Document ppQaGpdBRo0192jJZ1pLe5rjX

EPA Inspection Report - Page 1 of 8 Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 02/27-28/2018 Water Clean Water Act / NPDES Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Akzo Nobel Functional Chemicals LLC Akzo Nobel Battleground Site 730 Independence Parkway South LaPorte, Texas 77571 730 Independence Parkway South LaPorte, Texas 77571 Harries County Quinn Alexander Regional Environmental Manager quinn.alexander@akzonobel.com FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 110000463374 TX0006688 325199 2869, 2819 Personnel participating in inspection: Kenneth L. AuBuchon USEPA/6EN-WMH Quinn Alexander Akzo Nobel Functional Chemicals LLC Adam Myers Akzo Nobel Functional Chemicals LLC Environmental Engineer Regional Environmental Manager Environmental Specialist 281-983-2151 281-817-9211 281-817-9163 EPA Lead Inspector Signature/Date Supervisor Signature/Date Digitally signed by KENNETH AUBUCHON KENNETH AUBUCHON cn=KENNETH AUBUCHON, dnQualifier=0000014523 DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, Date: 2018.03.29 15:38:25 -05'00' Kenneth L. AuBuchon Date CAROL PETERSWAGNON Carol Peters Digitally signed by CAROL PETERS-WAGNON DN: c=US, o=U.S. Government, ou=USEPA, ou=Staff, cn=CAROL PETERS-WAGNON, dnQualifier=0000009981 Date: 2018.03.29 16:10:45 -05'00' Date 6ENFORM-019-R7 (2/15/2017) 1 EPA Inspection Report - Page 2 of 8 Section I - INTRODUCTION Akzo Nobel Functional Chemicals LLC / Akzo Nobel Battleground Site 02/27-28/2018 PURPOSE OF THE INSPECTION EPA Region 6 inspector Kenneth L. AuBuchon arrived at Akzo Nobel Functional Chemicals LLC Battleground Site, La Porte, Texas at approximately 9:30 am on February 27, 2018 for an unannounced Compliance Evaluation Inspection (CEI). I met with Quinn Alexander, Akzo Nobel Battleground Site Regional Environmental Manager and Adam Myers, Akzo Nobel Battleground Site Environmental Specialist, at the opening conference. I presented my credentials to all present at the opening conference and explained that this was an EPA inspection to determine compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act (CWA). The inspection was conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. This report is based on information supplied by Akzo Nobel Functional Chemicals LLC Battleground Site representatives (the permittee), observations made by the U.S. EPA inspector, and records and reports maintained by the permittee, the State of Texas, and the U.S. EPA. FACILITY DESCRIPTION The Akzo Nobel Functional Chemicals LLC Battleground Site (Akzo Nobel Battleground Site) is located at 730 Independence Parkway South, LaPorte, Texas. The Site manufactures commercial organometallic compounds. These compounds are used as catalysts and co-catalysts for polymer manufacturing and pharmaceutical uses. The compounds also are used for semiconductor grade metal organics that are used for electronic and research applications. The Akzo Nobel Battleground Site has internal Outfall 101 which is a 6,000 gpd sanitary package plant that is an extended aeration activated sludge process. The package plant consists of aeration, settling, and sludge return processes. When solids are removed, they are transported to Gulf Coast Waste Authority's Washburn Tunnel Facility for final treatment and disposal. The discharge from 101 is comingled with stormwater associated with industrial activity, cooling tower blowdown, and water generated from non-process external washing (Appendices 1 contains the facility Water Balance) into a 300,000gallon pond system. The 300,000gallon pond system is discharged thru Outfall 001 to segment 1005 of the Houston Ship Channel via Phillips Ditch and Santa Ana Bayou. Section II - OBSERVATIONS After introductions at the opening meeting were concluded and inspection objectives were discussed, I provided a list of documents to review as part of the inspection. Facility staff was able to provide all requested documents and information. At the conclusion of the day, a daily closing was conducted to request additional information not previously requested, discuss the activities for the next day, and discuss the following observations made. Operational logs maintained for discharge readings had flow reported in multiples of 100 gallons per day. The flow measurement device should be suitable to demonstrate compliance with permit limitations. Since daily maximum is only `report' and daily averages did not appear to be exceeded, this was only noted as an observation. 2 EPA Inspection Report - Page 3 of 8 Akzo Nobel Functional Chemicals LLC / Akzo Nobel Battleground Site 02/27-28/2018 Daily operational logs did not document pond levels or pond observations to insure a minimum freeboard of one foot was maintained. See Section III Areas of Concern. When I returned to the facility on 2/28/2018 and entered the guard shack, I was informed to shelter in place due to a fire. After the fire was contained, Mr. Myers accompanied me to a meeting room where the inspection continued. A tour of the Outfalls and the 6,000 gpd sanitary package plant was conducted on 2/28/2018. During the tour the following observations were made: While reviewing the outfall 001 location, no freeboard markings were visible nor was there a staff gauge to demonstrate pond levels did not exceed the 1-foot freeboard requirement. See Section III Areas of Concern. Mr. Roop demonstrated a strong knowledge of the treatment and sampling processes of the sanitary package plant. The system appeared in good working order and operational logs indicated no issues. When asked about his current certification, Mr. Roop said `that he held a wastewater treatment operator D state license'. See Section III Areas of Concern. Tank T-236 (Treated Waste Water tank) shown below is where treated domestic wastewater is held before discharge into the pond system via outfall 101. Mr. Roop explained that the tank is used to monitor the proper operation of the domestic wastewater treatment system. The tank is recirculated and discharged when needed. Chemicals may be added to the tank to insure proper treatment of the discharge. It was not clear if Tank-236 was part of the sanitary treatment process. 3 EPA Inspection Report - Page 4 of 8 Akzo Nobel Functional Chemicals LLC / Akzo Nobel Battleground Site 02/27-28/2018 Section III - AREAS OF CONCERN Requirement - TPDES Permit TX0006688, Other Requirements, 3. The pond (fire water reservoir, retention section, and north collection box) shall be operated in such a manner as to maintain a minimum freeboard of one foot. Concern: At the time of the inspection, it could not be demonstrated that the pond was operated in such a manner as to maintain a minimum freeboard of one foot. Requirement - TPDES Permit TX0006688, Other Requirements, 7. ... The domestic wastewater treatment facility must be operated by a chief operator or an operator holding a Category C license or higher... Concern: At the time of the inspection, the domestic wastewater operator held a Category D license. At the sanitary package plant I met with Mr. Jason Roop, the sanitary package plant operator. He explained the treatment and sampling processes and when asked about his current certification, Mr. Roop said `that he held a wastewater treatment operator D state license'. I requested a copy of his license which is Appendices 2 of this report. Section IV - FOLLOW UP No follow up was required. Section V - LIST OF APPENDICES Appendices 1 - Water Balance Appendices 2 - Mr. Jason Roop's State Operator Licensing Information 4 EPA Inspection Report - Page 5 of 8 Akzo Nobel Functional Chemicals LLC / Akzo Nobel Battleground Site 02/27-28/2018 Appendix 1 Water Balance EPA Inspection Report - Page 6 of 8 EPA Inspection Report - Page 7 of 8 Akzo Nobel Functional Chemicals LLC / Akzo Nobel Battleground Site 02/27-28/2018 Appendix 2 Mr. Jason Roop's State Licensing Information EPA Inspection Report - Page 8 of 8