NC0080853_Draft Permit_20240515

ROY COOPER
Governor
ELIZABETH BISER
Secretary
RICHARD E. ROGERS, JR
Director
NCFtTH CAACLINA
Enlrironmerrl!W quality
May 15, 2024
Nokia of America Corporation (Nokia)
Attn: John Galasso, PE, Remediation Manager
600-700 Mountain Avenue
Murray Hill, New Jersey 07974
Cristin Dolan, Engineer Environmental
AECOM / Raleigh
5438 Wade Park Boulevard, Suite 200
Raleigh, North Carolina 27607
Subject: Review of Permit Draft for 2°d Public Notice
NPDES Permit NCO080853
Nokia Groundwater Treatment System, WPCS Grade PC-1
Salem Business Park Remediation Site
3370 Old Lexington Road (Starlight Dr.), Winston-Salem
Forsyth County
Mr. Galasso:
The Division of Water Resources (DWR or the Division) has discussed the previous renewal draft
permit in our virtual meeting on April 22, 2024, including Nokia of America Corporation (Nokia)
and authorized consultant AECOM. We hereby transmit a second (2nd) renewal draft for your
review and comment. Please review it carefully to ensure your understanding of the permit limits
and monitoring requirements, and to correct errors, if any.
DWR has made additions and corrections as presented below. Concurrent with this notification, the
Division will solicit public comment on this draft by publishing a notice in newspapers having
circulation in the general Surry County area, as required by the NPDES Program. Please provide
your written comments, if any, to DENR / DWR / NPDES Program no later June 18, 2024
(approximately 30 days after receiving this document). Your written comments are welcome, but
they are not mandatory.
RENEWAL SUMMARY - REVISED
1. 2" Public Notice - Because DWR has increased permitted flow at the Permittee's request and
has relaxed monitoring conditions for 1,4-Dioxane (1,4-D) from Monthly to Quarterly, this
permit is less stringent [per EPA] than the previous draft, and therefore requires an additional
Public Notice [tentatively 15May2024].
2. 1,4-Dioxane (1,4-D) - DWR understands that 1,4-D originates onsite from previous processes.
The current 1,4-D effluent database does not show reasonable potential [see attached RPA - MAX
Predicted = 10 µg/L, Allowable = 80 µg/L]. Therefore, effluent monitoring for renewal is reduced
to Quarterly, no permit limits [see permit A. (1.)].
D_ + North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617 -- 919.707.3616

Nokia of America Corporation
John Galasso, PE
Renewal — Draft Review for 2nd IN
May2024
However, DWR continues to consider 1,4-D a statewide parameter of concern and has updated
Special Condition A. (4.) as a potential permit reopener. DWR notes that 1,4-D was not remediated
by previous treatment technology (air striping) nor has Nokia currently proposed a system to treat.
3. Effluent Flow — At Nokia's request, siting new remediation requirements and an intent to redesign
of the treatment system, DWR has revised effluent flow for this renewal from the previous draft
0.065 MGD to 0.070 MGD [see A. (1.)].
4. Receiving -Stream Flows — Limit Calculations — Nokia discharges to an existing storm sewer
system under zero flow receiving -stream conditions [7Q10 / 30Q2 = 0.0 cfs], i.e., this effluent
receives no credit for dilution per current Permitting Guidance. It follows that DWR has applied
zero flow to recalculate reasonable potential analyses (RPAs) and wasteload allocations (WLAs)
for this revised draft using an instream waste concentration (IWC) = 100%. Previously recorded
discharge conditions (in BIMS) were in error and have been updated for renewal.
5. Tetrachloroethylene (PCE) — based on revised IWC at 100%, PCE continues to show reasonable
potential to exceed its surface water -quality standard. Therefore, monitoring continues Monthly
with limits in accord with the RPA. New Limits = 3.3 µg/L Monthly Average (MA), and Daily Max
(DM) = 6.6 µg/L (MA x 2). Considering new limits, renewal provides a revised schedule for PCE
limits, postponing compliance for one (1) year from the permit effective date [see permit Condition
A. (3)].
6. Oil and Grease (O&G) and Total Suspended Solids (TSS) — renewal revises the previous
analytical parameter code for O&G from 00556 to 00552 (as appropriate for industrial
discharges); added limits of 15 mg/L MA and 30 mg/L DM. EPA requires both limits for TSS,
therefore renewal retains 30 mg/L as DM [anti -backsliding] and adds 15 mg/L as MA.
7. pH - added monitoring to the permit [as required by EPA for all industrial discharges]
8. DWR Updated - Supplement to Permit Cover Sheet, other permit texts, Electronic Reporting [A.
(5.)] and the Site Map.
Revised Schedule of Issuance
Draft Permit previously to Public Notice: November 15, 2023
Permit Withdrawn at Permittee's Request April 9, 2024
Re -draft (Post Meeting) to Public Notice (Tentative) May 15, 2024
Permit re -submitted for final signature (Tentative) June 21, 2024
Permit scheduled to issue (Tentative) July12, 2024
Effective Date (Tentative) Augustl, 2024

Nokia of America Corporation
John Galasso, PE
Renewal — Draft Review for 2nd PN
May2024
If you have questions, please email me at fioe.corporonkdeq.nc.gov]. Much of NC state government
currently functions remotely therefore correspondence via email is preferred.
Respectfully,
1 i
I %./.
Joe . Corrpor , P.G.
D / DWR NPDES ermitting
ec: NPDES Permit Files [Laserfiche]
DWR/WSRO, Gary Hudson [[e-mail]]; Jenny Graznak
DWR/Aquatic Toxicology Branch, Attn. Molly Nicholson [[e-mail]]
DWR / OCU, Jeffrey Talbot 'effre [e-mail]]
Nokia/John Galasso, Remediation Manager [e-mail]]
AECOM / Raleigh, Cristin Dolan, [[e-mail]]

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
(NEDES)
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
Salem Business Park Remediation Site
3370 Old 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 I, II, III, and IV hereof.
This permit shall become effective 2024.
This permit and the authorization to discharge shall expire at midnight on June 30, 2028.
Signed this day 2024.
r
John E. Hennessy
for the Director of the Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 7

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 0.070 MGD groundwater remediation treatment
system consisting of, but not limited to:
• extraction wells
feed -water equalization
• bag filtration (pre -filters for the GAC
granular activated carbon (GAC) filter, as back-up for air stripper
• low -profile air stripper
• appurtenant pipping to the outfall
these facilities located at the Salem Business Park Remediation Site, 3370 Old Lexington
Road, Winston-Salem, Forsyth County, and
2. discharge from said treatment works via Outfall 001, at the location specified on the attached
map, into existing storm sewer leading to unnamed tributary (UT) to Salem Creek [Stream
Segment _12-94-12-(4)], a waterbody currently classified C within hydrological unite 03-07-04
[HUC: 0304010113] of the Yadkin -Pee Dee River Basin.
Page 2 of 7

Permit NCO080853
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 15A NCAC 02B .0500 et seq.] WPCS Grade PC -I [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, monitored,
and reported 1 by the Permittee as specified below:
PARAMETER
EFFLUENT LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Daily
Measurement
Sample
Sample
Parameter Code
Average
Maximum
Frequency
Type
Location
Flow, MGD
50050
0.070
Continuous
Recorder
Influent or
Effluent
pH (Standard Units)
00400
Not < 6.0 or > 9.0 s.u.
Monthly
Grab
Effluent
Total Suspended Solids (TSS)
C0530
15.0 mg/L
30.0 mg/L
Monthly
Grab
Effluent
Oil and Grease (mg/L)
00552
15.0 mg/L
30.0 mg/L
Monthly
Grab
Effluent
Tetrachloroethene (PCE)
78389
3.3 µg/L 2
6.6 µg/L 2
Monthly 3
Grab
Effluent
1,4-Dioxane (µg/L)
82388
Monitor and Report 3
Quarterly
Grab
Effluent
Whole Effluent Toxicity 4
TGP3B
Monitor and Report
Quarterly
Grab
Effluent
Chronic
Footnotes:
1. The Penmittee shall submit Discharge Monitoring Reports electronically using NCDWR's
eDMR application system [see A. (5.)].
2. Compliance to effluent limits shall commence one (1) year from the Effective date of this
permit [see Special Condition A. (3)].
3. Monitoring and reporting of 1,4-Dioxane are subject to additional reporting requirements [see
Special Condition A. (4.)]. Analyses must embrace the laboratory's minimum detection level
(MDL) to reflect 1,4-Dioxan's surface water -quality standard.
4. Monitoring shall coincide with the Chronic WET testing as appropriate to frequency.
5. Whole Effluent Toxicity (WET) testing, Chronic, (Ceriodaphnia) P/F at 90% effluent
concentration during March, June, September, and December [see A. (2.)].
Condition: The Permittee shall discharge no floating solids or foam visible in other than trace amounts.
Page 3 of 7

Permit NCO080853
A. (2.) 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.
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 TGP3B 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
1623 Mail Service Center
Raleigh, NC 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at
the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will
be required during the following month. Assessment of toxicity compliance is based on the toxicity testing
quarter, which is the three-month time interval that begins on the first day of the month in which toxicity testing
is required by this permit and continues until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and modified
to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last
day of the month following the month of the initial monitoring.
Page 4 of 7

Permit NCO080853
A. (3.) SCHEDULE OF COMPLAINCE
[G.S. 143-215.1(b)]
To afford the Permittee a schedule to consider upgrades to the treatment system, compliance with permit
limits for Tetrachloroethene (PCE) shall begin one (1) year from permit Effective date.
A. (4.) SPECIAL CONDITION - PERMIT REOPENER
[G.S. 143-215.1(b)]
Upon receiving effluent analytical results for 1,4-Dioxane, equal to or greater than 80 µg/L, the
Permittee shall report this result, within 48 hrs, to the Division's Winston-Salem Regional Office
(WSRO). The Division may reopen this permit if deemed necessary, to modify requirements to address
1,4-Dioxane monitoring and limitations.
A. (5.) ELECTRONIC REPORTING OF DISCHARGE 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.) Reporting N
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)]
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
Page 5 of 7

Permit NC0080853
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, 2025, 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
►-a
In accordance with 40 CFR 122.41(1)(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:
hgps://www.federalre ig ster.gov/documents/2015/10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above. C
%,-!
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.
Page 6 of 7

Permit NC0080853
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:Hdeq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)l
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please
visit the following web page: http:Hdeq.nc.gov/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 OF
CERTIFICATION WILL BE ACCEPTED: VA\h
"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. "
5. Records Retention [Supplements Section D. (6.)]
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 7 of 7

i
ti �
1 -
i UT to Salem Creek
(flows W)
* Casswell Street
1 L
Nokia of America Corporation
3370 Old Lexington Road
Salem Business Park, Winston-Salem
Outfall Latitude: 36' 03' 18" N Outfall Longitude: 80' 13' 5 1 " W
Stream Class: C Receiving Stream: UT to Salem Creek
Stream Segment: 12-94-12-(4) Flow: 0.062 MGD
Subbasin: 03-07-04 USGS Quad: Winston-Salem East
HUC: 0304010113
Drainage Basin: Upper Yadkin, Yadkin Pee -Dee
�� 'North NPDES Permit NCO080853
Forsyth County