NC0004260_Permit (Modification)_19980706

NPDRS DOCUMENT SCANNING COVER SHEET
NPDES Permit: NC0004260
Document Type: Permit Issuance
S
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Complete File - Historical
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: July 6, 1998
This d tits priat®cl oa reuse patIm r-iapaors aay
co3Mt0at on the ra-Werss side

State of North Carolina
D.epartment of Environment
and Natural Resources 4 • •
Division of Water Quality rr
James B. Hunt, Jr., Governor 1
Wayne McDevitt, Secretary C A
A. Preston Howard, Jr., P.E., Director D C 1 V R
July 6, 1998
Mr. Layton Schuh
Environmental Manager
CR Industries
4307 York Road
Gastonia, North Carolina 28053-1767
Subject: Permit No. NCO004260
Permit Modification and
Authorization to Construct
Groundwater Remediation System
CR Industries
Gaston County
Dear Mr. Schuh:
The Division received a letter of request for a permit modification and an Authorization to
Construct on January 12, 1998. The discharge permit has been modified to allow CR Industries to
discharge no more than 0.148 MGD of wastewater'(consisting of treated groundwater, process industrial
wastewater, and domestic wastewater). Flow from the groundwater treatment system is not expected to
exceed 0.0144 MGD. All wastewater should be discharged through the same outfall. As shown on the
Effluent Limitations and Monitoring Requirements sheet,there are three different sample locations:
• E1 is for parameters associated with the process industrial wastewater flow,
E2 is for parameters associated with the groundwater remediation flow, and
• E3 is for parameters associated with both flows.
Please find enclosed the modified sections of the permit referenced in the preceding paragraph.
Replace the original sections in your permit with the newer enclosed sections and discard the original
sections. All other terms and conditions contained in the original permit remain unchanged and in full
effect. These permit modifications are issued pursuant to the requirements of North Carolina General
Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
If any parts,measurement frequencies or sampling requirements contained in this permit
modification 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,Post Office Drawer 27447,Raleigh, North Carolina 27611-7447. Unless
such demand is made this decision shall be final and binding.
P.O. Box 29535, Raleigh,North Carolina 27626-0535 Telephone [phone]FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%recycled/10%post-consumer paper

r
Mr. Schuh
July 6, 1998
NC0004260/AC0004260
Page 2
This letter also grants an Authorization to Construct and final plans and specifications for the
subject project have been reviewed and found to be satisfactory. Authorization is hereby granted for the
construction and installation of a groundwater remediation system consisting of an air stripper system
with surge tank,transfer pump, low profile air stripper and associated instrumentation. The treated
groundwater will discharge from the air stripper via a buried PVC line tied into an existing manhole that
leads to the facility's existing discharge line which discharges into Crowders Creek(Class C) in the
Catawba River Basin
This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES
Permit No. NC0004260 issued November 25, 1996 and modified April 11, 1997 and shall be subject to
revocation unless the wastewater treatment facilities are constructed in accordance with the conditions
and limitations specified in Permit No. NC0004260.
Any sludge generated from this treatment facility must be disposed of in accordance with G.S.
143-215.1 and in a manner approved by the North Carolina Division of Water Quality.
In the event that the facility fails to perform satisfactorily, including the creation of nuisance
conditions,the Permittee shall take immediate corrective action, including those as may be required by
this Division, such as the construction of additional or replacement wastewater treatment or disposal
facilities.
The Mooresville Regional Office,telephone number(704) 663-1699, shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in-place inspection can
be made. Such notification to the regional supervisor shall be made during the normal office hours from
8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been installed in
accordance with the NPDES Permit,this Authorization to Construct and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box 29535, Raleigh,
NC 27626-0535.
The Permittee for the life of the facility shall maintain a copy of the approved plans and
specifications on file.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with North Carolina
General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying
with any and all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies(local, state, and federal)which have jurisdiction.

Mr. Schuh
July 6, 1998
NC0004260/AC0004260
Page 3
One (1) set of approved plans and specifications is being forwarded to you. If you have any
questions or need additional information, please contact Paul Clark,telephone number(919) 733-5083
extension 580.
Sincerely,
Preston Howard,Jr.,P.E.
cc: Central Files f"
Mooresville Regional Office, Water Quality
Technical Assistance and Certification Unit
Point Source Compliance/Enforcement Unit
Bruce Hickman, Turner, Hart, and Hickman, P.C.
4421 Stuart Andrew Boulevard, Suite 300
Charlotte,NC 28217

Permit No. NC0004260
SUPPLEMENT TO PERMIT COVER SHEET
CR Industries
is hereby authorized to:
I. Continue to discharge 0.148 MGD of treated wastewater from treatment facilities. A package
plant for treating domestic wastewater consists of a comminutor, bar screen, diffused aeration
basin, and clarifier which empties to an aerated lagoon. The industrial wastewater treatment
process consists of a mechanical oil skimmer which empties to the previously mentioned
aerated lagoon, combining with the domestic wastewater. At this point,both industrial and
domestic wastewater are further treated via pH adjustment and aluminum addition, dissolved
air floatation (DAF),pH adjustment for the effluent, mechanical screening, ultrasonic flow
measurement, a sludge holding tank and a sludge filter press. These treatment systems are
located at CR Industries,the intersection of US Highway 321 and NCSR 1103, south of
Gastonia, Gaston County (See Part III of this permit), and
2. After receiving an Authorization to Construct a groundwater remediation system (consisting
of a surge tank, air stripper, and flow measurement),discharge 0.0144 MGD treated
groundwater from this treatment system. Treated groundwater flow(in combination with
process and domestic wastewater flow) is not to exceed 0.148 MGD. All wastewater will be
discharged through the same outfall.
3. Discharge from said treatment system at the location specified on the attached map into
Crowders Creek(Class C) in the Catawba River Basin.

}
A(1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO004260
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge process Industrial
wastewater,domestic wastewater,and treated groundwater from outfall(s) serial number 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT'-: LIMITS MONITORING REQUIREMENTS
'CHARACTERISTICS" r =
3, LbslDay'Y:` Lbs/Day Units(specify) Units(spec+fY1
= _ .Monthly Daily E -!Monthly,. Daily.Maximum Measurerrient Sample
`Average Maxi�inum Average ��. �Frequency <. aTpe, r.' Location�
�► Flow 0.148 MGD2 Continuous Recording I or E3
BOD, 5-day,20°C 37.0 55.0 Weekly Composite E1
Total Suspended Solids 31.0 mg/l 60.0 mg/l Weekly Composite E3
Dissolved Oxygen Weekly Grab E1, U, D 3
Temperature Weekly Grab E1, U, D
NH3 as N Weekly Composite E1 ;.
Fecal Coliform 200/100 ml 400/100 ml Weekly Grab Ell, U, D
Oil and Grease 26 mg/I 52 mg/l Weekly Grab E1
7 Conductivity Weekly Grab U, D
Total Nitrogen(NO2+NO3+TKN) Monthly Composite E1
Total Phosphorus Monthly Composite E1
Cadmium 60 ug/I Weekly Composite E1
Chromium 1510 ugll Weekly Composite E1
Copper 2.03 3.31 Weekly Composite E1
Cyanide 151 ug/I Weekly Grab E1
Lead 0.42 0.68 Weekly Composite E1
Nickel 2658 ugA Weekly Composite E1
Silver 0.23 0.42 Weekly Composite E1
Zinc 1.45 2.56 Weekly Composite E1
Total Toxic Organics 3 2.09 Weekly Grab E1
i, Iron 2/month Composite E1 .
x Chronic Toxicity" Quarterly Composite E3
Chloroform Monthly Grab E2
w 1,2-trans-Dichloroethene Monthly Grab E2
1,2-Dichloropropane Monthly Grab E2
j Methylene Chloride Monthly Grab E2
# Tetrachloroethene(PCE) Monthly Grab E2
fi Trichloroethene(TCE) Monthl Grab E2 y
(Please see Notes on following page)
_ i

Notes:
' Sample locations: E1 -Effluent from process industriatfdomestic wastewater stream following mechanical screening and prior to ultrasonic flow
measurement, E2-Effluent from treated groundwater stream following air stripper and prior to flow measurement, E3- Effluent at point after two
wastewater streams combine, but prior to discharge, I - Influent, U -Upstream, D-Downstream. See instream monitoring conditions an following
page.
2 Combined permitted flow from process industrial wastewater, domestic wastewater, and treated groundwater shall not exceed 0.148 MGD. Flow shall be
measuredtafter the two wastestreams have combined, but prior to discharge through outfall 001.
3 In lieu of monitoring Total Toxic Organics (TTOs), the permittee may submit the following certification statement: 'Based on my inquiry of the person or
persons direcifyy responsible for managing compliance with the permit limitation for total organics, I certify that, to the best of my knowledge and belief, no `
dumping of concentrated toxic organics into the wastewater has occurred since the filing of the last discharge monitoring report."
O.3zot`
4 Chronic Toxicity (Ceriodaphnia), PIF at.3:3-%, February, May,August, and November; See Supplement to Effluent Limitations and Monitoring
Requirements-Special Conditions page A(2).
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts. '
Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent Limitations and Monitoring Requirements-Special
Conditions page.
i
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i

OCF-5
11/20/95 Page of
CASH DISBURSEMENTS CODE SHEET
Shaded(ells(i.a.• Terms Code. SAS item No.. B 1099 Code)will be completed by the Controllers Office
Division: Wt� _ _�— Matching Invoices Only
Vendor Number: 0 $ Q Grp.No. I I New Vendor Buy Entity: 1 6 FIG=Buyi g Gonda as=Ot"senses
Vendor Name: V a PO Number: Partial Pmt.
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CH-ChW Nutrilk n Entered By: ^ CJU 5W Dale: APR 3 [1 148
PC.Cordrad Vendors
CASHDISALS Please use yellow paper.

1
- 1 Affidavit of Publication
PUBLIC NOTICE
STATE OF NORTH CAROLINA i THE GASTON GAZETTE
ENVIRONMENTAL "The Piadmeal's Growing Newspaper"
MANAGEMENT COMMISSION
POST OFFICE BOX 29535 Gastonia, N. C.
RALEIGH,NORTH CAROLINA
27626-0535 4
NOTIFICATION OF INTENT f
TO ISSUE A STATE Personally appeared before me, a Notary Public
NPDES PERMIT of the County of Gaston,State of North Carolina,
On the basis of thorough staff
review and application of Article on OW4,the Q 8 day of 19 9 8
21 of 'Chapter 143, General I
Statutes of North Carolina,
Public Law 92.500 and other of the Gaston Gazette, o, being duly sworn,
lawful standards and regulations,
the North Carolina Environmental states that the notice entitled
Management Commission propos-
es to issue a NPDES Fernqtt
permit to discharge to the persons
listed above effective
512W98 and subject to special
t3YliceTrot:rs. Copies of we—in.formation on file are available
r upon req'pest and payment of
the casts of reproduction, All
such comments or requests re-
garding a proposed permit ' +
should make reference to the I
NPDES permit number listed below, a true copy of which is attached hereto, appear,
ed in The Gaston Gazette, a newspaper publish-
Date 4/1198 + ad in the City of Gastonia, County of Gaston,
A.Preston Howard Jr.,P,E., rr once
Director ;t State of North.Caroline, a week
Division of
00 Environmental Management one e
F for weeks, on the following
' 1 Public notice of intent to issue a jY date&:
i State NPDES permit to the fol- f April $
lowing: nl�1„ 1998 9
VC I 19 —
go 1. NPDES No.NC0004260. CR I
Industries, 4307 South York i 19
Road, Gastonia, NC
28053-8351 has applied for a ; --- - - -- 19 ---
modification for a facility located at f __ _ 19
CR Industries, the intersection of
US Highway 321. and 19
NCSR 1103, south of Gastonia, 19
Gaston County.The facility pro-
poses to discharge treated ` _ 19
groundwater in addition to the f
process Industrial and domestic
wastewater the facility currently
discharge.The combined permitted f The Gaston (N. C.) Gazette
Clow shall not exceed
0.148 MGD (facility's current
permitted flow) and shall be dis-
charged from one outfall Into I Subscribed and swan to this-- 08th_
Crowders Creek, a Class C I
stream In the Catawba River I day of 19--u
Basin which has a 7010 flow of
6.7 cfs, Cadmium, chromium,
copper, nickel, lead,zinc,cyanide
and silver are water quality Notary Public
limited. None of the parameters I
in the treated groundwater ware
water quality limited. For some
parameters, the available load
capacity of the immediate re-
ceiving water will be consumed.
this may
1 C-Aptil 8.1998
my Col•ilfnissian Expires May 5, .21002

NC0004260 Summary
March 23, 1998
r
CR Industries has applied to modify the NPDES discharge permit to include groundwater
remediation treatment system flow (equal to about 0.0144 MGD). This modification is not
requesting an increase in permitted flow. Thus, total wastewater flow (consisting of
treated groundwater, process industrial wastewater, and domestic wastewater flow)is not
to exceed 0.148 MGD. All wastewater will be discharged through the same outfall.
CR's actual flows were examined for the period January 1996 -January 1998. It was
noted that the maximum average monthly flow was 0.059 MGD and the maximum daily
flow was 0.081 MGD during this period. These flows are well below the permitted flow,
thus the system is expected to be able to handle the additional treated groundwater flow
even if CR's process and domestic wastewater flow increases.
The existing permit allows the facility to discharge domestic wastewater and industrial
process wastewater through outfall 001 to Crowders Creek(Class C) in the Catawba River
basin (sub-basin 030837).
Turner, Hart, and Hickman conducted an environmental engineering alternatives analysis
(EAA) of the entire wastewater discharge flow (including industrial process and domestic
wastewater as well as groundwater remediation wastewater). The information needed to
complete the EAA was received January 12, 1998. An existing sewer line transports
wastewater from CR Industries to Crowders Creek. This line is in the vicinity of City of
Gastonia's main sewer line. Unfortunately, CR's sewer line is fairly old, in poor shape,
and composed of several different materials. City of Gastonia would require CR Industries
to remove their existing line and install a new sewer line of the same size and composition
as the main line in order for CR to connect to Crowders Creek WWTP.
The groundwater remediation treatment system will consist of two recovery wells and an
air stripper.
The-effluent will discharge to Crowders Creek(Class C) in the Catawba River basin.
Groundwater was analyzed using EPA Method 601. The highest concentrations detected
during monitoring are compared with water quality standards and EPA federal criteria.
7Q 1 OS=6.7 cfs, Qavg--42 cfs (10/96-WLA).
e r Cam
� � �Conclusil
chloroform YES 1 0.05 470 H o N Monitor
1,2-cis-dichloroe ene A 53 2.65 not s A A o mon
,2-trans-dic oroe ene O 2 .1 1 -o N Norator
1,2- ichloro ro ane NO 0.27 39 H-o NN Monitor
meth lene chloride YES 110 5.5 1600 H -o NN Monitor
tetras0 oroethene(PCE) YES 2 0.1 r-.8: -o orator
tnchloroethene (TCE) YES S T�--8 % H -0 1 2500 ozon
tor
trichlorofluoromethane NO 10 0. none none A o
Cmr--carcinogen
HH-o=Human Health Criterion - organisms
NA--not applicable NN--not necessary to do calculation
(a)Estimated concentrations based on 95 percent removal of volatiles
(b) More stringent of two used when both are available.
Page 1 of 2

• NC0004260 Summary
March 23, 1998
A compound was determined to not be of concern (no monitoring required)if the
compound did not have a water quality standard, federal criteria,or an action level and was
not a carcinogen.
Monitoring will be required if compound:
1. Is a suspected carcinogen,or ;
2.Is not a suspected carcinogen,but has a water quality standard,federal criteria and/or
action level.
The majority of the organics have human health standards. The proposed discharge is to a
Class C stream and therefore,the water and organism criteria are not appropriate and are
not listed in the table. The organism criteria are only appropriate if people consume fish or -
other organisms from the stream. It is impossible to determine this latter point and
therefore,it will be assumed that people may consume organisms from the stream and the
organism criteria will be used. .
Iron and manganese monitoring will also be required as part of standard groundwater
remediation monitoring requirements.
Page 2 of 2

CR Industries
NC0004260
Qeff=0.0144 MGD
Chloroform Trlchloroethene
Qavg (CFS) 42 Qavg(CFS) 42
DESIGN FLOW(MGD) 0.0144 DESIGN FLOW(MGD) 0.0144
DESIGN FLOW(CFS) 0,02232 DESIGN FLOW(CFS) 0,02232
STREAM STD (UGIL) 470.0 STREAM STD(f&[-) V 81.0
UPS BACKGROUND LEVEL(UGIL) 0 UPS BACKGROUND LEVEL(UGIL) 0
IWC(%) 0.05 IWC(%) 0.05
Allowable Concentration(ugll) 884878.60 Allowable Concentration(rogll) 152500
v
1113198

TURNER
HART -
HICKMAN, P.C.
Environmental Consultants & Engineers
March 4, 1998
North Carolina Department of Environment
�+ r
and Natural Resources
Division of Water Quality
P.O. Box 29535 ;ftURCE BRANCH
Raleigh,NC 27626-0535
Attention: Mr. Paul Clark
NPDES Unit
Re: Wastewater Treatment Block Diagram
Permit No. NCO004260
CR Industries, Gaston County
TH&H Job No. COL 1-0003
Dear Mr. Clark:
Enclosed,,per,your telephone request of February 23, 1998, is a block diagram describing
the domestic wastewater, industrial process wastewater, and the proposed recovered ground
water treatment systems at the CR Industries facility in Gastonia.
Please do not hesitate to contact us if you require further clarification or have additional
questions.
Sincerely,
TURNER HART& HICKMAN, P.C.
Gary C. Ribblett, P.E.
Senior Engineer
GCR/jbh
cc: Layton Schuh, CR Industries
Bruce Amig, Coltec Industries
Enclosure
c,WocslcorresSgcrVclazkdiagltr.doc
4421 Stuart Andrew Boulevard • Suite 300 Charlotte, North Carolina 28217
Telephone [phone] • Fax [phone]

{
CR Industries, Inc.
Wastewater Flow Diagram
Industrial Process Mechanical Oil for Disposal
Oil
Wastewater Skimmer Wastewater
1714 0 Ila Aerated Air
Air Lagoon �]
Domestic Overflow ,:r.7 0/000 f�ptL
Comminutor Bar Diffused {/
Wastewater Screen 1,6 of d
ICM
Solid,"O
Di sal
� Chemical Lime
Conditioning Alum
Sludge Solids
` Holding Dissolved Air Air
Flotation
Tank
Final pH Acid
Adjustment
Sludge
Sludge Filter
Disposal Press
Mechanical
Screening
Sampling
Point
Volatiles Ultrasonic
Sampling Z Flow
Point Measurement
Recovered Surge Air Fiow Discharge
Ground Water Tank Stripping Measurement via fall S
kF f Outfall r �}
flati+7 Gt 1,2 /4e_ t o f C�tJK
�rw��'c•X 1ti�'"'//tom. ic.T7�7d �

. r
!, q
t� JAN 2 8 19M .
NCDENR POINT SOURCE BRANCH
DIVISION OF WATER QUALITY
January 23, 1998
MEMORANDUM TO: Paul Clark
(Y
FROM: D. Rex Gleason
PREPARED BY: Todd St. John
SUBJECT: CR Industries
NPDES Permit No. NCO004260
Gaston County
This Office is in receipt of the Alternatives Analysis submitted by CR Industries dated
December 19, 1997. Earlier correspondence from CR Industries indicated that the Company
wants to add groundwater remediation equipment, treat contaminated groundwater(about 10
gpm or 0,0144 MGD), and add the treated groundwater to the effluent without obtaining an
increase of permitted flow. The permitted monthly average flow for the WWTP is 0.148 MGD.
The largest monthly average flow between November 1996 through November 1997 was 0.046
MGD, well below the monthly average permit limit. Therefore, it does not appear that CR
industries would need additional permitted flow at this time.
CR Industries has also proposed continuing to discharge to Crowders Creek. In the
subject Alternatives Analysis the Company has indicated that tapping into the City of Gastonia's
sewer line is economically infeasible. One reason that the Company claims that the project is
economically infeasible is that the Company will have to remove the existing effluent line and
install a new effluent line at a cost of approximately $212,000.00. The existing effluent line
crosses (over or under) the existing gravity sewer line owned by the City of Gastonia. This Office
believes that clarification is needed as to why the effluent line will have to be re-constructed.
(Also, it appears that the Company has inadvertently transposed the directions east and west in its
discussion of effluent/sewer line extension. Crowders Creek as well as Gastonia's subject sewer
line are actually west of the subject facility.)

• I
i
Resolve Environmental �Stervices. P.A.
138 South Main Street 111-Y4 j A 66- l ;o rd C (' 316 South Marietta Street
Monroe, NC 28112 [phone] kt�-A«3w l�o N C 9 7,�(ro/ Gastonia, NC 28052(704)868-8458
January 27, 1997
Mr. David A. Goodrich
-
NPDES Permit Supervisor rill 1
North Carolina Department of Environment, �N �
Health, and Natural Resources �r -J
-
P.O. Box 29535
Raleigh, North Carolina 27626-0535
Re: CR Industries, Gastonia, North Carolina
Modification of NPDES Permit NC0004260 �7
Resolve Protect No. 527.07
Dear Mr. Goodrich:
�o
In December 1996, Resolve Environmental Services, P.A. (Resolve), on behalf
of CR Industries and Coltec Industries, submitted a modification request for the ,
referenced NPDES permit. The letter requested that the existing permit be
modified and expanded to allow discharge of an additional 8 gallons per minute
(gpm) to 25 gpm treated, groundwater recovery wastestream. After re-evaluating
facility operations at CR industries, we do not anticipate that the groundwater
recovery system discharge combined with CR industries discharge will exceed the
daily flow allowed by the existing permit. Therefore, as I discussed with Mr.
Paul Clark, NPDES Permit Group, on January 15, 1997, we desir to continued ` Q
the.��permit ,modification process,�(b 't not�re`""quest an expansion to the allbwalil`e y
fiflaW.
It is our understanding that you have all the information needed to proceed with I
our request and issue a modification to CR industries' permit. Please contact me q
at { # - �1` you have any additional questions. We appreciate your a
assistance in this matter.
Sincerely,/A
Resolve Environmental Services, P.A.
Karen E. Heater, P.E.
Principal Engineer � a ICIJ
cc: ru mi , Coltec Industries V
Bill McGlocklin, SKF Industries
LL-ay-j-q =- -Industries

Aebo( TURNER
HART &
H AN, P.C.
Environmental Consultants & Engineers
January 9, 1998
North Carolina Department of Environment
and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
2 10096
Attention: Mr. Paul Clark �
Environmental Engineer F�Jj'�T SOURCE BRANCH
NPDES Group
Re: Evaluation of Wastewater Disposal Alternatives
Permit No. NCO004260
CR Industries, Gaston County
TH&H Job No, COL 1-0003
Dear Mr. Clark:
Per your telephone request of January 6, 1998, the following information is provided as a
supplement to the December 19, 1997 Evaluation of Wastewater Disposal Alternatives report
submitted to your office.
The information you requested included:
1. A breakdown of the cost estimate for connection to the POTW. Enclosed is Table 1
which includes more detail of the estimate. You will note that the total estimated cost
on the enclosed table is $219,935, which is $690 more than the estimate in the
original report due to a math error in the original report.
2. Additional costs related to the physical connection of the remediation system to the
existing NPDES discharge line. For either of the two primary discharge options
considered, connection to the existing NPDES discharge line or construct a new
POTW discharge line and connect to it, the point of connection would be in a similar
location. Also, the method of connection to the discharge line for either option would
be the same. Therefore, there is no significant cost difference between the options for
connection to the discharge line.
(-1 l o0v, 00)
c yulidcorrlgWcrclarkltr doc
4421 Stuart Andrew Boulevard • Suite 300 • Charlotte, North Carolina 28217
Telephone [phone] • Fax [phone]

TURNER HART & HICKMAN, P.C.
Mr. Paul Clark
January 9, 1998
Page 2
3. More recent Found water analytical data. Enclosed as Table 2 are historical data for
MW-1, which is in the approximate location of proposed recovery well RW-2, and for
RW-1. The most recent data available on Table 2 is from samples collected on
September 26, 1997. Drawing No. 003, also enclosed, shows the locations of these
monitoring wells.
Please do not hesitate to contact us if you require further clarification or have additional
questions.
Sincerely,
TURNER HART& HICKMAN, P.C.
Gary C. Ribblett, P.E.
Senior Engineer
GCR/j lr
Enclosures
cc: Layton Schuh, CR Industries
Bruce Amig, Coltec Industries
c:5j u I i eko:rlgcrlc rcl mkl tr.doc

Table 1
Preliminary Cost Estimate for Connection to Sewer Collection System
CR Industries,Inc.
Evaluation of Wastewater Disposal Alternatives
Task Description Cost
1. Construct 2 New 18"Bore and Casing Crossings Under Road $13,600
2. Abandon Existing Sewer on South Side of Road (1063 LF) $3,500
3. Remove Existing Sewer on North Side of Road (1127 LF) $6,750
4. Remove/Replacement of Asphalt Pavement(1250 LF)
5. Construct New 8" Sewer(2500 LF) )�$25MO
20 000
Subtotal $168,850
10 % Contingencies $16,885
Engineering $34,200
Total $219,935
Notes Concerning Estimate:
1. Estimate taken from September 1997 estimate by Robinson & Sawyer, Inc.
2. Estimate has been based on preliminary information assuming an alignment within the
existing right-of-way of Crowders Creek Road. No right-of-way costs have been included.
A survey of existing conditions and the chosen alignment will be necessary to determine
any additional right-of-way requirements.
3. Estimate includes provisions for two bores under Crowders Creek Road.
4. Estimate does not include provisions for rock excavation.
5. New sewer line will connect to an existing 10" sanitary sewer in Crowders Trail at the
intersection of Crowders Creek Road.

Table 2
Ground Water Analytical Results
CR Industries
Gastonia,North Carolina
Well Date PCE TCE trans-la-DCE cis-1,2-DCE l,l-DCE 1,2-DCP TCFM 1,1,1-TCA 1,1,2,2-TCA MC FZ07ror_
MW-01 Saprolite
12f M3 ROL 722 / RDL ROL ROL ROL DDL ROL ROL ROL ROL
06n9/94 nOtinDL 280/680 RDLRIDL I_DDIIDOL RDUnDL nDL/RDL DDL/DDL RDUDDL nDUDDL ODGRDL QDIIIIDL
03/31/95 ODL 660 ROL ROL ROL ROL DDL RDt, ROL DDL RDI.
01/23/96 ODL 920 ODL ROL ROL ROL ROL 49 ROL ROL ROL -
09/05/96 ROL 560 ROL ROL RDL DDL ROL ROL DDL 54 DDL
03/20/97 1.4 595 DDL 11.5 DDL ROL not, RDL ROL RDL ROL
06I25/97 1 505 ROL 14 DDL ROL ROL ROL ROL ROL ROL
09l26197 DOL 41S ROL ROL ROL DDL DDL ROL QDL DDL
LEGEND -
BDL=Below Laboratory Detection Limits PCE=Tetm.chloroethenc 1,2-DCP=1,2-Dichloropropane
NS=Not Sampled TCE=Trichloroethenc TCFM=Trichlorofluoromethane
"P=Indicates results of split samples trans-1,2-13CE=trans-1,2-Dichloroethene 1.T.I-TCA=1.1,1-Trichloroethane
"Saprolite"or"Bedrock"=Lithologyofscreen interval cis-f,2-DCE=cis-1,2-Dichloroethene 1,1,2,2-TCA=1,1,2,2-Tetrachloroethane
1.1-DCE=1.1-Dich laroethene MC=Methylene Chloride
Notes:
1.All detections arc in ug/L.
2.Table includes only those anal ytes with detections reported

Table 2 (continued)
Ground Water Analytical Results
CR Industries
Gastonia, North Carolina
Well Datc Y
PCE�// TCE trans-1,2-DCE cis-1,2-DC£ I,1-DCE 1,2-DCP TCFM I,l,i-TCA 1,1,2,2-TCA h1C Chloroform
RW-1 Saprolile 114 V
03/20/97 R➢L / j 63-0 R➢L RDL RDL RDL RDL RDL R➢L RDL 9.0
06/25/97 R➢L 37 RRL DDL RDL RDL DDL RDL RDL RDL 13
09/26/97 DDL , 24 ' RDL RDL a RDL R➢L ADL RDL RDL RRL 11
LEGEND
ODL=Below Laboratory Detection Limits PCE=TetrachlorDethene 1,2-DCP=1,2-Dichloropropane
NS=Not Sampled TC£=TrichlDroe[hene_ TCFM=Trichlorolluoromethanc
'P=Indicates results ofsplitsamples trans-l,2-DCE=trans-l,2-Dichlorocthcne I,1,1 TCA= I,1.I-Trichlomethanc
"Saprolite'or"Bedrock"-Lithology of screen interval cis-1,2-DCE=cis-1,2-Dichloroethene 1.1,2,2-TCA=1,1,2,2-Tetrachlomethane
L,I-DCE=1,1-Dichloroethcne MC=Methylene Chloride
Notes:
1.All detections are in ug/L.
2.Table includes only those analytes with detections reported

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NC00042601AC0004260 Summary
June 10, 1998
CR Industries has applied to modify the NPDES discharge permit to include groundwater
remediation treatment system flow(equal to about 0.0144 MGD). This modification is not
requesting an increase in permitted flow. Thus, total wastewater flow (consisting of treated
groundwater, process industrial wastewater, and domestic wastewater flow) is not to exceed
0.148 MGD. All wastewater will be discharged through the same outfall.
CR's actual flows were examined for the period January 1996 - January 1998. It was noted that
the maximum average monthly flow was 0.059 MGD and the maximum daily flow was 0.081
MGD during this period. These flows are well below the permitted flow, thus the system is
expected to be able to handle the additional treated groundwater flow even if CR's process and
domestic wastewater flow increases.
The existing permit allows the facility to discharge domestic wastewater and industrial process
wastewater through outfall 001 to Crowders Creek (Class C) in the Catawba River basin (sub-
basin 030837).
The groundwater remediation treatment system will consist of two recovery wells, a surge tank, a
transfer pump, a blower, an air stripper, and flow measurement.
Review of plans and specifications for the proposed treatment system indicate the system should
adequately treat the wastewater. Please refer to attached spreadsheet and summary for permit
modification for additional information.
Page I of 1

Groundwater Treatment System Design Review 6/10/98
Facility: ;CR Industries '
h--------------------------------------------------------------------------------
NPDES �
-N---C-----0004-2--6-------------------
# 0
Air Flow Rate Water Flow Rate
CFM --------14,4001GPD
I 195 redomneod-eA 54,504liters/day
Air/Water 10.0 GPM
Ratio = 112 wjmj ,•,uvk
146 "to✓nn��
Oil/Water I NA-----------gallons
Separator Size: #VALUE!__;minute detention time
Constituent Concentratiorl Removal Eff. Residual AC Adsorbe AC Absorbed
(ppb) (percent) (mg/1) (mg/g) (g/day)
Chloroform 1 99.59 4.1 E-06
1,2 trans dichlo 2 99.59 8.2E-06
1,2 dichloropro 5 99.59 0.0000205
methylene chlo 110 99.59 0.000451
tetrachloroethe 2 99.59 8.2E-06
trichloroethene 560 99.59 0.002296
I

Turner Hart & Hickman,LP.c.
Memorandum
Phone [phone] Fax [phone]
4421 Stuart Andrew Blvd. Suite 300 Charlotte, NC 28217
To: Paul Clark NCDENR
Fax [phone]
From: Bruce Hickman Date: 6/10/98
e-mail [e-mail]
Re: Extra copy of CR Industries Plans &Specs
Paul:
As you requested, please find attached a spare copy of the CR Industries plans & specs. I have
also inserted the previously submitted air stripper manufacturers' calculation of removal
efficiencies into the appendix so it is all in one place in your file.
Please let me know if you need any additional information.
Thank you,
Bruce Hickman, PE
i
}
dk'
POINT SOQRCE` BRANCH
4Z

IDENRA ATER UAL[ Y
POINT SOURCE 8FMICH
` � 98 MAY 26 AM 8: 18
MCDENR
DIVISION OF WATER QUALITY
May 22, 1998
Memorandum To: Paul Clark
From: D. Rex Gleason
Prepared by: Todd St. John
Subject: CR Industries Groundwater Remediation System
NPDES Permit No. NCO004260
Gaston County
This Office has no objection to issuing an Authorization to Construct permit for
the groundwater remediation system after or concurrently with the issuance of the permit
modification.