NC0088838_Final Permit_20180523

ti
;Y
Water Resources M
Environmental Quality
May 23, 2018
Mr. Stuart Kerkhoff
Environmental Health and Safety Manager
Radiator Specialty Company
600 Radiator Road
Indian Trail, NC 28079
Dear Mr. Smith:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: Final NPDES Permit Renewal
Permit NCO088838
Radiator Specialty Company
Union County
Facility Grade I
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached 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 October 15, 2007
(or as subsequently amended).
Please note that the receiving stream is listed as impaired for fish community (fair) and benthos
(poor) on the North Carolina Final 2014 303(d) Impaired Waters List. Addressing impaired waters
is a high priority with the Division, and instream data will continue to be evaluated. If there is
noncompliance with permitted effluent limits and stream impairment can be attributed to your
facility, then mitigative measures may be required.
The Division received your comments in a letter dated March 14, 2018 and the following
changes were made to the draft permit sent to you on February 7, 2018:
0 Monitoring frequency for TSS has been reduced from monthly to quarterly in light of
reviewed effluent data showing consistent compliance with permit limits, yielding 7%
detection over the span of eight years (from February 2010 through February 2018). TSS
monitoring will remain in the permit as this is a pollutant of concern and a parameter
routinely put in groundwater remediation NPDES permits.
• Monitoring frequency for pH has been reduced from monthly to quarterly in light of
reviewed effluent data showing consistent compliance with water quality standards. pH
will remain in the permit as this is a pollutant of concern and a parameter routinely in
groundwater remediation NPDES permits.
-- Nothing Compares':--,,
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

• The facility component list on the Supplement to Permit Cover Sheet was revised by
removing "with recorder" for the effluent meter per your request after verifying that the
meter does not have a chart or other recording device, but flow readings are taken manually
on a daily basis.
• 1,4 -Dioxane limits and monitoring will remain in the permit as this parameter does have a
NC calculated surface water criterion of 80 µg/L to protect human health in Class C waters.
The reopener will remain in the permit to allow for changes to address 1,4 -Dioxane
monitoring, treatment and/or compliance.
1,4 -Dioxane samples shall be analyzed by a NC certified laboratory using EPA Test Method
624. 1, and results shall be reported to the lower reporting level of the procedure. In September
2017, EPA promulgated the 2017 Methods Update Rule approving test method 624.1 for 1,4 -
Dioxane. All tests for parameters listed in the NPDES permit must be performed in accordance
with EPA approved test methods and by a NC certified laboratory. Currently, there are several
laboratories certified in NC to perform 1,4 -Dioxane testing. Radiator Specialty is required to
submit effluent data results on 1,4 -Dioxane using one of these certified labs. To learn what
certified labs are in your area, please contact Data Satterwhite, DWR Laboratory Certification
Branch, at 919-733-3908 ext. 202 or by e-mail: dana.satterwhite(a::ncdenr.gov.
The final permit maintains the following significant changes identified in the letter sent on
February 7, 2018:
• Removed monitoring for Chloroethane from this permit, since an evaluation of submitted
effluent data found no reasonable potential to exceed the EPA criterion of 550 µg/L.
• Removed monitoring 'for 1,1-Dichloroethene; 1,2-Dichloroethene (total); 1,1,1 -
Trichloroethane; and 1,2-Dichloroethane have been removed from this permit. These
parameters are no longer pollutants of concern, based on reasonable potential evaluation
and no significant levels in the influent.
• Revised daily limits for Tetrachloroethene and Vinyl Chloride. The 2015 EPA Human
Health water quality criterion for these parameters was applied in this permit (technical
change).
• Added monitoring with limits for pH. The pH is a pollutant of concern and the freshwater
standard for Class C waters was applied in this permit.
• Added quarterly monitoring and a limit of 80 gg/L for 1,4 -Dioxane to the permit with
provisional monitoring increase to monthly if a sample measurement is equal to or
greater than the limit. Added special condition A. (3.) REOPENER 1,4 -DIOXANE in
this permit. Adjacent monitoring wells data indicate potential migration of this pollutant
to the groundwater remediation collection system, thus a potential for this pollutant to
be present in excess of its WQBEL which may require modification of the permit to
address compliance.
Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted
and became effective on December 21, 2015. The requirement to begin reporting
discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application has been added to this permit. [See
Special Condition A. (4.)]
Page 2 of 3

For information on eDMR, registering for eDMR and obtaining an eDMR user account,
please visit the following web page: http://deq.nc.gov/about/divisions/water-
resources/edmr.
For more information on EPA's final NPDES Electronic Reporting Rule, please visit the
following web site: https://www.federalregister.gov/documents/2015/10/22/2015-
24954/national-pollutant-discharge-elimination-system-npdes-electronic-reporting-rule.
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, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
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
Resources or any other Federal, State, or Local governmental permits that may be required.
If you have any questions concerning this permit, please contact Gary Perlmutter at (919) 807-
6385 or via email at [e-mail].
Sincerely,
Linda Culpepper. nterim Director
ivision of Water Resources, NCDEQ
Hardcopy: NPDES Files
Central Files
DWR / Winston-Salem Regional Office / Water Quality Operations
e -Copy:
DWR / Aquatic Toxicity Branch / Susan Meadows
Page 3 of 3

Permit NC0088838
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Radiator Specialty Company
is hereby authorized to discharge wastewater from a facility located at the
Radiator Specialty Company
600 Radiator Road
Indian Trail
Union County
to receiving waters designated as an unnamed tributary to South Fork Crooked Creek in the Yadkin Pee -
Dee River Basin in accordance with effluent limitations, monitoring requirements, and other applicable
conditions set forth in Parts I, II, III, and IV hereof.
The permit shall become effective July 1, 2018.
This permit and the authorization to discharge shall expire at midnight on March 31, 2023.
Signed this day, May 23, 2018.
Linulpepper U '-
't
IntkrVi Director, Division of Water Resources
By Authority of the Environmental Management Commission
Pagel of 8

Permit NC0088838,
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Radiator Specialty Company is hereby authorized to:
1. Continue to operate a 0.090 MGD Ground Water Remediation treatment facility consisting of.
■ one (1) 6,000 -gallon equalization tank
■ one (1) transfer pump
• one (1) packed air stripper column with blower and overflow sump
• effluent meter
gravity sewer to outfall
Located at Radiator Specialty Company, 600 Radiator Road, Indian Trail in Union County.
2. Discharge from said treatment works at the location specified on the attached map into unnamed
tributary to the South Fork Crooked Creek, a class C water in the Yadkin River Basin.
Page 2 of 8

Permit NCO088838
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC .02B .0400 et seq., .02B .0500 et seq.]
a. Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized
to discharge treated groundwater from Outfall 001 of this Grade I facility. Such discharges shall be
limited and monitored' by the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
LIMITATIONS
MONITORING REQUIREMENTS
Monthly
.Average
0.090 MGD
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flow 2
Continuous
Recording
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
Quarterly
Grab
Effluent
Tetrachloroethene
3.3 gg/L
Monthly
Grab
Effluent
Vinyl Chloride
2.4 Ag/l,
Monthly
Grab
Effluent
pH
Between 6.0 and 9.0 S.U.
Quarterly
Grab
Effluent
1,4 -Dioxanes
80 µg/L
Quarterly 3
Grab
Effluent
1,1-Dichloroethane
Monitor and Report
Quarterly
Grab
Effluent
Trichloroethene
Monitor and Report
Quarterly
Grab
Effluent
Benzene
Monitor and Report
Quarterly
Grab
Effluent
Methyl Chloride
Monitor and Report
Quarterly
Grab
Effluent
Toluene
Monitor and Report
Quarterly
Grab
Effluent
Chronic Toxicity 4
Monitor and Report
Quarterly
Grab
Effluent
Footnotes:
1. The Permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR
application system. See Special Condition A. (4.).
2. Flow shall be measured with a totalizing flow meter.
3. 1,4 -Dioxane measurement shall be conducted by a NC -certified laboratory using EPA Test Method
624. 1, and the results shall be reported to the lower reporting level of the procedure. If a
measurement is equal to or greater than 80 µg/L, then monitoring shall immediately be increased
to monthly. See Special Condition A. (3).
4. Chronic Toxicity (Ceriodaphnia dubia) limit at 90% with testing in January, April, July, and
October; see Special Condition A. (2.). Quarterly toxicity testing shall coincide with the sampling
of all the other parameters.
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 8

Permit NC0088838•
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly)
[I 5A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum, quarter lx monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
January, April, July, and October. These months signify the first month of each three-month toxicity
testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent
Toxicity Test Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR -1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP313 for the Chronic Value. Additionally, DWR Form AT -
3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, NC 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine
is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Water Sciences Section at the address cited above.
Should the Permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Page 4of8

Permit NCO088838
(Continued A. (2) CHRONIC TOXICITY PERMIT LIMIT)
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later than
the last day of the month following the month of the initial monitoring.
A. (3.) REOPENER 1,4 -DIOXANE [G.S. 143-215.1(b)]
Upon measurement of an effluent 1,4 -Dioxane sample equal to or greater than 80 gg/L, monitoring shall
be increased immediately to monthly. If deemed necessary by the Division, the permit may be reopened
to modify permit requirements to address 1,4 -Dioxane monitoring, treatment and/or compliance.
Page 5 of 8

Permit NC0088838,
A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S. 143-215.1(b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21,
2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits): -
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section „E (5.) (a)i
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall. be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the following
address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative
forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address
above. See "How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Page 6 of 8

Permit NCO088838
(Continued A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS)
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The Permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of
each electronic submission. The Permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each
type of electronic submission and for each state. Instructions on how to access and use the appropriate
electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting
Rule is found at: htt s://www.federalre ister. ov/documents/2015/10/22/2015-24954/national-
ollutant-dischar e-elimination-system-nodes-electronic-reoortinp--rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to. the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver
shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be
submitted electronically to the Division unless the permittee re -applies for and is granted a new
temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not
transferrable. Only permittees with an approved reporting waiver request may submit monitoring data
and reports on paper to the Division for the period that the approved reporting waiver request is
effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
hftp://deg..nc.gov/about/divisions/water-resources/edi-nr
Page 7of8

Permit NC0088838,
(Continued A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS)
4. Sionatory Requirements (Supplements Section B. (11.) (b) and Supersedes Section B (11„) (d)t
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part II, Section
B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting
purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following
web page:
htti): eq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am
aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations. "
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions.
These records or copies shall be maintained for a period of at least 3 years from the date of the report.
This period may be extended by request of the Director at any time [40 CFR 122.41 ].
Page 8 of 8

USGS Quad: G16SW Matthews, NC
Outfall Facility
Latitude: 350 3' S5" W 350 3'45" W
Longitude: 800 39' 14" N 800 39'3" N
Stream Class: C North Facility Location
Subbasin: 03-07-12 HUC: 03040105 Radiator Specialty Company NC0088838
Zeceiving Stream: UT to South Fork Crooked Creek Union Countv

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 Company
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/1)
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.
Page 1 of 10

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
µg/L
1.11 1.4
0.77
Chloroethane
µg/L
13.3 15
9.4
2-Chlorotouluene µg/L
2.98 3.3 0.81
4-Chlorotouluene
m/L
< I
< I
< 0.5
1, 1 -Dichloroethane
µg/L
49.0
60
41
1,2-Dichloroetheane
µg/L
0.678
0.75
0.56
1, 1 -Dichloroethene
µg/L
27.0
31
23
Cis-1,2-Dichlorothene
µg/L
22.8
30
20
Trans-1,2-Dichloroethene
µg/L
2.52
3.0
2.0
Dichlorodifluoromethane
µg2
4.50
6.1
3.2
1,4 Dioxane
µg/L
< 80
< 80
< 80
Ethylbenzene
µg/L
< I
< I
Methyl ethyl ketone
µg/L
< 5
< 5
< 5
Methylene Chloride
µg/L
< 2
< 2
< 1
Methyl isobutyl ketone (MIBK)
µg/L
< 5
< 5
7<5
Tetrachloroethene
µg/l,
84.4
100
70
Toluene
µg/L
< 1
< I
< 0.5
1,1,1 -Trichloroethane
µg/l,
1.98
2.6
1.7
Trichloroethene
µg/L
5.94
7.4
4.4
Vinyl chloride
µg/L
4.72
6.5
3.2
Xylenes (Total)
µg/L
< 2
< 2
< 1
Page 2 of 10

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 7Q 10 (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
FuSGS 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 August 2017 for monitor only parameters.
Table. Effluent Data Summary
Parameter
Units
Average
Max
Min
Permit Limit'
Flow
MGD
0.0413
0.082
0.003
MA 0.090
TSS
mg/L
< 6.7
6.7
< 2.5
DM 45.0
MA 30.0
Chloroethane
gg/L
< 5.2
5.2
< 0.5
Monitor only
1, 1 -Dichloroethane
gg/L
< 3.3
3.3
< 0.5
Monitor only
1, 1 -Dichloroethene
gg/L
< 2.5
2.5
< 0.5
Monitor only
1,2-Dichloroethene (total)
gg/L
All non -detects, < 0.5 to < 10
Monitor only
Tetrachloroethene
gg/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
gg/L
All non -detects, < 0.5 to < 4
Monitor only
Benzene
gg/L
< 1
0.78
< 0.5
Monitor only
Methylene Chloride
gg/L
< 3.1
3.1
< 1
Monitor only
Page 3 of 10

1,2-Dichloroethane
Toluene
Vinyl Chloride
µg/L All non -detects, < 0.5 to < 1
pgIL < 1 < 0.5
µg/L I < 2 1 2 J < 0.5
'MA = Monthly Average, WA = Weekly Average, DM = Daily Maximum.
5. Instream Data Summary
Monitor only
Monitor only
DM 2.0
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/l 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 (YIN): NA
Name of Monitoring Coalition: NA
6. Compliance Summary
Summarize the compliance record with permit effluent limits (past S 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
S 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 maintained 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: 1 Q 10 streamflow (acute Aquatic Life); 7Q 10 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): NA
If applicable, describe any mixing zones established in accordance with ISA NCAC 2B. 0204(b): NA
Oxygen-ConsumiLig Waste 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
Page 4 of 10

(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/1(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/l (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 1/Z 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. Tetrachoroethene; Vinyl Chloride; 1,4 -Dioxane (predicted)
• Monitoring Only The 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-Dichloroetha ne; 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 Manage rient Strategy Considerations
If applicable, describe any other TMDLs/NutrientManagement 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 ORW) 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 213.0201. Each applicant for a new/expanding NPDES permit must
document an effort to consider non -discharge alternatives per 15A NCAC 21-1.0105(c)(2). In all cases,
Page 6 of 10

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 (EAA) and any water quality modeling results: NA
10. Antibacksliding Review
Sections 402(0)(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(0) 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
Flow MA 0.09 MGD No change 15A NCAC 2B .0505
Page 7 of 10

Page 8 of 10
No change in limits;
MA 30.0 mg/L reduce monitoring
TBEL. BPJ - reviewed data showed
TSS
DM 45.0 mg/L from monthly to
most non -detects with highest
No change
quarterly
detection at 21 in 2010.
WQBEL. State WQ standard, 15A
pH
No requirement 6 — 9 SU; add
NCAC 2B .0200; reviewed data
concentration < 50% of WQBEL,
quarterly monitoring
insufficient to show seasonal or
not a pollutant of concern
other variation.
WQBEL (correction). State WQ
Tetrachloroethene
DM 3.0 gg/L Technical change
standard, 15A NCAC 2B, RPA
concentration < 50% of WQBEL,
DM 3.3 gg/L
demonstrated predicted
not a pollutant of concern
concentration exceeds WQBEL
WQBEL (correction). State WQ
Vinyl Chloride
DM 2.0 gg/L Technical change
standard, 15A NCAC 2B, influent
concentration < 50% of the 2015
DM 2.4 gg/L
concentrations exceed WQBEL,
EPA criterion
pollutant of concern BPJ
Monitor only
'Mnn;tnr I
No WQBEL available; no
ChInmi-41iAnP
nnhi V_ c -F,-- ___;t
„i.l ,.
Page 8 of 10
-------- ----J
�...++..+ ... ++va++ 1.. va aaaa
avuuVllLLlJ1V tJVLVll L1LL1 1V LL11LL LL.7111r.,
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 gg/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 pg/1 surface water
1,4 -Dioxane
No requirement
80 Ag/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 flowmeter 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 TS S 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:"
Page 10 of 10

- Berry, Ron
From: Watson, Edward M
Sent: Friday, February 09, 2018 12:06 PM
To: Berry, Ron
Cc: Pitner, Andrew
Subject: RE: Your copy draft permit and fact sheet for Radiator Specialty Company NC0088838
Hello Ron,
MRO has reviewed the DRAFT PERMIT and has no additional comment or concerns. MRO is in agreement with the draft
permit.
Regards,
Ed
From: Berry, Ron
Sent: Tuesday, February 06, 2018 12:19 PM
To: Watson, Edward M <[e-mail]>; Basinger, Corey <[e-mail]>
Subject: Your copy draft permit and fact sheet for Radiator Specialty Company NC0088838
See attached, comment as needed.
Ron Berry
Engineer
Division of Water Resources/Complex Permitting
North Carolina Department of Environmental Quality
919 807 6396 office
512 N. Salisbury Street
1617 Mail Service Center
Raleigh, NC 27699-1617
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

PNIELA
NOTq�� �y
=oAGBCIG '
2 '
Public Notice
AFFP
North Carolina
Public Notice North Carolina
Environmental Management
Corir mission/NPCES Unit
Affidavit of Publication
1817 Mail Service center
Raleigh, NC 27699-1617
Notice of Intent to Issue a
NPDES Wastewater Permit
STATE OF NORTH SS
CAROLINA }
The North Carolina Environ -
COUNTY OF UNION)
mental Management Commis-
sion proposes to issue a NP -
Dale Morefield, being duly sworn, says:
DES wastewater discharge
That he is Publisher of the The Enquirer Journal, a daily
permit to the person(s)-listed
newspaper of general circulation, printed and published in
below,. Written comments re -
Monroe, Union County, North Carolina; that the
garding the proposed permit
publication, a copy of which is attached hereto, was
will be accepted until 30 days
published in the said newspaper on the following dates:
.after the publish date of this
February 09, 2018
notice. The Director of the NC
Division of Water Resources
DWR may hold a public hear-
ing should there be a signific-
ign f c -ant
antdegree of public interest.
please mall comments and/or
That said newspaper was regularly issued and circulated
information requests to DWR
on those dates.
SIGNED:
at the above address. Inter-
r
ested persons may visit the
�-
DWR at 512 N. Salisbury
Publisher
Street; Raleigh, NC to review
Subscribed to and sworn to me this 9th day of February
information on file. Additional
2018.
information on NP )E per-
mits and this notice may be
found on Our website;
Pamela D. Crump, Notary, Union CoAy, North Carolina
i n w r -r r w r-
r s r mii W r-
My commission expires: July 10, 2018
tranQht n eS-WAS WW!EV� ~iub-
i or by calling (91 9)
807-6397. The Radiator Spe-
cialty Company requested re-
30146484 30800478
newal of permit l CO088838
Wren Thedford
for Radiator Specialty Com—
Division Of Water Resources
pony in Union County; this fa -
1617 Mail Service Center
cility discharge is treated
Raleigh, NC 27699
groundwater to unnamed tribu-
tary to South Pork Crocked
Creek,River Basin.
y� //Yadki_n
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PNIELA
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2 '

serp 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 1
1617 Mail Service Center 9 2018
Raleigh, North Carolina 27699-1617 Water Resources
Permitting Section
Re: Comments to Draft NPDES Permit
Permit No. NCO088838
Class I
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 IA. (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
14
600 Radiator Road — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbronds.com

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 pH 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 (pg/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 pg/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 213). North Carolina
has proposed 80 gg/L as a guideline protective value for surface 14 aters 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
Stuart Kerkhoff, CHMM
Environmental Heath and Safety Manager
Attachments
cc: Richard L. Harmon, Harmon Environmental
Amanda Kitchen Short, McGuireWoods LLP
NPDESIDRAFTN PDESPERM ] RES PON SE2018.DOCX

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Attachment 1
NC Division of Water Resources
1,4 -Dioxane and
Bromide Monito ing
Plan
In Support of NFWF-Funded Project ID #8020.16.054182
ire, 'ciences section

NC DWR 1.4 -Dioxane and Bromide Monitorin,. Plan 2017-2019
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 potentia) 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 pg/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 pg/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 (DSPs) 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 DSPs 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 Monitorin 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.
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 IA -Dioxane and Bromide Monitorini Plan 2017-2019
c jb=
B0210000
Haw River at SR 1551 Hub Mill Rd. -
Cape Fear
Central
Both
2,3
60750000
South Buffalo Creek at SR 2821 at McLeansville
Cape Fear
Central
Both
2,3
80840000
Reedy Fork at NC -87 at Ossipee
Cape Fear
Central
Both
2,3
Bl
Haw River at SR 1712 (Brooks Bridge Rd)
Cape Fear
Central
Both
2,3
82100000
Haw River at SR 1713 near Bynum
Cape Fear
Central
Bath
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
S08
Belews Lake at NC 65
Roanoke
Central
Bromide
1,3
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 17161 near Mayfield
Roanoke
Central
Bromide
1
N3500OW
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
Q7150000
Pee Dee River at NC 731 near Shankle
Yadkin
Central
Both
1,2
Q7330000
Rocky River at Sit 2420 near Davidson
Yadkin
Central
Both
2
Q8090000
Irish Buffalo Creek at SR 1132 near Faggarts
Yadkin
Central
Both
2
Q8220000
Rocky River at SR 1006 near Concord
Yadkin
Central
Both
2
Q9400000
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
Q9940000
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
/4370000
Neuse River at US 70 Business at Smithfield
Neuse
Eastern
Both
1, 2, 3
/4510000
Neuse River at NC 42 near Clayton
Neuse
Eastern
Both
2,3
/5970000
Neuse River at SR 1915 near Goldsboro
Neuse
Eastern
Both
1, 2, 3
16150000
Neuse River at NC 11 at Kinston
Neuse
Eastern
Both
1, 2, 3
16740000
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
AN08
Lake Norman at Reeds Creek
Catawba
Western
Bromide
1,3
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
NC Public Water Supply Source Monitoring
* Proposed Monitoring Stations Q Districts
e UCMR3 1,4 -Dioxane 20.35 ug/L Major Waters
• Surface Water Sources w/ High DBPs River Basins
! Power Plants
Maes
0 20 40 so 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.
Laboratory instrumentation will be acquired, installed, and calibrated by lune 2017. A sampling and
analysis schedule for the 2017 sampling season will be established by lune 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 I.4-Dio)(anp and RrnmirlP�onitarin 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:11deco.nc.Rov,`abouticlivision / ate,r_resourceslwater-res_ources-
data water -sciences -home- a e rnicrobiol❑ -inorganics-branch same le -submission.
Page 6 of 6

Berry, Ron
From:
Sent:
To:
Cc:
Subject:
This is the full explanation...
Brower, Connie
Thursday, October 15, 2015 11:58 AM
Berry, Ron
Grzyb, Julie
FW: 1,4 Dioxane - reference to rules
Connie U. Brower
Water Quality Standards Coordinator
Classifications and Standards/ Rules Review Branch
Water Planning Section, Division of Water Resources
Department of Environmental Quality
919 807 6416 office
919 707 9000 main office
Connie. [e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1611 Mail Service Center, Raleigh, NC, 27699-1611
Nothing Cornro,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Brower, Connie
Sent: Wednesday, September 23, 2015 11:20 AM
To: Risgaard, Jon <[e-mail]>
Subject: FW: 1,4 Dioxane - reference to rules
From: Brower, Connie
Sent: Wednesday, September 02, 2015 12:34 PM
To: Risgaard, Jon; Ruhlman, Carrie; Gore, Deborah; Hill, Tammy; Godreau, Jessica
Cc: Grzyb, Julie; Sadosky, Rebecca; Kroeger, Steve; Manning, Jeff; Ventaloro, Christopher
Subject: FW: 1,4 Dioxane - reference to rules
Jon -
1

This was sent to'TR— nothing has changed except that I have a number of states noting that they, too, are seeing the
chemical in either finished or surface waters.
In accordance with 15A NCAC 02B .0208 (a) (2) — "....the concentration of toxic substances shall not exceed the level
necessary to protect human health through exposure routes of fish consumption, water consumption, or other route
identified as appropriate for the water body...."
The concentrations are calculated to protect from the carcinogenic effects of 1,4 Dioxane.
I copied the planet — because the question arises frequently!
Connie
From: Brower, Connie
Sent: Tuesday, January 27, 2015 10:40 AM
To: Reeder, Tom; Manning, Jeff
Cc: Ruhlman, Carrie
Subject: RE: 1,4 Dioxane
Good morning, Tom,
In accordance with 15A NCAC 0213, the calculated protective values for 1,4 Dioxane (CAS # 123-91-1) are 0.35 ug/L in
Water Supply classified waters, and 80 ug/L in Class C waters. 1,4 -Dioxane is a carcinogen. As we do not routinely
monitor for 1, 4 Dioxane , and as Jeff noted, no waters are impaired. As WSS reported to you, our current data is limited
to three months of samples. While disconcerting, I completely agree with them that it is very early to make conclusions
of source or extent of the issue.
You are correct that the federal government has not established an MCL for 1,4 Dioxane. We do, however, have an
established groundwater standard of 3 ug/L. This number is in need of revisions, as the information on which it is based
is outdated. If modified, it would be 0.35 ug/L—the same as the surface water number.
Let us know if you need additional information.
Connie
From: Reeder, Tom
Sent: Tuesday, January 27, 2015 9:57 AM
To: Brower, Connie; Manning, Jeff
Subject: 1,4 Dioxane
Do we have an surface water quality standard for 1,4 Dioxane? If so, what is it? Are any water listed as being impaired
for 1,4 Dioxane?
Thanks

• Berry, Ron
From: Moore, Cindy
Sent: Tuesday, October 13, 2015 3:24 PM
To: Berry, Ron
Cc: Meadows, Susan; Giorgino, John; Hollenkamp, Carol
Subject: RE: Question on toxicity test for NCO088838
Per our conversation, if this is a batch discharge, then a composite sample would be hard to achieve. I would suggest a
grab sample and continue use of the chronic test.
From: Berry, Ron
Sent: Tuesday, October 13, 2015 3:12 PM
To: Moore, Cindy <[e-mail]>
Subject: Question on toxicity test for NCO088838
Cindy,
I did not see a response to this original email. I need a decision so I can get this permit out to public notice.
Thanks, Ron
Cindy,
Radiator Specialty Company NPDES permit NCO088838 is being renewed and is for a ground water remediation
operation that began discharging under a NPDES permit in 2010. The permit requires quarterly chronic toxicity testing
using a grab sample at 90% effluent test concentration. The discharge varies from months with no discharge to months
with intermittent discharge to months with continuous discharge. What is the recommended test sample type and/or
appropriate toxicity test application? Should we concert to acute?
Thanks, Ron
Ron Berry, Engineer
Division of Water Resources/NCDENR
Phone: (919) 807 - 6396
Email: [e-mail]
Location Address - Archdale Building, Office 925K
512 N. Salibury St.
Raleigh, NC 27699
Mailing Address - Archdale Building, NCDENR/DWR
1617 Mail Service Center
Raleigh, NC 27669-1617
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

s Chernikov, Sergei
From: Ulishney, Adam
Sent: Monday, March 12, 2012 11:03 AM
To: Chernikov, Sergei
Subject: Radiator Specialty Site NCO088838
Dear Mr. Chernikov,
My name is Adam Ulishney with the NCDENR Hazardous Waste Section. One of my facilities that I currently manage is
Radiator Specialty located at 600 Radiator Road in Indian Trail, Union County, North Carolina. They currently maintain a
RCRA Post -Closure Permit. The portal website had listed you as the contact person for the site's NPDES permit. As part
of corrective action activities at the site the facility currently operates a groundwater pump and treat system for which
they maintain an NPDES permit (N00088838) for discharge of treated water to an unnamed tributary to Unnamed
Tributary to South Fork Crooked Creek in the Yadkin River Basin.
I just wanted to make you aware that one of the constituents within groundwater at the site is 1,4 -Dioxane. During the
most recent sampling event (October 2011), 1,4 -Dioxane concentrations in groundwater ranged from <150 ug/L to 1,100
ug/I. Based on the physical and chemical properties of 1,4 -Dioxane, groundwater treatment systems similar to the one
operating at the RSC facility have generally proven to be ineffective in treating this constituent. I have been
unsuccessful in getting Radiator Specialty to sample the effluent for the presence of 1,4 -Dioxane to ensure that via some
means this constituent is being treated (possibly by dilution) prior to discharge as it is not required by their NPDES
permit. They have however collected quarterly influent samples in 2010 and results for 1,4 -Dioxane ranged from <150
ug/L to 320 ug/I. Historically the NC and EPA criteria table had the limit for 1,4 -Dioxane at 110 ug/I for a Class C water,
however it appears that the table is currently being updated.
If you can provide me any feedback it would be appreciated. Again I just wanted to make your aware of this
information, should you feel that it is necessary to incorporate the sampling of 1,4 -Dioxane in any future NPDES permits
for the facility. In any case let me know what you decide for my future reference in reviewing their annual reports.
Should you need additional information or have any questions, comments, or concerns please feel free to contact me at
919-707-8210.
Adam Ulishney
1lvdrogeologist
North Carolina Hazardous Waste Section
'hone:' [phone] p �) o o�� Q,
Eraai:: adam.ulishneN'a ncdenr.�ov
NOTICE: Effective October 24, 2011 our new address will be: 0 5 1
217 West Jones St. �-�
X
Raleigh, NC 27603 0, 3"�c,y �L
and effective October 24, 2011 my new phone number will be:
919-707-8210 '`fit?
Email correspondence to and from this address is subject to the North Carolina Public Records Low and may be disclosed to third
parties unless the content is exempt by statute or other regulation.

Yadkin -Pee Dee River Basin
2014 AU Number: AU Name: AU Length Area: AU Units: Classification:
AU Description:
13-17c3 Rocky River
34.9 FW Miles C
From Anderson Creek to Lanes Creek
IRCategory: ACS: Parameter Of Interest:
Collection Year:
303(d)
5e EC Copper (7 pg/I, AL, FW)
2008
2008
5e EC Zinc (50 pg/I, AL, FW)
2008
2008
13-17d Rocky River
11.5 FW Miles C
From the Lanes Creek to the Pee Dee River
IRCategory: ACS: Parameter Of Interest:
Collection Year:
303(d) yr:
5e EC Copper (7 pg/I, AL, FW)
2008
2008
5 EC Turbidity (50 NTU, AL, FW miles)
2012
2008
13-17b1 Rocky River
9.2 FW Miles C
From Clarke Creek to Mallard Creek
IRCategory: ACS: Parameter Of Interest:
Collection Year:
303(d) yr:
5 EC Benthos Fair (Nar, AL, FW)
2003
2008
13-17-20-2a South Fork Crooked Creek 5.6 FW Miles C
From source to SR 1515
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr:
5 EC Fish Community Fair (Nar, AL, FW) 1995 1998
5 EC Benthos Poor (Nar, AL, FW) 1995 1998
13-17-20-2b South Fork Crooked Creek 8.8 FW Miles C
From SR 1515 to Crooked Creek
'IRCategory: ACS: Parameter Of Interest:
5 EC Benthos Fair (Nar, AL, FW)
Collection Year: 303(d) yr:
1995 1998
13-17-36-9-(1) Stewarts Creek 8.3 FW Miles WS -III
From source to a point 0.4 mile downstream of mouth of Stumplick Branch
IRCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr. -
5
r.5 EC Benthos Fair (Nar, AL, FW) 2006 2008
13-17-36-9-(4. Stewarts Creek [Lake Twitty (Lake Stewart)] 131.1 FW Acres WS-III;CA
From a point 0.4 mile downstream of mouth of Stumplick Branch to Union County SR 1681 (City of Monroe water
supply intake)
RCategory: ACS: Parameter Of Interest: Collection Year: 303(d) yr:
5 EC Chlorophyll a (40 pg/I, AL, NC) 2012 2008
2014 NC 303(d) List -Category 5 Final December 19, 2014 Page 142 of 149

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Date Data
1 4/14/2014 <
2 7/15/2014 <
3 10/14/2014 <
4 10/13/2015 <
5 1/12/2016 <
6 4/12/2016 <
7 7/19/2016
8 10/11/2016 <
9 1/17/2017 <
10 4/4/2017 <
11 7/25/2017 <
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Chloroethane vb1Ugh-mT-n'COPi 1,1 Dichloroethane
Mommum dais pdnss
zu
BDL=112DL Results i
2
1
Std Dev.
1.47'
2
1
Mean
0.8364
0.5
0.25
C.V.
1.7672
0.5
0.25
n
11
0.5
0.25
0.5
0.25
0.5
0.25
Mult Factor =
3.0400
5.2
5.2
Max. Value
5.2
0.5
0.25
Max. Pred Cw
15.8
0.5
0.25
0.25
0.5
0.25
0.5
0.5
0.25
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
then
-Cop-data 0,04"t
z .S4
0.5615
1.4802
13
2.4300
3.3 ug/L
8.0 ug/L
9595 GENERIC RPA2014_32, data
- 1 - 5/21 /2018
BDL=1/2DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
3.3
3.3
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
then
-Cop-data 0,04"t
z .S4
0.5615
1.4802
13
2.4300
3.3 ug/L
8.0 ug/L
9595 GENERIC RPA2014_32, data
- 1 - 5/21 /2018

REASONABLE POTENTIAL ANALYSIS
1 1,1 Dichloroethene
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
valour, snore -COPY"
YstlmSrtrt data pelen
yy
0.5000
1.2247
13
2.2000
2.5 Ng/L
5.5 Ng/L
1,2 Dichloroethene (total)
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 1/17/2017 <
10 4/4/2017 <
11 7/25/2017 <
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
BDL=1/2DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
2.5
2.5
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
valour, snore -COPY"
YstlmSrtrt data pelen
yy
0.5000
1.2247
13
2.2000
2.5 Ng/L
5.5 Ng/L
1,2 Dichloroethene (total)
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 1/17/2017 <
10 4/4/2017 <
11 7/25/2017 <
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Value than "CUP 7,
mvitmum "to "nil
x A,S
1.81320
1.6136
1.1663
11
2.3700
5.0 vg/L
11.9 Ng/L
9595 GENERIC RPA2014_32, data
-2- 5121/2018
BDL=1/2DL
Results
10
5
Std Dev.
1
0.5
Mean
10
5
C.V.
2
1
n
0.5
0.25
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
0.5
0.25
5
2.5
5
2.5
Value than "CUP 7,
mvitmum "to "nil
x A,S
1.81320
1.6136
1.1663
11
2.3700
5.0 vg/L
11.9 Ng/L
9595 GENERIC RPA2014_32, data
-2- 5121/2018

REASONABLE POTENTIAL ANALYSIS
I Tetrachloroethene I
Date Data
1 8/6/2013
2 9/30/2013
3 10/1512013
4 11/14/2013
5 12/4/2013
6 4/14/2014
7 5/15/2014
8 6/16/2014
9 7/15/2014 <
10 8/21/2014 <
11 9/25/2014 <
12 10/14/2014 <
13 12/17/2014 <
14 9/8/2015 <
15 10/13/2015 <
16 11/2412015 <
17 12/15/2015 <
18 1112/2016 <
19 2/9/2016 <
20 3/8/2016 <
21 4/12/2016 <
22 5/18/2016 <
23 6/21/2016 <
24 7/19/2016 <
25 8111/2016 <
26 9/14/2016 <
27 10/11/2016 <
28 11/16/2016 <
29 12/14/2016 <
30 1/17/2017 <
31 2/16/2017 <
32 3/20/2017 <
33 4/4/2017 <
34 5/17/2017 <
35 6/19/2017 <
36 7/25/2017 <
37 8/23/2017 <
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
V61Ye1" than "COPY"
Maximum dam Pon"
r -m
0.91 �4�
1.5351
0.5991
37
1.1300
5.8 yg/L
6.6 Ng/L
BDL=1/2DL
Results
1.6
1.6
Std Dev.
2.6
2.6
Mean
2.2
2.2
C.V.
5.8
5.8
n
2.5
2.5
1.7
1.7
Mult Factor =
1.4
1.4
Max. Value
2.5
2.5
Max. Pred Cw
1
0.5
1
1
0.5
; 5C
3
1.5
<
3
1.5
Mean
3
1.5
10/15/2013
3
1.5
0.5
3
1.5
4
3
1.5
1
3
1.5
38
3
1.5
<
3
1.5
3
1.5
4/4/2014
3
1.5
0.5
3
1.5
7
3
1.5
1
0.5
0.25
2.0 ug/L
3
1.5
<
3
1.5
Max. Pred Cw
3
1.5
7/15/2014
3
1.5
0.5
3
1.5
10
0.5
0.25
1
3
1.5
3
1.5
<
0.5
0.25
3
1.5
10/14/2014
3
1.5
2
0.5
0.25
13
3
1.5
0.5
V61Ye1" than "COPY"
Maximum dam Pon"
r -m
0.91 �4�
1.5351
0.5991
37
1.1300
5.8 yg/L
6.6 Ng/L
9595 GENERIC RPA2014_32, data
- 3 - 5/21/2018
1,1,1 Trichloroethane
Vuluva"1118"'L4PY"
M�rrimum dart pekan
. Sa
Date
Data
BDL=112DL
Results
1
8/6/2013
<
1
0.5
Std Dev.
; 5C
2
9/30/2013
<
1
0.5
Mean
1.3974
3
10/15/2013
<
1
0.5
C.V.
0.5488
4
11/14/2013
<
1
0.5
n
38
5
12/4/2013
<
1
0.5
6
4/4/2014
<
1
0.5
Mult Factor =
1.1100
7
5/15/2014
<
1
0.5
Max. Value
2.0 ug/L
8
6/16/2014
<
1
0.5
Max. Pred Cw
2.2 ug/L
9
7/15/2014
<
1
0.5
10
8/21/2014
<
1
0.5
11
9/25/2014
<
4
2
12
10/14/2014
<
4
2
13
11/18/2014
<
0.5
0.25
14
12/17/2014
<
4
2
15
9/8/2015
<
4
2
16
10/13/2015
<
4
2
17
11/24/2015
<
4
2
18
12/15/2015
<
4
2
19
1/12/2016
<
4
2
20
2/9/2016
<
4
2
21
3/8/2016
<
4
2
22
4/12/2016
<
4
2
23
5/18/2016
<
4
2
24
6121/2016
<
4
2
25
7/19/2016
1.1
1.1
26
8/11/2016
<
4
2
27
9/14/2016
<
4
2
28
10/11/2016
<
4
2
29
11/16/2016
<
4
2
30
12/14/2016
<
4
2
31
1/17/2017
<
0.5
0.25
32
2/16/2017
<
4
2
33
3/20/2017
<
4
2
34
4/4/2017
<
0.5
0.25
35
5/17/2017
<
4
2
36
6/19/2017
<
4
2
37
7/25/2017
<
0.5
0.25
38
8/23/2017
<
4
2
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
9595 GENERIC RPA2014_32, data
- 3 - 5/21/2018

REASONABLE POTENTIAL ANALYSIS
I Trichloroethene
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 9/8/2015 <
7 10/13/2015 <
8 1/12/2016 <
9 4/12/2016 <
10 7/19/2016 <
11 10/11/2016 <
12 1/17/2017 <
13 4/4/2017 <
14 7/25/2017 <
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
VaiU"- mwn -Cpvr'
41ax�data panel
0.4618
0.4464
1.0344
14
1.9400
2.0 pg/L
3.9 Ng/L
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Benzene
BDL=112DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
4
2
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
VaiU"- mwn -Cpvr'
41ax�data panel
0.4618
0.4464
1.0344
14
1.9400
2.0 pg/L
3.9 Ng/L
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Benzene
va[ti 4s' In en -C OF, Y"
Maximum deli pdinei
• 9E
0.ii',J
0.3677
0.4650
13
1.4400
0.8 pg/L
1.1 pg/L
9595 GENERIC RPA2014_32, data
-4- 5/21 /2018
BDL=1/2DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
0.78
0.78
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
va[ti 4s' In en -C OF, Y"
Maximum deli pdinei
• 9E
0.ii',J
0.3677
0.4650
13
1.4400
0.8 pg/L
1.1 pg/L
9595 GENERIC RPA2014_32, data
-4- 5/21 /2018

Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/1512014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016 <
10 10/11/2016 <
11 1/17/2017
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Methyl Chloride 1
Vnlue%"them "COPY-
Ma.xunum pas points
_5a
0.8538
0.8372
13
1.82
3.1 pg/L
5.6 pg/L
1 1,2 Dichloroethane J
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016 <
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
BDL=112DL
Results
2
1
Std Dev.
2
1
Mean
2
1
C.V.
2
1
n
1
0.5
1
0.5
Mult Factor =
1
0.5
Max. Value
1
0.5
Max. Pred Cw
1
0.5
1
0.5
3.1
3.1
1
0.5
1
0.5
Vnlue%"them "COPY-
Ma.xunum pas points
_5a
0.8538
0.8372
13
1.82
3.1 pg/L
5.6 pg/L
1 1,2 Dichloroethane J
Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016 <
10 10/11/2016 <
11 1/17/2017 <
12 4/4/2017 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Vniue -rn vn"COF: v'-
Kazifnu Wti pa -MA
�53
0.33
0.3674
13
1.3400
0.5 Ng/L
0.7 Ng/L
9595 GENERIC RPA2014_32, data
- 5 - 5/21 /2018
BDL=1/2DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
0.5
0.25
Vniue -rn vn"COF: v'-
Kazifnu Wti pa -MA
�53
0.33
0.3674
13
1.3400
0.5 Ng/L
0.7 Ng/L
9595 GENERIC RPA2014_32, data
- 5 - 5/21 /2018

Date Data
1 8/6/2013 <
2 10/15/2013 <
3 4/14/2014 <
4 7/15/2014 <
5 10/14/2014 <
6 10/13/2015 <
7 1/12/2016 <
8 4/12/2016 <
9 7/19/2016
10 10/11/2016 <
11 1/17/2017 <
12 4/4/1947 <
13 7/25/2017 <
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
Toluene
vwwct -inen "CW,Y..
Maximum dale poorns
s!4
0.126u
0.3462
0.3657
13
1.3400
0.5 Ng/L
0.7 Ng/L
BDL=1/2DL
Results
1
0.5
Std Dev.
1
0.5
Mean
1
0.5
C.V.
1
0.5
n
0.5
0.25
2
0.5
0.25
Mult Factor =
0.5
0.25
Max. Value
0.5
0.25
Max. Pred Cw
0.5
0.5
4
0.5
0.25
1
0.5
0.25
5
0.5
0.25
1
0.5
0.25
6
vwwct -inen "CW,Y..
Maximum dale poorns
s!4
0.126u
0.3462
0.3657
13
1.3400
0.5 Ng/L
0.7 Ng/L
Vnwn' then -COPY"
Maximum data ppmm
= 78
0.3444
0.8289
0.4154
38
1.0900
2.0 Ng/L
2.2 ug/L
9595 GENERIC RPA201432, data
-6- EF/2112018
Vinyl Chloride
Date
Data
BDL=1/2DL
Results
1
8/6/2013
<
1
0.5
Std Dev.
2
9/30/2013
<
1
0.5
Mean
3
10/15/2013
<
1
0.5
C.V.
4
11/14/2013
<
1
0.5
n
5
12/4/2013
<
1
0.5
6
4/14/2014
<
1
0.5
Mult Factor =
7
5/15/2014
<
1
0.5
Max. Value
8
6/16/2014
<
1
0.5
Max. Pred Cw
9
7/15/2014
<
1
0.5
10
8/21/2014
<
2
1
11
9/25/2014
<
2
1
12
10/14/2014
<
2
1
13
11/18/2014
<
0.5
0.25
14
12/17/2014
<
2
1
15
9/8/2015
<
2
1
16
10/13/2015
<
2
1
17
11/24/2015
<
2
1
18
12/15/2015
<
2
1
19
1/12/2016
<
2
1
20
2/9/2016
<
2
1
21
3/8/2016
<
2
1
22
4/12/2016
<
2
1
23
5/18/2016
<
2
1
24
6/21/2016
<
2
1
25
7/19/2016
2
2
26
8/11/2016
<
2
1
27
9/14/2016
<
2
1
28
10/11/2016
<
2
1
29
11/16/2016
<
2
1
30
12/14/2016
<
2
1
31
1/17/2017
<
0.5
0.25
32
2/16/2017
<
2
1
33
3/20/2017
<
2
1
34
4/4/2017
<
0.5
0.25
35
5/17/2017
<
2
1
36
6/19/2017
<
2
1
37
7/25/2017
<
0.5
0.25
38
8/23/2017
<
2
1
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
Vnwn' then -COPY"
Maximum data ppmm
= 78
0.3444
0.8289
0.4154
38
1.0900
2.0 Ng/L
2.2 ug/L
9595 GENERIC RPA201432, data
-6- EF/2112018

REASONABLE POTENTIAL ANALYSIS
0
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Fred Cw
VRi[I-&- try 4n -C OVY"
Mommum da[a pains
c ,A
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
9595 GENERIC RPA2014_32, data
- 7 - 5/21 /2018
1.4 Dioxane
Values" Mian "COPY-
. �ilpmu115 tlA�A p7�lidf
58
Date
Data
BDL=112DL
Results
1
6/21/2014
<
80
40
Std Dev.
O.LULJ
1
2
9/25/2014
<
80
40
Mean
40.0000
2
3
10/14/2014
<
80
40
C.V.
0.6000
3
4
11/18/2014
<
80
40
n
5
4
5
12/17/2014
<
80
40
5
6
Mult Factor=
2.3200
6
7
Max. Value
40.0 Ng/L
7
8
Max. Pred Cw
92.8 Ng/L
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
f 58
0
Date Data BDL=1/2DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Fred Cw
VRi[I-&- try 4n -C OVY"
Mommum da[a pains
c ,A
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
9595 GENERIC RPA2014_32, data
- 7 - 5/21 /2018

REASONABLE POTENTIAL ANALYSIS
vaiucs" tnnr, -CON-
MAXIMUM WX POWO
�x
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
0
Date Data
BDL=1/2DL Results
1
Std Dev.
2
Mean
3
C.V.
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
vaiucs" tnnr, -CON-
MAXIMUM WX POWO
�x
NO DATA
NO DATA
NO DATA
0
N/A
N/A
N/A
VAfYns' than'COPY,
Maximum dw4 "nt%
e 5�
NO DATA
NO DATA
0
NIA
N/A
N/A
9595 GENERIC RPA2014_32, data
-8- 5/21 /2018
0
Date Data
BDL=1/2DL Results
1
Std Dev.
2
Mean
3
C.V.
4
n
5
6
Mult Factor =
7
Max. Value
8
Max. Pred Cw
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
VAfYns' than'COPY,
Maximum dw4 "nt%
e 5�
NO DATA
NO DATA
0
NIA
N/A
N/A
9595 GENERIC RPA2014_32, data
-8- 5/21 /2018

Date Data
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
0
vdiU&S, man -COPS"
i
O
Vafv"- ltwk'�COPY"
MaRimum data paiF t
, Mm -mw n da6a painU
I
BDL=1/2DL Results
Date Data
BDL=1/2DL Results
Std Dev.
NO DATA
1
Std Dev.
NO DATA
Mean
NO DATA
2
Mean
NO DATA
C.V.
NO DATA
3
C.V.
NO DATA
n
0
4
n
0
5
Mult Factor =
N/A
6
Mult Factor =
N/A
Max. Value
N/A
7
Max. Value
N/A
Max. Pred Cw
N/A
8
Max. Pred Cw
NIA
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
9595 GENERIC RPA2014_32, data
- 9 - 5/21 /2018

REASONABLE POTENTIAL ANALYSIS
0
Date Data BDL=112DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Fred Cw
Yltluy" Vann "COPY'
M"Imm 4KU paintl
a
NO DATA
NO DATA
0
N/A
N/A
N/A
9595 GENERIC RPA2014_32, data
-10- 5/21 /2018
0
Volues" b)Wn "COPY-
. maxlc l d*U Pwfft
_m
Date Data
BDL=112DL Results
1
Std Dev.
NO DATA
1
2
Mean
NO DATA
2
3
C.V.
NO DATA
3
4
n
0
4
5
5
6
Mult Factor =
N/A
6
7
Max. Value
N/A
7
8
Max. Pred Cw
N/A
8
9
9
10
10
11
11
12
12
13
13
14
14
15
15
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
26
26
27
27
28
28
29
29
30
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
I
58
0
Date Data BDL=112DL Results
Std Dev.
Mean
C.V.
n
Mult Factor =
Max. Value
Max. Fred Cw
Yltluy" Vann "COPY'
M"Imm 4KU paintl
a
NO DATA
NO DATA
0
N/A
N/A
N/A
9595 GENERIC RPA2014_32, data
-10- 5/21 /2018

Date Data
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
REASONABLE POTENTIAL ANALYSIS
O
venNs^ men 'COPY'
U
valuef" lhrlt "Copy'
. *mdmum dW pwft
. Nlil;if im data mifaq
6!
= SS
BDL=1/2DL Results
Date Data
BDL=1/2DL Results
Std Dev.
Ni: DATA
1
Std Dev.
NO DATA
Mean
NO DATA
2
Mean
NO DATA
C.V.
NO DATA
3
C.V.
NO DATA
n
0
4
n
0
5
Mult Factor =
N/A
6
Mult Factor =
NIA
Max. Value
N/A
7
Max. Value
N/A
Max. Pred Cw
N/A
8
Max. Pred Cw
N/A
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
I
58
I
9595 GENERIC RPA2014_32, data
11 - 5/21 /2018

Warer. Resources
ENVIRONMENTAL OUALR*Y
February 26, 2016
Mr. Stuart Kerkhoff
Environmental, Health and Safety Manager
Radiator Specialty Company
600 radiator Road
Indian Trail, NC 28079
PAT MCCROR.Y
DONALD R. VAN DER VAART
Secrelary
S. JAY ZIMMERMAN
L aed r
RECENED/NCDEQ/DWR
MAR 01 2016
Water Quality
Permitting Section
Subject: Compliance Evaluation Inspection
Radiator Specialty Company
Ground water remediation
NPDES Permit No. NCO088838
Union County
Dear Mr. Kerkhoff:
Enclosed is a copy of the Compliance Evaluation Inspection for the inspection conducted at
the subject facility on February 21, 2016 by Ori Tuvia and Ed Watson. Your cooperation during the
site visit was much appreciated. Please advise the staff involved with this NPDES Permit by
forwarding a copy of the enclosed report.
As was discussed on site, please indicate in DMRs that grab sampling is used.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Ori Tuvia at [phone], or at
ori.tuvia @ ncde n r.p,ov.
Cc: NPDES (Ron Berry)
MRO Files
Sincerely,
Ori Tuvia, Environmental Engineer
Mooresville Regional Office
Division of Water Resources, DEQ
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623.6748

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 1 3 1 NCO088838 [11 12I 16/02/21 117 18I, I 191 s I 20
211.11111 1111111 11 111111111 1 111111 111111111111x8
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA Reserved
67'1.0 701a I 71 IN 1 72 L1 N 7374 751 111 I 1 I 180
L-1 J
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time(Date
Permit Effective Date
POTW name and NPDES permit Number)
10:OOAM 16/02/21
09/10/01
Radiator Specialty Company
600 Radiator Rd
Exit Time/Date .
Permit Expiration Date
Indian Trail NC 28079
11:15AM 16/02/21
13/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
///
Richard Herman///
Stuart A Kerkhoff///
Stuart A Kerkhoff/ORC/704-6841815/
Name, Address of Responsible. Official/Title/Phone and Fax Number
Contacted
Stuart Kerkhoff,600 Radiator Rd Indian Trail NC 28079/1704-684-181517046841868
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
® Self -Monitoring Program E Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Edward Watson MRO GW///
Ori A Tuvia MRO WQ//704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
William C Basinger MRO WQ//704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NC0088838 11 12I 16/02/21 17 18 I C I
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Noted by Ed Watson:
A review of historical groundwater analytical results indicate the presence of chlorinate volatile organic
compounds (CVOC's) in the onsite groundwater. However, these values have been shown to be being
reduced by the on-site remediation efforts. Trichloroethane and several of its various daughter products
remain in concentration in exceedance of the NC 2L standards. Historic reported values indicate these
constituents are moving forward with the expected degradation of chlorinated solvents.
Page#

Permit: NCO088838 Owner -Facility: Radiator Specialty Company
Inspection Date: 0212112016 Inspection Type: Compliance Evaluation
Yes
No NA NE
Are records kept and maintained as required by the permit?
Permit
Yes
No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
❑
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
Dates, times and location of sampling
❑
❑
❑
Is the inspector granted access to all areas for inspection?
Name of individual performing the sampling
❑
❑
❑
Comment: Permit has expired on 10/20/2013. The facility has.. applied for a new Dermit. The en rmit
renewal is in the process of being reviewed.
Record Keeping
Yes
No NA NE
Are records kept and maintained as required by the permit?
❑
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M
❑
❑
❑
Is the chain -of -custody complete?
■
❑
❑
❑
Dates, times and location of sampling
don't indicate what type of sampling method is used.
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are MRS complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
M
❑
Comment: DMRs, COC_ ORC lops and calibration lops for the months of June 2014 -December 2015
were examined during the inspection. Records are well kept. It was discovered that MRS
don't indicate what type of sampling method is used.
Flow Measurement - Effluent
Yes No NA NE
Page# 3

Permit: NCO088838 Owner -Facility:
Radiator Specialty Company
Are field parameters performed by certified personnel or laboratory?
❑
❑
Inspection Date: 02/21/2016 Inspection Type:
Compliance Evaluation
Are all other parameters (excluding field parameters) performed by a certified lab?
❑
Flow Measurement - Effluent
Yes
No NA NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational?
■
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑
❑
❑
Comment: Flow meter is calibrated annually b; Clearwater Inc.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
❑
❑
Are all other parameters (excluding field parameters) performed by a certified lab?
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
❑
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
M
❑
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
❑
M
❑
Comment: Prism Lab is contracted to analyze samples.
ETS Lab performs chronic toxicity testing,
Effluent Samolin❑
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
❑
Is sample collected below all treatment units?
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
❑
❑
representative)?
Comment: The Dermit requires arab samples for all reauired Darameters. Samoles are kept on ice in a
cooler until transferred to Prism Lab.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ■ ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ M ❑
Comment: The discharge was clear with no foam and did not appear to impact the receiving stream.
Page# 4

Permit: NCO088838 Owner-Facility: Radiator Specialty Company
Inspection Date: 02/21/2018 Inspection Type: compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The facility pumps -ground water from four recovery wells. treated by an air striver tower.
Page# 5

RSC
Chemical Solutions
a division of Radiator Specialty Company
July 9, 2015
Mr. Ron Berry
Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: 1,4 -Dioxane Analytical Results
Radiator Specialty Company
Indian Trail, Union County, North Carolina
Permit No. NCO088838
Dear Mr. Berry:
RECEIVED/DENROWR
JUL 16 2015
Water Quality
Permitiinq Sectiar
Radiator Specialty Company (RSC) is responding to your June 16, 2015 email
concerning the analytical results for the presence of 1,4 -Dioxane in RSC's groundwater
samples.
RSC understands DENR's position that it needs to see the actual measured values,
not just less than values, to properly evaluate the 1,4 -Dioxane concentrations. DENR
informed RSC that it would put a permit limit of eighty (80) micrograms/Liter (ug/L) in
RSC's new National Pollutant Discharge Elimination System (NPDES) Permit. Based on
that conversation, RSC requested its testing laboratory to report actual measured values
of 1,4 -Dioxane down to eighty (80) ug/L. As it turns out, RSC's testing laboratory can
only report measured values for 1,4 -Dioxane to eighty (80) ug/L. Any results at less than
this concentration can only be reported as estimate concentrations. The results reported
to the DENR on May 12, 2015 are below the analytical method reporting limit and
therefore cannot be reported as actual measured values.
RSC asked its testing laboratory if any other analytical methods were available
that could provide actual measured values at less than eighty (80) ug/L. The testing
laboratory advised that no accepted methods can provide actual measured values at less
than eighty (80) ug/L. Since DENR has already advised that it cannot use estimated
values, RSC did not request alternate analytical procedures be used.
Radiator Specialty Company appreciates the North Carolina Department of
Environment and Natural Resources cooperation and assistance in this matter. If you
have any questions or require additional information, please call me at [phone].
600 Radiator Road — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com

Mr. Ron Berry
July 9, 2015
Page 2
Sincerely,
Radiator Specialty Company
Lap /
Y
Stuart A. Kerkhoff, CHMM
Environmental Health and Safety Manager
cc: Mr. Richard Harmon, Harmon Environmental, PA
Mr. Benne Hutson, McGuireWoods LLP
NPDESU A-DIOXAN ERESPONSFIDOC

sorp RSC
Chemical Solutions
a division of Radiator Specialty Company
September 25, 2014
Mr. Ron Berry
Engineer
North Carolina Department of
Environment and Natural Resources
Division of Water Resources
1617 Mail Services Center
Raleigh, North Carolina 27669-1617
Re: Response To August S, 2014 E -Mail
Radiator Specialty Company
Indian Trail, North Carolina
Permit No. NCO088838
Dear Mr. Berry:
RECEIVED/DENR/DWR
SEP 2 5 2014
Water Quality
Permitting Section
Radiator Specialty Company (RSC) appreciates this opportunity to respond to the two
proposed changes to the pending National Pollutant Discharge Elimination System
(NPDES) Permit renewal for Permit No. NC0088838. For ease of review, we have
presented the North Carolina Department of Environment and Natural Resources
(DENR) intended incorporations from your August 5, 2014 e-mail in italics followed by
RSC's response.
1. Any submitted toxicity testing ",ill require a composite be taken as the test sample.
We understand that composite samples are typically required for NPDES permitted
facilities with either an intermittent discharge and/or the potential for variability in the
waste stream over a twenty-four (24) hour period. The groundwater recovery and
treatment system at Radiator Specialty Company discharges approximately 40,000
gallons of treated groundwater per day. The discharge flow is driven by the pumping of
groundwater from four (4) on-site recovery wells. As a result, the system discharges
continuously each day. Since the source of the water is limited to the four (4) recovery
wells, the influent water quality is well documented and variability in the waste stream
has not previously occurred and is not expected to occur in the future. As a result, grab
samples adequately represent the water quality for toxicity testing.
DENR has accepted this approach at at least one other facility with a similar discharge.
A May 8, 2014 determination by Ms. Cindy Moore. Mr. Tom Belnick and Mr. Wes Bell
of DENR authorized Equipment & Supply. Inc. (NPDES #0087858) to revise the toxicity
sampling protocol from composite to grab. The groundwater treatment and discharge
600 Radiator Road — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com

' Mr. Ron Berry
September 25, 2014
Page 12
system at the Equipment & Supply, Inc. facilty is comparable to the system operated by
RSC.
RSC requests the toxicity sampling protocol not be revised.
2. The presence of 1,4 -dioxane in the influent and groundwater sources will require
the addition of monthly 1,4 -dioxane monitoring with an 80 microgram per liter
(,ug/L) daily limit to protect for the Human Health surface water quality standard
RSC is aware that 1,4 -dioxane has historically been detected in groundwater samples
collected from the site and is not opposed to analyzing the effluent for 1,4 -dioxane.
However, this parameter is not targeted by standard method 624, the analytical method
currently required by the facility's Permit. Based on an August 11, 2014 telephone
conversation with you, RSC understands DENR would accept modifying the Permit
during the renewal process to specify SW -846 Method 8260 instead of Standard Method
624 for targeted volatile constituents. Further, based on this conversation, RSC
implemented this analytical method change during the August 2014 monthly sampling
event.
The Method Reporting Limit for SW -846 Method 8260 is 150 µg/L. Prism Laboratories,
Inc. has indicated that a normal Method Detection Limit for SW -846 Method 8260 is
-� 10.6 pg/L. Should 1,4 -dioxane be detected in the effluent sample at a concentration
between the permit limit and 150 µg/L, the result would be reported as a "Y' value.
Based on our telephone conversation on August 11, 2014, RSC anticipates three (3) to six
(6) months will be necessary to collect and evaluate 1,4 -dioxane analytical results to
determine if changes to the existing groundwater recovery system are necessary.
RSC appreciates DENR allowing us to review its recommended changes prior to issuing
the draft permit renewal. Please call if you have any questions or require any additional
information.
Sincerely,
Radiator Specialty Company
La"
Stuart Kerkhoff
Environmental, Health and Safety Manager
cc: Mr. Richard L. Harmon, Harmon Environmental. PA
Mr. Benne Hutson. McGuireWoods LLP
NPD1-.S/1TRMI I C11AN(ili.DOCX

Daily
Permit
Limits
Parameters ug/L
Flow (MGD) 0.09
Monthly Sampling
Total Suspended Solids
0.045
Monthly Average
0.030
Tetrachloroethene
3.0
1,1,1 -Trichloroethane
4.0
Vinyl chloride
2.0
1,4 -Dioxane """
80.0
Quarterly Sampling
<0.50
Chloroethane --
1,1-Dichloroethane --
1,1-Dichloroethene --
1,2-Dichloroethene (total)
cis-1,2-Dichloroehene
Trichloroethene
Benzene ---
Methylene chloride --
1,2-Dichloroethane --
Toluene ---
trans-1,2-Dichloroethene ---
Chronic Toxicity 90%
Comments:
Table 2
AIR STRIPPER EFFLUENT
RADIATOR SPECIALTY COMPANY
NPDES PERMIT NO. NC0088838
OUTFALL 001
08/21/14
09/25/14
10/14/14
11/18114
12/17/14
0.0006
0.0317
0.0270
0.0182
0.0332
<0.0025
<0.0026
<0.0026
<0.0025
<.0026
<1.0
<1.0
<3.0
1.213
<3.0
<1.0
0.61
<4.0
<0.50
<4.0
<2.0
<0.50
<2.0
<0.50
<2.0
<80
<80
<80
<80
<80
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
NA
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<1.0
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
<0.50
NA
NA
NA
NA
P
NA
NA
NA: Not Analyzed
P: Pass Chronic Toxicity
Flow: Flow is the reading from the flowmeter day of sample collection less flowmeter reading during last
outfall inspection divided by number of days between the two. See DMR Form.
1,4 -Dioxane: New Permit will have a limit of 80 ug/L. RSC started sampling it for evaluation in August 2014.
In addition, RSC swithced to SW846 Method 8260.
TABLE 2
Page 1

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R S C
Chemical Solutions
a division of Radiator Specially Company
May 12, 2015
Mr. Ron Berry
Engineer
North Carolina Department of Environment
and Natural Resources
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699
RE: 1,4 -Dioxane Data Collection and Evaluation
Radiator Specialty Company
Indian Trail, Union County, North Carolina
Permit No. NCO088838
Dear Mr. Berry:
Radiator Specialty Company (RSC) is responding to your August 5, 2014 email
concerning the presence of 1,4 -Dioxane in RSC's groundwater influent.
As we discussed, to address your concern, RSC implemented a monthly sampling
program in which both influent and effluent were sampled for 1,4 -Dioxane from August
through December 2014. The results of both the influent and effluent samples throughout
this sampling period were below the suggested Permit Limit of eighty (80) micrograms
per liter (ug/L). The results of these sampling activities are summarized in Tables 1 and
2.
Based on the results of this sampling program, RSC does not intend to modify the
current treatment technology at this time. RSC proposes to continue sampling the
effluent for 1,4 -Dioxane quarterly. In the event 1,4 -Dioxane concentrations in the
effluent indicate exceedances, RSC will evaluate additional treatment technologies at that
time.
On December 19, 2014, RSC shut down the groundwater recovery system due to
operational issues with the computer system that runs the groundwater recovery system.
RSC has been diagnosing the situation and proposes to resume operation of the
groundwater recovery system when the issues have been resolved.
Radiator Specialty Company appreciates the North Carolina Department of
Environment and Natural Resources cooperation and assistance in this matter. If you
have any questions or require additional information, please call me at [phone].
600 Radiator Road — Indian Trail, NC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com

Mr. Ron Berry
May 12, 2015
Page 2
Sincerely,
Radiator Specialty Company
ht'J a )
Stuart A. Kerkhoff, CHMM
Environmental Health and Safety Manager
cc: Mr. Richard Harmon, Harmon Environmental, PA
Mr. Benne Hutson, McGuireWoods LLP
NPDES\1.4-DI OXANERESPONSE.DOC

seVP RSC
Chemical Solutions
a division of Radiator Speeiaity Company
May 3, 2013
Mr. Charles H. Weaver
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
National Pollutant Discharge Elimination
System Unit
1617 Mail Service Center
--
RE: National Pollutant Discharge Elimination System
Permit Renewal Application
Radiator Specialty Company =
Indian Trail, Union County, North Carolina
Permit No. NCO088838 :
Dear Mr. Weaver:
Radiator Specialty Company (RSC) respectfully submits fdr your review, three
copies of its National Pollutant Discharge Elimination System WDES) Permit No.
NCO088838 Permit Renewal Application — Short Form C r GW. This submission serves
as RSC's request for renewal of NPDES Permit NC008883,8.
Based on the most recent analytical results, with the exception of chloroethane,
1, 1 -dichloroethane, 1, 1 -dichloroethene and vinyl chloride, detected at concentrations of
5.9 ug/L, 2.4 ug/L, 1.5 ug/L and 2.0 ug/L, respectively, no targeted constituents were
detected at concentrations exceeding the respective analytical method detection limit.
Radiator Specialty Company appreciates the North Carolina Department of
Environment and Natural Resources cooperation and assistance in this matter. If you
have any questions or require additional information, please call me at (704^ 1815.
Sincerely, y- 8 e'�' ` \
Radiator Specialty Company .�
e
Stuart A. Kerkhoff, CH
Environmental Health and Safety Manger NPD Es LT.DOC
600 Radiator Road — Indian Trail, INC 28079-5225 — Telephone: [phone] — Fax: [phone] — www.rscbrands.com