NCG500639_NOV-2022-PC-0201 Response_20220505

RECEIVED/NCDEO/DWR
MAY - na
WOROS
MOORESVILLE REGIONAL OFFICE
May 5, 2022
W. Corry Basinger
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
610 East Center Avenue
Suite 301
Mooresville, NC 28115
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-PC-0201
Permit No, NCG500639
BonaKemi USA, Inc.
Union County
Dear Mr. Basinger:
BonaKemi USA, Inc. ("Bona") has received the inspection report from April 14, 2022.
BonaKemi USA, Inc. would like to provide additional information for compliance of Permit No.
NCG500639.
Air Conditioning Condensate
As of May 5, 2022, Bona has attempted to take samples on two occasions. Due the cooler
weather, the amount of condensate was not enough to pull the required 2.5 liters for testing.
A sample has been scheduled with the Waypoint to be taken on May 20th. In addition, work
orders are being entered into COGZ, our preventative maintenance program, to have work
orders print out in May and September to ensure sample will be taken in a timely manner.
The work orders will be given to the SHE department to fulfil the work order. The SHE
department will contact Waypoint Analytical for a certified Field Technician to come onsite and
take the appropriate samples.
Bona US
24 Inverness Place East
Suite 100
Englewood, CO 80112
[phone]
www.bona.com

Cooling Tower
During the day of the inspection, the Cooling Tower was being blown out unbeknownst to me
or our Facilities Manager, Peter Schmitt. Bona took a small sample that day and checked pH.
The pH was 8.34 based on our calibrated in-house equipment. Bona did not have the
capabilities to send the samples to the certified lab on the day of the blow out. Bona
contacted Waypoint Analytical for quotes for this testing and field sampling as Bona does not
have a Certified technician onsite.
Bona does the blow out on the cooling tower once a year when preparing the tower(s) for
summer months. The towers recycle during the winter. One week before the cooling tower
water is discharged, the chemical system is turned off to allow chemicals to dissipate.
Within our COGZ system, we have preventative maintenance on a valve twice a year. During
this maintenance, we will have the field technician take samples. This is currently scheduled
to happen on May 20th when the sample of the Air Conditioning Condensate is done. Like the
condensate, this testing has been added to the COGZ system.
Bona will provide all test reports when received to show compliance with the permit.
If there are any questions, please feel free to contact me or Peter Schmitt.
r
Lisa King
SHE Specialist

nC IVIHRIIVIUIVI rr uuu . I IVI I T I.UIVIrHIV T UJIIVb I.VUG JUT" I VVHKC
Preventive Maintenance Work Order
WORK ORDER NO... 11,606 SCHEDULED"' 5/13/2022
PRIORITY
WO REQUEST #
ASSIGNED TO 5 LISA KING SUPERVISOR
EQUIPMENT CONDENSATE TEST CONDENSATE TEST ENTERED 5/05/2022 9:42 AM
LOCATION MAIN BUILDING REQUESTED BY. STARTED / /
MODEL SERIAL DEPT
MANUFACTURER.. LINE PAINT AREA SHIFT
WORK ORDER HEADER: PREVENTIVE WORK STATUS:
SEQ# DESCRIPTION DATE DO TIME INITIALS
APPLY ALL SAFETY PROCEDURES BEFORE STARTING YOUR WORK.... THINK SAFETY!!!
1 TEST FOR OIL AND GREASE, PH. TEMP, AND CHEMICAL OXYGEN DEMAND (COD)
Time
TAKE A WATER SAMPLE FROM 2" PVC WHITE PIPE NEXT TO UV UNIT.
Total Time:
Date Initials ADDITIONAL LABOR Time Date
Initials
Part Number
Description ADDITIONAL PARTS Location QTY Used
COMPONENT: #MISCELLANEOUS MISCELLANEOUS EQUIPMENT COMPONENTS COMMENT:
WHEN WORKING ON A MACHINE MAKE SURE THAT YOU USE YOUR LOCKOUT AND TAG OUT SYSTEM!!!!!
WHEN YOUR WORK IS COMPLETED TEST RUN YOUR EQUIPMENT. TEST ALL SAFETIES AND MAKE SURE ALL
GUARDS ARE IN PLACE. LOOK FOR POTENTIAL HAZARDS AND CORRECT IF NEEDED, CLEAN YOUR WORK
AREA AND RETURN ANY UNUSED PARTS TO THEIR PROPER LOCATIONS. NOTIFY YOUR SUPERVISOR AND
MAKE OUT A WORK ORDER FOR ANY WORK THAT YOU CANNOT COMPLETE.
Comments
Approved By:
Inspected By.
Previously Uncompleted ** PM Generated Up To Date or Due Date'AGE 1 Date: 5/05/2022

I i'7C IVIHAIIVIUIVI 1-MJUUI, I IVI I T LAMVIYHIA T UJIIVV l.Ut. L our I VVHKC
Preventive Maintenance Work Order
WORK ORDER NO... 11,605 SCHEDULED** 5/13/2022
PRIORITY
WO REQUEST #
ASSIGNED TO 5 LISA KING SUPERVISOR
EQUIPMENT CT-9010 COOLING TOWER ENTERED 5/05/2022 9:42 AM
LOCATION REQUESTED BY. STARTED / /
MODEL SERIAL DEPT
MANUFACTURER.AAAA LINE SHIFT
WORK ORDER HEADER: PREVENTIVE WORK STATUS:
SEQ# DESCRIPTION DATE DO TIME INITIALS
APPLY ALL SAFETY PROCEDURES BEFORE STARTING YOUR WORK.... THINK SAFETY!!!
2 SAMPLE COOLING TOWER WATER FOR COD FOR CHLORINE PH/ TEMPRETURE.
WAYPONT ANALYTICAL TEST
Time
Total Time:
Date Initials ADDITIONAL LABOR Time Date
Initials
Part Number Description ADDITIONAL PARTS Location QTY Used
COMPONENT: #MISCELLANEOUS MISCELLANEOUS EQUIPMENT COMPONENTS COMMENT:
WHEN WORKING ON A MACHINE MAKE SURE THAT YOU USE YOUR LOCKOUT AND TAG OUT SYSTEMUUI11
WHEN YOUR WORK IS COMPLETED TEST RUN YOUR EQUIPMENT. TEST ALL SAFETIES AND MAKE SURE ALL
GUARDS ARE IN PLACE. LOOK FOR POTENTIAL HAZARDS AND CORRECT IF NEEDED. CLEAN YOUR WORK
AREA AND RETURN ANY UNUSED PARTS TO THEIR PROPER LOCATIONS. NOTIFY YOUR SUPERVISOR AND
MAKE OUT A WORK ORDER FOR ANY WORK THAT YOU CANNOT COMPLETE.
Comments
Approved By:
Inspected By.
* Previously Uncompleted ** PM Generated Up To Date or Due Date'AGE 1 Date: 5/05/2022

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7018 3090 0001 2322 5375
Return Receipt Requested
April 14, 2022
Lisa King
Bonakemi USA Inc
4275 Corporate Center Drive
Monroe, NC 28110
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2022-PC-0201
Permit No. NCG500639
BonaKemi USA, Inc.
Union County
Ms. King:
The North Carolina Division of Water Resources conducted an inspection of the BonaKemi USA, Inc. on April 12,
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. NCG500639. 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 Mooresville
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Record Keeping No effluent samples are being collected.
The compliance issues below must be addressed:
Compliance Issue(s): At time of inspection, no sampling of effluent discharge was being conducted. In
accordance with Part I, Section B. (1.) and (2.) of NCG500639, grab samples are to be collected Semi -Annually for
analysis by a Certified Laboratory. Laboratory analysis and chain -of -custody forms are to be maintained on -site for
period of three years.
North Carolina Department of Environmental Quality 1 Division of Water Resources
Mooresville Regional Office l 610 East Center Avenue. Suite 3011 Mooresville. North Carolina 28115
704.663.1649

A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordancewith the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215-.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss
overall compliance, please respond in writing within ten (10) business days after receipt of this Notice. A review of
your response will be considered along with any additional information provided. You will then be notified of any
civil penalties that may be assessed regarding the violations. If no response is received in this Office
within the specified ten (10) business day period, a civil penalty assessment may be prepared.
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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and
you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of, a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you should have any questions, please do not hesitate to contact Roberto Scheller with the Water Quality
Regional Operations Section in the Mooresville Regional Office at 704-663-1699.
Sincerely,
f—DocuSigned by:
----A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: Peter Schmitt email: Peter.Schmitt©bona.com
LaserFiche
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 Mooresville, North Carolina 2R1I5
704.663.1699

EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Section A: National Data System Coding (i.e., PCS)
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
11,..Nj 2 5� 3 I NCG500639 111 121 22/04/12 117 18 (r+ I 19 j S I 201
21II11II IIIIIIIIIII IIIIIIIIIIIIIIIIIIli' Hit t66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
671
70I1 I 71 72 1 ti 1 731 1 174 79 1 1 1 1 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)
BonaKemi USA, Inc.
4275 Corporate Ctr Dr
Monroe NC 28110
Name(s) of Onsite Representative(s)mtles(s)/Phone and Fax Number(s)
///
Name, Address of Responsible Official/Title/Phone and Fax Number
Lisa King,4275 Corporate Ctr Dr Monroe NC 28110//704-220-6954/7042206960
Contacted
No
Entry Time/Date
09:43AM 22/04/12
Exit Time/Date
10:42AM 22/04/12
Other Facility Data
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement
Facility Site Review Effluent/Receiving Wate
Permit Effective Date
21/01/05
Permit Expiration Date
25/11/30
Records/Reports Self -Monitoring Progran
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)
DocuSigned by:
Roberto Scheller
91C2A007838943E_.
Agency/Office/Phone and Fax Numbers
DWR/MRO WQ/707-235-2204/
Date
4/13/2022
Signature of Management Q A Reviewer
Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger DWR/Division of Water Quality/704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
p-- 'DocuSigned by:
`—A14CC681AF27425...
4/14/2022
Page# 1

NPDES
NCG500639
111 12'
yr/mo/day
22/04/12
Inspection Type
117 181=1
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Certification of Coverage (CoC) NCG500639 is under General Permit NCG500000. Coverage
became effective January 5, 2021 and is valid for the duration of the General Permit. Attached to this
inspection, for your files, is copy of renewal letter. The subject discharge is to an unnamed tributary
to East Fork Twelve Mile Creek which is classified as Class C waters in the Catawba River Basin.
At time of inspection no sampling of effluent discharge was being conducted. In accordance with Part
I Section B. (1.) and (2.) of NCG500000, grab samples are to be collected Semi -Annually for analysis
by a Certified Laboratory. Laboratory analysis and chain -of -custody forms are to be maintained
on -site for a period of three years.
All non -contact cooling water sample locations shall provide representative samples of the discharge
and require sampling prior to discharge commingling with any other waters or substances, such as
stormwater or surface water, to enable characterization of a pollutant of concern.
All samples collected should be from a representative and measurable discharge event that results in
an actual discharge from the permitted discharge outfall.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Effluent temperature will be regulated so that temperature of the receiving stream does not increase
more than 2.8 degrees Celsius above the natural water temperature.
Page# 2

Permit: NCG500639
Owner - Facility: BonaKemi USA, Inc.
Inspection Date: 04/12/2022 Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or Tess). 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:
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?
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: No samples are being collected.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Yes No NA NE
❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑
❑ ❑ ❑
Yes No NA NE
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❑ ❑ El
0
0
El
0
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0
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Yes No NA NE
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Page# 3

Permit: NCG500639
Inspection Date: 04/12/2022
Owner - Facility: BonaKemi USA, Inc.
Inspection Type: Compliance Evaluation
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?
Comment: In accordance with Certification of Coverage (NCG500639) General Permit
NCG500000, effluent Flow is to be estimated .
Yes No NA NE
El ❑
❑ ❑ ❑
❑ ❑ ❑
Page# 4

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
GENERAL PERMIT NCG500000
CERTIFICATE OF COVERAGE NCG500639
DISCHARGE OF NON -CONTACT COOLING WATER, COOLING TOWER AND BOILER
BLOWDOWN, CONDENSATE, EXEMPT STORMWATER, COOLING WATERS ASSOCIATED
WITH HYDROELECTRIC OPERATIONS, AND SIMILAR WASTEWATERS UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and
the Federal Water Pollution Control Act, as amended,
Bonakemi USA, Inc.
is hereby authorized to discharge from a facility located at the
BonaKemi USA, Inc.
4275 Corporate Ctr Dr
Monroe
Union County
to receiving waters designated as an unnamed tributary to East Fork Twelvemile Creek, a class C
stream in subbasin 03-08-38 of the Catawba River Basin in accordance with the effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II, and III hereof.
This certificate of coverage takes effect 1/5/2021.
This Certificate of Coverage shall remain valid for the duration of the General Permit.
Signed this day 1/5/2021
/-1 110/7,
for S. Daniel Smith, Director
Division of Water Resources
By Authority of the Environmental Management Commission

END R COMPLETETHIS SECTION;
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I Print your name and address on the reverse
so that we can return the card to you.
I Attach this card to the back of the mailpiece,
or on the front if space permits.
. Article Addressed to:
BONAKEMI USA, INC
4275 CORPORATE CENTER DRIVE
MONROE NC 28110
ATTN: USA KING
dwr/rs 9/14/22
ii iiiiiiiiii i i 11 mmu
9590 9402 5027 9063 9741 36
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