NC0006351_Staff Comments_20150325

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Denard, Derek
From: Allocco, Marcia
Sent: Wednesday, March 25, 2015 3:47 PM
To: Denard, Derek; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
I wish it was a vacation; slave to my mother after knee replacement #2.
Marcia Allocco, MS - [e-mail]
Senior Environmental Specialist
North Carolina Department of Environment & Natural Resources
Division of Water Resources
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] x2204 Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 3:44 PM
To: Allocco, Marcia; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Marcia,
Thanks for getting back with me. Thought you were on vacation! I believe you have it right by everything you
mentioned below. Maybe worth running this by Jenn and Vanessa about ICIS upload issues. I will get backwith
everyone tomorrow.
Derek
From: Allocco, Marcia
Sent: Wednesday, March 25, 2015 3:18 PM
To: Denard, Derek; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Hey Derek,
Not in the office so I don't have the specifics in front of me but here is what I remember regarding
my review of the violations.
• There were no late reporting violations that I remember BIMS flagging. This may be related
to non -upload of data to ICIS as per Jenn Smith and Vanessa that they had mentioned related
to some other issues identified by a permittee accessing their compliance history in ECHO. I
would ask Jenn and Vanessa to look into what data has been uploaded to ICIS for this
permit. It highlights a bigger issue in that DWR does not QA/QC the data uploaded to ICIS to
ensure it is accurate and there are no issues.
• I BPJ'ed the nickel and BOD monitoring violations. They are reporting both of these
parameters as Ibs/day which makes sense since almost all other permit limits are in Ibs/day
but BIMS is looking ,fio' mg/L as the reporting units of measure. I was going to contact the
i

permit writer to see what their intent was since there are no units of measure noted in the
issued paper permit for these parameters when I returned but perhaps you can do that since
there is a time -sensitive response.
• They noted 0 on days when they were not discharging from their lagoon; I BPJ'ed these
violations as well. It is only recently that I learned from Tom Moore that 0 is not acceptable
for no flow; only "No Flow" should be written in the cell or in eDMR the reason needs to be
chosen from the drop -down menu.
• Wes and I verified the zinc violations against their amended DMRs submitted after Wes'
inspection this year. All zinc violations have been addressed by MRO by issuing NOV-NREs
and they should have a response back to us by early April I believe the 7th if my memory is
good. They ahve been compliant with their zinc limits for the past few months.
Regards,
Marcia
Marcia Allocco, MS - [e-mail]
Senior Environmental Specialist
North Carolina Department of Environment & Natural Resources
Division of Water Resources
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] x2204 Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 2:59 PM
To: Sledge, Bob; Parker, Michael; Allocco, Marcia; Bell, Wes
Subject: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Chemical Specialties Inc. got an NOV for Total Zinc and non -receipt of DMRs(?) from EPA Region 4 dated March 12,
2015. As far as I know, they did not show up on my Tate/missing DMR data pulls last year. I have attached some
compliance history from BIMS for 2014 for your reference which indicates Zinc NOVs but there is missing data for a few
parameters such as BOD and Flow with "No Action BPJ". Not sure if BIMS agrees with everything on the EPA's attached
spreadsheets for missing data. Does anyone have any comments that we can put together to reply to EPA in regard to
the cover letter addressed to the Director?
Hope everyone is having a good one.
Thanks,
Derek
Derek C Denard
Environments: SpeciiaE t
CJCDENR Division of Water Resources
Water Quality Permitting Section
Comp:.arce & Expedited Permitting Unit
[phone]
derekdenard iV nctfenr.goor
1617 kW" Scan^.a Cantar, itaio;g?m, NC 27L99-1fi17
httv/Icotstncdanr.crsiwebMyt`s+s'plps ipdas
2

Denard, Derek
From: Allocco, Marcia
Sent: Wednesday, March 25, 2015 3:47 PM
To: Denard, Derek; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
I wish it was a vacation; slave to my mother after knee replacement #2.
Marcia Allocco, MS - [e-mail]
Senior Environmental Specialist
North Carolina Department of Environment & Natural Resources
Division of Water Resources
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] x2204 Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 3:44 PM
To: Allocco, Marcia; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Marcia,
Thanks for getting back with me. Thought you were on vacation! I believe you have it right by everything you
mentioned below. Maybe worth running this by Jenn and Vanessa about ICIS upload issues. I will get back with
everyone tomorrow.
Derek
From: Allocco, Marcia
Sent: Wednesday, March 25, 2015 3:18 PM
To: Denard, Derek; Sledge, Bob; Bell, Wes
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Hey Derek,
Not in the office so I don't have the specifics in front of me but here is what I remember regarding
my review of the violations.
• There were no late reporting violations that I remember BIMS flagging. This may be related
to non -upload of data to ICIS as per Jenn Smith and Vanessa that they had mentioned related
to some other issues identified by a permittee accessing their compliance history in ECHO. I
would ask Jenn and Vanessa to look into what data has been uploaded to ICIS for this
permit. It highlights a bigger issue in that DWR does not QA/QC the data uploaded to ICIS to
ensure it is accurate and there are no issues.
• I BPJ'ed the nickel and BOD monitoring violations. They are reporting both of these
parameters as Ibs/day which makes, sense_ since almost all other permit limits are in Ibs/day_..
but BIMS is looking for mg/L as the-tsporting units of measure. I was going to contact the
4

-r
permit writer to see what their intent was since there are no units of measure noted in the
issued paper permit for these parameters when I returned but perhaps you can do that since
there is a time -sensitive response.
• They noted 0 on days when they were not discharging from their lagoon; I BPYed these
violations as well. It is only recently that I learned from Tom Moore that 0 is not acceptable
for no flow; only "No Flow" should be written in the cell or in eDMR the reason needs to be
chosen from the drop -down menu.
• Wes and I verified the zinc violations against their amended DMRs submitted after Wes'
inspection this year. All zinc violations have been addressed by MRO by issuing NOV-NREs
and they should have a response back to us by early April I believe the 7th if my memory is
good. They ahve been compliant with their zinc limits for the past few months.
Regards,
Marcia
Marcia Allocco, MS - marcia.allocco(ancdenr.gov
Senior Environmental Specialist
North Carolina Department of Environment & Natural Resources
Division of Water Resources
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] x2204 Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 2:59 PM
To: Sledge, Bob; Parker, Michael; Allocco, Marcia; Bell, Wes
Subject: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Chemical Specialties Inc. got an NOV for Total Zinc and non -receipt of DMRs(?) from EPA Region 4 dated March 12,
2015. As far as I know, they did not show up on my late/missing DMR data pulls last year. I have attached some
compliance history from BIMS for 2014 for your reference which indicates Zinc NOVs but there is missing data for a few
parameters such as BOD and Flow with "No Action BPJ". Not sure if BIMS agrees with everything on the EPA's attached
spreadsheets for missing data. Does anyone have any comments that we can put together to reply to EPA in regard to
the cover letter addressed to the Director?
Hope everyone is having a good one.
Thanks,
Derek
Derek C Denard
Enrironmertal 5periaFat
NCDENR DVaion of Water Re of rces
Water Qaa'rty Perri t ng section
Comolar.ce & Evened Permitting Unit
(9191807-6307
cderektierard@nWert gae
1517Ma: S2n4zaCants.%Ra y27699-117
http:,/,470rhlncdas, Lergfrxatel-'G. A -Al 'npdas
5

•
Y
Denard, Derek
From: Bell, Wes
Sent: Wednesday, March 25, 2015 3:08 PM
To: Denard, Derek; Sledge, Bob; Parker, Michael; Allocco, Marcia
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
CSI was on "inactive" status for many years until end of April 2014 and/or first of May 2014. Since then, they have
discharged and submitted DMRs. What months have they not submitted DMRs.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 2:59 PM
To: Sledge, Bob; Parker, Michael; Allocco, Marcia; Bell, Wes
Subject: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Chemical Specialties Inc. got an NOV for Total Zinc and non -receipt of DMRs(?) from EPA Region 4 dated March 12,
2015. As far as I know, they did not show up on my late/missing DMR data pulls last year. I have attached some
compliance history from BIMS for 2014 for your reference which indicates Zinc NOVs but there is missing data for a few
parameters such as BOD and Flow with "No Action BPI". Not sure if BIMS agrees with everything on the EPA's attached
spreadsheets for missing data. Does anyone have any comments that we can put together to reply to EPA in regard to
the cover letter addressed to the Director?
Hope everyone is having a good one.
Thanks,
Derek
Derek C Denard
Ern,onrtenta'Speda t
NCDENR D i i r, of Water Resources
Water Qivacrty Pero-at/Ng Sector
Comp arse & Exported Permittirg L r t
(91°r E07-6307
dere{derardC ocdenr_gor
1617M IS r caCents%R gh,t4C 7 9-1617
t• ,7)".porta? liccenr.crflNosEl glswpjGs,1npdas
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

Denard, Derek
From: Bell, Wes
Sent: Wednesday, March 25, 2015 3:14 PM
To: Denard, Derek; Sledge, Bob; Parker, Michael; Allocco, Marcia
Subject: RE: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
The Division placed CSI on inactive status...a.k.a. waived the monthly monitoring and operator visitation requirements
by letter dated 6/26/2006. They facility had not reported a discharge since June 2003 and only began discharging last
year at the end of April 2014.
From: Denard, Derek
Sent: Wednesday, March 25, 2015 2:59 PM
To: Sledge, Bob; Parker, Michael; Allocco, Marcia; Bell, Wes
Subject: EPA NOV 03-12-15 for NC0006531 Chemical Specialties Inc.
Chemical Specialties Inc. got an NOV for Total Zinc and non -receipt of DMRs(?) from EPA Region 4 dated March 12,
2015. As far as I know, they did not show up on my late/missing DMR data pulls last year. I have attached some
compliance history from BIMS for 2014 for your reference which indicates Zinc NOVs but there is missing data for a few
parameters such as BOD and Flow with "No Action BPJ". Not sure if BIMS agrees with everything on the EPA's attached
spreadsheets for missing data. Does anyone have any comments that we can put together to reply to EPA in regard to
the cover letter addressed to the Director?
Hope everyone is having a good one.
Thanks,
Derek
Derek C Denard
Environmental Speca`st
NCDENR Dnrsor of Water Resources
Water Q4a=rty Permtthrg Secret-.
Compliance & Expec:ted Rerrn`,ttsrg Unit
[phone]
[e-mail]
1517 Mal Sardca Canter, Ra ,g h, } iC 27 99-1e1;
ht•.p'+pertalncaanr.crg,'Arti q/rwFY'PV^0,0
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
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