NCS000321_COMPLIANCE_20100226

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PERMIT NO.
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DOC TYPE
❑ FINAL PERMIT
AVIONITORING INFO
❑ APPLICATION
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❑ OTHER
DOC DATE
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2ol0-C> 26

or
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 9, 2010
Mr. James P. Neill
Lubrizol Advanced Materials, Inc.
207 Telegraph Drive
Gastonia, North Carolina 28056
Subject: Compliance Evaluation Inspection
Lubrizol Advanced Materials, Inc.
Storrnwater Permit No. NCS00032I
Gaston County, N.C.
Dear Mr. Neill:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted
at the subject facility on January 26, 2010 by Mr. Wes Bell of this Office.
It is requested that a written response be submitted to this Office by March 3, 2010. addressing
the discrepancies noted on the Summary Page under the Facility Site Review, Self -Monitoring, and
Laboratory Sections of the attached report. In responding, please address your comments to the attention
of Mrs. Marcia Allocco.
The report should be self-explanatory, however, should you have questions concerning this
report, please do not hesitate to contact Mr. Bell at [phone].
Sincerely,
i" Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosures:
Inspection Report
pH Technical Assistance Document
cc: Gaston County Health Department
WB
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: hflp9lportal.ncdenr.orglweblwq
NorthCarolina
Naturally
An Equal Opportunity 1 Atprmative Action Employer - 50% Recyclec,10% Post Consumer paper

Permit: NCS000321
SOC:
County: Gaston
Region: Mooresville
Compliance Inspection Report
Effective: 06/12/09 Expiration: 06/30/14 Owner: Lubrizol Advanced Materials Inc
Effective: Expiration: Facility: Lubrizol Advanced Materials Inc
207 Telegraph Dr
Contact Person: James P Nelli
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
On -site representative
Related Permits:
Joe Parkulo
Title:
Inspection Date: 01/26/2010 EntryTime: 11:10 AM
Primary Inspector: Wesley N Bell U/Z,
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
® Storm water
(See attachment summary)
Gastonia NC 28056
Phone: [phone]
Certification:
Exit Time: 02:00 PM
a IR /la
Phone:
Phone: [phone]
Phone: [phone]
Ext.2192
Inspection Type: Compliance Evaluation
Paget

Permit: NCS000321 Owner - Facility: Lubnzol Advanced Malenals Inc
Inspection Date: 01/26/2010 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
FACILITY SITE REVIEW.
A white substance had been discharged onto the asphalt driveway (Acrylic Polymer Plant) adjacent to Telegraph Drive.
In addition, oil had been discharged onto the ground/gravel at the air compressor area. All affected areas should be
properly remediated with all contents (white substance, oil stained ground/gravel) being properly disposed. These spills
(and all corrective actions) should also be documented in the SPPP.
SELF -MONITORING:
The results of the stormwater sampling events were documented on the Division's Discharge Monitoring Report (DMR),
however, the DMRs had not been submitted to the Division as required by the subject permit. In addition, only zinc
samples were collected during the follow-up sampling events. Be advised that all parameters must be sampled during the
follow-up sampling events if any parameter exceeds the permit -listed benchmark value. Please review the notification
requirement in the permit that has to be made to the Division once more than four exceedances have occurred for any
specific parameter.
The stormwater analyses (BOD, COD, TSS, zinc) are performed by Prism Laboratories, Inc. (Certification #402). The
following discrepancies were noted regarding the on -site pH analyses:
- pH meter calibrations were not documented.
- one of the pH buffers had expired (and potentially a second buffer that had no expiration date).
The facility staff must ensure that the effluent pH collection and analysis times are documented to verify compliance
with the 15-minute holding time requirement (40 CFR 136.3 Table II). In addition, please refer to the technical guidance
document (attached to the inspection report) regarding pH meter calibration and required documentation.
Page:2

Permit: NCS000321 Owner - Facility: Lubnzol Advanced Materials Inc
Inspection Date: 01/26/2010 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? -
■
Cl
n
11
# 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 during the past 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility provide all necessary secondary containment?
■
n
n
n
# Does the Plan include a 6fvIP 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
# 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. The Stormwater Pollution Prevention Plan (SPPP) (and required
documentation) was organized and well maintained. The SPPP was last updated in
2/09. The facility staff must ensure the initials and date of each individual responsible
for implementing the Spill Prevention and Response Plan are documented in the SPPP
Qualitative Monitoring
Yes
No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
®
n
n
n
Comment. The last qualitative monitoring event was performed on 8/12/09.
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: The facility is required to monitor for BOD, COD, TSS, zinc, pH, and total
rainfall. The last analytical monitoring event (for all parameters) was performed on
9/9/09. The permit's zinc benchmark value were exceeded in the past three sampling
events (6/5/09, 9/9/09, 10/28/09). The facility is currently under the Tier 2 monitoring
requirements and staff are continuing their investigative efforts to identify the zinc
source. The facility staff must ensure to document all Tier 1 and 2 responses in the
SPPP. See "Summary" Section for additional comments.
Permit and Outfalls Yes No NA NE
Page: 3

Permit: NCS000321 Owner - Facility: Lubrizol Advanced Materials Inc
Inspection Date: 01/26/2010 Inspection Type: Compliance Evaluation
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Reason for Visit: Routine
Comment: The facility has designated one stormwater outfall. The stormwater flows
through two concrete basins that are operated In series. The stormwater is discharged
from the second basin via pump system and may also be discharged from the basin's
overflow spillway. The facility staff performs process control measurements (on -site
laboratory) in the second basin (during activation of a recirculation system) to ensure no
spills/leakages have occurred within the manufacturing areas. No discharge was
observed at the time of the inspection. The annual non-stormwater evaluation of the
stormwater drainage system should identify the permitted wastewater discharges
covered under the NCG500210 NPDES Permit.
Page:4

TECHNICAL ASSISTANCE FOR FIELD ANALYSIS OF pH
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 14,
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 VC
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.)
DOCUMENTATION:
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).

Page 2 of 2
Recommendation: Maintain a log of all chemicals, reagents and standards to include vendor, lot numbers,
and expiration date.
Ref: Standard Methods, 18th Edition - Method 4500-H' B. Ref: Standard Methods, 18th Edition - Method
2550 B.
Rev. 02/2009

Lubrizol
February 26, 2010
MAR - 3 2010
Ms. Maria Allocco
Mooresville Regional Office
North Carolina Division of Water Quality
610 East Center Avenue, Suite 301
Mooresville. NC 28115
Re: Compliance Evaluation
NPDES# NCS000321
Dear Ms. Allocco:
This letter is in response to the recent letter dated 2/9/2010 from your agency.
Actions taken specific to the compliance inspection include:
1. White substance on the asphalt at the northeast Acrylic gate has been
cleaned up. SPCC plan includes documentation of deficiency and
remediation.
2. Oil staining at the air compressor area has been cleaned up. SPCC plan
includes documentation of deficiency and remediation.
3. Self -monitoring requirements of the two NPDES permits have been reviewed
and future monitoring events will meet the requirements as specified.
4. pH meter calibration procedures have been implemented which include using
buffer solutions within the manufacturers specified recommendations.
If you have any questions, please give Joe Parkulo a call at [phone].
Sincerely,
James P. Nelli
Plant Manager