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Inspection Report: SGL Carbon Group, AFIN: 24-00014, Permit #: AR0037851

Inspection Report Page 2 of 13

WATER DIVISION INSPECTION REPORT AFIN: 24-00014 PERMIT #: AR0037851 DATE: 8/3/2015 COUNTY: 24 Franklin PDS #: 086163 MEDIA: WN GPS LAT: 35.411903 LONG: -93.771387 LOCATION: Entrance

FACILITY INFORMATION INSPECTION INFORMATION NAME:

SGL Carbon Group LOCATION:

3931 Carbon Plant Road CITY:

Ozark, AR

FACILITY TYPE:

2 - Industrial INSPECTOR ID#:

71330 S - State FACILITY EVALUATION RATING:

3 - Satisfactory INSPECTION TYPE:

Compliance Evaluation DATE(S): ENTRY TIME: EXIT TIME:

8/3/2015 09:30 12:48

PERMIT EFFECTIVE DATE:

7/1/2014 PERMIT EXPIRATION DATE:

6/30/2019 RESPONSIBLE OFFICIAL

NAME: / TITLE

Guy Veilleux / COMPANY: SGL Carbon Group MAILING ADDRESS:

3931 Carbon Plant Road CITY, STATE, ZIP: Ozark AR 72949 PHONE & EXT: / FAX:

479-468-8000 / EMAIL:

[email protected]

FAYETTEVILLE SHALE RELATED: N FAYETTEVILLE SHALE VIOLATIONS: N

INSPECTION PARTICIPANTS NAME/TITLE/PHONE/FAX/EMAIL/ETC.:

Kathereen Nunez, EHSA Manager, 479-468-8032

CONTACTED DURING INSPECTION: *** AREA EVALUATIONS

(S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Applicable/Evaluated)

S PERMIT S FLOW MEASUREMENT ** STORMWATER M RECORDS/REPORTS S LABORATORY S FACILITY SITE REVIEW S OPERATION & MAINTENANCE S EFFLUENT/RECEIVING WATER S SELF-MONITORING PROGRAM S SAMPLING S SLUDGE HANDLING/DISPOSAL ** PRETREATMENT ** OTHER:

SUMMARY OF FINDINGS The following violation was noted during inspection: Monthly average calculations are not being reported correctly on the DMR. Specifically, the Permittee is reporting a flow-weighted average as opposed to a straight average for grab samples. This is a violation of Part IA of the permit.

GENERAL COMMENTS I inspected this facility on August 2, 2015. Inspection consisted of a facility assessment, records audit, Industrial Stormwater inspection, and a Construction Stormwater inspection. The facility is currently utilizing “hot technology” graphite. They are in the process of constructing a new facility to replace this with “cold technology” graphite. While the upgrade is not being installed specifically to address effluent quality, they expect the cold technology to greatly reduce their dust and sediment creation thereby reducing pollution risks in their effluent. No effluent violations were noted. Treatment consists of drain filter bags, dewatering filter bags, and an oil skimmer. Samples are collected in the effluent box onsite. Effluent is then discharged via an underground pipe that runs approximately 1.4 miles underground until final discharge to the Arkansas River at Outfall 001. Ms. Kathereen Nunez participated in the inspection. Review of the facility revealed that all treatment systems were operational and well-maintained. Records were orderly and complete. With the exception of the item noted above in the “Summary of Findings,” records and reporting were found to be in compliance.

INS

SUP

SPECTOR’S S

PERVISOR’S

SIGNATURE:

S SIGNATURE

E:

Dannie

lle Gray

Kerri MMcCabe

DATE: 8

DATE: 8

Page 3 of 1

8/7/2015

8/28/2015

3



SECTION A: PERMIT VERIFICATION PERMIT SATISFACTORILY ADDRESSES OBSERVATIONS S M U NA NEDETAILS: 1. CORRECT NAME AND MAILING ADDRESS OF PERMITTEE: Y N NA NE 2. NOTIFICATION GIVEN TO EPA/STATE OF NEW DIFFERENT OR INCREASED DISCHARGES: Y N NA NE 3. NUMBER AND LOCATION OF DISCHARGE POINTS AS DESCRIBED IN PERMIT: Y N NA NE 4. ALL DISCHARGES ARE PERMITTED: Y N NA NE

SECTION B: RECORDKEEPING AND REPORTING EVALUATION RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT S M U NA NEDETAILS: 1. ANALYTICAL RESULTS CONSISTENT WITH DATA REPORTED ON DMRS: See comment below. Y N NA NE 2. SAMPLING AND ANALYSES DATA ADEQUATE AND INCLUDE: S M U NA NE

a. DATES AND TIME(S) OF SAMPLING: Y N NA NE b. EXACT LOCATION(S) OF SAMPLING: Y N NA NE c. NAME OF INDIVIDUAL PERFORMING SAMPLING: Y N NA NE d. ANALYTICAL METHODS AND TECHNIQUES: Y N NA NE e. RESULTS OF CALIBRATIONS: Y N NA NE f. RESULTS OF ANALYSES: Y N NA NE g. DATES AND TIMES OF ANALYSES: Y N NA NE h. NAME OF PERSON(S) PERFORMING ANALYSES: Y N NA NE

3. LABORATORY EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS ADEQUATE: S M U NA NE 4. PLANT RECORDS INCLUDE SCHEDULES, DATES OF EQUIPMENT MAINTENANCE AND REPAIR: S M U NA NE 5. EFFLUENT LOADINGS CALCULATED USING DAILY EFFLUENT FLOW AND DAILY ANALYTICAL DATA: Y N NA NE *monthly average is being calculated incorrectly.

SECTION C: OPERATIONS AND MAINTENANCE TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED S M U NA NEDETAILS: 1. TREATMENT UNITS PROPERLY OPERATED: S M U NA NE 2. TREATMENT UNITS PROPERLY MAINTAINED: S M U NA NE 3. STANDBY POWER OR OTHER EQUIVALENT PROVIDED: Gravity fed to pond. S M U NA NE 4. ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE: S M U NA NE 5. ALL NEEDED TREATMENT UNITS IN SERVICE: S M U NA NE 6. ADEQUATE NUMBER OF QUALIFIED OPERATORS PROVIDED: S M U NA NE 7. SPARE PARTS AND SUPPLIES INVENTORY MAINTAINED: S M U NA NE 8. OPERATION AND MAINTENANCE MANUAL AVAILABLE: Y N NA NE 9. STANDARD OPERATING PROCEDURES AND SCHEDULES ESTABLISHED: Y N NA NE 10. PROCEDURES FOR EMERGENCY TREATMENT CONTROL ESTABLISHED: Y N NA NE 11. HAVE BYPASSES/OVERFLOWS OCCURRED AT THE PLANT OR IN THE COLLECTION SYSTEM IN THE LAST YEAR: Two (2) Y N NA NE 12. IF SO, HAS THE REGULATORY AGENCY BEEN NOTIFIED: Y N NA NE 13. HAS CORRECTIVE ACTION BEEN TAKEN TO PREVENT ADDITIONAL BYPASSES/OVERFLOWS: Y N NA NE 14. HAVE ANY HYDRAULIC OVERLOADS OCCURRED AT THE TREATMENT PLANT: Y N NA NE 15. IF SO, DID PERMIT VIOLATIONS OCCUR AS A RESULT: Y N NA NE



SECTION D: SAMPLING PERMITTEE SAMPLING MEETS PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. SAMPLES TAKEN AT SITE(S) SPECIFIED IN PERMIT: Y N NA NE 2. LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES: Y N NA NE 3. FLOW PROPORTIONED SAMPLES OBTAINED WHEN REQUIRED BY PERMIT: Y N NA NE 4. SAMPLING AND ANALYSES COMPLETED ON PARAMETERS SPECIFIED IN PERMIT: Y N NA NE 5. SAMPLING AND ANALYSES PERFORMED AT FREQUENCY SPECIFIED IN PERMIT: Y N NA NE 6. SAMPLE COLLECTION PROCEDURES ADEQUATE: Y N NA NE

a. SAMPLES REFRIGERATED DURING COMPOSITING: Y N NA NE b. PROPER PRESERVATION TECHNIQUES USED: Y N NA NE c. CONTAINERS AND SAMPLE HOLDING TIMES CONFORM TO 40 CFR 136: Y N NA NE

7. IF MONITORING IS PERFORMED MORE OFTEN THAN REQUIRED ARE RESULTS REPORTED ON THE DMR: Y N NA NE

SECTION E: FLOW MEASUREMENT PERMITTEE FLOW MEASUREMENT MEETS PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. PRIMARY FLOW MEASUREMENT DEVICE PROPERLY INSTALLED AND MAINTAINED: TYPE OF DEVICE: Krohne totalizer Y N NA NE 2. FLOW MEASURED AT EACH OUTFALL AS REQUIRED: Y N NA NE 3. SECONDARY INSTRUMENTS (TOTALIZERS, RECORDERS, ETC.) PROPERLY OPERATED AND MAINTAINED: Y N NA NE 4. CALIBRATION FREQUENCY ADEQUATE: Every 2 years; last calibration 2/25/2013. Facility has calibration scheduled for 2015. Y N NA NE 5. RECORDS MAINTAINED OF CALIBRATION PROCEDURES: Calibration is outsourced. Y N NA NE 6. CALIBRATION CHECKS DONE TO ASSURE CONTINUED COMPLIANCE: Y N NA NE 7. FLOW ENTERING DEVICE WELL DISTRIBUTED ACROSS THE CHANNEL AND FREE OF TURBULENCE: Y N NA NE 8. FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGE OF FLOW RATES: Y N NA NE 9. HEAD MEASURED AT PROPER LOCATION: Y N NA NE

SECTION F: LABORATORY PERMITTEE LABORATORY PROCEDURES MEET PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. EPA APPROVED ANALYTICAL PROCEDURES USED (40 CFR 136.3 FOR LIQUIDS, 503.8(B) FOR SLUDGES) : Y N NA NE 2. IF ALTERNATIVE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN OBTAINED: Y N NA NE 3. SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT: Y N NA NE 4. QUALITY CONTROL PROCEDURES ADEQUATE: Y N NA NE 5. DUPLICATE SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 6. SPIKED SAMPLES ARE ANALYZED >10% OF THE TIME: Y N NA NE 7. COMMERCIAL LABORATORY USED: Y N NA NE

a. LAB NAME: Environmental Services Company, Inc.

b. LAB ADDRESS: Northwest AR Branch, 1107 Century Ave, Springdale, AR 72762

c. PARAMETERS PERFORMED: COD, O & G, pH, TSS, Flow, WET testing

8. BIOMONITORING PROCEDURES ADEQUATE: Y N NA NE a. PROPER ORGANISMS USED: Y N NA NE b. PROPER DILUTION SERIES FOLLOWED: Y N NA NE c. PROPER TEST METHODS AND DURATION: Y N NA NE d. RETESTS AND/OR TRE PERFORMED AS REQUIRED: Y N NA NE



SECTION G: EFFLUENT/RECEIVING WATERS OBSERVATIONS BASED ON VISUAL OBSERVATIONS ONLY S M U NA NEDETAILS: No discharge during inspection. OUTFALL #: OIL SHEEN GREASE TURBIDITY VISIBLE FOAM FLOATING SOLIDS COLOR OTHER

001 None None None None None Clear --

SECTION H: SLUDGE DISPOSAL SLUDGE DISPOSAL MEETS PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. SLUDGE MANAGEMENT ADEQUATE TO MAINTAIN EFFLUENT QUALITY: S M U NA NE 2. SLUDGE RECORDS MAINTAINED AS REQUIRED BY 40 CFR 503: S M U NA NE 3. FOR LAND APPLIED SLUDGE, TYPE OF LAND APPLIED TO: (E.G., FOREST, AGRICULTURAL, PUBLIC CONTACT SITE):

SECTION I: SAMPLING INSPECTION PROCEDURES SAMPLE RESULTS WITHIN PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. SAMPLES OBTAINED THIS INSPECTION: Y N NA NE 2. TYPE OF SAMPLE: GRAB: COMPOSITE: METHOD: FREQUENCY: 3. SAMPLES PRESERVED: Y N NA NE 4. FLOW PROPORTIONED SAMPLES OBTAINED: Y N NA NE 5. SAMPLE OBTAINED FROM FACILITY'S SAMPLING DEVICE: Y N NA NE 6. SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE: Y N NA NE 7. SAMPLE SPLIT WITH PERMITTEE: Y N NA NE 8. CHAIN-OF-CUSTODY PROCEDURES EMPLOYED: Y N NA NE 9. SAMPLES COLLECTED IN ACCORDANCE WITH PERMIT: Y N NA NE

SECTION J: STORM WATER POLLUTION PREVENTION PLAN STORM WATER MANAGEMENT MEETS PERMIT REQUIREMENTS S M U NA NEDETAILS: 1. SWPPP UPDATED AS NEEDED: DATE OF LAST UPDATE: Y N NA NE 2. SITE MAP INCLUDING ALL DISCHARGES AND SURFACE WATERS: Y N NA NE 3. POLLUTION PREVENTION TEAM IDENTIFIED: Y N NA NE 4. POLLUTION PREVENTION TEAM PROPERLY TRAINED: Y N NA NE 5. LIST OF POTENTIAL POLLUTANT SOURCES: Y N NA NE 6. LIST OF POTENTIAL SOURCES AND PAST SPILLS AND LEAKS: Y N NA NE 7. ALL NON-STORM WATER DISCHARGES ARE AUTHORIZED: Y N NA NE 8. LIST OF STRUCTURAL BMPS: Y N NA NE 9. LIST OF NON-STRUCTURAL BMPS: Y N NA NE 10. BMPS PROPERLY OPERATED AND MAINTAINED: Y N NA NE 11. INSPECTIONS CONDUCTED AS REQUIRED: Y N NA NE



DMR Calculation Check

Reporting Period: From 2015 06 01 To 2015 06 30 Year Month Day Year Month Day

Parameter Checked: COD

Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l

Reported Value: 4.16 7.33* 10.5 Calculated Value: 4.1253 6.75* 10.5 Permit Value: 30 50 75

If calculated value does not equal reported value, explain: Facility is calculating monthly average using a flow-weighted average. This is incorrect. Facility is collecting grab samples 2/month; and therefore, should be calculating with a straight average. Spoke with Kathereen Nunez on 8/7/2015 and she agreed to amend their calculation procedure accordingly.



DMR Calculation Check

Reporting Period: From 2014 11 01 To 2014 11 30 Year Month Day Year Month Day

Parameter Checked: TSS

Loading Concentration Mass Monthly Mo. Avg. - lbs/day Mo. Avg. - mg/l 7-day Avg. - mg/l

Reported Value: 2.55 3.37* 6 Calculated Value: 2.549619 3.5* 6.0 Permit Value: 12 20 30

If calculated value does not equal reported value, explain: Facility is calculating monthly average using a flow-weighted average. This is incorrect. Facility is collecting grab samples 2/month; and therefore, should be calculating with a straight average. Spoke with Kathereen Nunez on 8/7/2015 and she agreed to amend their calculation procedure accordingly.



Water Division Photographic Evidence Sheet

Location: SGL Carbon Group Photographer: Dannielle Gray Date: 8/3/2015 Time: 1117 Witness: Kathereen Nunez Photo #: 1 Description: Influent holding tank – facility uses potable city water for cooling associated with graphite activities.

Photographer: Dannielle Gray Date: 8/3/2015 Time: 1038 Witness: Kathereen Nunez Photo #: 2 Description: Oil skimmer basin.



Water Division Photographic Evidence Sheet

Location: SGL Carbon Group Photographer: Dannielle Gray Date: 8/3/2015 Time: 1039 Witness: Kathereen Nunez Photo #: 3 Description: Example of dewatering filter bag.

Photographer: Dannielle Gray Date: 8/3/2015 Time: 1053 Witness: Kathereen Nunez Photo #: 4 Description: Effluent box.



Water Division Photographic Evidence Sheet Location: SGL Carbon Group Photographer: Dannielle Gray Date: 8/3/2015 Time: 1054 Witness: Kathereen Nunez Photo #: 5 Description: Wet well in effluent box.

Photographer: Dannielle Gray Date: 8/3/2015 Time: 1053 Witness: Kathereen Nunez Photo #: 6 Description: Flowmeter.



Figure 1: Google Earth image dated Oct 26, 2012 showing location of treatment components (excluding filter bags, which are located in numerous places throughout the site).



Figure 2: Google Earth image dated Oct 26, 2012 showing outfall location in relation to facility location.

From: McCabe, KerriTo: McConnell, MelissaCc: Gray, DannielleSubject: FW: SGL Carbon Group Inspections (Franklin Co)Date: Tuesday, September 01, 2015 6:36:21 AMAttachments: image001.png

Melissa, Please attach to WID 17982/PDS 086163. Thank you.

Kerri McCabeInspector SupervisorADEQ – Water DivisionField Services – Inspection Branch Office – (501) 682-0642Work Cell – (501) 352-5641Fax – (501) 682-08805301 Northshore DriveNorth Little Rock, AR 72118-5317

From: Nunez, Kathy [mailto:[email protected]] Sent: Monday, August 31, 2015 2:42 PMTo: McCabe, KerriSubject: RE: SGL Carbon Group Inspections (Franklin Co) Thank you for sending this to me! On page 8, photo 7, let me offer the following comment to clarify: Discharge from thepond’s bottom valve doesn’t occur unless we intentionally drain the pond empty formaintenance purposes. The pond was drained once to remove sediment that had settled onthe pond bottom over a number of years. Discharge from the bottom valve will occur againwhen we need to perform this maintenance in the future, but it is only once every fewyears. Thanks, Kathy

mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MCCABEmailto:[email protected]:[email protected]

From: McCabe, Kerri [mailto:[email protected]] Sent: Friday, August 28, 2015 3:27 PMTo: Nunez, KathyCc: Gray, DannielleSubject: SGL Carbon Group Inspections (Franklin Co) Please find attached the inspection reports for the above-referenced site. Thank you.


mailto:[email protected]

From: Gray, DannielleTo: McConnell, MelissaSubject: FW: Inspection Report for SGL CarbonDate: Wednesday, September 02, 2015 8:10:54 AM

Please attach to WID 17982/PDS 086163. Thank you. Dannielle GrayADEQ Water Inspector, District 4(479) 424-0333

From: Nunez, Kathy [mailto:[email protected]] Sent: Monday, August 24, 2015 9:41 AMTo: Gray, DannielleSubject: RE: Inspection Report for SGL Carbon Thanks Dannielle From: Gray, Dannielle [mailto:[email protected]] Sent: Monday, August 24, 2015 9:05 AMTo: Nunez, KathySubject: RE: Inspection Report for SGL Carbon Good morning Katy,

I submitted the draft for approval on the 7th. EPA mandates that we finalize reports within 30 daysof inspection. Sometimes it takes a while to get through processing at headquarters, but that time

will not exceed 30 days. If you haven’t received it by September 3rd, I will follow up and see if I can’tget a status on it. If you have any other questions or concerns, please let me know. Have a great day! ~Dannielle Dannielle GrayADEQ Water Inspector, District 4(479) 424-0333

From: Nunez, Kathy [mailto:[email protected]] Sent: Monday, August 24, 2015 8:52 AMTo: Gray, DannielleSubject: Inspection Report for SGL Carbon Dannielle, We have not yet received your inspection report for your recent water inspection of our

mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=GRAYDmailto:[email protected]:[email protected]:[email protected]

facility. You mentioned you had completed it and forwarded it on to others at ADEQ. Doyou think you could check on it for us? I know you were expecting us to receive it morethan a week ago. Thanks, Kathy NunezSGL Group3931 Carbon Plant RoadOzark, AR 72949ph 479-468-8032fax [email protected]


From: Gray, DannielleTo: McConnell, MelissaSubject: FW: SGL Carbon Process Water Flow DataDate: Wednesday, September 02, 2015 8:09:06 AM

Please attach to WID 17982/PDS 086163. Thank you. Dannielle GrayADEQ Water Inspector, District 4(479) 424-0333

From: Nunez, Kathy [mailto:[email protected]] Sent: Thursday, August 06, 2015 4:15 PMTo: Gray, DannielleSubject: RE: SGL Carbon Process Water Flow Data I’m sorry, I’ve been in a meeting all day with our corporate environmental manager. You have to weight it by flow. First multiply each COD in mg/l by its flow. Add those twonumbers together then divide by the sum of the flows.: (10.5 mg/l x 54.6 GPM) + (3 mg/l x 40 GPM) = 573 + 120 = 693 GPM * mg/l 693 GPM * mg/l divided by (54.6 GPM + 40 GPM) = 7.33 mg/l flow weighted monthlyaverage COD Hope this helps. Kathy From: Gray, Dannielle [mailto:[email protected]] Sent: Thursday, August 06, 2015 1:38 PMTo: Nunez, KathySubject: RE: SGL Carbon Process Water Flow Data Good afternoon Kathy, I’m having some trouble replicating your monthly average on DMR’s. Can you tell me whatcalculation you are doing to get the number you are reporting? Loading numbers and daily max numbers are working out the same, it’s just monthly average thatI’m having trouble with. Looking at June 2015, you reported 7.33 mg/l as your COD monthly average. Lab reports show CODin two separate samples, one at 10.5 mg/l and one at 3.0 mg/l. when I calculate monthly average,I’m getting 6.75 mg/l ((10.5+3)/2).

mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=GRAYDmailto:[email protected]:[email protected]

I’m running across a similar difference for the November 2014 report. Thanks! ~Dannielle Dannielle GrayADEQ Water Inspector, District 4(479) 424-0333

From: Nunez, Kathy [mailto:[email protected]] Sent: Monday, August 03, 2015 2:55 PMTo: Gray, DannielleSubject: SGL Carbon Process Water Flow Data We left the process water flow data on the printer this morning. Here are the two monthsyou needed.

Initials Date Time FlowGPM

FlowmeterTotal Gal Pumped

ESC 06/01/2015 11:23 54.6

KN 06/03/2015 8:38 0.0 12962768

JF 06/08/2015 8:06 0.0 13002274

JF 06/09/2015 16:57 0.0 13023020

KN 06/16/2015 12:35 0.0 13049277

ESC 06/18/2015 11:54 40.0

KN 06/22/2015 14:48 0.0 13091128

KN 06/25/2015 9:42 0.0 13098774

KN 06/29/2015 7:18 0.0 13116119

KN 06/30/2015 7:21 48.4 13118772

Initials Date Time FlowGPM

FlowmeterTotal Gal Pumped

ESC 11/03/2014 11:22 66.4

KN 11/05/2014 8:45 0.0 11521831


ESC 11/10/2014 8:04 59.7 11535721

KN 11/11/2014 7:37 0.0 11538148

KN 11/19/2014 10:44 51.2 11593790

KN 11/20/2014 11:49 0.0 11601441

KN 11/24/2014 9:56 0.0 11631046

KN 11/26/2014 10:11 0.0 11647055

Kathy NunezSGL Group3931 Carbon Plant RoadOzark, AR 72949ph 479-468-8032fax [email protected]


September 18, 2015 Kathereen Nunez SGL Carbon, LLC 3931 Carbon Plant Road Ozark, AR 72949 RE: Response to Inspections (Franklin Co)

AFIN: 24-00014 NPDES Permit No.: AR0037851 ARR00C390 ARR154306 Dear Ms. Nunez: I have reviewed the response pertaining to my August 3, 2015 inspections of the above-referenced permits at the SGL Carbon facility. The information provided sufficiently addresses the violations referenced in my inspection report. At this time, the Department has no further comment concerning this particular inspection. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at (479) 424-0333 or you may e-mail me at [email protected]. Sincerely,

Dannielle Gray District 4 Field Inspector Water Division

From: McCabe, KerriTo: McConnell, MelissaCc: Gray, DannielleSubject: FW: SGL Carbon Water Inspection Report, AFIN: 24-00014, Permit Numbers: ARR154306, AR0037851, &

ARR00C390Date: Friday, September 18, 2015 11:34:30 AMAttachments: 2015 Water Inspection SGL Carbon.pdf

Environmental Audit - Maintenance 07-23-15.pdfimage001.png

Melissa, Please attach this email and two attachments to WIDs 17982, 17983, and 17984. Dannielle hassubmitted the adequate response letter and the response is not attached. Thank you.


From: Nunez, Kathy [mailto:[email protected]] Sent: Monday, September 14, 2015 12:54 PMTo: Water-Inspection-ReportCc: Gray, DannielleSubject: SGL Carbon Water Inspection Report, AFIN: 24-00014, Permit Numbers: ARR154306,AR0037851, & ARR00C390 Please see attached. Thanks, Kathy NunezSGL Group3931 Carbon Plant RoadOzark, AR 72949ph 479-468-8032fax [email protected]
mailto:/O=ARKANSAS DEPT. OF ENVIRONMENTAL QUALITY/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=MCCABEmailto:[email protected]:[email protected]:[email protected]

September 14, 2015

Jason Bolenbaugh, Branch Manager Water Division Inspection Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317 RE: SGL Carbon, LLC (SGL) Water Inspection Findings AFIN: 24-00014 Permit Numbers: ARR154306, AR0037851, & ARR00C390 Dear Mr. Bolenbaugh: SGL Carbon, LLC (SGL) has reviewed the issues noted during the August 03, 2015 water inspection by Dannielle Gray, ADEQ Inspector. SGL has taken corrective actions to address these issues, as described below. Permit ARR154306 Finding:

1. Silt fence was in disrepair and in need of maintenance. This is a violation of Part II, Section B.17.A of the permit. Specifically, the following items need to be addressed:

a) Tears were noted in the silt fence (Photo 4 below), b) Construction material and silt buildup was noted to be stressing the fence

capacity in some areas (Photo 6 below), c) Signs and construction material were placed on silt fences (Photo 7 below), and d) Areas where fencing overlapped were incorrectly installed.

Comments:

The silt fencing was replaced with a properly installed silt fence, the construction material and silt buildup were removed, and the sign was removed on August 4, 2015 (see photos below). The filter bags that had rolled into the vegetative swale were also removed at this time. Additionally, the broken silt fence in the stormwater ditch, which was used to enhance the rock check dam control before the hay was installed, was also removed on August 4, 2015.

3931 Carbon Plant Road, Ozark, AR 72949

DC0 public - (NUNEZKA)

Permit AR0037851 Finding:

Monthly average calculations are not being reported correctly on the DMR. Specifically, the Permittee is reporting a flow-weighted average as opposed to a straight average for grab samples. This is a violation of Part IA of the permit.

Comments: The calculation had been taken from the example calculations in the NPDES Reporting Requirements Handbook for flow weighted monthly average, rather than from the current process water permit. As a result of this inspection, SGL began using an arithmetic mean to calculate average monthly concentrations, beginning with the July 2015 DMR.


Permit ARR00C390 Finding:

Used oil containment was not being well-maintained. Specifically, used oil had saturated the filter bag at the secondary containment valve and was noted on the ground and moving towards a culvert (see Photos 9 and 10 below). This is a violation of Part 3.1.2 of the permit.

Comments: This area is regularly inspected as a part of SGL’s SWPPP. During one such inspection by an SGL internal auditor on July 23, 2015, approximately 1 ½ weeks prior to this ADEQ inspection, no oil was observed in this location (please see attached document). The oil spill was cleaned up (dug up) and oil contaminated materials disposed of properly on August 5, 2015 (please see photo below). This issue was reviewed with department employees to prevent reoccurrence.

SGL-Ozark continues to strive for environmental excellence and appreciates ADEQ’s assistance in this endeavor. Sincerely,

Bob Balentine Plant Manager

Quarterly SWPP Inspection SGL Carbon, LLC –Ozark, Arkansas

Inspector: Melinda C. & Tammie M. Date of Inspection: 7/23/15

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E- V9

DC1 For internal use only - (NUNEZKA)

Is it raining (during the inspection)? Yes No

Inspection Area

Maintenance Department

Conform?

√ Corrective Action Required / Notes

Date Completed

No evidence of leaks or drips on the ground around the maintenance diesel storage tank (AST)?

√

No evidence of leaks or drips on the ground around the maintenance gasoline storage tank (AST)? Containment drain valve closed and secured?

√ √

No evidence of leaks or drips on the ground around the used oil storage tank (AST)? Containment drain valve closed and secured?

√ √

No evidence of leaks or drips on the ground around the oil storage building? √

Housekeeping adequate inside the oil storage building? No spills or oil contaminated waste on the floor? Waste hoppers for oil contaminated material not overfilled?

√ √ √

Housekeeping was good.

No liquid chemicals, oils or hazardous wastes stored outside oil storage building? All totes and barrels stored outside are empty and bunged?

X

PI had stored two barrels outside the oil storage

building while organizing the area, but Paul said they would be moved within 20

minutes.

7/23/2015



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E- V9


Inspection Area


Conform?


Date Completed

No evidence of leaks or drips on the ground around the Maintenance Building, including the vehicle maintenance area on the South side of the building?

√

No miscellaneous containers/buckets of oil/grease stored outside without secondary containment around maintenance shop or metal recycle area?

√

No evidence of leaks or drips from totes on storage rack in maintenance shop? √

Lid to the parts cleaner is closed, if not in use? √

No evidence of leaks or drips from mobile equipment used in the Maintenance department?

√

Adequate supplies of spill control materials present in the store room? √

Spill control materials maintained in Spill Trailer? √

Trailer was also sealed



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E- V9


Inspection Area


Conform?


Date Completed

Waste batteries are stored indoors? (located in storeroom) Damaged batteries are stored in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Batteries” or “Waste Batteries” or “Used Batteries”?

√ √ √

(located W end of top hat bldg)

Waste lamps are stored indoors in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Lamps” or “Waste Lamps” or “Used Lamps”?

√ √

We need to have more containers for the waste

lamps. 7/24/2015

Waste mercury containing equipment is stored indoors? (located in storeroom) Damaged equipment is stored in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Mercury Containing Equipment” or Waste Mercury-Containing Equipment” or “Used Mercury-Containing Equipment”?

√

There was no waste mercury

Area around trash bins clean and free of debris? No oily material exposed to storm water?

√

No evidence of leaks or drips on the ground around the fire system storage tank (AST)? (located south of Admin) Containment drain valve closed and secured?

√



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E- V9


Inspection Area


Conform?


Date Completed

General housekeeping is adequate to minimize pollutants in the discharge?

√

Additional comments or observations:

Overall the maintenance area looked very good.

September 14, 2015

Jason Bolenbaugh, Branch Manager Water Division Inspection Branch Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, AR 72118-5317 RE: SGL Carbon, LLC (SGL) Water Inspection Findings AFIN: 24-00014 Permit Numbers: ARR154306, AR0037851, & ARR00C390 Dear Mr. Bolenbaugh: SGL Carbon, LLC (SGL) has reviewed the issues noted during the August 03, 2015 water inspection by Dannielle Gray, ADEQ Inspector. SGL has taken corrective actions to address these issues, as described below. Permit ARR154306 Finding:

1. Silt fence was in disrepair and in need of maintenance. This is a violation of Part II, Section B.17.A of the permit. Specifically, the following items need to be addressed:

a) Tears were noted in the silt fence (Photo 4 below), b) Construction material and silt buildup was noted to be stressing the fence

capacity in some areas (Photo 6 below), c) Signs and construction material were placed on silt fences (Photo 7 below), and d) Areas where fencing overlapped were incorrectly installed.

Comments:

The silt fencing was replaced with a properly installed silt fence, the construction material and silt buildup were removed, and the sign was removed on August 4, 2015 (see photos below). The filter bags that had rolled into the vegetative swale were also removed at this time. Additionally, the broken silt fence in the stormwater ditch, which was used to enhance the rock check dam control before the hay was installed, was also removed on August 4, 2015.

3931 Carbon Plant Road, Ozark, AR 72949


Permit AR0037851 Finding:

Monthly average calculations are not being reported correctly on the DMR. Specifically, the Permittee is reporting a flow-weighted average as opposed to a straight average for grab samples. This is a violation of Part IA of the permit.

Comments: The calculation had been taken from the example calculations in the NPDES Reporting Requirements Handbook for flow weighted monthly average, rather than from the current process water permit. As a result of this inspection, SGL began using an arithmetic mean to calculate average monthly concentrations, beginning with the July 2015 DMR.


Permit ARR00C390 Finding:

Used oil containment was not being well-maintained. Specifically, used oil had saturated the filter bag at the secondary containment valve and was noted on the ground and moving towards a culvert (see Photos 9 and 10 below). This is a violation of Part 3.1.2 of the permit.

Comments: This area is regularly inspected as a part of SGL’s SWPPP. During one such inspection by an SGL internal auditor on July 23, 2015, approximately 1 ½ weeks prior to this ADEQ inspection, no oil was observed in this location (please see attached document). The oil spill was cleaned up (dug up) and oil contaminated materials disposed of properly on August 5, 2015 (please see photo below). This issue was reviewed with department employees to prevent reoccurrence.

SGL-Ozark continues to strive for environmental excellence and appreciates ADEQ’s assistance in this endeavor. Sincerely,

Bob Balentine Plant Manager



- 1 -

E- V9


Is it raining (during the inspection)? Yes No

Inspection Area


Conform?


Date Completed

No evidence of leaks or drips on the ground around the maintenance diesel storage tank (AST)?

√

No evidence of leaks or drips on the ground around the maintenance gasoline storage tank (AST)? Containment drain valve closed and secured?

√ √

No evidence of leaks or drips on the ground around the used oil storage tank (AST)? Containment drain valve closed and secured?

√ √

No evidence of leaks or drips on the ground around the oil storage building? √

Housekeeping adequate inside the oil storage building? No spills or oil contaminated waste on the floor? Waste hoppers for oil contaminated material not overfilled?

√ √ √

Housekeeping was good.

No liquid chemicals, oils or hazardous wastes stored outside oil storage building? All totes and barrels stored outside are empty and bunged?

X

PI had stored two barrels outside the oil storage

building while organizing the area, but Paul said they would be moved within 20

minutes.

7/23/2015



- 2 -

E- V9


Inspection Area


Conform?


Date Completed

No evidence of leaks or drips on the ground around the Maintenance Building, including the vehicle maintenance area on the South side of the building?

√

No miscellaneous containers/buckets of oil/grease stored outside without secondary containment around maintenance shop or metal recycle area?

√

No evidence of leaks or drips from totes on storage rack in maintenance shop? √

Lid to the parts cleaner is closed, if not in use? √

No evidence of leaks or drips from mobile equipment used in the Maintenance department?

√

Adequate supplies of spill control materials present in the store room? √

Spill control materials maintained in Spill Trailer? √

Trailer was also sealed



- 3 -

E- V9


Inspection Area


Conform?


Date Completed

Waste batteries are stored indoors? (located in storeroom) Damaged batteries are stored in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Batteries” or “Waste Batteries” or “Used Batteries”?

√ √ √

(located W end of top hat bldg)

Waste lamps are stored indoors in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Lamps” or “Waste Lamps” or “Used Lamps”?

√ √

We need to have more containers for the waste

lamps. 7/24/2015

Waste mercury containing equipment is stored indoors? (located in storeroom) Damaged equipment is stored in a closed container that is structurally sound? Container is clearly marked as “Universal Waste-Mercury Containing Equipment” or Waste Mercury-Containing Equipment” or “Used Mercury-Containing Equipment”?

√

There was no waste mercury

Area around trash bins clean and free of debris? No oily material exposed to storm water?

√

No evidence of leaks or drips on the ground around the fire system storage tank (AST)? (located south of Admin) Containment drain valve closed and secured?

√



- 4 -

E- V9


Inspection Area


Conform?


Date Completed

General housekeeping is adequate to minimize pollutants in the discharge?

√

Additional comments or observations:

Overall the maintenance area looked very good.

Binder1.pdfFW_ Inspection Report for SGL CarbonFW_ SGL Carbon Process Water Flow DataFW_ SGL Carbon Process

SGL.pdfFW_ SGL Carbon Water Inspection Report, AFIN_ 24-00014, Permit Numbers_ ARR154306, AR0037851, & ARR00C3902015 Water Inspection SGL Carbon (2)Environmental Audit - Maintenance 07-23-15 (2)

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