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Home My WebLink AboutWQ0011038_Compliance Evaluation Inspection_20191217ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Ms. Renee Culler, EHS Manager CNA Holdings, LLC — Shelby Facility 2525 Blacksburg Road Grover, North Carolina 28073 Dear Ms. Culler: NORTH CAROLINA Environmental Quality December 17, 2019 via Email Subject: Non -Discharge Permit Inspection CNA Holdings, Inc. Celanese Shelby Plant Permit # WQ0011038 Land Application of Residuals Cleveland County Mooresville Regional Office staff conducted joint inspections for the NPDES permit #NC0004952, toxicity split sampling and the RLAP permit/rescission. Enclosed you will find the report for the non -discharge compliance inspection conducted on December loth, 2019, for the referenced permit. You will receive a separate report for the NPDES inspection conducted by Ori Tuvia, also from the Mooresville Regional Office (MRO). MRO records show this facility last land applied in 2009. A sludge judge grab sample at the overflow between the South lagoon and North lagoon show approximately 50% of the volume cloudy from residuals. Periodic evaluation of both storage lagoons is recommended and may warrant follow-up with a contractor (land application or septage hauler) to manage residuals. During the follow-up visit for second Toxicity split sample, the Non -Discharge program was further discussed for appropriate residuals management options w/o an internal permit. Per your request, here is a list of land application contractors who have worked in this area: 980-529-0000 (Local Vaugh 'Buck" Office) Bio-Nomic Services Stevenson vstevenson(@bio-nomic.com 704-930-8886 (Buck Cell Brent Collins 1-336-751-1441 brent.collins(a�emaresourcesinc.com EMA Resources Roy Whittaker 336-766-0328 x115 ro .whittaker emaresourcesinc.com Southern Soil Builders Zach Key 1-336-957-7871 (cell) zachkey(�southernsoilbuilders.com Synagro Central LLC Robert "Nate" Roth 1-336-403-4324 (Cell) rroth(a�synagro.com NORTH CAROHNA � D E QNorth Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 o.namremor �w.c�giuuei� /`� 704.663.1699 Additional items of interest are noted below and in the inspection report. • Two feet water level markers have been placed in both residuals lagoons, since noted in the last inspection. • Rescission of this permit was requested and MRO response forwarded to Central Office permitting. Questions about the rescission may be directed to Nathan iel.Thornburg(d_)ncdenr.gov. • Per on -site discussion, it is currently anticipated that you and Mr. Sparks (ORC) will NOT be at the facility after April 30th, 2020, but will inform MRO of proper contacts. The MRO would like to thank you and your staff for your time during the inspections/sampling. This inspection report should be self-explanatory; however, please contact Maria Schutte by phone (704-235-2184) or email (maria.schutte(a_ncdenr.gov) with questions. Sincerely, Docu Signed by: �z 4tV H P44,f4 F161FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment(s): Inspection Report December 2019 CC: Nicole B. Coffee, Site Leader, CNA Holdings (email) State of North Carolina Department of Environmental Quality Division of Water Resources Roy Cooper, Governor Michael S. Regan, Secretary Linda Culpepper, Director NON -DISCHARGE COMPLIANCE INSPECTION GENERAL INFORMATION Owner: CNA Holdings, Inc. — Shelby Plant County: Cleveland Permit #: W00011038 (non-503) Issued: 12/19/2014 Expiration: 04/30/2020 Permittee Contact: Renee Culler (EHS Manager) Cell: 1-682-218-6043 Email: renee.culler(a celanese.com Additional Contact: Nicole B. Coffee (Site Leader) Ph: 704-480-5803 Email: nicole.coffee(a-,celanese.com ORC Name: Roy Whittaker #13283 Phone: 336-766-0328 x115 Email: roy.whittaker(-ci�emaresourcesinc.com B/U ORC: Brent Collins #27651 Cell: 336-399-3646 Email: brent.collinsgemaresourcesinc.com B/U ORC: Jonathan Hill (print Waste) #27659 Cell: 336-918-2993 Email: jhill(ai)sprintwaste.com Reason for Inspection X ROUTINE COMPLAINT FOLLOW-UP OTHER Type of Inspection Collection System Spray Irrigation X Sludge Inspection Date(s): December 10 and 12, 2019 Inspection Summary: (additional comments may be included on attached pages) Other This inspection included a review of residuals processing and storage at the WWTP. The facility continues to manage their residuals in the on -site storage lagoons. No new records have been created since the previous inspection and the 2017 Annual Report; and, management has decided to rescind this permit. Please note the issues below to maintain overall compliance: Lagoon storage requires two feet of freeboard be maintained. Basic water level gauges, with inch or tenths of a foot increments, were emplaced to note 2 feet of freeboard or less. It is recommended lagoon inspection dates/freeboard levels be documented on plant inspection reports. The MRO should be informed of any changes to the contact information noted above. Please email corrections/updates to Maria Schutte at the email address above. Is a follow-up inspection necessary _yes X no? Inspector Name/Title: Maria Schutte, Environmental Specialist; Ori Tuvia, Engineer Telephone No.: 704-663-1699 Fax No. 704-663-6040 Date of Inspection: 12/10&12/2019 Residuals Inspection WQ0011038 CNA Holdings, Inc. — Shelby Plant — Cleveland County Page 2 Type of Residual X Land Application (class B) Record Keeping Y-yes N-no N/A -not applicable Distribution and Marketing (class A) N/E-not evaluated Y Copy of current permit available at residual generating site NA Current metals and nutrient analysis (see permit for frequency) NA TCLP analysis, NA SSFA (Standard Soil Fertility Analysis) NA Nutrient and metals loading calculations (to determine most limiting parameter) YTD Y Hauling records (# gal and/or ton hauled during calendar year to date) NA Field loading records, NA Field site maps and information NA Records of lime purchased NA Pathogen & Vector Attraction Reduction (Fecal analyses were done for the previous renewal application) Comments: All residuals records are maintained at the WWTP. No new residuals data has been generated since the last inspection and the permittee is now requesting rescission. There has been no land application since 2009. Staff and plant production was decreased main in the past year. Pathogen & Vector Attraction Reduction (PVAR) records This permit is 503 exempt — Pathogen and Vector Attraction Reduction analyses are not required Sampling Describe Sampling: There was no land application for 2017 — sampling was not observed Is sampling adequate? NE Is sampling representative? NE Treatment X_ Aerobic digestion Autothermal Thermophilic Aerobic Digestion Anaerobic digestion Drying beds (may not meet 503's) Alkaline Stabilization Lime Other -describe Transport No land application was taking, place during this inspection. Spill control plan in transport vehicle? NA Does transport vehicle appear to be maintained? NA Storage Number of days/weeks/months of storage: Per prior inspections, estimated at 1095 days. Describe storage: Sludge Residuals are stored in 2 unlined lagoons estimated at 1.66 MG and 2.23 MG. Basic water level gauges were installed at the lagoons, since the previous inspection. A sludge judge grab sample at the overflow between the South lagoon and North lagoon show approximately 50% of the volume cloudy from residuals. Periodic evaluation of both storage lagoons is recommended and may warrant follow-up with a contractor (land application or septage hauler) to manage residuals. Odors present N Vectors present N Non -Discharge Permit Inspection Page 3 WQ0011038 CNA Holdings, Inc. — Shelby Plant — Cleveland County Field Sites (end use for class B biosolids) No land application was taking place during this inspection. Field identification: NA — See note above. Monitoring well(s) Y/N: NA If yes, location of well(s): Comment: This permit does not require groundwater monitoring_ Odors/vectors No active land application was taking place during this inspection. Odors and vectors were not detected at the WWTP storage lagoons at the time of inspection. Describe any nuisance conditions and any corrective actions needed. NA Odors present N Vectors present N Other noted conditions Note for future inspections: This facility requires safety instruction for entry and PPE (steel toed shoes, eyeglasses and hard-hat if in the industrial plant). The safety instruction is valid for 1 year. Renee Culler is planned to remain until April 2020. Her replacement has not been determined.