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NC0086088_Permit Renewal_20151019
North Carolina Department of Environmental Quality Pat McCrory Donald R. van der Vaart Governor Secretary October 19, 2015 Ms. Erika H. Mau, Manager of Sustainability EHS Department SKF USA Inc. 890 Forty Foot Road P.O. Box 352 Lansdale, PA 19446-0352 Subject: Issuance of NPDES Permit Renewal Permit No. NCO086088 Girmes Site Remediation Buncombe County Facility Class PC I Dear Ms. Mau: 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 Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). No changes were made to the draft permit sent to you on August 26, 2015. The final permit authorizes the SKF USA Inc. to discharge wastewater from Girmes Site Remediation to Gashes Creek, a class C water in the French Broad River Basin. The permit includes discharge limitations or monitoring for flow, total suspended solids (TSS), pH, trichloroethene, 1,2 dichloroethene, and vinyl chloride. As identified previously, the renewal permit contains the following significant changes from your current permit: • In accordance with Class C Water Quality Standards [15A NCAC 02B .0211], a pH effluent limitation of "Not less than 6.0 nor greater than 9.0 Standard Units" with a monitoring frequency of quarterly was added to section A. (L). • The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit. [See Special Condition A.(3.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://i)ortal.nedenr.orWweb/wa/admin/bog/iyu/edmr. For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site: httn•//www2 epa gov/compliance/proposed npdes electronic reportinizrule. 1601 Mail Service Center, Raleigh, North Carolina 27699-1601 Phone: 919-707-86001 Internet: www.ncdenr.gov An Equal Opportunity I Affirmative Actlon Employer— Made in part by recycled paper • Some of the wording has changed in Special Condition A. (2), Chronic Toxicity Permit Limit, please review each paragraph carefully. The Division recognizes that the Permittee is currently conducting semi-annual monitoring of groundwater (MW-05, MW-10, and MW-21), pore water (PW-06, PW-07, PW-10, and PW-11), and surface water (SW-02, SW-03, SW-04, and SW-08) near Gashes Creek. The Penmittee shall submit all semi-annual monitoring results with its next permit renewal application. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Resources or any other Federal, State, or Local governmental permits that may be required. If you have questions concerning this permit, please contact Yang Song by e-mail (yang.song@ncdenr.gov) or phone at (919) 807-6479. Sincerely, e �' ran, Division of Water Resources Enclosure: NPDES Permit NC0086088 cc: NPDES Unit Central Files Asheville Regional Office / Water Quality Program e-copy: Susan Meadows, Aquatic Toxicity Branch Dan O. Madison, Engineer/Environmental Consultant, TRC David Ramey, Hydrogeologist, Inactive Hazardous Sites Branch Permit N00086088 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES 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 12 Old Charlotte Highway 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 applicable conditions set forth in Parts I, H, and III hereof. The permit shall become effective ............................................... December 1, 2015. This permit and the authorization to discharge shall expire at midnight on October 31, 2020. Signed this day...................................................................... October 19, 2015. ,fr ZimmermaiV.G/ ctor, Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 6 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, 12 Old Charlotte Highway, Asheville NC, Buncombe County; and 2. Discharge from said treatment works through Outfall 001 into Gashes Creek, a Class C water in the French Broad Raver Basin, at the location specified on the attached map. Page 2 of 6 Permit NCO086088 PART I A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] a. 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 IVIONITORING REQUIIEMENTS. EFFLi1�T ...Y ..a,u. f 7 - . L ' -: .. i Y 31: a - Y .. .'1' < !.i c a.•1_ i ti1.SRT CHARA CTE$TICS monthly Daily 1Vleasurement, Sample'ype _ Sample Average 'Maxi]. Frequency I;oca ion Flow 2 0.108 MGD Continuous Recording Effluent Total Suspended Solids 30.0 mg/L Quarterly Grab Effluent Trichloroethene (µg/L) Quarterly Grab Effluent 1,2 Dichloroethene (µg/L) Quarterly Grab Effluent Vinyl Chloride (µg/L) Quarterly Grab Effluent pH Not less than 6.0 nor eater than 9.0 Standard Units Quarterly Grab Effluent Chronic Toxicity 3 Quarterly Grab Effluent Footnotes: 1. No later than 270 days from the effective date of this permit, begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Special Condition A.(3.). 2. Flow may be measured using a totalizing flow meter. If no discharge during the month, report "No Discharge" on Monthly DMRs. 3. Chronic Toxicity (Ceriodaphnia) limit at 150Zo with testing in January, April, July and October (see A. (2)). b. There shall be no discharge of floating solids or visible foam in other than trace amounts. c. Quarterly samples for monitored parameters shall coincide with the chronic toxicity test. Part I, Page 3 of 6 Permit NCO086088 A. (2) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) [I 5A NCAC 02B .0200 et seq.] 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 December 2010, or subsequent versions or "North Carolina Phase If Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be performed during the months of January, April, July and October. These months signify the first month of each three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and 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 U Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions. 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, DWR Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1623 Mail Service Center Raleigh, NC 27699-1623 Completed Aquatic Toxicity Test Forms shall be filed with the Water 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 Water 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. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources 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. Part I, Page 4 of 6 Permit NCO086088 A. (3) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS [G.S. 143-215.1(b)] Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation in late 2013. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.) Records Retention • Section E. (5.) Monitoring Reports 1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1 Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / DWR / Information Processing Unit ATTENTION: Central Files / eDMR 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary waiver by the Division. Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http://Dortal.ncdenr.or web/wq/admin/bow u/p edmr Part L Page 5 of 6 Permit N00086088 Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. 2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)l All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part H, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://portal.ncdenr.org/web/wq/admin/bodipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: V certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualifiedpersonnelproperly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 3. Records Retention [Supplements Section D. (6.)1 The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Part I, Page 6 of 6 DENR / DWR / NPDES Unit FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit No. NCO086088 Facility Information Applicant/Facility Name: SKF USA Inc. / Girmes Site Applicant Address: 890 Forty Foot Road P.O. Box 352, Lansdale PA 19446 Facility Address : 12 Old Charlotte Highway, Asheville NC 28803 Permitted Flow (MGD) : 0.108 MGD Type of Waste: Groundwater Facility Class/Permit Status : PC1/ Renewal County : Buncombe Miscellaneous Receiving Stream : Gashes Creek Regional Office: Asheville Stream Classification : C 8-Digit HUC : 06010105 303(d) Listed : No Permit Writer: Yang Song Drainage basin : French Broad Date : October 6, 2015 Subbasin/ Stream Index: 04-03-02/ 6-78-21 Lat. 35034' 09" N Long. 82° 29' 59" W Drainage Area (sq. mi.) : 5.98 Summer 7Q10 (cfs) : 0.94 Winter 7Q10 (cfs) : 1.5 30Q2 (cfs) : 2.1 Average Flow (cfs) : 6.0 I WC (%) : 15 SUMMARY SKF USA Inc. was the former owner of a bearing manufacturing facility located at 12 Old Charlotte Highway, Asheville, Buncombe County, NC. In 1973, this facility was sold to Girmes, a textile manufacturer who operated the facility till 1990. SKF USA Inc. completed a Comprehensive Site Assessment and a Corrective Action Plan (CAP) to address the contaminated GW at the site. To implement the CAP, SKF USA Inc. began operating the groundwater remediation in 1998. The original NPDES permit was issued in 1997 and included limitations and/or monitoring of flow, total suspended solids, trichloroethene, 1,2-dichloroethene, vinyl chloride, barium, iron, and manganese. This groundwater remediation project was initiated by the Groundwater Section in the Division of Water Quality in the mid-1990s. DENR was re -organized and the Division of Waste Management became responsible for tracking the Girmes Site groundwater remediation. In 2009, the consulting company, RMT, conducted an evaluation of effectiveness on the recovery system. Based on the evaluation, RMT calculated "safe" concentrations of volatile organic compounds (VOCs) in the groundwater that could be discharged into Gashes Creek without violating surface water standards. A memorandum developed by RMT indicated that VOCs detected in groundwater near the Gashes Creek were significantly lower than the "safe" concentrations of VOCs. Thus operation of the groundwater recovery and treatment system was terminated in Nov. 2009. A groundwater injection permit (WI0100043) was issued in May 2007, which allowed the Permittee to inject sodium persulfate to chemically oxidize chlorinated ethenes at the site. The groundwater injection permit was for a two year period and it expired in May 2009. Fact Sheet Renewal -- NPDES Permit NCO086088 Page 1 Currently, TRC Environmental Corporation (TRC) operates and maintains the groundwater remediation system. Mr. Dan Madison, TRC Project manager, stated that semi-annual monitoring of tetrachloroethene, trichloroethene, 1,2 dichloroethene, and vinyl chloride is being conducted at groundwater monitoring wells, pore water monitoring sites, and surface water monitoring sites located near Gashes Creek. Mr. Dan Madison also indicated that the company's decision on whether to remain off-line or restart the remediation system will be made based on following criteria: 1) comparison between groundwater monitoring results and the allowable groundwater VOCs concentrations near Gashes Creek; and, 2) comparison between surface water monitoring results and the surface water quality standards. TRC also stated that consideration to put the remediation system back on-line will be made if they notice increasing concentrations of monitored parameters. SKF is requesting renewal of this NPDES permit (NC0086088) in case of a discharge of treated groundwater is necessary. The current NPDES permit will expire on October 31, 2015. The Permit renewal application was received on April 30, 2015. The Permittee did not request any modification to the permit during this renewal. Facility Description: The treatment system consists of an air stripping unit, a parshall flume and an effluent diffuser. COMPLIANCE REVIEW During the last permit cycle when there was a discharge (Dec. 2005 — Oct. 2010), no NOVs were issued. The most recent compliance evaluation inspection was conducted by Ashville Regional Office on August 19, 2011 and it found the facility to be in compliance. Whole Effluent Toxicity (WET) Test WET requirement is a Quarterly Chronic Toxicity Pass/Fail using Ceriodaphnia at 15%. According to the fact sheet dated January 9, 2012, they have passed all 12 toxicity tests from January 2007 until the shutdown in November, 2009. REASONABLE POTENTIAL ANALYSIS (RPA) Trichloroethene, 1,2-Dichloroethene and vinyl chloride were below detection levels through November of 2009, when the unit was shut down. It is still off-line; therefore a RPA was not required for this permit renewal. SEMI-ANNUAL MONITORING The facility has been conducting semi-annual monitoring for tetrachloroethene, trichloroethene, 1,2- dichloroethene and vinyl chloride at monitoring wells and sites since the groundwater treatment system was shut down. The monitoring data from 2012 through 2015 provided by TRC was reviewed. It showed the Permittee monitored groundwater at wells MW-05, MW-10, and MW-21; pore water near Gashes Creek through PW-06, PW-07, PW-10, and PW-11; and surface water from Gashes Creek through SW-02, SW-03, SW-04, and SW-08. The locations of these monitoring sites are shown in the attached map. The monitoring results showed no exceedance of surface water quality standards in surface water samples. However, there were several hits of groundwater and pore water samples that exceeded Groundwater Quality Standards (15A NCAC 02L. 0202). These groundwater exceedances were discussed with the Inactive Hazardous Sites Branch (IHSB) in the Division of Waste Management. IHSB staff stated that the facility was rated as less priority due to the fact of no residential well drinking water systems nearby as well as a buffer zone to the Gashes Creek. Since the facility is not involved in the voluntary Registered Environmental Consultant (REC) Program, they are not submitting groundwater monitoring results to IHSB. The semi-annual monitoring data shall be submitted with its next NPDES permit renewal application. Fact Sheet Renewal -- NPDES NCO086088 Page 2 PROPOSED MODIFICATIONS The following permit modifications are proposed for this permit renewal: 1. Addition of electronic DMR requirement. 2. Addition of revised Toxicity testing language. 3. Addition of pH limitation and monitoring requirement in A. (1.). BASIS FOR PERMIT EFFLUENT LIMITS EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS RATIONALE FOR LINIITATION Monthly Average Daily Maximum Flow 0.108 MGD 15A NCAC 02B .0400 et seq., 02B .0500 et seq. Total Suspended Solids 30.0 mg/L NCG 510000 Consistency Trichloroethene (µg/L) Monitor and Report NCG 510000 Consistency; BPJ 1,2 Dichloroethene (µg/L) Monitor and Report NCG 510000 Consistency; BPJ Vinyl Chloride (µg/L) Monitor and Report NCG 510000 Consistency; BPJ pH Not less than 6.0 nor greater than 9.0 Standard Units 15 A NCAC 02B .0200 et seq.; NCG 510000 Consistency Chronic Toxicity Monitor and Report 15A NCAC 02B .0200 et seq. PROPOSED SCHEDULE OF ISSUANCE Draft Permit to Public Notice: Permit Scheduled to Issue: NPDES DIVISION CONTACT September 2, 2015 (est.) October 19, 2015 (est.) If you have any questions on any of the above information or on the attached permit, please contact Yang Song at (919) 807-6404, or by email at yang.song@ncdenr.gov. NAME: S DATE: `'D / q ( 2110 1 t- COMMENTS No comments were received from Asheville Regional Office — Water Quality Program. Fact Sheet Renewal -- NPDES NCO086088 Page 3 SPRY 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: Un ag., ged (,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 IF-9-SWI COUNTY CODE: Buncombe [0211 STATE CODE: NC - [371 DISTRICT CODE: NC 3r 71 HYDROLOGIC UNIT CODE: 06010105 ENR BASIN CODE: 04-03-02 DRAINAGE AREA: 5.98 mil Flow statistics as follows: AVERAGE FLOW: Estimated using J:.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/mP 6.0 ft3/s see note. B f0/s/mi2 0.94 ft3/s see note C ft3/s/mi2 2.1- ft3/s see note LC� ft3/slmi2 1.5 f0/s see note LC—j ft3/s/mi2 1.7 ft3/s see note C [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 Warier 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 Erika H. Mau Erika.Mau@skf.com Manager of Sustainability (267)436-6933 September 14, 2015 Ms. Wren Thedford NC DENR/DWR/NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RECEIVEDIDENRIDWR SEP 2 4 2015 Subject: Change in SKF USA Inc.'s (SKF's) Representative Water Quality NPDES Permit Number NCO086088 Permitting Sectior Girmes Site Remediation Buncombe County, North Carolina Dear Ms. Thedford: This letter is notification that, effective October 1, 2015, I will be replacing Mr. William C. McGlocklin as SKF's representative for the above referenced site. For your reference, my contact information is as follows: Ms. Erika H. Mau Manager of Sustainability SKF USA Inc. EHS Department 890 Forth Foot Road P.O. Box 352 Lansdale, PA 19446-0352 Telephone: 2 67 - 43 6 - 69 3 3 Email: Erika.Mau@)SKF.com Mr. Dan O. Madison, TRC Environmental Corporation (TRC), retains delegated authority for preparation of the 2015_NPDES.Pcrrrdt-renewal-application.-Mr. Madison - also retains signature authority for NPDES DMR forms for this site. Sincerely, L ic- *IL- Erika H. Mau Manager of Sustainability cc: Mr. Yang Song, NCDENR Mr. Dan Madison, TRC SKF USA Inc. 890 Forty Foot Road, P.O. Box 352, Lansdale, PA 19446 Tel 267 436 6893 Fax 267 436 6021 Web www.skfusa.com PACE 10A I THOPHIAY, SEPTEMBEB J. 2011 t ASHEVILLE CIIISEN-TIMES CareerBuildecoom I cam.com I HomeFnoer.com I CITIZEWTIMES.com I findnwve.atfzw-t'mes.cem TheCarolinaClassifieds CITIZEN TMrs.com /classifieds YAR; 1 D Sell Know everything your aboutyour baby before stuff. it arrives. D —rnanY1001a I $30 WD SALE ADS to Ae!p you find 3UH"5!m S. roar two-wnaew vnm xw onEre. dbo1 N LEGEND Pore Water Sampling Locations O Pore Water Sample Location Distribution of TCE \' June 2009 Concentration (ppm), dashed where inferred • '� a � �[ j- � Well Locations i "`- �` • �� !. +� Injection Well & Performance _ • -' - , - ; 1 - - - - - o ooze - <� ' • Monitoring Well Location _ ;' •0.01- - - - - - -,."� �, • • Monitoring Well Location • Recovery Well Location �I' •= Ll ® A Surface Water Sampling Location I i' NwNN6wWxEo1 , • / I ,� � _ : r� Il j a+«', • I, 0 200 400 I Il Feet FORMER GIRMES SITE (SKF USA INC) {1 I ASHEVILLE, NC PORE WATER SAMPLING LOCATIONS 1-7 ^, � FEBRUARY 2010 '1 y GECREY R'I: lE. FIGURE NO.: / 1 ;., - �..o n vti..�avm. ALp ,erzarzaw—e.voae �mumanl'.C9Wevnm FYeswrcGsalmiemplem.wur N.wtoyo (kli00nfltl) Lntivepe amewaoe mrp nM au,uv RMT 30 Patewood Drive Suite 300 Greenville, SC 29615 o 864.281.0030 PHONE 864.281.0288 FAx www.tresolutions.com April 28, 2015 Mr. Wren Thedford _ NC DENR / DWR / NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: NPDES Permit Renewal RECEIVEDIDENRIDkAIR APR 30 'tL'1` Water Quality Pennittinq Sec"" SKF USA, Inc. — Girmes Site Remediation NCO086088 Buncombe County Dear Mr. Thedford: TRC Environmental Corporation (TRC) 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 recovery system was taken off-line in November 2009. If site conditions change, there may be a need to put the recovery system back on-line. Therefore, SKF is requesting renewal of this NPDES permit (NC0086088). 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, were detected in any of the effluent samples collected in at least the last two years of operation. Operating History As groundwater recovery operations continued, the volume of water recovered declined to an average of approximately 42,000 gallons per day (gpd) in 2009, prior to taking the system off line. Also, the concentration of VOCs in the recovered groundwater decreased. When recovery operations began in March 1998, the influent trichloroethene (TCE) concentration was approximately 2,900 parts per billion (ppb), but declined to approximately 300 to 400 ppb. In an effort to increase VOC removal, in \ \NTAPA-GRNVILLE\GVL-VOL5\-\ WPGVL\PFI2\200000\2015\0002\L2000002015-00I.DOCX raa ' Mr. Wren Thedford NC DENR / DWR / NPDES Unit April 28, 2015 Page 2 fi r November 2002, the system began operation in a pulsed pumping mode, with the IM 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 r' 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 II concentration of TCE was 338 ppb. Additionally, the amount of TCE removed by the recovery system declined over the last 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 r-M recovery system has been off-line since mid -November 2009 and may remain off-line pending results of periodic monitoring at the site and Gashes Creek. rM+ 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 `A situated adjacent to Gashes Creek. Using flow data for Gashes Creek, TRC 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 while protecting the surface water standard was significantly higher than the VOC concentrations detected in rl" groundwater near the creek. Periodic monitoring of select monitoring wells near Gashes Creek, surface water and pore water along Gashes Creek is conducted to evaluate any possible changes in the impact of the groundwater on Gashes Creek. If MI 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 hence the need for a renewed NPDES permit. Other Requirements Rgi Per the instructions for NPDES renewal packages, we are including the following additional information: ,l ■ 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), the last four sampling events prior to taking the system off line. Please note that these months include results for VOCs, TSS, and chronic IM toxicity. M4 11 NTAPA-GRNVILLE \ GV L-VOL51-1 WPGVL 1 PJ12120000012015100021 L2000002015-001. DOCX rm Mr. Wren Thedford NC DENR / DWR / NPDES Unit April28, 2015 Page 3 Since this facility does not generate sludge or other treatment residue, a sludge VW management plan has not been developed for the SKF — Girmes Site. A signed statement regarding sludge management is presented in Attachment 4. Fan SKF has designated Mr. Dan O. Madison, TRC as their Authorized Representative to prepare this permit renewal package. Mr. Madison also retains delegated signatory authority for NPDES DMR forms for this site. Documentation of this authorization is FR' presented in Attachment 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 the permit renewal with you. If there are any questions, please call me at (864) 234- FM 9329/dmadison@trcsolutions.com or Mr. William McGlocklin at SKF at (267) 436- 6930/William.c.mcglocklin@sfk.com. FIQI Sincerely, TR vironmental Corporation Fa, Dan O. Madison, PG Project Manager Attachments W, cc: Mr. William McGlocklin, SIG PSI faq Sol am FM \1N"A4RNVMLEIGVL-VOL51-1WPGVL\P)72120MW\2015100021L2000D02015-0O1.DOCX +�a rse�1 fm r� 1� Z� rA14 L� AM fAq Table 1 Summary of Current NPDES Permit Limitations PAIL49 ETM LI�i1TS FII QUETtCY Flow 0.108 mgd Continuous TSS 30 mg/L Monthly TCE MRO) Quarterly 1,2-Dichloroethene (DCE) MR Quarterly Vinyl chloride (VC) MR Quarterly [Toxicity (Chronic Value) ChV at 15% Quarterly (1) Elevated detection limit. Table 2 Summary of Maximum Observed Values for 2009 PARIIMETIER JANUARY Af RIL JULY OCTCHER 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 NDO) NDO) NDO) NDO) Toxicity (Chronic Value) ChV>60% ChV>60% ChV>60% ChV>60% Mn 0) Volatile halocarbons by Method 601 were not detected in the effluent at the detection limit of 1 Ng/L (2 Ng/L for chloromethane and methylene chloride) �' f-M-t 7 X=) \ \NTAPA-GRNVILLE1GVL-VOL51-1WPGVL\Pjr2\20WW\2015100021L2000002015-001.DOCX r r r 1 r 1 w/. � t ._ � �� i •'� arse 1. .5'' ..� I -�. - __ NV >0p NI 41 136 Fl 0!^9rijC i Well:- - ANNANOA i ice• :20 Q• . Villa° 1 qy�. _ SITE LOCATION 14 N I \� I -- I OUTFACE 001 / \� L }.f7 ill C i r � `�/��, , ` • �[l hOaklev��� � °v raft z o Pil f!O 1� © , I Zr 1'': -. �• • I .' NORTH'C it 1 ` State Grid: Asheville/Oteen Latitude: 35°34'09"N E85E/E95W Longitude: 82°29'59"W ITE LOCATION Receiving Stream: Gashes Creek Drainage Basin: French Broad Stream Class: C Sub -Basin: 04-003-02 41 4 BASE MAP FROM USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE SERIES. \_ / ` 1 * m 2.000' 0 z000 4,000 N 1:24,000 �T TRC SKF USA, INC. - GRIMES SITE DRA,VN BY AMF ASHEVILLE, SOUTH CAROLINA APPROVED BY: NK PROJECT NO: =W.a115 Patewooe Plaza One, Suite 300 Greenville. SC 29615 SITE LOCATION MAP FILE N0, 816Lm.mxE Phone: 864.281.0030 DATE. APRLIDIS Sludge Management 'ut, SKF USA, Inc. — Girmes Site Remediation, NPDES NCO086088 Buncombe County M1 The remediation system does not generate sludge or solids. It only consists of an air stripper, flume, and F' effluent diffuser. Since the facility does not generate sludge or other treatment residue, a sludge management plan has not been developed for the SKF USA Inc. — Girmes Site. Min 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. ft, C. William McGlocklin Director of Environmental Affairs fop Name and Title Title n G •- .Z / Jr Signature Date 126i� ftn M MAI Pq