NC0006351_Wasteload Allocation_19850923

ATCood‘351
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 23, 1985
MEMORANDUM
TO: File
FROM: Trevor Clements
SUBJECT: Mineral Research & Development
Wasteload Allocation
Mineral Research & Development does not fall under any specific
industrial category and thus are not limited by any specific federal
guidelines. The products manufactured by MR&D which generate process
wastewater are (from Doug Finan's Notes):
Aluminum Nitrate
Calcium Nitrate
Copper Nitrate
Magnesium Chloride
Magnesium dihydrogen phosphate
Magnesium Nitrate
Manganese Nitrate
Zinc Nitrate
According to the EPA Development Document for inorganic chemicals (440/1 -
84/007), only copper nitrate is covered by effluent guidelines-- 40 CFR
415.362 subpart AJ. The other products are not mentioned or the dis-
chargers of process waste from the manufacture of these products are too
insignificant based on production or flow to justify developing a nation-
wide regulation. Therefore, it will be more appropriate to base permit
limitations on best professional judgement (BPJ) with regard to treatment
technology.
Table 8- 11 of the EPA Development Document provides achievable long-
term averages for metals given a particular treatment technology (attached).
Mineral Research & Development utilizes lime addition and settling to remove

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metals from the wastewater. Based upon MR&D's identification of wastewater
characteristics and Doug Finan's notes, the following metals should be
limited in the NPDES permit:
Arsenic;
Cadmium
Chromium
Copper
Selenium
Zinc
The'upper extreme of the range of achievable levels will be used for
limitation, since there is strong evidence that existingifacilities are
operating at or below these levels. Therefore, BPJ limits will be:
Effluent Mass
Pollutant. Concentration Loading (*)
Arsenic 1.0 mg/1 (0.208-lbs/day) ^'
Cadmium 0.5 mg/1 (0.104 lbs/day)r.
Chromium 0.5 mg/1 (0.104 lbs:/day)
Copper 1.0 mg/1 (0.208 lbs/day)
Selenium 1.0 mg/1 (0.208 lbs/day)
Zinc 1.5 mg/1 (0.313 lbs/day)
(*) Based upon MR&D's design flow of 0.025 MGD
The BPJ limits can be compared with the water quality -based limits by
use of a simple mass balance model:
r., _ QD CD QU CU
Qw
where: Cw = Waste Concentration
Qw = Waste Flow
QD Downstream Flow
CD = Downstream 'Concentration (standard)
QU Upstream. Flow (7Q10)
CU = Upstream Concentration

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r
The model design conditions for this application will include a 7Q10 of
8.6 cfs (USGS sta. no. 0212418300) and an efffluent flow of 0.025 MGD
(0.039 cfs). Background concentrations (Cu) will be taken from the USGS
Statistical Summary of Minor Elements for Unpolluted Streams Section II,
(Table 6, 1982).
Arsenic
Cw =
standard = v/50 ug/1
("C" waters)
(8.639 cfs * 50 ug/1) - (8.6 cfs * 0.6 ug/1)
.039 cfs
10.9 mg/1 (2.273 lbs/day)
Cadmium standard = 2 ug/1
Cw =
Chromium
(8.639 cfs * 2 ug/1) - (8.6 cfs * 0 ug/1)
.039 cfs
= 0.443 mg/1 (0.092 lbs/day)
standard = `"50 ug/1
Cw =
Copper
Cw =
Selenium
(8.639 * 50) (8.6 * 12)
.039
= 8.429 mg/1 _(1.757 lbs/day)
action level = 15 ug 1
(8.639 * 15) - (8.6 * 4)
.039
= 2.441 mg/1 (0.509 lbs/day)
Cw =
-7
standard = 10 ug'I1 5
(8.639 * 10) - (8.6 * 0)
.039
= 2.215 mg/1 (0.462 lbs/day)
Zinc action level 50, ug/1
Cw =
.039
(8.639 * 50) - (86 *.7)
9.532 mg/1 (1.987 lbs/day)

In choosing• between the BPJ and the water quality based limits, the more
stringent of the two will be chosen. Therefore, final limits for metals
will be:
FINAL LIMITS
Effluent Mass Basis of
Parameter Concentration Loading Limit
Arsenic 1.0 mg/1 0.208 lbs/day BPJ
Cadmium 0.443 mg/1 0.092 lbs/day WQ
Chromium 0.5 mg/1 0.104 lbs/day BPJ.
Copper 1.0 mg/1 0.208 lbs/day BPJ
Selenium 1.0 mg/1 0.208 lbs/day BPJ
Zinc 1.5 mg/1 0.313 lbs/day BPJ
Since the majority of limits reflect BPJ, these limits should be checked --
where possible --with actual plant performance. Self -monitoring data is
collected for copper, chromium, and zinc. For the period between 4/83
and 3/85 copper averaged 0.168 mg/1, chromium averaged 0.403 mg/1, and
zinc averaged 1.016 mg/1. All of these averages fall below the proposed
limits, so Mineral Research & Development is capable of meeting those
limits.
Although there are no' categorical limits for NH3-N which.apply to
MR&D, it'is evident from the chemicals manufactured and past monitoring
data that a reasonable limit for NH3-N is needed. Preliminary modeling
indicates that.the discharge will not be water quality limited from either
an ammonia toxicity or dissolved oxygen standpoint. The dilution available
in the stream (7Q10 = 8.6 cfs) is large enough so that water quality 1imi-
tation would not occur until the effluent NH3-N concentration reached
levels well over 100 mg/1. Therefore, an effluent limit based upon best
professional judgment is warranted.
The —Mooresville Regional Office was contacted in order to find out
what could reasonably be expected of this plant from a treatment standpoint.
Thurman Horne responded (letter attached) with a recommendation of 2.0 lbs/
day for daily average and 4.0 lbs/day as a daily maximum. The daily average
value is the limit which MR&D is currently operating under and was approved
by the EPA in 1977 (see letter from Rex Gleason). Thurman provided a summary

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i
of the past year's self -monitoring data which demonstrates that MR&D can
meet these requirements (Table A). The facility's yearly average was 0.6
-1bs/day and the maximum monthly average was 1.8 lbs/day. Therefore, the
above limit's will be placed in the wasteload allocation recommendation.
Mineral Research and Development should also be required to continue
their biomonitoring efforts. DEM began requiring monthly bioassays in
July of this year. MR&D was given an LC50 target level of 39 percent,
based upon an instream waste concentration (IWC) of 0.39 percent. However,
based upon updated USGS flow information, MR&D's IWC is actually 0.45 per-
cent at 7Q10 conditions. This was determined using the following equation:
IWC = Design Wasteflow
Total Streamflow (7Q10 + Wasteflow)
0.03875 cfs
0.45%
8.6 cfs + 0.03875 cfs
Therefore, MR&D's target level should be 45 percent using the 1/100th
acute to chronic relationship. Past DEM bioassays have shown LC50 values
of 13 percent, 12 percent, and 29 percent.
JTC:mlt

MEMO TO: Trevor Clements
THRU: Rex Gleason q t6
FROM: Thurman Horne
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 17, 1985
SUBJECT: Mineral Research and Development Corporation
NPDES NC0006351
Cabarrus County
As per our recent telephone conversation, I have reviewed the Mooresville
Regional Office files for the subject facility for the purpose of providing assistance
in the development of an appropriate limitation for NH3-N.
Although there are no catagorical limitations for NH3-N appropriate to this
industry, it is evident from the Chemicals manufactured and past monitoring and
sampling records that a reasonable limitation for NH3-N is needed.
After reviewing the files and the most recent monitoring data (see attached
Table 'A'), it appears that a limitation of-2 lbs. per day as contained in the
existing permit is both reasonable and defensible. Attached is a copy of a letter
from Rex Gleason to MRD:advising that EPA and the State agreed to a limitation of
2 lbs.per day. Reviewing the past year's monthly self -monitoring data, it can
be seen that the company has consistently complied with this limitation.
Whereas, the company has clearly demonstrated that they already have the
necessary wastewater treatment facilitiesto comply with this limit and considering
that EPA has previously endorsed this limitation, we recommend that the new permit
contain an NH3-N limitation of 2.0 lbs./day (daily average) and 4.0 lbs./day
(daily maximum).
If you have any questions or need any additional assistance, please advise.

TABLE "A"
MINERAL RESEARCH AND DEVELOPMENT CORP.
: SUMMARY OF MONTHLY SELF MONITORING
DATA (MONTHLY. AVERAGES)
MONTH FLOW NH3-N NH3-N
MGD mg/1 lbs./day
July 1985 407 - 12.0 .7
June 1985 .011 ? 8.54 .8
May 1985..006 24.93 1.2
April 1985 .009 11.92 .9
March 1985 .017 12.74 1.8
February 1985. .011 5.6 .5
January 1985 .003 2.9 .1
December 1984 _ .003 8.9 .2
November 1984 .013 4.6 .5
October 1984 .017 1.05 .1.
September 1984 .015 2.1 .3
August 1984 .017 1.88 .3
Yearly. Average .011 8.1 .6

DIVISION OF ENVIRONMENTAL MANAGEMENT
January 3, 1977
Mr. Robert G. Scharff
Mineral Research and Development
Route 1, Box 340
Concord, North Carolina 28025
Subject: Ammonia Limits for
Mineral Research and Development
Cabarrus County
Dear Mr. Scharff:
Mr. John Lank of EPA has notified me of EPA's agreement with the State of
North Carolina to relax ammonia limits from the Harrisburg facility. Therefore,
the State of North Carolina proposes to reissue an NPDES Permit with the following
ammonia (NH3 as N) limitations as agreed upon bar the State and EPA:
Daily Average Daily Maximum
2.0 lbs. 3.0 lbs.
Please complete and return in duplicate the attached Short Form "C" permit
applitit4ons 4n order that these revised limits may be �._ de effective through
reissuance of the existing federal permit.
If you have any questions concerning this matter.; please do not hesitate to
contact me.
SI ncerely,
ORIGINAL SICNED BY
D. Rex Gleason
Regional Engineer
Attachment
cc: Mr. Robert A. Carter
REW:sju