NC0086088_Issuance of Permit_20151114

OF W A TFq
,off o� © A
-CIO r NCDENR
o �
Mr. C. Williams McGlocklin
SKF USA, Inc.
1111 Adams Ave.
Norristown, PA 19403
Dear Mr. McGlocklin:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
November 14, 2005
Subject: Issuance of NPDES Permit NCO086088
Girmes Site Remediation
Buncombe County
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 1 NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
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
[phone], extension 594.
Sincerely,
Luw r//-AAlatn W. Klimek, P.E.
cc: Central Files
Asheville Regional Office/Surface Water Protection
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.
J�'
G
r- an W. Klimek, P.E.
T)i'rPrtnr
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:
EFFLUENT
CHARACTERISTICS
EFFLUENT
LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
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 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 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 tonicity 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.

WV-07-2005 MON 12:06 PM ENV SCIENCES BRANCH
FAX NO. 919 733 9959 P, 01
►,t r r;; ra i rrl
f1nirummealal
Sufxriolr.;
November 2, 2005
Mr. C. imdes Wcavor
Waler 0ualily/NI'l)l-*.S Unit
NorlhC<irohna I)epa'llnentof Environment and Nalur, l Rosources
1617 Mail Service Center
Ralci�,h, Nurih Car(rlilut 27699-1617
Suhjecl: Rc;view of I)r.ift NI'I)i:S fermis k .1 AA ±
.to r.11CWl'od Drive, suilt! 100
1'.11cwood Plait (roe
(ilt•r lmv, su 29615 t535
fdvM"nw: Rbrl-3A14M10
%; S64 2414UAN
wtew.r mmmCor))
S1;1' -- Giri-nee Site
NPI)1':': I'er+nit No. NCO0860SS
lrllnlllllll-1t. C<)1111ty +.z..aa,Yv"::`�}ii
I )ear Mr. Wc-aver:
RMT haS rt'vicwc'll the proposed National I'ullutaut Di:>charf;e Elimination System (NI'UItS) I'crmit
Illat MIS iti: uccl on Soplember 28, 2005, by the North ('orolina I)epadrnent of FrIviionment and
Natural Nv,,;ourves (NC hl-?,NR). This tc'ttct• summ;►rizvs our review of the draft hermit mid includ,
for clonys that we bclievc: arc approp6ato fora discharge Of (his type.
Althuul;ia ihC 114111lrlittal letter indicates that there work- no significant chant es, RMT noted one
chonSo f"ba the current permit dust we l.tc•14ve is signihmnt, in that it will increase the level of effort
lcl hc�n3ply wills the perltitil. In the draft permil, NC DEN1: Kis proposed composite smilples for total
r:u:au>n(Ic d soli(ls (I SS) and chronic toxicity. The current permit specifics a Arab samples for dies-c as
well as to vulatilc' organic compounds. Since ('ontpusite sanlplirit; will increase the` effort to collet
snn11'>los, am! h"-auie RMT believes that gmb samp(c.S are adcd(o ualc r all parameters„we �
recowiiiend (hat iht` final pcnniI have grab sampling for all parameters. C%-0`'`i`' -jam
21 Rkfr does not agree with NC DENR's isserlioti Ihat'I'SS monitoring is necessary because it is an 'o
11 indicator of, vffcrtivo:tws of the treatment syslorn, We ilnderstind that TSS can be in important
cl McIvrahmi in caltnilrlling wasteload allucalium;, but This facility has never discharged measurable
cunccnhatiuns cl,f T.SS. 'l.'hercfore, we do not believe that it is worthwhile to conlinui ig the analysis of or
ISS hit Ilie treated effluvot and request that this paisnxicr be dropped fnivm the final hermit, AID
I:M'I Mtcrltl►t.•d tc, convince NC UENR in 2001 Hial. conlinuilte the effluent chronic toxicity io,<s will
nnl yield useful information. As the monitoring reports indicate, this discharge has an excellent
fecord of complimwe with all of the parameters ou isle 4411PS permit, intauding toxicity. RMT
thti,ll�lC1'S w1111 th(` :IS:<i'1'tll,rll that the di -,charge fr(mi Tv f,,KF—CArrIu%SW IS a crinlpQ musle. Wv .. //
ol!,o tli�.,igict' Owl, FA NCAC. 2B .050A, which dv�;cribt-; ino,liioririg frctj(wncien for intltic•lri,il - N0
dit;charg,or:i, is applicable to (his discharge. i;el'ause of the nalure of the wastewater discharged from
Ibis Sill' and tho wonilorinf; results that have consistently demonstrated that the chronic value is
gn lter Hun AD percent, we do not believe that cun""tied inunilorinl; is justified. We request that
I� lCl:. tit\�L4�l �IKA11•.!iVU1�l1"� PP7.1 )(N�

MOV-07-2005 MON 12:07 PM ENV SCIENCES BRANCH FAX NO. 919 733 9959 P. 02
Mr. Charlc!; Woaver
North C.Aroiina Dcliarlment of Environnit nl alit Nalural Resources
November 2., 2005
Page 2
grvaler than (►O Ix rcent, we do not bolieve ilia continued 111011it0ring iS juSlified. We requeA llim
chronic toxicity by dropped from the permit and believe that a no reasonable potential calculation will
stipport this.
Tha draft permit is based on file design capacity flow of 0.108 mgd. RM`T believes that the permit
shl)uld be hasr:d on aclual discharge flow data. For th►r days of 2005 when a discharge oCCurred (data
for January Iltrou�;l1 Schlcml!c�r), the monthly average flow rates ranged from 34,700 Slid t) 43,300
gpd. Thesc.- values .arc 32 to 40 percent of flu` flow rate Ihit the permit is bused on. Thc permil writer
s:hrmld acknowledge this discrepancy, adjust the permitted flow to a value that is representa live of
present oper,llions, and change the chronic lux irity lost concen I ration to the ahpropriale value. A /)
Finally, in lho )+ad S;hoct, NC DF?NR liras [lie facility address as 4328 Scxtth York Road in Gastonia.
'Ibis addro.-;s,nay br. for SKI' USA's CR IndList i ios facility in Gaston Counly. - 0\1c—
PIcase lei uS know if we can provide any information that will assist you when evalualing these
rrclurslctl tllndifiCalion. I CALL be reached at WA-234.9137 or at icff.friandPrmlinS_co ij. 'Thank you for
your effo rls in preraring an appropriale perrnit for the SKIT-Girnws silo.
Sincerely,
I:M'C Norllt Carolina, Inc.
l
Jaffrey A. Vrir-nd
O&M Coordinator
ce: I3ili McGlocklio -- SKF USA
Mika Parker, Dan Madison - RMT North Carolina
File 70114- 35
r VA%I%'IN P CIIehlI SV014.11'i W? I*IC

imap://[e-mail]:143/f...
Subject: Draft Permit Reviews (2)
From: John Giorgino <[e-mail]>
Date: Thu, 13 Oct 2005 14:15:40 -0400
To: sergei chernikov <[e-mail]>
Sergei, I have reviewed the following:
NCO086827 Brentag Southeast - No Comments
NCO086088 Girmes Site Remediation - sample is listed as a composite, this facility has
been taking a grab sample.
Thanks for forwarding the drafts.
-John
John Giorgino
Environmental Biologist
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
Mailing Address:
1621 MSC
Raleigh, NC 27699-1621
Office: 919 733-2136
Fax: [phone]
Email: [e-mail]
Web Page: http://www.esb.enr.state.nc.us
I of 1 10/ 14/2005 8:19 AM

PUBLIC NOTICE
STATE w i - ;
NORTH CARO -;,,. LINA � a
ENVIRONMENTAL He County hools, 3600HOY
lit Scgy
MANAGEMENT
Road, Henderson
COMMISSION/ wood
NPDES UNIT Ville, North Carolin
1617 MAIL SERVICE has applied for renews
NPDES Fermi
CENTER of
RALEIGH, NC NC for its Wes
High. Schoo
27699.1617 Henderson
e der
NOTIFICATIONHpermitt
TO SSUE County. This
treated wastewater discharge
AFFIDAVIT OF PUBLICATION
WA TEWATER
PERMITl I Mill Pond Road m th
French Broad River Ba
On the basis of th0r0u9 sin. Currently, CBO
and aPPIi I and ammonia nitroge
lim
staff revleW
cation of NC Genera are water quality
Statute 143.2E iced. This discharg
affect future alto
oth may
law 92 So0 and o
in this portion o
BUNCOMBE COUNTY
an
Ilawful standards an i cations
regulations, the Nart the watershed.
SS.
Carolina Environmen
tal Management Com Dana Hill Corporatio
has applied for renews
CAROLINA
1 mission Proposes To is �PWNORTH
o Ts WWTP Nn Hendof permit efso
D scharge�on Elimiinat
(NPDES County. This
wastewater dmitt
System discharge
ischarg facility
to the person(s treated wastewater 1
Before the undersigned, a Notary Public of said
permit
listed below effective
from the Publ, an unnamed inbuta
is to Devils Fork. e th
County and State, duly commissioned, qualified and
days enchCurrentlR1eBOD
date of this notice.
sin.
nitrogen, fe
authorized by law to administer oaths, personally
Written comments re ammonia
act v e residuaCal l) fo m a chlorine toots
with
appeared Darryl Rhymes, who, being first duly
permit be
until 3o days after th 'water quality limited
date of this na This discharge may of
sworn, deposes and says: that he is the Legal
publish
Lice. All comments re feet future allocation
ceived prior to that dot in this tertian . of t"
Broad River Ba
Billing Clerk of The Asheville Citizen -Times,
are considered in the fi French
nal determinations re sin. ,.
the propose
engaged in publication of a newspaper known as
garding r
permit. TheDirector o Mizpah, Healthcae, Inc
N00074110 fo
The NC Division of Wa has applied for renews 6,,j
Xhe Asheville Citizen -Times, published, issued,
Ter qualitY maY decid 0f permit
Vie
I hold a public meet n its Mountain
Henderso
and entered as second class mail in the City of
for The proposed .Fermi WWTP in
should the. Division re County.. This discharge
Asheville, in said County and State; that he is
ceive a significant de faciliiv
gree of Public interest. Onated UnnamedeTribul(I
authorized to make this affidavit and sworn
Copies of the draft per to Featherstone Cree
other support in the French Bros
mit Currentl
statement; that the notice or other legal
.,and
ing {ftformation. on fil River Basin.
used to determine can BOD, ammonia nitr
fecal c0liform rin
advertisement, a true copy of which is attached
ditions present m th Ben,
draft Permit are avail total residual chlorin
an are wafer gU01itY ism
hereto, was published in The Asheville Citizen -
able upon request
Payment of the costs a iced. This discharg
Mail com may affect future. silo
�,ments
Times on the following date: September 30, 2005
reproduction.
and/or request cations in this portion o
for information to th the French Broad Rive
in which said notice, paper, document or legal
NC Division of Wate Basin..
Quality at the above ad
Poin Henderson County
paper
advertisement were published were, at the time of
dress or call The re
Source Branch at (919 ties has applioededforr r
ext 520 or 363 newal of Fermi Pl ach and every publication, a newspaper meeting all
733.5083,
Please include th NCO086070 for Jts
NPDES Permit numbe Justice Academ,i
Henderso
of the requirements and qualifications of Section -
(attached) in any comWWTP in
munication. intereste. County. This. Per mitt
dischaige
597 of the General Statues of North Carolina and
1 Persons may also yisi ,facility
the Division of Wate ',treated wastewater t
N. Solis Lewis Creek it Tn
was a qualified newspaper within the meaning of
qualiiv at 512
Street, Raleigh French Broad River Ba
burr
NC 27604_„4g betwee sin. Currently BOD, am
feca
Section 1-597 of the General Statues of North
the hours of 8 am ^ 5 P monia nitrogen,
to a reviev Tnformati coliform °rid total resid
Carolina.
wale
on file.' g ual chlorine are wale
limited. Thl
Quality
f
Camp `Judaea Inc-, ane discharge' may off
future allocations In
' '
Camp .Judaea oo
Hendersonville, Nort portion of. French Broa
Signed this 3rd, October 2 05
Carolina 28739 has a River Basin.
plied for renewal o
Perms Inc. (11i
NPDES
Adams
Nuofor its Cam Adams Ave., Norris
WWTP in Hen town, ,PA 19403) has ap
Judaeaeo
' derson County. Thi plied' for renewpermi
facility dis NPDES
the
(Signature of n malting affid )
,permitted Gime
charges treated waste NC0086088 for
Henderso site in Buncombe Coun
per
water to
Creek.. in the , Frenc cilitY This
dischargesrmietreto
Basin. Cur at
Broad ;River
renTly, CB and am ed groundwater to th
creek in th
Sworn to and subscribed before me the 3rd day of
mania .nitrogen. are wa Gashes
ter qualitY {irrtited..Thi French Broad River ea
affe< Currently TSS ar
October 2005
discharge .may sin.
future allocations in thi water qualitY limited
discharge may of
Portion of the water This
shed. - ' "� fect future allocations 1
this portion of ih
J� rF
Henderson County Pub French Broad River Ba
`�,•`P
Uluz
lic Schools, 3555 HOY sin.
Road, Southeas
woad
September 30, 2005
of Rugby, North Caroli Septeepte
re
(Notary blic}
Sr
no has applied for (
1 newal. 6 NPDES pRugberms
NCo066664 for its -Echo
schoo
My Commission expires the 3rd day Qf ep` r�rr�b�#—
1
Junior High
in Henderso
�iy. This pschar a
P UBLIC
2008, t$)G
UkA facility - discharge
treated wastewater t�JCQf,�e`
th
�o,,;,,.•
Mill Pond Creek in
Broad River Ba
°j°°+an.11110°
French
sin. Currently, CBO
and ammonia nitroge
waThisle qu lim
ited. discharg
uTu re to
Po
ccations incthi rtion
the watershed.

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NCO086088
Far_ility InMrmatien
Applicant/Facility Name
SKF USA Inc. / Girmes Site
Applicant Address
1111 Adams Ave. Norristown, PA 19403
Facility Address
4328 South York Rd., Gastonia
Permitted Flow (MGD)
0.108
Type of Waste
Groundwater
Facility Class
NR
County
Buncombe
Facility Status
Renewal
Regional Office
Asheville
Receiving Stream
Drainage Area (sq. mi.)
Summer 7Q10 (cfs)
Winter 7Q10 (cfs)
30Q2 (cfs)
Average Flow (cfs)
IWC (%)
stream cnaracteristics
Gashes Creek
Stream Classification
5.98
Drainage basin
0.94
Subbasin
NA
Use Support
NA
303(d) Listed
NA
State Grid
15
USGS Topo Quad
C
French Broad
04-03-02
FS
No
E8SW / E9SW
Asheville / Often
Summary SKF USA Inc. owns the groundwater treatment system at the Girmes Site and:ui.
RMT Integrated Environmental Solutions operates the system. This treatment system has.,"I
been in operation since 1998.
Permit Issues SKF USA Inc. is requesting permit renewal and the elimination of TSS, and
chronic toxicity. `
Facility Description The treatment system consists of an air stripping unit, a parshall flume
and effluent diffuser.
COMPLIANCE REVIEW
NOVs
Review of the correspondence indicates that facility has a good compliance record.
During previous permit cycle only one NOV was issued on 04/08/02 for violating
toxicity standard. Compliance Evaluation Inspection Conducted on 07/22/04 found
that facility is in compliance.
Whole Effluent Toxicity (WET) Test
WET requirement is a Quarterly Chronic Toxicity Pass/Fail using Ceriodaphnia at 15%.
They have passed all the toxicity tests since 2001 with one exception.
Reasonable Potential Analysis (RPA)
Thrichloroethene, 1,2-Dichloroethene and vinyl chloride were below detection level Who g
past 3 years, therefore a RPA was not required. ,
Fact Sheet
Renewal -- NPDES Permit NCO086088
Page 1

PROPOSED MODIFICATIONS
No changes are proposed.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
NPDES UNIT CONTACT
September 28, 2005 (est.)
November 14, 2005 (est.)
If you have questions regarding any of the above information or on the attached permit,
please contact Sergei Chemikov at [phone] ext. 594.
Regional Office Comments:
(D <-Q" �55>'O'xv- 4p— ok r
Fact Sheet
Renewal -- NPDES NCO086088
Page 2

Integrated
Environmental
Solutions
April 27, 2005
MAY 3 2005
DENR - WATER QUALITY
POINT SOURCE BRANCH
Mr. Charles H. Weaver, Jr. y
Water Quality/NPDES Unit .. __
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
30 Patewood Drive, Suite 100
Patewood Plaza One
Greenville, SC 29615-3535
Telephone: [phone]
Fax: [phone]
www.rmthnc.com
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
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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.
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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).
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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 [phone].
Sincerely,
RMT North Carolina, Inc.
Jeffrey A. Friend
Operations Coordinator
Attachments
cc: Bill McGlocklin, SKF USA
Mike Parker, Dan Madison - RMT
File 70144.35
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Table 1
Summary of NPDES Permit Limitations
PARAMETER
LIMITS
FREQUENCY
Flow
0.108 m d
Continuous
TSS
30 m
Monthly
WE
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
PARAMETER
JANUARY
FEBRUARY
MARCH
Flow - m d
0.044
0.0391
02
T'SS - m
<3.3
<2.1
-
WE -
<1
-
-
1,2-DCE -
<1
-
-
VC -
<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
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FACT SHEET FOR EXPEDITED RENEWAL
Permit Number
to 0 3 8
Facility Name
Reviewer
Basin/Sub-basin
Receiving Stream
Stream Classification in permit
Stream Classification in BIMS
Is the stream impaired (listed on 303(d))?
Is stream monitoring required?
Do they need NH3 limit(s)?
Do they need TRC limit(s)?
Do they have whole -effluent toxicity testing?
Are there special conditions?
Existing Expiration Date
Proposed Expiration Date
Miscellaneous Comments:
If expedited, is this a simpler permit or a more difficult one?