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Home My WebLink AboutNCS000010_Fe and Zn Waiver_20170417Energy, Mineral & Land Resources ENVIRONMENTAL QUALITY Dieter Bettinger Envonik Corporation 2401 Doyle Street Greensboro, NC 27406 Subject: Compliance Inspection Permit No. NCS 000010 April 7, 2017 Envonik Industries - Greensboro Guilford County Dear Mr. Bettinger: ROY COOPER Governor MICHAEL S. REGAN Secretory TRACY DAVIS Director On April 4, 2017, Glen White of the North Carolina Department of Environmental Quality — Division of Energy, Minerals and Land Resources met with Ken Meyer (EHS Manger) at the Envonik facility located at 2401 Doyle Street in Greensboro to investigate Zinc and Iron exceedances that have resulted in Tiered Response Monitoring for almost two (2) decades. Investigation determined that Envonik has made significant attempts to determine the cause and contributors of exceedances of both elements. Stormwater has been tested both upstream and downstream of the site and in most cases, discharge was lower at Envonik's discharge locations. The resulting data appears to show that it is not a significant contributor to exceedance of either zinc nor iron and industrial activities do not appear to be a large contributors. (A spreadsheet from Envonik with several years of data is maintained in the DEMLR - WSRO file.) Given the facts as provided above, Envonik is hereby Granted a Waiver to Tiered Response Monitoring for Iron and Zinc and may return to Semi -Annual monitoring for these elements as with all other required parameters. This waiver applies to Iron and Zinc only. Enclosures: Inspection Report Sincerely, Matthew E. Gantt, P.E. Regional Engineer Land Quality Section Winston-Salem Regional Office cc: Division of Mineral and Land Resources (WSRO) State of North Carolina I Environmental (duality 1 Energy, Mineral and Land Resources Winston-Salem Regional Office 450 Hanes Mill Road. Suite 300 I Winston-Salem. NC 27103 336 T76 9800 Energy, Mineral & Land Resources ENVIRONMENTAL QUALITY Dieter Bettinger Envonik Corporation 2401 Doyle Street Greensboro, NC 27406 Subject: Compliance Inspection Permit No. NCS 000010 April 7, 2017 Envonik Industries - Greensboro Guilford County Dear Mr. Bettinger: ROY COOPER Governor MICHAEL S. REGAN Secretary TRACY DAVIS Director . On April 4, 2017, Glen White of the North Carolina Department of Environmental Quality — Division of Energy, Minerals and Land Resources met with Ken Meyer (EHS Manger) at the Envonik facility located at 2401 Doyle Street in Greensboro, to conduct a compliance inspection. The visit was requested by inspector to investigate the cause of exceedances of certain parameters monitored per the permit. This inspection consists of review of the facility outfalls and possible exposures. Mr. Meyers assistance with the inspection was greatly appreciated. A prior inspection was conducted by the City of Greensboro Water Resources Department on February 6, 2017. No deficiencies were observed. Permit: This facility holds Individual Stormwater Permit NCS000010 to discharge stormwater from industrial activity under the National Pollutant Discharge Elimination System (NPDES). The latest revision of the permit became effective February 1, 2010 and expired on January 31, 2015. Application was made prior to expiration as required and it remains under review. The facility may continue to operate under the expired permit until a new permit is issued. Records/Reports: This facility was required to develop and maintain a Stormwater Pollution Prevention Plan (SPPP) in accordance with Part II, Section A of the permit. All qualitative and analytical monitoring records are required to be maintained with the SPPP for a minimum of five (5) years. Records appear to be current and complete. Facility Site Review: This facility produces super absorbent polymers that are used in many areas of industry and for individual use. This plant held the patent for its product until its expiration. Disposable diapers are an example of a consumer product that uses the super absorbent polymers. There are +/- 170 employees at the Envonik Facility working on one of two 12 hour shifts. Stage oFNorth Carolina I Emiranrnerual Quality Cnergy, Mineral and Land Resources Winston-Salem Regional Office 450 Hanes Mill Road. Suite 300 ( Winston-Salem. NC 27103 336 7!6 9800 Effluent Receiving Waters: Effluent from this facility discharges to Mile Run Creek, a class WS-V; NSW of the Cape Fear River Basin. Self -Monitoring Program: This facility is required to provide Qualitative and Analytical Monitoring twice annually. Analytical Monitoring is required per the stormwater permit under current operating procedures. Parameters for Zinc and Iron have caused the facility to fall into Tier II and Then Tier III for analytical monitoring and they have been monitoring those parameters monthly for almost two decades. Mr. Meyers has even monitored offsite stormwater upstream and downstream of the property to provide comparative data. Results show that in most cases, stormwater leaves the Envonik facility with lower Iron and Zinc levels than the samples tested from upstream sources. It does not appear that industrial activities at this site are a significant factor in the exceedance of either parameter. The property is surrounded by heavily travelled streets, an auto body shop, and a hand soap and hand lotion manufacturer. Relief from Tiered Response to monitoring for Iron and Zinc will be granted under separate cover. The facility was found to be compliant with its industrial stormwater permit. If you have questions or need additional information, please contact Glen White at (336) 776-9660. Enclosures: Inspection Report Sincerely, Matthew E. Gantt, P.E. Regional Engineer Land Quality Section Winston-Salem Regional Office cc: Division of Mineral and Land Resources (WSRO) State of N'orthCarolina (6ivGonmcntril Qtr<Jil.y Energy, Mineral and Land Resources Winston-Salem Regional Office 1 450 Hanes Mill Road. Suite 300 I Winston-Salem. NC 27103 336 776 9800 Permit: NCS000010 SOC: County: Guilford Region: Winston-Salem Contact Person: Ken Meyer Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Compliance Inspection Report Effective: 02/01/10 Expiration: 01/31/15 Owner: Evonik Corp Effective: Expiration: Facility: Evonik Corp 2401 Doyle St Inspection Date: 04/04/2017 Primary Inspector: Glen White Secondary Inspector(s): Title: EHS Mgr. Entry Time: 10:OOAM Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Certification: Greensboro NC 27407 Phone: 336-333-3510 Phone: Exit Time: 12:OOPM Phone: 336-776-9800 Inspection Type: Compliance Evaluation Page: 1 Permit: NCS000010 Owner - Facility: Evonik Corp Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: (See Compliance Letter) Compliant. Page: 2 Permit: NCS000010 Inspection Date: 04/04/2017 Analytical Monitorinq Has the facility conducted its Analytical monitoring? Owner - Facility: Evonik Corp Inspection Type: Compliance Evaluation # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Reason for Visit: Routine MIT'"My"! LAREJU Comment: This facility has been in Tier III Response (mont_hlv)_monitorinq for manv vears for exceedances of Iron and Zinc. All other required parameters have consistently been within required parameters with only a few exceedances of TSS and COD. Sampling records are well kept and semi-annual monitoring conducted on all other parameters as allowed. Mr. Meyers has made significant efforts to find and prove the cause of exceedances and records show that Envonik is not likely a significant contributor to zinc or iron exceedances. No deficiencies. Given the facts found in the monitoring records spreadsheet (copy in WSRO file) Erivonik will be granted a waiver from Tiered Response monitoring for Iron and Zinc only and may return to semi-annual monitoring for those elements as with other parameters. Exceedance should be noted in semi-annual monitoring. The waiver does not apply to any other required parameters Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 11 R ❑ # 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? Comment: Mr. Meyers walked the grounds of the facilitv with the inspector and all outfalls were observed during inspection. All were clear of debris. Some might have less than desirable safety concerns for the person collecting samples. All tank farms have secondary containment that is discharged to City wastewater once inspected as permits require. No deficient. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ Comment: Records complete. Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? Page: 3 Permit: NCS000010 Owner - Facility: Evonik Corp Inspection Date: 04/04/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE # Does the Plan include a BMP summary? N ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? E ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑ # Does the facility provide and document Employee Training? N ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? 0❑ ❑ ❑ # Is the Plan reviewed and updated annually? 0❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ® ❑ ❑ ❑ Comment: SPPP well prepared and well maintained. Certifications, training, responsible party/emergency contacts, inspection records all current. No deficiencies. Page: 4