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Home My WebLink AboutNC0084638_Compliance Evaluation Inspection_20141202 A • • NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory John E. Skvarla, Ill Governor Secretary December 2, 2014 Mr. Michael Shatynski Solvay USA, Inc. 8 Cedar Brook Drive RECEIVEDIDENR/DWR Cranberry, New Jersey 08512 DEC 9 2014 Water Quality Subject: Compliance Evaluation Inspection Permitting Section Rhodia remediation site NPDES Permit No. NC0084638 Gaston County Dear Mr. Shatynski: Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection conducted at the subject facility on November 25, 2014, by Ms. Marcia Allocco of this office. I thank Messrs. Williams and Hockett of CH2M Hill for their assistance regarding the site visit/inspection. The inspection report should be self-explanatory; however, should you have any questions concerning the report, please do not hesitate to contact me at (704) 235-2204 or marcia.allocco@ncdenr.gov. Sincerely, Marcia Allocco, MS; Environmental Senior Specialist Water Quality Regional Operations Section Division of Water Resources, NCDENR cc: Wastewater Branch MSC 1617 — Central files basement Mr. Dan Hockett, CH2M Hill, ORC MA Mooresville Regional Office Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115 Phone:(704)663-16991 Fax:(704)663-60401 Customer Service:1-877-623-6748 Internet:http://portal.ncdenr.org/web/wq An Equal Opportunity 1 Affirmative Action Employer-30%Recycledi10%Post Consumer paper United States Environmental Protection Agency Form Approved. E PA Washington,D.C.20460 OMB No.2040-0057 Water Compliance Inspection Report 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 � 2 El 3 ( NC008463s 111 12 1 14/11/25 117 18�,. 19 1.11 j 201 I 21IIIIII IIIIIII II II I I11II1 1 I IIjII 111II1111I � Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved 6711.0 LJ I 70�d I 71 �tiil �,72 I I 731 I 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 Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 10:02AM 14/11/25 11/07/01 Rhodia remediation site 207 Telegraph Dr Exit Time/Date Permit Expiration Date Gastonia NC 280561306 11:46AM 14/11/25 15/12/31 Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Daniel Nathan Hockett/ORC/704-543-3264/ Name,Address of Responsible Official/Title/Phone and Fax Number Contacted Michael Shatynski,8 Cedar Brook Dr Cranbury NJ 08512//732-516-1104/6098802203 No Section C:Areas Evaluated During Inspection(Check only those areas evaluated) op Permit w Flow Measurement • Operations&Maintenance II Records/Reports W Self-Monitoring Program 1111 Facility Site Review lj Effluent/Receiving Waters 11 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 Date Marcia Allocco 0/1704-683-1699 Ext.2204/ -1(Y) 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 NPDES yr/mo/day Inspection Type 1 31 NC0084838 I11 121 14/11/25 117 18 U Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) • Page# 2 Permit: NC0084638 Owner-Facility: Rhodia remediation site Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ 0 I ❑ application? Is the facility as described in the permit? U 0 0 0 #Are there any special conditions for the permit? U 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? U ❑ 0 0 Comment: NC0084638 was reissued by the Division on June 1,2011,with an effective date of July 1, 2011. The permit is set to expire on December 31,2015. The previous compliance evaluation inspection was conducted on January 26,2010. Operations &Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? • ❑ 0 0 Does the facility analyze process control parameters,for ex: MLSS, MCRT, Settleable • 0 0 0 Solids, pH, DO, Sludge Judge,and other that are applicable? Comment: CH2MHiII staff periodically review contaminant levels in the treatment system influent and surrounding monitoring wells to aid in system performance and operation as well as modeling of plume dynamics. Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting? • 0 0 0 Is flow meter calibrated annually? • ❑ 0 0 Is the flow meter operational? • 0 0 0 (If units are separated)Does the chart recorder match the flow meter? U 0 0 0 Comment: The effluent flow meter(ISCO 4230 bubbler) has been calibrated annually and was last calibrated/verified by Clearwater, Inc. on July 15, 2014. The associated paperwork noted no deviation from true values. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? U ❑ 0 0 Are the receiving water free of foam other than trace amounts and other debris? 0 0 MI 0 If effluent (diffuser pipes are required) are they operating properly? 0 ❑ • 0 Comment: There was an intermittent discharge from the treatment system to the drainage swale and unnamed tributary to Crowders Creek during the inspection. Under normal operating conditions the majority of the treated effluent is used as process water by the adjacent property owner(Lubrizol Advanced Materials, Inc.). Effluent Sampling Yes No NA NE Page# 3 Permit: NC0084638 Owner-Facility: Rhodia remediation site Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 0 • 0 Is sample collected below all treatment units? • 0 0 0 Is proper volume collected? • 0 0 0 Is the tubing clean? 0 0 • 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0 Celsius)? Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0 representative)? Comment: The permit requires grab samples for all required parameters.All effluent samples are kept on ice in a cooler until transfer to the analytical laboratory. Effluent samples are collected downstream of the effluent flow meter. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? • ❑ 0 0 Are all other parameters(excluding field parameters)performed by a certified lab? U 0 0 0 #Is the facility using a contract lab? • 0 0 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0 Celsius)? Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 U 0 Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 U 0 Comment: On-site analyses(pH)are performed under field laboratory certification#5508(CH2MHiII). The permittee has also contracted Prism Laboratories, Inc. (certification#402)and Environmental Testing Solutions, Inc. (whole effluent toxicity testing)to provide the remaining permit analytical requirements. The contracted operator had an exemplary documentation system related to the on-site analyses of pH samples. However, please ensure that a calibration time is provided when calibrating the pH meter;this time must precede the sample/analysis time reported for the effluent. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? U 0 0 0 Is all required information readily available,complete and current? • 0 0 0 Are all records maintained for 3 years(lab. reg.required 5 years)? • 0 0 0 Are analytical results consistent with data reported on DMRs? • 0 0 0 Is the chain-of-custody complete? • 0 0 0 Dates,times and location of sampling • Name of individual performing the sampling • Results of analysis and calibration U Page# 4 • • Permit NC0084638 Owner-Facility: Rhodia remediation site Inspection Date: 11/25/2014 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Dates of analysis U 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 U ❑ (If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator 0 0 U 0 on each shift? Is the ORC visitation log available and current? • 0 0 0 Is the ORC certified at grade equal to or higher than the facility classification? • 0 0 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: A recent ORC change(October 7,2014) has left the Back-up ORC position vacant. Please ensure a back-up ORC is designated for the system by February 5,2015, as per 15A NCAC 08G .0201. The reviewed records were organized and well maintained and all documentation requested during the inspection was readily retrievable. Monthly discharge monitoring reports(DMRs) were reviewed for September 2013 through August 2014. No limit violations were reported and all monitoring frequencies were correct. • Page# 5