HomeMy WebLinkAboutNC0086088_Regional Office Physical File Scan Up To 9/10/2020r
f.a
Water Resources
ENVIRONMENTAL QUALITY
January 13, 2016
Erika Mau
SKF USA Inc
PO Box 352
Lansdale, PA 19446
SUBJECT: Compliance Evaluation Inspection
Girmes Site remediation
Permit No: NCO086088
Buncombe County
'-3 PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Director
Dear Ms. Mau:
.Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on
December 29, 2015. The facility appeared to be in compliance with permit NC00.86088.
Please refer to the enclosed inspection report for observations and comments. If you or your staff have any
questions, please call me at 828-296-4500. .
Sincerely,
a .. 6 ✓ c.
Linda Wiggs
Environmental Senior Specialist
Asheville Regional Office
Enc. Inspection Report
cc:. MSC 1617-Central Files -Basement
)%&heuill'e Files
G:\WR\WQ\Buncombe\Wastewater\Industrial\SKF Girmes 86088\CEI.Dec2015.Ltr.docx
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. Highway 70 Swannanoa, NC 28.778
828 296 4500
F
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
• Water-Gompliance 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
spector Fac, Type
2 1,5 1 3 NCoo86088 ill 121 15112/29 17 18 1 e, 1 19 I G I, 20.1
L
21[
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA -Reserved--
671
70 71 [_j 72 L�j 73 Lj I I I I I 1 180
_j 74 751
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 NPIDES permit Number)
10:O0AM 15/12129
15112/01
Girmes Site remediation
Exit Time/Date
Permit Expiration Date
Old US Hwy 74 E
Asheville NC 28806
11:00AM 15112129
20/10131
Name(s) of Onsite Representative(s)[rities(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Officialfritle/Phone and Fax Number
Erika H Mau,PO Box 352 Ldnsdale PA 19446/Manager of Sustainability/267-436-6933/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas.evaluated)
Permit Operations & maintenance E Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Linda S Wiggs ARO WQ#828-296-4500 Ext.4653/
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# 1
NPDES yr/mo/day Inspection Type 1
31 Nco086098_ I11 12 15/12/29 17 1a
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Met with Mark Swan (operator) onsite.
The GW remediation system remains inactive. However, all components observed during the
inspection appear to be in good condition.
The current owner of this property is Highland Brewing Company.
Page# 2
Permit: NCO086088 Owner - Facility: Giames Site remediation
Inspection Date: 12/29/2015 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? N ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ M ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted anew 0❑ ❑ ❑
application?
Is the facility as described in the permit? M ❑ ❑ ❑
# Are there any special conditions for the permit? ❑ ❑ N ❑
Is access to the plant site restricted to the general public? ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑
Comment: Anew permit was issued October 2015.
pH was added to the effluent parameters.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ❑ ❑ ❑
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? ❑ ❑ ❑
Comment: The_remediation system remains inactive, there is no discharge.
Page# 3
/Ro
North Carolina Department of Environmental Quality
Pat McCrory Donald R. van der Vaart
Governor
_ Secretary
Divis r of W� f Re D cep J'
October 19, 2015
Ms. Erika H. Mau, Manager of Sustainability N 0 V — 5 2015
EHS Department
SKF USA Inc. ; ` Water ouality Regional Operations
890 Forty Foot Road Ache,,-ille Re, ionai c5 fice
P.O. Box 352
Lansdale, PA 19446-0352
Subject: Issuance of NPDES Permit Renewal
Permit No. NCO086088
Girmes Site Remediation
Buncombe County
Facility Class PC I
Dear Ms. Mau:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October
15, 2007 (or as subsequently amended).
No changes were made to the draft permit sent to you on August 26, 2015. The final permit
authorizes the SKF USA Inc. to discharge wastewater from Girmes Site Remediation to Gashes
Creek, a class C water in the French Broad River Basin. The permit includes discharge limitations
or monitoring for flow, total suspended solids (TSS), pH, trichloroethene, 1,2 dichloroethene, and
vinyl chloride.
As identified previously, the renewal permit contains the following significant changes from
your current permit:
• In accordance with Class C Water Quality Standards [15A NCAC 02B .0211], a pH effluent
limitation of "Not less than 6.0 nor greater than 9.0 Standard Units" with a monitoring
frequency of quarterly was added to section A. (L).
• The requirement to begin reporting discharge monitoring data electronically using the NC
DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to
your NPDES permit. [See Special Condition A.(3.)]
For information on eDMR, registering for eDMR and obtaining an eDMR user account, please
visit the following web page: http://portal.nedenr.org/web/wq/admin/bog/ipu/edmr.
For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the
following web site: http://www2.epa.gov/compliance/proposed-npdes-electronic-re ortiri -rule.
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone:919-707-8600 \ Internet: www.ncdenr.gov
An Equal Opportunity \Affirmative Action Employer— Made in part by recycled paper
Some of the wording has changed in Special Condition A. (2.), Chronic Toxicity Permit Limit,
please review each paragraph carefully.
The Division recognizes that the _ Permittee is currently conducting semi-annual monitoring of
groundwater (MW-05, MW710, and MW-21), pore water (PW-06, PW-07, PW-10, and PW-11), and
surface water (SW-02, SW-63, SW-04, and SW-08) near Gashes Creek. The Permittee shall submit
all semi-annual monitoring results with its next permit renewal application.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have -the right to an adjudicatory hearing upon written request within thirty
(30) days 'following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water
Resources or any other Federal, State, or Local governmental permits that may be required.
If you have questions concerning this permit, please contact Yang Song by e-mail
(yang.song@ncdenr.gov) or phone at (919) 807-6479.
Sincerely,
Jay Zi rman, P.G.
Director, Division of Water Resources
Enclosure: NPDES Permit NC0086088
cc: NPDES Unit
Central Files
As eu�TJe Re�'g �o'� al[G+ ffi ,e7/ Wa-%er Q�ua1�ir �y grog
e-copy:
Susan Meadows, Aquatic Toxicity Branch
Dan O. Madison, Engineer/Environmental Consultant, TRC
David Ramey, Hydrogeologist, Inactive Hazardous Sites Branch
F,
Permit NC0086088
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
SKF USA, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Girmes Site
12 Old Charlotte Highway
Asheville
Buncombe County
to receiving waters designated as Gashes Creek in the French Broad River Basin in accordance with effluent
limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, and III hereof.
The permit shall become effective ............................................... December 1, 2015.
This permit and the authorization to discharge shall expire at midnight on October 31, 2020.
Signed this day...................................................................... October 19, 2015.
Vec
y Zimmermakff.& Itor, Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 6
Permit NC0086088
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As
of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge fiom this facility arises under the pen -nit conditions, requirements,
teens, and provisions included herein.
SKIP USA, Inc. is hereby authorized to:
1. Continue to operate an existing 0.108 MGD groundwater remediation facility that includes the
following components:
➢ Air stripping unit
➢ Parshall flume
➢ Effluent diffuser
This facility is located at the Girmes Remediation Site, 12 Old Charlotte Highway, Asheville NC,
Buncombe County; and
2. Discharge from said treatment works through Outfall 001 into Gashes Creek, a Class C water in the
French Broad River Basin, at the location specified on the attached map.
Page 2 of 6
Permit NC0086088
PART
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
a. Beginning on the effective date of this pen -nit and lasting until expiration, the Permittee is authorized to
discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored' by the
Pennittee as specified below:
EFFLUENT
CELARACTERISTICS
EFFLUENT
LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type'
Sample
Location
Flow 2
0.108 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
Quarterly
Grab
Effluent
Trichloroethene (µg/L)
Quarterly
Grab
Effluent
1,2 Dichloroethene (µg/L)
Quarterly
Grab
Effluent
Vinyl Chloride (µg/L)
Quarterly
Grab
Effluent
pH
Not less than 6.0 nor greater
than 9.0 Standard Units
Quarterly
Grab
Effluent
Chronic Toxicity 3
Quarterly
Grab
Effluent
Footnotes:
1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically
using NC DWR's eDMR application system. See Special Condition A.(3.).
2. Flow may be measured using a totalizing flow meter. If no discharge during the month, report "No Discharge" on
Monthly DMRs.
3. Chronic Toxicity (Ceriodaphnia) limit at 15% with testing in January, April, July and October (see A. (2)).
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
c. Quarterly samples for monitored parameters shall coincide with the chronic toxicity test.
Part I, Page 3 of 6
Permit NC0086088
A. (2) CHRONIC TOXICITY PIERMIT (LIMIT (Quarterly)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 15 %.
The permit holder shall perform at a minimum, quarterlX monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or subsequent versions
or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or
subsequent versions. The tests will be performed during the months of January, April, July and October.
These months signify the first month of each three-month toxicity testing quarter assigned to the facility.
Effluent sampling for this testing must be obtained during representative effluent discharge and shall be
performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the. two
following months as described in "North Carolina Phase H Chronic Whole Effluent Toxicity Test
Procedure?' (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, NC 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after
the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the
address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will.be
required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter,
which is the three month time interval that begins on the first day of the month in which toxicity testing is
required by this pen -nit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
Part I, Page 4 of 6
Permit NC0086088
A. (3) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify
that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations
will be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this permit
(Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
I. Reporting [Supersedes Section D. (2.) and Section F. (5) (a)1
Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting
discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report
(eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted
electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and
submit DMRs electronically using the internet. Until such time that the state's eDMR application is
compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be
required to submit all discharge monitoring data to the state electronically using eDMR and will be required
to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the
computer printed eDMR to the following address:
NC DEQ / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being
physically located in an area where less than 10 percent of the households have broadband access, then a
temporary waiver from the NPDES electronic reporting requirements may be granted and discharge
monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by
the Director. Duplicate signed copies shall be submitted to the mailing address above.
Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in
writing to the Division for written approval at least sixty (60) days prior to the date the facility would be
required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months
and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the
permittee re -applies for and is granted a new temporary waiver by the Division.
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http://poital.ncdenr.org/web/wq/admin/bog/ipti/edmr
Part I, Page 5 of 6
Permit NC0086088
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11, Section
B. (11.)(a) or by a duly authorized representative of that person as described in Part 11, Section B. (I I.)(b). A
person, and not a position, must be delegated signatory authority for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and
login credentials to access the eDMR system. For more information on North Carolina's eDMR system,
registering for eDMR and obtaining an eDMR user account, please visit the following web page.
http://portal.nedenr.or web/wq/admin/boiz/ipu/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the
following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE
ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of
nay knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations. "
3. Records Retention [Supplements Section D. (6.)l
The peimittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These
records or copies shall be maintained for a period of at least 3 years from the date of the report. This period
may be extended by request of the Director at any time [40 CFR 122.41).
Part I, Page 6 of 6
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SKF USA, Inc. - Girmes Site
8-Digit HUC:
06010105 Latitude:
35' 34' 09" N
Receiving Stream: Gashes Creek Longitude:
82' 29' 59" W
Stream Index:
6-78-21 River Basin:
French Broad
Stream Class:
C Sub -Basin:
04-03-02
Facility Location
not to scale
NPDES Permit NCO086088
North Buncombe County
NPDES Pen -nit Standard Conditions
Page 1 of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual AverajZe
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
colifonn, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
Version 1110912011.1
NPDES Permit Standard Conditions
Page 2of18
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWR or "the Division"
The Division of Water Resources, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Version 1110912011.1
NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Resources.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
pen -nit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any pen -nit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the pen -nit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a pen -nit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
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imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class Il penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in pen -nit conditions on 'Bypassing" (Part H.C.4), "Upsets" (Part II.C.5) and 'Power Failures"
(Part H.C.7), nothing in this pen -nit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthennore, the Pennittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 15013-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this pen -nit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Penmittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Pennittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Si ng ator,y Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recominendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, infonnation, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
7 certijy, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations. "
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Pennittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1,. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class 11, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Pennittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Pertmittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Pennittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Pennittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during nonnal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
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(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affnnative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part 11.13.2. of this permit.
c. Burden of proof [40 CFR 122.41(n)(4)]: The Pennittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Pennittee shall notify the Pen -nit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.410)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1. 1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other. reports required herein, shall be submitted to the following address:
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NC DENR / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908 or http://portal.nedenr.org/web/wq/lab/cert) for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Perinittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
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7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.611 or state statute.
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5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at (800) 662-7956, (800) 858-0368 or (919) 733-3300.
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215. 1 (b)(2) or in Section 309 of the Federal Act.
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11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that primarily collect or treat municipal or domestic wastewater and have
an average annual flow greater than 200,000 gallons per day shall provide an annual report to the Permit Issuing
Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The report shall summarize the
performance of the collection or treatment system, as well as the extent to which the facility was compliant with
applicable Federal or State laws, regulations and rules pertaining to water quality. The report shall be provided no
later than sixty days after the end of the calendar or fiscal year, depending upon which annual period is used for
evaluation.
The report shall be sent to:
NC DENR / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-3941, no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
c. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
detennine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART Id
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and 0) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903 (b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
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All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the pen -nit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any infonnation shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
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3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.440)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment ProZrams
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.440)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
Industrial Waste Survey(IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.440)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a smnmary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Pennittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Pennittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
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enforceable Pretreatment Standards as defined by 40 CFR 403,.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate,standard and special
conditions, and compliance schedules as necessary for the installation of treatment. and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which sunvnarizes the results of'the HWA and the limits
from all IUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the. HWA. [15'A NCAC 02H .0906(b)(6), .0909, .0916,, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtQ
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an A#C, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (.1UP) limitations. [15A NCAC. 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)]
7. POTW Inspection & Monitoring of their Ws
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable. pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SATs) at least once per calendar year;
b. Sample all Significant. Industrial Users (SIUs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke,the designation as non-
significant.
8. IU Self ]Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring, and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(ii); 40 CFR
122.440)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standard's
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (E'RP) approved by the Division. ['15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
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NC DENR / Division of Water Resources / Water Quality Permitting Section
Pretreatment, Emergency Response, and Collection Systems (.PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative.
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment, requirements;
b. Pretreatment Program Summary(PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (S1Us). 'These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director:
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (lUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the.
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(o)]
13.. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [15A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Progams
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 1110912011.1
30 Patewood Drive
Suite 300
j Greenville, SC 29615
F
864.281.0030 PHONE RECEIVED
864.281.0288 FAx o�;��° Z� /DENR/DWR
r
J t�.
www.tresolutions.com ��' APR 3 0 2015
April 28, 2015
p Water Quality
Permitting Section
Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Permit Renewal
SKF USA, Inc. — Girmes Site Remediation NCO086088
Buncombe County
Dear Mr. Thedford:
TRC Environmental Corporation (TRC) has been retained by SKF USA Inc. (SKF) to
operate and maintain the SKF — Girmes Site Groundwater System in Buncombe County
near Asheville, North Carolina per an approved Corrective Action Plan (CAP). The
system began discharging treated groundwater on March 4, 1998. Groundwater is
recovered using three groundwater recovery wells, treated in an air stripper, and
discharged under the site's NPDES permit. The receiving stream is Gashes Creek,
which was classified in 1997 as a "Class C" tributary of the Swannanoa River in the
French Broad River basin. The recovery system was taken off-line in November 2009.
If site conditions change, there may be a need to put the recovery system back on-line.
Therefore, SKF is requesting renewal of this NPDES permit (NC0086088).
Since the system began operation in 1998, there have been no instances where the
concentration of a permitted parameter exceeded the limit specified in the current
NPDES permit. In fact, no volatile organic compounds (VOCs), which are the
parameters of concern at this site, were detected in any of the effluent samples collected
in at least the last two years of operation.
Operating History
As groundwater recovery operations continued, the volume of water recovered
declined to an average of approximately 42,000 gallons per day (gpd) in 2009, prior to
taking the system off line. Also, the concentration of VOCs in the recovered
groundwater decreased. When recovery operations began in March 1998, the influent
trichloroethene (TCE) concentration was approximately 2,900 parts per billion (ppb),
but declined to approximately 300 to 400 ppb. In an effort to increase VOC removal, in
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Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
April 28, 2015
Page 2
November 2002, the system began operation in a pulsed pumping mode, with the
recovery system in operation for six to seven weeks, then shut down for the remainder
of the quarter. The pulse pumping cycles started in the beginning of January, April,
July, and October of each year. When the pulsed pumping mode of operation was
initiated, the concentration of TCE in the influent increased to approximately 1000 ppb.
Pulse pumping continued through the last quarter of 2009, when in October the influent
concentration of TCE was 338 ppb. Additionally, the amount of TCE removed by the
recovery system declined over the last four years of its operation where over 80 pounds
of TCE was removed in 2007 and 22 pounds of TCE were removed during 2009. The
recovery system has been off-line since mid -November 2009 and may remain off-line
pending results of periodic monitoring at the site and Gashes Creek.
An evaluation of the effectiveness of the recovery system was conducted prior to the
system being shut down in November 2009. This evaluation included reviewing the
groundwater sampling data collected from the recovery wells and monitoring wells
situated adjacent to Gashes Creek. Using flow data for Gashes Creek, TRC performed
an initial calculation to estimate VOC concentrations that could be present in
groundwater without contravening a surface water standard. The concentration of TCE
that could potentially discharge into the creek while protecting the surface water
standard was significantly higher than the VOC concentrations detected in
groundwater near the creek. Periodic monitoring of select monitoring wells near
Gashes Creek, surface water and pore water along Gashes Creek is conducted to
evaluate any possible changes in the impact of the groundwater on Gashes Creek. If
groundwater VOC concentrations increase to a point that water quality standards in
Gashes Creek are threatened, the recovery system may again be put back on-line hence
the need for a renewed NPDES permit.
Other Requirements
Per the instructions for NPDES renewal packages, we are including the following
additional information:
■ United States Geological Survey (USGS) topographical site location map
(Attachment 2) indicating the location of the outfall diffuser.
■ A summary of analytical results for January, April, July, and October 2009 (see
Table 2, Attachment 1), the last four sampling events prior to taking the system off
line. Please note that these months include results for VOCs, TSS, and chronic
toxicity.
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Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
April 28, 2015
Page 3
Since this facility does not generate sludge or other treatment residue, a sludge
management plan has not been developed for the SKF — Girmes Site. A signed
statement regarding sludge management is presented in Attachment 4.
SKF has designated Mr. Dan O. Madison, TRC as their Authorized Representative to
prepare this permit renewal package. Mr. Madison also retains delegated signatory
authority for NPDES DMR forms for this site. Documentation of this authorization is
presented in Attachment 5.
We appreciate your efforts to work with us to develop an appropriate permit for the
SET — Girmes Site Groundwater System and look forward to discussing the permit
renewal with you. If there are any questions, please call me at (864) 234-
9329/dmadison@trcsolutions.com or Mr. William McGlocklin at SKF at (267) 436-
6930/William.c.mcglocklin@sfk.com.
Sincerely,
TR nvironmental Corporation
Dan O. Madison, PG
Project Manager
Attachments
cc: Mr. William McGlocklin, SKF
\\NTAPA-GMVILLE\GVL-VOL5\-\WPGVL\Pf1 M0000\2015\0002\L2000002015-001.DOCX
Attachment 1
Tables
\ \NTAPA-GRNVILLE\GVL-VOL5\-\ WPG VL\PJT2\200000\2015\0002\L2000002015-OO1.DOCX
RECEIVED/DENR/DWR
APR 3 0 2015
Water Quality
Permitting Section
Table 1
Summary of Current NPDES Permit Limitations
PARAMETER
LIMITS
FREQUENCY
Flow
0.108 mgd
Continuous
TSS
30 mg/L
Monthly
TCE
MR0)
Quarterly
1,2-Dichloroethene (DCE)
MR
Quarterly
Vinyl chloride (VC)
MR
Quarterly
Toxicity (Chronic Value)
ChV at 15%
Quarterly
(1) Elevated detection limit.
Table 2
Summary of Maximum Observed Values for 2009
PARAMETER
JANUARY
APRIL
JULY
OCTOBER
Flow, average — mgd
0.046
0.045
0.046
0.045
TSS — mg/L
<1
<2
<5
<251
TCE — Ng/L
<1
<1
<1
<1
1,2-DCE — Ng/L
<1
<1
<1
<1
VC — Ng/L
<1
<1
<1
<1
VOCs by 601
ND0)
ND0)
ND0)
ND0)
Toxicity (Chronic Value)
ChV>60%
ChV>60%
ChV>60%
ChV>60%
Volatile halocarbons by Method 601 were not detected in the effluent at the detection limit of 1 Ng/L (2 Ng/L for
chloromethane and methylene chloride)
\ \ NTAPA-GRNVILLE \ GVL-VOL5 \-\ WPGVL \ PJT2\200000 \ 2015 \0002\L2000002015-001.DOC X
Attachment 2
USGS Location Map
\ \NTAPA-GRNVILLE\GVL-VOL5\-\ WPGVL\PJT2\200000\2015\0002\L2000002015-OO1.DOO(
TRC - GLS
'11i 1 f . ' "
.i)') �"�;`P `ij .l; ..t\''� `-�i �-�`r �/� •� -.1 ':i(. - ' �' )!l�;1 ki1 . • � i. - `�
�,-�-.Jr �p D .t�.. �'/�rl.C'' '•1' �/� .� li�`��� j�� �' - � ■i1�C1 I —_��-
• y \ C' ,� � K' �� _ } 1 �� S ►, Y_ r.•` .• UrSP- - 1 , �t-� I 14 ;' .•il:�. - -
` '\ -�'� = �� �;a;� t--R\O� � - - s ;� "'s��• a erly , �-• '`.�: � 0 ��_, 4JJ' •, ` fs �.L.
- . � ���,r, �\.,;' Y�: .'r—�, } ss. �� to �� . •�(�---
r `ii �j r �,61,�tr+�.i ��i�';.• 1U G 1 ;a eti 1 n j • y' • c . /
� _ t� �,.• /1//� %iJ � nurse / �i— 0 � .
Fil
J•. , � !�� • � �• � 1 ��\ Imo/ ���/�'' / 1 �' °� � ,�' • Uv/ r�ra�/
V� • j\ �.`�...� irk -� pi ) ; r-:` ,fs� �O - � 4 1 /�^• ;
-Y� \� Ian✓/{i� s'i-q` /F i� E 136 1 .
,205 Q.
r villaa tea- L : ° _ SITE LOCATION 9M N•5'i
Vk
OUTFALL 0
-�/``f �� �sy�• .Sr' • � 1. ,S-' �� ��--��\ � / ��h�"1��. `-•/,�� - •�;I ='r �,- ��
�}^I •• � > � •`��', ' '+r �$ 1 t `% 1 II '��'// '� .-�TI� �c/ � ` � `l \ � r � �/ IL�' C v - �
�1� � (\�`� �\��\�� ��� , +u• �•� \I. -` ;--� �` •�✓ = � �^ _/lam! ,n ` `y`t�i 5� � II � .
�1 5 `, f�`ISI`Ie �" {\ • l:_�f ' + :'j �\ 1�, �; • J; g�'/' ! I i 6' .•� NORTIfCAKOI INA,
State Grid: Asheville/Oteen ` Latitude: 35° 34' 09" N I'4 ''. ,'�wr
E85E/E95W Longitude: 82' 29' 59" W
,.,,"� SITELOCATION. �^
Receiving Stream: Gashes Creek Drainage Basin: French Broad �'� G• 1i -f ✓��
Stream Class: C Sub -Basin: 04-003-02 , •' *-
BASE MAP FROM USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE SERIES.
2,000' 0 2,000 4,0000-ts,
1:24,000 FEET - - ---
DRAWN BY: AMF
�) � SKF USA, INC. -GRIMES SITE
I ASHEVILLE, SOUTH CAROLING APPROVED BY: JMK
TI \
PROJECT NO: 200000.2015
Patewood Plaza One, Suite 300
Greentville,, SC 29616 SITE LOCATION MAP FILE N0. S!bLoc.mxd -
Phone: 864.281.0030
DATE: APRIL 2015
Attachment 3
NPDES Permit Renewal
Short Form C-Gw
\ \ NTAPA-GRNV ILLE \ GV L-VOL5 \-\ WPG VL\ Pf T2\200000 \ 2015 \ 0002 \ L2000002015-OO1.DOCX
NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number INCO086088
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
SKF USA, Inc.
Facility Name
Girmes Site Remediation
Mailing Address
SKF USA, Inc., 890 Forty Foot Road, PO Box 352
City
Lansdale
State / Zip Code
PA, 19446
Telephone Number
(267)436-6930
Fax Number
(267)436-6023
e-mail Address
william.c.mcglocklin@skf.com
2. Location of facility producing discharge:
Check here if same as
above ❑
Street Address or State Road off Old Highway 74 East
City
Asheville
State / Zip Code
NC, 28803
County
Buncombe
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name
SKF USA Inc.
Mailing Address
890 Forty Foot Road, PO Box 352
City
Lansdale
State / Zip Code
PA, 19446
Telephone Number
(267)436-6930
Fax Number
(267)436-6023
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Pagel of3 C-GW 03/05
NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs: 7 days per week when system is in operation
Duration:
8. Treatment System Design flow 0.108 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Gashes Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No additives are used.
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information
All applicants (including renewals):
A USGS topographical map (or copy of the relevant portion) which shows all outfalls
A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
Engineering Alternative Analysis
Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3 C-GW 03/05
XPDES PERMIT APPLICATIOZ - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
C. William McGlockUn Dir. of Environmental Affairs
Printed name of Person Signing Title
G
Signature of Applicant
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Attachment 4
Sludge Management
\ \NTAPA-GRNVILLE\GVL-VOL5\-\ WPGVL\PJT2\200000\2015\0002\L2000002015-001.DOCX
Sludge Management
SKF USA, Inc. ® Girmes Site Remediation, NPDES NCO086088
Buncombe County
The remediation system does not generate sludge or solids. It only consists of an air stripper, flume, and
effluent diffuser. Since the facility does not generate sludge or other treatment residue, a sludge
management plan has not been developed for the SKF USA Inc. - Girmes Site.
I certify that 1 am familiar with the information contained in the application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
C. William McGlocklin Director of Environmental Affairs
Name and Title Title
Signature
.2 t///
Date
Attachment 5
Authorized Representative Documentation
\ \ NTAPA-GRN VILLE \GV L-VOL5 \-\ WPG VL \ Pf I2\200000 \2015 \0002 \ L2000002015-001.DOIX
1
April 24, 2015
Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Authorized Representative
NPDES Permit Renewal
SKF USA Inc. — Girmes Site Remediation NCO086088
Buncombe County
-, I Dear Mr. Thedford:
This letter is notification that SKF USA Inc. has delegated authority for
preparation of the April 2015 NPDES Permit renewal application for
the above referenced site to Mr. Dan 0. Madison, TRC Environmental
Corporation (TRC). Mr. Madison also retains signatory authority for
NPDES DMR forms for this site.
Please contact me at 267-436-6930 if you have questions.
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
cc: Dan 0. Madison, TRC
SKF USA Inc.
890 Forty Foot Road, P.O. Box 352, Lansdale, PA 19446
Tel 267 436 6000 Fax 267 436 6033 Web www.skfusa.com
LPOWA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. C. William McGlockin
SKF USA, Inc.
Grimes Site Remediation
PO Box 352
Lansdale, PA 19446
Dear Permittee:
Donald R. van der Vaart
Secretary
April 30, 2015
Subject: Acknowledgement of Permit Renewal
Permit NCO086088
Buncombe County
The NPDES Unit received your permit renewal application on April 30, 2015. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to
complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Maureen
Kinney (919) 807-6388.
Sincerely,
W re x. Tltieol-ro�
Wren Thedford
Wastewater Branch
cc: Central Files
AFslae 11V Re- onal'Of
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-63001 Fax: 919-807-64921Customer Service: 1-877-623-6748
Internet:: www.ncwater.org
tieY�Y*e�1 ct�,e
An Equal OpportunityWffirmative Action Employer
A*4itA
rs
WDENR Y y
North Carolina Department of Environment and Natural Re
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
October 25, 2010
RETURN RECEIPT REQUESTED CERTIFIED MAIL 7007 0710 0000 5376 6726
Michael B. Parker, P.E., President
RMT North Carolina Inc.
30 Patewood Drive
Suite 100
Greenville, SC 29615-3535
Dear Mr. Parker:
es
0 CT 2 8 2010 1
Dee Freeman
L....._ ___-_._._.See-retar�,
WATER QUALITY SECTIO ,
>HEVII_LF REGiOf _U OFFICE �I
Subject: NOTICE OF VIOLATION — NOV - 2010 - LR - 0074
Grimes Site Remediation WWTP NCO086088
Buncombe County
This is to inform you that the Division of Water Quality has not received your monthly monitoring report for August
2010 after the required reporting date. This is in violation of Part ll, Condition D (2) of the NPDES permit, as well as 15A
NCAC 2B .506(a), which requires the submittal of Discharge Monitoring Reports no later than the thirtieth (30th) day
following the reporting period. Failure to submit reports as required will subject the violator to the assessment of a
civil penalty of up to $25,000 per violation. You will be considered noncompliant with the self -monitoring requirements
of your NPDES permit until the report has been submitted.
Please submit the August 2010 DMR report within 15 days of receipt of this notice if you have not yet
submitted it. To prevent further action, please submit future monthly reports within the above -mentioned
timeframe to avoid further enforcement actions.
The Division must take these steps because timely submittal of discharge monitoring reports.is essential to the
efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions
about this letter or Discharge Monitoring Reports, please contact me at 919-807-6387 or at bob.guerra(cDncdenr.gov.
Sincerely,
Bob Guerra
Western Region NPDES Unit
cc: , u as V,"ulrater,�P. fiec�o, uper�vis r Roger Edvuards
Central Files
Enforcement file
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: 919-807-6387 \ FAX: 919-807-64951 Customer Service:1-877-623-6748 NdfMaTo1111a
Internet: http://portal.ncdenr.org/web/wq/hoiTie
An Equal Opportunity 1 Affirmative Action Employer Naturally
Facility information
NPDES permit #:
I,11[�%I�%i:���:�:3
Buncombe County
Facility name: Girmes of America, Inc. - Girmes Site
(formerly: SKF USA Inc.)
Groundwater Remediation Facility
WWTP class:
I -PC
WWTP type: 0.108 MGD groundwater remediation facility.
Groundwater is recovered from three ground-
water wells and treated in an air stripping unit;
parshall flume; Isco 4210 ultrasonic flow meter;
and effluent diffuser.
Notes: This system began discharging treated groundwater on 3-4-1998 per
an approved Corrective Action Plan (CAP). Since that time, there have
been no instances of permit limits exceedances. There have been no
volatile organic compounds (VOCs) detected in any of the effluent
samples during the past two years. VOC sample results collected from
the recovery wells and monitoring wells located adjacent to the creek
have been declining over the past three years (as of 4-1-10). The
system is currently off-line, as of mid -November 2009. Just prior to
that time, a chemical oxidant injection of sodium persulfate (10%)
was done. The remediation treatment system was shut down, so that
there would be no interference with the migration path of the oxidant in
the aquifer. Monitoring and assessing is still being done to determine
if the oxidant is still persisting in the aquifer to reduce VOC levels.
Monitoring results indicate that the levels are not below NC 2L
groundwater standards yet, so the site should remain actively
permitted.
Current Average Flow: 42,000 gpd (when operating)
Permittee requests permit modification for 50,000
gpd monthly average flow limit with no maximum
flow limit (monitor & report).
WWTP location: off Old Highway 74 East; Asheville
Responsible official: C. William (Bill) McGlocklin
Responsible "'s title: Director of Environmental Affairs
Official's location: SKF USA Inc (new address Aug 2011)
Legal Department
890 Fortyfoot Road
PO Bx 352; Lansdale PA 19446-0352
Authorized Agent:
Michael B. Parker, P.E., now: TRC Solutions
(formerly: RMT North Carolina, Inc.)
(RMT owned by TRC Solutions as of 6-6-2011)
(send inspection letters to Michael)
30 Patewood Drive; Suite 100;
Greenville, SC 29615-3535
Phone numbers
864-234-9462
Michael B. Parker, P.E; Project Manager, TRC
(email: mparker@tresolutions.com)
864-281-0030
main number —Ashley
864-281-0288
" - fax
864-281-0030
Greg Mitchell, P.E., Project Engineer, TRC
610-630-2730
Bill McGlocklin — SKF USA Inc.
610-230-2780
" — fax (has environmental liability for the site)
828-776-3302 cell
Mark Swann — PACE Laboratories
828-254-7176
PACE Laboratories — Charlie Billings, Manager
828-298-5030
" — fax (PO Box 9097; AVL, NC 28815)
864-234-9437
Dan O. Madison, Professional Geologist
Greg Darnell, TRC; does groundwater monitoring
Beth Roland, TRC; coordinates GW monitoring
828-258-6919
Billy Clark, Attn — Roberts and Stevens - Asheville
Operator information
ORC contractor: Mark Swann — Cert. # 28897 — PC -I
Back-up ORC: Robert Barr — Cert. # 28151 — PC -I
Permit information
Date issued: 12-1-2005
Expiration date: 10-31-2010
New expiration date:
Currently under review: James McKay
Stream information
Stream:
River basin:
Sub -basin:
Hydrologic Unit Code:
Quad:
Grid:
Stream classification:
Drainage area sq mi:
Instream Waste Conc.:
Chronic Toxicity Conc.:
Average stream flow:
Summer 7Q10 cfs:
Winter 7Q10 cfs:
30Q2 cfs:
C iia'&17V 0r,1 -
Gashes Creek
French Broad River Basin
04-03-02
Asheville / Oteen, NC
E9SW/E8SW
C
n/a
90%
15% Ceriodaphnia dubia
(quarterly: January, April, July & October)
n/a
0
n/a
n/a
Notes: The old SKF USA Inc. manufacturing site building
is now owned by Blue Ridge Motion Pictures.
Highlands Brewery leases the facility. Bill
McGlocklin, SKF USA Inc. has environmental
liability for the site and remediation project.
The site is 40 acres and the total building area is
180,000 sq ft. There are 80,000 sq ft long term
leases in place (Highlands Brewery).
Blue Ridge Motion Pictures; 12 Old Charlotte
Highway; Asheville, NC 28803
Email: info(aD-blueridgemotionpictures.com
Business:(828) 296-1499
Directions: Exit right off of 1-240 Hwy at the River Ridge
Shopping Center exit. At the stop light, turn right
onto Fairview Road (Hwy 74). Go straight (past
Burger King). Turn right (at the DOT turn-off)
onto Old Charlotte Hwy. Follow the sign to Blue
Ridge Motion Pictures. Go to the top of the hill,
past the water tank. The remediation project site
is on the right.
Notes: Ad placed for the sale of Blue Ridge Pictures:
Tuesday, July 7, 2009
I have a "turn -key" business for sell. There is
around $700,000. +/- of inventory and or
equipment to sell for $ 250,000. Also, I'm
interested in selling the Land (40 acres) and total
building (180k sq ft). Currently 80k sq ft have long
term leases in place. Both can be bought for
$3,350,000.00 dollars. If you wish to stay in the
location now occupied by BRMP (80K sq ft, from
the construction Department to the front offices)
without buying the building, we can work
something out. The Red Camera, 35 MM, 3 Apple
Final Cut Pro computers, Sound Equipment, Grip
and Lighting is included in that price. Please call
me if you are interested or you have any ideas
you wish to share! Feel free to email this to other
possible interested parties!
Leanne M. Campbell
603.493.0805
lean nemcampbell(a-comcast. net
Job sites in Asheville where Asbestos Exposure Occurred
Asheville, North Carolina
Notes: Originally named Morristown, the city of Asheville is the largest city
in western North Carolina and serves as county seat of Buncombe County.
The county seat was appointed in 1793, and was established on a plateau
where two Indian trails crossed. In 1797, Morristown became an
incorporated city and was renamed Asheville after North Carolina Governor,
Samuel Ashe.
Since its early days, Asheville's location in the Blue Ridge Mountains at the
confluence of the Swannanoa River and French Broad River attracted
settlers to the area. By the late 19th century, Western North Carolina
Railroad, Richmond and Danville Railroad Company, and Southern Railway
reached the city. The railroads led to a boom in Asheville's textile and
business flourished with companies like Enka Textile Mill and Asheville
Cotton Mills leading the way. Petroleum businesses operated facilities in
Asheville as well, including Humble Oil & Refinery and Asheville Oil
Company. Today, Asheville's economy is supported by the major industries
of manufacturing, healthcare, and tourism. Largest employers in the area
are Buncombe County Schools, Ingles Markets, and Mission Health Care
Systems.
Use of asbestos containing products has been an issue in Asheville for
many years. Workers exposed to asbestos products in the manufacturing
and industrial settings may be at risk to develop mesothelioma, a form of
cancer.
Job sites in Asheville where Asbestos Exposure Occurred:
A number of jobsites in Asheville, NC have been identified as harboring asbestos
containing materials. These sites, at one point in their history, were known to have
exposed a variety of tradesmen to asbestos.
Alexander Perry Construction
American Enka Corp
Asheville Cotton Mills
Asheville Electric Company
Asheville Steel Company Incorporated
Beacon Manufacturing
Biemann and Rowell Company
Boling Chair Company
Carolina Power and Light
Carolina Truck & Body Company
Champion Paper Company
Citizens Heating Company
Colonial Baking Company
Drexel Enterprises
Drexel Furniture
Enka Textile Mill
Farnam Manufacturing Company
General Services Administration
Girmes of America
Gordon Furniture Company R & S
Hicks Corp
Humble Oil & Refinery
Hyatt Electric Company Incorporated
Enka High School
Enka Rayon Plant
Kearfott Inc.
Moser Plumbing Company
Public Service Company of NC
R & E Gordon Furniture Company
Rogers Plumbing & Heating
SKF Industries, Incorporated
Sayles Biltmore Bleacheries Inc
SKF Inc.
Skyland Powerhouse (? - CP&L / Progress Energy)
Southern Bell Telephone Company
Storage Supply Company
Permit number NCO086088
Program Category
NPDES WW
Permit Type
Industrial Process & Commercial Wastewater Discharge
Primary Reviewer
james.mckay
Coastal SW Rule
Permitted Flow
108000
Central Files: APS SWP
07/26/11
Permit Tracking Slip
Status Project Type
In review Renewal
Version Permit Classification
Individual
Permit Contact Affiliation
Facility
Facility Name Major/Minor Region
Girmes Site remediation Minor Asheville
Location Address County
Old US Hwy 74 E Buncombe
Asheville NC 28806 Facility Contact Affiliation
Owner
Owner Name Owner Type
SKF USA Inc Non -Government
Owner Affiliation
C William McGlocklin
PO Box 332
Dates/Events Kulpsville PA 194430332
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
07/21 /97 04/26/10
Regulated Activities Reguested/Received Events
Groundwater remediation Region comments on draft requested
Region comments on draft received
Outfall 001
Waterbody Name Stream Index Plumber Current Class Subbasin
Gashes Creek (Cedar Mountain Lake) 6-78-21 C 04-03-02
Preprint: Proceedings of the Fourth International Conference on the Remediation of Chlorinated and Recalcitrant Compounds (2004)
Novel Activation Technologies for Sodium Persulfate In Situ Chemical Oxidation
Philip A. Block (philip_block@ mc.com) (FMC Corporation, Philadelphia, PA)
Richard A. Brown (dick.brown@erm.com) (ERM, Inc., Ewing, NJ
David Robinson (david.robinson@erm.com) (ERM, Inc., Ewing, NJ)
ABSTRACT: Persulfate oxidation chemistry is an emerging technology for�the in situ
chemical oxidation of chlorinated and non -chlorinated organics. Activation of persulfate
to form sulfate radicals is a potent tool for the remediation of a wide variety of
contaminants, including chlorinated solvents (ethanes, ethanes and methanes), BTEX,
MTBE, 1,4-dioxane, PCB's and PAH's. Several new activation technologies now exist
to catalyze the formation of sulfate radicals, including persulfate combined with chelated-
metal complexes, persulfate combined with hydrogen peroxide and alkaline Tpersulfate.
The breadth of activator systems allows for the proper choice of persulfate technology for
given contaminants and site conditions.
Introduction
Persulfates (specifically dipersulfates) are strong oxidants that have been widely
used in many industries for initiating emulsion polymerization reactions, clarifying
swimming pools, hair bleaching, micro -etching of copper printed circuit boards, and TOC
analysis. In the last few years there has been increasing interest in sodium persulfate as
an oxidant for the destruction of a broad range of soil and groundwater contaminants.
Persulfates are typically manufactured as the sodium, potassium, and ammonium salts.
The sodium form is the most commonly used for environmental applications.
The persulfate anion is the most powerful oxidant of the peroxygen family of
compounds and one of the strongest oxidants used in remedia_tion. The standard
oxidation — reduction potential for the reaction
S208-2 + 2H+ + 2e- -4 2HSO4 Equation 1
is 2.1 V, as compared to 1.8 V for hydrogen peroxide (H2O2) and 1.4 V for the
peroxymono sulfate anion (HSOS). This potential is higher than the redox potential for
the permanganate anion (Mn04) at 1.7 V, but slightly lower than that of ozone at 2.2 V.
In addition to direct oxidation, sodium persulfate can be induced to form sulfate
radicals, thereby providing free radical reaction mechanisms similar to the hydroxyl
radical pathways generated by Fenton's chemistry. The generation of sulfate radicals is
Sz 08 2 + initiator -4 SO:- + (SO;- or SO4 2) Equation 2
The sulfate radical is one of the strongest aqueous oxidizing species with a redox
potential estimated to be 2.6 V, similar to that of the hydroxyl radical, 2.7 V.
In addition to its oxidizing strength, persulfate and sulfate radical oxidation has
several advantages over other oxidant systems. First, it is kinetically fast. Second, the
sulfate radical is more stable than the hydroxyl radical and thus able to transport greater
distances in the sub -surface. Third, persulfate has less affinity for natural soil organics
than does the permanganate ion (Brown 2003) and is thus more efficient in high organic
soils. These attributes combine to make persulfate a viable option for the chemical
oxidation of a broad range of contaminants.
Conventional Persulfate Activation
In the early 1960's, a significant body of work examined the kinetics and
mechanisms associated with persulfate oxidation (House, 1962 and Haikola, 1963).
While the persulfate anion by itself was found to be a strong oxidizer, it's reaction rates
are kinetically slow for the more recalcitrant contaminants, such as trichloroethylene.
However, the kinetics of persulfate oxidation can be significantly enhanced by the
generation of sulfate radicals.
Sulfate radical initiation (Equation 2) can be achieved through the application of
heat, transition metal catalysts or UV radiation. These processes are reviewed in several
references (House, 1962; Behrman, 1980; Balazs, 2000). With transition metal
activation, Balazs points out that while the mechanism is dependent on catalyst type,
organic substrate and oxidant concentration, the rate equation can be generally stated as:
d [Sz 08 2 ] / dt = —k[Sz 08 2 ]x [catalyst]'' Equation 3
where % < x < 3/2 and 0 < y < 3/2. This suggests that the reaction rate is independent of
the contaminant loading. Several recent patents have specifically disclosed the activation
of persulfate for the oxidation of organic contaminants by either heat or transition metals.
Pugh (1999) discusses both metal catalysis and heat activation, at temperatures above
200C, to oxidize organic contaminants. Hoag (2000, 2002) discusses divalent metal
catalysis and the application of heat in the range of 40 to 990C to oxidize VOCs. This
body of literature basically leads one to conclude that the effective use of persulfate for
environmental applications necessitates the use of either heat activation of the addition of
iron II.
In the laboratory, heat -activated persulfate has been
demonstrated in aqueous systems to be applicable to a wide
range of contaminants. The activation temperature required
varies by compound. Table 1 lists the oxidation of various
compounds as a function of temperature. At 45 °C and above
all the compounds tested were oxidized. Bruell (2001) has
shown that heat -catalyzed persulfate oxidation of organics in
a soil environment requires higher temperatures than in
aqueous systems:
For activation by transition metal catalysis, ferrous
iron (Fe+2) is the most common and readily available
activator, with common forms being ferrous sulfate (FeSO4)
and ferrous chloride (FeC12). Generally, 100 to 250 mg / L
of iron is required to effectively activate persulfate.
Additions of ferrous iron in excess, greater than 750 mg / L,
can lead to the rapid decomposition of persulfate and a loss
Table 1 ,
List of Contaminants
With > 90% Decomposition Treated
with Persulfate yb 200 C
Toluene, Ethylbenzene;
Xylene; 1,1-DCE;
1,2-Dichlorobenzene;
1,3-Dichlorobenzene,
1,2,4-Trichlorobenzene
List of Additional Contaminants
With > 90% Decomposition Treated
with Persulfate 350 C
1,2-DCE, PCE, TCE,
Vinyl Chloride,
Carbon Tetrachloride,
1,1-DCA; 1,2-DCA,
Benzene, Chlorobenzene,
MTBE
List of Additional Contaminants
With > 90% Decomposition Treated
with Persulfate 450 C
Methylene Chloride, Chloroform,
1,1,1-TCA
in remediation performance. If significant amounts of reduced metals are available in the
subsurface, addition of metal catalysts may not be necessary to catalyze the persulfate.
Divalent iron activated persulfate effectively oxidizes many of the compounds
susceptible to the heat -activated persulfate, including BTEX, chlorobenzene,
dichlorobenze, DCE, TCE, and PCE. However, its effectiveness against chlorinated
ethanes, such as TCA, and chlorinated methanes, such as chloroform, is limited.
While heat and iron II activation of persulfate are effective in bench scale
oxidation studies, they both have limitations for field application. Heat activation
requires installation of a parallel heating system to heat the aquifer matrix to the desired
temperature. This entails both capital expenditures as well as additional operating
expense. The options for in situ heating include steam or hot air injection,, electrical
resistance (joule) heating, or radio frequency heating. Generally heating is best applied
for source treatment where the target area is limited. In situ heating, with an external
heating source, is impractical for treating large groundwater plumes.
The problem with the use of iron II as an activator is its transportability. Iron II is
eventually oxidized by the persulfate to iron III, which, at a pH above 4, is insoluble. The
net reaction is:
2Fe+2 +S2Os-Z -> 2Fe+3 +2SO4-z;Fe+3 + 3H20—> Fe(OH)31 + 3H+ Equation 4
Meyers (Meyers, 2002) discussed the affect of the precipitation of iron on the loss
of persulfate activation in field applications. As an example, in a pilot treatment test of
TCE with persulfate, a persulfate and iron mixture (10% sodium persulfate and 174 mg/L
of available Fe+2) was injected into a sandy silt. Nine days after the injection, a
monitoring point 1.5 M down -gradient of the injection point
was sampled, and the iron concentration was found to be 0.3 Table 2: TCE @ 7 Days
mg/L, and the TCE concentration was 9.3 mg/L: Dosing Material TCE, µg/L
Groundwater samples from the monitoring point were Control — nodose 8,700
collected and re -dosed with either iron alone or with 1 WL Persulfate 7,500
persulfate without additional iron. After 7 days the re -dosed 250 mg/L Fe' 4,240
samples were reanalyzed for TCE. The results are shown in
Table 2. Greater reduction in TCE levels was achieved when additional Fe+z was added,
as compared to when only additional persulfate was added, suggesting a lack of available
catalyst, and not oxidant, in the subsurface at the down -gradient monitoring point.
Novel Activation Technologies
Practical constraints in sulfate radical formation by heating or addition of ferrous
iron indicate a need for improved persulfate activation systems. Such technologies
should:
be transportable in a groundwater system
increase the reactivity of persulfate with a broad range of organic
contaminants
be easy to apply in a variety of subsurface conditions.
Several new persulfate activation systems have recently been developed (FMC - ERM,
2002; FMC - Orin, 2603) that address these issues. A few of these technologies use non-
metal routes to generate sulfate radicals. The following is a discussion of these novel
activators.
A. Chelated Metal Catalysts
Chelated metal catalysts are complexes of transition metals bound to strong
chelating agents. Examples of chelating agents include: ethylenediaminetetraacetic acid
(EDTA), citrate, polyphosphate, glycolic acid, catechol, nitrotriacetic acid (NTA),
Tetrahydroquinine (THQ) and others in this class of materials. Previous work
(Pignatello, 1992) demonstrated the benefit of chelated iron complexes to activate
hydrogen peroxide for the destruction of complex pesticides. Chelated trivalent iron
(Fe+3), in addition to Fe+2, was found to have excellent oxidation performance.
Laboratory tests were conducted to test the efficacy of chelated iron catalysts for
persulfate activation utilizing several different iron - chelant complexes. The best
performing complex, Fe(III) — EDTA will be highlighted for discussion purposes. All
samples were prepared as aqueous solutions in VOA bottles with zero headspace. A
standard contaminant mixture was used: twenty-eight different VOCs were dissolved in
DI water to attain individual VOC concentrations of 10-20 mg/L. The Fe-EDTA complex
was generated by reacting equimolar concentrations of ferric chloride and EDTA. The Fe
-EDTA complex was dosed to provide 550 mg / L of available iron to the solution. An
oxidant dosage level of 10 % sodium persulfate was used. Samples were taken at time
zero, and at 7, 14 and 21 days and analyzed via GC -MS. All studies were conducted at
room temperature and ambient pH.
The 21-day results
are shown in Table 3, which
compares persulfate alone
and persulfate with: iron II
(unchelated), Fe(III)
(unchelated), and Fe(III)-
EDTA. A DI water control
was also run. The table
displays the results for
different classes of
contaminants. Several
observations can be made from the data. First, none of the persulfate / iron catalysts are
effective with the chloroethanes or chloromethanes. Second, all persulfate solutions
resulted in a low pH. Third, Fe(II) was the most effective catalyst. The second best
performing catalyst was the Fe-EDTA complex. Fourth, BTEX oxidation was effective
with persulfate alone. And fifth, Fe(III), at a low pH, is a moderately effective catalyst. It
should be noted that the results in Table 3 are at a pH of 2, where metal solubility and
Table 3
Performance of Persulfate + Iron Catal sts, Ambient pH, 21-Day Results
Ng / L
Control
Persulfate
Persulfate
Fe II
Persulfate
Fe III
Persulfate
Fe III -EDTA
hloromethanes
35000
34000
29100
35000
32000
hloroethanes
50000
52000
37600
50000
48000
hloroethenes
32700
9830
0
660
0
hlorobenzenes
34800
9300
0
3100
360
BTEX
43700
1370
0
0
0
rxygenates
46000
44000
830
17600
3550
H
1 6.9
1 2.2
2.3
2.3
2.2
activity is not an issue.
Under the neutral pH conditions that may be found in the field, chelating the
transition metal catalyst provides protection from hydration and subsequent precipitation
(see Eq. 4). Table 4 shows the results for different iron catalysts with persulfate at a
controlled pH of 7-8. The experimental conditions were similar to those used to generate
Table 3, except: 1) a commercial Fe (III) -EDTA (Aldrich) was used with the dosing
level at 100 mg/L iron,
and 2) the persulfate
concentration was
2.5% (instead of 10%).
As can be seen from
Table 4, at a pH of 7 -
8, only the Fe-EDTA
catalyst with persulfate
was effective; whereas
the un-chelated iron
Table 4
Performance of Iron Catal sts with Persulfate, Controlled pH -8), 21-Da Results
N9 / L
Control
Persulfate
Ctrl pH
Fe (II)
Amb pH
Fe (II)
Ctrl pH
Fe (III)
Ctrl pH
Fe-EDTA
Ctrl pH
Ethenes
34,083
32,606
0
27,730
31,230
9,870
Ethanes
67,115
62,379
61,908
63,702
64,756
50,246
Methanes
51,983
48,180
42,261
45,597
49,664
44,900
BTEX
40,119
3,963
0
13,538
13,560
647
Chlorobenzenes
56,089
36,990
0
31 824
34,662
7,428
Oxygenates
60,908
53,923
11,639
56,444
57,187
26,931
H
6.7
8.5
2
7.5
8
7.6
catalysts had reduced activity.
The solubility and availability of the transition metal catalysts are critical factors
in the activation of persulfate. Chelation is an effective means of maintaining metal
activity at neutral or alkaline groundwater conditions.
B. Dual Oxidant System: Sodium Persulfate & Hydrogen Peroxide
Hydrogen peroxide technology, known as Fenton's reagent, has been widely
applied in treating groundwater contaminants with varying results. In general, it is highly
reactive and is able to oxidize a wide range of contaminants. However, the limitation of
peroxide is its stability in some soil matrixes, where it rapidly decomposes, limiting its
transport and effectiveness. A dual oxidant system (FMC - Orin, 2003) utilizing
hydrogen peroxide and sodium persulfate has been developed that combines the
reactivity of peroxide in the reduction of compounds of concern with the enhanced
stability of persulfate. It is hypothesized that hydrogen peroxide and persulfate may have
several synergistic attributes. First, hydroxyl radicals can initiate persulfate radical
formation. Similarly, sulfate radicals can stimulate formation of hydroxyl radicals.
Secondly, hydrogen peroxide may react with a significant portion of the more reactive
contaminants, allowing the sulfate radicals to destroy the more recalcitrant compounds of
concern. Finally, a combination of peroxide and sulfate radicals may provide a multi -
radical attack mechanism, yielding either a higher efficiency in destroying contaminants,
or allowing for recalcitrant compounds to be more readily degraded.
Initial laboratory testing by Orin
RT (FMC - Orin, 2003) was performed
by adding chlorinated solvents to an
aqueous solution at room temperature.
Two grams of sodium persulfate and 8
mL of 12.5% hydrogen peroxide were
Table 5
Degradation of Contaminants with Persulfate + Peroxide
m
Time 0
Day 8
1,1-DCE
4.5
0.1
TCE
2.8
non -detectable
1,1-DCA
1.1
non -detectable
1,1,1-TCA
12.0
0.6
added per 100 grams of contaminated
solution. Samples were taken on Day 8 and analyzed by GC -MS. Table 5 displays the
results from the study. Significant reductions were measured not only for chlorinated
ethenes, but chlorinated ethanes as well.
A second laboratory study was run using soils from an MGP site. A slurry was
made using 400 g of processed soil and 1.08 L of distilled water. Sodium persulfate was
then added to a concentration of 11.5 g/L and allowed to mix. 120 mL of 50% peroxide
was then added. The slurry was then analyzed via GC -MS. The results are pictured in
Figure 1: Oxidation of MGP Residuals
OT=O i]T=14Contro1■T 114Persulfate
Figure 1. The VOCs present
were BTEX and styrene. The
SVOCs were 3 to 5 ring
PAHs. Dicylcopentadiene
(DCPD) was present as the
major constituent. As can be
seen from Figure 1, the
combined peroxide-
persulfate system was
effective against all of these
contaminants.
Total Target VOCs TOTALTarget SVOCs DCPD
The combined
peroxide-persulfate reaction
system appears to have a broad range of applicability. It not only oxidizes compounds
generally amenable to persulfate oxidation, but also oxidizes compounds not readily
oxidized by conventional persulfate technology.
D. Alkaline Persulfate
Persulfate is known to be highly reactive at low pH (<3), but it is also highly
reactive at pH's greater than 10. It should thus be possible to "activate" persulfate by
increasing the pH to high values. Initial laboratory testing indicated the persulfate
oxidation of contaminants was not just a matter of high pH, but of the buffering capacity
as well (mole ratio of pH modifier to persulfate).
Studies were conducted in VOA vials with zero headspace. While a variety of pH
modifiers were observed to activate persulfate, KOH will be used for discussion.
Samples were prepared by adding persulfate at a concentration of 25 g/L and KOH to
achieve mole ratios of 0.2, 0.4, 0.5 and 0.8 KOH: persulfate. The samples were analyzed
after 7 days by GC -MS. A
control with no persulfate or Figure 2: Effect of KOH Ratio on Persulfate Reactivity
KOH was also run. No other gD,
catalysts were added to the 80,
samples. The activation of 70.
persulfate that was observed is BD,
SD,
solely due to the added base. m 40-
The results of these studies are ' 2o.
pictured in Figure 2. The data .0.
d b 1 f
are groupe y c ass o Crrtfl-7 D 0.2 0.38 0.5 0.8
contaminant. Mole Ratio KOH:Pers
Several observations
can be made from these results.
First persulfate reactivity increases with increasing levels of KOH. Second, there appears
to be a threshold effect in the oxidation of some chlorinated VOCs. The mole ratio needs
to be 0.4 or above for the persulfate to effectively react with the recalcitrant chlorinated
VOCs (ethanes and methanes). The effect of the amount of KOH on the oxidation of
BTEX and oxygenates (MTBE, TBA, 1,4-dioxane) is more gradual. The amount oxidized
increases with increasing KOH.
Table 6 lists the pH observed at 7 and 14 days for the
different mole ratios of KOH and persulfate. The pH
appears to have a breakpoint similar to that observed for the
reactivity. A mole ratio of 0.4 or above is needed to achieve
a pH above 10.0.
An interesting result for this study is the effect of the
alkaline pH on historically difficult to destroy compounds,
such as chlorinated ethanes and methanes. Table 7 displays
We 14 day results from the study for a
selection of compounds for two different
KOH : persulfate mole ratios. In most
cases, there was complete destruction of
these compounds
A number of conclusions can be
drawn from these studies. First, alkaline
persulfate has a broad reactivity. Second, the
alkaline activation of persulfate appears to
be possible with a number of different bases.
Each base may have a different optimal ratio
andl beak t Th' d 1 ' th
Table 6: pH versus KOH mole Ratio
Mole Ratio
pH, 7-da s
H, 14-days
0
1.3
0.5
0.2
4.3
4.5
0.38
11.5
10.4
1
11.5
10.5
L0.5
L0.8
12.2
13
Table 7: Destruction of Recalcitrant Compounds with
Alkaline Persulfate — Day 14 Results
µg / L
Control
Day 14
0.5 mol
KOH:
Persulfate
0.8 mol
KOH:
Persulfate
1,1,1-TCA
19,000
14,400
3,400
1,1,2-TCA
25,000
ND
ND
1,2-DCA
22,000
ND
ND
1,1-DCA
17,000
1,600
ND
Carbon
Tetrachloride
18,000
ND
ND
Methylene
Chloride
20,000
ND
ND
Vinyl
Chloride
195
ND
ND
ND — non detect
or r pom . lr , m app ymg e
alkaline-persulfate activator technology it is important to add sufficient base (excess
buffering capacity). The quantity of base needs to take into account any acidity in the
soil. Fourth, there are reaction pathways for persulfate that are not currently well
understood and can potentially be further optimized. The reaction of persulfate under
basic conditions is a novel technology deserving further study.
Summary
Persulfate oxidation
chemistry is an emerging
technology for the in situ
chemical oxidation of
chlorinated and non -
chlorinated organics.
Activation of persulfate to
form sulfate radicals yields a
very potent tool for the
remediation of a wide variety
of contaminants, including
chlorinated solvents (ethenes,
ethanes and methanes),
BTEX, MTBE, 1,4-dioxane,
PCB's and polyaromatic
hydrocarbons.
There now exists a
Figure 3: Choosing the Right Activator
Eveloate
Persulfate
Mild Oxidation
Alone
t
BTEX &
Evaluate
Persulfate Strong
Oxidation
tthere
Fe-EDTA
Steam Yes
Evaluate
Available &
Heated PersulfateUsable?
Persulfam-Peroxide
Hs, Styrene
No
Alkaline Persulfate
-o
.�0
xane, etc.)
Permeable Yes,[ EveloateSoils?
Persulfate-PeroxideArAlkaline
PersulfateClNoCl-s
& benzenes)
variety of chemistries from which to choose to catalyze the formation of sulfate radicals.
Choosing which activator system to use is key to maximizing the efficacy of persulfate
oxidation. Figure 3 provides a logic -flow for assessing the different activator systems.
There are three levels of persulfate activators that can be used. These include "Mild
Oxidation," in which persulfate alone is used. This may be appropriate for BTEX sites. If
MTBE is present, then the "Strong Oxidation" system, which is persulfate activated with
Fe-EDTA, is appropriate. This "Strong Oxidation" system is also appropriate for sites
with only chlorinated ethenes (PCE, TCE, DCE) or chloro-benzenes. If there are
chlorinated ethanes or methanes present that need treatment, then the "Aggressive
Oxidation" systems should be evaluated. These include the alkaline-persulfate, combined
peroxide and persulfate, and heated persulfate. These aggressive activation chemistries
may be applied also for BTEX and chlorinated ethene sites if faster remediation is
desired, or if there is a high contaminant load.
Proper evaluation of the site conditions is also needed for the effective application
of the appropriate persulfate technology. Site geology, hydrogeology, soil properties, soil
oxidant demand, and the remedial goals are all key factors to evaluate. Persulfate
technology is not a "one -size -fits -all' technology. There is a rich and varied chemistry
that can be brought to bear on a wide variety of contaminant problems.
References
Balazs, G.B., J.F. Cooper, P.R. Lewis and G.M. Adamson. Emerging Technologies in
Hazardous Waste Management 8, ed. Tedder and Pohland, Kluwer Academic /
Plenum Publishers, New York, 2000.
Behrman, E.J. and J.O. Edwards. Reviews in Inorganic Chemistry, 2, p 179 (1980)
Brown, R.A., D. Robinson and G. Skladany. "Response to Naturally Occurring Organic
Material: Permanganate versus Persulfate", ConSoil 2003, Ghent Belgium, (2003)
Bruell, C. J. "Kinetics of Thermally Activated Persulfate Oxidation of
Trichloroethylene (TCE) and 1,1,1- Trichloroethane (TCA)," The First International
Conference on Oxidation and Reduction Technologies for In -Situ Treatment of Soil
and Groundwater, Niagara Falls, Ontario, Canada, June 25-29, 2001
Elmendorf, C., F. Sessa. Poster at the 4"' Annual Batelle Conference On the Remediation
of Chlorinated and Recalcitrant Compounds, Panther Technologies and FMC
Corporation (2004)
FMC Corporation and Environmental Resources Management, patent pending
technology (2002)
FMC Corporation and Orin RT, patent pending technology (2003)
Hakoila, E. Ann. Univ. Turku, Ser A, 66, (1963).
Hoag, G.E., P.V. Chhedda, B.A. Woody and G.M. Dobbs. US Patent 6,019,548 (2000)
Hoag, G.E., P.V. Chhedda, B.A. Woody and G.M. Dobbs. US Patent 6,474,908 (2002)
House, D.A. Chem Rev, 62, p 185 (1962).
Huang, K.C., R.A. Couttenye, and G.E. Hoag. Chemosphere, 49, p 413 (2002)
Meyer, M., "Sodium Persulfate Oxidation of TCE Plume In Belgium", The Second
International Conference on Oxidation and Reduction Technologies for In -Situ
Treatment of Soil and Groundwater, Toronto, Ontario, November 19-22, 2002
Pugh, J.R., US Patent 5,976,348 (1999)
Pignatello, J.J and Y. Sun. J. 4gr. Food Chem., 40, p 322 (1992)
Permit Number NCO086088
Central -Files: APS SWP
07/26/11
Permit Tracking Slip
Program Category
Status Project Type
NPDES WW
In review Renewal
Permit Type
Version Permit Classification
Industrial Process & Commercial Wastewater Discharge
Individual
Primary Reviewer
Permit Contact Affiliation
james.mckay
Coastal SW Rule
Permitted Flow
108000
Facility
Facility Name Major/Minor Region
Girmes Site remediation Minor Asheville
Location Address County
Old US Hwy 74 E Buncombe
Asheville NC 28806 Facility Contact Affiliation
Owner
Owner Name Owner Type
SKF USA Inc Non -Government
Owner Affiliation
C William McGlocklin
PO Box 332
Dates/Events Kulpsville PA 194430332
Scheduled
Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration
07/21/97 04/26/10
Regulated Activities Reauested/Received Events
Groundwater remediation Region comments on draft requested
Region comments on draft received
Outfall 001
Waterbody Name Stream Index Number Current Class Subbasin
Gashes Creek (Cedar Mountain Lake) 6-78-21 C 04-03-02
V1r 4
A74LA.
-10
NCDENR
North Carolina Department of Environment -and Natural Resources.
Division of Water Quality.;
Beverly Eaves Perdue Charles Wakild, P. E. r -- ----- � - - --Dee-Free an,
Governor Director z .1 j� EllL V E Si cr tary; j
JA N 19 2012 1 m�J
Januaryl 1, 2012
Mr. C. William McGlocklin -- iara
Director of Environmental Affairs
SKF USA Inc. r
890 Forty Foot Road
Lansdale, PA 19446
Subject: Issuance ofNPDES Permit
Permit NCO086088
Girmes Site Remediation
Buncombe County
Class PC
Dear Mr. McGlocklin:
Division personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15,
2007 (or as subsequently amended). There are no changes from the draft permit sent to you on November
28, 2011, or from your current permit.
If any parts, measurement frequencies, or sampling requirements contained in this permit are.
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days
after receiving this letter. Your request must take the form of a written petition conforming to Chapter
150B of the North Carolina General Statutes, and must be filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demand is made,
this permit remains final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division
may modify and re -issue, or revoke this permit. Please notice that this permit does not affect your legal
obligation to obtain other permits required by the Division of Water Quality, the Division of Land
Resources, the Coastal Area Management Act, or other federal or local governments.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-807-63001 FAX: 919-807-6492
Internet: www.ncwaterguality.orq
NorthCarolina
Naturally
An Equal Opportunity \ Affirmative Action Employer
If you have questions, or if we can be of further service, please contact Jim McKay at
james.mckay@ncdenr.gov or call (919) 807-6404.
Sincerely,
Charles Wakild, P.E.
cc: Ashevilleg Re ional Office/Surface Water Protections'
_ ----- - - - - =-- -
Central Files
Aquatic Toxicity Unit - via email
TACU, James Pugh - via email
NPDES Unit
Permit NCO086088
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
SKF USA, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Girmes Site
Off Old Highway 74 East
Asheville
Buncombe County
to receiving waters designated as Gashes Creek in the French Broad River Basin in accordance with effluent
limitations, monitoring requirements, and other conditions set forth in Parts I, II,111, and IV hereof.
The permit shall become effective February 1, 2012.
This permit and the authorization to discharge shall expire at midnight on October 31, 2015.
Signed this day January 11, 2012.
�y. Charlres Wakild, P.E.
Directo
Division of Water Quality
By Authority of the Environmental Management Commission
Permit NCO086088
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As
of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements,
terms, and provisions included herein.
SKF USA, Inc. is hereby authorized to:
1. Continue to operate an existing 0.108 MGD groundwater remediation facility that includes the
following components:
➢ Air stripping unit
➢ Parshall flume
➢ Effluent diffuser
This facility is located at the Girmes Remediation Site off Old Highway 74 East near Asheville in
Buncombe County.
2. Discharge from said treatment works through Outfall 001 into Gashes Creek, a Class C water in the
French Broad River Basin, at the location specified on the attached map.
Permit NCO086088
Permit NCO086088
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Pertnittee is authorized to discharge treated
groundwater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below:
:.EFFLUENT:
CHARACTERISTICS .
EFFLUENT
LIMITATI®NS
1VI01\TITOItING-REQTIRE1VINTS
Monthly
Average
Daily
Mamum
, Measurement ; .
Frequency
Sample Type
Sample' `
Location .
Flow'
0.108 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
Quarterly
Grab
Effluent
Trichloroethene
Quarterly
Grab
Effluent
1,2 Dichloroethene
Quarterly
Grab
Effluent
Vinyl Chloride
Quarterly
Grab
Effluent
Chronic Toxicity2
Quarterly
Grab
Effluent
Notes:
1. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnia) limit at 15% with testing in January, April, July and October (see A. (2)).
There shall be no discharge of floating solids .or visible foam in other than trace amounts.
Quarterly samples for monitored parameters shall coincide with the chronic toxicity test.
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 15 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase If Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or
subsequent versions. The tests will be performed during the months of January, April, July and October. Effluent
sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment
processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months
as described in "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection
methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase H Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
(continued on next page)
Permit NCO086088
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Continued)
All toxicity testing results required as partof this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the
facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No
Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month, in which toxicity monitoring is required, monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions'as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.
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PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day: However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
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(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
➢ Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
➢ Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
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Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Ouarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
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imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class 11 penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on 'Bypassing" (Part II.CA), "Upsets" (Part II.C.5) and 'Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsiblefor
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 15013-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a.principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person.,A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.221
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
7 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information"submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations. "
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
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(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.4 1 (n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part ILE.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Representative Sampling „
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.410)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1. 1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The fast DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
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NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908 or http://portal.ncdenr.org/web/wq/lab/cert) for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
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7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
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5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at (800) 662-7956, (800) 858-0368 or (919) 733-3300.
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or, electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215. 1 (b)(2) or in Section 309 of the Federal Act.
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11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
- Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The
report shall summarize the performance of the collection or treatment system, as well as the extent to which the
facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality. The
report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon which
annual period is used for evaluation.
The report shall be sent to:
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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OTHER REQUIREMENTS
Section A. Construction
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The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) permit. Issuance of an AtC will not occur until Final Plans and Specifications for the
proposed construction have been submitted by the Permittee and approved by the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to .
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and 0) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .09.03(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
I . Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs I or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
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Section B. Publicly Owned Treatment Works (POTWs)
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and.(2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
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aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (ICJ) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.440)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.440)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.440)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the defmition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.S.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
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4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all IUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtQ
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (IUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215. 1 (a)(8)]
7. POTW Inspection & Monitoring of their IUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(0(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;
b. Sample all Significant Industrial Users (SIUs) at least once per calendar year for all SILT permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revolve the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.446)(2) and 40 CFR 403.12]
Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903 (b)(7),.0906(b)(8) and .0905; 40 CFR 403.8(f (5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
Version 1013112011
NyLirS Permit Standard Conditions
Page 18 of 18
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
NC DENR / Division of Water Quality / Surface Water Protection Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
Ns that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (Ns) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [15A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SICJs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 1013112011
a�
MCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 26, 2010
MICHAEL B PARKER PE
PRESIDENT
RMT NORTH CAROLINA INC
30 PATEWOOD DRIVE
SUITE 100
GREENVILLE SC 29615-3535
Dee Freeman
Secretary
Subject: Receipt of permit renewal application
NPDES Permit NCO086088
Girmes Site Remediation
-Buncombe County
Dear Mr. Parker:
The NPDES Unit received your permit renewal application on April 26, 2010. A member of the NPDES
Unit will review your application. They will contact you if additional information is required to complete your
permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing permit
expires.
If you have any additional questions concerning renewal of the subject permit, please contact Jeff Poupart at
(919) 807-6309.
Sincerely,
Dina Sprinkle
Point Source Branch
cc: CENTRAL FILES
A"s`h v R-eiRRegio"7n- al f /Surface Water Protection
NPDES Unit
C. William McGlocklin, Director of Environmental Affairs, SKF USA-h
Norristown, PA 19403-2403 ,
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27644
Phone: 919-807-6300 \ FAX: 919-807-6492 \ Customer Service: 1-877-623-6748
Internet: wwvv.ncwaterquality.org
An Equal Opportunity \ Affirmative Action Employer
APR 2 9 2010
WATER QUA
A�SHEVILLE RE
y;•
• ENVIRONMENT • ENERGY • ENGINEERING
Itj
•, i
April 20, 2010
Ms. Coleen H. Sullins
Director, Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application
SKF — Girmes Site
NPDES Permit No. NCO086088
Buncombe County
Dear Ms. Sullins:
RMT North Carolina, Inc. (RMT) has been retained by SKF USA Inc. (SKF) to operate and maintain
the SKF — Girmes Site Groundwater System in Buncombe County near Asheville, North Carolina per
an approved Corrective Action Plan (CAP)The system began discharging treated groundwater on
March 4,1998. Groundwater is recovered using three groundwater recovery wells, treated in an air
stripper, and discharged under the site's NPDES permit. The receiving stream is Gashes Creek,
which was classified in 1997 as a "Class C" tributary of the Swannanoa River in the French Broad
River basin.
The current NPDES permit sets discharge limitations for the parameters identified in Table 1 (see
Attachment 1). The facility is also required to monitor the effluent for toxicity once per quarter and
has a chronic value limit of 15 percent. This test uses Ceriodaphnia dubia as the test organism.
Since the system began operation in 1998, there have been no instances where the concentration of a
permitted parameter exceeded the limit specified in the current NPDES permit. In fact, no volatile
organic compounds (VOCs), which are the parameters of concern at this site, have been detected in
any of the effluent samples collected in at least the past two years of monitoring. Concentrations of
VOCs detected in the groundwater samples collected from recovery wells and monitoring wells
located adjacent to the creek have also been declining over the past three years.
L•\ WPGVL\P]1'\00-70144\53\00004\L007014453-002.DOCX
30 Patewood Drive, Suite 100 m Greenville, SC 29615-3535 ® (864) 281-0030 c (864) 281-0288 FAX • www.rmtinc.com
CREATING 13ALANCEw
Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 2
Operating History
As groundwater recovery operations have continued, the volume of water recovered has declined to
the current average of approximately 42,000 gallons per day (gpdwhen the system is in operation.
Also, the concentration of VOCs in the recovered groundwater has decreased. When recovery
operations began in March 1998, the influent trichloroethene (TCE) concentration was approximately
2,900 parts per billion (ppb), but has declined to approximately 300 to 400 ppb. In an effort to increase
VOC removal, in November 2002, the system began operation in a pulsed pumping mode, with the
recovery system in operation for six to seven weeks, then shut down for the remainder of the quarter.
The pulse pumping cycles started in the beginning of January, April, July, and October of each year.
When the pulsed pumping mode of operation was initiated, the concentration of TCE in the influent
increased to approximately 1000 ppb. Pulse pumping continued through the last quarter of 2009,
when in October the influent concentration of TCE was 338 ppb. Additionally, the amount of TCE
removed by the recovery system has declined over the past four years of its operation where over 80
pounds of TCE was removed in 2007 and 22 pounds of TCE were removed during 2009. The
recovery system has been off-line since mid -November 2009 and may remain off-line pending results
of planned periodic monitoring at the site and Gashes Creek
An evaluation of the effectiveness of the recovery system was conducted prior to the system being
shut down in November 2009. This evaluation included reviewing the groundwater sampling data
collected from the recovery wells and monitoring wells situated adjacent to Gashes Creek. Using
flow data for Gashes Creek, RMT performed an initial calculation to estimate VOC concentrations
that could be present in groundwater without contravening a surface water standard. The
concentration of TCE that could potentially discharge into the creek is significantly higher than the
VOC concentrations currently detected in the monitoring and recovery wells near the creek. Periodic
monitoring of select monitoring wells near Gashes Creek, surface water and pore water along Gashes
Creek will be conducted to evaluate any possible changes in the impact of the groundwater on Gashes
Creek. If groundwater VOC concentrations increase to a point that water quality standards in
Gashes Creek are threatened, the recovery system may again be put back on-line and a renewed
NPDES permit will be needed.
We believe that the monitoring data since 1998 show that the treatment system can easily reduce the
influent VOCs to concentrations below the detection limit. The concentration of total suspended
solids (TSS) is also well below the NPDES permit limit. Therefore, we request that the Division of
Water Quality (DWQ) consider the permit modifications that we have detailed below.
I: \ WPGVL\Pf r\00-70144\53\00004\L007014453002.DOCX
CREAT{ NG BALANCE"'
Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 3
1. Flow — The NPDES permit is currently based on the design flow of the treatment plant.
Although the permitted flow is 0.108 million gallons per day (mgd), this flow rate is much higher
than the average or maximum daily flow from the site. The average flow for the first month of
each quarter in 2009 was 0.0229, 0.0421, 0.0425, and 0.0452 mgd. Therefore, we request that the
DWQ use 50,000 gpd as the flow basis for the revised permit and include monthly average limits
of 0.050 mgd and no maximum flow limit (monitor and report).
2. TSS — The site has never exceeded the permit limit of 30 milligram per liter (mg/L) and the results
have generally been no detection. Because of the nature of the water that is being discharged, we
do not believe that there is a reasonable potential for the TSS limit to be exceeded. Although
continuing the analysis of effluent samples will not provide any useful data, we understand that
TSS limits are minimum requirements on all permits. Therefore, we request that DWQ change the
monitoring frequency for TSS to once per year.
3. Chronic toxicity testing — The toxicity testing that has been conducted quarterly since operations
began in 1998 has never indicated that the discharge may cause an adverse impact to the
receiving stream. With one exception in January 2002, all test results have been reported as a
"pass" according to the bioassay procedure. All of the definitive chronic toxicity tests that have
been run have passed at a Chronic Value (ChV) significantly greater than 15 percent. Most tests
have indicated that the ChV is greater than 60 percent. This concentration is significantly higher
than the in -stream waste concentration in Gashes Creek.
40 CFR 122.44(d)(1)(ii) addresses certain requirements when determining whether a discharge
causes, or has the reasonable potential to cause, an in -stream impact. The regulation specifies
that the State must consider existing controls on point and non -point sources of pollution; the
variability of the pollutant or pollutant parameter in the effluent; the sensitivity of the species to
toxicity testing (when evaluating whole effluent toxicity); and, where appropriate, the dilution of
the effluent in the receiving water. Additional information is provided in the Technical Support
Document for Water Quality -based Toxics Control (EPA/505/2-90-001). RMT's interpretation of
these considerations is summarized below.
— Existing controls on point sources of pollution —The nature of the SKF — Girmes Site
Groundwater System precludes the possibility of chemical spills or dumps, treatment
process upsets, or other incidents that could have an adverse effect on the effluent.
I: \ WPGVL\P]T\00-70144\53\ 00004 \ L007014453-002.DOCX
CREATING 13ALANGE'
Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 4
— The variability of the pollutants in the effluent —The chemical characteristics of the
treated effluent have been well documented since the system's start-up in 1998. NPDES
permit compliance testing has shown that VOCs of concern are not present in the
discharge. Testing for volatile halocarbons by Method 601 has confirmed that other
volatile pollutants are absent from the discharge as well. The static nature of the site
dictates that it is very unlikely that there is any significant variability in the site's
discharge.
— The sensitivity of the species to toxicity testing — The test organism (Ceriodaphnia dubia)
has been shown to be a species sensitive to a large number of pollutants.
— Dilution of the effluent in the receiving water — The discharge has an average flow rate
of 42,000 gpd. Therefore, the test concentration stipulated in the existing permit is
extremely conservative. Gashes Creek is not effluent -dominated at the location of the
effluent diffuser.
After conducting an examination of these four criteria, RMT believes that there is no reasonable
potential for the treated effluent to cause an in -stream excursion above the ambient concentration of
either a numeric or narrative stream standard. 40 CFR 122.44(d) (1) (v) states that "limits on whole
effluent toxicity are not necessary where the permitting authority demonstrates ... that chemical -
specific limits for the effluent are sufficient to attain and maintain applicable numeric and narrative
State water quality standards." We believe that chemical -specific limits for the SKF-Girmes Site are
sufficient and, therefore, we request that the DWQ remove toxicity testing from the permit.
Other Requirements
Per the instructions for NPDES renewal packages, we are including the following additional
information:
■ United States Geological Survey (USGS) topographical site location map (Attachment 2)
indicating the location of the outfall diffuser.
■ A summary of analytical results for January, April, July, and October 2009 (see Table 2,
Attachment 1). Please note that these months include results for VOCs, TSS, and chronic toxicity.
Since this facility does not generate sludge or other treatment residue, a sludge management plan has
not been developed for the SKF — Girmes Site.
I:\ WPGVL\P]r\0470144\53\00004\L007014453-002.DOCX
C R E A T I N G 8 A L A .N C E'er
Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 5
We appreciate your efforts to work with us to develop an appropriate permit for the SKF — Girmes
Site Groundwater System and look forward to discussing these issues with you. If there are any
questions, please call me at 864.234.9462.
Sincerely,
RMT North Carolina, Inc.
A�'u R, P a'
Michael B. Parker, P.E.
President, RMT North Carolina Inc.
Attachments
cc: Bill McGlocklin—SKF USA Inc.
Travis Tarbet, Britney Barnes—RMT, Inc.
Billy Clarke, Roberts and Stevens, P.A.—Asheville, NC
Roger Edwards —Division of Water Quality—NCDENR
Central Files
IA WPGVL\P]T\00-70144\53\00004\L007014453-002.DOCX
C R E AT ! N G B A LA N C E't'
Attachment 1
Tables
IA WPGVL\PJT\00-70144\53\00004\L007014453-002.DOCX
Table 1
Summary of Current NPDES Permit Limitations
PARAMETER
LIMITS
FREQUENCY
Flow
0.108 mgd
Continuous
TSS
30 mg/L
Monthly
TCE
MR(')
Quarterly
1,2-Dichloroethene (DCE)
MR
Quarterly
Vinyl chloride (VC)
MR
Quarterly
Toxicity (Chronic Value)
ChV at 15%
Quarterly
Elevated detection limit.
Table 2
Summary of Maximum Observed Values for 2009
PARAMETER
JANUARY
APRIL
JULY
OCTOBER
Flow, average — mgd
0.046
0.045
0.046
0.045
TSS — mg/L
<1
<2
<5
<25'
TCE — Ng/L
<1
<1
<1
<1
1,2-DCE — Ng/L
<1
<1
<1
<1
VC — Ng/L
<1
<1
<1
<1
VOCs by 601
ND(')
ND(')
ND(')
ND(')
Toxicity (Chronic Value)
ChV>60%
ChV>60%
ChV>60%
ChV>60%
Volatile halocarbons by Method 601 were not detected in the effluent at the detection limit of 1 Ng/L (2 Ng/L for
chloromethane and methylene chloride)
I:\ WPGVL\PJT\00-70144\53\00004\L007014453002.DOCX
Attachment 2
USGS Location Map
L\ WPGVL\PJT\00-70144\53\00004\L007014453-002.DOCX
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Attachment 3
NPDES Permit Renewal
Short ]Form C-Gw
I: \ WPGVL\ PJT\ 00-70144 \ 53 \00004 \L007014453-002.DOCX
N. C. DENR/Division of Water Quality/NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCO086088
Please print or type
Applicant and facility producing discharge
A. Name SKF USA Inc. Girmes Groundwater Site
B. Mailing address of applicant:
Contact Person Mr. C. William McGlocklin
Street address 1111 Adams Avenue
City Norristown County Montgomery
State Pennsylvania Zip Code 19403-2403
Telephone Number (610) 630-2730
Fax Number (610) 630-2780
e-mail address: william.c.mcglocklin@skf.com
C. Location of facility:
Street off Old Highway 74 East
City Asheville County Buncombe
State North Carolina Zip Code 28803
Telephone Number ( ) not applicable
Fax Number ( ) not applicable
2. Standard Industrial Classification (SIC) code(s) (if known): none
3. This application is for a: ❑ New Permit 0 Permit Renewal ❑ Permit Modification
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvent
Other (describe)
5. (a) Check here if discharge occurs all year 0, or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge occurs: 7 days per week when the system is in operation
6. Volume of wastewater discharged to receiving stream(s): 42,000 GPD*
*Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) 0
If not, state the specific discharge location:
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is the only viable means of discharge, trace
the route of the storm sewer to its discharge point(s).
L•\ WPGVL\P]T\00-70144\53\00004\L007014453002.DOCX
8. Number of separate discharge points: one effluent diffuser in Gashes Creek
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of wastewater
flow at the facility.
9. Name of receiving water(s): Gashes Creek
All application packages (including permit renewals) must include the items listed below. This
application will be returned if the required items are not included.
❑ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
❑ A summary of the most recent analytical results (effluent data, if available) containing the maximum values for each chemical
detected
New applications for proposed (not vet permitted) discharges must also include the items listed
below. This application will be returned if the required items are not included.
❑ An engineering proposal describing the remediation project in detail (required by 15A NCAC 2H.0105 (c))
❑ A report of alternatives to surface water discharge as outlined by the Division's "Guidance for Evaluation of Wastewater Disposal
Alternatives" (required by 15A NCAC 2H.0105 (c))
❑ If the treatment system will discharge to a storm sewer, attach written approval from the municipality responsible for the sewer.
❑ A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for each
chemical (the most recent sample must be collected less than one year prior to the date of this application)
❑ A summary of analytical results containing the maximum values for each chemical detected
❑ The removal efficiency of each compound detected (if known)
For petroleum -contaminated sites, analyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel
additives likely to be present at the site should also be performed. At minimum, analyses should be performed for the following
compounds:
benzene* toluene* ethylbenzene* xylene* lead methyl tent-butylether (MTBE)
dibromoethane (EDB) 1,2-dichloroethane isopropyl ether napthalene phenol
(*an EPA -approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or other contaminants, an EPA Method 624/626 analysis should be performed.
I certify that I am familiar with the information contained in the application and that to the best of
my knowledge and belief such information is true, complete, and accurate.
C. William McGlocklin Director of Environmental Affairs
Printed name of Person Signing Title
.22//0
Signature of Applicant "' Date /
North Carolina General Statute 143-215.6B (i) provides that:
Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other
document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be
guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both.
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment for not more than 5 years, or both,
for a similar offense.)
G`\I17NNT\PROFILES\UKPCWM\LOC{BLS-1\TEW\NOTE561C35C\L007014453-001(2).DOCX
O�0� W A , QG Michael F. Easley
� WO Governor
CO r ®DENR William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
'� _--- -- ---Alan_W. Klimek, P.E., Director
1 Division'of-Water Quality
I_ November 14, 2005 �4 ! N' 0IV 2 - J
Mr. C. Williams McGlocklin
SKF USA, Inc. v,r•,,T 01 AJ_n-Y SECTION I
P•SH� \ iLLr= rif_ iONAL OFFICE i
1111 Adams Ave. -- -
Norristown, PA 19403 �—
Subject: Issuance of NPDES Permit NCO086088
Girmes Site Remediation
Buncombe County
Dear Mr. McGlocklin:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
This final permit includes the following major changes from the draft permit sent to you on
September 28, 2005:
• The sample type for Chronic Toxicity and TSS has been changed from Composite to Grab to correct an
error. Grab sampling for these parameters is consistent with the previous permit.
• The monitoring frequency for TSS has been reduced to Quarterly based on review of the DMR data.
The Division has also reviewed requests SKF submitted as a response to the Draft Permit and the Division's answers
are summarized below:
1). TSS monitorin&. The Division cannot grant your request to remove TSS monitoring. As explained in the Draft
Cover Letter, the TSS limit is one of the minimum requirements even in General Permits for groundwater
remediation. It is also a parameter that indicates the effectiveness of treatment system operation. The fact that you
have never discharged measurable quantities of TSS indicates that system is effectively removing solids from the waste
stream. In addition, this parameter also influences turbidity in the stream and has to be monitored to prevent
violations of the water quality standard for turbidity. Therefore, TSS monitoring cannot be removed. However, based
on the DMR review the sampling frequency for TSS has been reduced to quarterly.
2). Chronic Toxicity. The Division cannot grant your request to remove Chronic Toxicity testing. In accordance with
15A NCAC 2B.0508, toxicity test limits are applied to discharges of complex wastewater. Treated groundwater is
considered a complex waste due to the presence of organic chlorinated solvents. All permittees that have an individual
NPDES discharge permit for groundwater remediation have a Whole Effluent Toxicity Requirement.
3). Flow adjustment. The Division can change the flow limit in the permit only upon receipt of an official request
from the permittee for a Permit Modification. The permit writer cannot arbitrarily adjust the flow limit during each
permit renewal based on a "value representative of present operation". Flow rates can vary widely from month to
month and from year to year and depend on weather, operational conditions at the site, changes in the topography,
N. C. Division of Water Quality / NPDES Unit Phone: (919) 733-5083
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: (919) 733-0719
Internet: h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623-7748
and other factors that are too numerous to mention. If SKF USA, Inc. would like to change the flow limit in the
permit, please send us an official request for Permit Modification. If your request is granted, the Division will adjust
the concentration for chronic toxicity testing accordingly.
Please remember that changes in the permit might have to go through a public comment period. Please also consider
the fact that if your request is granted and the flow limit is lowered, any subsequent exceedences of the flow limit
would be considered violations of the Permit, and may be subject to fines, notices of violations and/or third party law
suits.
4). Address in the Fact Sheet. The correction has been made.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this permit, please contact Sergei Chernikov at telephone number
(919) 733-5083, extension 594.
Sincerely,
Alan W. Klimek, P.E.
cc: Central Files
NPDES Permit File
Asheville_Regianal-Office/Sizrfice Water Pfdtection�
Aquatic Toxicology Unit
Mr. Jeffrey A. Friend
RMT North Carolina, Inc.
30 Patewood Drive, Suite 100
Patewood Plaza One
Greenville, SC 29615
Permit NCO086088
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
. DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental.
Management Commission, and the Federal Water Pollution Control Act, as amended,
SKF USA, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Girmes Site
Off Old Highway 74 East
Asheville
Buncombe County
to receiving waters designated as Gashes Creek in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, and IV hereof.
The permit shall become effective December 1, 2005.
This permit and the authorization to discharge shall expire at midnight on October 31, 2010.
Signed this day November 14, 2005.
- ;�' an W. Klimek, P.E.
`T�irPrtnr
Division of Water Quality
By Authority of the Environmental Management Commission
Permit NCO086088
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked. As of this permit issuance, any previously issued permit bearing this
number is no longer effective. Therefore, the exclusive authority to operate and discharge
from this facility arises under the permit conditions, requirements, terms, and provisions
included herein.
SKF USA, Inc. is hereby authorized to:
1. Continue to operate an existing 0.108 MGD groundwater remediation
facility that includes the following components:
➢ Air stripping unit
➢ Parshall. flume
➢ Effluent diffuser
This facility is located at the Girmes Site remediation off Old Highway
74 East near Asheville in Buncombe County.
2. Discharge from said treatment works through Outfall 001 into Gashes
Creek, a Class C water in the French Broad River Basin, at the
location specified on the attached map.
Permit NCO086088
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized
to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
r.EFFLUENT
;CHARACTERISTICS
w- -
;EFFLUENT
LIMITATIONS
MONITORING REQUIREMENTS
k
Monthly
, Average ;
Daily v
Maximum
Measurements `
Frequency
Sample Type
h
Sample
Location
Flow'
0.108 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
Quarterly
Grab
Effluent
Trichloroethene
Quarterly
Grab
Effluent
1,2 Dichloroethene
Quarterly
Grab
Effluent
Vinyl Chloride
Quarterly
Grab
Effluent
Chronic Toxicity2
Quarterly
Grab
Effluent
Notes:
1. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnia) limit at 15% with testing in January, April, July and October (see
A. (2)).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Quarterly samples for monitored parameters shall coincide with the chronic toxicity test.
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 15 %.
The permit holder shall perform at a minimum, quarterlu monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
(continued on next page)
Permit NCO086088
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP313 for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3
(original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the
report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to
the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
State of North Carolina
Department of Environment
and .Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
September 28, 2005
Mr. C. Williams McGlocklin
SKF USA, Inc.
II11 Adams Ave.
Norristown, PA 19403
Dear Mr. McGlocldin:
17 ;WIA
4 • •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Draft NPDES Permit
Permit NCO086088
Girmes Site Remediation
Buncombe County
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefullyto ensure
thorough understanding of the conditions and requirements it contains.
The draft permit contains no significant changes from your current permit
The Division of Water Quality has reviewed your request to remove TSS monitoring from the permit[ :The
request cannot be granted since TSS limit is one of the minimum requirements in General Permits ;for•'
groundwater remediation, it is also a parameter that indicates effectiveness of treatment system operation.: i, i.,
As for Chronic Toxicity testing, in 15A NCAC 2B.0208 the Division is mandated to protect waters from toxic impacts.
Further, toxicity test limits are applied to discharges of complex wastewater as per 15A NCAC 2B .,.0508. The
minimum monitoring frequency for toxicity testing is defined as quarterly.
Please submit any comments to me no later than thirty days following your receipt of the draft. Comments should be
sent to the address listed at the bottom of this page. If no adverse comments are received from the public or from
you, this permit will likely be issued in earlyNovember, with an effective date of December 1, 2005.
If you have any questions or comments concerning this draft permit, contact me at the telephone number or e-mail
address listed at the bottom of this page.
cc: NPDES Files
Ashevi3eeBggionalOfficef-Surf acW _e-_ aterPh5tecf_io_n_;9
Aquatic Toxicology Unit___
Mr. Jeffrey A. Friend
RMT North Carolina, Inc.
30 Patewood Drive, Suite 100
Patewood Plaza One
Greenville, SC 29615
NPD S Unit,1617 Mail Service Center, Raleigh, North Carolina 27699
An Equal Opportunity Affirmative Action Employer
Sincerely,
Sergei Chernikov, Ph.D.
Environmental Engineei
NPDES-West V—r- P_
rll
LL-'
SEP 2 9 2005 it
NIATER QUALITY SECTION
SHEVILLE REGIONAL OFFI(
919 733-5083, extension 594 (fax) 919 733-0719
sergei.chemikov@ ncmail.net
Permit NCO086088
k
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
Draft PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM .
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, _
SKF USA, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Girmes Site
Off Old Highway 74 East
Asheville
Buncombe County
to receiving waters designated as Gashes Creek in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, and IV hereof.
The permit shall become effective
This permit and the authorization to discharge shall expire at midnight on October 31, 2010.
Signed this day June
Alan W. Klimek, P.E.
Director
Division of Water Quality
By Authority of the Environmental Management Commission
J
Permit NCO086088
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked. As of this permit issuance, any previously issued permit bearing this
number is no longer effective. Therefore, the exclusive authority to operate and discharge
from this facility arises under the permit conditions, requirements, terms, and provisions
included herein.
SKF USA, Inc. is hereby authorized to:
1. Continue to operate an existing 0.108 MGD groundwater remediation
facility that includes the following components:
➢ Air stripping unit
➢ Parshall flume
➢ Effluent diffuser
This facility is located at the Girmes Site remediation off Old Highway.
74 East near Asheville in Buncombe County.
2. Discharge from said treatment works through Outfall 001 into Gashes
Creek, a .Class C water in the French Broad River Basin, at the
location specified on the attached map.
Permit NCO086088
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized
to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
_EFFLUENT G
MONITORING RE QL7IREMENTS
EFFLUENT
(IMITATIONS
4, .,.
CHARACTERISTICS
Monthly
IDa�ly
Measurement La
Sample Type
Sample a:
Average
Maxunurri'_
s Frequency
Location
Flow,
0.108 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
Monthly
Composite
Effluent
Trichloroethene
Quarterly
Grab
Effluent
1,2 Dichloroethene
Quarterly
Grab
Effluent
Vinyl Chloride
Quarterly
Grab
Effluent
Chronic Twdcity2
Quarterly
Composite
Effluent
Notes:
1.. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnia) limit at 15% with testing in January, April, July and October (see
A. (2)).
There shall be no discharge of floating solids or visible foam in other than trace avid znts: !- . -':;
(quarterly samples for monitored parameters shall coincide with the chronic toxicity test., -
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 15 %.
The permit holder shall perform at a minimum,guarterlu monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised -February 1998) or subsequent versions. The tests will be performed during the months of
January, April, July and October. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below
the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the
two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are
specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
(continued on next page)
Permit NCO086088
A. (2) CHRONIC TONICITY PERAUT LIMIT (guarterly)
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3
(original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if,
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is -
required, the permittee will complete the information located at the top of the aquatic toxicity (AT), tcst
form indicating the facility name, permit number, pipe number, county, and the month/year of the''_.t-:!
report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to
the Environmental Sciences Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required;
monitoring will be required during, the following month. 4
Should any test data from this monitoring requirement or tests performed by the North Carolina'
Division of Water Quality indicate potential impacts to the receiving stream, this permit maybe re_
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental ;controls;
shall constitute an invalid test and will require immediate follow-up testing to be completed -no later
than the last day of the month following the month of the initial monitoring.
Michael F. Easley, Governor
O�O� W AT �RQG
C. William McGlocklin
SKF USA Inc.
1111 Adams Ave.
Norristown, PA.
Dear Mr. McGlocklin:
19403-2403
May 3, 2005
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division
rMAY
� �L 2005
1
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
Subject: Receipt of permit renewal application
NPDES Permit NCO086088
Girmes Site Remediation
Buncombe County
of Water Quality
The NPDES Unit received your permit renewal application on May 3, 2005. A member of the NPDES Unit will
review your application. They will contact you if additional information is required to complete your permit renewal. You
should expect to receive a draft permit approximately 30-45 days before your existing permit expires. The requirements in
your existing permit will remain in effect until the permit is renewed (or the Division takes other action).
If you have any additional questions concerning renewal of the subject permit, please contact me at (919) 733-5083,
extension 363.
Sincerely,
Carolyn Bryant
Point Source Branch
cc: CENTRAL FILES
Asheville Regional Office/Water Quality Section
NPDES Unit
N�&�i ►Carolina
dVwllCally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service
Intemet: h2o.em.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748
Integrated 30 Patewood Drive, Suite 100
Envir0nM6rt&"k Patewood Plaza One
Awe Solutions Greenville, SC 29615-3535
Telephone: 864-281-0030
Fax: 864-281-0288
www.rratmc.com
April 27, 2005
Mr. Charles H. Weaver, Jr.
Water Quality/NPDES Unit
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Renewal
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Mr.'Weaver:
RMT North Carolina, Inc. (RMT) has been retained by SKF USA Inc. (SKF) to operate and maintain
the Girmes Site Groundwater System near Asheville, North Carolina, in Buncombe County.
Attachment 1 contains the NPDES permit renewal application for the Girmes Site Groundwater
System.
Background
The system began discharging treated groundwater on March 4, 1998. Groundwater is recovered
using three recovery wells, is treated in an air stripper, and is discharged under the site's NPDES
permit. The receiving stream is Gashes Creek, which was classified in 1997 as a "Class C" tributary of
the Swannanoa River in the French Broad River basin.
The current NPDES permit sets daily maximum discharge limitations for the parameters identified in
Table 1 (Attachment 2). The facility is also required to monitor the effluent for toxicity once per
quarter and has a limit of "pass" at an effluent concentration of 15 percent. This test uses Ceriodaphnia
dubia as the test organism.
Since the system began operation in 1998, there have been no instances where the concentration of a
permitted parameter exceeded the limit specified in the existing NPDES permit. In fact, no volatile
organic compounds (VOCs), which are the parameters of concern at this site, have been detected in
any of the effluent samples collected in at least the past 2 years of monitoring.
Operating History
As groundwater recovery operations have proceeded, the volume of water recovered per month has
declined from a high of 1.64 million gallons in April 1998 to the current approximate average of
1: \ W PGV L \ PJT \ 00-70144 \35 \ L007014435-002. DOC
Mr. Charles H. Weaver, Jr.
North Carolina Department of Environment and Natural Resources
April 27, 2005
Page 2
1 million gallons. In addition, the concentration of VOCs in the recovered groundwater has
decreased. When recovery operations began in March 1998, the influent trichloroethene (TCE)
concentration was approximately 2,900 parts per billion (ppb), but subsequently declined to
approximately 380 ppb several years ago. Since November 2002, the system has been operated in a
pulsed pumping mode, where the recovery system operates for six to seven weeks, then is shut down.
Each cycle lasts approximately three months. With the pulsed pumping mode of operation, the
concentration of TCE in the influent has increased to approximately 1,000 ppb.
We believe that the monitoring data since start-up in 1998 show that the treatment system can easily
reduce the influent VOCs to concentrations below the detection limit. Total suspended solids (TSS) is
also well below the NPDES permit limit. Therefore, we request that the Division of Water Quality
consider the permit modifications that we have detailed below.
1. Flow — The NPDES permit is based on the design flow of the treatment plant. The permitted flow
is 0.108 mgd and is much higher than the average daily flow from the site. For the record, the
flow for the first three months of 2005 has been approximately 34,000 gallons per day (gpd).
2. TSS — The site has never exceeded the permit limit of 30 milligrams per liter (mg/L) and the
results have generally been no detection. Because of the nature of the water that is being
discharged, we do not believe that there is a reasonable potential for the TSS limit to be exceeded,
and therefore request that this parameter be dropped from the permit.
3. Chronic toxicity testing — The toxicity testing that has been conducted quarterly since operations
began in 1998 has never indicated that the discharge may cause an adverse impact to the
receiving stream. With one exception in January 2002, all test results have been reported as a
"pass" according to the bioassay procedure. All of the definitive chronic toxicity tests that have
been run have passed at a No Observable Effect Concentration (NOEC) of greater than
60 percent. This concentration is significantly higher than the in -stream waste concentration in
Gashes Creek.
40 CFR 122.44(d)(1)(ii) addresses certain requirements when determining whether a discharge
causes, or has the reasonable potential to cause, an in -stream impact. The regulation specifies
that the State must consider existing controls on point and non -point sources of pollution; the
variability of the pollutant or pollutant parameter in the effluent; the sensitivity of the species to
toxicity testing (when evaluating whole effluent toxicity); and, where appropriate, the dilution of
the effluent in the receiving water. Additional information is provided in the Technical Support
Document for Water Quality -based Toxics Control (EPA/505/2-90-001). RMT's interpretation of
these considerations is summarized below.
I: \ W PGV L\ PJT\ 00-70144\35 \ L007014435-002. DOC
Mr. Charles H. Weaver, Jr.
North Carolina Department of Environment and Natural Resources
April 27, 2005
Page 3
— Existing controls on point sources of pollution — The nature of the Girmes Site
Groundwater System precludes the possibility of chemical spills or dumps, treatment
process upsets, or other incidents that could have an adverse effect on the effluent.
— The variability of the pollutants in the effluent —The chemical characteristics of the
treated effluent have been well documented since the system's start-up in 1998. NPDES
permit compliance testing has shown that VOCs of concern are not present in the
discharge. Testing for volatile halocarbons by Method 601 has confirmed that other
volatile pollutants are absent from the discharge as well. The static nature of the site
dictates that it is very unlikely that there is any significant variability in the site's
discharge.
— The sensitivity of the species to toxicity testing — The test organism, Ceriodaphnia dubia,
has been shown to be a species sensitive to a large number of pollutants.
— Dilution of the effluent in the receiving water — The discharge flow rate has averaged
34,000 gpd for the first three months of 2005. Therefore, the test concentration stipulated
in the existing permit is extremely conservative. Gashes Creek is not effluent -dominated
at the location of the effluent diffuser.
Based on a close examination of these four criteria, RMT believes that there is no reasonable
potential to cause an in -stream excursion above the ambient concentration of either a numeric or
narrative stream standard. 40 CFR 122.44(d)(1)(v) states that "limits on whole effluent toxicity
are not necessary where the permitting authority demonstrates ... that chemical -specific limits for
the effluent are sufficient to attain and maintain applicable numeric and narrative State water
quality standards." We believe that chemical -specific limits for the Girmes Site are sufficient and,
therefore, we request that the Division remove toxicity testing from the permit.
Other Requirements
Per the instructions for NPDES renewal packages, we are including the following additional
information:
Table 2 (Attachment 2) contains the summary of the most recent analytical results for January
through March 2005.
United States Geological Survey (USGS) topographical site location map (Attachment 3)
indicating the location of the outfall diffuser.
A copy of SKF's letter granting RMT signatory authority for this project (Attachment 4).
f: \ W PGV L \ PJT\ 00-70144 \35 \ L007014435-002. DOC
Mr. Charles H. Weaver, Jr.
North Carolina Department of Environment and Natural Resources
April 27, 2005
Page 4
Since this facility does not generate sludge or other treatment residue, a sludge management plan has
not been developed for the Girmes Site.
We appreciate your efforts to work with us to develop an appropriate permit for the Girmes Site
Groundwater System and look forward to discussing these issues with you soon. If there are any
questions, please call me at (864) 234-9437.
Sincerely,
RMT North Carolina, Inc.
Jeffrey A. Friend
Operations Coordinator
Attaclunents
cc: Bill McGlocklin, SKF USA
Mike Parker, Dan Madison - RMT
File 70144.35
1: \ W PG V L \ PJT\00-70144 \35 \ L007014435-002. DOC
Attachment 1
Permit Renewal Application
1: \ W PGV L\ PJT\00-70144 \35 \ L007014435-002. DOC
NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCO086088
Please print or type
1. Applicant and facility producing discharge
A. Name SKF USA Inc. Girmes Groundwater Site
B. Mailing address of applicant:
Contact Person Mr. C. William McGlocklin
Street address 1111 Adams Avenue
City Norristown County Montgomery
State Pennsylvania Zip Code 19403-2403
Telephone Number (610) 630-2730
Fax Number (610) 630-2780
e-mail address: william.c.mcglocklin@skf.com
C. Location of facility:
Street off Old Highway 74 East
City Asheville County Buncombe
State North Carolina Zip Code 28803
Telephone Number ( ) not applicable
Fax Number ( ) not applicable
2. Standard Industrial Classification (SIC) code(s) (if known): none
3. This application is for a: ❑ New Permit QPermit Renewal ❑ Permit Modification
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvent
Other (describe)
5. (a) Check here if discharge occurs all year 0, or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge occurs: 7 days per week
6. Volume of wastewater discharged to receiving stream(s): 40,000 GPD*
*Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) 2
If not, state the specific discharge location:
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is the only viable means of discharge, trace
the route of the storm sewer to its discharge point(s).
Short Form C-GW Version 512004
NPDES PERMIT APPLICATION - SHORT FORM C-GW
To be filed by persons engaged in groundwater remediation projects
8. Number of separate discharge points: one effluent diffuser in Gashes Creek
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of wastewater
flow at the facility.
9. Name of receiving water(s): Gashes Creek
All application packages (including permit renewals) must include the items listed below. This
application will be returned if the required items are not included.
❑ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
❑ A summary of the most recent analytical results (effluent data, if available) containing the maximum values for each chemical detected
New applications for proposed (not yet permitted) discharges must also include the items listed
below. This application will be returned if the required items are not included.
❑ An engineering proposal describing the remediation project in detail (required by 15A NCAC 2H.0105 (c))
❑ A report of alternatives to surface water discharge as outlined by the Division's "Guidance for Evaluation of Wastewater Disposal
Alternatives" (required by 15A NCAC 2H.0105 (c))
❑ If the treatment system will discharge to a storm sewer, attach written approval from the municipality responsible for the sewer.
❑ A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for each chemical
(the most recent sample must be collected less than one year prior to the date of this application)
❑ A summary of analytical results containing the maximum values for each chemical detected
❑ The removal efficiency of each compound detected (if known)
For petroleum -contaminated sites, analyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel additives
likely to be present at the site should also be performed. At minimum, analyses should be performed for the following compounds:
benzene* toluene* ethylbenzene* xylene* lead methyl tert-butylether (MTBE)
dibromoethane (EDB) 1,2-dichloroethane isopropyl ether napthalene phenol
(*an EPA -approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or other contaminants, an EPA Method 624/625 analysis should be performed.
I certify that I am familiar with the information contained in the application and that to the best of
my knowledge and belief such information is true, complete, and accurate.
Printed name of Person Signing
North Carolina General Statute 143-215.6E (i) provides that:
Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other
document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing
that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be
operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be
guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both.
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment for not more than 5 years, or both, for
a similar offense.)
Short Form C-GW
Version 512004
Attachment 2
Tables
1: \ W PGV L\ PJT\ 00-70144 \ 35 \ L007014435-002. DOC
Table 1
Summary of NPDES Permit Limitations
PARAMETER.
%IMITS ,
'.FREQUENCY
Flow
0.108 m d
Continuous
TSS
30 m /L
Monthly
TCE
MR'
Quarterly
1,2-Dichloroethene (DCE)
MR
Quarterly
Vinyl chloride (VC)
MR
Quarterly
Toxicity
P/F at 15%
Quarterly
Table 2
Summary of Maximum Observed Values for 2005
PAIZAIVIETER
JANUARY
FEBRUARY;
MARCH
Flow — m d
0.044
0.0391
02
TSS — m /L
<3.3
<2.1
-
TCE - /L
<1
-
-
1,2-DCE - /L
<1
-
-
VC - /L
<1
-
-
VOCs by 601
ND3
Toxicity (P/F at 15%)
NOEC4>60%
-
-
1. Monitor and Report
2. The system was off-line for the month of March 2005
3. Volatile halocarbons by Method 601 were not detected in the effluent at the
detection limit of 1 µg/L (2 µg/L for chloromethane and methylene chloride)
4. No Observable Effect Concentration
I: \ W PGVL \ PJT\ 00-70144 \ 35 \ L007014435-002. DOC
Attachment 3
Topographical Site Location Map
I: \ W PGVL\PJT\ 00-70144 \35 \ L007014435-002. DOC
�� \ . � fir° _ ' a 1' }�. / �-•�� _ •/ (/) -
A� — � • 1 • tJI �, .� rr t
E{Q°•), • .. \\�_ � � ° � !\/l�• 1:.•L';-_ .+ram'^ t
\ 'l tr�ll� � •�__ r_-�rJ �,-1•'a�.°.'. _°/I.-:�' �:��� ;�.I 4 m_na7A vd� ia;,° m,�
NOW ra
�P III ;�.�.� - �� _ ,�• ` • � � �
ASHEVILLE QUAD.
si OTEEN QUAD
FIGURE 1
W'70144.12 ,� ," � ' Ili I� � �: � ;'\ f.� i
FORMERLY.
0297
111
C
2
Attachment 4
SKF Signatory Authority Letter
I: \ WPGVL \ PJT\ 00-70144 \ 35 \ L007014435-002. DOC
SKF USA Inc.
Norristown, PA
USA
June 25, 2001
Mr. Shannon Langley
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Center
Raleigh, North Carolina 27699-1617
Reference: Authorized Representative Delegation
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Mr. Langley:
This letter is notification that SKF USA Inc. has delegated signatory authority to
RMT North Carolina, Inc. as follows:
Dan O. Madison, RMT North Carolina Project Manager
NPDES DMR forms
Jeffrey A. Friend, Operations Coordinator, Operator -in -Charge
Please contact the undersigned if you need further information.
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
cc: Jeff Friend (RMT, Inc.)
Dan Madison (RMT, Inc.)
1111 Adams Avenue Telephone: (610) 630-2800
Norristown, PA 19403-2403 pas: (610) 6311-2801
s®
E
M
DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0086088
Facilit Information
Applicant/Faeility Name SKF USA Inc. / Girmes Site
Apphcant-Address' 1111 Adams Ave. Norristown, PA 19403
FadtlttyAddress �438 Seuth r�rk Rasp G r�nia delete1
fitted. Flow„(MGD) .
0.108 "
of Waste:
Groundwater
ity Class
NR
County
Buncombe
Ity;Status.. _
Renewal
Regional Office`
Asheville
Stream Characfer stics,, f
Ivmg Stream
Gashes Creek
Stream Classifidatlori.'
C
iageT.Area :(sq , m:)
NA
Drainage basin
French Broad
mer 7Q1.0 ('cfs)
0
Subbasin '
04-03-02
E)r 7Q� 0 _(cfs)
NA
Use Support
FS
(cfs)
NA
303(d) Listed
No
age"Flow, (:ifs) , - ° ,
NA
Statd Gnd'
E8SW / E9SW
90
.:,
USGS Topo ,Quad 'Asheville
/ Otten
Summary SKF USA Inc. owns the groundwater treatment system at the Girmes Site and
RMT Integrated Environmental Solutions operates the system. This treatment system has
been in operation since 1998.
Permit Issues SKF USA Inc. is requesting permit renewal and the elimination of TSS, 1,2
dichloroethene, vinyl chloride, barium, toxicity, iron and manganese and the reduction in
monitoring frequency for.TCE.
Facility Description The treatment system consists of an air stripping unit, a parshall flume
and effluent diffuser.
COMPLIANCE REVIEW
Whole Effluent Toxicity (WET) Test WET requirement is a Quarterly Chronic Toxicity
Pass/Fail using Ceriodaphnia at 90%. They have passed all the toxicity tests since 1996.
DMR Instream and Effluent Data Review DMR were reviewed for the period of January
1999 to October 2001. The average flow for this period was 0.0374 MGD. The maximum
flow discharged was 0.047 MGD. TSS was detected 4 times with an average of 5.3 mg/I
and a maximum of 18 mg/I. Thrich loroethene, 1,2-Dichloroethene and vinyl chloride were
not detected.
Reasonable Potential Analysis (RPA)
Thrichloroethene, 1,2-Dichloroethene and vinyl chloride were below detection level for all
samples therefore a RPA was not required.
Fact Sheet
Renewal -- NPDES Permit NCO086088
Page 1
Barium —The average vai.__ .-)r barium was 0.04 pg/I. There is no ..u„dard or criteria for
this parameter and it is not a parameter of concern, therefore the monitoring requirement
can be eliminated.
Manganese - The average value for manganese was 0.032 pg/I..There is no standard or
criteria for this parameter and it is not a parameter of concern, therefore the monitoring
requirement can be eliminated.
Iron — A resonable potential analysis was performed for iron. The allowable concentration is
1000,ug/I, the maximum predicted concentration is 0.234Ng/I. Iron does not present
reasonable potential to exceed water quality standard and is not a pollutant of concern
therefore the monitoring requirements can be eliminated from the permit.
PROPOSED MODIFICATIONS
• The sampling requirements for iron, manganese and barium were eliminated from the
permit.
• The monitoring for thrichloroethene, 1,2-Dichloroethene and vinyl chloride was reduced
to quarterly. These parameters were not detected in the effluent. Monitoring will remain
because these are the solvents being recovered from the groundwater.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: February 20, 2002.
Permit Scheduled to Issue: April 12, 2002.
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit,
please contact Teresa Rodriguez at (919) 733-5083 ext. 595.
NAME: DATE:
Regional Office Comments
NAME: DATE:
NPDES SUPERVISOR: DATE:
Fact Sheet
Renewal -- NPDES NCO086088
Page 2
TOXICANT ANALYSIS
Facility Name
SKF / Girmes Site
Parameter=
TCE
Parameter
1,2 DCE
Pai;ameter=
Vinyl Chl
NPDES#
NC008B088
Standard
92.4,ug/l
#ta rd
:n �da
99
pg/l:Standard
=
525
ug1l
Ow (MGD)
0.108
7010s (cfs)
0
n
BDL=1/2DL
-,tual Data
RESULTS
n0l-112D,tualData
IRESULTS
n
3DL=1/2D
kctual Data
/WC (%)
100.00
1
<1
Std Dev.
#DIV/01
1
<1
j Std Dev.
#DIV/01
1
<1
ec'ving Stream
Gashes Creek
2
<1
Mean
#DIV/O!
2
<1
Mean
#DIV/01
2
Stream Class
C
3
<1
C.V.
#DIV/0!
3
<1
C.V.
#DIV/O!
3
<1
4
<1
4
<1
4
<1
FINAL RESULTS
5
<1
5
<1
5
<1
TCE
6
<1
Muir Factor=
6
<1
Mult Factor=
6
<
Max. Pred Cw
0
ug/
7
<1
Max. ValuE
0
:::
/jg/i: : 7
<1
Max. Value
0
pgfi.: 7
1<1
Allowable Cw
92.4
ug/,
8
<1
Max. Pred
0
pg/[:.:. 8
<1
Max. Pred
0
/ig/[::.:. 8
<1
Max. Value
0
9
<1
Allowable
92.40.uqj/�
9
<1
Allowable C
99.00,ug/l:-.:-,
9
<1
-4 n nr,E
Pred Cw
�,..wable Cw
10
<1
10
<1
10
<1
0
ug/
11
<1
11
<1
11
<1
99.0
ug/
12
<1
12
<1
12
<1
Max. Value
0
13
<1
13
<1
13
<1
Vinyl Chl
14
<1
... 14
<1
14
<1
Max. Pred Cw
i 0
ug/
15
<1
15
<1
15
<1
Allowable Cw
j 525.0
ug/
16
<1
16
<1
16
<1
Max. Value
0
17
<1
17
<1
17
<1
Ba
18
<1
18
<1
18
<1
Max. Pred Cw
0.065
ug/
19
<1
19
<1
19
1<1
Allowable Cw
#VALUE!
ug/
20
<1
20
<1
20
<1
Max. Value
0.05
21
<1
21
<1
21
<1
Iron
22
<1
22
<1
22
<1
Max. Pred Cw
0.234
ug/
231
<1
23
<1
23
<1
'Allowable Cw
1000.0
ug/
241
<1
1
24
<1
24
<1
Max. Value
0.09
25
<1
25
<1
25
<1
Nsn
26
<1
26
<1
26
<1
Max. Pred Cw
0.301
ug/
27
<1
27
<1
1
27
<
Allowable Cw
#VALUE!
ug/
28
<1
28
<1
1 28
<1
ax. Value
0
Max.Pred Cw
0.07
29
<1
29
<1
29
<1
30
<1
30
<1
30
<1
0
ug/
31
1<1
31
<1
31
<1
rMax.
Cw
j 0.0,
ug/j
32
1<1 I
1
32
<1
32
<1
1123/02
TOXICANT ANALYSIS
RESULTS
n
BDL=1 /2DI
kctual Data
RESULTS
n
DL=1/2D
tual Dat
RESULTS
n
01-=1/2D
Actual Data
RESULTS
Mult Facto r—
6
0.046
0.0461
Mult Factot
1.3
6
0.01
mult Facto)
2.6
6
0.0025
Mult Ftacto4
3
14
1/n/02
Integrates 100 Verdae Blvd. 29607-382S
Iwo Environmental P.O. Box 16778 29606-6778
Solutions Greenville, SC
Telephone: 864-281-0030
Fax: 864-281-0288
June 29, 2001
Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Point Source Branch
1617 Mail Center
Raleigh, North Carolina 27699-1617
EU UE
D '--
J U L
I]Et�1R-\YATER QUALITY
pOINT SOURCE BRANCH
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Renewal
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Ms. Stephens:
RMT North Carolina, Inc. (RMT) has been retained by SKF USA, Inc. (SKF) to operated and maintain
the Girmes Site Groundwater System near Asheville in Buncombe County. The system began
discharging treated groundwater on March 4,1998. Groundwater is recovered from three recovery
wells, treated in an air stripper, and discharged under the site's NPDES permit. The receiving stream
is Gashes Creek, which was classified in 1997 as a "C" tributary of the Swannanoa River in the French
Broad River basin.
NPDES Permit History
The current NPDES permit sets a daily maximum discharge limitations for the parameters identified
in Table 1. The facility is also required to monitor the effluent for toxicity once per quarter and has a
limit of "pass" at an effluent concentration of 90 percent. This test uses Ceriodaphnia dubia as the test
organism.
Since the system began operation in 1998, there have been no instances where the concentration of a
permitted parameter exceeded the limits specified in the existing NPDES permit. In fact, no volatile
organic compounds (VOCs), which are the parameters of concern at this site, have been detected in
the effluent in any of the effluent samples collected in at least the past 2 years of monitoring.
As groundwater recovery operations have proceeded, the volume of water recovered per month has
declined from a high of 1.64 million gallons in April 1998 to the current average of approximately
1 million gallons per month now. Also, the concentration of VOCs in the recovered water has
decreased. When recovery operations began, the influent trichloroethene (TCE) concentration was
approximately 2,900 parts per billion (ppb) and has declined to approximately 380 ppb now. We
believe these data show that the treatment system can easily reduce the influent VOCs to well below
the permit limit of 92.4 ppb and that other permitted parameters, namely total suspended solids
P:\ DATA\O&M\SKF-GIRMES\ NPDESRENEW ALDOC
Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 2
(TSS), barium, manganese, and iron are also well below the NPDES permit limits. Therefore, we
request that the Division of Water Quality consider the permit modifications that we have detailed
below.
1. Flow - The NPDES permit is based on a flow of 0.108 million gallons per day (mgd) and is the
design flow of the treatment system and is much higher than the average daily flow from the site.
For the record, the flow for the first five months of 2001 has been approximately 33,800 gallons
per day (gpd).
2. TSS - The site has never exceeded its permit limit of 30 milligram per liter (mg/L) and the results
have generally been no detection. Because of the nature of the water that is being discharged, we
do not believe that there is a reasonable potential for the TSS limit to be exceeded, and request
that this parameter be dropped from the permit.
3. TCE - The site has never exceeded its permit limit for TCE and the results have generally been no
detection (<1 ppb). The only detection of this parameter occurred during the first month of
operation at an effluent concentration of 2.1 ppb. We do not believe that continued monitoring of
this parameter will yield additional useful information. Nevertheless, this is the primary VOC of
concern at the site and we believe that quarterly monitoring is sufficient to confirm proper
operation of the treatment system. Therefore, we request that the frequency of monitoring TCE
be reduced to once per quarter.
4. 1,2-dichloroethene - This parameter has not been detected in the treated effluent. We do not
believe that there is a reasonable potential for this parameter to cause a violation of water quality
standards and that continued monitoring of this parameter will not yield additional useful
information. Therefore, we request that 1,2-dichloroethene be dropped from the permit.
5. Vinyl chloride - This parameter has not been detected in the treated effluent. We do not believe
that there is a reasonable potential for this parameter to cause a violation of water quality
standards and that continued monitoring of this parameter will not yield additional useful
information. Therefore, we request that vinyl chloride be dropped from the permit.
6. Barium - This parameter is present in the discharge at approximately 0.045 mg/L. Even without
dilution by the receiving stream, this concentration is much lower than North Carolina's Water
Supply Classification standard of 1 mg/L. We do not believe that there is reasonable potential
for this parameter to cause a violation of water quality standards and that continued monitoring
of this parameter will not yield additional useful information. Therefore, we request that barium
be dropped from the permit.
7. Iron - This parameter is generally not detected in the discharge at a quantitation limit of
0.02 mg/L. Even without dilution by the receiving stream, this concentration is much lower than
North Carolina's Action Level standard of 1 mg/L. We do not believe that there is a reasonable
P: \ DATA I O&M I SKF-GIRMES j NPDESRENEWAL.DOC
Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 3
potential for this parameter to cause a violation of water quality standards and that continued
monitoring of this parameter will not yield additional useful information. Therefore, we request
that iron be dropped from the permit.
8. Manganese - This parameter is generally not detected in the discharge at a quantitation limit of
0.005 mg/L. Even without dilution by the receiving stream, this concentration is much lower
than North Carolina's Action Level standard of 0.2 mg/L. We do not believe that there is a
reasonable potential for this parameter to cause a violation of water quality standards and that
continued monitoring of this parameter will not yield additional useful information. Therefore,
we request that manganese be dropped from the permit.
9. Chronic toxicity testing - The toxicity testing that has been conducted quarterly since operations
began in 1998 has never indicated that the discharge may cause an adverse impact to the
receiving stream. All test results have been deemed to be a "pass" according to the bioassay
procedure.
40 CFR 122.44(d)(1)(ii) addresses certain requirements when determining whether a discharge
causes, or has the reasonable potential to cause, an in -stream impact. The regulation specifies
that the State must consider existing controls on point and non -point sources of pollution; the
variability of the pollutant or pollutant parameter in the effluent; the sensitivity of the species to
toxicity testing (when evaluating whole effluent toxicity); and, where appropriate, the dilution of
the effluent in the receiving water. Additional information is provided in the Technical Support
Document for Water Quality -based Toxics Control (EPA/505/2-90-001). RMT's interpretation of
these considerations is summarized below.
Existing controls on point sources of pollution - The nature of the Girmes Site
Groundwater System precludes the possibility of chemical spills or dumps, treatment
process upsets, or other incidents that could have an adverse effect on the effluent.
The variability of the pollutants in the effluent- The chemical characteristics of the
treated effluent have been well documented since the site's start-up in 1998. NPDES
permit compliance testing has shown that VOCs of concern are not present in the
discharge. Testing for volatile halocarbons by Method 601 has confirmed that other
volatile pollutants are absent from the discharge as well. The static nature of the site
dictates that it is very unlikely that there is any significant variability in the site's
discharge.
The sensitivity of the species to toxicity testing- The test organism, Ceriodaphnia dubia,
has been shown to be a species sensitive to a large number of pollutants.
Dilution of the effluent in the receiving water- The discharge flow rate has averaged
33,800 gpd for the first 5 months of 2001'. Therefore, the test concentration stipulated in
P: \ DATA \ O&M \ SKF-GIRMES \ NPDESRENEWAL.DOC
Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 4
the existing permit is extremely conservative. Gashes Creek is not effluent -dominated at
the location of the effluent diffuser.
Based on a close examination of these four criteria, RMT believes that there is no
reasonable potential to cause an in -stream excursion above the ambient concentration of
either a numeric or narrative stream standard. 40 CFR 122.44(d)(1)(v) states that limits
on whole effluent toxicity are not necessary where the permitting authority
demonstrates ... that chemical -specific limits for the effluent are sufficient to attain and
maintain applicable numeric and narrative State water quality standards. We request
that the Division remove toxicity testing from the permit.
Per the instructions for NPDES renewal packages, we are including the following additional
information:
■ United States Geological Survey (USGS) topographical site location map indicating the outfall
diffuser.
■ A copy of the surface water discharge alternatives analysis prepared in 1997, which we believe
reasonably reflects the current operation.
■ A summary of the most recent analytical results for January through April 2001 (see Table 2).
We appreciate your efforts to work with us to develop an appropriate permit for the Girmes Site
Groundwater System and look forward to discussing these issues with you soon. If there are any
questions, please call me at (864) 234-9437.
Sincerely,
RMT North
qq Carolina, Inc.
A.
Jeffrey A. Friend
O&M Coordinator
Wastewater Treatment Services
Attachments
cc: Bill McGlockhn, SKF USA, Inc.
Dan Madison, RMT
Central Files
P: % DATA % OW SKF-CIRMES I NPDESRENEWAL.DOC
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCO086088
Please print or type
1. Applicant and facility producing discharge
A. Name: SKF USA, Inc. Girmes Groundwater Site
B. Mailing address of applicant:
1. Street address: 1111 Adams Avenue
2. City: Norristown
3.
County: Montgomery
4. State: Pennsylvania 5.
Zip Code: 19403-2403
Telephone Number
(610) 630-2730
Fax Number
(610) 630-2780
e-mail address:
C. Location of facility:
1. Street off Old highway
74 East
2. City: Asheville
3.
County: Buncombe
4. State: North Carolina 5.
Zip Code
Telephone Number
( ) not applicable
Fax Number
( ) not applicable
2. Standard Industrial Classification (SIC) code(s) (if known): none
3. This application is for a: ❑ New Permit Q Permit Renewal ❑ Permit Modification
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvents
Other (describe)
5. (a) Check here if discharge occurs all year Q, or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge occurs: 7 days per week
6. Volume of wastewater discharged to receiving stream(s): 33,800 GPD*
*Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) Q
If not, state the specific discharge location:
Mark the path taken by the wastewater to the receiving stream(s) on the site map. If a storm sewer is the only viable means of
discharge, trace the route of the storm sewer to its discharge point(s).
P:\ DATA\O&M\SKF-GIRMES\ NPDESRENEW ALDOC
8. Number of separate discharge points: 1— there is a single effluent diffuser in Gashes Creek
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of wastewater
flow at the facility.
9. Name of receiving water(s): Gashes Creek
This application package must include the items listed below. This application will be returned if the
required items are not included.
❑ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
❑ A report of alternatives to surface water discharge as outlined by the Division's "Guidance for Evaluation of Wastewater Disposal Alternatives"
(required by 15A NCAC 2H.0105 (c))
❑ A summary of the most recent analytical results containing the maximum values for each chemical detected
Applications for new (un-permitted) discharges must also include the items listed below. This application
will be returned if the required items are not included.
❑ An engineering proposal describing the remediation project in detail (required by 15A NCAC 2H.0105 (c))
❑ If the treatment system will discharge to a storm sewer, attach written approval from the municipality responsible for the sewer.
❑ A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for each chemical (the most
recent sample must be collected less than one year prior to the date of this application)
❑ A summary of analytical results containing the maximum values for each chemical detected
❑ The removal efficiency of each compound detected (if known)
For fuel remediation proiects, analyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel additives likely to be
present at the site should also be performed. At minimum, analyses should be performed for the following compounds:
benzene* toluene* ethylbenzene* xylene* lead methyl tert-butylether (MTBE) dibromoethane (EDB)
1,2-dichloroethane isopropyl ether napthalene phenol
(*an EPA -approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or unidentified proiects, an EPA Method 624/625 analysis should be performed. The data submitted with this application should include
the ten largest peaks not identified as targeted compounds and not present in the procedural blank. These peaks should be identified and
approximately quantitated (as per the same restrictions found on the NC DENR/DWQ Annual Pollutant Analysis Monitoring (APAM)
Requirement- Reporting Form A).
If metals or pesticides are suspected to be present, these compounds should be analyzed to the same detection level as presented in the NC APAM.
I certify that I am familiar with the information contained in the application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
OM1-1IftG
Printed name of Person Signing
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any
application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or
maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by
a fine not to exceed $10,000, or by imprisonment not to exceed six months, or by both.
(18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or imprisonment for not more than 5 years, or both, for a similar offense.)
P:\ DATA\ O&M\SKF-GIRMES\ NPDESRENE W AL DOC
u
Z
W
Z
x
V
N
Z_
w
S
H
Section 3
System Discharge Alternatives
(This section was revised on March 27,1997.)
The following treated groundwater discharge alternatives were evaluated for the Girmes site:
sewer discharge and subsurface discharge.
3.1 Connection to Sewerage System
The alternative of discharging treated groundwater to a publicly owned treatment works
(POTW) is applicable to the treated groundwater, provided that the quality of the water meets
the pretreatment requirements of the local regulatory agency. The Girmes site is served by the
Metropolitan Sewerage District of Buncombe County (MSD); however, MSD is limiting
discharges from groundwater remediation systems to a maximum of 20,000 gpd. The CA
system will have a design capacity of 108,000 gpd and a projected initial flow rate of 75,000 gpd
from the three recovery wells.
Confirmation of a telephone conversation with MSD is found in Appendix C.
3.2 Subsurface Disposal System
RMT has evaluated the potential installation of an infiltration gallery to receive treated effluent
from the groundwater remediation system. This evaluation included review of site
topographic characteristics, soil type classification, soil characteristics, and hydrogeologic
conditions.
The site topography is shown on Plate 1. The Girmes facility is perched on a hilltop and
surrounded on three sides by steeply sloping, wooded terrain. The installation of an infiltration
gallery on the steep slopes would be impractical. The only flat area of the site is located
southeast of the facility encompassing an area of approximately 3 acres. Soil and groundwater
in this area have not been affected by past on -site activities.
The site is underlain by saprolite soils 20 feet to 30 feet in thickness overlying crystalline
bedrock. Saprolite throughout the site consists of silts, silty sands, and clayey silty sands. Soils
data provided by the Buncombe County Soil and Water Conservation District indicates a soil
permeability of 0.6 to 2 inches per hour from the surface to a depth of 4 feet. Using the more
conservative value of 0.6 inches per hour and a design hydraulic loading rate of 108,000 gpd,
approximately 12,000 sq. ft or 0.3 acres of infiltration gallery would be required. Based on
RMT, Inc. 1$ Girmes Site
1:\WPGVLI70117014472.DOG March 1997
W
RMT's experience, a design safety factor of 5 should be applied to account for continuous
versus intermittent flooding. This safety factor results in a total requirement of approximately
1.5 acres. Uniform hydraulic loading in a 1.5 acre infiltration gallery would be difficult and
would result in continuously flooded as well as hydraulically starved areas. This area could
not be used for further expansion of the facility or truck parking.
Placement of an infiltration gallery on the southeast site of the Girmes facility would cause a
local increase in hydraulic head immediately beneath the gallery and increased hydraulic
gradients across the site area. Increased gradients in the north to northeast directions would
result in increased groundwater flow velocities, causing the northest plume of affected
groundwater to migrate more rapidly in the direction of the NC DOT facility. The natural
attenuation rate of the VOCs per unit distance would, as a result, decrease in response to
increased flow velocities. This creates the potential for higher VOC concentrations to migrate
further offsite. In addition, infiltrated water would not be captured by the existing
groundwater recovery system, given the only suitable location on the site for an infiltration
gallery southeast of the facility.
3.3 Feasibility of Discharge Alternatives
The information discussed in the previous sections shows that, because of local POTW policies
and site conditions, the evaluated discharge alternatives are not feasible. The MSD limitation of
20,000 gpd for groundwater remediation systems would not allow the system to meet the CA
objectives. Site topography, hydrogeology, and soil permeability prevent the installation of an
infiltration gallery of sufficient area to meet the requirements of the projected discharge and
meet the CA objectives. However, system discharge to the Gashes Creek is environmentally
feasible because of the creek's proximity to the property and the quality of the treated
groundwater that would be discharged to the creek.
RMT, Inc.
l: � VVPGVL 170117014472. DOC
16
Girmes Site
March 1997
Table 1
Summary of NPDES Permit
PARAMETER
„LIMITS
FREQUENCY
Flow
0.108 m d
Continuous
TSS
30.0 m / L
Monthly
TCE
92.4 µ / L
Monthly
1,2-DCE
None
Monthly
VC
None
Monthly
Ba
None
Monthly
Fe
None
Monthly
Mn
None
Monthly
Toxicity
Pass
Quarterly
Table 2
Summary Maximum Observations for 2001
PARAMETER
JANUARY
FEBRUARY
MARCH
APRIL
Flow - m d
0.038
0.036
0.035
0.051
TSS - m /L
<5
<5
<5
<5
TCE - µ / L
<1
<1
<1
<1
1,2-DCE - µ / L
<1
<1
<1
<1
VC - µ / L
<1
<1
<1
<1
Ba - m / L
0.046
0.045
0.044
0.039
Fe - m / L
<0.02
<0.02
<0.02
<0.02
Mn - m /L
<0.005
<0.005
<0.005
<0.005
Toxicity P/ F
Pass
Pass
P:\ DATA\O&M\ SKF-GIRMES\ NPDESRENEW ALDOC
z SKF USA Inc.
Norristown, PA
USA
June 25, 2001
Mr. Shannon Langley
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Center
Raleigh, North Carolina 27699-1617
Reference: Authorized Representative Delegation
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Mr. Langley:
This letter is notification that SKF USA Inc. has delegated signatory authority to
RMT North Carolina, Inc. as follows:
Dan O. Madison, RMT North Carolina Project Manager
NPDES DMR forms
Jeffrey A. Friend, Operations Coordinator, Operator -in -Charge
Please contact the undersigned if you need further information.
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
cc: Jeff Friend (RMT, Inc.)
Dan Madison (RMT, Inc.)
I I I I Adams Avenue Telephone: (610) 630-28DO
Nnrrislown. PA 19403-2403 Fax: (610) 630-2801
r
AL
CCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
SURFACE WATER PROTECTION SECTION
August 26, 2011
Mr. C. William McGlocklin,
Director of Environmental Affairs
SKF USA Inc. - Legal Department
PO Box 352
Lansdale, PA 19446-0352
SUBJECT: Compliance Evaluation Inspection
Girmes Site - Asheville
Groundwater Remediation
Permit No: NCO086088
Buncombe County
Dear Mr. McGlocklin:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the
inspection conducted on August 19, 2011. The facility was found to be in compliance with permit
NC0086088.
Please refer to the enclosed inspection report for additional observations and comments.
If you or your staff should have any questions, please call me at 828-296-4662.
Sincerely,
Wanda P. Frazier
Environmental Specialist
Enclosure
cc: Michael B. Parker, P.E.; TRC; 30 Patewood Drive.; Suite 100; Greenville, SC 29615-3535
Central Files
NW
SURFACE WATER PROTECTION — ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swannanoa, NC 28778 NOnrthCarolina
Phone: 828-296-4500 Fax: 828-299-7043 Customer Service: 1-877-623-6748 Naturally
Internet: www.ncwatergual!tV.org
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 INI 2 I5I 31 N00086088 I11 121 11/08/19 117 18ICI 19ISI 20III
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIII IIIIIIIIIIII11111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -- - - ------Reserved--- - ----
671 1.0 169 70I 31 711 I 721 N I 73 W 74 751 I I I I I Li
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)
Girmes Site remediation
11:00 AM 11/08/19
05/12/01
Exit Time/Date
Permit Expiration Date
Old US Hwy 74 E
Asheville NC 28806
11:30 AM 11/08/19
10/10/31
Name(s) of Onsite Rep resentative(s)Fritles(s)/Phone and Fax Number(s)
Other Facility Data
Mark P Swann/ORC/828-254-7176/
Name, Address of Responsible Official/Title/Phone and Fax Number
C William McGlocklin,PO Box 332 Kulpsville PA Contacted
194430332//610-630-2730/6106302780 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Wanda P Frazier ARO WQ//828-296-4500 Ext.4662/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Aw 64 �11-vil
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
NPDES yr/mo/day Inspection Type
NCO086088 I11 12I 11/08/19 117 18ICI
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Facility information:
Girmes of America, Inc. - Girmes Site (formerly: SKF USA Inc.)
Groundwater Remediation Facility
WWTP class: I -PC
WWTP type: 0.108 MGD groundwater remediation facility.
Description: Groundwater is recovered from three ground -water wells and treated in an air
stripping unit; parshall flume; Isco 4210 ultrasonic flow meter; and effluent diffuser.
Notes: This system began discharging treated groundwater on 3-4-1998 per an approved Corrective
Action Plan (CAP). Since that time, there have been no instances of permit limits exceedances.
There have been no volatile organic compounds (VOCs) detected in any of the effluent samples
during the past two years. VOC sample results collected from the recovery wells and monitoring
wells located adjacent to the creek have been declining over the past three years (as of
4-1-10). The system is currently off-line, as of mid -November 2009. Just prior to that time, a
chemical oxidant injection of sodium persulfate (10%) was done. The remediation treatment
system was shut down, so that there would be no interference with the migration path of the
oxidant in the aquifer. Monitoring and assessing is still being done to determine if the
oxidant is still persisting in the aquifer to reduce VOC levels. Monitoring results indicate
that the levels are not below NC 2L groundwater standards yet, so the site should remain
actively permitted.
Current Average Flow: 42,000 gpd (when operating)
The permittee requests permit modification for 50,000 gpd monthly average flow limit with no
maximum flow limit (monitor & report).
Officials:
Responsible official: C. William (Bill) McGlocklin
Responsible "'s title: Director of Environmental Affairs
Official's location: 1111 Adams Avenue; Norristown, PA 19403-2403
Authorized Agent: Michael B. Parker, P.E., now: TRC
(formerly: RMT North Carolina, Inc.; RMT is now owned by TRC, as of 6-6-2011)
Address: 30 Patewood Drive; Suite 100; Greenville, SC 29615-3535
Phone numbers: 864-234-9462 Michael B. Parker, P.E; Project Manager
Email: mparker@tresolutions.com
Operator information:
ORC contractor: Mark Swann — Cert. # 28897 — PC -I
Back-up ORC: Robert Barr — Cert. # 28151 — PC -I
Page # 2
Permit: NCO086088
Inspection Date: 08/19/2011
Permit information:
Date issued: 12-1-2005
Expiration date: 10-31-2010
New expiration date:
Currently under review: James McKay
Stream information:
Owner - Facility: Girmes Site remediation
Inspection Type: Compliance Evaluation
Stream: Gashes Creek
River basin: French Broad River Basin
Sub -basin: 04-03-02
Hydrologic Unit Code:
Quads: Asheville / Oteen, NC
Grids: E 9 SW / E 8 SW
Stream classification: C
Drainage area sq mi: n/a
Instream Waste Conc.: 90%
Chronic Toxicity Conc.: 15% Ceriodaphnia dubia - quarterly
Average stream flow:
Summer 7Q10 cfs:
Winter 7Q10 cfs:
30Q2 cfs:
Other information:
January, April, July & October
The old SKF USA Inc. manufacturing site building is now owned by Blue Ridge Motion Pictures.
Bill McGlocklin, SKF USA Inc. has environmental liability for the site and remediation project.
The site is 40 acres and the total building area is 180,000 sq ft. There are 80,000 sq ft long
term leases in place.
Page # 3
Permit: NC0086088
Inspection Date: 08/19/2011
Owner - Facility: Girmes Site remediation
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Is the facility as described in the permit?
# 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:
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
■nnn
Page # 4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 5, 2009
William McGlocklin
SKF USA Inc
1111 Adams Avenue
Norristown PA 19403 2403
SUBJECT: Bioassay Compliance Inspection
Girmes Site Remediation
Permit No: NCO086088
Buncombe County
Dear Mr. McGlocklin:
Enclosed please find a copy of the Bioassay Compliance Inspection conducted on
October 20, 2009.. No violations of permit requirements or applicable regulations were
observed during this inspection. Test results for the samples indicate that the effluent
would not be predicted to have water quality impacts on receiving water.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at 828-296-4500.
Sincerely,'
Jeff Menzel
Environmental Specialist
Enclosure
'cc==AsheuilleFile's"'
Central Files
Mark P Swann, ORC
/ SURFACE WATER PROTECTION — ASHEVILLE REGIONAL OFFICE
4Location: 2090 U.S. Highway 70, Swannanoa, NC 28778 One
Phone: (828) 296-4500\FAX: 828 299-7043\Customer Service: 1-877-623-6748 NorthCarollina
Internet: www.ncwaterguality.org G:\WPDATA\DEMWQ\Buncombe\86088 SKF Girmes Nawralllf
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Com fiance inspection Re
ort
Approval expires 8.31-9B
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
T LJ 2 U 31 INCO086088 111 121 09/10/20- 17
�!
181 Lv1 19 Lis 20LII
l J
Remarks
211111111111llIIIIIIIj_II llllllllll�lillllll�lil6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 121 CA
——Reserved
67I 169 70L71 U72IJ
73Il174 751 11—I
I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POND, also include
Entry Time/Date
Permit Effective Date
POND name and NPDES per uil Number)
cizmes site remediacion
10:00 AM 09/10/20
os/12/01
Exit Time/Date
Permit Expiration Date
Old vs Hwy 74 6
Asheville NC 28806
11:00 AM 09/10/20
10/10/31
Name(s) of Onsite Representative(s)ritles(s)/Phone and Fax Number(s)
Other Facility Data
Mark P SWann/ORC/628-254-7176/
Name, Address of Responsible Official/Title/Phone and Fax Number
C William MCOlocklin,llll Atlams Ave Norristown PA Contacted
194032403//610-630-2730/6106302780 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated
Operations 8 Maintenance IN Effluent/Receiving Waters
Section D: Summary of Finding/Comments Attach additional sheets of narrative
and checklists as necessary)
(See attachment summary)
Name(s) and Signature/s) f In'pector(s / t Agence cylOff/Phane and Fax Numbers
Jeff Men-- /)`.f� ARO WQ//828-296-4500/
` fDate
Signature of ManagettReviewer Agency/Office/Phone and Fax Numbers , Dale%.
EPA Form 3560-3 (Rev 9.94) Previous editions are obsolete.
NPDES yr/mo/day Inspection Type (Cont. 1
3I NCO086088 I11 12I 09/10/20 I17 18'2,
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
SKF USA Inc. has an effluent discharge permitted that is 0.108 million gallons per day
(MGD) entering Gashes Creek (7Q10 of 0.94 CFS). Whole effluent samples were collected on October 20
and October 23 by Jeff Menzel for use in a chronic Ceriodaphnia dubia multiple -dilution toxicity test. The
test using these samples resulted in a ChV > 60 % which is higher than the 15.0 % whole effluent toxicity
limit for this facility. Toxicity test information follows.
Test Type 3-Brood Ceriodaphnia dubia chronic multiple dilution
Test Concentrations 0.0, 3.75, 7.5, 15.0, 30.0, 60.0% sample
Test Result ChV >60%
Control Survival 100%
Control Mean Reproduction 25.8 neonates
Test Treatment Survival 100%
Treatment Mean Reproduction 25.1 neonates at 60.0% test concentration
First Sample pH 7.97 SU
First Sample Conductivity 388 micromhos/cm
First Sample Total Residual Chlorine <0.1 mg/L
Second Sample pH 7.95 SU
Second Sample Conductivity 335 micromhos/cm
Second Sample Total Residual Chlorine <0.1 mg/L
Test results for the above samples indicate that the effluent would not be predicted to have water quality
impacts on receiving water. These samples were split and sent to Pace Analytical Services in Asheville, the
contract laboratory used by SKF USA Inc. The test performed by Pace also resulted in a ChV>60%.
No violations of permit requirements or applicable regulations were observed during this inspection.
Page # 1 Page # 2
Permit: NCO08608B Owner - Facility: Girmes Site remediation
I Date: 1MO2009 Inspection Type: Bioassay Compliance
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 Solids, pH, DO, Sludge ❑ Cl a ❑
Judge, and other that are applicable?
Comment:
Page # 3
i r'Se
NCDEN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 3, 2009
William McGlocklin
SKF USA Inc
1111 Adams Avenue
Norristown PA 19403 2403
SUBJECT: Compliance Sampling Inspection
Girmes Site Remediation
Permit No: NCO086088
Buncombe County
Dear Mr. McGlocklin:
Enclosed please find a copy of the Compliance Sampling Inspection conducted on
October 20, 2009. No violations of permit requirements or applicable regulations were
observed during this inspection.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at 828-296-4500.
Sincerely,
Jeff Menzel
Environmental Specialist
Enclosure
cc: Mark P Swann, ORC
Central Files
�sl�avtlle*-Flles�`
SURFACE WATER PROTECTION —ASHEVILLE REGIONAL OFFICE
Location: 2090 U.S. Highway 70, Swannanoa, NC 28778 One
Phone: (828) 296-4500\FAX: 828 299-7043\Customer Service: 1-877-623-6748 NorthCarolliina
Internet: www.ncwaterauality.org G:\WPDATA\DEMWQ\Buncombe\86088 SKF Girmes Naturally
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 1 X1 2 I�l 31 NC0086068 111 121 09/10/20 117 18I gl 191 .cl 201LJ
U
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA ------- —--- —------------ Reserved ----- ---------------
67 I 169 701 3 I 71 IU 72 I , I 73 LLJ 74 751 I I I I I Li
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)
10:00 AM 09/10/20
05/12/01
Girmes Site remediation
Exit Time/Date
Permit Expiration Date
Old US Hwy 74 E
Asheville NC 28806
11:00 AM 09/10/20
10/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mark Swann//828-254-7176 /
Mark P Swann/ORC/828-254-7176/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
C William McGlocklin,llll Adams Ave Norristown PA
194032403//610-630-2730/6106302780 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement N Operations & Maintenance 0 Self -Monitoring Program E Facility Site Review
Effluent/Receiving Waters
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jeff Menzel ARO WQ//628-296-4500/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Roger C Edwards ARO WQ//828-296-4500/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
NPDES yr/mo/day Inspection Type
3I N00086088 I11 12I 09/10/20 I17 18ISI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This was a compliance sampling event. At the time of inspection both a TSS and a Toxicity sample was
collected. The result for the TSS sample WAS TSS 6.2 mg/L with qualifier U or Undetectable. The Toxicity
result will be reported in a Bioassay report.
No violations of Permit requirements or applicable regulations were observed during this
Page # 2
Permit: NCO086088
Inspection Date: 10/20/2009
Owner - Facility: Girmes Site remediation
Inspection Type: Compliance Sampling
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
0
❑
❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑
❑
■
❑
Judge, and other that are applicable?
Comment: Pace Analytical handles the sampling at this facility.
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The flow meter was calibrated November 2008.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment: There was no visible sign that the effluent was having an impact on the
receiving stream.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: All samples are grabs at this facility.
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page # 3
North Carolina Department
ivn�uaci r. �aaicy, vvvcinvi
William G. Ross Jr., Secretary
rvironment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Asheville Regional Office
SURFACE WATER PROTECTION
May 24, 2007
._
am
Ea ff
C William McGlocklin
SKF USA Inc
1111 Adams Ave
Norristown PA 194032403
SUBJECT: Compliance Evaluation Inspection
Girmes Site Remediation
Permit No: NCO086088
Buncombe County
Dear Mr. McGlocklin:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for
the inspection, which I conducted at the site on May 11, 2007. The facility was found to
be in Compliance with permit NC0086088.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please do not hesitate to contact me
at 828-296-4500.
Sincerely,
a14-41-�
Keith Haynes
Environmental Specialist
Enclosure
cc: Mark Swann, ORC
Central Fil
= saheviill' I rle
NoLCarotina
Natwally
2090 U.S. Highway 70, Swannanoa, NC 28778 Telephone: (828) 296-4500 Fax: (828) 299-7043 Customer Service 1 877 623-6748
United Stales Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 15I 3I NCO086088 111 121 07/05/11 117 181 cI 191 SI 20III
Remarks
21IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------- —------------------ Reserved --- ------------------
67I 169 701 I 71 UI 72I N I 73I I 174 751 I I I I I 1-1 80
W
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)
09:00 AM 07/05/11
05/12/01
Girmes Site remediation
Exit Time/Date
Permit Expiration Date
Old US Hwy 74 E
Asheville NC 28806
09:30 AM 07/05/11
10/10/31
Name(s) of Onsite Representative (s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mark P Swann//828-254-7176 /
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
C William McGlocklin,llll Adams Ave Norristown PA
No
194032403//610-630-2730/6106302780
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement ® Operations & Maintenance ■ Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
�7
Keith Haynes ARO WQ//828-296-4500/ �i o?3.0 T
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Roger C Edwards`�I�� ARO WQ//828-296-4500/ 5 L y 6
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1
Permit: NCO086088
Inspection Date: 05/11/2007
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Owner - Facility: Girmes Site remediation
Inspection Type: Compliance Evaluation
V-.. I.1.. AIA K1.
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ Cl ■ ❑
Judge, and other that are applicable?
Comment: The groundwater remediation site is operated on a six weeks on six weeks
off schedule. All systems appeared to be operating properly during the time of the
inspection.
Page # 3
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
SURFACE WATER PROTECTION SECTION
Mr. C William McGlocklin
SKF USA Inc.
1111 Adams Avenue
Norristown, Pennsylvania 19403
Dear McGlocklin:
July 22, 2004
SUBJECT: Compliance Evaluation
Inspection SKF USA Inc
Girmes Site remediation
Permit No: NCO086088
Buncombe County
Enclosed please find a copy of the Compliance Evaluation Inspection form from
the inspection conducted on July 8, 2004. Mr. Keith Haynes and I of the Asheville
Regional Office conducted the Compliance Evaluation Inspection. The facility was
found to be in Compliance with permit NC0086088.
Please refer to the enclosed inspection report for additional observations and
comments. If you or your staff have any questions, please call me at (828) 296-4500.
Sincerely;
L Fr st
nvironmental Chemist
Enclosure
cc: Mark Swann - Pace Analytical
Central Files
Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: 828-296-4500 / FAX: 828-299-7043/ Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
Nne
orthCarolina
.Vaturallry
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Form Approved.
OMB No. 2040-0057
Water Com liance 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 INI 2 U 31 NC0086088 111 121 04/07; G8 117 181,1 19 U 20 U
Remarks
211 1 1 1 1 1��
IIIIIIIIII IIIIIILi I I I I 1 1 66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------- ----------
67 169 70 U 71 Lij 72 U1 73 W 74 751 I I I I I I 180
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)
i;irrnes Site remediation
01:00 PM 04/0'7/08
02/07/01
Ol.d U.S. H.i.yhway 74 East
Exit Time/Date
Permit Expiration Date
Asheville NC 28806
01:30 PM 04/07/08
05/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mark _ S:aann/0RC/828-254-7176/
Name, Address of Responsible Official/Title/Phone and Fax Number
C 1,1i11iam McGlocklirr, 11.11 Adams Azle Rorral.stoT,7ii PZ1 Contacted
19403//610-630-273i1/6106302780 INo
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Operations & Maintenance N Facility Site Review
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
arry Frost AR.O WQ//828-296-45GGi828-299-7043
F:eitn HaynesARC :dQ//828-296-=1500/873-299-70-3
Signature of Management ie Agency/Office/Phone and Fax Numbers Date
"t/ I
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
NPDES
3I iC00851. 111 12
yr/mo/day Inspection Type
04%07/08 117 18 Li
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
wl aci.i.ity appears to be in good condition.
Grass riF?eds to be cut: and road better Iilairltairie .
Permit: NCO086088 vner - Facility: SKF USA Inc - Girmes Site i -,..-Jiation
Inspection Date: 07/08/04 Inspection Type: Compliance Evaluation
OoQra#ions & Maint nan Yes No NA N
Does the plant have general safety structures in place such as rails around or covers over tanks, pits, or wells? 0 ❑ ❑ ❑
Is the plant generally clean with acceptable housekeeping? M❑ ❑ ❑
Comment: Facility appears to be in good condition.
Grass needs to be cut.
Road needs to be maintained.