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HomeMy WebLinkAboutNC0083658_Permit Issuance_20170127Water Resources ENVIRONMENTAL QUALITY ROY COOPER Gommor MICHAEL S. REGAN Secretary S. JAY ZIMMERMAN Director January 27, 2017 Paul Heim, Legal Council Daikin Applied Americas, Inc. 13600 Industrial Park Blvd Minneapolis, Minnesota 55441 Subject: Issuance of NPDES Permit NCO083658 former HeatCraft Site - GW REM, Class PC-1 602 Sunnyvale Drive, Wilmington, NC New Hanover County Dear Mr. Heim: The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject facility. We issue this permit 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. Changes for Renewal. In compliance with EPA/NC's updated surface water -quality criteria and standard for Trichloroethylene (TICE), we have lowered your TCE permit limit from 30.0 ug/L to 3.0 ug/L (both Monthly Average and Daily Maximum), considering a discharge under zero -flow receiving - stream conditions [see A. (L)]. The monitoring frequency has increased from 1/Month to 2/Month, per NCAC 15A 2B.0505. Based on correspondence with Daikin's Paul Heim [Joe Corporon, NPDES, 02Dec2016], DWR is assured that the current remediation system is adequate to treat TCE to 1.0 ug/L in compliance with new TCE limits. Therefore, this permit requires no compliance period for new limits. The Division understands that you have made no significant changes to your treatment processes since last renewal, but may have added shallow pumping wells, increasing influent flow. We have therefore made only minimal changes to the remainder of your permit by updating permit format and site map. Implementing Electronic Discharge Monitoring Reports (eDMRs). Please be advised that the Division has implemented an electronic Discharge Monitoring Report (eDMR) program, in accord with recently promulgated requirements by the Environmental Protection Agency (EPA). We include the details to implement the eDMR program in this permit [see Section A. (3.)]. Federal regulations require electronic submittal of all DMRs and specify that, if North Carolina does not establish a program to receive such submittals, Permittees must then submit eDMRs directly to EPA. For more information on eDMRs, registering for eDMR submittal, and obtaining an eDMR user account, please visit DWR's webpage: http://portal.ncdenr.org/web/wq/admin/bog/it)u/edmr Slate of North Carolina I Envitonnental Quality I Water Resources 1611 Mail service Center I Raleigh, North Carolina 27699-1611 919 707 9000 '0 . Paul Heim, Legal Council Daikin Applied Americas, Inc. January 27, 2017 Page 2 For information on EPA's proposed NPDES Electronic Reporting Rule, please visit EPA's website: htto://www2.epa.goy/compliance/proposed-npdes-electronic-reporting-rule If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B of the North Carolina General Statutes, and you must file it with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. This permit is not transferable except after notifying the Division of Water Resources. The Division may require permit modification, or revocation and re -issuance. Please note that this permit does not affect your legal obligation to obtain other permits required by the Division of Water Resources, the Division of Land Resources, the Coastal Area Management Act, or other federal or local governments. If you have questions, or if we can further assist you, please contact Joe R. Corporon L.G. at []oe.corporonCa,ncdenngov] or call his direct line (919) 807-6394. G Enclosure: NPDES Permit NC0083658 (issuance final) hc: Central Files NPDES Program Files WiRO/SWPS, Jim Gregson, Supervisor ec: WiRO/SWPS, Jim Gregson, Supervisor; Dean Hunkele OCU, Maureen Kinney ATU, Cindy Moore; Susan Meadows Daikin: Paul Heim [paul.heim@daikinapplied.com] Daildn: Raymond Roblin [correri@verizon.net] 0 Permit NCO083658 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM DES 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 Water Quality Commission, and the Federal Water Pollution Control Act, as amended, Daikin Applied Americas Inc. 13600 Industrial Park Blvd Minneapolis, Minnesota 55441 is hereby authorized to discharge wastewater from a facility located at the former [former] HeatCraft Site -Groundwater Remediation (GW- REM) 602 Sunnyvale Drive, Wilmington New Hanover County to receiving waters designated as an unnamed tributary to Barnard's Creek within the Cape Fear River Basin in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts I, H, III, and IV hereof. This permit shall become effective March 1, 2017. This permit and the authorization to discharge shall expire at midnight on December 31, 2021. Signed this day, January 27, 2017. ay Zimmerman, P.G. Director, Division of Water Resources' By the Authority of the Environmental Management Commission Page 1 of 7 I' r 4 Permit NCO083658 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. Daikin Applied Americas Inc. is hereby authorized to: 1. continue to operate facilities to treat a discharge from a groundwater-remediation system designed for chlorinated solvents, consisting of • eight (8) each GW extraction wells [EW #1 thru EW #8] • primary accumulation tank • two (2) each QED EZ-24 6SS air strippers • appurtenant piping, valves, flow meters and sample ports • discharge line to a concrete ditch located at the former HeatCraft Site GW-REM, 602 Sunnyvale Drive, Wilmington, New Hanover County, and 2. discharge from said treatment works via Outfall 001, a location specified on the attached map, into an unnamed tributary (UT) to Barnard's Creek [stream segment 18-88], a waterbody currently classified C; Swamp within Subbasin 03-06-17 [HUC: 03030006] of the Cape Fear River Basin. Page 2 of 7 t Permit NCO083658 PART I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated, remediated groundwater via Outfall 001. Such discharges shall be limited, monitored and reported 1 by the Permittee as specified below: El _/�,,,���J.■■,, . QJ ? H� •� ~ l ,h l _�.' �i'�'-`�1•R r, T .^Q....r�..J.1,-ti...w. .J1.:.Y��i.._-.i�.� ^- e� �/ 1` rT l I.+.^' �. j]'e'.tI .? F .•Ti 4... S f 1 '�'i M1_ ij ': .CC.-t /� ::.i k .U.:. .J Daily . `#1VI""esui�eui�eat Sample Snipe [Parum ter e G'oaes] , a ti fr' �i�'�e.�ge-� , �� �r A�`g��..// F , r Y`l�ia�mum � Frec�ency - Type, . Lo�a�iQ f, Flow (MGD) 50050 0.360 Continuous Recording Influent or Effluent Trichloroethylene (TCE) 78391 3.0 µme- 3.0 µg/L 2/Monthly Grab Effluent pH 00400 Not < 6.0 or > 9.0 Standard Units Monthly Grab Effluent WET Testing 2 THP3B Quarterly Grab Effluent Volatile Organics EPA 601 Annually Grab Effluent Footnotes: 1. Beginning no later than December 21, 2016, the Permittee shall submit discharge Monitoring Reports electronically using DWR's eDMR submittal system [See Section A. (3.)]. 2. Whole Effluent Toxicity (WET) Testing; Chronic (Ceriodaphnia dubia) P/F at 90%: during the months of February, May, August and November [see A. (2)J. Condition: The Permittee shall discharge no floating solids or foam visible in other than trace amounts. A. (2.) CHRONIC TOXICITY - PERMIT LIMIT (QUARTERLY) [I 5A NCAC 02B .0500 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 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 February 1998, or subsequent versions or, "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. NOTE: If the test procedure, performed as the first test of any single quarter, results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. Page 3 of 7 t Permit NCO083658 The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental 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 Environmental 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. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (3.) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports and specify that, if a state does not establish a system to receive such submittals, then permittees must submit monitoring data and reports electronically to the Environmental Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. Page 4 of 7 Permit NC0083658 NOTE: This special condition supplements or supersedes the following sections within Part H of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reportina Reuuirements (Supersedes Section D. (2.) and Section E. (5.) (a)1 Effective December 21, 2016, 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), Permittee 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 DENR / 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. 1, 2, 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. 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). Page 5 of 7 4, It Permit NCO083658 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://portal.ncdenr.or web/wg/admin/bogCl2u/edmr 2. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) Lim 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: hqp://portal.ncdenr.or web/wq/admin/bogfipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: '7 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. " Records Retention [Supplements Section D. (6.)1 The Permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. Page 6 of 7 Permit NCO083658 - �Il • • • •� 1 �55 1� �1 Ci — ; .. .�•��a• , . HWY 421 nt� Oatfall 001Id (flows South) mt v L �1v1` V fAil� 'AI Sunnyvale � UT to Barnard's v Creek (flows S) ' Barnard's Creek -_ River Road j b ��'\ , 3rco�) '�' - � z � Daikin Applied Americas, Inc. [former] HeatCraft Site GW-REM Rxdvina Stream: B.T. C.&[g -regmmt I8-801 USES O."SUte Grid: Wdmmgtm NC/K-'N UiWde: N34'10'33" S.o-Bmm: 03-06-17 U. le v& W 77° 56' 14" HOC: 03030005 Dtaleaee li W Cape Fear Rivet Bast. Stream C1. C; Swamp Facility Location AORW [not to Scale] NPDES Permit NCO083658 North New Hanover County Page 7 of 7 AFFIDAVIT OF PUBLICATION STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Public Notice North Carolina Environmental Man- agement1617 Mail Service Commission/NPDES unit Before the undersigned, a Notary Public of Said County and State, Raleigh. NC 27699-1617 Notice of Intent to Issue a NPDES Wastewater Permit The North Carolina Environmental Jarim Springer y p ger Management Commission proposes to issue a NPDES wastewater dls- cha ge permit to the person(s) Written Who, being duly sworn or affirmed, according to the law, says that he/she is listed below. comments re- garding the proposed permit will be accepted until 30 days after the publish date of this notice. The Di- Accounting Specialist rector of the NC Division of Water Resources (DWR) may hold a public hearing should there be a signifi- of CA North Carolina Holdings, Inc., a corporation organized and doing business under the Laws cant degree of public interest. Please mail comments and/or in- of the State of North Carolina, and publishing a newspaper known as StarNews in the City of formation requests to DWR a[ the above address. Interested persons Wilmington may visit the DWR at 512 N. Salis. information nAdditional Raleigh, 1in Public Notice North Carolina Environmental Management CammissioWNPDES Unit 1617 formation on NPDES permits and Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES Wastewater this notice may be found on our website: Permit The North Carolina Environmental Management Commission proposes to issue a hbp lideq.nc govlabouVdivisionslwater- remmceslwafer+esourc o-permitslwmtmater. NPDE branchlnpdes-wastewatedpubiio-nobms,or by calling (919) 807-6397. Dalian Applied Americas, Inc. ap- plle l to renew NPDES permit NC0083658 to discharge treated groundwater from the Heatcraft W-REM site (602 Sunnyvale Dr.; Wilmington, New Hanover County) was inserted in the aforesaid newspaper insace, and on dates as follows: into an unnamed tributaryP Bamards Creek, Cape Fear River Basin. 1215 Ix And at the time of such publication Star -News was a newspaper meeting all the requirements and v� qualifications prescribed by Sec. No. 1-597 G.S. of N.C. Title: Accounting Specialist Sworn or affirmed to, and subscribed before me this _1y j—�_ day of D(-1-e1nbtr- ,A.D., XeIt.. In Testimony Whereof, I have hereunto set my hand and affixed my official seal, the day and day of Upon reading the aforegoing affidavit with the advertisement thereto annexed it is adjudged by the Court that the said publication was duly and properly made and that the summons has been duly and legally served on the de£endant(s). This day of Clerk of Superior Court MAIL TO: Corporon, Joe From: Corporon, Joe Sent: Friday, December 02, 2016 10:57 AM To: Hunkele, Dean; Gregson, Jim Subject: [Former] HeatCraft GW-REM, Wilmington - NC0083658 Dear WiRO - Paul Heim (Daikin) called me back to say he has talked to his operator onsite, and has been assured that the current treatment system "as is" maybe tuned to treat TCE to 1.0 ppb (-1.0 ug/L). Therefore, considering a likely permit -effective date of 01F62017, this permit will NOT require a "compliance period" to achieve limits. I will re-edit the permit and email, addressed to Paul/ cc to Ray Roblin (in Texas); copies to follow. Thanks Gentlemen, for your input. Respectfully, Joe R. Corporon, L.G. NCDEQ hm— �/ Nothing Compares 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. Corporon, Joe From: Hunkele, Dean Sent: Thursday, December 01, 2016 10:00 AM To: Corporon, Joe Cc: Gregson, Jim Subject: RE: Review and NPDES Permit DRAFT NC0083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Hey Joe, I wasn't sure if it had gone out given the letter is dated 12-14-16. Why can't we see and have chance to comment on these permits internally before they go out the door? TCE is too volatile to composite so that settles that item. So if the frequency is changed to 2x/month then will they get both a daily and a monthly limit? I have some concerns over the condition of the system even though I'm no expert on these things. They did hook new or additional shallow recovery wells which will likely have more iron which can cause issues per Tom Tharrington. Tom thinks 1.5-2 years would be a reasonable compliance schedule, but you should ask them if they need one and ask them to suggest timeframe. Lastly, Ray Roblin is in Plano, Texas last I heard not Minnesota. Paul Heim is in Minnesota I think. You should email a copy of this to Ray along with an add -info about new limit. Dean Hunkele Senior Environmental Specialist Water Quality Regional Operations Section Division of Water Resources Department of Environmental Quality 910.796.7215 Reception Desk 910.796.7380 Direct 910.350.2004 Fax Dean.Hunkele@ncdenr.go Wilmington Regional Office 127 Cardinal Drive Ext Wilmington, NC 28405 !-- 'Nothing Compares .� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if no additional information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once issued, the record stays on the site for 30 days. For previously issued sewer permit info or to check on sewer certification receipt status, please use the Division's Sewer Extension Permit Tracker. Using the Issue Date on top of the Engineer Certification Form is best way to ensure getting what you want especially for multi -version permits; using today's date only gives Info on the latest permit version. Confirmation using this method will replace letters and emails: it is recommended that confirmation he Printed and/or saved. Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources- Permits/pe res/coilection-system s-perm its Subscribe to Collection System Updates listserve to receive automatic alerts for changes to applications, policies, regulations, etc. From: Corporon, Joe Sent: Thursday, December 01, 2016 6:20 AM To: Hunkele, Dean <dean.hunkele@ncdenr.gov> Subject: FW: Review and NPDES Permit DRAFT NCO083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Dean — sorry, in accord with to 2B .0505, Class PC-1 for toxicants w/ limits should be monitored 2/Month minimum — my bad. But again this may be corrected w/o re -noticing. Joe From: Corporon, Joe Sent: Thursday, December 01, 2016 5:58 AM To: Hunkele, Dean <dean.hunkele@ncdenr.fov> Cc: Gregson, Jim <Iim.Rreason@ncdenr.gov>; Hennessy, John <lohn.hennessy@ncdenr.gov>; Chernikov, Sergei <sergei.chernikov@ncdenr.gov>;'Moore, Cindy' <cindv.a.moore@ncmail.net> Subject: RE: Review and NPDES Permit DRAFT NCO083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Dean — This has gone to Public Notice, but I see no issue that can't be resolved during the review period. 1. Regarding the monitoring frequency, 1/Month is consistent with Class PC-1 statewide. If they have compliance issues with their Monthly Average, they may volunteer to collect extra samples in an effort to remain compliant. I'll ask if this may be altered, or if that's preferable. 2. With flows averaging 0.112 MGD, I see no reason not to require Composite sampling, and we can add this to the permit final without re -notice. Your question however about TCE volatility is a good one. I will ask the Lab. 3. Concerning compliance with the new TCE limit of 3.0 ug/L (10x lower than the previous), I too documented your non-compliance concerns about the database during my RPA. My only suggestion is to soften the permit by adding a "compliance period," say two years (?), to allow the Permittee time to implement treatment system upgrades. Again, this is more stringent and would not require re -noticing the permit. Discussion? Respectfully, JoeR. Corporon, L.G. NCDEQ PC- -^Nothing Compares . 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. From: Hunkele, Dean Sent: Wednesday, November 30, 2016 4:55 PM To: Corporon, Joe <ioe.corporon@ncdenr.aov> Cc: Gregson, Jim <jim.gresson@ncdenr.eov>; Hennessy, John <john.hennessy@ncdenr.Rov> Subject: RE: Review and NPDES Permit DRAFT NCO083658 for [former] Heatcraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Importance: High Joe, We hope this hasn't gone out to Notice yet. Why is this facility allowed to do grab samples versus composite based on their flow limit? Material too volatile? In regards to the lower limit, our review of the data from BIMS shows they have violated this new limit about 50% of the time they have reported data since 1-2011(see attached). Consequently, we think they should have increased monitoring to weekly ideally or at least bi-monthly and consider a monthly average limit. They have violated the current daily limit several times and never get assessed based on current policy and would more likely do the same. An increased sampling frequency with the lower limit would require them to manage and maintain the system better than the currently do. See below that I lust got from the project manager. From: Raymond Roblin fmailto:correri@verizon.net l Sent: Wednesday, November 23, 2016 3:19 PM To: Hunkele, Dean <dean.hunkele@ncdenr.eov> Cc: steve.tyler10@ymail.com; Heim, Paul <Paul.Heim@daikinapplied.com> Subject: Former Heatcraft remediation site, effluent test result NC83658 Mr. Hunkele — Concerning the former Heatcraft remediation site, 602 Sunnyvale Drive in Wilmington (NC83658). As a follow up to the November 17 notification to your office of the effluent TCE concentration above the permit limit (42.3 ug/L or ppb); the system operator had rebalanced the influent flow rate and inspected the treatment system for any faults to determine the cause of the permit exceedance. No outward system faults were identified and the treatment plant systems were operating under normal conditions. The cause was likely greater or higher than average flow rates from the shallow aquifer system due to the heavy rainfall in the region from the hurricane. The higher than normal groundwater levels allowed for greater formation yield from the various pumping wells which likely provided higher flow rates through the treatment plant. With the rebalance of the influent flow rates, the follow on testing indicted the TCE fraction at 2.0 ug/L for testing on November 18. The two data results for November, when averaged, provides for a mean concentration of 22.6 ug/L for this month which should be considered compliant. I have instructed the operator to collect the December effluent sample at the end of next week (Dec 2), so we can have a secondary result to the November 18 data just to make sure we remain within our 30 ug/L permit limit for TCE. If you have any questions or concerns, please contact me. Cordially, Raymond Roblin PG CORR Environmental Resources, Inc. 972-303-1039 office direct 972-523-0487 wireless 972-534-1725fax correri@frontier.com Dean Hunkele Senior Environmental Specialist Water Quality Regional Operations Section Division of Water Resources Department of Environmental Quality 910.796.7215 Reception Desk 910.796.7380 Direct 910.350.2004 Fax Dean.Hu nkele@ncdenr.gov Wilmington Regional Office 127 Cardinal Drive Ext Wilmington, NC 28405 PC. -::11NothMg Compatms Email correspondence to and from this address is subject to the North Carolina Public Records Low and may be disclosed to third parties The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if no additional information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once issued, the record stays on the site for 30 days. For previously issued sewer permit info or to check on sewer certification receipt status, please use the Division's Sewer Extension Permit Tracker. Using the Issue Date on top of the Engineer Certification Form is best way to ensure getting what you want especially for multi -version permits; using today's date only gives Info on the latest permit version. Confirmation using this method will replace letters and emails: it is recommended that confirmation be printed and/or saved. Links to both trackers can be found on the sewer permitting site here: https://deo.nc.gov/about/divisions/water-resources/water-resources- permits/pe res/collection-systems-permits Subscribe to Collection System Updates Iistserve to receive automatic alerts for changes to applications, policies, regulations, etc. From: Corporon,Joe Sent: Wednesday, November 30, 201612:40 PM To: Paul.heim@daikinapplied.com Cc: Hunkele, Dean <dean.hunkele@ncdenr.gov>; Gregson, Jim <jim.areason@ncdenr.aov> Subject: Review and NPDES Permit DRAFT NCO083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County For your review and comment, as needed (see attached). Hardcopy to follow by mail. Respectfully, Joe R. Corporon, L.G. NCDEQ PC. !Nothing Compares � 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. Joe From: Sent: To: Corporon, Joe Thursday, December , 2016 5:58 AM Hunkele, Dean Cc: Gregson, Jim; Hennessy, John; Chernikov, Sergei; 'Moore, Cindy' Subject: RE: Review and NPDES Permit DRAFT NCO083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Attachments: 83658 HeatCraft DRAFT and Fact Sheet w sigs Nov2016.pdf Dean — This has gone to Public Notice, but I see no issue that can't be resolved during the review period. 1. Regarding the monitoring frequency, 1/Month is consistent with Class PC-1 statewide. If they have compliance issues with their Monthly Average, they may volunteer to collect extra samples in an effort to remain compliant. I'll ask if this may be altered, or if that's preferable. 2. With flows averaging 0.112 MGD, I see no reason not to require Composite sampling, and we can add this to the permit final without re -notice. Your question however about TCE volatility is a good one. I will ask the Lab. 3. Concerning compliance with the new TCE limit of 3.0 ug/L (1 Ox lower than the previous), I too documented your non-compliance concerns about the database during my RPA. My only suggestion is to soften the permit by adding a "compliance period," say two years (?), to allow the Permittee time to implement treatment system upgrades. Again, this is more stringent and would not require re -noticing the permit. Discussion? Respectfully, Joe R. Corporon, L. G. NCDEQ N:. !/ Nothing Compares , 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. From: Hunkele, Dean Sent: Wednesday, November 30, 2016 4:55 PM To: Corporon, Joe <joe.corporon@ncdenr.gov> Cc: Gregson, Jim <jim.gregson@ncdenr.gov>; Hennessy, John <john.hen nessy@ncdenr.gov> Subject: RE: Review and NPDES Permit DRAFT NCO083658 for [former] HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County Importance: High Joe, We hope this hasn't gone out to Notice yet. Why is this facility allowed to do grab samples versus composite based on their flow limit? Material too volatile? In regards to the lower limit, our review of the data from BIMS shows they have violated this new limit about 50% of the time they have reported data since 1-2011(see attached). Consequently, we think they should have increased monitoring to weekly ideally or at least bi-monthly and consider a monthly average limit. They have violated the current daily limit several times and never get assessed based on current policy and would more likely do the same. An increased sampling frequency with the lower limit would require them to manage and maintain the system better than the currently do. See below that I must got from the aroiect manager. From: Raymond Roblin fmaiito:correri@verizon.net] Sent: Wednesday, November 23, 2016 3:19 PM To: Hunkele, Dean <dean.hunkele@ncdenr.gov> Cc: steve.tvierl0@vmail.com; Heim, Paul <Paul.Heim@daikinapolied.com> Subject: Former Heatcraft remediation site, effluent test result NC83658 Mr. Hunkele —Concerning the former Heatcraft remediation site, 602 Sunnyvale Drive in Wilmington (NC83658). As a follow up to the November 17 notification to your office of the effluent TCE concentration above the permit limit (42.3 ug/L or ppb); the system operator had rebalanced the influent flow rate and inspected the treatment system for any faults to determine the cause of the permit exceedance. No outward system faults were identified and the treatment plant systems were operating under normal conditions. The cause was likely greater or higher than average flow rates from the shallow aquifer system due to the heavy rainfall in the region from the hurricane. The higher than normal groundwater levels allowed for greater formation yield from the various pumping wells which likely provided higher flow rates through the treatment plant. With the rebalance of the influent flow rates, the follow on testing indicted the TCE fraction at 2.0 ug/L for testing on November 18. The two data results for November, when averaged, provides for a mean concentration of 22.6 ug/L for this month which should be considered compliant. I have instructed the operator to collect the December effluent sample at the end of next week (Dec 2), so we can have a secondary result to the November 18 data just to make sure we remain within our 30 ug/L permit limit for TCE. If you have any questions or concerns, please contact me. Cordially, Raymond Roblin PG CORR Environmental Resources, Inc. 972-303-1039 office direct 972-523-0487 wireless 972-534-1725fax correri@frontier.com Dean Hunkele Senior Environmental Specialist Water Quality Regional Operations Section Division of Water Resources Department of Environmental Quality 910.796.7215 Reception Desk 910.796.7380 Direct 910.350.2004 Fax Dean. Hunkele@ ncdenr.Rov Wilmington Regional Office 127 Cardinal Drive Ext Wilmington, NC 28405 -��Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if no additional information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once issued, the record stays on the site for 30 days. For previously issued sewer permit info or to check on sewer certification receipt status, please use the Division's Sewer Extension Permit Tracker. Using the Issue Date on top of the Engineer Certification Form is best way to ensure getting what you want especially for multi -version permits; using today's date only gives info on the latest permit version. Confirmation using this method will replace letters and emails, it is recommended that confirmation be printed and/or saved. Links to both trackers can be found on the sewer permitting site here: https://dea nc gov/about/divisions/water-resources/water-resources- perm its/peres/col lectio n-syste ms-perm its Subscribe to Collection System Uodates listserve to receive automatic alerts for changes to applications, policies, regulations, etc. From: Corporon, Joe Sent: Wednesday, November 30, 2016 12:40 PM To: paul.heim@daikinapplied.com Cc: Hunkele, Dean <dean.hunkele@ncdenr.Rov>; Gregson, Jim <Iim.Rregson@ncdenr.Rov> Subject: Review and NPDES Permit DRAFT NCO083658 for [former) HeatCraft GW-REM , 602 Sunnyvale Drive, Wilmington, New Hanover County For your review and comment, as needed (see attached). Hardcopy to follow by mail. Respectfully, Joe R. Corporon, L.G. NCDEQ PC- !-Nothing Compares - rDA/K/N Daikin Applied Americas Inc. Permit Renewal Application Former Heatcraft Remediation Site 602 Sunnyvale Drive New Hanover County Wilmington, North Carolina NPDES Permit NCO083658 NCD 057 451 270 June 2016 Prepared bv: CORKEnvironmental Resources Inc. Project Number #3081 (16) RECEIVED/NCDEQ/DWR JUN 1 u 2016 Water Quality Permitting Section Environmental Resources, Inc. June 9, 2016 Ms. Wren Thedford NC DEQ/DWQ/Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Re: 2016 Permit Renewal Application .. NPDES Permit # NCO083658 Daikin Applied Americas, Inc. Former Heatcraft Remediation Site 602 Sunnyvale Drive, Wilmington Ms. Thedford: CORR Environmental Resources Inc. (CORR) as an authorized representative of Daikin Applied Americas, Inc. (DAA) is submitting one original and two copies of the enclosed request for a NPDES permit renewal for existing permit number NC0083658. The renewal application is in reference to the groundwater remediation water treatment system at the former Heatcraft property located at 602 Sunnyvale Drive in Wilmington, New Hanover County. The environmental remediation is overseen by the NCDEQ Hazardous Waste Section (HWS) with EPA ID# 057 451270. The following items are included with the renewal application: • NPDES Permit Application — Short Form C-GW; • Letter of delegation by DAA for CORR to act as an Authorized Representative to prepare and submit the application; • A topographic map indicating the location of the property and the outfall location; • An Expanded Site Plan presenting prominent site features including the outfall 001 location along with longitude and latitude coordinates; • A signed narrative description of the sludge management plan for the facility; and • A data summary (as Table 1) of the monthly 2015-2016 effluent and quarterly influent laboratory testing results. Also included is the most recent aquatic toxicity testing report for the quarterly discharge sampling conducted in May 2016. Since the last permit renewal in 2011 and as recommended and approved by the HWS in 2014, a phase separation hydrocarbon recovery system was installed in one area of the site property. One additional recovery well was added to the extraction well array as EW-8. EW-8 was installed within a backfilled excavation where high concentration soil _ contamination was remediated in calendar year 2012. The extraction well was installed to a depth of approximately 6-ft below ground surface to collect residual groundwater impacted with latent hydrocarbon liquids and dissolved chlorinated solvents such as trichloroethene (TCE). 4609 Candlestick . Garland,Texas 75043 • Phone (972) 303-1039 . Fax (972) 534-1725 Email: correri@verizon.net =Environmental Resources, Inc. Ms. Wren Thedford June 9, 2016 ^' Page 2 The hydrocarbon liquids are a mixture of mineral and motor oils with minor percentages of diesel fuel and kerosene type products in the matrix. The recovery operation uses air lift pumps which collect free phase liquids for transfer to a 500-gallon separation tank. ., The separation tank acts to skim the hydrocarbon liquids from the influent after settling for collection to DOT approved 55-gallon drum(s). The resultant hydrocarbon product is then properly disposed of at an offsite permitted hazardous waste disposal site. As required for the permit renewal application and with the new hydrocarbon influent, effluent samples were collected for semi -volatile organic constituent analysis (SVOC) using EPA Method 8270 by a North Carolina certified laboratory [SGS Laboratory, NC#481]. Total lead testing was also conducted using SW846 Method 6010. No SVOC or lead constituents were indicated above the various laboratory Method Detection Limits (MDLs). Effluent is also tested on a monthly basis for the full VOC constituent analysis using EPA Method 8260B. The May 2016 analytical testing report is appended to the renewal application. The attached drawings are presented to provide the DWQ with the following information: • Effluent outfall location map, USGS Wilmington topographic (FIG 1); • The expanded site plan showing the full system layout and locations of various recovery wells, monitoring wells, treatment system, lift station and the NPDES effluent outfall [001] (FIG 2); • The conceptual process flow diagram (DWG 2); .. • The lift station piping layout (DWG 5); • The treatment system layout including the separation tank and drum container for phase separated product collection (DWG 12); ., • Separator Profile Drawing (FIG 14); and • The treatment system equipment and pad layout (DWG 22). RECEIVEDINCDENWR Contact information for DAA: JUN 16 2016 Mr. Paul M. Heim water Quality Daikin Applied Americas, Inc. Permitting Section .. Legal Department 13600 Industrial Park Blvd. Minneapolis, MN 55441 (651)335-9761 Contact information for CORR as the Authorized Representative: Mr. Raymond Roblin PG Principal Hydrogeologist 4609 Candlestick Garland, TX 75043 972-523-0487 ., Former Heatcraft Site NPDES #NC0083658 Environmental Resources, Inc. Ms. Wren Thedford June 9, 2016 Page 3 If there are any questions concerning the renewal application or for the site in general, please contact me at the above referenced phone number or via email at correriCcDverizon.net. Thank you for you consideration of the application. Cordially, CORR Environmental Resources Inc. Raymond Roblin, PG Principal Cc: Mr. Paul Heim — DAA RECEIVED/NCDEWWR Steve Tyler; ORC and Site File JUN l 0 2015 Enclosures Water Quality Permitting Section File: c:\CORRDOCS\WilmingtomNPDES Issues\2016 Files\2016 permit renewal cvr Itr. doc - r .. Former Heatcraft Site NPDES #NC0083658 am Site History Daikin Applied Americas, Inc., (formerly AAF-McQuay Inc), a successor to the 04 Refrigeration Products Group of SnyderGeneral Corporation, was the former owner of the Heatcraft facility. The facility is located in New Hanover County at 602 Sunnyvale Drive, Wilmington, North Carolina. SnyderGeneral Corporation sold the Heatcraft facility ,-, in 1986 to Lennox Industries Inc. who then sold the property to Port City Supply in late 2010. Lennox Industries continued to operate the manufacturing facility until 1988 when the plant was shut down. In 1996, vacant space in the plant building was leased to fm International Paper and ultimately to Port City Supply who currently operates as S&R Packing and Crating. S&R provides shipping services to local entities. S&R is not involved with the groundwater remediation program at the property and does not utilize any hazardous materials or generate any hazardous wastes. Am Former manufacturing operations by the Refrigeration Products Group and Lennox at the facility included the fabrication of heating and air conditioning equipment. Historically an the fabrication of air conditioning involved the stamping and machining of various metals into refrigeration coils which required cleaning prior to testing and shipping. The cleaning typically involved mechanical vapor degreasing using the organic solvent ffim trichloroethene (TCE). The use of TCE was discontinued and was replaced with 1,1,1 trichloroethane (TCA). The facility recorded a release of TCA of approximately 400 to 500-gallons in 1983 on the northwest side (rear) of the plant building. A second release of approximately 55- gallons of TCA occurred in July 1987 also in the rear of the building. Subsequent to these releases, the DEHNR — Division of Solid Waste Management required closure of the second TCA release area by capping and implementation of a quarterly groundwater monitoring program. In addition to the two TCA releases, the facility also experienced a localized release of fuel oil from underground storage tanks on the southwest corner of the property. DAA began groundwater remediation from a single extraction well at the site in 1994. Groundwater treatment was effected by air stripping technology to remove the volatile organic compounds. During this initial phase of groundwater remediation no attempt was made to address the localized fuel oil issue resulting from the UST release. In 2000 DAA authorized the removal and replacement of the existing air stripping equipment with replacement with newer technology for greater efficiency. Concurrent with that project, additional groundwater extraction wells were installed to better control the contamination plume beneath the plant building along Sunnyvale Drive. f" em oft T f The attached Figures identify the site as it currently exists for the proposed NPDES discharge permit. The following Figures are appended to the renewal application: Figure 1 — The USGS topographic map, 1:24,000 scale, Wilmington, North Carolina 1969, photo revised 1993. The map presents the approximate location of the single treatment system effluent outfall. Figure 2 — The Expanded Site Plan base map identifying all pertinent site features and landmarks including improvements and wells. Drawing 2 — The conceptual process flow diagram of the groundwater treatment system IM as currently configured. Drawing 5 — Depicts the year 2000 lift station at extraction well EW-3, updated as of June 2011. Extracted groundwater from EW-3 and recovery wells EW-2, EW-4 and EW- "" 5, located parallel to Sunnyvale Drive manifold via double walled piping to a lift station. The collected groundwater is then transferred from the lift station, via double walled piping, over and across the roof of the plant building to the treatment system at the rear of the plant building. MM Drawing 12 — Depicts the layout of the treatment system as it is currently configured. Drawing 14 — Oil separator detail plan. e" Drawing 22 — Presents a detailed layout of the treatment system. The only modification made to the groundwater treatment and extraction system at the site since the 2011 NPDES permit renewal was the addition of one shallow extraction well for removal of latent free phase hydrocarbons on the rear of the property. This extraction well, coupled with pre-existing wells EW-101 and EW-7, were fitted with pneumatic lift pumps for transfer to a separation tank. The separation tank acts to settle (float) the liquid hydrocarbons for skimming to 55-gallon accumulation drum for proper offsite disposal. The resultant nuisance water is then allowed to gravity feed to the primary accumulation tank and to the air stripping treatment unit. The air stripping treatment process has remained the same. The receiving water ditch on the south side of the property flows to the east and Sunnyvale Drive where it flows via a culvert to the ditch parallel to Sunnyvale Drive to the south where it flattens to a low lying area to the east toward Barnards Creek. Barnards Creek is a local tributary to the Cape Fear River at a distance of several miles from the outfall. The system contaminant load and source of the impacts remain as in previous permit renewals. rM go 0" 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 FM Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC . 27699-1617 NPDES Permit Number INCO083658 If you are completing this form in computer use the TAB key or the up - down arrows to move from one a field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type. 1. Contact Information: M" Owner Name Daikin Applied Americas, Inc. Facility Name Former Heatcraft Remediation Site Mailing Address 13600 Industrial Park Blvd City Minneapolis State / Zip Code MN 55441 Telephone Number (651)335-9761 Fax Number (763)553-5302 e-mail Address paul.heim@daikinapplied.com rya 2. Location of facility producing discharge: Check here if same as above ❑ Street Address or State Road 602 Sunnyvale Drive City Wilmington State / Zip Code NC 28412 County New Hanover 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 CORR Environmental Resources, Inc. Mailing Address 4609 Candlestick Drive City Garland State / Zip Code TX 75043 Telephone Number (972)523-0487 Fax Number (NA)email correri@verizon.net 4. Ownership Status: Federal ❑ State ❑ Private ® Public ❑ om Page 1 of 3 C-GW 03l05 O, am NPDES PERMIT APPLICATION - SHORT FORM C - GW ' For discharges associated with groundwater treatment facilities. 5. Products recovered: Gasoline ❑ Diesel fuel ❑ Solvents ® Other 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: S. Treatment System Design flow 0.36 MGD Duration: 9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitudep. OR Unnamed tributary of Barnards Creek 10. Please list all additives to the treatment system, including chemicals or nutrients, that have MR the potential to be discharged. PW MR None added. 11. Is this facility located on Indian country? (check one) `m 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) 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. Page 2 of 3 C-GW 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. 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. Raymond Roblin Authorized Aeent for Daikin Applied Printed name of Person Signing Title Signature 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 G-GW 03105 Cl F,'DAFKJFN June 8, 2016 Ms. Wren Thedford NC DEQ/DWR/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Re: NPDES Permit # NCO083658 Former Heatcraft Remediation Site 602 Sunnyvale Drive, Wilmington 2016 Renewal Application Delegation of Authority _ Ms. Thedford: Daikin Applied Americas, Inc. (DAA) delegates Mr. Raymond Roblin of CORR Environmental Resources Inc. (CORR) to act as our Authorized Representative to prepare and submit the NPDES permit renewal application for the active permit referenced above. Mr. Roblin with CORR will act to respond to any agency questions and requests for additional information as needed. Upon permit renewal, Mr. Roblin will continue to act as the Authorized Representative for discharge monitoring report submittals. Cordially, Daniel R. Donoghue Assistant Secretary Senior Attorney _ cc: Raymond Roblin P.G. - CORR _ _ _ _ Daikin Applied Americas Inc. World Headquarters 13600 Industrial Park Boulevard Minneapolis, MN 55441 763-553-5330 Sludge Management Former Heatcraft Remediation Site NC0083658 Currently no sludge or solid wastes are generated during the groundwater treatment activities. No industrial waste water is included in the influent stream and site related groundwater contaminants are volatile organic compounds (VOCs); primarily trichloroethene (TCE), and 1,1,1 trichloroethane (TCA) and their degradation breakdown products dichloroethene and vinyl chloride. The VOC contaminants are off -gassed during the air stripping operation and no residuals remain after treatment. The only solid waste generated is accumulated dirt (sediments) and windblown sand which collects in the secondary containment area sump. These solids can include pine tree needles and leaves which are removed as warranted maintaining operation of the sump. These solids are removed from the sump and placed in DOT approved 55-gallon drum for nearly immediate disposal. The removal of sediments/solids from the sump happens on average every two years or greater. The drum is properly disposed of as hazardous waste by contract to an approved vendor to Daikin Applied. Waste disposal transport manifest(s) and disposal certification documents are filed on site when received from the vendor. The basic groundwater recovery system now includes the use of two additional groundwater extraction points (shallow wells) at the rear of the facility as a change from the 2011 permit renewal application. These two additional extraction point wells were required by the NCDEQ Hazardous Waste Section. The remedial activity removes free phase hydrocarbon liquids (primarily diesel fuel, motor and mineral oils). These liquids are piped to an above ground tank (-500-gallons) which uses gravity separation to skim the hydrocarbons from the influent groundwater. The skimmed hydrocarbon liquids are containerized in DOT approved 55-gallon drums. The skimming operation typically recovers less than one 55-gallon drum on a semiannual basis. The separated groundwater is then added to the other dissolved solvent recovery well influent(s) to the air stripping treatment units. The skimmed/separated hydrocarbon liquids are then containerized in DOT approved 55-gallon drums and properly disposed of as a hazardous waste (F002 and/or D043) as required by law. Raymond Roblin; CORR ERI Authorized Representative Printed Name of Person Signing Title .. /Z' ldi:z G- Signature Date M L1 M M Table 1 2015-16 Effluent Testing Results Former Heatcraft Site Sample Sample pH 1,1 DCA c-1,2 DCE 1,1 DCE TCE 1,1,1 TCA VC 1,4 dioxane Total Date Identification ppb ppb ppb ppb ppb ppb ppb VOC's Class C Surface Water 20.000 ug/L 4,900 ug/L 5,400 ug/L 30 ug/L Not Listed 2.4 ug/L 28 HH Standard 100 ug/L 720 ug/L 7.1 ug/L 30 ug/L NIL 2 4 ug/L 80 ug/L 5/5/2015 influent 126 2080 169 771 352 84.1 3582.1 T=21.7 effluent 7.13 <1 <1 <1 <1 <1 <1 30A 6/3/2015 influent NT NT NT NT NT NT 0 T=22.3 effluent 7.72 <1 <1 <1 <1 <1 <1 7/10/2015 influent NT NT NT NT NT NT 0 T=24.8 effluent 6.38 <1 2.39 <1 <1 <1 <1 8/13/2015 influent NT NT NT NT NT NT 0 T=23.9 effluent 7.73 <1 <1 <1 <1 <1 <1 9/11/2015 influent NT NT NT NT NT NT 0 T=25.3 effluent 6.55 <1 1.28 <1 4 <1 <1 17.6 10/17/2015 influent NT NT NT NT NT NT 0 T=21.6 effluent 6.38 <1 <1 <1 <1 <1 <1 11/3/2015 influent NT NT NT NT NT NT 0 T=24.4 effluent 6.59 <1 <1 <1 <1 <1 <1 12/8/2015 influent NT NT NT NT NT NT 0 T=19.7 effluent 8.01 <1 <1 <1 <1 <1 <1 1/11/2016 influent NT NT NT NT NT NT 0 T=19.5 effluent 7.69 <1 <1.0 <1 <1 <1 <1 2/4/2016 influent NT NT NT NT NT NT 0 T=21.2 effluent 7.66 <1 9.12 <1 <1 <1 <1 29.9 3/17/2016 influent NT NT NT NT NT NT 0 T=21.8 effluent 8.44 <1 2.63 <1 <1 <1 <1 4/11/2016 influent NT NT NT NT NT NT 0 T=21.5 effluent 8.38 <1 7.91 <1 <1 <1 <1 5/10/2016 influent 85.2 1370 123 506 156 137 2377.2 T=22.8 effluent 7.71 <1 18.6 <1 2.11 <1 <1 19.6 Notes; 1,1 OCA= dichloroethane; 1,1 DCE = dichloroethene; cis-1,2 DCE = cis dichloroethene; 1,1,1 TCE= trichloroethane TCE = trichloroethene; VC = vinyl chloride; 1,4 dioxane. nr� n.� NCD0083658 Former Heatcraft iff Vertex Railcar (former Terex Crane) 202 Raleigh Street No W-1 BNW-Q Q EW-8 C \ NPDE: Outfall Building E1lV-, Q EW-7 Long: 77. 56' 2" Lat: 34. 10' 41" f Treatment Plant EWE ♦a MW-2A \ Former Heatcraft Building \L 602 Sunnyvale Dr. _ single story high bay ceiling \ cinder block and steel construction NPDES Permit # NCO083658 American Property Experts \ 606 Sunnyvale Dr. (formerly Praxair/National \ FNW-4A FNW 4 L�W�l ��------------- SevenTen LLC Welders Supply) --- ---- EW-3Q�FNvV 4 710 Sunnyvale Dr. EW- _ __ (Bradford Products) Sunnyvale Dr OSW-2 i OSW-4 Cameron Company Ltd. _ .�� -�^" � (upland area with (/ pine and live oak) l l I Undeveloped Low Lying Area Tributary of Bernards Creek 0 MW-13 EW-4 FW-2C North Creek I IFNW-2A FNW-2B / f�IFNW-2 / f / Paved Driveway & Parking 0 F1 EW-S Q0F OF City of Wilmington Easement for sanitary sewer OSW-'1 e CAM-2 Q50SW--Io - Groundwater monitoring well locations / Q - Active groundwater recovery wells OSW$ 0 CAM-1 R Undeveloped I 0 7 A Residential a _ APPROVED BY: RAYMOND W ROBLIN TEXAS L.G. NO.: 1732 0 09 05-05 Initial drawing FIGURE 2 1 06-06-11 - Revised for NPDES renewal application. ME71NNVIRONMENTALRESOURCES, INC. DATE: JUNE 9, 2016 EXPANDED SITE PLAN MAP 2 06-09-16 Revised for NPDES renewal application; Add EW-8 DESIGNED BY: RWR CHECKED BY: RWR Former Heatcraft Facility Wilmington, North Carolina VERIFYSCALES: NOscALEINTENDED 4609Candlestick, Garland, Tx75043 DRAWING NO.: ESP 3082 16 NO SCALE INTENDED PROJECT: PN 3082 (16) FILE: C:ICORROAAMILMCADDIscrexp.map I -; u ... All _/' - .; •r. `.. it .*::aTolks ! �� t•. ..Talks • so- -�"- �� iLLT ��•• go''. Tenk,r -�SITEEE� ' OUT. ALL LOCH ON I ��1�' ••� •s 'i1 ' - 1 1 � t ` T"" aar cam• -. a \ _'A ! 1 Source: Wilmington, North Carolina ji j Environmental Resources, Inc USGS 1969, Photorevised 1993 Scale 1:24,000 FIGURE I EFFLUENT OUTFALL LOCATION Fortner Heatm Facility Wilmington, NC ttnwN: RWR 1ATe:09-27-02 ' : 3034 EVISION: NOR I rf PV'D: RWR FILE-. 0 e:'eaddlwilmin nbutfatl z NEW MAIN,; AND PUMP 3" SDR I1 3" ADAPTOR SI)R 11 HDPE WELD N FNP 3" ADAPTOR VC SCH 80 FS X 'PT_ 3" PVC SCH 80 IPE 3" PVC SCH 80 90 ELL FS X FS I INSTALL 3'-0" DIA. ACCESS W/ LIP FOR UNISTRUT SUMP SURGE/TRANSFER TANK INSTALL NEW 4" STEEL PIPE FOR TANK OUTLET -1 FOOT OFF TANK 130TTOM AND CLAMPS FOR PIPE TANK SECONDARY CONTAINMENT I 8'-0" 2'-0" 9'-0" 2 -0" --------- ---- -- 3 I f I AIR STRIPPER 1 I 6'-0" AIR STRIPPER PUMPS AND 1 TRAYS GAUGES 1 I 1 I 9'-0" j LI CTRICAL 500-gal HYDROCARBON j ANEL SEPARATION TANK- I ETBACK I 55-gal RECOVERY DRUM I I ELECTRICAL P^ ANEL�I TRAY I ELECTRICAL I I I MAINTENANCE I PANEL I 6-1114"1 AREA I SETBACK --_.__. I I I ENVIRONMENTAL RESOURCES, INC. 4609 Candlestick Dr., Garland, TX APPROVED BY: SCOTT S. HUISMANN NORTH CAROLINA P.E. NO.: 23779 DATE: MARCH 20, 2000 DESIGNED BY: FRE CHECKED BY: SSH DRAWING NO.: 3036-22 PROJECT: ARN 003036 AIR STRIPPER I AIR STRIPPER TRAYS PUMPS AND GAUGES 3" FLANGE ADAPTOR ,3" FLANGE ADAPTOR 3" FLANGED CHECK VALVE 3" FLANGE ADAPTOR ELECTRICAL PANEL -9" I TRAY I ELECTRICAL MAINTENANCE I PANEL I AREA SETBACK I J I — 6'_6" L J Y CONTAINMENT BERM 0 03/20/00 FINAL DRAWING -RELEASE FOR CONSTRUCTION 1 12/20/00 JAS BUILT REVISIONS - POST CONSTRUCTION 2 6/07116 ' REVISED; ADD HYDROCARBON SEPARATION SYSTEM VERIFY SCALES: IF SCALE DOES NOT MATCH BAR ADJUST ACCORDINGLY 4-0" 3'_0" 2'_0" V-0" 0 4'_0" 8-_0„ 1 = 4'-0 RAMP OFFICE DRAWING 22 EQUIPMENT AND PAD LAYOUT Former HeatCraft Facility Wilmington, North Carolina FILE: C:\CORRIDAAIW I LM INGTON\I M W\DES IGN\DRAWINGS\DW G22.TON I r r MAP OF SURVEY FOR CORR ENVIRONMENTAL OF THE FORMER HEATCRAFT FACILITY CITY OF WILMINGTON - NEW HANOVER COUNTY NORTH CAROLINA SCALE: 1 INCH = 40 FEET DATE: NOVEMBER 29, 1999 ROBERT H. GOSLEE & ASSOCIATES, P.A. LAND SURVEYORS - LAND PLANNERS 513 CHESTNUT ST. WILMINGTON, NC 2940 (910) 763-1941 EMAIL: rhgilm@cape-fearm O 4� SAY ZA.Z��' TO DRAWING 30�7A ENVIRONMENTAL RESOURCES, INC. 4609 Candlestick Dr., Garland, TX ►1 N � P \\4"DR 11 DUAL WALL HDPE %0� FROM LIFT5TATION / 6" THICK REINFORCED CONCRETE PATCH FOR TRUCK TRAFFIC REFER TO DWG 3036-23 125 OFFICE :i KEEP THREE FOOT BUFFER AROUND ALL SIDES EXCEPT TANK TWO QED EZ-24.6SSAIR STRIPPER G�� 50 APPROVED BY: SCOTT S. HUISMANN NORTH CAROLINA P.E. NO.: 23779 DATE: MARCH 20, 2000 DESIGNED BYSSH CHECKED BY: SSH DRAWING NO.3036-1 2 PROJECT: ARN 003036 REFER TO DRAWING 22 FOR MORE DETAIL PIPE RACK FOR VALVES AND FLOW METERS CHANGED FROM PVC TO HDPE PIPE USE EXISTING PIPE FROM EW-1 USE EXISTING PIPE FROM EW-1 yq+ 0 03/20/001 FINAL DRAWING - RELEASE FOR CONSTRUCTION 1 6107/16 1 REVISED TO ADD HYDROCARBON SEPARATION SYSTEM VERIFY SCALES: IF SCALE DOES NOT MATCH BAR ADJUST ACCORDINGLY 60, 40' 20' 0 30' 60' 90, 120' 150' 180' 1"= 60' LEGEND: ® ROOF VENT ROOF DRAIN © SANITARY SEWER MANHOLE ® FIRE HYDRANT MONITORING OR REMEDIATION WELL O REMEDIATION MANHOLE POWER LINE \o POWER POLE WITH GUY WIRES AREA LIGHT FENCE FENCE POST TELEPHONE LINE GAS LINE DRAWING 12 TREATMENT SYSTEM LAYOUT Former HeatCraft Facility Wilmington, North Carolina F I LE: C:\CORR\DAA\W I LM I NGTON\I M W\DES IGN\DRAWINGS\DWG12 f- F rF- LEGEND: ROOF VENT ROOF DRAIN POWERLINE ® SANITARY SEWER MANHOLE \o ® FIRE HYDRANT POWER POLE WITH GUY WIRES ® FNW-# MONITORING WELLS N 1K AREALIGHT FENCE EW-3 REMEDIATION WELL o FENCE POST O REMEDIATION MANHOLE TELEPHONE LINE GAS LINE REMEDIATION SYSTEM COMPONENTS 6" THICK CONCRETE SLAB REFER TO DRAWING 3036-21 APPROX. 3,000 GAL. STAINLESS STEEL TANK W/ SECONDARY CONTAINME 00 3'-8. � sr-4B O�. 6-1- 12" DIA. SDR 26 PIPE 0 70' MAX. BEND 10" DIA. HDPE SDR 26 PIPE 1 E�ENVIRON)II,?NTAL RE:SoURCII? S, INi;. 4609 Candlestick Dr., Garland, TX US (TYP APPROVED BY: SCOTT S. HUISMANN NORTH CAROLINA P.E. NO.: 23779 DATE: JUNE 13, 2000 DESIGNED BY: FIRE CHECKED BY: SSH DRAWING NO.: 3036-05 PROJECT: ARN 003036 PLANT STORM DRAIN BUFFER ---------- SANITARY SEWER BUFFER ZONE 10" DIA. HDPE SDR 26 PIPE __ - _ # 1115) J — -- - PtiE Dg1VE fig. g. - CIL NOTE: THE BOUNDARY LINE HAS NOT BEEN SURVEYED. IT WAS TAKEN FROM AN UNRECORDED MAP DONE BY JACK G. STOCKS, R-L.S. DONE IN .NNE OF 1988. THE RIGHT OF WAY OF SUNNYVALE ROAD IS SHOWN ON THIS MAP IS 60 FEET. THIS RIGHT OF WAY DISTANCE WAS OBTAINED FROM THE CITY SURVEYOR FOR THE CITY OF W a IINGTON. THE CITY OF W ILMINGTON MAINTAINS SUNNYVALE ROAD. 0 03/20/001 FINAL DRAWING - RELEASE FOR CONSTRUCTION 1 06/13/00 AS -BUILT WELL LOCATION, REVISED PIPING ROUTE 2 12/20/00 JAS BUILT REVISIONS - POST CONSTRUCTION VERIFY SCALES; IF SCALE DOES NOT MATCH BAR ADJUST ACCORDINGLY 10' 8' 6' 4' 2' 0 5' 10, 15' 20' i SCALE: 1" = 10' MAP OF SURVEY FOR CORR ENVIRONMENTAL OF THE FORMER HEATCRAFT FACILITY CITY OF W ILMINGTON - NEW HANOVER COUNTY NORTH CAROLINA SCALE: I INCH=40 FEET DATE: NOVEMBER 29, 1999 ROBERT H. GOSLEE & ASSOCIATES, P.A. LAND SURVEYORS - LAND PLANNERS 513 CHESTNUT ST. WILMINGTON, NC 29401 (910)763-1941 EMAIL: rhgilm@cape-fear.net DRAWING 5 WELL EW3, PIPING, AND LIFT STATION LAYOUT Former HeatCraft Facility Wilmington, North Carolina FILE: C:\CORR\DAA\WILM I NGTOW M W\DES IG N\DRAW I NGS\DWG05.TCW A 7 1 1 1 1 1 0 1 1 1 9 1 TO NPDES 001 DISCHARGE EFFLUENT OTALIZE R; METER J WELLS AND EQUIPMENT LOCATED IN THE BACK OF THE FACILITY — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — I - �500-GAL HYDROCARBON EXFIAUST TO ATMOSPHERE EXHAUST TO ATMOSPHERE SEPARATION TANK I I I I I I I I I I I I WELL WELL WELL EW-7 EW-1 EW-8 AIR LIFT AIR LIFT AIR LIFT L- - - - - - - - - - - - - 55-(iAL.LUN I)RUM FREE PRODUCT YDROCARBONSTORAGE: WELL # EW-6 BEDROCK [Electric] --------------- Y GRAVITY ROM SEPAF F - - - PRIMARY ACCUMULATION TANK W/ SECONDARY CONTAINMENT SECONDARY CONTAINMENT I AIR IN AIR IN I I I I I I I I LOW PROFILE AIR STRIPPER I I ------------------------� LEGEND O ► FLOW -IMF- CHECK VALVE I I -Ckl- BALL VALVE I I WELL PUMP I I � HOLE IN PIPE FOR , ® SUMP PUMP FREEZE PROTECTION I I I CENTRIFUGAL PUMP OGRESSIVE CAVITY O OR BLOWER FAN FLROW METER © TOTALIZER 12 SUMP PUMP I STAINLESS STEEL WELL SCREEN WELL WELL WELL WELL HDPE MANHOLE T STATION TANK I EW-2 EW-3 EW-4 EW-5 W/ SECONDARY HALLOW AQUIFER ELECTRIC PUMPS CONTAINMENT I--- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - J WELLS AND LIFT STATION EQUIPMENT LOCATED IN THE FRONT OF THE FACILITY 1 ' ' ENVIRONMENTAL RESOURCES, INC. 4609 Candlestick Dr., Garland, TX APPROVED BY: SCOTT S. HUISMANN NORTH CAROLINA P.E. NO.: 23779 DATE: DECEMBER 20, 2000 DRAWN BY: FIRE CHECKED BY: SSH DRAWING NO.: 3036-02 PROJECT: PN 3036 - PN 3082 (16) 0 03/201001 FINAL DRAWING - RELEASE FOR CONSTRUCTION 1 12/20/00 AS BUILT REVISION -POST CONSTRUCTION 2 06117/2011 REVISED FOR 2011 NPDES PERMIT RENEWAL 3 6/07/2016 REVISED FOR 2016 NPDES PERMIT RENEWAL; ADD HYDROCARBON SEPARATION SYS VERIFY SCALES: IF SCALE DOES NOT MATCH BAR ADJUST ACCORDINGLY NOT TO SCALE DRAWING 2 CONCEPTUAL PROCESS FLOW DIAGRAM Former HeatCraft Facility Wilmington, North Carolina FILE: C:\CORR\DAA\WILMINGTOMIMW\DESIGMDRAWINGSIDRAWING02 Influent from Recovery Wells Old EW-1, EW-7 and EW-B AIR STRIPPER ACCUMLATION TANK All Equipment Located within Treatment System Secondary Containment Environmental Resources, Inc Drawn By: ST I Checked By: RWR Vent Free -Phase Product GRAVITY SEPARATOR 500 GALLON Daikin Applied Former HeatCraft Site Wilmington, NC Project: 2100801/3077(14) Diffuser Screen Product Drain Valve To 55-Gal DOT Drum FIGURE 14 SEPARATOR PROFILE File: HeatCraft_FPS_fig 14