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Home My WebLink AboutNC0084638_Compliance Evaluation Inspection_20181010NORTH CAROLINA ROY COOPED Erxlrlronmantaf�e�aNty coves MICHAEL S. RECAN October 10, 2018 Ser 1-Y LINDA CULPE<PPLP, hrrerfrA &[rector Mr. Michael Shatynski Solvay, USA, Inc. 8 Cedar Brook Drive Cranberry, New Jersey 08512 Subject: Compliance Evaluation Inspection Rhodia Groundwater Remediation System NPDES Permit No. NCO084638 Gaston County Dear Mr. Shatynski: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on September 25, 2018, by Edward Watson. The MRO would like to thank Mr. Teg Williams and Mr. Scott Smida for their assistance during the site visit. The system is compliant with the permit. However, the items listed below are worth particular attention to maintain compliance: Please keep the DWR informed regarding the proposed rebound study and planned shut -down of the facility. If a permit rescission request results from the rebound study, please submit a copy of the annual report to the DWR, so it can be used as support documentation. Please place a well tag on MW-34A. A copy of the inspection report is attached, which should be self-explanatory. However, should you have any questions regarding this report, please do not hesitate to contact Edward Watson at (704) 235-2198 or by email at edward.watsonkncdenr.gov. Attachment: Inspection Report Sincerely, DOCUSigned by: A H ALU" F161 FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources EQ.:> � r North Carolina Department of Environmental Quality I Division of Water Resources I Water Quality Regional Operations Section Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 704.663.1699 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 I 2 IF I 3 I NCO084638 111 12 I 18/09/25 I17 18 I S J 19 L G] 201 I 211111 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 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 1.0 70 I z I 71 I p JI 72 I I 73 I I I74 751 I I I I I I I80 I —I I I i Section B: FacilityDataI� 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) 10:30AM 18/09/25 16/05/01 Rhodia remediation site 207 Telegraph Dr Exit Time/Date Permit Expiration Date Gastonia NC 280561306 11:40AM 18/09/25 20/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Scott Alan Smida/ORC/704-543-3286/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Michael Shatynski,504 Carnegie Ctr Princeton NJ 08540//732-516-1104/6098602203 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Facility Site Review Compliance Schedules 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 Edward Watson MRO GW/// Signature of Management Q A Revie Docusigned by: Agency/Office/Phone and Fax Numbers Date EA*-.aw H P,z,<'`z 10/10/2018 1`161 FB69AMUAI.. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO084638 I11 121 18/09/25 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On September 25th, 2018, Edward Watson of the MRO/DWR performed a Compliance Evaluation Inspection of the Rhodia Remediation site under permit NC0084638. During the site visit there was additional discusion regarding the time -line and schedule for a proposed rebound study and step-down site closure. Should it be determined that a permit rescission is warranted, a written request for the rescission will need to be submitted to the NPDES permitting group in Raleigh by the permittee. It was identified that the consultant generates an Annual Report as part of their responsibilty to DWM-IHSB. Please submit a copy of the Annual Report to the DWR so it may be used as support documentation should the rebound study prove that a permit rescission is applicable. The consultant indicated that self monitoring of the influent water is reportiong all constituents are below 2L standards. A review of some of the onsite MWs discovered that MW34A is missing a well tag. This will need to be corrected. Page# Permit: NCO084638 Owner - Facility: Rhodia remediation site Inspection Date: 09/25/2018 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 ❑ ❑ 0 ❑ application? 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 rebound studv was mentioned durina the site visit. MRO-DWR reauested that the consultant speak to DWM IHSB staff to keep MRO-DWR in the conversation during the step down period and the possible permit rescission. The consultant also agreed to email a copy of the Annual Report, so DWR would have analytical data to reference if a request for rescission was made. Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? 0 ❑ ❑ ❑ Is the facility compliant with the permit and conditions for the review period? 0 ❑ ❑ ❑ Comment: Chronic toxicitv and NDMR data was reviewed for 2018 durina the site visit. WET toxicit has consisitently had passing results. 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 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: O&M records were in order and up to date. The air stripper is cleaned on an annual basis. I was also able to review self monitoring influent data. The influent analysis indicate the system is effectively removing the chlorinated solvents to a point of analytical results reporting as non -detect. Page# 3