NCS000064_Compliance Evaluation Inspection_20231130

Compliance Inspection Report
Permit:NCS000064 Effective: 04/09/18 Expiration: 03/31/23 Owner: C N A Holdings LLC
SOC: Effective: Expiration: Facility: Celanese Shelby Facility
County: Cleveland 2525 Blacksburg Rd
Region: Mooresville
Grover NC 28073
Contact Person:Lawrence Wolnik Title: Phone: [phone]
Directions to Facility:
Take 1-85 towards Spartanburg,take exit 2 NC-216 toward Kings Mtn. Park,Turn Right onto Battleground Road (NC-216),turn Left
onto S. Battleground Ave, right onto Carolina Ave(becomes Cleveland Ave), Left onto Lavendar Rd, Right onto Blacksburg Rd.
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 11/30/2023 Entry Time 01:OOPM Exit Time: 03:OOPM
Primary Inspector:Jerry W Eplin Phone: [phone]
Secondary Inspector(s):
Kathryn S Peterson
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
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Permit: NCS000064 Owner-Facility:C N A Holdings LLC
Inspection Date: 11/30/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On November 30, 2023, a compliance evaluation inspection was completed by Jerry Eplin and Kathryn Peterson of DEQ.
Eric Johnson and Randy Turner from CNA Holdings were present for the inspection.
Facility records were not well organized. The version of the SWPPP provided during the inspection had not been reviewed
within the last year. After the inspection, Mr. Johnson provided a more recent version of the plan that had been reviewed
within the last year. Likewise, training records were not available on site, but were provided shortly after the inspection by
email.
The facility is conducting analytical monitoring and qualitative monitoring. However, better follow up is needed for potential
issues identified in the qualitative monitoring. Records indicating a light odor and indicating poor clarity were present in the
qualitative monitoring, without documented follow up actions. When a potential issue is identified via qualitative monitoring,
follow up actions should be well documented and should be maintained with the SWPPP.
The stormwater outfalls were observed during the inspection and no issues were identified. Construction was occuring near
one outfall under an approved Erosion and Sediment Control Plan.
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Permit: NCS000064 Owner-Facility:C N A Holdings LLC
Inspection Date: 11/30/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment: Organization of records should be improved. The version of the SWPPP reviewed on-site had
not been updated within the past year. After the inspection, the permittee provided
documentation that a newer SWPPP exists and provided a copy. Training records were not
available during the inspection, but were provided after the inspection.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment: Follow up to qualitative monitoring needs to be improved. When Qualitative Monitoring
indicates a potential issue, documentation of the facility responded is required and should be
kept with the SWPPP. Qualitative monitoring records indicating a light odor and indicating
clarity levels of 3 and 4 were observed without documented follow up actions.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
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