NC0088838_Fact Sheet_20180523

Fact Sheet
NPDES Permit No. NCO088838
Permit Writer/Email Contact Gary Perlmutter, [e-mail]
Date: May 21, 2018
Division/Branch: NC Division of Water Resources/NPDES Complex Permitting
Fact Sheet Template: Version 09Jan2017
Permitting Action:
® Renewal
❑ Renewal with Expansion
❑ New Discharge
❑ Modification (Fact Sheet should be tailored to mod request)
Note: A complete application should include the following:
• For New Dischargers, EPA Form 2A or 2D requirements, Engineering Alternatives Analysis, Fee
• For Existing Dischargers (POTW), EPA Form 2A, 3 effluent pollutant scans, 4 2nd species WET
tests.
• For Existing Dischargers (Non-POTW), EPA Form 2C with correct analytical requirements based
on industry category.
Complete applicable sections below. If not applicable, enter NA.
1. Basic Facility Information
Facility Information
Applicant/Facility Name:
Radiator Specialty Company/Radiator Specialty Compan-
Applicant Address:
600 Radiator Road. Indian Trail, NC 28709
Facility Address:
600 Radiator Road. Indian Trail, NC 28709
Permitted Flow:
0.09 MGD
Facility Type/Waste:
MINOR Industrial, Ground Water Remediation
Facility Class:
Class I
Treatment Units:
EQ/collection tank, air stripper, gravity flow to outfall
Pretreatment Program (Y/N)
No
County:
Union
Region
Mooresville
Briefly describe the proposed permitting action and facility background: Radiator Specialty Company
operates a 0.09 MGD ground water remediation facility at its Indian Trail site, and had applied to renew its
NPDES permit in May 2013. The site is part of a 1994 RCRA post -closure remediation requirement.
Initially the remediated wastewater was accepted by a local utility. However, in 2009, the local utility
informed Radiator Specialty Company that it would no longer accept the wastewater. As a result, Radiator
Specialty Company applied for and was issued a NPDES permit in 2009.
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The Division was advised by the Hazardous Waste Section in 2012 that significant levels of 1,4 -Dioxane
was being reported in the monitoring wells data, which indicated migration of the pollutant in the aquafer.
This migration may result in 1,4 -Dioxane in the collected groundwater remediation influent. To assist with
development of this permit and to better characterize influent pollutants of concern, the Permittee submitted
a series of influent volatile organic analysis as requested by the Division.
2. Influent Volatile Organic Data Summary
Influent volatile organic data is summarized below for monthly samples for the period August through
December 2014.
Table. Influent Volatile Organic Data Summary
Parameter
Unit of Measure Average
Maximum
Minimum
Benzene
gg/L 1.11
1.4
0.77
Chloroethane
gg/L 13.3
15
9.4
2-Chlorotouluene
gg/L 2.98
3.3
0.81
4-Chlorotouluene
gg/L < 1
< 1
< 0.5
1, 1 -Dichloroethane
gg/L 49.0
60
41
1,2-Dichloroetheane
gg/L 0.678
0.75
0.56
1, l -Dichloroethene
gg/L 27.0
31
23
Cis-1,2-Dichlorothene
gg/L 22.8
30
20
Trans-1,2-Dichloroethene
gg/L 2.52
3.0
2.0
Dichlorodifluoromethane
µg2 4.50
6.1
3.2
1,4 Dioxane
gg/L < 80
< 80
< 80
Ethylbenzene
gg/L < i
< 1
< 0.5
Methyl ethyl ketone
gg/L < 5
< 5
< 5
Methylene Chloride
gg/L < 2
< 2
< 1
Methyl isobutyl ketone (MIBK)
gg/L < 5
< 5
< 5
Tetrachloroethene
gg/L 84.4
100
70
Toluene
gg/L < i
< 1
< 0.5
1,1,1 -Trichloroethane
gg/L 1.98
2.6
1.7
Trichloroethene
gg/L 5.94
7.4
4.4
Vinyl chloride
gg/L 1 4.72
6.5
3.2
Xylenes (Total)
µg2 <2
<2
<1
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3. Receiving Waterbody Information
Receiving Waterbody Information
Outfalls/Receiving Stream(s):
Outfall 001- UT to South Fork Crooked Creek
Stream Segment:
13-17-20-2
Stream Classification:
C
Drainage Area (mi2):
2.2
Summer 7Q10 (cfs)
0
Winter 7Q10 (cfs):
0
30Q2 (cfs):
0.07
Average Flow (cfs):
-
IWC (% effluent):
100%
303(d) listed/parameter:
This segment is impaired for Benthos and Fish Community
on the Final 2014 303(d) list, first listed in 1998
Subject to TMDL/parameter:
No
Subbasin/HUC:
Yadkin Pee -Dee; 03-07-12/03040105
USGS Topo Quad:
G16SW Matthews, NC
4. Effluent Data Summary
Effluent data is summarized below for the period September 2015 through August 2017 for limited
parameters and April 2014 through Aug .st 2017 for monitor only parameters.
Table. Effluent Data Summary
Parameter
Units
Average
Max
Min
Permit Limit'
Flow
MGD
_ _ _ _
0.082
MA 0.090
TSS
mg/L
< 6.7
6.7
-2.5
DM 45.0
MA 30.0
Chloroethane
µg/L
< 5.2
5.2
< 0.5
Monitor only
1, 1 -Dichloroethane
µg/L
< 3.3
3.3
< 0.5
Monitor only
1, 1 -Dichloroethene
µg/L
< 2.5
2.5
< 0.5
Monitor only
1,2-Dichloroethene (total)
n/L
All non -detects, < 0.5 to
Monitor only
Tetrachloroethene
µg/L
All non -detects, < 0.5 to < 3
DM 3.0
1,1,1 -Trichloroethane
mg/L
< 4
1.1
< 0.5
DM 4.0
Trichloroethene
n/L
All non -detects, < 0.5 to < 4
Monitor only
Benzene
µg/L
1
0.78
< 0..*)
Monitor only
Methylene Chloride
n/L
< 3.1
3.1
< 1
Monitor only
Page 3 of 10

1,2-Dichloroethane
µg2
All non -detects, < 0.5 to < 1
Monitor only
Toluene
n/L
< 1
< 0.5
< 0.5
Monitor only
Vinyl Chloride
µg/L
< 2
2
< 0.5
DM 2.0
'MA = Monthly Average, WA = Weekly Average, DM = Daily Maximum.
5. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when
model results for instream DO are within 1 mg/1 of instream standard at full permitted flow; 2) to verify
model predictions for outfall diffuser; 3) to provide data for future TMDL; 4) based on other instream
concerns. Instream monitoring may be conducted by the Permittee, and there are also Monitoring Coalitions
established in several basins that conduct instream sampling for the Permittee (in which case instream
monitoring is waived in the permit as long as coalition membership is maintained).
If applicable, summarize any instream data and what instream monitoring will be proposed for this permit
action: NA
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/Ag: NA
Name of Monitoring Coalition: NA
6. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): There was one reported limit
exceedance: for the daily maximum Tetrachloroethane in November 2013. As a results, a Notice of
Violation was issued.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past
5 years): Beginning in 2013 the facility had performed and passed 15 chronic toxicity tests at 90% effluent
concentration.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted
in 2016 reported that the facility was well main- _fined and operated.
7. Water Quality -Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations
for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic Aquatic
Life; non -carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): "T "
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B. 0204(b): NA
Oxy-gen-Consumingaste Limitations
Limitations for oxygen -consuming waste (e.g., BOD) are generally based on water quality modeling to
ensure protection of the instream dissolved oxygen (DO) water quality standard. Secondary TBEL limits
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(e.g., BOD = 30 mg/L for Municipals) may be appropriate if deemed more stringent based on dilution and
model results.
Ifpermit limits are more stringent than TBELs, describe how limits were developed: NA
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of
1.0 mg/L (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from chronic criteria, utilizing
a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non -Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection
of aquatic life (17 µg/L) and capped at 28 ug/1(acute impacts). Due to analytical issues, all TRC values
reported below 50 gg/L are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: NA
Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality
standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent
effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d)(i). The NC
RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero
background; 3) use of '/h detection limit for "less than" values; and 4) stream flows used for dilution
consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of
dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of
Instream Dissolved Metals Standards, dated June 10, 2016.
A reasonable potential analysis was conducted on effluent toxicant data collected between August 2013
and August 2017. Pollutants of concern included toxicants with positive detections and associated water
quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this
permit:
• Effluent Limit with Monitoring. The following parameters will receive a water quality -based
effluent limit (WQBEL) since they demonstrated a reasonable potential to exceed applicable water
quality standards/criteria based on effluent concentrations or continue to be a major pollutant of
concern, BPJ. _etrachoroethene; Vinyl Chloride; 1,4 -Dioxane (predicted)
• Monitoring On1LThe following parameters will not receive a limit, since they did not demonstrate
reasonable potential to exceed applicable water quality standards/criteria and the maximum
predicted concentration was > 50% of the allowable concentration and continue to be pollutants
of interest, BPJ. l,l-Dichloroethane; Trichloroethene: Benzene; Methyl Chloride; Toluene
• No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since
they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria
and the maximum predicted concentration was < 50% of the allowable concentration and are not
pollutants of concern, BPJ. Chloroethane; 1,2-Dichloroethene (total), 1,1,1 -Trichloroethane; 1,1-
Dichloroethene; 1,2-Dichloroethane
If applicable, attach a spreadsheet of the RPA results as well as a copy of the Dissolved Metals
Implementation Fact Sheet for freshwater/saltwater to this Fact Sheet. Include a printout of the RPA
Dissolved to Total Metal Calculator sheet if this is a Municipality with a Pretreatment Program.
Toxicity Testing, Limitations
Permit limits and monitoring requirements for Whole Effluent Toxicity (WET) have been established in
accordance with Division guidance (per WET Memo, 8/2/1999). Per WET guidance, all NPDES permits
Page 5 of 10

issued to Major facilities or any facility discharging "complex" wastewater (contains anything other than
domestic waste) will contain appropriate WET limits and monitoring requirements, with several exceptions.
The State has received prior EPA approval to use an Alternative WET Test Procedure in NPDES permits,
using single concentration screening tests, with multiple dilution follow-up upon a test failure.
Describe proposed toxicity test requirement: This is a Ground Water Remediation wastewater and as such
is considered complex wastewater. A chronic WET limit at 90% effluent will continue on a quarterly
frequency using a garb sample for testing.
Mercury Statewide TMDL Evaluation
There is a statewide TMDL for mercury approved by EPA in 2012. The TMDL target was to comply with
EPA's mercury fish tissue criteria (0.3 mg/kg) for human health protection. The TMDL established a
wasteload allocation for point sources of 37 kg/year (81 lb/year), and is applicable to municipals and
industrial facilities with known mercury discharges. Given the small contribution of mercury from point
sources (-2% of total load), the TMDL emphasizes mercury minimization plans (MMPs) for point source
control. Municipal facilities > 2 MGD and discharging quantifiable levels of mercury (> 1 ng/L) will receive
an MMP requirement. Industrials are evaluated on a case-by-case basis, depending if mercury is a pollutant
of concern. Effluent limits may also be added if annual average effluent concentrations exceed the WQBEL
value (based on the NC WQS of 12 ng/1) and/or if any individual value exceeds a TBEL value of 47 ng/1.
Describe proposed permit actions based on mercury evaluation: This facility is not considered a source of
mercury; thus, the TMDL does not apply.
Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within
this permit: NA.
Other WOBEL Considerations
If applicable, describe any other parameters of concern evaluated for WQBELs: NA
If applicable, describe any special actions (HQW or OR W) this receiving stream and classification shall
comply with in order to protect the designated waterbody: NA
If applicable, describe any compliance schedules proposed for this permit renewal in accordance with 15A
NCAC 2H. 010 7( c)(2)(B), 40CFR 122.4 7, and EPA May 2007 Memo: NA
If applicable, describe any water quality standards variances proposed in accordance with NCGS 143-
215.3(e) and 15A NCAC 2B. 0226 for this permit renewal: NA
8. Technology -Based Effluent Limitations (TBELs)
NA
9. Antidegradation Review (New/Expanding Discharge)
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not
degrade water quality. Permitting actions for new or expanding discharges require an antidegradation
review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 2H.0105(c)(2). In all cases,
Page 6of10

existing instream water uses and the level of water quality necessary to protect the existing use is maintained
and protected.
If applicable, describe the results of the antidegradation review, including the Engineering Alternatives
Analysis ") and any water quality modeling results: NA
10. Antibacksliding Review
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(1) prohibit
backsliding of effluent limitations in NPDES permits. These provisions require effluent limitations in a
reissued permit to be as stringent as those in the previous permit, with some exceptions where limitations
may be relaxed (e.g., based on new information, increases in production may warrant less stringent TBEL
limits, or WQBELs may be less stringent based on updated RPA or dilution).
Are any effluent limitations less stringent than previous permit (YES/NO): NO
If YES, confirm that antibacksliding provisions are not violated: NA
11. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations
and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500; 2) NPDES
Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced
Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012 Memo); 4) Best Professional
Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered
effluent limitations under Section 402(o) of the Clean Water Act, and therefore anti -backsliding
prohibitions would not be triggered by reductions in monitoring frequencies.
Monitoring for TSS will be reduced from monthly to quarterly based on BPJ following review of data
provided by the Permittee following draft Public Notice.
For instream monitoring, refer to Section 4.
12. Electronic Reporting Requirements
The US EPA NPDES Electronic Reporting Rule was finalized on December 21, 2015. Effective December
21, 2016, NPDES regulated facilities are required to submit Discharge Monitoring Reports (DMRs)
electronically. Effective December 21, 2020, NPDES regulated facilities will be required to submit
additional NPDES reports electronically. This permit contains the requirements for electronic reporting,
consistent with Federal requirements.
13. Summary of Proposed Permitting Actions
Table. Current Permit Conditions and Proposed Changes
Parameter
Current Permit
Proposed Change
Basis for Condition/Change
Flo-
MA 0.09 MGP
No char
15A NCAC 2B .0505
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Page 8 of 10
MA 30.0 mg/L
No change in limits;
reduce monitoring
TBEL. BPJ - reviewed data showed
TSS
DM 45.0 mg/L
from monthly to
most non -detects with highest
quarterly
detection at 21 in 2010.
WQBEL. State WQ standard, 15A
pH
No requirement
6 — 9 SU; add
NCAC 2B .0200; reviewed data
quarterly monitoring
insufficient to show seasonal or
other variation.
WQBEL (correction). State WQ
Tetrachloroethene
DM 3.0 pg/L
Technical change
standard, 15A NCAC 2B, RPA
DM 3.3 µg/L
demonstrated predicted
concentration exceeds WQBEL
WQBEL (correction). State WQ
Vinyl Chloride
DM 2.0 µg/L
Technical change
standard, 15A NCAC 2B, influent
DM 2.4 µg2
concentrations exceed WQBEL,
pollutant of concern BPJ
No WQBEL available; no
Chloroethane
Monitor only
Remove from permit
reasonable potential found using
EPA criterion
1, 1 -Dichloroethane
Monitor only
No change
Pollutant of concern BPJ
RPA demonstrated predicted
1, 1 -Dichloroethene
Monitor only
Remove from permit
concentration < 50% of WQBEL,
not a pollutant of concern
1,2-Dichloroethene
RPA demonstrated predicted
(total)
Monitor only
Remove from permit
concentration < 50% of WQBEL,
not a pollutant of concern
1.1.1-
RPA demonstrated predicted
Trichloroethane
DM 4.0 µg/L
Remove from permit
concentration < 50% of the 2015
EPA criterion
Trichloroethene
Monitor only
No change
Pollutant of concern BPJ
Benzene
Monitor only
No change
Pollutant of concern BPJ
Methyl Chloride
Monitor only
No change
Pollutant of concern BPJ
RPA demonstrated predicted
1,2-Dichloroethane
Monitor only
Remove
concentration < 50% of WQBEL,
not a pollutant of concern
Toluene
Monitor only
No change
Pollutant of concern BPJ
Chronic limit, 90%
WQBEL. No toxics in toxic
Toxicity Test
effluent using grab
No change
amounts. 15A NCAC 2B.0200 and
sample
15A NCAC 2B.0500, ATU
approved sampling type
Add quarterly
WQBEL. Pollutant of concern,
monitoring with DM
based on the 80 µg/1 surface water
1,4 -Dioxane
No requirement
80 µg/L, increase
criterion to protect human health.
monitoring to monthly
Monitoring wells indicate increased
once DM exceeded
presence; existing treatment will not
remove.
Page 8 of 10

Electronic Reporting
No requirement
Add Electronic
Reporting Special
In accordance with EPA Electronic
Condition
Reporting Rule 2015.
MGD — Million gallons per day, MA - Monthly Average, WA — Weekly Average, DM — Daily Max
14. Public Notice Schedule
Permit to Public Notice: January 9, 2018
Per 15A NCAC 2H .0109 & .0 111, The Division will receive comments for a period of 30 days following
the publication date of the public notice. Any request for a public hearing shall be submitted to the Director
within the 30 days comment period indicating the interest of the party filing such request and the reasons
why a hearing is warranted.
15. Fact Sheet Addendum (if applicable)
Were there any changes made since the Draft Permit was public noticed (Yes/No): YES. Comments were
received from Mr. Stuart Kerkhoff, Radiator Specialty Company, on March 19, 2018, requesting the
following changes to the permit:
• Removal of the recording flow meter requirement from the draft permit, as the Supplement to the
Permit Cover Sheet lists an effluent meter with recorder, which is inconsistent with a totalizing
flow meter in Footnote 2;
o Requested change was made (see below).
• Removal of TSS monitoring requirements from the draft permit, citing low concentrations and cost
of testing.
o Requested change was not made, but an alternative was (see below).
• Removal of pH monitoring requirements from the draft permit, citing consistent historical data and
cost of testing.
o Requested change was not made, but an alternative was (see below).
• Removal of 1,4 -Dioxane limitation, monthly monitoring in the event of exceedance, and reopener
clause from the permit; instead proposing to maintain quarterly monitoring. Mr. Kerkhoff stated
that imposing 1,4 -Dioxane limits are inappropriate as there is no established federal maximum
contaminant level, state water quality standard and state evaluation of 1,4 -dioxane concentrations
in waterbodies is underway.
o Requested change was not made, because the 80 µg/l, limit is an established NC calculated
surface water criterion to protect human health for Class C waters based on fish
consumption.
If Yes, list changes and their basis below:
• The words "with recorder" were removed from "effluent meter" on the facility component list on
the Supplement to the Permit Cover Sheet after verifying that the effluent meter does not have a
chart or other recording device, but readings are taken manually. Manual readings are considered
satisfactory by the regional inspector as long as flow data are consistent without major variations
indicating operational or monitoring issues. To date, flows have been satisfactorily consistent.
• TSS monitoring frequency has been reduced from monthly to quarterly in light of effluent data
showing consistent compliance with limits, yielding 7% detection over a span of over eight (8)
Page 9 of 10

years (from February 2010 — February 2018). TSS concentrations over the past five years mostly <
2.5 mg/L with the highest detection at 6.7 mg/L.
pH monitoring frequency has been adjusted from monthly to quarterly in light of effluent data
provided by the Permittee that show consistent compliance with the water quality standards,
ranging 7.3-8.3 (quasi -annually, from May 2008 — November 2017). However, the submitted data
were collected at frequencies too low to show seasonal or other variation (if any). pH will remain
in the permit as it is a parameter of concern that is put in groundwater remediation NPDES permits.
16. Fact Sheet Attachments (if applicable):
• DMR data trend charts
• WET Test Summary, page 90
• 2014 NC 303(d) List, page 142
• RPA Spreadsheet Summary
• Public Comment letter from Permitttee
Date: May 23, 2018
Permit Writer:"
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