NC0088838_Analytical Results_20150716

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Chemical Solutions
a division of Radiator Specialty Company
RECEIVED/DENR/DWR
July 9, 2015 L .l h 2015
Mr. Ron Berry Water Quality
Permitting Sectior
Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: 1,4-Dioxane Analytical Results
Radiator Specialty Company
Indian Trail, Union County, North Carolina
l'ermit No. NC0088838
Dear Mr. Berry:
Radiator Specialty Company (RSC) is responding to your June 16, 2015 email
concerning the analytical results for the presence of 1,4-Dioxane in RSC's groundwater
samples.
RSC understands DENR's position that it needs to see the actual measured values,
not just less than values, to properly evaluate the 1,4-Dioxane concentrations. DENR
informed RSC that it would put a permit limit of eighty (80) micrograms/Liter (ug/L) in
RSC's new National Pollutant Discharge Elimination System (NPDES) Permit. Based on
that conversation, RSC requested its testing laboratory to report actual measured values
of I,4-Dioxane down to eighty (80) ug/L. As it turns out, RSC's testing laboratory can
only report measured values for 1,4-Dioxane to eighty (80) ug/L. Any results at less than
this concentration can only be reported as estimate concentrations. The results reported
to the DENR on May 12, 2015 are below the analytical method reporting limit and
therefore cannot be reported as actual measured values.
RSC asked its testing laboratory if any other analytical methods were available
that could provide actual measured values at less than eighty (80) ug/L. The testing
laboratory advised that no accepted methods can provide actual measured values at less
than eighty (80) ug/L. Since DENR has already advised that it cannot use estimated
values, RSC did not request alternate analytical procedures be used.
Radiator Specialty Company appreciates the North Carolina Department of
Environment and Natural Resources cooperation and assistance in this matter. If you
have any questions or require additional information, please call me at [phone].
600 Radiator Road— Indian Trail, NC 28079-5225— Telephone: [phone]— Fax: [phone] — www.rscbrands.com

Mr. Ron Berry
July 9, 2015
Page 2
Sincerely,
Radiator Specialty Company
Abj °• 16,41
Stuart A. Kerkhoff, CHMM
Environmental Health and Safety Manager
cc: Mr. Richard Harmon, Harmon Environmental, PA
Mr. Benne Hutson, McGuireWoods LLP
NPDES\I.4-DIOXANERESPONSE2.DOC