NC0006351_Compliance Evaluation Inspection_20170622

z.
Water Resources
Environmental Quality
June 22, 2017
Mr. Jeff Bruening
EHS Manager
Chemical Specialties, LLC
Post Office Box 1330
Harrisburg, North Carolina 28075
SUBJECT: Compliance Evaluation Inspection
Chemical Specialties, LLC
NPDES Permit NC0006351
Cabarrus County, NC
Dear Mr. Bruemng:
ROY COOPER
Governor
MICHAEL S. REGAN
Secreory
S. JAY ZIIVIMERMAN
Director
RECEIVEMCDEWWR
JUL 06 2017
'dater Quality
Permitting Section
On June 15, 2017, Roberto Scheller of this Office conducted a compliance inspection at the
subject facility. This inspection was conducted as Compliance Evaluation Inspection (CEI) to
insure compliance with permit requirements and conditions. At time of inspection the wastewater
treatment facility appeared to be well maintained and operated. We wish to thank you and the
operating staff for their assistance regarding this inspection.
It was noted during inspection that the 2 -acre storage lagoon only had 7 inches of freeboard
Lagoon should have, at a minimum, enough storage capacity to hold a 24-hour storm event.
Typical treatment lagoon freeboard is 18 inches. Please be advised that in accordance with your
NPDES Permit NC0006351, Part II, Section C, 2. Proper Operation and Maintenance, "The
Permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control...". Item 3. Need to Halt or Reduce not a Defense, "It shall not be a defense for a
Permittee in an enforcement action that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the condition of this permit [40 CFR
122 42 ©]."
The enclosed report should be self-explanatory; however, should you have any questions, please
do not hesitate to contact myself or Roberto Scheller at [phone] or
[e-mail].
Sincerely,
V,C, W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
''Nothing Compares
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

Enclosed
cc. Wastewater Branch
File
rls

United Slates 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 1 2 15 I 3 I NC0006351 I11 12 17/06/15 17 18 � I 19 G 201
211111 1 1 I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -----Reserved— ---
I80
I 72 �, 73 I I 174 751 I I I I 1__U80
67 70 71 J
IJ I I I
Section B FacilityDataL�
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 OOAM 17/06/15
14/05/01
Chemical Specialties, LLC
Exit Time/Date
Permit Expiration Date
5910 Pharr Mill Rd
12 28PM 17/06/15
18/11/30
Harrisburg NC 28075
Name(s) of Onsite Representative(s)fritles(s)/Phone and Fax Number(s)
Other Facility Data
Jonna A Stein/ORCf704-455-4171/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jonna A Stein,PO Box 1330 Harnsburg NC 28075/Interim Site
No
Managerf104-455-4171 /7044556507
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N 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(s) Agency/Office/Phone and Fax Numbers Date
-Roberto Scheller MRO WQ//252-946-6481/
Signature of Management Q A Agency/Office/Phone and Fax Numbers Date
W Corey Basinger 1 1 Q//704-235-2194/ i.9 •�1 - 1•—'/
P�%R
.�
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete
Page#

NPDES yr/mo/day Inspection Type
NC0006351 I� 121 17/06/15 117 18 ICI
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit NC0006351 Owner - Facility Chemical Specialties, LLC
Inspection Date 06/15/2017 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 ❑ ❑
M
❑
application?
Is all required Information readily available, complete and current?
0
❑
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?
0 ❑
❑
❑
Is the Inspector granted access to all areas for Inspection?
0 ❑
❑
❑
Comment The current permit was Issued on May 1
2014 and expires on November 30, 2018 The
Company continues to evaluate potential options to upgrade wastewater treatment facilities
Name of Individual performing the sampling
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required Information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab reg required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
❑
❑
❑
❑
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?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility Is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
M
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
M
❑
❑
❑
Is a copy of the current NPDES permit available on site?
M
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
❑
Comment Records reviewed were well organized and maintained
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑
Page# 3

Permit NC0006351 Owner - Facility Chemical Specialties, LLC
Inspection Date 06/15/2017 Inspection Type Compliance Evaluation
Yes No NA NE
Is composite sampling flow proportional?
❑
Laboratory
Yes No NA NE
Are all other parameters(excluding field parameters) performed by a certified lab?
N
❑
❑
❑
# Is the facility using a contract lab?
N
❑
❑
❑
# is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
0
❑
❑
❑
Celsius)?
# Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
❑
❑
❑
Incubator (Fecal Coliform) set to 44 5 degrees Celsius+/- 0 2 degrees?
❑
❑
M
❑
Incubator (BOD) set to 20 0 degrees Celsius +/- 1 0 degrees?
❑
❑
0
❑
Comment On-site laboratory (Certification # 526) performs analyses for pH, metals, ammonia, total
suspended solids Pace Analytical Services (Certification # 40) perform analyses for BOD
and toxicity
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable ❑ ❑ M ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
❑
Is sample collected below all treatment units?
Yes No NA NE
❑
❑
❑
Is proper volume collected?
M
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
❑
❑
❑
❑
Celsius)?
❑
Is the facility sampling performed as required by the permit (frequency, sampling type
M
❑
❑
❑
representative)?
Comment Current permit reoulres all samples be collected qrab and Chronic Toxicity collected b
composite sample Facility discharges on a batch basis with effluent discharge
pump
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
i
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment Flow meter Is located at effluent
Lagoons
Yes No NA NE
Page# 4

Permit NC0006351 Owner -Facility Chemical Specialties, LLC
Inspection Date 06/15/2017 Inspection Type Compliance Evaluation
Lagoons Yes No NA NE
Type of lagoons?
# Number of lagoons In operation at time of visit? 1
Are lagoons operated In?
# Is a re -circulation line present?
❑
❑
M
❑
Is lagoon free of excessive floating materials?
0
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
❑
❑
M
❑
Are dike slopes clear of woody vegetation?
❑
0
❑
❑
Are weeds controlled around the edge of the lagoon?
M
❑
❑
❑
Are dikes free of seepage?
M
❑
❑
❑
Are dikes free of erosion?
M
❑
❑
❑
Are dikes free of burrowing animals?
M
❑
❑
❑
# Has the sludge blanket In the lagoon (s) been measured periodically In multiple
❑
❑
❑
locations?
# If excessive algae Is present, has barley straw been used to help control the growth?
❑
❑
0
❑
Is the lagoon surface free of weeds?
0
❑
❑
❑
Is the lagoon free of short circuiting?
M
❑
❑
❑
Comment Woody vegetation growing on dike should be removed
It was noted at time of Inspection that there was approximately 7 Inches of
freeboard In
lagoon
Page# 5