NC0004952_Compliance Evaluation Inspection_20220203

ROY COOPER
Correrrror
ELIZABETH 5, 315BR
searrary
S. DAMEL SMITH
DorroDr
Mr. Lawrence Wolnik, Site Director
CNA Holding, LLC
2525 Blacksburg Road
Grover, NC 28073
Dear Mr. Wolnik:
NEORTH CAROL! NA
£nwironrrrrntaf Quality
February 3, 2022
Subject: Compliance Evaluation Inspection
Celanese — Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
Enclosed is a copy of the Compliance Sampling Inspection for the inspection conducted
at the subject facility on February 1, 2022, by Ori Tuvia. Randy Turner's cooperation during the
site visit was much appreciated. Please advise the staff involved with this NPDES Permit by
forwarding a copy of the enclosed report.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Ori Tuvia at [phone], or at [e-mail].
Cc: NPDES, MRO Files (Laserfiche)
Sincerely,
p-DocuSigned by:
A4.41tit, H P: t4
F161 FB69A2D84A3...
for
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
North Carolina Rcparlmcnt of Etwiranmenial Quality I Division of Water Resources
I,$i oec 1IIe Regional Office I bt0 East Center Avonue, Suite 301 I MocxrsvFlle. North Carolina 2836
704.6631691

United States Environmental Protection Agency
EPA 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
1 IN
Code
I 2
L
NPDES yr/mo/day Inspection Type Inspector Fac
3 I NC0004952 111 121 22/02/01 117 18110 19 I S I 201
Type
21IIIIII
IIIIIIIIIIIIIIIIII
I
IIIIII
IIIIIIIIIII
P6
Inspection
67I1.0
Work Days
Facility Self -Monitoring
I 70I4
Evaluation Rating
I 71IN
B1
I 72
QA
I N I
731
I
I I
Reserved
74 751
1
I
I I
I
I
I
180
l
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Celanese Shelby Facility
2525 Blacksburg Rd
Grover NC 28073
Entry Time/Date
09:55AM 22/02/01
Permit Effective Date
21/08/01
Exit Time/Date
11:30AM 22/02/01
Permit Expiration Date
26/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Randall L Turner/ORC/704-480-5793/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Lawrence Wolnik,2525 Blacksury Rd Grover NC 28073/Site Director/704-480-5728/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling Dispo: Facility 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) ' `' lj Agency/Office/Phone and Fax Numbers Date
and
Ori ATuvia
ve,
BB057A2DE017498...
@dc5(y)
E- DWR/MRO WQ/704-663-1699/ 2/3/2022
Signature of M
Andrew Pit
@f1901MicIAReviewer Agency/Office/Phone and Fax Numbers Date
e/r1"4' H t' " bWR/MRO WQ/704-663-1699 Ext.2180/ 2.3.22
F161 FB69A2D84A3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/mo/day
31 NC0004952 111 121 22/02/01
I17
Inspection Type
18 [j
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
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 ❑ ❑•❑
application?
Is the facility as described in the permit? • ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ • ❑ ❑
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: The subject permit expired; on 7/31/2026.
new permit added an upstream sampling.
The facilty permit limits are in pounds/day rather then mg/L.
Record Keeping Yes No NA NE
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? • ❑ ❑ ❑
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 records reviewed during the inspection were organized and well maintained.
DMRs, COCs, Bench sheets, Calibration logs and ORC visitation logs, were reviewed
for the period June 2021 through October 2021.
Page# 3

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
Inspection Type: Compliance Evaluation
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
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ • ❑
Comment: On -site effluent analyses (pH, temperature, TSS) are performed under the Company's
laboratory certification #221. Waypoint Laboratories. (BOD, oil & grease, total
nitrogen, total phosphorus, pollutant scan, fecal coliform) and ETT, Inc. (toxicity) have
also been contracted to provide analytical support. The laboratory instrumentation
used for field analyses appeared to be properly calibrated/verified and documented.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • El El El
Is sample collected below all treatment units? • ❑ El El
Is proper volume collected? • El El El
Is the tubing clean? • El ❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ El El El
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type • El El El
representative)?
Comment: The subject permit requires both composite and grab effluent samples.
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Comment:
Yes No NA NE
• ❑ ❑ ❑
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • El El El
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable El El El
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The wastewater facility appeared to be properly operated and well maintained. The
facility staff incorporate a comprehensive process control program with all
measurements being properly documented and maintained on -site.
Page# 4

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
Inspection Type: Compliance Evaluation
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
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
•
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
• ❑ • ❑
Comment: The process wastewater flows through three equalization basins (in series) prior to
combining with the domestic wastewater. Sodium hydroxide (pH adjustment) is added
to the first EQ Basin and phosphoric acid (nutrient supplement) is added on an
as -needed basis at the third EQ Basin. A fourth equalization tank is also available for
emergency situations.
Chemical Feed Yes No NA NE
Is containment adequate? • ❑ ❑ ❑
Page# 5

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
Inspection Type: Compliance Evaluation
Chemical Feed Yes No NA NE
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
II El El El
• ❑ ❑ ❑
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots? • El ❑ ❑
Are surface aerators and mixers operational? ■ El El El
Are the diffusers operational? ❑ El • El
Is the foam the proper color for the treatment process? • El El El
Does the foam cover less than 25% of the basin's surface? ■ El ❑ ❑
Is the DO level acceptable? • El El El
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El • El
Comment: only one of the aeration basins was in use in the time of the inspection due to low flow.
the other aeration basin is also operational, and can be used if flow was increased.
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: Both secondary clarifiers were operational and in service.
Yes No NA NE
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• ❑ ❑ ❑
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• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Pumps-RAS-WAS Yes No NA NE
Page# 6

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
Inspection Type: Compliance Evaluation
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Yes No NA NE
• ❑ ❑ ❑
Lagoons Yes No NA NE
Type of lagoons? Aerated
# Number of lagoons in operation at time of visit? 3
Are lagoons operated in? Series
# Is a re -circulation line present? El El • El
Is lagoon free of excessive floating materials? ■ El El El
# Are baffles between ponds or effluent baffles adjustable? El El • El
Are dike slopes clear of woody vegetation? • El El El
Are weeds controlled around the edge of the lagoon? • El El El
Are dikes free of seepage? ■ El El El
Are dikes free of erosion? • El El El
Are dikes free of burrowing animals? • El El El
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple El El • El
locations?
# If excessive algae is present, has barley straw been used to help control the growth? El El El
Is the lagoon surface free of weeds? • El El El
Is the lagoon free of short circuiting? • El El El
Comment: The facility is equipped with three polishing ponds (operated in series) and two sludge
holding ponds
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present? ■ El El El
Is the filter surface free of clogging? • El ❑ ❑
Is the filter free of growth? El El El •
Is the air scour operational? ❑ ❑ • ❑
Is the scouring acceptable? • El El El
Is the clear well free of excessive solids and filter media? El El • El
Comment: All six tertiary filters were operational and in-service.
Page# 7

Permit: NC0004952
Inspection Date: 02/01/2022
Owner - Facility: Celanese Shelby Facility
Inspection Type: Compliance Evaluation
Filtration (High Rate Tertiary) Yes No NA NE
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
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The flow meter is calibrated/verified on a quarterly basis by the Company's I & E
personnel.
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:
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: The facility rescinded it's land application permit.
Yes No NA NE
❑ ❑ ❑ •
• ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 8