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Home My WebLink AboutNC0004952_Compliance Inspection_20180209water Resources ENV#RONNE:NTAL QUALITY February 9, 2018 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director RECEIVED/DENR/DWR Ms. PEM Carter, Sr. Environmental Engineer FEB R 3 2018 CNA Holding, LLC Water Resources 2525 Blacksburg Road Permitting Section Grover, NC 28073 Subject: Compliance Inspection Celanese — Shelby Plant NPDES Permit No. NC0004952 Cleveland County Dear Ms. Carter: Enclosed is a copy of the Compliance Sampling Inspection for the inspection conducted at the subject facility on February 7, 2018, by Ori Tuvia and Maria Schutte. Michael Sparks, Randy Turner's and your cooperation during the site visit was much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of the enclosed report. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at ori.tuvia@ncdenr.gov. Cc: NPDES Unit MRO Files Sincerely, On Tuvia, Environmental Engineer Mooresville Regional Office Division of Water Resources, DEQ Mooresville Regional Office Location 610 East Center Ave , Suite 301 Mooresville, NC 28115 Phone (704) 663-16991 Fax (704) 663-6040 \ Customer Service 1-877-623-6748 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 N 1 2 15 I 3 I NC0004952 111 12 16/02/07 117 18 ICI 19 I c I 20 I I 211 1 1 1 I I I I I I 11 I I I I I I I I I I I I I I I I I I I -I I I I I I_I i l l i �6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -- Reserved 67 10 70 JLJ 71 IN 72 L__] 73 74 75 1 1 80 Section B Facility Data Name and Location of Facility Inspected (For industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 10 OOAM 18/02/07 13/11/01 Celanese -Shelby Facility Exit Time/Date Permit Expiration Date NC Hwy 198 12 20PM 18/02/07 18/08/31 Shelby NC 28150 Name(s) of Onsite Representative(s)fTities(s)/Phone and Fax Number(s) Other Facility Data /// Michael D Sparks/ORCf704-480-5793/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Nicole Coffee,2525 Blacksburg Rd Grover NC 28073/f7O4-480-5728/ No Section C Areas Evaluated Dunng Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters 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 Maria Schutte Division of Water Quality//704-663-1699, On A Tuvia Al MRO WQ//704-663-1699/ -:� o j Signature of Management Q A ev ewer Agency/Office/Phone and Fax Numbers Date Andrew Pltner I'� `WRO WQ//704-663-1699 Ext 21 Lip EPA EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete Page# NPDES yr/mo/day Inspection Type 31 NC0004952 111 121 18/02/07 117 18 JCJ Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On -Site Representatives The following Company personnel were in attendance during the inspection Ms PEM Carter/Sr Environmental Engineer, Mr Michael Sparks/ORC, Mr Randy Turner Lab Supervisor, and Mr Michael Queen/Backup ORC Page# Permit NC0004962 Owner - Facility Celanese -Shelby Facility Inspection Date 02/07/2018 Inspection Type Compliance Evaluation Yes No NA NE Are records kept and maintained as required by the permit? M ❑ Permit Yes No NA NE (If the present permit expires In 6 months or less) Has the permittee submitted a new ❑ ❑ M ❑ application? 0 ❑ ❑ ❑ Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ 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 subject permit expires on 8/31/2018. The facilty permit limits are in pounds/day rather then mg/L Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? M ❑ ❑ ❑ Is all required Information readily available, complete and current? M ❑ ❑ ❑ Are all records maintained for 3 years (lab reg required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 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 CDCs Are DMRs complete do they include all permit parameters? M ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (if the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ 0 ❑ on each shift? Is the ORC visitation log available and current? M ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? 0 ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ M Comment The records reviewed during the Inspection were organized and well maintained DMRs. COCs Bench sheets, Calibration logs and ORC visitation logs, were reviewed for the period February 2017 through December 2017 Laboratory Yes No NA NE Page# 3 Permit NC0004952 Owner - Facility Celanese -Shelby Facility Inspection Date 02/07/2018 Inspection Type Compliance Evaluation Yes No NA NE Is composite sampling flow proportional? N ❑ 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 0 ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44 5 degrees Celsius+/- 0 2 degrees? 0 ❑ ❑ ❑ Incubator (BOD) set to 20 0 degrees Celsius +/- 1 0 degrees? ❑ ❑ 0 ❑ Comment On-site effluent analvses (fecal coliform, pH, temperature, TSS) are performed under the Company's laboratory certification #221 Prism Laboratories, Inc (BOD, oil & grease, total nitrogen, total phosphorus, pollutant scan) and ETT, Inc (toxicity) have also been contracted to provide analytical support The laboratory instrumentation used for field analyses appeared to be properly calibrated/verified and documented Effluent Sampling Yes No NA NE Is composite sampling flow proportional? N ❑ ❑ ❑ Is sample collected below all treatment units? N ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? E ❑ ❑ ❑ # 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 N ❑ ❑ ❑ representative)? Comment The subiect permit requires both composite and grab effluent samples Since the past Inspection the ORC and staff have begun to perform/document periodic aliquot verifications on the composite sampler at the time of the Inspection the effluent sampler pulled 155 ml aliquot Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? E ❑ ❑ ❑ Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are appllcaLle? Comment The wastewater facility appeared to be properly operated and well maintained The facilit ry staff incorporate a comprehensive process control program with all measurements being Properly documented and maintained on-site Bar Screens Type of bar screen a Manual Yes No NA NE Page# 4 Permit NC0004952 Owner -Facility Celanese -Shelby Facility Type of grit removal N a Manual Inspection Date 02/07/2018 Inspection Type Compliance Evaluation ❑ Is the grit free of excessive organic matter? N ❑ ❑ ❑ Bar Screens Yes No NA NE b Mechanical ❑ ❑ ❑ ❑ Are the bars adequately screening debns? ❑ ❑ ❑ ❑ Is the screen free of excessive debris? E ❑ ❑ ❑ Is disposal of screening In compliance? E ❑ ❑ ❑ Is the unit In good condition? 0 ❑ ❑ ❑ Comment Grit Removal Yes No NA NE Type of grit removal N a Manual ❑ b Mechanical ❑ Is the grit free of excessive organic matter? N ❑ ❑ ❑ Is the grit free of excessive odor? 0 ❑ ❑ ❑ # Is disposal of grit In compliance? E ❑ ❑ ❑ Comment Equalization Basins Yes No NA NE Is the basin aerated? N ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? E ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? ❑ ❑ 0 ❑ Are all pumps operable? ❑ ❑ E ❑ Are float controls operable? ❑ ❑ E ❑ Are audible and visual alarms operable? ❑ ❑ N ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment The process wastewater flows through three equalization basins (in series) prior to combining with the domestic wastewater Sodium hydroxide (pH adjustment) is added to the first EQ Basin and phosphoric acid (nutrient supplement) is added on an as -needed basis at the third EQ Basin A fourth equalization tank is also available for emergency situations Chemical Feed Is containment adequate? Is storage adequate? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 5 Permit NC0004952 Owner - Facility Celanese -Shelby Facility Inspection Date 02/07/2018 Inspection Type Compliance Evaluation Chemical Feed Yes No NA NE Are backup pumps available? ❑ ❑ ❑ Is the site free of excessive leaking? ❑ ❑ ❑ Comment Aeration Basins Yes No NA NE Mode of operation Ext Air ❑ ❑ Type of aeration system Surface E ❑ Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? 0 ❑ ❑ ❑ Are the diffusers operational? ❑ ❑ 0 ❑ Is the foam the proper color for the treatment process? N ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? N ❑ ❑ ❑ Is the DO level acceptable? E ❑ ❑ ❑ Is the DO level acceptable?(1 0 to 3 0 mg/1) ❑ ❑ 0 ❑ Comment Both aeration basin trains were operational and In service at the time of the inspection One Is the overflow clear of excessive solids/pin floc? 0 of the surface aerators was out for maintenance at the time of the inspection ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site fres of excessive buildup of solids in center well of circular clarifier? E ❑ ❑ ❑ Are weirs level? N ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? N ❑ ❑ ❑ Is the site free of excessive floating sludge? N ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? N ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) 0 ❑ ❑ ❑ Comment Both secondary clarifiers were operational and in service Pumps -RAS -WAS Yes No NA NE Are pumps in place? N ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Page# 6 I Permit NC0004952 Owner -Facility Celanese -Shelby Facility Inspection Date 02/07/2018 Inspection Type Compliance Evaluation Pumps -RAS -WAS Yes No NA NE Are there adequate spare parts and supplies on site? ❑ ❑ ❑ 0 Comment. Lagoons Yes No NA NE Type of lagoons? Aerated # Number of lagoons In operation at time of visit? 3 ❑ ❑ Is the filter surface free of clogging? z Are lagoons operated In? Series ❑ Is the filter free of growth? # Is a re -circulation line present? ❑ ❑ 0 ❑ Is lagoon free of excessive floating materials? M ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ 0 ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? 0 ❑ ❑ ❑ Are dikes free of erosion? 0 ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ 0 ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ M ❑ Is the lagoon surface free of weeds? 0 ❑ ❑ ❑ Is the lagoon free of short circuiting? M ❑ ❑ ❑ Comment The facility Is equipped with three polishing ponds (operated in series) and two sludge holding ponds Filtration (High Rate Tertiary) Yes No NA NE Type of operation Down flow Is the filter media present? 0 ❑ ❑ ❑ Is the filter surface free of clogging? z M ❑ ❑ ❑ Is the filter free of growth? ❑ ❑ ❑ M Is the air scour operational? ❑ ❑ 0 ❑ Is the scouring acceptable? ❑ ❑ ❑ Is the clear well free of excessive solids and filter media? ❑ ❑ 0 ❑ Comment All six tertiary filters were operational and in-service. Page# 7 Permit NC0004952 Owner -Facility Inspection Date 0 210 71201 8 Inspection Type Celanese -Shelby Facility Compliance Evaluation observed at the manhole where the effluent leave the facility, the effluent appeared Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? M ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: The flow meter is calibrated/verified on a quarterly basis and was last calibrated/verified on 1/9/2018 by the Company's I & E personnel observed at the manhole where the effluent leave the facility, the effluent appeared Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ ❑ 0 Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ 0 If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment. Effluent pipe discharge was not examined during the Inspection however, effluent was observed at the manhole where the effluent leave the facility, the effluent appeared clear with no floatable solids or foam Aerobic Digester Yes No NA NE Is the capacity adequate? M ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming In the tank? M ❑ ❑ ❑ # Is the odor acceptable? M ❑ ❑ ❑ # Is tankage available for properly waste sludge? N ❑ ❑ ❑ Comment: The facility is authorized to land apply digested sludge under the authority of Permit W00011038 Page# 8