NC0080853_Permit issuance_20190102

ROYCOOPER
Covt9'nor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Nokia of America Corporation
Attn: Gary M. Fisher, Owner
600 Mountain Avenue
Murray Hill, New Jersey 07974
Dear Mr. Fisher:
NORTH CAROLINA
EnvironmentalQuaAty
January 2, 2019
Subject: Final NPDES Permit Renewal
Permit NCO080853
Salem Business Park Remediation Site
Forsyth County
Grade I PCWPCS
SIC Code 3661
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached 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 October 15, 2007
(or as subsequently amended).
Please note that the receiving stream is listed as impaired for benthos on the North Carolina 2016
303(d) Impaired Waters List. Addressing impaired waters is a high priority with the Division, and
instream data will continue to be evaluated. If there is noncompliance with permitted effluent
limits and stream impairment can be attributed to your facility, then mitigative measures may be
required.
In response to comments received from AECOM on behalf of Nokia of America Corporation
on November 28, 2018, the following changes were made to the draft permit sent to you on
October 31, 2018:
• A component description revision was made which adds language to indicate that the
granular activated carbon (GAC) is used as a back-up at the facility.
• The description of the receiving waters has been adjusted from "Salem Creek" to
"unnamed tributary to Salem Creek."
• 1,4-Dioxane monitoring — A typographical error was made in the description of the 1,4-
dioxane monitoring requirement in the draft cover letter, citing annual monitoring instead
of quarterly monitoring. The language has been revised to reflect the permit requirement:
As 1,4-dioxane is considered a parameter of concern and the facility is near Water Supply
waters, quarterly monitoring for 1,4-dioxane and Special Condition A.(4.) 1,4-Dioxane
Monitoring and Limits Reopener have been added to the permit.
DEQ
North Carolina Department of Environmental Quality I Oh'Islonof Water Resources
512 North Salisbury Street 11617Mail Servke Center I Ralelgh. North Carolina 27699-1617
919.707.3601

The fmal permit maintains the following significant changes identified in the letter sent on
October 31, 2018:
• Based on the reasonable potential analysis (RPA) results, quarterly monitoring for
trichloroethene has been removed from the permit.
• Based on the reasonable potential analysis (RPA) results, quarterly monitoring has been
changed to monthly monitoring for tetrachloroethene (PCE), the daily maximum limit for
PCE has been removed, and a monthly average limit of 6.12 ug/L has been added to the
permit.
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The requirement to continue 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. (5.)].
• Parameter characteristic codes have been added to the Effluent Limitations and Monitoring
Requirements [ See A. (1.)].
• Regulatory citations have been added to the permit.
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 any questions concerning this permit, please contact Nick Coco at [phone] or
via email at [e-mail].
Sincerely,
rDivision
��'Culpepper, Director
of Water Resources, NCDEQ
Hardcopy: NPDES Files
Central Files
Ecopy: DWR/Winston Salem Regional Office/Water Quality/Sherri Knight
DWR/Aquatic Toxicology Branch/Susan Meadows
AECOM/Project Manager/Erin Stewart
Page 2 of 2

Permit NCO080853
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 provisions 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,
Nokia of America Corporation
is hereby authorized to discharge wastewater from a facility located at
3370 Lexington Road
Winston-Salem
Forsyth County
to receiving waters designated as unnamed tributary to Salem Creek in the Yadkin -Pee -Dee River
Basin in accordance with the discharge limitations, monitoring requirements, and other conditions
,set forth in Parts 1, II,.III, and IV hereof.
This permit shall become effective .................................. February 1, 2019.
This permit and the authorization to discharge shall expire at midnight on June 30, 2023.
Signed this day ............... January 2, 2018.
,4or,, *da Culpepper, Director
66ivision of Water Resources
By Authority of the Environmental Management Commission

Permit NCO080853
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.
Nokia of America Corporation is hereby authorized to:
1. Continue to operate and maintain an existing 0.302 MGD groundwater remediation
treatment system consisting of the following components:
• Extraction wells
• Feed -water equalization
• Bag filtration
• Low profile air stripper
• Granular Activated Carbon (as back-up)
The facility is located at the Salem Business Park remediation site (3370 Lexington Road,
Winston-Salem) in Forsyth County.
2. Discharge from said treatment works at the location specified on the attached map into
Salem Creek, currently a class C stream in the Yadkin -Pee Dee River Basin, at the location
specified on the attached map.
Page 2 of 8

Permit NCO080853
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (0.302 MGD)
[15A NCAC 02B .0400 et seq., 15A NCAC 02B .0500 et seq.] Grade I Physical/Chemical
Water Pollution Control System [15A NCAC 08G .0306]
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee
as specified below:
PARAMETER CHARACTERISTICS
EFFLUENT LIMITS
MONITORING REQUIREMENTS
Parameter Code
Monthly
Daily
Measurement
Sample
Sample
Average
Maximum
. Frequency
Type
Location
Flow, MGD 50050
0.302
Continuous
Recorder
Influent or
Effluent
Total Suspended Solids,
C0530
mg/L
30.0
Monthly
Grab
Effluent
Oil and Grease', mg/L 00556
Monthly
Grab
Effluent
Tetrachloroethene, µg/Iz 78389
6.12
Monthly
Grab
Effluent
1,4-Dioxane3, µg/I 82388
Quarterly"
Grab
Effluent
Chronic Toxicity' TGP38
Quarterly
Grab
Effluent
Footnotes:
1. The grab sample for oil and grease should be skimmed from the surface in a quiescent zone, such as a holding
tank, if possible.
2. The Tetrachloroethene limit becomes effective [within two (2) years of the effective date of the permit]. The
Permittee shall follow the compliance schedule detailed in Section A. (2.).
3. Monitoring for 1,4-dioxane shall be conducted using EPA Method 624.1.
4. All quarterly monitoring listed above shall coincide with the chronic toxicity monitoring.
5. Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September, and December (see A. (3)).
There shall be no discharge of floating solids or foam visible in other than trace amounts.
Page 3 of 8

r
Permit NCO080853
A. (2.) SCHEDULE OF COMPLIANCE FOR TETRACKOROETHENE LIMITATION.
[NCGS 143-215.1(b)]
1. Within six (6) months from the effective day of the permit, the Permittee shall submit to the
Division of Water Resources a Corrective Action Plan summarizing the strategy or actions to
be taken to achieve compliance with the tetrachloroethene limitation listed in Section A. (1.),
which includes specific dates for completion or implementation of each action.
2. Within one (1) year from the effective date of the permit, the Permittee shall submit a report
to the Division summarizing actions taken during the previous six (6) months to achieve
compliance with the tetrachloroethene limitation. The actions shall be in accordance with
the Corrective Action Plan submitted and approved by DWR.
3. The Permittee shall achieve compliance with the tetrachloroethene limitation specified in
Section A. (1.) within two (2) years of the effective date of this permit.
Upon approval of the Corrective Action Plan by the Division, the report and actions become an
enforceable part of this permit. Any modifications to the schedule shall be requested to the
Division at least ninety (90) days before the deadline. Modifications to the schedule in excess of
four (4) months will be subject to public notice.
Corrective Action Plan and Reports shall include the owner's name, NPDES permit number and
Permittee contact person, and shall be submitted to:
(1) NCDEQ/ Division of Water Resources (2) NCDEQ/ Division of Water Resources
NPDES Permitting Winston-Salem Regional Office
1617 Mail Service Center 450 West Hanes Mill Road, Suite 300
Raleigh, NC 27699-1617 Winston-Salem, NC 27105
A. (3.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B.0200]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration. of 90%.
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 II Chronic Whole Effluent
Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. The tests will be
performed during the months of March, June, September and December. 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.
Page 4 of 8

Permit NC0080853
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 -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 TGP36 for the pass/fail results and THP313 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
1621 Mail Service Center
Raleigh, NC 27699-1621
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.
Page 5 of 8

V
Permit NCO080853
A. (4.)1,4-DIOXANE MONITORING AND LIMITS REOPENER
[G.S.143-215.1]
Pursuant to N.C. General Statutes Section 143-215.1 and the implementing rules found in the
North Carolina Administrative Code at 15A NCAC 2H.0112 (b) (1) and 2H.0114 (a) and Part II
sections B-12 and B-13 of this permit, the Director of DWR may reopen this permit to require
additional monitoring or effluent limitations for the discharge based on the sample results
required by Section A. (1.).
A. (5.) ELECTRONIC REPORTING OF MONITORING REPORTS
[G.S.143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
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.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)l
Upon reactivation of the facility, the permittee shall report 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/ Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
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,
1.11 21 3) or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the mailing address above. See "How to Request a Waiver from Electronic
Reporting" section below.
Page 6 of 8

Permit NCO080853
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.
Starting on December 21, 2020, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(I)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and
use the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federaIregister.gov/documents/2015/10/22/2015-24954/nationa I-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers 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 submitting monitoring data and reports. The
duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such
time, monitoring data and reports shall be submitted electronically to the Division unless the
permittee re -applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the
Division for the period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found
on the following web page:
http://deg.nc.gov/about/divisions/water-resources/edmr
Page 7 of 8

19
Permit NCO080853
4. Sienatory Requirements (Supplements Section S. (11.) (b) and Supersedes Section B. (11.) (d))
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(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://deg.nc.goy/about/divisions/water-resources/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 OP CERTIFICATION
WILL BE ACCEPTED:
"i 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 qualified personnel
properly 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."
S. Records Retention [Supplements Section D. (6.)l
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].
Page 8 of 8

Fact Sheet
NPDES Permit No. NCO080853
Permit Writer/Email Contact Nick Cow, [e-mail]:
Date: July 13, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 21 species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Nokia of America Corporation/ Salem Business Park Remediation Site
Applicant Address:
600 Mountain Avenue, Murray Hill, NJ 07974
Facility Address:
3370 Lexington Road, Winston-Salem, NC 27107
Permitted Flow:
0.302 MGD
Facility Type/Waste:
MINOR Industrial; 100% industrial
Facility Class:
Grade I Physical/Chemical Water Pollution Control System (PCWPCS)
Treatment Units:
Extraction wells, feed -water equalization, bag filtration, low profile air
stripper, granular activated carbon (as backup)
Pretreatment Program (Y/N)
N
County:
Forsyth
Region
Winston-Salem
Briefly describe the proposed permitting action and facility background: Nokia of America Corporation
has applied for an NPDES permit renewal at 0.302 MGD for the Salem Business Park Remediation Site.
The facility has a primary Outfall 001. The DWM incident number for this facility is NCD003213907.
Page 1 of 8

2. Receiving Waterbody Information:
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001 — UT to Salem Creek
Stream Segment:
12-94-12-(4)
Stream Classification:
C
Drainage Area (mi2):
0.4
Summer 7Q10 (cfs)
0.05
Winter 7Q10 (cfs):
0.13
30Q2 (cfs):
0.14
Average Flow (cfs):
0.4
IWC (% effluent):
90%
303(d) listed/parameter:
ListedBenthos
Subject to TMDL/parameter:
No
Subbasin/HUC:
03-07-04; 03040101
USGS Topo Quad:
C18SW
3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of January 2014 through July 2018.
Table 1. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit
Limit
Flow
MGD
0.07
0.09
0.001
MA 0.302
TSS
mg/l
3.58
5
<2
DM 30.0
Oil and Grease
mg/l
5.22
15
5
Trichloroethene
µg/l
0.82
1.5
< 0.5
Tetrachloroethene
µg/l
2.83
6.8
< 0.5
DM 17.0
MA -Monthly Average, WA -Weekly Average, DM -Daily Maximum, DA=Daily Average
Page 2 of 8

4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions
when model results for instream DO are within I mg/l of instream standard at full permitted flow; 2) to
verify model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other
instream concerns. Instream monitoring may be conducted by the Permittee, and there are also
Monitoring Coalitions established in several basins that conduct instream sampling for the Permittee (in
which case instream monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this
permit action: Instream monitoring is not required in the permit.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): NO
Name of Monitoring Coalition: NA
5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported no limit
violations from June 2013 to June 2018.
Summarize the compliance record with aquatic toxicity test limits and any second species test results
(past 5 years): The facility passed 18 of 18 quarterly chronic toxicity tests from March 2014 to June
2018.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in February 2016 reported that the facility was in compliance.
6. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and MixingZones
ones
In accordance with 15A NCAC 213.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HID.
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): N/A
Oxygen -Consuming Waste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
(e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: N/A
Page 3 of 8

Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria,
utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 ug/1) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 ug/1 are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: N/A
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of 1/z detection limit for "less than" values; and 4) streamflows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDESImplementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between March 2014
and March 2018. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable
water quality standards/criteria: Tetrachloroethene
• Monitoring Only. The following parameters will receive a monitor -only requirement since they
did not demonstrate reasonable potential to exceed applicable water quality standards/criteria,
but the maximum predicted concentration was >50% of the allowable concentration: NA
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality
standards/criteria and the maximum predicted concentration was <50% of the allowable
concentration: Trichloroethene
• POTW Effluent Pollutant Scan Review: Three effluent pollutant scans were evaluated for
additional pollutants of concern.
o The following parameter(s) will receive a water quality -based effluent limit (WQBEL)
with monitoring, since as part of a limited data set, two samples exceeded the allowable
discharge concentration: NA
o The following parameter(s) will receive a monitor -only requirement, since as part of a
limited data set, one sample exceeded the allowable discharge concentration: NA
Page 4 of 8

If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicitv Testine Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several
exceptions. The State has received prior EPA approval to use an Alternative WET Test Procedure in
NPDES permits, using single concentration screening tests, with multiple dilution follow-up upon a test
failure.
Describe proposed toxicity test requirement: This is a Minor Industrial facility, and a chronic WET limit
at 90% effluent will continue on a quarterly frequency.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply
with EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury *minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (>1 ng/1) will
receive an MMP requirement. Industrials are evaluated on a case -by -case basis, depending if mercury is a
pollutant of concern. Effluent limits may also be added if annual average effluent concentrations exceed
the WQBEL value (based on the NC WQS of 12 ng(1) and/or if any individual value exceeds a TBEL
value of 47 ng/l.
Describe proposed permit actions based on mercury evaluation: The facility is not known to discharge
mercury.
Other TMDL/Nutrient Management Strateev Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation
within this permit: N/A
Other WOBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: Per a 2005 email
exchange between the Permittee and the Division, there is reason to believe 1,4-Dioxane is in the
groundwater treated at the facility. The value discussed in 2005 is far below the NC protective value of 80
ug/L for class C waters. However, the facility is approximately 13 miles from the Yadkin River, which is
designated as WS-IV waters. Water supply waters have an NC protective value of 0.35 ug/L for 1,4-
Dioxane. The attached preliminary calculations indicate, based on the 2005 value of 8.2 ug/L, 1,4-
Dioxane presence is not likely to negatively affect downstream waters. However, to better understand the
level of concern for this contaminant in the facility's discharge, quarterly monitoring of 1,4-Dioxane
coinciding with chronic toxicity monitoring has been added to the permit. Monitoring for 1,4-Dioxane
shall be conducted using EPA Method 624.1. During the next renewal, the parameter may be removed if
no reasonable potential to exceed water quality standards is shown.
Page 5 of 8

If applicable, describe any special actions (HQW or OR99 this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with
15A NCAC2H.0107(c)(2)(B), 40CFR 122.47, and EPA May 2007 Memo: A 2-year compliance schedule
is proposed for meeting the new tetrachloroethene effluent limit. Annual milestones are included for this
Special Condition.
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B.0226for this permit renewal: NA
7. Technology -Based Effluent Limitations (TBELs)
Industrials (if not awlicable, delete and skip to next Section)
Describe what this facilityproduces: The facility is a groundwater remediation facility.
List the federal effluent limitations guideline (ELG) for this facility: The facility is not subject to any
federal ELGs.
If the ELG is based on production or f ow, document how the average production/f ow value was
calculated. NA
For ELG limits, document the calculations used to develop TBEL limits: NA
If any limits are based on best professional judgement (BPJ), describe development: NA
Document any TBELs that are more stringent than WQBELs: NA
Document any TBELs that are less stringent than previous permit: NA
7. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 213.0201. Each applicant for a new/expanding NPDES permit
must document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all
cases, existing instream water uses and the level of water quality necessary to protect the existing use is
maintained and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis (EAA) and any water quality modeling results: NA
8. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibackslidingprovisions are not violated: NA
Page 6 of 8

9. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following
regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2)
NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance,
Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best
Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not
considered effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -
backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.
10. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective
December 21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports
(DMRs) electronically. Effective December 21, 2020, NPDES regulated facilities will be required to
submit additional NPDES reports electronically. This permit contains the requirements for electronic
reporting, consistent with Federal requirements.
11.Summary of Proposed Permitting Actions:
Table 2. Current Permit Conditions and Proposed Changes 0.302 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flow
MA 0.302 MGD
No change
15A NCAC 213.0505
TSS
DM 30 mg/l
No change
WQBEL 15A NCAC 02B WQS
Oil and Grease
Monthly monitoring
No change
15A NCAC 02B WQS
Trichloroethene
Quarterly monitoring
No requirement
WQBEL 15A NCAC 02B WQS;
EPA NRWQC(M 2006; Based on
RPA results
Tetrachloroethene
DM 17 ug.L
MA 6.12 ug/L,
WQBEL 15A NCAC 02B WQS;
Quarterly monitoring
Monthly monitoring,
EPA NRWQC(MD 2006; Based on
Compliance Schedule
RPA results
Special Condition
1,4-Dioxane
No requirement
Quarterly monitoring
NC Protective Value; Considered a
parameter of concern;
Facility is near WS waters
Toxicity Test
Chronic limit, 90%
No change
WQBEL. No toxics in toxic
effluent
amounts. 15A NCAC 2B.0200 and
15A NCAC 213.0500
Electronic
No requirement
Add Electronic
In accordance with EPA Electronic
Reporting
Reporting Special
Reporting Rule 2015.
Condition
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
Page 7 of 8

12. Public Notice Schedule:
Permit to Public Notice: 10/31/2018
Per 15A NCAC 211.0109 & .0111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the
Director within the 30 days comment period indicating the interest of the party filing such request and the
reasons why a hearing is wan -anted.
13. Fact Sheet Addendum (if applicable):
The following comments were received from AECOM on behalf of Nokia of America Corporation on
November 28, 2019:
Comment: "Alcatel Lucent USA Inc." and "Alcatel -Lucent' should be replaced by "Nokia of America
Corporation" throughout the permit due to a corporate merger that occurred on January 1, 2018.
Response: The final permit has been altered to reflect the ownership change.
Comment: The list of treatment system components should be updated to remove Granular Activated
Carbon (GAC).
Response: As the facility employs its GAC as a back-up, the component will remain listed. Indication of
the component being a back-up has been added to the description.
Comment: No schedule is provided for annual effluent monitoring of 1,4-dioxane, which is a new
monitoring requirement. AECOM proposes to conduct this monitoring in March of each year.
Response: Monitoring for 1,4-dioxane shall be conducted quarterly. Reference to annual monitoring in
the draft cover letter was a typographical error and should be disregarded.
Comment: As the 61 tetrachloroethene (PCE) data point in the RPA is a pH value, please remove it for
the final RPA calculation. The result does not affect the outcome of RPA analysis.
Response: The 61 data point has been omitted in the final calculation.
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES
If Yes, list changes and their basis below:
• A component description revision was made which adds language to indicate that the granular
activated carbon (GAC) is used as a back-up at the facility.
• As the facility discharges to an unnamed tributary to Salem Creek, the description of the
receiving waters has been adjusted from "Salem Creek" to `unnamed tributary to Salem Creek."
14. Fact Sheet Attachments (if applicable):
• RPA Spreadsheet Summary
• Dissolved Metals Implementation/Freshwater or Saltwater
• Comments from AECOM
Page 8 of 8

AdSCOM Imagined.
Delivered.
November 28, 2018
Mr. Nick Coco
Water Quality Permitting
North Carolina Department of Environmental Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Comments on the Draft NPDES Permit Renewal
Permit NCO080853
Salem Business Park Remediation Site
Nokia of America Corporation (Former Alcatel -Lucent Facility)
Winston-Salem, Forsyth County, North Carolina
Dear Mr. Coco:
AECOM
1600 Perimeter Park, Suite 400
Morrisville, NC 27560
T 919.461.1100
F 919.461.1415
aecom.com
On behalf of Nokia of America Corporation (Nokia), AECOM prepared this letter to summarize Nokia's
comments on the draft National Pollutant Discharge Elimination System (NPDES) permit issued on
October 31, 2018 for the groundwater treatment system (GWTS) operating at the site.
Comment #1— Permit Cover Sheet (page 1 of 8)
"Alcatel -Lucent USA Inc." and "Alcatel -Lucent" should be replaced with "Nokia of America Corporation"
throughout the permit due to a corporate merger that occurred on January 1, 2018.
Comment #2 — Supplement to Permit Cover Sheet (page 2 of 8)
The list of treatment system components should be updated to remove Granular Activated Carbon (GAC).
In April 2017, AECOM discovered a leak in the bottom of the GAC tank and shut -down the GWTS.
AECOM notified the North Carolina Division of Water Resources (DWR) of the problerh in a letter dated
May 4, 2017. The letter stated that Nokia was considering eliminating the GAC since the air stripper is
capable of treating water to below permit limits and the GAC did not provide further significant reductions
of PCE. The letter also inquired about whether a permit modification would be required to eliminate the
GAC. AECOM was advised by DWR that no permit modification was required. The GWTS resumed
operating in May 2017 without the GAC unit.
A new GAC unit was installed in August 2017, which currently serves as a back-up unit that can be used
when higher than normal VOC concentrations are anticipated.
Comment #3 — Condition A. (1.) — Annual Monitoring Requirement for 1,4-Dioxane (page 3 of 8)
No schedule is provided for annual effluent monitoring of 1,4-dioxane, which is a new monitoring
requirement. AECOM proposes to conduct this monitoring in March of each year.
Comment #4 — Reasonable Potential Analysis Calculations
The 'data' sheet in the Reasonable Potential Analysis (RPA) calculation workbook contains a data entry

AECOM
error. Datapoint #6 for tetrachloroethene (PCE), dated April 27, 2015, is a pH value. PCE was not
analyzed in April 2015, so this data point should be removed from the data set. This results in a lower
maximum predicted effluent concentration, but does not change the calculated PCE discharge limit
because the maximum predicted effluent concentration (7.5 micrograms per liter [µg/L]) is still greater than
the allowable effluent concentration (6.12 µg/L).
If you have any questions or need additional information, please contact Erin Stewart at [phone].
Yours sincerely,
Erin Stewart, PG
Project Manager
Attachments
cc: Gary Fisher — Nokia of America Corporation
John Moran
Environmental Engineer
Comments on the Draft NPDES Permit Renewal
Permit NCO080853 2/2

Salem Business Park Remediation Site NCO080853
1,4-Dioxane Calculations
Givens
Permitted Flow=
0.302
MGD
Permitted Flow =
0.468
cfs
Facility Average Flow (QAf) =
0.4
cfs
Facility Average Flow (QAf) =
0.26
MGD
Facility Sample
8.2
ug/L
WS Standard =
0.35
ug/L
Receiving Stream Drainage Area (DA) =
2220
sq mi
USGS Site 02116500 Drainage Area (DAs) =
2280
sq mi
USGS Site 02116500 Average Flow (QAs) =
2993
cfs
Solved
Receiving Stream Average Flow (QA) =
2914
cfs
Receiving Stream Average Flow (QA) =
1880
MGD
Water Supply Load =
5.49
Ib/d
Allowable Effluent Concentration =
2180
ug/L
Formulas
Yield = QA/DA
Load = Concentration * Permitted Flow * 8.34
Concentration at WS = Load/(8.34*QA at WS)*1000
Calculations
Yield = QAs/DAs = 2993 cfs/2280 sq mi = 1.31 cfs/sq mi
Receiving Stream Average Flow = QA = Yield * DA = 1.31 cfs/sq mi * 2220 sq mi = 2914 cfs
WS Load = 0.00035 mg/L * 1880 MGD * 8.34 = 5.49 Ib/d
Allowable Effluent Concentration = 5.49 Ib/d /(8.34 * 0.302 MGD) * 1000 = 2.18 mg/L = 2180 ug/L
Note: As the allowable concentration is so high, the minimum limit on instream water quality is based on the NC 02B
Standard of 80 ug/L. The allowable concentration based on the NC 02B Standards = (80ug/L)/IWC@QA =148.4 ug/L

Coco, Nick A
From: Weaver, John <[e-mail]>
Sent: V Tuesday, November 27, 2018 10:28 AM
To: 0 r" N [e-mail]
Cc: V 7' Coco, Nick A; John C Weaver
Subject: C `JT Nr'% Response from USGS concerning... Re: [EXTERNAL] streamflow statistics
Ms. Stewart,
In response to your inquiry about the low -flow characteristics (7Q10, 30Q2, W7Q10, 7Q2) for an unnamed tributary to
Salem Creek at Winston Salem in central Forsyth County, the following information is provided:
A check of the low -flow files here at the USGS South Atlantic Water Science Center (Raleigh office) does not indicate previous low -
flow determinations for the ]at/long coordinates (36.055208 //-80.230861) provided via your email dated November 14,
2018. However, the low -flow files do indicate previous low -flow determinations at nearby locations within this Salem Creek tributary
basin, based on transfer of flow characteristics from nearby index sites.
No USGS discharge records are known to exist for the point of interest
In the absence of site -specific discharge records sufficient for a low -flow analysis, estimates of low -flow characteristics at ungaged locations
are determined by assessing a range in the low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby sites where
estimates have previously been determined.
A basin delineation completed using the online USGS StreamStats application for North Carolina
(http://water.usgs.gov/osw/streamstats/north carolina.html) indicates the drainage area for the point of interest (36.05519, -
80.23081 NAD83) is about 0.05 sgmi.
For streams in Forsyth County, low -flow characteristics published by the USGS are provided in two reports
(1) The first is a statewide report completed in the early 1990's. It is USGS Water -Supply Paper 2403, "Low -flow
characteristics of streams in North Carolina" (Giese and Mason, 1993). An online version of the report is available
at http://pubs.usgs.gov/wsp/2403/report.Ddf. The report provides the low -flow characteristics (based on data through
1988) via regional relations and at -site values for sites with drainage basins between 1 and 400 sgmi and not considered
or known to be affected by regulation and/or diversions.
(2) The second is a statewide report published in March 2015. It is USGS Scientific Investigations Report 2015-5001,
"Low -flow characteristics and flow -duration statistics for selected USGS continuous -record streamgaging stations in
North Carolina through 2012" (Weaver, 2015). The report is available online
at http://Pubs.usgs.gov/sir/2015/5001/. The report provides updated low -flow characteristics and flow -duration
statistics for 266 active (as of 2012 water year) and discontinued streamgages across the state where a minimum
of 10 climatic years discharge records were available for flow analyses.
Inspection of the two reports indicates the presence of eight nearby selected USGS partial -record sites (6) and
continuous -record streamgages (2) in general vicinity of the point of interest where low -flow characteristics were
published. Among these 8 sites, the low -flow discharge yields for the indicated flow statistics are as follows:
Annual 7Q10 low -flow yields ==> from 0.08 to 0.28 cfsm (average about 0.15 cfsm, median about 0.14 cfsm)

Annual 30Q2 low -flow yields =_> from 0.2 to 0.51 cfsm (both average and median about 0.33 cfsm)
Winter 7Q30 low -flow yields =_> from 0.16 to 0.38 cfsm (average about 0.27 cfsm, median about 0.28 cfsm)
Annual 7Q2 low -flow yields ==> from 0.16 to 0.42 cfsm (both average and median about 0.26 cfsm)
Average annual discharge yields ==> from 0.9 to 1.24 cfsm (average about 1.03 cfsm, median about 1 cfsm)
Application of the above range in yields to the drainage area (0.05 sgmi) for the point of interest results in the following
estimated low -flow discharges:
Annual 7Q10 discharges =_> from 0 to 0.01 cfs (both average and median about 0.01 cfs, rounded down to zero flow)
Annual 30Q2 discharges =_> from 0.01 to about 0.03 cfs (both average and median about 0.02 cfs)
Winter 7Q10 discharges =_> from about 0.01 to 0.02 cfs (both average and median about 0.01 cfs, rounded down to
zero flow)
Annual 7Q2 discharges ==> from about 0.01 to 0.02 cfs (both average and median about 0.01 cfs, rounded down to zero
flow)
Average annual discharge ==> from 0.05 to 0.06 cfs (both average and median about 0.05 cfs)
Notes:
(1) The extremely low magnitudes of the above estimated low -flow characteristics reflect the very small drainage area
for the point of interest.
(2) The USGS does not provide estimates of the IQ10 discharge within the scope of standard responses to low -flow
requests. However, because the estimated 7Q10 discharge is zero flow, the estimated 1Q10 discharge mathematically
defaults to zero flow.
(3) Please note that because your site is located in the vicinity of downtown Winston-Salem, it should be acknowledged
the effects of development on low -flow characteristics in urban basins have not been formally studied by the USGS for
North Carolina. There has been discussion within the hydrologic community that development may reduce low -flow
characteristics because increases in impervious areas reduce the available surface area where infiltration of runoff can
occur, thereby reducing the available base flow to streams during extended dry periods.
(4) Please note that I have cc:ed Mr. Nick Coco, N.C. Department of Environmental Quality, whom you identified in
your email request dated November 12, 2018
Please understand the information provided in this message is based on a preliminary assessment and considered
provisional, subject to revision pending further analyses.
Hope this information is helpful.
Thank you.
Curtis Weaver
3. Curtis Weaver, Hydrologist, PE Email: icweaver0usos.cov
USGS South Atlantic Water Science Center Online: httos:llwww.usas.00v/centerslsa-water
North Carolina - South Carolina - Georgia
3916 Sunset Ridge Road
Raleigh, NC 27607
Phone: [phone] // Fax: [phone]

On Ivion, Nov 12, 2018 at 8:29 AM Stewart, Erin <[e-mail]> wrote:
Curtis,
I was given your contact info by Nick Coco in the NCDEQ NPDES Permitting Unit. I manage a facility that is currently
undergoing a NPDES permit renewal. The streamflow statistics that were used to calculate the permit limits have been
the same since at least the 1999 permit. 1 was wondering if there are more recent data available?
The stream is an unnamed tributary to Salem Creek in Forsyth County, Winston-Salem. Site address is 3300 Old
Lexington Road. Specifically I am interested in the 7Q10s, 70,10w, 30Q2, QA, and 1Q10s.
Please let me know if you have any questions about this request.
Thank you,
Erin
Erin Stewart, PG
Project Manager
Environment
D 919.461.1323 M 919.610.4639
Erin.StewartaC)aecom.com
AECOM
1600 Perimeter Park Drive, Suite 400, Morrisville NC 27560
T 919.461.1100
www.aecom.com

Re: Lucent Winston Salem Facility NPDES#NC0080853 ...
Subject: Re: Lucent Winston Salem Facility NPDES#NC0080853 EPS ID# NCD-003-213-907
From: Tom Belnick <tom [e-mail]>
Date: Fri, 29 Jul 2005 13:34:45 -0400
To: "Simpson, David" <[e-mail]>
David- based on the assumption that the 1,4 dioxane concentrations are in ug/l, we do not see any need for an NPDES permit modification at
this time. The max groundwater concentration that you reported for 1,4-dioxane of 8.2 ug/l is well below our human health criteria of 300
ug/l for C class waters, thus we would not consider this a pollutant of concern for an NPDES discharge. It looks like the NC 2L groundwater
standard of 7 ug/l groundwater standard will present the greater environmental concern. I would recommend that you include any analytical
results for 1,4-dioxane with your next NPDES permit renewal in 2009.
Simpson, David wrote:
I have revised the text to show micrograms/liter written out, not sure what happened to the fonts in the abbreviation used in the original
email.
Sorry for any "electronic" confusion
David H. Simpson, P.G.
Geology Section Mgr - Southeast CSC
ENSR Consulting and Engineering (NC) Inc.
Raleigh, North Carolina
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616
[phone] ext. 222
[phone] fax
From: Simpson, David
Sent: Friday, July 29, 2005 10:50 AM
To: [e-mail]
Cc: Stephenson, Greg
Subject: Lucent Winston Salem Facility NPDES#NC0080853 EPS ID# NCD-003-213-907
As requested in our telephone conversation this morning, I am providing you with the following information regarding recent
sampling conducted at this site.
At the request of Mr. Billy Meyer, the NCDENR-HWS Case Manager for this site, ENSR Consulting and Engineering (NC),
Inc. (ENSR) sampled the following wells and submitted those samples for laboratory analysis to detect the presence of
1,4-Dioxane: extraction wells VOC-1 and EW-15, and monitoring wells: C-2, MW-2A, C-5, and MW-18A. The sampling
event was conducted on June 13, 2005, and the results were reviewed to determine whether 1,4-Dioxane is present in
groundwater at concentrations above the NC 2L standard of 7 micrograms/liter.
The results of the laboratory analysis of the groundwater samples were provided in a report submitted to Billy Meyer on July
18, 2005. 1,4-Dioxane was not detected in two of the monitoring wells, C-2, C-5, nor was it detected in extraction well
VOC-1. Detection limits were 3.3 mg/I - micrograms/liter for analyses performed on each of these samples. 1,4-Dioxane
concentrations were recorded in groundwater samples collected from extraction well EW-15 (8.2 mg/L - micrograms/titer)
and monitoring wells MW-18A (6.2 mg/L-micrograms/liter), and MW-2A (5.1 mg/L-micrograms/liter).
David H. Simpson, P.G.
Geology Section Mgr - Southeast CSC
ENSR Consulting and Engineering (NC) Inc.
Raleigh, North Carolina
7041 Old Wake Forest Road, Suite 103
Raleigh, NC 27616
[phone] ext. 222
1 of 2 7/29/2005 1:37 PM

Re: Lucent Winston Salem Facility NPDES#NC0080853 ...
[phone] fax
[e-mail]
N.C. DENR/DWQ/NPDES
919-733-5083,ext. 543
of 2 7/29/2005 1:37 PM

2014 Generic RPA - 95% Probability/95% Confidence
MAXIMUM DATA POINTS = 58
REQUIRED DATA ENTRY
Table 1. Proiect Information
❑CHECK IF HOW OR ORW
Facility Name
Salem Business Park Remediation Site
WWTPIWTP Class
NPDES Permit
NCO080853
Outfall
001
Flow, Qw (MGD)
0.302
Receiving Stream
LIT to Salem Creek
Stream Class
C
7Q10s (cfs)
0.05
7Q10w (cfs)
0.13
30Q2 (cfs)
0.14
QA(cfs)
0.40
1 Q10s (cfs)
0.04
Data Source(s)
Trichloroethene and tetrachloroethene are NC 02B
Standards.
❑CHECK TO APPLY MODEL
Follow directions for data entry. In some cases a
comment menu list the available choices or a
dropdown menu will provide a list you may select
from. Error message occur if data entry does not
meet input criteria.
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Pares
Par09
Par10
Par11
Par12
Par13
Par14
Paris
Parts
Par17
Pads
Par19
Par20
Par21
Par22
Table 2. Parameters of Concern
Name Typo Chronic Modifier Acute PQL Units
Trichloroethene
C
30
HH
pg/L
Tetrachloroethene
C
3.3
HH
pg/L
Salem Business Park Remediation Site RPA, input
12/20/2018

REASONABLE POTENTIAL ANALYSIS
Trichloroethene
"a10a'��'"a" oorr
. Maxl=n, data
points = 58
Date Data
BDL=112DL
Results
3119114
0.64
0.64
Sid Dev.
0.3737
614/14
0.96
0.96
Mean
0.7650
9/3/14 <
0.5
0.25
C.V.
0.4884
12/3/14
0.98
0.98
n
18
3/31/15
0.54
0.54
6/1/15
1
1
Mull Factor =
1.33D0
919/15
1
1
Max. Value
1.500 pg/L
12/7/15
1.5
1.5
Max. Fred w
1.995 pg/L
3/7/16
0.63
0.63
6/6/16
1.3
1.3
917/16
1
1
12/5116
0.8
0.8
1118117 <
0.5
0.25
3/17/17
0.57
0.57
6116/17
1.1
1.1
9114117 <
0.5
0.25
1215117 <
0.5
0.25
3116118
0.75
0.75
Tetrachloroethene
�' ,
Maslmum data
points = 58
Date Data
BDL=112DL
Results `..
3/19/14
2.6
2.6
Std Dev.
1.3986
6/4/14
1.6
1.6
Mean
2.5972
913/14
1.7
1.7
C.V.
0.5385
1213114
2.4
2.4
n
18
3131/15
2
2
611115
4.2
4.2
Mult Factor=
1.3700
919115
3.5
3.5
Max. Value
5.600 lig/L
12/7/15
3.9
3.9
Max. Pred w
7.7 pg/L
317/16
1.6
1.6
6/6/16
5.6
5.6
No detects
9/7/16
3.2
3.2
12/5116
2.4
2.4
1/18/17
1
1
3117117
1.1
1.1
6/16/17
4.2
4.2
9/14/17 <
0.5
0.25
1215117
1.6
1.6
3/16/18
3.9
3.9
Salem Business Park Remediation Site RPA, data
1- 12/20/2018

REASONABLE POTENTIAL ANALYSIS
Salem Business Park Remediation Site
NCO080853 2014 Generic RPA - 95% Proba6/11ty195% Confidence
MAXIMUM DATA POINTS = 58
Qw (MOD) = 0.302 W WTP/WTP Class:
IQIOS(ch)= 0.04 lWC @IQIOS = 91.58%
7QIOS(cts)= 0.05 IWC @7QIOS= 90.35%
7QIOW(c&)= 0.13 IWC@7QIOW= 78.26%
30Q2 (cts)= 0.14 IWC @ 30Q2= 76.98%
Avg. Stream Flow, QA (cfs) = 0.40 IWC @ QA = 53.92%
Receiving Stream: LIT to Salem Creek Stream Class: C
Outfall 001
Qw = 0.302 MGD
PARAMETER
STANDARDS B CRITERIA(2)
m
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
r
II # De[. Max Fred Cw Allowable Cw
(1)
NC WQS / Applied '/: FAV /
S
Chronic Standard Acute
Acute: NO WQS
Trichloroethene
C
30 HH(QA)
ug/1
18 14
1.995
_ __
_ _ _ _ _ _ _ _ _ _ _ _
Chronic: 55.64
NO RPA, Pretlicted Max<50%of Allowable Cw-No
No value> Allowable Cw
Monitoring required
Acute: NO WQS
Tetrachloroethene
C
3.3 HH(QA)
ug/I
18 17
7.7
_ -__ _ __
_ _ _-_-_ _-_-_-_-_-_-_ _
Chronic: 6.12
RPA for non AL -apply Monthly Monitoring with Omit
No value> Allowable Cw
Salem Business Park Remedia8on Sde RPA, rpa
Page 1 of 1 12120/2018

Whole Effluent Toxicity Testing and Self Monitoring Summary
LP Corp- Roaring River WWTP
NCO0OS266/001
County: Wilkes
Region:
WSRO
Basin:
YAD01
Jan Apr Jul Oct
Ceri7dPF Begin:
4/1/2014 chr lim: 1.3%
NonComp:
Single
7Q10:
228.0
PF: 2.0
IWC:
1.3
Freq: Q
J
F M
A
M
J
J
A
S
O
2014 Pass
- -
Pass
-
-
Pass
-
-
Pass
2015 Pass
- -
Pass
-
-
Pass
-
-
Pass
2016 Pass
- -
Pass
-
-
Pass
-
-
Pass
2017 Pass
- -
Pass
-
-
Pass
-
-
Pass
2018 Pass
- -
Pass
-
-
Pass
-
-
-
Lucent Technologies, Inc.
NC0080853/001
County: Forsyth
Region:
WSRO
Basin:
YAD04
Mar Jun Sep Dec
CerOcIPF Begin:
7/1/2009 chr lim: 90%
NonGomp:
Single
7Q10:
0.05
PF: 0.302 IWC:
90
Freq: Q
J
F M
A
M
J
J
A
S
O
2014 -
- Pass
-
-
Pass
-
-
Pass
-
2015 -
- Pass
-
-
Pass
-
-
Pass
-
2016 -
- Pass
-
-
Pass
-
-
Pass
-
2017 -
- Pass
-
-
Pass
-
-
Pass
-
2018
- Pass
Pass
-
-
-
-
Lumberton Power, LLC
NCOD5H301/003
County: Robeson
Region:
FRO
Basin:
LUM51
Feb May Aug Nov
Ced7clPF Begin:
12/1/2015 chr llm: 0.51%
NonComp:
Single
7Q30:
220.0
PF: 0.45 IWC:
OSS
Freq: Q
J
F M
A
M
J
J
A
5
O
2014 -
H -
-
H
-
-
H -
-
-
2015 -
H -
-
H
-
-
H
-
-
2016 -
Pass -
-
Pass
-
-
Pass
-
-
2017 -
Pass -
-
Pass
-
-
Pass
-
-
2018 -
Pass -
-
Pass
-
-
-
-
-
Lumberton WWTP
NCD02457UMI
County: Robeson
Region:
FRO
Basin:
LUMS1
Feb May Aug Nov
Cen7dPF Begin:
8/1/2017 chr lim: 21%
NonComp:
Single
7Q10:
120
PF: 20
IWC:
21
Freq: Q
J
F M
A
M
!
J
A
S
O
2014 -
>84(P) Pass -
-
Pass
-
-
Pass
-
-
2015 -
Pass -
-
Pass >84(P)
-
-
Pass
-
-
2016 -
Pass -
-
Pass
-
-
Pass
-
-
2017 -
Pass >84(P) -
-
Pass
-
-
Pass
-
-
2018 -
Pass -
-
>84(P)Pan
-
-
-
-
-
Magellan Selma Terminal
NCD052311/001
County: Johnston
Region:
RRO
Basin:
NEU02
Fthd24Ac Begin:
12/1/2013 24hr LC50 ac monit a NonComp:
7Q10:
0.0
Pk --
IWC
100.0 Freq: Q
J
F M
A
M
J
J
A
S
O
2014 -
- >100
-
>100
-
-
-
-
>100
2015 -
- -
>100
-
-
-
-
-
-
2016 -
- -
-
100
-
>100
-
-
-
2017 >100 >100
- -
-
>100
-
-
-
>100
-
2018 -
>100 -
-
>100
-
-
-
-
-
SOC_JOC:
N
SOC JOC:
N
SOC JOC:
N
H
Pass
Pass
Pass
SOC JOC:
N
Pass
Pass
Pass >84(P)
Pass
0
D
Pass
Pass
Pass
Pass
E
M
SOC JOC:
N D
>100
Legend: P= Fathead minnow (Pimohales oromelas). H=No Flow (facility is active). s= Solit test between Certified Labs Page 69 of 124

Final 2016 Category 5 Assessments-303(d) List
emdm,,,mcnta� Yadkin River Headwaters Subbasin Yadkin -Pee Dee River Basin
QuaW
Assessment Unit Name Assessment Unit Description
Assessment Unit Number Water Quality Classification Length/Area Units
Salem Creek (Middle Fork Muddy
12-94-12-(4)a
From Winston-Salem Water Supply Dam (Salem Lake) to Burke Creek.
C
7.5 FW Miles
4ssessment Criteria Status
Reason for Rating
Parameter of Interest
IR Category
Exceeding Criteria
Fair
Benthos (Nar, AL, FW)
5
Salem Creek (Middle Fork Muddy From Burke Creek to SR1120
12-94-12-(4)b C 1.9 FW Miles
Salem Creek (Middle Fork Muddy From SR1120 to Muddy Creek
12-94-12-(4)c C 2.6 FW Miles
UT to UT to North Deep Creek From source UT to North Deep Creek
12-84-1-(0.5)ut14ut13 1.6 FW Miles
YADKIN RIVER From Reddies Riverto Mulberry Creek
12-(38)b C 3.3 FW Miles
YADKIN RIVER From a point 0.2 mile upstream of Big Bugaboo Creek to a point 0.9 mile
upstream of mouth of Elkin Creek (River)
12-(47.5) WS-IV 9.7 FW Miles
3/23/2018 Final 2016 NC Category 5 Assessments Page 180 of 196

MONITORING REPORT(MR) VIOLATIONS for:
Permit: NCO080853 MRs Between 6 - 2013 and 6 - 2018 Region:
Facility Name: % Param Name % County:
Major Minor: %
Report Date: 07/23/18 Page: 1 of 1
Violation Category:Limit Violation Program Category: %
Subbasin: % Violation Action: %
PERMIT: FACILITY: COUNTY: REGION:
MONITORING OUTFALU VIOLATION UNIT OF CALCULATED %
REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE O"r VIOLATION TYPE VIOLATION ACTION

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 204"057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES ydmo/day Inspection Type Inspector Fac Type
1 E 2 15 1 3 NCO080853 111 12 16/02/10 17 18 L d 19 t s t 20 LJ
2111 1 1 I I I I I I 11 l l l l l l l l l l l l l l l l Ill l l l I I I I I I I I f
Inspection Work Days Facility Seff-Monitoring Evaluation Rating B1 QA Reserved
67 70 J_j 71 Lj 72 [_�j 73 I I j74 751 I I 1 I I I I8O
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
01:00PM 16/02/10
09/07/01
Salem Business Park remediation site
3370 Lexington Rd
Exit Time/Date
Permit Expiration Date
Winston Salem NC 27107
02:OOPM 16/02/10
14/06/30
Name(s) of Onsite Representative(s)f7-ities(syPhone and Fax Number(s)
Other Facility Data
111
Gregory Marlin Stephenson/ORC/336-784-2716/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Fred Bleachinger,3370 Lexington Rd Winston Salem NC 27107//336-784-2716/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenances Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone WSRO WQ//336-776-9690/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day inspec5on Type
31 NCO080853 I11 12 16/02/10 17 18 I C I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Please refer to the attached inspection summary letter.
Page#

Permit: NC0080853 Owner - Facility: Salem Business Park remediation site
Inspection Date: 02/10/2016 inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
❑
❑
❑
# Are there any special conditions for the permit?
❑0
❑
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: None
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
1 ❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
M
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
M
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Page# 3

Permit NC0080853 Owner - Facility: Salem Business Park remediatEon site
Inspection Date: 02/10/2016 Inspection Type: Compliance Evaluation
Record Keepina Yes No NA NE
Facility has copy of previous years Annual Report on file for review? ❑ ❑ 0 ❑
Comment: None
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑
Comment: None
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
M
❑
❑
❑
Comment: Yes
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
❑
❑
Comment: None
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
❑
❑
❑
Is the,tubing clean?
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Page# 4

Permit: NC0080863
Inspection Date: 02/10/2016
Effluent Sampling -
Owner - Facility: Salem Business Park remediation site
Inspection Type: Compliance Evaluation
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Comment: None
Yes No NA NE
■ ❑ ❑ ❑
Page#

Winston-Salem Journal
Advertising Affidavit
P.O Box 3159
Winston-Salem, NC 27102
NCDENR/DWO/POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
Account Number
3376309
Date
November 04, 2018
PO Number Order Category Description
ALCATEL-LUCENT 0000514252 Legal Notices PUBLIC NOTICE North Carolina Environmental Management Commission Division of Water I
PUBLIC NOTICE
North Carolina Environmental
Management Commission
Division of Water
Resources/Water Quality
Pei'mitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Notice of Intent to Reissue an
NPDES General Wastewater
Permit
The North Carolina Environmental
Management Commission proposes
to issue a NPDES wastewater dis-
charge permit to the person(s) listed
below. Written comments regarding
the proposed permit will be accept-
ed until 30 days after the publish
date of this notice. The Director of
the NC Division of Water Resources
(DWR) may hold a public hearing
Should there be a significant degree
of public Interest. Please mall com-
ments and/or Information requests
to DWR at the above address. Inter-
ested persons may visit the DWR at
512 N. Salisbury Street, Raleigh, NC
to review Information on file. Addi-
tiunallnformallon on NPDES permits
and this notice may be found on our
I
webslte: hNp'✓/deq,nc.gov/abwVdi
visions/water-resources/water. Publisher of the
branch/npdes-wastewater/public- Winston-Salem Journal
notices,or by calling [phone].
Alcatel -Lucent USA, Inc. has re- mdersi e
quested renewal of permit gn d, a Notary Public of Guilford, North Carolina, duly commissioned,
NCOD80853 for Its Salem Business id authorized by law to administer oaths, personally appeared the Publisher
Park tow re mediation) site In h for- ive who b being dui swum deposes and says: that he/she is the Publisher's
sylh County; this facility discharges Y B Y P Y
remedlated groundwater to Salem ive of the Winston-Salem Journal, engaged in the publishing of newspaper
Creek, in the Yadkin -Pee Dee River /ton -Salem Journal, published, issued and entered as second class mail in the
Basin.
WO; November4. 2018 stonSalem, in said County and State: that he/she is authorized to make this
affidavit and swum statement: that the notice or other legal advertisement, a copy of which
is attached hereto, was published in the Winston-Salem Journal on the following dates:
11104/2018
and that the said newspaper in which such notice, paper document, or legal advertisement
was published was, at the time of each and every such publication, a newspaper meeting all
the requirements and qualifications of Section 1-597 of the General Statures of North
Carolina and was a qualified newspaper within I e meaning of Section 1-597 of the General
Statutes of North Carolina. i
(signalWofpersorr, nm)Ft—ng gfdavi!)
Sworn to and subscribed before me the 5 day of November, 2018
LEA ANNE LAMB (Notary Public)
NOTARY PUBLIC
GUILFORD COUNTY, NC
My Commission Expires 06-15-19
THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU

AECOM AECOM 919461-1100 phone
1600 Perimeter Park Drive, Suite 400 919461-1415 fax
Morrisville, North Carolina 27560
October 16, 2018
Nicholas A. Coco
N.C. Department of Environmental Quality
Division of Water Resources, Water Quality Permitting
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Proposed Compliance Schedule
Salem Business Park Remediation Site #NC0080853
Nokia of America Corporation
3370 Lexington Road, Winston-Salem, Forsyth County, North Carolina
Dear Mr. Coco
On behalf of Nokia of America Corporation (Nokia), AECOM Technical Services of North Carolina
Inc. (AECOM) is submitting the following Compliance Schedule for approval to ensure compliance
with the proposed tetrachloroethene (PCE) limits specified in National Pollutant Discharge
Elimination System (NPDES) Permit #NC0080853 for the groundwater treatment system located
at the former Nokia facility, now known as the Salem Business Park Remediation Site, in Winston-
Salem, Forsyth County, North Carolina.
Background
A groundwater treatment system (GWTS) currently operates at the Site to remediate groundwater
impacted with volatile organic compounds (VOCs). The primary treatment unit of the GTWS is a six -
tray air stripper unit designed for up to 120 gallons per minute (gpm) of groundwater flow and 600
standard cubic feet per minute (scfm) of air flow through the unit. The air stripper was designed to
reduce concentrations of PCE in groundwater to below the laboratory detection limit.
As part of the NPDES permit monitoring requirements, AECOM collects quarterly system effluent
samples from a flume (FE-151) located approximately 100 feet downstream of the air stripper. In
addition to these quarterly samples, AECOM collects monthly air stripper influent and effluent
samples to evaluate the system effectiveness at removing VOCs. Since 2015, the PCE
concentration in quarterly system effluent samples collected from flume FE-151 has ranged from
<0.5 micrograms per liter (pg/L) to 5.6 pg/L, with an average concentration of 2.4 pg/L. During the
same time period, the PCE concentration in monthly air stripper effluent samples has ranged from
<0.5 pg/L to 8.8 pg/L, with an average concentration of 2.6 pg/L.
On August 29, 2018, AECOM received notification from the North Carolina Division of Water
Resources (DW R) that the facility would be receiving a new NPDES permit that would include a
PCE discharge limit of 6.1 pg/L, which is significantly lower than the previous limit of 17 Ng/L.
While the system effluent FE-151 has not exceeded this proposed limit, the PCE concentrations
have been very close to the proposed limit. Based on the expectation that the air stripper unit is
capable of reducing PCE concentrations to below the laboratory detection limit, AECOM proposes
the following actions to evaluate and improve the air stripper's performance to ensure consistent
compliance with the new PCE discharge limit.

AECOM
Compliance Schedule
The plan to ensure consistent compliance with the new PCE discharge limit will be conducted in a
tiered approach. Tier 2 will only proceed if the actions in Tier 1 do not improve system
performance or provide sufficient evidence to confidently assume effluent concentrations will
remain below the PCE discharge limit.
Tier 1 — October 2018 through October 2019 ! 117 V 5 ri
t t
ti
• Upgrade Air Stripper Flow Instrumentation October 2018)
The air stripper does not currently have instrumentation to precisely measure the volumetric -air _
or groundwater M5o roi uF gl—tFe system. uTlow is -currently estimated using tie air injectio
pressure and blower flow curve, and groundwater flow is estimated from the air stripper sump
discharge flow rate. To improve these measurements, AECOM proposes to install an influent
groundwater flow meter and an in -line differential pressure gage to measure volumetric air flow.
These instruments will allow for accurate and precise measurements of air and water flow
through the air stripper during operation.
Air to Water Ratio Testing (October 2018-March 2019)
Following the installation of upgraded flow measurement instrumentation, monthly adjustments
will be made to the volumetric air flow to test the impact of various air -to -water volumetric flow
ratios on system performance. Higher air -to -water ratios typically increase volatilization of VOCs
and increase system efficiency. However, air -to -water ratios can be set too high and result in
groundwater flooding across trays, resulting in uncontrolled and inadequately treated
groundwater flow through the system. Monthly air Stripper influent and effluent VOC samples
will be collected to evaluate the impact of air -to -water ratio changes on PCE removal efficiency.
Monitor Optimal Air to Water Ratio (April 2019-October 2019)
After a review of the air -to -water ratio testing results, the ratio with the highest PCE removal
rate will be selected for continuous operation. Monthly air stripper influent and effluent samples
will be collected to evaluate the performance of the air stripper over a six month period while
operating at the selected ratio. This will determine if adjustments to the air -to -water ratio in the
air stripper will be sufficient to consistently maintain PCE concentrations below the new
discharge limit.
Evaluate Sample QA/QC (January 2019-June 2019)
Duplicate air stripper influent and effluent samples will be collected for six months as part of an
effort to evaluate laboratory analytical precision. Air stripper effluent PCE concentrations are
typically between 1 and 5 pg/L, a difference of four parts per billion. The collection of duplicate
samplesGvill evaluate the reproducibility of PCE concentration results and determine if month -
to -month variability in effluent concentrations is a result of changes to air stripper operation, or
at least in part due to laboratory precision.
n �� Tier 2 — November 2019 through November 2020
�1T Evaluate Air Stripper Tray Performance (November 2019)
The higher than expected effluent PCE concentrations could be a result of inadequate
h C treatment of groundwater on one or more air stripper trays. AECOM proposes installing sample
ports on each of the six trays of the air stripper to collect groundwater samples. These samples
will be abed to evaluate PCE removal efficiency on each tray and could identify -trays that are
not achieving optimal performance.
• Evaluation Follow-up (fjanuary 2019-March 2019)
Based on the results of the air stripper tray performance testing, AECOM will conduct one of
two follow-up steps:

AECOM
1. If the air stripper tray performance evaluation results clearly indicate one or more trays are
ineffective in reducing PCE concentrations, system modifications targeting specific trays will
be made to improve the air stripper PCE removal efficiency.
If the air stripper tray performance evaluation results do not clearly identify specific trays that
require modification, AECOM will evaluate other potential options for reducing effluent PCE
concentrations. AECOM may request an extension to the compliance schedule to allow for 91
further testing and evaluation. SI 4,,* 1
r n ...- 144
Monitor Modified System Performance (April 2019 - November 2020) _
Following system modifications, monthly air stripper influent and effluent samples will be
collected through November 2020 to evaluate the effectiveness of system modifications.
If you have any questions or require additional information, please contact Erin Stewart at
919-461-1323.
Sincerely,
AECOM
John an
Staff Engineer
Christopher Brownfield, P.E.
Project Engineer
r
Erin Stewart, P.G.
Project Manager

WOM AECOM 919.854.6200 tel
701 Corporate Center Drive, Suite 475 919.854.6259 fax
Raleigh, North Carolina, 27607
12@20W[l
JAN 3 2014
December 31, 2013
Wren Thedford
N.C. Department of Environment and Natural Resources
Division of Water Resources, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Request for Renewal of NPDES Permit NCO080853
Salem Business Park Remediation Site
Alcatel -Lucent USA Inc.
3370 Lexington Road, Winston-Salem, Forsyth County, North Carolina
Dear Ms. Thedford:
On behalf of Alcatel -Lucent USA Inc., AECOM North Carolina Inc. (AECOM) is requesting renewal
of National Pollutant Discharge Elimination System (NPDES) Permit NCO080853 for the
groundwater treatment system located at the former Alcatel -Lucent facility, now known as the
Salem Business Park Remediation Site, in Winston-Salem, Forsyth County, North Carolina. The
completed application is enclosed as Attachment 1.
Recent Changes to Facility
Since the last issuance of the NPDES permit, the groundwater treatment system was replaced and
a minor permit modification was issued November 12, 2012. There were no changes to the
contaminants the system is treating, the basic treatment technology, permit effluent limits, or
permitted outflow location. The prior NPDES permit (dated June 12, 2009) specified that the
remediation system consists of the following components:
• Extraction wells
• Oil/water separator
• Granular media filtration
• Feed -water storage and equalization
• Parallel filtration and air -stripping treatment trains receiving segregated flow
• Activated carbon
• Solids removal (filter press)

AECOM
The early 1990s design of the original remediation system was based on using parallel treatment
systems for different contaminant types, with System A receiving flow from diesel fuel extraction
wells and perimeter volatile organic compound (VOC) extraction wells, and System B receiving flow
from interior VOC extraction wells. Twenty years of system data indicate that contaminant
concentrations and flow rates are significantly lower than anticipated during the original remediation
system design. As a result, a new single -stream remediation system was designed and installed to
treat the extracted groundwater. The new system consists of the following components:
• Extraction wells
• Feed -water equalization
• Bag filtration
• Low profile air stripper
• Granular activated carbon
The system component list on the "Supplement to Permit Cover Sheet" portion of the NPDES
permit was modified in the November 12, 2012 minor permit modification to reflect the new
components listed above (Attachment 2).
In addition to the minor changes described above, AECOM also began using oxidizing biocides
(sodium hypochlorite and hydrogen peroxide) and a biodispersant (Redux-620) to prevent biological
fouling of treatment system unit processes and piping. The biocide and biodispersant application
and associated approval for use from the Division of Water Quality are included as Attachments 3
and 4, respectively.
Authorized Representative
Attached is the previous signature authority letter from Alcatel -Lucent dated November 25, 2008,
delegating signature authority for NPDES correspondence to the ENSR Project Manager
(Attachment 5). ENSR was purchased by AECOM, so an updated letter is also included in this
submittal delegating signature authority to the AECOM project manager.
Sludge Management
This facility is a groundwater remediation system and does not have a Sludge Management Plan;
however, a small volume of solids (spent bag filters) are generated and managed as hazardous
waste. Two parallel bag filters provide particulate filtration and require changing approximately
once per week. Spent bag filters are placed in a labeled, covered 55 gallon drum. To date, less
than one drum of spent bag filters has been generated. Once a full drum accumulates, the drum
will be sealed and moved from the Satellite Accumulation Area to the Temporary Storage Area.
Within 90 days of being moved to the Temporary Storage Area the drummed spent bag filters will
be picked up, transported and disposed of as hazardous waste. Annual generation of spent bag
filters is expected to be approximately one to two drums, or 500 to 1,000 pounds.

AECOM
If you have any questions or require any additional information, please contact Erin Stewart at
[phone] or Mr. Gary Fisher at [phone].
Yours sincerely,
Erin Stewart, P.G.
Project Manager
Christopher Mason
Project Manager
Attachments: Attachment 1 — NPDES Permit Application
Attachment 2 — Minor Permit Modification issued November 12, 2012
Attachment 3 — Biocide and Biodispersant Application
Attachment 4 — Biocide Use Approval
Attachment 5 — Signature Authority Delegation Letters

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number NC0080853
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Alcatel -Lucent USA Inc.
Facility Name
Salem Business Park Remediation Site
Mailing Address
600 Mountain Avenue
City
Murray Hill
State / Zip Code
New Jersey 07974
Telephone Number
[phone]
Fax Number
[phone]
e-mail Address
[e-mail]
2. Location of facility producing discharge:
Check here if same as above ❑
Street Address or State Road 3370 Lexington Road
City
Winston-Salem
State / Zip Code
North Carolina
County
Forsyth
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name AECOM
Mailing Address 701 Corporate Center Drive, Suite 475
City Raleigh
State / Zip Code North Carolina
Telephone Number [phone]
Fax Number [phone]
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Page 1 of 3 C-GW 03/05

NPDES PERMIT APPLICATION - SNORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ❑ Other groundwater impacted
with chlorinated solvents and petroleum hydrocarbons
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs:
Duration:
S. Treatment System Design flow avg 0.095 MGD (66 gpm): peak 0.130 MGD (90 gam) MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude):
Salem Creek (see attached Figure 1)
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
Kuene Strong Bleach - sodium hypochlorite aqueous solution 10-20% (w/w) and sodium
hydroxide aqueous solution 1% (w/w)
hydrogen peroxide 35% aqueous solution
Redux-620 - aqueous solution of acrylate copolymer (60/6), proprietary organic phosphorous
compound (60/o), and proprietary sulfonated phosphonium salt (10%)
Please refer to AECOM's April 9, 2013 letter titled "Proposed Biocide and Biodispersant
Application at Salem Business Park Rememdiation Site" and the NCDENR DWQ acceptance
of these proposed additives (enclosed).
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information
All applicants (including renewals):
> A USGS topographical map (or copy of the relevant portion) which shows all outfalls
> A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
> Engineering Alternative Analysis
> Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
> If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
> A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
Page 2 of 3 C-GW 03105

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
13. Applicant Certification
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.
�Evt' V-\ S�-ewak�- ve
Printed name of Person Signing Title
of Applicant
Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3 C-GW 03105

..,
'I Map Location
v4KYWVVA
QNCE2SC
iJ
i
Discharge Point
e r.� •• yt._.
T✓ I 1
•:..� � _ ill}'.. ._
I •' • •�F:yn s ��
,
n •side'
411,1
am
ti
f �
Location \
S r lY i
V:
Easton
�. Vieµ '.. `'•
X + „ Lrnion Y.}dge {
I
� ;1•, I' ESL -_ _ � _ : L
� 5 L � � ( � - 4 _ •J 4 ✓•fit••
40 t
l
\ [ r•' /mot-- �
Winston-Salem East, NC USGS Topographic Quadrangle (1994)
0 2,000 4.000
Feet
�Ia
Alcatel -Lucent USA Inc. A_COM
Winston-Salem, North Carolina Discharge Location Map
Project No.: 60265073 Date:2013-07-25 Figure 1

Table 1
Summary of Effluent Volatile Organic Compound Analytical Results
Salem Business Park Remediation Site
Alcatel -Lucent USA Inc.
Winston-Salem, North Carolina
1. 1, 1,2-Tetrachloroethane
< 0.50
1, 1, 1 -Trichloroethane
< 0.50
1,1,2,2-Tetrachloroethane
< 0.50
1, 1,2-Trichlo roetha ne
< 0.50
1,1-Dichloroethane
< 0.50
1,1-Dichloroethylene
< 0.50
1, 1 -Dichloropropylene
< 0.50
1,2,3-Trichlorobenzene
< 2.0
1,2,3-Trichloropropane
< 1.0
1.2.4-Trichlorobenzene
< 1.0
1,2,4-Trimethylbenzene
< 0.50
1,2-Dibromo-3-chloropropane
< 2.0
1,2-Dibromoethane
< 0.50
1,2-Dichlorobenzene
< 0.50
1,2-Dichloroethane
< 0.50
1,2-Dichloropropane
< 0.50
1,3,5-Trimethylbenzene
< 0.50
1,3-Dichlorobenzene
< 0.50
1,3-Dichloropropane
< 0.50
1,4-Dichlorobenzene
< 0.50
2,2-Dichloropropane
< 2.0
2-Chloroethyl Vinyl Ether
< 2.0
2-Chlorotoluene
< 0.50
4-Chlorotoluene
< 0.50
4-Isopropyltoluene
< 0.50
Acetone
< 5.0
Acrolein
< 20
Acrylonitrile
< 20
Benzene
< 0.50
Bromobenzene < 0.50
Bromochloromethane < 0.50
Bromodichloromethane
< 0.50
Bromoform
< 1.0
Bromomethane
< 1.0
Carbon disulfide
< 5.0
Carbon Tetrachloride
< 0.50
Notes:
Sample collected on October 31, 2013
Sample analyzed for volatile organic compounds by EPA Method 8260
µg/L - micrograms per liter
Chlorobenzene
< 0.50
Chloroethane
< 0.50
Chloroform
< 0.50
Chloromethane
< 0.50
cis-1,2-Dichloroethylene
< 0.50
cis-1,3-Dichloropropylene
< 0.50
Dibromochloromethane
< 0.50
Dibromomethane
< 0.50
Dichlorodifluoromethane
< 1.0
Ethylbenzene
< 0.50
Hexachlorobutadiene
< 2.0
Isopropyl Ether
< 0.50
Isopropylbenzene (Cumene)
< 0.50
m,p-Xylenes
< 1.0
Methyl Butyl Ketone (2-Hexanonr
< 5.0
Methyl Ethyl Ketone (2-Butanone
< 5.0
Methyl Isobutyl Ketone
< 5.0
Methylene Chloride
< 1.0
Methyl-tert-Butyl Ether
< 0.50
Naphthalene
< 1.0
n-Butylbenzene
< 1.0
n-Propylbenzene
< 0.50
o-Xylene
< 0.50
sec-Butylbenzene
< 0.50
Styrene
< 0.50
tert-Butylbenzene
< 0.50
Tetrachloroethylene
< 0.50
Toluene
< 0.50
trans-1,2-Dichloroethylene
< 0.50
trans-1,3-Dichloropropylene
< 0.50
Trichloroethylene
< 0.50
Trichlomfluoromethane
< 0.50
Vinyl acetate
< 2.0
Vinyl chloride
< 0.50
Xylenes, total
< 3.0
AECOM

A=COM AECOM 919.872.6600 tel
8540 Colonnade Center Drive, Suite 306 919.872.7996 fax
Raleigh, North Carolina, 27615
April 9, 2013
Ms. Cindy Moore
Aquatic Toxicology Unit Supervisor
N.C. Department of Environment and Natural Resources
Division of Water Quality, Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Subject: Proposed Biocide and Biodispersant Application at Salem Business Park
Remediation Site, Discharge #NC0080853
Dear Ms. Moore:
AECOM North Carolina, Inc. (AECOM) currently operates and maintains a groundwater remediation
system on behalf of Alcatel -Lucent USA, Inc. (Alcatel -Lucent) at the Former North Carolina Works —
Lexington Road Plant in accordance with Resource Conservation and Recovery Act permit NCD
003 213 907. The groundwater remediation system uses a combination of air stripping and
granular activated carbon (GAC) to treat volatile organic compounds in extracted groundwater prior
to discharging to an unnamed tributary of Salem Creek under National Pollutant Discharge
Elimination System (NPDES) Permit #NC0080853. To prevent biological fouling of treatment
system unit processes and piping, AECOM requests permission to apply the following oxidizing
biocides to above -ground treatment unit processes and piping:
• Sodium hypochlorite
• Hydrogen peroxide
AECOM also requests permission to apply the following biodispersant to above -ground treatment
unit process and piping for the same reason:
• Redux-620
Enclosures provided with this letter include materials safety data sheets (MSDS) for a typical high
strength sodium hypochlorite and typical hydrogen peroxide product, the manufacturer's MSDS and
fate -and -transport statement for Redux-620, and the Aquatic Toxicology Unit's biocide application
worksheet and spreadsheet.
It is anticipated that complete or nearly complete reduction of applied oxidizing biocides will occur
within the GAC unit process prior to discharge. It is also expected that catalytic hydrolysis of the
iron dispersant within Redux-620 (tetrakis hydroxymethyl phosphonium sulfate, or THPS) to occur
within the GAC unit process. Therefore, AECOM has completed the enclosed spreadsheet and
worksheet as a calculation of the maximum discharge concentration of sodium hypochlorite,
hydrogen peroxide, and Redux-620 product that may be discharged to the NPDES outfall assuming
decomposition or adsorption with the GAC unit process, no 7Q10 flow, and negligible product
decay. AECOM proposes to monitor the GAC unit process effluent using field test kits for free and
residual chlorine, for peroxide, and for THPS in order to maintain discharge concentrations below
that which would result in the dosage rate specified on the enclosed spreadsheet and worksheet.

AECOM
Monitoring of the active ingredients hypochlorite, peroxide, and THPS is proposed as a real-time
method for estimating the amount of applied whole product that is discharged to the NPDES outfall.
The proposed action levels are:
• Sodium hypochlorite: 1 milligram per liter (mg/L) as OCI-
• Hydrogen peroxide: 0.35 mg/L H2O2
• Red ux-620: 10 mg/L as TH PS
The proposed action levels correspond to the concentrations used to calculate the dosage rate on
the enclosed biocide application spreadsheet and worksheet. At the proposed action levels,
discharge of the measured components of strong bleach, hydrogen peroxide, and Redux-620 can
be sustained for up to 1 minute, 5 minutes, and 60 minutes, respectively, without exceeding or
potentially exceeding the whole -product mass discharge limits as defined by the enclosed
worksheets and spreadsheet. Real-time monitoring is therefore proposed at a frequency of one half
the maximum sustained discharge time at the action level concentration, or every 30 seconds
during sodium hypochlorite application, every 2.5 minutes during hydrogen peroxide application,
and every 30 minutes during Redux-620 application. Testing will be conducted at the onset of the
application period, throughout the application period and for 20 minutes following the application
period, which is approximately enough time for 1,000 gallons to be conducted through the treatment
unit processes at an influent flow rate equivalent to the current system throughput (0.075 MGD).
Discharge of effluent with concentrations of monitored constituents above the proposed action
levels will be discontinued immediately if monitoring indicates that action levels are exceeded.
Application of the proposed biocides or biodispersant is proposed daily for one week each and on
an as -needed basis thereafter. The testing rigor outlined in this letter is proposed as an initial
assessment. One-time spot checking is proposed for subsequent, as -needed applications that may
follow the initial treatment if complete treatment of the monitored constituents can be demonstrated
by the initial assessment. Please contact Chris Brownfield at [phone] with questions.
Yours sincerely,
Erin Stewart, P.G.
Project Manager
Enclosures (8): Biocide Spreadsheet
Christop r S. Brownfield, E.
Staff Engineer
Hydrogen Peroxide Biocide Worksheet
Hydrogen Peroxide MSDS
Redux-620 Biocide Worksheet
Redux-620 MSDS
Sodium hypochlorite Biocide Worksheet
Sodium hypochlorite MSDS
Redux-620 Fate and Transport Documentation

1x
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E.
Governor Director
MMRMQ11M
To: Chris Brownfield
Salem Business Park Remediation Site
AECOM
Staff Engineer with AECOM
From: Susan Meadows
Aquatic Toxicity Unit
Subject: Biocide Use Review
Salem Business Park Remediation Site
NPDES # NC80853
Forsyth County
John Skvarla
Secretary
Salem Business Park Remediation Site has requested approval of the following chemicals,
Redux 260, Hydrogen Peroxide, & Kuene Strong Bleach. These products will be discharged into
their Outfall 001 and in to an unnamed tributary of Salem Creek.
Calculations predict the use of these products, at the stated dosage rates, will not cause toxic
impacts to aquatic life in the receiving stream, unnamed tributary of Salem Creek. Therefore, the
use of these products as an additive to their cooling water system at Salem Business Park
Remediation Site is acceptable.
cc: Tom Belnick, Western NPDES Program
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: http://aortal.ncdenr.ora/webtwaless/home
NoChCarolina
Nhu&Ilff
An Equal Opportunity 1 Affirmative Action Employer

Dishcharger Name BIOCIDE WORKSHEET
PERMIT#: NCO080853
RECEIVING STREAM: unnamed tributary of Salem Creek (Middle Fork Muddy Creek)
7Q10 (cfs): 0.00
I.W.C.%: 100.00
PRODUCT: Redux 620
ACTIVE INGREDIENT: Aqueous solutions of acrylate copolymer (6%), proprietary
organic phosphorous compound (6%), and proprietary sulfonated
phosphonium salt (10%)
HALF LIFE (DAYS): 1000.00 STEADY STATE DISC CON(4.1604
LC50/EC50 OF SELECTED TOX DATA (MG 700 DEGRADATION FACTOR: 75.000
DECAY RATE: 0.0000 APPLICATION FACTOR: 0.010
DOSAGE RATE (GRAMS/DAY): 1181.0448
AVG DAILY DISCHARGE (MGD): 0.075 INSTREAM BIOCIDE CONC:4.1604
VOLUME OF SYSTEM (MIL. GAL'S): 0.001 REGULATED LIMITATION: 7
PASS/FAIL: PASS
PRODUCT: Kuene strong bleach or eq.
ACTIVE INGREDIENT: sodium hypochlorite aqueous solution 10-20% (w/w)
and sodium hydroxide aqueous solution 1 % (w/w)
HALF LIFE (DAYS): 1000.00 STEADY STATE DISC CON(0.0069
LC50/EC50 OF SELECTED TOX DATA (MGi 0.9 DEGRADATION FACTOR: 75.000
DECAY RATE: 0.0000 APPLICATION FACTOR: 0.01
DOSAGE RATE (GRAMS/DAY): 1.968408
AVG DAILY DISCHARGE (MGD): 0.075 INSTREAM BIOCIDE CONC:0.0069
VOLUME OF SYSTEM (MIL. GAL'S): 0.001 REGULATED LIMITATION: 0.009
PASS/FAIL: PASS
PRODUCT: Hydrogen Peroxide
ACTIVE INGREDIENT: 35% aqueous solution of hydrogen peroxide
HALF LIFE (DAYS): 1000.00 STEADY STATE DISC CON(0.0104
LC50/EC50 OF SELECTED TOX DATA (MG/ 1.38 DEGRADATION FACTOR: 75.001
DECAY RATE: 0.0007 APPLICATION FACTOR: 0.01
DOSAGE RATE (GRAMS/DAY): 2.952612
AVG DAILY DISCHARGE (MGD): 0.075 INSTREAM BIOCIDE CONC:0.0104
VOLUME OF SYSTEM (MIL. GAL'S): 0.001 REGULATED LIMITATION: 0.0138
PASS/FAIL: PASS

It
BIOCIDE/CHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This. worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
1. Facility Name'Pb-eV-- S 1 TF
NPDES # NC DO 008!E�3 Outfall # NA
County
Receiving Stream L1N&A&E.�;:k iIZ&LL7- 7A,;Ly of S4,LEA& 7Q10 CfD 4 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 0.0-4S (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC - (A.D. D. X 100 _ (.os� X 100 _ oa
(7 10)(0.646) + (A.D.D) (a )(0.646) + (.ow)
G
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Please list the active ingredients and percent composition:
C�Z�A*•t c i-toS� Nrodz�.�.-S o N`PG� u�u'fl '�- �o %
�tt.t� .-c�t.1 A►�T�n �Nt�'SP6titat►� 1�f� SPc�-T~ �-- IG� %
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24hr period.
D.R.= 1 11$ grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Gmms. Oi pmrii iet = fliji n of nrnrlt ictX,:I-
X. SPecific OcavitY Of Moduct i( 4
128 fl. oz. 1 gal. water 1 lb.
100 4P 1 g 52 atlw�.s �t 60 :Y► 3 .��SLi L 46W
L �Ow 1 000 r**� r", ;VA 2� ` f 6.Ar

-Facility Name: 6cA_'-.+1-JEss PA --V, NPDES #: NC0C45oe5S:;�_,
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.) F4�2 • G act._
GA�C _ - 7-A F ?� 40oo es-o o . Lt P"_-n (
Volume= d • do 1 million gall ,�
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. A,
What is the decay rate (D.K.) of the product? If unknow assume no decay (D.K.= and proceed to asterisk.
The degradation must be stated at pH level within 1 /2 pH standard unit wit in handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. _ C* Days
The decay rate is equal to H1L X 0.69 = =Decay Rate (D.K.)
Calculate degradation factor (D.F.). This is the first order loss coefficient.
* D.F. = A-i . D. = 0.01s o = S
(Volume) + (D.K. ) (p . cot) + ( )
Calculate Steady State Discharge Concentration:
Dischg Conc. - (D.F.)(Vollume)(3785) _ (-45 )(o.atl)(3785) = y • t mg/I
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Dischg. Conc.) x (IWC%) (4•Ito) x (�ao i _ '{. I (p mg/l
100 = 100
Receiving Stream Concentration
III. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism
Test Duration
LC50/EC50 (mg/1)
'9 oO
0
D. Yi! Q. Form 101 (612000) 2

Fmillty Nar��; "�?��-w.+�.u��-:��o.,�,° NPG Jl. fill e ,
Chogm th@ lowwat LCgg/9059 I19t9d abov@ � yr
Ent@r tho LOOO/ECOv, - _ 1. &-
If th@ half lifa (b,L) W laao th@M 4 d@yg, patfgrm th@ (©Il@wing CAICU Ign
ftgalatod Limitsflgn s 0,05 x LC60 a my/1
If th@ half lif® RL.) i§ gr@at@r thm nr agrrral W 4 day§ -_ n ftgrm tho follywing §F&►_.iMon
13@90-00 Limit0on a 0:01 x LCgg - mg/I
Chwm th@ @ppropft@ F@gul-Rt@d li► Utinn ffom the gal latign ifntnadiatMy aba+ra and plop in thi§ hlank:
+ __- mg/lftf
hfQM Daft it W@f If!a fa9a1aing WOW Pons@n §VQn
`1 I (p o i,.) I tar
it th@ w0ving Worm wontratinn i§ gfeatw th@n th@ olwla* f@gulatad Ilmbtlon, than thin bigc.id@ ig
�rnaa���tal�i� f@r usa.
Par§gn In Roponaihl@ Chargs
int)
�ar�an �fnplating ToI� Wlrltaha@t of of mnt tram @h©v®)
Nam@ (Print)
Lj
AgY0q fi oohogy Unit
1621 Malt smio NNW
R&O, NG 2700921001
NnWipt into; Oody Moan f _1 y,a: ����ra a i_,natj or John olor-Al o ML1,100

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
I. Facility Name Sils A,!` '¢.acmes, FAOOJ� S (-r'
NPDES # NC a�3 Outfall # ��
County
Receiving Stream 1alSrlAtNMr> 'TV-cguT 9-Y c:) T::7 7Q10 (cfs)
(All above information supp ied by the Division of Water Quality) b� S:Pp W=I?—' 't-"t- CSC
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = a• o"755 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
lWC _ (A.D.D.) X 100 _ �� X 100 _ /o
o
(7 0)(0.646) + (A.D.D) { 0)(0.646) + (
o�
O
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Please list the active ingredients and percent composition:
A 3d�7- % Mki vim`.
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24hr period.
D.R.= 2 -95 grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
1281 oz. 1 gal. water 1 lb.
o. o o i5 2 �5�t ia�.S �'c,� 3 .�'-t
L.. ta-w m %VI

Facility Name: !!. kt..g tw FAutst 9E6#95, Fir NPDES #: NC
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume= C' . ao I
-7 l 4 O caat C. 7 A<L- . G' Ps,PP'�C_ tT`'r
million gallons pl` -r9ZAcr�F�--r StsTV-rk^, -
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. -4
What is the decay rate (D.K.) of the product? If unknown, ume no =decay(D.K.:==O)and proceed to asterisk.
The degradation must be stated at pH level within 1 /2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = o0
Days
The decay rate is equal to H1L X 0.69 =
=Decay Rate (D.K.)
Calculate degradation factor (D.F.). This is the first order loss coefficient.
" D. F. = AS- D. D.) + (D. K.) = a. o-4 +S—
(Volume) (o. oc>o
Calculate Steady State Discharge Concentration:
Dischg Conc. = (D.R.) - (ZR� - O • ot�-{mgll
(D.F.)(Volume)(3785) - ( -4S )(o.00l )(3785)
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Dischg. Conc.) x (IWC%) (b•oleo x ( too) _ 0• of
100 - 100 - �`"f mg/i
Receiving Stream Concentration
Ill. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism TestDuration
'FIS
aFlMERAP99.5L�►� •s i ■
FISAA
W is at
P .
r a ► a \
r
LC50/EC50 (mall
D. W. Q. Form 101 (612000) 2

1!
..
Facility Name:., OAK-, , NPCES M ISIC4kOPS0189SP
RUB 1A o I%3 dS t'r,
Choose the lowest I.C60/E060 listed above',
Enter the LC60/SC6®;
If the half life (M,L.) is lass than 4 days, perform the following calWation,
Regulated Limitation s 0.05 x LC60
It the halt life (H,L,) Is grouter than or equal to 4 da#'. '.0i unknown 1:;�I)o►srm tho following calculation:
Regulated Llmitetion 1; 0,01 x LC64 i . rngli
choose the appropriate raguietad limitation from ft calculations ImmodlMoly above and place its this blank
From Part II ontor tho recelving etroam cone@ntretlom
• 0 t (D'-+ rig/litor
IV Analysis,
If the receiving stream concontrMlon is greater than the calculated rogulMad limitation, then this biocide 4
unaceoptabio for use:
Parson In Roaponsible Charge
Na t)
Sig ®tiro - gate
Person mploting This Workohoot (if Jiff®rent from above)
- Nark@ (Print) �
Oat@
Plug@a submit to, Diviaion of WOW Quality
Agw0c Toxicology Unit
1621 MW Sewlce Cent@r
l' aMph, NC 27099.1021
Contact WO! Cindy Moaro (cindy,o.tnoorc�'a,)roc-mall,not) or John eicroino tjohn,gioroinoC ne-alAncta

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name �J+at,F-M '�.�u-S���SS PA21L RCMUC ykTtOt-J S'TrM
NPDES # Outfall # i Z k
County��T!-�
Receiving Stream L0-It4Ady� TRAQt CjA ?,.-%j o F � LsM 7010 C� �'�` (cfs)
(All above information suppliea by the Division of Water Quality) ksos-u`� FoFL- Tlj� m CAta.
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = d •b'75' (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
A.D.D. X 100
0
(.oqq X 100 = too
( o )(0.646) + ( )
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
li. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Please list the active ingredients and percent composition:
AYft Gth.o 6GGsUCS d7M-T l O - Zo % My L6M.
�jct4t u•w�- !-E� K. t�� L t4 cL d4 l % aK wZ'-.
SDDI uL,A� Gil t.oS2-t'D� a� Utz > 1 % SY WT
�.�► R�d-�► C. i4G� �� '� c ��� t v�rv� S A I.rT 7 i a/ $q t+.IT-.
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24hr period.
D.R.= I - Q(o e) * grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
128 fl. oz. 1 gal. water 1 lb.
10_ 223 P�dVa+
(
62(xsP+
3�a 574LJt"j
L
�4J j't�

,Fdcility Name: NPDES #: NC s-z
'" 1 Mnot. N
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.) > I,ovwt Arcs c-APAC.I-I a OF
Volume= d . cx:> 1 million gallons 772F..A r-T-A4 7SleSTXM
What is the pH of the handling system prior to biocide addition? If unknown, enter NIA. N. hr
What is the decay rate (D.K.) of the product? If unknow assume no decay (D.K.=0 d proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial -product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = coo Days
The decay rate is equal to _ L X 0.69 =
=Decay Rate (D.K.)
Calculate degradation factor (D.F.). This is the first order loss coefficient.
* D.F. = A.D.D. + (D.K.) _ .o4S +
(Volume) (.00 t )
Calculate Steady State Discharge Concentration:
Dischg Conc. - (D.R.) - (16'%18) = O.00GA "mg/I
(D.F.)(Volume)(3785) r ('}� )(o.00i )(3785)
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
Q
(Dischq. Conc.) x (IWC%) x ( lack )
100 - 100 - 0.00 mg/I
Receiving Stream Concentration
III. Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism
Test Duration
O. S Kv�
LC50/EC50 (mg/1)
d=) • =t om
D. W. Q. Form 101 (612000) 2

0
Facility Name: �c�wx AL NPDES #: NC eaDSc�2
Choose the lowest LC50/EC50 listed above:
Enter the LC50/EC50 n ' rt o
If the half life (H.L.) is less than 4 days, perform the following calculation
Regulated Limitation = 0.05 x LC50
If the half life (H.L.) is greater than or equal to 4 days sper(orw the following calculation.
Regulated Limitation = 0.01 x LC50 = • o mg/i
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
0.0c)="k __ , 1 1 nglliter
From Part II enter the receiving stream concentration
__mg/liter
IV Analysis.
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
gCmpllefingThis
t)
ature Date
PeWorksheet (If different from above)
CAS
fume (Print)
:,ic�<«ilurr: Date
�1
Please submit to:
Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699-1621
Contact info: Cindy Moore ([e-mail]) or John Giorgino [e-mail])

Alcatel•Lucent 0
600 Mountain Avenue
Room 7F407A
Murray Hill, NJ 07974
November 26, 2008
Ms. Dina Sprinkle
NCDENR, DWQ, Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: REQUEST FOR DIVIR SIGNATURE AUTHORITY
Lucent Technologies, Inc.
3370 Lexington Rd, Winston-Salem, NC
NPDES Permit No. NCO080853
Dear Mrs. Sprinkle:
As the Permittee and as a representative of Lucent Technologies, Inc., now known as Alcatel -
Lucent USA Inc. (Alcatel -Lucent). I am requesting that the signature authority for the above
referenced facility continue to be delegated to the ENSR Consulting and Engineering (NC), Inc.,
Project Managers for the Alcatel -Lucent Winston-Salem Facility (currently David H. Simpson,
P.G. and Erin Stewart, P.G.), duly authorized representatives of Alcatel -Lucent. This
representative will continue to review, determine compliance status, and certify by signature
monthly monitoring reports. I recognize that pursuant to 15A NCAC 2B .0506 (b) (2) (D), that the
process of authorizing another individual or position to sign as a representative in no way
relinquishes any responsibility for the permit or responsibility to remain familiar with the permit
conditions, limits, including any modifications, and for the compliance data reports for the
permit.
If you have any questions regarding this request please contact me at [phone].
Thank you.
4GaM.
ely,
r
4f Fisher
Permittee
Cc: David Simpson 1 ENSR

Alcatel -Lucent 6
600 Mountain Avenue
Room 2A-359
Murray Hill, NJ 07974
December 23, 2013
Wren Thedford
N.C. Department of Environment and Natural Resources
Division of Water Resources, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: REQUEST FOR DMR SIGNATURE AUTHORITY
Salem Business Park Remediation Site
Alcatel -Lucent USA Inc.
3370 Lexington Road, Winston-Salem, Forsyth County, North Carolina
Dear Ms. Thedford:
As the Permittee and as a representative of Alcatel -Lucent USA Inc., I am requesting that
the signature authority for the above referenced facility continue to be delegated to the
AECOM North Carolina Inc. Project Manager for the Facility (currently Erin Stewart,
P.G.), duly authorized representatives of Alcatel -Lucent. This representative will
continue to review, determine compliance status, and certify by signature monthly
monitoring reports. I recognize that pursuant to 15A NCAC 2B .0506 (b) (2) (D), that the
process of authorizing another individual or position to sign as a representative in no way
relinquishes any responsibility for the permit or responsibility to remain familiar with the
permit conditions, limits, including any modifications, and for the compliance data
reports for the permit.
If you have any questions regarding this request please contact me at [phone].
Thank you.
Sincerely,
e
.11
Gary Fisher
Environmental Engineering Manager
Permittee
Cc: Erin Stewart - AECOM

�Elerry,Ron
From: Boone, Ron
Sent: Wednesday, October 16, 2013 2:33 PM
To: Berry, Ron
Subject: NPDES Permit Renewals
Ron,
I have no questions, comments, or concerns about the renewal of the following three NPDES permits:
NC0080853
Lucent Technologies, Inc.
NC0085871
Flakt Products, Inc.
NC0086762
City of Winston Salem
Salem Business Park Remediation Site
Flakt Products Remediation Site
Northwest WTP
Please go ahead and reissue these permits. Let me know if you have any questions or concerns.
Thanks,
Ron
Ron Boone
NC DENR Winston-Salem Regional Office
Division of Water Resources, Surface Water Protection
585 Waughtown Street
Winston-Salem, NC 27107
Email: [e-mail]
Voice: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.