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Home My WebLink AboutWQ0001492_Compliance Evaluation Inspection_20210526DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director Certified Mail # Return Receipt Reauested Frank R Barone Occidental Chemical Corporation 5408 Holly Shelter Rd Castle Hayne, NC 28429 tta SPATE Q„ Q� a•+m.0 O Y QUAM1V\dam# NORTH CAROLINA Environmental Quality May 26, 2021 SUBJECT:Compliance Inspection Report Elementis Chromium Castle Hayne Manufacturing Facility Non -discharge Permit No. WQ0001492 New Hanover County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Elementis Chromium Castle Hayne Manufacturing Facility on 4/13/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non -discharge Permit No. WQ0001492 and to support the Central Office/Non-Discharge Branch (CO) with the review of the permit renewal application package. The Regional Office findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report" and were also provided to the CO. There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. However, it is required that the permittee addresses the comments from the CO e-mailed on 05/20/2021. If you should have any questions, please do not hesitate to contact Morella Sanchez -King with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215 or via email at morel la.sanchez-king@ncdenr.gov. ATTACHMENTS Cc: Laserfiche Sincerely, DocuSigned by - EH, ullk "c� K;s'& 3ABA14AC7DC434... Morella Sanchez -King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ D_E Q�� North Carolina Department of Environmental Quality I Division of Water Resources Wilmington Regional Office 127 Cardinal Drive Extension Wilmington, North Carolina 28405 ft /`� 910.796,7215 DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 Compliance Inspection Report Permit: WQ0001492 Effective: 09/01/16 Expiration: 08/31/21 Owner : Occidental Chemical Corporation SOC: Effective: Expiration: Facility: Elementis Chromium Castle Hayne Manufactur County: New Hanover 5408 Holly Shelter Rd Region: Wilmington Castle Hayne NC 28429 Contact Person: Frank R Barone Title: Site Manager Phone: 910-675-7310 Directions to Facility: The facility is located on Holly Shelter Road (NCSR 1002) approximately 1 mile east of 1-40. System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0003875 Elementis Chromium Inc - Castle Hayne Plant Inspection Date: 04/13/2021 Entry Time 02:10PM Exit Time: 03:10PM Primary Inspector: Morella Sanchez -King Docusigned bL�y::Phone: 910-796-7218 Secondary Inspector(s): EH a1 aE3ABA14AC7DC434...� ection: Other Inspection Type: Compliance Evaluation p p Yp p Permit Inspection Type: Surface Disposal of Residual Solids(503 Exempt) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Land Application Site (See attachment summary) Page 1 of 5 DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 Permit: WQ0001492 Owner - Facility: Occidental Chemical Corporation Inspection Date: 04/13/2021 Inspection Type: Compliance Evaluation Reason for Visit: Other Inspection Summary: Geoff Kegley and Morella Sanchez King performed a site inspection to the Elementis Chromium Facility on 04/13/2021. We appreciate the kindness and support offered by Sean Coury and Scott Drury during the inspection. The inspection was to document the compliance of the facility with the requirements of the permit and to provide recommendations to the Central Office for permit renewal. The facility is deemed complaint. The following aspects were noted in the staff report for the renewal of the permit. 1. Permit Description The description of the current permit refers the operation of the residuals management program which consists of the surface disposal of Industrial Byproducts, the approved residual sources in Attachment A, the disposal sites in Attachment B, and the groundwater monitoring schedule in Attachment C. The permittee refers to these wells as the "SDIBR Permit compliance wells". The current permit description does not include the groundwater monitoring related to the Corrective Action Plan (L-CAP) approved in July 1999. It would be benefitial that the permit mentions the monitoring wells associated with the L-CAP since they are also SDIBR wells. 2. Residual Application: Annual residuals reports during the permit cycle indicate compliance with permit requirements. 3. Groundwater Monitoring: As indicated above, two groundwater monitoring programs take place at the site: (a) GW Monitoring wells currently listed in the permit (also referred as SDIBR wells by the permittee); and (b) Monitoring wells related to the L-CAP. a. Groundwater Monitoring Disposal basins (currently in the permit): The permit is for the continued operation of a residuals management program consisting of the surface disposal of industrial byproduct residuals generated by the Elementis Chromium Castle Hayne Manufacturing Facility (NPDES Permit NC0003875). The non -discharge permit (W00001492) requires 24 monitoring wells, sixteen of which overlap with the wells required by the L-CAP and also includes 8 additional wells which surround the plant process area and the closed former sludge lagoon. The wells are sampled in July and November for chloride, total chromium, total iron, total nickel, pH, and TDS. b. GW Monitoring L-CAP: Groundwater exceedances are being addressed under the natural attenuation corrective action plan mentioned in item 1 (L-CAP). The overall trend in COCs shows lowering from historic highs. It appears that natural attenuation is successfully implemented. However, there were some total chromium exceedances, though it was atypical and likely in response to flooded conditions caused by Hurricane Florence. c. Non -Compliance Issues: • 2018-2010 Summary: Record precipitation from Hurricane Florence in 2018 produced some anomalous values leading to exceedances for iron and TDS for both the upper and lower aquifers. Permit -required monitoring was completed in November 2018, two months after Hurricane Florence. Total chromium was detected above the 2L standard of 10 ug/I in MW-1/CPW-13S, MW-9/CPW-9D, and MW-10/CPW-10D (11, 19, and 18 ug/l, respectively) which do not typically contain elevated total chromium concentrations. MW-1 is located along the southeastern perimeter of Quarry Section 2 and MW-9 and MW-10 are located along the western perimeter of Quarry Section 1 (adjacent to the Northeast Cape Fear River). During the July 2019 permit -required sampling event, total chromium was detected above the 2L standard in well MW-2/CPW-14S (upper aquifer, 37 ug/1) and MW-9/CPW-9D and MW-1 5/CPW-1 5D (lower aquifer, 19 and 232 ug/l, respectively). Wells were resampled in August 2019 and total chromium was above the 2L standard in two of the wells MW-2/CPW-14S (120 ug/1) and MW-9/CPW-9D (150 ug/1), total chromium was not detected in MW-1 5/CPW-1 5D. • 2020-2021 Summary: Permit -required compliance groundwater monitoring schedule was completed in 2020 and 2021. Results of analysis of the July and November 2020 samples, and March 2021 indicate total nickel was detected above the 2L standard of 100 ❑g/I (228, 723, and 332 ug/I, respectively) in samples collected from MW-17/CPW-7S. Total nickel is not a COC which is being addressed by the L-CAP. Page 2 of 5 DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 Permit: WQ0001492 Owner - Facility: Occidental Chemical Corporation Inspection Date: 04/13/2021 Inspection Type: Compliance Evaluation Reason for Visit: Other Monitoring well MW-17/CPW-7S is located along the eastern perimeter of Quarry Section 1 between the plant production area (PPA) of the site and the Quarry. Residual solids generated by the Elementis Chromium Castle Hayne Manufacturing Facility's wastewater treatment plant (WWTP) are currently disposed in Quarry Section 2, and therefore not in the area of monitoring well MW-17/CPW-7S. Compliance monitoring samples have been analyzed for total nickel during only those monitoring events completed after issuance of the current Permit (i.e., since November 2016). With the exception of the total nickel detections in MW-17/CPW-7S during July and November 2020 and March 2021, total nickel was detected in only one other compliance sample (below the 2L standard at a concentration of 81 ❑g/I in the November 2018 sample from Upper Aquifer well MW-3/CPW-15S). • The WiRO suggests that the new permit includes a condition to address recurrent exceedances to the 2L standards. For example, if monitoring results show exceedances of the same parameter after 3 consecutive sampling events, a localized site assessment or modeling evaluation should be performed to (1) determine the cause of such exceedances and (2) plan a corrective action in the affected area. d. Summary table of all wells: The WiRO recommends to expand Attachment C to include L-CAP wells and their sampling schedule. Similarly, the well Identification List (Site Map) should identify all monitoring wells — including the ones currently listed and the L-CAP wells. 4. Remaining Disposal Volume in Quarry, Sections 1 and 2 The renewal application dated March 2, 2021, summarizes the calculations of the life remaining in Sections 1 and 2 of the Quarry. Calculations were made based on the maximum bichromate equivalent (BE) production of 360 tons per day resulting in a life remaining of 3.4 years for Section 1 and 4.0 years for Section 2. The combined life remaining for both basins would be - 7 years while the life remaining in each of the basins would be less than the length of the upcoming permit cycle. Please provide an updated estimate of the life remaining in the basins considering the average typical production rate. Page 3 of 5 DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 Permit: WQ0001492 Owner - Facility: Occidental Chemical Corporation Inspection Date: 04/13/2021 Inspection Type: Compliance Evaluation Reason for Visit: Other Type Yes No NA NE Distribution and Marketing ❑ Land Application Record Keeping Yes No NA NE Is GW monitoring being conducted, if required? 0 ❑ ❑ ❑ Are GW samples from all MWs sampled for all required parameters? 0 ❑ ❑ ❑ Are there any GW quality violations? 0 ❑ ❑ ❑ Is GW-59A certification form completed for facility? 0 ❑ ❑ ❑ Is a copy of current permit on -site? 0 ❑ ❑ ❑ Are current metals and nutrient analysis available? 0 ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? ❑ ❑ 0 ❑ Are PAN balances being maintained? ❑ ❑ 0 ❑ Are PAN balances within permit limits? ❑ ❑ 0 ❑ Has land application equipment been calibrated? 0 ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? ❑ ❑ 0 ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? ❑ ❑ 0 ❑ Are hauling records maintained and up-to-date? ❑ ❑ 0 ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑ Comment: Non -Compliance issues: • 2020-2021 Summarv: Permit-reauired comDliance aroundwater monitorina schedule was completed in 2020 and 2021. Results of analysis of the July and November 2020 samples, and March 2021 indicate total nickel was detected above the 2L standard of 100 ❑O (228, 723, and 332 ua/I. resDectively) in samDles collected from MW-17/CPW-7S. Total nickel is not a COC which is being addressed by the L-CAP Land Application Site Yes No NA NE Is a copy of the permit on -site during application events? 0 ❑ ❑ ❑ Is the application site in overall good condition? ❑ ❑ ❑ Is the site free of runoff/ponding? ❑ ❑ ❑ If present, is the application equipment in good operating condition? ❑ ❑ ❑ Are buffers being maintained? ❑ ❑ ❑ Page 4 of 5 DocuSign Envelope ID: E3057E65-9C90-4417-BD97-DBB496CA0941 Permit: WQ0001492 Owner - Facility: Occidental Chemical Corporation Inspection Date: 04/13/2021 Inspection Type: Compliance Evaluation Reason for Visit: Other Are limiting slopes buffered? 10% for surface application ❑ ❑ 0 ❑ 18% for subsurface application ❑ ❑ 0 ❑ Are there access restrictions and/or signs? 0 ❑ ❑ ❑ Is the application site free of odors or vectors? 0 ❑ ❑ ❑ Have performance requirements for application method been met? For injection? ❑ ❑ 0 ❑ For incorporation? ❑ ❑ 0 ❑ Does permit require monitoring wells? 0 ❑ ❑ ❑ Have required MWs been installed? 0 ❑ ❑ ❑ Are MWs properly located w/ respect to RB and CB? ❑ 0 ❑ ❑ Are MWs properly constructed (including screened interval)? 0 ❑ ❑ ❑ Is the surrounding area served by public water? 0 ❑ ❑ ❑ If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ 0 ❑ Are soil types consistent w/ Soil Scientist report/evaluation? ❑ ❑ 0 ❑ Is the water table greater than 173' bls. ❑ ❑ ❑ Is application occurring at the time of the inspection? 0 ❑ ❑ ❑ Comment: There are several wells located inside the review boundary. The site has constraints (Northeast Cape Fear River) that prevent moving the wells to the RB and away from the quarries. Page 5 of 5