NCS000003_2019 Staff Report_20191227

NC Division of Energy, Mineral and Land Resources
Review for Permit — NCS000003
Elementis Chromium, Inc
Facility Activities and Processes:
• SIC Code: 2819 - Industrial Inorganic Chemicals
• The facility manufactures a range of commodity and specialty chromium products. These include
chromic acid, chromic oxide, ammonium dichromate, potassium dichromate, sodium
dichromate, chrome sulphate and sodium sulphate. The facility receives chrome ore from out of
the country and processes it into liquid and powder.
• North Carolina is Elementis Chromium's primary US operation producing dichromate and
chromic acid to serve the North American market.
• Elementis Chromium is a division of Elementis plc, the international specialty chemicals group.
Monitoring Information:
• 2 Outfalls — natural vegetative swales and ditches are used to convey stormwater to Outfalls 004
and 005.
• Quarry on -site dug by nearby company for building materials.
• Stormwater that falls in process areas of the plant is either collected and used in the process or
drained to an internal storm water system for treatment before being discharged through
permitted industrial discharges.
• Process areas are designed to contain any stormwater that falls on them. These designs include
curbed process areas, lined trench systems, paved roadways and areas beneath pipe racks, an
eternal stormwater collection system, and grading designed to prevent runoff.
• Materials are stormed to prevent leaks and reduce the possibility of runoff to stormwater
discharges. This includes adequate secondary containment for all product, fuel, and process
storage tanks and storing all containers, drums, and bags in covered warehouse to prevent
exposure to the weather.
• Chromium exists in three distinct forms of valency states, metallic, trivalent and hexavalent. The
hazards and practices relating to managing the risk vary depending on the form present.
Metallic chromium, present in the chromium -plated objects and alloys such as stainless steels, is
essentially inert. Trivalent compounds occur naturally in the environment in mineral ores, are
the most stable and are not classified as hazardous. Commercial uses include pigments,
refractories and leather tanning.
• Fuel oil and chrome ore are used to heat the furnace. They want to change to coal. So they will
have to store coal on -site. From the site visit we learned they have no current plans for coal
because the price of fuel oil went down. The understand that their SPPP plan must include coal
piles if they do store coal. There is a rail spur on the property that the coal will be stored near.
They used coal in the early 90's. There is a concrete pad and conveyor belt in place that drains to
detention pond and discharges with stormwater.
• Hexavalent chromium compounds do have recognized hazards and are regulated accordingly.
They occur in the primary manufacturing process and are used in some downstream process

industries, such as chromium plating. Elementis Chromium works to manage these hazards
responsibly during manufacture and for the purpose of distribution.
• Chromium chemicals can be found in a wide range of everyday items:
o Plumbing fixtures, car accessories and domestic appliances such kettles and toasters are
chrome plated.
o Ingredient of products applied to protect timber used to build bridges, utility poles,
marine piles, and many other industrial applications.
o Super alloys used in aircraft engines and land -based turbines contain chromium metal
made from chromic oxide. In addition chromic oxide is used in applications to color
ceramics, surface coatings, cosmetics, plastics, and construction products.
o Chrome sulfate tans leather used to make clothing and shoes.
o Sodium sulphate is an ingredient in washing powders.
Impairment:
• The Northeast Cape Fear is listed as an impaired waters, experiencing issues with arsenic, lead,
fecal coliform, pH, water temperature, iron, copper, nickel, zinc, turbidity, fish tissue mercury,
cadmium, and dissolved oxygen.
Threatened or Endangered:
• Picoides borealis (Red -cockaded Woodpecker)
Staff Review Comments:
Okay, that makes sense. Yes, then that part of the permit needs to be revised.
The DWR Lab website is very helpful for looking into metals analyses. I looked at the PQL
(practical quantitation limit) info for Inorganics to see what was available, and how low it can
detect. One challenge is not being able to measure low enough sometimes (silver is an
example; our benchmark falls below quantification levels because it's a calculation). I don't
know how Cr VI compares, but there is a method listed. Based on Chris V's recent email, this
must be dissolved:
Odd I fdfl.�aMahldd
Here's the info for total chromium (the test we usually have permittees run because we're not
worried about Cr VI being present, and we just use the Cr III benchmark as a comparison).
I.-rsrt} I Ld-s4 - 1— 1 1—h I GI.M1 — G- J I SG i ■ 'G 1 — I 1M1 I GP..��l
Attached is the entire list for reference, but you can always find PQL info here:
https://deg.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-
home-page/microbiology-inorganics-branch/methods-pgls-qa#QA

Brian's staff report from 2010 mentions he kept Total Cr because of the ore stored on site, but
decided against hexavalent (there was a typo in there -- he had Cr IV instead of VI) because all
stormwater in the process area was collected and treated. It may be fine to carry this through
renewal if there's no reason to suspect Cr VI in stormwater discharges.
I don't see anything about the monitoring data from the last term? Did they have any detects
of total chromium? Keep in mind where the PQL for total Cr falls in comparison to Cr VI's PQL
(5 ug/I vs. 0.2 ug/1) and the benchmarks. But if there's very little likelihood of any chromium
from the process escaping in stormwater, I'd say it's reasonable to consider keeping total. The
take-home point here is that this decision should be documented before finalizing the
permit. Also, in the permit as it's drafted, you should revise "Chromium III" to just "Chromium,
Total Recoverable" because that's really what's being analyzed. (It's just that the benchmark
you have in the table is specifically based on Chr III).
Also, is nitrate -nitrite being maintained because of the ammonium dichromate? The staff
report says this facility produces ammonium dichromate, potassium dichromate, sodium
dichromate, chrome sulphate and sodium sulphate. What about sulfates? (They must be
British to spell it differently!) Are there any concerns with that or where these products are
stored? Brian's staff report says nitrate -nitrite came from the EPA MSGP, but aluminum and
iron (also in the MSGP for this sector) was omitted because they weren't present. That's fine;
think it is just important to maintain rationale for why nitrate -nitrate is still in here in the
review documents for this renewal. What were the data for that parameter like? Does it
make sense to keep it? I did not find a discussion of their monitoring results, which would also
be good to include.
I am not sure why TSS was never in this permit. It's a standard parameter that I think should be
considered -- especially with the future possibility of bringing in coal.
Whatever became of Brian's recommendation to add another outfall? It sounds like they still
have the same two.
It sounds like EC has kicked around the idea of using coal and having to store it on site for
several years. You might consider language requiring them to come in for a modification if they
change their fuel to coal, since any run-off will be regulated (and subject to the same
requirements as ww coal pile runoff).
I hope this helps. I didn't review the draft itself so thoroughly beyond what's above because I
know there have been some universal changes to the template. If you have any questions, let
me know!
Revisions: TSS was added to the permit. A condition was included that should industrial activities
change at the facility involving the storage of coal, the facility shall contact the Division and request a
permit modification. Monitoring data was well below benchmarks.