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Home My WebLink AboutNCG500244_NOV2022PC0202 & CEI Report_20220414 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. April 14, 2022 Matt Haynes Giles Chemical Corporation Email: mhaynes@premiermagnesia.com SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2022-PC-0202 Permit No. NCG500244 Waynesville plant Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Waynesville plant on April 7, 2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NCG500244. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Effluent sampling was not conducted from at least 2017 through 2020. Starting in 2021, effluent sampling was conducted on one of the eight outfalls. All of the eight outfalls have not been sampled individually. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Patrick Owen (Bulk Operations Manager) Jim Pikul (Compliance Manager) DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA EPA United States Environmental Protection Agency 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 yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NCG500244 22/04/07 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Waynesville plant 102 Commerce St Waynesville NC 28786 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 22/04/07 20/12/18 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 11:30PM 22/04/07 25/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number Patricia Cruse,102 Commerce St Waynesville NC 28786//828-452-4784/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Facility Site Review Effluent/Receiving Waters 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 Date Lauren E Armeni DWR/ARO WQ/828-296-4500/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA 4/14/2022 4/14/2022 NPDES yr/mo/day 22/04/07 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Giles Chemical Corporation - Waynesville Plant on April 7, 2022. The inspection was conducted to determine if the system is being operated and maintained in compliance with General NPDES Permit No. NCG500000. Patrick Owen (Bulk Operations Manager), Jim Pikul (Compliance Manager), and Jason Bumgarner (Engineer) were present and assisted in the inspection. At the time of the inspection, the facility appeared well-maintained. The Certificate of Coverage under General NPDES Permit No. NCG500000 was recently revised and reissued for this facility with the correct stream designation. The stream was incorrectly designated as class B-Trout, but it is class B only. Richland Creek appeared to be free of any visual impairments from the eight outfalls. Mr. Owen indicated that the eight outfalls would each be labeled on the back of the building. A new sign had been placed on the non-contact cooling water tank. The eight outfalls are as follows (order at the facility): Hot Well #3, Hot Well Helper #1, Hot Well Helper #2, Hot Well #1, Hot Well #2, Creek Water Overflow, Creek Tank Purge, and Chiller Cooling. Mr. Owen indicated that the two Hot Well Helper outfalls do not constantly discharge, as they only discharge if one of the Hot Well water levels gets too high. Effluent Sampling: During past inspections, there has been confusion on how many outfalls are at the facility. It was confirmed that there are eight outfalls total. From at least 2017-2020, no effluent samples were taken. Starting in 2021, effluent samples were collected at one of the eight outfalls, Hot Well #3. Mr. Owen was under the assumption that this outfall was representative of all of them; however, each of the eight outfalls needs to be sampled separately. Following the inspection, Mr. Pikul sent Ms. Armeni an updated outfall map that lists the eight outfalls and an updated sampling spreadsheet they will use moving forward. Additionally, Mr. Pikul contacted Pace Analytical to conduct the effluent sampling of the eight outfalls sometime this month. Per the NPDES General Permit No. NCG500000, Giles Chemical is required to monitor flow, pH, and temperature semi-annually. The following violation was noted during the inspection: 1. Effluent Sampling: Effluent sampling was not conducted from at least 2017 through 2020. Starting in 2021, effluent sampling was conducted on one of the eight outfalls. All of the eight outfalls have not been sampled individually. NCG500244 17 (Cont.) Page#2 DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA Permit:NCG500244 Inspection Date:04/07/2022 Owner - Facility: Inspection Type: Waynesville plant 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? The current Certificate of Coverage issued in 2020 indicates that the receiving water is Richland Creek, a class B-Trout stream. The section of Richland Creek at this facility is designated as a class B stream. Mr. Charles Weaver (NCDEQ Permitting) revised and reissued the Certificate of Coverage on April 14, 2022. Comment: 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 Solids, pH, DO, Sludge Judge, and other that are applicable? This system is non-contact cooling water discharge only.Comment: 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? Page#3 DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA Permit:NCG500244 Inspection Date:04/07/2022 Owner - Facility: Inspection Type: Waynesville plant Compliance Evaluation Record Keeping Yes No NA NE 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? All effluent sampling data was not available. See summary for details. A copy of the most recent Non-contact Cooling Water General NPDES Permit, as well as the Certificate of Coverage is kept onsite. Comment: Effluent Pipe Yes No NA NE 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? During the inspection, it was confirmed that there are eight outfalls total at the facility. Each outfall is not currently labeled, but Mr. Owen said they will have them labeled. Comment: 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)? Effluent sampling was being conducted on one of the eight outfalls. See summary for details. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? All upstream/downstream sampling data was available for review and was within compliance of permit limits. Upstream/downstream temperature data is being compared with the freshwater classification temperature of 2.8 degrees Celcius. Comment: Page#4 DocuSign Envelope ID: 7EC4FB92-B9F8-410F-A676-3E81C13D64AA