NC0086088_Permit Issuance_20020607

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Mr. C.William McGlocklin
SKF USA, Inc.
1111 Adams Avenue
Norristown, Pennsylvania
Dear Mr. McGlocklin:
19403-2403
Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
June 7, 2002
Subject: Issuance of NPDES Permit NCO086088
Girmes Site remediation
Buncombe County
Division staff have reviewed and approved your renewal application. for an NPDES discharge permit- Accordingly,
the Division is forwarding the subject NPDES 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).
In response to the letter of March 15, 2002 from your Authorized Representative (RMT North Carolina, Inc.) we
offer the following comments:
• Total Suspended Solids (TSS): TSS is a concern for groundwater remediation sites because it can be present in
the influent. The General Permit for groundwater discharges includes a TSS limit of 30 mg/L. Although there is
no numeric standard for TSS or a specific policy for individual groundwater remediation permits, the General
Permit reflects the minimum requirements, therefore the Emit is required for this individual permit.
• Whole Effluent Toxicity: Because this groundwater remediation permit specifies treatment of volatile organic
compounds, a toxicity test is required by the Division.
• Instream Waste Concentration (IWC): This permit's IWC was recalculated based on the low -flow estimates
provided by the USGS. The estimated s7Q10 for the discharge location is 0.94 cfs. Using this value the
corresponding instream waste concentration is 15%. The toxicity test requirement has been changed accordingly.
If any pans, 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 a demand is made, this permit shall be final and binding.
Please take notice 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, the Division of Land Resources, the Coastal
Area Management Act, or any other federal or local governmental permit. If you have any questions concerning this
permit, please contact Teresa Rodriguez at telephone number [phone], extension 595.
Sincerely,
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan W. Klimek, P.E.
cc Asheville Regional Office, Water Quality
Aquatic Toxicology Unit
Central Files
NPDES Unit I
Dan O. Madison — RMT North Carolina, Inc.
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer Visit us on the INTERNET 0 www.enr.state.nc.us

Permit NCO086088 0
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 July 1, 2002.
This permit and the authorization to discharge shall expire at midnight on October 31, 2005.
Signed this day June 7, 2002.
ORIGINAL SIGNED BY
SUSAN A. WILSON
Alan W. Klimek, P.E.
Director
Division of Water Quality
By Authority of the Environmental Management Commission
A

Permit NCO086088
SUPPLEMENT TO PERMIT COVER SHEET
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 Outfall 001 into Gashes
Creek, a Class C water in the French Broad River Basin, at the
location specified on the attached map.

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Permit NCO086088
A. 00 EFFLUENT LEWTATIONS 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
LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Daffy' '�
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flows
0.108 MGD
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
Monthly
Composite
Effluent
Trichloroethene
Quarterly -
Grab
Effluent
1,2 Dichloroethene
Quarterly
Grab
Effluent
Vinyl Chloride
Quarterly
Grab
Effluent
Chronic Toxicityz
Quarterly
Composite
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 PERAUT LBUT (Quarterly)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Cerk0aphnia dubia at an effluent concentration of 15 %.
The permit holder shall perform at a minimum, quarterIU 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 LDUT (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 Branch
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.

SUMMARY OF LOW -FLOW ESTIMATES IN RESPONSE TO REQUEST
REQUEST NO: 91611 SITE NO: 01 DATE: 05/10/2002
SOURCE: Consultant ACTION: Existing
STATION NUMBER: 03450621 STATION TYPE: Ung_aged (estimate only)
STATION NAME: Gashes Creek at Oakley, NC
LOCATION: At SR 2862 (location of old U.S. Hwy 74). at Oakley, and 0.6 mile above mouth
LATITUDE: 35°34'02" LONGITUDE: 82°30'03"
QUANDRANGLE NAME AND NUMBER: Oteen, NC FE-9-SW1
COUNTY CODE: Buncombe 10211 STATE CODE: NC [371 DISTRICT CODE: NC
3f 71
HYDROLOGIC UNIT CODE: 06010105 ENR BASIN CODE: 04-03-02
DRAINAGE AREA: 5.98 mil
Flow statistics as follows:
AVERAGE FLOW: Estimated using 1.0
ANNUAL 7Q10 MINIMUM FLOW: 0.1578
ANNUAL 30Q2 MINIMUM FLOW: 0.3440
WINTER 7Q10 MINIMUM FLOW: 0.2475
ANNUAL 7Q2 MINIMUM FLOW: 0.2810
NOTES:
ft3/s/mi2
6.0
ft3/s see note
B
ft3/s/mi2
0.94
ft3/s see note
C
ft3/s/mi2
2.1
ft3/s see note
C
ft3/s/mi2
1.5
ft3/s see note
LC�
ft3/s/mi2
1.7
ft3/s see note
ICE
[A] Estimate is based on records collected at or near the request site.
[B] Estimate is based entirely on runoff characteristics observed at nearby streams.
[C] Estimate based on procedures given in USGS Water Supply Paper 2403 "Low -flow Characteristics
of Streams in North Carolina" (Giese and Mason,1993).
[D] Estimate based on procedures given in USGS Water Supply Paper 2403 and in conjunction with
streamflow records collected at or near the request site.
[E] See remarks.
These data are considered provisional and subject to revision pending approval by the Director, USGS.
REMARKS:
• Low -flow estimates computed for existing USGS location where "old U.S. Hwy 74" (now SR 2862) used to
cross Gashes Creek prior to I-240/I-40 interchange (located approx. 0.2 miles upstream of request site).
• Requested by Ms. Sharon Korleski, RMT, Inc., Greenville, South Carolina
ENTERED BY: JCW FEE CHARGED: $ 150

Transmittal Letter
RMT North Carolina, Inc. ("RMT")
100 Verdae Boulevard (29607-3825)
PO Box 16778 (29606-6778)
Greenville, South Carolina
Tel. [phone] • Fax [phone]
MAY 2 : I U
c::urr
FIrWT SUUKC£ 6.,,;,,cu
To: Ms. Teresa Rodriguez Date: 5/24/02
NPDES Unit - Division of Water Quality Project No.: 70144.29
NC DENR Subject: SKF - Girmes Site
1617 Mail Service Center NCO086088
Raleigh, North Carolina 27699-1617 Buncombe County
Prepared By: Jeff Friend
Ms. Rodriguez:
Enclosed please find one copy of the low flow information prepared by the United States Geological
Survey in Raleigh, North Carolina. We hope this information satisfies DWQ's needs at this time.
Please call me at 864-234-9437 if you have further questions.
RMT North Carolina, hic.
Je1�Friend
Copy: File 70144.29
IC\DATA\O&M\SKFGMMFS\7Q70_DATA.DOC 5/24/02 TRANSULDOT FORMF (04/24/01)

United States Department of the Interior
U.S. GEOLOGICAL SURVEY
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
May 10, 2002
Ms. Sharon Korleski, Senior Civil Engineer
RMT, Inc.
Post Office Box 16778
Greenville, South Carolina 29606-6778
Dear Ms. Korleski:
In response to your request for low -flow data, the U.S. Geological Survey (USGS) does not have site -spe-
cific, low -flow discharge data for Gashes Creek at Oakley, NC (station id 03450621, drainage area 5.98
mi2). The low -flow characteristics that are provided on the attached sheet have been computed by using
the techniques presented in USGS Water -Supply Paper "Low -flow characteristics of streams in North Caro-
lina" (Giese and Mason, 1993). Please note that the flow estimates do not account for the presence of any
diversions or regulation, present or future, which may occur upstream of the request site.
Please be aware that the location (Sta. 03450621) where the low -flow estimates were determined is approx-
imately 0.1 mile upstream from the location of your request location. However, due to the short distance
and because no tributaries enter into Gashes Creek between the two locations (as indicated by the Asheville
and Oteen topographical quad maps), there is no appreciable increase in drainage area. Hence, the low -flow
characteristics at the upstream are considered applicable at your location. More specifically, the upstream
location is near the end of Secondary Road 2862, formerly "old" U.S. Highway 74 where it crossed Gashes
Creek prior to the construction of the I-240 / 1-40 interchange which resulted in the relocation of Highway
74. This location is also where the USGS has records of two discharge measurements that were made in
1943 and 1962.
Examination of the estimated low -flow yields (expressed in units of ft3/s per square mile drainage area) are
comparable to the average of yields obtained from nearby USGS sites in vicinity of Gashes Creek where
the USGS has collected streamflow records and determined low -flow estimates based on those records.
A charge for accessing and processing information has been assessed to partially offset these costs. Your
requested data and an invoice covering processing costs for these data are enclosed. Please forward the
original bill with your check to the U.S. Geological Survey, 12201 Sunrise Valley Drive, MS 271, Reston,
Virginia 20192.
These data are preliminary and subject to revision pending approval for publication by the Director of the
U.S. Geological Survey, and are made available through our cooperative program of water -resources inves-
tigations with the North Carolina Department of Environment and Natural Resources.
If you have any questions regarding this information, please contact us at [phone].
Enclosures
Sincerely,
ZVezve,
J. Curtis Weaver
Hydrologist
(919) 5714000 - LAX [phone]

Integrated
Environmental
® Solutions
March 15, 2002
Ms. Teresa Rodriguez
NPDES Unit - Division of Water Quality [In
North Carolina Department of Environment and Natural Resources1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: NPDES Draft Comments
Permit No. NC0086088, SKF Girmes Site
Buncombe County
Dear Ms. Rodriguez:
100 Verdae Blvd. 29607-3825
P.O. Box 16778 29606-6778
Greenville, SC
Telephone: [phone]
Fax: [phone]
l5 � IS � U � N
MAR 2 0 2W2
D tiR - WATER QUALITY
F6NT SOURCE BRANCH
On behalf of SKF USA, Inc. (SKF), RMT North Carolina, Inc. (RMT) is submitting comments
regarding the proposed draft permit dated February 6, 2001.
We appreciate the Department's efforts to review and implement some of our requested permit
changes submitted as part of the NPDES renewal package. Overall, the proposed permit changes are
encouraging. However, we do have a few requested changes that we believe will assist the
Department in developing an appropriate permit for this site.
Volatile Organic Compounds (VOCs)
We appreciate the Department's willingness to reduce effluent monitoring frequencies for these
parameters from monthly to quarterly.
Iron, Barium, and Manganese
We appreciate the Department's willingness to eliminate monitoring for these parameters.
Total Suspended Solids (TSS)
We appreciate the consideration the Department has given to evaluating whether numerical
limitations should be maintained in the renewed permit. However, we believe there is justification to
6(OA eliminate the monitoring requirements for TSS.
LP
nub Monitoring results indicate that the numerical limitation for TSS has never been exceeded by the
discharge. In the past 3 years, the highest effluent monthly sample was 18 mg/L. We believe this
was most likely the result of laboratory error, because the vast majority of samples in that 3-year
period have been below the method detection limit. In fact, the only values that were not below the
method detection limit were 1.5 mg/L and 1 mg/L. Two sampling events in 2000 were not
monitored due to an omission by the contract laboratory.
r:\ W eGVL\PJT\W7or44\29\ L007014429-0Ur.DOC

Ms. Teresa Rodriguez
North Carolina Department of Environment and Natural Resources
March 15, 2002
Page 2
This system discharges treated groundwater. With wells that have been developed, we do not expect
any measurable solids to be in the effluent. Your February 6, 2002, draft cover letter states that
"Monitoring for Total Suspend Solids shall remain in the permit. TSS has been detected in the
effluent, although the permit limit has not been exceeded there is still the possibility of solids in the
discharge." We acknowledge that sampling has indicated that TSS has been detected in the effluent
in previous sampling events. We do not agree that a significant level of TSS can be expected in the
discharge. The mere presence of TSS in the effluent does not warrant a permit limitation, and neither
federal nor North Carolina regulations require a TSS limitation simply because TSS has been detected
in the effluent.
Limitations for TSS are necessary if there is a technology -based effluent limitation that has been
established for this type of discharge for TSS, or if there is reasonable potential for the effluent to
cause or contribute to an instream excursion of a narrative or numeric water quality standard for TSS.
There is no promulgated technology -based effluent limitation for TSS for this type of discharge. The
only water quality criterion associated with TSS is from the Division of Water Quality's Red Book (as
amended January 1, 2002), which states for Class C streams (of which Gashes Creek is one) that
"settleable solids... shall not make the water unsafe or unsuitable for aquatic life and wildlife or
impair the waters for any designated uses." A review of effluent sampling data from the last 3 years
indicates that there is no reasonable potential for the treated effluent to cause or contribute to an
instream excursion of this narrative water quality criterion for settleable solids. Therefore, there is no
justification for an effluent limitation for TSS, and SKF respectfully requests that the Department
eliminate this parameter from the permit.
If the Department considers the information presented above and cannot justify eliminating TSS from
the permit, we request that the monitoring frequency be reduced to once per quarter and the sample
type be changed to a grab sample. Composite sampling is not necessary at this site because the
effluent cannot reasonably be expected to change significantly throughout the sampling event.
Whole Effluent Toxicity (WET) Testing
The Department has indicated that WET testing cannot be eliminated from the permit due to Division
policy for complex wastewater discharges. However, because the system treats and discharges
-� 7 treated groundwater, there is no reason to expect the effluent to be complex. The groundwater at the
C site has been characterized, and the effluent is not expected to change significantly over time. This
NPDES permit is a minor NPDES permit for a small discharge. Labeling the discharge "complex"
does not appear to be reasonable because of the nature of the discharge and the effluent. Toxic
parameters of concern are not expected to be in the effluent at levels that would cause individual
effects or combined effects in the receiving stream that would cause, or contribute to, an instream
excursion of the State's numeric or narrative water quality criteria.
L•\ W PGVL\ PJT\00-70144\29\ 1,007014429-001.DOC

Ms. Teresa Rodriguez
North Carolina Department of Environment and Natural Resources
March 15, 2002
Page 3
�-'The testing concentration for the discharge assumes that there is no dilution in the receiving stream.
S This is not the case. While the Department has indicated that they believe the 7Q10 flow for Gashes
,1Sb Creek is 0.0 cfs, RMT contacted Mr. Curtis Weaver (919-571-4043) of the North Carolina office of the
U United States Geological Survey (USGS) to determine the 7Q10 flow of the stream. Mr. Weaver
indicated that the 7Q10 for that stream is expected to be 0.9 cfs (0.58 mgd). Documentation of the
telephone communication is attached. The average discharge from the system in 2001 was 35,000 gpd
.1 ! (0.035 mgd); this effluent is discharged in Gashes Creek via a full -width effluent diffuser. While the
), flow rate through the system can be increased to perhaps 45,000 or 50,000 gpd, the yield from the
three wells at the site cannot reasonably be expected to exceed 52,000 gpd —much less approach the
108,000 gpd flow on which the permit is based. With an average effluent flow rate of 35,000 gpd, the
Y' instream waste concentration (IWC) is 5.7 percent.
Given that this is not a complex effluent, the IWC is only 5.7 percent, and the effluent is not expected
to cause or contribute to an instream excursion of water quality standards, SKF respectfully requests
that WET testing be eliminated from the permit. However, if after consideration the Department
cannot justify eliminating WET testing, then SKFrequests that the test concentration be reduced to
5.7 percent effluent, the monitoring frequency be reduced to once per year, and the sample type be
changed to a grab sample. Composite sampling is not necessary at this site because the effluent
cannot reasonably be expected to change significantly throughout the sampling event.
We appreciate your consideration of these comments. We look forward to hearing from you. If you
have any questions, please contact me at [phone].
Sincerely,
RMT North Carolina, Inc.
i ►4
Jeffrey A. Friend
O&M Coordinator
Wastewater Services
Attachments: USGS Phone Communication
cc: Bill McGlocklin, SKF USA, Inc.
Mike Parker, RMT
Dan Madison, RMT
Central Files
L\WPGVL\PjT\W014 \29\ L00701"2"01.DOC

ALW��
Communication Record
RMT, Inc., North Carolina (" RMT" )
100 Verdae Boulevard (29607-3825)
PO Box 16778 (29606-6778)
Greenville, South Carolina
Tel. [phone] Fax [phone]
Participant
Curtis Weaver
Prepared By:
Signature:
Project Name:
Project No.:
Date:
Company Name Telephone No.
United States Geological Survey 919-5714043
(USGS)--North Carolina
Sharon Korleski Title Sr. Civil Engineer.
Grimes Site (formerly SKF USA Inc.)
70144.29 Meeting At:
3/5/02 Time: 10:00 Telephone Conversation: Yes
Subject/Purpose: 7Q10 Flow
Discussion/Decision (Summary):
According to Curtis his estimate of the 7Q10 flow for Gashes Creek at the Grimes Site is 0.9 cfs.
I faxed Curtis a copy of the USGS map showing our location. He checked his records and found there
was no previous low flow characteristics on Gashes Creek. However, there was two miscellaneous
measurements at Highway 74 on Gashes Creek. There is a report of equations for estimating 7Q10
flow for this part of North Carolina. It uses flow measurements from other creeks in the area and the
drainage area. The 7Q10 yeild for other creeks in the area ranges from 0.10 to 0.15 cubic feet per
sec/square mile (cfs/sgmd.). He estimated the drainage area at Highway 74 to be about 6 square
miles and a yeild for the area based on the report equation to be 0.15 cfs/sm. A 7Q10 nflow of 0.9 cfs
is obtained by multiplying the 6 square miles by 0.15 cfs/sq.mi.
Followup Assignments:
We can get a copy of this report of equations for North Carolina for future estimates. Curtis can give
us the details on how to obtain it.
G:\DATA\KORLESKS\7Q10-CR.DOC 3/5/02 COMMREC.DOT FORM F59 (06/13/99)

AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
PUBLIC NOTICE
vies of the draft permit
td other supporting in-
mialion an file used to
dermine conditions pre-
m in the draft permit are
lailable upon request
id payment of the costs
reproduction. Mail
mmenis and(or requests
r information to the NC
vision of Water quality
the above address or
tamrareou in any com,
munication Interested
persom may else visit the
Division of Water quality
a1512 N. Salisbury Street.
Raleigh, NC 27604-1148 be
tureen the hours of 8:00 am
and 5:00 Pm to revieW in-
formation on file.
Before the undersigned, a Notary
County and State, duly commissi
qualified and
authorized by law to administer oaths, personally
appeared Crystal Fender who, being first duly
sworn, deposes and says: that he (she) is the Legal
Billing Clerk of TheAsheville Citizen -Times
Company, engaged in publication of a newspaper
known as The Asheville Citizen -Times, published,
issued, andenteredas second class mail in the City
of Asheville, in said County and State; that he (she)
is authorized to make this affidavit and sworn
statement; that the notice or other legal
advertisement, a true copy of which is attached
hereto, was published in The Asheville Citizen -
Times on the following dates: Feb. 9And that the
said newspaper in which said notice, paper,
document or legal advertisement were published
were, at the time of each and every publication, a
newspaper meeting all of the requirements and
qualifications of Section 1-597 of the General
Statues of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of
the General Statues of North Carolina.
0 V `, %i.� 44�
(Signature of person making affidavit)
Sworn to and subscribed before me the 14th day of
February, 2002
(Nu ublic)
My Commission expires the 201h day of June
Februory9,2002
(4117)

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.)
NA
Drainage basin
French Broad
Summer 7Q10 (cfs)
0
Subbasin
04-03-02
Winter 7010 (cfs)
NA
Use Support
FS
30Q2 (cfs)
NA
303(d) Listed
No
Average Flow (cfs)
NA
State Grid
E8SW / E9SW
1WC (%)
90
USGS Topo Quad
Asheville / Otten
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 and the elimination of TSS, 1,2
dichloroethene, vinyl chloride, barium, toxicity, iron and manganese and the reduction in
monitoring frequency for.TCE.
Facility Description The treatment system consists of an air stripping unit, a parshall flume
and effluent diffuser.
COMPLIANCE REVIEW
Whole Effluent Toxicity (WET) Test WET requirement is a Quarterly Chronic Toxicity
Pass/Fail using Ceriodaphnia at 90%. They have passed all the toxicity tests since 1996.
DMR Instream and Effluent Data Review DMR were reviewed for the period of January
1999 to October 2001. The average flow for this period was 0.0374 MGD. The maximum
flow discharged was 0.047 MGD. TSS was detected 4 times with an average of 5.3 mg/I
and a maximum of 18 mg/l. Thrichloroethene, 1,2-Dichloroethene and vinyl chloride were
not detected.
Reasonable Potential Analysis (RPA)
Thrichloroethene, 1,2-Dichloroethene and vinyl chloride were below detection level for all
samples therefore a RPA was not required.
Fact Sheet
Renewal -- NPDES Permit NCO086088
Page 1

Barium — The average value for barium was 0.04 /jg/I. There is no standard or criteria for
this parameter and it is not a parameter of concern, therefore the monitoring requirement
can be eliminated.
Manganese - The average value for manganese was 0.032 /ug/l. There is no standard or
criteria for this parameter and it is not a parameter of concern, therefore the monitoring
requirement can be eliminated.
Iron — A resonable potential analysis was performed for iron. The allowable concentration is
1000 jig/I, the maximum predicted concentration is 0.234 /ig/l. Iron does not present
reasonable potential to exceed water quality standard and is not a pollutant of concern
therefore the monitoring requirements can be eliminated from the permit.
PROPOSED MODIFICATIONS
• The sampling requirements for iron, manganese and barium were eliminated from the
permit.
• The monitoring for thrichloroethene, 1,2-Dichloroethene and vinyl chloride was reduced
to quarterly. These parameters were not detected in the effluent. Monitoring will remain
because these are the solvents being recovered from the groundwater.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: February 20, 2002.
Permit Scheduled to Issue: April 12, 2002.
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit,
please contact Teresa Rodriguez at [phone] ext. 595.
NAME: DATE:
Regional Office Office Comments
NAME: DATE:
NPDES SUPERVISOR:
Fact Sheet
Renewal -- NPDES NCO086088
Page 2
DATE:

04/16/2002 03:53 4 PAGE 01
NCDENR-DWQ Fax:[phone] Apr 11 T.0, 11:21 P.08✓08
pia, rium -The average value for barium was 0.04#911, Where is no standard or criteria for
this parameter and;l t is not a parameter of concern, therefore the monitoring requirement
can be eliminated.
I_vtsn as nese - The average value for manganese was 0.032 pg/I. There is no standard or
criteria for this parameter and it Is not a parameter of concern, therefore the monitoring
requirement can be eliminated,
Iron - A resonabie :potential analysis was performed tar iron. The allowable concentration is
1000 /.►ylt, the maxknurn predicted concentration is 0,234.rg/l. Iron does not present
reasonable potential to exceed water quaRy standard "{s not a pollutant of concem
therefore the monitoring requirements Can be eliminated from: the permit.
PROPOSED MODIFICATIONS
The sampling requirements for Iron, manganese and Wrlum were eliminated from the
permit. 1.
The monitoring for thrichlorcethene,1,2-DkNorloethene and vinyl chloride was reduced
to quarterly. ['hose parameters were not detected in the effluent. Monitoring will remain
beca se these;,are the solvents being recovered frbrn the groundwater.
PROPOSED SGHECULE OF ISSUANCE
Draft Permit to Pti6lic Notice: February 20, 2002.
Permit Scheduled �o Issue: April 12, 2002.
' NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit,
please contact Teresa RodrlgueZ at [phone] ext. 595.
NAME:0�-
' Regional 'lice Corliments
1.
ll.. ...r. ..
I
is
is
r
Y
is
a
Post-Ir Fax Note 7671
DW
pt196s III
1To
ro 11-4
COJEW1.
Go.
Phone Y
Phono N
Fax 0
Fax x
NAME:
NPDES SUPERVISOR:
�N Fact sheet
Renowid •- N10083 NC008150W
i

TOXICANT ANALYSIS
Facility Name
SKF / Girmes Site
Parameter =
TCE
Parameter=
1,2 DCE
99
ligA
Data
<1
<1
I
RESULTS
Std Dev.
Mean
#Dl
#DIV101
ftrameter =
:gA
;Standard =
n
1
2
Vinyl Chl
NPDES #
NC0086088
Standard =
92.4
jjgA
:;:Standard
525
li
Qw (MGD)
0.108
7Q10s (cfs)
0
n
BDL=1/2DLotual
Data
RESULTS to
I
n1DL=1/2D1ual
3DL=1 /2D
kctual Data
IN C' (0/0)
100.00
1
<1
Std Dev.
#DIV/O!
1
<1
?ec'ving Stream
Gashes Creek
2
<1
Mean
#DIV/01
2
<1
Stream Class
C
3
<1
C.V.
#DIV101
3
1<1
I C.V.
#DIV/0!
3
<1
4
<1
4
1<1
1<1
1<1
1<1
<1
Mult Factor=
Max. Value 0
Max. Pred 0
4
5
61
7
pgA::,: 8
1<1
<1
FINAL RESULTS
5
<1
5
TCE
6
<1
Mult Factor=
6
<1
Max. Pred Cw
0
ug/
7
<1
Max. ValuiE
0
/J 7
<1
Allowable Cw
92.4
ug/
8
<1
Max. Pred
0
k fi 8
1<1
Max. Value
0
9
<1
Allowable
92.40
p 19
<1
<1
<1
<1
Allowable C
99.00
pgA:: 9
101
11
121
<1
1,2 DCE
10
<1
10
<1
Max. Pred Cw
j 0
ug4
11
<1
11
<1
Allowable Cwj
99.0
U
12
<1
12
<1
<1
Max. Value
0
13
<1
13
<1
<1
131
K
Vinyl Chi
14
<1
14
<1
Max. Pred Cw
0
u 9/
15
<1
15
<1
<1
<1
<1
<1
<1
<1
<1
<1
1<1
<1
15
16
17
18
19
20
21
22
23
24
25
<1
Allowable Cw
525.0
ug/
16
<1
16
<1
Max. Value
0
17
<1
17
<1
Ba
18
<1
18
<1
Max. Pred Cw
0.065
ug/
19
<1
19
<1
Allowable Cw
#VALUE!
ug/
20
<1
20
<1
Max. Value
0.05
21
<1
21
<1
Iron
221
<1
22
<1
Max. Pred Cw
0.234
ug/
231
<1
23
<1
Allowable Cw
1000.0
ug/
24
<1
24
Max. Value
0.09
25
<1
25
1<1
<1
<1
<1
Mn
26
<1
26
<1
<1
<1
<1
<1
<1
1<1
26
27
28
29
30
1
32:1
Max. Pred Cw
0.301
ug/
27
<1
27
Allowable Cw
#VALUEl
ug/
28
<1
28
Max. Value
0.07
29
<1
29
<1
0
1 30
<1
30
<1
Max. Pred Cw
0
u 94,
311
<1
LE
31
1<1
Allowable Cw
j 00 .
ugA
321
1<1
321
1<1
1/23/02

TOXICANT ANALYSIS
rameter
Ba
Iron
:parameter:parameter=
Mn
I Vandard =
lig
Standard
1000
':Standard
PU
RESULTS
n
BDL=1/2D[kctual
0.051
0.05
0.05
0.05
0.051
0.0461
Data
< 1
<.I
<.1
<.I
<. 1
0.0461
RESULTS
Std Dev.
Mean
C.V.
Mult Facto t
0.00918
0.04334
0.21183
1.3
n
1
2
3
4
5
6
1DL=1 /2D
kctual Date
RESULTS
n
1DL=1 /2D
Actual Data
RESULTS
Std Dev.
#DIV/01
1
0.091
0.09
Std Dev.
0.0211
1
0.07
0.07
Std Dev.
0.0176
Mean
#DIV/O!
2
0.051
0.06
Mean
0.02113
2
0.061
0.06
Mean
0.0094
C.V.
#DIV/01
3
0.0251
C.V. 1
0.99896
3
0.075
0.05
C.V.
1.8661
4
0.025
4
0.0051
5
0.025
5
0.005�
Mult Factor
6
0.01
Mult Facto,
2.6
6
0.00251
Mult Facto
4.3
Max. Value
-J
0
7
0.045
0.045
0.045
0.045
Max. Value
Max. Pred
0.05
0.065
A 7
ligA;.::;:: 8
0.01
Max. Value
0.09
7
0.032
1 0.032
Max. Value
0.07
/i g/
Max. Pred 1
0
/ 8
JgA
0.01,
Max. Pred
0.234
/igAi 8
0.00251
Max. Pred
0.301
agi
Allowable C
525.00
Pg&,-;9
0.039
0.039
Allowable C
#######
p A 9
0.01
Allowable
1000.00
11 9
0.00251
Allowable
######
IjW
10
0.048
0.048
10
0.01
10
0.00251
11
0.048
0.048
11
0.079
0.079
11
0.00251
12
0.05
0.051
1
12
0.01
12
-6.-0�0541
-
0.0054
13
0.046
0.048
0.046
0.048
13
14
0.01
131
0.00251
14
0.01
0.023
0.023
14
15
0.0025
15
0.046
0.044
0.044
0.027
0.026
0.046
0.044
0.044
0.027
0.026
15
16
17
... 18
19
0.0025
16
0.01
16
0.0025
17
0.0311
0.031
17
0.0063
0.0063
18
0.01
18
0.0025
19
0.01
0.032
0.032
19
201
0.00261
20
0.043
0.043
20
0.0098
0.0098
21
0.049
0.049
21
0.01
21
0.0025
22
0.047
0.047
22
0.066
0.066
22
0.0025
23
0.004
0.004
23
0.02
0.02
23
0.0025
24
0.045
0.045
24
0.01
24
0.0025
25
0.046
0.045
0.044
0.046
0.045
0.044
25
26
27
0.01
25
0.0025
26
0.01
26
0.0025
27
0.01
0.01
27
28
0.0025
28
0.039
0.039
28
0.0026
29
0.04
0.047
0.04
0.047
1
... 29
30
0.01
29
0.0025
30
0.01
,
;ju
0.0025
311
0.04
0.046
0.04
0.046
1
31
32
0.011
31
0.0025
321
0-011
32
0.00251
1/23/02

Integrated
Mw� Environmental
Solutions
June 29, 2001
Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Point Source Branch
1617 Mail Center
Raleigh, North Carolina 27699-1617
100 Verdae Blvd. 29607-3825
P.O. Box 16778 29606-6778
Greenville, SC
Telephone: [phone]
Fax: [phone]
p� E E
D
JUL 6 2001
I CENR-WATER OUALITY
.n,Kr gc)uRCE BRANCH
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Renewal
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Ms. Stephens:
RMT North Carolina, Inc. (RMT) has been retained by SKF USA, Inc. (SKF) to operated and maintain
the Girmes Site Groundwater System near Asheville in Buncombe County. The system began
discharging treated groundwater on March 4,1998. Groundwater is recovered from three 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 "C" tributary of the Swannanoa River in the French
Broad River basin.
NPDES Permit History
The current NPDES permit sets a daily maximum discharge limitations for the parameters identified
in Table 1. 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 90 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 limits 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
the effluent in any of the effluent samples collected in at least the past 2 years of monitoring.
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 average of approximately
1 million gallons per month now. Also, the concentration of VOCs in the recovered water has
decreased. When recovery operations began, the influent trichloroethene (TCE) concentration was
approximately 2,900 parts per billion (ppb) and has declined to approximately 380 ppb now. We
believe these data show that the treatment system can easily reduce the influent VOCs to well below
the permit limit of 92.4 ppb and that other permitted parameters, namely total suspended solids
P:\DATA\O&M\SKFGMMES\NPDESRENEW ALDOC

Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 2
(TSS), barium, manganese, and iron are also well below the NPDES permit limits. 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 a flow of 0.108 million gallons per day (mgd) and is the
design flow of the treatment system and is much higher than the average daily flow from the site.
For the record, the flow for the first five months of 2001 has been approximately 33,800 gallons
per day (gpd).
2. TSS- The site has never exceeded its 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, and request
that this parameter be dropped from the permit.
3. TCE - The site has never exceeded its permit limit for TCE and the results have generally been no
detection (<1 ppb). The only detection of this parameter occurred during the first month of
operation at an effluent concentration of 2.1 ppb. We do not believe that continued monitoring of
this parameter will yield additional useful information. Nevertheless, this is the primary VOC of
concern at the site and we believe that quarterly monitoring is sufficient to confirm proper
operation of the treatment system. Therefore, we request that the frequency of monitoring TCE
be reduced to once per quarter.
4. 1,2-dichloroethene - This parameter has not been detected in the treated effluent. We do not
believe that there is a reasonable -potential for this parameter to cause a violation of water quality
standards and that continued monitoring of this parameter will not yield additional useful
' information. Therefore, we request that 1,2-dichloroethene be dropped from the permit
5. Vinyl chloride - This parameter has not been detected in the treated effluent. We do not believe
j 1' that there is a reasonable potential for this parameter to cause a violation of water quality
standards and that continued monitoring of this parameter will not yield additional useful
information. Therefore, we request that vinyl chloride be dropped from the permit.
6. Barium - This parameter is present in the discharge at approximately 0.045 mg/L. Even without
dilution by the receiving stream, this concentration is much lower than North Carolina's Water
Supply Classification standard of 1 mg/L. We do not believe that there is reasonable potential
for this parameter to cause a violation of water quality standards and that continued monitoring
of this parameter will not yield additional useful information. Therefore, we request that barium
be dropped from the permit.
7. Iron - This parameter is generally not detected in the discharge at a quantitation limit of
0.02 mg/ L. Even without dilution by the receiving stream, this concentration is much lower than
North Carolina's Action Level standard of 1 mg/L. We do not believe that there is a reasonable
P:�DATA �O&M � SKF.GIRMES � NPDESRENEWAL.DOC

Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 3
potential for this parameter to cause a violation of water quality standards and that continued
monitoring of this parameter will not yield additional useful information. Therefore, we request
that iron be dropped from the permit.
8. Manganese - This parameter is generally not detected in the discharge at a quantitation limit of
0.005 mg/L. Even without dilution by the receiving stream, this concentration is much lower
than North Carolina's Action Level standard of 0.2 mg/L. We do not believe that there is a
reasonable potential for this parameter to cause a violation of water quality standards and that
continued monitoring of this parameter will not yield additional useful information. Therefore,
we request that manganese be dropped from the permit.
9. 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. All test results have been deemed to be a "pass' according to the bioassay
procedure.
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 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 site'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
33,800 gpd for the first 5 months of 2001. Therefore, the test concentration stipulated in
P.I DATA IO&M\ SKFGIRMES I NPDESRENEWAL.DOC

Ms. Valery Stephens
North Carolina Department of Environment and Natural Resources
Division of Water Quality
June 29, 2001
Page 4
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 request
that the Division remove toxicity testing from the permit.
Per the instructions for NPDES renewal packages, we are including the following additional
information:
United States Geological Survey (USGS) topographical site location map indicating the outfall
diffuser.
■ A copy of the surface water discharge alternatives analysis prepared in 1997, which we believe
reasonably reflects the current operation.
■ A summary of the most recent analytical results for January through April 2001(see Table 2).
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
O&M Coordinator
Wastewater Treatment Services
Attachments
cc: Bill McGlocklin, SKF USA, Inc.
Dan Madison, RMT
Central Files
P.I DA rA I OBM I SKF-GIRMFS \ NPDESRENE WA L. DOC

A
's
i
x
ie
ILL.
N0. KENTUCKY ••Y�
TENN ESSEE ­ iN.0
MISS. ••:Al.ti:.• GA. S.C.
QUADRANGLE LOCATION
A$NEViLLE QUAD,
OTEEN QUAD
70144.12
® 0297
c
FIGURE 1
SITE LOCATION MAP GIRMES SITE
SCALE: 1"=2000' FORMERLY SKF_USA INC.
Vol
F

Section 3
Svstem Discharge Alternatives
(This section was revised on March 27,1997.)
The following treated groundwater discharge alternatives were evaluated for the Girmes site:
sewer discharge and subsurface discharge.
3.1 Connection to Sewerage System
The alternative of discharging treated groundwater to a publicly owned treatment works
(POTW) is applicable to the treated groundwater, provided that the quality of the water meets
the pretreatment requirements of the local regulatory agency. The Girmes site is served by the
Metropolitan Sewerage District of Buncombe County (MSD); however, MSD is limiting
discharges from groundwater remediation systems to a maximum of 20,000 gpd. The CA
system will have a design capacity of 108,000 gpd and a projected initial flow rate of 75,000 gpd
from the three recovery wells.
Confirmation of a telephone conversation with MSD is found in Appendix C.
3.2 Subsurface Disposal System
RMT has evaluated the potential installation of an infiltration gallery to receive treated effluent
from the groundwater remediation system. This evaluation included review of site
topographic characteristics, soil type classification, soil characteristics, and hydrogeologic
conditions.
The site topography is shown on Plate 1. The Girmes facility is perched on a hilltop and
surrounded on three sides by steeply sloping, wooded terrain. The installation of an infiltration
gallery on the steep slopes would be impractical. The only flat area of the site is located
southeast of the facility encompassing an area of approximately 3 acres. Soil and groundwater
in this area have not been affected by past on -site activities.
The site is underlain by saprolite soils 20 feet to 30 feet in thickness overlying crystalline
bedrock. Saprolite throughout the site consists of silts, silty sands, and clayey silty sands. Soils
data provided by the Buncombe County Soil and Water Conservation District indicates a soil
permeability of 0.6 to 2 inches per hour from the surface to a depth of 4 feet. Using the more
conservative value of 0.6 inches per hour and a design hydraulic loading rate of 108,000 gpd,
approximately 12,000 sq. ft or 0.3 acres of infiltration gallery would be required. Based on
RMT, Inc. 15 Girmes Site
Mw VLtroiMM72.00c March 1997

RMT's experience, a design safety factor of 5 should be applied to account for continuous
versus intermittent flooding. This safety factor results in a total requirement of approximately
1.5 acres. Uniform hydraulic loading in a 1.5 acre infiltration gallery would be difficult and
would result in continuously flooded as well as hydraulically starved areas. This area could
not be used for further expansion of the facility or truck parking.
Placement of an infiltration gallery on the southeast site of the Girmes facility would cause a
local increase in hydraulic head immediately beneath the gallery and increased hydraulic
gradients across the site area. Increased gradients in the north to northeast directions would
result in increased groundwater flow velocities, causing the northest plume of affected
groundwater to migrate more rapidly in the direction of the NC DOT facility. The natural
attenuation rate of the VOCs per unit distance would, as a result, decrease in response to
increased flow velocities. This creates the potential for higher VOC concentrations to migrate
further offsite. In addition, infiltrated water would not be captured by the existing
groundwater recovery system, given the only suitable location on the site for an infiltration
gallery southeast of the facility.
3.3 Feasibility of Discharge Alternatives
The information discussed in the previous sections shows that, because of local POTW policies
and site conditions, the evaluated discharge alternatives are not feasible. The MSD limitation of
20,000 gpd for groundwater remediation systems would not allow the system to meet the CA
objectives. Site topography, hydrogeology, and soil permeability prevent the installation of an
infiltration gallery of sufficient area to meet the requirements of the projected discharge and
meet the CA objectives. However, system discharge to the Gashes Creek is environmentally
feasible because of the creek's proximity to the property and the quality of the treated
groundwater that would be discharged to the creek.
RMT, Inc.
1:11VPG VL 1701 1 7014412.DOC
16
Girrnes Site
March 1997

Table 1
Summary of NPDES Permit
PARAME�l"ER 1 ,�
!1 �', t. I 7 is f. Vq En' G #
c SIB ,
:.imf ..u•ii t�3i�;t„ 'f...,
�tS �# }ifi�! !!� fi �t11..,.,
; ,
�fi ! i:fa , i! •a;! It
Flow
0.108 m d
Continuous
TSS
30.0 m / L
Monthly
TCE
92.4 µ / L
Monthly
1,2-DCE
None
Monthly
VC
None
Monthly
Ba
None
Monthly
Fe
None
Monthly
Mn
None
Monthly
Toxicity
Pass
Quarterly
Table 2
Summary Maximum Observations for 2001
PARAMETER
E 3} .t:r '` F.. '.
K
1. 'i,7 Y'
E .• tt• i i y. - e
r r t r
�.�. t. 11 .E.... =-,jl�t.. ;�._
t *1'!ih i y -t rrl -
�S•. ._ ._k��i.ltLLi�. i-.al--y
Flow - m d
0.038
0.036
0.035
0.051
TSS - m /L
<5
<5
<5
<5
TCE - µ / L
<1
<1
<1
<1
1,2-DCE - µ / L
<1
<1
<1
<1
VC - µ / L
<1
<1
<1
<1
Ba - m / L
0.046
0.045
0.044
0.039
Fe - m / L I AL
<0.02
<0.02
<0.02
<0.02
Mn - m / L
<0.005
<0.005
<0.005
<0.005
Toxicity P/ F
Pass
Pass
P:\ DATA\C&M\SKF-GIRMES\NPDESRENEW ALDOC

• SKF USA Inc.
Norristown, PA
USA
June 25, 2001
Mr. Shannon Langley
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Center
Raleigh, North Carolina 27699-1617
Reference: Authorized Representative Delegation
Girmes Site Groundwater System
NPDES Permit No. NCO086088
Buncombe County
Dear Mr. Langley:
This letter is notification that SKF USA Inc. has delegated signatory authority to
RMT North Carolina, Inc. as follows:
Dan O. Madison, RMT North Carolina Project Manager
NPDES DMR forms
Jeffrey A. Friend, Operations Coordinator, Operator -in -Charge
Please contact the undersigned if you need further information.
Sincerely,
C.W. McGlocklin
Director of Environmental Affairs
cc: Jeff Friend (RMT, Inc.)
Dan Madison (RMT, Inc.)
11 I I Adams.Venue Telephone: [phone]
Norrislonn. PA 194113-2403 Fax: [phone]