NC0004375_Permit (Modification)_19920127

NPDES DOCIMENT SCANNING: COVER SHEET
NPDES Permit:
NC0004375
Clariant Corporation
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Additional Information Received
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
January 27, 1992
This document is printed on reuse paper - ignore any
content on the resrerse side

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D.
William W. Cobcy, Jr., Secretary Director
January 27, 1992
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. W. M. Archer
Sandoz Chemicals Corporation
PO Box 669246
Charlotte, NC 28266
Subject: NPDES Permit No. NC0004375
Sandoz Chemicals Corporation
Mecklenburg County
Dear Mr. Archer:
In accordance with your Petition for Contested Case Hearing filed on August 7, 1991, we
are forwarding herewith a modification to the subject permit. This modification is to delete the
mercury limit in the permit and to replace it with a monthly monitoring requirement. Attached
are revised effluent pages for outfall 001 only. These sheets should be placed in the permit and
the current outfall 001 sheets discarded.
All other terms and conditions contained in the original permit remain unchanged and in
full effect. These modifications are 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 December 6, 1983.
If any terms or conditions adjudicated that were resolved by this modification are
unacceptable to you, you should notify us within thirty (30) days following receipt of this letter.
Unless such demand is made, this decision shall be final and binding. If this permit modification
is acceptable, Sandoz Chemicals Corporation must complete the attached Notice of Withdrawal of
Petition form within 30 days of receipt of this modification and submit one copy to the Attorney
General's Office as specified on the withdrawal form and one copy to this division.
Pollution Prevention Pays
P.U. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Archer
Page Two
If you have any questions concerning this permit, please contact Mr. Dale Overcash at
telephone number 919/733-5083.
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
Mecklenburg County Department of Environmental Protection
Permits and Engineering Unit
Compliance
Central Files
George T. Everett
/62.,e)

STATE OF NORTH CAROLINA
COUNTY OF
Petitioner,
v.
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
FILE NO.
NOTICE OF WITHDRAWAL
OF PETITION
Petitioner hereby withdraws its petition for a contested case hearing.
No further proceedings are needed or required to resolve the contested case
captioned above.
This the day of , 19 .
Petitioner/Authority for Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the attached NOTICE OF
WITHDRAWAL on by having same placed in the United States Mail bearing
sufficient postage for delivery by first class mail and addressed as
follows:
Attorney General's Office
Environmental Protection Section
PO Box 629
Raleigh, NC 27602-0629
(Date) Petitioner/Attorney for Petitioner

A
A. ( ). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be.limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Lbs/day. Units (specify) Measurement Sample *Sample
Mon. Avg. Daily Max Mon. Avg. Daily Max. Frequency Type Location
Flow 3.9 MGD Continuous Recorder t or E
BOD, 5 Day, 20 °C 852.0 2236.0 Daily** Composite E,U,D
Total Suspended Residue 976.0 2928.0 Daily— * Composite E
NH3 as N 651.0 977.0 Daily** Composite E,U,D
Dissolved Oxygen Daily** Grab E,U,D
Fecal Coliform Monthly Grab E
Total Phosphorus Monthly Composite E
Total Nitrogen (NO2+NO3+TKN) Monthly Composite E
OCO Monthly Composite E
MBAS Monthly Composite E
Manganese Monthly Composite E
* Sample locations: E - Effluent, I - Influent, U - Upstream at NC Highway 27, D - Downstream at 1-85
Upstream and downstream samples for BOD5, NH3 as N, dissolved oxygen, temperature, conductivity, and pH shall be collected three times
per week during June, July, August, and September and once per week during the remaining months of the year.
'_" Daily is defined as every day except Saturday, Sunday, and legal holidays.
*`* Chronic Toxicity (Ceriodaphnia) P/F at 1.8%; March, June, September, and December; See Part III, Condition D.
* * * * See Part III, Condition E.
***** Staging Requirements (Applicable April 1 - October 31) - See Part III, Condition F.
+ Weekly average limit
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored daily at the effluent, upstream, and
downstream by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. (Continued)
Effluent Characteristics
Iron
Chlorides
Sulfate
Mercury
Conductivity
Temperature
Total Phenols
Chronic Toxicity***
Pollutant Analysis****
4-chloro-3-methylphenol
2-methylphenol
4,6-dimethylphenol
Pentachlorophenol
2,4, 5-trich lorophenol
Lbs/day.
Discharge Limitations
Other Units (specify)
Mon. Avg. Daily Max Mon. Avg. Daily Max.
1.8
3.6
Monitoring
Measurement
Frequency
Monthly
Monthly
Weekly
Monthly
Daily**
Weekly
Quarterly
Annually
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Requirements
Sample *Sample
Type, Location
Composite 'E
Composite E
Composite E
Composite E
Grab U,D
Grab E, U, D
Grab E
Composite E
E
Grab E
Grab E
Grab E
Grab E
Grab E

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL NC0004375
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall serial number 001. (Continued) Such discharges
shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
Acenaphthene** 0.39 0.50 Quarterly Grab E
Acrylonitrile 1.69 4.30 Quarterly Grab E
Benzene 0.75 2.70 Quarterly Grab E
Carbon Tetrachloride 0.32 0.67 Quarterly Grab E
Chlorobenzene 0.31 0.57 Quarterly Grab E
1,2,4-Trichlorobenzene 1.20 2.46 Quarterly Grab E
Hexachlorobenzene 0.26 0.49 Quarterly Grab E
1,2-Dichloroethane 1.20 3.71 Quarterly Grab E
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab E
Hexachloroethane 0.39 0.95 Quarterly Grab E
1,1-Dichloroethane 0.39 1.04 Quarterly Grab E
1,1,1-Trichloroethane 0.37 0.95 Quarterly Grab E
Chloroethane 1.83 4.72 Quarterly Grab E
Chloroform 0.37 0.81 Quarterly Grab E
2-Chlorophenol 0.62 1.95 Quarterly Grab E
1,2-Dichlorobenzene 1.57 3.32 Quarterly Grab E
1,3-Dichlorobenzene 0.62 0.90 Quarterly Grab E
1,4-Dichlorobenzene 0.31 0.57 Quarterly Grab E
1,1-Dichloroethylene 0.28 0.44 Quarterly Grab E
1,2-trans-Dichloroethylene 0.37 0.95 Quarterly Grab E
2,4-Dichlorophenol 0.77 2.22 Quarterly Grab E
1,2-Dichloropropane 2.69 4.05 Quarterly Grab E
1,3-Dichloropropylene 0.51 0.77 Quarterly Grab E
2,4-Dimethylphenol 0.36 0.71 Quarterly Grab E
2,4-Dinitrotoluene 1.99 5.03 Quarterly Grab E
2,6-Dinitrotoluene 4.40 11.28 Quarterly Grab E
Ethylbenzene 0.65 2.20 Quarterly Grab E
Fluoranthene 0.47 1.20 Quarterly Grab E
Methylene Chloride 0.70 1.57 Quarterly Grab E
Methyl Chloride 1.51 3.34 Quarterly Grab E
Hexachlorobutadiene 0.35 0.86 Quarterly Grab E
Naphthalene** 0.45 0.50 Quarterly Grab E
Nitrobenzene 0.48 1.20 Quarterly Grab E
2-Nitrophenol 1.23 2.08 Quarterly Grab E
4-Nitrophenol 2.17 3.74 Quarterly Grab E
2,4-Dinitrophenol 2.15 3.71 Quarterly Grab E
4,6-Dinitro-o-cresol 1.55 5.50 Quarterly Grab E
Phenol 1.56 2.70 Quarterly Grab E
Bis(2-ethylhexyl)phthalate 1.81 4.91 Quarterly Grab E
Di-n-butyl phthalate 0.48 1.00 Quarterly • Grab E
Diethyl phthalate 1.43 3.57 Quarterly Grab E
Dimethyl phthalate 0.33 0.83 Quarterly Grab E
Benzo(a)anthracene** 0.31 0.50 Quarterly Grab E
Benzo(a)pyrene** 0.40 0.50 Quarterly Grab E
(Continued)

Effluent Characteristics
3,4-Benzofluoranthene**
Benzo(k)fluoranthene* *
Chrysene**
Acenaphthylene**
Anthracene**
Fluorene**
Phenanthrene**
Pyrene**
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Total Cyanide
Mon. Avg. Daily Max. Measurement Sample *Sample
lbs/day lbs/day Frequency Type Location
0.40
0.39
0.39
0.39
0.39
0.39
0.39
0.44
0.39
0.53
0.37
1.82
7.39
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.99
1.63
0.95
4.70
9.01
*Sample Location: E-Effluent
**These parameters are water -quality limited.
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Quarterly
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
E
E
E
E
E
E
E
E
E
E
E
E
E

DIVISION OF ENVIRONMENTAL MANAGEMENT
September 26, 1991
MEMORANDUM
TO: Dale Overcash
cy(-/(-
THROUGH: Trevor Clements
FROM: Ruth Swanek 2E.3
SUBJECT: Sandoz Chemical Company
NPDES No. NC0004375
Permit Adjudication
Mecklenburg County
I have reviewed Sandoz' petition filed with the Office of
Administrative Hearings. The mercury limit may be dropped as it
was based on one reading at detection level. However, the facility
must continue to monitor for mercury in its effluent, and the
monitoring should be done using the EPA approved method with the
lowest detection level (currently at 0.2 ug/l).
If you have any questions, please contact me at extension 503.
cc: Rex Gleason

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph. D.
William W. Cobey, Jr., Secretary Director
October 15, 1991
MEMORANDUM
To: Daniel C. Oakley
From: George T. Everett
II: Lit
Subject: Permit Adjudication
Sandoz Chemical Corporation
91 E H R 0746
Permit No. NC0004375
Mecklenburg County
On July 12, 1991, the DEM issued a renewal permit to Sandoz Chemical Corporation.
As result of issuance of the permit, Sandoz adjudicated the permit base on the two following
concerns:
1. There was insufficient time to allow installation of control equipment to meet the
limits for 2,4-Dinitrophenol and 4-Nitrophenol; and
2. The impossition of the limit for mercury.
It is our understanding that the permit was adjudicated for item No. 1 to allow the
equipment to be installed before the permit became effective. Betsy Rouse of your staff has an
understanding of the issue with this item. Therefore, there will he no furthur discussion of this
item.
After a second review of the permit file, the DEM will concur with changing the
mercury limit to monthly monitoring only for the duration of the permit to resolve the conflict.
Due to the fact that mercury has been detected in the permit over the past five years, the DEM
feels that monitoring for duration of the permit is a fair resolution of the adjudication. Monthly
monitoring is not a burden for a company the size of Sandoz. The DEM will wait for furthur
guidance from you before preparing a final permit.
Ale powt 5,C. /Z/Zo�(J
n Mr Dale Overcash at (919)7�-5083.
If you have any questions, please contact N'
cc: Ms. Brenda Smith
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626.0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

LAW OFFICES
OGLETREE, DEAKINS, NASH, SMOAK & STEWART
4101 LAKE BOONE TRAIL
POST OFFICE BOX 31608
RALEIGH, NORTH CAROLINA 27622
TELEPHONE [phone]
FAX [phone]
DAMES M. KUSZAJ, PH.D.
PARTNER
October 2, 1991
Elizabeth E. Rouse, Esquire
Associate Attorney General
Department of Justice
Post Office Box 629
Raleigh, North Carolina 27602-0629
OTHER OFFICES:
GREENVILLE. SOUTH CAROLINA
WAS HINGTON. D. C.
ATLANTA. GEORGIA
COLUMBIA, SOUTH CAROLINA
NASHVILLE. TENNESSEE
ALBANY, NEW YORK
NORTH CAROLINA
ATTORNEY GENERAL'S OFFICE
OCT 03 19q1
ENVIRONMENTAL PROTECTION SECTION
RECEIVED
Re: Sandoz Chemical Corporation
91 EHR 0746
Dear Ms. Rouse:
Now that we have the ALJ's order staying the contested case until Jan dry
15, 1992, I think we can reach agreement on the remaining mercury issue.Irou
suggested that your client might be willing to agree that the mercury'
permit be amended to a monitoring requirement only. This would bccce limitab i to
Sandoz. In addition,we understandp
from previous discussions that the Departnignt
may also be willing to remove the mercury monitoring requirement altogether a no
mercury is detected after one year of monitoring.
If you would confirm your client's willingness to settle the appeal of • e
mercury issue on the basis of converting the present limit to a monitoring only with the possibilityof dropping that requirement after one year of
monitoring, I will include that in the settlement document we intend to file by
January 15, 1992.
JMK/lg
Sincerely,
OGLETREE, DEAKINS, NASH,
SMOAK AND STEWART
IZ tI lid J--13016

Division of Environmental Management
September 27, 1991
MEMO TO: Don Safrit
FROM: Rex Gleason
-op
PREPARED BY: Michael Parker;
SUBJECT: Sandoz Chemicals Corporation
NPDES Permit No. NC0004375
Mecklenburg County
cn
Below please find a listing of the contested permit
conditions as raised by the petitioner (Sandoz) and this Office's
comments and recommendations.
1 Insufficient time is allowed for Sandoz to install
facilities capable of complying with the proposed limits
for 2,4-Dinitrophenol and 4-Nitrophenol:
This Office has no objection to including a compliance
schedule in the subject permit provided a reasonable
time frame is established through negotiations with the
Central and Regional Office. As we have stated
previously, issuance of an SOC appears to be
inappropriate since there is no evidence of
noncompliance with either parameter at the present time.
2. The mercury limit is unnecessary since Sandoz does not
discharge mercury:
A sample collected at Sandoz on 7-24-89 reflected a
mercury concentration of 0.5 mg/l. Which contradicts
Sandoz's claim. This Office supports the Central
Office's decision to leave the mercury limit in the
permit for one year and upon request, delete the
monitoring requirement if data indicates that the
constituent is not present.
If you have any questions, please advise.
MLP

LAW OFFICES
OGLETREE, DEAKINS, NASH, SMOAK & STEWART
4101 LAKE BOONE TRAIL
POST OFFICE BOX 31608
RALEIGH, NORTH CAROLINA 27622
TELEPHONE [phone]
ATTORNEY GENE^AL'S OFFICE FAX [phone]
NORTH CAROLINA
tugi)9 311
JAMES M. KUSZAJ, PH.D.
PA RT N E 'ENVIRONMENTAL PROTECTION SECTION
RECEIVED
August 9,1991
John C. Hunter, Esquire
Registered Agent
Office of General Counsel
Department of Environment, Health & Natural Resources
Archdale Building, Room 1442
512 North Salisbury Street
Post Office Box 27687
Raleigh, North Carolina 27611
Dear Mr. Hunter:
AUG U g;199#1
OTHER OFFICES:
GREENVILLE. SOUTH CAROLINA
WASHINGTON, O. C.
ATLANTA, GEORGIA
COLUMBIA, SOUTH CAROLINA
NASHVILLE, TENNESSEE
ALBANY, NEW YORK
Re: Petition for Contested Case
Enclosed is a copy of a Petition for a Contested Case Hearing.
undersigned represents Petitioner in this matter.
Sincerely,
OGLETREE, DEAKINS, NASH,
SMOAK AND STEWART
f. es M. Kusza'
S. to Bar #14006
4101 Lake Boone Trail, Suite 511
Post Office Box 31608
Raleigh, North Carolina 27622
[phone]
2) .
•
The

STATE OF NORTH CAROLINA
COUNT'U F (1) Mecklenburg
)Sandoz Chemicals Corporation
Petitioner.
(Your Name)
VERSUS
(3)Dept. of Environment, Health &
Natural Respondent. Resources
(The State Agency or Board about which you are
complaining)
IN II li oN l•10E cji:OV
ADMINISTRATIVE4E'lRI1GS
PETITION
FOR .A
CONTESTED CASE HEARING
I hereby ask for a contested case hearing as provided for by G.S. 1SOB-23 because the Dept . of Environment
(4) Health & Natural Resources has (briefly state facts showing how you believe you lave
(name of agency)
been harmed by the state agency or board)
issued Petitioner NPDES Permit No. 000.4375 with permit conditions that are
arbitrary, capricious and not required by law.or regulation. Petitioner's specific
objections to the permit include but are not necessarily limited to the following:
( S E E ATTACHMENT) •
(if more space it needed. use additional sheets and attach)
(5) (Check all that apply)
Because of these facts, the agency has:
X deprived me of property;
ordered me to pay a fine or civil penalty, or
--X—has otherwise substantially prejudiced my rights; and based on these facts the agency has
exceeded its authority or jurisdiction;
X acted erroneously;
failed to use proper procedure.
-acted arbitrarily or capriciously; or
X failed to act as required by law or rule.
VERIFICATION
I, the undersigned. first being duly sworn. say that this petition is true to my own knowledge. except as to matters
stated on information and belief. and as to those, I believe them to be true.
SWORN TO AND SUBSCRIBED BEFORE ME
•
2 —0!/://D
H ,i-cdeezA4-4-01%--
at
(11)
(12)
(13) er signal
Title of person thorized to administer oaths
(14) My Commission Expires: (CV/ 2/93
(15) (Seal)
LiA
B7/q/
Date
Your Signature
Y• i.Ce President Operations
(8)-•
Sandoz Chemicals Corporation
(9) 4000 Monroe Road, Charlotte, NC 28205
Your Address
(10) Area Code Z04) 331-7088
Your Telephone Number
Mail the original and one copy to the Office of Administrative Hearings, P. O. Drawer 27447, Raleigh, N.C.
27611-7447 and mail a copy to the State agency involved.
tk - (revised 02-27-91)
NORTH CAROLINA
ATTORNEY GENE^AL'S OFFICE
n>>rn91991
• H-06
ENVIRONMENTAL PROTECTION SECTION
- RECEIVED . -

Attachment
1) Insufficient time is allowed for Petitioner to install control equipment to meet
the limits for 2,4-Dinitrophenol and 4-Nitrophenol, and
2) The limit for Mercury is unnecessary because Petitioner does not discharge
Mercury.
Pursuant to G.S. 150B-3, the filing of this Petition stays the September 1, 1991 effective
date of NPDES Permit No. NC0004375.

CERTIFICATE OF SERVICE
I certify that this Petition for a Contested Case Hearing has been served on
the parties named below by hand delivering copies thereof to the offices of
.1
Dean C. Farrar
Chief Hearings Clerk
Office of Administrative Hearings
Post Office Drawer 27447
Capehart-Crocker House
424 North Blount Street
Raleigh, North Carolina 27611-7447
John C. Hunter, Esquire
Registered Agent
Office of General Counsel
Department of Environment, Health & Natural Resources
Archdale Building, Room 1442
512 North Salisbury Street
Post Office Box 27687
Raleigh, North Carolina 27611
This the q 111 day of CU- , 1991.
frAQz.d')n. 44.
Jades M. Kuszaj
Attorney for Petitioner
State Bar Number 14006
Ogletree, Deakins, Nash, Smoak & Stewart
4101 Lake Boone Trail, Suite 511
Raleigh, North Carolina 27607
[phone]

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DIVISION OF ENVIRONMENTAL MANAGEMENT
July 23, 1990
MEMO TO: Trevor Clements
FROM: Julia Storm ao
SUBJECT: Rationale for Phenols Water Quality Standard for Water
Supplies
The water quality standard for phenols for surface waters
classified as drinking water supplies may be found in 15A NCAC 2B
.0211(c)(3)(C), .0211(d)(3)(D), and .0211(e)(3)(B) for WS-I,
WS-II, and WS-III classes, respectively. The standard of 1 ug/1
is to protect water supplies from taste and odor problems from
chlorinated phenols. In WS-III waters, specific phenolic
compounds may be given a different limit if it is demonstrated
that taste and odor problems will not arise and that no detriment
to other best usage will occur.
The rationale for the standard may be found in the 1980 EPA
criteria document Ambient Water Quality Criteria for Chlorinated
Phenols and the 1976 document Qaulity Criteria for Water,
commonly referred to as the "redbook". Estimated recommended
ambient concentrations based on available organoletptic data for
a number of chlorinated phenols are listed below.
3-chlorophenol 0.1 ug/1
4-chlorophenol 0.1 ug/1
2,3-dichlorophenol 0.04 ug/1
2,5-dichlorophenol 0.5 ug/1
2,6-dichlorophenol 0.2 ug/1
3,4-dichlorophenol 0.3 ug/1
2,4,5-trichlorophenol 1.0 ug/1
2,4,6-trichlorophenol 2 ug/1
2,3,4,6-tetrachlorophenol 1 ug/1
2-methyl-4-chlorophenol 1800 ug/1
3-methyl-4-chlorophenol 3000 ug/1
3-methyl-6-chlorophenol 20 ug/1
A criterion of 1 ug/1 phenol was recommended in the "redbook" to
protect the freshwater environment for water supply and fish
consumption uses. In addition, the "redbook" states that
conventional water treatment is inefficient at removing phenol
and that chlorination of phenol results in the formation of
odor-producting chlorinated phenols.
Insufficient toxicity data on which to base a human health
standard are available for many of the chlorinated compounds
listed above. However, based on a 98-day feeding study in rats,
the toxicity -based criterion for protection of human health for
water and aquatic organism consumption for 2,4,5-trichlorophenol
is 2.6 mg/1. Based on its carcinigenicity, levels of 1.2 ug/1 and
3.6 ug/1 of 2,4,6-trichlorophenol are recommended to protect at
the 10-6 risk level for consumption of water and aquatic

organisms and organisms only, respectively. For the protection of
aquatic life, no criterion has been established. The lowest
concentrations at which acute toxicity occurs for a chlorinated
phenol is 30 ug/1 for a freshwater species and 440 ug/1 for a
saltwater species.
The Ambient Water Quality Crieria for Phenol (1980) states that
acute toxicity values (lowest effect levels) to freshwater and
saltwater aquatic life are in the mg/1 range. For protection of
human health, based on toxicity data, a level of 3.5 mg/1 is
recommended, while a level of 300 ug/1 is estimated based on
organoleptic data. A check of the IRIS database confirms this
information as the latest available.
While the level of 1 ug/1 seems justified for chlorinated
phenols, use of this concentration for other phenolic compounds
may be overly restrictive, depending on the water treatment
capabilities of current technology. Further characterization of
compounds initially determined as total phenols would be helpful
in setting effluent limits, since our standards do specify
chlorinated phenols. Although it has utility as a screening
method, the total phenol method is not appropriate for
implementing the 1 ug/1 standard. EPA Method 604, a gas
chromatography/flame ionization --electron capture detection
method, may be used to determine the following specific phenols
at ug/1 detection limits: 4-chloro-3-methylphenol,
2-chlorophenol, 2,4-dichlorophenol, 2,4-dimethylphenol,
2,4-dinitrophenol, 2-methylphenol, 4,6-dimethylphenol,
2-nitrophenol, 4-nitrophenol, pentachlorophenol, phenol, and
2,4,5-trichlorophenol. Use of the 300 ug/1 value for phenol (as
opposed to phenols) seems appropriate in setting effluent limits
for this specific compound, where necessary.
phenols.std/jfs/vol3
cc: Steve Tedder
Alan Klimek
Greg Thorpe

07/20/90
10:07 V -
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) ditz Jo. j
INDUSTRIAL & ENVIRONMENTAL ANALYSTS, INC.
P.O. Box 12846
Research Triangle Park, North Carolina 27709
JI4I.2O, Ic&10
FAX COVER SHEET
To: Pa e) j
From: u-� R02CJp,r-
Date: 71 2 0 Time:
Receiver's Facsimile Number:
10 ; 1 O a.m.\ p.m.
C7o1() gZ2 - l0 5 2. q
Number of Pages (including the cover sheet): —1
Comments: F P
Pt- rn
If all pages are not transmitted legibl please let us know as soon as possible.
Facsimile Operator:
IEA Facsimile Number: 919-677-0427
lEA Telephone Number: 919-677-0090
IEA's Shipping Address: 1901 N. Harrison Avenue, Cary, North Carolina 27513

u!/Zu/uu
lu:uo
i
tJuu4
Industrial & Environmental Analysts, Inc.
P.O. Box 12846
Research Triangle Park, North Carotene 27709
[phone]
FAX [phone]
July iS, 1990
Paige Straley
Sandoz Chemical
Hwy 27 West
Charlotte, NC 28266
Reference IEA Report No.: 821006
Project ID: APAM
Dear Me. Straley,
Transmitted herewith are the results of analyses on three samples submitted
to our laboratory.
Please see the enclosed reports for your results.
Very truly yours,
INDUSTRIAL & ENVIRONMENTAL ANALYSTS, INC.
Linda F. Mitchell
Director, Technical Support Services
State Certification:
Alabama - #40210 New Jersey - #67719 South Carolina - #99021
Georgia - #816 Tennessee - #00296 North Carolina - #37720
Kansas - #E-158 Virginia - #00179 #84

U / ZU/ iu : ua •c�
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Sample ID: 821-006-1, Effluent
A. Purgeable (Volatile Organic) Fraction
Number of chemicals detected in Fraction
Fraction STORET Number 84085
STORET Compound
Number
Pollutants to be analyzed for:
34210
34215
34030
32101
32104
34413
32102
34301
34311
34576
32106
34481
32105
34496
34531
34501
34546
34541
34704
34699
34371
34423
34516
34475
34010
34506
34511
39180
34488
39175
3
Detection
Limit Target
(ug/L) •
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
Dibromochloromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
trans-1,2-Dichloroethylene
1,2-Dichloropropane
cis-1,3-Dichloropropane
trans-1,3-Dichloropropene
Ethylbenzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Vinyl chloride
Other purgeables (up to 10 highest peaks:
100
100
5
5
5
10
5
6
10
10
5
10
5
5
5
5
5
6
5
5
8
5
7
5
6
5
5
5
10
10
compound name
Unknown
1,1,2-Trichloro-1,2,2-trifluoroethane
(Trifluoromethyl) - Benzene
Page 2 of 6
Concentration GC/MS Confirmation
Detected Yee/No
(ug/L)
<100
<100
<5
<5
<5
<10
<5
<6
<10
<10
<5
<10
<5
<5
<5
<5
<5
<6
<5
<5
<8
<5
<7
<5
<6
<5
<5
<5
<10
<10
conc (ug/L)
52
6 -- p)01-'-
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yee
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yee
Yes
Yes
Yes
Yes
Yes
Yes
Yes

u l / LU/ yU
1u:UV
tUtfU4J.t
pea
Sample ID: 821-006-1, Effluent
B. Acid Extractable Fraction
Number of chemicals detected in Fraction 6
Fraction STORET Number 45582
STORET
Number
Compound
Pollutants to be analyzed for:
34452
34586
34601
34606
36
34657
34591
34646
39032
34694
34621
4-Chloro-3-methylphenol
2--Chloropheno l
2,4-Dichlorophenol
2,4-Dimethylphenol
•
-
Page 3 of 6
Detection Concentration GC/MS Confirmation
Limit Target Detected Yes/No
2-Methyl-4,6-dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
(ug/L) (ug/L)
10
10
10
10
24
10
50
50
10
10
Other acid extractables (up to 10 highest peaks:
<10
<10
<10
<10
8
<24
<10
<50
<50
<10
<10
compound name conc (ug/L)
3-(trifluoromethyl) - Phenol 67
Unknown Organic Acid 10
Chloro-nitrophenol Isomer 26
Substituted Butenoic Acid 19
Unknown 8
C. Base/Neutral Fraction
Number of chemicals detected in Fraction 10
Fraction STORET Number 45583
STORET
Number
Compound
Pollutants to be analyzed for:
Yee
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Detection Concentration GC/MS Confirmation
Limit Target
Detected Yee/No
(ug/L) (ug/L)
34205 Acenaphthene 10 <10 Yes
34200 Acenaphthylene 10 <10 Yes
34220 Anthracene 10 <10 Yes
39120 Benzidine 44 <44 Yes
34526 Benzo (a) anthracene 10 <10 Yes
34247 Benzo (a) pyrene 10 <10 Yes
34230 Benzo (b) fluoranthene 10 <10 Yes
34521 Benzene (ghi) perylene 10 <10 Yes
34242 Benzo (k) fluoranthene 10 <10 Yes
34278 Bis (2-chloroethoxy)methane 10 <10 Yes

U 7/ 2U/ 9U it : lu •Gl
L�Jr. v4al
821-006-1, Effluent
C. Base/Neutral Fraction (Continued from page 3)
Fraction STORET Number 45583
STORET
Number
Compound •
Page 4 of 6
Detection Concentration GC/MS Confirmation
Limit Target Detected Yes/No
Pollutants to be analyzed for: (ug/L)
34273 Bis(2-chloroethyl)ether 10
34283 Bis(2-chloroisopropyl)ether 10
39100 Bis(2-ethylhexyl)phthalate 10
34636 4-Bromophenyl phenyl ether 10
34292 Butyl benzyl phthalate 10
34581 2-Chloronaphthalene 10
34641 4-Chlorophenyl phenyl ether 10
34320 Chrysene 10
34556 Dibenzo(a,h) anthracene 10
34536 1,2-Dichlorobenzene 10
34566 1,3-Dichlorobenzene 10
34571 1,4-Dichlorobenzene 10
34631 3,3-Dichlorobenzidine 20
3E+05 Diethyl phthalate 10
34341 Dieethyl phthalate 10
39110 Di-n-butyl phthalate 10
34611 2,4-Dinitrotoluene 10
34626 2, 6 -Dinotrotoluene 10
34596 Di-n-octyl phthalate 10
34346 1,2-Diphenylhydrazine 10
34376 Fluoranthene 10
34381 Fluorene 10
39700 Hexachlorobenzene 10
34391 Hexachlorobutadiene 10
34386 Hexachlorocyclopentadiene 10
34396 Hexachloroethane 10
34403 Indeno(1,2,3-cd)pyrene 10
34408 Isophorone 10
34696 Naphthalene 10
34447 Nitrobenzene 10
34438 N-nitrosodimethylamine 10
34428 N-nitroso-di -n-propylamine 10
34433 N-nitrosodiphenylamine 10
34461 Phenanthrene 10
34469 Pyrene 10
34551 1,2,4-Trichlorobenzene 10
Other Base/Neutrals (up to 10 highest peaks:
compound name
Substituted Cyclohexadiene
Unknown Alcohol
mawa-Aminobenzartmlial
Chloro-nitrobenzene Isomer 24
Unknown 34
Unknown 31
2-Chloro-5-nitroaniline 160
2-Methoxy-5-nitroaniline 20
Unknown 115
Unknown 51
1. 1F i.a.: :iiT14.':71i; arc
(ug/L)
<10 Yea
<10 Yee
<10 Yes
<10 Yes
<10 Yee
<10 Yes
<10 Yee
<10 Yes
<10 Ye8
<10 Yes
<10 Yes
<10 Yes
<20 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Ye9
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yes
<10 Yea
conc (ug/L)
34
85
Triz\1�

ui, ZtI/ 6u
s
lu : 11 *44.
►fir. uvu
Sample ID:
821-006-1, Effluent
D. Organochloride Pesticides and PCB's
Number of chemicals detected in Fraction 0
Fraction STORET Number 00188
STORET
Number
Pollutants
39330
39337
39338
34259
39340
39350
39310
39320
39300
39560
39380
34361
34356
34351
39390
34366
39410
39420
39480
39755
39540
39400
34871
39488
39492
39496
39500
39504
39508
Compound
to be analyzed for:
Aldrin
alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Linden)
Chlordane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Demeton
Dieldrin
Endosulfan I (alpha)
Endosulfan II (beta)
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Methoxychlor
Mirex
Parathion (ethyl)
Toxaphene
PCB 1016
PCB 1221
PCB 1232
PCB 1242
PCB 1248
PCB 1254
PCB 1260
Page 5 of 6
Detection Concentration GC/MS Confirmation
Limit Target Detected Yes/No
other Pesticides (up to 10 highest peaks:
None
(ug/L)
5.0
5.0
5.0
5.0
5.0
50
10
10
10
10
1.0
5.0
10
10
1.0
1.0
5.0
5.0
50
6.0
60
100
50
50
50
50
50
100
100
(ug/L)
<5.0
<5.0
<5.0
<5.0
<5.0
<50
<10
<10
<10
<10
<1.0
<5.0
<10
<10
<1.0
<1.0
<5.0
<5.0
<50
<6.0
<60
<100
<50
<50
<50
<50
<50
<100
<100
Comments:
Quantitation limit elevated due to extract dilution prior to analysis.
Extract diluted due to the presence of non -target compounds.
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

t]007
Sample ID:
821-006-1, Effluent
E. Herbicides
Number of chemicals detected in Fraction
Fraction STORET Number 00148
0
Page 6 of 6
STORET Compound Detection Concentration GC/MS Confirmation
Number Limit Target Detected Yes/No
Pollutants to be analyzed for: (ug/L) (ug/L)
39730 2,4-D 50 <50 No
39045 Silvex 50 <50 No
39740 2,4,5-T 5 <5 No
Other Herbicides (up to 10 highest peaks:
None
F. Metals and Other Chemicals
Number of chemicals detected in Fraction
Fraction STORET Number 45583
STORET
Number
Compound
7
Detection
Limit Target
Detected
Pollutants to be analyzed for: (uq/Lli ./
01c rSt t �tii o S�
01002 Arsenic 10 <10
01012 Beryllium
01027 Cadmium
01034 Chromium
c0 - sffppcat
01051 Lead
25 <25
2 <2
7 * <7
2 GlYJ / iy
10 <10
01147 Selenium 5 <5
01077 Silver 9 * <9
01092:- ^- zinc , Q40z
Other Inorganics:
01007 Barium 500 <500
00940 Chloride 1000 850,000
00720 Cyanide 20 30
00951 Fluoride 100 1,200
Comment:
*Quantitation limit elevated due to sample matrix interference.
Analytical Laboratory Representative:
Signed: Date:
Facility Operator in Responsible Charge (OCR):
I certify that this report is accurate and complete to the best of my knowledge.
Signed: Date:

DRf FT R€,kd ire, (rded
1-6 per make .
PERMIT NO.: NC00 D(13`73
FACILITY NAME: S&rldOL
Facility Status:
Permit Status:
Major ✓
�l[iS bn5
Renew]
Pipe No.: 001
Minor
Design Capacity: 3.q M6D
Domestic (% of Flow): Z%o
NPDES WASTE LOAD ALLOCATION
Industrial (% of Flow): g$%
Comments:
PLOTTED
RECEIVING STREAM: CC kt)ba 2ver
Class: 05 -1TI
Sub -Basin: - 03eg3h4
Reference USGS Quad: FI4S
County: l l ecK1&ib7U►'
Regional Office: fl7RO
Requested by:
Prepared by:
Reviewed by:
u)q wA.1.--,n
-SOD C s wl Ski
\u �C
(please attach)
Date:
Date:
Date:
Modeler
Date Rec.
#
GCS
('\'4rbi
53/3 hart
Drainage Area (mi2 ) a011
Avg. Streamflow (cfs): aDI(.e
7Q10 (cfs)3z
gt Winter 7Q10 (cfs)
Toxicity Limits: IWC 1.$ % Acute Chronic
Instream Monitoring:
Parameters
Upstream Location
Downstream Location
30Q2 (cfs)
Effluent
Characteristics
(Ylp. Ails
Dkj May
All3-N llbla)
051
q"1")
lnercuit l (Old)
o . o2 z = 2.41At5
Phenols (lb/d)
I.?
&11 1-e (lbe)
Oqa -734
7114.5 ANA regTh
r e) made.
hb 0'/129 F
lim,fs3 rhGn5ed
ba) erl on dkscu1sort
al mee ij tok3
lt'fe(curU Conc.
/;m,t mal be ii (rased
to 5..R ,uJc%P i
diffuser er irufalled.
Recommend a#aehed
6 inj rQ2emed
` for
Reuynae / u52_
Of C d-ihar i ank
( e cSimiL't t �p
aibched.
. v
Ca)
1
849.3
1/Yl.
Comments: The ct 'errg,if'.146 ¢o{aj pA /Zs Ohail Graf
eFr,
le
peon Li-.
ram.

CL ier
0,..-, -let C Q)e.
k e otA-cird ait.' ejl'aet
'6 Dam )41,

WASTELOAD
Facility Name:
NPDES No.:
Type of Waste:
Status:
Receiving Stream:
Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Quad:
Wasteflow (mgd) :
NH3N (lb/d) :
Mercury (lb/d) :
Phenols (lb/d) :
Sulfate (lb/d) :
Sandoz
NC0004375
98% Industrial
Existing
Catawba River
WSIII
030834
Meckl burg
MR
Har is (orig.)
F14SE
Request No.:5313 e
OF Ar4
ALLOCATI:N APPROVAL FORM -1 ikIi-ti4. R4L
qR 1 ..Vr
MAR
.V M
28 1990 �'rsrog
�oORfsyiQf �f r:�r41 -AP
> �!r,INFt trtn!r, 6l0141 s1
MfNr
PERMIT84 S
Drainage
Summer
Winter
Average
RECOMMENDED EFFLUENT LIMITS
Mo Dly
Avg Max
3.9 (Year Round)
651 977
art
7Q10:
7Q10:
flow:
30Q2:
2011
329 (R)
3016
1990
OfFje f
LUcow er-`�.�i� p2.rvA%
41 swupp ,, �. n. �. cbt.'-t-a p 12,4 .
'Q -
e.t
or vKovufov.�., dHL% . ""J bi7V1'S
U S
0.022 and%2.4 ug/1 �g-Cy
.. an /no concentration limit
C452,10�nd no concentration limit
Specific phenolic compound limits will be the Br and NSPS limits in
Federal Register. Phenolic compounds include: 2-Chlorophenol,
2,4-Dichlorophenol, 2,4-Dimethylphenol, 2-Nito€ phenol, 4-Nitrophenol,
2,4-Dinitrophenol, 4,6-Dinitro-o-cresol, Phenol.
COMMENTS
This approval form reflects changes made in the draft permit.
Limits changed based on discussion at meeting with Sandoz.
Mercury concentration limit may be increased to 5.3 ug/1 if diffuser
installed.
Recommend inclusion of the attached staging requirement.
Recommend use of an additional DMR page similar to one attached to
monitor compliance with BOD and NH3 staging requirements during summer.
The statement that total polynuclear hydrocarbons shall not exceed
0.50 lb/day (15.5 ug/1) shall be deleted from the permit.
Recommended by: It i • j "t.itPIZ Date:
Reviewed by
Tech Support Supervisor: Date:
Regional Supervisor: }'U.A,a ) ( wrt�h Date:
Permits & Engineering: v �,Y� Date:
RETURN TO TECHNICAL SERVICES BY: APR 13 1990
Je-cAab, ,0-4 Pi 6J, c,s,)-( uv,k
,3i� 3/qU
3(0,/610
31231g0
3/2 /Co

Staging Requirements (Applicable April 1 - October 31)
The operating day runs from 7:00 am to 7:00 am. Each day, the
permittee will calculate a running daily average stream flow as
determined by turbine operation at Mt. Island Dam, leakage at the
dam (80 cfs) , and the 7Q10 flow of Dutchman Creek (15 cfs) .
Effluent release is to be controlled such that projected release of
BOD and ammonia, using the most recent analytical values for these
parameters, will not exceed the value given in the following for-
mulas:
When daily average river flow is calculated to be <= 175 cfs:
BOD5 + 0.54 (NH3-N) <= 566.4 lb/d
When daily average river flow is calculated to be > 175 cfs
but <= 250 cfs:
BOD5 + 0.54(NH3-N) <= 1044 lb/d

Additional DMR Sheet for Sandoz
EFFLUENT
NPDES Permit No. NC0004375 Discharge Month Year_
Sandoz Class 4 Mecklenburg County
Operator in Responsible Charge (ORC):
Certified Laboratory:
Person(s) Collecting Samples:
Check if ORC has changed
I certify that this report is accurate and
and complete to the best of my knowledge.
River Allowable Actual
Qw Flow BOD5 NH3 BOD+.54NH3 BOD+.54NH3 Comp?
Date Time (mgd) (cfs) (lb/d) (lb/d) (lb/d) (lb/d) Case (Y/N)
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
Average
Case 1: River Flow <= 175 cfs BOD5 + 0.54NH3 <= 566.4 lb/d
Case 2: 175 cfs<River Flow<= 250 cfs BOD5 4- 0.54NH3 <= 1044 lb/d
Case 3: Riv. Flow>250 cfs, BOD5<=852 lb/d (mo avg), BOD5<=2236 lb/d (dly max)
NH3<=651 lb/d (mo avg), NH3<=977 lb/d (dly max)

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 8, 1990
MEMORANDUM
TO: Sandoz WLA File
FROM: Ruth Swanek
SUBJECT: Sandoz Draft Permit Changes
NPDES No. NC0004375
Catawba River (030834)
Mecklenburg County
On February 9, 1990 representatives of Sandoz met with DEM to
discuss the draft permit for the facility. The permit was modified
to include a flow limit of 3.9 mgd year round. This new flow was
then used to develop a BPJ limit for ammonia assuming a concentra-
tion of 20 mg/l. The resulting monthly average limit was 651 lb/d.
A factor of 1.5 was used to develop the daily maximum limit of
977 lb/d.
Since the new BOD and NHS limits were more stringent than in
past permits, the staging requirements were only more restrictive
than the permitted limits during the summer months. Therefore, the
staging requirements were simplified. An additional DMR page was
designed in order to monitor compliance with the staging require-
ments (attached) .
The company was concerned that it would not be able to meet
its phenols and mercury concentration limits. Since the facility
has been designed so it can store large quantities of effluent in
order to meet its staged discharge, requirements, the facility often
discharges only 0.5 MGD during the low flow summer months. Since
the IWC is only 1.8%, the effluent should not cause detrimental
effects instream if it discharges higher concentrations of these
parameters at low effluent flows if loading remains constant.
Therefore, loading was kept at the draft permit levels, and efflu-
ent flow was reduced to 0.5 MGD to obtain new concentration limits
for mercury. The result was 5.3 ug/l. However, the acute criteria
for mercury is only 2.4 ug/1, and therefore this limit was assigned
in the modification. If Sandoz wishes to obtain higher concentra-
tion limits for mercury, it will have to install a diffuser.
Since DEM's agreement with EPA is to report water quality lim-
ited parameters which are oxygen -consuming wastes or toxics in
terms of concentration and mass limits, it is not required by DEM
to assign limits for phenols in terms of both since the standard is
based on taste and odor. The original limits were derived under
the assumptions. that the facility was operating at design flow and

that the stream flow was equivalent to the minimum daily release.
Since the flow of the Catawba River is usually much higher, the
phenols in the effluent should not cause taste and odor problems
when only the mass limit is assigned. Therefore, the concentration
limit was dropped. The sulfate limit was dropped for the same rea-
son since the company had initially expressed concern about this
limit.
The company also revealed that it would prefer to meet the
specific phenolic compounds limits given in the Federal Register
although compliance with some of the effluent guidelines would
result in noncompliance with the total phenols limit. However,
this action makes the company noncompliant with only one parameter
rather than two, and this request was granted.
Sandoz provided us with information (attached) which indicates
that the North Carolina standard for polynuclear aromatic hydrocar-
bons (PAHs) is based on individual concentrations rather than total
concentrations. The information was reviewed by a DEM chemist and
it was determined that the company was correct. Therefore, the
statement that total PAH's could not exceed 0.50 lb/d (15.5 ug/l)
was deleted from the permit.
Finally, the company reported that fifteen substances have
been remanded from the OCPSF list. EPA has told us that only one
substance has been remanded. This issue is currently being
resolved.

•
1
1
Efficiency of absorption from oral
SF _ Sfety facto; following guidelines given
above. -
More formal pbarmacokineticmodels
must be developed on a compound -by -
compound
basis.
It should be noted that the safety
mart+ors •used in the above formulae are
intended to account for species
variability. Consequently,the mg/
surface area/day conversion factor is
not used in the derivation of toxicity
based criterion.-
C. O,'genoleptic Criteria
organoleptic criteria define •
concentrations of materials which
impart undesirable taste and/or odpr to
water. In developing and utilizing such
criteria two factors must be appreciated:
the limitations of most organoleptic data
and the human health significance of
organoleptic properties.
The publications which report taste
and odor thresholds are, with Very few
exceptions, cryptic in their descriptions
of test methodologies. number of
subjects tested, concentration: response
relationships, and sensory
characteristics at specific
concentrations above threshold. Thus,
the quality of organoleptic data is o.Len
significantly less than that of toxicologic r A class criterion usuai:y applies to -
based on biological endpoints (e.g.,
each member of a class rather than to o . y
data used fly. critical evaluation criteria. the sum of the compounds within the carcinogens/non-carcinogens), potency, Consequenly, a critical of and/or sufficiency of data (e.g., a
the available organoleptic data must be class. 'While le the potential hazards of
multiple toxicant exposure are not to be criterion for some members of a class
made and the selection of the most appropriate data base for the criterionminimize, a criterion, by definition, but no criterion for others). While no a
priori limits can be placed on the extent
most Oiler: applies to an individual P •
must be based on sound scientific pl?be of subclassification, each
compound. EXceptions may made for of subciasi ifi subclassification must be explicitly
judgment. complex -which
,... � •.:stilled by the available data.
praanoleptic criteria are not based on con-.; ...a mixtures z+'a-uch are p roduced,
' toxicologic information and have no released, and toxicologically tested as l •Class criteria, ifv properly derived and
direct relationship to potential adverse mixtures (e.g., toxap'hene and PCBs). For
such exceptions, some attempt is made supported, can constitute valid scientific
h health effects. Although l ammo-srnerts of potential risk/safety.
Convereelt, the development of a class
criterion from an insufficient data base
can lead to serious errors in
underest:rating or overestimating risk/
safety and should be rigorously avoided.
Although scientific judgment hasa • c
proper role in the development of class
criteria. such criteria are useful and
defensible only if they are based on
adequate data and scientific reasoning.
The definition of sufficient data on
Frida hog ember 2$, 1980 f Notices ?5335
Federal Register i Vol. 45, NO. 231 / . S 5
Register
• ea
' •� ,r,,!; ::..i:�. and
level is . L'rirsg available or2ano11eptic `1. A detailed review o. to
'e taste and physical properties of chemicals within the
data, for cont.-•v1i;. g undesirable
estimated groupshould be made. A close relationship
near at:ality of ambient waterthe e_
thatwithin the class with respect to chemical
level is -. It should be recognizedt , Class
d suggest ra similar potential to
organoleptic data as a basis for establirhing a acttivi-y .
water quality criteria have no demonstr aied -reach common biological sites with. tissues.
relationship to potential adverse humane es the possibility ofid lubiliEes comparable�d
suggest P
absorption and tissue distribut�on.
2. r,talittive and quar.etat: -=''- _'
chemicals within the group are examined.
Adequate toxicologic data oat des er of
more
compounds within a group P
health•efects.
In those instances where a level1to
l,. bo derived, the
imit ta'i`niL'aty cannot �•a.a. dew
following statement is to be
appropriately inserted
•
Sufficient data are not available for reasonable basis for extr apolabon toother
to derive a level which would ` chemicals of the same class than minimal
protect against the potential toxicity of this data -on one chemical or a few chemicals .
within the group.
compound. 3. Similarities in the nature of the
D. Criteria for Chemical Classes toxicologic response to chemicals in the class
A chemical class is broadly defined as provides additional support for the prediction
that d e response to other members of the
an};,group of chemical compounds which class maybe sirniler•. In contrast, where the
are reviewed in a single risk assessment biological response has been shown to differ
document. In criterion derivation, markedly on a qualitative and quantitative
isomers should be regarded as a part of besis for chemicals within a class, the
a chemical class rather than as a single extrapolation of a criterion to other members
of that class is not appropriate.
compound. A•class criterion is an 4_ Additional support for the validity of
estimate of risk/safety which applies to extrapolation of a criterion to other members
more than one member of a cuss. It of a cams could be provided by evidence of
involves the use of available data on similar metabolic and pharmacokinetic data
one or more chemicals of a class to for some members of the class.
•
derive criteria for other compounds of Based on the above considerations. it
the same class in the event that there
are insufficient data available to derive - may be reasonable in some cases to
divide a chemical class into various
compound -specific criteria. �. subclasses. Such divisions could be
Liman ea a i� • . a
sufficiently intense o ganaleptic to assess the effects of environr.nenta
i
characteristics could result in depressed partitioning o (•.e., different patterns of
fluid intake which, in turn, might environmental transport and
aggravate a variety cf,f�unctional disease degradattion) on the validity of the
states (i.e.. kidney and circulatory criterion. If these effects cannot be
assessed, an appropriate statement of
diseases), such effects are not used in
the derivation process of erpano1eptic uncertainty should accompany the
criteria ur.lees eveil.a1' - data ::'nrld criterion.
Since relativelminor structL a
indicate an lri:.irQ:.: i.'.: �c1 .' .',`C.l:: effect-
via decreased fi id co-"•= ern =-tali. changes within a class of compounds
1y f_ can have pronounced effects on their
criteria derive_ sd:e,; ..err a:garioieptic1• n class
data are based ut oc aesthetic qualities
only.
Since organoleptic and human health
effects criteria are be sod on c:.:event
endpoints, a distinction ^oust b=' made
between these tevo sets c: !nice -elation.
ter sly-..—•ar its i . of g both
typesy criteria
data,the following ft,r neat is
used:
-Isar. pe ;.grins twit a;•;-ce:hes
For c:,;..Ya.
were used le Ce:. ..:.......... :
for
biological activities, reliance e
' chemical
criteria should be minimized: Whenever similarities in physical, , •
sufficient toxicologic data are available pharr acokinetic, or toxicologic
on a chemical within a class, a properties to justify a class criterion
criterion should be may vary markedly depending on the
compound -specific derived. Nonetheless, for some chemical degree of structural similarity and the
classes, scientific 3urlement may suggest gravity of the perceived risk.
a sufficient degree of similarity among Consequently, it is imperative that -the
chemicals within a class to justify a criterion derivation section of each
class criterion applicable to some of all document in which a class criterion is
e recommended explicity address each of
members of a C_s�SS. -
'; .r:'„ .e development of a class c:itr rion the':ey' issues discussed ab0 e. and
• •• t� fot'a:N-' 1g: define as clearly as possible. the
t�:.;:s ...:o �:or:�,�_-o,;on ►,�e .,:,� into.
•,,-ram,

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 7, 1990
MEMORANDUM
TO: Dale Overcash
THROUGH: Trevor Clements'
FROM: Ruth Swanek 2LS
SUBJECT: Sulfate Limit for Sandoz
NPDES No. NC0004375
Mecklenburg County
I have reviewed the BPJ limit you derived for Sandoz based
upon the data which the facility recently submitted. The limit
looks reasonable and should be included in the final permit. The
daily maximum sulfate limit will be 292,734 lb/day.
If you have any questions or comments, please call me at
extension 507.
cc: Rex Gleason

SANDOZCHEMICALS
6,11 licf. T5I3
Mallard Creek Research Center
P.O. Box 669304
Charlotte, North Carolina 28266
704.547.5600
Telefax: 704.547.5610
April 27, 1990
Ms. Lula M. Harris
Environmental Engineer I
NC Div. of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
RE: Sulfate Concentration Data for
Sandoz - Mt. Holly Plant Effluent
Dear Ms. Harris:
Environmental, Safety and
Product Safety Deportment
Suite 100
2300 W.T. Harris Boulevard
Charlotte, North Carolina 28213
'�• �M .::AJ L
APR :3 u 'I LJ
NIRMITS .n. ►'? !IF P:N^
In response to your request concerning effluent sulfate
concentration data for our Mt. Holly facility, we reviewed all
available historical sampling data. Unfortunately, we were
unable to find any recent records of sulfate analyses.
Therefore, we initiated a five-day sampling program for sulfates
which began April 18, 1990.. All samples were taken from the
chlorine contact basin as grab samples between 7:15 and 8:00 AM
each day. The following data were obtained:
DATE SULFATE (ppm)
April 18, 1990
April 19, 1990
April 20, 1990
April 21, 1990
April 22, 1990
4404
4239
4049
4878
4950
Average: 4504
The effluent sulfate concentration is affected by numerous
factors which fluctuate over varying time periods. These factors
include the batch nature of the manufacturing processes, process
scheduling, production levels and rainfall. Additionally,
changes in the amount of caustic used as a neutralizing agent
significantly affect sulfate concentrations in the effluent.

Ms. Lula Harris
April 27, 1990
Page 2
Given the large potential for sulfate concentration variability,
five samples do not comprise a very representative data set.
Therefore, we would appreciate considerable leeway in our permit
limit for sulfates, possibly as much as 2 or 2.5 times the
average value shown above.
Please feel free to contact me if you have any questions or
require further information.
Sincerely,
Michael A. Teague, Ph.D.
Environmental Manager
cc: Bill Archer
Paige Straley
/‘"eju( 1 �L
z(g5„ (z) (_ 3 f M�� (� 3r)
& Cour5P)
(sr

To: Paige Straley, Sam Hill
From: Ed orth
Subj: ackwash canal sampling program
Dat
The intentions of backwash sampling is identify conditions of
wash water and possibly justify a separate discharge permit
for this flow. The parameters to be charted are BOD, COD, and
TSS on influent and effluent. The influent sample point is at
the pipe where backwash water is discharged into the north
end of canal. The effluent sample point at the north side of
the earthen dam across canal. Other conditions to be noted
are backwash flow (mgd), clarity of river ( clear or muddy ),
and time of sampling. We sample 1-3 times per week. depending
on conditions of river. Program will begin the first week of
April and run for 60-90 days.
Ed Duckworth

SANDOZCHEMICALS
Mallard Creek Research Center
P.O. Box 669304
Charlotte, North Carolina 28266
704.547.5600
Telefax: 704.547.5610
April 27, 1990
Ms. Lula M. Harris
Environmental Engineer I
NC Div. of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
RE: Sulfate Concentration Data for
Sandoz - Mt. Holly Plant Effluent
Dear Ms. Harris:
Environmental, Safety and
Product Safety Department
Suite 100
2300 W.T. Harris Boulevard
Charlotte, North Carolina 28213
1
gmar
•
APR ;3 U 1990
PERMITS &FZ�f ;dfi Rfft!r
In response to your request concerning effluent sulfate
concentration data for our Mt. Holly facility, we reviewed all
available historical sampling data. Unfortunately, we were
unable to find any recent records of sulfate analyses.
Therefore, we initiated a five-day sampling program for sulfates
which began April 18, 1990. All samples were taken from the
chlorine contact basin as grab samples between 7:15 and 8:00 AM
each day. The following data were obtained:
DATE SULFATE (ppm)
April
April
April
April
April
18,
19,
20,
21,
22,
Average:
1990
1990
1990
1990
1990
4404
4239
4049
4878
4950
4504
The effluent sulfate concentration is affected by
RECEIVED
J U L 27 1991
CENTRAL FILE COPY
numerous
factors which fluctuate over varying time periods. These factors
include the batch nature of the manufacturing processes, process
scheduling, production levels and rainfall. Additionally,
changes in the amount of caustic used as a neutralizing agent
significantly affect sulfate concentrations in the effluent.

Ms. Lula Harris
April 27, 1990
Page 2
Given the large potential for sulfate concentration variability,
five samples do not comprise a very representative data set.
Therefore, we would appreciate considerable leeway in our permit
limit for sulfates, possibly as much as 2 or 2.5 times the
average value shown above.
Please feel free to contact me if you have any questions or
require further information.
Sincerely,
Michael A. Teague, Ph.D.
Environmental Manager
cc: Bill Archer
Paige Straley
KECEIVED
JUL 27 1991
CENTRAL FILE COPY

SANDOZCHEMICALS
Sandoz Chemicals Corporation
4000 Monroe Road
Charlotte, North Carolina 28205
704.331.7088
Fax: [phone]
William M. Archer, III
Director, Environmental Affairs
Mr. Ken Eagleson, Supervisor
Biological Services Unit
North Carolina Department of Environment,
Health and Natural Resources
Water Quality Section
512 N. Salisbury St.
Raleigh, NC 27611
Dear Mr. Eagleson:
Mt.Holly Plant
P.O. Box 669246
Charlotte, NC
Thank you for meeting with us to discuss the draft NPDES permit for our Mt. Holly facility. Per
our discussion on February 9, 1990, I am submitting this letter as documentation of Sandoz' efforts to
characterize and reduce effluent bioassay toxicity at the Mt. Holly plant.
Sandoz is committed to improving and maintaining the effectiveness of wastewater treatment at
the Mt. Holly facility. The facility is a very complex operation, producing hundreds of products by
batch processes.
For more than a decade the plant has been looking at ways to improve the bioassay test results of
its effluent. The Mt. Holly facility conducted hundreds of fathead minnow bioassay tests on
differentially -treated wastewaters from 1977 to 1981 in an effort to identify the extent of effluent
toxicity. These studies were initiated at a time when toxicity bioassays were just beginning to be
accepted as an indicator of effluent impact. Mt. Holly's studies established an early precedent for the
toxicity reduction efforts which continue at Sandoz today. One result of the early testing was the
provision of preaeration to a equalization basin, which reduced the fish toxicity.
In 1981 gravity clarifiers were built to replace the somewhat experimental dissolved air flotation
units. Much improved biological treatment resulted from the modification.
In 1983 two significant events occurred. We brought a new controlled -discharge facility on line
as a part of our new NPDES permit. This facility gave us 360 million gallons of post -treatment
equalization, and allowed us complete control over the rates and timing of our discharge. (It will be
shown later, however, that the controlled -discharge facility may complicate our efforts to pinpoint the
source of chronic toxicity.) Second, we started up a new pretreatment facility for phenolic wastes.
These facilities allowed us to meet the effluent quality specified in our new NPDES permit and to
provide better protection of water quality during varying river flow conditions.

Also between 1983 and 1985 we discontinued the production of two significant products. This
was in order to meet both our internal goals of waste minimization, and also to ensure effluent
quality.
In 1985 the State asked us to begin acute toxicity testing using Daphnia pulex as the test species.
As the testing went on, it became apparent that the effluent was often not acutely toxic at all, and in
general was substantially less toxic than in former years. Acute toxicity appeared to be linked with
the seasons, with cold weather (and lower biological activity) adversely affecting effluent quality.
Studies conducted during this time also determined a rough dose/response• relationship for dissolved
salts in the effluent. Under normal operating circumstances the salt concentration of the effluent was
below the level found to cause acute toxicity.
The State acknowledged the progress Sandoz has made in reducing effluent toxicity in a letter
from George Everett to William Archer dated July 7, 1987. This letter required Sandoz to begin a
more subtle test (chronic toxicity, using Ceriodaphnia) to determine effluent toxicity, since the acute
toxicity test was now within generally acceptable limits.
It is useful to note here that the chronic toxicity test does not appear to reflect the effect of the Mt
Holly effluent on the Catawba River biotic community. An in -river analysis of species diversity in
1986 showed that there was no statistical difference in the macroinvertebrate communities upstream
and downstream of the Mt Holly plant discharge. The macro -invertebrates are continually exposed to
the various in -stream concentrations of the effluent, and are the acid test of stream quality.
In late 1987 Sandoz began a RCRA-required upgrade of our wastewater treatment plant. The
construction activities, which lasted into mid-1989, proved to be a serious disruption of the treatment
system. During this period the effluent quality was not representative of the normal system, and
understandably, the chronic toxicity results during this time were not favorable. However, acute
toxicity generally remained under good control, and we felt that good chronic test results might be
forthcoming when the construction -related upset conditions were ended.
This did not stop us from continuing our efforts to improve treatment. Results from various
experiments (from as far back as 1977) indicated that powdered activated carbon (PAC) helped the
WWTP perform best and reduced toxicity. Daily addition of PAC was begun in October 1988, with
a semi -automated silo system being commissioned in September 1989 for ongoing use. While the
PAC has shown benefits in terms of conventional and phenolic permit parameters, we have been quite
disappointed that improvements in chronic toxicity have not been apparent at the levels of PAC that
the current system is able to accommodate without major modifications. ,. •
Our efforts to reduce chronic toxicity have gone forward on multiple fronts. In April 1989, we
performed a small study to help characterize the nature of the effluent toxicity present at that time,
and to determine if the causative agents were amenable to more exhaustive biological treatment. This
study indicated that high dosage carbon would remove the toxicity but that extended biological
treatment alone did not. Thus we focused on refractory organic compounds as a likely source of the
2

residual toxicity at that time.
In June 1989 we commissioned a study by Enwright Laboratories to perform chronic toxicity
studies on six process wastestreams which we suspected of exhibiting chronic toxicity. These
wastestreams had partly been identified through wastewater characterization studies performed
previously. Two wastestreams did indeed show a potential effect. Verifying whether these are the
source of our residual chronic problems has been complicated by stored wastewater being released
from the controlled -discharge facility for re -treatment through the biological waste treatment plant.
Residual materials in the stored water mask correlations between bioassay results and production
schedules. .
We continue to measure chronic toxicity quarterly, and it appears that some improvement is
occurring due to our ongoing work with the system. As the attached DEM form AT-1 (rev 9/89)
shows, reproduction is certainly enhanced over past tests.
Our new NPDES permit, set to be issued sometime later in 1990, will establish the chronic
toxicity as a permit parameter. Compliance with other permit parameters in the new permit will
likewise present challenges, that must be addressed in concert with toxicity. We have chosen a well-
known environmental engineering firm to do a complete treatability study, which will result in a plant
upgrade to insure consistent compliance with the new permit. A Toxicity Reduction Evaluation is a
major part of the treatability study.
Working with the NC DEM Biological Services Unit, we have already set up a chronic toxicity
lab here at Mt Holly. Our intent is to track down all suspect wastestreams and then to determine what
combination of pretreatment and enhanced biological treatment will eliminate the toxicity. Our
environmental engineering consultants will work with Sandoz professionals to form a Toxicity
Reduction Team. The chronic toxicity lab is already at work and the consultant team should begin
work in April.
The time necessary to completely eliminate the problem is difficult to pin down for several
reasons. We think the ultimate solution to both the toxicity limit and other new limits will involve a
combination of waste minimization, waste pretreatment and possibly enhanced end -of -pipe treatment.
The specific modifications will depend on the final permit limits and on the results from our
engineering treatability studies. If major modifications are indicated we anticipate that, as in 1987
and 1988, some process disruption will be inevitable. Thus it is unlikely that we can fully comply
with all permit parameters, including toxicity, until the major portions of the upgrade are complete.
Sandoz' record indicates a good faith effort to attack the problem of effluent toxicity. The goal
has been somewhat of a moving target --the change from acute toxicity to chronic toxicity testing is an
example --but Sandoz remains committed to compliance with all applicable environmental regulations.
We are confident that our continued efforts will attain compliance with the chronic toxicity discharge
permit standards.
3

I hope this letter has been informative; however, if there are further questions, or if I may be of
help to you in any way, please do not hesitate to call me at 704 822 2701.
Sincerely,
(//11. Citri-o-t— g-c..-1.
J. Paige Straley, * PE
Environmental Manager
cc: Mooresville Regional Office
Dale Overcash
W.M. Archer
M. Teague
M. J. Smith

EflWRIGHT
ENVIRONMENT Al_
MINI CHRONIC PASS/FAIL
C E R I O DA PH N I A TOXICITY TEST
Client: Sandoz Chemical Corp.
Location: Charlotte, North Carolina
County: Mecklenburg
Identification: 1.8% Effluent
Test Initiation: 02/20/90
EL
Enwright Environmental Consulting Laboratories. Inc.
(25 Woods Lake Rd. 20607) PO Box 17467 Greenville, SC 29606 803 235.0707

I N'TEEZPRETAT ION OF RESULTS
This toxicity test was conducted to determine if the effluent at
the given concentration (the in -stream waste concentration - IWC) causes
death (acute toxicity) or reduction in the reproduction of the test
organisms (chronic toxicity) during a seven day period. Acute toxicity
is checked by statistically analyzing whether significantly more
organisms died in the effluent treatment than in the control treatment.
Chronic toxicity is checked by statistically analyzing whether
significantly fewer young were produced by test organisms exposed to
the effluent treatment. If either analysis indicates a significant
difference, the test is considered a failure. Results are summarized
as follows:
Acute Toxicity: No significant acute toxicity by Fisher's Exact Test.
Chronic Toxicity: Significant chronic toxicity by t Test.
Final Result: Fail

TEST SYSTEM
Client: Sandoz Chemical Corp.
Test Start Date: 02/20/90
Test Completion: 02/27/90
Test Type: 7 Day Chronic Toxicity - Pass/Fail
Test Location: Enwright Environmental Consulting Laboratories
(NC Certification #: 010)
Test Organism: Ceriodaphnia dubia Source: Enwright
Age: <24 hrs
Test Procedure: Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms.
EPA 600/4-89/001 Method 1002
North Carolina Ceriodaphnia Chronic Effluent Bioassay
Procedure. NC Dept of Nat. Res. and Comm. Dev., DEM, Water
Quality Section. December 1985. Revised September 1989
Test vessels: 20 ml plastic beakers
Amount Test Soln: 15 ml / replicate
# Replicates/Concentration: 12
Test Organisms/Replicate: 1
Test Dilutions Used: 0 & 1.8% Effluent
Test Solution Renewal: Day 2 & Day 5
Test Solution Treatment: None
Food Source: 0.10 ml Selenastrum (3.0-3.5 x 107 cells/ml)
and 0.05 ml YCT daily / test vessel
Test Set By: Joel Stephens - Biologist
Test Results Checked By: Robert. W. Kelley, Ph.D
Biology Laboratory Manager

SAMPLING INFORMATION
Two effluent samples were collected in plastic liter -size
cubitainers for use in this toxicity test. The effluent samples were
collected by on -site personnel and shipped to Enwright Environmental
Consulting Laboratories by overnight delivery. The samples were chilled
during shipping.
Client: Sandoz Chemical Corp.
Date: 02/20/90
Sample Sample
#1 #2
Lab # Bio 403 Bio 409
Type composite composite
Date sampled (Composite started) 2/19/90 2/22/90
Time sampled 0700
Days of use Init,Day 2 Day 5
Maximum hold time: 72 hrs 72 hrs
Temperature upon receipt: 4°C . 4°C

n,ESLJLrrs
Client: Sandoz Chemical Corp.
Sample Identification: 1.8% Effluent
Start Date: 02/20/90
ACUTE TOXICITY (Effects on Survival)
# organisms dead - control: 0 % dead: 0.0%
# dead producing young: 0
# organisms dead- effluent: 0 % dead: 0.0%
# dead producing young: 0
# males & # lost - control: 0
# males & # lost- effluent: 0
No significant acute toxicity by Fisher's Exact Test.
i

IZEStJT.,•rs
Client: Sandoz Chemical Corp.
Sample Identification:
Start Date: 02/20/90
1.8% Effluent
CHRONIC TOXICITY (Effects on Reproduction)
Dailx Reproduction Totals:
Rep Day 4 Day 5 Day 6 Day 7 Total
Control A 2 1 0 13 16
B 1 4 4 12 21
C 1 5 10 11 27
D 1 5 9 15 30
E 0 6 0 13 19
F 4 6 1 10 21
G 2 0 9 10 21
H 0 3 0 15 18
I 3 5 14 0 22
J 7 0 9 14 30
K 4 7 0 14 25
L 5 0 0 17 22
Av. young/ female: (including mortalities): 22.67
(excluding mortalities): 22.67
%3rd brood: 75%
1.8% A 4 5 0 0 9
Effluent B 3 0 0 0 3
C 2. 0 0 1 3
D 2 0 1 2 5
E 5 6 0 2 13
F 5 0 0 1 6
G 4 1 0 0 5
H 4 0 0 4 8
I 5 1 0 0 6
J 4 3 12 5 24
K 11 1 0 5 17
L 9 2 9 0 20
Av. young/ female: (including mortalities): 9.92
(excluding mortalities): 9.92

D A.T.. ANIA. 1 Y S IS
Client: Sandoz Chemical Corp.
Sample Identification: 1.8% Effluent
Start Date: 02/20/90
ACUTE TOXICITY
Fisher's Exact Test is used to analyze the data to determine if the
mortality among the effluent test organisms is significantly greater
than among the controls.
The effluent caused no significant acute toxicity.
CHRONIC TOXICITY
Data analysis is dependent upon whether the data is normally distributed
and the control and effluent treatments have equal variances.
The data is normally distributed.
X2= 9.37 (p=0.01)
The treatments have equal variances.
F= 4.99 (p=0.01)
(Chi Square Test)
(F Test)
Because the data meets the assumptions of a parametric test,
the t Test is used.
't' Value:
Critical Value:
4.06
2.508
Because the calculated 't' value exceeds the critical value,
the reduction in reproduction in the effluent treatment
is significant, indicating chronic toxicity. (p=0.01)

WATERS CHEMISTRY ANALYSIS
Client: Sandoz Chemical Corp.
Sample Identification:
Start Date: 02/20/90
1.8% Effluent
Dilution Water
Effluent
ID: Mi11iQ Ultra Pure Water & 10% Perrier (10% DMW)
Preparation:
Hardness:
Conductivity:
Aerated 24 Hours
42 mg/L
Conductivity (Sample 1):
Conductivity (Sample 2):
Residual Chlorine:
Test Solutions
CONTROL
63 umhos
4520 umhos
3000 umhos
<0.05 mg/L
D.O. D.O. pH Temp
(mg/L) (% sat.) (C)
Initial 8.3 105% 7.9 25.6
Day 2 (old) 7.9 100% 7.6 25.7
Day 2 (new) 8.3 105% 7.5 25.7
Day 5 (old) 7.9 99% 7.1 25.0
Day 5 (new) 8.3 104% 6.8 25.0
Final 7.1 89% 7.3 25.4
EFFLUENT 1.8%
Initial 8.0 101% 7.5 25.6
Day 2 (old)
Day 2 (new)
Day 5 (old)
Day 5 (new)
Final
7.8 99% 7.6 25.7
8.3 105% 7.7 25.7
7.9 99% 7.1 25.0
8.1 101% 7.1 25.0
7.1 89% 7.2 25.4

RUALITY CONTRC) Li
Client: Sandoz Chemical Corp.
Sample Identification: 1.8% Effluent.
Start Date: 02/20/90
Culture Health:
Sensitivity: Culture organisms were exposed to NaC1 as a
reference toxicant.
The 48 Hour LC50 for this test was • 2.43 g/L.
The mean LC50 value at . this laboratory for NaC1
as a toxicant is 2.06 g/L. Std. Dev.= 0.29
Therefore, the current LC50 value is 1.28 standard
deviation units above the mean. This suggests the
sensitivity of the test organisms was within the
normal range.
Reproduction: The control test organisms produced a mean of
22.67 young over the 7 day test period. The mean
number of young produced at this laboratory for
in-house control tests is 19.93 Std Dev= 2.44
Reproduction levels during this test were 1.12
standard deviation units above the mean.
Therefore, reproduction of the control organisms was
within the normal range.
Test Precision:
Mean Significant Difference (MSD):
The MSD for this test was 6.016 young.
This is the least difference in the number of young
produced by the control organisms vs. the number of
young produced by any effluent treatment organisms
which can be detected as statistically significant.
The ratio of the MSD to the control mean (percent
reduction) for this data is 26.54 percent.
Water Analysis:
Dissolved Oxygen: Some readings exceed recommended limits.
(Limits: 50% to 105%)
Temperature: All readings are within acceptable limits.
(Limits:24°C to 26°C )
phi: All readings are within acceptable limits.
(Limits:G.5 to 8.0)

Effluent Aquatic Toxicity Report Form/Chronic Pass/Fail and LC50 Date 3/`.i/
Paolity
P
x -rJ 1, ) -,r.
Sandoz Chemical Cor. .
Laboratory Performing Test Fm riahs Environmental
Signature of Operator/Lab Supervisor
NI DESU \'(' Pile 11 Cun ily
Mecklenburg
Comments
North Carolina Ceriodapiulia Chronic Pass/Fail Reproduction Bioassay
Control Organism Reproduction
1 2 3 4
Organisinll
5 6 7 8 9 10
11 12.
Start Date: 02/20/90
1! Young Produced
16
21
27
30
19
21
21
18
22
30
25
22
Adult (Wive (D )ead
Treatment 2 Organism Reproduction
EfIIuent% 1.8% 1 2 3 4
# Young Produced
Adult (L)Ive (D lead
1st sample
Control
pH
Treatment 2
Control
).0.
1Yeatment 2
7.9
rganIsm11
5 6 7 8 9 10 11 12
9
3
3
5
13
6
5
3
6
24
17
20
Chronic Test &fiats
•
CALCULATED "T" 4.06
%Mortality
ox
Control
Avg.Reprod.
22.67
Control
O.
TreatIllent 2
9.92
Treatment 2
% control
organisms
producing
3rd brood
75:
PASS FAIL
1�
Check One
7.1
7.'.
7.•
s e
ta
n
r d
t
1st sample
8.
3 7.
8'.
0 7.
1st sample
7•.°
7.1
7.1
7.1
2nd sample Complete This For Either Test
6.8
7.3
7.1
7.2
s s
t e t e
a n a
n
r d r d
t t
1st sample 2nd sample:
8.Z
7.5
8...
7.5
8.3 7.1
8.1
7.1
;.C50/Acute Tonicity Test
viortallty expressed as %, combining replicates)
Collection (Start] Date
Sample 1 2/19/90 sample 2/22/90
SamoleType/Du rat ion
Sample 1
Sample 2
_Grab
Comp.
Duration
X
24 hr
X
24 hr
41.
O
I-ardness(mg/1) 42-y.<::v:• .:t.u~.r'`
•Spec.Cond.(grnhos)
Chlorine(mg/1)
Sample temp. at receipt
63 4520
• " ---- tc v. JT
c0.91
° 4°C
Ok
u'/o'
°io
°o
%
%
UV
Concentration
Mortality
start/end
LC50= °r6
95% Confidence Limits
0/0
Method of Determination
Moving Average ❑
Spearman 'tuber ❑
Probit ❑
Other • •
Mail original to:
TT: Environmental Sciences Branch
Dtv.of Environmental Management
N.C. Department of EHNR
P.O. Box 27687
Raleigh, N.C. 27611
DEM form AT-1 (3/87) rev.9/89
Note: Please
Complete lids
Section Also
start/end
Control
High
Conc.
pii
D.O.
Organism Tcstcd

EflWRI GHT
ENVIRONMENTAL
MINI CHRONIC PASS/FAIL
C E R I O D A PH N I A TOXICITY TEST
Client: Sandoz Chemical Corporation
Location: Charlotte, North Carolina
County: Meckelenburg
Identification: 1.8% Effluent
Test Initiation: 02/06/90
Enwright Environmental Consulting Laboratories. Inc.
(25 Woods Lake Rd. 29(307) PO Box 17467 Greenville, SC 29606 803 235-0707

INTERPRETATION OF RESULTS
This toxicity test was conducted to determine if the effluent at
the given concentration (the in -stream waste concentration - IWC) causes
death (acute toxicity) or reduction in the reproduction of the test
organisms (chronic toxicity) during a seven day period. Acute toxicity
is checked by statistically analyzing whether significantly more
organisms died in the effluent treatment than in the control treatment.
Chronic toxicity is checked by statistically analyzing whether
significantly fewer young were produced by test organisms exposed to
the effluent treatment. If either analysis indicates a significant
difference, the .test, is considered. a failure. Results are summarized
as follows:
Acute Toxicity: No significant acute toxicity by Fisher's Exact Test.
Chronic Toxicity: No significant chronic toxicity by t Test.
Final Result: Pass
NOTE: On the test initiation day a small ethanol spill caused
a backup of fumes from the drain into the incubator room.
As a result, the control organisms did not reproduce well
enough to meet minimum criteria and the test was repeated.
The test data should not be considered valid to make
statistical comparisons between the control and the IWC treatment.
However, results do indicate a lessening of chronic toxicity
as compared to the previous quarter.

TEST SYSTEM
Client: Sandoz Chemical Corporation
Test Start Date: 02/06/90
Test Completion: 02/13/90
Test Type: 7 Day Chronic Toxicity - Pass/Fail
Test Location: Enwright Environmental Consulting Laboratories
(NC Certification #: 010)
Test Organism: Ceriodaphnia dubia Source: Enwright
Age: <24 hrs
Test Procedure: Short -Term Methods for Estimating the Chronic Toxicity
of Effluents and Receiving Waters to Freshwater Organisms.
EPA 600/4-89/001 Method 1002
North Carolina Ceriodaphnia Chronic Effluent Bioassay
Procedure. NC Dept of Nat. Res. and Comm. Dev., DF.M, Water
Quality Section. December 1985. Revised September 1989
Test vessels: 20 ml plastic beakers
Amount Test Soln: 15 ml / replicate
# Replicates/Concentration: 12
Test Organisms/Replicate: 1
Test Dilutions Used: 0 & 1.8% Effluent
Test Solution Renewal: Day 2 & Day 5
Test Solution Treatment: None
Food Source: 0.10 ml Selenastrum (3.0-3.5 x 107 cells/ml)
and 0.05 ml YCT daily / test vessel
Test Set By: Joel Stephens - Biologist
4f�h
Test Results Checked By: Robert W. Kelley, Ph.D
Biology Laboratory Manager

SAMPLING I N FORMAT I ON •
Two effluent samples were collected in plastic liter -size
cubitainers for use in this toxicity test. The effluent samples were
collected by on -site personnel and shipped to Enwright Environmental
Consulting Laboratories by overnight, delivery. The samples were chilled
during shipping.
Client: Sandoz Chemical Corporation
Date: 02/06/90
Sample Sample
#1 #2
Lab # Bio 387 Bio 390
Type composite composite
Dale sampled (Composite started) 2/5/90 2/8/90
Time sampled 0700 0700
Days of use Init,Day 2 Day 5
Maximum hold time: 72 hrs 72 hrs
Temperature upon receipt: 1°C 4°C

aHs CJLrrS
Client: Sandoz Chemical Corporation
Sample Identification: 1.8% Effluent.
Start Date: 02/06/90
ACUTE TOXICITY (Effects on Survival)
# organisms dead - control: 1 % dead: 8.3%
# dead producing young: 1
# organisms dead- effluent: 1 % dead: 8.3%
# dead producing young: 1
# males & # lost - control: 0
# males & # lost- effluent: 0
No significant acute toxicity by Fisher's Exact Test.

WATER CHEMISTRY ANALYSIS
Client: Sandoz Chemical Corporation
Sample Identification: 1.8% Effluent
Start Date: 02/06/90
Dilution Water
ID: Mil1iQ Ultra Pure Water & 10% Perrier (10% DMW)
Preparation: Aerated 24 Hours
Hardness: 45 mg/L
Conductivity: 88 umhos
Effluent
Conductivity (Sample 1):
Conductivity (Sample 2):
Residual Chlorine:
Test Solutions
CONTROL
Initial
Day 2 (old)
Day 2 (new)
Day 5 (old)
Day 5 (new)
Final
4910 umhos
6520 umhos
<0.05 mg/L
D.O. D.O. pH Temp
(mg/L) (% sat.) (C)
8.3 106% 7.4 26.0
7.5 95% 7.2 25.9
7.8 99% 7.3 25.9
7.1 90% 7.1 25.8
7.6 96% 7.3 25.8
EFFLUENT 1.8%
Initial 8.3 104% 7.3 25.2
Day 2 (old) 7.3 92% 7.2 25.9
Day 2 (new) 8.2 104% 7.2 25.9
Day 5 (old) 7.4 94% 7.0 25.8
Day 5 (new) 8.1 .103% 7.0 25.8
Final

v A.L1Z'y C t`T PoL
Client: Sandoz Chemical Corporation
Sample Identification: 1.8% Effluent
Start Date: 02/06/90
Culture Health:
Sensitivity: Culture organisms were exposed to NaCI as a
reference toxicant.
The 48 Hour LC50 for this test was . 2.29 g/L.
The mean LC50 value at this laboratory for NaC1
as a toxicant is 2.02 g/L. Std. Dev.= 0.25
Therefore, the current LC50 value is 1.08 standard
deviation units above the mean. This suggests the
sensitivity of the test organisms was within the
normal range.
Reproduction: The control test organisms produced a mean of
12.00 young over the 7 day test period. The mean
number of young produced at this laboratory for
in-house control tests is 19.93 Std Dev= 2.44
Reproduction levels during this test were 3.25
standard deviation units below the mean.
Therefore, reproduction of the control organisms was
outside the normal range.
Test Precision:
Mean Significant Difference (MSD):
The MSD for this test was 6.447 young.
This is the least difference in the number of young
produced by the control organisms vs. the number of
young produced by any effluent treatment organisms
which can be detected as statistically significant.
The ratio of the MSD to the control mean (percent
reduction) for this data is 53.73 percent.
Water Analysis:
Dissolved Oxygen: Some readings exceed recommended limits.
(Limits: 50% to 105%)
Temperature: All readings are within acceptable limits.
(Limits:24°C to 26°C )
pH: Some readings exceed recommended limits.

•
Sandoz Chemicals Corporation
Mount Holly Plant
Safety and Environmental Department
Memo No: MOO5C-90
To: P. Straley
cc: S. Hill
From: B. Dunbar
Date: Feb. 20, 1990
Subject: Planned Work Agenda for In-house Chronic Toxicity
Pass/Fail Testing
The planned work agenda for in-house
testing of Sandoz wastewater/process streams, as
Hill and myself, is shown below. The planned
will permit us to systematically identify as
possible, the streams thought to be toxic.
chronic toxicity
developed by S.
agenda, we feel,
expeditiously as
Each weekly run of tests will be conducted as follows:
. 3 sets of 12 vials, total of 36 vials per weekly run
. each set of 12 vials will consist of the following:
• 1 vial - blank
▪ 2 vials - 0.5% test stream composite
. 3 vials - 1.0% test stream composite
▪ 3 vials - 1.5% test stream composite
• 3 vials - 2.0% test stream composite
. sets will be identified as A,B,C
. date of sample composite will be recorded
: stream composites will ordinarily be taken on Mon., Wed.,
Fri. so as to capture concentration variance expected from
normal manufacturing operations
The planned agenda for testing:
week
week
week
week
1 (2-19
2 (2-26
3 (3-05
4 (3-12
to 2-25) -
to 3-04) -
to 3-11) -
to 3-18) -
Final Effluent Composite
Acid Waste Stream
Alkaline Waste Stream
Study results of weeks 1,2,3 ...
Target plant streams thought to be
indicated by any fail test result
if acid stream fails test, then test protocol is to be:
1 - Bldg. 16 Acid Stream (Nitroso, Carbazole indo, etc.)
2 - Bldg. 46 Acid Stream (Nitro -AAA, etc.)
3 - Bldg. 45 Acid Stream (Nofz, solvents, etc.)
Page 1

a
•
MOO5C-90
Feb. 20, 1990
Page 2
4 - Bldg. 09 Acid Stream (DNCB, Picric acid, MCB, etc.)
5 - Bldg. 39 Acid Stream (PSA, Green 2G base, DCMA)
if alkaline
be:
1 - Bldg.
2 - Bldg.
3 - Bldg.
4 - Bldg.
5 - Bldg.
6 - Bldg.
stream fails test, then test protocol is to
•40 Alkaline
16 Alkaline
09 Alkaline
46 Alkaline
48 Alkaline
32 Alkaline
Stream (Dyes, Thiosulfate, AAA, etc.)
Stream (Dyes, Rotary melts, etc.)
Stream (DNP, etc.)
Stream
Stream (Dyes, Metal compounds, etc.)
Stream (Dyes, chemicals, etc.)
Other target test protocol is:
1 - Cooling tower water, Bldg. 16
2 - WWTP streams at different stages between
final effluent where impact of chemicals
or degraded is thought to impact chronic
influent and
added, reacted,
toxicity
The planned test agenda and protocol is based on present
notions that may or may not yield expected results. The planned
work agenda provides a good basis for startup of the in-house
program. Consideration of test data in conjunction with a
flexible work agenda should permit a good understanding of the
toxic nature of the Sandoz Mount Holly process and wastewater
streams in due time.
41,4„
B. Dunbar

TO:
FRU�:
Su8JECT:
DATF:
SAmDOZ/MT L L.Y ENVIRONnENTAL AND SAFETY DEPT
nF.MOR.ANDUn
Rav mocvrzoae. |==::.mztn
J^ Pazqe 6trale`
przorz-cv po11 utqy
�es�zng m
Jan 2z, �989
anu cnronzc toxzczTv effluent
Ac cne requesc oth -Cne �� ly piaoc zs oozng a serzes
of testzny on our e++j.uenwe wz1.1 tie testznl:.y tr*te thzro weex zn
Jaouary ano also uurzng �ne c�zro weex zn Feoruarv^ The
was'CewaT,er 'UreaT,(Ti enn oianT I oPeranznq ve,v weil ior tnzs tzme
oT vear, so tne January tesnzno wzi1 gzve an zopa o� our orzorz�v
poiJ.onant sT,a*cus ourzng C(000 exoect toe
crea'tment wzi1 oeerzora�e zn Feoruary as warer temperatures
oec�zne �rzver w�er nempera�orecon�rol�zno �ac�or`. so
�ne Fenrua/`y ces�zn� wzii ozve os a p'zorz�v Poi1o�ann stacus �or
`oresvmaoi»` voon*r,er ooeranznn^
� ma�or con�ern �nar nnzs tes�1og wz1i answe, is wnecner t�e
pian� can meez ur000seo ozscoar�e stanoaros zn tne Feuerai
er riuenc auzoeiznes for- the Urganzc ��emzcai znoustry (UCP6F
quz�eiznes/ our,n� wznter operat�n� conoit�ons. we also expect
tnan a cnronzc T,oxzcztv tesT, wzil »e one of t n e terms of our new
wastewa�er ozscna'�e �mPDE6) Permz�^
'
J. �ne answers are zn �ne ne�anzve, we mav �ave to low::at
�ranuiar ac7,zvaT.eo carj:,,on zreatment of art or all of our
effiuent^ ln anv case, the clata wz1l be an zmoorr,ant ParZ of our
ionq ranue PJ.annznr-f for cpntznueu compizance wztn ozsce
1J.mzczons^
Fznai1v, trizs rouno o-r tesTzng wi.11 also 1oox at the s1udge we
put zn our sLooge 1andzils^ we nave some �azrlv iarge num�ers
�or tne tons of certazn orqanzcs �nat are ca1leJ oun our 6ARA
rePort^ w.e useo EPA auzoeiznes tor-- estzmatzng tnese num�ers^
The auzoe1znes aimost, cerTazniy give large over—esTzmates, so we
t ito provzoe more apnroprzate
are oozng some o�rec samp zn �
,eoorczng �or our SAHA emissions znventorv^
Tne sa(np)zn1:1 ano testznu sc�eooie wz]l oe as �ollows:
Cn,00zc �oIx, zczTv: Tnzs wzl1 be uooe oy Enwrzgnt Labs,
6rnvzlieam
. SC^ Soies wzil be coIiected Jan
eeuary 25 anu
comooszT�en. ano sent no t n e lao. 11-1e fvrtner samole
�z�l �e sen�noss�*ie. t�e samp�es
�nemseives snaii be �rom cnp e��iuenc comonsz�e samPer~
�nncn
�''er� rnnxc �oxzcztv nestPara�le� tn tne
Fenrvary or1or1tv oniionan� scans^ T^e cosn �s ���0 oer cest
v�us so�nr�o� nf sam»ies^ (.ne n+ topse cn,onzc to»�cz�v
tesT,s zs present1v eouzreo eacn ouarTe/` accordzng 1;0 our
exzsT,zDE6 permzt.^

^
oage cwo
January
prIorI�v oo�iotan�s^ The analvses wzil be uone my 6enera]
Engzneerzng Laos of Cnar1eston. SC- Composite eff1uent
samP�es wzli tie taxen on January T�ey wzll �e
shzppeo eacn oav to.Genera1 Enqzneerznq^ The testing will
oe oer�o�meo �o}` przorzty 1:1011utant volatzIes, acId
ex�ractao1es. anu oase'neuural extractao1es^ A secon� rounc!
o� tes�zn� wz�l �e oone approxzmatelv Feoruary 24, 25, aod
2(,^ All a1yszs wz11 cos� per samPie <total $48�)0), p1us
snzpp:1ntj^
luuqe a1-1 �a1vszs^ A �our—ounce samp1e o� siuuge �rom a
/ repuiar run off �ne bel� fzi�er oress macnznes wzil �e
cauqn� eacn Tnursoav for cnree weexs. �egznnzng January t.L.:.^
6amoies wIii oe sT,oreo zn T n e ref-ri -.:Ierator ac apprn:zma�eiy
4 C^ A�te, cne '17,nz,u samo�e �s naxen, a1i tn,ee samPies
zceo cno�er to 6ene,al En�zneer�nu La�s
Ana1vszs wzii he �o' ace�nne.
`
/
/
' ToT,a1 coss wory wzi1 oe oius snzpp1og^
�or comoosszs^
xv�ene. ano ca,nzroi^ imr cosr w�ii oe �o50 pius �»�Pnzn�^
/ dDareo �W^ �rcoer^
/
/ 8o�cu/ 8raoiev wzi1 oe zn cnarge of maxznq sure tnat tne samoles
' are scneou�eo. sampizn� zs oone properlv, cr/azn of custouv zs
mazncazneu, tne samples are 1oggeo on trle envzronmenna1
oeparnmen� sampie io�. and tnet t�ev are properl� s�zppeu^
^
/
In
^

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 9, 1990
MEMORANDUM
TO: Mike Parker
()-/
THROUGH: Trevor Clements
FROM: Ri[th Swanek !4,5
SUBJECT: Sandoz' Additional DMR to Determine Compliance with
Staging Requirement
NPDES No. NC0004375
Mecklenburg County
I have attached a draft of an additional DMR page which can be
used to determine Sandoz' compliance with its summer staging
requirement for BOD and ammonia. (Note: this form is also
attached to the revised NPDES approval form). I showed the form to
staff of the Compliance Group here, and they stated that they will
not be able to key the different cases into the computer. They
also stated that it may be better to have three DMR sheets for each
summer month, one for each river flow scenario. Using three sheets
allows a monthly average to be calculated under each flow regime.
However, under the new permit, the facility must meet a monthly
average BOD5 limit of 852 lb/d and a monthly average NH3 limit of
651 lb/d regardless of the daily flows. Therefore, the three cases
should be treated equally when determining the monthly average lim-
its.
Since the regional office reviews the submitted DMRs, I wanted
you or someone in your office to review the form. You may have
thoughts on a better format to determine compliance or you may
think that three additional forms may be better for each month. If
you have any changes or suggestions, please contact me.

Additional DMR Sheet for Sandoz
EFFLUENT
NPDES Permit No. NC0004375 Discharge Month Year
Sandoz Class 4 Mecklenburg County
Operator in Responsible Charge (ORC):
Certified Laboratory:
Person(s) Collecting Samples:
Check if ORC has changed
I certify that this report is accurate and
and complete to the best of my knowledge.
River Allowable Actual
Qw Flow BOD5 NH3 BOD+.54NH3 BOD+.54NH3 Comp?
Date Time (mad) ACJIL (lb/d) (lb/d) (lb/di (lb/d) Case (Y/N)
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
Average
Case 1: River Flow <= 175 cfs BOD5 + 0.54NH3 <= 566.4 lb/d
Case 2: 175 cfs<River Flow<= 250 cfs BOD5 = 0.54NH3 <= 1044 lb/d
Case 3: Riv. Flow>250 cfs, BOD5<=852 lb/d (mo avg), BOD5<=2236 lb/d (dly max)
NH3<=651 lb/d (mo avg), NH3<=977 lb/d (dly max)

LAW OFFICES
OGLETREE, DEAKINS, NASH, SMOAK AND STEWART
A PARTNERSHIP INCLUDING PROFESSIONAL ASSOCIATIONS AND PROFESSIONAL CORPORATIONS
SUITE ONE HUNDRED
3724 NATIONAL DRIVE
POST OFFICE BOX 31608
RALEIGH, NORTH CAROLINA 27622
[phone]
JAMES M. KUSZAJ, Ph.D.
PARTNER
William Archer
Director, Environmental Affairs
Sandoz Chemicals
4000 Monroe Road
Charlotte, North Carolina 28205
Dear Bill:
OTHER OFFICES:
GREENVILLE. SOUTH CAROLINA
WASHINGTON, D. C.
ATLANTA. GEORGIA
COLUMBIA. SOUTH CAROLINA
NASHVILLE. TENNESSEE
ALBANY. GEORGIA
SPARTANBURG. SOUTH CAROLINA
SCHENECTADY, NEW YORK
You have asked for our initial opinion on certain general questions
concerning your pending NPDES permit. I have briefly summarized our conclusions
below. We would be happy to research any of these questions in more detail if you
feel that is necessary. If you have any questions, please give me a call.
QUESTION 1
Can an NPDES permit be issued with both mass limitations and
concentration limitations for the same pollutant?
ANSWER 1
Yes. The NPDES regulations for calculating NPDES permit conditions, (40
C.F.R. § 122.45(f)(2)), specifically provide that "pollutants limited in terms of mass
additionallymay be limited in terms of other units of measurement, and the permit
shall require the permittee to comply with both limitations". However, the NPDES
regulations also express a strong preference for mass limitations. Specifically,40
C.F.R. § 122.45(f)() requires all pollutants limited in a permit to have limitations
expressed in terms of mass unless one of the three following exemptions is
demonstrated:
1) the pollutant (e.g. pH, temperature) cannot appropriately be
expressed by mass;
2) the applicable standards are expressed in terms of other units of
measurement; or
3) limitations expressed in terms of mass are infeasible because the mass
of the pollutants discharged cannot be related to a measure of
operation.

William Archer
Sandoz Chemicals
February 27, 1990
Page 2
For the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)
industrial category, the November 5, 1987, effluent guidelines state that the permit
limitations should be expressed as a mass limitation.
'The limitations promulgated today are concentration -
based and thus do not regulate flow. The permit writer
must use a reasonable estimate of process wastewater
flows and the concentration limitations to develop mass
limitations for the NPDES permit".
52 Fed. Reg. 42566 (emphasis added)
QUESTION 2
What is the deadline for compliance with the permit limitations contained in
a newly issued NPDES permit?
ANSWER 2
It depends on whether the limitations are water quality based or technology
based. Compliance dates for water -quality and technology -based limitations are
generally governed by the statutory deadlines in Section 301 of the federal Clean
Water Act (CWA). Facilities that discharge toxic pollutants into water bodies listed
by the state as "impaired" under paragraph B of Section 304(1) of the CWA are
additionally regulated.
For technology -based effluent limitations (such as those applicable to the
OCPSF category), Section 301(b) of the CWA provides that a facility must be in
compliance "as expeditiously as practicable but in no case later than three years
after the date the requirement is promulgated or established, and in no case later
than March 31, 1989. This date has obviously passed for your facility. To deal with
this problem, the conference report accompanyingthe Water Quality Act of 1987
(which imposed the March 31, 1989 deadline) states that if a discharger is unable to
meet the March 31, 1989, deadline as a result of the Administration's failure to
promulgate effluent limitations in sufficient time to allow for compliance, then such
non-compliance should be dealt with under EPA's current post-1984 enforcement
policy. That policy calls for the permit issuing authority to issue the NPDES permit
containing the statutory date but to simultaneously:
issue an administrative order to the non -complying
company which specifies a schedule of compliance as
expeditiously as practicable, but not later than three

William Archer
Sandoz Chemicals
February 27,1990
Page 3
years after permit issuance. H.R. Conf. Rep No. 1004,
99th Cong., 2d Sess. 115-116 (1986) (emphasis added)
The permit -issuing agency must use an administrative order, in lieu of a
compliance schedule in the permit, where the statutory deadline has been past. In
North Carolina, an administrative order is known as a Special Order on Consent
(SOC) and would be issued pursuant to N.C.G.S. § 143-215.2.
Inyour present situation, since the plant is subject to the technology, based
effluent limitations for the OCPSF category, you could ask for a SOC extending the
compliance deadline up to three years from the date the permit issues.
With respect to water -quality based effluent limitations, the question of the
applicable compliance deadline is less clear. Some EPA Regions have taken the
position that such standards are effective immediately. However, EPA/Washington
has not established a policy as to whether compliance with water quality standards is
required immediately. Section 301 of CWA supports the position that compliance
with water quality standards are not required immediately but that a schedule of
compliance can be specified in the NPDES permit. Specifically, Section
301 1 c of the CWA provides that a facility shall achieve compliance
"not later than July 1, 1977, [with] any more stringent
limitations, including those necessary to meet...a
schedule of complaince...required to implement any
applicable water quality standard established pursuant
to this Act.
Moreover, EPA has stated that
"effluent limitations based upon newly developed water
quality standards or new interpretations of existing
water quality standards, may be covered by compliance
schedules in the NPDES permit.
54 Fed. Reg. 37372
In your present situation, you should maintain that you have a "reasonable" into to come compliance with a water quality based limitation and ask for a
reasonable compliance schedule in the NPDES permit. This schedule of
compliance would be part of the NPDES permit itself and not part of a Special
Order on Consent.

William Archer
Sandoz Chemicals
February 27,1990
Page 4
Finally, there is a statutory compliance deadline applicable to "impaired
waters" identified under the "toxic hot spot" provisions to Section 304(1) of the
CWA. For such impaired waters, compliance with water quality based effluent
limitations must be achieved so as to assure compliance with state water quality
standards by June 4,1992.
QUESTION 3
Are taste and odor for phenol aesthetic parameters for purposes of 15 NCAC
.0206?
ANSWER 3
Yes. The applicable state regulations and statutes do not define "aesthetic
parameters". However, EPA considers the "taste and odor" quality of water to be
aesthetic qualities. For example, EPA derived the taste and odor water quality
criterion for phenol from available organoleptic data. With respect to such data,
EPA states: "criteria derived solely from organoleptic data are based upon aesthetic
qualities only". 45 Fed. Reg. 79318. In establishing standard maximum contaminant
levels pursuant of the Safe Drinking Water Act, EPA also clearly identified taste
and odor as aesthetic parameters when it stated�� that it was concerned about
"expected aesthetic effects (primarily taste and odor) . 54 Fed. Reg. 22062
QUESTION 4
Is there any restriction in using the 3002 flow for aesthetic parameters in a
flow regulated stream pursuant to 15 NCAC .0206?
ANSWER 4
No. For a flow regulated stream, the only limitation on flow design criteria is
found in 15 NCAC .0206(b). That section allows a minimum daily flow to be used
as a substitute for the 7Q10 flow. On its face, 15 NCAC .0206(b) does not address
or otherwise limit the use of 30Q2 flow.
QUESTION 5
If the permit limitations in the final permit are unacceptable, how do we
appeal the decision?

William Archer
Sandoz Chemicals
February 27,1990
Page 5
ANSWER 5
When the final permit issues, you have 30 days to file for a "contested case"
hearing. Such a hearing is a formal trial -type hearing before an administrative law
judge where you can contest each condition of the permit that is unacceptable. The
filing of a contested case hearing prevents the contested provisions of your permit
from going into effect.
Sincerely,
OGLETREE, DEAKINS, NASH,
SMOAK AND STEWART
James M. Kuszaj
JMK/lg

LStnrtoz,
Q3o834
(Sandoz r5ua.sled Conc. For 1 p/rrth f' te. ta&ci
100)e,4 'Glow ncc Can ?Ortfra/ arncw2/ dischea,cce ec2sI/ j. .Sncc
Itt)C = I.8 % .5hoo.ld not <slu jc Stream c re%te,51- (seems re yr able.
4)111 !.(,fie aueRCQe ct3clxt,c c. e lean 5/nP- 41/99 tb ci ciri/ftc /m b
0.4
GsoePtA'10-V-
tbld hind _ , Ozz IbIdaj = 1.319 tJJ
phenols = I. Ibis' = IOS ,u�cl,P
JFF I owls cry) 8e,t Worn 0.5 1-16D c,K, Su ynrn .
lit! ethical. at 0.5 /460 Go cod I
. 02.2 Ibld = ,3 I� . �3uf 0a cn kt on
= Sandoz wiihao conc. hduu 11-inan ?. (! 411 .c.I wilt have
fo mild a d;flier (2.2x)
AWL): 1.7 Ib(d = 4/32 dug/
coal I haLA!. fD ,Mej,f Vaud 3WdiJtto ;dual pitepg .

DIVISION OF ENVIRONMENTAL MANAGEMENT
February 20, 1990
fri6
•
FF 1'E
MEMO TO: Lula Harris /
f.
FROM: Julia Storm
SUBJECT: Sandoz Permit Comments Regarding APAM Requirement
The questions raised by Sandoz concerning the Annual
Pollutant Analysis Monitoring (APAM) requirement are addressed by
a memo (currently in draft form, to be distributed shortly)
clarifying several aspects of the APAM requirement. Although not
specifically referenced, many of the elements of the procedure
outlined in Sandoz's comments have been incorporated into the
instructions and clarifying information to be issued to all
affected parties in the near future. The APAM reporting form has
also been revised to include information critical to determining
the confidence level of "significant peak" identifications and
information that will facilitate any further identification
efforts. A copy of this section of the draft revised form is
attached. _lease request that Sandoz provide me with the full
reference (title, au or, repor , p 'cation date) for the EPA
Contract Laboratory Program protocol so that it may be included
in the memo referred to earlier. If there are other questions,
please let me know.
JS/kls
Harris.mem/D-1
Attachment
cc:
Greg Thorpe
Dale Overcash
Ruth Swanek
NECEIVED
J U L 2 7 1991
CENTRAL FILE COPY

When daily average river flow is calculated to be
>175 cfs but 5_250 cfs:
Lbs BOD's + [0.54 x (Lbs NH3-N)] 51044
UPSET PROVISION - We request that an upset provision be included in the
permit to indicate that exceedance of any limits does not constitute a
violation if it can be shown to be caused by an upset condition in the
treatment system.
SECTION H: APAM REQUIREMENT
Sandoz' primary concern with regard to the APAM requirement is the
lack of specific guidance in identifying and quantifying the largest 10
GC/MS peaks. The APAM Requirement Reporting Form A states that
"appropriate EPA approved methods" shall be used to meet monitoring
requirements. Such methods for routine GC/MS analysis for listed
substances are well established and codified. However, specific methods
for identifying and quantifying unknown peaks are not as well
established. Sandoz requests that a protocol for such analyses be
specified in the permit. Without a mutually agreed -upon protocol, the
identification and quantification of unknown peaks becomes highly
arbitrary and may vary between analyses.
In order to meet the "10 significant peaks rule" requirement, Sandoz
proposes to use EPA's Contract Laboratory Program protocol for reporting
tentatively identified compounds from GC/MS analyses (see Attachment #2,
Tasks III and V). This protocol establishes checkpoints and limits by
which matches of unknown spectra to reference library spectra are
considered significant and reportable. It also firmly establishes a
quantification scheme which provides a consistent basis for estimating
concentration. Sandoz proposes that this methodology be included in the
permit and/or specifically referenced by this section of the permit.
Doing so will establish an unambiguous and reproducible protocol which
will ensure the highest possible accuracy in identifying and quantifying
unknowns.
Because the results of the APAM requirement will become public
record, Sandoz requests that the limits of the detection and
quantification technology used to determine unknown peaks be included in
any documents made available to the public.
Again, Sandoz appreciates the opportunity to supply these
comments and looks forward to meeting with you to discuss them.
Attachments
cc. Mr. Dale Overcash
Sincerely,
W. M. Archer t< GOVED
JUL 271991
CENTRAL FILE COPY

OM:SANDO2 MT HOLLY PLT
TO:MR-EXEC
SECTION II
sPEC FIc REQTIREMENTs
A. For each sample, the Contractor shall perform the following tasks:
JAN 19, 1990 8:51AM 4468 P.03
ti v
ISiS,..I: Receive and Prepare Hazardous Waste Samples,
1. Receive and handle samples under the chain -of -custody procedures
described in Exhibit P.
2. Prepare samples as described in Eachibit P. VOA analysis of water
or soil samples must be completed within 10 days of VTSR (Validated
Tice of Sample Receipt). If reparatory funnel or sanitation
procedures are employed for extractions for semivotatile and
pesticide analyses; extraction of waver samples shall be completed
within 5 days of VTSR, and extraction of soil, samples shall be
completed within 10 days of VTSR. If continuous liquid -liquid
extraction procedures are employed, extraction of water samples
'shall be started within 5 days of VTR.
Extracts of either water or soil samples must be analyzed Within 40
days of VTSR. This does not release the Contractor from the data
tttrnarourd, time specified in Exhibit B, Section I,
Extraction and Analysis for Identification of Specific
Organic Compounds.
1. txtracts and aliquots prepared it Task I shall be analyzed by GC
and CC/MS techniques given in Exhibit D for the target compounds
listed in Exhibit C.
2. The target compounds listed i.zt Exhibit C shall, be £dentified as
described in the methodologies given in Exhibit D. Automated
computer programs may be used to facilitate the identification.
Task 'ilj: Qualitative Verification of the Compoundnti fled• in
Task II.
1. The compounds Analyzed by CC/MS techniques and initially identified
in 'Cask i shall be verified by an analyst competent in the
interpretation of macs spectra by comparison of the suspect mass
spectrum to the muss spectrum of a standard of the suspected
compound. Two criteria must be satisfied to verify the L identifications: �.��'� L�
a. Elution of the sample component at the sane GC relative j ui 2,7 1991
retention time as the standard component, and
CENTRAL FILE COPY
b. Correspondence of thetjsample component end standard component
'Ass xpnCtza. This procedure requires the use of multiple
internal Standards,
A-4
2/88

OM:SAND03 MT HOLLY PLT
TO:MR-EXEC JAN 19, 1990 8:53AM 4468 P.06
2. For establishing correspondence of the GC relative retention time
(RRT), the sample component RRT must compare within ± 0.06 RRT
units of the RRT of the standard component. For reference, the
calibration standard must be run on the same 12-hour time period as
the sample,
For comparison of standard and sample component mass spectra, Maas
spectral obtained en the Contraato 's GC/MS are required_ once
obtained, these standard spectra may be used for identification
purposet only if the Contractor's GG/NS meets the DFt2P or BfS
daily tuning requirements of Tables 1.1 and 1.2 in Exhibit E. The
standard spectra used may be from a laboratory generated library on
the same -instrument or obtained from the calibration standard run
used to obtain reference RRTs. The requirements for qualitative
verification by comparison of ass spectra are as follows: -
a. All ions present in the standard.mass spectrum at a relative
intensity greater than 10 percent (most abundant ion in the
spectrnm equals 100 percent) fin' be present in the sample
spectrum.
b. ' The relative intensities or ions specified in (1) must agree
Within plus or minms 20 percent between the standard and
sample spectra.
0. Ions greater: than 10 percent in the s.amole spectrum but not
present it. the 1standard spec rum must be considered and
accounted for by the analyst making the comparison. When
cc/MS computer data processing programs are used to obtain the
sample component spectrum, both the processed and the raw
spectra squat be evaluated. In Task III, tiha verification
process should favor false positives.
3. If st compound analyzed by CC/iis techniques and initially identified
in Tozk II cannot be verified by all of the criteria in items 1 and
2 above, but in the technical, judgement of the mass spectral
Interpretation specialist the identification is correct, then the
Contractor shall report that identification, and proceed with
quantification in Task IV.
4, The pesticide/PCB compounds listed in Exhibit C and analyzed by
GC/EC techniques shall have their identifications verified by an
analyst competent in the interpretation of gas chromatograms. Two
criteria must be satisfied to verify the identifications:
a. Elution of the sample component within tho retention time
window.(established by the procedures in Exhibit E) of the
standard component analyzed on the same GC column and instrument, as part of the same 72-hour analyt:ica1 . 4V _ �D
specified in Exhibit: D PEST. 0�►
JU! 271991
CENTRAL FILE COPY
A-5 2/68

ROM:SANDOZ MT HOLLY PLT TO:MR-EXEC JAN 19, 1992 6:52AM 4468 P.05
b.
Analysis of the sample and standard one second CC column with
a stationary phase, with retention characteristics dissimilar
to that used in a. above,, and meeting the same criteria for
elution of the sample component and the standard as in a.
above.
Task 2V: quantification of Compounds Verified in Task III.
1. The Contractor shall quantify components analyzed by GC/MS
techniques and identified in Task II and verified in Task III by
tha internal standard method stipulated in Exhibit D. Whsre
multiple intosnal standards are required by EPA, the Contractor
shall porfora' quantitatiozs utilizing the internal standards
specified in Exhibit E, Paxt•2, Tables 2.1 or 2.2,
2. The, Contractor shall determine reaponsa factors for each 12•hour
time period of GC/MS snalysia and shall include a calibration check
of the initial five point calibration as described in Exhibit E.
S. The Contractor shall quantify components analyzed by GC/EC
,techniques and identified in Task II and verified in Taak III by
'the, external atimaArd method stipulated in Exhibit A FEST.
4, The Contractor shall perform an initial three-point calibration,
verify its linearity, determine the degradation of labile
components, and determine calibration factors for all standards
analyzed by GC/EC techn.iquag as part oe a< 72-hour analytical
sequence, as described in Exhibit D FEST and Exhibit E.
Task V: Tentative Identification of Non-TCL Sample Components.
1. For each analysis of a sample, the Contractor shall conduct mass
apeetral library searches to determine tacit:. tine compound
identifications as follows. Poi' each volatile fraction, the
Contractor shall conduct a march to determine the possible
identity of the tan (10) nonsurrogate organio ooarpounds of greatest
concentration which Ate nottilisted in Exhibit C. For each
base/neutral/acid fraction, the Contractor shall conduct a search
to determine the possible identification of the (20) nonsurrogate
organic eompounds of greatest concentration which are not listed in
Exhibit C. In performing searches, the 1985 (or most recant)
release of the National Bureau of Standards library (Containing
42,261 spectra) mast be used, NOTE: Substances with respa s s� �''�p
less than 10 percent of the nearest internal, standard aren��EIVE
required to be searchad in this fashion.
JUL 27 199!
Only after-ristial comparison of sample spectra with the s a qr,1e,,.
from the library seazohos will the Bass spectraterpreta + RAL FILE COPY
specialist assign a tentative identification. If the compound does
tot meet the identification criteria of Task III, it shall be
reported as uplcnown. The mA s spectral specialist should givo
additional claasifioation of the unknown compound, if possible
(i.a., unknown aromatic, unknown hydrocarbon, unknown acid type.
A-6 2/88

OM:SANDOZ :IT HOLLY PLT
TO:MR-EXEC JAN 19, 1990 9:51AM 446E P.04
unknown chlorinated compound). If probable molecular wei,ghte enn
be distinguished, ivalude them.
The Contractor shall nu roport as tentatively identified compounds
(TIC) any TCL compounds from another analytical. fraction (i.e,, do
not report late eluting volatile compounds as TICs in tho
R �L{ ›. _� eemivolatile analysis), r
has v;: Quality Assurance/quality Control procedures.
1. All specific quality' assurance procedures prescribed it E hibi.t E
shall be strictly adhered to by the Contractor. Records
documenting the use of the protocol sha17, be maintained in
accordant* with the document control procedures prescribed in
Exhibit F, end shall, be reported in accordance with Exhibit S,
Reporting Requirements, end Deliverables.
2. The Contractor shall perform one spiked sample analysis (matrix-
Mpika) and orLe duplicate spiked sample analysis (matrix spike
duplicate) for each group of samples of a similar matrix (for water
or soil samples) and concentration level (foe' soil samples only),
once;
o each Cate of field samples received, OR
o each 20 samples in a Case, 4R
a each 14 calendar day period daring which field samples in a
Cease were received (said period beginning with the receipt o£
the first sample in that Sample Delivery Croup) ►
whichem _r_e most freautn.
Matrix spikes and matrix spike duplicates shall be carried through
the entire analytical process from extraction to final GC/MS or
CC/EC analysis, including all Contract Performance/Delivery
Requirements (see Contract Schedule).
3. The Contractor shall prepare ,and analyze one labotetory reagent
blank (method blank) for each group of samples of A similar matrix
(for water or soil samples), extracted by a similar method
(separator) funnel or eontinuoue liquid -liquid extraction), and a
esmilax concentration level, (for soil samples only), once:
o each Case of field samples received. Q.
o each 20 samples in a Casa, including matrix spikee and
reanalyses, OR
o each 1.4 calendar day period during which field aamplee in a
Case were received (said period beginning with the receipt of
the first sample in that Sample Delivery Croup), OR ECE1 Y E D
✓ whenever samples are extracted, ••
whichev_eS 5 Mont �MA/Y11pMN
JUL 27 1991
Volatile analysis requires one method blank for each 1XWORAIII4NHOPY
period when volatile TCL compounds are analyzed.
A-7
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SANDOZCHEMICALS
Sandoz Chemicals Corporation
4000 Monroe Road
Charlotte, North Carolina 28205
704.331.7088
Fax: [phone]
William Al. Archer, 111
Director, Environmental Affairs
Ms. Lula Harris
Environmental Engineer I
NC Div. of Environmental Management
512 North Salisbury Street
Raleigh, NC 27611
Re: NPDES Permit No. NC0004375
Sandoz Chemicals Corporation
Draft Permit
Dear Ms. Harris:
642L AA4Mt
WmAi.A.t 74 fuAji,
January 20, 1990
i
JAN ti 1 9U
PERMITS & FWINEERINf:
i
Sandoz appreciates the opportunity to review the preliminary
draft of the permit. The renewed permit, when issued, will result in
major changes to our discharge limits that will require substantial
modifications to our treatment facilities and possibly to some production
operations. We foresee that a Special Order of Consent will be needed at
the same time the new permit is issued to allow interim limits while
facility modifications are designed and constructed.
We have organized our comments by sections in the order that
they appear in the draft permit and also have attached several revised
pages that reflect our proposed changes to numeric limits. We would
appreciate the opportunity to meet with you in the near future to discuss
our comments.
Permit Number - We assume our permit number will not change from
NC0004375.
SUPPLEMENT TO PERMIT COVER SHEET - The description of the plant should
be modified as follows:
Continue to operate a 3.9 MGD WWTP (outfall 001) to treat chemical
manufacturing and domestic wastewater; comprising two basins for
biological waste treatment, stormwater equalization basin for nonalkaline
wastewater, stormwater equalization basins for alkaline wastewater,
gravity secondary clarifiers, acid neutralization, gravity primary
clarifiers, sludge dewatering, effluent polishing pond, staged discharge
facility including effluent storage, and post aeration. Outfall 002,
treating herbicide manufacturing wastewater, discharging to the acid
sewer, thence to the 3.9 MGD WWTP described under outfall 001. All
located at NC Hwy 27 West and the Catawba River, north of Charlotte,
Mecklenburg County (See part III of this permit) and...

(t ( )
LOCATION MAP - A revised map is included to more accurately show the
location of discharge 001.
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
FLOW - Our original renewal application requested a winter flow limit
of 2.6 MGD in order to allow a higher dilution factor when running
chronic toxicity tests during these winter months. As the dilution
factor based on a flow of 3.9 is used year-round in the draft permit, we
request the flow of 3.9 MGD apply year-round.
AMMONIA - In reviewing our ammonia discharge history, we have found
periods when process flow plus release from our effluent storage facility
would result in ammonia discharges above the proposed limits, even though
all other limitations are being met. The ammonia value in our current
permit is limited on the basis of NH3 being an oxygen demanding
substance. On this basis, a specific ammonia limit could be derived from
the current summer BOD/NH3 limits and the proposed BOD limits as follows:
Monthly average NH3 = 2666 - 852
.54
Daily Maximum NH3
= 3359 Lbs
8001 - 2236
.54
= 10676 Lbs
0143 }DX . not Cthvc.
Ibld
(u510mf• 11010))`.
(.22)(32q)t x(62045)= I(335.W5 )
While we do not need limits this high, we do believe the proposed limits
are overly restrictive without a good technical basis.
TOTAL RESIDUAL CHLORINE - Chlorine is not used for disinfection. Thus we
request that the monitoring requirement for Total Residual Chlorine be
deleted.
IRON - We question the need to monitor iron and request that it be
deleted.
SULFATE - As the sulfate is a water quality based limit, we believe a
mass limit is appropriate rather than a concentration limit. If the
concentration limit is used, it should be applied as the monthly average
rather than a daily maximum.
MERCURY - We are not sure how this limit was derived. The water quality
standard of 0.012 ug/1 at the minimum daily average river flow of 329 CFS
would allow .022 Lbs Hg/day discharge. If a limit is included in the
permit it should be a mass limit. However, we believe that Mercury should
not be present in our wastewater and would like the opportunity to
demonstrate this through a sampling program. Analysis of Mercury at the
tenths of a part per billion level in our complex effluent matrix is
quite difficult and imprecise. We believe there is a potential for false
positives that would cause apparent permit violations. We propose that

Mercury be monitored in our effluent for one year, with a permit
condition that would reasonably phase in a limit if Mercury is truly
found at significant levels.
TOTAL PHENOLS - The new Water Quality Standards that took effect in
October, 1989 revised the flow design criteria for effluent limitations
to allow 30Q2 flows as the design basis for aesthetic parameters. We
believe taste and odor causing phenol clearly relates to aesthetic
quality and thus should be limited on the basis of 30Q2 river flow. For
this reason, the permit limit should be no lower than the existing limit
of 1.8 Lbs/day monthly average and 3.6 Lbs/day daily max., monitored
monthly. We also request that the stream sampling for total phenols be
deleted because the sensitivity of the method we use is not suicint to
produce meaningful upstre m/dow steam comppa�riso s . '`)Cagy scab - 00 n lU
C.) .. K7 1 D, ci� u8i u,Ia ocwr, eru nn to do L 4- th
CHRONIC TOXICITY - The wording of the chronic toxicity requirement is
that "no observable inhibition of reproduction" is to occur. Even in the
control samples of Ceriodaphnia reproduction varies. Sandoz suggests
that a more appropriate wording here would be "no statistically
significant inhibition of reproduction..."
There is some question whether Ceriodaphnia is the most appropriate
organism for predicting in -stream effects given that no significant
impacts were seen in a 1986 DEM stream study of our facility. Sandoz is
doing in-house toxicity testing and will keep the State informed of our
findings. If our results indicate that Ceriodaphnia is inappropriate,
we will bring it to the State's attention and suggest an alternate
organism for use in this testing. For this reason, we request that
language in Section G be modified to specify the use of Ceriodaphnia or
another organism acceptable to DEM.
The draft permit makes two references to reopening the permit upon
finding that the toxicity limits are exceeded. However, the reopener is
contingent on "potential" impacts. With this in mind, Sandoz suggests
that an indication of potential toxic effects trigger a requirement for
an in -stream benthic study. A showing of some impact on the taxa
diversity might then determine if reopening the permit is appropriate.
Sandoz is in the midst of studying the complex problem of toxicity
identification and reduction. Treatability studies will soon be underway
that should identify facility modifications to meet new bioassay limits.
If major construction of new treatment or pretreatment facilities is
needed, completion of this work may take as long as three years.
SPECIFIC ORGANICS
The Federal Fifth Circuit Court of Appeals remanded 19 substances from
the OCPSF list to EPA for further study in a decision dated October 10,
1989. The remanded materials included phenol and all the polyaromatic
hydrocarbon (PAH) substances specifically regulated in the draft NPDES
discharge permit. We believe these compounds should be deleted from the
specific list of organic limitations until new standards are established.
A summary of this ruling and the court opinion dealing with this remand
is attached for your reference.

Mercury be monitored in our effluent for one year, with a permit
condition that would reasonably phase in a limit if Mercury is truly
found at significant levels.
TOTAL PHENOLS - The new Water Quality Standards that took effect in
October, 1989 revised the flow design criteria for effluent limitations
to allow 30Q2 flows as the design basis for aesthetic parameters. We
believe taste and odor causing phenol clearly relates to aesthetic
quality and thus should be limited on the basis of 30Q2 river flow. For
this reason, the permit limit should be no lower than the existing limit
of 1.8 Lbs/day monthly average and 3.6 Lbs/day daily max., monitored
monthly. We also request that the stream sampling for total phenols be
deleted because the sensitivity of the method we use is not sufficient to
produce meaningful upstrea,ttim/dow streamm co ari�spdns. �b dJ nlwoo
x5 d,5CD9r
CHRONIC TOXICITY - The wording of the chronic toxicity requirement is
that "no observable inhibition of reproduction" is to occur. Even in the
control samples of Ceriodaphnia reproduction varies. Sandoz suggests
that a more appropriate wording here would be "no statistically
significant inhibition of reproduction..."
There is some question whether Ceriodaphnia is the most appropriate
organism for predicting in -stream effects given that no significant
impacts were seen in a 1986 DEM stream study of our facility. Sandoz is
doing in-house toxicity testing and will keep the State informed of our
findings. If our results indicate that Ceriodaphnia is inappropriate,
we will bring it to the State's attention and suggest an alternate
organism for use in this testing. For this reason, we request that
language in Section G be modified to specify the use of Ceriodaphnia or
another organism acceptable to DEM.
The draft permit makes two references to reopening the permit upon
finding that the toxicity limits are exceeded. However, the reopener is
contingent on "potential" impacts. With this in mind, Sandoz suggests
that an indication of potential toxic effects trigger a requirement for
an in -stream benthic study. A showing of some impact on the taxa
diversity might then determine if reopening the permit is appropriate.
Sandoz is in the midst of studying the complex problem of toxicity
identification and reduction. Treatability studies will soon be underway
that should identify facility modifications to meet new bioassay limits.
If major construction of new treatment or pretreatment facilities is
needed, completion of this work may take as long as three years.
SPECIFIC ORGANICS
The Federal Fifth Circuit Court of Appeals remanded 19 substances from
the OCPSF list to EPA for further study in a decision dated October 10,
1989. The remanded materials included phenol and all the polyaromatic
hydrocarbon (PAH) substances specifically regulated in the draft NPDES
discharge permit. We believe these compounds should be deleted from the
specific list of organic limitations until new standards are established.
A summary of this ruling and the court opinion dealing with this remand
is attached for your reference.

Ch(oyopk.c*t63 4-id
nol- a 0(01D) e.A,,

SPECIFIC PHENOLICS - The provision that or individual phenolic compounds
or the sum of individual phenolic compound can not exceed 1.8 Lbs should
be deleted for several reasons. First, the 1.8 Lb limit should be
higher, based on a 30Q2 flow. Second, there is good reason to believe
that most of the specific phenolic compounds listed will not appreciably
contribute to taste and odors. The nitro groups present in several
compounds tend to deactivate the ring making chlorination difficult.
Also, the molecular weight of Dinitrophenol (DNP) is roughly twice that
of phenol, thus requiring twice as much mass of DNP to be equivalent to
phenol on a mole basis.
In monitoring specific organics, the permit should clearly state that a
result of nondetectable constitutes compliance with the limitation.
Matrix effects may be encountered that will raise the detection limits
that can be achieved in actual practice over those that are published.
OUTFALL 002
ORGANIC PESTICIDE CHEMICALS - Norflurazon is not a regulated pesticide
chemical under 40 CFR 455 and should not be limited.
BODS - We request that the BOD limitation for pesticide production be
monitored and limited with the total plant discharge at outfall 001.
The pH and floating foam and solids restrictions should not apply to this
intermediate sampling point. A statement should be included to allow the
biological sludge from the 002 pretreatment process to be transferred to
the sludge holding tanks for dewatering with the other treatment plant
sludges.
STAGING REQUIREMENTS
The staging requirements Section can be greatly simplified because
the reduction in overall BOD limits renders much of it inapplicable. The
only circumstances under which the staging requirements would be more
restrictive than the proposed BOD/NH3 limits would be during low river
flow conditions in summer months (April 1 - October 31). We propose the
following language:
STAGING REQUIREMENTS (Applicable from April 1 - October 31)
a.m.
The operating day runs from 7:00 a.m. to 7:00 .p,m. Each day, the
permittee will calculate a running daily average stream flow as
determined by turbine operation at Mt. Island Dam, leakage at the dam (80
cfs), and the 7Q10 flow of Dutchman Creek (15 cfs). Effluent release is
to be controlled such that projected release of BOD and ammonia, using
the most recent analytical values for these parameters, will not exceed
the value given in the following formulas:
When daily average river flow is calculated to be -175 cfs:
tam
,rowS
Lbs BOD's +[0.54 x (Lbs NH3-N) ] 5566.4 tbkbl

When daily average river flow is calculated to be
>175 cfs but <--250 cfs:
Lbs BOD's + [0.54 x (Lbs NH3-N) ] <_1044 MiCL9
UPSET PROVISION - We request that an upset provision be included in the
permit to indicate that exceedance of any limits does not constitute a
violation if it can be shown to be caused by an upset condition in the
treatment system.
SECTION H: APAM REQUIREMENT
Sandoz' primary concern with regard to the APAM requirement is the
lack of specific guidance in identifying and quantifying the largest 10
GC/MS peaks. The APAM Requirement Reporting Form A states that
"appropriate EPA approved methods" shall be used to meet monitoring
requirements. Such methods for routine GC/MS analysis for listed
substances are well established and codified. However, specific methods
for identifying and quantifying unknown peaks are not as well
established. Sandoz requests that a protocol for such analyses be
specified in the permit. Without a mutually agreed -upon protocol, the
identification and quantification of unknown peaks becomes highly
arbitrary and may vary between analyses.
In order to meet the "10 significant peaks rule" requirement, Sandoz
proposes to use EPA's Contract Laboratory Program protocol for reporting
tentatively identified compounds from GC/MS analyses (see Attachment #2,
Tasks III and V). This protocol establishes checkpoints and limits by
which matches of unknown spectra to reference library spectra are
considered significant and reportable. It also firmly establishes a
quantification scheme which provides a consistent basis for estimating
concentration. Sandoz proposes that this methodology be included in the
permit and/or specifically referenced by this section of the permit.
Doing so will establish an unambiguous and reproducible protocol which
will ensure the highest possible accuracy in identifying and quantifying
unknowns.
Because the results of the APAM requirement will become public
record, Sandoz requests that the limits of the detection and
quantification technology used to determine unknown peaks be included in
any documents made available to the public.
Again, Sandoz appreciates the opportunity to supply these
comments and looks forward to meeting with you to discuss them.
Sincerely,
W. M. Archer
Attachments
cc. Mr. Dale Overcash

-TAN-19-9 et
•
FR I 11 : 53 SANDOZ CH,EM _ E S&PS P . 04
•
• ATTACgIMENT # 1
ROUTE TO:
Water Compliance Personnel
No vembe'r 6, 1989
TO: Official Representatives.
Fifth Circuit Remands Effluent Limitations for Certain Chemicals to' EPA
The Fifth Circuit Court of Appeals remanded 19 limitations in EPA's
final BAT2 standards for direct dischargers and 13 limitations in the
pretreatment standards for existing sources (PSES) that were based on
in -plant biological treatment. A list of the pollutants for which
limitations were remanded is attached.
The practical effect of the Court's ruling is to require EPA to initiate
another rulemaking to establish BAT and PSES for these pollutants. When the
pretreatment guidelines emanating from that process are finalized, companies
will.have three years from their date of promulgation in which to meet the
new limits. The schedule for meeting the new BAT limitations, when they are
published, will be a subject of permit negotiations, but direct dischargers
can generally rely on having a maximum of three years in which to come into
compliance.
For those pollutants not impacted by the Court's decision, the deadline
for meeting pretreatment standards is November 5 1990. 'Again, the deadline
for meeting BAT limitations is a subject for permit negotiations, but direct
dischargers can generally rely on having until that date in which to comply.
Those companies affected by the Court's decision should alert the
appropriate local and state regulatory agencies that these limitations for
the attached list of pollutants will no longer be in effect.
We will continue to keep you apprised of ail relevant developments.
Copies of the decision may be obtained by calling Ms. Chris Reiter at SOCMA.
Catherine A. Marshall
Director, Government and )ublic
Affairs
Attachment
cc: Environmental Quality Committee
Water Subcommittee

F R I 1 1: 5 4
r
SANDOZ CHEM . E A SS&,PS P.05
t
.POLLUTANT
FOR WHICH LIMITATIONS WERE REMANDED BY THE FIFTH CIRCUIT DECISION
BAT2
(Direct Dischargers)
Acenaphthene
2 4-Dimethylphenol
Fluoranthene
Naphthalene
Phenol
Bis(2-Ethylhexyl)Phthalate
Di-N-butyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate •
Benza a Anthrancene
Benzo a p rene
3,4-Benzofluoranthene
Benzo(k)Fluoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene.
Pyrene
PSES
(Ind jrect Dischargers)
Acena ht1ene
2 4-Dimethylphenol
Fiuoranthene
Naphthalene
Phenol '•
Bis(2-,Ethylhhexyl )Phthalate
Di-N-butyl Phthalate
Diethyl Phthalate
Dimethyl'phthalate
Anthracene
Fluorine'
Phenanthrene
Pyrene
•

undoes O?Aoa„7„'s0 4: 7 SANDOZ/PHARM E/HANOVER
P.2/16
1ST OPINION of Level 2 printed in FULL format.
CHEMICAL MANUFACTURERS ASSOCIATION, et al., Petitioners,
v. U.S. ENVIRONMENTAL PROTECTION AGENCY, Respondent
Nos. 87'4849, et al,
UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
1989 U.S. App. LEXIS 16509
October 10, 1989; As Corrected; Original Opinion Reported
at 1989 U.S. App. LEXIS 5232
APPEAL -STATEMENT:
C*13
PAGE
Petitions for Review of an Order of the Environmental Protection Agency. No.
52 Fed. Reg. 42522.
COUNSEL:
COVINGTON 8 BURLING, Theodore L. Garrett, Corinne A. Goldstein, Jay T. Smith,
Washington, D. C.
Doy Weitman, Michael Wanig, David J. Kaplan, Washington, D.C.
INTERVENOR: NATURAL RESOURCES, ETC., Ronald J. Wilson, Robert Wayne Adler,
Washington, D.C.
OPINI0NBY: RUBIN; KING
OPINION:
Before, RUBIN, GARZA, and KING, Circuit Judges.
ON PETITIONS FOR REHEARING AND SUGGESTION FOR REHEARING EN BANC
ALVIN B. RUBIN and KING, Circuit Judges:
At the conclusion of our original opinion n1 we encouraged the parties to
file petitions for rehearing in order to ensure that we had given each issue in
this complex case its due. n2 After considering the parties' arguments, we now
clarify certain aspects of our earlier opinion and grant rehearing and remand
two parts of the regulations to the Environmental Protection Agency (EPA) for
further rulemaking proceedings. As in our original opinion, we have divided
responsibility for drafting this opinion: Judge King prepared the section
concerning the regulations based on the best practicable control technology
(BPT) , and Judge Rubin prepared the sections concerning regulations based
0123 on the best available technology (BAT) . No issues have been raised on
rehearing with respect to the parts of the original opinion authored by Judge
Garza.
ni 870 F.2d 177 (5th C1r.1989)
n2 See id. at 266.
I. Best Practicable Technology (BPT) Issues

1
q;JAN 17 '90 11:35 SANDOZ/PHARM E/HANOVER
3rvice c., ,.,aa„ IJ %d 4Cniras
P.13/16
1989 U.S. App. LEXIS 16509, *27
discharge was due either to an upset or to a quality -control problem. Because
the data concerning the cause of an unusually high discharge often will.be
uniquely within a plant operator's control, and because the EPA has considerable
expertise in interpreting sampling data, we do not believe that the EPA's
exclusion of the isolated and extremely high discharge was unreasonable.
We also reaffirm our holding that the EPA may determine the "best" plant upon
which to base BAT limitations an a pollutant -by -pollutant basis. The fragments
of legislative history that the petitioners .quote to us are out of context and
do not -address the point at issue. The Fourth -Circuit's decision in Tanners'
Council of America v. Train n50 does hold that.EPA limitations had not been
shown to be achievable when the plants in the data base had met "the limitations
for some, but not all of the pollution parameters." n51 That court's rational~
was unclear, however, and we have declined to follow its decision. t*283
Association of Pacific Fisheries v. EPA n52 and CPC international, Inc. v.
Train, n53 also relied on by PPG and Dow, are not contrary to this court's
ruling. In CPC International the EPA's regulations were remanded because they
were not supported by data from any plant, n54 and in Pacific Fisheries, a
regulation was remanded because the study upon which the EPA relied did not
demonstrate that the sole data -base plant could comply with the regulations. n55
Here, in contrast, at least one plant can meet every BAT limitation, and, as we
held originally, the fact that no plant has been shown to be able to meet all of
the limitations does not demonstrate that all the limitations are not
achievable.
n50 540 F.2d 1188 (4th C i r .1976) .
n51 Id. at 1192-94.
PAGE 13
n52 615 F.2d 794 (9th Cir.1980) .
n53 540 F.2d 1329 (8th Ci r.1976) .
n54 See id. at 1338-40.
n55 See 615 F.2d at 819.
E. The Achievability of the BAT Limitations for Priority Pollutants for Which
In --Plant Biological Treatment is the Model Technology
The EPA designated in -plant biological treatment as the model, technology for
the treatment of twenty priority pollutants. To establish the BATED t*293
limitations for these pollutants, however, the EPA relied on a data base
consisting solely of three end--of-pipe biological treatment plants, n56 As a
result, CMA argues, the EPA has failed to demonstrate that the BATC23 limits for
the priority pollutants are achievable.
n56 See 870 F.2d at 240.
We initially rejected Cl1A's argument, stating
Ct3he petitioners have failed to demonstrate that end -of -pipe biological
treatment systems are sufficiently different from in -plant systems to make the
EPA's reliance on end -of -pipe data irrational. For all we can tell from the
parts of the record that have been cited, the only difference between the two

3Nices aa,.1Z. ;90 11 35 SANDOZ/PHARM E/HANOVER
P.14/16
PAGE 14
1989 U.S. App. LEXIS 16509, *29
systems is that they are installed at different positions in the production
process. n57
n57 Id, at 24U.
CMA has now clarified its position. End -of --pipe systems, CMA points out,
typically employ much longer detention tunes than ire -plant systems. indeed, the
record shows that the three end -of -pipe plants used to develop the BATi23
limitations for the priority pollutants —plants 1293T, 948F, and 2536T-- -had
detention times of 17.2, 3.5, and 1.6 days respectively. In contrast, the EPA
used a maximum detention time of 2.1 days to estimate [*301 the costs of
in -plant treatment systems, a period substantially shorter than the detention
times at two of the three end -of -pipe plants. Because detention time is a key
variable determining the effectiveness of biological treatment, CMA asserts that
the achievability of the SATC27 limitations for the priority pollutants, which
the CWA requires the EPA to demonstrate, n58 has not been established.
n58 See 33 U.S.C. S 1314(b) (2) (1982).
The EPA justifies its use of data from the three end -of -pipe plants on the
grounds that end -of -pipe and in -plant systems utilize the same biological
processes and the three plants treated wastestreams comparable to those that
would enter an in --plant treatment system. n59 It does not follow, however, that
the differing detention times can rationally be ignored; if anything, these
similarities suggest that the differences in detention times are unlikely to he
compensated for by an offsetting variable.
n59 Dev.Doc. VII-49, reprinted in Joint App. at 3749.
The EPA further maintains that CMA's focus on detention time is inappropriate
because detention time is only one of many factors that affect the efficacy of a
biological treatment system. L*313 Other factors include the organic loading
of biodegradable material in the influent, the concentration of biodegrading
organisms in the aeration basin (MLVSS), and the length of time that these
organisms remain in the aeration basin. The EPA adds that some plants treat
priority pollutants successfully even with detention times less than thirty
hours, and that increasing MLVSS concentrations can shorten the time necessary
for successful treatment.
Nevertheless, the record contains no performance data for in -plant treatment
of the twenty priority pollutants at issue, and the EPA concedes that detention
time does affect the efficacy of a treatment system. Although the record
supports the EPA's assertion that higher MLVSS concentrations decrease the
detention time necessary for a given level of treatment, it does not make clear
exactly what level of pollution would result from any given combination of
shorter detention time and increased MLVSS. The EPA's claim that the BATE21
limitations can be met because MLVSS concentrations can be increased
consequently appears to be no more than an educated guess.
The EPA bears the burden of producing a reasonable basis on the record for
its regulations.' £*32I n60 The EPA has failed, however, to demonstrate a
reasonable basis for its conclusion that in -plant treatment can eliminate
pollutants as effectively as the end -of -pipe systems of Plants i 293T and 948F .
The limitations based an these plants therefore are arbitrary and capricious,
and must be remanded to the EPA for further ruLemaking proceedings. The

:rvices o„MN 17 'a' 0 11:36 SANDOZ/PHARM E/HANOVER
P.15/16
1989 U.S. App. LEXIS 16509, *32
portions of our previous opinion to the contrary are withdrawn.
n60 See Pacific Fisheries, 615 F.2d at 819; E.I. du
Train, 541 F.2d 1018, 1037-38 (4th Cir.1976), rev' d in
430 U.S. 112, 97 S.Ct. 965, 51 L.Ed.2d 204 (1977); CPC
1338-40; FPIC Corp. v. Train, 539 F.2d 973, 981-82 (4th
& Steel Inst. v. EPA, 526 F.2d 1027, 1062-63, 1065 (3d
PAGE 15
Pont de Nemours & Co. v.
part on other grounds,
intl., 540 F.2d at
Cir.1976); American Iron
Ci r .1975) .
F. The EPAts Erroneous Inclusion of Three Complexed Metals in the Limits for
Uncomplexed Metals
Appendix A of the effluent limitations establishes limits for the discharge
of toxic uncomplexed metals. Appendix B lists "complexed metals," that is metals
bonded with an organic molecule, and provides that limits for such pollutants
will be established ona case -by -case basis by the t*333 individual NPDES
permit writer. n61 In its initial brief DuPont contended that the EPA
erroneously included three complexed metals, including tetraethyl lead,
tetramethyl lead, and anti -knock fuel additives, in Appendix A. DuPont contended
that these compounds should have been listed in Appendix B .with otter complexed
metals. In its rehearing petition DuPont notes that this Court failed to address
this issue.
n61 52 Fed.Reg. 42,542-43.
By notice filed May 12, 1989, the EPA conceded that these three compounds are
complexed metals and it erred by including them in Appendix A. This Court
therefore grants the petition for review, strikes these three compounds from
Appendix A, and remands the issue to the Administrator for further rulemaking
proceedings.
Conclusion
clusion
The petitioners' request for a rehearing is denied in all respects except
that 11 our previous opinion is clarified as explained above; 2) the limitations
for priority pollutants for which in -plant biological treatment is the model
technology are remanded to the EPA for further rulemaking proceedings insofar as
they are based on Plants 12931 and 948F; and 31 the three complexed metals
erroneously included in Appendix A are t*343 ordered stricken from that
Appendix, and the issue is remanded to the Administrator for further rulemaking
proceedings.

r • •
FROM:SANDOZ MT HOLLY PLT TO:MR-EXEC JAN 19, 1990 8:51AM #468 P.02
•
ATTACHMENT ## 2
USEPA CONTRACT LASORATOaY PROCRAI(
STATEMENT Ole YOU
rOR
ORGANIC$ ANALYSIS
Multi -Media
Multi'Cofcentration
2/88
60