NC0086088_Permit Modification_20020823

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
August 23, 2002
Mr. Dan O. Madison
1111 Adams Ave.
Norristown, PA 19403-2403
Subject: NPDES Permit Modification
Permit No. NCO086088
SKF USA Inc. - Girmes Site
Buncombe County
Dear Mr. Madison:
On June 7, 2002, the Division of Water Quality issued NPDES Permit No. NCO086088 to SKF USA Inc.
On July 15, 2002 the Division received a letter from RMT requesting modifications to the permit. The
Division evaluated the requests and the following modifications were made to the permit:
Total Suspended Solids — Sampling for TSS was modified to a grab sample. The sampling
frequency will remain as monthly.
Chronic Toxicity — Sampling for chronic toxicity was changed to a grab sample.
Operation and Maintenance, Certified Operator — The rules for Water Pollution Control System
Operators Certification specify the frequency for visiting a treatment system. SKF USA Inc. system
is classified as a Grade I physical chemical system and is therefore subject to this rules. Section 15A
NCAC 8G.204(2) Requires the Operator in Responsible Charge to visit the system no less frequently
than weekly.
The Technical Assistance and Certifications Unit has given facilities until December 2003 to
designate the ORC. The boilerplate language in the permit is general language that is included in
every permit. As stated in the letter from the Technical Assistance and Certifications Unit you have
until December 2003 to designate the ORC and you will not be in violation of your permit.
Nevertheless your current operator must visit the site on a weekly basis as required in the rule.
Accordingly, we are forwarding herewith the modifications to the effluent page of the subject permnit.
Please replace this page in your permit.
If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone number
[phone]. ext. 595.
Sincerely,
an W. Klimek, .E.
cc: Asheville Regional Officc Water Quality
Point Source Compliance Enforcement Unit
Aquatic Toxicology Unit
Central Files
L'I
Jeffrey Friend — RMT North Carolina. Inc.
P.O Box 16778
Grenville, SC 29606-0030
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET @ www.enr.state.nc.us

Integrated
Environmental
Solutions
July 2, 2002
pr
I;;! , U L 1 5 2002
DENR - WATER QUALITY
POINT SOURCE BRANCH
Ms. Teresa Rodriguez
NPDES Unit - Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
100 Verdae Blvd. 29607-3825
P.O. Box 16778 29606-6778
Greenville, SC
Telephone: [phone]
Fax: [phone]
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Comments
Permit No. NC0086088, SKF Girmes Site
Buncombe County
Dear Ms. Rodriguez:
On behalf of SKF USA Inc. (SKF), RMT North Carolina, Inc. (RMT) is submitting comments regarding
the proposed permit dated June 7, 2002. We appreciate the Division efforts to review and implement
some of our requested permit changes submitted as part of the NPDES renewal package. Generally,
the NPDES permit is acceptable; however, we request that the Division make the following minor
modifications.
■ Total Suspended Solids (TSS) - We request that the sample type be changed to grab samples
collected on a quarterly basis. We believe that since volatile organic compounds (VOCs) are
required to be monitored quarterly, this frequency should be adequate for TSS as well.
■ Chronic toxicity - We request that the sample type be changed to a grab sample. All of the
monitoring data that we have generated since the discharge began have demonstrated that the
effluent quality is very consistent and uniform. With the exception of one anomalous toxicity test
failure, all past toxicity testing has demonstrated that there is no reasonable potential for any
impacts in the receiving stream. With the steady state nature of the aquifer, we do not have any
reason to believe that there would be a significant change in the characteristics of the discharge
over a period of weeks or even months. A 24-hour composite sampling period appears to be
unnecessary.
w Operation and Maintenanr_e, Certified Operator - Part II Section C.1 stipulates that a certified
operator must visit the site once per week. Since startup, the system has been routinely visited
once per month with additional quarterly maintenance visits. We believe that this schedule is
adequate for this type of treatment system because of the controls and alarms that were
incorporated into the system design. In the event the strippers blower malfunctions, the system
will shut down and initiate an alarm. If the discharge piping should become obstructed, a high
level switch in the stripper sump will initiate an alarm. General alarms are also initiated if there
is a power failure or if the building temperature is high or low. The operators can also remotely
listen to the operation of the air stripper and monitor the conditions of these alarms. It is RMT's
opinion that this type of treatment system can be safely monitored on a monthly basis. The fact
that the system has operated since March 1998 without a permit violation of, or even detection of,
any VOCs demonstrates its reliability.
R:\ DATA\O&M\SKF-G I RM ES\ NPDESRESPONSE2. DOC

Ms. Teresa Rodriguez
North Carolina Department of Environment and Natural Resources
July 2, 2002
Page 2
Finally, RMT has been notified by Mr. Tony Arnold (copy of letter attached) that the permittee
has until December 31, 2003, to comply with the requirement for a North Carolina -certified
Operator in Responsible Charge. Please modify Section C.1 to reflect that this requirement does
not become effective until the end of 2003.
We appreciate your consideration of these comments. We look forward to hearing from you. If you
have any questions, please contact me at [phone].
Sincerely,
RMT North Carolina, Inc.
'A ft
• I
Jeffrey A. Friend
O&M Coordinator
Wastewater Services
Attachments: NC DENR letter dated August 17, 2001
cc: Bill McGlocklin, SKF USA, Inc.
Mike Parker, RMT
Dan Madison, RMT
Central Files
R:\ DATA\C& M\SKF-GIRMES\ NPDESRESPONSE2 DOC