WQ0001077_Staff Report_20210209 (2)

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: n NPDES Unit ® Non -Discharge Unit
Attn: (Poonam Giri, Non -Discharge Branch)
From: (Edward Watson)
Mooresville Regional Office
Application No.: (WQ0001077)
Facility name: Innospec Active Chemicals, LLC
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or n No
a. Date of site visit: 11-24-2020
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No (available in BIMS/LF)
c. Person contacted: Allen Robey and their contact information: (336) 847 - 5061 ext.
e. Driving directions:
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: James C. White Certificate #: SI/25861 Backup ORC: Kristopher Houpt Certificate #: SI/26351
2. Is the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
If no, please explain:
Description of existing facilities: Innospec is a manufacturer of personal care products. The primary portion of
the effluent waste stream is directed to The City of Salisbury under Salisbury's Industrial Waste Permit. The
remaining effluent flow is treated in the onsite lagoon and DAF and the effluent is transferred via pipe -line to the
holding tank located at the dedicated spray irrigation field.
Proposed flow: Current permitted flow: 12,000 GPD to the dedicated Spray Irrigation Fields.
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) The permit modification of 2018 removed Field 1 from the permit. Field 2 is the only dedicated irrigation
field remaining at this facility. There are 6 sections to Field 2. These sections are reported individually on the
NDMR.
FORM: WQROSSR 04-14 Page 1 of 4

3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ® Yes or n No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? n Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or n No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes n No n N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? n Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
If no, please explain:
10. Were monitoring wells properly constructed and located? ® Yes n No n N/A
If no, please explain: the monitoring well coordinates correct in BIMS? ® Yes n No n N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
11. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Z Yes or n No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
If yes, please explain:
13. Check all that apply:
Z No compliance issues n Current enforcement action(s) n Currently under JOC
n Notice(s) of violation n Currently under SOC n Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes n No n N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
n Yes ®No n N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: N/A unless not operated as a ND system
16. Pretreatment Program (POTWs only): Innospec has a pre-treatment permit from Salisbury -Rowan Utilities
FORM: WQROSSR 04-14 Page 2 of 4

REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? n Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Attachment C GW
Monitoring
Please remove monitor wells MW4, MW-9, MW-10, amd MW-11 from BIMS.
These wells have been abandoned. Please mark these wells as permanently
abandoned in BIMS.
4. Recommendation: n Hold, pending receipt and review of additional information by regional office
n Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
® Issue
n Deny (Please state reasons: )
5. Signature of report preparer: Edward Watson 02/08/2021
Signature of regional supervisor:
DocuSigned by:
f��.dticw N P4144
F161FB69A2D84A3...
2.9.21
Date:
FORM: WQROSSR 04-14 Page 3 of 4

III. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This permit was modified in 2018. Monitor wells MW-9, MW-10, and MW-11 need to be removed from the permit
and sampling requirements for these wells are to be discontinued. These well have been abandoned. The GW-30,
Well Abandonment Records can be found on Laserfiche.
Well MW-4 was abandoned in 1993, but never removed from BIMS. The MRO has attached documentation of the
wells abandonment as shown in a map with the 1993 permit. MRO has not located a GW-30 for MW-4 and the well is
no longer present based on site visits.
FORM: WQROSSR 04-14 Page 4 of 4