NC0006351_Report_19960530

May 30, 1996
CSI
CHEMICAL SPECIALTIES, INC.
Attention: NPDES Supervisor
Permits and Engineering Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Subject: 12 Month Status Report
NPDES Permit No. NC0006351
Chemical Specialties, Inc.
Harrisburg, NC Facility
Cabarrus County
Dear NPDES Supervisor:
In accordance with Part III, Condition F of our NPDES permit, Chemical
Specialties, Inc. (CSI) herein submits a 12 month status report. This report outlines
actions taken towards eliminating pesticide process waste water from being discharged to
surface water.
Background
CSI was issued a NPDES permit for discharge to surface waters on May 31, 1995
with substantially unchanged effluent limits from its previous permit. This current permit
will expire on May 31, 1997 at which time the site must then comply with 40 CFR 455
regarding Pesticide Chemicals.
This report meets the requirements set forth in Part III, Condition F of that permit,
requesting a report to update on the progress towards complying with 40 CFR 455.
Specifically requested was as follows:
• Details regarding connection to Water and Sewer Authority of Cabarrus
County (WSACC).
• Other methods for complying with 40 CFR 455 if not connecting to WSACC.
• Pollution prevention, spill response and process waste stream recycling efforts.
These specific areas will be addressed in detail below:
PO Box 610.5910 Pharr Mill Road • Harrisburg, NC 28075.704-455-5181 • FAX [phone] • LAB FAX [phone]

NPDES Supervisor
May 30, 1996
Page 2
WSACC Connection
The Division strongly encouraged CSI to pursue connection to WSACC to
eliminate surface water discharge. As a result, a meeting was arranged between CSI,
WSACC and NCDEHNR representatives on June 21, 1995 following issuance of our
permit in May, 1995.
The meeting included a review of existing waste streams, an update on historical
ammonia effluent levels, pesticide process review and a site tour. General consensus
during that meeting was that the WSACC was apprehensive about taking our waste
stream due to the potential presence of zinc and arsenic. Additionally, it was noted that if
there were problems with the WSACC treatment system that we would be the first likely
focus of the WSACC concern.
Mr. Joe Pearce of the NCDEHNR indicated that there was a proposed
modification to the Federal Pesticide Regulations which would "definitely affect
pretreatment for pesticides". A copy of these proposed modifications was supplied by Mr.
Pearce subsequently. The proposal does address Pretreatment Standards as well as
proposes pollution prevention methods as alternatives to zero discharge.
CSI also considered the connection to WSACC from an environmental impact
position. It is believed that due to the inorganic nature of our pesticide products that these
compounds would "pass through" WSACC treatment systems. This would simply transfer
the pesticide waste water from being discharged to surface water from our facility to the
WSACC facility with no additional level of pollutant removal.
Connection to the WSACC would require a circa $150,000 capital investment and
a continued operating costs for disposal. To summarize, the concerns associated with
connecting to WSACC for elimination of pesticide waste water discharge are as follows:
• WSACC concern over site metals potentially present in effluent
• Proposed modifications to 40 CFR 455
• No substantial reduction in actual pollutant loading to surface water
• And high initial and continued operating costs.
Thus, CSI will not purse connection to WSACC as the best option to eliminating
pesticide process water from being discharged to surface water. However, CSI does
intend on fully complying with the requirements of 40 CFR 455 and the requirements of
the NPDES permit as outlined in the next section.

NPDES Supervisor
May 30, 1996
Page 3
Compliance with 40 CFR 455
As stated in the NPDES Permit Issuance letter dated May 5, 1995, "compliance
with 40 CFR 455 will require complete recycle or non -surface water discharge handling
of all process waste waters, wash waters, scrubber blowdown wastes, etc. and the
complete segregation or containment of and non -surface water discharge disposal of all
storm water which contacts raw materials, process areas, or finished product."
The CSI facility currently complies with these requirements for two of our
pesticide products; Chromated Copper Arsenate (CCA) and Arsenic Acid processes and
has complied for many years. The only remaining pesticides present on site, based on the
Division's assessment are:
1. Copper Count N (CCN)
2. Copper Ammonium Carbonate (CAC)
3. Amine Copper Carbonate (ACC)
4. Mold Guard Products
To comply with 40 CFR 455, CSI plans to segregate the production, storage and
loading areas for CCN, CAC and ACC. The segregation will be facilitated by
constructing a containment dike around these specific areas and providing sump pumps
and water collection tanks to act as surge capacity. All of the collected water will be
recycled or reused in the process unless it is uncontaminated stormwater. As we gain
experience with our usage rates we may need to roof areas to reduce the amount of water
collected but this is as of yet undetermined. Truck loading/unloading will be contained
and again a sump arrangement supplied to collect and transfer spills, leaks and wash water
to process for reuse. We have also planned on segregating warehouse space to isolate
spills or leaks and direct them again to collection points for reuse.
This methodology has worked well for the CCA and arsenic acid processes and we
feel confident that we can comply with 40 CFR 455 with this approach. In addition, this
approach is more economical and environmentally more attractive since it completely
eliminates the discharging of pesticide effluents to surface water either by CSI or the
WSACC.
Mold Guard products on the other hand, is being approached differently. In fact,
CSI and our sister company Laporte Water Technologies and Biochem still contend that
the Mold Guard series of products is not a pesticide but is a chemical preservative as
defined by American Feed Control and regulated by FDA under Reg. 582.3081. Mr. John
Puetz of Laporte Water Technologies and Biochem has prepared an argument to this end
and will submit this to the NCDEHNR under separate letter.
Also in reference to the NPDES Permit Issuance letter dated May 5, 1995, the
letter indicates that with segregation the only waste streams allowable for surface water
discharge are softener blowdown, uncontaminated storm water, and other non -contact
waste streams such as boiler blowdown, condensate blowdown, etc. Please be advised

NPDES Supervisor
May 30, 1996
Page 4
that information specifically submitted during our review of the draft permit leading up to
the permit issued May 31, 1995 concentrated on resolving the pesticide issue.
As you are aware, pesticide production is only a portion of the chemicals
manufactured at the CSI facility. All of these processes were submitted in our last permit
application. Process waste waters from wash down, vessel rinsing, scrubber blowdown,
filter cleaning, etc. from these processes are not subject to the requirements of 40 CFR
455 and should be permitted in our NPDES permit.
Pollution prevention, spill response and process waste stream recycling efforts
The following outlines continued efforts by the CSI facility to minimize waste
generated at the site. Many of these efforts require capital money to be approved prior to
implementing. Money is currently being sought for these.
• Pollution Prevention Plan developed as part of our Stormwater Permit.
• Spill response has been enhanced with a site HAZWOPER team to address
spill and leaks.
• New spill procedures for operation personnel requiring primarily reuse, then
absorption and disposal as opposed to flushing to waste treatment.
• Stormwater segregation from waste waters. This will reduce the volume of
water needing to be treated in our waste treatment system.
• Recycle opportunities are being investigated to reuse effluent for wash down
waters, where possible, as opposed to fresh water.
• Secondary containment for many of the site storage tanks to facilitate spill and
leak reuse in lieu of treatment.
• Wash water recycling system for the maintenance area.
Conclusion
The CSI facility is committed to complying with our NPDES permit and 40 CFR
455 for our pesticide processes. The course of action outlined for complying with 40 CFR
455 is underway for implementation by the June 1, 1997 deadline. We are confident this
direction meets the regulatory intent, is the best environmentally and is economically
practical.
We also continue to aggressively pursue all waste reduction and pollution
prevention options available to us. If you have any questions of concerns over our current
plans please advise us at the earliest possible time since money is being allocated to
perform the required work.

NPDES Supervisor
May 30, 1996
Page 5
Sincerely,
Sylvester J. Bartos
Compliance Manager
Chemical Specialties, Inc.
cc: S. B. Ainscough
C.T. Baccich
D.W. Moon
B. Callihan, Delta Environmental Consultants