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HomeMy WebLinkAboutNC0003573_Compliance Evaluation Inspection_20200205ROY COOPER cove no MICHAEL 5. REGAN secretary S. DANIEL SMITH Director Brian Long The Chemours Company Fc LLC 22828 NC Highway 87 West Fayetteville, NC 28306-7332 NORTH CAROLINA En viror men tat Quality February 28, 2020 SUBJECT: Compliance Inspection Report Chemours Company -Fayetteville Works NPDES WW Permit No. NC0003573 Bladen County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Chemours Company -Fayetteville Works Facility on 2/05/2020. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0003573. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". The cooperation of Jamie Lewis, facility ORC, was greatly appreciated during the inspection. There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. Comments: • The facility was clean and neat in appearance at the time of inspection. . Records for sample collection, analytical results, and plant maintenance were well organized. • During the inspection it was noted that thermometers in composite sampling units were not annually calibrated. Thermometers should be calibrated annually to insure that proper sample holding temperatures are maintained. In response to this issue, the facility has purchased new NIST traceable thermometers, which will be installed in the composite sampling units and will be calibrated annually. N-DrtF.7�srD.r.a6epsrtmentofEPvr-Dnir.er.ta:Qo-arty I D:vs*r.ofWater Res]Lrss Fayettev e F,eg:ora.:Wre I t.253reer,Street, 5ute714 I Fay;etter;:e, NortF tiara rs 2SSD1 PEq ... - 1, , �, $1C: 422-2,200 Flow monitoring data for 11/20/2019 was missing from November 2019's eDMR. This omission was corrected during the inspection and an updated eDMR was submitted to the division. A Whole Effluent Toxicity sample was collected at Outfall 002 from Chemour's 24-hour composite sampling equipment on February 4th and 61" for use in a chronic Ceriodaphnia dubia pass/fail toxicity test. These samples were sent to the Division of Water Resources (AT) Laboratory (located on Reedy Creek Road in Raleigh). The Whole Effluent Toxicity pass/fail test resulted in "PASS". If you should have any questions, please do not hesitate to contact Kristen Slodysko with the Water Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at kristen.slodysko@ncdenr.gov. Sincerely, EDocuSigned by: YlSluti �(hj-,jS6 2/28/2020 DAF4695DFF454.. Kristen Slodysko, Environmental Specialist Water Quality Regional Operations Section Fayetteville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: WQS Fayetteville Regional Office N-DrtF.7�srD.r.aDepsrt me- ntofEPvr-Dnir.er.ta:Qo-arty I D:vs*r.ofWater Resources Fayettev e F,eg:ora.:Offte 1 2.253reer,Street,5ute714 I Fay;etter;:e, North £sroEra2830J. PEq ... - 1, , �, 91CJ433-2,200 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 IF I 3 I NC0003573 111 12 I 20/02/05 I17 18 I Q I 19 I G I 201 I 211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 671 70 I z I 71 I —n I 72 I n, I 73 I I 174 751 I I I I I I I80 I —I I� I I i Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES oermit Number) 09:40AM 20/02/05 12/03/01 Chemours Company -Fayetteville Works 22828 NC Highway 87 West Exit Time/Date Permit Expiration Date Fayetteville NC 283067332 12:40PM 20/02/05 16/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Jamie Ray Lewis/ORC/910-678-1219/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Brian Long,22828 Hwy 87 W Fayetteville NC 28306H910-678-1415/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of InsgectoNs,) Agency/Office/Phone and Fax Numbers Date Docu igned y: / Kristen N Slodysko ViSfLU, (� y,.S� DWR/FRO WQ/919-433-3300/ 2/28/2020 EDAF4695DFF454... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: Mark Brantley F(q evaAclWQ/910-433-3300 Ext.727/ 2/28/2020 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NC0003573 I11 121 20/02/05 117 18 JBI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Comments: • The facility was clean and neat in appearance at the time of inspection. • Records for sample collection, analytical results, and plant maintenance were well organized. • During the inspection it was noted that thermometers in composite sampling units were not annually calibrated. Thermometers should be calibrated annually to insure that proper sample holding temperatures are maintained. In response to this issue, the facility has purchased new NIST traceable thermometers, which will be installed in the composite sampling units and will be calibrated annually. • Flow monitoring data for 11/20/2019 was missing from November 2019's eDMR. This omission was corrected during the inspection and an updated eDMR was submitted to the division. • A Whole Effluent Toxicity sample was collected at Outfall 002 from Chemour's 24-hour composite sampling equipment on February 4th and 6th for use in a chronic Ceriodaphnia dubia pass/fail toxicity test. These samples were sent to the Division of Water Resources (AT) Laboratory (located on Reedy Creek Road in Raleigh). The Whole Effluent Toxicity pass/fail test resulted in "PASS". Page# Permit: NC0003573 Owner - Facility: Chemours Company -Fayetteville Works Inspection Date: 02/05/2020 Inspection Type: Bioassay Compliance Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Plant analyzes for PH, DO, and sludge fudge. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ Page# 3 Permit: NC0003573 Inspection Date: 02/05/2020 Record Keeping Facility has copy of previous year's Annual Report on file for review? Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Bioassay Compliance Yes No NA NE ❑ ❑ ■ ❑ Comment: ComDared analvtical data to eDMR from Mav 2019. Found no errors or inconsistencies between the two. BIMs indicated a missing flow value for 11/20/2019. Missing value was due to transcription error. eDMR was updated to include the flow value during the inspection. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ Comment: Flow meter last calibrated on 11/11/19 for Outfalls 001 and 002. Solids Handling Equipment Yes No NA NE Is the equipment operational? 0 ❑ ❑ ❑ Is the chemical feed equipment operational? 0 ❑ ❑ ❑ Is storage adequate? 0 ❑ ❑ ❑ Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ❑ ❑ ❑ Is the site free of sludge buildup on belts and/or rollers of filter press? 0 ❑ ❑ ❑ Is the site free of excessive moisture in belt filter press sludge cake? 0 ❑ ❑ ❑ The facility has an approved sludge management plan? ❑ ❑ 0 ❑ Comment: Sludge is disposed of at a landfill in Alabama. Chemical Feed Yes No NA NE Is containment adequate? 0 ❑ ❑ ❑ Is storage adequate? 0 ❑ ❑ ❑ Are backup pumps available? 0 ❑ ❑ ❑ Is the site free of excessive leaking? 0 ❑ ❑ ❑ Comment: Page# 4 Permit: NC0003573 Inspection Date: 02/05/2020 Chemical Feed Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Bioassay Compliance Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Yes No NA NE Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: At the time of inspection, the two mixers had been pulled from the equalization basin for routine maintenance. ORC reports that the mixers will be placed back in the basin after inspection. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) 0 ❑ ❑ ❑ Comment: Sludge level in the large clarifier was approximately 4.5 ft. Clarifier is 16 ft deep. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ Celsius)? Page# 5 Permit: NC0003573 Owner - Facility: Chemours Company -Fayetteville Works Inspection Date: 02/05/2020 Inspection Type: Bioassay Compliance Laboratory Yes No NA NE Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑ Comment: Lab is neat and organized. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: Calibration needs to be verified annually for the thermometers in composite sampling units. Annual calibration is necessary to insure that proper sample holding temperatures are being maintained. Facility has purchased NIST traceable thermometers, which they will use in composite samplers going forward. Upstream / Downstream Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Facility is a member of the Middle Cape Fear River Basin Association. Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Comment: Yes No NA NE ❑ ❑ ■ ❑ Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 6 Regional Inspectors' Checklist for Field Parameters [This checklist is to be completed during regional plant inspections for Field Laboratories, denoted by certification numbers in the 5000s] Facility Name: The Chemours Company Regional Plant Inspector: Kristen Slodysko NPDES #: NC0003573 Regional Inspector Contact #:910-433-3343 Field Lab Certification #: 5105 Region: FRO Lab Contact: Jamie Lewis Date: 2/5/20 I. Check the parameter(s) performed at this site for reporting purposes. ❑ Total Residual Chlorine (TRC) ® Temperature (TEMP) ❑ Specific Conductivity (SC) ® pH ❑ Dissolved Oxygen (DO) ❑ Settleable Residue (SETT) II. General Laboratory (note any exceptions in section XI) Are instruments, meters, probes, photometric cells, etc. maintained in good condition? ® Yes ❑ No Are standards, reagents and consumables used within manufacturer expiration dates? [TRC gel standard is exempt.] ® Yes ❑ No Are the following items documented ( where applicable): Item TRC pH TEMP DO SC SETT Date of sample collection* NA Y Y NA NA NA Time of sample collection* NA Y Y NA NA NA Sample collector's initials or signature NA Y Y NA NA NA Date of sample analysis* NA Y Y NA NA NA Time of sample analysis* NA Y Y NA NA NA Analyst initials or signature NA Y Y NA NA NA Sample site i.e., facility name, location, ID, etc. NA Y Y NA NA NA Instrument ID NA Y Y NA NA NA Parameter NA Y Y NA NA NA Data qualifiers, when required NA I NA I NA NA NA NA *Date and time of sample collection and analysis may be the same for in situ or on -site measurements. III. Total Residual Chlorine — reference method: Total Residual Chlorine meter make and model: Is a check standard analyzed each day of use? Circle one: gel or liquid standard ❑ Yes ❑ No What is the assigned/observed value of the daily check standard? Is a 5-point calibration verification performed? Note date of last verification: ❑ Yes ❑ No Alternatively, does the lab construct a linear regression, using 5 standards, to calculate results? Note date of last calibration curve constructed: ❑ Yes ❑ No True values: ❑ pg/L ❑ mg/L Obtained values: ❑ pg/L ❑ mg/L What program are samples analyzed on? Are results reported in proper units? Check one: ❑ p /L ❑ mg/L ❑ Yes ❑ No Are results reported between the facility's permit limit and the compliance limit of 50 pg/L? If value is less than the low standard, report as "<x", where x=low standard conc. ❑ Yes ❑ No Are samples analyzed within 15 minutes of collection? ❑ Yes ❑ No IV. pH — reference method: pH meter make and model: Hach, HQ440d Multi Is the pH meter calibrated with at least 2 buffers per mfg's instructions each day of use? Note buffers used: 4,7, and 10 ® Yes ❑ No Is the pH meter calibration checked with an additional buffer each day of use? Note check buffer used: 7 ❑ Yes ❑ No Does the check buffer read within ±0.1 S.U. of the known value? ® Yes ❑ No Are the following items documented: Meter calibration? ® Yes ❑ No Check buffer reading(s)? ® Yes ❑ No Are samples analyzed within 15 minutes of collection? ® Yes ❑ No Are sample results reported to 0.1 pH units? I ® Yes ❑ No V. Temperature — reference method: What instrument(s) is used to measure temperature? Check all that apply: ❑ pH meter ❑ DO meter ❑ Conductivity meter ❑ Digital thermometer ❑ Glass thermometer Is the instrument/thermometer calibration checked at least annually against a NIST traceable or NIST certified thermometer? ® Yes ❑ No Are temperature corrections even if zero posted on the instrument/thermometer? ® Yes ❑ No Are samples measured in situ or on -site? [REQUIRED - there is no holding time for temperature] ® Yes ❑ No Are sample results reported in degrees C? ® Yes ❑ No VI. Dissolved Oxygen — reference method: DO meter make and model: Is the air calibration of the DO meter performed each day of use? ❑ Yes ❑ No Are the following items documented: Meter calibration? ❑ Yes ❑ No Are samples analyzed within 15 minutes of collection? ❑ Yes ❑ No Are results reported in m /L? ❑ Yes ❑ No VII. Conductivity — reference method: Conductivity meter make and model: Is the meter calibrated daily according to the manufacturer's instructions? Note standard used this is generally a one -point calibration): ❑ Yes ❑ No Is a daily check standard analyzed? Note value: ❑ Yes ❑ No Are the following items documented: Meter calibration? ❑ Yes ❑ No Are samples analyzed within 28 days of collection? ❑ Yes ❑ No Are results reported in mhos/cm some meters display equivalent S/cm units)? ❑ Yes ❑ No Vill. Settleable Residue — reference method: Does the laboratory have an Imhoff Cone in good condition? ❑ Yes ❑ No Is the sample settled for 1 hour? ❑ Yes ❑ No Is the sample agitated after 45 minutes? ❑ Yes ❑ No Are the following items documented: Volume of sample analyzed? Note volume analyzed: ❑ Yes ❑ No Date and time of sample analysis(settling start time)? ❑ Yes ❑ No Time of agitation after 45 minutes of settling? ❑ Yes ❑ No Sample analysis completion (settling end time)? ❑ Yes ❑ No Are samples analyzed within 48 hours of collection? ❑ Yes ❑ No Are results reported in ml/L? ❑ Yes ❑ No IX. Was a paper trail (comparing contract lab and on -site data to DMRs) performed? If so, list months reviewed: May 2019 ® Yes ❑ No X. Is follow-up by the Laboratory Certification program recommended? ❑ Yes ® No XI. Additional comments: Lab is neat and well organized. Please submit a copy of this completed form to the Laboratory Certification program at: DWR Lab Certification, Water Sciences Section, 1623 Mail Service Center, Raleigh NC, 27699-1623 Electronic copies may be emailed to linda.chavis @_ncdenr.gov. Docu Signed by: Revision 09/11/2015 ViSfLA& �(Ad_�SL6 2/14/2020 2CDAF4695DFF454...