OSLATE WATER CONTROL BOARD

Richard N. BurtonExecutive Director

Poet Office Box 11143mond, Virginia 23230-

(804) 527-5000TDD (804) 527-4261

Rlchmon lr|nla523230-li43 September 20, 1991

Mr. Paul SpauldingARARS CoordinatorDepartment of Waste Managementllth Floor Monroe Building101 N. 14th streetRichmond, Virginia 23219

T

RE: Arrowhead Electroplating Superfund Site, and GreenwoodChemical Superfund Site

Dear Mr. Spaulding:

This letter is in response to the EPA/DWM conference call ofAugust 27,1991, regarding the subject facilities.Please find attached the revised effluent limitations and theToxic Monitoring Program as discussed. The Greenwood effluentlimitations are based upon the Virginia Water Quality Criteria(proposed and adopted) reflecting the site hardness data of 43mg/1 supplied by DWM, and the staff's best professionaljudgement in accordance with the memorandum entitled "VPDESPermitting Strategy for Discharges Resulting From UstRemediation Projects and Similar Projects", a copy is enclosed,

The Arrowhead effluent limitations have been revised to allowfor instream mixing (dilution) of the pollutants. The effluentlimitations were determined by mass balance calculationsreflecting the instream effluent concentration of 22.4% and arebased upon the staff's best professional judgement in accordancewith the memorandum entitled "VPDES Permitting strategy forDischarges Resulting From Ust Remediation Projects and SimilarProjects", The parameter tetrachloroethene effluent limitationhas been changed from "NL" to 40.0 ug/1 in accordance with theEPA Freshwater Criteria for tetrachloroethylene.

4900 Cox Road, Innsbrook Corporal?

Page 2

The Arrowhead effluent discharge shall be monitored once permonth by 24 hour composite sample for all parameters except phwhich shall be monitored once per month by grab sample.If we can be of further assistance, please do not hesitate tocontact me at 804/527-5083.

Sincerely

urton R. Tu*£ord, IIEnvironmental Engineer ConsultantOffice of Water Resources Management

Enclosure

CCt OWRM - (3. CosbyOWRM - K. RollerTRO - D. MoscaVRO - B. Kregloe

fla x xa

<n to vo co to g00 H U> CO n H m S

Arrowhead Electroplating Superfund Site

Below are the effluent limitations base on a hardness of 43for the following parameters:

1. Dissolved Hexavalent Chromium 49.1 ug/1

2. Total Recoverable Copper 25.7 ug/1

3. Total Recoverable Nickel 344,7 ug/1

4. Total Cyanide 23.2 ug/1

5. Total Recoverable Cadmium 32.6 ug/1

6. Total Recoverable Lead 4.9 ug/17. Total Zinc 231.5 ug/1

AB302250

ct a M T s - z -xoo

MEMORANDUMState Water Control Board

2" 1 No-lH-B~>:rc.i Street p ° Sex 11143 Richmond. VA 2322'

SUBJECT: VPDES Permitting Strategy for Discharges Resulting From USTRemediation Projects and Similar Projects

TO: Regional Directors

FROM: Larry G. Lawson -

DATE: September 8, 1989COPIES: William Woodfin, John Roland, Regional Water Resources

Managers, Martin Ferguson, Fred Holt, Richard Ayers, FredCunningham, OWRM Permits and Groundwater Staff

INTRODUCTION

The Agency is becoming increasingly involved with the clean-upof releases from gasoline, diesel fuel, heating oil and Kerosene(petroleum) underground storage tanks. The purpose of this memo isto provide guidance to the regional offices on how to address thepoint source discharges associated with remediation of these sitesvia a VPDES permit.

VPDES Permits

In developing a VPDES permit for these activities, the RORegulatory Services (RS) staff and the Technical Services (TS) staffmust coordinate their efforts in order to develop a permit which willaddress both the proposed discharge and the site remediationefforts. Draft procedures for Ground Water Corrective Action Plans,(CAP), are contained in a memorandum dated February 10, 1989, fromFred Cunningham to the Water Resource Managers. This, memo addressesthe coordination of CAP and VPDES permitting efforts.

Cleanup technology for remediation of these sites include (1)recovery of free product and incidental ground water which may bepresent from the recovery process, (2) separation of free product andwater, (3) removal or treatment of ..contaminated soil, (4) treatmentof the contaminated water to remove dissolved toxic organic compoundsand, (5) discharge of the treated water to surface water, orreinjection/soil flushing of treated water. (Reinjection/soilflushing will be addressed by OWRM on a case by case basis through aVPA/Corrective Action Plan permit).

In our experience so far, the principle pollutants of concernfrom a surface water discharge point of view appear to be Benzene,Toluene, Ethylbenzene, Xylene, (collectively referred to as BTEX),lead, and Total Petroleum Hydrocarbons, (TPH).

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Since most groundwater clean up systems for petroleum USTs willutilize acceptable existing available technology (e.g. preliminarytreatment for product removal, and air stripping and/or granularactivated carbon treatment) to remove dissolved organic compounds forprevention of potential aquatic toxicity, OWRM does not believe a TMPis necessary. We are instead recommending that permit limits beestablished which assure protection of aquatic life and that a onetime Total Toxic Organics (TTO), analysis be conducted as a screenfor the presence of other toxics, Specific individual limitationsfor BTEX and lead should be established either on 1) the basis of theperformance data obtained in treatability studies or otherinformation that is provided in the CAP or permit application,(technology limits), or on 2) Water Quality. If a mass balanceindicates that the technology limits result in the followingin--stream values being exceeded, then water quality based limitswhich ensure the following values are being met in-stream, should beincorporated into the permit.

In-Stream Value

Parameter Freshwater (mg/1) Saltwater

Benzene .053 .007Toluene .175 .05Ethylbenzene .32 ,0043Xylene .038 ,013Lead WQ criteria WQ criteria

The above values for Benzene, Toluene, and Ethylbenzene arebased on EPA aquatic life toxicity levels which have been divided by100 in order to place them in the context of a workable criteria-typevalue. The values for xylene were recently established by the OWRMtoxics group after evaluating bioassay results found in EPA'sIntegrated Risk Information System (IRIS) data base.

In the future, additional parameters may be identified which mayneed to be addressed. If additional parameters are discovered orpresented, please contact OWRM for guidance.

An example of discharge limits and special conditions are foundin Attachment A.

SUMMARY FOR ADDRESSING POINT SOURCE DISCHARGES

The permit limits should reflect either technology limits asproposed by the pilot studies, or water quality based values,whichever are more stringent. These limits are to be determined by amass balance calculation and should be placed in the permit as adaily maximum.

AR302252

The following table presents the limits and parameters to be usedin writing the discharge portion of these types of VPDES permits:

Parameter Permit Limit (Daily Max)

Flow NLBenzene (technology or water quality limiting)Toluene (technology or water quality limiting)Ethylbenzene (technology or water quality limiting)Xylene (technology or water quality limiting)Lead, Total Recoverable (water quality based using State criteria)Total Toxics Organics(TTO) (one time analysis with identification and

quantification of individual compounds) ,Total PetroleumHydrocarbons 10 ag/1 (or other technology limit

proposed)

OWRM believes that the above approach will adequately maintain thequality of receiving streams for the referenced discharges. Shouldowners seek to justify higher limitations, the proposal should beevaluated for a TMP.

Once the discharge portion of the VPDES permit is developed, the ROTS staff and the permit writer shall address the groundwater remediationportion of the project and incorporate these goals into the VPDES permitalso. Generally most CAPs will propose groundwater monitoring. Thisrequirement for groundwater monitoring should be incorporated in theVPDES permit. An example of a permits page for remediation wellmonitoring can be found in the February 10, 1989 memo.

After adoption of the UST technical regulation, further guidanceregarding remediation of UST sites will be forthcoming. Until this memois released, the Regional Technical Services division should provide theRegulatory Services permit writer with the information needed for thissection of the VPDES permit.

A8302253

M E M O R A N D U MOffice of Water Resources Management

State Water Control Board

P. 0. Box 11143 Richmond, Virginia 23230

SUBJECT: Toxics Management Program for Arrowhead ElectroplatingSuperfund site.

TO; Burton Tuxford

FROM: Ken Roller, OWRM-TMP

DATE: 9/20/91

COPIES: TMP file

The Arrowhead Electroplating Superfund site is located inMontross, Virginia on the grounds of what is now A.R. Winarick,Inc. The groundwater under this facility is contaminated withmetals and volatile organics compounds. As part of the longterm remedial activities at this site, the groundwater will becollected, treated and subsequently discharged to Scates Branch;Potomac River Basin; Section la, The specific treatmenttechnology to be used was not specified. According to the June14, 1991 letter from Paul spalding, DWM, the treated groundwaterwill be discharged at an approximate flow rate of 30 gallons perminute (0.0432 MGD), Assuming a 7Q10 of 0.15 MGD (as previouslyestablished by Keith Fowler and approved by Richard Ayers), theinstream effluent concentration during critical flow periodswould be predicted to approximate 22.4%.

In a May 27, 1987 memo to V.A, Carpano, Richard Ayerscalculated permit limits for a proposed discharge from theArrowhead Electroplating metal treatment ponds. The proposeddischarge was to result from pond dewatering which was predictedto take around 1 month (2 million gallons at a" maximum flow rateof 0.15 MGD). Richard used a hardness value of 35 mg/1 forScates Branch, the maximum dewatering flow rate of 0.15 MGD, andthe 7Q10 of the receiving stream (0.15 MGD) to calculate metalslimits for this discharge.

Apparently, the Department of Waste Management isconsidering applying the effluent limits derived by RichardAyers to the discharge resulting from the groundwaterremediation project. This would be inappropriate as the flowsof the two discharges (the pond dewatering and treatedgroundwater are substantially different). Therefore, I wouldrecommend the. inclusion of the following effluent limitations inlieu of those proposed by Richard in 1987:

Dissolved Hexavalent Chromium 49.1 ug/1Total Recoverable Copper 21,5 ug/1Total Recoverable Nickel 192,0 ug/1Total Cyanide - '-23.2 ug/1Total Recoverable cadmium 2,2 ug/1Total Recoverable Lead 3,8 ug/1

Also proposed are effluent limitations for a number ofvolatile organic pollutants. These limits were derived fromeither the proposed Water Quality Standards or, in the case ofBTEX, from Larry Lawson's September 8, 1989 memo concerning thepermitting of UST type discharges. The concentrations proposedfor limits appear to have been taken directly from either theproposed standards or Larry fs memo and do not allow for anywastewater assimilation (dilution) provided by the receivingstream, as is normal OWRM procedure. Therefore, I wouldrecommend that, unless statistical studies have been performedto determine the 30Q5 or harmonic mean of Scates Branch (seeproposed standards VR6SO-21-01.4C.), these limits be derivedusing the instream effluent concentration of 22.4% as determinedabove.

Based on the information provided, I have attached aToxics Management Program for the discharge which includesquarterly acute and chronic toxicity tests for a period of oneyear, followed by annual compliance monitoring, providing theeffluent passes the Toxics Management Regulation screeningcriteria. I have also included a requirement to monitor forbase/neutral and acid extractable organic pollutants using theEPA methods 608 (pesticides and PCBs) and 625 (general GC/MSscreen).

AR3022S5

6. Toxics Management Program

A. Biological monitoring:

(1) In accordance with the schedule in D. below andcommencing within six months following the initialdischarge of treated groundwater, the permittee shallconduct quarterly acute and chronic toxicity tests for aperiod of one year using 24-hour composite samples offinal effluent from outfall __, The acute tests shallbe 48-hour static tests using Ceriodaphnia andPimephales promelas. both conducted in such a manner andat sufficient dilutions for calculation of a validLC50, The chronic tests shall be static renewal testsusing Ceriodaphnia and Pimephales promelas. TheCeriodaphnia test shall be a 7-day reproduction test andthe Pimephales test shall be a 7-day larval growthtest. These chronic tests shall be conducted in such amanner and at sufficient dilutions to determine the "NoObserved Effect Concentration" (NOEC) for survival andgrowth or reproduction. The permittee may provideadditional samples to address data variability duringthe one year period of initial data generation. Thesedata may be included in the evaluation of effluenttoxicity. The results of all such additional analysesshall be reported. Technical assistance in developingthe procedures for these tests shall be provided by theState Water Control Board staff, if requested by thepermittee. Test protocols and the use of alternativespecies shall be approved by the State Water ControlBoard staff prior to initiation of testing.

(2) If the LC50 is greater than or equal to 100% effluent in6 or more of the total of 8 acute toxicity tests, or inat least 75% of the tests conducted if more than 8 testsare conducted, and if the NOEC is greater than or equalto the instream waste concentration (IWC) of 22.4%effluent in 6 or more of the total of 8 chronic toxicitytests, or in at least 75% of the tests conducted if morethan 8 tests are conducted, the permittee shall continueacute and chronic toxicity testing of the effluent fromoutfall 001 annually. The first annual tests shall beconducted within three months of the last quarterlytests. The test organisms shall be those identified asthe most sensitive species from the quarterly acute andchronic tests or alternative species approved by theState Water Control Board staff,

(3) If the LC50 is less than 100% effluent in 3 or more outof the total of 8 acute toxicity tests, or in more than25% of the tests conducted if more than 8 tests areconducted, or if the NOEC is less than the IWC of 22.4%effluent in 3 or more out of the total of 8 chronictoxicity tests, or in more than 25% of the testsconducted if more than 8 .tests are conducted, a toxicityreduction evaluation will be required.

(4) If, in the testing according to (2) above, any of theannual acute toxicity tests yields an LC50 of less than100% effluent or any annual chronic toxicity test yieldsan NOEC of less than the IWC of 22.4% effluent, the testshall be repeated within 3 months, if the retest alsoindicates an LC50 of less than 100% effluent or an NOECof less than the IWC, quarterly toxicity testing as in(1) above shall commence within three months. Theresults of these tests will be included in theevaluation of the need for toxicity reduction. If theretest does not confirm the results of the first test,then annual testing in accordance with the originalannual compliance schedule shall resume,

B. Chemical monitoring:

(1) In accordance with the schedule in D. below andcommencing within six months following the initialdischarge of treated groundwater, and continuingquarterly for a period of one year, the permittee shallcollect 24-hour composite samples of the effluent fromoutfall __. These samples shall be analyzed in thefollowing manner:(a) Priority pollutant and non-priority pollutant

extractable organics using EPA's gaschromatography-mass spectrometry method 625, orother equivalent EPA approved methods. Thepermittee shall:

(i) report all priority pollutant organicspresent at the method detection limitsestablished in method 625, and

(ii) tentatively identify and report a maximum of20 substances which are detected but are notlisted as priority pollutants including allof the non-priority substances of greatestapparent concentration for the combinedbase/neutral and acid extractable fractions,to a maximum of 20.

(b) Organochlorine pesticides and PCBs using the EPAmethod 60S. The permittee shall determine andreport the concentrations of all compounds listedin this method at the detection limits specifiedin method 608.

(2) The above chemical analyses shall be conducted using EPAapproved methods. The permittee shall obtain approvalfrom the State Water Control Board staff before usingnon-EPA approved test methods and/or detection andreporting limits other than those required in thisspecial condition.

SR302257

(3) The above chemical analyses shall be conducted inconjunction with the biological monitoring required inA.(1) whenever possible. When the results oftesting indicate the necessity of resuming quarterlytoxicity testing, the quarterly chemical analysesdescribed in B,(1) shall also resume. The permittee mayprovide additional samples to address data variabilityduring the one year period of initial data generation.These data may be included in the evaluation of effluenttoxicity. The results of all such additional analysesshall be reported.

C, Toxicity Reduction Evaluation:

If the results of this Toxics Management Program or otheravailable information indicate that the wastewaters areactually or potentially toxic, the permittee shall submit: (1)a toxicity reduction evaluation plan, or (2) at thepermittee's option, an instream impact study plan, and (3) anaccompanying implementation schedule within 120 days of thenotification of such a determination by the State WaterControl Board. The requirement of this plan, pursuant to theVirginia Toxics Management Regulation (VR 680-14-03), shall beto (1) assure the absence of actual or potential toxicity, orto (2) demonstrate that there is, or would be, no adverseimpact from the discharge on all reasonable and beneficialuses of the state's waters. Upon completion of the review ofthe plan, the permit may be modified or alternatively revokedand reissued in order to reflect appropriate permit conditionsand a compliance schedule.

D, Testing and Reporting Schedule:

The permittee shall conduct and report the results of thetoxicity tests and chemical analyses specified in this ToxicsManagement Program in accordance with the following schedule:

(1) Submit toxicity test Within two months following theprotocols for initial discharge of treatedapproval groundwater

(2) Conduct first Within six months following thequarterly biological initial discharge of treatedand chemical tests groundwater

(3) submit results of with the Discharge MonitoringD.(2) Report (DMR) for the seventh

month following the initialdischarge of treated groundwater

(4) Conduct second Within nine months following thequarterly biological initial discharge of treatedand chemical tests groundwater

A.R302258

(5) Submit results of With the DMR submitted for theD, (4) tenth month following the

initial discharge of treatedgroundwater

(6) Conduct third Within twelve months followingquarterly biological the initial discharge of treatedand chemical tests groundwater

(7) Submit results of With the DMR submitted for theD. (6) thirteenth month following the

initial discharge of treatedgroundwater

(8) Conduct fourth Within fifteen months followingquarterly biological the initial discharge of treatedand chemical tests groundwater

(9) Submit results of With the DMR submitted for theD. (8) sixteenth month following the

permit effective date

(10) Conduct first annual Within eighteen months followingbiological tests the initial discharge of treated

groundwater(11) Submit results of With the DMR submitted for the

first annual nineteenth month following thebiological tests initial discharge of treated

groundwater(12) Conduct subsequent Within subsequent 12 month

annual biological periods from D.(10)tests

(13) Submit results of With the DMR submitted every 12subsequent annual months from D.(11)biological tests

ft;R3Q2259

• COMMONWEALTH of VIRQINIASTATE WATER CONTROL BOARD

Rlehird N, Burton 4900 COX ROAD BOARD MCMIER3Ex«cut)v» Director

William T. ClementsPott Office Box 1TJ43 H«nry 0, Hollimon. Jr

Richmona. V'fgmia J323&-H43 Acntld M Plotlcirt(804) 527-5000 HQ TELEFAX 11 ftfl4-«»?-V v*imiM.SmitnTDD !80*) J67-97$3 y'-' Tv/. e 5 7 e ~7~b X. p»Irtcl< Stanainj

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TELECOPY TRANSMITTAL

DATE: _____ ?/2 */?/ ________ TIMB; X'

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OPFICS:

TO; NAME:__ ^ /

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TELECOPIER NO:_____X^ S~ - ____

NUMBER OF PAGES (INCLUDING TRANSMITTAL SHEET).

REMARKS: x vflE/fgy (~0ss><-/ V** ^ o«J / xt SftsP-s/

SENDER USE ONLY:

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RETURN TRANSMITTAL TO SENDER: YES_____ NO_____

TRANSMITTED BY ____|____________(INITIAL)

H-.R302260