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HomeMy WebLinkAboutNC0085821_Complete File - Historical_20050126Z_ NC®ENR" North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director January 26, 2005 Mr. Glen L. Foster Tyco Electronics Corporation P.O. Box 3608 Harrisburg, Pennsylvania 17105-3608 Subject: Rescission of NPDES Permit NCO085821 Building 42: Church Street site Guilford County Dear Mr. Foster: Division staff has confirmed that the subject permit is no longer required. Therefore, in accordance with your request, NPDES Permit NCO085821 is rescinded, effective immediately. If in the future you wish to again discharge wastewater to the State's surface waters, you must first apply for and receive a new NPDES permit. Discharge of wastewater without a valid NPDES permit will subject the responsible party to a civil penalty of up to $25,000 per day. If you have questions about this matter, please contact Charles Weaver of my staff at the telephone number or address listed below. You may also contact the Winston-Salem Regional Office at (336) 771-4600. Sic el4y, I Alan ek cc: Central Files Winston-Salem Regional Office / Corey Basinger NPDES Permit file Fran McPherson, DWQ Budget Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, Nodh Carolina 27604 Internet: h2o.encstate.nc.us Phone: 919-733-5083, extension 511 / FAX 919 733-0719 charles.weaverftcmail. net NorthCarohna Naturally An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper Re: NCO085821 - rescission request Subject: Re: NCO085821 - rescission request From: Corey Basinger <Corey.Basinger@ncmail.net> Date: Tue, 25 Jan 2005 15:22:31 -0500 To: Charles Weaver <charles.weaver@ncmail.net> Rescind. That means one less inspection for me. Thanks for the info. Corey On 1/25/2005 3:24 PM, Charles Weaver wrote: Corey - Tyco Electronics has decided not to install the remediation system covered by this permit. They have asked that we rescind it. If the WSRO has no objections, I will proceed. Let me know.... Thanks, CHW Corey Basinger <Corey.Basinger(a,NCmail.net> NC DENR WSRO 1 of 1 1/26/2005 9:53 AM tgvu Electronics Glen L. Foster Manager, Environmental Health & Safety M.S.140-42 Phone: 717-986-7916 Fax: 717-985-2683 glfoster@tycoelectronics.com January 14, 2005 Tyco Electronics Corporation PO Box 3608 Harrisburg, PA 17105-3606 USA Phone: 717-564-0100 w tycoelectronics cam CERTIFIED MAIL RECEIPT NO. 7001 0320 0001 0029 0966 RETURN RECEIPT REQUESTED Mr. Charles H. Weaver, Jr. North Carolina Department of Environment & Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 RE: REQUEST TO RESCIND PERMIT NPDES PERMIT NO. NC 0085821 TYCO ELECTRONICS BUILDING 42 — CHURCH STREET GREENSBORO, NORTH CAROLINA Dear Mr. Weaver: Tyco Electronics originally applied for the NPDES permit to authorize the discharge of treated groundwater at this groundwater remediation site. For several reasons, we have not ever discharged under this permit and in fact, the piping necessary for a discharge under this permit has never been installed. The permit expires on August 31, 2005. We do not wish for the permit to be renewed and thus will not be submitting an application for renewal. Please allow the permit to expire on August 31, 2005, or if more convenient for the Department, you may rescind the permit at an earlier date. If you have any questions regarding this request, please contact me at (717) 986-7916. Sincerely, 'Glen L. Foster Manager, Environmental Health & Safety Enclosures cc: Mr. Jason Davis, HRP A 04, a NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor November 29, 2004 Glen L. Foster Tyco Electronics Post Office Box 3608 Harrisburg, PA 17105 William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director Subject: Renewal Notice NPDES Permit NCO085821 Tyco Electronics/Greensboro Guilford County Dear Permittee: Your NPDES permit expires on August 31, 2005. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e)) regulations require that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If you have already mailed your renewal application, you may disregard this notice. To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than March 4, 2005. Failure to request renewal by this date may result in a civil assessment of at least $500.00. Larger penalties may be assessed depending upon the delinquency of the request. If any wastewater discharge will occur after August 31, 2005, the current permit must be renewed. Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1; unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day. If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact me at the telephone number or address listed below. Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with the permit renewal application. If you have any questions, please contact me at the telephone number or e-mail address listed below. Sincerely, Charles H. Weaver, Jr. NPDES Unit cc: Central Files Winston-Salem Regional Office, Water Quality Section NPDES File 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 512 Noah Salisbury Street, Raleigh, North Carolina 27604 NorthCarolina Phone: 919 733-5083, extension 511 / FAX 919733-0719/chades.weaver@ncmail.net Na firg//l/ An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10°/ Post Consumer Paper ` `! f� NPDES Permit NCO085821 Tyco Electronics/Greensboro Guilford County The following items are REQUIRED for all renewal packages: ❑ A cover letter requesting renewal of the permit and documenting any changes at the facility since issuance of the last permit. Submit one signed original and two copies. ❑ The completed application form (copy attached), signed by the permittee or an Authorized Representative. Submit one signed original and two copies. ❑ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares the renewal package, written documentation must be provided showing the authority delegated to any such Authorized Representative (see Part II.B.I1.b of the existing NPDES permit). ❑ A narrative description of the sludge management plan for the facility. Describe how sludge (or other solids) generated during wastewater treatment are handled and disposed. If your facility has no such plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed original and two copies. The following items must be submitted by any Municipal or Industrial facilities discharg1 process wastewater. Industrial facilities classified as Primary Industries (see Appendices A D to Title 40 of the Code of Federal Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a Priority Pollutant Analysis (PTA) in accordance with 40 CFR Part 122.21. The above mquimment does NOT apply to privately owned facilities treating 100% domestic wastewater, or facilities which discharge non process wastewater (cooling water, lilterhackwash, etc PLEASE NOTE: Due to a change in fees effective January 1,1999, there is no renewal fee required with your application package. Send the completed renewal package to: Mr. Charles H. Weaver, Jr. NC DENR / Water Quality / NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Michael F. Easley AA Governor r William G. Ross, Jr., Secretary ©� NR North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality October 10, 2003 Mr. Glen Foster Tyco Electronics Corporation P.O. Box 3608 Harrisburg, PA 17105-3608 Subject: NPDES Permit Modification Request Permit No. NCO085821 Dear Mr. Foster: This letter is to confirm our understanding regarding your intent to modify the carbon filters in the groundwater remediation system at your Greensboro facility, and to insure that Tyco is aware of the Division's position in this matter. Per your letter dated September 12, 2003 and two telephone conversations with Dawn Jeffries of the NPDES Unit, we understand that one of the 1000 lb. carbon filters in your groundwater remediation system has developed a leak, and the system has been down for several months. You desire to repair the system by replacing the leaking filter with one of lesser capacity, as you feel that a smaller one would be sufficient. You understand that this will require an Authorization to Construct (ATC) permit and intend to submit the appropriate paperwork to get that authorization as you do want to maintain your permit to discharge in the event that you need it in the future. However, you wish to begin remediation again as soon as possible, and feel that a delay of several more months (to get the ATC) would not be advisable. Therefore, since you are not currently discharging under the permit but into a municipal sewer, you intend to replace the filters and begin water treatment promptly. You understand that you may not discharge into surface waters under your current permit until modifications to it are approved by the division. This request is very unusual, but we are willing to accommodate it. Please understand that this course of action entails some level of risk to you. We cannot guarantee that the application for an ATC will be approved as requested. Also, if you should need to discharge under your NPDES permit in the interim, you could not. If you have any questions concerning this letter, please call Dawn Jeffries at telephone number (919) 733- 5083, ext.595. Sincere y �lan 4�/. Klimek, P.E. cc: Central Piles Winston-Salem Regional Office/Water Quality Secuon NPDES Unit N. C. Division of Water Quality / NPDES Unit Phone: (919) 733-5083 1617 Mail Service Center, Raleigh, NC 27699-1617 tax: (919) 733-0719 Internet: h2o.enrstate.nc.us DENR Customer Service Center: 1 800 623-7748 yCO Tyco Electronics Corporation P.O. Box 3608 e' Glen L. Foster Manager, Environmental Health & Safety Harrisburg PA 77705-3608 'I }L Electronics USA M.S. 140-02 �Y Phone: 717-986-7916 Fax: 717-985-2683 Phone. 717-564-0100 glfosler@tycoelectronlcs.com w tycoelectronicscom September 12, 2003 CERTIFIED MAIL RECEIPT NO. 7001 1940 0005 3352 9256 RETURN RECEIPT REQUESTED Ms. Christie Jackson Department of Environment & Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 RE: NOTIFICATION OF SYSTEM MODIFICATION NPDES PERMIT No. NC 0085821 TYCO ELECTRONICS BUILDING 42 —CHURCH STREET GREENSBORO, NORTH CAROLINA Dear Ms. Jackson: Per our consultant's conversation with Ms. Valerie Stevens of the NC-DENR Division of Water Quality on 13 August 2003, Tyco Electronics Corporation is submitting this letter to notify the NC-DENR Division of Water Quality of a proposed groundwater treatment system modification for the above referenced site (NPDES Permit No. NC 0085821). The purpose of this letter is to detail the proposed modification to the groundwater remediation system operating under the referenced NPDES permit. The site currently operates a groundwater pump and treat system consisting of two (2) recovery wells, two (2) bag filters, an equalization tank, two (2) air stripping towers in series, and two (2) carbon filters in series for final polishing prior to discharge. The system currently discharges treated water on -site into the POTW sewer system. The treatment system maintains a NPDES Permit allowing discharge into an unnamed tributary of Buffalo Creek; however, the discharge pipe has not been connected and the system has not yet discharged under the NPDES Permit. On 05 May 2003 the system was shutdown because a leak had formed in one carbon canister, allowing the carbon and treated water to escape from the system. The system has remained shutdown since 05 May 2003 because of the compromised carbon vessel and because the site has been undergoing substantial development and the remediation system was not accessible until last month. The treatment system utilizes the carbon vessel for the final polishing of the treated water in the event of the reduced performance of the two (2) existing air strippers. Based on site access and logistics, Tyco Electronics proposes to replace the permitted dual series 1000 lb. Granular Activated Carbon (GAC) filters with three (3) Carbtrol HP- 200 canisters in parallel. The canisters will be filled with 200 lbs. of reactivated carbon (Iodine Average of 1000) for a system total of 600 Ibs with five (5) minutes of carbon contact time. Historical sampling data from after the 2nd air stripper (42-EFF-1, prior to the carbon canisters) is provided in Table 1 (following text). Since 1998, there have only been three monthly samples (4/00, 7/02, and 3/03) in which Volatile Organic Ms. Christie Jackson Page 2 September 12, 2003 Compounds (VOC's) were detected in the samples collected after the 2"d air stripper. Based on this historical information and the low levels of VOC's detected in these three samples (2.0 pg/L, 1.0 pg/L, and 1.4 pg/L), the proposed system modification of the three (3) Carbtrol HP-200 canisters in parallel will provide adequate carbon contact time for final polishing of the treated water in the event that the extracted groundwater is not completely treated by the two (2) existing air strippers. Historical sampling data following the previous carbon canisters (42-EFF 3) is also provided in Table 2. As detailed in Table 2, all groundwater constituents monitored in accordance with applicable discharge permits have been Non -Detect (ND) or Below Quantifiable Limits (BQL) following the carbon canisters. Please note that on April 24, 2000, chloromethane was detected in effluent samples from both the air strippers and the carbon canistersat 2 ug/I; however, this constituent has not historically been detected in groundwater samples and is considered to be an anomaly or laboratory artifact. The Carbtrol HP-200 canisters (rated at 10 GPM, 75 PSI each) will function in parallel allowing the processing of 30 GPM. Based on historical system readings, the system Column #2 (2"d air stripper) discharges at an average "instantaneous" flow rate of 30 GPM and at an average "instantaneous" 30 PSI line pressure before the carbon unit, therefore the proposed modification of the system will enable the system to effectively process the same volume of water with same line pressure as the present configuration of dual carbon vessels. In essence, the proposed three (3) Carbtrol HP-200 canisters in parallel will collectively function in equal magnitude of water processed and treated as the current dual GAC canisters. Please note that we are not requesting a change to the flow rate specified in the current permit (28,000GPD or 19.4 GPM). Pending approval of the treatment system and NPDES Permit modification by NC-DENR Division of Water Quality, Tyco Electronics proposes to modify and restart the treatment system on or before 30 September 2003 unless otherwise notified. If you have any questions regarding this notification, please contact me at (717) 986- 7916. Sincerely, J Gen L. Foster Manager, Environmental Health & Safety Enclosures cc: Mr. Jason Davis, HRP Table t Summary of Chlorinated VOCs Analysis from 2"d Air Stripper Effluent Sample IdentiFler 42-EFF-I Building 42, Church Street, Greensboro, North Carolina <1 All units In micrograms per liter (pglL). M-DCA = 1,1-Dichlomethene. SOL = Below quantitation limit. 1,1-DCE'= 1,1-01chlwoeNane. < = Compaund mncenUation less than laboratory reporting limit PCE = Totrachlo osthene. VOCs = Volatile organic compounds. 1,1,1-TCA = 1,1,1-Tnmloroathane. EFF = Effluent. TCE = TnUdoroethene. NS = Not Sampled due to system shutdown. Table 2 Summary of Chlorinated VOCs Analysis from Carbon Unit Effluent Sample Identifier 42-EFF-3 Building 42, Chumh Street, Greensboro, North Carolina Ali units in mkMrams per liter (pg/L). 1,1-0CA = 1,1-0icNomethane. BOL = Below Quantilation limit 1,1-0CE = 1,1-Olchlomethene. NS = Not Sampled. PCE = Taeedilometherm. <- Compound concentration less than laboratory reporting limtL 1,1,1-TCA=1,1,1-Tridlloroethane. VOCs = Volatile organic Compounds. TCE = Trichlomethene. EFF = Effluent. '-Chlommethane -State of North CarolinaIT Department of Environment and Natural Resources - 4 Division of Water Quality ��r• A James B. Hunt, Jr.,Governor N C D E N R Bill Holman, Secretary Kerr T. Stevens, Director August 7, 2000 Mr. Glen L. Foster Project Manager Global Environmental Services Health and Safety TYCO Electronics Corporation P.O. Box 3608 Harrisburg, Pennsylvania 17105-3608 Subject: Issuance of NPDES Permit NCO085821 and Issuance of Authorization to Construct TYCO Electronics Corporation / Greensboro (formerly AMP, Inc.) Guilford County Dear Mr. Foster: Division personnel have reviewed your permit modification request and your request for an Authorization to Construct Accordingly, the Division is forwarding herewith the subject NPDES permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994. On November 18, 1999, the Division received comments submitted by Harding -Lawson Associates (HLA) regarding the draft NPDES permit for this facility. The final permit reflects the changes made after review of HLA's written comments as well as any changes based on subsequent discussions between Division personnel and HLA personnel. This permit also approves relocation of the effluent outfall from an unnamed tributary to North Buffalo Creek to North Buffalo Creek. After further consideration, the Division has approved the request to reduce (from monthly to quarterly) the monitoring requirements for the volatile organic parameters of concern (VOCs). Although TYCO Electronics Corporation has not yet submitted effluent discharge data collected under an NPDES permit, data from the treatment system was available and sufficient to resolve this issue. The data verified that VOC levels have been below detection level. It is not expected that VOC levels will rise during this permit cycle, as the current treatment system has been active for several years. However, should VOCs be found in detectable levels during this permit cycle, the Division will likely increase the monitoring frequencies for VOCs. Additionally, whole effluent toxicity testing is still required and should coincide with the monitoring for the VOCs. The lead limit implemented in this permit represents 1/2 the final acute value at a hardness of 50 mg/L and is based on total lead Instead of dissolved lead). This limit protects instream aquatic fife from any acute effects that may be caused by the discharge of lead in the effluent. No dilution calculations are required for this implementation method. Additionally, a reasonable potential analysis (RPA) was performed on the existing monitoring data for lead. The RPA indicated that there was a reasonable potential for violation of the instream standard [ref. EPA's Technical Support Document for Water Quality -based Toxics Control]. 1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROUNA 27699-1617 - TELEPHONE 919-733-5083/FAX 919-733-0719 AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER- 50% RECYCLED/ 10% POST -CONSUMER PAPER VISIT US ON THE WEB AThttp://h2o,enr.stote.nc.us/NPDES This permit also grants an Authorization to Construct (ATC) for the approximately 1700-foot effluent force main, flow meter, and all other appurtenances associated with relocation of the effluent outfall to North Buffalo Creek. The existing effluent pump (rated at 20 gpm, 31 ft. TDH) will remain in use as the outfall pump. After construction tinder this ATChas been completed and an Engineer's CerdLcare (enclosed with thispermit) has been submitted, the permitree is authorized to operate with the approved design components. This ATC is issued in accordance with Part III, Paragraph A of NPDES Permit NCO085821 (attached). This ATC shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in the permit. A copy of the approved plans and specifications shall be maintained on Ale by the Pennittee for the life of the facility. The issuance of this ATC does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable except after notice to the Division of Water Quality. The Division of Water Quality may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal or local governmental permit. If you have any questions concerning this permit, please contact Susan Wilson at telephone number (919) 733-5083, ext. 510. A copy of the approved plans and specifications is also enclosed with this permit. Sincerely, Original Signed By David A. Goodrich Kerr T. Stevens cc: Winston-Salem Regional Office, Water Quality Point Source Compliance Enforcement Unit Aquatic Toxicology Unit Technical Assistance & Certification Unit Central Files NPDES Files i Jason Prosser (Permit and Engineer's Certification) Harding Lawson Associates 2000 Aerial Parkway #106 Morrisville, NC 27560 Permit No. NCO085821 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Water Quality Commission, and the Federal Water Pollution Control Act, as amended, TYCO Electronics Corporation is hereby authorized to discharge wastewater from a facility located at Greensboro Facility 1126 North Church Street Greensboro Guilford County to receiving waters designated as an unnamed tributary to North Buffalo Creek in the Cape Fear River Basin in accordance with the discharge limitations, monitoring requirements, and other conditions set forth in Parts I, II, 11I, and IV hereof. This permit shall become effective September 1, 2000. This permit and the authorization to discharge shall expire at midnight on August 31, 2005. Signed this day August 7, 2000. Original Signed By David A. Goodrich Kerr T. Stevens, Director Division of Water Quality By the Authority of the Environmental Management Commission TYCO Electronics Corporation NPDES No. NCO085821 Permit No. NCO085821 SUPPLEMENT TO PERMIT COVER SHEET TYCO Electronics Corporation is hereby authorized to: Continue to operate an existing wastewater treatment plant consisting of an influent holding/ equalization tank, two air strippers in series, two carbon filters in series, and flow meter located at 1126 North Church Street, Guilford County, and 2. Discharge wastewater from said treatment works at the location specified on the attached map into an unnamed tributary to North Buffalo Creek which is classified C- NSW waters in the Cape Fear River Basin. 3. After notification to the Division of Water Quality/Water Quality Section [see Special Condition A.(5)], TYCO Electronics Corporation may relocate the effluent outfall and discharge treated wastewater from said treatment works at the location specified on the attached map into North Buffalo Creek which is classified C-NSW waters in the Cape Fear River Basin. TYCO Electronics Corporation NPDES No. NCO085821 TYCO Electronics Corporation/ Greensboro A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NCO085821 During the period beginning on the effective date of the permit and lasting until expiration or relocation, the Permittee is authorized to discharge from outfall(s) serial number 001 into an unnamed tributary to North Buffalo Creek. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENTCHARACTERISTICS LIMITS MONITORING REQUIREMENTS[ , Monthly Weekly Daily Maximum Measurement Sample, ,Sample , 'Locations` Avera a Avera a Frequency Type Flow MGD 0.0288 Weeklv Instantaneous I or E 1,1 Dichloroethene 1,1 DCE Quarterly Grab E 1,1 Dichloroethane 1,1 DCA Quarterly Grab E 1,2 Dichloroethene 1,2 DCE Quarterly Grab E Tetrachloroethene PCE Quarterly Grab E 1,1,1 Trichloroethane 1,1,1 TCA Quarterly_Grab E Trichloroethene TCE Quarterly Grab E Arsenic Monthly Grab E Chromium Monthly Grab E Copper Monthly Grab E Lead 25 4glI 33.8 /I 2/Month Grab E Iron Monthly Grab E •Man anese Monthly Grab E Zinc Monthly Grab E 2 Quarterly Composite E Chronic Toxicity Notes: 1 Sample Locations: E - Effluent, I - Influent. 2 Chronic Toxicity (Ceriodaphnia), P/F at 90 %, January, April, July, and October. See Special Condition A (3). Quarterly toxicity testing should coincide with quarterly monitoring for volatile organic parameters. The facility may choose to perform composite sampling for Arsenic, Chromium, Copper, Lead, Iron, Manganese, and Zinc. Should 12 months of effluent sampling of these parameters indicate no reasonable potential to exceed allowable levels, the facility may request reduction or elimination of monitoring for these parameters. There shall be no discharge of floating solids or visible foam in other than trace amounts. TYCO Electronics Corporation/ Greensboro A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Permit No. NCO085821 During the period beginning upon relocation of the outfall and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001 into North Buffalo Creek. Such discharges shall be limited and monitored by the Permittee as specified below: 'EFFLUENT CHARACTERISTICS LIMITS + IVIONITORING REQUIREMENTS; 4- Month). y Average Weekly Average Daily Maximum Measurements Fre uenc Sample,; T e �-'=Sample,.-. . Location" Flow MGD 0.0288 Weekly Instantaneous I or E 1,1 Dichloroethene 1;1 DCE Quarterly Grab E 1,1 Dichloroethane 1,1 DCA Quarterly Grab E 1,2 Dichloroethene 1,2 DCE Quarterly Grab E Tetrachloroethene PCE Quarterly Grab E 1,1,1 Trichloroethane 1,1,1 TCA Quarterly Grab E Trichloroethene TCE Quarterly Grab E Arsenic Monthly Grab E Chromium Monthly Grab E Copper Monthly Grab E Lead 33.8 /1 2/Month Grab E Iron Monthly Grab E Manganese Month) Grab E Zinc Month) Grab E Chronic Toxicity 2 Quarterly Composite E Notes: 1 Sample Locations: E - Effluent, I — Influent. 2 Chronic Toxicity (Ceriodaphnia), P/F at 8.4 %, January, April, July, and October. See Special Condition A. (4). Quarterly toxicity testing should coincide with quarterly monitoring for volatile organic parameters. The facility may choose to perform composite sampling for Arsenic, Chromium, Copper, Lead, Iron, Manganese, and Zinc. Should 12 months of effluent sampling of these parameters indicate no reasonable potential to exceed allowable levels, the facility may request reduction or elimination of monitoring for these parameters. There shall be no discharge of floating solids or visible foam in other than trace amounts. A (3). CHRONIC TOXICITY PASSMAIL PERMIT LIMIT (QRTRI: 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, auarterlu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II 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. 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. 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 Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Branch 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. TYCO Electronics Corporation NPDES No. NCO085821 A (4). CHRONIC TOXICITY PASSMAIL PERMIT LIMIT (QRTRh The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 8.4 %. The permit holder shall perform at a minimum, auarterlu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II 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. 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 H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1.998) or subsequent versions. 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 Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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 Branch 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. TYCO Electronics Corporation NPDES No. NCO085821 A (5). OUTFALL RELOCATION REQUIREMENT This permit conditionally approves relocation of the Buffalo Creek to North Buffalo Creek via an approv Electronics Corporation choose to relocate the outfall, with this permit) must be submitted to the Division Buffalo Creek. outfall from an unnamed tributary to North ed pump station/ force main. Should Tyco an Engineer's Certification (which is attached of Water Quality prior to discharge to North TYCO Electronics Corporation NPDES No. NCO085821 NOTE5 TO FILE. 8/1/00: AM TYCO Electronics, Corporation. NCO085821 Harding Lawson Assoc./ Consultants 5tarted dealing with new consultant with HL Assoc. (Jason Prosser, located in Morrisville). They and TYCO were debating (as early as 1119100) if relocation of outfall was actually needed. Repeated calls indicated that they may do in situ remediation and not need a permit. (5/22/00 phone call indicated this). Finally e-mailed Glen Foster anc told him we needed to issue permit and we could give option of relocation in the permit. They could then take their time in deciding what they wanted to do. He indicated OK with this via e-mail7/27/00, G LF05TE R@tycoelectronic5.com JProsser@harding.com NOTES TO FILE. 12/16/9941ZA10,67 AMP, Inc. NC0085821 Harding Lawson Assoc./ Consultants Consultant requested modification of the permit on behalf of AMP to relocate the outfall and to reduce Some monitoring requirements. Also submitted plans and specifications for the outfall relocation from UT to North Buffalo Creek. Additionally, requested change in permitted flow based on available flow data. The site has been active since 1988 and AMP first requested a permit in 1996. Monitoring data included most parameters that were found in detectable levels in the monitoring wells. 5ome inorganic monitoring was required. Chlorinated solvents were the primary contaminants. Part of the facility's flow went to the City of Greensboro and part went to a subsurface system. Greensboro is cutting the GW flow off and the subsurface system cannot take the entire remediation amount, so the NPDE5 discharge is needed. The proposed discharge location has a 7010s = 0.049 cfs, Qavg =12.9 cfs (per C. Weaver, U5G5). This corresponds with flows at 0209518100, IWC is 5.4%. The requested flow is 0.0286 MGP (reduction from 40 gpm to 20 gpm). The subsurface system was approved via W00004491 at 0.0576 (2 galleries at 28,500 gpd). The treatment units (equal. Tank, 2 air strippers, 2 carbon filters, and flow meter) are already in place and assumed approved via the WQ permit. 5ubmitted monitoring data show no levels of detection with the exception of lead. The draft permit reflects monitoring for the POCs that are primary contaminants and the inorganics that were in the previous permit (and had not been monitored). A lead limit was placed in the permit which reflects'/2 FAV, a reasonable potential analysis was Performed which showed the need for a lead limit. 5ome parameters were eliminated due to having no presence in the effluent to the city/ subsurface system. The consultant requested that the VOCs that are primary contaminants be reduced to quarterly due to their lack of presence in previous monitoring data. The revised permit reflects this request [the site has been active for several years and no detect levels were shown for those parameters]. this permit also reflects an ATC for the force main for the relocation. 51nce this force main is not technically a "sewer" it does not have to conform to all the stipulations presented for a pump station force main at a collection system. The ATC was given a cursory review [consultant presented calculations which were adequate]. RE: AMP/Greensboro Facility Subject: RE: AMP/Greensboro Facility Date: Thu, 27 Jul 2000 15:54:40 -0400 From: "Foster, Glen L" <GLFOSTER @ tycoelectronics.com> To: "'Susan Wilson"' <susan.a.wilson@ncmail.net> Susan, we have reviewed this approach below and agree that under the present circumstances it makes sense to issue the permit with both outfalls identified. Thanks. Glen L. Foster Manager, Americas Environmental Health & Safety Tyco Electronics Corporation MIS 140-042 P.O. Box 3608 Harrisburg, PA 17105-3608 717-986-7916 717-760-0108 (pager) 717-985-2683 (fax) glfoster@tycoelectronics.com -----Original Message ----- From: Susan Wilson [mailto:susan.a.wilson@ncmail.net] Sent: Tuesday, July 11, 2000 12:24 PM To: Foster, Glen L Cc: TProsser@harding.com Subject: AMP/Greensboro Facility Glen, Jason Prosser (HL&Assoc.) sent me your e-mail address because I wanted to let you know how we were going to proceed with issuance of the AMP permit. Unfortunately, due to our backlog level (which EPA tracks, etc.) we can no longer "hold" this permit. I need to send this up to my supervisor for issuance. Because AMP is still in the decision making process as far as further action on this discharge, this is the way I'd like to present this permit: Issue the permit with both the existing location and the relocation noted and with limits/monitoring to reflect each (previously, DWQ only presented limits/monitoring for the relocation). Should AMP choose not to relocate or find there is no need for an NPDES discharge, AMP can inform the Division in writing at a later time. Also, should AMP provide convincing information that the acute lead limit is not appropriate, AMP can present that information and DWQ will review at a later time. We'll work with AMP on any issue as best as possible. I'll also revise the expiration date to 5 years ( because the existing expiration date was set at June 30, 2001 to correspond with other permits in the river basin). Sorry for the push on this one, but DWQ has been patient and the previous consultant, (prior to Jason Prosser who has been extremely helpful and cooperative), was continually pushing us to move on the permit (and I've essentially held this for 7.months after it's been ready to issue). Thanks for your time. Susan A. Wilson, P.E. NCDWQ/NPDES Unit 1 of 1 7/31/00 9:36 AM State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secratary Kerr T. Steven /T 7 "� n F N R 1Division of Water Quality MEMO From: Date: To: Subject: — FAX TO: Jason AMP, Inc. Con rSusan {Jal ✓ UJ : 733 5 Jason, Enclosed is a 46tl �e of the other info) �iti"�° Irther questions. " If you have I� J �n G rCoEIxCT(&JtCS"CbM 4�FA* NCDENR North Carolina Department of Environment and Natural Resources PO Box 29535, Raleigh, North Carolina 27626-0535 / Phone: 733-5083 State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director ATMAI +rr � D E N R Division of Water Quality NPDES Unit FAX: (919) 733-0719 12/23/99 4al -ag31 I FAX TO: Jan Smith. P.E. Hardina Lawson Ass. I FAX NUMBER: 703 391 - 2608 1 Inc. Consultant FROM: Susan A. Wilson PHONE: 733-5083, ext. 510 NO. OF PAGES INCLUDING THIS SHEET: 3 Unfortunately, we need a representative from Tyco to fill out the name change form (don't know when this took place, but we could have gotten this done earlier had I known). Sorry for any delays. As for the lead limit, as I indicated in the previous Fax, the lead limit is based on an acute value (1 /2 FAV). NC uses a hardness of 50 mg/I (this could be the reason you are not getting similar values) and also uses a limit based on a total (not a dissolved as EPA criteria indicate). Due to only 2/month sampling, we implemented a daily maximum based on this acute value of 33.8 ug/I. The calculation to derive the acute value of 33.8 ug/I is exp(1.273(ln(hardness)) + (- 1.460)), the constants being taken from EPAs derivation equations. Ref. Federal Register publication 4/22/99 (FRL-6330-2), EPA, National Recommended Water Quality Criteria. I'll be out next week, but someone else in the NPDES unit may be able to help you if you have further questions about the name change. Have a good holiday. 4u 1 4-S' News & Record Published by News & Record, Inc. Greensboro, North Carolina North Carolina, Guilford County AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to administer oaths, personally appeared Lolita Cousin who being first duly sworn, deposes and says: OF PUBLIC ENT NOTICE INTENT(ISSUE 1. That she is the Publishers Representative of the Greensboro News A STATE PERMIT TO THE FOLLOWING: & Record, Inc. a corporation, engaged in the publication of DES Permit Number C0085821. AMP. Incomorat- newspapers known as "News & Record", published, issued and 1 P.O.05- 6Box 3608 Harrisburg 71 Gr 1 odific do08 of its ES has arff4D r a entered as second class mail in the City of Greensboro in said armit for the AMP/Greensboro uun8water remeeiation facili- County and State; located at 1126 North ``JJ ; 2. That she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement, a true copy of which is attached hereto, was published in the News & Record on the following dates: October 20, 1999 for Public Notice of Intent to Issue a State NPDES permit and placed through NCDENR 3. That the said newspaper (or newspapers) in which such notice, * paper, document, or legal advertisement was published was, at the �yAli time of each and every such publication, a newspaper meeting all of Y the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina. This 20 day of October, 1999 Publishers Representative Sworn to and subscribed before me, this 20 da of October ,1999 Notary Public My commission expires: December 12, 2000 T. PARRISH NOTARY PUBLIC ALAMANCE COUNTY, N¢ Commission Expires 4-10-ZW-c •11/18/1999 10:51 703-391-2608 HARDING LAWSON. ASSOC PAGE 01104 Y 1 1 Harding Lawson Associates -)Reston, VA 12030 Sunrise valley Drive Suite 250 Reston. VA 20191 Phone: (703)391-2524 Fax: (703)391-2608 To: Stud,h W:`Sah Organization: Fax Number: R t9.9 3 3•03-01q o-1 1 a From: Jpr •5v..i Date: %%,IIy Subject: Project Number: Number of Pages (Including Cover Sheet): �{ The information Contained in this facsimile is proprietary and confidential, intended only for the use of the individual or entity named above, if the reader of ibis transmission is not the intended recipient, or employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this transmission is strictly probibited, If you receive this transmission in error, please immediately notify us by telephone, and return the tmnsmission to us at the above address via the U.S. Postal Sarvice. Thank You. 11/18/1999 10:51 703-391-280e HARDING LAWSON ASSOC PAGE 02/04 Harding Lawson Associates November 18, 1999 David Goodrich, Supervisor NCDENR-DWQ NPDES Group P.O. Box 29535 Raleigh, NC 27626-0535 RE: Comments to Draft NPDES Permit AMP lucorporated, 1126 North Chureb Street Greensboro, Guilford County, NC Permit No. NCO085821 Dear Mr. Goodrich: We have reviewed the draft NPDES permit and offer the following comments. For your convenience, applicable text from the draft permit and cover letter is included with our comments. Also, please note that AMP Incorporated has changed their name to Tyco Electronics Corporation, which we request be reflected in the NPDES permit. DWQ Cover Letter: Because the other volatile organics (i.e., chlorinated VOCs) are primary contaminants and parameters of concern, they have been included in this draft to be monitored on a monthly basis. A reduction of the monitoring frequency may be requested upon completion of 12 months of sampling under the NPDES permit. This can be done as a minor permit modification. Cownent., Inorganic and certain organic parameters were removed from the draft permit because they were not present in the submitted effluent data. Similarly, chlorinated VOCs are not present in the effluent; no additional sampling is necessary to determine the monitoring frequency. Chlorinated VOCs are the groundwater constituents of concern and have been the focus of remedial efforts at this site for years under the jurisdiction of the Groundwater Section. The treatment system effluent has been monitored for these VOCs for over 10 years with no observed detections. These data have been provided to the DWQ Winston-Salem Regional Office and the Central Office, and the City of Greensboro Pretreatment Coordinator. In addition, a summary of these data for the last year of monthly VOC monitoring was included in the permit modification request. These data clearly indicate that no chlorinated VOCs have been detected in the effluent_ This -in icates that the treatment system is extremely reliable and the VOC removal efficiency is 00 perce t. One additional year of monthly $ ouaD Ii5 monitoring will not provide the NPDES Group any better data to evaluate our request Tyco Electronicsa- 'AE r Corporation believes there are sufficient data that support the request for a quair erly monitoring frequency and we ask the NPDES Group to reevaluate the monthly monitoring frequency included in the draft permit. In addition, the influent VOC concentration has decreased substantially over the last 10 years; and therefore, the treatment system VOC loading has been very much reduced. There has been a 96 percent reduction in the influent concentration, and as 88 percent reduction in the VOC mass loading to the . Engineering and EnVlmnmePlai Services IaM 50nrl-e Vain/ PNe, 5UIte 250, Reticn, VlgINa 20191 70fd91-2524 Fax 703/991.289e E 11/18/1999 10:51 702-391-2608 HARDING LAWSON ASSOC PAGE 03/04 November 16, 1999 Mr. David Goodrich NCDENR-DWQ Page 2 Harding Lawson Associates treatment system. Because of the success of the groundwater remediation program and the reduction in the influent constituents, the treatment system is expected to function even more efficiently. AWQCover Letter: Arsenic, chromium, copper, iron, manganese and zinc monitoring have been left in the permit due to lack of data to eliminate. Upon initial review and development of the permit, these parameters were shown at levels above detection in monitoring well data. Although these parameters may not be primary contaminants, they may be present in the effluent in amounts approaching allowable levels. As stated above, monitoring frequency may be reduced or eliminated after the collection of 12 months of data. Comment: The metals listed above are common naturally occurring constituents in soil typically observed at concentrations of I to over 100 m&1Xg. No releases of these Constituents occurred at this site and therefore they arc not contaminants of concern, and have not have been monitored routinely. Because the groundwater treatment system is a pump and treat -type system, soil particles, on occasion, may be pumped out of the subsurface with groundwater and the constituents may be observed to an analysis of groundwater. Because the constituents are naturally occurring Tyco Electronics Corporation believes that no ol� additional metals testing is necessary. however, because there is limited effluent metals data, we will collect monthly data for a year and then request any appropriate changes in the permit. AWQCover Letter and Permit .Lindmions: Lead has been limited due to its presence in existing �Je tN data and the monitoring frequency is 2 per month. Cormnent: Similar to the above listed metals, lead is another very common naturally occurring metal in soil; typical concentrations range between I to 300 mg/Kg. No release of this constituent occurred at this site and therefore lead is not a site contaminant of concern. However, effluent lead has been monitored monthly as a requirement of our existing pretreatment permit with the City of Greensboro. A summary of the data submitted to the POTW was included in the permit modification request (repeated here as Table 1). These data are not substantially different than the data used to develop the original NPDES permit (Table 2), which includes a monthly monitoring frequency with no specified lead limit. Tyco Electronics Corporation does not agree that, based on essentially the Samee� data, a more aggressive sampling frequency with a specified limit on a naturally occurring constituent is/ No warranted. As suggested, we are currently initiating analyses of total and soluble lead to assess the concentration uN'^ is ok5cD oN and form of lead that may periodically exist in the influent and effluent. We do not believe that theme current data is sufficient to establish an effluent limitation for lead. As an alternative to the draft permit requirements, we propose to collect monthly samples of the influent and effluent, analyze these samples_ 4 e o > for total and soluble lead, and submit the results to the DWQ. The data can then be used to determine if a permit limit is warranted and, if necessary, to develop methods to reduce lead from entering the treatment system. The first effluent sampling event for total and soluble lead was conducted last week (November 10, 1999). The concentration of lead in both the total and soluble analyses was below the quantitation limit (BQL). C:lprojectLUMP\Church\NPDES\Permit mod\Draft Parmit comments.doc 4 .11/18/1999 10.51 703-391-2909 HARDING LAWSON ASSOC PAGE 04104 November 16,1999 Mr. David Goodrich NCDENR-DWQ Page 3 Harding Lawson ASSOeIffies Table 1. Last Year of Monthly lead Data (Included in Permit Modification Request) Metals NO Monthly Effluent Pb Concentration For Last 12 Months (µg/L) 3030C 213 R 239.2 Sit& Apr- May.96 Jun.98 Jul-98 Aug-98 Sep 98 Oct-96 Nov-96 Doc-96 Jan-99 Feb-99 Mar-99 88 T. Lead 25 10.2 7.92 BQL 1 11.1 1 BQL I BQL 1 61.1 1 BQL I BQL I BQL I BQL 1 25.1 Table 2. Lead Data Included in the Original NPDES Permit Application Metals NO 28 NPDES Permit Application Data (0196) (ugll.) Std. RW-7 Composite I Composite 2 Lead 25 2.4 20.1 1.3 a Composite I —Composite sample from exnacdon wells RW-1, RW-6, RW-8, RW-9 b Composite Z = Composite sample from the Extraction ]tench, and extmctioA wells RW-3, RW-4, RW-5 V in addition, there appears to be an error in the Instream Waste Concentration (ICW) listed in the draft' L `�Z permit that may have led the DWQ to calculate an incorrect lead limitation and sampling frequency. Note 2 of the permit limitations incorrectly indicates that the ICW is 90 percent, The correct lCW is $A percent as indicated in our permit modification request calculations and Section A(2) of the draft permit. Tyco Electronics Corporation requests that the DWQ review the lead limitation calculation to ensure that 3 n)o caw It is correct and provide us a copy of the calculation for review. ` Vz FA\1 PerrrdiSectlOnA:(1): Note 2 indicates hat chronic toxicity testing should be conducted at an efflueat MR' — concentration of 90%. Comment. As indicated in the above comment, there is an error in the note. The correct ICW for the chronic toxicity testis 8.4% as indicated in Section A(2) of the draft permit. An effluent concentration of 8A% is supported bytbc data submitted is the permit modification request. Thank you for the opportunity to review the draft permit. Please contact the undersigned at (703) 391- 2614 ext. 226) if additional information is required. We look forward to your favorable determination. Sincerely, Harding Lawson Associates � an Smith, P.E. C:1Projects\AND)lChurchINPDES',Pormit mod\DrattPermitcomments.doc 4 Division of Water Quality Water Quality Section 1617 Mail Service Center Raleigh, NC 27699-1617 FAX: (919) 733 — 9919 10/12/99 FAX TO Mike Mickey, Water Quality Section WSRO FROM: Susan A. Wilson 9 PHONE: (919) 733 — 5083, ext. 510 NO. OF PAGES INCLUDING THIS SHEET: Mike, Give this a once over. Nothing out of the ordinary. Eliminated some requirements based on submitted data. Added lead limit due to some data above 1/2 final acute value. Couldn't eliminate other metals requirements due to no previous data. 7Q10 increased from 0.0 cfs to 0.49 cfs, so toxicity % reduced to 8.4% (also because flow requested reduced to 0.0288 MGD). Thanks! Have a great day. If you can get back with me prior to noon Wednesday (10/13) I would appreciate it. A(, MIA IV7 Pgwjr- A (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NC0085821 During the period beginning on the effective date of the permit and lasting until expiration, the Permillee is authorized to discharge treated groundwater at outfall number 001. Such discharges shall be limited and monitored by the Permiltee as specified below: nth I Chrommm I u & I I I Moninly I urai, I tmuem q r� r N91va: If the discharge is not continuous, flow may be monitored weekly by an instantaneous flow estimate- 2 Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. 3 Chronic Toxicity (Ceriodaphnia), P/F a[ o, January, April, July, October, See Supplement to Effluent Limitations and Monit ,ring Requirements - Special Conditions page A (2). `_� q r4"o Gc (6" -D There shall be no discharge of floating solids or visible foam in other than trace amounts. Design and construction of waste treatment facility will emphasize the use of plastic pipe and fittings where practically possible. Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent Limitations and Monitoring Req drernents - Special Conditions page. TOXICANT ANALYSIS Facility Name NPDES # _ Ow (MGD) 7010s (cls) IWC (%) Rec'ving Stream Parameter- Standard = n 1 2 3 Lead pg/I Actual Data RESULTS 10.2 Std Dev. 17.12158623 _ 7.92. Mean 11.07666667 _ <51 �C.V _ 1.545734538 11.1 -- <5 <5 Mult Factor= 7.5 61.1 Max. Value 61.1 pg/1 <5 Max. Pred Cw 458.25 pgA <5 Allowable Cw 299.42 po <5 L AMP Inc. NC0085821 25 0.0208 BDL=1/2DL� 0.49 8.35 10.2 North Buffalo Crk 7.92 Stream Class --_- C-NSW _ 2.5 _ 4 5 11.1 FINAL RESULTS 2.5 _ Lead 6 2.5 Max. Pred Cw 458.25 ugA 71 61.1 Allowable Cw 299.4 ugA 8 2.5 Max. Value 61.1 9 2.5 10 2.6 ill 2.5 <5 121 25.1 25.1 ior, AV�OWkB�e (2`l ft. j 'f� /y2 W ��'? Sll,,b-lG). IlnrIT A-r l�hl�� 1W A OF %, Ff 1 33 . S , /j- M-g I -row 2/0-414" fofL G rss 10/12/99 Table 1. Monthly Effluent Volatile Organic Constituent Historical Summary For Last 12 Months EPA Method 601 Analyte Concentrations Quantitation Limt M nthly Effluent VOC Concentration For Last 12 Months IL (µglL) (µglL) Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 BromOChloromethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Bromoform 2 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Bromomethane 2 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Carbon tetrachloride 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Chlorobenzene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Chlomethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Chloroform 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Chloromethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Dibromochloromethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,2-Dibromoethane(EDB) 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,2-Dichlorobenzene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,3-Dichlorobenzene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,4-Dichlorobenzene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,1-Dichloroethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,2-Dichloroethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,1-Dichloroethene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Cis-1,2-Dichloroethene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Trans-1,2-Dichloroethene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,2-Dichloropropane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Cis-1,3-Dichloropropene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Trans-1,3-Dichloropropene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Methylene Chloride 5 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,1,2,2-Tetrachloroethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Tetmchloroethene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,1,1-Trichloroethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL 1,1,2-Trichloroethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Trichloroethene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Trichlorofluoromethane 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Vinyl Chloride 1 1 BQL I BQL I BQL I BQL I BQL I BQL I BQL I BQL I BQL 1 BQL I BQL I BQL G:\40682\Church\NPDES Table 2-1. Monthly Effluent Petroleum Hydrocarbon (BTEX, DIPE, MTBE) Concentration Summary For Last 12 Months EPA Method 602 Analyte Concentrations Quantitation Urnt NC 2B Standards onthly Effluent Petroleum Hy drocarbon Concentration For Last 12 Months IL lµ9/LI (µgli.) (pg/L) Apr-98 May-98 Jun-98 Jul98 Au -98 Sep98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Benzene 1 71.4 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Diisopropyl Ether (DIPE) 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Ethylbenzene 1 BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL BQL Methyl-Tert-Butyl-Ether (MTBE) 2 BQL BQL BQL BQL BQL BQL BQL BOL BQL BQL BQL BQL Toluene 1 11 BQL BQL BQL BQL BOL BQL BQL BQL BQL BQL BQL BQL m/p-Xylene 2 BQL BQL BQL BQL BQL BQL BOL BQL BQL BQL BQL BOL o-Xylene 2 1 BQL BQL BOL BQL BQL BQL BQL BQL BQL BQL BQL BQL Table 2-2. Monthly Effluent Total Petroleum Hydrocarbon Concentration Summary For Last 12 Months EPA Method 418.1 Analyte Concentrations (µg/L) Quantitation Limit (µglL) Monthly Effluent TPH Concentration For Last 12 Months L Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 TRPH 100-104 BOL BQL 300 BQL BQL BQL I BQL I BQL BQL BQL BQL BQL 141 Review of the analytical chromatograms for this sample by laboratory chemists indicated that no petroleum hydrocarbon compounds exist. The result is a false positive associated with an organic carbon compound that is not differentiated by the method. Table 2-3. Monthly Effluent Total Lead Concentration Summary For Last 12 Months EPA Method 3030C & 239.2 Analyte Concentrations (µglL) Quantitation Limt (µg/L) NC 2B Standard (µg/L) Monthly Effluent TPH Concentration For Last 12 Months IL fel Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Lead, Total Extractable 5 25 10.2 7.92 BQL 11.1 BQL BQL 61.1 BQL BQL BQL BQL 25.1 let The analytical procedure is for determing the concentration of total lead; the samples are not fihemd in the field and acidified. Total lead in groundwater is highly dependent on the background lead concentration in soil and the amount of sediment in a sample. G:\40682\Chumh\NPDES Table 3. Historic Groundwater pH at Background or Plume Fringe Monitoring Wells(l) Sa rolite Shallow)A uifer Well Id Date pH (S.U: MW-5d 07/30/96 5.78 01/21/97 6.22 01/27/98 5.64 11/13/98 6.06 01/19/99 5.89 04/29/99 -------------------- MW-9 07/30/96 •---- ---- ---- 6.19 01 /21 /97 6.26 07/29/97 6.25 01 /27/98 6.00 11/13/98- 6.17 MW-10 07/31/96 5.5 ------------------- MW-16d ------------ 07/29/96 -------------- 5.36 01/23/97 5.9 11/13/98 5.79 01/19/99 6.13 04/29/99- 5.78 MW-18s 07/31/96 5.85 01/23/97 6.08 MW-19d 01/23/97 6.11 ------------------- MW-25s ------------ 01/23/97 -------------- 6.15 01/28/98 6.55 11/13/98 6.52 01/19/99 6.23 04/28/996.51 RW-2 - 01/21/97 ------------- 6.31 01/28/98 6.13 11/13/98 6.20 01/19/99 6.25 104/29/991 6.00 pH Range Minimum 5.36 Maximum 6.55 Bedrock Dee Aquifer Well Id Date pH (S.U.) MW-16d 07/29/96 5.36 01/23/97 5.9 11/13/98 5.79 01/19/99 6.13 04/29/99 07/30/96 5.78 7.62 MW-24 01/22/97 7.85 07/28/97 8.05 10/29/97 7.63 01/29/98 8.07 11/13/98 8.02 01/19/99 8.12 04/29/99 01/23/97 8.01 6.38 MW-25d 01 /29/98 8.04 11/13/98 7.15 01/19/99 6.79 04/28/99 6.66 pH Range Minimum 5.36 Maximum 8.12 Background and plume fringe wells are located outside the influence of groundwater contamination and represent natural groundwater chemical conditions. G:\40682\Church\NPDES V' 'SOC 'MAV. 1 M'.,l k�� !"99 12:09PM HARDING L NonfMg Law*m Assoclat" Engineefirg and PROJECT SUBJECT NO, 38921 P. 2 SHEET OF JOB NO. qQ(dl,.7,0� DATE COMPUTED BY CHECKED BY i FI= ^RUG.30.1999 9:12PM HARDING LAWSON ASSOCIATES NO.882 P.1i3 LE ems= Harding Lawson Associates - Reston, VA 12030 Sunrise Valley Drive, Suite 250 Reston, VA 20191 Phone: (703)391.2524 Pax: (703) 391-2608 �VSar (nJ�`Sort Or �� €S Organization: D Fax Number: From: jc' , SEP 0 1 1949 Date: 5/3o/aa Subject: POINT SOURCE BRANCH Project Number. /�''� Number of Pages (Including Cover Sheet): l_ The information contained in this facsimile is proprietary and confdential, intended only for the use of the individual or entity named above. If the reader of this transmission is not the intended recipient, or employee or agent responsible for delivering it to the intended recipient, you are hereby notified thar any dissemination, distribution, or copying of this transmission is strictly prohibited. If you receive this transmission in error, please immediately notify us by telephone, and return the transmission to as at tho above address via the U.S. Postal Service. Thank You. I` oele , "tC0-0a5921 -t I IFrf1•Vtavva` 1"tv ^`I you re%vt44-A Wipy ph o.rr N1u..� ��IAQ ¢.trW.�� wt-A rc�vesf- ,RUG.30.1999 9:12RM HRRDING LRWSON ASSOCIATES NO.GG2 P.2i3 Harding Lawson Associates in August 27, 1999 VIA FACSIMME: (919) 733-9919 Susan Wilson NCDENR-DWQ NPDI;s Unit P.O, Box 29535 Raleigh, NC 27626-0535 RE: . Additional Requested Steam Information NPDLS Permit Modification and Authorization to Construct AMP Incorporated, 1126 North Church Street Greensboro, Guilford County Permit No, NTCO085821 Dear Ms. Wilson: In May 1999, AMP Incorporated (AMP) requested Authorization to Construct (ATC) a new effluent discharge line and a modification to the NPDHS Permit for their Church Street site groundwater treatment system (Pemtit No. NC0085821). The requested ATC and N'PDES permit modification is for relocation of the current discharge point, an unnamed tributary to North Buffalo Creek, to a new discharge point at North Buffalo Creek. The new discharge location is approximately 1,500 lineal feet downstream from the current location. No other structural modifications are requested. We spoke last week regarding the status of your review. During that conversation you requested additional information on the proposed discharge stream; particularly the drainage area used to calculate the new Instream Waste Concentration (IWC). As indicated in the permit modification and ATC request, Mr. Curtis Weaver, Low Flow Stream Analyst, USGS, was contacted to estimate the proposed discharge stream drainage are and 7Q10 £low, Mr. Weaver estimated that the drainage area at the proposed discharge point, the confluence of North Buffalo Creek and the unnamed tributary is 14 square miles. The resulting low flow estimate provided by Mr. Weaver is 0.49 cfs. The following tables summarize the information provided by the USGS and our resulting calculation of the new IWC. Fable 1. Calculation of Stream Low Flow at Proposed Discharge Point Drainage Basin Location Drainage USGS Low Flow 7Q10 Basin Area Factor (cfsimi=) (cfs) (mil) North Buffalo Creekatthe Confluence 14 0.035 0,49 of the Unnamed Tributary (1) From Mr. Curtis Weaver, USGS, Raleigh, NC, USGS Method For Estimating Low Stream Flow. Englowring and Environmental Eevins 12030 Sunrso Valloy O N2, Sui1D 250, Reeton, V,rginla 20191 7031391-2524 Fax 70VS91.2005 �J i. AU6.30.1599 5:13RN HPRDIN6 LP.WSON RSSOCIRTES i . NO.Ee2 P.3i3 Ms. Susan Wilson August 27, 1999 Page 2 Harding Lawson Associates Table 2. Calculation of The Proposeel IWC (at low flow) Parameter Formula Result Effluent Disoharge Design Flow, Q,, cfs D,045 Dilution Factor, DF (7010 (cfs) + QoK (cfs))I%ff (cfs) 11.996 Instream Waste Concentration, IWC (1IDF) " 100 8.336 Mr. Kevin Bowden and Ms, Christy Robeson of the DWQ Aquatic Survey and Toxicology Unit reviewed the IWC calculation. Please contact the undersigned of FILA if additional information is required. We look forward to your favorable determination. Harding Lawson Associates Jan Smith, P.E. Principal Engineer Cc: Olen Foster, AMP Inc DESIGN CALCULATIONS Force Main Head Loss and Pump Requirement 1 12 : 0 9 PM HARDING LAWSON ASSOC Knagm Lawsm Amewdet" Engime" and PROJECT SUBJECT NO. 3 8 9 2 P. 2 SHEET OF JOB NO. DATE COMPUTED BY CHECKED BY i FI= •IA-1. __. 1999 12:11PM HARDING LAWS,)N ._zoC Pd4 ?392 P. Herding Lawson Assoelstes Englneedng and Envirommenial SenAcss PROJECT SUBJECT SHEET Z OF-77_ JOB NO. d Z D DATE -3- r- COMPUTED BYl i CHECKED BY .I�7 - - - ..... _. i Ilk I ' - '-�ryV 1- . — — -- -- t - - -- -- ------------ L i _1 I I j__ __ __ I _ ( __ ! _ � i.. I i i I 1 I I 1 7 ' - = - --- - "-- -' - - - - - _ 1 --- 1 1 - - - -.- --- I , i At i I }� - r`Lx r-� :- Z - --- - - - - -- - - I , - 1 ' ' ! I s.l -l� , - I i I - I I I. � .._.. T i • I AMP Inc. ChurEh Street NPDES Force Main Discharge Sheet 3 cf 3 GA40682\ChurchXNPDES AMP Inc. Church Street NPDES Force Main Discharge Buried Pipe Deflection OD 2.3750 K 0.1000 D 1.5000 w 50.7986 PS 174.9955 E' 2000.0000 E 133000.0000 DC 1.6667 SD 120.0000 SDR 17.0000 t 0.1481 1 0.0003 R 1.1135 Soil Press 20.0000 X 0.0515 -616 Deflection 2.1667 OK allowable is 5% orth Carolina rtment of Environment nd Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne Ker T. 0 McDevitt, Secretary oc L 2 4 1999 1� _ DfN^ -IT I D August 26, 1999 Mr. Glen L. Foster, Project Manager Global Environmental Services Health and Safety AMP Incorporated P.O. Box 3608 Harrisburg, Pennsylvania 17105-3608 Dear Mr. Foster: NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RF-50URCES j�S ov\ Subject: Additional Information Request Permit Modification AMP Inc- Groundwater Remediation NPDES Permit No. NCO085821 Guilford County A letter of request for a permit modification. along with supporting documentation, was received May 15. 1999 by the Division of Water Quality and has undergone an initial review. Because the modification request involves relocation from an unnamed tributary to the mainstem of North Buffalo Creek, the Division considers this request a major permit modification which must be publicly noticed in the regional newspaper. Additionally, a major modification request of this permit is subject to an administrative Lee of 5215.00 This was discussed August 10, 1999 with Mr. Jan Smith of Harding Lawson Associates. The Division apologizes for any initial confusion regarding the required fee. AMP has also requested in this modification that monitoring for certain parameters be eliminated. Multiple data for organic parameters and lead was included with the modification request. However, AMP also requested elimination of other inorganic and metal parameters. If AMP has data available for those constituents (taken at the effluent or at any of the monitoring wells), that data would potentially support removal of those parameters and expedite the modification request. Those inorganic parameters were required initially due to the detection of them in the facility's groundwater monitoring tests. Please compile and submit any effluent or other data which may support your request. Total suspended solids and ofl/grease will be removed from the permit as these parameters are not expected to be present with the treatment provided. 1617 Mail Service Center, Raleigh, North Carolina 27699.1617 919 733-5083, extension 510 (fax) 919 733-0719 An Equal Opportunity Affirmative Action Employer Susan_Wilson@ncmail.net AMP INCORPORATED (038-55) P.O. BOX 68355, HARRISBURG, PENNSYLVANIA 17106-8355 REMITTANCE STATEMENT VENDOR NO: VENDOR NAME: CHECK DATE: CHECK NUMBER: AMP Incorpgrated Phone: 717-564-0100 Gam L. Foster P.O. Box 3608 w .amp.com Direct Dist: 717/810-3858 I LJ` ��/ Harrisburg, PA Mail Stop 021-020 17105-3608 FAX: 717/810-3888 Q USA Blfaete�unp.com ...........-................................................................................................................................................................................................................ May 11, 1999 M113b�/1� Mr. David Goodrich, Supervisor NCDENR-DWQ NPDES Unit P.O. Box 29535 Raleigh, NC 27626-0535 RE: NPDES Permit Modification and Authorization to Construct AMP Incorporated, 1126 North Church Street Greensboro, Guilford County Permit No. NCO085821 Dear Mr. Goodrich: AMP Incorporated (AMP) hereby requests Authorization to Construct (ATC) a new effluent discharge line and a modification to the NPDES Permit for our Church Street site groundwater treatment system (Permit No. NC0085821). The requested ATC and NPDES permit modification is for relocation of the current discharge point, an unnamed tributary to North Buffalo Creek, to a new discharge point at North Buffalo Creek. The new discharge location is approximately 1,500 lineal feet downstream from the current location. No other structural modifications are requested. It is our understanding these modifications are minor and, at this time, no formal application or fee is required. AMP also would to like notify the NPDES Unit that we have retained Harding Lawson Associates (HLA) to serve as our engineering and technical consulting representative for design and construction of the new discharge line and implementation of the NPDES permit modification. All technical questions should be directed to Mr. Jan Smith, P.E. of HLA. He can be reached by telephone at (919) 481-1660. Proposed Structural Modifications The treatment system is located at 1126 North Church Street in Greensboro, North Carolina. The treatment system consists of a series of groundwater extraction pumps and piping that transport groundwater to a small treatment system. The treatment system consists of an influent holding/equalization tank, two in -series air stripping towers, two in -series carbon vessels, and in -plant pumps, flow meters and appurtenances. The current flow is approximately 9 gpm (13,000 gpd). Mr. Don Geddes of the DWQ- Groundwater Section, Winston-Salem Regional Office has been the case manager for this site for a number of years and is very familiar with the treatment system and the history of the site. In addition to Jan Smith, Mr. Geddes should be contacted if you have any questions regarding the operations of the treatment system. The proposed modification includes changing the permitted effluent discharge point from an unnamed tributary to North Buffalo Creek to North Buffalo Creek at the confluence of the same unnamed tributary. Mr. David Goodrich May 11, 1999 Page 2 Consequently, a new In -stream Waste Concentration (IWC) for chronic toxicity testing must be developed based on the 7Q10 flow of the new receiving stream. A two-inch force main is proposed to convey effluent groundwater to the new discharge point. The force main will tie into the existing pump station at AMP's groundwater treatment system. The proposed alignment of the force main will parallel an existing City of Greensboro storm sewer. The force main will be constructed within the City's storm sewer easement, which has been approved by the City of Greensboro Department of Water Resources and the City Attorney's Office. The approximate force main alignment is presented in the attached plan sheets. The alignment will be verified during construction. The estimated future discharge flow (design flow) is 20 gpm (29,000 gpd), which is less than the current permitted flow. Proposed Permit Modifications Flow The permitted flow is 0.0576 MGD (40 gpm). However, the current actual flow is 9 gpm and the estimated future average flow is 20 gpm (0.0288 MGD). Therefore, AMP requests that the more accurate estimated future flow of 0.0288 MGD be reflected in the permit. Effluent Limitations —Monitoring Requirements and Frequency The current permit requires monthly monitoring for a number of chemical parameters that are not associated with the impacted groundwater at the site. The groundwater is impacted by chlorinated solvents (tetrachloroethene, or PCE, is the primary constituent of concern), which are effectively monitored for by EPA Method 601. Thus, AMP requests that chemical parameters not associated with the impacted groundwater be deleted from the monitoring requirements. These parameters are Total Suspended Solids, Oil and Grease, Benzene, Toluene, Arsenic, Chromium, Copper, Iron, Lead, Manganese and Zinc. To support this request for deletion of these parameters, attached are Tables 1, 2-1, 2-2 and 2-3, which summarize the results of monthly effluent monitoring for VOCs, BTEX, TPH and Total Lead for the last 12 months. Effluent VOCs are voluntarily measured on a monthly basis for internal operating control. Effluent BTEX, TPH and Total Lead are measured as required by the pretreatment permit issued by the City of Greensboro. As summarized in these tables, the monitored constituents are either not detected or, if detected, at low concentrations below applicable water quality standards. Low levels of Total Lead have been periodically detected because of the testing methods specified by the City (EPA Method 3030C); which requires an unfiltered acidified sample that captures background lead from sediment. In addition, no pH monitoring is specified in the current NPDES permit. If, during your review of the pernut modification, pH is determined to be required, AMP requests that a pH range appropriate for the background groundwater chemistry conditions be used. Background groundwater pH at the site ranges from 5.3 to 8.1 (Table 3) and it is this background pH that influences the treatment system final effluent pH. Therefore, if pH is required, AMP requests that a pH range of 5.0 to 9.0 be incorporated into the modified permit. AMP further requests that the monitoring frequency be reduced from monthly to quarterly. Because of the low discharge volume and the simplicity and redundancy of the treatment train, AMP believes a less rigorous sampling frequency requirement is justified. To support this request, attached are Tables 2.1, 2.2 and 2.3 which summarizes effluent data for the last 12 months. Ten years of similar data are on file with LADATA\GES%=e&atim\Church St\NPDES Modification Rque doc Mr. David Goodrich May 11, 1999 Page 3 Mr. Don Geddes of the DWQ Winston-Salem Regional Office. No compounds have been detected in the effluent by Method 601 since 1989. Need For The Modification IWC and Chronic Toxicity Testing Chronic toxicity testing was conducted during start-up of the treatment system prior to initiating a discharge. The pilot testing demonstrated that the effluent groundwater discharge could not consistently meet the limitations specified in the permit at the current discharge point. Consequently, AMP has never used its NPDES Permit at this site. In lieu of discharging to the unnamed tributary as specified in the NPDES permit the effluent was split into two streams. A portion of the effluent is directed to the City of Greensboro sewer system under a pretreatment permit, and a portion of the effluent is discharged back to the subsurface groundwater. Both discharges are limited by the allowable flow. The effluent flow that is directed back to the subsurface groundwater is at the maximum absorptive capacity of the on -site soils. The maximum allowable discharge rate to the POTW, which is established in the pretreatment permit, is 10 gpm. The combined capacity of these two discharge points is less than the expected future discharge flow. In addition, because the treatment system effluent is clean groundwater, there is uncertainty in how long the City will allow this discharge to take up useful capacity at their wastewater treatment plant. Thus, AMP is seeking an alternative effluent discharge plan that uses our NPDES permit for its intended purpose. However, because the current permitted receiving stream drains a very small sub watershed, the 7Q10 is low and the resulting IWC is high (90%). Consequently, as described above, the effluent could not consistently meet the permitted chronic toxicitylimitation. Data.and Information for Modification Approval For your information we have included a summary of the flow and water quality conditions at the new discharge point. These data were obtained from interviews with state and federal personnel that the NPDES Unit typically relies upon to complete their review. AMP calculated an IWC for the new discharge location as well. The key personnel interviewed for this modification request included: Mr. Curtis Weaver, Stream Low Flow Analyst, USGS; Mr. Kevin Bowden and Ms. Christy Robeson of the DWQ Aquatic Survey and Toxicology Unit; Ms. Andrea Leslie of the Water Quality Planning Branch; Mr. Mike Mickey of the Winston-Salem Regional Office; and several personnel within the NPDES Unit. The data and information obtained include the following: 7QI0 and IWC Curtis Weaver (USGS) was contacted to provide an estimate of the Summer 7Q10 flow conditions at the proposed discharge point (the confluence of the unnamed tributary at North Buffalo Creek, see Figure 1). Mr. Weaver reported that the estimated 7Q10 under natural flow conditions is 0.49 cfs. Based on the 7Q10 and AMP's estimated effluent discharge flow (20 gpm), the IWC is estimated to be 8.4%. The IWC calculation was reviewed by Kevin Bowden and Christy Robeson. They confirmed the calculation and the IWC based on the effluent flow data provided by AMP and the 7Q10 provided by the USGS. LADATkOEM mediatiionThurch St\NPDES Modificafion Requestdoc Mr. David Goodrich May 11, 1999 Page 4 Stream Classification and Impaired Rating (303d List) The proposed discharge point is located within a segment of North Buffalo Creek that appears on the 303d list; thus, the stream segment has an impaired rating. In addition, the stream segment is in the Cape Fear Watershed Basin and is classified as C NSW. Andrea Leslie was contacted to determine problem parameters of the impaired segment. Ms. Leslie indicated that the problem parameters include fecal colifomt bacteria and ammonia, and the biological community is impaired. According to personnel within the NPDES Unit, these parameters are typical of municipal wastewater treatment plants and should not impede the permit modification for an effluent groundwater discharge. Winston-Salem Regional Office Comments Mike Mickey of the NPDES Unit, Winston-Salem Regional Office indicated that he is familiar with the site and treatment system and is not aware of any concerns that would impede the permit modification. Three sets of plans and specification for the proposed force main and three sets of force main design calculations are attached. Please contact the undersigned or Jan Smith of HLA if additional information is required. We look forward to your favorable determination. AMP Incorporated k� - -644- Glen L. Foster Project Manager Global Environmental Services Health and Safety Enclosures cc: Jan Smith, Harding Lawson Associates LADATA\GES\R=cdia ion\Church St\NPDES Modification Requestdoc `\u✓� �� / Environmental Resources L � Management 7300 Cannel Executive Park t Suite 200 Charlotte, NC 28226 (704) 541-8416 October 27,1998 dI�1 WWW �(` (� �] (704) 541-816 (Fax) Zr Mr. Dave Goodrich ENR/DWQ P. O. Box 29535� Raleigh, NC 27626-0535 ` �� bject: Wetland Pilot System rERM AMP, Inc. Site in Greensboro, NCB' w t iweat a NPDES Permit No. WQ0004491 r,�Don 'Y "^ - wl l�l �eaz Mr. Goodrich: c 7 Z�In a letter to you dated September 29,1998, we advised you of our Q-'4innterest in constructing and operating a pilot -scale constructed wetland �i system at the AMP, Inc. site in Greensboro. The purpose of this pilot 3 project will be to demonstrate the feasibility of using a wetland process co for polishing treatment after an existing on -site ground water treatment system and prior to discharge to a nearby stream via terms of the subject - t NJ NPDES permit. After several conversations with Paul Clark of your office, it is our Runderstanding that we do not need a formal permit from your office to I 'cbnduct the study outlined above. As a result of these conversations, we `^-CCU o Qkagreed to prepare the following description of how we anticipate the study will be conducted. We have deliberately not proceeded with any v design activities until we advised your office of our intent and received at least preliminary concurrence with our concept. Therefore, the '11ollowing explanation will lack some details. On the other hand, we Y think that there is sufficient information provided herein to give you a good understanding of how we would conduct the study. b -?The size of the pilot system will be dependent upon the size and shape of q ` athe areas available on the site. Ideally, we like to use a minimum size of • � 25 feet by 100 feet. Preparation of the test plot will consist of clearing rand grading the test site into a relatively flat area. Only enough soils will be excavated to create one to two feet high berms around the plot. The Z, excavated soils will be used to construct the berms. Therefore, less than Q ,one foot of cut is anticipated. If the finish grade soils are found to be �imoderately or more than moderately permeable, powdered bentonite a`k will be mixed into the top several inches of soil to create a low Mr. Dave Goodrich Page 2 October 27,1998 permeability surface layer. After the test plot is prepared, it will be planted with a mixture of several different types of vegetation, most of which will be tolerant to wet soil conditions. We plan to operate the system by taking a portion (ranging from 1 to 10 gpm) of the treated effluent from the existing ground water treatment system and routing it to the test plot. We will start loading the plot at relatively low hydraulic loading rates to allow the vegetation to grow and to acclimate the naturally occurring microorganisms and the vegetation to the treated ground water. After operating for a period of time (typically two to four weeks) at a specific hydraulic loading rate, the test plot effluent will be tested to determine whether it meets the limitations of the current NPDES permit, including the aquatic toxicity requirement. If the effluent sample meets the permit conditions, the hydraulic loading rate will be increased. After another two to four weeks, the effluent will be sampled and tested again. This process will continue to the point where the effluent sample no longer meets the permit conditions. This will establish the design loading rate for the full scale system. Our plan is to design the test plot so that the effluent flow from the plot can be captured and directed to either the on -site infiltration trenches or to the local POTW, both of which are currently permitted. The test plot will also be designed to prohibit surface run-on from storm events and a simple cover will be used to prevent rainfall from falling directly on to the test plot. Thus, it is unlikely that there will be a need to discharge to the receiving stream. The length of time needed for testing is unknown at this time. Unlike pilot systems using conventional technologies, the wetland test plot will require time for the vegetation to establish itself. It will then take several weeks under each loading rate condition for the system to become acclimated to the increased loading rate. Finally, we cannot at this time predict the maximum loading rate that can be used before the system no longer performs satisfactorily. A study of this nature typically takes . between nine months to a year to obtain sufficient data upon which to base a full-scale design. Environmental Resources Management. �y ,r e !'.�.c (�yy :..f„r(/.L� �b�✓".,..fi�": t*7VaY Mr. Dave Goodrich Page 3 October 27,1998 We will be glad to provide your office with any additional information that you require as we design and conduct the study. We will also keep you apprised of our progress. Sincerely, Thomas M. Wilson, P.G. cc: Glen Foster Jan Smith Steve Earp e 0 (,,-e, &tzd (ws R0 - wQ S) P u" Don Deemer, P.E. Environmental Resources Management. �041je(WsRo-Gw� s� �krA�� dl 0 V / r-s.'Q io6, w sly-� ,t./ a kt-'/d 46 C 11 a0)4 ,, ll-ec o .,.c.. >/ �1 w� 'ja lv Q S r.�-c�aa a� y o ti ,a � , �2�.0/1*1 uae. 109/29/98 TUE 10:16 FAX 1 704 541 8416 ERN-Southeast,Inc. (6 001 FACSIMILE COVER PAGE To: c 3 /E- C�ao�rlr� Company: Fax Number: Front: Project Number: Date: Number of Pages., 709'd 9- "2Q- V / (including cover) Comments: /OIRI.q '- c'oey�GaQa /Ian ti/ ww row �o oc �vtw� coo /� od�oC �6rt/Pe. 1 In�jo. fldC . V/V vµ' s pc1 ``AA ( PRIVILEGE AND CONFIDENTIALITY NOTICE This message is intended only for the use of the Individual(s) to whom it is addressed and may contain information that is privileged and/or confidential. If the reader of this message is not the intended incipient, you are hereby notified that any dissemination, distribution. or copying of This communication is strictly prohibited. If you have received this communlcotien in error, please notify us Immediately at (704) 541- 8345 and return the origind message to us at the above address via the US Postal Service. Thank you, /,(you do not nerve allpages, Please contact (704)'- 5441345. 1,t,,�/��`1 10 - ,dl Tt8'.1 eoa.ee A— Lit�`� d doe � ataw t V17 y� 1 Environmental Resources Management 7300 Carmel Executive Park Suite 200 Charlotte, NC 28226 (704)541-9345 (704)541-8416 (Fax) (a) r. ■ G�nwN rn J =..; r., r 7., rkmo. sy '� .57 M � B,�Ino w!/ YVJ�{a�GM�xq _ly1/_y . Oaf af Cl "'o ff �hy � �� moq res�7.vn �✓'y �A O�i�`+J -p ,)-+✓• , J pa^ ���*'�Y { 0/ cad �4ly may,; p� *���"i �� I d'°a �ucD FY7� ly2 yd (/ `"�111 %.rri -fir r..pt�`y�.�,�r✓-yam �nr*'r✓y� � p�,�,p7+c1 '09/29/98 TOE 10:16 FAX 1 704 541 8416 ERA-Southeast,Inc. U 002 n September 29,1998 Mr. Dave Goodrich DENR/ DWQ P. O. Box 29535 Raleigh, NC 27626-0535 Subject: AMP, Inc. Site in Greensboro, NC NPDES Permit No. VVQ0®94491-- Dear Mr. Goodrich: /VCOO 858a IVia Fax: 919-715-0588 AMP, Inc. is currently operating a ground water remediation system at its Church Street Site in Greensboro, NC. Recovered ground water is treated via air stripping and activated carbon. The discharge alternatives for the treated ground water include (1) ground water recharge via on - site infiltration trenches, (2) discharge to the local POTW, and (3) discharge to an unnamed tributary via NPDES permit number WQ0004491. The on -site infiltration trenches have been found to have limited capacity and, being in the central portion of the site, these trenches may limit future development of the site. The local POTW has capacity limitations and can take only a portion of the treated ground water flow. Therefore, the NPDES discharge is becoming an increasingly favored alternative. In order to provide an additional measure of treatment and protection for meeting the NPDES permit requirements, we have suggested to AMP that consideration be given to polishing the treated ground water with a constructed wetland system. The wetland process could be installed on a portion of the property that would be out of the way of future site development and would receive treated ground water from the current ground water treatment system prior to discharge to the unnamed tributary. We have further suggested that a small pilot -scale system should be installed and operated at the site to verify the treatment potential of the process and to develop design criteria for a full-scale system. Environmental Resources Management 7300 Carmel Exccutive Park Suite 200 Chmiotte, NC 28226 (704)541-9345 (704) 541-8416 (Fax) 43� its,$ *09/29/98 TUE 10:17 FAX 1 704 541 8416 ERM-8outheast.Inc. f@a03 Mr. Dave Goodrich Page 2 September 29,1998 We are hereby requesting your advice as to how to proceed with a pilot - scale wetland system. What type of approval would be required from DENR/DWQ to construct and operate the pilot system. Please recognize that we are not at this time requesting a permit modification to install a full-scale wetland system_ This request is simply related to how we handle the pilot -scale testing. We would appreciate your advising us as to how we should proceed. Please call me at your convenience. Sincerely, x4W4,9 Ai Thomas M. Wilson, P.G. Principal cc: Paul Clark (DENR/DWQ) Glen Poster (AMP) Jan Smith (HLA) Steve Earp (SHMM) R/tom/amp/rtPdesltr Environmental Resources Management. State of North Carolina Department of Environment, Health and Natural Resources �� Division of Water Quality r James B. Hunt, Jr., Governor r f� Wayne McDevitt, Secretary p E H N F� A. Preston Howard, Jr., P.E., Director September 12, 1997 Mr. Martin O'Neill AMP Inc. Post Office Box 3608 Harrisburg, Pennsylvania 17105-3608 Subject: NPDES Permit Error Modification NPDES Permit No. NCO085821 AMP Inc./Church Street (Building 42) Guilford County Dear Mr. O'Neill: On February 26, 1997, the Division of Water Quality issued NPDES Permit No. NCO085821 to AMP, Inc. A review of the permit file has indicated that the flow limit was omitted from the Effluent Limitations and Monitoring Requirements page. We are forwarding the modification to correct the error. Please find enclosed the modified section of the permit referenced in the first paragraph. Replace the original section in your permit with the newer enclosed section and discard the original section. All other terms and conditions contained in the original permit remain unchanged and in full effect. This permit modification is issued pursuant to the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U. S. Environmental Protection Agency. If any parts, measurement frequencies or sampling requirements contained in this permit modification are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this decision shall be final and binding. If you have any questions concerning this permit modification please contact Paul B. Clark at telephone number (919)733-5083, extension 580. Sincerely, /f/ A. Preston Howard, Jr., P.E. cc. Central Files /_ Winston-Salem Regional Office, Water Quality Section Point Source Compliance/Enforcement Unit Aquatic Toxicology Unit P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper A (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NC0085821 During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated groundwater at outfall number 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Weekly Daily Measurement Sampl=Sa Average Average Maximum Frequency Type Flows Total Suspended Solids 0.0576 MGD Continuous Recorder Effluent Oil and Grease 2 30.0 m /I Monthly Grab Effluent 1,1 Dichloroethene 1,1 DCE ---Monthly Grab Effluent 1,1 Dichloroethane 1,1 DCA Monthly Grab Effluent 1,2 Dichloroethene 1,2 DCE)-----Monthly Monthly Grab Effluent Tetrachloroethene PCE Grab Effluent 1,1,1 Trichloroethane 1,1,1 TCAMonthly ---MonthlyGrab Effluent Trichloroethane TCE Grab Effluent Meth Chloride Monthly Grab Effluent Benzenene ---MonthlyGrab Effluent Toluene---MonthlyGrab ---MonthlyGrab Effluent Arsenic---MonthlyGrab Effluent Chromium----MonthlyGrab Effluent CopperMonthlyGrab Effluent Lead Effluent IronMonthlyGrab ---MonthlyGrab Effluent Man anese Effluent Zinc MonthlyGmb Effluent Chronic Toxicit 3 Monthly Grab Effluent Quarterly Composite Effluent Notes: 1 If the discharge is not continuous, flow may be monitored weekly by an instantaneous flow estimate. 2 Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. 3 Chronic Toxicity (Ceriodaphnia), P/F at 90%, January, April, July, October, See Supplement to Effluent Limitations and Monitoring Requirements - Special Conditions page A (2). There shall be no discharge of floating solids or visible foam in other than trace amounts. Design and construction of waste treatment facility will emphasize the use of plastic pipe and fittings where practically possible. Special permit conditions applicable to the subject facility are listed on the Supplement to Effluent Limitations and Monitoring Requirements - Special Conditions page. DESIGN CALCULATIONS Force Main Head Loss and Pump Requirement MA . '_. 1999 12: I IPM HARD i IG LA19SU'1 A._ 'U , 110.3892 P. 3 PROJECT SUBJECT Harding Lawson Associates Engineering and Envimrnnental Servkes SHEET 77- CF JOB NO. DATE COMPUTED BY tR CHECKED BY ,I!�2 I 1 I r • iUv : I� I I i � I .I I I I ' � i I i � � - I i i I S A I------------ Ll Ii i i I i i I I , ------------- I ` I r i I 11i ' : Lam.; r f I : - • -Z- --------�--- I i --�- - - ----- ---------- - I� - � i • i- I�-- ' I ? ._... . .I ._:--�' + - -�� - - --�-- . - - -_ZED -- I • I 1 I i 1 ..5q '1 I r i - ---- - - - - ---- -- -- -- -- - --'-- --' ------------- AMP Inc. Chureh Street NPDES Force Main Discharge Sheet 3 of 3 G:M0662lChurchlNPDES AMP Inc. Church Street NPDES Force Main Discharge Buried Pipe Deflection OD 2.3750 K 0.1000 D 1.5000 w 50,7986 PS 174.9955 E' 2000.0000 E 133000.0000 DC 1.6667 SD 120.0000 SDR 17.0000 t 0.1481 1 0.0003 R 1.1135 Soil Press 20.0000 X 0.0515 % Deflection 2.1667 OK allowable is 5% O Sher � .171; r e TIM Off C� I :� y„ ♦ Fon roa• icha+� a -park f. - ,-..T, w' �4 plv S ...rrCm .. *+ Is i yItudF 36°05132' 5ub-eaain: Longitude: 79`4703' Quad. #: C195W 5trcam Clara: CNSW Raoe'v'na Stream: Unnamed tributary to North Buffalo Creek permittrA Fioz 0.0256 MGD Facility yy Location TYfA ECu ffiu Carpwatbn GuWonord wunq