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Home My WebLink AboutNC0005258_NOV2023PC0275_20230706 SENT VIA ELECTRONIC COPY ONLY: NO HARD COPY WILL BE MAILED July 6, 2023 Shane Holland, Plant Manager Sgl Carbon LLC 307 Jamestown Rd Morganton, NC 28655-9948 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2023-PC-0275 Permit No. NC0005258 SGL Carbon, LLC Burke County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the SGL Carbon, LLC on June 18, 2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0005258. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Sampling 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 _________________________________________________________________________________________________________________________________________________________________________ De-chlorination De-chlorination system is not effective at adequately mixing during high flows. Total Residual Chlorine readings on 6/18/23: 234 µg/L, 125 µg/L, and 68 µg/L _________________________________________________________________________________________________________________________________________________________________________ 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 15 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. DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or melanie.kemp@deq.nc.gov. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Stephen Richards, SGL Carbon DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A 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 NC0005258 23/06/18 S S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- 3 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) SGL Carbon, LLC 307 Jamestown Rd Morganton NC 286559948 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 23/06/18 18/03/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Not Required/ORC/919-807-6353/ Other Facility Data 12:30PM 23/06/18 23/02/28 Name, Address of Responsible Official/Title/Phone and Fax Number Stephen Richards,307 Jamestown Rd Morganton NC 28655//828-432-5783/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program 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 Melanie Kemp DWR/ARO WQ/ - - / Daniel J Boss DWR/ARO WQ/828-296-4658/ 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: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A 7/6/2023 NPDES yr/mo/day 23/06/18 Inspection Type S3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Melanie Kemp and Daniel Boss, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of SGL Carbon on June 22, 2023 to ensure the facility is operating in compliance with NPDES permit NC0005258. Stephen Richards, EHSA Manager, was present for the inspection. In January 2023 a petroleum discharge into Silver Creek was traced back to the facility. Investigations revealed that the leak was a result of a failing heat exchanger discharging hydraulic fluid to contact cooling water, which was plumbed to the stormwater drains. The heat exchanger was repaired and the contact water from this area was re-plumbed to drain to the sanitary sewer system. This area was inspected, and repairs are acceptable. The facility utilizes potable water from the town of Morganton as contact and non-contact cooling water for the facility. Most of this process water is discharged into the facility’s stormwater drain system. A combination of stormwater and wastewater drains to two storage basins for oil/water separation and sediment removal. These basins are pumped approximately every 6 months. Effluent is then de-chlorinated prior to being discharged into a basin that drains to Silver Creek. The facility utilizes liquid bisulfate for de-chorination. Effluent grab samples are collected weekly for Total Residual Chlorine (TRC) readings. During the inspection, the ARO tested TRC at the effluent sampling basin. All three readings (234 µg/L, 125 µg/L, and 68 µg/L) were above the permit limit (50 µg/L). The sample analyzed by the on-site lab was also above the permit limit (result of 145 µg/L). It should be noted that rain was moderate/heavy during the inspection. The on-site lab supervisor indicated that the de-chlorination system was likely not properly de-chlorinating due to heavy flows resulting in inadequate mixing time. Therefore, the following deficiency was noted during the inspection: -De-chlorination: The facility needs to alter the de-chlorination system to ensure adequate mixing during high flows. As a reminder, since the wastewater and stormwater are comingled, sampling for each permit needs to be representative. NC0005258 17 (Cont.) Page#2 DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A Permit:NC0005258 Inspection Date:06/18/2023 Owner - Facility: Inspection Type: SGL Carbon, LLC Compliance Sampling 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? Comment: 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? Permit renewal in process.Comment: De-chlorination Yes No NA NE Type of system ?Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? Are the tablets the proper size and type? Dechorination system is not effective at adequately mixing during high flows. See summary for details. Comment: Are tablet de-chlorinators operational? Number of tubes in use? NAComment: 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 Page#3 DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A Permit:NC0005258 Inspection Date:06/18/2023 Owner - Facility: Inspection Type: SGL Carbon, LLC Compliance Sampling Record Keeping Yes No NA NE 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: 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? Effluent flows into catch basin prior to discharging to creek.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)? There is no flow meter, therefore samples are not flow-proportional.Comment: Flow Measurement - Effluent Yes No NA NE Page#4 DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A Permit:NC0005258 Inspection Date:06/18/2023 Owner - Facility: Inspection Type: SGL Carbon, LLC Compliance Sampling Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Facility measures flow based on real-time bucket measurements when collecting samples. Comment: Page#5 DocuSign Envelope ID: F4B8AAAE-0427-4CEE-8BEC-31CE13FEA76A