NCG500639_NOV-2022-PC-0201 Response_20220401

aserfiche
fECEIVED/NCDE©/DWR
AAY ?Oa
WQRROS
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
Bona®
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

Bona®
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.
Sincerely,
r
Lisa King
SHE Specialist

Inc IVIHAIIVIUIVI rr uijU , I IVI I i l.vmrMrvr UJIIVb t..UUL Jur 1 vviArcW
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"
I I I I
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 flC IVI HIl11VIUlYI t'KUUUl. 11 VI 1 T I.VIVI!'HIV T UJIIVt7 l.UI.,L JUr 1 vv, r C
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.
Time
WAYPONT ANALYTICAL TEST
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 SYSTEM1111�
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