NC0088838_Staff Report_20231102

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ® NPDES Unit ❑ Non -Discharge Unit Application No.: NCO088838
Attn: (Joe Corporon in Raleigh) Facility name: Radiator Specialty Company
From: (Edward Watson)
Mooresville Regional Office
Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: November 1, 2023
b. Site visit conducted by: Edward Watson
c. Inspection report attached. ® Yes or ❑ No
d. Person contacted: Stuart Kerkhoff and their contact information: (704) 904 - 0094 ext.
e. Driving directions:
2. Discharge Point(s):001
Latitude: 3 5.066720 Longitude:-80.653915
3. Receiving stream or affected surface waters:
Classification: C
River Basin and Subbasin No.03-07-12 (UT to South Fork Crooked Creek)
Describe receiving stream features and pertinent downstream uses: conveyance to S. Fork Crooked Creek
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Stuart Kerkhoff Certificate #:PC-1/993806 Backup ORC: Richard Harmon Certificate #:PC-1/988627
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities:
Current permitted flow:0.090 MGD (the system has not reported flow for about 3.5 years).
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
FORM: WQROSSR 04-14 Pagel of 3

3. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
4. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program:
5. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
6. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
7. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
8. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
9. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
10. Are there any permit changes needed to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
11. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
12. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
13. Possible toxic impacts to surface waters: System restart may have elevated contaminants that may cause the
system to initially fail Whole Effluent Toxicity.
14. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 3

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office.
❑ Issue upon receipt of needed additional information.
® Issue
❑ Deny (Please state reasons: )
Signature of report preparer: Edward Watson Date:11/2/23
Docu Signed by:
EF161FB69A2D84A3
4.1 w H P;,Uf4
4. Signature of regional supervisor: ... Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Under Changes for Renewal: Please correct spelling for Vinyl Chloride.
11/2/2023
1. The facility experienced a Process Unit Failure in April 2020. During the time of the Process Unit Failure, the
property was in the process of ownership change. The regional office observed the failure has not been corrected
and the system is not in service. This facility has not reported flow under this permit for about 3.5 years. MRO
requests that MRO be given notice when/if the system is placed back into service.
2. During the site visit, the system control room was viewed. There is no indication that the control system would
not be operational once the piping repairs have been completed and treatment media has been replaced.
3. The permittee may wish to present a suggestion for alternative treatment media if that media is more cost effective
and can effectively remediate the constituents of concern at the site.
4. The GW monitoring data indicates elevated constituents the reporting above DWM permit limits or 2L standards
in February 2023 sample analysis.
1, 1, Dichloroethane
Trichloroethene (Perc)
Tetrachloroethene
1,4 Dioxane
Phenol
5. MRO recommends the treatment system be repaired and placed back into service.
6. GW monitoring frequency is being monitored under NCD091245969 by DWM HWS.
7. The permittee requests further clarification of the A. (3.) Permit reopener for 1,4, Dioxane.
8. The outfall was not visited during the site visit. However, there is access to the outfall.
9. Please place the renewal application on Laserfiche for the RO to be able to have access.
FORM: WQROSSR 04-14 Page 3 of 3