NC0086088_Renewal Application_20150430

30 Patewood Drive
Suite 300
Greenville, SC 29615
864.281.0030 PHONE
864.281.0288 FAx
www.tresolutions.com
April 28, 2015
Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Permit Renewal
RECEIVEDIDENRID\NR
APR 3 0 2015
Water puaiity
PermOnQ Sec'tir
SKF USA, Inc. — Girmes Site Remediation NCO086088
Buncombe County
Dear Mr. Thedford:
TRC Environmental Corporation (TRC) has been retained by SKF USA Inc. (SKF) to
operate and maintain the SKF — Girmes Site Groundwater System in Buncombe County
near Asheville, North Carolina per an approved Corrective Action Plan (CAP). The
system began discharging treated groundwater on March 4, 1998. Groundwater is
recovered using three groundwater recovery wells, treated in an air stripper, and
' discharged under the site's NPDES permit. The receiving stream is Gashes Creek,
which was classified in 1997 as a "Class C" tributary of the Swannanoa River in the
French Broad River basin. The recovery system was taken off-line in November 2009.
' If site conditions change, there may be a need to put the recovery system back on-line.
Therefore, SKF is requesting renewal of this NPDES permit (NC0086088).
Since the system began operation in 1998, there have been no instances where the
concentration of a permitted parameter exceeded the limit specified in the current
NPDES permit. In fact, no volatile organic compounds (VOCs), which are the
parameters of concern at this site, were detected in any of the effluent samples collected
in at least the last two years of operation.
Operating History
As groundwater recovery operations continued, the volume of water recovered
declined to an average of approximately 42,000 gallons per day (gpd) in 2009, prior to
taking the system off line. Also, the concentration of VOCs in the recovered
groundwater decreased. When recovery operations began in March 1998, the influent
trichloroethene (TCE) concentration was approximately 2,900 parts per billion (ppb),
but declined to approximately 300 to 400 ppb. In an effort to increase VOC removal, in
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Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
April 28, 2015
Page 2
November 2002, the system began operation in a pulsed pumping mode, with the
recovery system in operation for six to seven weeks, then shut down for the remainder
of the quarter. The pulse pumping cycles started in the beginning of January, April,
July, and October of each year. When the pulsed pumping mode of operation was
initiated, the concentration of TCE in the influent increased to approximately 1000 ppb.
Pulse pumping continued through the last quarter of 2009, when in October the influent
concentration of TCE was 338 ppb. Additionally, the amount of TCE removed by the
recovery system declined over the last four years of its operation where over 80 pounds
of TCE was removed in 2007 and 22 pounds of TCE were removed during 2009. The
recovery system has been off-line since mid -November 2009 and may remain off-line
pending results of periodic monitoring at the site and Gashes Creek.
An evaluation of the effectiveness of the recovery system was conducted prior to the
system being shut down in November 2009. This evaluation included reviewing the
groundwater sampling data collected from the recovery wells and monitoring wells
situated adjacent to Gashes Creek. Using flow data for Gashes Creek, TRC performed
an initial calculation to estimate VOC concentrations that could be present in
groundwater without contravening a surface water standard. The concentration of TCE
' that could potentially discharge into the creek while protecting the surface water
standard was significantly higher than the VOC concentrations detected in
' groundwater near the creek. Periodic monitoring of select monitoring wells near
Gashes Creek, surface water and pore water along Gashes Creek is conducted to
evaluate any possible changes in the impact of the groundwater on Gashes Creek. If
groundwater VOC concentrations increase to a point that water quality standards in
Gashes Creek are threatened, the recovery system may again be put back on-line hence
the need for a renewed NPDES permit.
' Other Requirements
' Per the instructions for NPDES renewal packages, we are including the following
additional information:
' ■ United States Geological Survey (USGS) topographical site location map
(Attachment 2) indicating the location of the outfall diffuser.
■ A summary of analytical results for January, April, July, and October 2009 (see
' Table 2, Attachment 1), the last four sampling events prior to taking the system off
line. Please note that these months include results for VOCs, TSS, and chronic
' toxicity.
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Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
April 28, 2015
Page 3
Since this facility does not generate sludge or other treatment residue, a sludge
management plan has not been developed for the SKF — Girmes Site. A signed
statement regarding sludge management is presented in Attachment 4.
SKF has designated Mr. Dan O. Madison, TRC as their Authorized Representative to
prepare this permit renewal package. Mr. Madison also retains delegated signatory
authority for NPDES DMR forms for this site. Documentation of this authorization is
presented in Attachment 5.
We appreciate your efforts to work with us to develop an appropriate permit for the
■ SKF — Girmes Site Groundwater System and look forward to discussing the permit
renewal with you. If there are any questions, please call me at (864) 234-
9329/[e-mail] or Mr. William McGlocklin at SKF at (267) 436-
■ 6930/[e-mail].
Sincerely,
■ TR vironmental Corporation
■ Dan O. Madison, PG
Project Manager
1 Attachments
cc: Mr. William McGlocklin, SKF
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Attachment 1
Tables
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Table 1
Summary of Current NPDES Permit Limitations
PAR UMEHR
arts
FRBCAN311 `Y
Flow
0.108 mgd
Continuous
TSS
30 mg/L
Monthly
TCE
MRO)
Quarterly
1,2-Dichloroethene (DCE)
MR
Quarterly
Vinyl chloride (VC)
MR
Quarterly
Toxicity (Chronic Value)
ChV at 15%
Quarterly
I11 Elevated detection limit.
Table 2
Summary of Maximum Observed Values for 2009
PARAE7ER
JANUUWY
APRL
AXY
OCiO M
Flow, average — mgd
0.046
0.045
0.046
0.045
TSS — mg/L
<1
<2
<5
<251
TCE — Ng/L
<1
<1
<1
<1
1,2-DCE — Ng/L
<1
<1
<1
<1
VC — Ng/L
<1
<1
<1
<1
VOCs by 601
NDO)
NDO)
NDO)
NDO)
Toxicity (Chronic Value)
ChV>60%
ChV>60%
ChV>60%
ChV>60%
Volatile halocarbons by Method 601 were not detected in the effluent at the detection limit of 1 Ng/L (2 Ng/L for
chloromethane and methylene chloride)
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1 Attachment 2
' USGS Location Map
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Attachment 3
NPDES Permit Renewal
Short Form C-GW
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NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number C0086088
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name SKF USA, Inc.
RECEIVED/DENROWR
Facility Name Girmes Site Remediation
4 P R 30 20151
Mailing Address SKF USA, Inc., 890 Forty Foot Road, PO Box 352
Water Quality
City Lansdale
ermi mg Sectior
State / Zip Code PA, 19446
Telephone Number [phone]
Fax Number [phone]
e-mail Address [e-mail]
2. Location of facility producing discharge:
Check here if same as above ❑
'
Street Address or State Road off Old Highway 74 East
City Asheville
State / Zip Code NC, 28803
County Buncombe
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
'
Operator in Responsible Charge or ORC)
Name SKF USA Inc.
Mailing Address 890 Forty Foot Road, PO Box 352
City Lansdale
' State / Zip Code PA, 19446
Telephone Number [phone]
Fax Number [phone]
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Page 1 of C-GW 03105

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other
6. Number of separate discharge points: 1
OutfaU Identification numbers) 001
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs: 7 days per week when system is in operation
Duration:
S. Treatment System Design flow 0.108 MGD
9. Name of receiving streams) (Provide a map shouring the exact location of each outfall, including
latitude and longitude):
Gashes Creek
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No additives are used.
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information
All applicants (including renewals
• A USGS topographical map (or copy of the relevant portion) which shows all outfalls
• A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
Engineering Alternative Analysis
D Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3 C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
C. William McGlocklin Dir. of Environmental Affairs
Printed name of Person Signing Title
Signature of Applicant
Date
.z
s
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)

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Attachment 4
Sludge Management
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Sludge Management
SKF USA, Inc. — Girmes Site Remediation, NPDES NCO086088
Buncombe County
The remediation system does not generate sludge or solids. It only consists of an air stripper, flume, and
effluent diffuser. Since the facility does not generate sludge or other treatment residue, a sludge
management plan has not been developed for the SKF USA Inc. — Girmes Site.
I certify that 1 am familiar with the information contained in the application and that to the best of my
knowledge and belief such Information is true, complete, and accurate.
C. William McGlocklin Director of Environmental Affairs
Name and Title Title
Signature Date
I

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Attachment 5
I Authorized Representative Documentation
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April 24, 2015
Mr. Wren Thedford
NC DENR / DWR / NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Authorized Representative
NPDES Permit Renewal
SKF USA Inc. - Girmes Site Remediation NCO086088
Buncombe County
Dear Mr. Thedford:
This letter is notification that SKF USA Inc. has delegated authority for
preparation of the April 2015 NPDES Permit renewal application for
the above referenced site to Mr. Dan 0. Madison, TRC Environmental
Corporation (TRC). Mr. Madison also retains signatory authority for
NPDES DMR forms for this site.
Please contact me at 267-436-6930 if you have questions.
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
cc: Dan 0. Madison, TRC
SKF USA Inc.
890 Forty Foot Road, P.O. Box 352, Lansdale, PA 19446
Tel [phone] Fax [phone] Web www.skfusa.com

A�
Gla
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. C. William McGlockin
SKF USA, Inc.
Grimes Site Remediation
PO Box 352
Lansdale, PA 19446
Dear Permittee:
Donald R. van der Vaart
Secretary
April 30, 2015
Subject: Acknowledgement of Permit Renewal
Permit NCO086088
Buncombe County
The NPDES Unit received your permit renewal application on April 30, 2015. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to
complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days
before your existing permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Maureen
Kinney [phone].
Sincerely,
W {revv Tkzd2 orOL
Wren Thedford
Wastewater Branch
cc: Central Files
Asheville Regional Office
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone]Customer Service:1-877-623-6748
Internet:: www.ncwater.org
An Equal OpportunibWirmativeAction Employer