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Home My WebLink AboutNCG500210_Inspection_20180606'P" sk Am 7 Environmental Quality June 6, 2018 Mr. Joe Parkulo, Regional HSE Manager Lubrizol Advanced Materials, Inc. 207 Telegraph Drive Gastonia, NC 28056 ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Subject: Compliance Evaluation Inspection 207 Telegraph Drive NPDES Permit No. NCG500210 Gaston County Dear Mr. Parkulo: Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at the subject facility on June 5, 2018, by Ori Tuvia. Your cooperation during the site visit was much appreciated. As discussed on site, the facility should maintain internal sampling records for pH and Temperature. The records should include the dates, times and name of individual performing the sampling as well as the calibration time (for pH). Additionally, the Total Residual Chlorine (TRC) testing detection level of 29 ug/L was noted on the chlorine testing lab results. The NPDES permit limitation for TRC of 17 ug/L will require the use of instrumentation appropriate to measure down to the 17 ug/L. If you have any questions, please contact Ori Tuvia at (704) 235-2190, or via email at ori.tuviagncdenr. _ og_v. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger Regional Supervisor Mooresville Regional Office Division of Water Resources Cc: NPDES, MRO Files (Laserfiche) Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-60401 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org 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 15 I 3 I NCG500210 111 12 I 18/06/05 I17 18 I S i 19 LG] i 201 I 211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166 Inspection Work Days Facility Self-Monitoring Evaluation Rating 131 QA ----------------------Reserved------------------- 67 1.0 70Iq I 71 72n, 73I i74 751 1 1 1 1 80 u Int 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 oermit Number) 09:30AM 18/06/05 15/11/04 Lubrizol Advanced Materials 207 Telegraph Dr Exit Time/Date Permit Expiration Date Gastonia NC 280561306 10:30AM 18/06/05 20/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Joe Parkulo,207 Telegraph Dr Gastonia NC 280561306/Manager/704-865-7451/7048654919 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program 0 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 DocuSigned by: Ori A Tuvia C�=r_— MRO WQ//704-663-1699/ 6/6/2018 EBB057A2DE017498... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger MRO WQ//704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 6/6/2018 / Page# A14CC681 AF27425... NPDES yr/mo/day Inspection Type NCG500210 111 121 18/06/05 1 17 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCG500210 Owner - Facility: Lubrizol Advanced Materials Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation Yes No NA NE Are records kept and maintained as required by the permit? 0 Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Are all records maintained for 3 years (lab. reg. required 5 years)? 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 7/31/2020. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ 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 ❑ (pH and Temperature) should be recorded with the Dates, times Name of individual Name of individual performing the sampling performing the sampling as well as the calibration time (for PH). Results of analysis and calibration Dates of analysis Name of person performing analyses Transported CM 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? ❑ ❑ 0 ❑ 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? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: The permittee's records were very organized and well maintained. Internal sampling records (pH and Temperature) should be recorded with the Dates, times Name of individual performing the sampling as well as the calibration time (for PH). Effluent Sampling Yes No NA NE Page# 3 Permit: NCG500210 Owner - Facility: Lubrizol Advanced Materials Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ❑ ❑ 0 ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: The permit requires -grab samples for all samples. 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: Prism Laboratories. Inc. (certification #402) has been contracted to Drovide analvtical support. The permittee also uses an on-site laboratory to perform temperature and pH analyses. Total Residual Chlorine (TRC) testing detection level of 29 ug/L was noted on the chlorine testing lab results. The NPDES permit limitation for TRC of 17 uq/L will require the use of instrumentation appropriate to measure down to the 17 uq/L. 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: Non -contact coolina water. boiler blowdown. and stormwater are directed to two on-site concrete basins (operated in series) before discharge to surface waters. Process control measurements are taken before the wastewater is discharged to the unnamed tributary to South Crowders Creek via a pumping system. The approved biocide (Biosperse 261T) is used in the cooling tower systems. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Page# 4 Permit: NCG500210 Owner - Facility: Lubrizol Advanced Materials Inspection Date: 06/05/2018 Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Flow is estimated. 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? ❑ ❑ 0 ❑ Are audible and visual alarms operable? ❑ ❑ 0 ❑ # Is basin size/volume adequate? ❑ ❑ 0 ❑ Comment: Non -contact coolina water. boiler blowdown. and stormwater are directed to two on-site concrete basins (operated in series) before discharge to surface waters. chemicals are added as needed in order to get the pH 6-9 prior to discharge. 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: The permittee was not discharging at the time of the inspection. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: The permittee met the temperature requirements noted in NCG500000 (<2.8 degrees C above the natural water temperature of the receiving stream) Page# 5