NC0004952_Staff Comments_19930128

NPDES DOCIMENT SCANNING COVER SHEET
NPDES Permit:
NC0004952
Celanese Shelby Facility
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
5-67r roAti7e/4 .
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
January 28, 1993
Thins document ins printed on reuee paper - ignore any
content on the reNrerise oldie

DIVISION OF ENVIRONMENTAL MANAGEMENT
January 28, 1993
MEMORANDUM
TO: Randy Kepler
THRU: Trevor Clements
Ruth Swanek
Carla Sanderson Ce
FROM: Jackie Nowell
SUBJECT: Draft Comments from Hoechst Celanese Corp.- Shelby Plant
NPDES Permit No. NC0004952
Cleveland County
The Technical Support Branch has reviewed the letter from the subject facil-
ity and have comments and recommendations on selected items addressed by the
permittee.
Item 5. We concur with the replacement language recommended by Hoechst
Celanese for the second sentence in the paragraph regarding pH monitoring.
The facility is concerned that a pH value below 6.0 SU would also trigger a
violation when the intent is protection from pHs in the high range.
Item 6. The polishing ponds experience algae growth during the summer and
compliance data shows the effluent discharge with elevated pH values from June
to October, 1992. The facility has an IWC of 4.5% into Buffalo Creek and a
slightly elevated pH would not severely impact the receiving stream. A November
20, 1990 memo from the ARO stated that no water quality violations have occurred
as a result of algae being discharged. Based on this and a relatively high
retention time in the polishing ponds (per telecon with Jim Reid of ARO), we
c•:,ncur with a weekly instream monitoring frequency for pH when the effluent from
she polishing pond exceeds 9.0 SU.
Item 7. In a telephone conversation with Mr. Atkins of Hoechst Celanese,
he indicated that in lieu of a response from DEM on the draft comments, this
recommended compliance schedule would have to be revised. He has asked to be
contacted eft personally this item.
Item 8. Technical Support defers comment to the Mooresville RO and Permits
and Engineering on the revision of sample type from grab to composite. Regard-
ing the question on total phenolic compounds, the recommended limit of 0.111
lb/day should be revised to 0.344 lb/day. The previous limit was calculated
using the 7Q10 flow instead of the 30Q2 flow. The facility can use EPA Method
625 - GC Mass Spectrometry to sample for total phenolic compounds.
It is our opinion that Items 9 and 10 would be best answered by Division
chemical or laboratory personnel.

If are any additional questions concerning this matter, please contact me.
cc: Rex Gleason
Central File
WLA File

Hoechst Celanese
Textile Fibers
Hoechst Celanese Corporation
PO Box 87
Shelby, NC 28151-0087
704 482 2411
November 23, 1992
Ms. Coleen Sullins
North Carolina Department of Environment,
Health and Natural Resources
NPDES Permits Group
PO Box 27687
Raleigh, North Carolina 27611-7687
Re: Draft NPDES Permit No. NC0004952
Dear Ms. Sullins:
After reviewing the subject draft permit several areas have been
identified which need clarification and/or consideration for
slightly altered language. These points are highlighted below:
(1) It would appear that on page 2 of the Priority Pollutants
Limitations and Monitoring Requirements schedule that the
column headers "Daily Max" and "Monthly Avg" are
reversed.
(2) For ease in transition from our current permit to the
new, would it be possible to make the effective date
January 1, 1993? If that option cannot be afforded,
we presume two (2) Discharge Monitoring Reports (DMRs)
must be submitted for December, 1992.
Under "Effluent Limitations and Monitoring Requirements
Final" for outfall serial number 002, this water
receives no chlorine at any point_ after withdrawal from
Buffalo Creek. We understand, therefore that no
monitoring for "total residual chlorine" is required.
(4) Under "Effluent Limitations and Monitoring Requirements
Interim/Final" for outfall serial number 001, the permit
requires daily pH analysis by grab sample. Since the pH
of outfall 001 is continuously recorded can daily
monitoring be eliminated?
(3)
Hoechst El

Ms. Coleen Sullins
November 23, 1992
Page 2
(5)
Under "Effluent Limitations and Monitoring Requirements
Interim/Final - page two" the effluent pH is defined and
limited. We would like to offer the following language
to replace the second sentence in the subject paragraph:
"If the pH of the effluents from the polishing ponds
exceed 9.0, there will be no effluent violation if the
wastewater from the final clarifier has not exceeded 9.0
during the thirty (30) days preceding the measurements of
the pH above 9.0 of the effluent from the polishing
ponds."
(6) Under the same paragraph mentioned in (5) above the
following requirement exists: "Upstream and downstream
monitoring shall be conducted on any day the pH of the
effluent from the final polishing pond is outside the
6 - 9 standard unit range." Due to algae growth in the
polishing ponds during the summer, this monitoring
requirement could require over seventy-five (75) 6.4 mile
trips to sample upstream and downstream annually. In
order to maximize manpower effectiveness we would propose
that a weekly frequency (in lieu of daily) would be
sufficient and could be combined with the weekly
monitoring of temperature for outfall serial number 002.
(7)
Under the "Schedule of Compliance" section, we propose
the following changes:
- Begin Construction
on or before January 1, 1993
- Complete Construction
on or before April 31, 1994
- Achieve Compliance
on or before May 31, 1994
(8) With reference to the "Effluent Limitations and
Monitoring Requirements Interim/Final" we request that
the sample type be changed from grab to composite. In
our wastewater treatment system, as in most systems, the
waste stream can change over a particular time period.
We propose that a composite sample be formulated for
analysis of volatile compounds. The composite sample may
be formulated by combining a number of grab samples into
a single sample for analysis in the laboratory. We
propose that 4 grab samples be collected over an 8 hour
period for this use. Also at the end of the parameter
list is a limit on total phenolic compounds. We request

Ms. Coleen Sullins
November 23, 1992
Page 3
(9)
a definition of total phenolic compounds as it pertains
to this permit.
With reference to part II, page 11 of 14, Test
Procedures, we request that the section be revised to
specify particular analytical procedures for the volatile
and semivolatile organic compounds. It is requested that
EPA Methods 624 and 625 be specified. These methods are
acceptable for use with NPDES discharge points and is
approved for this use in 40 CFR 136.
(10) With reference to Part III Section E "Annual Pollutant
Analysis", please provide a definition of each analytical
c.? fraction (i.e. list) and the respective acceptable EPA
methods to be used.
Please forward one (1) original of the following report forms as
referenced in our permit:
- Discharge Monitoring Report
(DMR) Form
- DEM No. MR 1
- DEM No. MR 1.1
- DEM No. MR 2
- DEM No. MR 3
- DEM No. AT-1
- Annual Pollutant Analysis Monitoring
(APAM) Requirement Reporting Form A
Your careful consideration and response to the above mentioned
issues is appreciated. Should any additional information be needed
or verbal responses required due to permit timing, please do
not hesitate to contact me at [phone] Ext. 4189. Thank you
for your assistance.
Sincerely
Terry D. Atkins
Utilities/Maintenance/Environmental Supt.
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cc: Les Conner
Jack Timberlake
Jim Pullen
Carl Burrell - Davis & Floyd

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State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
Mr. S. F. Olp
Senior Environmental Engineer
Hoechst Celanese Corporation
Post Office Box 87
Shelby, North Carolina 28151-0087
September 18,1991
03ag05
Cv
Subject: Proposed Anti -foam Agent
Hoechst Celanese Corporation
NPDES Permit No. NC0004952
Cleveland County
Dear Mr. Olp:
This Office is in receipt of your request dated August 7, 1991
concerning the trial use of an anti -foaming agent in your
wastewater treatment facility. You indicated that you were
experiencing mild foaming problems at your outfall.
Our Technical Support Group in Raleigh was contacted regarding
your request and some concern was expressed over the anti -foaming
agent you proposed to use. Specifically, Technical Support
expressed concern regarding the potential for elevated BOD5 levels
and effluent toxicity.
It is requested that you contact Mr. Larry Ausley in our
Aquatic Toxicology Unit at [phone] to discuss the specific
use of this or any other anti -foaming agent.
If we can be of any help regarding this or any other matter,
please contact Mr. Michael L. Parker or me at [phone].
Sincerely,
2/ 7
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
cc: L 'rry Ausley
aria Sanderson
919 North Main Street, Mooresville, N.C. 28115 • Telephone [phone] • FAX [phone]
An Equal Opportunity Affirmative Action Employer