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HomeMy WebLinkAboutNC0000892_Historical_2004-2008Permit Inspection �r l 7l t v NC oc�cogq a Subject: Permit Inspection From: "Lorbacher, David" <David.Lorbacher@arclin.com> Date: Wed, 2 Jul 2008 11:43:28 -0400 To: "stephanie.brixey@ncmail.net" <stephanie.brixey@ncmail.net> In response to the letter received on May 30, 2008 regarding the permit inspection performed on May 22, 2008. A new operator responsible charge was submitted and received on June 24, 2008. Another calibration was performed on the flowmeter using the three point method (zero flow, high flow, and mid range). The Stormwater Pollution Prevention Plan is currently being updated to include the name change, updated site map, recertifying all outfalls and is scheduled to be completed by July 31, 2008. Future training for employees will also be documented. DavufLor6acher Systems technician Arclin - Performance applied Moncure, NC Bus:(919)542-2526 Ext.3054 Cell: (919)353-0739 www.arelin.com 1 of 1 7n12008 12:14 PM \o�CF W ATFROG o 0 60 June 9, 2008 Mr. Art Schermbeck Plant Manager Archn USA Inc. 790 Corinth Road Moncure, NC 27559 Michael F. Easley, Govemor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Subject: Retraction of Notice of Violation and Assessment of Civil Penalty Case No. LV-2008-0171 Arclin USA hic. NPDES Permit No. NC0000892 Chatham County Dear Mr. Schermbeck: Coleen H. Sullins, Director Division of Water Quality The Raleigh Regional Office staff has reviewed your response dated May 28, 2008, requesting the Notice of Violation and Assessment of Civil Penalty be retracted. Your letter explained that DWQ had misread the units on the Discharge Monitoring Report (DMR). As such, the RRO re-evaluated the DMR and confirmed that the actual value of 0.0068 pounds per day is much lower than the daily maximum and monthly average limit of the permit. This office agrees with your request, by copy of this letter the Notice of Violation and Assessment of Civil Penalty, LV-2008-0171 dated May 9, 2008, are rescinded. If you have questions or wish to discuss this matter further please call Stephanie Brixey or myself at (919) 791- 4200. Sincere s:�/L�� S. Daniel Smith Surface Water Protection Supervisor Raleigh Regional Office Cc: Central Files RRO-SWP files Vanessa Manuel, NPDES Eastern Program r4w- Caro JV ha>t!!y Q North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet h2o.encstate.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 571-4718 1-877-623-6748 An Equal Opportunity/Affirmative Action Empbyer— 50% Reryck d/10% Post Consumer Paper Service,,., U.S. Postal MAIL,,., RECEIPT �RTIFIED Coverage Provided) mestic Mail Only; No Insurance _ ... ..___..__..._.. ..... ,.,ersua M..usos.com E D 1 A L 0 —D Postage 1 $ J fU Certified Fee O Postmark F3 ReWm Receipt Fee Here C3 (Endorsernenl Required) O Restricted Delivery Fee ra (Endorsement Required) ca ARTHUR L. SCHERMBECK, PLANT MANAGER C3 T` ARCLIN USA, INC. -0 790 CORINTH ROAD C3 Xn MONCURE, NC 27559 I.- NOVA-2008-0171.NC892 0000 orF ARCLIN USA, INC.CHATHAM.COUNTY c;ry 5/9/08.MAILED.S/16/08,$WP.BRIXEY �OF WATF90 Michael F. Easley, Governor William G. Ross Jr., S£cretary O v o M p North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director p Division of Water Quality May 09, 2008 CERTIFIED MAIL RETURN RECEIPT REQUESTED 7006 0810 0002 6049 3040 Arthur L Schermbeck, Manager Plant Arclin USA Inc 790 Corinth Rd Moncure, NC 27559 SUBJECT: Notice of Violation and Assessment of Civil Penalty for Violations of North Carolina General Statute (G.S.) 143-215.l(a)(6) and NPDES Permit NC0000892 Arclin USA Inc Arclin USA, Inc Case No. LV-2008-0171 Chatham County Dear Mr. Schermbeck: This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $649.68 ($600.00 civil penalty + $49.68 enforcement costs) against Arclin USA Inc. This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report (DMR) submitted by Arclin USA Inc for the month of February 2008. This review has shown the subject facility to be in violation of the discharge limitations and/or monitoring requirements found in NPDES Permit NC0000892. The violations that occurred in February 2008 are summarized in Attachment A to this letter. Based upon the above facts, I conclude as a matter of law that Arclin USA Inc violated the terms, conditions or requirements of NPDES Permit NC0000892 and G.S. 143-215.1(a)(6) in the manner and extent shown in Attachment A. In accordance with the maximums established by G.S. 143- 215.6A(a)(2), a civil penalty may be assessed against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215. 1 (a). Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary of the Department of Environment and Natural Resources and the Director of the Division of Water Quality, I, S. Daniel Smith, Division of Water Quality Regional Supervisor for the Raleigh Region, hereby make the following civil penalty assessment against Archn USA Inc: Np on` hCaro ina vatura)ty North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Internet: www.ncwaternuality.org 1628 Mail Service Center Raleigh, NC 27699-1628 An Equal OpportunitylAf rmative Action Employer -50%Recydedll0% Post Consumer Paper Phone (919) 7914200 Customer Service FAX (919)788-7159 1-877-6236748 Archn USA Inc. Case Nq L•V-20d8-0171 1 of the 1 violations of G.S. 143-215. 1 (a)(6) and NPDES Permit No. 100.00 NC0000892, by discharging waste water into the waters of the State in violation of the Permit Daily Maximum limit for NICKEL. 1 of the 1 violations of G.S. 143-215.1(a)(6) and NPDES Permit No. 500.00 NC0000892, by discharging waste water into the waters of the State in violation of the Permit Monthly Average limit for NICKEL. 600.00 TOTAL CIVIL PENALTY 49.68 Enforcement Costs 649.68 TOTAL AMOUNT DUE Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B- 282'. 1 (b), which are: (1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; (2) The duration and gravity of the violation; (3) The effect on ground or surface water quantity or quality or on air quality; (4) The cost of rectifying the damage; (5) The amount of money saved by noncompliance; (6) Whether the violation was committed willfully or intentionally; (7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and (8) The cost to the State of the enforcement procedures. Within thirty days of receipt of this notice, you must do one of the following: 1. Submit payment of the penalty: Payment should be made directly to the order of the Department of Environment and Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s). Please submit payment to the attention of: Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 OR 2. Submit a written request for remission or mitigation including a detailed justification for such request: Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing, such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you believe the civil penalty should be Arelin USA Inc. Case No. LV-2008-0171 remitted, and submit it to the Division of Water Quality at the address listed below. In determining whether a remission request will be approved, the following factors shall be considered: (1) whether one or more of the civil penalty assessment factors in NCGS 143B-282. I (b) was wrongfully applied to the detriment of the petitioner; (2) whether the violator promptly abated continuing environmental damage resulting from the violation; (3) whether the violation was inadvertent or a result of an accident; (4) whether the violator had been assessed civil penalties for any previous violations; or (5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions. Please note that all evidence presented in support of your request for remission must be submitted in writing. The Director of the Division of Water Quality will review your evidence and inform you of her decision in the matter of your remission request. The response will provide details regarding the case status, directions for payment, and provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider information that was not part of the original remission request considered by the Director. Therefore, it is very important that you prepare a complete and thorough statement in support of your request for remission. In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form within thirty (30) days of receipt of this notice. The Division of Water Quality also requests that you complete and submit the enclosed "Justification for Remission Request." Both forms should be submitted to the following address: Point Source Compliance/Enforcement Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 OR 3. File a petition for an administrative hearing with the Office of Administrative Hearings: If you wish to contest any statement in the attached assessment document you must file a petition for an administrative hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with the Office of Administrative Hearings within thirty (30) days of receipt of this notice. A petition is considered filed when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original and one (1) copy of the petition must be filed with the Office of Administrative Hearings. The petition may be faxed - provided the original and one copy of the document is received in the Office of Administrative Hearings within five (5) business days following the faxed transmission. The mailing address for the Office of Administrative Hearings is: Office of Administrative Hearings 6714 Mail Service Center Raleigh, North Carolina 27699-6714 Telephone (919) 733-2698 Facsimile: (919) 733-3478 Archn USA Inc. Case No. LV-2008-0171 and Mail or hand -deliver a copy of the petition to Mary Penny Thompson, General Counsel Department of Environment and Natural Resources 1601 Mail Service Center Raleigh, North Carolina 27699-1601 Please indicate the case number (as found on page one of this letter) on the petition. Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by an internal date/time received stamp (not a postmark), will result in this matter being referred to the Attorney General's Office for collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations that occur after the review period of this assessment. If you have any questions, please contact Stephanie Brixey of the Raleigh Regional Office at 919- 7914200. Since/rely, /. Jl' �( alv S. Daniel Smith Water Quality Regional Supervisor Raleigh Regional Office ATTACHMENTS cc: Point Source Compliance w/ attachments Enforcement File w/ attachments Eastern NPDES Program Central Files w/ attachments JUSTIFICATION FOR REMISSION REQUEST DWQ Case Number: LV-2008-0171 County: Chatham Assessed Party: Arclin USA Inc Permit No. (if applicable): NC0000892 Amount Assessed: $649.68 Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of Facts" form to request remission of this civil penalty. You should attach any documents that you believe support your request and are necessary for the Director to consider in evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or more of the following five factors apply. Please check each factor that you believe applies to your case and provide a detailed explanation, including copies of supporting documents, as to why the factor applies (attach additional pages as needed). (a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b) were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment document); (b) the violator promptly abated continuing environmental damage resulting from the violation (i.e., explain the steps that you took to correct the violation and prevent future occurrences); (c) the violation was inadvertent or a result of an accident (i.e., explain why the violation was unavoidable or something you could not prevent or prepare for); (d) the violator had not been assessed civil penalties for any previous violations; _ (e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing the activities necessary to achieve compliance). EXPLANATION: STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT COUNTY OF Chatham AND NATURAL RESOURCES Arclin USA Inc IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN OF CIVIL PENALTIES AGAINST ) ADMINSTRATIVE HEARING AND Arclin USA, Inc ) STIPULATION OF FACTS PERMIT NO. NC0000892 ) FILE NO. LV-2008-0171 Having been assessed civil penalties totaling $649.68 for violation(s) as set forth in the assessment document of the Division of Water Quality dated, the undersigned, desiring to seek remission of the civil penalty, does hereby waive the right to an administrative hearing in the above - stated matter and does stipulate that the facts are as alleged in the assessment document. The undersigned further understands that all evidence presented in support of remission of this civil penalty must be submitted to the director of the Division of Water Quality within thirty (30) days of receipt of the notice of assessment. No new evidence in support of a remission request will be allowed after (30) days from the receipt of the notice of assessment. This the day of 20 SIGNATURE ADDRESS TELEPHONE ATTACHMENT Arclin USA Inc CASE NUMBER:LV-2008-0171 PERMIT: NC0000892 FACILITY: Arclin USA, Inc COUNTY: Chatham REGION: Raleigh PENALTY MONITORING REPORT OUTFACE/ PPI LOCATION PARAMETER VIOLATION DATE FREQUENCY UNIT OF MEASURE CALCULATED LIMIT VALUE %OVER LIMB VIOLATION TYPE $100.00 2-2008 001 Effluent NICKEL 02/19/08 Ouartedy ugA 1.527 11 620.37 Daily Maximum Exceeded $500.00 2-2008 001 Effluent NICKEL 02/29/08 Ouadedy ugA 0.648 11 1.597.53 Monthly Average Exceeded 6 C _I � r��G10 1- OFFICE 49 a D�; Q4 TMS APR 01 2008 EFFLUENT COPY: DL, LL, FILE NPDES PERMIT NO: NCOOOO892 DISCHARGE NO: 001 MONTH February YEAR: 200E FACILITY NAME: Arclin, USA Inc. CLASS: II COUNTY: Chatham OPERATOR IN RESPONSIBLE CHARGE (ORC): David Lo acher GRADE: II PHONE: (919) 542-2526 CERTIFIED LABORATORY: (1) TriTest, (2) Carolina E ironmental, (3) Dynea, USA. CHECK BOX IF ORC HAS CHANGED O PERSON(S) COLLECTING SAMPLES: David Lorbacher Mail ORIGINAL and ONE COPY to: '9rY Attn: Central Files XK�,/ Z Division o/ Water Quality (SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE 1617 Mall Service Canfer By MIS SIGNATURE, I CERTIFY MAT MIS REPORTIS RALEIGH, N.C. 27699.1617 ACCURATEANDCOMPLETE TO THEeESTOFMYKNOWI.EDGE. DATE OPERATOR ARRNAL TIME 2400CLOCK OPER- ATOR TIME ON SITE FORC ON SITE FLOW. EFFLUENT DAILY RATE 00010 TEMP CELSIUS 00400 PH 00300 DISSOLVE OXYGEN 00310 BOD (:day) 20-C. W530 TOTAL SUSPEND RESIDUE D0610 NH3 asN 00625 TKN 00630 NO2+ NO3 00600 TOTAL NITROGEN 00665 TOTAL PROS- PHORUS U694 PHENOL 71880 FORM- ALDEHYDE ACUTE TOXICITY P6 1 HRS 8:00 HRS 8 YM Y MOD -C 0D63023 UNITS I M9& LBS LBS mg/I mg/I mg/L mg/L mglL LBS mg& 2 0.098181 3 0.047772 4 800 8 Y 0.051125 5 800 8 Y OD7 2244 6 :00 8 Y 0.073638 17 7.1 5.0 1.2 0.6 4.0 8.8 10.7 19.5 0.3 7 8:00 8 Y 0.082815 8 8:00 e Y OO72725 9 0.062093 10 0.051362 11 8:00 8 Y 1 0.057936 12 8:00 8 V 1 0.053242 13 TO 8 Y 0.0579441 14 6.9 5.0 1.0 1.0 2.1 9 4.2 9.1 0.3 14 1 8:00 8 Y 0.062372 15 8:00 B Y 0.051992 16 0.097379 17 0.089884 18 8:0( 8 Y 0.088848 19 8:00 8 Y 0.074128 16 6.8 4.0 1.2 0.6 2.2 2.2 4.9 7 1 6,85 < 0.006 0.4 Pass 20 8.00 8 Y 0.078171 21 8:00 8 Y 0.078791 22 8:00 8 Y 0.074558 23 1 0,0836551 24 1 0,097199 25 700 8 Y 0.097199 26 800 8 Y 0.040190 27 8:00 8 Y 0.065583 16 7.5 5.0 1.3 1.1 4.1 6.3 5.0 11.3 1 0A 28 8:00 -8 8 Y 0.100269 29 o-0 8 Y 0.087363 AVtM:KAG 0. 7.1 4.8 6.2 11.8 A 0.0 MAXIMUM 0.100269 17.0 ZS 5.0 1.3 1.1 4.1 8B 10.7 19.5 6.85 < 0.006 0.4 NA MINIMUM 0.640190 14.0 6.8 4.0 1.0 0.6 2.1 2.2 4.2 7.1 NA < 0. 006 0.0 NA Composite C /Grab (G G G G C C G C C C G G C Monthly Limit: Average 0.1 D0 6-9 24.0 Ibs 26.0 Ibs 0.0O61b 0.39% Daily aximum s s uec-U/ 0 W FACILITY STATUS (Please check one of the following) All monitoring data and sampling frequencies meet permit �( requirements. o p a All monitoring data and sampling frequencies do NOT meet permit requirements. oncomp rant If the facitlity is noncompliant, please comment on corrective actions being taken in respect to equipment. operation, maintenance, etc.,and a time table for Improvements to be made. " I certify, under penality of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my Inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the Information, the Information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." Art Schertnbeck r i as e a r ortype 3-/9 or Signature of PernniTfee ate 790 Corinth Road , Moncure N.C. 27559 919/542-2526 July 31,2011 erml ee ress Phone Number Permit Exp. Date 00010 QOOT6 OOOeO OoW2 own Temperature Turbblly Cabr(%to) Cobr(ADMI) OorMuctNlty, OWN 00600 00610 00625 006J0 011 and Ore... Tohl Neropen Ammonium Nitrogen Total Kjeldahl Nitrogen NNnte.Mereea 00960 00951 01002 01027 Olon Total C111oride Total Fluoride 1 Total Artemis01092 cadmium HexavaWnt Chromium 01061 Ot0)T 01105 0110 Nicael Silver Zlnc Aluminum Total Sabnlum 50060 716e0 719M 01551 Total Realduel Chlorine Formaldshyde Mercury xylem. 00300 Dl.aolved oxygen ON" Total Phcaphorus 010J6 Chromium 31616 Fecal colHorm OOJlo B (5(5) OOT20 Lyanlda 01037 Total Cobalt Je69e Phenol (; COD 00765 Total SuMlde 01012 Copper U235 Benzene 00a05K011andGrgeZa.. 0092I Total Magnesium aim Iron Nall Toluene 005J0 j 00929 Total Sodium Of051 Lead Ja260 MBAs Oe6.5 39516 PCB'. 0 5556 50050 FLOW Parameter code ...hitanee may be obtained by calling the Water Ouamy ComPllanc. GIMP et 'll)- JJa06J, .xtensbn let or 5b1. The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting facility's for reporting data. •ORC must visit facility and document visitation of facility as required per 15ANCAC8A.0202 (b) (5) (B). **IF signed by other than the permittee, delegation of signatory authority must be on file with the state per 15ANCACM.0506 (b) (2) (D ). 1029/t °y` Permit Enforcement History by Owner 05/08/08 1 Owner: Arclin USA Inc Facility: Arclin USA, Inc Permit: NC0000892 Region: Raleigh County: Chatham Penally Remission Ent EMC EMC RAH Collection Has Re Assessment penalty Enforcemen Requ¢st Elf Colt Remission Hearing Remission Remission Memo Sent Prot Case Case Number MR Approved Amount t Costs Damages Received Held Amount Held Amount Amount to AGO Total Paid Balance Due Plan Closed LV-2000-0206 06/20/00 $2250.00 $29.96 $2.279.96 $.00 No 07/27/00 TX-2000.0031 06/28/00 $1,500.00 $39.24 $1,539.24 $.00 No 07/27/00 LV-2000-0265 07/26/00 $2,000.00 $47.73 $2,047.73 $.00 No 08/21/00 TX-2001-0016 05/29/01 $1,000.00 $39.24 $1, 039.24 $.00 No 07/02/01 Total Cases: 4 $6.760.00 $166.17 $6,906.17 $.00 Total Penalties: $6,906.17 Total Penalties after remission(s): $6,906.17 Permit NC000f y1 A. (1 J EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Ave2ge Weekly Average Daily Maximum Measurement ' FreauencX Sample Tylye Sample Location' Flow 0.1 MGD Continuous RecordingInfluent or Effluent BOD, 5-day, 20°C 24 Ibs/day 63 lbs/day Weekly Composite Effluent Total Suspended Solids 26 lbs/day 84 Ibs/day Weekly Composite Effluent NH3 as N Weekly Grab Effluent Dissolved Oxygen Weekly Grab Effluent, Upstream & Downstream pH Between 6.0 and 9.0 s.u. Weekly Grab Effluent Formaldehyde Weekly Grab Effluent Temperature, °C Weekly Grab Upstream & Downstream Conductivity Weekly Grab Upstream & Downstream TKN Weekly Composite Effluent NO2+NO3 Weekly Composite Effluent Total NO3) fI(TEN+ NOz Quarterly Composite Effluent Total Total Phosphorusz Quarterly Composite - Effluent Chronic Tox1city3 Quarterly Composite Effluent Notes: 1. Upstream = 100 feet above the discharge. Downstream = In the Haw River prior to confluence with the Deep River. Instream monitoring is waived as long as Dynea remains a member of the Upper Cape Fear River Basin association. See special condition A(3). 2. See Special Condition A(8). 3. Chronic Toxicity (Ceriodaphnia) ® 0.39%; February, May, August, and November (see Special Condition A.4. Supplement to Effluent Conditions) There shall be no discharge of floating solids or visible foam in other than trace amounts 0 0 0 0 ARM— Performance Applied May 28, 2008 Mr. S. Daniel Smith, Water Quality Regional Supervisor Raleigh Regional Office NC Department of Environment & Natural Resources 3800 Barrett Drive Raleigh, NC 27609 RE: Notice of Violation and Assessment of Civil Penalty NPDES Permit Number NC0000892 Case Number LV-2008-0171 Arclin USA, Incorporated —Moncure, North Carolina Dear Mr. Smith: �i -JUN - 4,2008 Arclin USA, Incorporated owns and operates a chemical manufacturing facility in Chatham County, North Carolina. We have received the above -referenced Notice of Violation and Assessment of Civil Penalty issued by the NCDENR related to wastewater discharges in February, 2008. Arclin believes this NOV was issued in error, and requests that the NCDENR formally withdraw the NOV. The NOV was issued for exceeding the "Daily Maximum" and "Monthly Average" discharge limits for Nickel during monitoring conducted in February, 2008. The NPDES permit limits discharge of Nickel to 1.527 pounds/day (daily maximum), and 0.648 pounds/day (monthly average). With a measured Nickel concentration of 11 µg/l, and the discharge quantity of 74,128 gallons on February 19, 2008 (the day of sampling), Nickel discharges were only 0.0068 pounds during that day, which is well below both the daily maximum and monthly average Nickel discharge limits. A review of the NCDENR NOV issued to Arclin seems to indicate the State misread the units of measure for discharge permit limits, reading the discharge permit limits as micrograms/liter, instead of pounds/day. If you concur that the NOV was issued in error, please provide Arclin with a written withdrawal of the Notice of Violation and Assessment of Civil Penalty. We request that this be done as quickly as possible, in order for us to avoid the need to file a petition for an administrative hearing with the Office of Administrative Hearings, in accordance with the terms and conditions set forth in the NOV. 790 Corinth Road • Moncure, North Carolina 27559 -USA - p 919.542.2526 f919.542.2817 • w .arclin.com 0 of If we have misunderstood the calculations used to determine that Arclin violated the NPDES permit, and NCDENR still believes the NOV was correctly issued, please contact us so that we may have discussions to better understand the basis of the NOV. If you have questions concerning this submittal, please feel free to contact Brad Crawford at (919) 542-2526 extension 3075. Sincerely, Arthur L. Schermbeck Plant Manager BSC/ Cc: Brad Crawford David Lorbacher Chris McKeeman DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT Violator: Arclin USA Inc County: Chatham Case Number: LN'-2008-0171 ASSESSMENT FACTORS 1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property resulting from the violation; No known damage to environment, public health or private property. 2) The duration and gravity of the violation; One daily maximum and one monthly average exceeded for total nickel. 3) The effect on ground or surface water quantity or quality or on air quality; Not documented. 4) The cost of rectifying the damage; Not documented. 5) The amount of money saved by noncompliance; It is not believed any money was saved by this violation. 6) Whether the violation was committed willfully or intentionally; It is not believed that the violations were committed intentionally. 7) The prior record of the violator in complying or failing to comply with programs over which the Environmental Management Commission has regulatory authority; and There has not been any NOV's or NOVA'S in the past year. 8) The cost to the State of the enforcement The cost is $49.68. D to Dannv Smtt Water Quality Regional Supervisor Raleigh Regional Office .o�OF W A r�q h r ' -� MILD o < 217 May 27, 2008 Mr. Art Schermbeck Plant Manager Arclin USA Inc. 790 Corinth Road Moncure, NC 27559 Subject: Compliance Evaluation Inspection Arclin USA Inc. NPDES Permit Number NC0000892 Chatham County Dear Mr. Schermbeck: Michael F. Easley, Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality On May 22, 2008, Ms. Stephanie Brixey of the Raleigh Regional Office conducted a compliance evaluation inspection of the facility with the assistance of Mr. David Lorbacher, ORC of the facility. His help was appreciated as it facilitated the inspection process. The following observations were made: 1. The Arclin W WTP is currently permitted to discharge at a rate of 0.100 MGD and consists of: an aerated equalization basin, an aeration basin with activated sludge, a secondary clarifier, sand filters, effluent trough with flow meter and sludge drying beds. The facility's permit also includes stormwater requirements for three outfalls (002, 003 and 004). The facility discharges into the Haw River, classified as WS-IV waters in the Cape Fear River Basin. 2. Mr. Lorbacher stated that Mr. James Frick is no longer a backup ORC. An ORC or backup ORC is required to notify TACU in writing within 14 days of vacating an ORC or backup ORC position. The ORC designation form can be found at: http://h2o.enr.state.nc.us/tacu/forms.html. Please submit an updated form immediately. Mr. Chris Lamm and Mr. Thomas Dixon are still backups for the facility. 3. Arclin has a field lab certification to analyze pH, temperature and D.O. All other parameters are sent to Carolina Environmental and TriTest Laboratories. 4. A review of plant records indicated that all records are being kept as required. A comparison of the January through March 2008 DMRs indicated no discrepancies. 5. McGill Composting disposes of the sludge from the facility's seven drying beds. The drying beds were being cleaned the day of the inspection. 6. The sand filter is used when TSS levels are high. Currently there are no problems with solids; therefore the filters are not in operation. Carolina _ it%nhiwr/ji North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet h2c.enr.state.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 5714718 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% RegGed/10% Post Consumer Paper Arclin USA, Inc. NPDES Permit No. NC0000892 Chatham County • Mr. Lorbacher stated that he calibrates the flow meter annually used for reporting. He calibrates using two points (low flow and high flow). Please make sure a three-point calibration is performed and documented. It is recommended that the three points be at: zero flow, high flow and mid -range of the previous two points. 8. The facility has a Delta V system that sets off an alarm if something vanes from the set range. The pH meters in the equalization basin and the aeration basin are set to trigger the alarm when levels are too low or too high. The system also monitors the sludge level in the secondary clarifier and the flow in the effluent trough. 9. The facility no longer has an individual stormwater permit number NCS000150. The stormwater requirements are now part of the NPDES permit number NC0000892. Stormwater records were reviewed during the inspection. The following items were noted: I. The Stormwater Pollution Prevention Plan (SPPP) needs to be updated. The facility has had a name change, which should be incorporated into the plan. II. The site map needs to be updated to include outfall 004 and some buildings that have been added to the site. III. All outfalls should be re -certified. IV. Employee training is computer based but needs to be documented some way in the records. 10. Mr. Lorbacher is keeping the files in a well -organized fashion. Such order eased the file review process. The overall conditions of the Arclin W WTP and stormwater program are compliant with Division standards. If you have any questions regarding the attached report or any of my findings, please contact Stephanie Brixey at (919) 791-4200 (or email: stephanie.brixey@a,ncmail.net). Sincerely, Stephanie Brixey Senior Environmental Specialist Cc: Mr. David Lorbacher, Arclin Stephanie Brixey, RRO-SWP Central Files United States Environmental Protection Agency FormApproved. EPA Washington, D.0 20460 OMB OMB No. 2040-0057 Water Compliance Inspection ReDort 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 UN 2 151 31 NC0000892 111 121 08/05/22 117 181 C 191 S 20IJ v U U U L Remarks 21111111111111111111111111111111111111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 OA ------•—•---Reserved•-------- 67I 1 69 70u 711J 721 j 73LU 74 75I 1 1 1 1 1 1 1 80 Section B: FacilityData Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry rime/Date Permit Effective Date POTW name and NPDES permit Number) Arclin USA, inc 09:00 AM 08/05/22 07/08/01 Exit Time/Date Permit Expiration Date 790 Corinth Rd Moncure NC 27559 01:00 PM 08/05/22 11/07/31 Name(s) of Onsite Representafive(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data David Wayne Lorbacher/ORC/919-542-2526/ Name, Address of Responsible Offidal/Title/Phone and Fax Number Bradford S Crawford,790 Corinth Rd Moncure NC 27559/Health, Safety o 5,ntacted Environmental Engineer/919-542-2526/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program . Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Laboratory Storm Water 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 n p� Stephanie Brixey LY�,U,t' �`; RRO WQ/// 5�z `IDv Signature o Manage ent Q A Rev r Agenc�y//Offifioel o and Fax Numbers /a '1 yDate A v EPA Form 3560.3 (Rev 9- ) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 1 3I NC0000892 I11 12� 08/05/22 I17 18UC Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) See inspection letter. Page # 2 lJ Permit: NC0000892 Owner - Facility: Arclin USA, Inc Inspection Date: 05/22/2008 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 application? ❑ ❑ ■ ❑ Is the facility as described in the permit? ■ n n n # Are there any special conditions for the permit? n ■ n ❑ Is access to the plant site restricted to the general public? ■ n n n Is the inspector granted access to all areas for inspection? ■ n n O Comment: The individual stormwater permit is no longer active and has been incorporated into the NPDES permit no. NC0000892. 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? ■ n n O Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n Are analytical results consistent with data reported on DMRs? ■ n n n Is the chain -of -custody complete? ■ O ❑ Q 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? ■ Q 0 Has the facility submitted its annual compliance report to users and DWQ? C3 ❑ ■ ❑ (if the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Q ❑ ■ Cl Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n Is the backup operator certified at one grade less or greater than the facility classification? ■ O n n Is a copy of the current NPDES permit available on site? ■ n n n Facility has copy of previous year's Annual Report on file for review? n n ■ n Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ ❑ ❑ ❑ Page # 3 E Permit: NC0000892 Owner • Facility: Arclin USA, Inc Inspection Date: 050212008 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Is flow meter calibrated annually? Is the flow meter operational? Yes No NA NE ■❑00 ■ Q 0 Q (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ■ ❑ 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? Comment: Equalization Basins Yes No NA NE Is the basin aerated? ■ n n n Is the basin free of bypass lines or structures to the natural environment? ■ 0 ❑ I] Is the basin free of excessive grease? ■ Q O ❑ Are all pumps present? ■ n n 0 Are all pumps operable? ■ n n n Are float controls operable? O 0 ■ ❑ Are audible and visual alarms operable? Cl Q ■ ❑ # Is basin size/volume adequate? ■ ❑ n O Comment: Aeration Basins Yes No NA NE Mode of operation Type of aeration system surface Is the basin free of dead spots? ■ n n n Are surface aerators and mixers operational? ■ 0 n I] Are the diffusers operational? n n ■ n Is the foam the proper color for the treatment process? ■ O n n Does the foam cover less than 25% of the basin's surface? ■ ❑ n n Is the DO level acceptable? ❑ Q Q ■ Is the DO level acceptable?(1.0 to 3.0 mg4) O ❑ ❑ ■ Comment: Page # 4 0 Permit: NC0000892 Owner - Facility: Arclin USA, Inc Inspection Date: 05/22/2008 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ ❑ Are weirs level? ■ ❑ ❑ ❑ Is the site free of weir blockage? ■ ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑ Is scum removal adequate? ■ ❑ ❑ ❑ Is the site free of excessive floating sludge? ■ ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ ■ ❑ Is the return rate acceptable (low turbulence)? ■ ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth) ❑ ❑ ❑ ■ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall property maintained? ■ Cl 110 Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑ Comment: Is containment adequate? ■ ❑ ❑ ❑ Is storage adequate? ■ ❑ ❑ ❑ Are backup pumps available? ■ ❑ ❑ ❑ Is the site free of excessive leaking? ■ ❑ ❑ ❑ Comment: Drying Beds Yes No NA NE Is there adequate drying bed space? ■ ❑ ❑ ❑ Is the sludge distribution on drying beds appropriate? ■ ❑ ❑ ❑ Are the drying beds free of vegetation? ■ ❑ ❑ ❑ # Is the site free of dry sludge remaining in beds? ■ ❑ ❑ ❑ Is the site free of stockpiled sludge? ■ ❑ ❑ ❑ Is the filtrate from sludge drying beds returned to the front of the plant? ■ ❑ ❑ ❑ Page # 5 Permit: NC0000892 Owner -Facility: Arclin USA, Inc Inspection Date: 05/22/2008 Inspection Type: Compliance Evaluation Drying Beds Yes No NA NE # Is the sludge disposed of through county landfill? ❑ ■ ❑ ❑ # Is the sludge land applied? ❑ ■ ❑ ❑ (Vacuum filters) Is polymer mixing adequate? ■ ❑ ❑ ❑ Comment: McGill hauls the sludge from the drying beds and uses it in compost. 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)? ■ ❑ ❑ ❑ Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory.. ■ ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? ■ ❑ ❑ ❑ # Is the facility using a contract lab? ■ ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ ❑ ❑ ❑ Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ■ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ■ ❑ Comment Page # 6 Permit: NCOcLGM Owner - Facility: Arclin USA Inc Inspection Date: 051=200F Inspection Type: Stormwater Reason for Visit: Routine Stommmater Pollution Prevention Plan Yes No NA NE Does the site have a Stonnwater Pollution Prevention Plan? ■ ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? ■ ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? ■ n Cl ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? ■ ❑ ❑ ❑ # Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ Cl Cl # Does the facility provide and document Employee Training? ■ Cl ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ Q Q 0 # Is the Plan reviewed and updated annually? ■ ❑ Cl ❑ # Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? ❑ ❑ ■ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑ Comment: The facility is only required to do analytical monitoring if vehicle maintenance is performed on -site. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑ # Were all outfalls observed during the inspection? ■ n ❑ n # If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ n ❑ ❑ Comment Page: 3 N N A-rdin- Performance Applied May 9, 2008 Mr. Ken Schuster, Water Quality Supervisor Raleigh Regional Office NC Department of Environment & Natural Resources 3800 Barrett Drive Raleigh, North Carolina 27609 RE: Arclin USA, Incorporated Formaldehyde Release Follow-up Report Dear Mr. Schuster: MAY 1 2 2D This submittal is to provide written follow-up reporting, required by 40 CFR 355.40(b)(3), related to the May 7, 2008 release incident at the Arclin USA, Incorporated facility in Moncure, North Carolina. Verbal notifications of this incident, which resulted in the release of 250-300 pounds of formaldehyde to the air, were provided to Mr. Chris Tant at the SERC, and Ms. Denise Suits of the Chatham County LEPC, as well as the National Response Center (Mr. Tant indicated our written follow-up notification should be sent to you). Listed below is the information requested to be submitted by the regulation: (i) Actions taken to respond to and contain the release; The release incident occurred when a formaldehyde storage tank was overfilled, resulting in the release of approximately 175 gallons of a 54% formaldehyde solution to the concrete containment dike surrounding the tank. The transfer was immediately terminated, and clean-up of the material commenced. The spilled formaldehyde solution, and all clean-up water used to clean the area, were recovered and will be re -used in our resin production process. Our calculations indicate that during clean-up operations, which took about 90 minutes, approximately 250-300 pounds of formaldehyde evaporated into the air. (fi) Any known or anticipated acute or chronic health risks associated with the release; No employees or off -site personnel were exposed as a result of this incident; therefore no acute or chronic health effects are known or anticipated. 790 Corinth Road • Momme, North Carolina 27559 • USA • p 919.542.2526 f919.542.2817 • w .amlin.com MPage 2 (fii) Where appropriate, advice regarding medical attention necessaryfor exposed individuals; No employees or off -site personnel were exposed as a result of this incident; therefore, no medical treatment was necessary for any individual. If you have questions concerning this submittal, or need additional information related to the incident, please feel free to contact me at (919) 542-2526, extension 3075. Sincerely, Bradford S. Crawford, P.E. Health, Safety & Environmental Engineer BSC/ Cc: Mr. Tony Tucker, Director Chatham County Emergency Operations P.O. Box 613 Pittsboro, NC 27312 ft � y � Y Mr. Art Schermbeck Plant Manager Dynea USA, Inc. 790 Corinth Road Moncure, NC 27559 May 17, 2007 Subject: Compliance Evaluation Inspection Dynea USA, Inc. NPDES Permit Number NC0000892 Stormwater Permit Number NCS000150 Chatham County Dear Mr. Schermbeck: M Michael F. Easley, Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources . t V Alan W. Klimek, P.E., Director Division of Water Quality On May 16, 2007, Ms. Stephanie Brixey of the Raleigh Regional Office conducted a compliance evaluation inspection of the facility with the assistance of Mr. David Lorbacher, ORC of the facility, and Mr. James Frick, back-up ORC. All help was appreciated as it facilitated the inspection process. The following observations were made: 1. The Dynea W WTP is currently permitted to discharge at a rate of 0.100 MGD and consists of: an equalization basin, aeration basin, secondary clarifier, sand filter and drying beds. The facility's permit also includes stormwater requirements for two outfalls (002 and 003). A third outfall (outfall 4) is being monitored and will be included in the new permit when issued. 2. Dynea has a laboratory certification to analyze pH, temperature and D.O. All other parameters are sent to Carolina Environmental and TriTest Laboratories for analyses. 3. McGill Composting disposes of the sludge from the facility's seven drying beds. McGill was cleaning the drying beds on the day of the inspection. 4. The sand filter is used when TSS levels are high. There are no current problems with solids, and the sand filter is not in operation. 5. Mr. Lorbacher stated that he calibrates the flow meter used for reporting. Please make sure that a three- point calibration is performed and documented. It is recommended that the three points be at: zero flow, high flow and mid -range of the other points. 6. A review of the plant records indicated that all records are being kept as required. A comparison of the January through March 2007 DMRs indicated no discrepancies. Nopp�rt1tCaro�n ,NQflln2(l(/ North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet h2o.enr.state.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 571 4718 1-877-623-6748 An Equal Opportunity/A(8mtaliva Action Employer— 50% RecycWlO% Post Consumer Paper Dynes USA, Inc. NPDFS NC0000892 Chatham County 7. An inspection of the facility's stormwater permit (NCS000150) was also conducted during the site visit. Stonnwater records were reviewed and found to be satisfactory. The site map needs to be updated to include stormwater outfall 004. All outfalls should be re -certified. Mr. Frick said this would be completed once the new permit becomes effective so he can incorporate any additional changes required by the new permit. All three stormwater outfalls were observed. It is recommended that the right away to each outfall be maintained so Dynea employees and DWQ staff can easily perform visual monitoring. 8. Mr. Lorbacher and Mr. Frick are keeping the files in a well -organized fashion. Such order eased the file review process. The overall conditions of the Dynea W WTP and stormwater program are compliant with Division standards. If you have any questions regarding the attached report or any of the findings, please contact Stephanie Brixey at (919) 791-4200 (or email: stephanie.brixev(@ncmail net). Sincerely, Stephanie Brixey Environmental Specialist Cc: W. David Lorbacher, Dynea Mr. James Frick, Dynes. Stephanie Brixey - RRO Central Files 06 N United States Environmental Protection Agency Form Approved. Washington, D.C. 20460 A OMB No. 2040-0057 Water Com liance Inspection Re ort 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 I vl 2 ICI 31 NC0000892 111 121 07/05/16 117 18I r' 19I CI 20U IJ U U U Remarks 211111111111111111111111111llllllllllllllllll11116 Inspection Work Days Facility Self -Monitoring Evaluation Rating Bi OA -------•-•-------Reserved•-------- 67I 1 69 70J 71 72J 73L74 75L I 1 I 1 180 U Section B: Facility Data Nam and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Entry Time/Date Permit Effective Date Dynea U.S.A. 10:00 AM 07/05/16 04/05/01 790 Corinth Rd Exit Time/Date Permit Expiration Date Moncure NC 27559 12:00 AM 07/05/17 06/07/31 Names) of Onsite Representafive(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data David Wayne Lorbacher/ORC/919-542-2526/ Name, Address of Responsible OfficiaVTitle/Phone and Fax Number Danny E Lakes, 790 Corinth Rd Moncure NC 27559//919-542-2526/ Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit ■ Flow Measurement E Operations & Maintenance Records/Reports Self -Monitoring Program . Sludge Handling Disposal E Facility Site Review Effluent/Receiving Waters Laboratory 0 Storm Water 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 Stephanie Brixey ��[1•'.,5._ _ RRO WQ/// 5I11%IM Signature of Manag nt O A Reviewer Agency/Office/Phone and Fax Numbers Date `S,1/7l D 7 EPA Form 3560-3 (Rev 9-94) Previous edg�rn S are obsolete. Page # 1 a* so NPDES yr/nnolday Inspection Type 3I NC0000892 1 11 12I 07/05/16 I17 181C1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The facility has field lab certification to analyze pH, DO & temperature. All other parameters are contracted out to Carolina Environmental and/or TriTest. Sludge is disposed of by McGill Composting. The drying beds were being cleaned the day of the inspection. The sand filter is only used when the facility has high TSS. Currently the sand filter is not being operated. Page # 2 Permit: NC0000892 Owner • Facility: Dynea U.S.A. Inspection Date: 05/16/2007 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 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: Permit expired July 31, 2006 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 2417 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: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ ❑ ❑ ❑ Page # 3 so so I Permit: NC0000892 Inspection Date: 05/16/2007 Owner -Facility: Dynea U.S.A. Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is flow meter calibrated annually? s ❑ ❑ ❑ Is the flow meter operational? E ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ N ❑ Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑ Judge, and other that are applicable? Comment: Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ❑ # Is basin size/volume adequate? ❑ ❑ ❑ Comment: Aerators, pumps & flow meters are connected to a Delta V system that sets off an alarm if something varies from the set range. Aeration Basins Yes No NA NE Mode of operation Type of aeration system Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ ❑ Are the diffusers operational? ❑ ❑ ❑ Is the foam the proper color for the treatment process? ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ N Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ 0 Comment: Page # 4 Permit: NC0000892 Owner -Facility: Dynea U.S.A. Inspection Date: 05/1612007 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? In ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ❑ ❑ ❑ Is scum removal adequate? ❑ ❑ ❑ Is the site free of excessive floating sludge? ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow clear of excessive solids/pin Floc? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) ❑ ❑ ❑ 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? ❑ ❑ N ❑ Comment: Chemical Feed Yes No NA NE Is containment adequate? M ❑ ❑ ❑ Is storage adequate? M ❑ ❑ ❑ Are backup pumps available? ❑ ❑ M ❑ Is the site free of excessive leaking? 0 ❑ ❑ ❑ Comment: Drying Beds Yes No NA NE Is there adequate drying bed space? 0 ❑ ❑ ❑ Is the sludge distribution on drying beds appropriate? 0 ❑ ❑ ❑ Are the drying beds free of vegetation? 0 ❑ ❑ ❑ # Is the site free of dry sludge remaining in beds? ❑ ❑ ❑ Is the site free of stockpiled sludge? ❑ ❑ ❑ Is the filtrate from sludge drying beds returned to the front of the plant? M ❑ ❑ ❑ Page # 5 so ot Permit: NC0000892 Owner -Facility: Dynea U. S.A. Inspection Date: 05/16/2007 Inspection Type: compliance Evaluation Drying Beds If Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Comment: Sludge is disposed of by McGill Composting. Effluent Sampling 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 1.0 to 4.4 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Comment: Yes No NA NE ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Page # 6 NPDES REGIONAL WATER QUALITY STAFF REPORT AND RECOMMENDATIONS (This form is best filled out on computer, rather than hard copy) Date: May 18, 2006 County: Chatham To: NPDES Discharge Permitting Unit Permitee: Dvnea USA, Inc. Atm. NPDES Reviewer: Bryant Application/ Permit No.: NC0000892 Staff Report Prepared By: Christopher Wu Project Name: Dvnea USA, Inc. SOC Priority Project? (Y/1) NL If Yes, SOC No. A. GENERAL INFORMATION 1. This application is (check an that apply): ❑ New ® Renewal ❑ Modification 2. Was a site visit conducted in order to prepare this report? ® Yes or ❑ No. a. Date of site visit: May 17, 2006 b. Person contacted and telephone number: David Lorbacher, 542-2526 c. Site visit conducted by: Christopher Wu d. Inspection Report Attached: ® Yes or ❑ No. 3. Keeping BIMS Accurate: Is the following BIAS information (a. through e. below) correct? ® Yes or ❑ No. If No, please either indicate that it is correct on the current application or the existing permit or provide the details. If none can be supplied, please explain: (If there is more than one discharge pipe, put the others on the last page of this form.) a. Location OK on Application ❑, OK on Existing Permit ❑, or provide Location: b. Driving Directions OK on Application ❑, OK on Existing Permit ❑, or provide Driving Directions (please be accurate): c. USGS Quadrangle Map name and number OK on Application ❑, OK on Existing Permit ❑, or provide USGS Quadrangle Map name and number: d. Latitude/Longitude OK on Application ❑, (check at bft://www.!mzone.com These are often inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude: e. Receiving Stream OK on Application ❑, OK on Existing Permit ❑, or provide Receiving Stream or affected waters: a. Stream Classification: b. River Basin and Sub basin No.: c. Describe receiving stream features and downstream uses: For NEW FACILITIES Proceed to Secdon C Evaluation and Recommendations (For renewals or modifications continue to section B) NPDES REGIONAL WATER QUALITY STAFF REPORT AND RECOMMENDATIONS B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only) 1. Describe the existing treatment facility: The Dynea WWTP is permitted to discharge at a rate of 0.100 MGD and consists of: an equalization basin, aeration basin, secondary clarifier, sand filter, and drying beds. The permit also has stormwater requirements for 2 outalls. The facility now has 3 stormwater outfalls for which they monitor and sample (004 is new and needs to be added to the permit). 2. Are there appropriately certified ORCs for the facilities? M Yes or ❑ No. Operator in Charge: David Lorbacher Certificate # 985295 (Available in BIMS or Certification Website) Back- Operator in Charge: James Frick Certificate # 987003 3. Does the facility have operational or compliance problems? Please comment: None. Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle; Current enforcement action(s)): None. Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes or ❑ No. If no, please explain: 4. Residuals Treatment: PSRP ❑ (Process to Significantly Reduce Pathogens, Class B) or PFRP M (Process to Further Reduce Pathogens, Class A)? Are they liquid or dewatered to a cake? Land Applied? Yes ❑ No ❑ If so, list Non -Discharge Permit No. Contractor Used: Landfilled? Yes ❑ No❑ If yes, where? Other? Adequate Digester Capacity? Yes ❑ No ❑ Sludge Storage Capacity? Yes ❑ No ❑ Please comment on current operational practices: McGill Composting is responsible for hauling and composting the sludge from the drying beds. 5. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes or M No. If yes, please explain: C E VAL UA TION AND RECOMMENDATIONS 1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give regional perspective for each option evaluated: Spray Irrigation: N/A Connect to Regional Sewer System: N/A Subsurface: N/A FORM: NPDES-RRO 06/03, 9/03 2 NPDES REGIONAL WATER QUALITY STAFF REPORT AND RECOMMENDATIONS Other Disposal Options: N/A 2. Provide any additional narrative regarding your review of the application: Aside from adding stormwater outfall 004 there are no problems with the current permit. 3. List any items that you would like NPDES Unit to obtain through an additional information request. Make sure that you provide a reason for each item: Recommended Additional Information I Reason 4. List specific Permit requirements that you recommend to be removed from the permit when issued. Make sure that you provide a reason for each condition: 5. List specific special requirements or compliance schedules that you recommend to be included in the permit when issued. Make sure that you provide a reason for each special condition: 6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold, pending review and approval of required additional information by NPDES permitting office; ® Issue; ❑ Deny. If deny, please state reasons: Reminder: attach inspection report if Yes was checked for 2 d. Signature of report preparer Signature of WQS regional FORM: NPDES-RRO 06/03, 9/03 Michael F. Easley, Governor William G. Ross, Jr., secretary rNorth Carolina Department of Environment and Natural Resources —I Alan W. Klimek, P.E., Director Division of Water Quality May 17, 2006 Mr. Bill Langley Plant Manager Dynea USA, Inc. 790 Corinth Road Moncure, NC 27559 Subject: Compliance Evaluation Inspection Dynes USA, Inc. NPDES Permit Number NC0000892 Chatham County Dear Mr. Langley: On May 17, 2006 Mr. Christopher Wu of the Raleigh Regional Office conducted a compliance evaluation inspection of the Dynes USA, Inc. facility with the assistance of Mr. David Lorbacher, ORC of the facility, and Mr. James Frick, back-up ORC. All help was appreciated as it facilitated the inspection process. The following observations were made: The Dynea WWTP is currently permitted to discharge at a rate of 0.100 MGD and consists of: an equalization basin, aeration basin, secondary clarifier, sand filter, and drying beds. The facility's permit also includes stormwater requirements for two outfalls (002 and 003). A third outfall (outfall 004) is being monitored, but it is not currently included in the permit. Outfall 004 merely drains an open field and does not include process. It should, however, be included in the renewed permit. 2. Dynes USA, Inc. has a contract with McGill Composting to pump and compost sludge collected from its seven drying beds. 3. While Dynea USA, Inc. has its own field certified laboratory it still contracts Carolina Environmental and TriTest Laboratories to conduct analyses. Dynea staff are only certified to analyze pH, temperature, and DO. 4. The low -rate sand filter is used when TSS levels are high. Because there are no current problems with solids, the sand filter is not in operation. 5. An inspection of the facility's stormwater permit (formerly NCS000150) was also conducted during the site visit. The stormwater files are kept in excellent condition. Ncal cats a V mCmr North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet h2o.em.stats.nc.us 3800 Barrett Drive Raleigh, NC 27699-1628 FAX (919) 571-4718 1-877623-6748 An Equal OpportunitylAffirmatwe Action Employer- 50% Recydedl10% Post Consumer Paper Dynea USA, Inc. NC0000892 Most of the required facets of the plan were easily accessible for review. A comprehensive SPPP plan was present, as were a SPCC, semi-annual qualitative monitoring, a list of potential pollutants of concern, and annual stormwater employee training. The site map, however, needs to be updated to include stormwater outfall 004. Also, the stormwater outfall certification for outfalls 002 and 003 was last signed on November 1, 1994. Because of the addition of 004, all outfalls should be recertified. The analytical monitoring for the stormwater permit is currently being conducted as specified by the permit (quarterly samples are to be taken for the second year of the permit cycle so that all data can be submitted prior to the next permit issuance). The newest permit, however, was effective on May 1, 2004, and Dynea staff are currently admist their second year quarterly sampling. The required analytical sampling will not be available till the end of July 2006 at the earliest. 6. Both Mr. Lorbacher and Mr. Frick are keeping all of the files and data in a well organized fashion. Such order eased the file review process. I The overall conditions of the Dynea WWTP are compliant with Division standards. If you have any questions regarding the attached report or any of our findings, please contact Christopher Wu at: (919) 791-4260 (or email: chris.wu@ncmail.net). Sincerely, Christopher Wu Environmental Specialist Cc: Mr. David Lorbacher, Dynea Mr. James Frick, Dynea Carolyn Bryant, DWQ — NPDES Christopher Wu, RRO Central Files Permit: NC0000892 Inspection Date: 05/1712006 Owner - Facility: Dynea U.S.A. Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ ❑ Q O Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ■ n 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? 0 0 ❑ Q Is the facility as described in the permit? ■ ❑ ❑ # Are there any special conditions for the permit? n ■ n n Is access to the plant site restricted to the general public? ■ O n Cl Is the inspector granted access to all areas for inspection? ■ ❑ ❑ Comment: There are no special conditions to the permit. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ Q Cl Is all required information readily available, complete and current? ■ ❑ n n Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n Are analytical results consistent with data reported on DMRs? ■ Q Q ❑ Is the chain -of -custody complete? ■ Q O 0 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? ■ ❑ 0 O Has the facility submitted its annual compliance report to users and DWQ? n n ■ n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? ❑ ❑ ■ O Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n Is the backup operator certified at one grade less or greater than the facility classification? ■ n n n Is a copy of the current NPDES permit available on site? ■ n n n Page # 3 Permit NC0000892 Owner - Facility: Dynea U.S.A. Inspection Date: 05/17/2006 Inspection Type: Compliance Evaluation Record Keopi_g Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ O Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? E ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? ■ O O ❑ If effluent (diffuser pipes are required) are they operating properly? Comment: Drying Beds Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? # Is the site free of dry sludge remaining in beds? Is the site free of stockpiled sludge? Is the filtrate from sludge drying beds returned to the front of the plant? # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Comment: The sludge is composted by McGill Composting. Chemical Feed Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? Comment: Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page # 4 Permit: NC0000892 Owner -Facility: Dynea U.S.A. Inspection Date: 05/172006 Inspection Type: Compliance Evaluation Yes No NA NE 44alization Basins 0000 Are float controls operable? ■ ❑ ❑ ❑ Are audible and visual alarms operable? ■ ❑ ❑ ❑ # Is basin size/volume adequate? Comment: Yes No NA NE Secondary Clarifier Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Are weirs level? ■ ❑ ❑ ❑ Is the site free of weir blockage? ■ ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑ Is scum removal adequate? ■ ❑ ❑ ❑ Is the site free of excessive floating sludge? ■ ❑ ❑ ❑ Is the drive unit operational? ■ ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) ■ ❑ ❑ ❑ Comment: Yes No NA NE Aeration Basins Mode of operation Type of aeration system ■ ❑ ❑ ❑ Is the basin free of dead spots? Are surface aerators and mixers operational? ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Are the diffusers operational? ■ ❑ ❑ ❑ Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Is the DO level acceptable? ❑ ❑ ■ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/l) Comment: Yes No NA NE Laboratory Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑ Page # 5 r Permit: NC0000892 Inspection Date: 05/17/2006 owner • Facility: Dynea U.S.A. Inspection Type: Compliance Evaluation Laboratory Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Comment: Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ OONO Page # 6 Mr. James Frick Dynea U.S.A., Inc 790 Corinth Road Moncure, North Carolina Dear Mr. Frick: 0414;1Y] December 20, 2006 Subject: Michael F. Easley, Governor State of North Carolina William G. Ross, Jr., Secretary Department of Environment and Natural Resources Draft NPDES Permit Permit NC0000892 Dynea WWTP Chatham County Alan W. Klimek, P.E., Director Division of Water Quality Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully to ensure thorough understanding of the conditions and requirements it contains. This draft has the following significant changes from your current permit: • Stormwater outfall 004 has been added to this permit. • The Cape Fear River (from the confluence of the Haw and Deep Rivers to Sanford) is listed on the 2006 303(d) list due to chlorophyll a exceedances. DWQ expects to initiate stream studies in 2010 and modeling in 2012 to determine limits for nutrient and oxygen -demanding wastes in these waters. To prepare for that effort, TN monitoring has been added to this permit, along with Special Condition A(8) that may require additional nutrient monitoring at a future date. Due concerns about nutrient -related impacts, Dynea should bg aware that allowable nutrient loads for any future expansions may be held to historical loading rates. Please submit any comments to me no later than thirty days following your receipt of the draft. Comments should be sent to the address listed at the bottom of this page. If no adverse comments are received from the public or from you, this permit will likely be issued in two months. If you have any questions or comments concerning this draft permit, please contact me at (919) 733-5083 x 551 or via email at toya.fields@ncmail.net. Sincerely, 4r ; LeToya Fields Western NPDES Program cc: �gh, gional Office, Surface Water Protection NPDES Unit Marshall Hyatt, EPA Region IV Aquatic Toxicology Unit Michael Douglas, DEH, Raleigh Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733-7015 FAX (919) 733-0719 D j "}Itbcaro�ina 512 N. Salisbury Street, Raleigh, North Carolina 27604 On the Internet at http://�.�aterquality.org aterquality.org al 7y An Equal Opportunity/Affirmative Acton Employer PermitNC0000892 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions 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, Dynea is hereby authorized to discharge wastewater from a facility located at Dynea 790 Corinth Road Moncure Chatham County to receiving waters designated as the Haw River in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on July 31, 2011 Signed this day Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0000892 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Dynea is hereby authorized to: 1. Continue to operate an existing 0.100 MGD wastewater treatment facility consisting Of. • aerated equalization basin; • aeration basin with activated sludge; • clarifier; • sand filters; • effluent trough with flow meter and • sludge drying beds. The facility is located at Dynea, 790 Corinth Road, Moncure, Chatham County, and 2. Discharge wastewater through outfall 001 and stormwater through outfalis 002, 003 and 004 from said treatment works at the location specified on the attached map into the Haw River, which are classified WS-IV waters in the Cape Fear River Basin. Wt '..- A ! �1h Vyp 93 To 00 00 R _ 1 _ \r� Discharge location 1 (Outfalls 002, 003, and 004 are stormwater outfalls) e Al C0003433 , Litt sSka@dox—__ 1 -S •� %V .-r.. •? CG^,v"t5rit +c J,. GAa .lnc-. S l- rDYNEA� USA - NCO000892 Facility • Location �✓ USGS Quad Name: Moncure Outfall 001: Receiving Stream: Haw River Lat.: 35°36'12" Stream Class: WS IV Long.:79'03'02" Subbasin: Cape Fear —03 06 07 N Not to SCALE Permit NC0000892 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Penmittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Ave a Daily Maximum Measurement Frequency Sample a Sample Location' Flow 0.1 MGD Continuous RecordingInfluent or Effluentt BOD, 5-day, 20°C 24lbs/day 63 lbs/day Weekly Composite Effluent Total Suspended Residue 26 lbs/day 84 lbs/day Weekly Composite Effluent NH3 as N Weekly Grab Effluent Dissolved Oxygen - - L- - - Weekly -- - Grab - - Effluent, Upstream & Downstream pH Between 6.0 and 9.0 s.u. Weekly Grab Effluent Formaldehyde Weekly Grab Effluent Temperature, °C Weekly Grab Upstream & Downstream Conductivity Weekly Grab Upstream & Downstream THIN Weekly Composite Effluent NO2+NO3 Weekly Composite Effluent Total Nitrogen (TKN + NO2+ NO3) Quarterly Composite Effluent Total Phosphorus Quarterly Composite Effluent Chronic Toxicity3 Quarterly I Composite Effluent Notes: 1. Upstream = 100 feet above the discharge. Downstream = In the Haw River prior to confluence with the Deep River. See special condition A(3). 2. Chronic Toxicity (Ceriodaphnia) 0 0.39%; February. May, August, and November (see Special Condition A.4. Supplement to Effluent Conditions) There shall be no discharge of floating solids or visible foam in other than trace amounts Permit NC000089,2 A. (2) EFFLUENT LIMITATIOI ND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge OCPSF related process wastewater from outfall serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below: Effluent Characteristic Daily Maximum Ibs/da Monthly Average Ibsida Daily Maximum Measurement Fre uenc Sample T e Sample Location' Acenaphthene 0.023 0.008 Quarterly Grab E cenaphihylene 0.023 0.008 Quarterly Grab E Acrylonitrile 0.093 0.037 Quarterly Grab E Anthracene 0.023 0.008 Quarterly Grab E Benzene 0.052 0.014 Quarterly Grab E Benzo(a)anthracene 0.023 0.008 Quarterly Grab E 3,4-Benzofluoranthene 0.023 0.009 Quarterly Grab E Benzo(k)fluoranthene 0.023 0.008 Quarterly Grab E Benzo(a)pyrene 0.023 0.009 Quarterly Grab E Bis(2-ethylhexyl) phthalate 0.107 0.040 Quarterly Grab E Carbon Tetrachloride 0.015 0.007 Quarterly Grab E Chlorobenzene 0.011 0.006 Quarterly Grab E Chloroethane 0.103 0.040 Quarterly Grab E Chloroform 0.018 0.008 Quarterly Grab E -Chlorophenol 0.038 0.012 Quarterly Grab E Chrysene 0.023 0.008 Quarterly Grab E Di-n-butyl phthalate 0.022 0.010 Quarterly Grab E 1,2-Dichlorobenzene 0.063 0.030 Quarterly Grab E 1,3-Dichlorobenzene - 0.0111 - 0.012 Quarterly Grab-- - - - E 1,4-Dichlorobenzene 0.011 0.006 Quarterly Grab E 1,1-Dichloroethane 0.023 0.008 Quarterly Grab E 1,2-Dichloroethane 0.081 0.026 Quarterly Grab E 1,1-Dichloroethylene 0.010 0.006 Quarterly Grab E 1,2-trans-Dichloroethylene 0.021 0.008 Quarterly Grab E ,4-Dichlorophenol 0.043 0.015 Quarterly Grab E 1,2-Dichloropropane 0.088 0.059 Quarterly Grab E 1,3-Dichioropropylene 0.017 0.011 Quarterly Grab E Diethyl phthalate 0.078 0.031 Quarterly Grab E ,4-Dimethylphenol 0.014 0.007 Quarterly Grab E Dimethyl phthalate 0.018 0.007 Quarterly Grab E ,6-Dinitro-o-cresol 0.106 0.030 Quartedy Grab E ,4-Dinitrophenol 0.047 0.027 Quarterly Grab E ,4-Dinitrotoluene 0.109 0.043 Quarterly Grab E ,6-Dinitrotoluene 0.246 0.098 Quarterly Grab E Ethylbenzene 0.041 0.012 Quarterly Grab E Fluoranthene 0.026 0.010 Quarterly Grab E Fluorene 0.023 0.008 Quarterly Grab E Hexachlorobenzene 3.3 Quarterly Grab E Hexachlorobutadiene 0.019 0.008 Quarterly Grab E Hexachloroethane 0.021 0.008 Quarterly Grab E Methyl Chloride 0.073 0.033 Quarterly Grab E Methylene Chloride 0.034 0.015 Quarterly Grab E Naphthalene 0.023 0.008 Quarterly Grab E Nitrobenzene 0.026 0.010 Quarterly Grab E -Nitrophenol 0.026 0.016 Quarterly Grab E -Nitrophenol 0.048 0.028 Quarterly Grab E Phenanthrene 0.023 0.008 Quarterly Grab E Phenol 0.010 0.006 Quarterly Grab E Pyrene 0.026 0.010 Quarterly Grab E etrachloroethylene 0.021 0,008 Quarterly Grab E Toluene 0.031 0.010 Quarterly Grab E Total Chromium 1.063 0.426 Quarterly Grab E otal Copper 1.297 0.556 Quarterly Grab E Total Cyanide 0.460 0.161 Quarterly Grab E Total Lead 0.265 0.123 Quarterly Grab E Total Nickel 1.527 0.648 Quarterly Grab E Total Zinc 1.001 0.403 Quarterly Grab E 1,2,4-Tnchlorobenzene 0.054 0,026 Quarterly Grab E 1, 1. 1 -Trichloroethane 0.021 0.008 Quarterly Grab E 1,1,2-Trichloroethane 0.021 0.008 Quarterly Grab E 0.021 0.008 Quarterly Grab E rrichloroethylene in Chloride 0.103 0.040 Quarterly Grab E