NCS000041_EPA Inspection Report_20190603

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
<a TW REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
C PROTEGE ATLANTA, GEORGIA 30303-8960
MAY 2 9 2019
CERTIFIED MAIL 7017 1450 0000 7973 2809 F-
RETURNED RECEIPT REQUESTED " ; '
JUN 03 2019
Mr. Daniel C. Grieneisen
Environmental Safety and Health Affairs DENR-!_AND QUA>_I-P(
Clariant Corporation STORMWATER PERI�Ii i 'ING
P.O. Box 866
Mount Holly, North Carolina 28120
Re: Compliance Evaluation Inspections
Clariant Corporation — Mount Holly West Facility
NPDES Permit No. NCS000041
Dear Mr. Grieneisen:
On March 19, 2019, the U.S. Enviroinnental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the Clariant Corporation — Mount Holly West Facility located at 625 East Catawba Avenue in Mount
Holly, NC. The purpose of the CEI was to evaluate Clariant Corporation — Mount Holly West Facility's
compliance with the requirements of Sections 301 and 402(p) of the Clean Water Act (CWA), 33 U.S.C.
§§ 1311 and 1342(p); the regulations promulgated thereunder at 40 C.F.R. § 122.26; and, the State of
North Carolina's NPDES Stormwater Permit NCS000041.
The EPA and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren.aarcia a?nedenr. ov.
There is no need to respond directly to the EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Kenneth Kwan, P.E., at the above address, by email at
[e-mail], or at [phone].
Sincerely,
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Enclosures
cc: Ms. Annette Lucas
NCDEQ
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)

1"'� U.S. Environmental Protection Agency, Region 4
61 Forsyth Street SW, Atlanta, GA 30303
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Water Compliance Inspection Report
FACILITY DATA
NPDES ID: NCS000041 Effective Date: 11/01/2009 Expiration Date: 10/31/14 (admin continued)
Facility Name: Clariant, Corporation — Mount Holly SIC Code: 2821
Address: 625 East Catawba Ave, Mount Holly, NC 28120
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Daniel C. Grieneisen Fernando Henrique Colombo
Environmental Safety and Health Affairs VP of Operations North America
P.O. Box 866 625 East Catawba Ave
Mount Holly, NC 28120 Mount Holly, NC 28120
704-822-2137 704-822-2101
INSPECTION DATES/TIMES
Entry Date/Time: 03/19/19, 2:30 pm Exit Date/Time: 03/19/19, 6:00 pm
NAMES OF EPA AND STATE INSPECTORS
EPA Inspectors: Ahmad Dromgoole, Kenneth Kwan
NCDENR Inspectors: Tamera Eplin, Tom Poe, Thad Valentine, Lauren Garcia, Alaina Morman
AREAS EVALUATED DURING INSPECTION
X Permit Self -Compliance Program Pretreatment
X Records
Compliance Schedule Pollution Prevention
X Facility Site Review
Laboratory X Storm Water
X Effluent / Receiving Waters X
Operations & Maintenance Combined Sewer Overflow
Flow Measurement Sludge Handling/ Disposal Sanitary Sewer Overflow
INSPECTION NOTES
The inspection team, consisting of EPA inspectors and state inspectors from various regional offices, arrived at the facility on March
19, 2019 to perform an unannounced Compliance Evaluation Inspection (CEI). This CEI, which focused on the facility's NPDES
Industrial Stormwater permit, was performed as both a joint inspection with the state and a training opportunity for state inspectors.
Upon arrival at the facility, EPA inspectors presented credentials and facilitated an opening conference. The CEI included both a
records review portion and a facility walk through. Upon completion, an exit conference was held with facility personnel in which
they were informed of EPA's preliminary findings and told that an actual inspection report will be sent to the facility by EPA.
.♦ REPRESENTATIVES
Inspector Signature/Name Office/Phone Number Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9212
Ahmad Dromgoole, Environmental Engineer
USEPA Region 4/WPD-CWEB-SRES
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signature/Name
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SRES
404-562-9434
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
Page 1 of 6

GPS
Coordinates
Coordinates
1. FACILITY LOCATION INFORMATION
Latitude 35017'45.95"N Longitude
810 0'28.80"W
Receiving
Site
Weather
Water(s) or
Catawba River
Acreage
43
Condition
Clear skies, Low 50s
MS4
Date of
Does the site
Permit
Discharge to 303(d)
discharge pollutants
Coverage
04/02/2014
SIC
2821
listed or
Yes
contributing to the
Yes
Renewal
Code(s)
receiving stream
Application
waterrss
impairment.
Form
2. BASIC STORMWATER POLLUTION PREVENT PLAN (SPPP) INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
SPPP on -site (obtain a copy of the plan) & signed Section A
X
A complete SPPP dated Oct. 2107 was provided by the facility via e-mail. However, this SPPP was not signed or
dated with the proper management approval.
Site Description Section A(1)(b)
X
(storage practices, loading/unloading activities, outdoor processes, dust generating processes, and waste
processes)
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
X
(include inventory of materials handled at the site, information pertaining to any pollutant sources, information
pertaining to the storage and application of pest control chemicals)
Site Maps (general location map and site specific map) Sections A(1)(a & c)
X
(include identification of receiving waters and/or MS4s, identification of impaired waters, lat/long of discharge
points, drainage areas to each discharge point, site boundaries, site topography, drainage features and flow
directions, impervious areas, industrial activities, and site best management practices (BMPs)
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
X
The SPPP stated that the facility has not experienced a reportable spill incident in the past 3 years. However, it is
uncleared as to the timeframe since the SPPP was dated 10/17 and have not been updated recently. The permit
requires a list of current spills or leaks for the previous 3 years.
SPPP Certification Section A(1)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
An annual non-stormwater certification for 2018 was sent in via e-mail. However, this certification did not have
the day the test was performed, which outfall was evaluated, type of test conducted, the actual result of these
tests, and name of the person conducting the test. Also, the Annual Non-stormwater Discharge Certification
Form in Appendix C-6 of the SPPP was not used for the 2018 certification submitted in the e-mail.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis of control options like eliminating exposure or controlling runoff)
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
(Should include a table or summary clearly inventorying the sources and procedure for making visual observations
of accumulated liquid and how to dispose of it).
Appendix B of the SPPP contain a table of all storage tanks volume and stored materials. However, their associated
secondary containment capacity was not listed.
Page 2 of 6

2. BASIC STORMWATER POLLUTION PREVENT INFORMATION
SPPP TOPICS (Part II)
YES
NO
N/E
Stormwater BMP Summary Section A(2)(c)
X
(Include all structural and non-structural BMPs at the site)
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
(Stormwater specific plan identifying the various responsible officials and their signatures)
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
(address maintenance and cleaning schedules of control systems, outfalls, adjacent waters, handling of industrial
activities, drainage structures, and BMPs- Include a list of the areas incorporated in the program)
The SPPP did not address preventative maintenance and good housekeeping practices on storm drains, retention
basins, and catch basin.
Employee Training Section A(5)
X
(minimal annual training of spill response and cleanup/prevention and potential areas of industrial stormwater)
Identify the Responsible Party Section (A)(6)
X
SPPP Modified or Update to Current Conditions Section (A)(7)
X
(review and update at least annually, recertify, and include the review of most recent benchmarks samples)
The latest annual review and update of the SPPP was conducted in October 2017. The SPPP Plan Amendments
and Review Log in Table 1-1 of the SPPP show no records of annual review in 2018.
Schedule and Procedures for Routine Inspections (minimum of semiannually) Section A(8)
X
The SPPP provided by the facility states that the routine system inspections will be performed twice per year.
These inspections required the completion of a checklist which is maintained in a file. In addition to the
semiannual inspections, facility operators are required to perform checks every shift of the stormwater outfalls
and the stormwater containment areas.
Clariant Corporation operates a specialty chemical manufacturing facility in Mount Holly, NC. There are currently approximately 164
employees at the roughly 43-acre Mount Holly facility. The facility processes operate 24 hours a day/7 day a week. The facility
manufactures a variety of personal -care products, as well as chemicals for biocides, detergents, surfactants, deicers, and metalworking,
crop -protection, and textiles. There are currently four batch processing plants at the Mount Holly facility: three plants are active while
the forth is idle. Except for a few raw materials and a product that are shipped by rail, most of the materials used and/or produced at the
site are transported by truck. The chemical processes at this plant are closed batch processes which are housed either indoors or within
covered area.
The areas around the Mount Holly plant were primarily impervious/paved. Runoff from the site would typically flow towards one of the
drainage systems at the site. There facility currently holds two NPDES permits: NCS000041 (industrial stormwater) and NCS000047
(industrial wastewater). Depending on the operations in a drainage area, the drain inlets were tied into either the wastewater treatment
plant or the stormwater treatment system. The drain inlets were color coordinated allowing for a determination of where runoff in the
area would be direct.
For this inspection, the focus was on the facility's NPDES stormwater permit (NCS000041). The facility operated 6 stormwater outfalls
associated with this permit. These outfalls are all tied to either the two retention basins or one of the four small basins. The stormwater
discharges from these retention basins are controlled by manual valves that are normally closed. Before releasing any stormwater, facility
personnel conduct a visual observation of the characteristic of stormwater prior to batch release to receiving water.
Page 3 of 6

4. RECORD REVIEW
Record Review
YES
NO
N/E
Representative on -site
X
Records of the Implementation of the SPPP Part II Section A(9), Part III Section D(6)
X
Records from 2017 and 2018 of implementation of the SPPP were spot checked during the inspection and
appeared to have been maintained in accordance with the permit.
Records of Maintenance and Housekeeping Programs Part II, Section A(9)
X
The facility maintains records of it maintenance and housekeeping activities in an electronic database. Samples
of these records were made available during the inspection.
Records of Routine Inspections Part II, Section A(9)
X
The inspection records for 2018 were provided for review during the inspection. During the 11/3/18 semi-annual
inspection, three issues noted. No records were available during the inspection on how and when these issues
were addressed. This information was later provided to EPA via email. However, the timeframe on when these
issues were addressed are still missing.
Records of Employee Training Part H, Section A(9)
X
Records of employee training were provided and reviewed for 2018.
Records for the Approval of Representative Outfalls Part III Section D(5)
No request was made for the approval of a representative outfall.
X
Records of Benchmark Monitoring Part II, Section B & D, Part III Sections D, & E(1)
X
The records of benchmark monitoring were reviewed for 2017-2018. According to facility personnel, a contract
lab is used for the analysis of all benchmark parameters except for pH which is run on site. From the review of
the available records, the appropriate lab methods, holding times, and preservatives were used for the benchmark
monitoring. A more expansive review of the benchmark history was later performed on data provided by the
state. This review showed that for 2017 and 2018, Clariant only performed annual benchmark monitoring instead
of semiannual as required by the permit.
Records of Qualitative Monitoring Part II Section C, Part III Section D
X
(minimum of 60 days between periodic sampling)
Qualitative monitoring is performed at the various outfall prior to the releasing of the stormwater at the outfalls.
These records from 2018 were available and reviewed.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
X
From the review of the 2018 benchmark monitoring records, there were benchmark exceedances for BOD, COD
and TSS at various time and at different outfalls. A Tier One response was submitted to EPA via email for
review. However, these responses need to be filled out utilized the form in Appendix C-7 of the SPPP.
Records of Bypasses Part III Sections E(7)
According the facility, there had been no reportable bypasses since 2017.
X
Records of 24 hr Reporting Part III Sections E(8 &9)
According the facility, there had been no events at the facility since 2017 requiring 24 hr reporting.
X
Pollutant Sources Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
A few raw materials and products at the facility are shipped by rail. The railcar unloading area near plant 3 can
Loading/Unloading be seen in photo DSCN1871. In this unloading area, the observed storm drains were red meaning that runoff
Area from this area would be directed to the wastewater treatment system. The loading/unloading area near
warehouse # 1 has sediment deposit along the storm drain area.
Page 4 of 6

5. SITE EVALUATION & SWP3 IMPLEMENTATION
Pollutant Sources
Note location, quantitative description, design issue, O&M deficiencies (including the nature and
extent), and pollutants off -site
Raw Material
Storage Facilities
No issue noted during the inspection.
Outdoor Process
Operations
No issue noted during the inspection.
Product Storage
Areas
No issue noted during the inspection.
Two storm drain systems were in place at the Clariant facility: the green painted storm drains were associated
with stormwater manage while red storm drains were tied into the facility's wastewater treatment system. The
Storm drains
impervious areas around the facility drained to various storm drain inlets which, depending on the area, would
direct water to the appropriate treatment area. An example of these catchments can be seen in photo
DSCN1870.
Housekeeping
No issue noted during the inspection.
Liquid Storage
No issue noted during the inspection.
Tanks
Most of the stormwater outfalls at the Clariant site have some form of holding/retention capacity prior to
Best Management
discharging. Two outfalls were associated with larger retention ponds. This included the retention ponds for
Practices (BMPs)
Outfall 1 (see photo DSCN1872) and Outfall 6 (see photo DSCN1878). Out outfalls have smaller retention
areas like the retention area for Outfall 3 (seen in photo DSCN1875).
Spills/Leaks Handing
No issue noted during the inspection.
Disposal/Waste
Handling Areas
No issue noted during the inspection.
Vehicle Maintenance
No outdoor vehicle maintenance actives were observed.
Areas
6. OUTFALL, STORMWATER
DISCHARGE & RECEIVING WATER OBSERVATIONS
Outfall, Stormwater
Discharge & YES NO
Receiving Water
Number & location
Describe: According the facility's SPPP, 6 stormwater outfalls are operated at this site. The
of stormwater
large retention pond near the northeast corner of the site discharges to Outfall 1 (seen in photo
discharge(s)/outfall(s)
X
DSCN1873). South of Outfall 1 along the east side of the site there are Outfalls 3 (seen in photo
consistent with the
DSCN1874), Outfall 4 (seen in photo DSCN1876), Outfall 5 (seen in photo DSCN1877), and
SPPP
Outfall 6 (seen in photo DSCN1879). Outfall 7, seen in photos DSCN1868-DSCN1869),
received runoff from the area along the west side of the site near the truck scale.
Page 5 of 6

1 1
1DISCHARGE ; RECEIVING WATER OBSERVATIONS
Outfall, Stormwater
Discharge & YES NO
Receiving Water
Evidence of off -site
accumulation of
X
Describe: During the inspection, no evidence of pollutant accumulation was observed in the
pollutants observed
receiving water.
in receiving water
Other potential
discharges off -site
(through outfalls not
X
Describe: During the inspection, no stormwater outfalls were observed aside from those
included in the
identified in the facility's SPPP.
SPPP)
Non-stormwater
Describe: The facility has a permit and treatment system for both stormwater and wastewater.
discharge observed
X
During the inspection, no discharges of non-stormwater were observed at the stormwater
outfalls.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagram of the facility area as
necessary:
An exit conference was held with Shawn Moye, Clay Dunn, Daniel Grieneisen, and Fernando Colombo were the following
observations were relayed:
1. The loading/unloading area near warehouse # 1 has sediment deposit along the storm drain area.
2. A punch list of records to be submitted to EPA was provided to facility personnel
a. SPPP
b. Non-Stormwater Discharge Certification Form
c. Documentation of the three issues noted during the 11/3/18 semi-annual inspection was addressed
d. Records of Tier One response for benchmark exceedances
Page 6 of 6

SW-NCS000041-031919
Clariant Corporation - Mount Holly West Plant
625 East Catawba Ave
Mount Holly, NC 28120
SW-NCS000041-031919 Page 1 of 13

DSCN1868.JPG
,..
Attributes
File Name
DSCN1868.JPG
Description
Photograph of Outfall 7. This outfall drains the area of the site near the truck scale.
Latitude
N 35° 17' 42.29"
Longitude
W 81' 00' 28.96"
SW-NCS000041-031919 Page 2 of 13

DSCN 1869.J PG
Attributes
File Name
DSCN1869.JPG
Description
Photograph of Outfall 7. This outfall drains the area of the site near the truck scale.
Latitude
N 35° 17' 42.30"
Longitude
W 81' 00' 28.99"
SW-NCS000041-031919 Page 3 of 13

DSCN 1870.J PG
�r
Attributes
File Name
DSCN1870.JPG
Description
Storm drain inlets along the loading area at Warehouse 1. Some sediment accumulation was
observed in this area which drains to Outfall 3.
Latitude
N 35° 17' 43.27"
Longitude
W 81' 00' 27.55"
SW-NCS000041-031919 Page 4 of 13

DSCN 1871.J PG
Attributes
File Name
DSCN1871.JPG
Description
Photograph of the railcar unloading area near Plant 3. The catchment in this area drains to the
facility's wastewater treatment plant.
Latitude
N 35° 17' 45.98"
Longitude
W 81' 00' 23.51"
SW-NCS000041-031919
Page 5 of 13

DSCN 1872.J PG
Attributes
File Name
DSCN1872.JPG
Description
Photograph of the retention basin which discharges to Outfall 1. There were two outlet structures
near the corner of the pond. One outlet structure led to the stream. The other led to the
wastewater treatment system. The conditions of the accumulated water would determine
whether it was sent to the stream or to the treatment plant.
Latitude
N 35' 17' 44.45"
Longitude
W 81' 00' 21.39"
SW-NCS000041-031919 Page 6 of 13

DSCN 1873.J PG
+�.� �* � •*AFC zT' •!� � Y.t= .�^ t
T 4:.
4. ti
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Attributes
File Name
DSCN1873.JPG
Description
Photograph of Outfall 1. This outfall was not discharging at the time of the inspection.
Latitude
N 35° 17' 44.06"
Longitude
W 81' 00' 19.71"
SW-NCS000041-031919 Page 7 of 13

DSCN 1874.J PG
Attributes
File Name
DSCN1874.JPG
Description
Photograph of Outfall 3. This outfall was not discharging at the time of the inspection.
Latitude
N 35° 17' 40.35"
Longitude
W 81' 00' 21.72"
SW-NCS000041-031919 Page 8 of 13

DSCN1875.JPG
Attributes
File Name
DSCN1875.JPG
Description
Photograph of the catch basin associated with Outfall 3.
Latitude
N 35° 17' 43.13"
Longitude
W 81' 00' 20.44"
SW-NCS000041-031919 Page 9 of 13

DSCN 1876.J PG
Attributes
File Name
DSCN1876.JPG
Description
Photograph of the basin structure and inlet for Outfall 4.
Latitude
N 35° 17' 39.07"
Longitude
W 81° 00' 25.78"
SW-NCS000041-031919 Page 10 of 13

DSCN 1877.J PG
Oto
Attributes
File Name
DSCN1877.JPG
Description
Photograph of Outfall 5. This outfall was not discharging during the inspection.
Latitude
N 35° 17' 35.97"
Longitude
W 81' 00' 25.38"
SW-NCS000041-031919 Page 11 of 13

DSCN 1878.J PG
Attributes
File Name
DSCN1878.JPG
Description
Photograph of the retention basin associated with Outfall 6.
Latitude
N 35° 17' 34.97"
Longitude
W 81° 00' 27.29"
SW-NCS000041-031919 Page 12 of 13

DSCN 1879.J PG
Attributes
File Name
DSCN1879.JPG
Description
Photograph of Outfall 6 which was not discharge during the inspection.
Latitude
N 35° 17' 34.97"
Longitude
W 81' 00' 27.29"
SW-NCS000041-031919 Page 13 of 13