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HomeMy WebLinkAboutNC0003573_Compliance Evaluation Inspection_20211210ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Dawn Hughes The Chemours Company Fc LLC 22828 Hwy 87 W Fayetteville, NC 28306 NORTH CAROLINA Environmental Qualify December 10, 2021 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 on 12/03/2021. 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". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. Inspection Summary The facility is well -maintained and orderly. All records, including laboratory and plant maintenance, were available and complete at the time of the inspection. A permit application was submitted in 2016. The plant records pH, DO, and sludge judge for process control. The 2020 DMRs for Jan. and Feb. were reviewed during the inspections. No inaccuracies or missing entries were found. The laboratory was neat and well -organized. BOD and TSS analysis are performed by TBL. Meritech is contracted to perform toxicity tests. Flow meters are calibrated every six months. The last calibration for both outfalls (001 and 002) occurred on 8/19/2021. Kuraray is using 80-90% less water due to process change. The facility is downsizing, therefore the existing predigestor tank (currently empty) will be used to accommodate diminished flow. The Division is aware that the predigestor is currently out of service. Two new blowers are currently being installed. DE North Carolina Department of Environmental Quality 1 Division of Water Resources Fayetteville Regional Office 1225 Green Street, Suite 714 I Fayetteville, North Carolina 28301 910.433.3300 The large aeration tank will be used for stormwater control. Two aerators were in use during the inspection. Each tank is drained and serviced every five years. Two out of three mixers in the equalization basin were operational. Parts have been ordered for repair of the third mixer. The sludge blanket level in the secondary clarifier was 1.5 ft. The clarifier is 16 ft. deep. If you should have any questions, please do not hesitate to contact Stephanie Zorio with the Water Quality Regional Operations Section in the Fayetteville Regional Office at 910-433-3300 or via email at stephanie.zorio@ncdenr.gov. ATTACHMENTS Cc: laserflche Sincerely, DocuSigned by: l]*: A99704FAED5D494... Dr. Stephanie D. Zorio, Environmental Specialist Water Quality Regional Operations Section Fayetteville Regional Office Division of Water Resources, NCDEQ DE North Carolina Department of Environmental Quality Division of Water Resources Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, North Carolina 28301 910.433.3300 United States Environmental Protection Agency E PA Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code 1 IN I 2 L 21IIIIII IIIIIIIIIII NPDES yr/mo/day Inspection 3 I NC0003573 111 121 21/12/03 117 Type 1810I IIIIIIIIIII Inspector Fac Type 191S I 2011 IIIIIII I IIIIII P6 Inspection Work Days 671 I Facility Self -Monitoring Evaluation Rating B1 QA Reserved 70I I 711 172 I N I 731 1 74 71 I I I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Chemours Company -Fayetteville Works 22828 NC Highway 87 West Fayetteville NC 283067332 Entry Time/Date 10:30AM 21/12/03 Permit Effective Date 12/03/01 Exit Time/Date 12:45PM 21/12/03 Permit Expiration Date 16/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jamie Ray Lewis/ORC/910-678-1219/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Brian Long,22828 Hwy 87 W Fayetteville NC 28306//910-678-1415/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) Stephanie Zorio of Inspector(s) Agency/Office/Phone and Fax Numbers Date —Docusignedby: DWR/FRO WQ/910-433-3322/ 12/22/2021 "-A99704FAED5D494... Signature of Mana C4R ilakti Yewer Agency/Office/Phone and Fax Numbers Date Mark Brantley"""�JWR/FRO WQ/910 433-3300 Ext.727/ 12/22/2021 E4E1A9691DB248E... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 31 NPDES yr/mo/day NC0003573 111 121 21/12/03 117 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The facility is well -maintained and orderly. All records, including laboratory and plant maintenance, were available and complete at the time of the inspection. A permit application was submitted in 2016. The plant records pH, DO, and sludge judge for process control. The 2020 DMRs for Jan. and Feb. were reviewed during the inspections. No inaccuracies or missing entries were found. The laboratory was neat and well -organized. BOD and TSS analysis are performed by TBL. Meritech is contracted to perform toxicity tests. Flow meters are calibrated every six months. The last calibration for both outfalls (001 and 002) occurred on 8/19/2021. Kuraray is using 80-90% less water due to process change. The facility is downsizing, therefore the existing predigestor tank (currently empty) will be used to accommodate diminished flow. The Division is aware that the predigestor is currently out of service. Two new blowers are currently being installed. The large aeration tank will be used for stormwater control. Two aerators were in use during the inspection. Each tank is drained and serviced every five years. Two out of three mixers in the equalization basin were operational. Parts have been ordered for repair of the third mixer. The sludge blanket level in the secondary clarifier was 1.5 ft. The clarifier is 16 ft. deep. Page# 2 Permit: NC0003573 Inspection Date: 12/03/2021 Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new MODE application? Is the facility as described in the permit? • ❑ ❑ ❑ # Are there any special conditions for the permit? El • El El Is access to the plant site restricted to the general public? • ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment: A permit application was submitted in 2016. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable MODE Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The plant records PH, DO, and sludge judge for process control. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • • • Page# 3 Permit: NC0003573 Inspection Date: 12/03/2021 Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Compliance Evaluation Record Keeping 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? Facility has copy of previous year's Annual Report on file for review? Comment: The 2020 DMRs for Jan. and Feb. were reviewed during the inspections. No inaccuracies or missing entries were found. Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Yes No NA NE • ❑ ❑ ❑ ▪ El El El ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: BOD and TSS analysis is performed by TBL. Meritech is contracted to perform toxicity tests. Equalization Basins Yes No NA NE Is the basin aerated? • ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? • ❑ ❑ ❑ Is the basin free of excessive grease? • El El El Are all pumps present? • El El El Are all pumps operable? • ❑ El El Are float controls operable? • El El El Are audible and visual alarms operable? ❑ El • El # Is basin size/volume adequate? • El El El Comment: Two out of three mixers in the equalization basin are operational. Parts have been ordered for repair of the third mixer. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? ■ El El El Are surface aerators and mixers operational? • El El El Page# 4 Permit: NC0003573 Inspection Date: 12/03/2021 Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE 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/I) • ❑ ❑ ❑ Comment: Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Comment: Sludge blanket level was 1.5 ft. The clarifier is 16 ft. deep. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Comment: Flow meters are calibrated every six months. The last calibration for both outfalls (001 and 002) occured on 8/19/2021. Chemical Feed Yes No NA NE Is containment adequate? • ❑ ❑ ❑ Is storage adequate? • ❑ ❑ ❑ Are backup pumps available? • ❑ ❑ ❑ Is the site free of excessive leaking? • ❑ ❑ ❑ Page# 5 Permit: NC0003573 Inspection Date: 12/03/2021 Owner - Facility: Chemours Company -Fayetteville Works Inspection Type: Compliance Evaluation Chemical Feed Comment: Yes No NA NE Effluent Sampling Yes No NA NE Is composite sampling flow proportional? • ❑ ❑ ❑ Is sample collected below all treatment units? • ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ ❑ Is the tubing clean? • ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 • ❑ ❑ ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type • ❑ ❑ ❑ representative)? Comment: Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Yes No NA NE • ❑ ❑ ❑ Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, MI El El El and sampling location)? Comment: The facility is a member of the Middle Cape Fear River Basin Association. 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: Stephanie Zorio Permit #: NC0003573 Regional Inspector Contact #: 919-368-6077 Field Lab Certification #: 5105 Region: FRO Lab Contact: Jamie Lewis 910-991-7390 Date: 12/3/2021 I. Check the parameter(s) performed at this site for reporting purposes. ❑ Total Residual Chlorine (TRC) ❑ Temperature (TEMP) ❑ Specific Conductance (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? /1 Yes ❑ No Are standards, reagents and consumables used within manufacturer expiration dates? [TRC gel standard is exempt.] Yes ❑ No Are the following items documented ( \I where applicable): Item TRC pH TEMP DO SC SETT Date of sample collection* NA X X NA NA NA Time of sample collection* NA X X NA NA NA Sample collector's initials or signature NA X X NA NA NA Date of sample analysis* NA X X NA NA NA Time of sample analysis* NA X X NA NA NA Analyst initials or signature NA X X NA NA NA Sample site (i.e., facility name, location, ID, etc.) NA X X NA NA NA Instrument ID NA X X NA NA NA Parameter NA X X NA NA NA Data qualifiers, when required NA NA 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: NA Is a check standard analyzed each day of use? (Circle one: gel or liquid standard) ❑ Yes ❑ No Does the check standard recover within ±10% of the known value? ❑ Yes ❑ No What is the assigned/observed value of the daily check standard? Is a 5-standard 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: ❑ pg/L ❑ mg/L ❑ Yes ❑ No Are results reported between the facility's permit limit and the compliance limit of 50 pg/L? ❑ Yes ❑ No Are results less than the low standard reported as "<x", where x=low standard conc.? ❑ Yes ❑ No Is DPD/buffer added within 15 minutes of collection? ❑ Yes ❑ No Is a post -analysis check standard analyzed if samples are analyzed at multiple sites? ❑ Yes ❑ No IV. pH — reference method: pH meter manufacturer 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, 10 ❑ No Yes Is the pH meter calibration checked with an additional buffer prior to sample analysis? Note check buffer used: 7 ❑ No Yes Does the check buffer read within ±0.1 S.U. of the known value? r Yes ❑ No Are the following items documented: Meter calibration? /1 Yes ❑ No Check buffer reading(s)? r Yes ❑ No Are samples analyzed within 15 minutes of collection? /1 Yes ❑ No Are sample results reported to 0.1 pH units on the eDMR? /1 Yes ❑ No Is a post -analysis check buffer analyzed if samples are analyzed at multiple sites? NA ❑ 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 thermometer? ❑ No r Yes Is NIST traceability documentation maintained on site? r Yes ❑ No Are samples measured within 15 minutes? r Yes ❑ No Are sample results reported in degrees C? r Yes ❑ No VI. Dissolved Oxygen — reference method: DO meter make and model: NA Is the air calibration of the DO meter performed each day of use? ❑ Yes ❑ No Is meter calibration documented? ❑ Yes ❑ No Are samples analyzed within 15 minutes of collection? ❑ Yes ❑ No Are results reported in mg/L? ❑ Yes ❑ No If samples are analyzed at multiple sites, is the meter recalibrated at each site or a post - analysis calibration verification performed? Yes ❑ No Does the post -analysis verification theoretical value agree within 0.5 mg/L of the meter calibration reading? ❑ Yes ❑ No VII. Conductivity — reference method: Conductivity meter make and model: NA 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 Is meter calibration documented? ❑ Yes ❑ No Are samples analyzed within 28 days of collection? ❑ Yes ❑ No Is a post -analysis check standard analyzed if multiple samples are analyzed? Are results reported in pmhos/cm (some meters display equivalent pS/cm units)? ❑ Yes ❑ No VIII. Settleable Residue — reference method: NA 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 (must use 1 L): ❑ 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: Jan., Feb. 2020 r Yes ❑ No X. Is follow-up by the Laboratory Certification program recommended? ❑ Yes /1 No XI. Additional comments: Lab was orderly and well -maintained. 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 Jennifer.seaver@ncdenr.gov. Revision 3/2021