NCS000329_Staff Eval_20091208

NCS000329
ALT-WYWAa
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
ATI Allvac.
NPDES Permit Number:
NCS000329
Facility Location:
1700 Teledyne Road, Monroe, NC (Union County)
Type of Activity:
Metals
SIC Code:
3356
Receiving Streams:
See Figure 1
River Basin:
Yadkin River Basin, Sub -basin 03-07-14
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Response Requested by (Date):
Z�Z�q
Central Office Staff Contact:
Return to: Brian Lowther, [phone]
Special Issues:
Issue
Rating Scale: 1 eas to 10 hard
Compliance history
3
Benchmark exceedance
5
Location (TMDL, T&E
species, etc)
Other Challenges:
• Waste Watef
4
6
18/40
Difficulty Ratin :
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Special Issues Explanation:
• In a letter dated May 9, 1996 ATI Allvac Bakers Site requested representative outfall status for
SDO#1. In the letter a subsequent fax from Mr. Sanjay Patwardham (National Environmental
Technologies), on -site conditions were further defined, demonstrating the stormwater pond was capable of
containing one inch of rainfall for 24 hours. In response (July 26, 1996), DENR granted representative
outfall status for SDO# 1 and then decided to exempt the outfall from the pond because it could contain 1
inch of rain for 24 hours. Based on a recent site visit the pond does discharge because they are no longer
drawing water from it. Therefore, the discharge will be covered under the permit and sampling will be
required.
0 The permit has both stormwater and wastewater (non contact cooling water). There are two outfalls
onsite, but one goes to the retention pond. The only true outfall looks to be the outlet from the retention
Page 1 of 8

NCS000329
pond. The stormwater and wastewater commingle in the pond.
• Permit includes a Section E which is copied from NCG500000 for non -contact cooling water.
Description of Onsite Activities:
• There are two plants on one site. One is an existing titanium mill and the other is a brand new facility.
The new facility is for Nickel based alloys that are from the Monroe Plant.
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, 2008 draft, 2006 final
• '1008 (draft) Yadkin Poe-T►ee Ba-iinwide Plan
History:
• February 9, 1996: Date permit first issued. Analytical data included BOD, Cadmium, COD, Lead, Nickel
and TSS. Includes non -contact cooling water.
• May 29, 1996: Letter from Allvac asking for representative outfall status. A follow up fax from Mr. Sanjay
Patwardhan (National Environmental Technologies), described the outfall pond as capable of containing one
inch of rainfall in a 24 hour period.
• July 26, 1996: NCDENR granted request for SDO#1 to be the representative outfall sampling site. Further,
the May 29, 1996 letter demonstrated that the outfall pond can contain 1 inch of rainfall for 24 hours
NCDENR exempted the outfall pond and SDO41 from sampling.
• August 24, 2000: Renewal package sent to permittee.
• August 15, 2003: Date permit re -issued. The permit included effluent limits and monitoring for non -contact
cooling water. Flow, Temperature, Total Residual Chlorine, oil and grease, and pH. No qualitative
monitoring for stormwater was included.
• January 24, 2007: Renewal package sent to permittee.
• May 6, 2009: Renewal package resent to permittee.
• July 9, 2009: Date permittee submitted renewal application.
Page 2 of 8

NCS000329
Figure 1: Map of Facility
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NCS{}00329
ATI Allvac
ATI Allvac - Bakers Site
Kati rude: ° 1' 14" N
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Receiving Stream: Dry Fork
Stream Mass: C
Facility Location
AW Scale 1.24,000
Sub -basin: 03-07-14 (Yadkin River Basin)
Page 3 of 8

NCS000329
Central Office Review Summary:
1. Owner's Other Permits:
• NC0004642Inactive
• NCG500288 Non -contact Cooling, Boiler Blowdown, Inactive
2. General Observations: New facility for Nickel based alloys.
3. Impairment: Dry Fork is not on the 2006 303(d) list. The Yadkin Basinwide Plan does not mention Dry Fork.
4. Threatened and Endangered: Based on the Natural Heritage Virtual Workroom there are no federally endangered
aquatics species within two miles of the site. There was one endangered plant within two miles: Helianthus
schweinitzii (Schweinitz's Sunflower.)
5. Location: C stream
6. Industrial Changes Since Previous Permit: The site has modified material storage onsite. Nickel ingots from the
Monroe Plant are stored uncovered at the southeast corner of the PQ Building on the Bakers SAF Facility. A re-
fueling station is also currently under construction and is expected to he in use in the near fixture
7. Analytical Monitoring Notes: There was no analytical monitoring required in the last permit because NCDENR
exempted the site from monitoring based on rare or no discharge.
Central files included sampling data which was conducted as part of the facility's NPDES wastewater permit
renewal. See Table 1.
The SIC code 3356 is covered in the EPA General Multi -Sector Permit under Sector F. Primary Metals.
Subsector F. Rolling, Drawing, and Extruding of Nonferrous Metals recommends monitoring for Total Copper
and Total Zinc.
BOD, COD, Cadmium, Nickel, TSS, Copper, Zinc and Chromium have been added to the permit based on these
parameters being potential pollutants because of onsite materials and exposure.
Required monitoring in Draft Permit:
• SW only Discharge: Conventional pollutants, BOD, COD, pH and TSS, plus the five metals listed
above. Benchmarks and tiers.
• For Wastewater only: From NCG50, limits on pH, Temperature, and maybe TRC and Oil&Grease.
• Commingled SW and WW: SW parameters with benchmarks and tiers. Limits on WW. pH subject to
both limits and benchmarks.
8. Qualitative Monitoring Notes: Eight visual monitoring reports were included with the renewal.
Visual monitoring reports show there is cooling pond overflow. Some of the discharges are brown in color.
Page 4 of 8

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NCS000329
Revised Permit Recommendations: Analytical Monitoring:
1. BOD, COD, Cadmium, Lead, Nickel, TSS, Copper, Zinc, Chromium and pH have been added to the
analytical monitoring requirements based on these parameters being potential pollutants. Monitoring
includes two tables based on whether stormwater is commingled or stormwater only.
2. 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.
3. 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 iequiie a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific paiarneter 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.
4. 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.
5. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables 1, 4,
and 5.
6. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
7. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring. TPH is included instead of Oil and Grease.
8. Section E has been updated to be consistent with NCG50 Non- contact cooling water Permit.
9. Boiler Plate includes a few parts from the General Wastewater Permit NCG50. Definition: Concentration
Measurements. Operation and Maintenance: Removed Substances and Power Failures. Reporting Requirements:
Noncompliance Notification Procedure. Other Requirements: Construction.
Other Proposed Changes to the Previous Permit:
1. 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 TMDL 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
spills that have occurred in the past three years and also must certify that the outfalls have been inspected 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. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part 11 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 § 122.26(g), the facility may qualify
Page 6 of 8

NCS000329
for a No Exposure Exclusion from NPDES stormwater discharge pen -nit requirements. Additional information
is provided in Part I Section A.
Discussions with permittee: Kenneth Reynolds, 704-289-4511 ext. 3823, 9/15/09
1. General description of onsite industrial activities? There are two plants on one site. One is an existing titanium
mill and the other is a brand new facility. The new facility is for Nickel based alloys that are. from the Monroe
Plant. They use a 10, 000 ton press and then shape, grind, cut for sampling and peel the metal to get it ready to
sell. Currently the new facility is not up to full production yet.
2. What products/materials are stored outside? There is staged ingot nickel and titanium stored outside at times to cool.
3. Does the stormwater pond ever discharge? Yes
4. What is the process cooling water from? Does it have biocides? Is the cooling water chlorinated? Do you have grab
sample data (2-3 years)? What is the Plow? The discharge is fr-o7u cooling towers that are filled by the pond or city
water. Since the cooling water evaporates the percent dissolved solids increases. Once the dissolved solids reach a
certain level the water is discharged. The water is treated with a bromine biocide, Chemicals are added to control
corrosion. About 50 gallons per day per tower are added to the pond. There is continuous monitoring for
conductivity and dissolved solids. No data was collected because they thought they were exempt.
Flow is at 20 gallons per min. Chemicals used are SELtect 460 and SELcide 740T.
Talked with Ken and Mark on I I -10-09 for more information. 6 Cooling Towers and furnaces (VARs — Vacuum Arc
Remelt and PAM— Plasma Arc Melt).. All noncontact. Three of the towers make up water from the pond and three
get the water from the city. 120, 000 gallons is taken out of the pond or from city water and approximately 29, 000
gallons is added to the pond each day.
5. Do you have vehicle maintenance? No. They will add awash down area but the area will be enclosed and the water
will be removed by a contracted company.
6. What is your SIC code? 3356
Page 7 of 8

NCS000329
Recommendations: Based on the documents reviewed, the application information submitted on July 9, 2009
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) --� Date
t
Stormwater Permitting Unit Supervisor Date 11 19
for dley B nnett
Concurrence by Regional Office y"j� Date
RO Water Quality Supervisor Date
Regional Office Staff Comments (attach additional pages as necessary)
n
7/' '�9 r .5 <t � , �'t 1 r c , i�'rl , ! (�ti'o4�i ✓l7716
Page 8 of 8

Bou-ghazale, Samar
From: Samar Bou-Ghazale [Samar. Bou-Ghazale@ncmail. net]
Sent: Tuesday, March 31, 2009 11:52 AM
To: Bethany Georgoulias
Cc: Bradley Bennett; [e-mail]
Subject: Re: NCS000329 - Teledyne
Bethany,
As always, Thank You for your quick reply/action.
I originally asked the Company to apply for NCG500000 for cooling tower discharge etc.., But
when Brian sent me a copy of the stormwater permit and find out that the wastewater is
included in their SW permit, than I asked them not to apply for the NCG500000 until we figure
this out. However, I did not ask them not to renew the permit because I didn't know if they
apply to renew the permit or not.
Thanks
Samar
Bethany Georgoulias wrote:
> Bradley,
> Samar just called about this site in Monroe, NC. It is unusual
> because they have WW discharges from non -contact cooling/boiler
> blowdown covered in an individual SW permit. Apparently it all goes
> to a pond (i.e., commingled to all become WW), so only WW
> monitoring/limits (pH, Temp) apply. [TRC and 0&G are conditional and
> don't apply at this site.] Not sure how it got in our permit, but it
> all got wrapped under NCS000329. Samar recently visited and noted
> several problems:
> -company hasn't been monitoring for anything b/c they claimed pond
> didn't discharge (not the case now, though, because they're.no longer
> drawing water out of it) -several illicit discharges (problems in and
> of themselves) -permit expired in August 2008 and they never applied
> for renewal (can you confirm?)
> This one ought to be on our backlog, but if they never applied for a
renewal 180 days before, technically they do not have a permit for any
> of those discharges. Originally Samar told them to hold off doing
> anything; because he wasn't sure if we'd keep this wastewater, in our
> stormwater permit or do something else. However, I advised him to
> tell the company they need to apply for a renewal (regardless of
> whether we decide this combo -arrangement needs to be changed) because
> they are out of compliance as long as they do nothing. Do you agree?
> Questions:
> -Are we going to keep this one as an individual stormwater permit with
> wastewater in it, when the pond discharge is technically all
> wastewater anyway? -If we keep it in our shop, should we have them
> monitor for parameters we use as SW quality indicators as well? Or at
> least specify qualitative monitoring there during discharge from rain?
> It seems this kind of discharge falls through the cracks because it
> defaults to WW, and there are no 'SDOs' to visually inspect, etc. It
> should almost be a combined type of monitoring strategy (hmmm,
> something to think about for NCG02 & 14).
1

> Thanks,
> Bg
Samar Bou-Ghazale - Samar.Bou-Ghazalepncmail.net Environmental Engineer II North Carolina
Dept. of Environment & Natural Resources Div. of Water Quality 610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
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.
2

Bou-ghazale, Samar
From:
Sent:
To:
Cc:
Subject:
Bethany,
I will follow
application,
Thanks
Samar
Samar Bou-Ghazale [[e-mail]]
Tuesday, April 07, 2009 4:53 PM
Bethany Georgoulias
Bradley Bennett; [e-mail]
Re: NCS000329 - Teledyne
up with the permit renewal for this facility. When you receive the permit
please send it to me for a Staff Report/Comments.
Bethany Georgoulias wrote:
> Samar,
> We discussed this situation briefly in our staff meeting today.
> Because the permit is combined as it is right now, and because there
> are no other SDOs at the site, we're not sure we'd structure it any
> differently at renewal. The company should be advised to apply for
> renewal (like they should have done in the first place 6 mos. before
> expiration). It may be that the person here who works on this one
> when it comes in will draft a renewal permit with stormwater
> characteristics monitoring at the discharge in addition to meeting
> applicable effluent limits (I guess that's an option). In the past
> we've generally treated other SDOs on site like an SDO and WW outfalls
> like wastewater (no color, odor, etc. or benchmark -related
> monitoring), but this might be a situation where the one outfall
> should be observed just the same. Anyway, looks like this permit will
> continue to be with us with both these discharges for now.
> -Bg
> Samar Bou-Ghazale wrote:
>> Bethany,
>> As always, Thank You for your quick reply/action. I originally asked
the Company to apply for NCG506+00CI for cooling tower discharge etc ..,
>> But when Brian sent me a copy of the stormwater permit and find out
>> that the wastewater is included in their SW permit, than I asked them
>> not to apply for the NCG500000 until we figure this out.
>> However, I did not ask them not to renew the permit because I didn't
>> know if they apply to renew the permit or not.
>> Thanks
>> Samar
>> Bethany Georgoulias wrote:
>>> Bradley,
>>> Samar just called about this site in Monroe, NC. It is unusual
>>> because they have WW discharges from non -contact cooling/boiler
>>> blowdown covered in an individual SW permit. Apparently it all goes
>>> to a pond (i.e., commingled to all become WW), so only WW
>>> monitoring/limits (pH, Temp) apply. [TRC and 0&G are conditional

>>> and don't apply at this site.] Not sure how it got in our permit,
>>> but it all got wrapped under NCS000329. Samar recently visited and
>>> noted several problems:
>>> -company hasn't been monitoring for anything b/c they claimed pond
>>> didn't discharge (not the case now, though, because they're no
>>> longer drawing water out of it) -several illicit discharges
>>> (problems in and of themselves) -permit expired in August 2008 and
>>> they never applied for renewal (can you confirm?)
>>> This one ought to be on our backlog, but if they never applied for a
>>> renewal 180 days before, technically they do not have a permit for
>>> any of those discharges. Originally Samar told them to hold off
>>> doing anything because he wasn't sure if we'd keep this wastewater
>>> in our stormwater permit or do something else. However, I advised
>>> him to tell the company they need to apply for a renewal (regardless
>>> of whether we decide this combo -arrangement needs to be changed)
>>> because they are out of compliance as long as they do nothing. Do
>>> you agree?
>>> Questions:
>>> -Are we going to keep this one as an individual stormwater permit
>>> with wastewater in it, when the pond discharge is technically all
>>> wastewater anyway? -If we keep it in our shop, should we have them
>>> monitor for parameters we use as SW quality indicators as well? Or
>>> at least specify qualitative monitoring there during discharge from
>>> rain? It seems this kind of discharge falls through the cracks
>>> because it defaults to WW, and there are no 'SDOs' to visually
>>> inspect, etc. It should almost be a combined type of monitoring
>>> strategy (hmmm, something to think about for NCG02 & 14).
>>> Thanks,
>>> Bg
Samar Bou-Ghazale - Samar.Bou-Ghazale(@ncmail.net Environmental Engineer II North Carolina
Dept. of Environment & Natural Resources Div. of Wator Quality 610 F, Canter Ave,, Suite "301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
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.
2