NC0088838_Comments on Draft Permit_20180314

# RSC
Chemical Solutions
a division of Radiator Specialty Company
March 14, 2018
Mr. Ron Berry
Environmental Engineer
North Carolina Department of Environmental Quality
Division of Water Resources RECEIVED/DENR/DWR
NPDES Permitting Branch MAR 9 2018
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 Water Resources
Permitting Section
Re: Comments to Draft NPDES Permit
Permit No. NC0088838
Class 1
Radiator Specialty Company
600 Radiator Road, Indian Trail, Union County, North Carolina
Dear Mr. Berry:
Radiator Specialty Company (RSC) respectfully submits for your review this response to
the February 7, 2018 draft NPDES Permit for the groundwater recovery and treatment
system at the Indian Trail, North Carolina facility that RSC received on February 14,
2018. As you know, this remediation system has been in operation since 1994. Initially,
the effluent was discharged to the Union County Publicly Owned Treatment Works
(POTW). In 2009, RSC received a National Pollutant Discharge Elimination System
(NPDES) permit to discharge the effluent to an unnamed tributary to the South Fork of
Crooked Creek.
During twenty-four (24) years of operation, the groundwater recovery and treatment
system at RSC has accumulated a substantial volume of analytical data that indicates the
effluent incorporated in this permit is very consistent.
Part I A.(1) Effluent Limitations and Monitoring Requirements
• Page 3 of the draft permit states that flow shall be measured with a totalizing
flowmeter. The Supplement to Permit Cover Sheet calls it an "effluent meter with
recorder". RSC respectfully requests the requirement for a recording flow meter
be removed from the draft permit.
• The draft Permit includes daily maximum limitations and monthly testing
requirements for total suspended solids (TSS). Based on historic data (See Table
1). TSS has been detected a total of six (6) times over a period of eight (8) years
0
600 Radiator Road— Indian Trail, NC 28079-5225— Telephone [phone]— Fax [phone]— www rscbrands corn

Mr. Ron Berry
March 14, 2018
Page 2
at concentrations slightly above the method detection limit. These detected
concentrations ranged from 3 to 21 milligrams per liter (mg/L) and are well below
the Proposed Permit Limit of 45 mg/L.
TSS analysis prices range from$15 to $20 per sample Based on these costs,
elimination of the parameter from the monthly sampling requirement would save
RSC between $180 and $240 per year, or up to $1,200 during the life of the
Permit.
Based on the consistent nature of the effluent, the lack of TSS concentrations in
the eight (8) years of historic effluent sampling data, and the unnecessary cost
associated with these tests, RSC respectfully requests this Monitoring
Requirement be removed from the draft Permit.
• The draft Permit requires monthly pH testing. While pH is not a Monitoring
Requirement in the expired Permit, RSC has periodically collected pH data in
conjunction with the required parameters (See Table 2) This data has been
collected in general accordance with North Carolina Department of
Environmental Quality (DEQ) protocol, but not by a North Carolina Certified
Laboratory As indicated in Table 2, the pH samples historically collected from
the effluent have consistently been between 6 0 and 9 0 Standard Units (SU) To
comply with the pH sampling requirement of the draft Permit, RSC will be
obligated to retain a North Carolina Certified Field Laboratory to collect the
monthly effluent samples. Use of a Certified Laboratory will increase the
sampling cost by up to $150 per month, or $9,000 during the life of the Permit.
Based on the consistent nature and the consistent pH values documented in
historic data, and the additional cost RSC will incur to implement pI-I testing of
the monthly effluent samples, RSC respectfully requests this Monitoring
Requirement be removed from the draft Permit.
• The draft Permit requires quarterly testing for 1,4-dioxane with a proposed
effluent limit of 80 micrograms per liter (µg/L) This compound was not a
monitoring requirement in the expired Permit.
RSC understands that no federal maximum contaminant level (MCL) for drinking
water has been established for 1,4-dioxane. While North Carolina has established
a Groundwater Quality Standard for 1,4-dioxane of 3.0 µg/L, no other state or
federal standards have been established Further, RSC understands that the DEQ
has no Surface Water Quality Standard for 1,4-dioxane under North Carolina
Administrative Code, Title 15A, Subchapter 2B (15A NCAC 2B). North Carolina
has proposed 80 µg/L as a guideline protective value for surface waters for 1,4-
dioxane. It is RSC's opinion that the DEQ does not have the authority to establish
an Effluent Limitation based on a regulatory guideline and not a written
regulation

Mr. Ron Berry
March 14, 2018
Page 3
On March 28, 2017, the DEQ, Division of Water Resources, Water Sciences
Section published a paper entitled 1,4-Dioxane and Bromide Monitoring Plan
(See Attached) In this study, the DEQ outlines a sampling and analysis program
underway to evaluate 1,4-dioxane concentrations in specific surface waters of
North Carolina This study is not anticipated to be completed until June 2019.
Based on the lack of a federal MCL, the lack of an established 15A NCAC 2B
standard and the fact that the DEQ is in the process of conducting a study
evaluating 1,4-dioxane concentrations in surface water bodies of North Carolina,
it is RSC's opinion that including an effluent limit for 1,4-Dioxane in the draft
permit is not appropriate at this time. RSC proposes to continue to sample
quarterly for 1,4-dioxane and report these results to the DEQ RSC respectfully
requests the Permit Limit for 1,4-dioxane, the monthly Monitoring Requirement
in the event of an exceedance, and the Reopener Clause be removed from the
draft Permit
We appreciate your consideration of these concerns. Please call or email if you have any
questions or require any additional information.
Sincerely,
Radiator Specialty Company
. it,i/Ap (61 j
Stuart Kerkhoff, CHMM
Environmental Heath and Safety Manager
Attachments
cc Richard L Harmon, Harmon Environmental
Amanda Kitchen Short, McGuireWoods LLP
NPDES\MAI-I NPDESPERMI I RESPONSE2018 DOCX

TukIe1
Total'Suspended Solids
Radiator Speczlly Company
Indian Trntl, North CaroLira
Permit No, NC008'8838
2010 - 2011_ 2012 _ 2013 2i�l4 2015 1 2016 _ 2017 -- 2018 =i
January _ <5 <5 ,; <2,6 <2 5 <26
Feb,ruery <5 _ _ e'5 , , Vie` <2 6 <Q 26 X2.5
March <5 <5 <2 5 <2,5
April <5 <5 <5 - <5 <2,5
May <6 2 <12 <5 fr - " <5 <2a5 «,5
i )idle <5 <5 <5 <2,5 <2 5 <2 5 '
July <5 _<5 <5 <2,5 le- <2 5 <2 5
August <5 _ <5 <5 <5 <2 .5 '""X‘'' a <2,5 <2.5 _
5ept,ember 21 <5 <5 <5 <2.5 <2 5 6.7 3,0 '
October <5 <5 <5 <5 _ <2,6 <2 5 i 3 2 <2.5
November _ 11 __ <5 <5 5.4 <2 5 _ <2 6 <2.5 i <2.5
December <5 <5 <5 <5 I <2,6 <2 5 <2 5 <2 5
ATI dutu pr.esenred rn thts table it preserriMd in milligrarus per Iitter 1mg/L),
Proposed Total Sulpendod'Solyds Limit In the Drefr Petmrt is 45 rrtg/L
The Proposed Monthly Average Limit in fhe Druft PenTdf is 30 mg/,L
April 2011 - No Flow
February 2012, through March 2012 . NQ Flot<
fpebrLrary 2013 through Augu�1 2013 -No'Flow
January 0113 through Math 2013 -No FtOV
January 2015 through August 2015 =No Flow
July 2016 Returnied k-1 to ysterr?
August 2016 through Septernrs r 2016 R-1 Not Opera,tIone,l
Bold irrdicatts d detecttrbth coecerrlratic of T'01 a 5uvendod SO.11d$

Table 2
pH
Radiator Specialty Company
Indian Trail, North Carolina
NC0088838
5/7/2008 11/5/2008 12/8/2010 11/8/2013 11/10/2014 11/17/2015 11/16/2016 11/20/2017
pH 83 78 78 74 78 78 80 73
•
Notes
pH checked using an Orion pH Meter with Orion Triode calibrated on the date of pH Measurement in 2008 and 2010
pH checked using a Hanna Instruments H198127 pH Meter calibrated on the date of pH Measurement in 2013, 2014 and 2015
pH checked using an Eco Tester 2 pH Meter calibrated on the date of pH Measurement in 2016 and 2017

Attachment 1
NC Division of Water Resources
1 , 4Dioxane and
romi a
Monitoring
Plan
In Support of NFWF-Funded Project ID#8020.16.054182
Water Science; Section
3-2E-2017

NC DWR 1,4-Dioxane and Bromide Monitoring Plan 2017-2019
Background
1,4-Dioxane
1,4-dioxane is an organic compound that readily dissolves in water at all concentrations, is persistent in
the environment,and is difficult to remove through standard water and wastewater treatment processes.
It is used as an industrial solvent and formed as a byproduct of some industrial processes. The compound
has been characterized as"likely to be carcinogenic to humans"and identified as a potential contaminant
of concern in public drinking water by the United States Environmental Protection Agency(USEPA).
1,4-dioxane was recently monitored in selected finished drinking water supplies nationwide under the
USEPA's Third Unregulated Contaminant Monitoring Rule (UCMR3). The USEPA uses UCMR studies to
determine the extent of contamination and provide data for the consideration of new drinking water
regulations. UCMR3 data indicated that finished drinking water from at least 23 large (serving> 10,000
people) utilities in North Carolina contained levels of 1,4-dioxane in excess of the NC calculated surface
water criterion (0.35 µg/L) to protect human health. Nearly all of these utilities used surface water as
their primary water source,and they were located in the Cape Fear, Neuse,and Yadkin River basins. Due
to wide-spread presence of this constituent throughout the United States as identified through the
UCMR3 study, it is possible that the USEPA will develop health-based standards for 1,4-dioxane in the
future.
A North Carolina Division of Water Resources(NC DWR)study was conducted from 2014-2016 to monitor
ambient concentrations of 1,4-dioxane in the Cape Fear River and its tributaries,and to identify potential
sources of the contaminant. This study garnered media attention and was the focus of several news
articles. In order to fully understand and identify the sources of 1,4-dioxane in NC, this study will be
continued in the Cape Fear River basin and expanded into the other two river basins(Yadkin and Neuse)
with UCMR3 1,4-dioxane results>_0.35 µg/L in public drinking water.
Bromide
Bromide in surface water has been associated with industrial and agricultural chemicals and coal ash
facilities. It is a health concern due to its contribution to the formation of trihalomethanes(THMs). THMs
are disinfection byproducts (DBPs) resulting from chlorine disinfection treatment of drinking water.
Several THMs are characterized by the USEPA as "likely to be carcinogenic to humans" or as having
"suggestive evidence of carcinogenic potential"and are regulated under the federal Safe Drinking Water
Act with Maximum Contaminant Levels(MCLs).
Based on quarterly DBP monitoring,the NC DWR Public Water Supply Section (PWS)has determined that
approximately 20% (27 of 138) of NC drinking water systems that utilize surface water sources have
elevated DBPs containing significant amounts of brominated trihalomethane compounds. Results from
these facilities included at least one sample point at which >_ 30%of DBPs were made up of brominated
compounds and the amount of DBPs was>_50%of the MCL.
Bromide samples have been collected by the NC DWR in conjunction with 1,4-dioxane sampling in the
Cape Fear River basin. Expansion and continuation of this study will involve an additional 18 months of
ambient and source identification monitoring throughout the state Initially, this will be targeted
Page 1 of 6

NC DWR 1,4-Dioxane and Bromide Monitoring Plan 2017-2019
upstream of the NC public drinking water treatment facilities identified by PWS monitoring as
experiencing elevated levels of brominated DBPs. Some of these facilities utilize multiple surface water
sources and/or supply water to multiple municipalities.
Objective
The NC DWR Public Water Supply Section protects nearly 6000 public water systems within NC,serving
the homes of approximately three-fourths of the state's population, as well as workplaces, schools,
restaurants,and other public facilities. The NC DWR Water Sciences Section(WSS)will monitor bromide
and 1,4-dioxane in selected surface waters used as public drinking water supply sources in order to
provide data to assist the NC Department of Environmental Quality with proactively addressing areas of
contamination. The long-term conservation outcome supported by these projects will be increased
protection of surface water as a water supply resource and increased safety of North Carolina's drinking
water.
Activities
Samples will be collected in the same stream networks as public drinking water with elevated THM and/or
1,4-dioxane concentrations. Monitoring sites will be established at current ambient stations when
possible, and additional stations will be established as needed to track sources. All samples will be
collected as near-surface (i.e.0.1-meter depth)grab samples,and will be analyzed for bromide and field
parameters(pH,specific conductance,water temperature,and dissolved oxygen). Samples from stations
in close proximity to power plants and/or public water treatment plants with elevated UCMR3 results will
also be analyzed for 1,4-dioxane.
Sampling will occur monthly for 18 months during 2017-2018 at the stream stations indicated in the map
and table below, in accordance with methods described in North Carolina's Ambient Monitoring System
(AMS) Quality Assurance Project Plan (QAPP) (NCDENR, 2014). Bromide sampling will also occur once
during the project period at the two lake stations in the table, in accordance with the Ambient Lakes
Monitoring Program(ALMP)QAPP(NCDENR,2012). All samples will adhere to the NC DWR Laboratories'
Sample Submittal Guidelines (DWR, 2016) and further instructions provided by the NC DWR Central
Laboratory for bromide and 1,4-dioxane sample collection, processing, and preservation. Quality
assurance (QA)samples, including duplicates, matrix spikes, and matrix spike duplicates will be collected
per the QAPPs and laboratory guidance.
Page 2 of 6

NC DWR 1,4-Dioxane and Bromide Monitoring Plan 2017-2019
Station LO atiott „_., L4. ..�i,, ,.: . a .� ,x - P,.4511.1 .- jD15trict 3Parameter(s') :.Issue(s)f
B0210000 Haw River at SR 1561 Hub Mill Rd. Cape Fear Central Both 2,3
B0750000 South Buffalo Creek at SR 2821 at McLeansville Cape Fear Central Both 2,3
B0840000 Reedy Fork at NC-87 at Ossipee Cape Fear Central Both 2,3
B1 Haw River at SR 1712(Brooks Bridge Rd) Cape Fear Central Both 2,3
B2100000 Haw River at SR 1713 near Bynum Cape Fear Central Both 1,2,3
B4 Haw River at Troxler Mill Rd near Reidsville Cape Fear Central Both 2,3
B6 Reedy Fork at NC-61 near Ossipee Cape Fear Central Both 2,3
DAQBELEW Belews Lake at NC 65 Roanoke Central Bromide 1,3
S08
N0150000 Dan River at NC 704 near Francisco Roanoke Central Bromide 1,3
N1400000 Mayo River at SR 1358 near Price Roanoke Central Bromide 1,3
N2300000 Dan River at SR 2150 near Wentworth Roanoke Central Bromide 1,3
N2430000 Smith River at SR 1714 near Eden Roanoke Central Bromide 1,3
N3000000 Dan River at SR 1761 near Mayfield Roanoke Central Bromide 1
N3500000 Dan River at NC 57 at VA line at Milton Roanoke Central Bromide 1
N4250000 Hyco River below dam near McGhees Mill Roanoke Central Bromide 1
N4406000 Marlowe Creek at SR 1322 near Woodsdale Roanoke Central Bromide 1
N4590000 Mayo Creek at SR 1501 near Bethel Hill Roanoke Central Bromide 1
NCSU24 Hasketts Creek at WOW Road near Asheboro Cape Fear Central Both 1,2,3
Q2810000 Yadkin River at US 64 at Yadkin College Yadkin Central Both 1
Q4660000 Yadkin River at NC 150 near Spencer Yadkin Central Both 1
Q6120000 Yadkin River at SR 1002 at High Rock Yadkin Central Both 1,2
Q6810000 Uwharrie River at NC 109 near Uwharrie Yadkin Central Both 2
07150000 Pee Dee River at NC 731 near Shankle Yadkin Central Both 1,2
07330000 Rocky River at SR 2420 near Davidson Yadkin Central Both 2
08090000 Irish Buffalo Creek at SR 1132 near Faggarts Yadkin Central Both 2
Q8220000 Rocky River at SR 1006 near Concord Yadkin Central Both 2
09400000 Pee Dee River at US 74 near Rockingham Yadkin Central Both 2
Q9916000 Pee Dee River at NC 109 near Mangum Yadkin Central Both 2
09940000 Marks Creek at SR 1812 near Hamlet Yadkin Central Both 2
B6370000 Cape Fear River at US-401 at Lillington Cape Fear Eastern Both 1,2,3
B7480000 Cape Fear River at Hoffer WTP intake at Fayetteville Cape Fear Eastern Both 2,3
B8 Cape Fear River at Harnett Cty Public Utilities intake Cape Fear Eastern Both 1,2,3
B8350000 Cape Fear River at Lock 1 near Kelly Cape Fear Eastern Both 2,3
/1890000 Neuse River at SR 2000 Neuse Eastern Both 2,3
J4370000 Neuse River at US 70 Business at Smithfield Neuse Eastern Both 1,2,3
J4510000 Neuse River at NC 42 near Clayton Neuse Eastern Both 2,3
J5970000 Neuse River at SR 1915 near Goldsboro Neuse Eastern Both 1,2,3
/6150000 Neuse River at NC 11 at Kinston Neuse Eastern Both 1,2,3
J6740000 Contentnea Creek at NC 581 near Lucama Neuse Eastern Bromide 3
N5000000 Nutbush Creek at SR 1317 near Henderson Roanoke Eastern Bromide 3
N7300000 Roanoke River at NC 48 at Roanoke Rapids Roanoke Eastern Bromide 3
C4380000 S Fork Catawba River at NC 10 near Startown Catawba Western Bromide 3
C7000000 S.Fork Catawba River at SR 2524 near S.Belmont Catawba Western Bromide 1
DAQNORM Lake Norman at Reeds Creek Catawba Western Bromide 1,3
AN08
Note: Issue Types' 1-Power Plant;2-WTP with 1,4-Dioxane;3-WTP with DBPs
Page 3 of 6

NC DWR 1,4-Dioxane and Bromide Monitoring Plan 2017-2019
*#. filY41 iiito k—^* ,,,,,,x* IVA lig*f!..? :: -'1"—*WarkTh.. '141
, .. crvc:c5,.. . ",,,,,,,6644 ,,,..s.,,i s \kl,
<9 -,-
ill' , ,n , " 1111:
y jy
+.SO,µ 1 '}Yr.`11 m.`ffi_ *.*, rp ,
V O
s 12:isti1/4,4,,,_ 4,,,,,,,* ' '
44 4
„AL
\,... -- .4.- ii
ve
Aft
NC Public Water Supply Source Monitoring 4
4
* Proposed Monitoring Stations n �ER
Districts � s £
uMtk
® UCMR3 1,4-Dioxane z0 35 pg/L Major Waters
• Surface Water Sources w/High DBPs River Basins
Miles
Power Plants o 20 40 80 120
During past 1,4-dioxane monitoring, a contract laboratory was utilized for analysis because the NC DWR
Central Laboratory did not have the analytical testing capacity to measure this compound.
Instrumentation improvements will enable the NC DWR to develop enhanced long-term data analysis and
tracking capabilities for 1,4-dioxane, as well as other volatile contaminants that may be identified in the
future. Through the acquisition of a gas chromatography mass spectrometer(GC-MS)with an automated
purge-and-trap sample preparation system, the project will build the capacity of the WSS Organic
Chemistry Branch to measure concentrations of 1,4-dioxane and other organic compounds in NC's waters
Additional funds will be utilized for the supplies and materials necessary to collect and analyze the samples
described above
Outcomes and Indicators
Laboratory instrumentation will be acquired, installed, and calibrated by June 2017 A sampling and
analysis schedule for the 2017 sampling season will be established by June 2017, and sampling will begin
by July 2017. Data will be compiled, subjected to a quality assurance process, and uploaded to the NC
DWR water quality data management system on a quarterly basis during the period of sample collection
and analysis
All project-related sampling and analysis activities are expected to be completed within the project
timeline below. The project schedule will be monitored by the project manager,and regular reports will
be made to NFWF to confirm project progress
Page 4 of 6

NC DWR 1,4-Dioxane and Bromide Monitoring Plan 2017-2019
(NCDEQ)N.C.Department of Environmental Quality,Division of Water Resources,Water Sciences Section.
2016. Sample Submittal Guidelines — DWR Water Sciences Section Chemistry Laboratories.
Available as a link from http://deq.nc.govjabout/divisions/water-resources/water-resources-
data/water-sciences-home-page/microbiology-inorganics-branch/sample-submission.
Page 6 of 6