Request for Class 3 Permit Modification by CR/T from GA-EPD 2016-06-22

Update 2016-06-24: report and video of the meeting.

A chemical plant on E. Hill Ave. in Valdosta wants to stop monitoring chemicals in one of its wells, it says because of difficult access due to stormwater that collects there. Yet they want to “add analysis of naphthalene, 2-methylphenol, and phenol for the post-closure care monitoring program.”

Facebook: event

When: 6-7 PM Wed June 22nd 2016

Where: South Georgia Regional Library
300 Woodrow Wilson Dr, Valdosta, Georgia 31602

This is the same location as the Arizona Chemical plant that almost closed in 2008. Stuart Taylor, VDT, 30 November 2014, Made in Valdosta: Chemical Research Technology,

“Printing ink, about 10 years ago, I’d say, was a very good market,” said Ramesh Mulani, operations manager at Chemical Research Technology in Valdosta. “As soon as the Internet came in, it was a big downward jump. At that time, a lot of printing companies went out of business.”

Quad Graphics responded to the industry changes by going on an acquisition and consolidation campaign, picking up ink and ink-related companies that were going out of business.

When Arizona Chemical started making plans to shut down its Valdosta plant in 2013, Quad Graphics decided to buy the facility, creating CR\T.

There’s a public meeting about this CR/T permit request at the main Lowndes County library 6-7PM Wednesday June 22nd 2016. This is not a public hearing, but it is possible to call for one, and comments can be submitted before, and apparently after, that date.

Public Notice gpn14, Valdosta Daily Times, 13 May 2016, Notice of Intent to Modify Permit,

In accordance with the Georgia Hazardous Waste Management Act, O.C.G.A. Section 12-8-60, et seq., as amended, Chemical Research/Technology Company (CR/T) is holding a public meeting concerning a Class 3 RCRA Part B Permit Modification Request to the Georgia EPD. CR/T will hold the public meeting on June 22, 2016 from 6:00PM to 7:00PM at the Valdosta Lowndes County Library located at 300 Woodrow Wilson Drive, Valdosta, Georgia.
On February 13, 2014, EPD issued Hazardous Waste Facility Permit HW-053(CA&D)-2 to CR/T. The Permit includes corrective action for Solid Waste Management Units and areas of concern and post-closure care of a Hazardous Waste Management Unit. The Class 3 permit modification request, which is the subject of the notice, proposes to amend the existing permit to remove monitoring well MW-20 from the Corrective Action Plan (CAP) monitoring program and add analysis of naphthalene, 2-methylphenol, and phenol for the post-closure care monitoring program. The permit modification request has been prepared in accordance with the Georgia Rules for Hazardous Waste Management, Chapter 391-3-11. Before making its final decision to modify the permit, Section 391-3-11-.11 (40 CFR 270.42) of the Rules requires an opportunity for public comment. Accordingly, a public comment period has been arranged from May 13, 2016 to July 12, 2016. During the public comment period a copy of the draft permit modification request and supporting documents will be available for public review at the following locations during regular business hours:
Georgia Environmental Protection Division
Hazardous Waste Corrective Action Program
2 Martin Luther King Jr. Dr., SE
Floyd Tower East, Suite 1054
Atlanta, Georgia 30334
Monday—Friday
8:00am—4:30pm
(404) 656-2833
Valdosta Lowndes County Library
300 Woodrow Wilson Drive
Valdosta, Georgia 31602
Monday—Thursday: 9:30am—8:00pm
Friday: 9:30am—5:30pm;
Saturday: 11:00am—5:30pm;
Sunday: 2:00pm—6:00pm
(229) 333-0086
Georgia EPD invites comments on the Class III permit modification to be made in writing during the public comment period. All comments that are received on or before 4:30 pm on July 12, 2016 will be considered in making the final decision to modify the permit. All submissions should be addressed to
Mr. Bruce Khaleghi, Unit Manager,
Hazardous Waste Corrective Action Program,
2 MLK, Jr. Drive, SE, Suite 1054,
Atlanta, Georgia 30334.
For additional information regarding public participation please contact Mr. Bruce Khaleghi at (404) 656-2833. 001018355/13/16

I took the two pictures above of the well sites from East Hill Avenue. Gretchen Quarterman photographed the entire permit packet at the library; those pictures are below. Click on any of them to get a bigger picture. And you can send in comments and go to the meeting.

Chemical Research/Technology Co.
1401 East Hill Avenue
Valdosta, GA 31601
tel. 229.333.8445
May 9, 2016
Mr. Bruce Khaleghi
Environmental Protection Division
Land Protection Branch
2 Martin Luther King Jr. Drive, Suite 1054
Atlanta, GA 30334
Re: Request for Class 3 Permit Modification
Chemical Research/Technology Company
Valdosta, Georgia
Facility Permit No. HW-053 (CA&D)
EPA ID No. GAD003299526
Dear Mr. Khaleghi:
The Chemical Research / Technology Company (CR/T) facility (GAD003299526) located in Valdosta, Georgia requests a Class 3 permit modification to its Hazardous Waste Post-Closure Permit No. HW-053 (CA&D), effective February 13, 2014. The modification is described below.

Background

The Permit includes corrective action for solid waste management units (SWMUs) and areas of concern. Currently, the SWMUs are monitored by nine groundwater monitoring wells on an annual basis. The Georgia Environmental Protection Division (EPD) inspected the monitoring wells on May 13, 2015 and issued a Notice of Violation (NOV) on June 8, 2015 for the inaccessibility of monitoring well MW-20 due to its location within a secondary containment structure containing storm water. Because the secondary containment structure cannot be prevented from accumulating storm water. CR/T attempted to identify an alternate location for a replacement well. A suitable alternate location could not be identified due to the presence of aboveground piping and tanks. The only potential alternate locations were in the vicinity of existing monitoring well SMW-3, located approximately 130 feet downgradient of MW-20. Groundwater monitoring results for well MW-20 have been below GWPS since 2001. In addition, groundwater results from PCC monitoring wells have decreased or remained stable. Since the groundwater plume is stable, concentrations in monitoring well MW-20 have been below GWPS since 2001, and a suitable alternate monitoring well location does not exist, CR/T recommended abandoning monitoring well MW-20 and relying on SMW-3 for Corrective Action Program (CAP) groundwater monitoring in the Response to NOV letter dated July 7, 2015. In a letter dated July 8, 2015, EPD indicated that the responses adequately addressed the NOV and that a permit modification must be submitted and approved to remove well MW-20 from the Permit. The EPD NOV letter, CR/T responses to the NOV, and EPD response are provided in Attachment 1.

The Permit also requires post-closure care (PCC) consisting of groundwater monitoring at former Hazardous Waste Management units (i.e., Tanks T-56/T-57). As described in the 2015 Annual Groundwater Monitoring Report, the Appendix IX groundwater sampling of monitoring well MW-41 conducted on August 19, 2015 identified naphthalene, 2-methylphenol, and phenol. Confirmation groundwater sampling was conducted on October 15, 2015 and EPD was notified of the Appendix IX detections on November 11, 2015. Naphthalene, 2-methylphenol, and Phenol are not included in the current PCC groundwater monitoring program. As a result, CR/T recommended adding analysis of naphthalene, 2~methylphenol. and phenol for to the PCC groundwater monitoring programs.

Class 3 Permit Modification

CR/T submits the Class 3 permit modification as described below….