NC0086088_Permit Issuance_20051114

' o� WATER
QtA
r? 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 monitoring. 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.05081, 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:1800 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,
L ur f Alan W. Klimek, P.E.
cc: Central Files
NPDES Permit File
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.
r- �an W. Klimek, P.E.
'TlirPrtnr
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 Outfa11001 into Gashes
Creek, a Class C water in the French Broad River Basin, at the
location specified on the attached map.

Permit NC00860.88
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:
�FFLIJEN'S¢ 4�� '
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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, guarterlu 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 toxicity 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.

NOV-07-2005 MON 12:06 PM ENV SCIENCES BRANCH
FAX NO. 919 733 9959 P. 01
h!h`;; rnlerl
1•anrirunureufn!
ee
SoGrrioa.;
November 2, 2005
1(1 r.11lW1nul nl ivi, su;,c too
O wlvillc, sC 2061S 1.511
lV4 p1 m.: 664-1H100W
kt,; X(,A 2.4l-WR8
wawJ mI II IC.IUIII
Mr. Clmden Weaver
Walcr Quglily/NI'DIr.S Unit
North Carolina Depar[rllentof Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Suhiccl: Review of Draft Ni'DES Permit
SKh--GirmcsSite
((liiJ
NI'Di'l+ Permit No. NCO086088
f;uncolnb,, C0tmiy
I:...
Dear M r. Wt•:i V(-r:
RA9T has ieviewcd the proposed Nalional I'ollulant Dh,charge Elimination System (NI'UhS) 1'onllit
Iltat was issued on Scplember 28, 2005, by Lila Norlh Carolina Department of Environment and
Nalurol Rc;:ources (NC DENR). This letter sunnnorires our review of the draft permit and includes
sug,;estions for elmliges that we bclicvc are appropriate: fora discharge of [his type.
�IAlthough the transmittal letter indicates that shore were no significant changes, RMT noted one
chenfo from the curnmil. perlllit that we believe is significant, in that it will increase tile, level of effort
to comply Willi the permit. In the draft permit, NC DJ;NR has proposed composite samples for total
;:usponJd•d t;ohd:; ('1;4S) and chronic toxicity. The current permit specifics a grab samples for these as
well as 1110 volatile orgallic compounds. Since composite sampling Will increase the effort to collect
samples, and became RMT believes that grah s.impli•s me aderluale for all parmimers,,we UV
I(TOltlnlend (hat tilt, final pen»il have grab sampling for all parameters.-t✓�lt' �
2l I MT does not agrov with NC DENT. s assertion That TSS monitoring is necessary because it is an �r �,
/ intlicalor of of feet ivello's of (he treatment syslom. We midersland that TSS can be nn important
cnn.sideration in calculaling wasteload allocations, but this facility has never discharged measurable
conecntrntions oPISS. 711orefore, we do not believe that it is worthwhile to continuing the analysis of
I'ti$ ill Ilse ireatcd cffluont and request ([lit this parmllcler be dropped from the (inal permit n/0
RMT ottemplvd to convince NC. DENR in 2001 (11a1 continuing the effluent chronic toxicity teals will
nnl yield u.neful information. As the nlortitoring reporls indicate, (his discharge has an excellent
record of compliance with all of the paranlclerson the NPDPS permit, including toxicity. RMT
di:at;rcrs wills the as:+erhori lint (he, discharge from Lhe SKp-Uroles Silt, is a complex waste. We
Aso du•agiev that. VA NCAC 2f'..t508, which di-sc'i)a•; inn,tiloring froqueocie. for indu urial - A/0
Jischnrt;ors, is applicable to thindischarge. fiec,mse of the nature of tale wastewater dischari;cd from
this Site ants the monitoring resulls that have wrisiMerilly demonstrated that the chronic value is
grealer Ilan 60 percent, we do not believe [liar continued monitoring is justified. We request that
I' \(L'.M\?I,1-I,IKNASI7UI 11'5-0m.mA'

MOV-07-2005 MON 12:07 PM ENV SCIENCES BRANCH FAX NO. 919 733 9959 P. 02
.. f
Mr. (.'hark►!; wi,aver
North C'nrolin.n Department of Environniont amd Mitural klesources
November 2, 2005
Page 2
f;I'viller than 60 poi -cent, we do not belim.- that cowimied munitoring is justified. We request that
chronic toxicity be dropped from the pci-mit and believe that a no reasonable potential c 1CLIlatiun will
Support this.
1'lle draft hermit is based Ott the design capacity flow of 0.108 mpd, RMT believes that [lie permit
sho(Ild be based an ac:lual discharge flow dam. Tlor tho clays of 2005 when a discharge occurred (data
fo r Ja,tuary (hrou6.11 Sch(VInber), the monthly average flaw rates rangy ed fro>n 34,700 ppd it) 43,300
gpd. Them'.- values are 32 to 40 Perccnt of (lie flow n1le. II1,1t the }permit is Wised oil. The permit wriler
shntild ad.1lowledge {leis discrepancy, adjust U,ct permitted flow to a value that is representative of
I)fc-SVIlt c' poraIioms, and change the ehroltic toxicity last concentration to the ahpropriate vaILI0. 1p
Filially, iri the 11,id Shed, NC: DFNR lists the facility address as 4325 SOUtl1 York I:oad in Gastonia.
finny by for SKI' USA's Cl� lndustt jes facility in Qlston County. - 0 `_
'Ilk"" e Im tif� know if we can provide any inforr>>ation that will assist you when evaltiatint; these
r1'du0sled modification. I cell be readied at 861-234-9437 or at jeff.fricnci(ci)rmlinc_cotn. Thank you for
your efforls iti preparing firm appropriate permit for t110. SKr -- Girmtme; silo.
Sim-orely,
I:MT NOOIt Carolina, Inc.
1A,
Jaffrey A. Frioiid
O&M C oorklin:ttor
cc: hill McGlockliti -- SKF USA
Mika Pilrkcr, D,m Madison — RMT North Carolina
Fik, 70114.35
� � � -71

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 chemikov <[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
1 of 1 10/14/2005 8:19 AM

PUBLIC nutN
STATE OF -
IORTH CAROLILINA ,,yf
lNVIRONMENTAL Henderson COao1Y so MANAGEMENT " lic Schools,-3600 HaY
COMMISSION1 ,iu. ., Read,HE
HeCarolin
facility "`?P "vih ` AFFIDAVIT OF PUBLICATION
Mi11 rid Road in
French Broad River Ba
+Il m+eq rpia.= ,BUNCOMBE COUNTY
anon' in this portion o
sepi watershed. SS.
land -Hill Corporatio
,as.appeed for renews )yu,NORTH CAROLINA
rf Pe .rmr�o NC0073793, fo
_ ,n Hpnderx
t °+s=°a„
to the persons created wastevtribut .
Before the undersigned, a Notary.Public of said
permit
Permit
listed beloweffecrwe, an unnamed tribute
days from the pubes is Devds Fork, m fh
iverr a
Fredchsin
County and State, duly commissioned, qualified and
date of this notice. CBrood
ntly
ammonia nitrogen, f
authorized by law to administer oaths, personally
Written comments re
Cal
will 6e propose residual forchlofine and taste
le hlo
appeared Darryl Rhymes, who, being first duly
permit water -aa [I It
-unto 30 days offer
date of this n Tnis dtxharge may gf
sworn, deposes and says: that he is the Legal
publish
stop. All comments - r I fed- future , allocation
caived prior to that dot. in this road River of r ih
fi ''French Broad Rver Be
_
Billing Clerk of The Asheville Citizen -Times,
are considered In the
net determinations r sin. -. ... -.
the propose
engaged in publication of a newspaper known as
permit. The. Director a has ap liedHealthcare, Inc
permit has applied for renews
the NC on of I-
Asheville Citizen -Times, published issued
d ,�1fThe
I ar OualisY may. decid of. permd..N00074710
lily
t hold a public meeiIn. its Mountain' <' Vie
and entered as second class mail in the City of
o
�shou de the ore sIo ` re c TP in Hende ne
discharge
Asheville, in said County and State; that he is
celve a stgnittcant facility
wastewater
gree of public interest. heateda to atbuta'
Tribute
authorized to make this affidavit and sworn
�Cooies of draft 'Per tam o-. Featherstone
•.mU other., spppart in "the French. Bros
Currentf
statement; that the, notice or other legal
land
in, Information, an I River Basin.
ndr
used IT determine can BOD;— ammonia
l) feral coliform an
advertisement, a true copy of which is attached
-ditions Present in gen,
draft Permit are avail ,are I tyres aua I vlOr,
sport reaueit
hereto, was published in The Asheville Citizen-
able
PaymeM of the costs ited. This dtschar9
Moil .cam may affect future, all
o
Times on the following date: September 30, 2005
reproduction.'
merits .and/or. regues casians in this portion
far information to -th the French Broad Rive
paper in which said notice, paper, document or legal
NC -Division of Ovate epsin.
Uallty the County
in g'
Henderson
advertisement were published were, at the time of
advertisement
r the Ispi
Source Bronchthat (919 ties
a of
r. M N JPeach and every publication, a newspaper meeting all
t S2D newid 070 . i15ef
p �3,.
'NPDES-Permitnumbe Justice Acadern
of the requirements and qualifications of Section l-
(attached)
au�jpaj a�:i� InterestC°uMY. This pefmip
`gi
597 of the General Statues of North Carolina and
ine Division Wine !;9ealiee. wastewater
of
512 N. saes i Lewis' ' CreekInth
Ba
was a qualified newspaper within the meaning of
OaaBly-at
bury Street, Raleigh French Broad River
p7yp4-1148 hetwee sin. Currently BOD, am
-1
Section 1-597 of the General Statues of North
,NC..
the hours 8 am - 5 p me . nitrogen,' feca
to `ilreview informatro
chlorine tare)
Cazolina.
unit wute
an file. quality limited. Thl
Camp Judaea, Inc., -4 discharge'. may Off" ;
Judaea Lane future allocations in +ht
Camp
Hendersonville, portion of French erba
Sipped this 3rd, October 2 OS
s
Herders . 28739 has p River Basin.
plied for .renewal Inc. (ill
NPDES Perm; SKF U
NCW33430 for its Cam Adams Ave., Norris
CJ Judaea WWTP m Hen town; PA- 79403, has a
�{ derson County. Thy reneWcei
I
,,•
oermtttetl-afuahty d-ts NPDES°f
_ e.-,.rod waste Nf008408a (of the Gim
(Signature of pe n making afft )
September 30, 2005
(1589)
NC4Y066 6NPI
for
Junior Hig
WWTP : in
County. This
lJ" facility
Swom to and subscribed before me the 3rd day of
October 2005
My Commission expires the 3rd day
2008.
30yF
rd

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NCO086088
Facility Information
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
Stream Characteristics
Receiving Stream
Gashes Creek
Stream Classification
C
Drainage Area (sq. mi.)
5.98
Drainage basin
French Broad
Summer 7Q10 (cfs)
0.94
Subbasin
04-03-02
Winter 7Q10 (cfs)
NA
Use Support
FS
30Q2 (cfs)
NA
303(d) Listed
No
Average Flow (cfs)
NA
State Grid
E8SW / E9SW
IWC 1%)
15
USGS Topo Quad
Asheville / Otten
Summary SKF USA Inc. owns the groundwater treatment system at the Girmes Site ancrur.-
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 fgrrthe
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 Chernikov at [phone] ext. 594.
Regional Office Comments: r
=� .2CDrnM�c`O.s L?
Fact Sheet
Renewal -- NPDES NCO086088
Page 2

Integrated
Environmental
Solutions
April 27, 2005
Mr. Charles H. Weaver, Jr.
p
M AY 3 2005
BEHR - WATER QUALITY
POINT SOURCE BRANCH _
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.rmtinc.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
I:\WPCVL\PJT\00-70144\35\LOW014435-0 2DOC

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 (NOEL) 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.
I: � W PCVLI P)TI00-701441351 L007014435-002. DOC

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).
1:1 W PGV L 1 P)T100-701441351 1,007014435.002. DOC

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
I:\WPCVL\PJT\OLL10144\35\L007014435-OD DOC

Table 1
Summary of NPDES Permit Limitations
PARAMETER
LYMITS .
.. "FREQUENCY
Flow
0.108 m d
Continuous
TSS
30 m
Monthly
TCE
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
TSS — m
<3.3
<2.1
-
TCE -
<1
-
-
1,2-DCE - L
<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
1:1 W PGV L 1 I'JT100-701441351 L007014435-002. DOC

FACT SHEET FOR EXPEDITED RENEWAL
Permit Number
0U 0 3
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?