NCS000330_Staff Report Original Signed_20090512

STORMWATER DIVISION CODING SHEET
NCS PERMITS
PERMIT NO.
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING RFPORTS
❑ APPLICATION
X COMPLIANCE
❑ OTHER
DOC DATE
❑ Z" 0 dS b
YYYYM M D D

N ISQ00330
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
Facility Name:
NPD> S Permit Number:
Facility Location:
T3TO of Aotivity:
SIC Code:
Receiving Streams:
River Basin:
Stream Classification:
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
ATI Allvac.
NCS000330 X%I •
1 2020 Asheraft Ave, Monroe, NC (Union County)
Proposed Permit Requirements
Monitoring Data:
Response Requested by (Date):
Central Office Staff Contact:
Special Issues:
Secondary Stlielthig wid Refining of Nonfeit M
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3341
See Figure 1
Yadkin Pee -Dee River Basin, Sub -basin 03-07-14'
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See attached draft permit
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See Table 1
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Return to: Brian Lowther, [phone]
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Issue
Rating Scale: 1 eas ' to 10(hard)
Corn Hance history
5
Benchmark exceedance
7
Location (TMDL, T&E
5
$ Qvies, Glc
Other Challenges:
8
• Finding the
Company Name
and Signature
Authority
Difficult Rating:
25/40
Special Issues Explanation:
• ATI Allvac is the doing business as (dba) name. TDY Industries, Inc. is the owner.
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Description of Onsite Activities:
• Allvac operates a plant in Monroe, North Carolina that has a SIC code of 3341. The Monroe plant is
engaged in the melting, casting, forging, rolling, sawing and grinding of nickel and titanium alloys. In
addition, the plant also carries out "conversion" type processes (forging, rolling, sawing, and grinding,) of
Pagel of 8

NCS000330
tools steels, stainless steels, and various other alloys for outside customers.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP) Threatened and Endangered Species Database
• SPU File
• Central Files
• EPA Sector -Specific Permit, 2008
• 303(d) List 2006 final
• 2008 (draft) Yadkin Pee -Dee Basinwide Plan
History:
• January 1, 2006: Date permit first issued. Analytical monitoring included BOD, COD, TSS, total
cadmium, total lead and total nickel. Samples were to be taken annually.
• March 20, 1996: Request for Identical Outfall Exemption given. Outfall #3 is representative of outfalis #1,
2, 4 and 5.
• ,tune 12., 2000: Renewal reminder letter sent
• February 14, 2.003• hate permit re -issued, Analytical monitoring included BOD, COD, TSS, total
cadmium, total lead, total nickel, total zinc, and total chromium. Samples were to be taken annually, the
first three years and quarterly during the 41" year.
• September 12, 2007: Renewal reminder letter sent.
• October 15, 2007: Date permittee submitted renewal application.
• May 16, 2008: Compliance Inspection
Page 2 of 8

NCS000330
Figure 1: Map of Facility
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Map Scale 1;18,206
Allvac
Monroe Plant
Latitude: 350 50' 05" N
Longitide: 800 36'30" W
County: Uhion
Receiving Stream; Richardson Creek
Stream Class: C
Sub-badn: 03-07-14 (Yadkin Pee -Dee River Basin)
Fa A i ty Location
Page 3 of 8

NCS000330
Central Office Review Summary:
1. Owner's Other Permits: AFS 3717900055 ATI Allvac —Monroe Plant
• NCO045993 — Teledyne Allvac-Monroe Plant. There are limits on Chromium, Copper, Cyanide,
Flow, Fluoride, Lead, Nickel, Ammonia Total Nitrogen, Oil & Grease, Ceriodaphnia, pH, TSS, Specific
Conductance, Temperature, and Zinc.
2. General Observations:
ATI Allvac is a world leader in the production of cobalt -base and nickel -base super alloys, titanium -base alloys
and specialty steels —metals of exceptional wear resistance, corrosion resistance, heat resistance, toughness and
strength. Under the leadership of Allegheny Technologies (ATI), ATI Allvac provides manufacturers of
medical and surgical devices with one reliable source for a large portion of their metallic biomaterials needs.
3. Impairment: Richardson Creek 13-17-36-(5)a is on the 303(d) for impaired biological integrity. Basinwide
Plan recommendations are below:
1998 Recommendation: The 1998 basin plan discusses naturally low dissolved oxygen, excess nutrients and
sedimentation in Richardson Creek. Reconnnendations are that no new discharges of oxygen consuming wastes
be permitted above the Monroe WWTP discharge. The plan also states that further investigation into the causes
and sources of water quality impacts is needed before more specific recommendations to impimu 'water qualify
can be made.
2002 Recommendations: DWQ will work with the Division of Water Resources in order to determine whether
a minimum instream flow requirement is feasible and/or necessary for the Lake Lee dam. Local actions are
needed to reduce nutrients from all sources (agriculture, wastewater infrastructure and stormwater runoff) in the
Richardson Creek watershed above SR 1649 and Salem Creek.
4. Threatened and Endangered: No protected species within 2 miles based on the Natural Heritage Virtual
Workroom.
5. Location: Outfall drains to a classified C Stream.
6. Industrial Changes Since Previous Permit: The operations have not changed since the permit was issued.
7. Analytical Monitoring Notes: A summary of the analytical monitor was provided in the renewal application.
Central files had three rain events with 2 samples taken about 15 minutes apart from each other. Many values
are above the current benchmarks for BOD, COD, TSS and nickel. Especially for the first of the two samples
for each storm.
Rlo'od on the SIC of i i4 l tlu+ iudustty is omlolod under Soctor E' "Primary Motals" in the 2009 Multi Sectau
General Permit but there are no recommendation for analytical monitoring.
Maintain monitoring for BOD, COD, TSS, Cadmium, bead, Nickel and zinc. Add additional monitoring for
Oil & Grease and Chromium because of potential pollutant onsite.
8. Qualitative Monitoring otes: Visual monitoring was done two times at six different outfalls. Some of the
values are high (6-7) for clarity. The colors are light -medium brown and light -medium gray. There are some
suspended solids.
Page 4 of 8

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NCS000330
Revised Permit Recommendations: Analytical Monitoring:
1. Maintain monitoring for BOD, COD, TSS, Cadmium, Lead, Nickel and Zinc. Add monitoring for Oil &
Grease and Chromium.
2. pII has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
4. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
initigatioii hlaii withhi two inotalis. If during (lie leiiii of [his pemilt, [lie sampling results aie above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition
of the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every
outfall where a sampling result exceeded the benchmark value for two consecutive samples.
5. The permittee is required to collect all of the analytical and qualitative monitoring samples during
representative storm events as defined in Part II Section B. Qualitative monitoring is required regardless of
representative outfall status.
6. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1,
4, and 5.
7. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
S. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDI . established It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
4,llilk (ha( have. oc,cuued ill the Jim( thlec years s.uid also must certify that the outl':Atis have been imt)ecteel to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II
Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. Mote
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do
not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials
and activities are not exposed to precipitation or runoff as described in 40 CFR § I22.26(g), the facility may
qualify for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional
information is provided in Part I Section A.
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r'
NCS000330
Recommendations: Based on the documents reviewed, the application information submitted on October 15, 2007
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) �-.. �/ Date 3 It C , 9
Stormwater Permitting Unit Supervisor Date
for Bradley Bennett
Concurrence by Regional Office pf Date
RO Water Quality Supervisor Date 5 v /
Regional Office Staff Comments (attach additional pages as necessary)
Verifv that Outfall #3 is still representative ofoutfalls #1, 2, 4 and 5. ,
le,
Page 8 of 8

{
NCS000330
Discussions with permittee: Kyle Dunn, 704 289 4511, 01/14/09
1. What is the name of the company? Why would it not be in the Dept. of the Secretary of State Corporations?
ATI,Allvac. Found the owner to be TDYIndustries, Inc. Delegation of Authority was sent in for Kyle Dunn.
2. Have there been any changes since filing the application? No
3. What chemicals or materials are stored outside? Some metals products stored outside: titanium and high nickel
alloys. Some by products that aren't supposed to be covered.
4. The analytical monitoring shows high values for BOD, COD, TSS and nickel. Any reasons for that? Some of
the products are high in nickel but not sure why the values are high.
5. The qualitative monitoring shows colors of gray and brown. Also, high number for clarity (4-7) as well as
solids (3-6). Can you describe the stormwater outfall? The outfall has lime rip rap and some of the roads
aren't paved around it. The outfall is in pretty good shape.
6. How many outfalls are there? (5) Total, but one of those is the NPDES permitted cooling pond effluent
7 Do you do vehicle maintenance onsite9 ATo
8. What is you SIC code? 3356
Page 7 of 8

NCS000330
Site visit/facility inspection conducted 5-1-2009.
Proposed changes in draft permit discussed with permittee. Facility may have
difficulty complying (meeting) some of the benchmark values established in the
draft permit. Specifically, compliance with the benchmark values for BOD, COD,
TSS, Nickel, and Zinc_ may prove difficult to achieve on a consistent basis based
on a review of recent monitoring data. The benchmark value for Zinc is of a
particular concern in that one of the sources of this constituent is suspected
to be the metal roofing that covers most, if not all of the manufacturing
buildings located at this site and amounts to several hundred thousand square
feet of surface area. In conversations with the permittee, a re-evaluation of
these values will likely be requested or avoidance of the Tier TT and TTT
sampling requirements will be nearly impossible.
Site visit cunEiimed l.hal. uuLfal.l. 003 is still representative of outfallS 1, ?,
4, and b.
Another conce.rn mentioned by the permittee is the requirement to sample the SW
at mahole No. 633.668.01 even though the water from this manhole is not a SW
outlet nor does .it discharge directly through a permitted SW outfall. The SW
sampling requirement is actually part of this facility's regular NPDES permit
(NC0045993). Analytical testing from this manhole has consistently produced
elevated levels of constituents, which reflect negatively on the permittee even
though the SW from this manhole qoes into a settling pond and does not outlet
directly to surface waters. Prior to reissuance of the SW permit, a decision
should be made as to whether continued sampling of manhole No. 633.668.01 is
appropriate for compliance with the SW permit.
Qualitative monitoring results indicating high values for clarity and solids may
be the result of unpaved roads that both line and cross -cross this site. Fines
and other gray/brown particles from these unpaved roads likely contribute to the
elevated clarity and solids observations.