NCS000064 2007 Staff Report

NCS 000064
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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleco H. Sullins, Deputy Director
Division of Water Quality
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
CNA Holdings, Inc. - TICONA
NPDES Permit Number:
NCS000064 =`
Facility Location:
Shelby, NC (Cleveland County)
Type of Activity:
Resin manufacturing
Receiving Streams:
See Figure 1 �' v
River Basin:
Broad River Basin, Sub -basin 03-08-05
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
lYowfi 11) dmn
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Description of Onsite Activities:
This facility manufactures semicrystalline "engineering resins", which differs from amorphous resins. These are such
materials as acetal copolymers, liquid crystal polymers, long -fiber reinforced thermoplastics and ultra-high molecular
weight polyethylene.
• Vectra® LCP: A liquid crystal polymer.
• Polyester products: Celanex® PBT, Impet® PET, Vandaa Polyester Alloys and Riteflex® Polyester
Elastomer
• Compounds of Vectra® and the polyester products (such as fiberglass compounds). `\_
Documents Reviewed:
• NPDES Stormwater Permit Application Materials �*
• Stormwater Permit File a`T 2c
• Broad River Basinwide Plan
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft \
• Check 40 CFR Subchapter N, Stormwater Effluent Guidelines
History: Vy 'y
• 31 August 1994: Permit issued to Hoechst Celanese Corporation (same address). Analytical mons oring
required with cut-off concentrations: TSS (100 mg/L), TKN (20 mg/L), BODS (30 mg/L), COD (120
mg/L), MBAS (0.50 mg/L), Phenols (no cut-off), Total Lead (0.033 mg/L), Bis (2-Ethylhehyl) phthalate (10
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748

NCS000064
ug/L). Visual and vehicle maintenance monitoring were also required.
a 23 December 1997: Name change from "Hoechst Celanese Corporation" to "HNA Holdings, Inc."
a 30 December 1997: The Division changed the name on the COC.
a 24 March 1999: Facility applied for a permit renewal.
a 29 July 1999: Name change from "HNA Holdings, Inc." to "CNA Holdings, Inc.".
a 1 August 2000: Permit issued to "HNA Holdings, Inc." (Note that this was incorrect according to the
record on file. No further correspondence regarding fixing this error is on file.) Analytical monitoring was
required, quarterly in the 4s' year (no cut-off concentrations). Parameters unchanged. Qualitative and
vehicle monitoring also required.
a June 2001: Discussions with permittee about second containment of their recycled process water. Division
approved their request to not have secondary containment for this water.
a 2 February 2005: Submitted permit renewal application. "CNA Holdings, Inc. – TICONA" is listed as the
facility name. "CNA Holdings, Inc." is listed as the owner. The permittee requested that three additional
waste streams be specified in the permit, 1.) Water mixed with spring water, 2.) Firewater, and 3.) Recycle
process water.
�— -- —
Central Office Review Summary:
General Observations: My main concern is that there are actually two companies onsite that are operating under this
permit. Originally, the two were a single company. Now, the other company, Invista, is a separate entity. The
permittee explained to me that Invista does not have outfalls, and therefore shares outfalls with CNA Holdings and
discharges under the CNA permit. The original permit was written to cover the combined operations of Invista and
CNA Holdings (which were a single company at the time). The companies split in 1998, but it does not appear that
the changes at the facilities were understood at that time. The analytical parameters were unchanged in the 2000
permit. I would recommend that Invista have its own permit covering its own discharges. I have written the current
draft to reflect only parameters of concern for operations at CNA Holdings. However, I am uncertain as to how to
create outfalls for Invista. A site visit is recommended to investigate this situation.
2. Impairment: Buffalo Creek is not impaired or listed as a concern in the Broad River Basinwide Plan.

' NCS000064
3. Changes Since Previous Permit: There have not been significant changes since the previous permit, however it
appears that changes prior to the 2000 permit's issuance were not considered at that time and should be
considered now. The permittee has requested that three additional sources of water be added to the permit. The
first source, water mixed with spring water comes from an unidentified source of water flowing to the north
outfall (-6-7 gpm). This may be either a spring or a leaking water line that can not be found. The second water
source is fire water, which is contact quenching water mixed with clean water streams -usually from their lake.
The third water source is recycle process water (Buffalo Creek water mixed with contact quenching water).
Normally, process water is treated and discharged under their NPDES effluent limits. She was concerned that
when a pipe breaks and water leaves the site, that they are in violation of their stormwater permit. I explained to
the permittee that this permit does not cover wastewater.
4. Analytical Monitoring: The East outfall has high COD and BODS. The permittee does not know the source of
the problem.
5. Qualitative Monitoring: Qualitative monitoring is not summarized in this report. It did not show any signs of
concern.
Revised Permit Recommendations: Analytical Monitoring:
1. TKN, MBAS, Phenols, Total Lead, and Bis (2-Ethylhehyl) phthalate have been removed. These chemicals are
not used at CNA Holdings.
2. pH has been added to the analytical monitoring requirements.
3. Due to a potential lag time between the expiration of this permit and its renewal, I have specified in the permit
that the permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables
1, 4, and 5. This approach is recommended because there has been a significant lag time since the expiration of
the previous cycle. This will provide testing if there is a lag in future timeframes. "Measurement Frequency: All
analytical monitoring will be performed two times per year for each year until either another permit is issued for
this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle, the permittee has
submitted the appropriate paperwork for a renewal application before the submittal deadline, the permittee will
be considered for a renewal application. The applicant must continue semi-annual analytical monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle."
4. Benchmarks have been added to this draft permit.
5. All analytical monitoring has been set to semi-annually.
6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters are in this permit, however.) (There was no flow requirement in the previous permit.)
7. The permittee is required to collect all of the analytical monitoring samples during representative stone events as
defined in this permit. Qualitative monitoring does not have to be performed during a representative storm
event.
Other Proposed Changes to the Previous Permit:
1. Part II Section A has been revised. It now specifies all of the items to include on the site map.
2. Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring.
3. I will mention in the cover letter that Form SWU-242-020705 is available for qualitative monitoring.
4. I will mention in the cover letter that this permit does not address 1.) Unknown sources of discharge water,
2.) Fire water, or 3.) Recycle process water.

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' NCS 000064
3. Which of the materials listed as products on your website are manufactured at this facility?
a. ANSWER: They manufacture Vectra (a liquid crystal polymer), polyester polymers, and compounds of
these substances (compounded with fiberglass, etc).
4. Is Bis(2ethyl hexyl) Phthalate used onsite? Other phthalates? What is it used for?
a. ANSWER: There are two companies on this site. They used to be a single company. The other company,
Invista, discharges through CNA Holding's outfalls. (Invista does not have its own permit.) Before the split
in 1998, the stormwater permit addressed all of the testing parameters for the facility. Bis(2ethyl hexyl)
Phthalate was used at the Invista portion of the site. CNA uses dimethyl phthalate, but this is liquid only
when molten and would therefore not be a stormwater contaminant.
5. You are currently required to report on lead, phenols, MBAS, and TKN. What are the sources of these materials at
your facility? You have had very low analytical results for them, and these are not part of the EPA Sector -Specific
Permit. Do you have zinc onsite? EPA recommends zinc testing.
a. ANSWER: Phenols are a contaminant of one of their byproducts. After it is made, it is stored in a tank with
secondary containment. (Phenols had very low analytical data.) Lead is not used in their process. She does
not know why lead was added initially. (Lead had very low analytical data.) She does not know the source
of MBAS onsite. When Invista was a part of the company, she reports that they had emulsions and
surfactants in their process. MBAS are not used at CNA. (However, this still appears in their stormwater
because Invista discharges to CtV). The only nitrogen used onsite is stored as liquid nitrogen and used as
nitrogen as `�
g g (N2). This is inside secondary containment. She does not know why TKN was added initially.
The facility does not use zinc.
6. You reported several values for BODS at your East outfall to be "560", ">58", and ">55". Is this a typo?
a. ANSWER: She believes it is a typo, and that the numbers should be 60, 58, and 55, respectively. These
numbers are above are current benchmark but they are in-line with COD values found at the same outfall for
the same rain event.
7. What do you think could be causing high COD at your East outfall?
a. ANSWER: She does not know why it is high. They dredged out the Swale that flows to the East outfall a
few years ago (prior to this sampling). They replaced over -grown weeds with rip -rap. This facility was
designed to contain and treat the first inch of rain (which they did voluntarily). So, she does not know why
their discharge would have any high numbers.
8. You have requested that three additional sources of water be added to your permit. Water mixed with spring water
comes from an unidentified source of water flowing to the north outfall (-6-7 gpm). This may be either a spring or a
leaking water line that can not be found. The second water source is fire water, which is contact quenching water
mixed with clean water streams -usually from their lake. The third water source is recycle process water (Buffalo
Creek water mixed with contact quenching water): Your application says that "water" is used for quenching
polymers and plastic resins. It is circulated back to two large clarifiers where it is treated with ferrous sulfide and a
flocculant. It then goes through seven anthracite coal filters, and then stored until it is re -used. Are you asking for
this process water to be allowed to leave the site?
a. ANSWER: The process water normally either continues in the recycle loop or is eventually treated and
discharged under their NPDES effluent limits. However, on occasion a line will break and they will have a
discharge. The concern about a line breaking is for both the fire water and the recycle stream. After
discussion, I explained to her that the stormwater permit does not cover process water discharge.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748

Discussions with permittee: Pem Carter, 704.480.4900, 6 May 2007
1. Permitting options onsite:
a. Pursue to separate permits for the two businesses: This is not an option
because the stormwater is co -mingled.
b. Pursue a co -permit for the two businesses
c. Pursue a single permit in one company's name: CNA Holdings will be the
owner of the permit.
Can you provide a contact name for Invista so that we can determine the possible
chemical components of their stormwater?
a. Pem explained that all of the chemical components that would be present
in the stormwater would originate from CAN Holdings. All of Invista's
manufacturing is inside. NP
b. CNA owns the land. Invista is a tenant of a small portion of the site.

NCS000064
Recommendations: Based on the documents reviewed, the application information submitted on 2 February
2005sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Q Date
Stormwater Permitting Unit Supervisor / Date 7
> si �1i21(e) a+ne7i
Concurrence by Regional Offic�/y� Date / A z -&l
Water Quality Supervisor Date
Regional Office Staff Comments
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