NC0086088_Permit Issuance_20120111

'" 00
�A- A Y�AA�
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. C. William McGlocklin
Director of Environmental Affairs
SKF USA Inc.
890 Forty Foot Road
Lansdale, PA 19446
Dear Mr. McGlocklin:
Division of Water Quality
Charles Wakild, P. E.
Director
Januaryl 1, 2012
Dee Freeman
Secretary
Subject: Issuance of NPDES Permit
Permit NCO086088
Girmes Site Remediation
Buncombe County
Class PC 1
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 October 15,
2007 (or as subsequently amended). There are no changes from the draft permit sent to you on November
28, 2011, or from your current permit.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days
after receiving this letter. Your request must take the form of a written petition conforming to Chapter
150B of the North Carolina General Statutes, and must be filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demand is made,
this permit remains final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division
may modify and re -issue, or revoke this permit. Please notice that this permit does not affect your legal
obligation to obtain other permits required by the Division of Water Quality, the Division of Land
Resources, the Coastal Area Management Act, or other federal or local governments.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: wwwwaterauality.ona
None Caro
lina
�tura!!�
An Equal Opportunity 1 Affirmative Action Employer

If you have questions, or if we can be of further service, please contact Jim McKay at
[e-mail] or call [phone].
Sincerely,
a
Charles Wakild, P.E.
cc: Asheville Regional Office/Surface Water Protection
Central Files
Aquatic Toxicity Unit - via email
TACU, James Pugh - via email
NPDES Unit d

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 February 1, 2012.
This permit and the authorization to discharge shall expire at midnight on October 31, 2015.
Signed this day January 11, 2012.
S' 44
11%)k%TCharles Wakild, P.E.
r
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 Remediation Site 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
Fes..
�I
�'r�I�
s'3
,. i�� � ��,16gr�•p`1
✓'C��% f
F.
�•�,.�.�" �l-il�:�''�'.�"�t d.`�
bZ
RM
1,
lrr�
r�
v ,
A��•.
"♦�
tom' a\`�►�•�.
�����..
« I. I I•

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
EMIITATIONS
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 Toxicity,
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 H 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 H 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 H Chronic
Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
(continued on next page)

Permit NCO086088
A. (2) CHRONIC TOXICITY PERMIT LIMIT (Continued)
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 / En 'ronmental Sciences Secti n
1621 Mail Service Center
Raleigh, North Carolina 27 -
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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 Section 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.
ou st data from this monitoring requirement or tests performed by the North Carolina Dicn:;D�
ater Quali indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
in mate 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.

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENTAL AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
facsimile transmittal
To: Chuck Cranford - ARO Fax: [phone]
From: Jim McKay Date: June 10, 2010
Phone: [phone] Pages # 2, including this cover page
E-mail: [e-mail]
❑ Urgent ❑ For Review ❑ Please Comment ❑ Please Reply
Chuck,
Please review the attached letter from SKF USA regarding their GWR NPDES
permit. The renewal is out for public notice at this time. Once the review period is
over, the permit will be finalized as normal.
Please contact me if there are any questions or comments.
Jim McKay

5KF
December 7, 2011
Mr. Jim McKay
Complex NPDES Permitting Group
North Carolina Department of Enviromental & Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Draft N FOES Permit
Permit NC 0086088
Girmes Site Remediation
Buncombe County
Class PC1
Dear Mr. McKay
SKF USA Inc. (SKF) received the draft NPDES Permit NC 0086088 from your office on November
28, 2011. We have thoroughly reviewed the draft and have no reason to ask for any changes.
The Girmes site has been an active groundwater remediation site since March 1998. In 2009
sodium persulfate (10%) was injected through four (4) injection wells (Injection Well Permit
W10100043) into the impacted groundwater. The injection wells will permanently be closed in
2012. Since mid -November 2009 the groundwater treatment system has been off-line and no
discharge has occurred. SKF desires to keep the NPDES Permit open in an event that site
conditions dictate that the system should be restarted. We continue to conduct groundwater and
surface water monitoring periodically at the site.
If you have any questions, please contact me at 267.436.6930, or e-mail me at
[e-mail].
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
SKF USA Inc.
Legal Department
890 Forty Foot Road, P.O. Box 352
Lansdale, PA 19446-0352
cc: Mike Parker- TRC
SKF USA Inc.
890 Forty Foot Rd., P.O.Box 352, Lansdale, PA 19446-0352
Tel [phone] Fax [phone] Web w skfusa.com

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
Off Old Highway 74 East near Asheville in Buncombe County
Permitted Flow (MGD)
0.108
Type of Waste
Groundwater
Facility Class
PC 1
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 7Q 10 (cfs)
1.5
Use Support
FS
30Q2 (cfs)
2.1
303(d) Listed
All NC waters are
listed as impaired
for Hg.
Average Flow (cfs)
6.0
State Grid
E8SE / E9SW
IWC (%)
15
USGS Topo Quad
Asheville / Oteen
Summary: SKF USA Inc. owns the groundwater treatment system at the Girmes Site and RMT
Integrated Environmental Solutions operates the system. This treatment system has been in operation
since 1998.
Permit Issues: SKF USA Inc. is requesting permit renewal, reduction of flow rating, the elimination
of TSS monitoring, and chronic toxicity testing. None of the requested changes were made, as all are
germane to groundwater remediation monitoring.
Facility Description: The treatment system consists of an air stripping unit, a parshall flume and
effluent diffuser.
COMPLIANCE REVIEW
Review of the correspondence indicates that facility has a good compliance record. During previous
permit cycle no NOVs were issued. Compliance Evaluation Inspection Conducted on 10/31/2010
found no violations of permit requirements or applicable regulations were observed during this
inspection.
Whole Effluent Toxicity (WET) Test
WET requirement is a Quarterly Chronic Toxicity Pass/Fail using Ceriodaphnia at 15%. They have
passed all 12 toxicity tests from January 2007 until the shutdown in November, 2009.
Fact Sheet
Renewal -- NPDES Permit NCO086088
Page 1

Reasonable Potential Analysis (RPA)
Thrichloroethene, 1,2-Dichloroethene and vinyl chloride were below detection level through
November of 2009, when the unit was shut down. It is still down, therefore a RPA was not required
for this permit renewal.
PROPOSED MODIFICATIONS
No changes are proposed.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: November 23, 2011 (est.)
Permit Scheduled to Issue: February 1, 2012 (est.)
CHANGES IN THE FINAL PERMIT
NOTE: Coleen Sullins is Director of the Division of Water Quality at the present. She has announced that
she plans to retire at the end of December, 2011. Chuck Wakild has been chosen to serve as the new
Director, effective January 1, 2012. The names should be changed when the draft permit is finalized for
issue in 2012.
STATE CONTACT
If you have any questions on any of the above information or on the attached permit, please contact
Jim McKay at [phone], or by email at [e-mail].
A't ` I/'� DATE: I - 9 —
NPDES SUPERVISOR
REGIONAL OFFICE COMMENT
Fact Sheet
Renewal -- NPDES NCO086088
Page 2

ASHFVIT.T F
MIZEN T& ES
VOICE OFTTIE MOUNTAINS a CfTTZEN-T IMFS.com
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
Before the undersigned, a Notary Public of said County and
State, duly commissioned, qualified and authorized by law
to administer oaths, personally appeared Anne Gardner,
who, being first duly sworn, deposes and says: that she is
the Legal Billing Clerk of The Asheville Citizen -Times,
engaged in publication of a newspaper known as The
Asheville Citizen -Times, published, issued, and entered as
Publlc NoticeManagement
North Carolina Environmema)
COmmisslONNPpCe
first class mail in the City of Asheville, in said County and
Dnit
Rale,g1617 it IC 27eCe"ter
Raleig NCrn
Noti<eo
State; that she is authorized to make this affidavit and
Intent t0laeula
to Is .
NPDEB Wastewater Permit
sworn statement; that the notice or other legal
North Carolina Environmental Management
Imis ion proposes to issue a NPpE, waas5te.
•r tltschame Permit to the person s) 115tetl
advertisement a true copy of which is attached hereto was
r >
W.
ten comments repardin the proposed per.
III be
published in The Asheville Citizen -Times on the
acccptetl until 30 tlaare after the ph C
ate of this notice. The Dlrecah of the NC
orb of Water (DWQ)
following date: November 24, 2011 and that the said
Qdu�lior mu hold a
Ic earIn should or Ce a 51 n cent de
pf pY6r�p mere:t. Pfease mafl cmmmente
'or in
newspaper in which said notice, paper, document or legal
ormation re0u2515 to DWp at the atltlress. Inter¢s[eedd persons visit
DWo at f r N. Salisbpry Street pamleph, NC
ewew Infarmatlon flle. AtldiflonpI Infor
advertisement was published was, at the time of each and
.pn
on On NPDES permi(s and this np& mey
I and oan/ ouPPr//oowebsrte httpy/portal.ncdenY
every publication a newspaper meeting all of the
f
gw(939)W7W8300.�nPtle1/calendar, or Cp
requirements and qualifications of Section 1-597 of the
YSA Inc has applietl for reewal oePUES
l t t�C00B6pB8 for Me Girmes S5he In Bun.
re County. This tlech
General Statues of North Carolina and was a qualified
permitted
h Broad River Basin. Gashes creek in th
newspaper within the meaning of Section 1-597 of the
mbar 242011 Base
General Statues of North Carolina.
Signed this 300' day of December, 2011.
Sworn to and subscribed before me the 301h day of
My Cor4mission expires the 51" day of October, 201
[phone] 1 [phone] FAX �OT`i
14 O. HENRY AVE. I P.O. BOX 2090 1 ASHEVILLE, NC 28802 1 [phone]
PUBLIC
ds GAPI6ff

m
- RMY
• ENVIRONMENT .. ENERGY a ENGINEERING
April 20, 2010 p @ [2 NO
O
Ms. Coleen H. Sullins APR 2 6 2010
Director, Division of Water Quality
North Carolina Department of Environment and Natural Resources ENR-WATER �uAt_mr
1617 Mail Service Center POINT SOURCE BRANCH
Raleigh, North Carolina 27699-1617
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application
SKF — Girmes Site
NPDES Permit No. NCO086088
Buncombe County
Dear Ms. Sullins:
RMT North Carolina, Inc. (RMT) 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 current NPDES permit sets discharge limitations for the parameters identified in Table 1 (see
Attachment 1). The facility is also required to monitor the effluent for toxicity once per quarter and
has a chronic value limit 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 current 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 two years of monitoring. Concentrations of
VOCs detected in the groundwater samples collected from recovery wells and monitoring wells
located adjacent to the creek have also been declining over the past three years.
I:\ WPGVLIPIT100-70144153\000041L00701445UMDOCX
30 Patewood Drive, Suite 100 • Greenville, SC 28615-3535 • [phone] • [phone] FAX • www.rmfnc.com
CREAT1.N'.G_,I.,ALAN..CE

Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 2
Operating History
As groundwater recovery operations have continued, the volume of water recovered has declined to
the current average of approximately 42,000 gallons per day (gpdwhen the system is in operation.
Also, 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 has declined to approximately 300 to 400 ppb. In an effort to increase
VOC removal, in 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 has declined over the past 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 planned 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, RMT 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 is significantly higher than the
VOC concentrations currently detected in the monitoring and recovery wells near the creek. Periodic
monitoring of select monitoring wells near Gashes Creek, surface water and pore water along Gashes
Creek will be 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 and a renewed
NPDES permit will be needed.
We believe that the monitoring data since 1998 show that the treatment system can easily reduce the
influent VOCs to concentrations below the detection limit. The concentration of total suspended
solids (TSS) is also well below the NPDES permit limit. Therefore, we request that the Division of
Water Quality (DWQ) consider the permit modifications that we have detailed below.
L• 1 WPGVLIPMOO-701441531000041IA07014453-002.DOCX
CREATIK-G 0ALANC

Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 3
1. Flow — The NPDES permit is currently based on the design flow of the treatment plant.
Although the permitted flow is 0.108 million gallons per day (mgd), this flow rate is much higher
than the average or maximum daily flow from the site. The average flow for the first month of
each quarter in 2009 was 0.0229, 0.0421, 0.0425, and 0.0452 mgd. Therefore, we request that the
DWQ use 50,000 gpd as the flow basis for the revised permit and include monthly average limits
of 0.050 mgd and no maximum flow limit (monitor and report).
2. TSS — The site has never exceeded the permit limit of 30 milligram 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. Although
continuing the analysis of effluent samples will not provide any useful data, we understand that
TSS limits are minimum requirements on all permits. Therefore, we request that DWQ change the
monitoring frequency for TSS to once per year.
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 Chronic Value (ChV) significantly greater than 15 percent. Most tests
have indicated that the ChV is 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.
— Existing controls on point sources of pollution — The nature of the SKF — 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.
L•1 WPGVL\PJt100-7014415310000111AD7014453o02AOCX
CREAT:I,NG 8ALANCE;'

Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 4
— 77te variability of the pollutants in the effluent — The chemical characteristics of the
treated effluent have been well documented since the systems 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.
— DiIution of the effluent in the receiving water — The discharge has an average flow rate
of 42,000 gpd. 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.
After conducting an examination of these four criteria, RMT believes that there is no reasonable
potential for the treated effluent 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 SKF-Girmes Site are
sufficient and, therefore, we request that the DWQ remove toxicity testing from the 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). Please note that these months include results for VOCs, TSS, and chronic toxicity.
Since this facility does not generate sludge or other treatment residue, a sludge management plan has
not been developed for the SIG — Girmes Site.
L-1 WPGVI.IPJT10a701441531000041 LA0701445MMDOCX
CRi;ATI BALANCk�O'

Ms. Coleen H. Sullins
North Carolina Department of Environment and Natural Resources
April 20, 2010
Page 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 these issues with you. If there are any
questions, please call me at 864.234.9462.
Sincerely,
RMT North Carolina, Inc.
o
Michael B. Parker, P.E.
President, RM'I' North Carolina Inc.
Attachments
cc: Bill McGlocklin—SKF USA Inc.
Travis Tarbet, Britney Barnes—RMT, Inc.
Billy Clarke, Roberts and Stevens, P.A.—Asheville, NC
Roger Edwards —Division of Water Quality-NCDENR
Central. Files
L•1WPGVLIPJf10a70144153100OD41L D701445-A-MDOCX
C R.E AT1. N G B A LA N C I�

Table 1
Summary of Current NPDES Permit Limitations
H.:
.`. PARAMETER:
.r. I.
•LIMITS
Flow
0.108 mgd
Continuous
TSS
30 mg/L
Monthly
TCE
MR")
Quarterly
1,2-Dichloroethene (DCE)
MR
Quarterly
inyl chloride (VC)
I
MR
Quarterly
oxicity (Chronic Value)
ChV at 15%
Quarterly
(1) Elevated detection limit.
Table 2
Summary of Maximum Observed Values for 2009
=_ PARAMETER
JANUARY
�''APRIL
.lULY �`
OCTOBER
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
ND(')
ND(1)
ND(')
ND(')
Toxicity (Chronic Value)
CW>60%
ChV>60%
ChV>60%
ChV>60%
Volatile halocarbons by Method 601 were not detected in the effluent at the detection limit of 1 pg/L (2 pg/L for
chloromethane and methylene chloride)
L'\ WPGVL\PJT\00.701"\53\00004\L007014453.002.DOCX

N. C. DENR/Division of Water Quality/NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit NCO086088
Please print or type
1. Applicant and facility producing discharge
A. Name SKF USA Inc. Girmes Groundwater Site
B. Mailing address of applicant:
Contact Person Mr. C. William McGlocklin
Street address 1111 Adams Avenue
City Norristown County Montgomery
State Pennsylvania Zip Code 19403-2403
Telephone Number [phone]
Fax Number [phone]
e-mail address: william.c.mcglocklinD-skf.com
C. Location of facility:
Street off Old Highway 74 East
City Asheville County Buncombe
State North Carolina Zip Code 28803
Telephone Number ( ) not applicable
Fax Number ( ) not applicable
2. Standard Industrial Classification (SIC) code(s) (if known): none
3. This application is for a: ❑ New Permit El Permit Renewal ❑ Permit Modification
4. Product(s) recovered (circle all that apply): Gasoline Diesel fuel Solvent
Other (describe)
5. (a) Check here if discharge occurs all year CAI, or
(b) Circle the month(s) in which discharge occurs: January February March April
May June July August September October November December
(c) Days per week discharge occurs: 7 days per week when the system is in operation
6. Volume of wastewater discharged to receiving stream(s): 42.000 GPD*
'Gallons per operating day
7. Check here if wastewater is discharged directly to the receiving stream(s) Q
If not, state the specific discharge location:
Mark the path taken by the wastewater to the receiving streams) on the site map. If a storm sewer is the only viable means of discharge, trace
the route of the storm sewer to its discharge point
0
K
APR 2 6 2010
L• \ WPGVL\PMOo-70144\53\00004\L,OOM144&UMDOCX

B. Number of separate discharge points: one effluent diffuser in Gashes Creek
NOTE: If the facility has separate discharge points (outfalls), include a schematic diagram of wastewater
flow at the facility.
9. Name of receiving water(s): Gashes Creek
All application Packages (including Permit renewals) must include the items fisted below. This
application will be returned if the required items are not included.
o A USGS topographical map (or copy of the relevant portion) which shows all outfalls _
o A summary of the most recent analytical results (effluent data, if available) containing the maximum values for each chemical
detected
New applications for proposed (not yet Permitted) discharges must also include the items listed
below. This application will be returned if the required items are not included
o An engineering proposal describing the remediation project in detail (required by 15A NCAC 2H.0105 (c))
o A report of alternatives to surface water discharge as outlined by the Division's °Guidance for Evaluation of Wastewater Disposal
Alternatives" (required by 15A NCAC 21-1.0105 (c))
o If the treatment system will discharge to a storm sewer, attach written approval from the municipality responsible for the sewer.
o 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)
o A summary of analytical results containing the maximum values for each chemical detected
o The removal efficiency of each compound detected (if known)
For petroleum -contaminated sites, analyses for volatile organic compounds (VOCs) should be performed. Analyses for any fuel
additives likely to be present at the site should also be performed. At minimum, analyses should be performed for the following
compounds:
benzene* toluene ethylbenzene' xylene' lead methyl tert-butylether (MTBE)
dibromoethane (ED8) 1,2-dichlorcethane isopropyl ether napthalene phenol
ran EPA -approved method capable of detection levels to 1 ppb should be used to detect these compounds).
For solvents or other contaminants. an EPA Method 624/625 analysis should be performed.
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 Director of Environmental Affairs
Printed name of Person Signing line
.2 2//O
Signature of Applicant Date
North Carolina General Statute 143-215.6E (i) 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 for not more than 5 years, or both,
for a similar offense.)
cXWINbMPRoFILESXUK C%VMXwa+tS-IXM"XNOTE56I 35CNL0o7o1,a53-WI m.000c Working Copy