NC0088838_Correspondence_20150709

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Chemical Solutions
a division of Radiator Specially Company
July 9, 2015
Mr. Ron Berry
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
Permit No. NCO088838
Dear Mr. Berry:
RECEIVED/DENRIDWR
JUL 16 2015
Water Quality
Permitting Sectior
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 IA-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 Rood — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com

Mr. Ron Berry
July 9, 2015
Page 2
Sincerely,
Radiator Specialty Company
ce,
Stuart A. Kerkhoff, CHMM
Environmental Health and Safety Manager
cc: Mr. Richard Harmon, Harmon Environmental, PA
Mr. Benne Hutson, McGuireWoods LLP
NPDES\ 1.Q-D10XAN ERI:SPONS 1:2.QOC-

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AM Am
RSC
Chemical Solutions
a division of Radiator Specialty Company
May 12, 2015
Mr. Ron Berry
Engi neer
North Carolina Department of Environment
and Natural Resources
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: 1,4-Dioxane Data Collection and Evaluation
Radiator Specialty Company
Indian Trail, Union County, North Carolina
Permit No. NCO088838
Dear Mr. Berry:
Radiator Specialty Company (RSC) is responding to your August 5, 2014 email
concerning the presence of 1,4-Dioxane in RSC's groundwater influent.
As we discussed, to address your concern, RSC implemented a monthly sampling
program in which both influent and effluent were sampled for 1,4-Dioxane from August
through December 2014. The results of both the influent and effluent samples throughout
this sampling period were below the suggested Permit Limit of eighty (80) micrograms
per liter (ug/L). The results of these sampling activities are summarized in Tables 1 and
2.
Based on the results of this sampling program, RSC does not intend to modify the
current treatment technology at this time. RSC proposes to continue sampling the
effluent for 1,4-Dioxane quarterly. In the event 1,4-Dioxane concentrations in the
effluent indicate exceedances, RSC will evaluate additional treatment technologies at that
time.
On December 19, 2014, RSC shut down the groundwater recovery system due to
operational issues with the computer system that runs the groundwater recovery system.
RSC has been diagnosing the situation and proposes to resume operation of the
groundwater recovery system when the issues have been resolved.
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

� O S
Mr. Ron Berry
May 12, 2015
Page 2
Sincerely,
Radiator Specialty Company
hl�uj G' )(JkA
Stuart A. Kerkhoff, CHMM
Environmental Health and Safety Manager
cc: Mr. Richard Harmon, Harmon Environmental, PA
Mr. Benne Hutson, McGuireWoods LLP
NMEMI A-UIOXANERCSPONSELDOC

AIR STRIPPER INFLUENT
RADIATOR SPECIALTY COMPANY
VOLATILE ORGANIC COMPOUNDS
Parameters 08/21/14 09/25/14 10/14/14 11/18/14 12/17/14
Benzene
1.2
0.77
1.1
1.1
1.4
Chloroethane
15
9.4
15
12
15
2-Chlorotoluene
1.5
0.81
3.2
3.3
3.1
4-Chlorotoluene
<1.0
<0.50
<0.50
<0.50
<0.50
1, 1-Dichloroethane
49
47
48
41
60
1, 2-Dichloroethane
0.74J
0.56
0.64
0.70
0.75
1, 1-Dichloroethene
26
28
31
23
27
cis-1,2-Dichloroethene
20
20
23
21
30
trans-1, 2-Dichloroethene
2.5
2.5
2.6
2.0
3.0
Dichlorodifluoromethane
6.1
4.0
4.8
3.2
4.4
1,4-Dioxane
<80
<80
<80
<80
<80
Ethylbenzene
<1.0
<0.50
<0.50
<0.50
<0.50
Methyl ethyl ketone
<5.0
<5.0
<5.0
<5.0
<5.0
Methylene chloride
<2.0
<1.0
<1.0
<1.0
<1.0
Methyl Isobutyl Ketone (MIBK)
<5.0
<5.0
<5.0
<5.0
<5.0
Tetrachloroethene
100
100
80
70 B, BH
72
Toluene
<1.0
<0.50
<0.50
<0.50
<0.50
1, 1, 1-Trichloroethane
1.8
1.8
2.0
1.7
2.6
Trichloroethene
7.4
5.8
6.1
4.4
6.0
Vinyl chloride
3.2
2.6
6.5
5.7
5.6
Xylenes (total)
<2.0
<1.0
<1.0
<1.0
<1.0
TOTAL:
234
223
224
189
231
Comments:
RESULTS ARE PRESENTED IN UG/L.
Effective with the August 2014 sample, analytical method was changed to SW846-8260.
J: Detected but below the Reporting Limit;
therefore, the result
is an estimated concentration
(CLP J-Flag).
B: Analyte was found in the associated blank
at a concentration
>112 RL.
BH: MB greater than one half of the RL, but the sample concentrations are greater than 10x the MB.
11F:1= Wil
NPDES11,4-DI0XAN ERESPONSE.XLSX

Table 2
d
AIR STRIPPER EFFLUENT
RADIATOR SPECIALTY COMPANY
NPDES PERMIT NO. NCO088838
OUTFALL 001
Daily
Permit
Limits
Parameters ug/L 08/21/14 09/25/14 10/14/14 11/18/14 12/17/14
Flow (MGD) 0.09
Monthly Samplinq
Total Suspended Solids
0.045
Monthly Average
0.030
Tetrachloroethene
3.0
1, 1, 1 -Trichloroethane
4.0
Vinyl chloride
2.0
1,4-Dioxane ***
80.0
Quarteriv Samplin
Chloroethane ---
1,1-Dichloroethane ---
1,1-Dichloroethene ---
1,2-Dichloroethene (total) ---
cis-1,2-Dichloroehene -�-
Trichloroethene ---
Benzene ---
Methylene chloride ---
1,2-Dichloroethane ---
Toluene ---
trans-1,2-Dichloroethene ---
Chronic Toxicity 90%
Comments:
0.0006 0.0317 0.0270 0.0182 0.0332
<0.0025 <0.0026 <0.0026 <0.0025 <.0026
<1.0
<1.0
<3.0
1.213
<3.0
<1.0
0.61
<4.0
<0.50
<4.0
<2.0
<0.50
<2.0
<0.50
<2.0
<80
<80
<80
<80
<80
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<1.0
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
P
NA
NA
NA: Not Analyzed
P: Pass Chronic Toxicity
Flow: Flow is the reading from the flowmeter day of sample collection less flowmeter reading during last
outfall inspection divided by number of days between the two. See DMR Form.
*** 1,4-Dioxane: New Permit will have a limit of 80 ug/L. RSC started sampling it for evaluation in August 2014.
In addition, RSC swithced to SW846 Method 8260.
TABLE 2
Page 1

rr
Chemical Solutions
o division of Rodiolor Speciolty Compony
September 25, 2014
Mr. Ron Berry
Engineer
North Carolina Department of
Environment and Natural Resources
Division of Water Resources
1617 Mail Services Center
Raleigh, North Carolina 27669-1617
Re: Response To August 5, 2014 E-Mail
Radiator Specialty Company
Indian Trail, North Carolina
Permit No. NCO088838
Dear Mr. Berry:
RECEIVED/DENR/DWR
SEP 2 5 2014
Water Quality
Permitting Section
Radiator Specialty Company (RSC) appreciates this opportunity to respond to the two
proposed changes to the pending National Pollutant Discharge Elimination System
(NPDES) Permit renewal for Permit No. NC0088838. For ease of review, we have
presented the North Carolina Department of Environment and Natural Resources
(DENR) intended incorporations from your August 5, 2014 e-mail in italics followed by
RSC's response.
1. Any submitted toxicity testing ivill require a composite be taken as the test sample.
We understand that composite samples are typically required for NPDES permitted
facilities with either an intermittent discharge and/or the potential for variability in the
waste stream over a twenty-four (24) hour period. The groundwater recovery and
treatment system at Radiator Specialty Company discharges approximately 40,000
gallons of treated groundwater per day. The discharge flow is driven by the pumping of
groundwater from four (4) on -site recovery wells. As a result, the system discharges
continuously each day. Since the source of the water is limited to the four (4) recovery
wells, the influent water quality is well documented and variability in the waste stream
has not previously occurred and is not expected to occur in the future. As a result, grab
samples adequately represent the water quality for toxicity testing.
DENR has accepted this approach at at least one other facility with a similar discharge.
A May 8, 2014 determination by Ms. Cindy Moore. Mr. Tom Belnick and Mr. Wes Bell
of DENR authorized Equipment & Supply. Inc. (NPDES #0087858) to revise the toxicity
sampling protocol from composite to grab. The groundwater treatment and discharge
600 Radiator Road — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com

Mr. Ron Berry
September 25, 2014
Page 12
system at the Equipment & Supply, Inc. facilty is comparable to the system operated by
RSC.
RSC requests the toxicity sampling protocol not be revised.
2. The presence of 1,4-dioxane in the influent and groundwater sources will require
the addition of monthly 1,4-dioxane monitoring with an 80 microgram per liter
(,ug/L) daily limit to protect for the Human Health surface water quality standard.
RSC is aware that 1,4-dioxane has historically been detected in groundwater samples
collected from the site and is not opposed to analyzing the effluent for 1,4-dioxane.
However, this parameter is not targeted by standard method 624, the analytical method
currently required by the facility's Permit. Based on an August 11, 2014 telephone
conversation with you, RSC understands DENR would accept modifying the Permit
during the renewal process to specify SW-846 Method 8260 instead of Standard Method
624 for targeted volatile constituents. Further, based on this conversation, RSC
implemented this analytical method change during the August 2014 monthly sampling
event.
The Method Reporting Limit for SW-846 Method 8260 is 150 µg/L. Prism Laboratories,
Inc. has indicated that a normal Method Detection Limit for SW-846 Method 8260 is
10.6 µg/L. Should 1,4-dioxane be detected in the effluent sample at a concentration
between the permit limit and 150 µg/L, the result would be reported as a " J" value.
Based on our telephone conversation on August 11, 2014, RSC anticipates three (3) to six
(6) months will be necessary to collect and evaluate 114-dioxane analytical results to
determine if changes to the existing groundwater recovery system are necessary.
RSC appreciates DENR allowing us to review its recommended changes prior to issuing
the draft permit renewal. Please call if you have any questions or require any additional
information.
Sincerely,
Radiator Specialty Company
Lj",
IC��J
Stuart Kerkhoff
Environmental, Health and Safety Manager
cc: Mr. Richard L. Harmon. Harmon Environmental. PA
Mr. Benne Hutson. McGuireWoods LLP
N11DE 1111*1 01TUIIAN(il:.1)0('N

Perlmutter, Gary - e4Z1rrFo Fhor� F,�e 4 t• tg
From: Berry, Ron
Sent: Thursday, October 09, 2014 3:19 PM
To: Bell, Wes
Subject: FW: 1,4 dioxane data collection and evaluation
Attachments: response letter.pdf
Wes, I attached a copy of the response letter for your review
From: Berry, Ron
Sent: Thursday, October 09, 2014 3:18 PM
To: 'Stuart KerkhofP
Cc: Bell, Wes
Subject: 1,4 dioxane data collection and evaluation
Mr. Kerkhoff,
I had forwarded you request letter to continue grab sampling for the chronic toxicity test at the Radiator Specialty
Company NCO088838 facility to the Aquatic Toxicity Branch for review and for a final decision on the required sample
method. In regards to the 1,4,-dioxane, I concur on moving forward with data collection and evaluation. Therefore, I
am setting a due date no later than April 6, 2015 for your submittal to the Division of the design of the necessary
treatment and/or operation changes to remediate the worst case effluent 1,4 dioxane levels occurring above 80 µg/L
to less than 80 jig/L. As far as the correct test method, the method must be capable of minimum detection to less than
80 µg/L which apparently the proposed method can do provided the lab is calibrated appropriately. The design must
include a reasonable time table to implement the proposed changes.
If you have any questions let me know.
Ron Berry, Engineer
Division of Water Resources/NCDENR
Phone: (919) 807 - 6396
Email: ron.berrv@ncdenr.¢ov
Location Address - Archdale Building, Office 925Y
512 N. Salibury St.
Raleigh, NC 27699
Mailing Address - Archdale Building, NCDENR/DWR
1617 Mail Service Center
Raleigh, NC 27669-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

Perlmutter Gary — V (L% JT&0 F"r\ {: �\,E $ t$
From:
Sent:
To:
Cc:
Subject:
Tracking:
Berry, Ron
Tuesday, August 05, 2014 4:22 PM
'Stuart Kerkhoff'
Parker, Michael
New Requirments in Radiator Specialty Company NPDES Permit NCO088838
Recipient
'Stuart Kerkhoff'
Parker, Michael
Stuart Kerkhoff
Environmental Health and Safety Manager
Radiator Specialty Company
Indian Trail, NC 28079
Delivery
Delivered: 8/5/2014 4:22 PM
Mr. Kerkhoff:
The Division has completed a preliminary review of your NPDES renewal application and noted two important changes
that will occur in this renewal.
1) Any submitted toxicity testing will require a composite be taken as the test sample (you may already being doing
this).
2) The presents of 1,4 dioxane in the influent and ground water sources will require the addition of monthly 1,4
dioxane monitoring with a 80 µg/L daily limit to protect for the Human Health surface water quality standard.
Based on the historical data reported to other NCDENR Divisions (data above 80 µg/Q additional treatment
technology will be require to remove the 1,4 dioxane to meet the daily limit.
Note: We are allowed to apply the QA steam flow for dilution but no value is available so you may contact USGS
and obtain the OA value for your designated discharge location. However, as seen previously at this discharge
location the estimated stream flows are very low flows, in fact a definable QA flow may not exist or its impact to
an adjusted daily limit may be small. The current air stripping process will most likely will have no impact on 1,4
dioxane removal. Under current legislation you are not required to obtain an Authorization to Construct permit
as before.
Before proceeding with this renewal, your input as far as providing a GA stream flow if you so choose and a time frame
to completed the necessary treatment changes for 1,4 dioxane removal is required. If you have any additional influent
data from 2011 to present for 1,4 dioxane please provide.
If you have any questions let me know.
Sincerely,
Ron Berry, Engineer
Division of Water Resources/NCDENR
Phone: (919) 807 - 6396
Email: ron berryCpncdenngov_
Location Address - Archdale Building, Office 925Y
512 N. Salibury St.
Raleigh, NC 27699

Mailing Address - Archdale Building, NCDENR/DWR
1617 Mail Service Center
Raleigh, NC 27669-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

'Chernikov, Sergei
From: Ulishney, Adam
Sent: Monday, March 12, 2012 11:03 AM
To: Chernikov, Sergei
Subject: Radiator Specialty Site NCO088838
Dear Mr. Chernikov,
My name is Adam Ulishney with the NCDENR Hazardous Waste Section. One of my facilities that I currently manage is
Radiator Specialty located at 600 Radiator Road in Indian Trail, Union County, North Carolina. They currently maintain a
RCRA Post -Closure Permit. The portal website had listed you as the contact person for the site's NPDES permit. As part
of corrective action activities at the site the facility currently operates a groundwater pump and treat system for which
they maintain an NPDES permit (NC0088838) for discharge of treated water to an unnamed tributary to Unnamed
Tributary to South Fork Crooked Creek in the Yadkin River Basin.
I just wanted to make you aware that one of the constituents within groundwater at the site is 1,4-Dioxane. During the
most recent sampling event (October 2011), 1,4-Dioxane concentrations in groundwater ranged from <150 ug/L to 1,100
ug/I. Based on the physical and chemical properties of 1,4-Dioxane, groundwater treatment systems similar to the one
operating at the RSC facility have generally proven to be ineffective in treating this constituent. I have been
unsuccessful in getting Radiator Specialty to sample the effluent for the presence of 1,4-Dioxane to ensure that via some
means this constituent is being treated (possibly by dilution) prior to discharge as it is not required by their NPDES
permit. They have however collected quarterly influent samples in 2010 and results for 1,4-Dioxane ranged from <150
ug/L to 320 ug/l. Historically the NC and EPA criteria table had the limit for 1,4-Dioxane at 110 ug/I for a Class C water,
however it appears that the table is currently being updated.
If you can provide me any feedback it would be appreciated. Again I just wanted to make your aware of this
information, should you feel that it is necessary to incorporate the sampling of 1,4-Dioxane in any future NPDES permits
for the facility. In any case let me know what you decide for my future reference in reviewing their annual reports.
Should you need additional information or have any questions, comments, or concerns please feel free to contact me at
919-707-8210.
Adam Ulishney
Hydrogeologist
North Carolina Hazardous Waste Section
Phone: [phone]
Email: adam.uGshnevl7a,ncdenr.eov
NOTICE: Effective October 24, 2011 our new address will be:
217 West Jones St.
Raleigh, NIC 27603
and effective October 24, 2011 my new phone number will be:
919-707-8210
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Email correspondence to and from this address is subject to the North Carolina Public Records Law and maybe disclosed to third
parties unless the content is exempt by statute or other regulation.