NCS000037_Complaince_20091119

XLTX
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 19, 2009
Mr. Gilbert Insley
Clariant Corporation
625 East Catawba Avenue
Mount Holly, NC 28120
Subject: Compliance Evaluation Inspection
NPPFS Stormwater NOSOC 00'. 7
Clariant Corporation
Mt. Holly Facility
County
Dear Mr. Insley: (GP.c 1bU-t
On November 17, 2009, Ms. Dee Browder from the Mooresville Regional Office of the Division of Water Quality
conducted a site inspection of the permitted facility. The site drains to the Catawba River.
Accordingly, the following observations were noted during the Division of Water Quality inspection.
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ® No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ® No ❑
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ❑ NA x❑'.
Also, see attached iiispectiolI report for site Specific, oomments Thank you for the. assistance. and cooperation
during this inspection. Overall, the facility's Stormwater program was well developed and implemented and
this Office commends the permittee's efforts to ensure compliance with your NPDES permit.
If you have any questions, comments, or need assistance with understanding any aspect of your permit,
please do not hesitate to contact me at [phone].
Sincere) --- '
f Al
F
I
B. Dee Browder, Environmental Engineer
Mooresville Regional Office
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville; NC 28115 �TOne 1
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 1 v o thCarolina
Internet: www.ncwaterquality.org
/ atimallil

ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicable to both the general permits and
individual stormwater permits is the requirement to develop and implement site -specific comprehensive
stormwater pollution prevention plans (SPPP). These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following webpage:
IIt[p.//l120.ellr.State.Ilu.us/su/f-oiifis Ducuineiits.Iihrl Pcii tlt toxt, teclrllival bulletins, disuhaiye inuNtumig
forms, and a Notice of Intent [which is the application of for coverage under a NPDES General Stormwater
Permit] can be found at this web site.
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. That said, please see
the above mentioned web site in order to obtain a copy of the permit such that you may fully comply with all the
conditions therein. Failure to properly comply with conditions of the permit, like those bulleted below,
constitutes violations and are subject civil penalty assessment of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by the filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and'a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked
• Any other point source: dischargu to :surface water of the state is prohibited unless it is an allowable
non-stormwater discharge or is covered by another peri nit, autlruiitutiuii or uppr oval.
• There are currently 19 active general permits. Permit conditions vary accordingly; however, most of the
permits have following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
o Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting and recording of Qualitative Monitoring
o Collection, reporting and recording of Vehicle Maintenance Monitoring
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
One
NorthCarohna
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o Records — Visual monitoring shall be documented and records maintained at the facility along
with the Stormwater Pollution Prevention Plan. Copies of the analytical monitoring results shall
also be maintained on sito. The Pormittoo shall rotain records of all monitoring information,
including all calibiatiun arid rriaiii[eiiarlce records acid all uiigirlal strip chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this general permit
for a period of least 5 years for the date of the sample measurement, report or application.
o Expiration — The permittee Is not authorized to discharge after the expiration date of the general
permit. In order to receive automatic authorization to discharge beyond the expiration date, the
permittee shall submit forms and fees as are required by the agency authorized to issue permits
no later than 180-days prior to expiration date. Any permittee that has not requested renewal at
least 180 days prior to expiration, or any permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will be subject to
enforcement. Failure to renew your permit is a violation.
o Transfer — The Certificate of Coverage (COC) issued pursuant to this general permit is not
transforablo to any porson expect after notice to and approval by the Director The Director may
require Inudiflcatiulr or revuualluii acid ieissualtue of the Gellifivate of Coverage to cllarlye llle
name and incorporate such other requirements as may be necessary under the Olean Water
Act. The Permit Is NOT transferable.
o Name Change, Closure or Facility Ownership change — Permittee is required to notify the
Division in writing in the event the permitted facility is sold or closed. The Division of Water
Quality views changes of name or ownership as a modification that requires the Director's
approval and reissuance of the permit. Name and ownership changes required you to complete
a Name/ownership Change Form from the Division and mail it back to the Division of Water
Uuality along with all appropriate information.
o Proper Operation and Maintenance is a requirement of the permit.
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterqualit .org
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NorthCarolina
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Permit: NCS000037
SOC:
County. Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 06/01/03 Expiration: 04/30/08 Owner: Clariant Corporation
Effective: Expiration: Facility: Mount Holly East (MHE) Facility
PO Pox 660246
Charlotte NC 28266
Contact Person: Bill Archer Title: Phone: [phone]
Directions to Facility:
From the intersection of NC Hwy. 27 and NCSR 1666 (Mt. Holly-Huntersville Road), travel west on NC Hwy. 27 approximately 0.2
miles. The entrance to MHE is on the left (south) side of the road.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORG(s)-
On-Site Representative(s):
Related Permits:
Inspection Date: 11/17/2009
Primary Inspector: Uee browder
Secondary Inspector(s):
Entry Time: 01:30 PM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Exit Time: 04:30 PM
Phone. 704 GG3 1G99
Ext.2203
Inspection Type: Compliance Evaluation
Page:1

Permit: NCC000007 Owner- raeility: Clariont Corporation
Inspection Date: 11/17/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The faoilily hnd a amnll release prior to the in.speotion An evaluation of the oporational proeeedures revealed that tho
roof could potentially have small amounts of process porduct given the occasional "burping" of the presurized plumbing
system. The roof drains will be re-routed to the VW TP.
There was no eveidence of residual product at outfall #6 or at the entrance to the river
Currently there is little space to provide any detention for waters discharged from storm events. The plan site is
approximately 12 acres and outfall #6 also takes stormwater from the surrounding community that is draining to that
location.
The valve/gate sytem exsisting at outfall #6 could be closed to contain released product but could not hold significant
water during an ongoing rain event.
Several issues associated with record keeping were discussed at the time of the site visit. The plan will be updated to
reference plant documents that record staff and/or proceedures that insure compliance with the permit.
Also, some details about outside storage and time frames will be added to the plant operations description.
This site was very well maintained at the time of the inspection.
Page: 2

Permit: NCS000037 Owner -Facility: Clariant Corporation
Inspection Date: 11/17/2009 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?
■
n
n
n
# Does the Plan include a General Location (USGS) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n
n
# Does the Plan include a list Of.Significant spills occurring durinf7 the last 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility piuvide all necessary secondary containment?
■
n
n
# Does the Plan include a BMP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
n
n
n
# Does the facility provide and document Employee Training?
■
n
n
n
# Does the Plan include a list of Responsible Party(s)?
■
❑
n
❑
# Is the Plan reviewed and updated annually?
■
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
■
n
n
n
Comment: Permittee is waiting for the new permit and some changes will be made to
the Plan after reciept. I discussed how references can be made in the plan to other
plant oporational managment documents that confirm that conditions of the permit are
being met.
Qualitative Monitoring Yes No NA N
Has the facility conducted its Qualitative Monitoring semi-annually? ■ n n n
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? n n n ■
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n n n ■
Comment: New permit will have additional parameters that will need to be evaluated.
Permit and Outfalls
Yes
No
NA
N
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
n
n
n
# Were all outfalls observed during the inspection?
■
n
n
n
# If the facility has representative outfall status, is it properly documented by the Division?
■
n
n
n
# Has the facility evaluated all illicit (non stormwater) discharges?
■
n
n
n
Page: 3

Permit: NUS000031 Uwner -Facility: Clarianl Corporation
Inspection Date: 11/17/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Some changes are being implimented associated with the roof drain
following a small release. The prior SOP for the equipment operator to oheok for
releases after an equipment malfunction did not catch the small release. The product
was clear and not visible on the roof at the time of the release. In the following rain
event the material caused some sheen etc. which was noticed by the staff checking the
stormwater outfall location. The roof drains will be rerouted to the WVVfP in the future.
Page: 4