NC0080853_Fact Sheet_20190102

Fact Sheet
NPDES Permit No. NCO080853
Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: July 13, 2017
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2" a species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Nokia of America Corporation/ Salem Business Park Remediation Site
Applicant Address:
600 Mountain Avenue, Murray Hill, NJ 07974
Facility Address:
3370 Lexington Road, Winston-Salem, NC 27107
Permitted Flow:
0.302 MGD
Facility Type/Waste:
MINOR Industrial; 100% industrial
Facility Class:
Grade I Physical/Chemical Water Pollution Control System (PCWPCS)
Treatment Units:
Extraction wells, feed -water equalization, bag filtration, low profile air
stripper, granular activated carbon (as backup)
Pretreatment Program (Y/1)
N
County:
Forsyth
Region
Winston-Salem
Briefly describe the proposed permitting action and facility background.• Nokia of America Corporation
has applied for an NPDES permit renewal at 0.302 MGD for the Salem Business Park Remediation Site.
The facility has a primary Outfall 001. The DWM incident number for this facility is NCD003213907.
Page 1 of 8

2. Receivim, Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — UT to Salem Creek
Stream Segment:
12-94-12-(4)
Stream Classification:
C
Drainage Area (mi2):
0.4
Summer 7Q10 (cfs)
0.05
Winter 7Q10 (cfs):
0.13
30Q2 (cfs):
0.14
Average Flow (cfs):
0.4
TWC (% effluent):
90%
303(d) listed/parameter:
ListedBenthos
Subject to TMDL/parameter:
No
Subbasin/HUC:
03-07-04; 03040101
USGS Topo Quad:
C18SW
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of January 2014 through July 2018.
Table 1. Effluent Data Summary Outfall. 001
Parameter
Units
Average
Max
14ifn
Permit
Limit
Flow
MGD
0.07
0.09
0.001
MA 0.302
TSS
mg/1
3.58
5
< 2
DM 30.0
Oil and Grease
mg/l
5.22
15
5
Trichloroethene
µg/1
0.82
1.5
< 0.5
Tetrachloroethene
µg/l
2.83
6.8
< 0.5
DM 17.0
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
Page 2 of 8

4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within 1 mg/l of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: Instream monitoring is not required in the permit.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (YIN): NO
Name of Monitoring Coalition:
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported no limit
violations from June 2013 to June 2018.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 18 of 18 quarterly chronic toxicity tests from March 2014 to June
2018.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in February 2016 reported that the facility was in compliance.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, W.
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): N/A
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/1 for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: N/A
Page 3 of 8

Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/1(summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/l (acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: N/A
Reasonable Potential Analysis _((RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between March 2014
and March 2018. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitorin-: The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Tetrachloroethene
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitorin : The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: Trichloroethene
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA
Page 4 of 8

If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Slieet for fieshii ater/s,.7ltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testine Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Minor Industrial facility, and a chronic WET limit
at 90% effluent will continue on a quarterly frequency.
Mercin Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-20/o of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL
value of 47 ng/l.
Describe proposed permit actions based on mercury evaluation: The facility is not known to discharge
mercury.
Other TMDL/Nutrient Mann ement Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: N/A
Other W BEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: Per a 2005 email
exchange between the Permittee and the Division, there is reason to believe 1,4-Dioxane is in the
groundwater treated at the facility. The value discussed in 2005 is far below the NC protective value of 80
ug/L for class C waters. However, the facility is approximately 13 miles from the Yadkin River, which is
designated as WS-IV waters. Water supply waters have an NC protective value of 0.35 ug/L for 1,4-
Dioxane. The attached preliminary calculations indicate, based on the 2005 value of 8.2 ug/L, 1,4-
Dioxane presence is not likely to negatively affect downstream waters. However, to better understand the
level of concern for this contaminant in the facility's discharge, quarterly monitoring of 1,4-Dioxane
coinciding with chronic toxicity monitoring has been added to the permit. Monitoring for 1,4-Dioxane
shall be conducted using EPA Method 624.1. During the next renewal, the parameter may be removed if
no reasonable potential to exceed water quality standards is shown.
Page 5 of 8

If applicable, describe any special actions (HQW or ORW) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC2H. 0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A 2-year compliance schedule
is proposed for meeting the new tetrachloroethene effluent limit. Annual milestones are included for this
Special Condition.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226 for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not wlicable, delete and skip to next Sectionl
Describe what this facility produces: The facility is a groundwater remediation facility.
List the federal effluent limitations guideline (ELG) for this facility: The facility is not subject to any
federal ELGs.
If the ELG is based on production or flow, document how the average production/flow value was
calculated: NA
For ELG limits, document the calculations used to develop TBEL limits: NA
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
7. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105( c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the EngineeringAlternatives
Analysis (EAA) and any water quality modeling results: NA
8. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
Page 6 of 8

9. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
10. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
11.Summary of Proposed Permitting Actions:
Table 2. Current Permit Conditions and Proposed Changes 0.302 MGD
Parameter
Current Permit
Proposed Change Basis for Condition/Change
Flow
MA 0.302 MGD
No change 15A NCAC 2B .0505
TSS
DM 30 mg/1
No change WQBEL 15A NCAC 02B WQS
Oil and Grease
Monthly monitoring
No change 15A NCAC 02B WQS
Trichloroethene
Quarterly monitoring
No requirement WQBEL 15A NCAC 02B WQS;
EPA NRWQC(HH) 2006; Based on
RPA results
Tetrachloroethene
DM 17 ug.L
MA 6.12 ug/L, WQBEL 15A NCAC 02B WQS;
Quarterly monitoring
Monthly monitoring, EPA NRWQC(HH) 2006; Based on
Compliance Schedule RPA results
Special Condition
1,4-Dioxane
No requirement
Quarterly monitoring NC Protective Value; Considered a
parameter of concern;
Facility is near WS waters
Toxicity Test
Chronic limit, 90%
No change WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 2B.0200 and
15A NCAC 2B.0500
Electronic
No requirement
Add Electronic In accordance with EPA Electronic
Reporting
Reporting Special Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 7 of 8

12. Public Notice Schedule:
Permit to Public Notice: 10/31/2018
Per 15A NCAC 2H .0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is warranted.
13. Fact Sheet Addendum (if applicable):
The following comments were received from AECOM on behalf of Nokia of America Corporation on
November 28, 2019:
Comment: "Alcatel Lucent USA Inc." and "Alcatel -Lucent" should be replaced by "Nokia of America
Corporation" throughout the permit due to a corporate merger that occurred on January 1, 2018.
Response: The final permit has been altered to reflect the ownership change.
Comment: The list of treatment system components should be updated to remove Granular Activated
Carbon (GAC).
Response: As the facility employs its GAC as a back-up, the component will remain listed. Indication of
the component being a back-up has been added to the description.
Comment: No schedule is provided for annual effluent monitoring of 1,4-dioxane, which is a new
monitoring requirement. AECOM proposes to conduct this monitoring in March of each year.
Response: Monitoring for 1,4-dioxane shall be conducted quarterly. Reference to annual monitoring in
the draft cover letter was a typographical error and should be disregarded.
Comment: As the 61 tetrachloroethene (PCE) data point in the RPA is a pH value, please remove it for
the final RPA calculation. The result does not affect the outcome of RPA analysis.
Response: The 61 data point has been omitted in the final calculation.
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• A component description revision was made which adds language to indicate that the granular
activated carbon (GAC) is used as a back-up at the facility.
• As the facility discharges to an unnamed tributary to Salem Creek, the description of the
receiving waters has been adjusted from "Salem Creek" to "unnamed tributary to Salem Creek."
14. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
• Comments from AECOM
Page 8 of 8

►1 COM Imagine it.
►�+1��.r /� Delivered.
November 28, 2018
Mr. Nick Coco
Water Quality Permitting
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Comments on the Draft NPDES Permit Renewal
Permit NCO080853
Salem Business Park Remediation Site
Nokia of America Corporation (Former Alcatel -Lucent Facility)
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Coco:
AECOM
1600 Perimeter Park, Suite 400
Morrisville, NC 27560
T 919.461.1100
F 919.461.1415
aecom.com
On behalf of Nokia of America Corporation (Nokia), AECOM prepared this letter to summarize Nokia's
comments on the draft National Pollutant Discharge Elimination System (NPDES) permit issued on
October 31, 2018 for the groundwater treatment system (GWTS) operating at the site.
Comment #1— Permit Cover Sheet (page 1 of 8)
"Alcatel -Lucent USA Inc." and "Alcatel -Lucent" should be replaced with "Nokia of America Corporation"
throughout the permit due to a corporate merger that occurred on January 1, 2018.
Comment #2 — Supplement to Permit Cover Sheet (page 2 of 8)
The list of treatment system components should be updated to remove Granular Activated Carbon (GAC).
In April 2017, AECOM discovered a leak in the bottom of the GAC tank and shut -down the GWTS.
AECOM notified the North Carolina Division of Water Resources (DWR) of the problem in a letter dated
May 4, 2017. The letter stated that Nokia was considering eliminating the GAC since the air stripper is
capable of treating water to below permit limits and the GAC did not provide further significant reductions
of PCE. The letter also inquired about whether a permit modification would be required to eliminate the
GAC. AECOM was advised by DWR that no permit modification was required. The GWTS resumed
operating in May 2017 without the GAC unit.
A new GAC unit was installed in August 2017, which currently serves as a back-up unit that can be used
when higher than normal VOC concentrations are anticipated.
Comment #3 — Condition A. (1.) — Annual Monitoring Requirement for 1,4-Dioxane (page 3 of 8)
No schedule is provided for annual effluent monitoring of 1,4-dioxane, which is a new monitoring
requirement. AECOM proposes to conduct this monitoring in March of each year.
Comment #4 — Reasonable Potential Analysis Calculations
The 'data' sheet in the Reasonable Potential Analysis (RPA) calculation workbook contains a data entry

AECOM
error. Data point #6 for tetrachloroethene (PCE), dated April 27, 2015, is a pH value. PCE was not
analyzed in April 2015, so this data point should be removed from the data set. This results in a lower
maximum predicted effluent concentration, but does not change the calculated PCE discharge limit
because the maximum predicted effluent concentration (7.5 micrograms per liter [µg/L]) is still greater than
the allowable effluent concentration (6.12 µg/L).
If you have any questions or need additional information, please contact Erin Stewart at [phone].
Yours sincerely,
Erin Stewart, PG
Project Manager
Attachments
cc: Gary Fisher — Nokia of America Corporation
A& -
John Moran
Environmental Engineer
Comments on the Draft NPDES Permit Renewal
Permit NCO080853 2/2

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Coco, Nick A
From:
Sent: � VC
To:
Cc:`
Subject:�'�'
Ms. Stewart,
Weaver, John <[e-mail]>
Tuesday, November 27, 201810:28 AM
[e-mail]
Coco, Nick A, John C Weaver
Response from USGS concerning... Re: (EXTERNAL] streamflow statistics
In response to your inquiry about the low -flow characteristics (7Q10, 30Q2, W7Q10, 7Q2) for an unnamed tributary to
Salem Creek at Winston Salem in central Forsyth County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate previous low -
flow determinations for the lat/long coordinates (36.055208 //-80.230861) provided via your email dated November 14,
2018. However, the low -flow files do indicate previous low -flow determinations at nearby locations within this Salem Creek tributary
basin, based on transfer of flow characteristics from nearby index sites.
No USGS discharge records are known to exist for the point of interest.
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at ungaged locations
are determined by assessing a range in the low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby sites where
estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(http://water.usgs.gov/osw/streamstats/north caro ) indicates the drainage area for the point of interest (36.05519, -
80.23081 NAD83) is about 0.05 sgmi.
For streams in Forsyth County, low -flow characteristics published by the USGS are provided in two reports:
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available
at http://Pubs.usgs.gov/wsp/2403/report.pdf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sgmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online
at http://Pubs.usgs.pov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration
statistics for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum
of 10 climatic years discharge records were available for flow analyses.
Inspection of the two reports indicates the presence of eight nearby selected USGS partial -record sites (6) and
continuous -record streamgages (2) in general vicinity of the point of interest where low -flow characteristics were
published. Among these 8 sites, the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0.08 to 0.28 cfsm (average about 0.15 cfsm, median about 0.14 cfsm)

Annual 30Q2 low -flow yields =_> from 0.2 to 0.51 cfsm (both average and median about 0.33 cfsm)
Winter 7Q10 low -flow yields =_> from 0.16 to 0.38 cfsm (average about 0.27 cfsm, median about 0.28 cfsm)
Annual 7Q2 low -flow yields ==> from 0.16 to 0.42 cfsm (both average and median about 0.26 cfsm)
Average annual discharge yields ==> from 0.9 to 1.24 cfsm (average about 1.03 cfsm, median about 1 cfsm)
Application of the above range in yields to the drainage area (0.05 sgmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 discharges =_> from 0 to 0.01 cfs (both average and median about 0.01 cfs, rounded down to zero flow)
Annual 30Q2 discharges =_> from 0.01 to about 0.03 cfs (both average and median about 0.02 cfs)
Winter 7Q10 discharges =_> from about 0.01 to 0.02 cfs (both average and median about 0.01 cfs, rounded down to
zero flow)
Annual 7Q2 discharges ==> from about 0.01 to 0.02 cfs (both average and median about 0.01 cfs, rounded down to zero
flow)
Average annual discharge ==> from 0.05 to 0.06 cfs (both average and median about 0.05 cfs)
Notes:
(1) The extremely low magnitudes of the above estimated low -flow characteristics reflect the very small drainage area
for the point of interest.
(2) The USGS does not provide estimates of the 1Q10 discharge within the scope of standard responses to low -flow
requests. However, because the estimated 7Q10 discharge is zero flow, the estimated 1Q10 discharge mathematically
defaults to zero flow.
(3) Please note that because your site is located in the vicinity of downtown Winston-Salem, it should be acknowledged
the effects of development on low -flow characteristics in urban basins have not been formally studied by the USGS for
North Carolina. There has been discussion within the hydrologic community that development may reduce low -flow
characteristics because increases in impervious areas reduce the available surface area where infiltration of runoff can
occur, thereby reducing the available base flow to streams during extended dry periods.
(4) Please note that I have cc:ed Mr. Nick Coco, N.C. Department of Environmental Quality, whom you identified in
your email request dated November 12, 2018
Please understand the information provided in this message is based on a preliminary assessment and considered
provisional, subject to revision pending further analyses.
Hope this information is helpful.
Thank you.
Curtis Weaver
J. Curtis Weaver, Hydrologist, PE Email. icweaveriMusas.aov
USGS South Atlantic Water Science Center Online. hMm://www.usas.aov/centers/sa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]

On Mon, Nov 12, 2018 at 8:29 AM Stewart, Erin <[e-mail]> wrote:
Curtis,
I was given your contact info by Nick Coco in the NCDEQ NPDES Permitting Unit. I manage a facility that is currently
undergoing a NPDES permit renewal. The streamflow statistics that were used to calculate the permit limits have been
the same since at least the 1999 permit. I was wondering if there are more recent data available?
The stream is an unnamed tributary to Salem Creek in Forsyth County, Winston-Salem. Site address is 3300 Old
Lexington Road. Specifically I am interested in the 7Q10s, 7Q10w, 30Q2, QA, and 1Q10s.
Please let me know if you have any questions about this request.
Thank you,
Erin
Erin Stewart, PG
Project Manager
Environment
D 919.461.1323 M 919.610.4639
AECOM
1600 Perimeter Park Drive, Suite 400, Morrisville NC 27560
T 919.461.1100
www.aecom.com

Re: Lucent Winston Salem Facility NPDES#NC0080853 ...
Subject: Re: Lucent Winston Salem Facility NPDES#NC0080853 EPS ID# NCD-003-213-907
From: Tom Belnick <[e-mail]>
Date: Fri, 29 Jul 2005 13:34:45 -0400
To: "Simpson, David" <[e-mail]>
David- based on the assumption that the 1,4 dioxane concentrations are in ug/l, we do not see any need for an NPDES permit modification at
this time. The max groundwater concentration that you reported for 1,4-dioxane of 8.2 ug/l is well below our human health criteria of 300
ug/1 for C class waters, thus we would not consider this a pollutant of concern for an NPDES discharge. It looks like the NC 2L groundwater
standard of 7 ug/l groundwater standard will present the greater environmental concern. I would recommend that you include any analytical
results for 1,4-dioxane with your next NPDES permit renewal in 2009.
Simpson, David wrote:
I have revised the text to show micrograms/liter written out, not sure what happened to the fonts in the abbreviation used in the original
email.
Sorry for any "electronic" confusion
David H. Simpson, P.G.
Geology Section Mgr - Southeast CSC
ENSR Consulting and Engineering (NC) Inc.
Raleigh, North Carolina
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616
[phone] ext. 222
[phone] fax
From: Simpson, David
Sent: Friday, July 29, 2005 10:50 AM
To: '[e-mail]
Cc: Stephenson, Greg
Subject: Lucent Winston Salem Facility NPDES#NC0080853 EPS ID# NCD-003-213-907
As requested in our telephone conversation this morning, I am providing you with the following information regarding recent
sampling conducted at this site.
At the request of Mr. Billy Meyer, the NCDENR-HWS Case Manager for this site, ENSR Consulting and Engineering (NC),
Inc. (ENSR) sampled the following wells and submitted those samples for laboratory analysis to detect the presence of
1,4-Dioxane: extraction wells VOC-1 and EW-15, and monitoring wells: C-2, MW-2A, C-5, and MW-18A. The sampling
event was conducted on June 13, 2005, and the results were reviewed to determine whether 1,4-Dioxane is present in
groundwater at concentrations above the NC 2L standard of 7 micrograms/liter.
The results of the laboratory analysis of the groundwater samples were provided in a report submitted to Billy Meyer on July
18, 2005. 1,4-Dioxane was not detected in two of the monitoring wells, C-2, C-5, nor was it detected in extraction well
VOC-1. Detection limits were 3.3 mg/I - micrograms/liter for analyses performed on each of these samples. 1,4-Dioxane
concentrations were recorded in groundwater samples collected from extraction well EW-15 (8.2 mg/L - micrograms/liter)
and monitoring wells MW-18A (6.2 mg/L-micrograms/liter), and MW-2A (5.1 mg/L-micrograms/liter).
David H. Simpson, P.G.
Geology Section Mgr - Southeast CSC
ENSR Consulting and Engineering (NC) Inc.
Raleigh, North Carolina
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616
[phone] ext. 222
of 2 7/29/2005 1:37 PM

Re: Lucent Winston Salem Facility NPDES#NC0080853
[phone] fax
[e-mail]
N.C. DENR/DWQ/NPDES
919-733-5083,ext_ 543
of 2 7/29/2005 1:37 PM

2014 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Project Information
❑CHECK IF HQW OR ORW
Facility Name
WWTP/WTP Class
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
Data Source(s)
❑CHECK TO APPLY MODEL
Salem Business Park Remediation Site
I
NCO080853
001
0.302
UT to Salem Creek
C
0.05
0.13
0.14
0.40
0.04
Trichloroethene and tetrachloroethene are NC 02B
Standards.
Follow directions for data entry. In some cases a
comment menu list the available choices or a
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Par20
Par21
Par22
Table 2. Parameters of Concern
Name Type Chronic Mobfier Acute PQL Units
Trichloroethene
C
30
HH
pg/L
Tetrachloroethene
C
3.3
HH
pg/L
Salem Business Park Remediation Site RPA, input
12/20/2018

REASONABLE POTENTIAL ANALYSIS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Trichloroethene
Values" then "COPY"
. Maximum data
points = 58
Date Data
BDL=1/2DL
Results
3/19/14
0.64
0.64
Std Dev.
0.3737
1
6/4/14
0.96
0.96
Mean
0.7650
2
9/3/14 <
0.5
0.25
C.V.
0.4884
3
12/3/14
0.98
0.98
n
18
4
3/31/15
0.54
0.54
5
6/1/15
1
1
MultFactor=
1.3300
6
9/9/15
1
1
Max. Value
1.500 Ng/L
7
12/7/15
1.5
1.5
Max. Pred Cw
1.995 Ng/L
8
3/7/16
0.63
0.63
9
6/6/16
1.3
1.3
10
9/7/16
1
1
11
12/5/16
0.8
0.8
12
1/18/17 <
0.5
0.25
13
3/17/17
0.57
0.57
14
6/16/17
1.1
1.1
15
9/14/17 <
0.5
0.25
16
12/5/17 <
0.5
0.25
17
3/16/18
0.75
0.75
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Tetrachloroethene
Values" then "COPY"
. Maximum data
points = 58
Date Data
BDL=1/2DL
Results
3/19/14
2.6
2.6
Std Dev.
1.3986
6/4/14
1.6
1.6
Mean
2.5972
9/3/14
1.7
1.7
C.V.
0.5385
12/3/14
2.4
2.4
n
18
3/31/15
2
2
6/1/15
4.2
4.2
Mult Factor =
1.3700
9/9/15
3.5
3.5
Max. Value
5.600 Ng/L
12/7/15
3.9
3.9
Max. Pred Cw
7.7 Ng/L
3/7/16
1.6
1.6
6/6/16
5.6
5.6
No detects
9/7/16
3.2
3.2
12/5/16
2.4
2.4
1/18/17
1
1
3/17/17
1.1
1.1
6/16/17
4.2
4.2
9/14/17 <
0.5
0.25
12/5/17
1.6
1.6
3/16/18
3.9
3.9
Salem Business Park Remediation Site RPA, data
1 12/20/2018

REASONABLE POTENTIAL ANALYSIS
Salem Business Park Remediation Site
NCO080853
2014 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
Qw (MGD) =
0.302
WWTP/WTP Class:
1Q10S (cfs) =
0.04
IWC @ 1Q10S =
91.58%
7Q10S (cfs) =
0.05
IWC @ 7Q10S =
90.35%
7Q10W (cfs) =
0.13
IWC @ 7Q10W =
78.26%
30Q2 (cfs) =
0.14
IWC @ 30Q2 =
76.98%
Avg. Stream Flow, QA (cfs) =
0.40
IWC @ QA =
53.92%
Receiving Stream:
UT to Salem Creek
Stream Class:
C
Outfall 001
Qw = 0.302 MGD
PARAMETER
STANDARDS & CRITERIA (2)
(1)
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
(t)
�
a.
�
z
NC WQS / Applied '/z FAV /
n # Det. Max Pred Cw Allowable Cw
Chronic Standard Acute
Acute: NO WQS
Trichloroethene
C
30 HH(QA)
ug/l
18 14
1.995
Chronic: 55.64
No RPA, Predicted Max < 50 % of Allowable Cw - No
No value > Allowable Cw
Monitoring required
Acute: NO WQS
Tetrachloroethene
C
3.3 HH(QA)
ug/l
18 17
7.7
Chronic: 6.12
RPA for non -AL - apply Monthly Monitoring with Limit
No value > Allowable Cw
Salem Business Park Remediation Site RPA, rpa
Page 1 of 1 12/20/2018

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Final 2016 Category 5 Assessments-303(d) List
EnVftW~W Yadkin River Headwaters Subbasin Yadkin -Pee Dee River Basin
QWW
Assessment Unit Name Assessment Unit Description
Assessment Unit Number Water Quality Classification Length/Area Units
Salem Creek (Middle Fork Muddy From Winston-Salem Water Supply Dam (Salem Lake) to Burke Creek.
12-94-12-(4)a C 7.5 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria Fair Benthos (Nar, AL, FW) 5
Salem Creek (Middle Fork Muddy From Burke Creek to SR1120
12-94-12-(4)b C 1.9 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria > 10% and < 90% conf Zinc (50 µg/I, AL, FW) 5e
Exceeding Criteria > 10% and < 90% conf Copper (7 jig/I, AL, FW) 5e
Exceeding Criteria Fair Benthos (Nar, AL, FW) 5
Salem Creek (Middle Fork Muddy From SR1120 to Muddy Creek
12-94-12-(4)c C 2.6 FW Miles
Assessment Criteria Status Reason for Rating Parameter of Interest IR Category
Exceeding Criteria > 10% and >90 conf Zinc (50 µg/l, AL, FW) 5
Exceeding Criteria > 10% and < 90% conf Copper (7 jig/I, AL, FW) 5e
LIT to LIT to North Deep Creek From source UT to North Deep Creek
12-84-1-(0.5)ut14ut13
1.6 FW Miles
Assessment Criteria Status
Reason for Rating Parameter of Interest
IR Category
Exceeding Criteria
FCB 5in30 GM >200 or >2 Fecal Coliform (GM 200/400, REC, FW)
5
YADKIN RIVER
From Reddies River to Mulberry Creek
12-(38)b
C
3.3 FW Miles
Assessment Criteria Status
Reason for Rating Parameter of Interest
IR Category
Exceeding Criteria
> 10% and < 90% conf Copper (7 jig/I, AL, FW)
5e
YADKIN RIVER
From a point 0.2 mile upstream of Big Bugaboo Creek to a point 0.9 mile
upstream of mouth of Elkin Creek (River)
12-(47.5)
WS-IV
9.7 FW Miles
Assessment Criteria Status
Reason for Rating Parameter of Interest
IR Category
Exceeding Criteria
> 10% and < 90% conf Zinc (50 µg/I, AL, FW)
5e
3/23/2018 Final 2016 NC Category 5 Assessments Page 180 of 196

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United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type
Inspector Fac Type
1 L 2 15 I 3 I NCO080853 Ill 121 16/02/10 I17 18 t Sj
19 L G j 201 I
21III1 I I I I I III 1 I I I 1 I I I I I I I I I I I I I I I I I
III I I I I I r6
I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
Reserved
67 70IJ 71 I I 72 LLJ ti j 731 I 174 75I Ill I I I I80
I I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:OOPM 16/02/10
09/07/01
Salem Business Park remediation site
3370 Lexington Rd
Exit Time/Date
Permit Expiration Date
Winston Salem NC 27107
02:0013M 16/02/10
14/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Gregory Martin Stephenson/ORC/336-784-2716/
Name, Address of Responsible Officialffitle/Phone and Fax Number
Contacted
Fred Bleachinger,3370 Lexington Rd Winston Salem NC 27107//336-784-2716/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement M Operations & Maintenance Records/Reports
Self -Monitoring Program 0 Facility Site Review 0 Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signatures) of Inspector(s) Agency/OfficelPhone and Fax Numbers
Date
Ron Boone WSRO WQ//336-776-9690/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
31 NC0080853 I� � 1 2I 16/02/10 7 8 I C I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please refer to the attached inspection summary letter.
Page#

Permit: NCOD80853 Owner - Facility: Salem Business Park remediation site
Inspection Date: 02/10/2016 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
M
❑
application?
Is the facility as described in the permit?
M
❑
❑
❑
* Are there any special conditions for the permit?
❑
❑
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
Is the inspector granted access to all areas for inspection?
❑
❑
❑
Comment: None
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
■
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
' ❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Page# 3

Permit: NCO080853 Owner - Facility: Salem Business Park remediation site
Inspection Date: 02110/2016 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑
Comment: None
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? M ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑
Comment: None
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
M
❑
❑
❑
Is flow meter calibrated annually?
M
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment: Yes
Laborato"
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
0
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
M
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
❑
❑
Comment: None
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
M
❑
Is sample collected below all treatment units?
M
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
❑
❑
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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Celsius)?
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Permit: NC0080853
Inspection Date: 02/10/2016
Effluent Sampling
Owner - Facility: Salem Business Park remediation site
Inspection Type: Compliance Evaluation
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: None
Yes No NA NE
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