NC0003875_NOV-2019-MV-0009 Response_20190207

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CERTIFIED MAIL: 917108 2133 3939 7137 0535
RETURN RECEIPT REQUESTED
February 7,2019
NCDENR Division of Water Quality OW
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Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
127 Cardinal Drive
Extension
Wilmington,N. C. 28405-3845
\Afater Qua6j,ty Reglc�n
f Violation and Intent to Assess Civil Penalty
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RE: Notice o
Tracking Number: NOV-2019-MV-0009
Permit No.NC0003875
Castle Hayne Plant,New Hanover County
Dear Mr.Hunkele:
Elementis is in receipt of the Notice of Violation and Intent to Assess Civil Penalty.(Tracking Number: NOV-
2018-MV-0009). Elementis reviewed the operating conditions. of the quarry water return system (Outfall
003) for the month of December and reviewed all available monitoring data after the system was restarted on
December 24, 2018. There were no abnormalities noted in quarry water return system for the month of
December that could have potentially impacted BOD, -chloride, pH, TSS or temperature. Turbidity is
continuously monitored while the quarry water return system is operating and the highest turbidity recorded
during the period between December 24, 2018 and:January 1, 2018 was 8 N.T.U.s. Additionally, samples
were collected on December 31, 2018 and analyzed for BOD, chloride, pH, TSS or temperature. The BOD
and TSS values were less than detection limits and pH was reported to be 6.95. The samples collected on
December 31 2018 are representative of what.was discharged during the week ending;December 29 2018.
Therefore,based on the fact that-there were no abnormalities noted that could impact sampled parameters an
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the samples collected immediately after the missed sample event are in a normal range, Elementis does not
believe that the missed sample.resulted in potential harm to the environment.
Elementis also conducted an internal investigation to understand the root cause of the missed sample event.
The quarry water return system was offline during the majority of December and started up on December 24,
2018.. The sampling technician thought that the:sample needed to be collected within 7 days of restarting the
system rather than during the calendar week. The sampler has been trained on the sample requency
requirements. If you have any questions concerning these reports, please do not hesitate to call me at (910)
675-7229.
Sincerel
Calvin Overcash
Regulatory Manager
Elementis Chromium
ELEMENTIS CHROMIUM.
5408 Holly Shelter Road
Castle Hayne,NC 28429
Telephone:[phone]
Facsimile;910/675-7201