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Home My WebLink AboutNC0004952_Compliance Evaluation Inspection_20231218ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Lawrence Wolnik CNA Holdings, LLC. Celanese Shelby Facility 2525 Blacksburg Road Grover, NC 28073 SUBJECT: Compliance Evaluation Inspection Celanese — Shelby Facility WWTP NPDES Permit No. NC0004952 Cleveland County Dear Mr. Wolnik: NORTH CAROLINA Environmental Quality December 18, 2023 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on December 14, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all WWTP staff for their cooperation and assistance that was provided throughout this inspection. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bellkdeq.nc. gov. Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche Sincerely, DocuSigned by: A HNuft F161 F669A2D84A3... Andrew H. Pitner, P.G., Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 704.6631699 United States Environmental Protection Agency Form Approved. EPA 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 IN 1 2 u 3 I NC0004952 111 121 23/12/14 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 701d I 71 I„ I 72 I r., I 71 I 74 79 I I I I I I I80 L—I ty L-1 I I 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) 09:15AM 23/12/14 21/08/01 Celanese Shelby Facility 2525 Blacksburg Rd Exit Time/Date Permit Expiration Date Grover NC 28073 12:35PM 23/12/14 26/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Michael G. Blanton//704-480-4691 / Randall L Turner/ORC/704-480-5793/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Lawrence Wolnik,2525 Blacksury Rd Grover NC 28073//704-480-5728/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate 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 Wes Bell cusignedby: DWR/MROWQ/704-235-2192/ 12/18/2023 �r.& E�:�96D90=437— Signature of Ma Bty41d%Feviewer Agency/Office/Phone and Fax Numbers Date Andrew Pit e��-' H P44-f'DWR/MRO WQ/704-663-1699 Ext.2180/ 12/18/2023 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NC0004952 I11 12I 23/12/14 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NC0004952 Owner -Facility: Celanese Shelby Facility Inspection Date: 12/14/2023 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? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? M ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The last compliance evaluation inspection at this facility was performed by DWR staff on 2/1/2022. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? Dates, times and location of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis Name of person performing analyses Transported COCs Are DMRs complete: do they include all permit parameters? Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? Is the ORC visitation log available and current? Is the ORC certified at grade equal to or higher than the facility classification? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 Permit: NC0004952 Inspection Date: 12/14/2023 Record Keeping Owner -Facility: Celanese Shelby Facility Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed durinq the inspection were orqanized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed for the period November 2022 through October 2023. No limit and/or monitoring violations were reported. The ORC will contact the contracted laboratory to determine if the silver value reported in September 2023 was correct. A revised September 2023 will be submitted if the contracted laboratory reported an incorrect detection level for silver. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # 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: Effluent analyses (pH, temperature and TSS) are performed under the Company's laboratory certification #221. Waypoint Analytical (NPDES parameters) and ETT (toxicity) have also been contracted to provice analytical support. The NIST thermometer used to verify in-house temperature measuring devices had not been recalibrated by the listed due date (December 2020). The facility staff must have the NIST thermometer recalibrated/verified as soon as possible. Once the NIST thermometer is recalibrated/verified, staff must perform verifications with the NIST thermometer on all applicable temperature measuring devices (pH meter, etc.). In addition, laboratory staff must ensure that the model and serial numbers for the laboratory field instrumentation used for effluent field analyses are documented on the calibration lops. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ ❑ Is the tubing clean? ■ ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 0 ❑ ❑ ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ representative)? Comment: The subject permit requires composite and grab effluent samples. The facility staff must ensure to document the monthly aliquot calibrations/verifications performed on the composite sampler. Upstream / Downstream Sampling Yes No NA NE Page# 4 Permit: NC0004952 Inspection Date: 12/14/2023 Owner -Facility: Celanese Shelby Facility Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑ and sampling location)? 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: The wastewater treatment facility appeared to be properly operated and well maintained. The facility staff incorporate an in-depth process control program with all measurements being documented and maintained on -site. The facility is equipped with a computer monitoring system (P.I.) to assist the wastewater staff in treatment operations. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? ■ ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual b.Mechanical ❑ Is the grit free of excessive organic matter? ■ ❑ ❑ ❑ Is the grit free of excessive odor? 0 ❑ ❑ ❑ # Is disposal of grit in compliance? ❑ ❑ ❑ Comment: Screenings and grit are disposed at a permitted landfill. Equalization Basins Yes No NA NE Is the basin aerated? M ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Page# 5 Permit: NC0004952 Owner -Facility: Celanese Shelby Facility Inspection Date: 12/14/2023 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? ❑ ❑ ■ ❑ Are all pumps operable? ❑ ❑ 0 ❑ Are float controls operable? ❑ ❑ 0 ❑ Are audible and visual alarms operable? ❑ ❑ 0 ❑ # Is basin size/volume adequate? ■ ❑ ❑ ❑ Comment: The facility is equipped with three equalization basins (operated in series via gravity flow) with in -line pH monitoring and adjustment. There is also an emergency EQ tank available for the isolation of spills, etc. Chemical Feed Yes No NA NE Is containment adequate? ■ ❑ ❑ ❑ Is storage adequate? 0 ❑ ❑ ❑ Are backup pumps available? 0 ❑ ❑ ❑ Is the site free of excessive leaking? ■ ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Surface Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ■ ❑ ❑ ❑ Comment: One of two aeration basins were in service due to low influent flows. 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? ■ ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Page# 6 Permit: NC0004952 Owner -Facility: Celanese Shelby Facility Inspection Date: 12/14/2023 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? ■ ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0 ❑ ❑ ❑ Comment: Both secondary clarifiers were operational and in service. Polymer is added to the aeration basin effluent to enhance settling in the clarifiers. The effluent from both secondaries is combined and flows through three polishing ponds (operated in series) prior to tertiary filtration. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ ❑ ■ Comment: Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Comment: All six tertiary filters were operational and in service. Flow Measurement - Effluent # 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? Yes No NA NE Down flow • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 7 Permit: NC0004952 Inspection Date: 12/14/2023 Owner -Facility: Celanese Shelby Facility Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Comment: The flow meter is calibrated quarterly and was last calibrated on 11/15/2023 by the Company's I&E Department. 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? ❑ ❑ 0 ❑ Comment: The facility was not discharging at the time of the ins[ and/or sheens were observed in the polishing ponds. Lagoons Type of lagoons? # Number of lagoons in operation at time of visit? Are lagoons operated in? # Is a re -circulation line present? Is lagoon free of excessive floating materials? # Are baffles between ponds or effluent baffles adjustable? Are dike slopes clear of woody vegetation? Are weeds controlled around the edge of the lagoon? Are dikes free of seepage? Are dikes free of erosion? Are dikes free of burrowing animals? 71=0511 7M.101 Me 151Mt Mil # Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations? Yes No NA NE 2 ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? ■ ❑ ❑ ❑ Is the lagoon free of short circuiting? M ❑ ❑ ❑ Comment: Both sludge lagoons were operational and in service. The land application permit has been previously rescinded and staff indicated that the sludge would be disposed at a permitted facility (landfill). The facility currently has sufficient sludge storage due to low influent flow/loading: however, staff have initiated sampling (TCLP, etc.) for a potential sludge removal/disposal event in the future. Page# 8