NCS000329_COMPLIANCE_20190603

NUH # H UAHULINA
Department of Environmental Qual
II

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
JUC-�7-
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING REPORTS
❑ APPLICATION
�, COMPLIANCE
❑ OTHER
DOC DATE
❑ Zatiq 5C#63
YYYYMMDD

a��sA rFs.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OZ REGION 4
lu
ATLANTA FEDERAL CENTER
S 61 FORSYTH STREET
4L PROSATLANTA, GEORGIA 30303-8960
MAY 2 8 2019
CERTIFIED MAIL 7017 1450 0000 7973 2823
RETURNED RECEIPT REQUESTED
Mr. Ryan Scott
Environmental Manager
���`�'�
ATI Allvac — Bakers Plant JUN 03 2019
P.O. Box 5030
Monroe, North Carolina 28111-5030 DENR-LAND QUALITY
STORMWATER PrRtO) TING
Re: Compliance Evaluation Inspections
ATI Allvac — Bakers Plant, Monroe, North Carolina
NPDES Permit No. NCS000329 -
Dear Mr. Scott:
On March 20, 2019, the U.S. Environmental Protection Agency Region 4 and North Carolina
Department of Environmental Quality (NCDEQ) conducted a Compliance Evaluation Inspection (CEI)
at the ATI Allvac — Bakers Plant• located at 6400 and 3570 Alloy Way in Monroe, NC. The purpose of
the CEI was to evaluate ATI Allvac — Fakers Plant's compliance with the requirements of Sections 301
and 402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p); the regulations promulgated
thereunder at 40 C.P.R. § 122.26; and, the State of North Carolina's NPDES Stormwater Permit
NCS000329.
The EPA,and NCDEQ appreciate your cooperation in conducting this CEI. Enclosed is the EPA's CEI
report, which includes EPA's observations. Please review the report and contact Ms. Lauren Garcia at
the NCDEQ office within 14 days of receiving this letter by calling [phone] or by sending an
email to lauren.garciaPncdenr..
There is no need to respond directly to the'EPA at this time; however, please note that the EPA will
continue to closely coordinate with NCDEQ to ensure compliance at this facility. If you do happen to
have questions for the EPA, you can contact Mr. Ahmad Dromgoole at the above address, by email at
[e-mail], or at [phone].
Enclosures
cc: Ms. Annette Lucas
NCDEQ
Sincerely,
Daniel J. O'Lone, Chief
Surface Water and Ground Water Section
Water Enforcement Branch
Intemet Address (URL) . http://www.apa.gov
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4

LFACILITY LOCATION I Ntt e
GPS Latitude 3501'6.26"N Longitude
80036'39.81"W
Coordinates
-
R calving �
aters} or Bearskin Creel:
Siteage,
°•
82 acres
10�andition
Cloudy skies
Acre'
.
" "``'-"�'Does
is #,
!Date off
. SIC
3356.
discharge toW `
tlfe site
1�p�p
discharge pollutants
Perm tF� 09/03/2014
303(d} listed or
No
contribuEing to the NIA
"
� Coae(s).
3341
Application
, q
PM]"" waters l
receivirigstream
E.°
im airment.
'INFORMATION,
$PPP -TOPICS (Part In
Y+ES 1�C) 1\!E
SPPP on -site (obtain a copy of the plan) Section A
X
A copy of the SPPP was provided during the inspection. The SPPP is kept electronically and did not
have dated signatures for updates. According to facility personnel, the last save date of the document
provided was 02//24/18.
Site Description Section A(1)(b)
X
A site description was provided in the SPPP.
Identify potential Pollutant Sources and Particular Pollutants Section A(1)(b)
X
The site description in the plan included information about most of the potential pollutant sources and
control measures in place at each of the outfalls. The plan did not identify the locations of the various
dust! articulate control 2rocesses, s ecificall , the locations of the various ba houses.
Site Maps (general location map and site specific map) Sections A(1)(a & e)
X
A site map specific to the SPPP was not provided during the inspection. Instead, the facility provided
the site map from the facility's SPCC plan. These maps, though they did include some information
on outfalls and flow patterns, did not include information on the various pollutant sources (i.e. dust
generation sources, outdoor storage, and outdoor processes).
Spill History (3 year history or spills and corrective actions) Section A(1)(d)
X
A statement was provided in the SPPP stating that there had been no reportable spills in the past
three years. The statement did not include a date (identifying what was the three year window) nor
was there a date on the SPPP (which could be used as in indication of when the portions of the
SPPP was evaluated).
SPPP Certification Section A(1)(e)
X
(Annual recertification of no evidence of non-stormwater discharging)
The SPPP did not include annual certifications or information pertaining to annual plan updates.
Stormwater Management Strategy (Feasibility Study) Section A(2)(a)
X
(Analysis•of control options like eliminating exposure or controlling runoff)
The SPPP provides a description of when and how feasibility studies would be performed at the site.
Neither the plan nor facility personnel were able to confirm the existence and resulting actions of any
feasibility studies.
Stormwater Management Strategy (Secondary Containment) Section A(2)(b)
X
The SPPP'included a section discussing the secondary containment requirements. The section siates
that there- is a table of secondary containment structures, but it was not included in the copy of the
;
SPPP provided. A copy of the SPCC plan was provided which did include a table of the above ground
tanks and their secondin containment volume.
Page 2 of 6

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wr _ —r.�.vwat�*'�."�::w,-.m.-6�.:+^�+=*tlPaA�•�:i :"c'N7"i'"��'�`"..x'�"r�`,€ •rv^c�7d.�'"!?�'_'�'�,pr�.�°�"g"szc•'�
^SPPP TOPICS (Part`In
^"�#`� x � `v^'?'l.".'_L°r'-
YES NO IN/E'
Stormwater BMP Summary Section A(2)(c)
X
Section 8 of the SPPP provided a description of the various BMPs implemented at the site. This
included both structural and non-structural BMPs.
Spill Prevention & Response Procedures (SPRP) Section A(3)
X
The provided SPPP included a section referring to the SPCC for spill procedures. This section
included information on the various responsible officials and their contact information.
Preventative Maintenance and Good Housekeeping Program Section A(4)
X
Sections 8 and 9 of the SPPP provided descriptions of the routine preventative maintenance and
housekeeping measures to be implemented at the site. Additionally, these measures were included in
the inspection checklist used at the facility. Although the descriptions of measures were included, the
SPPP did not establish schedules for the various' measures.
Employee Training Section A(5)
X
Per the SPPP, monthly general. awareness training is provided in which spill prevention and
environmental housekeeping topics are discussed.
Identify the Responsible Party Section (A)(6)
X
According to the SPPP, the EHS Manger is responsible for the overall coordination, development,
and implementation of SPPP plan.
SPPP Modified. or Update to Current Conditions Section (A)(7)
X
The SPPP provided during the inspection included neither a signature nor dates in the annual updates
section. Additionally, benchmark data has shown consistent exceedances for a number of years for
copper, zinc, and chlorine. The SPPP provided during the inspection included no mention of
y
additional measures to be implemented by the facility to address these benchmark exceedances.
Schedule and Procedures for Routine Inspections Section A(8)
X
According to the SPPP, routine inspections are to be performed monthly. This was consistent with
the provided inspection documents which show monthly inspections.
ATI Allvac operates multiple metal alloy facilities in Monroe, NC. Its Bakers North and Bakers South facilities operated'
under the same NPDES permits. Operations at Bakers North and South complex began in the 1960s. In 2017, ATI began
operations at a third facility, the Bakers Powder facility. A separate permit application has been submitted for this facility.
At the Bakers North and South facilities, a variety of titanium alloys are formed and nickel ingots from the Monroe facility
are reformed and finished. The raw materials for these plants include titanium revert and nickel ingots. The products from
the processes include metal ingots used as a raw material for other forming processes.
The Bakers North and South facilities both operate under the one NPDES permit: NCS000329. This permit provides
coverage for both industrial stormwater and wastewater from non -contact cooling water. The facility operated three external
outfalls discharging to the stream (SW Outfall #1, Outfall #2, and Outfall 43). Of those outfalls, only Outfall 41 was
commingled with process wastewater from the cooling processes. In addition to the external outfalls, there are a number of
internal outfalls throughout the site that discharge to the primary pond associated with SW Outfall # 1. Many of these internal
outfalls are associated with various water quality and retention ponds.
Page 3 of 6

1
X- 4.11ECORDREVIEW
-iV tF. PM A-3
-R&6Vd-R C1 qeW
YES
-
jt06rds'of Maintenance and Housekeeping' Programs Part H, Section A(4)'
Samples of the maintenance and housekeeping records were requested for 2017-2019. These records,
x
which are kept electronically, were provided and appeared to show the facility performing periodic
maintenance of its stormwater BMPs.
Records of Routine Inspections Part 11, Section A(0)
A sample of the monthly inspection records were provided by the company. These records were
x
reviewed, identified the various areas inspected, and included descriptions of the concerned found.
Records of Employee Training Part II, Section A(9)
Records of employee training were provided for 2018.
x
Records for the Approval of Representative Outfalls Part III Section D(5)
The facility had not requested the use of representative outfalls.
x
Records of Benchmark Monitoring Part 11, Section B & D, Part III Sections D, & E(1)
Records of benchmark monitoring were reviewed back through 2017. The review of these records
appeared to show the required preservatives and holding times being met for the samples. Sampling
records were reviewed for the three outfalls. From this review, consistent copper exceedAnces were
x
observed at all three outfalls. Additionally, consistent total chlorine exceedances were reported for
Outfall 1 the commingled outfall).
'Records of Qualitative Monitoring Part 11 Section C, Part III Section D
Qualitative monitoring was performed with periodic benchmark monitoring. Qualitative monitoring
records were reviewed back through 2017. A review of these records appeared show the required
x
observations being made.
Records of Tiered Approach to Benchmark Exceedances Part III Sections B
From the review of benchmark data since 2017, it was determined that the facility has had consistent
benchmark exceedances for copper at all of the outfalls and chlorine at Outfall 1. Additionally, Outfall
2 had two back to back occurances of benchmark exceedances for zinc. The most recent Tiered
x
response (a Tier I response), was provided by the facility and dated 07/30/18, The copper and chlorine
exceedances have continued since this last Tiered evaluation but there have been no additional
measures implemented nor was monthly monitoring being performed.
Records of Bypasses Part III Sections E(7)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
x
requirement.
Records of 24 hr Reporting Part HI Sections E(8 &9)
According to facility personnel, there have been no instances during 2017 and 2018 meeting this
X
reSuirement.
nature and." leittetitY 8W.01hi ts off-sito-
The Bakers South facility receives, metal ingots from the Monroe facility which it further.
processes. Outside storage of these unfinished ingots was observed at the site and seen in
V photos DSCN 1913 and DSCN 1917-DSCN 1918. to addition to some of the raw ingots, there
Material Storage Areks..' was also the storage of cut and finished ingots awaiting shipping. These can be seen in photos
DSCN 1920 and DSCN1922. At the Bakers North facility, an overflow material storage area
was observed' along its west side (seen in photos DSCN 1927-fDSCN 1928). This area was
observed as miscellaneous storage for waste and product samples.
ATI operated several baghouses at the Bakers facilities for air pollution control. These units
were typically located outdoors with silt sacks or barrel in place for the collecting of
liorip -, in - g, 11 and4ir pollifti , on
- - 'r particulate materials. One of these baghouse areas can be see in photo DSCN 1914.
control ,eluipmeat 'areas):-.
Page 4 of 6

5. SITE o e
Sources'' Note location, quantitativejdescription, design issue, O&Msdef;cienciesv(includirigitlie'
•Pollutant
_. _
i C,11 and extent), 'andpollutants,off'stfe =' s
-
Storm drains throughout the site are used to collect stormwater and direct it to the primary
'
cooling water pond (often by way of dretention or water quality pond). At the Bakers North
drains: ` ;;
facility, Storm drain inlets were observed along the south side of one of the process buildings.
'Storm•
Some of these inlets, seen in photos DSCN 1933-DSCN 1934, were observed unprotected and
with exposure to furnace dust and other particulates.
„ . t
Some potential housekeeping concerns were observed throughout the site. In the waste bin
''Housekeeping
staging area near the southwest corner of the Bakers South facility, the waste bins used for
�-
the storage of SWARF material were observed with seepage discharging to the storm drain
system (seen in photos DSCN 1924-DSCN 1925).
Outdoor storage of fluid material was observed in various area throughout to the site. Per the"
,Fluid' Storage/Secondary
facility's SPPP, any bulk storage of liquid materials of 55-gals or greater require secondary
4Cc ontainment _ 11
containment. Photograph DSCN 1926 shows a hazardous waste storage area at the Bakers
South facility. Although the drums were observed on pallets off the ground, no secondary
containment was observed in this area.
The stormwater runoff throughout the site can be directed to either one of the three outfalls;
to the stream or to one of the internal water quality ponds at the site. At the Bakers North
facility, stormwater runoff can be directed either directly to a stormwater only outfall (Outfalls
'Best,Management
#2 and #3) or to the commingled outfall (Outfal l # 1) by way of the primary cooling water
Fractices{BMPs)"
pond. At the Bakers South facility, there are internal ponds used to collect stormwater runoff
-
for reuse at the facility or to direct water to the primary cooling water pond. These internal
ponds include Water Quality Pond 2 (photo DSCN1912), Water Quality Pond 1 (photo
DSCN1915), Detention Pond I (photo DSCN1916), and Detention Pond 2 (photo
DSCN 1921).
Various waste storage areas were observed throughout the site. In the areas near the process
buildings, roll off bins (seen in photos DSCN 1923' DSCN 1925) and process waste including
spend furnace rods (seen in photo DSCN 1919) were observed. Additionally, a haz waste
,DisposaVWasteHandling',.
storage area was observed near the southwest corner of the Bakers South facility (seen in
Areas,
photo DSCN 1926). In this area, waste was stored in a sealed bin and in 55 gal drums. Some
of the drums in this area were located on pallets off the ground and underneath shed cover.
z
Other drums, some containing metal shavings, though also raised off of the ground were not
staged underneath the covered area.
Whiele-and Equipment
Between the two processes buildings at the Bakers North facility, there was an equipment
Maintenance -Areas
storage and maintenance area (seen in photos DSCN1931-DSCN1932).
OBSERVATIONS
Outfall;,Storinwater
Discharge& -Receiving YES NO:
-.
Water.
Describe: According to the facility's SPPP, there were three NPDES outfalls
Number; & l6cation`of �
discharging to the stream. Two of these outfalls (Outfall 93 seen in photos
stormwater
DSCN 1929-DSCN 1930 and
discharge(s)/6' td l(s) .
X
Outfall #2 seen in photos DSCN 1935) are stormwater only outfalls and discharge
;consistent=..with the..; ` .s
directly to the tributary. The third outfall, Outfall 41 seen in photo DSCN 1936, is
SPPP 9: `'.
a commingled stormwater and process cooling water outfall. This outfall
f.
discharges from the primary cooling water pond to Dry Folk.
Page 5 of 6

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Describe: Altliough the tributary was not observed during the inspection,
.accami%tatiogof , i'.
Eoliutan observed.
X
observation was made of the various outfall which dial not show evidence of
�
discharged pollutants.
receiiviu water'°'"'�
+Otlaeirpoteiiitial�'" _ - -
tiisc-arges;off=site _
Describe: No exterier outfalls aside from those identified in the SPPP were
thrc►u h Duffs
X
observed during the inspection.
-incleided.in,tlte SPPP -,�
Nonce"stormwater,
Describe: During the inspection, the inspection team did not observe any
=discharge -observed ;':, i,i
X
unauthorized non-stormwater discharges.
•__� __ Fit_._ _ ...-- -- _.
Additional inspection summary, narrative, findings, comments, photos, and schematic diagrain of the facility area
as necessary:
At the end of the site visit, an exit conference was held with Facility personnel were the following observations provided:
• SPPP Observations
o No date was not provided on the SPPP documenting the most recent revision
o All of the stormwater pollutant sources were not provided in the plan. Specifically, the site plan did not
identify all of the material storage areas, baghouse areas, or the S WARF waste bins.
o The site plan did not include of the stormwater management features like the storm drain inlets
• Records Observations
o Due to time restraints and the availability of records during the inspection, an initial assessment of the
facility records was not proved during the closing. This analysis would be performed upon recent of the
requested documents.
• 'Site Observations
o Some housekeeping concerns were observed at the site including sediment trails from baghouse areas, roll
off dumpsters, and storm drain inlets with significant pollutant exposure.
Page 6 of 6

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DSCN1912.JPG `
Attributes
File Name DSCN1912JPG
Description Photograph of Water Quality Pond 2. The outfall for this pond is an Internal outfall leading to the
facility's primary pond and outfall.
Latitude
Longitude
N 350 01' 09.10"
W 80° 36' 50.77"

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DSCN1914.JPG
Attributes
File Name I DSCN1914JPG
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Description Photograph of one of the baghouses at the Bakers South facility. Some sediment trailing was
observed from this area leading to one of the storm drain inlets
Latitude N 350 01' 06.70"
Longitude _ W 80° 36' 44.15"

DSCN1915.JPG
File Name
Attributes
DSCN1915JPG
Description
Photograph of Water Quality Pond 1.
Latitude
N 350 01' 07.43"
Longitude
W 80' 36' 43.39"

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DSCN1917.JPG
File Name
Description
Latitude
longitude
Attributes
DSCN1917.JPG
Photograph of the outdoor storage area at the Bakers South facility which discharges to Detention
_Pond 1.
N 35° 01` 05.54"
W 80' 36' 39.32"

Attributes
File Name DSCN1918.IPG I
Description Photograph of the outdoor storage area at the Bakers South facility which discharges to Detention
Pond 1
Latitude N 350 OV 05.58"
Longitude I W 80° 36' 39.57"

DSCNI919.)PG
File Name
Description
Latitude
Loneitude
DSCN1919JPG
Photograph of an outdoor
N 35° 01' 0Z.75"
W 800 36' 47.06"
Attributes
area at the Bakers South facilitv for saend furnace rods.

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_ Attributes
File Name DSCN1920.JPG
Description Photograph of an outdoor product storage area at the Bakers South facility.
Latitude N 35° 01' 02.93"
Longitude 1 W 80' 36' 47.11"

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DSCN1922JPG

JSi. N1923.JPG
Attributes
File Name DSCN1923.JPG
&ascription Photograph of the roll of dumpsters for swarf at the Bakers South facility.
'Latitude N 350 dl' Q3.52"
LonF-itude W 80° 36' 53.33"

D5CN1924.)PG
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Attributes
File Name D5CN1924.JPG
Description Photograph of the area around the two swarf roll off dumpsters. Although the dumpsters were
covered, they were not water tight and were observed with leakage. The leakage from the
dumpster, which was observed with metal shavings and sediment, appear to drain towards
nearby storm drain inlet. _
Latitude N 359 01' 04.75" _
Longitude W 800 36' 52.87"

DSCN192S.JPG
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Attributes
File Name DSCN1925.JPG
Description Photograph of the area around the two swarf roll off dumpsters. Although the dumpsters were
` covered, they were not water tight and were observed with leakage. The leakage from the
E dumpster, which was observed with metal shavings and sediment, appear to drain towards
nearby storm drain inlet.
Latitude N 35° 01' 04.69" --
W 800 36' 52.86"

Attributes
File Name DSCN1926JPG
Description Photograph of a waste storage area at the Bakers South facility. The waste drums (blue drums)
were located under shed cover with all but one observed with covers on. The gray drums, which
were for metal shavings and other facility waste, were not located under the shed cover. Some of
these drums were observed with an unknown fluid in them.
Latitude N 35° 01' 04.80"
Longitude W 80' 36' 53.33"

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DSCN1928.JPG
Attributes
File Name
DSCN1928JPG
Description
Photograph of the material storage area along the southwest side of the Bakers North facility.
Latitude
N 35' 01' 10.87"
Longitude
W 80' 36' 56.63"

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Attributes
File Name
DSCN1930.JPG
Description
Photograph of the stormdrain outlet leading to Outfall 3.
Latitude
N 35" 01' 22.48"
Longitude
W 80° 36- 42.10"

DSCN1931.JPG
Attributes
File
I Descriotion I Photoeraoh of the outdoor stora¢e area at Baker Plant North near Outfall 2.
I Latitude I N 35° 01' 17.50"
W 80' 36' 43.52"

DSCN1932.1PG
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Attributes — - -�-
File Name DSCN1932JPG
Description Photograph of the outdoor storage area at Bakers Plant North near Outfall 2.
Latitude N 35' 01' 17.78"
Longitude _LW 80- 36' 43.99"

DSCN1933.JPG
On
--- Attributes
File Nanny CN1933.JPG
Description Photograph of a storindrain inlet at the Bakers North facility near the Helium tan -s. I hiFinlet was
located in a gravel area and was unprotected from potential sand and gravel runoff. Additionally,
some staining was observed in this area from the process.
latitude N 35° 01' 19.29" —
Longitude W 80' 36' 46.08"

File Name
Description
Latitude
Longitude
Attributes
DSCN1934JPG
Photograph of a gravel area at the Bakers North facility near the main pond. Some staining from
furnace dust was observed in this area.
N 35` 01' 17.21"
W 80° 36' 444.68"--

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