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HomeMy WebLinkAboutNC0089109_Compliance Evaluation Inspection_20190304 March 04, 2019 Robert D Williamson American Zinc Products LLC 484 Hicks Grove Rd Mooresboro, NC 28114 SUBJECT: Compliance Inspection Report American Zinc Products, LLC NPDES WW Permit No. NC0089109 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the American Zinc Products, LLC on 2/19/2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0089109. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report EC: WQS, ARO Server LF DocuSign Envelope ID: 64FBB199-1D00-48A9-82C5-7AEB0E11C86F EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 52 NC0089109 19/02/19 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) American Zinc Products, LLC 484 Hicks Grove Rd Mooresboro NC 28114 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:00AM 19/02/19 16/01/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 12:00PM 19/02/19 18/07/31 Name, Address of Responsible Official/Title/Phone and Fax Number Robert D Williamson,484 Hicks Grove Rd Mooresboro NC 28114//828-919-3134/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Self-Monitoring Program Sludge Handling Disposal Pollution Prevention Facility Site Review Effluent/Receiving Waters 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 Timothy H Heim ARO WQ//828-296-4665/ Mikal Willmer Division of Water Quality//828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 64FBB199-1D00-48A9-82C5-7AEB0E11C86F 3/4/2019 3/4/2019 3/4/2019 NPDES yr/mo/day 19/02/19 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer and Tim Heim, with the Asheville Regional Office, conducted a compliance evaluation inspection of the NPDES permit that services the industrial wastewater component of the AZP production process. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0089109. Aili Spearman (Environmental Manager), Rob Williamson (General Manager) and Tim Basilone (VP-Environmental Affairs) were present and assisted in the inspection. The facility is currently not in zinc production. Production is expected to resume in April of this year with a projection for full production to resume sometime in 2020. AZP has continued to sample as required by permit during extensive upgrades. Ms. Spearman reports wastewater being generated is due to the construction process and processing of stormwater. There were no violations of permit limits and sampling frequency during 2018. The overall process is being upgraded to increase water management capacity. Collection tanks have been added to better distribute contaminated water into the correct step of the production/wastewater process. Additional Upgrades: Manholes have been raised, floor drains are being capped, roofs are being installed over previously open areas, improved ability to handle stormwater throughout the facility and new truck washing stations to limit the potential spread of contaminants. No violations of permit conditions were noted at the time of the inspection. A follow-up visit will be conducted once production resumes later this year. NC0089109 17 (Cont.) Page#2 DocuSign Envelope ID: 64FBB199-1D00-48A9-82C5-7AEB0E11C86F Permit:NC0089109 Inspection Date:02/19/2019 Owner - Facility: Inspection Type: American Zinc Products, LLC Compliance Evaluation 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? AZP is currently undergoing significant upgrades to better manage stormwater, manage traffic flow and reduce transportation of particulates throughout the facility and off site. Comment: 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? 2013 permit requires toxicity testing. The new permit is currently in draft. The cadmium limit has changed within the draft permit and the limits for fluoride and lead were removed (cadmium compliance schedule included). Fish sampling and a priority pollutant scan are now listed in the draft permit. Division of Water Resources Fish Study SOP & QAP will be sent via email for reference. 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? No visual impacts to the receiving stream noted at the time of the inspection.Comment: Flow Measurement - Effluent Yes No NA NE # 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? Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Page#3 DocuSign Envelope ID: 64FBB199-1D00-48A9-82C5-7AEB0E11C86F Permit:NC0089109 Inspection Date:02/19/2019 Owner - Facility: Inspection Type: American Zinc Products, LLC Compliance Evaluation Effluent Sampling Yes No NA NE 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)? Facility is not currently in Zinc production. Samples being collected are from wastewater being produced during construction and collection of stormwater. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Staff are collecting upstream and downstream samples approximately 50' from the effluent discharge. Comment: Page#4 DocuSign Envelope ID: 64FBB199-1D00-48A9-82C5-7AEB0E11C86F Certificate Of Completion Envelope Id: 64FBB1991D0048A982C57AEB0E11C86F Status: Completed Subject: Please DocuSign: 20190304_NC0089109_CEI.ltr.docx, 20190304_NC0089109_CEI.draft.pdf Source Envelope: Document Pages: 5 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 2 Mikal Willmer AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Mar 4, 2019 | 10:55 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: Mar 4, 2019 | 10:57 Viewed: Mar 4, 2019 | 10:57 Signed: Mar 4, 2019 | 10:57 Electronic Record and Signature Disclosure: Not Offered via DocuSign Tim Heim tim.heim@ncdenr.gov DWR DEQ Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Mar 4, 2019 | 10:57 Viewed: Mar 4, 2019 | 11:17 Signed: Mar 4, 2019 | 11:17 Electronic Record and Signature Disclosure: Not Offered via DocuSign G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 149.168.204.10 Sent: Mar 4, 2019 | 11:17 Viewed: Mar 4, 2019 | 11:21 Signed: Mar 4, 2019 | 11:21 Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Mar 4, 2019 | 11:17 Certified Delivered Security Checked Mar 4, 2019 | 11:21 Signing Complete Security Checked Mar 4, 2019 | 11:21 Completed Security Checked Mar 4, 2019 | 11:21 Payment Events Status Timestamps