NCS000386_MCSWS Cover Letter and Report_20140826

Charlotte -Mecklenburg
�,
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August 26, 2014
Jamie Watts, EH&S Delivery Leader
Rohm and Haas Chemicals, LLC
6101 Orr Road
Charlotte, NC 28213
Subject: Industrial Facility Inspection
Rohm and Haas Chemical, LLC
Dear Mr. Watts:
700 North Tryon Street
Charlotte, NC 28202
Fax [phone]
On August 20, 2014, Jonathan Beller of Charlotte -Mecklenburg Storm Water Services
(CMSWS) conducted an inspection of the above referenced facility as a requirement of the City
of Charlotte's NPDES Permit, NCS000240, Part II Section H. Inspection authority is granted by
Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility
was observed to be in compliance with the City of Charlotte Storm Water Pollution Control
Ordinance.
The inspection was also conducted as part of a cooperative working agreement between
Mecklenburg County and the North Carolina Department of Environment and Natural Resources
(NCDENR) — Division of Energy, Mineral and Land Resources (DEMLR). NCDENR —
DEMLR has been copied on this report and made aware of the following observations regarding
the facility's NPDES stormwater permit:
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and
implemented.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded.
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded. Temperature of pH sample is not to be
adjusted prior to analysis. See attached "Technical Assistance for Field Analysis of pH"
document for procedures.
Thank you for the assistance and cooperation with the site inspection. The att
ached
report provides details about inspection observations and should be self-explanatory. Please
contact me at 980-721-9361 if you have any questions or need additional information. For
questions specifically regarding your NPDES stormwater permit, please contact Donna Hood
with NCDENR — DEMLR at [phone].Wm
•
To report pollution or drainage problems, call: 311
http://s tormti�ater.charmeak.org �'
cennr cn11r.

vh,. Jamie Watts
Page 2
8/26/14
Sincerely,
p3L�_
Jonathan Beller
Sr. Environmental Specialist
Charlotte -Mecklenburg Storm Water Services
cc: Craig Miller, Charlotte Storm Water Services
Erich Schweiber , NCDENR — DEMLR
Attachment: Technical Assistance for Field Analysis of pH

North Tryon Street
STORM
r ,
ME
WATER Eadlitv lnoaectim 1
4.336,4391
Facility Name: Rohm And Haas Chemicals LLC
s
To report pollution 5
Inspection ID: 15226
Contact: James Watts
Permit #: NCS000386
Inspector: Jonathan Beller
Receiving Stream: BRIAR
Inspection Date: 08120/2014 Entry Time:
9:00 am Exit Time:
12:30 pm sic #:
Facility Description: Rohm and Haas
Chemicals LLC operates a ten -acre manufacturing plant that manufactures
water-based emulsions of vinyl acetate, acrylic homopolymers, copolymers and thickeners. Wastewater is collected;
treated, and discharged to the sanitary
sewer.
File Review/History: A review of CMSWS databases and files was conducted prior to the inspection. The facility was
last inspected by CMSWS on April 10,
2010. No violations
were noted during the previous inspection.
Inspection Summary: Please see the
recommendations in
the report.
Site`Inspection`De%ficiencyComment'
Stormwater system (catch basins,
No
inlets, outfalls, etc.)
Erosion issues
No
Structural stormwater BMPs
No
Two retention basins are located on the property where storm
water is collected prior to being released via outfall 001.
Illicit discharges/connections
No
Aboveground storage tank(s) - list
No
tank sizes & contents
Underground storage tank(s) - fill
No
port area; list tank sizes & contents
Outdoor material storage area(s)
Recommendation
CMSWS recommends the facility move their 275 gallon
intermodal containers to an area on the property that would
drain to the facilities wastewater pre-treatment system if
compromised.
Outdoor processing area(s)
No
Loading/unloading area(s)
Recommendation
Service the rail car loading arm to prevent product from
dripping onto the gravel railway. Product was observed
solidified on the gravel near the rail car loading area. This
would not be considered a threat to stormwater based on the
nature of the product.
Vehicle/equipment area(s) - fueling,
No
Gear box maintenance is performed primarily done indoors.
washing, storage, etc.
No deficiencies were observed.
Oil/water separator and/or
No
pretreatment
Waste storage/disposal area -
No
dumpsters, scrap metal bins, etc.
Food service area(s)
No
or drainage problems call: 311
http://stormwater.charmeck.org .`,��°
CRARLOTTIij,.
a126/2014 2:06:04PM
Page 1 of 3

Sitelnspection
%
"Deficiency Comment
Indoor material storage area(s)
Recommendation
Water was present on the floor of the storage area due to a
small leak in the roof. There was a berm at the entry point of
the storage area to prevent spills from leaving the building. A
hole was also observed at the rear of the building near floor
level. CMSWS recommends that the roof be repaired to
prevent water ponding in the containment area and that the
hole in the back of the building be sealed to prevent a by-pass
of the containment area.
Indoor processing area(s)
No
Floor drains
No
Floor drains are connected to onsite wastewater pretreatment
system.
Spill response equipment
No
Stormwater Pollution
Plan Observed
%Comment
Does the facility have a stormwater
Yes
pollution prevention plan?
General location (USGS) map
Yes
Narrative description of practices
Yes
Detailed site map
Yes
List of significant spills (past 3 years)
Yes
Non-stormwater discharge
Yes
evaluation of outfall(s)
Feasibility study
Yes
All necessary secondary
Yes
containment provided
Collected water evaluated and
Yes
documented prior to release
BMP Summary
Yes
Spill prevention and response plan
Yes
Preventative maintenance and good
Yes
housekeeping plan
Facility provides and documents
Yes
employee training
List of responsible parties
Yes
Reviewed and updated annually
Yes
Stormwater facility inspection
Yes
program conducted semi-annually
Qualitative/Analytical Monit%oring . Ob%served%%,
Comment
Qualitative monitoring conducted
Yes
semi-annually
Analytical monitoring conducted
Yes
Temperature of pH sample is not to be adjusted prior to
semi-annually
analysis. See attached "Technical Assistance for Field
Analysis of pH" document for procedures.
Analytical monitoring from vehicle
N/A
maintenance
Permit and Outfalls
:% %%Observed
'%%
Comment ,
Copy of permit and certificate of
Yes
coverage onsite
All outfalls observed
Yes
No issues observed at outfall 001 or outfall 002.
Representative outfall status
N/A
documented by NCDWQ
Annual no -exposure self
N/A
re -certification documented
Additional Findings Observed Comment
Observation(s)
No
•
To report pollution or drainage problems call: 311
http:!lstormwater.charmeck.org ``,lr�b
CUMLOTTE.
8/26/2014 2:06:04PM
Page 2 of 3

Additional Findings: ' Ob%served ..% Com%ment
Observation(s)
No
pollution
Observation(s)
INo
or
Phase IhP%eemit Require%ments%%
Obse%rved%
%Comment
Wastes removed from the MS4
N/A
311
properly disposed
http://stormwater.charmeck.org
Public transportation (roadway)
N/A
projects constructed within the last
year
Curb miles and parking lots swept
N/A
documented
Catch basin and storm drain pipe
N/A
cleaning documented
Records of pesticide/herbicide
N/A
applicator licenses maintained for
staff and contractors
If pesticide treatment areas
N/A
exceeded, was permit application
submitted?
Pesticide limitations in Goose Creek
N/A
Watershed followed
To
report
pollution
or
drainage
problems
call:
311
http://stormwater.charmeck.org
8/26/2014 2:06:04PM Page 3 of 3

This document is intended to provide technical assistance and guidance for the measurement of pH. This is not meant to be a
substitute for the method, but is offered as a guide to the method.
HOLDING TIME:
• Samples must be analyzed within 15 minutes of collection.
METER CALIBRATION:
• The meter must be calibrated prior to the analysis of samples.
• If compliance samples are analyzed throughout the day, a post calibration check (e.g., 7 buffer) must be analyzed mid-
day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day).
For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 142 equipped with a
temperature compensation device. Follow all manufacturers' recommendations for the calibration of the meter each
analysis day. In all cases, the meter must be calibrated with at least two buffers. Calibrating with the pH 4 and pH 10
buffers meets standard methods requirements and brackets the pH range for most monitoring (with the exception of
sludge) scenarios. The calibration; however, must bracket the range of the samples being analyzed. In addition to the
calibration standards, the meter must be verified with a third calibration standard (e.g., pH 7 buffer).
• In order to meet the above-specified criteria, the standard must read within a range of pH 6.9 to 7.1 to be acceptable.
General Information:
• Samples shall be gently stirred during measurement.
• The electrode must be rinsed and blotted dry between measurements.
All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or
NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature
results. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter
against a NIST certified or NIST traceable thermometer and record the two temperatures. The thermometer/meter
readings must be less than or equal to 1•C from the NIST certified or NIST traceable thermometer reading. The
documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was
used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate
sheet to be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.)
The following must be documented whenever sample analysis is performed.
1. Time and date of sample collection
2. Time of calibration
3. Time and date of analysis (to verify 15 minute holding time is met)
4. Collector's/analyst's name
5. Value of buffers used for calibration
6. Value obtained for check buffer (e.g., pH 7 buffer)
7. Sample location/site
8. Post calibration checks (if applicable)
9. Report all data values to the nearest 0.1 pH unit.
10. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be
retained for 5 years).
11. Traceability for chemicals, reagents, standards and consumables
Ref: Standard Methods, 18th Edition -Method 4500-H* B. Ref: Standard Methods, 18th Edition -Method 2550 B.
Rev. 07/2010