NC0004260_Fact Sheet_20181207

Fact Sheet
NPDES Permit No. NC0004260

Permit Writer/Email Contact Nick Coco, [e-mail]:
Date: August 15, 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:
SKF USA Inc./ Former CR Industries

Applicant Address:
890 Forty Foot Road, Lansdale, PA 19446-0352

Facility Address:
4328 South York Street, Gastonia, NC 28053

Permitted Flow:
0.0072 MGD

Facility Type/Waste:
MINOR Industrial; 100% industrial

Facility Class:
Grade I Physical/Chemical Water Pollution Control System (PCWPCS)

Treatment Units:
Surge tank with transfer pump, bag filter, multi-tray air stripper unit with blower, flow meter with recorder

Pretreatment Program (Y/N)
N

County:
Gaston

Region
Mooresville


Briefly describe the proposed permitting action and facility background: The permit was originally issued to CR Industries for the treatment of domestic and industrial waste. The permit
has been modified extensively since it was issued in 1996. In 1998 they added a groundwater treatment system and began discharging the treated groundwater through the same outfall as
the industrial/domestic treatment plant. In
1999 they closed the facility and ceased the domestic/industrial discharge. They eventually sold the facility and the new owner connected the domestic/industrial portion of the effluent
to the City of Gastonia WWTP. SKF USA retained the groundwater treatment system and the responsibility for its operation and maintenance. The groundwater remediation system was installed
to remediate/extract trichloroethene, tetrachloroethene, and cis-1,2dichloroethene from the groundwater.
Initially, a Chronic toxicity test at 0.33% concentration was required for the GWR discharge. But in the 2002 permit renewal the permitted flow was decreased resulting in the toxicity
test requirement being changed to Acute to comply with Division policy. The policy stated that when the toxicity test concentration (defined by the IWC) is less than 0.25% then a Chronic
test is not applicable and an Acute toxicity test at 90% must be applied.
The last reported discharge from this GWR system was in March 2008. In February 2010, the permittee requested and was granted a waiver to discontinue monitoring and submittal of DMR
while no discharge occurred. The treatment system is currently deemed inactive, and the region has confirmed that subsequent piping had been removed to disengage the treatment system
from the outfall. All fees and other permit conditions still apply.
The groundwater treatment system consists of 2 collection wells which discharge to a 500 gallon surge tank. A transfer pump conveys the liquid from the surge tank through a bag filter
and then to a 5 tray air stripper. As the flow leaves the air stripper collection sump, a flow meter/recorder measures the flow. The effluent flow continues through a buried gravity
line and discharges through the permitted Outfall 001 into Crowders Creek. Crowders Creek flows into South Carolina and is a tributary to Lake Wylie.
Hart & Hickman, PC, representative/operator for this GWR system has submitted a permit renewal as they believe they will be required to restart this system. The DWM incident number for
this facility is NCD006556963.

In 2010, the Division received and reviewed a request for a waiver of monthly reporting requirements. As the facility had not been producing any wastewater discharge and the remediation
system had been inactive since 2008, the request was granted. The site remains inactive. The Permittee shall contact and notify the Mooresville Regional Office within 30 days of site
reactivation.

A special condition has been added to the permit requiring the Permittee to conduct an influent and effluent VOC scan as well as an effluent 1,4-dioxane scan within 30 days of site reactivation.
As chlorinated solvents were present at the site, 1,4-dioxane may also be present in the groundwater. The addition of these scans acts as a reasonable precaution. A second, complementary
special condition was added to the permit allowing the Division to reopen the permit to address pollutants of concern in the case the required scans turn up results with reasonable
potential for harm.

Note: The draft permit was addressed to the incorrect person but was received and reviewed by the Permittee. The final cover letter has been adjusted and addressed to Erika Mau, the
current authorized SKF USA, Inc. representative.

2. Receiving Waterbody Information:
Receiving Waterbody Information

Outfalls/Receiving Stream(s):
Outfall 001 – Crowders Creek

Stream Segment:
11-135

Stream Classification:
C

Drainage Area (mi2):
35.6

Summer 7Q10 (cfs)
6.7

Winter 7Q10 (cfs):
10.2

30Q2 (cfs):
14.4

Average Flow (cfs):
42

IWC (% effluent):
0.17%

303(d) listed/parameter:
Listed/Benthos

Subject to TMDL/parameter:
No

Subbasin/HUC:
03-08-37; 03050101

USGS Topo Quad:
G14NW


3. Effluent Data Summary
Effluent data for Outfall 001 is summarized below for the period of January 2014 through July 2018.
Table. Effluent Data Summary Outfall 001
Parameter
Units
Average
Max
Min
Permit Limit

Flow
MGD
N/A
N/A
N/A
MA 0.0072

pH
s.u.
N/A
N/A
N/A


Methylene Chloride
µg/l
N/A
N/A
N/A


1,2-trans-Dichloroethene
µg/l
N/A
N/A
N/A


1,2-Dichloropropane
µg/l
N/A
N/A
N/A


Trichloroethene (TCE)
µg/l
N/A
N/A
N/A


Tetrachloroethene (PCE)
µg/l
N/A
N/A
N/A


 MA-Monthly Average, WA-Weekly Average, DM-Daily Maximum, DA=Daily Average

No flow data was provided during the period of January 2014 through July 2018, as the facility has been inoperative for this time.
4. Instream Data Summary
Instream monitoring may be required in certain situations, for example: 1) to verify model predictions when model results for instream DO are within 1 mg/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: Instream monitoring is not required in this permit.
Is this facility a member of a Monitoring Coalition with waived instream monitoring (Y/N): NO
Name of Monitoring Coalition: NA

5. Compliance Summary
Summarize the compliance record with permit effluent limits (past 5 years): The facility reported no limit violations from August 2014 to July 2018.
Summarize the compliance record with aquatic toxicity test limits and any second species test results (past 5 years): The facility reported no flow from 2014 to 2018.
Summarize the results from the most recent compliance inspection: The last facility inspection conducted in March 2017 reported that the facility was neither in nor out of compliance.
According to the report, Mooresville Regional Office staff were unable to gain access to the two onsite recovery wells, as they were locked and a key was unavailable at the time. The
inspection summary explains that the system was shut down in 2008 and is in an inoperative state. It was recommended that, should the system be reactivated, the system discharge be
connected to a nearby storm drain. The MRO would need to be present at system startup in this case.

6. Water Quality-Based Effluent Limitations (WQBELs)
Dilution and Mixing Zones
In accordance with 15A NCAC 2B.0206, the following streamflows are used for dilution considerations for development of WQBELs: 1Q10 streamflow (acute Aquatic Life); 7Q10 streamflow (chronic
Aquatic Life; non-carcinogen HH); 30Q2 streamflow (aesthetics); annual average flow (carcinogen, HH).
If applicable, describe any other dilution factors considered (e.g., based on CORMIX model results): N/A
If applicable, describe any mixing zones established in accordance with 15A NCAC 2B.0204(b): N/A

Oxygen-Consuming 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
(e.g., BOD= 30 mg/l for Municipals) may be appropriate if deemed more stringent based on dilution and model results.
If permit limits are more stringent than TBELs, describe how limits were developed: N/A
Ammonia and Total Residual Chlorine Limitations
Limitations for ammonia are based on protection of aquatic life utilizing an ammonia chronic criterion of 1.0 mg/l (summer) and 1.8 mg/l (winter). Acute ammonia limits are derived from
chronic criteria, utilizing a multiplication factor of 3 for Municipals and a multiplication factor of 5 for Non-Municipals.
Limitations for Total Residual Chlorine (TRC) are based on the NC water quality standard for protection of aquatic life (17 ug/l) and capped at 28 ug/l (acute impacts). Due to analytical
issues, all TRC values reported below 50 ug/l are considered compliant with their permit limit.
Describe any proposed changes to ammonia and/or TRC limits for this permit renewal: N/A

Reasonable Potential Analysis (RPA) for Toxicants
If applicable, conduct RPA analysis and complete information below.
As the facility has been in an inactive state and has reported no flow, no RPA was conducted.

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 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 Minor Industrial facility. Should the facility reactivate, an acute WET limit at 90% effluent will continue on a quarterly frequency.

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/l) and/or if any individual value exceeds a TBEL value of 47
ng/l.
Describe proposed permit actions based on mercury evaluation: The facility is not known to discharge mercury.

Other TMDL/Nutrient Management Strategy Considerations
If applicable, describe any other TMDLs/Nutrient Management Strategies and their implementation within this permit: N/A

7. Antidegradation Review (New/Expanding Discharge):
The objective of an antidegradation review is to ensure that a new or increased pollutant loading will not degrade water quality. Permitting actions for new or expanding discharges
require an antidegradation review in accordance with 15A NCAC 2B.0201. Each applicant for a new/expanding NPDES permit must document an effort to consider non-discharge alternatives
per 15A NCAC 2H.0105( c)(2). In all cases, 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

8. Antibacksliding Review:
Sections 402(o)(2) and 303(d)(4) of the CWA and federal regulations at 40 CFR 122.44(l) 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

9. Monitoring Requirements
Monitoring frequencies for NPDES permitting are established in accordance with the following regulations and guidance: 1) State Regulation for Surface Water Monitoring, 15A NCAC 2B.0500;
2) NPDES Guidance, Monitoring Frequency for Toxic Substances (7/15/2010 Memo); 3) NPDES Guidance, Reduced Monitoring Frequencies for Facilities with Superior Compliance (10/22/2012
Memo); 4) Best Professional Judgement (BPJ). Per US EPA (Interim Guidance, 1996), monitoring requirements are not considered effluent limitations under Section 402(o) of the Clean
Water Act, and therefore anti-backsliding prohibitions would not be triggered by reductions in monitoring frequencies.
For instream monitoring, refer to Section 4.

10. 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.

11.Summary of Proposed Permitting Actions:
A. Table. Current Permit Conditions and Proposed Changes 0.0072 MGD
Parameter
Current Permit
Proposed Change
Basis for Condition/Change

Flow
MA 0.0072 MGD
No change
15A NCAC 2B .0505

pH
Quarterly Monitoring
No change
WQBEL. State WQ standard, 15A NCAC 2B .0200

Methylene Chloride
Quarterly Monitoring
No change
WQBEL. NC Protective Value for Surface Waters; Integrated Risk Information System

1,2-trans-Dichloroethene
Quarterly Monitoring
No change
WQBEL. EPA Nationally Recommended Water Quality Criteria

1,2-Dichloropropane
Quarterly Monitoring
No change
WQBEL. EPA Nationally Recommended Water Quality Criteria

Trichloroethene (TCE)
Quarterly Monitoring
No change
WQBEL. 15A NCAC 02B Water Quality Standards for Surface Waters

Tetrachloroethene (PCE)
Quarterly Monitoring
No change
WQBEL. 15A NCAC 02B Water Quality Standards for Surface Waters

Toxicity Test
Acute limit, 90% effluent
No change
WQBEL. No toxics in toxic amounts. 15A NCAC 2B.0200 and 15A NCAC 2B.0500

1,4-Dioxane
No requirement
See Special Condition A.(4.)
G.S. 143-215.66

VOC Scan
No requirement
See Special Condition A.(4.)
G.S. 143-215.66

Reopener Clause
No requirement
See Special Condition A.(5.)
G.S. 143-215.1

Electronic Reporting
No requirement
Add Electronic Reporting Special Condition
In accordance with EPA Electronic Reporting Rule 2015.

MGD – Million gallons per day, MA - Monthly Average, WA – Weekly Average, DM – Daily Max

12. Public Notice Schedule:

Permit to Public Notice: August 15, 2018

Per 15A NCAC 2H .0109 & .0111, 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.

13. Fact Sheet Addendum (if applicable):

Were there any changes made since the Draft Permit was public noticed (Yes/No): NO
If Yes, list changes and their basis below: NA

14. Fact Sheet Attachments (if applicable):
303d Impaired Waters Listing
Toxicity Summary
Monitoring Violations Summary