. OF BNVM0DNhHW, MALT6 , & NATURAL IRJlWtiPXM APR 1 41998 !!fMW i WMIE MM PPG Industries, Inc., located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by Consent (SOC) with the State of North Carolina on March 11, 1997. This report is to satisfy the requirements of Item 2.d. of the SOC which states that PPG -Shelby shall submit a Quarterly Progress Report by the 15th day of April 1998. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1-4). As indicated in our January 1998 progress report, plans and specifications for upgrading the WWTP were submitted in accordance with the September 30, 1997 deadline (Activity 2.c.3). The Authorization to Construct (ATC) for permanent implementation of the upgrades to the wastewater treatment system was issued by the Division of Water Quality (DWQ) on January 13, 1998. We have completed conversion of the pilot clay feed system to permanent use (Activity 2.c.4). The Engineer's Certification of completion of the system was submitted to the DWQ and a copy of this certification is also attached. The only remaining activity is to achieve compliance with final effluent limitations by June 30, 1998 (Activity 2.c.5). The results of the full range chronic toxicity monitoring performed in January 1998 in accordance with the SOC are summarized in Table 1. As indicated in Table 1, the test passed with an NOEC of 49.5 %. The sample reproduction at the 33 % in -stream waste concentration (IWC) was 102 % of the control reproduction. s We are continuing to optimize the bentonite clay dosage to the system. This optimization program includes the performance of monthly toxicity screening tests in addition to the quarterly testing required in the SOC. Table 2 presents a summary of all of the effluent toxicity testing performed from 1997 to date. Bentonite clay was first introduced to the treatment system on March 25, 1997 with 1000 lbs being added directly to the aeration basin. On March 26, 1997, a program of adding 250 lbs/day of bentonite clay to the WWTP on a 24 hour basis, via a slurry system, was started. Since that time we have maintained an on -going program for optimizing the bentonite clay dosage in order to control effluent toxicity on a consistent basis while minimizing sludge production. We are currently feeding 285 lbs/day of bentonite clay to the aeration basin and believe that this dosage is sufficient to control effluent toxicity in our discharge. Full Range Monitoring will be performed in April 1998 to satisfy the quarterly monitoring requirements of the SOC. We will also continue to monitor fluoride on a weekly basis as required by the SOC. We feel that we have implemented a system to produce a discharge which will consistently meet the chronic toxicity limits. We anticipate that we will achieve consistent compliance with the permitted final effluent limitations by June 30, 1998 as required in Activity 2.6.5 of the SOC. We will continue to keep you informed of our progress and the status of further SOC task deadlines and will let you know when we receive an ATC for the clay feed system. In the meantime, if you have any questions, please do not hesitate to call me at (704) 434-2261 Ext. 544. Sincerely, Lacy Ballard Staff Engineer Attachments cc: A. Astroth R. Hutton, AEI M. LeCroy M. Reilly C. Bromby TABLE 1 PPG Shelby - Full Range Effluent Toxicity Monitoring January 1998 TEST REPRODUCTION % REDUCTION CONTROL 26.0 NA 8.25 % 27.4 -6.5 % 16.5 % 27.1 -4.2 % 33% 26.4 -1.5% 49.5 % 25.6 1.5 % 66 % 14.7 43.5 % W"To :011-W" ENGINEER'S CERTIFICATION FOR BENTONITE CLAY ADDITION SYSTEM Z1 PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150 April 1, 1998 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products Permits and Engineering Unit State of North Carolina Department of Environment and Natural Resources P.O. Box 29535 Raleigh, N.C. 27626-0535 Re: NPDES Permit Number NC00046845 Authorization to Construct - PPG Industries, Shelby Cleveland County Dear Sirs: 704-434-2261 Extension 544 Iballard@ppg.com Based on your January 13, 1998 authorization to construct, we have completed the installation of a bentonite clay feed system with additional tanks, valves, piping and control equipment. The equipment has been installed in accordance with the approved plans and specifications. Attached is a copy of our engineer's certification for this facility. Please let me know if you have any questions regarding this certification or if additional information is needed. Sincerely, Lacy Ballard cc: M. LeCroy B. Blackwell J � � . PPG Industncs Fgineer's Certit'ication I, Robert M. Stein. , as a duly registered professional Engineer in the State of North Carolina, having been authorized to observe (periodically weekly full time) the construction of tine Bentonite Clay Feed System NG Industries project, NPDES Permit No. NC0004685 , Cleveland County, NC for the Benton ProAc Named. System Location Perm u= hereby Suez that, to the best of my abilities, due care and diligence was used for the above referenced protect such that the construction was observed to be built within substantial compliance and intent of the approved plans and specifications. Signature � Registration No. 12869 Date March 12, 1998 ESS1G,y �O -INS ,6��'T M. r. estate of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E.; Director January 1.3, 1998 Ms. Lacy Ballard PPG Industries, Inc. 940 Washburn Switch Rd. Shelby, North Carolina 28150 ME, ARM kV6 op I'&AUriiA 12Utd(:'rsS Subject: Permit Number NCO04685 Authorization to Construct PPG Ind./Shelby Plant Cleveland County Dear Ms. Ballard: JAN 16 199a i tE � et1 &'Fr1 'E A letter of request for an Authorization to Construct (ATC) was received October 2.1, 1.997 by the Division and final plans, specifications, and pilot test data for the subject project have been reviewed and found to be satisfactory. Authorization is hereby granted for the construction and installation of the proposed components to upgrade the existing 1.3 MGD wastewater treatment plant with outfall 001 discharging to Brushy Creek in .lie Broad River Basin. This ATC allows the installation of a bentonite clay feed system and additional tanks, mixers, pumps, piping, valves, and control equipment with feed to the aeration splitter box. This Authorization to Construct is issued in accordance with Part11I, Paragraph C of NPDF.,S No. NC0004685 issued September 28, 1994.and shall be subject to revocation unless the water treatment facilities are constructed in accordance with the conditions and limitations specified above, and in Permit No. NC0004685. Any sludge generated from this treatment facility must be disposed of in accordance with G.S. 43-215.1 and in a manner approved by the North Carolina Division of Water Quality. In the event that the facility fails to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those as may be required by this Division, such as the construction of additional or replacement water treatment or disposal facilities. The Mooresville Regional Office, telephone number (704) 663-1699, shall be notified at least forty-eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be made. Such notification to the regional supervisor shalt be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. Upon completion of construction and prior to operation of this permitted facility, a certification must be received from a professional engineer certifying that the permitted facility has been installed in accordance with the NPDES Permit, this Authorization to Construct and the approved plans and specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC 27626-0535. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 04685 ATC 50 recycled/ 10% post -consumer paper Ift A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life of the facility. Failure to abide by the requirements contained in this Authorization to Constrict may subject the Permittee to an enforcement action by the Division of Water Quality in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction. One (1) set of approved plans and specifications is being forwarded to you. If you have any questions or need additional information, please contact Steven D. Pellei, telephone number (919) 733-5083 extension 516. Sincerely, '.1��"� Q--A. Preston Ho ard, Jr., P.E. cc: Central Files -Mooresville-Regional Office, Water Quality Training and Certification Unit NPDES Files Steven Pellei 1NSCNA p0.(.' .OLA�10*, 00\ ROAD CLASSIFICATION PRIMARY HIGHWAY LIGHT -DUTY ROAD, HARD OR HARD SURFACE IMPROVED SURFACE SECONDARY HIGHWAY HARD SURFACE UNIMPROVED ROAD Latitude 35°20'43" Longitude 81 °37'02" Map # F12SE Sub -basin 030834 Stream Class C Discharge Class 100% Industrial Receiving Stream Brush/ Branch Design Q 1.3 MG D Permit expires 12/31/98 SCALE 1:24 000 QUAD LOCATION PPG Industries NC0004685 ClevelandCounty WWTF EWE` I/ V PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA -. January 9, 1998 Mr. D. Rex Gleason, P.E. North Carolina Department of Environment and Natural Resources Division of Water Quality 919 North Main Street Mooresville, NC 28115 Subject: Quarterly Progress Report Special Order by Consent EMC WQ No. 96-24 PPG Industries, NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Gleason: PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by Consent (SOC) with the State of North Carolina on March 11, 1997. This report is to satisfy the requirements of Item 2.d. of the SOC which states that PPG -Shelby shall submit a Quarterly Progress Report by the 15th day of January 1998. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1 & 2) and submitted Plans and Specifications for upgrading the WWTP to your office prior to the SOC deadline of September 30, 1997. We have also submitted the required information to the State - Division of Water Quality Unit in Raleigh in order to obtain an Authorization to Construct (ATC). To date we have not received any response from the State - Division of Water Quality Unit on this matter. Due to the fact that we are converting our pilot unit to permanent use, we feel that we have complied with SOC Activities 2.c.3 & 4 with the previous submittal (October 1997) and the only remaining activity is to achieve compliance with final effluent limitations by June 30, 1998 (Activity 2.c.5). Since the last Quarterly Progress Report, presented to the State in October of 1997, PPG -Shelby has continued full scale testing of feeding bentonite clay to the WWTP biological system. Full range monitoring, as required by the SOC, was performed during the week of October 27 - 31, 1997. The full range monitoring performed in October indicated an LOEC of 66 %, an NOEC of 49.5 % and a Chronic Value of 57.1 %. Results of these tests are presented in Table 1. These results continue to show permit compliance. Single concentration toxicity tests at PPG-Shelby's permitted NOEC (33 %) were also performed during the weeks of November 24 - 28, 1997 and December 15 - 19, 1997. The results of these two (2) single concentration tests indicated reproductions of 109 % and 86% respectively (Table 2). Bentonite clay was first introduced to the treatment system on March 25, 1997 with 1000 lbs being added directly to the aeration basin. On March 26, 1997, a program of adding 250 lbs/day of bentonite clay to the WWTP on a 24 hour basis, via a slurry system, was started. Bentonite clay dosages have been increased as necessary to control effluent toxicity and decreased in order to determine the most effective dosage that will control effluent toxicity and produce minimal excess sludge. We are currently feeding 400 lbs/day to the aeration basin and believe that this dosage is sufficient to control effluent toxicity in our discharge. Table 2 presents the results of all full scale effluent toxicity testing performed in 1997. All PPG -Shelby effluent toxicity tests, since May of 1997 have been in compliance with permit criteria. The addition of the bentonite clay has reduced and controlled chronic toxicity in PPG-Shelby's effluent. Full Range Monitoring will be performed in January of 1998 to satisfy the first quarter monitoring requirements of the SOC. We will continue to monitor fluoride on a weekly basis as required by the SOC. PPG feels that we have found and implemented a system to produce a discharge that will consistently meet the chronic effluent toxicity limits at our permitted dilution. At this time we are planning to sample and test our discharge for chronic toxicity at a frequency of approximately one (1) time per month. This frequency, in excess of the SOC requirements, will allow PPG to optimize the clay feed system and feed requirements. We will continue to keep you informed of our progress and the status of further SOC task deadlines and will let you know when we receive an ATC for the clay feed system. In the meantime, if you have any questions, please do not hesitate to call me at (704) 434-2261 Ext. 544. Sincerely, Lacy Ballard Staff Engineer Attachments cc: A. Astroth T. Keesling, AEI M. LeCroy C. Bromby M. Reilly TABLE 1 PPG Shelby - Full Range Effluent Toxicity Monitoring October 27 - 31, 1997 TEST REPRODUCTION % REDUCTION CONTROL 21.6 NA 8.25 % 22.2 -2.8 % 16.5 % 22.7 -5.1 % 33% 20.5 5.0% 49.5 % 19.7 10.1 % 66 % 12.9 40.2 % TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 11 CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 38 1/14/97 ROUTINE EFFLUENT MONITORING (2) 27.3 9.6 35% 0% 1016/986 FAIL 50 mg/1 Bentonite added + filtration 38-A 1/14/97 EFFLUENT MONITORING (2) 27.3 18.9 69% 0% 1029/952 FAIL 250 mg/l Bentonite added + filtration 38-B 1/14/97 EFFLUENT MONITORING (2) 27.3 23.3 85% 0% 1040/1023 PASS 500 mg/l Bentonite added + filtration 38-C 1/14/97 EFFLUENT MONITORING (2) 27.3 27.3 100% 0% 1047/1051 PASS 39 1/29/97 EFFLUENT MONITORING (2) 27.0 12.8 47% 0% 874/958 FAIL filtered with TSS filter 39-A 1/29/97 EFFLUENT MONITORING (2) 27.0 22.5 83% 0% 867/951 PASS 40 2/ 12/97 EFFLUENT MONITORING (2) 22.3 8.4 38 % 0% 1002/ 1162 FAIL 41 2/26/97 EFFLUENT MONITORING (2) 25.2 22.3 88% 0% 845/966 PASS 42 3/ 12/97 EFFLUENT MONITORING (2) 24.2 8.4 35 % 0% 1320/ 1291 FAIL 8.25 % 43 -A 3/26/97 EFFLUENT MONITORING (2) 23.2 23.7 102 % 0% 1557/1340 PASS 16.50 % 43-B 3/26/97 EFFLUENT MONITORING (2) 23.2 21.7 94 % 0% 1557/1340 PASS 33 % 43-C 3/26/97 EFFLUENT MONITORING (2) 23.2 12.2 53 % 10 % 1557/1340 FAIL 49.50 % 43-D 3/26/97 EFFLUENT MONITORING (2) 23.2 1.5 6% 20% 1557/1340 FAIL 66 % 43-E 3/26/97 EFFLUENT MONITORING (2) 23.2 0.0 0% 40% 1557/1340 FAIL 44 4/2/97 EFFLUENT MONITORING (2) 24.2 11.4 47% 0% 1593/1518 FAIL filtered with TSS filter 44-A 4/2/97 EFFLUENT MONITORING (2) 24.2 11.6 48% 0% 1588/1521 FAIL untreated effluent 44-B 4/ 13/97 EFFLUENT MONITORING (2) 26.2 13.8 53 % 0% 1610/ 1528 FAIL 250 mg/1 Bentonite added + filtration 44-C 4/ 13/97 EFFLUENT MONITORING (2) 26.2 15.6 60 % 0% 1655/ 1590 FAIL 1/5/98 Toxtest2 EFFLUENT SAMPLING 1 of 4 TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 11 SAMPLE DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/FAIL 44-D 4/13/97 1000 mg/1 Bentonite added + filtration EFFLUENT MONITORING (2) 26.2 23.2 89% 0% 1795/1738 PASS 45 4/9/97 EFFLUENT MONITORING (2) 24.6 18.8 76% 0% 1067/1356 FAIL 45-A 4/9/97 filtered with TSS filter EFFLUENT MONITORING (2) 24.6 22.2 90% 0% 1060/1347 PASS 46 4/ 16/97 EFFLUENT MONITORING (2) 23.2 6.8 29 % 0% 1395/ 1215 FAIL 46-A 4/16/97 filtered with TSS filter EFFLUENT MONITORING (2) 23.2 7.8 34% 0% 1404/1210 FAIL 47-A 4/23/97 8.25 % EFFLUENT MONITORING (2) 22.8 22.1 97% 0% 1133/1420 PASS 47-B 4/23/97 16.50 % EFFLUENT MONITORING (2) 22.8 19.1 84% 0% 1133/1420 PASS 47-C 4/23/97 33 % EFFLUENT MONITORING (2) 22.8 15.7 69% 0% 1133/1420 FAIL 47-D 4/23/97 49.50 % EFFLUENT MONITORING (2) 22.8 8.0 35% 0% 1133/1420 FAIL 47-E 4/23/97 66 % EFFLUENT MONITORING (2) 22.8 3.3 14% 10% 1133/1420 FAIL 48 4/30/97 EFFLUENT MONITORING (2) 20.4 19.2 94 % 0% 1298/ 1159 PASS 49 5/7/97 EFFLUENT MONITORING (2) 23.0 20.2 88% 0% 1015/1028 PASS 50 5/ 14/97 EFFLUENT MONITORING (2) 26.3 19.1 73 % 0% 1109/ 1098 FAIL 51 5/21/97 EFFLUENT MONITORING (2) 21.6 17.6 81 % 0% 1137/932 PASS 52 5/28/97 EFFLUENT MONITORING (2) 23.0 22.7 99 % 0% 857/945 PASS 53 6/4/97 EFFLUENT MONITORING (2) 24.0 21.2 88 % 0% 952/1181 PASS 54 6/11/97 EFFLUENT MONITORING (2) 16.0 15.7 98% 0% 1000/1155 PASS 55 6/25/97 EFFLUENT MONITORING (2) 20.4 22.7 111 % 0% 1072/ 1010 PASS 1/5/98 Toxtest2 EFFLUENT SAMPLING 2 of 4 TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 C CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 56 7/2/97 EFFLUENT MONITORING (2) 23.8 21.7 91 % 0% PASS 8.25 % 57-A 7/23/97 EFFLUENT MONITORING (2) 21.2 23.4 110% 0% 1144/1086 PASS 16.50 % 57-B 7/23/97 EFFLUENT MONITORING (2) 21.2 22.7 107 % 0% 1144/1086 PASS 33 % 57-C 7/23/97 EFFLUENT MONITORING (2) 21.2 22.2 105 % 0% 1144/1086 PASS 49.50 % 57-D 7/23/97 EFFLUENT MONITORING (2) 21.2 21.2 100% 0% 1144/1086 PASS 66 % 57-E 7/23/97 EFFLUENT MONITORING (2) 21.2 14.7 69% 0% 1144/1086 FAIL 58 7/31/97 EFFLUENT MONITORING (2) 25.3 28.2 111 % 0% 1153/957 PASS 8.25 % 59-A 8/I1/97 EFFLUENT MONITORING (2) 23.0 22.8 99% 0% 1128/1164 PASS 16.50 % 59-B 8/I1/97 EFFLUENT MONITORING (2) 23.0 21.7 94% 0% 1128/1164 PASS 33 % 59-C 8/11/97 EFFLUENT MONITORING (2) 23.0 22.0 96% 0% 1128/1164 PASS 49.50 % 59-D 8/11/97 EFFLUENT MONITORING (2) 23.0 20.6 90% 0% 1128/1164 PASS 66 % 59-F 8/I1/97 EFFLUENT MONITORING (2) 23.0 18.1 79% 0% 1128/1164 FAIL 60 8/25/97 EFFLUENT MONITORING (2) 17.9 21.3 119 % 0% 1200/ 1355 PASS 8.25 % 61-A 9/15/97 EFFLUENT MONITORING (2) 21.4 25.3 118% 0% 1258/1557 PASS 16.50 % 61-B 9/15/97 EFFLUENT MONITORING (2) 21.4 22.6 106% 0% 1258/1557 PASS 33 % 61-C 9/15/97 EFFLUENT MONITORING (2) 21.4 21.3 100% 0% 1258/1557 PASS 49.50 % 61-D 9/15/97 EFFLUENT MONITORING (2) 21.4 22.5 105% 0% 1258/1557 PASS 66 % 61-E 9/15/97 EFFLUENT MONITORING (2) 21.4 10.5 49% 40% 1258/1557 FAIL 1/5/98 Toxtest2 EFFLUENT SAMPLING 3 of 4 TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 11 CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 8.25 % 62-A 10/29/97 EFFLUENT MONITORING (2) 21.6 22.2 103% 0% 1173/1314 PASS 16.50 %- 62-B 10/29/97 EFFLUENT MONITORING (2) 21.6 22.7 105% 0% 1173/1314 PASS 33 % 61-C 10/29/97 EFFLUENT MONITORING (2) 21.6 20.5 95% 0% 1173/1314 PASS 49.50 % 61-D 10/29/97 EFFLUENT MONITORING (2) 21.6 19.7 91 % 0% 1173/1314 PASS 66 % 61-E 10/29/97 EFFLUENT MONITORING (2) 21.6 12.9 60 % 10 % 1173/1314 FAIL 62 11/26/97 EFFLUENT MONITORING (2) 22.1 24.1 109% 0% 1190/1381 PASS 63 12/15/97 EFFLUENT MONITORING (2) 20.9 18.1 86% 0% 1152/1348 PASS 1/5/98 Toxtest2 EFFLUENT SAMPLING 4 of 4 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek-, P. E- Director Division of Water Quality April 12, 2005 Mr. Todd Winn Environmental Engineering Associate PPG Industries Fiber Glass Products, Inc. 940 Washburn Switch Road Shelby, NC 28150 Subject: Compliance Evaluation Inspection Shelby Facility WWTP NPDES Permit No. NC0004685 Cleveland County, North Carolina Dear Mr. Winn: Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on April 1, 2005 by Ms. Donna Hood of this Office. Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report. The report should be self-explanatory, however, should you have any questions conceiving this report, please do not hesitate to contact Ms. Hood or me at (704) 663-1699. Sincerely, D. Rex Gleason, P.E. Surface Water Protection Regional Supervisor Enclosure cc: Cleveland County Health Department DH N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 (704) 663-1699 Customer Service 1-877-623-6748 United States Environmental Protection Agency Form Approved. EPA Washington. D.C. 20460 /-� OMB No. 2040-0057 InspectionWater Compliance Approval expires 6-31-96 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 17 1B I C I 19 U 20 U 1 I Nuu I 2 U 31 NC0004685 1 11 121 05/04/01 �--� Remarks 211111Jill 11IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII Li66 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---Reserved 671 1.5 169 70 U 71 U 72 U 73 LU 74 75I I I I I I I I B0 Section B: Facility Data 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) 09:3C AM 05/04/01 99/05/C1 PPGIndustries Fiber Glass Products =nc - Shelby Exit Time/Date Permit Expiration Date 940 Washburn Switch Rd Shelby NC 28150 12:00 PM 05/04/02 C3/CB/31 Name(s) of Onsite Rep resentative(s)rritles(s)/Phone and Fax Number(s) Other Facility Data Her_ry F Blackwell//7C4-434-2261 / Henry F Blackwell/ORC/704-434-2261/ Name, Address of Responsible Officiallritle/Phone and Fax Number Todd Winn, Ergir_eerirg Associate,94C Washburr_ Switch Rd Shelby NC Contacted 2815C/Engineering Associate/7044342261359/7044340792 Yes 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 Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspectors) Agency/OfficelPhone and Fax Numbers Date Dorr Hood MRO WQ/// 1 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Richard M Bridgemar_ 704-663-1699 Ext.264/ EPA Form 3550-3 (Rev 9-94) Previous editions are obsolete. �IlDlt (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Yes No NA NF ■ ❑ ❑ ❑ Is the facility as described in the permit? 0 ❑ ❑ ❑ Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: See attached summary Onerations A Maintenance Y No NA N Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells? -c MO ❑ ❑ Is the plant generally clean with acceptable housekeeping? ❑ ❑ ❑ Comment: Bar S Yes No NA NF .reans Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? M ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Yes No NA Eauali7ntion Basins Is aeration adequate? NF ❑ 13 1 ❑ Is the basin free of bypass lines or structures to the natural environment? ■ ❑ ❑ ❑ Is the general housekeeping acceptable? M ❑ ❑ ❑ Is the basin free of excessive grease? N ❑ ❑ ❑ i Are all pumps.present? M ❑ ❑ .❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? E ❑ .❑ ❑ Are audible and visual alarms operable? M ❑ 0-0 Is basin sizelvolume adequate? E ❑ ❑ ❑ Comment: Yes No NA NF Primary Clarifier Is the clarifier free of black and odorous wastewater? No ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? N ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? M ❑ ❑ ❑ Is the site free of evidence of short-circuiting? E ❑ ❑ ❑ Is scum removal adequate? i ❑ ❑ ❑ Is the site free of excessive floating sludge? ! ❑ ❑ ❑ Is the drive unit operational? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? ❑ ❑ ❑ M Comment: Secondary Clarifier Is the clarifier free of black and odorous wastewater? Yes No NA NF 00 ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ 13 ❑ u O O O O O O O O IL O O 2 O O O O O■■ IL 2 0 O O O.O O LL O 2 O■ O O O O O O O O 42 O O O O O O O O O O O■ O O O O Q� O O■ 1 0 0 0■ ■■ ■■■■■ O O O O O O O O O / J O O O O Q O O i O Q O O Q O O O O O O O O O O O O ■■■■■■■ m■■ o■ Q■■■ O O �■■ m O O■■ cr Q O O O O O O O O O .% C, m \ \) \ cm k f { ° 2 a; D 7 ) e { k- 0 § B . § C RCL Cb Go � / k � a I§ § R B \ / © § ( B ' / & §ƒ{.2 § g 2 0 s E k @ D 2 £ � # 2) 0 C o � � e 0 k k k f f § e a a % o � 0, � $ f § 4 E E ® R % MY) s © % fCIOE c B 0. g 2 t t = E . k k 2§ »� 0 ƒ 7)�# 'a ` k § \ k tG m\ R ` ` \ 2 - < | § 2 E§ @ \ 5 / k 0 ƒ' 2ƒ\ e \ a f§ k k m$ c _ \ . m S' _ k§ k / e [ _ / g E / a o 3 c k f % 2 i§ ( / : c] k \ L \ § t n 1fectio 1 Ire tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? (Sodium Hypochlorite) Is pump feed system operational? Is bulk storage tank containment area adequate? (free of leaks/open drains) Is the level of chlorine residual acceptable? Is there adequate detention time Is the contact chamber free of growth, or sludge buildup? Comment: See attached summary Standby Power Is automatically activated standby power available? Is generator tested weekly by interrupting primary power source? Is generator tested under load at least quarterly? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Does generator have adequate fuel? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Comment: LaboratnEy Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? Is the facility using a contract lab? Are analytical results consistent with data reported on DMRs? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Incubator (Fecal Coliiform) set to 44.5 degrees Celsius+/- 02 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? Comment: See attached summary Is flow meter used for reporting? Is flow meter calibrated annually? Is flow meter operating properly? (if units are separated) Does the chart recorder match the flow meter? Comment: See attached summary 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? Are sampling and analysis data adequate and include: 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 Yes No NA NF M ❑ ❑ ❑ ❑■❑❑ 0 ❑ ❑ ■ O o❑■❑ ❑OEO ❑❑■❑ 0000 Yes No NA NF ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ O ❑ ■ M ❑ ❑ ❑ M ❑ .❑ ❑ 0000 Yes No NA NF ® ❑ ❑ ❑ 0000 M ❑ ❑ ❑ ® ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑❑'O■ ❑ ❑ ❑ M Yes No NA NF ■ O O ❑ ■ ❑ ❑ ❑ 0000 ❑ ! O ❑ Yes No NA NF ❑ ❑ ❑ ®❑ O ❑ ■❑❑❑ ®❑❑❑ 0000 M ■ Record Keeping Transported COCs Yes No NA NF .0 Plant records are adequate, available and include ! 000 O&M Manual As built Engineering drawings Schedules and dates of equipment maintenance and repairs 0 Are DMRs complete: do they include all permit parameters? N ❑ ❑ ❑ Has the facility submitted its annual compliance report to users? ❑ ❑ N ❑ (If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? ❑ ❑ N ❑ Is the ORC visitation log available and current?. 0 ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? r -❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 D ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ .❑ ❑ Is the facility description verified as contained in the'NPDES permit? 0 .❑ ❑ ❑ Does the facility analyze process control parameters, for example: MLSS, MCRT, Settleable Solids, DO,.Sludge E :❑ ❑ ❑ Judge, pH, and others that are applicable? Facility has copy of previous year's Annual Report on file for review? ❑ ❑ E ❑ Comment See attached summary Influent Sampling Yes No NA NF Is composite sampling flow proportional? N ❑ ❑ ❑ Is sample collected above side streams? ■ ❑ ❑ ❑ Is proper volume collected? N ❑ ❑ ❑ Is the tubing clean? ❑ ❑ ❑ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? E ❑ ❑ ❑ Is sampling performed according to the permit? ❑ ❑ 0 ❑ Comment See attached summary Effluent Sgmpli= Yes No NA NF Is composite sampling flow proportional? N ❑ ❑ ❑ Is sample collected below all treatment units? N ❑ ❑ ❑ Is proper volume collected? M .❑ ❑ •❑ Is the tubing clean? 0 .❑ . ❑ ❑ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ❑ N ❑ ❑ Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ❑ ❑ ❑ Comment See attached summary Aerobic Digester Yes No NA NF Is the capacity adequate? N ❑ ❑ ❑ Is the mixing adequate? N ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ .❑ ❑ Is the odor acceptable? 0 ❑ ❑ ❑ Comment: The digester is used as a sludge holding tank. Solids Handling EgyiRment Yes No Is the equipment operational? NA NF E ❑ ❑ ❑ Is the chemical.feed equipment operational? E ❑ ❑ ❑ Is storage adequate? E ❑ ❑ ❑ 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? 0 0 0 0 10 Solids Handling Fn,ifinment Is the site free of excessive moisture in belt filter press sludge cake? Comment: See attached summary Is right of way to the outfall properly maintained? Are receiving water free of solids and floatable wastewater materials? Are the receiving waters free of solids / debris? Are the receiving waters free of foam other than a trace? Are the receiving waters free of sludge worms? If effluent (diffuser pipes are required) are they operating properly? Comment: See attached summary Ywc Nn NA NF ❑ ❑ ❑ SECTION D: SUMMARY OF FINDING/COMMENTS Additional Observations: Permit: PPG's permit expired on.8/31/2003. A renewal package was received by the Department on February"25, .2003. Mr. Todd Winn has been in touch with Raleigh twice concerning the new permit. Raleigh has informed Mr. Winn that personnel shortages have caused the delay in the permit reissuance. Laboratory: :Samples care currently sent to Pace Laboratory. This practice started on March 143 2005. PPG no longer does analyses other than field analyses, although they have retained the lab certification to perform such tests. Record Keeping: DMRs for February 2004 through February 2005 were reviewed. Oil and grease violations were noted for .5/04 and 6/04; the violations were addressed through NOV-2004-LV-0391 and NOV 2004-LV-0517. No other violations were noted. The facility has extensive records and calibrations kept for 5 years. It was noted during the inspection that -.calibration time was not recorded on the bench sheet. Please:adjust the pH calibration bench sheet to include calibration time. .Please continue the monitoring and reporting on outfall 002. Amended DMRs need to be sent to reflect .the data compiled at outfall 002 in 2004. Influent Sampling: PPG regularly samples influent for monitoring purposes. Mr. Winn was advised to report this information on the monthly DMR as per the permit, Part II, E. 5b. Effluent Sampling: Effluent. composite. samples are already being collected at the proper amount and frequency. An exemplary effort by PPG considering these sampling instructions have yet to arrive in the new permit. Effluent sample is pumped into the lab office where it is collected.inside a refrigerator. The temperature inside was observed to be 5°C. Be advised that the proper temperature for sample storage is 1.0°- 4.4°C. Effluent Flow Measurement: The Foxboro Company calibrates the flow meter. The chart recorder was off by. l hour at .the time of inspection. The inspector was advised that the chart had just been changed and was off due to operator error. Please be careful to install the chart correctly. Disinfection: As of .this inspection PPG is not utilizing disinfection. There has been no .occurrence of -fecal violation and fecal counts -are usually very low. Be advised that facilities designated for,chlorine use -are :receiving Total Residual Chlorine :(TRC) limits with permit renewal. While this is not an issue :for the facility:at this time, should a future need .arise .to chlorinate, :these .limits will be enforced. `Steps to provide dechlorination in a timely fashion should be considered. Solids Handling: PPG has a belt press for solids handling. Cake coming off the press looked good and centrate was clean. Cake is stored in a dumpster and is disposed of at the landfill. Effluent Pipe: Brushy Creek was rain .swollen at the time of inspection. Thorough analysis by close proximity to the pipe was not accomplished. From the bridge, near the outfall, .all looked well. PPG Industries, 940 Washburn Switch Road, Shelby, NC 28150 Via Certified Mail - Return Receipt Requested October 6, 2005 Mr. (e:1no>1eas�on NC frepartment of Environment and Natural Resources Division of Water Quality 610 East Center Ave. Mooresville, NC 28115 A%iD N X- LiFRP L RE-S0URCE8 __ 710 AL OFFICE OCT i- 1 1 200e RE: Industrial Wastewater Overflow Response Evaluation — 10/01/2006 NPDES Permit No. NC0004685 Dear Mr. Gleason: On 10/1/06, the PPG Industries Fiber Glass Products Inc., Works 52, ("PPG") spilled approximately 170,000 gallons of wastewater when the treatment plant's surge tank overflowed for approximately 8 hrs before discovery. Most of the spillage followed contours of PPG property, an earthen storm water ditch, and settled into a low lying area (approximately 1.5 acres in area). In addition, approximately 7000 to 9000 gallons migrated off -site from a storm water out�faallll into Beaverdam Creek. The spill event was reported t6 Mr.__Wesley Bell ?t the Mooresville DWQ Regional office along with local news media as required y C General Statute 143. A copy of an article in the local newspaper is included with this letter as requested by Mr. Bell. The overflow began at approximately 3:00 PM and remained undetected until 10:55 PM when the night shift Technical Manager found the spill. He immediately diverted the waste water to the pre -designated WWTP holding pond ending the spill then contacted the treatment plant ORC who arrived on -site within 20 minutes. The ORC immediately inspected the spill area and contacted the Plant Environmental Engineer who arrived on - site within 30 minutes. While waiting on the engineer the ORC investigated and found the "Moore PLC Pump Controller" and alarm system had failed causing the surge tank to overflow. He re-established normal flow back through the treatment plant by operating the pumps in manual mode at approximately 11:45 PM. Plant operators were called in to operate the pumps until the controller could be repaired. approximately 11:50 PM the ORC and Engineer inspected the spill site and made determinations that the spill was a non -hazardous substance and the volume was approximately 170,000 gallons. At this time the spill was found not to have had a path to surface waters. At approximately 3:00 AM a Spill Recovery Contractor arrived on -site. He investigated the spill area and returned after daylight with three suction trucks and began transferring the spill residual to the WWTP holding pond. Later in the morning a heavy underbrush area was inspected and some of the spill was found to have escaped through a small ditch line into Storm Water Outfall #3. The noncompliance has been corrected; the spill residual was cleaned up, the surface water was and still is being monitored during rainfall events at the request of DWQ.. The cause was determined to be a complete failure of a "Moore PLC" which controlled the automatic pump system. The control was repaired by installation of a new Allen Bradley PLC pump controller and the alarm circuitry has been rewired. The repairs were completed and the automatic system was re -commissioned on Wednesday 10/4/06 at 3 PM. Steps have been taken and are planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. They include the following; 1- The Moore controller was replaced by installation of a new Allen Bradley PLC pump controller. 2- Weekly alarm testing has been expanded to include testing of all liquid level alarm points. 3- PPG will replace all remaining "Moore PLC Controllers" at the WWTP with an Allen Bradley 555 Processor which will insure future reliability of pump controls, alarm systems and all other controlled functions. This upgrade will be completed by year end. If you have any questions regarding this incident, please feel free to contact me at (704) 434-2261 x 359. Sincerely, ajye_� Richard Young Environmental Engineer cc: P. Westbrook D. Lemmon B. Blackwell P. Pride T. Mathis File .Nasdaq diary Advanced: 2,197 New highs .96 Declined: ' 647 New lows Unchanged: .122 '65 Volume: 2,222,817,799 AP LO CAL STOCKS Quotes for the previous day are provided by Edward Jones. COMPANY CLOSE CHG Allstate CP 64.14 +.26 Bank of America 54.82 +.41 BUT Corp. 44.10 +.24 BellSouth Corp. ' 42.99 +.22 B P 65.05 +1.33 Celanese 17.78 -.01 Curtiss-Wright 31.98 +.94 CVS Corp. 32.15 +,40 DollarGeneml 13.54 -.19 Duke Energy 31.28 +.03 Emerson Electric 84.77 +34 Eaton Corp. 69.70 +.17 ' FMC 65.88 +.97 . First Charter 23.35 +.26 Family Dollar 30.11 +.70 GE 36.10 +.39 Home Depot 37.49' '•'- +.66 Honeywell191 -42.45 • - Ingles Markets .::, .26.78 , .55 •:,,+.28, Kemet - r ,KrispyKreme 8.44•'" , +.23 Lowe's 29.96 +1.33. PPG Industries 67.11 - . +A2 Piedmont Natl Gas 25.80 +55 RBC 44.48 -.12 ' ockwell 57.93. ,' 4.48 dick 26.28 +.53 Corp. '16.33 +.27 er 18.57 +.23 74.49 +.88 ' 56.72 +.60 iuu miuiun noses of Liu vaceuie this year." BUSINESS nun uoses snoulu ue avauaule in most' doctors' offices .and L1evelanct bounty tiealtli Director Denese Stallings said Pa-rtidlly.-.�-treate-d wa stewater spills into.,."Be''aver am Cree Cassle'Tarpley . of water used in the' plant's The North Carolina cassietarpley@shelbystar.com • processing was released before. Division 'of Water Quality- is SHELBY - A "very, very it was fully treated, Mathis reviewing the incident. , strange event" at . PPG.. said. PPG's: environmental staff Industries caused a spill ater • ' of : "We treat it and ,then'dis; .inspected .the 'creek down - partially -treated - wastewcharge -it - into - ..the , local stream and found no evidence into Beaverdam Creek Sunday. stream,-" he said, "so what hap- . of any, detrimental. impact -to PPG- Plant Manager Tim pened is it didn't get fully the stream, the company said Mathis called "a malfunction heated. in a press release. with some of our equipment" He did: not elaborate about unusual and said because , -of the breakdown but said; "Our ON THE WEB:' the size of the spill (1,000 gal system has run very, very well , lops or more), the .,,state.- for 40 something years. PPG Industries:. . requires it to be reported and Obviously, we're working to http://corporateportal.ppg. published in local media. make sure' it' doesn't • happen i com/ppg/ About 7,000 to 9,000 gallons again,."'" -INDIAN MOTORCYCLE Indian record setter tapped for hall'; of fame; Forty' years after he sped..,- :w ' arid" build�theorld's latest : across the Bonneville salt flats motorcycle compeny: on his Indian motorcycle, New Zealander Burt Munro- will .: CassleTarpley this week be inducted into the American . Moforcyclist ,Association Hall of Fame. ' ; ,,T L 1 O'TTET)J\Y Munro,l the subject; of the .1 movie "The World's Fastest' Indian," set a world land speed of,165.517 mph (266.373 IF" Lharolrecord Cttkm/h) on his modified 1920sery vintage Indian in 1966. He returned to Utah in 1967 Wednesday's numbers: ; and set a new record of 190.7, _DI[%I( d 1. HE, s{r:-,For a•subscri}ption" please call our ' ..circulatjo.n department . (704) .484-7007 .Liva ,lu ��a�uii, 1.0 Vilcy. i Child] needs to: step' aside there,' =•1�x& -�, TEENS Fifth,.':uarater,}}��, continues.,,,. s : ':, • . o: WHAT,KIDS WANT TO KNOW;;=;' Chaperone What: The Fifth Quarter'.-,, ' i ',.-.,mo'r_q.w( Who: For all high and middle Secuie% S school'students in Cleveland,', `,�'r;;SfWlo Iea' „County:. ' ;', ��,: r',� ' '•�=:'�-'r',��;.,.., ., When: Fdday,'Oct 6, Right after' : ' Admission, football games, about 9:30 , "usingth p.m. to midnight ,°; : "Refreshmei Where: Shelby City Park gym'='j1'�` ' 4 lral cost Details: Music by DJ High Octane • , . �` "'�' :r (WillBoykins) '1;i; ;; .FIND•OUT: TVs to watch all the Football. Frlday `.;: HoiAr.toilb'e. Night highlights' a F� ''r Pompey Recognition of Game of with plaques fortopplayer from �• '�-•�. " .y each team','" Admission: $3, free with report:: 'card showingB'or.better. aver ` 4OWTHE`! ,'age" CI1�jrof.She WHAT PARENTS WANT TOV KNOW ' Wecom ll-known"location -'Shelby City Park gym llillillljll Join`,'Us'In��Th ' e ' _ � _ - �� ' • ``' • SQe Shy , � , V �Y State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director Ms. Lacy Ballard PPG Industries, Inc. 940 Washburn Switch Rd. Shelby, North Carolina 28150 Dear Ms. Ballard: �,�VA A/ •• ftL ® E ?.,,.. November 12, 1997 NOV 1997 Subject: Application Number ACB004685 ATC Request Acknowledgment PPG Ind./Shelby Plant Cleveland County The Division of Water Quality, NPDES Unit, hereby acknowledges receipt of your request for Authorization to Construct wastewater treatment facilities in accordance with NPDES Permit Number NC0004685 on October 21, 1997. This application has been assigned the number shown above. Please be aware that the Division's regional office, copied below, must provide recommendations from the Regional Supervisor prior to final action by the Division. Your request has been assigned to Steven D. Pellei for a detailed engineering review. Should any additional information be required you will be contacted in the near future. If you have any questions, please contact the review engineer at (919)733-5083, extension 516. PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING ANY INQUIRIES ABOUT THIS APPLICATION. cc: oM��oresilleRegiorialOffice NPDES Unit Permit File Sincerely, _�, David A. Goodrich Supervisor, NPDES Unit P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Ties, Inc. Wolff w� ? I Shelby, North Carolina 28150 USA ^ p 1997 Mr. David Goodrich State of North Carolina Department of Environment and Natural Resourceg!u!SVI71 Oil E` aF uYff Division of Water Quality 512 North Salisbury Street Raleigh, North Carolina 27611 Subject: Authorization to Construct PPG Industries NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Goodrich: By this letter PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) is formally requesting an Authorization to Construct (ATC) to be issued by the NCDENR - Division of Water Quality for the conversion of a full scale bentonite clay feed system from pilot operations to permanent operations. The pilot scale system, which has been in operation since April of 1997, is designed to un-bag, slurry, age, and feed a controlled amount of bentonite clay to the aeration basin of the existing on -site Wastewater Treatment Plant (WWTP). Please find enclosed the following: 1. A check in the amount of $200 for the Application Fee. 2. Three sets of Plans and Specifications of the existing full scale pilot system which is to be converted to permanent use. - Plans have bee sealed by a Professional Engineer licensed to practice in the State of North Carolina. - Plans have been marked "Final" and "Review Only, Not For Construction". - Manufacturers specifications on the bentonite clay and on the bentonite clay unbagging and feeding system have been included. 3. This is a chemical feed system that discharges approximately 1000 gallons/day of bentonite slurry to the WWTP aeration basin influent. Therefore, no design calculations or hydraulic profiles are included. Item 6 addresses pilot test data. 4. A flow schematic of the pilot bentonite clay feed system on 8 1/2 x 11" paper. 5. The system is an existing full scale pilot system that PPG -Shelby is converting to permanent use. Therefore, a Construction Sequence Plan for continuous operation is not required. 6. Pilot test data from March of 1997, when the bentonite clay feed system was put into use, to present is included. If you have any comments or questions on the attached information, please do not hesitate to call me at (704) 434-2261 Ext. 544. Sincerely, Lacy Ballard Staff Engineer Attachments cc: T. Keesling, AEI R. Gleason, Mooresville Regional Office - w/o attachments G. Bromby M. Reilly M. LeCroy i 1 PPG Industries, 940 Washburn Switch Road, Shelby, N.C. 28150tv:F'r? November 20, 1997 Lacy Ballard, R. E. M. Staff Engineer, Environmental Fiber Glass Products 704-434-2261, ex. 544 Iballard@ppg.com ✓ Mr. Rex Gleason, Regional Supervisor Water Quality Division N.C. DENR 919 North Main Street Mooresville, N.C. 28115 Re.: Effluent toxicity, PPG - Shelby Dear Mr. Gleason: I thought you might like to have a copy of the paper presented by Tim Keesling of Aware Environmental at the Nov. 18 meeting of the N.C. Water Environment Association in Winston-Salem. The paper is on the toxicity investigation process and the successful use of bentonite clay to resolve the toxicity issue at PPG- Shelby. We continue to fine tune the process and learn more about the use of clay in our, process. Sincerely, Lacy Ballard cc: M. LeCroy C. Bromby M. Reilly SUCCESSFUL REDUCTION OF EFFLUENT TOXICITY AT AN INDUSTRIAL WASTEWATER TREATMENT PLANT Timothy L. Keesling, P.E. - AWARE Environmental Inc. Lacy H. Ballard - PPG Industries, Inc Edward.C. Fiss, Jr, P.E. - AWARE Environmental Inc. Robert M. Stein, P.E. - AWARE Environmental Inc. ABSTRACT PPG Industries in Shelby, NC (PPG - Shelby) is required to comply with an effluent chronic bio-monitoring criteria of 33 % No -Observed -Effect -Concentration (NOEL). Based on the results of toxicity reduction investigations and evaluations, it was determined that high effluent total dissolved solids (TDS) and unidentified organic toxicant(s) were both contributing to effluent toxicity. Effluent toxicity was successfully removed through a phased approach involving step -wise toxicity evaluation, treatment process development, and process implementation for successive removal of multiple toxicants. The reduction of the high effluent TDS through optimization of the physical/chemical treatment process and the addition of bentonite clay to the biological system of the treatment plant has been shown to selectively remove the toxicant(s) and allow PPG - Shelby to meet their effluent NOEC criteria. The toxicity reduction effort included on -going monitoring of effluent and bench -scale treatability testing and full-scale pilot testing of both PAC and bentonite clay addition. After successful bench -scale testing using bentonite clay, a full-scale pilot system was implemented to feed bentonite clay at an operator controlled rate. The work resulted in the development of a treatment process which successfully and economically removes the toxic constituents from the plant effluent. In this treatment process, bentonite clay is fed into the mixed liquor of the secondary biological treatment system for removal of cationically charged toxicants. Bentonite clay usage has ranged from 250 to 1000 lbs/day during the full-scale pilot testing. The addition of bentonite clay increases overall sludge production slightly without adversely affecting sludge dewaterability. Two addition points for the bentonite clay were evaluated. Based on the full-scale Page 1 operating results, it appears that the addition of the clay prior to the aeration basin gave the best overall toxicity removal performance. BACKGROUND PPG Industries owns and operates a fiber glass manufacturing facility in Shelby, North Carolina (PPG - Shelby). The manufacturing facility discharges to an on -site wastewater treatment plant (WWTP) permitted to treat 1.3 MGD of combined sanitary and industrial wastewaters for direct discharge to a receiving stream. PPG - Shelby's discharge permit with the State of North Carolina calls for quarterly chronic toxicity testing of the treated effluent using ceriodaphnia dubia as the test organism. According to this permit, PPG - Shelby is required to produce an effluent that will pass the chronic toxicity test at a No -Observed -Effect -Concentration (NOEL) of 33 % . The wastewater treatment system at the PPG - Shelby facility is a primary physical/chemical system followed by an activated sludge biological system and tertiary filtration. The existing primary system utilizes lime and aluminum chloride addition for the removal of fluoride. A highly charged low molecular weight cationic coagulant and an anionic polymer are used for solids coagulation and turbidity removal. Following primary clarification, the wastewater enters the secondary biological treatment system which consists of a 0.4 million -gallon aeration basin with diffused aeration, a secondary flocculation tank/splitter box and three (3) secondary clarifiers. A shallow bed, gravity sand filter is the final treatment process. A process flow diagram showing the PPG - Shelby WWTP is presented in Figure 1. Prior to the effluent toxicity issues discussed in this paper, PPG - Shelby had an excellent history of compliance with all parameters of their discharge permit with the State of North Carolina. In April of 1995 consistently occurring problems with the effluent bio-monitoring criteria were experienced. These problems had not been seen previously and PPG - Shelby initiated action to address the situation immediately. Page 2 PPG Industries commissioned AWARE Environmental Inc (AEI) to perform a toxicity reduction evaluation (TRE) at the PPG - Shelby facility. The work began with an initial review of the historical WWTP operating data along with an inspection of the treatment plant and manufacturing facility to determine the best approach for meeting the effluent bio-monitoring criteria. The PPG - Shelby facility is a producer of a large variety of specialty fiber glass products for use in the marine, electrical, automotive and other manufacturing industries. The fiber glass is produced continuously with a variety of products being simultaneously manufactured at any one time. The combinations of products being manufactured, and subsequently the characteristics of the resulting wastewater, changes almost daily. AEI's review and inspection indicated that the effectiveness of a conventional THE would be limited due to the highly variable nature of the discharge characteristics associated with the frequent changes in the products being manufactured. A conventional THE involves intensive laboratory analysis of the WWTP effluent to identify known toxic components and the elimination of the identified toxicants through raw material substitutions and/or product modification. This typically involves repetitive and extensive laboratory analysis and subsequently significant expenditures for GC/MS and other sophisticated lab analysis. A drawback to the conventional THE approach of identifying and reducing toxicants at the source is that synergistic effects of multiple toxicants, toxic byproducts formed during physical/chemical and/or biological treatment, and the continuously changing concentrations of each compound make the individual toxicants extremely difficult to identify and understand. Because each analytical snapshot of the effluent may identify slightly different versions and concentrations of potentially toxic constituents, it is frequently very difficult to successfully identify and eliminate all of the toxicity causing compounds which may be intermittently present in a complex and variable wastewater. Based on discussions with manufacturing personnel and WWTP personnel, AEI and PPG - Shelby agreed that a step -wise process treatability approach would be the best Page 4 ICI AII.1� INI 1:(lAl,l li PI11 rul luw * IL uul ' I 111,1'111 A III ql HIM At? IAf(h ',I'I I111 It ( 11 (r Ilex null I r I I III IAI I:AIIIIII '' `III I II II IIII III 'Alln;l IAtlt. 1'IIMI' IIIt111ANKIxNI IIII 1111111 WI I WI II Ill III',I.IIPIfIJ (INNI•JII IININI I 1(� I III III NI NMI, un onulx SY'.II Af F'NIMANY CI Altll II N :.I IIIICI / PUMP I'111MAlt Y I;I AI411 II It YJ AV l / I ulru. IY'111Y1A1 I.Pixl W At ItA III AI I AlixllliW j II,IN A' I AI NA4'1fl AI IJA IU x! IIl 4 NA'.IN 1,I'1II II I< uux I IIIMI".11 it 11• 111111;1 IIII IIINC _.A IANK '.1 uUCl I11 IMI III II I< `� .� I ANN III nuxnn m ' �'� lelI IIII.NI N11 WI 11 SLCONl'lLHOAIIY CI.Altl`..... ' ,., (A'';/WA'i I'IJMI' I.1IMI' IKxJ a Illllll Nl I� -- 1�I Illtl;l ... - - til l:(INIIANY - _-- - - \ IANK :tANlt 111 IINI I _ ANK AAltll Il It LEGEND M I MIXER ) I PUMP I II,vIsnLln ll, I'I'1/ II. IU: •1/ ILIA. IhInvNNI 1 : \rn:nwudl:.\7r,'nnl'(14.Uwc --�..... I(A5 IJLIMP SYSIEM :A:CIINIIANY CLAKII IN zu 17 AY AINYIIIW r I I OCI:NI A 11L IANK/:lI'I 11 II It Illlx WASTEWATER TREATMENT PLANT PROCESS FLOW SCHEMATIC PPG INDUSTRIES SHELBY, NORTH CAROLINA SCALE NOT TO SCALE APPROVED BY : DRAWN BY: J.K.S. DATE NOVEMBER 1997 DESIGNED BY : REVISED PROJECT NUMBER AVJW- DRAWINO NO. N 2 5 9 - 01 8305-J MONROE RD. CNARLOnt, NC 28270 FIGURE 1 strategy for the PPG - Shelby facility. This approach would allow AEI and PPG - Shelby the opportunity to identify and develop a treatment process or processes which could be implemented at the PPG - Shelby WWTP to consistently remove toxic constituents and/or byproducts without knowing the exact identity of the material. TOXICITY REDUCTION EVALUATIONS AND EMPLEMENTATION Evaluation and reduction of effluent chronic toxicity at a facility having multiple toxicants and a complex and variable wastewater is difficult at best. Following a review of all available data, the process approach to a THE is to capture a sample of the treated effluent while the wastewater is exhibiting chronic toxicity, and then subjecting aliquots of that sample to bench -scale treatability tests followed by chronic toxicity tests to identify processes which are capable of reducing or eliminating the toxicity. By identifying processes that are capable of removing the toxicity, we are also able to identify the types of toxicants which are removed, although we may not know their exact chemical identities. The toxicity reduction investigation and evaluation at PPG - Shelby focused on both organic and inorganic toxicants. Phase I Testing The initial phase of the THE involved screening of effluent samples known to be toxic with a variety of treatment processes. Processes which were screened are shown in Table 1 along with potential target toxicants. EDTA Chelation Activated Carbon Adsorption Clay Adsorption C-18 Solid Phase Extraction Metals Polar and Non -Polar Organics Cationic Organics and Trace Metals Non -Polar Organics and Metals The first phase of toxicity testing indicated that none of these processes were successful in removal or significant reduction of the effluent toxicity. Page 5 E u H 0 t E v V Z 0 U 2500 oiiIoP 1500 1000 500 0 A-- Jul-92 PAPERDAT. XLS Figure 2 11/11/97 FIGURE 2 EFFLUENT CONDUCTIVITY DURING BIO-MONITORING • • PPG-SHELBY • Jan-93 Aug-93 Mar-94 Sep-94 Apr-95 Oct-95 May-96 TABLE 2 EFFLUENT CONDUCTIVITY DURING BIO-MONITORING PPG - SHELBY DATE CONDUCTIVITY (umhos/cm) PASS/FAIL (33 % NOEC) Feb-93 1025 PASS Apr-93 1350 PASS Jul-93 1100 PASS Oct-93 1500 PASS Jan-94 1915 PASS Apr-94 1600 FAII. May-94 1900 PASS Jul-94 1400 PASS Nov-94 1500 PASS Jan-95 1400 PASS Apr-95 2100 FAIL May-95 1900 FAIL Jun-95 1830 FAIL Jul-95 2030 FAII. Aug-95 2210 FAIL Sep-95 2010 PASS Oct-95 1846 . FAIL Nov-95 2100 FAIL Dec *95 2100 FA11L AVG 1706 MAX 2210 MIN 1025 CONDUCTIVITY PASSING RATE < 1500 515 = 100 % 1500 - 2000 4/8 = 50 % > 2000 1 /6 = 17 % 11/11/97 PAPERDAT.XLS Table 2 A further review of historical process data from the facility revealed that the initial appearance of persistent effluent toxicity had coincided with an overall increase in the effluent Total Dissolved Solids (TDS) concentration and that most failures of the toxicity tests had occurred during periods when effluent conductivities exceeded 1500 µmhos/cm (Table 2 & Figure 2). A further review of the treatment process indicated that the TDS and conductivity of the PPG - Shelby wastewater increased as the wastewater passed through the WWTP. The increase in TDS through the WWTP is a function of the type and amount of chemical fed for physical/chemical treatment of the wastewater. A series of bench -scale treatability tests were conducted for optimization of the primary physical/chemical process. The goals of these tests were to achieve adequate levels of fluoride and turbidity removal while minimizing increases in the salt content of the wastewater based on TDS and conductivity measurements. The bench -scale testing indicated that the desired level of fluoride and turbidity removal could be achieved at significantly reduced lime and aluminum chloride dosages. These reduced dosages of lime and aluminum chloride, in turn, resulted in lower effluent TDS and conductivity. The residual turbidity, caused by colloidal particles in the wastestream, was controlled through the addition of a highly charged, low molecular weight, cationic coagulant to the primary physical/chemical treatment system. Further bench -scale testing of influent wastewater samples collected during periods of effluent toxicity were conducted to determine the impact of reduced lime and aluminum chloride dosages and addition of the new coagulant on the effluent toxicity. The samples were collected, treated with "optimum" chemical dosages at controlled pH levels and then treated in batch, bench -scale, activated sludge units to mimic the full- scale process. The results confirmed that ceriodaphnia reproductions from effluent Page 6 treated in the bench -scale study were higher than those measured in matching full-scale WWTP effluent samples. Phase I Implementation The Phase I test results led AEI to recommend and PPG - Shelby to implement changes to the primary system to lower the effluent TDS concentrations. The changes included upgrading the lime feed system for a more consistent feed, relocating and reducing the feed of aluminum chloride and the addition of another coagulant to control primary effluent turbidity that was known to increase with lower dosages of aluminum chloride. The above changes were in place prior to the effluent bio-monitoring performed in January of 1996. Effluent samples were sent to two separate labs. The results of the January sampling are shown in Table 3 and Figure 3. These results indicated that the permitted effluent bio-monitoring criteria were being met. Effluent conductivity had been lowered from approximately 2000 µmhos/cm to approximately 1400 µmhos/cm. Effluent reproduction exceeded that of the control. Based on the results of the January 1996 sampling, effluent toxicity was thought to be under control. However, the effluent toxicity sample collected in February 1996 proved to be acutely toxic with 83 % mortality in the test organisms. The conductivity of this effluent sample was below 1000 µmhos/cm, indicating that high TDS was not a significant issue in this sample. PPG - Shelby continued to test for chronic toxicity on a monthly basis to determine if the existing wastewater treatment system could produce an effluent that would pass the permitted 33 % NOEC on a consistent basis. Overall reproductions, on average, did increase when the effluent TDS concentration was brought under control; however, the occurrence of high mortality in the test organisms also increased. Page 9 FIGURE 3 BIO-MONITORING RESULTS NOVEMBER 1995 - MARCH 1996 PPG-SHELBY 140% 120% 100% Z O 80% U D 0 O W. IL UJ 60% 40% 20% 0% Nov-95 Nov-95 Dec-95 Dec-95 Jan-96 Jan-96 Feb-96 Mar-96 PAPERDATALS Figure 3 11/11/97 TABLE 3 BIO-MONITORING RESULTS NOVEMBER 1995-MARCH 1996 PPG-SHELBY DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/FAIL 11/8/95 ROUTINE EFFLUENT MONITORING (1) 20.2 2.8 14% 25% 2000 FAIL 11/8/95 ROUTINE EFFLUENT MONITORING (2) 25.2 13.9 55% 0% 2100 FAIL 12/6/95 ROUTINE EFFLUENT MONITORING (1) 20.4 0.0 0% 0% 1900 FAIL 12/6/95 ROUTINE EFFLUENT MONITORING (2) 24.7 7.2 29% 0% 2100 FAIL 1/24/96 ROUTINE EFFLUENT MONITORING (1) 20.9 27.3 130% 8% 1300 PASS 1/24/96 ROUTINE EFFLUENT MONITORING (2) 24.5 23.2 94% 0% 1501 PASS 2121/96 ROUTINE EFFLUENT MONITORING (1) 24.8 0.2 1% 83% 970 FAIL 3/25/96 1 ROUTINE EFFLUENT MONITORING (1) 24.8 18.3 73% 8% 1200 PAIL PAPERDAT.XLS Table 3 11/11/97 Phase H Testing The Phase I full-scale results led AEI and PPG - Shelby to consider two possibilities for further investigation: • The treatment processes that had caused the high effluent TDS concentrations (high lime and aluminum chloride dosages), while causing problems in the chronic toxicity test, may have been providing treatment in some form that controlled the discharge of acutely toxic materials. • The chronic toxicity caused by high effluent TDS concentrations had been "masking", to some degree, other toxicant(s) that the biological system was unable to remove. It was surmised that some of the original pilot -scale testing for organic toxicant(s) may have been skewed by the high TDS concentrations. To investigate, AEI repeated car tain bench scale testing for the removal of organic toxicant(s) while maintaining close control of final effluent TDS. Retesting of activated carbon adsorption was performed. Results of the bench -scale testing indicated that high dosages of Powdered Activated Carbon (PAC) would provide excellent toxicity removal, if the effluent TDS was kept under control (Table 4 & Figure 4). Phase II Implementation PPG - Shelby initiated a system for the addition of PAC to the mixed liquor of the WWTP. The overall plan to use PAC, on a continuous basis, hinged on the PAC dosage required to control effluent toxicity. The high dosage of PAC that worked in the pilot study would be extremely costly for use in the full-scale system. However, feeding the PAC to the activated sludge system instead of directly to the effluent would allow the PAC to be recycled and concentrated in the aeration basin mixed liquor by the return activated sludge system. This would also provide some opportunity for bio- Page 12 FIGURE 4 BENCH -SCALE PAC TREATABILITY TESTING PPG-SHELBY 120% 100% 80% Z O F- U D 0 60% w IL w w 0 40% 20% 0% 0 500 mg/L 1500 mg/L 2500 mg/L PAC Addition PAPERDAT. XLS Figure 4 11/11/97 TABLE 4 BENCH -SCALE PAC TREATABILITY TESTING PPG - SHTLBY CONTROL SAMPLE % OF SAMPLE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL ROUTINE EFFLUENT MONITORING 27.4 4.8 17% 75% 1045/1073 FAIL BENCH SCALE EFFLUENT 500 m /L PAC 27.4 26.6 97% 0% 1094/1042 PASS BENCH SCALE EFFLUENT 1500 mg/L PAC 27.4 26.2 96% 0% 1083/1115 PASS BENCH SCALE EFFLUENT 2500 mg/L PAC 1 27.4 1 25.2 92% 0% 1137/1125 PASS PAPERDAT.XLS Table 4 11/11/97 100% 90% 80% 70% p 60% F- U D 0 50% w IL w a 40% 30% 20% 10% 0% Aug-96 PAPERDATALS Figure 5 11/11/97 FIGURE 5 BIO-MONITORING RESULTS AUGUST 1996 - OCTOBER 1996 PPG -SHE LBY Aug-96 Sep-96 Sep-96 Oct-96 Oct-96 TABLE 5 BIO-MONITORING RESULTS AUGUST 1996-OCTOBER 1996 PPG-SHELBY DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/PAIL 8/14/96 ROUTINE EFFLUENT MONITORING (2) 26.8 20.6 77% 0% 954/1094 FAIL 8/28/96 ROUTINE EFFLUENT MONITORING (2) 25.7 17.8 69% 0% 1315/1281 FAIL 9/9/96 ROUTINE EFFLUENT MONITORING 23.8 20.4 86% 0% 1204/1338 PASS 9/23/96 ROUTINE EFFLUENT MONITORING 23.6 20.5 87% 0% 1102/1268 PASS 10/7/96 ROUTINE EFFLUENT MONITORING (2) 26.4 14.8 56% 0% 1253/1373 FAIL 10/28/96 ROUTINE EFFLUENT MONITORING J(2) 25.7 5.9 23% 17% 1308/1379 FAIL PAPERDAT.XLS Table 5 11/11/97 regeneration of recycled PAC within the activated sludge treatment process. The PAC supplier provided a rental unit to feed the PAC to the aeration basin. The feed system consisted of a hoist to lift the 900 lb bulk bags of PAC, a screw feeder and an eductor system to deliver a controlled amount of PAC to the aeration basin influent. PAC was fed to the aeration basin by adding 18001bs of PAC as an initial dose and then varying the maintenance dosage from 100 lbs/day up to 225 lbs/day. Original toxicity results, performed immediately after the addition of the initial dose of PAC, showed good reproduction (> 85 % through the month of September 1996 - Table 5 & Figure 5). Overall, results of the full-scale PAC study were mixed. Sample reproduction ranged from 23 % to 111 % of that of the control during the test period. The best results appeared to occur when the PAC was first introduced into the system and when large amounts of PAC were added to the system. The PAC did appear to control the acutely toxic materials seen in bio-monitoring following the reduction of lime and aluminum chloride feed rates in the primary system to control effluent TDS concentrations. Phase III Testing With the mixed results of the full-scale PAC testing, AEI and PPG - Shelby performed additional bench -scale testing on samples of chronically toxic effluent in an effort to find a process variation or treatment chemical that would more consistently control effluent chronic toxicity. Bench scale testing with bentonite clay had been performed previously in the Phase I tests when high effluent TDS was a problem. It was decided to retest the effluent following treatment with bentonite clay addition. Page 15 TABLE 6 BENCH -SCALE BENTONITE CLAY TREATABILITY TESTING PPG-SHELBY CONTROL SAMPLE % OF SAMPLE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL I MORTALITY I CONDUCTIVITY PASS/FAIL EFFLUENT MONITORING 27.3 9.6 35% OBE 1016/986 FAIL BENCH -SCALE EFFLUENT 50 m T/I Bentonite added + filtration 27.3 18.9 69% 0% 1029/952 FAIL BENCH -SCALE EFFLUENT 250 mg/1 Bentonite added + filtration 27.3 23.3 85% 1 0` 1040/1023 1 PASS BENCH -SCALE EFFLUENT 500 in/1 Bcntonite added + filtration 27.3 27.3 10096 0�1t, 1047/IOSI PASS PAPERDAT.XLS Table 6 11/11/97 FIGURE 6 BENCH -SCALE BENTONITE CLAY TREATABILITY TESTING PPG-SHELBY 120% 100% 80% z O U D a 60% w a w w 0 40% 20% 0% 0 50 mg/L 250 mg/L 500 mg/L Bentonite Clay Addition PAPERDAT.XLS Figure 6 11/11/97 (SCREW FEEDER / ELEVATOR) m ^ AND MIXER"^ FEED TANK AND (1,000 GALLONS) MIXER (1,000 GALLONS) November 11, 1997 11:14:22 a.m. Drawing: C:\DRAWINGS\25901PO3.DWG 6Y FED TO 1TTER BOX PRIOR AERATION BASIN IIONAL CLAY FEED TO CCULANON IK/SPUTTER BOX EA AERATION BASIN CLAY FEED SYSTEM SCHEMATIC PPG INDUSTRIES SHELBY, NORTH CAROLINA GALE NOT TO SCALE APPROVED BY : DRAWN UY: J.K.S. ATE NOVEMBER 1997 DESIGNED BY : REVISED ROJECT WING NO. N259 NUMBER01 9305—J M0� RD. CNARLOnF, NC 28270 DRAFIGURE 7 FIGURE 8 FULL RANGE BIO-MONITORING RESULTS MARCH - APRIL 1997 PPG-SHELBY 120% 100 % 80% z 0 H U 0 60% x 40 % 20% 0% Mar-97 . Apr-97 PAPERDAT. XLS Figure 8 11/11/97 Bentonite clay addition was tested on three aliquots of a toxic effluent sample at dosages ranging from 50 to 500 mg/L. The bentonite was added to the effluent samples, mixed and allowed to settle. The supernatant was then decanted and tested for chronic toxicity. Results of these tests are presented in Table 6 and in Figure 6. As shown in Figure 6, the bench -scale testing with bentonite clay showed excellent results in terms of toxicity removal. Further bench -scale testing was performed on another effluent sample with bentonite clay in order to confirm the original results. After confirmation of the results, plans were made to implement a full-scale pilot test by adding bentonite clay to the secondary treatment system. The bentonite clay supplier provided a rental unit to unload and feed the bentonite clay to a mixing/aging tank (Figure 7). The feed system consists of a base to support the 2000 lb bulk bags of bentonite clay, a screw feeder and an elevator to rapidly deliver a controlled amount of bentonite clay to the mixing/aging tank. From the mixing/aging tank the aged bentonite slurry is transferred to a feed tank. From this point the clay slurry is fed with a diaphragm metering pump to the aeration basin influent or effluent by means of a rubber hose. Phase III Implementation PPG - Shelby implemented a full-scale bentonite clay addition system at the end of March 1997. An initial dose of 1000 lbs of bentonite clay was added to the aeration basin and a maintenance dose of 250 lbs/day was added to the secondary flocculation tank (Figure 1). Results of the first Full Range Chronic Toxicity test did not show any marked improvements in terms of toxicity removal with the bentonite clay in the system (Figure 8). The bentonite clay dosage was varied in an effort to meet the required effluent bio-monitoring criteria (33 % NOEC). By the beginning of May 1997, effluent COD results indicated that the clay had established itself in the system and was removing organics (COD) to a level not seen previously. Effluent COD's at PPG -Shelby historically ranged between 250 and 300 mg/L. The effluent COD Page 18 TABLE 7 FULL RANGE BIO-MONITORING MARCH - SEPTEMBER 1997 PPG - SHELBY DATE Effluent Dilution % OF CONTROL REPRODUCTION 8.3% 16.5% 33% 49.5% 66% March 1997 102% 94% 53% 6% 0% April 1997 97% 84% 69% 35% 14% July 1997 110% 107% 105% 100% 69% August 1997 99% 94% 96% 90% 79% Se tember 1997 118 % 106 % 100 % 105 % 49 % PAPERDAT. XLS Table 7 11/11/97 350 411 250 J OI E c 200 0 4� c a� u 0 150 U m 100 50 FIGURE 9 EFFLUENT COD AT VARIOUS CLAY CONCENTRATIONS PPG - SHE, LBY —A Weekly Avg Eff COD (mg/L) Clay Concentration (mg/L) 250 Ib/d 750 lb/d Ib/d 0 _i i i i i 1 i r Jun-96 Aug-96 Sep-96 Nov-96 Dec-96 Feb-97 Apr-97 May-97 PAPERDAT.XLS Figure 9 11/11/97 750 Ib/d 500 lb/d 000 Ib/d Jul-97 Sep-97 4000 3500 3000 rn E c 0 w 2500 e a� U c 0 c) 2000 v E 1500 V �a 1000 2 V 500 FIGURE 10 FULL RANGE BIO-MONITORING RESULTS MARCH 1997 - SEPTEMBER 1997 PPG-SHELBY ` 120% 100% 80% Z O l- U D 0 60% w a w w 0 40% 20% 0% Mar-97 Apr-97 Jul-97 Aug-97 . Sep-97 PAPERDAT. XLS Figure 10 11/11/97 dropped to 200 mg/L with bentonite clay dosages of 500 lbs/day (Figure 9). The results of the toxicity testing during May 1997 were borderline between Pass and Fail. It was thought that the highly cationically charged bentonite may have been reacting with the anionic polymer fed in the secondary floc tank and loosing some of its reactive properties. At this point the bentonite clay feed was moved from the secondary floc tank to the influent of the aeration basin. The bentonite clay dosage was varied from 250 to 1000 lbs/day from May to August of 1997 with varying results in terms of effluent COD (Figure 9). Since late May of 1997, PPG -Shelby has passed all chronic toxicity tests at it's permitted NOEC of 33%. Additional Full Range Chronic Toxicity tests have also been conducted in order to determine the optimal dosage of bentonite clay feed. The results of all Full Range Chronic Toxicity tests performed, since the addition of bentonite clay, are shown in Table 7 and Figure 10. PROCESS OPTS IIZATION Once a treatment system was in place and providing excellent toxicity removal, AEI and PPG - Shelby made efforts to optimize the treatment process. The cost of PAC was approximately $0.75/lb versus $0.25/lb for bentonite clay. Considering the cost difference between the two (2) treatment chemicals, efforts to reduce the amount of PAC fed to the system were implemented. The initial trials performed with reduced PAC feed showed no change (increase) in effluent toxicity. The PAC feed that was started in September of 1996 was terminated in June of 1997 with no observed effect (increase) on effluent toxicity. Bentonite clay feed to the activated sludge system, began in late March of 1997, and is ongoing. The feed of bentonite clay has ranged from 250 to 1000 lbs/day with approximately 500 lbs/day being fed to the system at present. This correlates to a treatment chemical cost, for bentonite clay alone, of Page 23 • f1 approximately $0.125 per 1000 gallons of treated effluent. Ongoing efforts are being made to reduce the amount of bentonite clay fed to the wastewater treatment system. DISCUSSION Bentonite clay is a volcanic ash consisting primarily of the clay mineral montmorillonite. The bentonite clay used at PPG - Shelby is a sodium based bentonite. Bentonite clays are typically used in potable water applications for the removal of very fine particulate matter and trace metals. Bentonite clays are strongly cationic in nature and exhibit excellent ion -exchange capabilities. These ion -exchange characteristics of the clay particles are what is believed to be the toxicant removal technique. The displacement of inorganic cations, such as sodium, by large organic cations has been thoroughly researched. It has also been shown that the organics with the highest affinity for the clay particles include quaternary amines which are typically present in cationic surfactants. CONCLUSIONS Based on the results of the phased toxicity reduction and process evaluation, it was determined that high effluent TDS and unidentified organic toxicants were both contributing to the chronic toxicity level of the WWTP effluent. Optimization of existing and new primary treatment chemical usage and the addition of bentonite clay to the activated sludge process have successfully reduced the chronic toxicity of the PPG - Shelby effluent and the permitted 33 % NOEC standard is consistently being achieved. The resulting treatment process has proven to be both reliable and economical to operate. The success of this program demonstrates the viability of the process based treatability approach to provide cost-effective, successful toxicity reduction. 23235 Page 27 • 4 -C.'. D-U T. CA PPG Industries, Inc. �.P�`! �r�IIGmL-_,5 _, g Works No. 52 940 Washburn Switch Road Shelby, North Carolina 281 1AiU'raL r:Us October 7, 1997 OCT 1 Q 1997 j !3V1 Mr. D. Rex Gleason, P.E. PIvVKSVtlE North Carolina Department of Environment and Natural Resources Division of Water Quality 919 North Main Street Mooresville, NC 28115 Subject: Quarterly Progress Report Special Order by Consent EMC WQ No. 96-24 PPG Industries NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Gleason: PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by Consent (SOC) with the State of North Carolina on March 11, 1997. This report is to satisfy the requirements of Item 2.d. of the SOC which states that PPG -Shelby shall submit a Quarterly Progress Report by the 15th day of October 1997. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1 & 2) and submitted Plans and Specifications for upgrading the WWTP to your office prior to the SOC deadline of September 30, 1997. We are in the process of also submitting the required information to the State - Division of Water Quality Unit in Raleigh in order to obtain an Authorization to Construct (ATC). Due to the fact that we are converting our pilot unit to permanent use, we feel that we have complied with SOC Activities 2.c.3 & 4 with this latest submittal and the only remaining activity is to achieve compliance with final effluent limitations by June 30, 1998 (Activity 2.c.5). Since the last Quarterly Progress Report, presented to the State in July of 1997, PPG - Shelby has continued full scale testing of feeding bentonite clay to the WWTP without the use of Powdered Activated Carbon (PAC). -2- Full range monitoring, as required by the SOC, was performed during the week of July 14 - 18 and indicated a LOEC of 66%, a NOEC of 49.5 % and a Chronic Value of 57.1 %. A second full range monitoring was performed for system analysis during the week of August 11 - 15. The full range monitoring performed in August indicated a LOEC of 66 %, a NOEC of 49.5 % and a Chronic Value of 57.1 %. A third full range monitoring was performed for system analysis during the week of September 15 - 19 resulting in a LOEC of 66 %, a NOEC of 49.5 % and a Chronic Value of 57.1 %. Results of these tests are presented in Table 1. These results indicate excellent toxicity removal at effluent dilutions in excess of our permit requirements. Single concentration toxicity tests at PPG-Shelby's permitted NOEC (33 %) were also performed during the weeks of July 28 - August 1 and August 25 - 29. The results of these two (2) single concentration tests indicated reproductions of 99 % and 119 % respectively (Table 2). PPG -Shelby has not failed an effluent toxicity test, at our permitted dilution, since May of 1997. Bentonite clay was first introduced to the treatment system on March 25, 1997 with 1000 lbs. being manually added directly to the aeration basin. On March 26, a program of adding 250 lbs/day of bentonite clay to the system on a 24 hour basis via a clay slurry system was started. Bentonite clay dosages have been increased as necessary to control effluent toxicity and decreased in order to determine the most effective dosage that will control effluent toxicity and produce minimal additional sludge. We are currently feeding 500 lbs/day to the aeration basin and have demonstrated that this dosage is sufficient to control effluent toxicity in our discharge. We plan to lower this feed rate further in the near future in an effort to reduce excess sludge production. Full Range Monitoring will be performed in October to satisfy the fourth quarter monitoring requirements put forth in the SOC. We also continue to monitor fluoride on a weekly basis as required by the SOC. PPG feels that we have found and implemented a system to produce a discharge that will consistently meet the chronic effluent toxicity limits at our permitted dilution. At this time, we are planning to sample and test our discharge for chronic toxicity at a frequency of approximately one (1) time per month. This frequency, in excess of the SOC requirements, will allow PPG to optimize the clay feed system and feed requirements. We will evaluate the need for increased testing frequency based on future toxicity test results. -3- We will continue to keep you informed of our progress and the status of further SOC task deadlines and will let you know when we receive an ATC for the clay feed system. In the meantime, if you have any questions, please do not hesitate to call me at (704) 434-2261 Ext. 544. Sincerely, Lacy Ballard Staff Engineer Attachments cc: T. Keesling, AEI A. Astroth M. LeCroy J. Buchanan B. Blackwell C. Bromby, Hunton and Williams M. Reilly ppg-socl.doc TABLE 1 PPG Shelby - Full Range Effluent Toxicity Monitoring July 14 - July 18 TEST REPRODUCTION % REDUCTION CONTROL 21.2 NA 8.25 % 23.4 -10.4 % 16.5 % 22.7 -7.1 % 33 % 22.2 -4.7 % 49.5 % 21.2 0.0 % 66% 14.7 30.7 % PPG Shelby - Full Range Effluent Toxicity Monitoring August 11 - August 15 TEST REPRODUCTION % REDUCTION CONTROL 23.0 NA 8.25 % 22.8 0.9 % 16.5 % 21.7 5.7 % 33% 22.0 4.3% 49.5 % 20.6 10.4 % 66% 18.1 21.3% PPG Shelby - Full Range Effluent Toxicity Monitoring September 15 - September 19 TEST REPRODUCTION % REDUCTION CONTROL 21.4 NA 8.25 % 23.3 -8.9 % 16.5 % 22.6 -5.6 % 33 % 21.3 0.5 % 49.5 % 22.5 5.1 % 66% 10.5 50.9% TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 38 1/14/97 ROUTINE EFFLUENT MONITORING (2) 27.3 9.6 35% 0% 1016/986 FAIL 50 mg/l Bentonite added + filtration 38-A 1/14/97 EFFLUENT MONITORING (2) 27.3 18.9 69% 0% 1029/952 FAIL 250 mg/1 Bentonite added + filtration 38-B 1/14/97 EFFLUENT MONITORING (2) 27.3 23.3 85% 0% 1040/1023 PASS 500 mg/1 Bentonite added + filtration 38-C 1/14/97 EFFLUENT MONITORING (2) 27.3 27.3 100% 0% 1047/1051 PASS 39 1 /29/97 EFFLUENT MONITORING (2) 27.0 12.8 47 % 0% 874/958 FAIL filtered with TSS filter 39-A 1/29/97 EFFLUENT MONITORING (2) 27.0 22.5 83% 0% 867/951 PASS 40 2/12/97 EFFLUENT MONITORING (2) 22.3 8.4 38% 0% 1002/1162 FAIL 41 2/26/97 EFFLUENT MONITORING (2) 25.2 22.3 88 % 0% 845/966 PASS 42 3/12/97 EFFLUENT MONITORING (2) 24.2 8.4 35% 0% 1320/1291 FAIL 8.25 % 43 -A 3/26/97 EFFLUENT MONITORING (2) 23.2 23.7 102% 0% 1557/1340 PASS 16.50 % 43-B 3/26/97 EFFLUENT MONITORING (2) 23.2 21.7 94% 0% 1557/1340 PASS 33 % 43-C 3/26/97 EFFLUENT MONITORING (2) 23.2 12.2 53% 10% 1557/1340 FAIL 49.50 % 43-D 3/26/97 EFFLUENT MONITORING (2) 23.2 1.5 6% 20% 1557/1340 FAIL 66 % 43-E 3/26/97 EFFLUENT MONITORING (2) 23.2 0.0 0% 40% 1557/1340 FAIL 44 4/2/97 EFFLUENT MONITORING (2) 24.2 11.4 47% 0% 1593/1518 FAIL filtered with TSS filter 44-A 4/2/97 EFFLUENT MONITORING (2) 24.2 11.6 48% 0% 1588/1521 FAIL untreated effluent 44-B 4/ 13/97 EFFLUENT MONITORING (2) 26.2 13.8 53 % 0% 1610/ 1528 FAIL 250 mg/l Bentonite added + filtration 44-C 4/ 13/97 EFFLUENT MONITORING (2) 26.2 15.6 60 % 0% 1655/1590 FAIL 1000 mg/l Bentonite added + filtration 44-D 1 4/13/97 EFFLUENT MONITORING (2) 26.2 23.2 89% 0% 1795/1738 PASS 10/2/97 Toxtest2 EFFLUENT SAMPLING 1 of 3 TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 SAMPLE DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/FAIL 45 4/9/97 EFFLUENT MONITORING (2) 24.6 18.8 76% 0% 1067/1356 FAIL 45-A 4/9/97 filtered with TSS filter EFFLUENT MONITORING (2) 24.6 22.2 90 % 0% 1060/ 1347 PASS 46 4/16/97 EFFLUENT MONITORING (2) 23.2 6.8 29% 0% 1395/1215 FAIL 46-A 4/16/97 filtered with TSS filter EFFLUENT MONITORING (2) 23.2 7.8 34% 0% 1404/1210 FAIL 47-A 4/23/97 8.25 % EFFLUENT MONITORING (2) 22.8 22.1 97% 0% 1133/1420 PASS 47-B 4/23/97 16.50 % EFFLUENT MONITORING (2) 22.8 19.1 84% 0% 1133/1420 PASS 47-C 4/23/97 33 % EFFLUENT MONITORING (2) 22.8 15.7 69% 0% 1133/1420 FAIL 47-D 4/23/97 49.50 % EFFLUENT MONITORING (2) 22.8 8.0 35% 0% 1133/1420 FAIL 47-E 4/23/97 66 % EFFLUENT MONITORING (2) 22.8 3.3 14% 10% 1133/1420 FAIL 48 4/30/97 EFFLUENT MONITORING (2) 20.4 19.2 94 % 0% 1298/ 1159 PASS 49 5/7/97 EFFLUENT MONITORING (2) 23.0 20.2 88% 0% 1015/1028 PASS 50 5/14/97 EFFLUENT MONITORING (2) 26.3 19.1 73% 0% 1109/1098 FAIL 51 5/21/97 EFFLUENT MONITORING (2) 21.6 17.6 81 % 0% 1137/932 PASS 52 5/28/97 EFFLUENT MONITORING (2) 23.0 22.7 99 % 0% 857/945 PASS 53 6/4/97 EFFLUENT MONITORING (2) 24.0 21.2 88% 0% 952/1181 PASS 54 6/11/97 EFFLUENT MONITORING (2) 16.0 15.7 98% 0% 1000/1155 PASS 55 6/25/97 EFFLUENT MONITORING (2) 20.4 22.7 111 % 0% 1072/1010 PASS 56 7/2/97 EFFLUENT MONITORING (2) 23.8 21.7 91 % 0% PASS 57-A 1 7/23/97 8.25 % EFFLUENT MONITORING (2) 21.2 23.4 110% 0% 1144/1086 PASS 10/2/97 Toxtest2 EFFLUENT SAMPLING 2 of 3 TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE I REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 16.50 % 57-B 7/23/97 EFFLUENT MONITORING (2) 21.2 22.7 107% 0% 1144/1086 PASS 33 % 57-E 7/23/97 EFFLUENT MONITORING (2) 21.2 22.2 105% 0% 1144/1086 PASS 49.50 % 57-F 7/23/97 EFFLUENT MONITORING (2) 21.2 21.2 100% 0% 1144/1086 PASS 66 % 57-G 7/23/97 EFFLUENT MONITORING (2) 21.2 14.7 69% 0% 1144/1086 FAIL 58 7/31/97 EFFLUENT MONITORING (2) 25.3 28.2 111% 0% 1153/957 PASS 8.25 % 59-A 8/11/97 EFFLUENT MONITORING (2) 23.0 22.8 99% 0% 1128/1164 PASS 16.50 % 59-B 8/11/97 EFFLUENT MONITORING (2) 23.0 21.7 94% 0% 1128/1164 PASS 33 % 59-E 8/11/97 EFFLUENT MONITORING (2) 23.0 22.0 96% 0% 1128/1164 PASS 49.50 % 59-F 8/11/97 EFFLUENT MONITORING (2) 23.0 20.6 90% 0% 1128/1164 PASS 66 % 59-G 8/11/97 EFFLUENT MONITORING (2) 23.0 18.1 79% 0% 1128/1164 FAIL 60 8/25/97 EFFLUENT MONITORING (2) 17.9 21.3 119 % 0% 1200/ 1355 PASS 8.25 % 61-A 9/15/97 EFFLUENT MONITORING (2) 21.4 25.3 118% 0% 1258/1557 PASS 16.50 % 61-B 9/15/97 EFFLUENT MONITORING (2) 21.4 22.6 106% 0% 1258/1557 PASS 33 % 61-E 9/15/97 EFFLUENT MONITORING (2) 21.4 21.3 100% 0% 1258/1557 PASS 49.50 % 61-F 9/15/97 EFFLUENT MONITORING (2) 21.4 22.5 105% 0% 1258/1557 PASS L61-G 66 % 9/15/97 EFFLUENT MONITORING (2) 21.4 10.5 49% 40% 1258/1557 FAIL NOTES (1) SAMPLE SENT TO PACE ANALYTICAL (2) SAMPLE SENT TO WATER TECHNOLOGY AND CONTROLS * FIRST SAMPLE COLLECTED AFTER ADDITION OF PAC TO AERATION BASIN. 10/2/97 Toxtest2 EFFLUENT SAMPLING 3 of 3 Facility Effluent Aquatic Toxicity Report Form/Phase 11 Chronic Cerfodaphnia ADG NPDESk NC 013OMbSS Pipe#�1 County ift e-VP lc�rt Performing T � � -Aa,, d 'Con -+a 15 amrw s X of Signature &Lab Supervisor Sample Information Collection Start Date Grab Composite (Duration) Hardness(mg/1) Spec.Cond.0 mhos/cm) Chlorine(mg/l) Sample temp. at receipt Sample 1 Sample 2 Control 7 /Iy(g7 7 //71R7 Z� 7(W Zq / ,96 (gZ 4o . ( -<0 , 1 / . [F °c Z . `O Control Start Date I End Date IS= Tine End Tune . A(1/9 7AV-37 /3 : Co 1/3 :0c Treatment pH Initial pH Final D.O. Initial D.O. Final emp. Initial emp. Final Start Renews Ranew2l Stan lRenewfenew2iI 496 6,e 66 Control Control Control it 7 -& '76 6 903 793 $D/ 7.97 'T. D 6 Z91f V6 ?g 9 79 D '7.9 6 . ?Dq ITA9 gb$ 7 j 19 '�, r 0 -C (c -j 7 TZ3 T,31 Zp e!'' zy,9 2<(•7 Zqf 6 Zqf S i Z.�.( Z`($ 2q.7 VS 2-q7 ZY.7 Organism# 1 9 2 d &Z a 7 a a 1n 11 #Young Z3 /9 Z2 7-3 23 Z./ ? 21, Zo a/ 2/ Adult (L)ive (D)ead L L �- L L. �- L L- L L Effluent% I# Young Adult • (L) ive (D)ead Effluent9'o Zq ZS Z3 Z(o /4Z! Z.L( Z6, 26 L k, c,-1 c_ L-1 r: (- I L I L- t. 1 9 a d r, a 7 a a 1n Chronic Test Results 19 m— Final Control Mortality %1 D % Control 3rd Brood 110 O Control Repro CV �, p 48 Hour Mortality Control IWC "n of /D d of /0 1"' 1 Slonifimnt?n N % Final Mortality Sigpirant or ►mn E::E ?2.7 a► ' . Repro. LOEC= G %; NOEC=�% x Red Method: n/IR Normal Distrib? o Method:', Statistic: .'304 2- Critical: Effluent% # Young Z ! ZY 20 1 g ZS 22- 23 2$ 14 12:7 2Z 33 Adult (L) ive (D) ead L L L L (_ L L i- FWd NIA Equal Variances? Method: %Y Statistic:9.7 5'9 Critical: !S. L' Analis (if applic ble)* Method: 1 2 3 4 5 6 7 S 9 10 Me- a/ n ti ENluen&o # Young Z� /1-5Z3 2S /9 Z.'L ZZ. Z.Z H Z2 Z• Adult (L) ive (D)ead L L. L L L L �- L-: �-- L Red NlA a — 1 ! .S -7S 4 5 6 7 8 9 10 Effluent'/o # Young�5 S IS 17 ( (Z 11-7 i Z (3 P9 IN Oveimll t 7 Result P AIL': DI :. // Adult Rea ;:Test LO �0& %; NOEC=. 67% L% (L)ive (D)ead �- �- �- L- L- L- L- L Chronic Value= I' % 'Should use highest test concentration or MAIL ATT: Environmental Sciences highest concentration w th D.O. >5.0 mg l Div. of Environmental Management t% Redmbw tram coma R pmdLm n Mean, TO: N.C. Department of EHNR 4401 Reedv Creek Rd. ' luent Toxicity Report Form - Chronic pass/Fail and Acute LC58 Date: 08/08/97 acility: PPG INDUSTRIES (SHELBY) NPDES#: MC0004685 Pipe#: 901 County: CLEVELAND Lab tort' Pe f ofm' g es : WATER TECH AND CONTROLS INC Comments: PPG #3 killed in X ignat e '01 UperatoriAn Resp9helbie'Charge transfer 8/1/97 Signature of Laboratoryi-Supervisor } PASSED: 0.69% Reduction I Work Order: 07309734 Environmental Sciences Branch HAIL ORIGINAL TO: Div. of Environmental Management N. C. Dept. of EHNR 4401 Reedy Creek Road 1lnrfh Carolina Ceriedanhnia Raleigh, North Carolina 27607-6445 Chronic Pass/Fail Reproduction Toxicity Test CONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 # Young Produced 25125125124126126 25128125126126123 Adult (L)ive (D)ead IL IL IL IL IL IL IL IL IL IL IL' IL' Effluent %: 33% FREATMEHT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV 4. 859% # Young Produced 25 25 0 26 26 25 21 27 28 22 26 26 % control orgs producing 3rd brood Adult (L)ive (D)ead L L* L IL IL L L L L L L 100% Chronic Test Results Calculated t = 0.218 Tabular t = 2.518 % Reduction = 0.60 % Mortality Avg. Reprod. 0.00 25.33 Control Control 0.00 25.18 Treatment 2 Treatment 2 PASS FAIL :K] Check qOne let sample let sample 2nd.sample Complete This For Either Test PH Test Start Date: 07/30/97 Control 7.98P7.98 7.97 8.03 8.01 8.00 Collection (Start) Date Sample 1: 07/28/97 Sample 2: 07/31/97 Treatment 2 7.94 7.92 8.05 8.04 7.99 Sample Type/Duration 2nd let P/F Grab Comp. Duration D t e t e t e I I S S a n a n a n Sample 1 X 24 hrs L A A r d r d r d U M M t t t Sample 2 X 24 bra T P P let sample 1st sample 2nd sample D. 0. Hardness (mg/1) 46 € Control 8. 07 8. 30 8.04 M8.068.38 ••Spec. Cond.(umhos) 188 1153 977 Treatment 2 7.88 8.22 7. Chlorine (mg/1) Q. 1 Q. 1 LC50/Acute Toxicity Test Sample temp. at receipt(°C) 2.3 2.0 _....... (Mortality expressed as %, combining replicates) MMMMMMMMMMI Note: Please Concentration Complete This Mortality Section Also start/end start/end LC50 = % Method of Determination 95% Confidence -Limits Moving Average Probit _ % -- % Spearman Karber — Other Control High Cane_ pH I z '•.:Ear t-'.?d .. - 1! Effluent Aquatic Toxicity Report Form/Phase 11 Chronic Ceriodaphnia Facility 5AX 16 PDES#: NCOoo S Pipe# I County C e 14,n ILIratory Perf rming T xj4�170- 40 is Comrnerds t c X x Signatu of Y,: Signature o Supervisor Samole Information Sample 1 Sample 2 Control IQA Start Date End Data start Time End rune of • g�/3 $ �L T7 (F ; 5 p 09 : a0i Collection Start Date $jt,,197 $(/f(�i7 start Renewt Renewt start Renewt enew2 Grab Treatment !oh �olo� !c!o Control Control Control Composite Zvi pH Initial ?� ?.70 ?.19 25'f r6 $o& (Duration) pH Final 7�0�( -iZ 719I 1.01 `�01 Hardness(mg/1) D.O. Initial "?Q I �. r lO g0I 8.07 Spec. Cond.(µmhos/cm) '' ((Z,g /�(o[f D.O. Final 1•2 136 $fit) -93`) 19,3 g29 Chlorine(mg/l) <O • / <O . 1 Temp. Initial Z5: / LS, o Z�{cj f. (0 Z�•S 2 8 Sample temp. at receipt Z °c Z •O `c Temp. Final 2�f$ Z47W-12-g4q Zg06 Z-q99 Orcianism# Chronic Test Results 1 9 A A � A 7 A 9 10 11 12__ m— Final Control Mortality% 0 Control # Young Z3 Z3 Zlo 22 Z ZSf 23 14 zq Z 6 2j. % Control 3rd Brood Control Repro CV q 0 /Y-7 Adult (L) ive (D)ead �- L Z- L L L L- L t, �' ,1 �2 �3 -4 -5 6 7 - 9 10 11 12 "'G'" 48 Hour Mortality Control 1wc Qof )C7 a ofl� EffluenWo # Young Z-q L3 2.q LS Z3 22- l "f Zqf Z/ (L)ry d(p)ead �-- L L L L L �- 10 �+ t Ll 1 2 3 4 5 6 7 8 9 11 EffluenWo # Young Z3 U lg ZL Z! 22- Z3 ZZ ZZ ZZ- 21"7 • «o .S Adult (L)ive (D)ead L �-- L- i, c 6 A 9 A G C 7 a o i n Umn Effluent% # Young Z - 2-3 Z/ LZ Zl lzz Z•S zq 2-I Izz. Adult L L - L $, L. Effluent9'° # Young ZO (4 Z( lcl Z.0 2.3 17 22 Zo Z2120 Adult (L)ive (D)ead ` L L L L. L- L L lr L Pad f0 �{ K—RwAl Final Mortality Si -• 'cant 0.6 or C c. .vvvwuv•. v.. J .... =5!!. S Repro. LOEC=L(a-%; NOEC Method: Normal Distrib? _N2_ Method- a(C Statistic:/ • O9I I Critical.. S Equal Variances?qe_S_ Method: r Oak Method:. t5ftll 5 Effluent % Q, z.S Rank Sum Critical Sum c)7 ?S -rz.S Ts .S3 -To -.5 7S 44•S �3•i bolo foSS' '75 — 4 b tj IU MUM EffWent% # Young Z 1 �g 2Z (? 1�% !S Zt� 17 IS A 19.1 :.Overall Arta :'Result.= PA :.Test LOEC= Ctirontc Val � Adult (L)ive (D)ead t-- - �-- L L- L- L L- �- Red Zf.3 JV %; NOEL=E19 '� % ./... . . 'Should use highest test concentration or ATT: Environmental Sciences highest concentration with D.O. >5.0 rngn MAIL Div. of Environmental Management t% Reducton from conW PWPv*x w Mean N.C. Department of EHNR TO. 4401 Reedy Creek Rd. Raleigh. N.C. 27607 DEM form AT-3 (8/91) Rev. 11/9 effluent Toxicity Report Form'- Chronic Pass/Fail and Acute IMS Date: 09/08/97 Facility: PPG INDUSTRIES (SHELBY) NPDES#: NC0094685 Pipet: 00i County: CLEYMAKU Labor tory P�erfiohwip Wiest: WATER TECH AND CONTROLS INC [Comments: X . PASSED:-19.07% Reduction P gna ure o ory upery sor Work Order: 08279711 Environmental Sciences Branch MAIL ORIGINAL TO: Div. of Environmental Management N. C. Dept. of EHHR 4401 Reedy Creek Road Raleigh, North Carolina 27607-6445 iortn caroiana ueraoaa nnia Chronic Pass/Fail eproduction Toxicity Test :OHTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 # Young Produced 12311911511711711812011811811811511 Adult (L)ive (D)ead RL IL IL 'L IL IL IL IL IL IL IL IL `ffluent %: 33% PREATMENT 2 ORGANISMS 1 2. 3 4 5 6 7 8 9 10 11 a Young Produced l22125121121120121123122120122I20I1 Adult (L)ive (D)ead IL IL IL IL IL IL IL IL IL IL IL JL Chronic Test Results Calculated t = -4.400 Tabular t = 2.598 % Reduction = -19.07 % .Mortality Avg. Reprod. . 0.00 17.92 Control Control 0.00 21.33 Treatment 2 1 Treatment 2 Control CV 12.608% PASS FAIL % control orgga 2:1 producing 3rd brood Check qOne 100X lot sample Lot sample 2nd sample Complete This For Either Test pH I Test Start Date: 08/27/97 Control 8.00 7.91 8.13 7.98 8.09 7.97 Collection (Start) Date Sample 1: 08/25/97 Sample 2: 08/28/97 2nd Treatment 2 7.96 7.99 7.98 7.94 7.96 7.97 Sample Type/Duration 1st P/F s s s Grab Comp. Duration D t e t e t e I S S a n a n a n Sample 1 X 24 hrs L M AM r d r d r d t t t Sample 2 X 24 hrs T P P Lot sample lot sample 2nd sample D. 0. Hardness (mg/ 1) 45 Control 8.11 7.96 8.40 8.25 8.11 8.08 Spec. Cond. (pahos) 190 12W 1355 Treatment 2 8.08 8.00 8.30 8.15 8.10 8.20 Chlorine(mg/1) c0.1 LC50/Acute Toxicity Test Sample temp. at receipt(°C) 1.5 2.5 (Mortality expressed as %, combining replicates) Note. Please x x x x X x x x x x X X x x X X x X X % Concentration Complete This Section Also Mortality start/end start/end X50 = % Method of Determination 95% Con) a ence unit SpoeareenAURN = b pert _ Control High Conc. pH D. 0. Organism Tested: Ceriodaphnia dubia Duration(hrs): __ Water Tc-ch no l oe v 9103421522 103421522 P. 01 l � � Ike L, ,.,� ftr-+r, '.' I `t t ��! lvi r wn .G3 � Effluent Aquatic TOXIlty Report Form/Phase I! Chron c Cerlodaphnia Facility 7 Sf'� NPDES#: NC 000` 4&t57 Pipe# 1 County Cleve C Laboratory Performing Test �.Ja << " I 6�7-a 1s carrnents x x Signature of Signdlu'id6ftab Supervisor Sample lnformation Collection Start Date Grab Composite (Duration) Hardness(mg/1) Spec.Cond.(µmhos/crrl Chlorine(mg/l) Sample temp. at receipt Sample 1 Sample 2 Control ojOiS -r 7 �'t"1w qS /5-5 7 190. 2q1�v l2S% -eo . t <o . Z - S `c ✓_ 3 `o AM itormation• Start Date c ©7/q I End Date 9�� % I Start Time 101 VT End Time to :3D Treatment pH Initial PH Final D.O. Initial D.O. Final emp. Initial 'emp. Final Start Renewl new2j Start RQns Qnew2 46% Control Control Control 7.q q -70 0$ 7`l7 g. DD S.0 ) 76c? q.1 Z- Y.9 W-9 1 1711 TO!5 $.(p `6;Z .f .00 1 WZ0 92S -%CS 7'70 770 eta WO ?.rrp `� Zq.9 Z-57 -,q Z�¢5 ZrfS Zjf(Q 2-4.% Zq.$ Z.�f.S Z`fcl ZY�6 0!:5misEm 7 Control #Young 27- 17,3 1 2-D k3 1 1'7Z.f 117 u- zz Z7 Adult -[-L I(L)ive (D)ead C L It— L t-' L L L' Effluent% # Young 7-4 2N VI Zq210 Z�f ZI u-- L 2-7 Adult L L - ` L.. L L (L) Iva (D)ead n e A c a 7 R a 1n um Effluent% # Young 2.4 zq 2,3 2.1 'L4 :?� 24 ZO Z3 Z3 22. <<o Adult (Wive (D)ead L (` L A1iR E4fluenM 33 Effluent% �9 �S # Young LS zZ 2L 2r; Z Z3 Z�s O IL 24.1 Adult (L)ive (D)ead_ t. - 1. �, �-— o n l— 4 n PWd o ..Y- # Young 25 ZS 20 ( a ?5- Z I 2-4 2-3 2L Adult (L)ive (D)ead Effluent% #Young P� t7 D 1� o (3 ig Adult (L)ive (D)ead "an Final Control Mortality % 2f I % Control 3rd Brood / Control Aspro CY / != I o of toll o of b-R-10 Final Mortality Si 111cant O NI % or No Conc. Reproduglion Analyslai u� �- Repro. LOEC= %; NOEC=1i 57% Method - Normal Distribl �I Method: Statlstic:0.72Z 3 Criti: 0- Equal Variancal _.� Method Statistic:2q•(a/ Critical:-13"L7t n- l i Method: _^ °u- R 2� 141,.D -7 b I(o.S /2 5 .,5 3 O rz/ . o /!$. CO Qye Il Analysts: 'Result = PAS Ali.. or iQst LCEC- 6 A ®!,; NO EC= r -r _ "% Chronic Value- ? - ! 9G 'Should use highest test concentration or ATr: Environmental Sciences highest concentration with D-0- >5.0 fTW MAILDiv. of Environmental Management tx aed=S" horn conaal A.V0dUcaon MW N.C. Department of EHNR TO. 4401 Reedy Creek Rd. Raleigh, N.C. 27607 DEM foml AT-3 (6/91) Rev. 11195 ) L- ) � , + V-c'l " t ra- D * ZA --�- �L 11 PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA September 27, 1997 HATUr,�,Y,>._. Mr. D. Rex Gleason, P.E. SEP 3 0 i r97 North Carolina Department of Environment and Natural Resources Division of Water Quality DIVIS!N U 919 North Main Street Mooresville, NC 28115 Subject: Submission of Plans and Specifications for Additional Wastewater Treatment Facilities to Achieve Compliance with Permitted Effluent Chronic Toxicity Limitation Special Order by Consent EMC WQ No. 96-24 PPG Industries - Shelby, NPDES Permit No. NC004685 Cleveland County, NC Dear Mr. Gleason: PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by .Consent (SOC) with the State of North Carolina on March 11, 1997. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1 & 2). This report is to satisfy the requirements of Item 2.c. 3 of the SOC which states that PPG -Shelby shall "Submit plans and specifications by September 30, 1997 for upgrading the WWTP". Our toxicity studies to date have found that through bentonite clay addition to the aeration basin we have been able to control effluent toxicity. Therefore, we plan to convert our pilot system to permanent operation. The attached plans and specifications (Attachment A) represent the existing full scale pilot bentonite clay feed system. This equipment will now be used as the full scale permanent feed equipment. Sheet EN-1 is a schematic of the entire Wastewater Treatment Plant indicating the possible feed points for the bentonite clay. Bentonite clay can be fed either immediately before or immediately after the activated sludge aeration basin. EN-1 also indicates an optional feed point for Powdered Activated Carbon (PAC), prior to the activated sludge aeration basin, if it is needed at some point in the future. We do not anticipate the need to feed PAC in order to control effluent toxicity. ti Sheet EN-2 is a schematic of the bentonite clay feed system. This schematic details how the clay is transferred from 2000 lb. bulk bags, slurried and fed to one of the two optional feed points shown on Sheet EN-1. Data on the bentonite clay and the clay feed equipment from the manufacturer is also included in Attachment B. We feel that this submittal satisfies items 2.c.3 and 2.c.4 of the remaining activities to be performed by PPG -Shelby under the SOC. Please let us know if anything further is needed for item 2.c.4. The next and final activity (2.c.5) is to achieve compliance with final effluent limitations by June 30, 1998. A quarterly progress report detailing our findings since July of 1997 will be sent prior to October 15, 1997 in order to satisfy Item 3.d. of the SOC. We are pleased to report that, to date, we have passed all toxicity tests performed at our permitted dilution since our last quarterly progress report in July of 1997. If you have any questions, please do not hesitate to call me a (704) 434-2261 Ext. 544. Sincerely, Lacy Ballard Staff Engineer Attachments cc: T. Keesling, AEI A. Astroth M. LeCroy B. Blackwell M. Reilly C. Bromby - Hunton and Williams ATTACHMENT A EN-1 - Wastewater Treatment Plant Process Schematic EN-2 - Clay Feed System Schematic n n 7 n r) u 1 ll p ll 7 u L n u r) y Z C J i CLAY i K3p04 OPTIONAL SON AERATION �� ADDITION �� BASIN I � I UME AERATION BASIN sul SPLITTER s INFLUENT BOX LIFT SURGE T PUMP !T. SYSTEM FLOW INFLUENT WET WELL TO W04ARCE (ERU41Y arEmc) EF C OEFOMQ2 NOTE DRAWING IS SCHEMATIC IN NATURE ONLY AND IS NOT MEANT TO SHOW DETAILS. AERATION BASIN Feat —� POLYI/ER r— OPTIONAL 1 CLAY ( ADDITION ,E' `�� •r r. r o- ss .�J t� O FLOCCULATION TANK/SPUTTER BOX WASTEWATER TREATMENT PLANT PROCESS SCHEMATIC PPG INDUSTRIES SHELBY. NORTH CAROLINA ="wr To SGIE Appoomm r : Tu DAB E m AWAW- lid rowM IM C MWM NC 2WO rOBT 10@ !� CLAY FEED TO SPUTTER BOX PRIOR TO AERATION BASIN ' OPTIONAL CLAY FEED TO FLOCCULATION TANK/SPUTIER BOX AFTER AERATION BASIN BULK BAI (SCREW FEED goe�btalHll//,/// `��Y1 CARS, �`'•� iev mmome0000a s m. Ca s I mpw � o 1105 o a m ii A am�0mammO00 4� III all% �I NOTE DRAWNG IS SCHEMATIC IN NATURE ONLY AND IS NOT MEANT TO SHOW DETAILS um ALL PPNG M BE SOH 8D PVC. ALL' TUEING TO BE CLEAR PVC ALL SLURRY FEED HOSE TO BE EDDY CLAY FEED SYSTEM SCHEMATIC PPG INDUSTRIES SHELBY, NORTH CAROLINA 7hYImr7o somr mmm w:TlX w !ire L® w - TJJL ATTACHMENT B Bentonite Clay Data Sheet Detailed Drawings of Bentonite Clay Feed Equipment COLLOID ENVIRONMENTAL TECHNOLOGIES COMPANY TECHNICAL DATA ISHEET Description Accofloc SDG is a sodium bentonite based material. It is cl " sified as a flocculant aid for use in industrial and municipal treatment plants. It is used in conjunction polymers and/or flocculating agents to remove suspended solids, heavy metals, oils, and grease. This product will not generate a floc on its own. Function When Accofloc SDG is dispersed into a wastestream, it size and weight. The resulting floc increases waste dewatering. Chemical and Physical Properties Appearance: Beige powder Odor: Earthy Moisture: 10% maximum pH: 8-10.5 in water Powder particle size: Minimum 85% Maximum 15% Bulk Density: 52-54 pounds pi Specific gravity: 2.6 Directions for Use Accofloc SDG should be added with tap water and mixec should be completely hydrated for 24 hours prior to adding added to a wastestream prior to the addition of polymers or 1 Precautions Accofloc SDG is hydrophilic and becomes slippery when should be swept up immediately. Accofloc SDG is NSF approved for use in potable water. ACCOSDG .with contaminants and helps increase floc treatment efficiency and improves sludge issing 30 mesh screen )assing 100 mesh screen cubic foot into a 5% slurry by weight. The Accofloc o the wastestream. Accofloc SDG should be xculating agents. Accofloc SDG spilled in a work area January, 95 1350 W. Shure Drive • Arlington Heights, Illinois 60004-1440 • (847) 392-5800 is FAX (847) 506-6150 A wholly owned subsidiary of AMCOL International The information and data contained herein are'believed to be accurate and reliable. CETCO makes no warranty responsibility for the results obtained through application of this information. CET-2001 Printed on mcycbtl paper any kind and accepts no COLLOID ENVIRONMENTAL TECHNOLOGIES COMPANY TECHNICAL DATA 350 I i j „� �,�• t^I.� 1 �➢�! v� 1 lit 1 j � I i`� HEET Description Accofloc 350 is a sodium bentonite based material. It is classified as a flocculant aid for use in industrial and municipal treatment plants. It is used in conjunctioni with polymers and/or flocculating agents to remove suspended solids, heavy metals, oils, and grease. Thlis product will not generate a floc on its own. Accofloc 350 has been NSF approved for potable water. Function When Accofloc 350 is dispersed into a wastestream, it binds with contaminants and helps increase floc size and weight. The resulting floc increases treatment efficiency and improves sludge dewatering. Purity Hydrous aluminum silicate comprised principally of the clay mineral montmorillonite. Montmorillonite content 94% minimum. Contains small portions of feldspar,:biotite, selenite, etc. Chemical and Phvsical Properties Chemical Composition Appearance: Odor: Moisture: pH: Powder particle size: Bulk Density: Specific gravity: Wet Particle Size: Si02 A1203 Fe203 FeO MgO Na20 CaO H2O Trace Elements Swelling Power Minimum 28 milliliters per 2 grams clay (typical) Beige powder Earthy 10% maximum 8-10.5 in water Minimum 80% passing 200 mesh screen 52-54 pounds per cubic foot 2.6 Minimum 97% finer than 200 mesh Minimum 95% finer than 325 mesh 63.02% 21.08% 3.25 % 0.35%1 2.67%I 2.57%, 0.65%1 5.64%I 0.72% Directions for Use Accofloc 350 should be added with tap water and mixed it be completely hydrated for 24 hours prior to adding to the a wastestream prior to the addition of polymers or floccula Precautions Accofloc 350 is hydrophilic and becomes slippery when be swept up immediately. ACC0350 1350 W. Shure Drive a Arlington Heights, Illinois 60004- A wholly owned subsidiary of M ation and data contained herein are believed to be accurate and r responsibility for the results obtained through a 5% slurry by weight. The Accofloc should istestream. Accofloc 350 should be added to agents. Accofloc 350 spilled in a work area should January,95 440 a (847) 392-5800 e FAX (847) 506-6150 COL International liable. CETCO makes no warranty of any kind and accepts no wolication of this information. CET-2001 (�,{S armieo 11 I-Iciea Accofloc® Accofloc particle structure. Accofloc in hydrated form. The Accofloc products are high swelling pure sodium bentonite clays found only in the Black Hills region of the western United States. The Accofloc clays are selected for their unique ion exchange capability. This capability allows Accofloc to increase clarity and remove trace metals from wastewater. Accofloc is NSF approved for use in potable water applications. 0_ ; Increasing Dosage Rate (ppm) 7'-3 3/16' 1, aO in I io 10 ga. HOPPER m �r 6'-9 3/16' itlG 31QE � in��i "� COLLOID ENVIRONMENTAL TECHNOLOGIES COMPANY ELEVATOR HEIGHT MAY VARY ASSUME 4' ABOVE TANK ENTRANCE POINT uwHomN HnoHrs, IwNOIB DA3-M-B6 BULK FEEDER WITH ELEVATOR GENERAL ARRANGEMENT DRM BY LB CHK E DNO NO. DESIGN BY dMt ih BW-153 .P / N.C. DFPT. OF ENVII'c©�I',z�?;1T, I•SW �3,TFI , & NATUl"' PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA JUL 1 0 1997 July 9, 1997 Mr. D. Rex Gleason, P.E. North Carolina Department of Environmental Health and Natural Resources Division of Water Quality 919 North Main Street Mooresville, NC 28115 Subject: Quarterly Progress Report Special Order by Consent EMC WQ No. 96-24 PPG Industries NPDES Permit No. NC0004685 Cleveland County, NC Dear Mr. Gleason: PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by Consent (SOC) with the State of North Carolina on March 11, 1997. This report is to satisfy the requirements of Item 2.d. of the SOC which states that PPG -Shelby shall submit a Quarterly Progress Report by the 15th day of July 1997. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1 & 2). The next activity to complete is Submission of Plans and Specifications for Upgrading the WWTP by September 30, 1997. Since the last Quarterly Progress Report, presented to the State in April of 1997, PPG - Shelby has implemented full scale testing of feeding Powdered Activated Carbon (PAC) and bentonite clay and full scale testing of bentonite clay addition without PAC. Full range monitoring, as required by the SOC, was performed during the week of April 21 - 25. These tests were conducted less than three (3) weeks after the completion and initiation of operation of the full scale bentonite clay addition system. Results of this test are presented in Table 1. The full range monitoring indicated an LOEC of 33 %, an NOEC of 16.5 % and a Chronic Value of 23.3 % for this sample. These overall results are identical to the full range testing performed in March of 1997. The samples collected for the full range monitoring had conductivity readings of 1133 uMhos/cm and 1420 uMhos/cm. Bentonite clay was first introduced to the treatment system on March 25, 1997 with 1000 lbs being added directly to the aeration basin. On March 26, a program of adding 250 lbs/day of bentonite clay to the WWTP on a 24 hour basis via a slurry system was started. Bentonite clay dosages have been increased as necessary to control effluent toxicity. We are currently feeding 750 lbs/day to the aeration basin and believe that this dosage is sufficient to control effluent toxicity in our discharge. Table 2 presents the results of all full scale effluent toxicity testing that have been performed since the beginning of 1997. The last five (5) weekly tests and seven (7) out of the last eight (8) chronic toxicity tests have passed. The addition of the bentonite clay has reduced and controlled chronic toxicity in PPG-Shelby's effluent. The most recent sample produced more young than the control in the toxicity test. Full Range Monitoring will be performed in July to satisfy the third quarter monitoring requirements put forth in the SOC. We continue to monitor fluoride on a weekly basis as required by the SOC. The next SOC Activity, the development of Plans and Specifications for the full scale treatment plant modifications is underway and this Activity is on Schedule. We plan to change our sampling schedule from weekly to bi-weekly for toxicity testing through the month of July and will evaluate the need for continued testing depending on those results. We will keep you informed of our progress and the status of further SOC task deadlines. If you have any questions, please do not hesitate to call me at (704) 434-2261 Ext. 544. Sincerely, 1-� 7~7 A � �� Lacy Ballard Staff Engineer Attachments cc: T. Keesling, AEI A. Astroth M. LeCroy B. Blackwell M. Reilly C. Bromby - Hunton and Williams TABLE 1 PPG Shelby - Full Range Effluent Toxicity Monitoring April 21 - April 25 TEST REPRODUCTION % REDUCTION CONTROL 22.8 NA 8.25% 22.1 3.0% 16.5 % 19.1 16.2 % 33 % 15.7 31.1 % 49.5 % 8.0 64.9 % 66 % 3.3 85.5 % TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 CONTROL SAMPLE % OF SAMPLE SAMPLE DATE TYPE OF SAMPLE REPRODUCTION REPRODUCTION CONTROL MORTALITY CONDUCTIVITY PASS/FAIL 38 1/14/97 ROUTINE EFFLUENT MONITORING (2) 27.3 9.6 35% 0% 1016/986 FAIL 50 mg/l Bentonite added + filtration 38-A 1/14/97 EFFLUENT MONITORING (2) 27.3 18.9 69% 0% 1029/952 FAIL 250 mg/l Bentonite added + filtration 38-B 1/14/97 EFFLUENT MONITORING (2) 27.3 23.3 85% 0% 1040/1023 PASS 500 mg/l Bentonite added + filtration 38-C 1/14/97 EFFLUENT MONITORING (2) 27.3 27.3 100% 0% 1047/1051 PASS 39 1/29/97 EFFLUENT MONITORING (2) 27.0 12.8 47% 0% 874/958 FAIL filtered with TSS filter 39-A 1/29/97 EFFLUENT MONITORING (2) 27.0 22.5 83% 0% 867/951 PASS 40 2/12/97 EFFLUENT MONITORING (2) 22.3 8.4 38% 0% 1002/1162 FAIL 41 2/26/97 EFFLUENT MONITORING (2) 25.2 22.3 88% 0% 845/966 PASS 42 3/12/97 EFFLUENT MONITORING (2) 24.2 8.4 35% 0% 1320/1291 FAIL 8.25 % 43 -A 3/26/97 EFFLUENT MONITORING (2) 23.2 23.7 102% 0% 1557/1340 PASS 16.50% 43-B 3/26/97 EFFLUENT MONITORING (2) 23.2 21.7 94% 0% 1557/1340 PASS 33 % 43-C 3/26/97 EFFLUENT MONITORING (2) 23.2 12.2 53% 10% 1557/1340 FAIL 49.50 % 43-D 3/26/97 EFFLUENT MONITORING (2) 23.2 1.5 6% 20% 1557/1340 FAIL 66 % 43-E 3/26/97 EFFLUENT MONITORING (2) 23.2 0.0 0% 40% 1557/1340 FAIL 44 4/2/97 EFFLUENT MONITORING (2) 24.2 11.4 47% 0% 1593/1518 FAIL filtered with TSS filter 44-A 4/2/97 EFFLUENT MONITORING (2) 24.2 11.6 48% 0% 1588/1521 FAIL untreated effluent 44-B 4/13/97 EFFLUENT MONITORING (2) 26.2 13.8 53% 0% 1610/1528 FAIL 7/7/97 TOXTEST2.XLS EFFLUENT SAMPLING TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 SAMPLE DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/FAIL 44-C 4/13/97 250 mg/1 Bentonite added + filtration EFFLUENT MONITORING (2) 26.2 15.6 60% 0% 1655/1590 FAIL 44-D 4/13/97 1000 mg/1 Bentonite added + filtration EFFLUENT MONITORING (2) 26.2 23.2 89% 0% 1795/1738 PASS 45 4/9/97 EFFLUENT MONITORING (2) 24.6 18.8 76% 0% 1067/1356 FAIL 45-A 4/9/97 filtered with TSS filter EFFLUENT MONITORING (2) 24.6 22.2 90% 0% 1060/1347 PASS 46 4/16/97 EFFLUENT MONITORING (2) 23.2 6.8 29% 0% 1395/1215 FAIL 46-A 4/16/97 filtered with TSS filter EFFLUENT MONITORING (2) 23.2 7.8 34% 0% 1404/1210 FAIL 47-A 4/23/97 8.25 % EFFLUENT MONITORING (2) 22.8 22.1 97% 0% 1133/1420 PASS 47-B 4/23/97 16.50% EFFLUENT MONITORING (2) 22.8 19.1 84% 0% 1133/1420 PASS 47-C 4/23/97 33 % EFFLUENT MONITORING (2) 22.8 15.7 69% 0% 1133/1420 FAIL 47-D 4/23/97 49.50 % EFFLUENT MONITORING (2) 22.8 8.0 35% 0% 1133/1420 FAIL 47-E 4/23/97 66 % EFFLUENT MONITORING (2) 22.8 3.3 14% 10% 1133/1420 FAIL 48 4/30/97 EFFLUENT MONITORING (2) 20.4 19.2 94% 0% 1298/1159 PASS 49 5/7/97 EFFLUENT MONITORING (2) 23.0 20.2 88% 0% 1015/1028 PASS 50 5/14/97 EFFLUENT MONITORING (2) 26.3 19.1 73% 0% 1109/1098 FAIL 51 5/21/97 EFFLUENT MONITORING (2) 21.6 17.6 81% 0% 1137/932 PASS 52 5/28/97 EFFLUENT MONITORING (2) 23.0 22.7 99% 0% 857/945 PASS 53 6/4/97 EFFLUENT MONITORING (2) 24.0 21.2 88% 0% 952/1181 PASS 7/7/97 TOXTEST2. XLS EFFLUENT SAMPLING TABLE 2 1997 EFFLUENT MONITORING PPG - SHELBY AEI JOB No. N259-01 SAMPLE DATE TYPE OF SAMPLE CONTROL REPRODUCTION SAMPLE REPRODUCTION % OF CONTROL SAMPLE MORTALITY CONDUCTIVITY PASS/FAIL 54 6/11/97 EFFLUENT MONITORING (2) 16.0 15.7 98% 0% 100011155 PASS 55 6/25/97 EFFLUENT MONITORING (2) 20.4 22.7 111% 0% 1 1 PASS NOTES (1) SAMPLE SENT TO PACE ANALYTICAL (2) SAMPLE SENT TO WATER TECHNOLOGY AND CONTROLS 7/7/97 TOXTEST2.XLS EFFLUENT SAMPLING ATTACHMENT B Bentonite Clay Data Sheet Detailed Drawings of Bentonite Clay Feed Equipment COLLOID ENVIRONMENTAL TECHNOLOGIES COMPANY TECHNICAL DATA SHEET ACCOFLOC SDG SPECIFICATIONS Description Accofloc SDG is a sodium bentonite based material. It is classified as a flocculant aid for use in industrial and municipal treatment plants. It is used in conjunction with polymers and/or flocculating agents to remove suspended solids, heavy metals, oils, and grease. This product will not generate a floc on its own. Function When Accofloc SDG is dispersed into a wastestream, it binds with contaminants and helps increase floc size and weight. The resulting floc increases wastewater treatment efficiency and improves sludge dewatering. Chemical and Physical Properties Appearance: Beige powder ' Odor: Earthy Moisture: 10% maximum pH: 8-10.5 in water Powder particle size: Minimum 85% passing 30 mesh screen Maximum 15% passing 100 mesh screen Bulk Density: 52-54 pounds per cubic foot Specific gravity: 2.6 Directions for Use Accofloc SDG should be added with tap water and mixed into a 5% slurry by weight. The Accofloc should be completely hydrated for 24 hours prior to adding to the wastestream. Accofloc SDG should be added to a wastestream prior to the addition of polymers or flocculating agents. Precautions Accofloc SDG is hydrophilic and becomes slippery when wet. Accofloc SDG spilled in a work area should be swept up immediately. Accofloc SDG is NSF approved for use in potable water. ACCOSDG January, 95 1350 W. Shure Drive • Arlington Heights, Illinois 60004-1440 • (847) 392-5800 • FAX (847) 506-6150 A wholly owned subsidiary of AMCOL International The information and data contained herein are'believed to be accurate and reliable. CETCO makes no warranty of any kind and accepts no responsibility for the results obtained through application of this information. CET•2001 e-9 11-mw .. r.cyci.a p.- 4611111 =4 COLLOID ENVIRONMENTAL TECHNOLOGIES COMPANY TECHNICAL DATA SHEET ACCOFLOC 350 SPECIFICATIONS Description Accofloc 350 is a sodium bentonite based material. It is classified as a flocculant aid for use in industrial and municipal treatment plants. It is used in conjunction with polymers and/or flocculating agents to remove suspended solids, heavy metals, oils, and grease. This product will not generate a floc on its own. Accofloc 350 has been NSF approved for potable water. Function When Accofloc 350 is dispersed into a wastestream, it binds with contaminants and helps increase floc size and weight. The resulting floc increases treatment efficiency and improves sludge dewatering. Purit Hydrous aluminum silicate comprised principally of the clay mineral montmorillonite. Montmorillonite content 94% minimum. Contains small portions of feldspar, biotite, selenite, etc. Chemical and Phvsical Properties Appearance: Odor: Moisture: PH: Powder particle size: Bulk Density: Specific gravity: Wet Particle Size: Chemical Composition Si02 A1203 _ - - Fe203 FeO MgO Na20 CaO H2O Trace Elements Swelling Power Minimum 28 milliliters per 2 grams clay (typical) Beige powder Earthy 10% maximum 8-10.5 in water Minimum 80% passing 200 mesh screen 52-54 pounds per cubic foot 2.6 Minimum 97% finer than 200 mesh Minimum 95% finer than 325 mesh 63.02% 21.08% ' 3.25% 0.35 % 2.67% 2.57% 0.65% 5.64% 0.72% Directions for Use Accofloc 350 should be added with tap water and mixed into a 5% slurry by weight. The Accofloc should be completely hydrated for 24 hours prior to adding to the wastestream. Accofloc 350 should be added to a wastestream prior to the addition of polymers or flocculating agents. Precautions Accofloc 350 is hydrophilic and becomes slippery when wet. Accofloc 350 spilled in a work area should be swept up immediately. ACC0350 January, 95 1350 W. Shure Drive • Arlington Heights, Illinois 60004-1440 • (847) 392-5800 • FAX (847) 506-6150 A wholly owned subsidiary of AMCOL International The information and data contained herein are believed to be accurate and reliable. CETCO makes no warranty of any kind and accepts no responsibility for the results obtained through application of this information. CET-2001 Pnmaa on n yclw oawc Easy to Use.. Accof 1 oc® Accofloc particle structure. Accofloc in hydrated form. The Accofloc products are high swelling pure sodium bentonite clays found only in the Black Hills region of the western United States. The Accofloc clays are selected for their unique ion exchange capability. This capability allows Accofloc to increase clarity and remove trace metals from wastewater. Accofloc is NSF approved for use in potable water applications. Accofloc is normally premixed with tap water to a 5% by weight slurry. Accofloc is never added directly to a wastewater stream in the dry form. After approximately two hours of hydration time, the slurry can be added to the,. wastewater treatment mix tank at a rate of 200 to 500 ppm. It is important to note that Accofloc will " normally not floc on its own. In order to create a floc, Accofloc must.be used in conjunction with polyelectrolytes or inorganic flocculating salts Accofloc is Offered in Two Forms Accofloc 350 • Accofloc SDG Accofloc 350 is a high quality powder sodium .; bentonite clay chosen especially for its flocculation characteristics. Accofloc SDG consists of uniformly sized granules that have been produced from high -` quality ground, selectively mined sodium .: bentonite clay. 7'-3 3/16' 4'-7' 1 OD Ln -a f io 10 go.. HOPPER OD ju .r 6'-9 3/16' itlu 31OE 0 ELEVATOR HEIGHT MAY VARY COLLOID EWRONUENTAL TECHNOLOGIES COMPANY /JWHGTGN HooHTS, ASSUME 4' ABOVE TANK ENTRANCE POINT �+ eo-96 BULK FEEDER ER WITH ELEVATOR GENERAL ARRANGEMENT DRM By LB 11PYdE 3/B•-Y-0' DMD ND. DEM BY *K DY DW-133 PPG Industries, Inc. Works No. 52 940 Washburn Switch Road Shelby, North Carolina 28150 USA' September 27, 1997 Mr. D. Rex Gleason, P.E. North Carolina Department of Environment and Natural Resources Division of Water Quality 919 North Main Street Mooresville, NC 28115 Subject: Submission of Plans and Specifications for Additional Wastewater Treatment Facilities to Achieve Compliance with Permitted Effluent Chronic Toxicity Limitation Special Order by Consent EMC WQ No. 96-24 PPG Industries - Shelby, NPDES Permit.No. NC004685 Cleveland County, NC Dear Mr. Gleason: PPG Industries, Inc. located in Shelby, North Carolina (PPG -Shelby) entered into a Special Order by Consent (SOC) with the State of North Carolina on March 11, 1997. PPG -Shelby has complied with the time schedule of the activities listed in the SOC to date (Activities 2.c.1 & 2). This report is to satisfy the requirements of Item 2.c. 3 of -the SOC which states that PPG -Shelby shall "Submit plans and specifications by September 30, 1997 for upgrading the WWTP" . Our toxicity studies to date have found that through bentonite clay addition to the aeration basin we have been able to control effluent toxicity. Therefore, we plan to convert our pilot system to permanent operation. The attached plans and specifications (Attachment A) represent the existing full scale pilot bentonite clay feed system. This equipment will now be used as the full scale permanent feed equipment. Sheet EN-1 is a schematic of the entire Wastewater Treatment Plant indicating the possible feed points for the bentonite clay. Bentonite clay can be fed either immediately before or immediately after the activated sludge aeration basin. EN-1 also indicates an optional feed point for Powdered Activated Carbon (PAC), prior to the activated sludge aeration basin, if it is needed at some point in the future. We do not anticipate the need to feed PAC in order to control effluent toxicity. Sheet EN-2 is a schematic of the bentonite clay feed system. This schematic details how the clay is transferred from 2000 lb. bulk bags, slurried and fed to one of the two optional feed points shown on Sheet EN-1. Data on the bentonite clay and the clay feed equipment from the manufacturer is also included in Attachment B. We feel that this submittal satisfies items 2.c.3 and 2.c.4 of the remaining activities to be performed by PPG -Shelby under the SOC. Please let us know if anything further is needed for item 2.c.4. The next and final activity (2.c.5) is to achieve compliance with final effluent limitations by June 30, 1998. A quarterly progress report detailing our findings since July of 1997 will be sent prior to October 15, 1997 in order to satisfy Item 3.d. of the SOC. We are pleased to report that, to date, we have passed all toxicity tests performed at our permitted dilution since our last quarterly progress report in July of 1997. If you have any questions, please do not hesitate to call me a (704) 434-2261 Ext. 544. Sincerely, ;Zr� e Lacy Ballard Staff Engineer Attachments cc: T. Keesling, AEI _ A. Astroth M. LeCroy B. Blackwell M. Reilly C. Bromby - Hunton and Williams ATTACHMENT A EN-1 - Wastewater Treatment Plant Process Schematic EN-2 - Clay Feed System Schematic 1 VWIOSV3 RUJON HS s3msnum odd OILVV(3HOS SS30o21d 1NVId 1N3YtLV3ML H3LVA% LSVM x08 a3unds/mv.L NOLLVlnDDO-U b alb • +JJti /9 a �•P �cL� J�`"�s �� 4 1 mae�oe®$ �Vv �je1�` NOLLIOOVJLVM 1 mi\\\y IVN 1Ld10 --i M3PAIDd _ 's1tVt30 IMOHS OL INV3M ION Si ONV k-M 3WUVN NI 3LLVK3N3S SI ONWIVSa- =310N I i � ulS „ id I f c>OMO AMnW) I i 113M 13M 1N3f113N1 CW., MO'U W31SAS aanr�vs dried x08 IVl mans n 1N3f1 2aaund NISV8 NISV$; NOLLV83V NOLLV83 F-c� T� I 1 1 � j NISVB / NOLLIOOVI I NOLLb2pV i NOSMI 1 lVNMCIO 1 'OdTH 1 I j j AVID \ / I t �---- N.C. DES. PUBLIC N O T I C E IPMROM , ENT, NZALIU, NATURAL RESOURCES STATE OF NORTH CAROLINA MAR 2 g 1997 ENVIRONMENTAL MANAGEMENT COMMISSION POST OFFICE BOX 29535 otuis,^ Cr E l�s'p°F"TAt'1.0-AGPIENT RALEIGH, NORTH CAROLINA 27626-0535 t MESSULE RE AL OFFSE NOTIFICATION OF INTENT TO ISSUE A CONSENT ORDER Public notice of intent to issue a State Consent Order to the following: PPG Industries, 940 Washburn Switch Road, Shelby, NC 28150, Cleveland Coum nt�y Special Order by Consent EMC WQ 96-24. Currently, the facility operates a 1.3 MGD wastewater treatment works that discharges treated wastewater to Brushy Creek, Class "C" waters of this State in the Broad River Basin. The facility is unable to comply with final effluent limits contained in their.NPDES Permit NC0004685 for Chronic Toxicity and Fluoride. This Order, if issued, will allow the facility to exceed final effluent limits for the aforementioned parameters. Compliance will require construction and operation of additional treatment facilities. This Order contains a detailed schedule for compliance and stipulated penalties for failing to meet interim requirements. This Order will expire on September 30, 1998. On the basis of thorough staff review and application of Article 21 of Chapter 143, General Statutes of North Carolina, and other lawful standards and regulations, the North Carolina Environmental Management Commission proposes to issue a Consent Order to the persons listed above effective May 12, 1997, and subject to special conditions. Persons wishing to comment upon or object to the proposed determinations are invited to submit same in writing to the Water Quality Section Chief, PO Box 29535, Raleigh, NC 27626-0535, no later than April 25, 1997. All comments received prior to that date will be considered in the formu ation of final determinations regarding the proposed Order. A public meeting may be held where the Director of the Division of Water Quality finds a significant degree of public interest in a proposed Order. A copy of the draft Order is available by writing or calling the Division of Water Quality, PO Box 29535, Raleigh, NC 27626-0535, telephone number (919) 733-5083 ext. 530, or the Mooresville Regional Office at 919 North Main Street, Mooresville, NC 28115 telephone number (704) 663-1699. The Order and other information may be inspected at these locations during normal office hours. Copies of the information on file are available upon request and payment of the costs of reproduction. All such comments or requests regarding a proposed Order should make reference to the name listed above. Date�� i N D vid H. Moreau, Ch irman Environmental Management Commissic i State of North Carolina 17 Department of Environment, Health and Natural Resources A o YIWA Division of Water Quality James B. Hunt, Jr., Governor IIIIN Jonathan B. Howes, Secretary ID C C F1 A. Preston Howard, Jr., P.E., Director March 19, 1997 Linda C. Thrift CLERK OF COURTS 100 Justice Place Shelby, NC 28150 Dear Ms. Thrift: Prior to issuance of consent orders, the Environmental Management Commission is required to give notice of the proposed action by posting a copy of the public notice at the courthouse in the county where the order is in effect. Please post the attached public notice for a period of thirty days in those places usually set aside for this purpose. Sincerely yours, 21, Robert L. Sledge, Supervisor Facilities Assessment Unit Attachment RLS/cs P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -cons �- State of North Carolina Department -of Environment, Health and Natural Resources Division of Water Quality James.B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director March 19, 1997 Shelby Star ATTENTION: Legal Ad Department P. O. Box 48 Shebly, NC 28151 Dear Sirs: Prior to the issuance of a consent order, the Environmental Management Commission is required to give notice of the proposed action by publishing a public notice in a newspaper having general circulation in the county where the order is in effect. Please publish the attached Public Notice in your paper one time on Wednesday March 26, 1997. Ten days following publication, please send three copies of your invoice and two copies of affidavits of publication to the following address: Environmental Management Budget Office Post Office Box 29535 Raleigh, North Carolina 27626-0535 The affidavits and invoices must be sent together to assure prompt payment. Sincerely, > Robert L. Sledge, Supervisor Facilities,_ Assessment Unit RLS/cs P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director September 17, 1996 MR A.A. ASTROTH PPG INDUSTRIES INC 940 WASHBURN SWITCH ROAD SHELBY NC 28150 Processing Fee Special Order by Consent EMC WQ SOC 96-24 Cleveland County Dear Mr. Astroth: N.C. DFPT. oiz ENVIRONMENT, HEALTH; & NATURAL RESOURCES SEP 2 9 1996 DIVISION OF ENWRONMENTAL IMANAGHHUT MOORESVILLE REGIONAL OFFICE This is to acknowledge receipt of your check No. 2728244 in the amount of S400.00 received from PPG Industries Inc. on September 17, 1996. If you have questions concerning the Order you may call Rex Gleason of the Mooresville Regional Office at.(704) 663-1699 or Dianne Wilburn at (919)733-5083 ext. 232. Sincerely, Robert L. Sledge, Supervisor Compliance Group RLS/bc cc: "Nfooresville Regional Office SOC Files - P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper