NCS000064_Tier2Notification_20241021

Eplin, Jerry W
From: Wolnik, Lawrence, Celanese <[e-mail]>
Sent: Monday, October 21, 2024 5:09 PM
To: Eplin, Jerry W; [e-mail]; Eplin, Jerry W
Cc: Shipman, Craig, Celanese
Subject: [External] Celanese Shelby Stormwater Tier 2 Notification
Attachments: 10 21 24 Total Copper Exceedance Response.pdf
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Mr. Eplin and Ms. Peterson,
Please find attached Tier 2 stormwater notifications for exceeding copper benchmarks.
Feel free to contact me with any questions.
Regards,
Larry Wolnik
Site Director
Celanese—Shelby Plant
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Celanese
The chemistry inside innovatiorf
2525 Blacksburg Road
Grover, NC, USA 28073
Office+1-704-480-5728
Mobile[phone]
[e-mail]
www.celanese.com
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Celanese
The chemistry inside innovation
Celanese-Shelby Facility
(CNA Holdings LLC, -Ticona)
2525 Blacksburg Road
Grover, NC 28073-9641
October 21, 2024
North Carolina Department of Environmental Quality
Mooresville Regional Office
Attn: Ms. Kathryn Peterson
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Ms. Peterson,
The 3"'quarter Stormwater Discharge Outfall Monitoring Report for the North outfall sample collected
on 9/17/24 and reported to our ORC on 10/7/24 resulted in a higher than normal level of Total Copper at
13.4 Ug/I. Since this exceeds the benchmark value of 10 Ug/I,as defined in Table 2 of Permit NCS000064
for CNA Holdings, LLC at 2525 Blacksburg Road in Grover, North Carolina,we are notifying the Division's
Mooresville Regional Office as defined in section D-6 Tier Two Response. The second quarter results for
Total Copper were also high,at 21.4 Ug/I.
Until the copper levels are reduced, we will continue to sample monthly at the north outfall as rainfall
allows.
A Stormwater Management Inspection was completed on 10/21/24 with the following individuals
participating in the inspection:
Craig Shipman--Stewardship Manager Randy Turner—ORC
Michael Blanton—ORC Backup Nathan Bradshaw—Tank Farm
During the inspection, no causes were identified as potential contributors to the measured exceedance.
Since copper is not a raw material intended to be used in our process, we have not yet been able to
identify a definite source. However,one suspected contributor is the laydown area which is on the
correct side of the property to contribute if any copper is leaching from materials from the past.
Another potential change that could be impacting the system is the change in the flow of stormwater on
this side of the property based on the permitted project to redesign the hydrology on this side of the
property and north outfall. It is possible that higher than normal copper levels are in the soil that has
been disturbed and that could be contributing to the results. We are planning on sampling the soil and
testing it for copper levels and we will capture a rainwater sample during the next significant rainfall to

Celanese
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see if there is any contribution from that as a source. As results are collected from these different
potential sources, we will include that as updates along with the copper reporting.
Should you have questions or need additional information regarding corrective actions taken or to be taken
by the Facility, please contact me at(704)480-5728 or via e-mail at [e-mail].
Sincerely,
0 �d'p- W4,
Larry Wolnik
Site Director