NC0085928_Permit Modification_20030801

State of North Carolina
Department of Environment AWWipA
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor 11CDEl.iR
William G. Ross, Jr., Secretary NORTH CAROLINA DEPARTMENT OF
Alan W. Klimek, P.E., Director ENVIRONMENT AND NATURAL RESOURCES
August 1, 2003
Mr. Dirk Jaekel
American Truetzschler Inc.
P.O. Box 669228
Charlotte, North Carolina 28266
Subject: NPDES Permit Modification
Permit NC0085928
American Truetzschler Inc.
Mecklenburg County
Dear Mr. Jaekel:
The Division has reviewed and approved your request to change the monitoring requirement for
Toxicity from composite to grab for the subject permit.
Please find enclosed the revised permit page. The revised page should be inserted into your permit.
The old page may then be discarded. All other terms and conditions contained in the original permit
remain unchanged and in full effect. This permit modification is issued under 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 a written petition conforming to
Chapter 150B of the North Carolina General Statutes, 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.
If you have any questions concerning this permit modification, please contact Valery Stephens at
telephone number [phone], extension 520.
Sincerely,
ianFr`
A an W. Klimek, P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
Point Source Compliance Enforcement Unit
NPDES Unit
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 Telephone[phone] FAX[phone]
An Equal Opportunity Affirmative Action Employer VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration,the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified
below:
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS Monthly Daily Measurement Sample Type Sample Location
Average _Maximum Frequency
Flow 0.05MGD Weekly Pump or Meter Effluent
1,1-DichloroetheneI 0.057µg/L Monthly Grab Effluent
1,2-Dichloroethanel 0.38.tg/L Monthly Grab Effluent
Trichloroethylene(TCE) 2.7µg/L Monthly Grab Effluent
1,1-Dichloroethane 2/Month Grab Effluent
1,1,1-Trichloroethane Monthly Grab Effluent
Tetrachloroethylene(PCE) Monthly Grab Effluent
pH2 Monthly Grab Effluent
Chronic Toxicity3 Quarterly Grab Effluent
Footnotes:
1. The detection limit for 1,1-Dichloroethene and for 1,2-Dichloroethane is 1.0 µg/L. If
the measured level of 1,1-Dichloroethene or 1,2-Dichloroethane is below the detection
limit,then the measurement is considered to be zero for compliance purposes and should be
reported on the Discharge Monitoring Report(DMR)as<1.0 p.g/L.
2. pH shall not fall below 6.0 nor exceed 9.0 standard units.
1. Chronic Toxicity(Ceriodaphnia P/F at 90%),monitor quarterly in February, May, August and
November[see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.

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• ,
A&W
Professional Services, PLLC
JUL 16
July 14,2003
David Goodrich
Director
NCDENR-Permits&Engineering
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: Request Approval for Minor Modification to Ground Water Treatment System
American Truetzschler,Inc.
NPDES Permit No.NC0085928
A&W Project No. 30304X
Dear Mr. Goodrich:
On behalf of American Truetzschler, Inc. (ATI), Aaron & Wright Technical Services,
Inc. (Aaron & Wright) and its professional subsidiary company A&W Professional Services,
PLLC (A&W) is requesting permission to implement minor ground water remediation system
modification. The original National Pollutant Discharge Elimination System (NPDES) Permit
for this system was issued on December 3, 1996 and became effective on January 1, 1997. The
current permit was issued on October 1,2001 and expires on midnight September 30,2006.
Reason for System Modification
Due to failed chronic toxicity testing in 1999 and 2000, ATI requested a modification to
the ground water remediation system in August 2000.The modification at that time included the
addition of two strongly acidic sodium cation exchange units to remove dissolved and total zinc
from the treated ground water followed by the addition of two small limestone filtration filters to
add cations back into the treated ground water prior to discharging to an open ditch. The request
was granted and the modifications completed in August 2001.
On August 28, 2001, ATI's consultant prepared the system for start-up and ran a batch
sample through the system. ATI's consultant collected a sample of the effluent water and had it
analyzed for total and dissolved zinc as well as for VOCs. The system was turned off
immediately after the batch sample was collected. The sample results indicated that the total
zinc levels were still too high to have a successful chronic toxicity analysis. ATI reduced the
bypass water to approximately four gallons per minute (gpm) and increased the amount of
discharge that runs through the resin at approximately twelve gpm. This made the discharge
ratio of one-third-bypass water and two-thirds resin treated water.
A&W Professional Services, PLLC
7523 A Little Avenue, Suite 213,Charlotte,NC 28226 704/543-4221 Fax [phone]

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Mr.David Goodrich
July 14,2003
Page 2
On September 19, 2001, All's consultant turned on the system long enough to sample
the effluent water for VOCs in accordance with EPA Method 601 plus cis-1,2 dichloroethene and
for both total and dissolved zinc. Upon completion of the sampling activities, All's consultant
turned the system off. The analytical results did not indicate detectable VOC concentrations
with the exception of methylene chloride, which was flagged as a common laboratory
contaminant. The analytical report also indicated zinc concentrations were within a range that
ATI's consultant believed would pass the chronic toxicity sampling parameters. ATI's
consultant collected effluent water samples for chronic toxicity testing on September 25 and 29,
2001. All's consultant also collected a grab sample for analysis of total and dissolved zinc on
September 25, 2001. The September 25, 2001 laboratory report indicated acceptable
concentrations of zinc. The laboratory report also indicated a passing chronic toxicity sample.
ATI started the treatment system operations on October 8,2001.
On November 6 and 9, 2001, ATI's consultant collected a sample of the effluent water
and had it analyzed for pass/fail chronic toxicity utilizing Ceriodaphnia dubia at the 90
percentile. The laboratory analysis indicated that the results failed the chronic toxicity test at 90
percent. As a result of this failed test, All's consultant conducted two separate full range
chronic toxicity test utilizing Ceriodaphnia dubia. The first test sample was collected on
December 4 and 7,2001. The results of this chronic test showed a chronic value of 76.5 percent,
which is below the required 90 percent. This test result was similar to the May 2, 2000 bench
test results, which showed that the Ceriodaphnia dubia would live but not reproduce as well as
the control. The test conducted in May 2000 was conducted utilizing the sodium cation
exchange resin, however no limestone filter was used. The similarity in the results suggest that
the limestone filter residence time was not adequate for the current flow or that the limestone has
ceased providing enough cations to produce an environment suitable for the Ceriodaphnia dubia
to live and reproduce.
All's consultant reduced the flow rate from 16 gpm to 6 gpm to increase the limestone
filter residence time and maintained the mixture rate of two parts effluent run through the sodium
cation exchange resin to one part bypass water. All's consultant re-sampled the system effluent
with the reduced flow rate on December 18 and 21, 2001. The results of this full range chronic
toxicity test revealed a second failed chronic value of 76.5 percent. Since no change in chronic
value was observed, ATI's consultant determined that the limestone was no longer dissolving
cations and anions in the effluent water. ATI's consultant also sampled the effluent for water
quality parameters to help establish a proper ratio of calcium and magnesium as well as other
parameters such as total dissolved hardness, alkalinity, standard pH, and sulfate. ATI's
consultant decided to turn the system off on December 27, 2001 until a solution could be
achieved and to help reduce or avoid additional fines while a solution was found.
On January 23 and 25, 2002, ATI's consultant turned the system on long enough to get a
sample of effluent to test several new media and satisfy the NPDES requirement of a second

Mr.David Goodrich
July 14,2003
Page 3
chronic toxicitytest. Duringthis testingperiod, All's consultant conducted a
month full range
full chronic toxicity test utilizing crushed limestone. It should be noted that no water was
allowed to bypass the resin filters during this sample collection to prevent an influence by low
levels of zinc. All's consultant also collected and conducted a sample with 1/3 bypass water
utilizing a neutralite filter media(i.e. 50 percent magnesium/carbonate media)and a soil compost
filter. The neutralite and compost chronic test were conducted for pass/fail at 90 percent only.
The results of the full chronic toxicity test utilizing the crushed limestone passed the test above
90 percent. The neutralite filter media test failed the pass/fail chronic toxicity at 90 percent. The
compost media sample passed the chronic toxicity test above 90 percent. These chronic tests
results also helped confirm that the problem with failed chronic toxicity is the result of the
discharge water being absent of sufficient cations to support the test species. Based on this test
All's consultant determined that the limestone would help add cations back into the system but
that the rate at which limestone adds cations can be unpredictable. The compost filter was used
to see if adding organic matter and naturally occurring nutrients might help buffer the discharge
and provide a more predicable range of cations that would be conducive for sustaining the
Ceriodaphnia dubia.
On February 5 and 8, 2002, All's consultant collected an effluent sample and ran the
sample through a crushed limestone bed and then through a compost filter prior to submittal to
PACE for analysis of pass/fail chronic toxicity at 90 percent. The result of this test passed the 90
percent chronic toxicity. Based on this test it appeared that adding of nutrients by way of organic
material may provide a more stable and reproducible chronic toxicity result.
On April 4, 2002 All was issued civil penalties for failing the chronic toxicity test in
November and December 2001. On May 6, 2002 All requested an administrative hearing,
which was granted and originally set for November 2, 2002. On July 26, 2002, All met with
representatives of the NCDENR, DWQ to discuss the problems with the remediation system.
During that meeting it was agreed that ATI would submit an application requesting for a Special
Order by Consent(SOC)to operate the remediation system for a period of one year to try several
options to resolve the chronic toxicity problem. The three solutions for the system at that time
included the adding of a compost filter, moving the discharge point to the Catawba River or
changing the outfall location to allow the discharge to naturally move through some organic
matter before sampling. In September 2002 ATI submitted an application requesting the SOC.
On October 17, 2002 the NCDENR, DWQ sent a draft SOC for review and signature by All.
All responded by signing the SOC and re-submitted it to the NCDENR. On January 13, 2003
the fmal SOC was received by All.
In an effort to solve the chronic toxicity problem, All and it's new consultant A&W
decided to run several full-scale pilot test while under the SOC. All and A&W revamped the
remediation system by thoroughly cleaning the system, replacing the 3/.-inch limestone filtration
units with two 55-gallon crushed limestone filtration units, and replacing components that failed
to work during trial test runs. On November 15, 2002, Aaron &Wright started the remediation

Mr.David Goodrich
July 14,2003
Page 4
system. As part of the start-up procedures, the sodium cation exchange resins filters were
regenerated and the reject water contained for evaporation. The system was allowed to run for 4
days prior to sampling. On Tuesday,November 19, 2002, A&W collected an effluent sample at
the original outfall (Outfall 001) for volatile organic compounds (VOCs) plus Cis 1,2-
dichloroethene (DCE) in accordance with EPA Method 601. A sample was also collected for
water quality parameters from Outfall 001. In addition, a grab sample of the effluent was
collected for chronic toxicity 90%by Ceriodaphnia dubia. A second grab sample was collected
for acute pass/fail Toxicity Test utilizing Pimphales promelas. A&W took a third grab sample at
a second outfall created approximately 40 feet down stream of Outfall 001. This second sample
was collected to determine if the migration of water through natural debris in the outfall ditch
would affect the test results of chronic toxicity. The third sample was taken from the
downstream location for both water quality parameters and chronic toxicity pass/fail 90%by test
species Ceriodaphnia dubia. On November 22, 2002, A&W personnel returned to the site and
collected a second grab sample from both outfall 001 and the downstream location to complete
the chronic toxicity testing of the Ceriodaphnia dubia 90%pass fail tests.
The laboratory analytical results for VOCs plus Cis 1,2-DCE sample collected on
November 19, 2002, from outfall 001 did not detect VOC constituents above the laboratory
quantitation limit. All three chronic toxicity tests) Outfall 001 Ceriodaphnia dubia, Pimhales
promelas and the down stream Ceriodaphnia dubia)passed. Since all the tests passed, A&W has
concluded that the change in limestone media from Y4 -inch limestone to crushed limestone
sufficiently added cations into the discharge water to allow the test to be successful.
Unfortunately, due to the successful passing all of the chronic tests, the results did not yield a
clear path for ATI to pursue to effectively solve the periodic chronic failures. Attached for your
review is a copy of the laboratory analytical results for the November 2002 testing period. From
this point on ATI and A&W did not pursue the down stream sampling location since it was close
to being off the subject property. The Outfall sample for Pimhales promelas was conducted only
to determine a last alternative if a solution could not be determined.
The system was inactive due to ice damage, which occurred on December 4, 2002, from
December 4, 2002 through February 21, 2003. The system was re-started after repairs on
February 21, 2003. The system ran for a total of 7 days during the month. The system was
sampled for volatile organic compounds(VOC) in accordance with EPA Method 601 plus cis 1,2
dichloroethene per the NPDES requirements on February 25, 2003. In addition, the system was
sampled on February 21 and 28, 2003 for chronic toxicity utilizing Ceriodaphnia dubia at 90%
pass/fail along with other water quality parameters. The analytical results showed no VOCs
present above the laboratory detection limit. However, the chronic toxicity test failed the 90%
Cheriodaphnia dubia pass/fail test. The water quality parameters appeared to be within the
normal range observed when the system passed the chronic rates. In addition, the VOC
constituents were all below the laboratory detection limit. Based on the laboratory analysis, it
appeared at the crushed limestone bed was again not producing enough cations to provide an
optimum environment for the Ceriodaphnia dubia to survive and reproduce at the same rate as

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Mr.David Goodrich
July 14,2003
Page 5
the control. See attached laboratory analytical data sheets for a complete list of constituents and
test results.
Due to the failed chronic toxicity test in February 2003,A&W installed a stainless steel compost
filter at the discharge point at outfall 001. The compost filter was constructed of Stainless Steel
and had the dimensions of 3.79 feet square and 3 feet tall. The compost filter allows
approximately 7 cubic feet of compost to be used as a filter media, which will add nutrients to
the discharged water prior to it being discharged to the open ditch. The filter was installed on
March 14, 2003. The compost was purchased form a local hardware store (Lowe's Home
Improvement). On March 25 and 28, 2003 A&W collected a grab sample of the compost
material and had it analyzed for total RCRA metals, Semi-volatile organic compounds,(SVOCs),
VOCs, and Pesticides. In addition, A&W collected grab samples of the effluent from outfall 001
for chronic toxicity pass/fail testing utilizing Ceriodaphnia dubia along with the water quality
parameters and volatile organic compounds (VOCs) plus cis 1,2 dichloroethene in accordance
with EPA Method 601 per the NPDES requirements. The discharge water sample passed the
chronic toxicity test. In addition, no VOCs were detected in the effluent water above the
laboratory detection limits. Therefore, the system met the effluent limit requirements for the
month of March 2003. The compost sample results did detect several metals and SVOCs present
in.the compost but they did not cause problems with the chronic toxicity. See attached
laboratory analytical results.
On each Tuesday and Friday,ATI opens the compost filter and replaces approximately 1
cubic foot of compost material. The removed compost material is placed back with the other
compost for re-use. On April 22 and 25, 2003, May 20 and 23, 2003, A&W collected grab
samples of the effluent from Outfall 001 and delivered it to PACE Analytical Services, Inc. for
chronic toxicity pass/fail testing utilizing Ceriodaphnia dubia along with the water quality
parameters and volatile organic compounds (VOCs) plus cis 1,2 dichloroethene in accordance
with EPA Method 601 per the NPDES requirements. The discharge water sample passed the
chronic toxicity test. In addition, no VOCs were detected in the effluent water above the
laboratory detection limits. See attached,laboratory analytical results.
Based on the last four months of successfully passing the chronic toxicity sampling while
utilizing the compost filter it appears that the solution to the chronic toxicity problem is the
addition of nutrients through the compost filter. Based on these successes ATI and A&W are
requesting the system modifications become permanent.
System Modifications
The ground water remediation system modifications include the changing out of the two
8-inch diameter by 4 feet tall limestone filtration units which originally used 3/4-inch limestone as
. a buffering agent with two 55-gallon,gravity feed,crushed limestone filtration units. These units

Mr.David Goodrich
July 14,2003
Page 6
will each hold approximately 5 cubic feet of crushed limestone or a total of approximately 10
cubic feet. After the crushed limestone, A&W is adding a compost filtration unit constructed
out of stainless steel. The unit holds approximately 7 cubic feet of compost material. The entire
compost filter measures 3.79 feet wide by 3.79 feet long by 3 feet tall. See the attached flow
diagram for the minor modification schematics.
Based on the research and bench test conducted by A&W,the above minor modifications
should resolve the toxic levels of zinc discovered in the effluent water. Attached for your review
is a letter from All authorizing Aaron & Wright Technical Services, Inc. (Aaron & Wright) to
submit this request for system modification. Aaron & Wright has subcontracted it's subsidiary
A&W Professional Services,PLLC a North Carolina professional corporation submit this request
on All's behalf. In addition, attached is the flow schematic and supporting laboratory analytical
results. Please contact me with your approval to construct the minor system modifications. Per
your guidelines A&W has included three copies of the request. If you have any questions or need
additional information please contact me at(704)543-4221.
Sincerely, ,.11'jf141�j �s�.
X01 _ C A:;,`; }'1`'i
A&W PROFESSION: c;' ' ' :." ; �.C.
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Andrew Pitner,NCDENR,Mooresville Regional Office
Kevin Bowden,NCDENR,DWQ
Shannon Langley,Point Source Compliance/Enforcement
Dirk Jaekel,All
John Guglielmetti,All

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VALVE MOORES CHAPEL ROAD SCALE: NONE
CHECKCHARLOTTE, NORTH CAROLINA PROJECT NO. 030304X