NC0086088_Permit Modification_20020823 (2)

�'_FW^A_TF`R\pG Michael F. Easley, Governor
,\ r William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 23, 2002
Mr. Dan O. Madison
I I11 Adams Ave.
Norristown, PA 19403-2403
Subject: NPDES Permit Modification
Permit No. NCO086088
SKF USA Inc. - Girmes Site
Buncombe County
Dear Mr. Madison:
On June 7, 2002, the Division of Water Quality issued NPDES Permit No. NCO086088 to SKF USA Inc.
On July 15, 2002 the Division received a letter from RMT requesting modifications to the permit. The
Division evaluated the requests and the following modifications were made to the permit:
Total Suspended Solids — Sampling for TSS was modified to a grab sample. The sampling
frequency will remain as monthly.
Chronic Toxicity — Sampling for chronic toxicity was changed to a grab sample.
Operation and Maintenance, Certified Operator — The rules for Water Pollution Control System
Operators Certification specify the frequency for visiting a treatment system. SKF USA Inc. system
is classified as a Grade I physical chemical system and is therefore subject to this rules. Section 15A
NCAC 8G.204(2) Requires the Operator in Responsible Charge to visit the system no less frequently
than weekly.
The Technical Assistance and Certifications Unit has given facilities until December 2003 to
designate the ORC. The boilerplate language in the permit is general language that is included in
every permit. As stated in the letter from the Technical Assistance and Certifications Unit you have
until December 2003 to designate the ORC and you will not be in violation of your permit.
Nevertheless your current operator must visit the site on a weekly basis as required in the rule.
Accordingly, we are forwarding herewith the modifications to the effluent page of the subject permit.
Please replace this page in your permit.
If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone number
[phone]. ext. 595.
Since an W. Klimek, F E.*4`
cc: Asheville Regional Office. Water Quality
Point Source Compliance Enforcement Unit
Aquatic Toxicology Unit
en
Jeffrey Friend — RMT North Carolina, Inc.
P.O Box 16778
Grecnville, SC 29606-0030
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportuni!y Affirmative Action Employer Visit us on the INTERNET 0 www.enr.state.nc.us

Permit No. NCO086088
SECTION 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 LIMITATIONS
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/1
Monthly
Grab
E
TrachloroetYien�`
Quarterly
Grab
E
1;2 Dlc-hToroetj�ene-"',
Quarterly
Grab
E
Vinyl Chloride-,,,--
Quarterly
Grab
E
Chronic Toxicity2
Quarterly
Grab
E
Notes:
1. Flow may be measured using a totalizing flow meter.
2. Chronic Toxicity (Ceriodaphnea) P/F at 15 %, January, April, July and October; See Condition 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.

Re: SKF USA permit modification NCO086088
Subject: Re: SKF USA permit modification NCO086088
Date: Thu, 01 Aug 2002 12:59:24 -0400
From: Matt Matthews <[e-mail]>
Organization: NC DENR DWQ
To: Teresa Rodriguez <[e-mail]>
Teresa,
Consistency in the waste stream is a valid reason for utilizing a grab
sample. If the facility personnel can prove this to your satisfaction,
I'm OK with the modification. It might be a good idea to check in with
the regional office on this as well.
Matt
Teresa Rodriguez wrote:
>Matt,
>I received a letter from the consultant for SKF USA requesting changes
>to the recently issued permit. They are requesting to change the
>chronic toxicity sample to grab based on their compliance record and the
>consistency in the characteristics of the wastewater discharged. Could
>you please comment on this request,
>Thanks
>Teresa
Matt Matthews
NC DENR/Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
v-[phone]
f-[phone]
MailTo:[e-mail]
------------------------------------------
A few observations and much reasoning lead to error;
many observations and a little reasoning to truth.
--Alexis Carrel $11(p
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8/15/2002 7:57 AM

Integrated
Environmental
Mw� Solutions
July 2, 2002
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�DENR - WATER QUALITY
POINT SOURCE BRANCH
Ms. Teresa Rodriguez
NPDES Unit - Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
100 Verdae Blvd. 29607-3825
P.O. Box 16778 29606-6778
Greenville, SC
Telephone: [phone]
Fax: [phone]
Subject: National Pollutant Discharge Elimination System (NPDES) Permit Comments
Permit No. NC0086088, SKF Girmes Site
Buncombe County
Dear Ms. Rodriguez:
On behalf of SKF USA Inc. (SKF), RMT North Carolina, Inc. (RMT) is submitting comments regarding
the proposed permit dated June 7, 2002. We appreciate the Division efforts to review and implement
some of our requested permit changes submitted as part of the NPDES renewal package. Generally,
the NPDES permit is acceptable; however, we request that the Division make the following minor
modifications.
■ Total Suspended Solids (TSS) - We request that the sample type be changed to grab samples
collected on a quarterly basis. We believe that since volatile organic compounds (VOCs) are
required to be monitored quarterly, this frequency should be adequate for TSS as well.
■ Chronic toxicity - We request that the sample type be changed to a grab sampled All of the
monitoring data that we have generated since the discharge began have demonstrated that the
effluent quality is very consistent and uniform. With the exception of one anomalous toxicity test
failure, all past toxicity testing has demonstrated that there is no reasonable potential for any
impacts in the receiving stream. With the steady state nature of the aquifer, we do not have any
reason to believe that there would be a significant change in the characteristics of the discharge
over a period of weeks or even months. A 24-hour composite sampling period appears to be
unnecessary.
Operation and Maintenance, Certified Operator - Part II Section C.1 stipulates that a certified
operator must visit the site once per week. Since startup, the system has been routinely visited
once per month with additional quarterly maintenance visits. We believe that this schedule is
adequate for this type of treatment system because of the controls and alarms that were
incorporated into the system design. hi the event the stripper's blower malfunctions, the system
will shut down and initiate an alarm. If the discharge piping should become obstructed, a high
level switch in the stripper sump will initiate an alarm. General alarms are also initiated if there
is a power failure or if the building temperature is high or low. The operators can also remotely
listen to the operation of the air stripper and monitor the conditions of these alarms. It is RMT's
opinion that this type of treatment system can be safely monitored on a monthly basis. The fact
that the system has operated since March 1998 without a permit violation of, or even detection of,
any VOCs demonstrates its reliability.
R:\DATA\OhM\SRFGIRAIES\NPDESRESPONSE2.D

Ms. Teresa Rodriguez
North Carolina Department of Environment and Natural Resources
July 2, 2002
Page 2
Finally, RMT has been notified by Mr. Tony Arnold (copy of letter attached) that the permittee
has until December 31, 2003, to comply with the requirement for a North Carolina -certified
Operator in Responsible Charge. Please modify Section C.1 to reflect that this requirement does
not become effective until the end of 2003.
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.
Jeffrey A. Friend
O&M Coordinator
Wastewater Services
Attachments: NC DENR letter dated August 17, 2001
cc: Bill McGlocklin, SKF USA, Inc.
Mike Parker, RMT
Dan Madison, RMT
Central Files
R:\DATA\O&M\SKF-GMMES\NPDESR MNSE7.DDC