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NC0004952
Celanese Shelby Facility
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 14, 2017
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ROY COOPER
Governor
Water Resources
ENVIRONMENTAL QUALITY
February 14, 2017
Ms. PEM Carter, Sr. Environmental Engineer
CNA Holding, LLC
2525 Blacksburg Road
Grover, NC 28073
Dear Ms. Carter:
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
RECEIVEDOE O
FEB 2 2 Z017
Water Quality
on
Penn►ttin9
Subject: Compliance Sampling 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 8, 2017, by Ori Tuvia. Michael Sparks, Michael Queen's,
Randy Turner's and your 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.
Split samples were taken during the inspection. Results of the split sampling will be
forwarded upon completion of analyses.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at
ori.tuvia@ncdenr.gov.
Cc: NPDES Unit
MRO Files
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Mooresville Regional Office
i ............. can A. Quill 9t11 nMnrnc,tiuc P otl11F
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 Code NPDES yrlmo/day Inspection
3 I NC0004952 111 12 17/02/08 117
1 1�, 1 2 1.i
Type
18 I I
I I I I1111I
Inspector Fac Type
19 1 2 I 20 i 1
211II1 I I I II [II I II 1I I I1 I II I I I I I I
ILI I i66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67110 1 701d I 71I„j 72 Lii
Reserved
731 1 V 751
1 I I I 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Celanese -Shelby Facility
NC Hwy 198
Shelby NC 28150
Entry Time/Date
10:05AM 17/02/08
Permit Effective Date
13/11/01
Exit Time/Date
01:10PM 17/02/08
Permit Expiration Date
18/08/31
Name(s) of Onsite Representative(s)/iles(s)/Phone and Fax Number(s)
1/1
• Michael D. Sparks/ORC/704-480-5793/
Other Facility Data
Name, Address of Responsible OfficiaVTitle/Phone and Fax Number
Contacted
Rafael Gonzalez,2525 Blacksburg Rd Grover NC 28073/Site Director/704-480-5728/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Row Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Ori A Tuvia MRO WQ//704-663-1699/
Date
n / 114 03...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
/4-/es 2i0,F
Page# 1
31
NPDES
NC0004952
r 1 121
yr/mo/day
17/02/08
17
Inspection Type
18[II
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On -Site Representatives:
The following Company personnel were in attendance during the inspection: Ms. PEM Carter/Sr.
Environmental Engineer; Mr. Michael Sparks/ORC; Mr. Randy Turner Lab Supervisor; and Mr. Michael
Queen/Backup ORC
Page# 2
Permit: NC0004952
Inspection Date: 02/08/2017
Owner - Facility: Celanese -Shelby Facility
Inspection Type: Compliance Sampling
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 0 0 • 0
application?
Is the facility as described in the permit? 11 0 0 0
# Are there any special conditions for the permit? • 0 0 0
Is access to the plant site restricted to the general public? 0 0 0
Is the inspector granted access to all areas for inspection? • 0 0 0
Comment: The subject permit expires on 8/31/2018.
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? • 0 0 0
Is all required information readily available, complete and current? • ❑ 0 0
Are all records maintained for 3 years (lab. reg. required 5 years)? • 0 0 ❑
Are analytical results consistent with data reported on DMRs? • 0 0 0
Is the chain -of -custody complete? 11 0 0 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? • 0 0 0
Has the facility submitted its annual compliance report to users and DWQ? 0 0 11.❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 0 • 0
on each shift?
Is the ORC visitation log available and current? 11 0 0 0
Is the ORC certified at grade equal to or higher than the facility classification? • 0 ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? • 0 0 0
Is a copy of the current NPDES permit available on site? • 0 0 0
Facility has copy of previous year's Annual Report on file for review? • 0 0 0
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
January 2016 through September 2016.
Laboratory Yes No NA NE
Page# 3
Permit: NC0004952
Owner - Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
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
■ ❑ 0 0
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑❑■❑
Comment: On -site effluent analyses (fecal coliform, pH, temperature, TSS) are performed under the
Company's laboratory certification #221. Prism Laboratories. Inc. (BOD, oil & grease, total
nitrogen, total phosphorus. pollutant scan) 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? ■ ❑ ❑ ❑
Is sample collected below all treatment units? ■ ❑ ❑ ❑
Is proper volume collected? ■ ❑ ❑ ❑
Is the tubing clean? ■ 0 0 0
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ■ ❑ 110
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ■ ❑ ❑ ❑
representative)?
Comment: The subject permit requires both composite and grab effluent samples. The ORC and staff
must ensure to perform/document periodic aliquot verifications on the composite sampler.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Yes No NA NE
■ ❑ ❑ ❑
110 ❑ ❑
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.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Yes No NA NE
■
0
Page# 4
Permit: NC0004952
Owner - Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
Bar Screens
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
■ ❑ ❑❑
IN ❑ ❑ ❑
• ❑ ❑ Cl
■ ❑❑❑
Yes No NA NE
•
0
• ❑ Cl ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
❑ ❑ 1 ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
• ❑ ❑ ❑
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.
Ch em i cal Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Yes No NA NE
• ❑ •❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Page# 5
Permit: NC0004952
Owner - Facility: Celanese -Shelby Facility
Inspection Date: 02/08/2017 Inspection Type: Compliance Sampling
Chemical Feed Yes No NA NE
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots? • 0 ❑ 0
Are surface aerators and mixers operational? • 0 0 0
Are the diffusers operational? 0 ❑ • 0
Is the foam the proper color for the treatment process? 11 0 ❑ ❑
Does the foam cover Tess than 25% of the basin's surface? •❑ ❑ 0
Is the DO level acceptable? 11 0 0 0
Is the DO level acceptable?(1.0 to 3.0 mg/I) 0 ❑ • 0
Comment: Both aeration basin trains were operational and in service at the time of the inspection.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? • 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? •❑ ❑ ❑
Are weirs level? • 0 0 ❑
Is the site free of weir blockage? 11 0 0 0
Is the site free of evidence of short-circuiting? • 0 0 0
Is scum removal adequate? 11 0 0 0
Is the site free of excessive floating sludge? • 0 0 0
Is the drive unit operational? • 0 0 0
Is the return rate acceptable (low turbulence)? • 0 0 0
Is the overflow clear of excessive solids/pin floc? ❑ ❑ ❑
Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) MEI ❑ ❑
Comment: One of the wto secondary clarifiers was operational and in service, the second was taken
down for maintenance..
Pumps-RAS-WAS Yes No NA NE
Are pumps in place? • 0 0 0
Are pumps operational? • ❑ ❑ ❑
Are there adequate spare parts and supplies on site? ❑ ❑ ❑ •
Page# 6
Permit: NC0004852
Inspection Date: 02/08/2017
Owner - Facility: Celanese -Shelby Facility
Inspection Type: Compliance Sampling
Pumps-RAS-WAS Yes No NA NE
Comment:
Lagoons
Type of lagoons?
# Number of lagoons in operation at time of visit?
Are lagoons operated in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes dear of woody vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
• # Has the sludge blanket in the lagoon (s) been measured periodically in multiple
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
Is the lagoon surface free of weeds?
Is the lagoon free of short circuiting?
Yes No NA NE
Aerated
3
Series
❑ ❑ • ❑
• ❑ ❑ ❑
❑ ❑ II ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑❑
• ❑ ❑ ❑
11 ❑ ❑ ❑
❑ ❑ III ❑
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
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? 1 ❑ ❑ ❑
Is the filter surface free of clogging? II 0 0 0
Is the filter free of growth? 0 Cl 0 •
Is the air scour operational? 0 0 • 0
Is the scouring acceptable? 1 ❑ 0 ❑
Is the clear well free of excessive solids and filter media? 0 0 11 0
Comment: All six tertiary filters were operational and in-service.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Yes No NA NE
• ❑ ❑ ❑
Page# 7
Permit: NC0004952
Inspection Date: 02/08/2017
Owner - Facility: Celanese -Shelby Facility
Inspection Type: Compliance Sampling
Flow Measurement - Effluent
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
■❑❑❑
111 ❑ ❑ ❑
❑ ❑ II ❑
Comment: The flow meter is calibrated/verified on a quarterly basis and was last calibrated/verified on
2/1/2017 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: The effluent appeared clear with no floatable solids or foam.
Yes No NA NE
❑ ❑■❑
11000
O 0110
Aerobic Digester Yes No NA NE
Is the capacity adequate? 110 ❑ ❑
Is the mixing adequate? •❑ ❑ ❑
Is the site free of excessive foaming in the tank? • ❑ ❑ ❑
# Is the odor acceptable? 111 0 ❑ ❑
# Is tankage available for properly waste sludge? 11 ❑ 0 ❑
Comment: The facility is authorized to land apply digested sludge under the authority of Permit
WQ0011038.
Page# 8