NC0074756_approval_20160525

NPDES DOCWWENT SCANNINO COVER SHEET
NPDES Permit:
NC0074756
Greater Badin W&S WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Approval
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
May 25, 2016
This document is printed on reuse paper -ignore any
content on the resrerBe Bide

PaA-rvl i- -No- 000 -74 -1s(D
Rodriguez, Teresa
From: Gore, Deborah
Sent: Wednesday, May 25, 2016 1:24 PM
To: Michael Worden; Mcdaniel, Robert; Rodriguez, Teresa
Cc: 'Prezbindowski, Robert';'Tim White'; Basinger, Corey
Subject: RE: Alcoa/Badin Landfill; Alcoa, Inc.; Badin, NO Regulatory Review for the Existing Seep
Collection System Proposed Modifications
Mr. Worden,
You are correct that DWR staff have expressed no concerns regarding the proposed modification to the existing seep
collection system. There is no need to modify the NPDES permit. The permit preparation documents did acknowledge
the Alcoa landfill leachate discharge to the Stanly County WWTP and that no pretreatment program is necessary, but did
not specify within the permit where or how the leachate samples should be collected. Therefore, if based upon my
analysis of the data provided by Alcoa, Stanly County wishes to accept the leachate under the proposed modified
collection system, it is entirely up to Stanly County. If there is an agreement between Stanly County and Alcoa that
specifies the collection method that agreement may need to be updated by the two parties.
I hope this addresses any concerns you may have,
Deborah Gore
PERCS Unit Supervisor
Division of Water Resources
Department of Environmental Quality
919-807-6383 office
919-807-6489 fax
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617
0- Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Michael Worden [mailto:[e-mail]]
Sent: Wednesday, May 25, 2016 12:04 PM
To: Gore, Deborah <[e-mail]>; Mcdaniel, Robert <[e-mail]>; Rodriguez, Teresa
<Teresa. Rodriguez@ ncde nr.gov>
Cc:'Prezbindowski, Robert' <Robert.Prezbindowski @alcoa.com>; 'Tim White' <[e-mail]>
Subject: Alcoa/Badin Landfill; Alcoa, Inc.; Badin, NC: Regulatory Review for the Existing Seep Collection System Proposed
Modifications
Ms. Gore,

Per our conversation on Monday, May 23, 2016, please find attached a memo of our understanding of the internal review
process performed by NCDEQ for the above referenced site. If our understanding is incorrect, please advise us as soon
as possible. I can be reached at any of the numbers below, or you can reach Robert Prezbindowski with Alcoa at (865)
977-3811.
Thanks-
ITmz
Michael W. Worden, P.G.
Geologist I Environeering, Inc.
Raleigh, North Carolina I Houston, Texas
o: 919.341.6492 1 c: 919.244.8988
htto://www.environeerinainc.com
Confidentiality Notice. This transmittal ani attachment (the "Communication") is confidential to ENVIRONEERING, Inc. and may also be onenvise privilegei tl you are not the intended reapient, you
are hereby notified! that you have received this Communication in error and any dissemination, distribution or copying of this Communication is strictly prohibited. If you have received this Communication
In error, please notify us immediately by reply e-mail or by telephone [phone]) and promptly delete and purge this Communication.

O
ALCOA
Ms. Donna Davis
Utilities Director
County of Stanly
201 South Second Street
Albemarle, North Carolina 28001
Alcoa Badin Works
PO Box 576
Badin, North Carolina 28009 USA
Re: Alcoa/Badin Landfill Seep Possible Waste Classification and Notification
Alcoa Badin Works, Badin, NC
Dear Ms. Davis:
As you are aware the Alcoa Badin Works Plant ("Alcoa") requested in 2005 that the Stanly County POTW (the
"POTW") in Badin, North Carolina receives a flow of collected seep water from the Alcoa/Badin landfill.
Alcoa received approval from your office by correspondence dated November 28, 2005 to discharge collected
seep water to the Greater Badin Wastewater Treatment Plant. A copy of that approval letter is attached for ease
of reference and your convenience. After receiving this approval the collected seep water was conveyed via
below grade piping to the POTW sanitary sewer system connection on Wood Street in Badin North Carolina.
Alcoa is currently evaluating upgrades and modifications to the existing seep collection system. The purpose of
this letter is to notify your office of the potential change to our previous description of how seep water will be
collected prior to discharge. Alcoa anticipates the existing three individual seep collection points will be
replaced with trench based seep collection system. This upgrade to a trench system will improve overall seep
capture and collection efficiency. This greater efficiency is achieved by intercepting seep water below grade
immediately down gradient to the landfill. Second, the use of a below grade collection system will
dramatically decrease the potential inflow of surface stone water into the collection system during rain or
flooding events.
A review has been completed for data collected from the existing seeps and from groundwater monitor wells
located within the proposed trench based seep collection system footprint. This assessment showed that
potential collected seep water within this area can contain cyanide at concentrations ranging from non -detect to
0.041 mg/L with the average concentration estimated at 0.027 mg/L. Data collected from the current discharges
to the POTW is non -detect for available cyanide from the seeps at a detection level of <0.001I mg/L. See
attached tables I and 2 for a summary of the data collected.
Total fluoride concentrations ranging from 2.3 mg/L to 48.2 mg/L have been reported in wells located within
the footprint of the proposed trench based seep collection system, with the average concentration being
estimated at 22.7 ppm. The current total fluoride discharge to the POTW ranges from 0.31 to 28.9 mg/L with
an average concentration estimated at 17.67 mg/L.

Ms. Donna -Davis January 15, 2016
Page 2 of 2
The estimated average flow from the proposed trench based seep collectio'ni system is anticipated to be
approximately 5 gpm, with a maximum flow rate of 20 gpm. This could potentially result in a mass loading of
the following constituents:
Potential Average Potential Maximum
Monthly Loading Monthly Loading
(lbs)' (lbsy
Cyanide. 0.0486 0.3
Fluoride 40.8 86.7
'Based -on the average concentration recorded (0.027 mg/L CN; 22.7 mg/L Fl) in the wells or seeps at
the average flow rate (5 gpm).
2Based on the maximum concentration recorded (0.041 mg/L CN; 48.2 mg/L Fl) in the.wells or seeps at
the average flow rate (5 gpm). .
As you may recall, Alcoa was required to provide notification in writing of its intent to discharge this material
to the. POTW under 40 CPR 403.12(p)(1). Alcoa feels that the discharge characterization has not change. and
that the initial notification provided in 2004 fulfills the RCRA notification requirements. A copy of that initial
notification is provided for your convenience.
Alcoa appreciates the efforts of the NCDEQ and looks forward to working with them in the future. If you have
any questions, please feel free to contact me at [phone].
Sincerely, .
Mark J.
Plant Manager -
attachments
PC: Robert Prekindowski — Alcoa
Robyn Gross - Alcoa

Stanly County
1000 N Plot street
ALBEMARLE, NORTH CAROLINA
28MI
Phone [phone]
November 28. 3005
Mr l intothy !i'hite. REM
Em ironeerina. Inc
16350 Park Ten Place
Suite 140
Houston, Tetas "7084
Dear '.It White
The Greaiet Badin 1i'asiewater freatment Plant is read} to begin recek ing tlo\\ from the
Alcoa/Badin landfill. This discharge from the landfill teas specifically acknowledged b}' the
North Carolina Department of Environment and Natural Resources Division of ]Cater Quality in
the NPDES Permit NC0074756 issued March 22. 3004 and effective May 1, 2004 As a result of
the preliminary analysis of the seepage from the Alcoa Badin landfill, monitoring for fluoride.
cyanide and toxicitc have been added to the routine testing required by permit I lotvever, the
permit writers sa\v no need to require a pre-treatment program for this bp -product Furthcr, it
was explained to both parties that should the need arise in the future due the quality of the
effluent from the landfill, the POTW \could become subject to a pre-treatment program at that
time
i have enclosed for your revie\\ a cop}of the NPDES permit NC0074756. If you have any
questions related this matter, please contact our offices at (704) 98(*1-3686
Sincere]\. yours.
Donna 1, Davis
Director
cc Robert Prezbindowski
File

ALCOA INC.
2300 North Wright Rd.
Alcoa TN, 37701
April 8, 2004
Ms. Donna Davis
Utilities Director
County of Stanly
201 South Second Street
Albemarle, North Carolina 28001
Re: Alcoa/Badin Landfill Seep Possible Waste Classification and Notification
Alcoa Badin Works, Badin, NC
Dear Ms Davis:
As you are aware, the Alcoa Badin Works Plant ("Alcoa") has requested that the Stanly County POTW
(the "POTW") in Badin, North Carolina accept a continuous flow of approximately four gallons per
minute ("gpm") of collected seep water from the Alcoa/Badin landfill. The town of Badin and Alcoa used
this landfill for 70 years to manage municipal and industrial solid waste. The composition of the waste
streams placed in the landfill by the town of Badin and Alcoa is not known. It is expected that typical
municipal refused generated by the town and undetermined amounts of industrial solid waste from Alcoa
Badin Works were managed at this landfill. The industrial wastes could possibly include wood, paper,
metal, carbon dust, small amounts of spent pot lining, spent carbon anodes, waste aluminum oxide bath,
and debris containing asbestos.
Spent pot lining (SPL) is generated during primary aluminum reduction and is currently listed as a
hazardous waste, K088. if SPL were in the landfill, leachate impacted by the SPL would be a "derived
from" hazardous waste. While the cyanide and fluoride observed in the Alcoa/Badin landfill seep are
constituents associated with SPL, the concentrations measured in the seep could be caused by other
sources, such as pot insulation, bath, and other non -hazardous waste materials. The historical measured
concentration of fluoride and cyanide in the seep are not indicative of what is typically measured at
known SPL landfills. However, as an overly conservative measure, Alcoa is considering this water to
potentially contain a listed hazardous waste.
As such Alcoa is required to provide notification in writing of its intent to discharge this material to the
POTW under 40 CFR 403.12(p)(1), which states:
The Industrial User shall notify the POTW, the EPA Regional Waste Management Division Director, and
State hazardous waste authorities in writing of any discharge into the POTW of a substance, which, if
otherwise disposed of, would be a hazardous waste under 40 CFR part 261. Such notification must
include the name of the hazardous waste as set forth in 40 CFR part 261, the EPA hazardous waste
number, and the type of discharge (continuous, batch, or other). If the Industrial User discharges more
than 100 kilograms of such waste per calendar month to the POTW, the notification shall also contain the
following information to the extent such information is known and readily available to the Industrial

Ms. Donna Davis
Director of Utilities
Stanly County
Page 2 of 7
User. An ident f cation of the hazardous constituents contained in the wastes, an estimation of the mass
and concentration of such constituents in the wastestream discharged during that calendar month, and an
estimation, of the mass of constituents in -the wastestream expected to be discharged during the following -
twelve months. All notifications must take place within 180 days of the effective date of this rule.
Industrial users who commence discharging after the effective date of this rule shall provide the
notification no later than 180 days after the discharge of the listed or characteristic hazardous waste. Any
notification under this paragraph need be submitted only once for each hazardous waste discharged.
However, notifications of changed dischargesmust be submitted under 40 CFR 403.12 (j). The
notification requirement in this section does not apply to pollutants already reported under the self -
monitoring requirements of 40 CFR 403.12 (b), (d), .and (e).
The above -referenced information for the subject discharge previously has been provided to you in earlier
correspondence. Nevertheless, this letter presents the information in one :explicit notification as required
by 40 CFR 403.12(p)(1). The wastewater. stream is. primarily comprised of groundwater seepage coming
from the area of the A1coaBadin Landfill. Table 1 summarizes the analytical results of a recent
wastewater sample collected onMarch 27, 2.003. Table 2 and 3 summarize the cyanide and fluoride data,
respectively, collected from the landfill seep since 1998.
A review of data collected from the wastewater during the past five years indicate that the water can
contain cyanide at concentrations ranging from non -detect to 0.061 mg/Li and fluoride in concentrations
from 11 mg/L to 27 mg/L. The historical wastewater flows have averaged approximately 4 gallons per
minute (gpm). with a maximum of .15 gpin. The higher flow rates and concentrations of cyanide were
observed prior to the closure and 'capping of the. landfill. This could. potentially result in a mass loading of
the following hazardous constituents:
Potential Average Potential Average 12 .
Monthly Loading Month Loading
(lbs)' (lbs)'
Cyanide 0.08 0.95
Fluoride2 35 420
'Based on the maximum.concentration recorded (0.061 mg/L CN, 27 mg/L F) in the past 5 years at the average flow
rate (3.6 gpm).
2Not a hazardous constituent, listed for informational purposes only.
If y_ou have any questions regarding the issue or desire additional information, please contact me at your
convenience.

a
Ms. Donna Davis
Director of Utilities
Stanly-County
Page 4 of 7
TABLE 1
Analytical Results ofAlcoa Badin Landfill Wastewater Stream
Lab Parameters
EPA Method
Water
Sample
BL-EFF
0719/7)
Detection
Limit
im��
NC Surface
Water
Standards
(nng/l� for
WS-IV
Cyanide
SM4500 CN C E.
ND
0.005
0.005
Amenable Cyanide
SM4500-I
ND
0.605
No Standard
Fluoride
SM 4500 F C
21
0.2
1.8
BOD
Method 405.1 .
ND
2.0
No, Standard
TOC
Method 415.1
5.3
1.0
No Standard
Alkalinity
Method 310.1
690
1.0
No Standard
Carbonate
Method
232014500
51
-
No Standard
Sulfate
Method 375.4
130
5.0
No Standard
Chloride
Method 325.2
16
1.0
250
Nitrate
Method 353.2
2.3
0.05
10
Iron:
Meth6d.3500
0.18
6.1
No Standard
Bromide
Method 300.0
ND
L 0
No Standard
Iodide
Method 300.0 .
ND
5.0
No Standard
Calcium
Method 6010
38
0.5
No Standard
Potassium
Method 6010
9.1
1.0
No Standard
Sodium
Method 6010
360
0.50
No Standard
Magnesium
Method 6010..
11
0.50
No Standard,
Manganese
Method 6010
1.41
0.01
200
Aluminum
Method 6010
0.34
6.2
No Standard
Strontium
Method 6010
0.17
0.01
No Standard

Ms. Donna Davis
Director of Utilities
Stanly County
Page 5 of 7
TABLE 2
Historical ABL Cyanide Loadings
Alcoa Badin Works
Badin, North Carolina
Cyanide
Seep Flow
Cyanide
Concentration
Rate
Loading
Date
(mg/L)
(gpm)
(lbs/day)
1/21/1998
NA
15.15
NA
2/25/1998
NA
14.83
NA
3/26/1998
NA
10.03
NA .
4/30/1998
NA
8.07
NA
5/26/1998
0.0120
2.22
0.0003 -
6115/1998
0.0050
3.13
0.0002
7/20/ 1998
0.0050.
0.98
0.0001
8/2411998
0.0056
0.97
0.0001
9/23/1998
0.0196
0.98
0.0002
: 10/23/1998
0.0110
1.29
0.0002
11 /10/1.998
0.0277..
1.80.
0,0006 .
12/7/1998
0.0610
1.81
0.0013
1/11/1999
0.0580
3.30
0.0023
2/10/1999
0.0480
4.26
0.0025
3/29/1999
0.0290
4.03
0.0014
4/1911999
0.0340
2.45
0.0010
5/28/1999
0,0110
2.16
0.0003
6/23/1999
0.0240
2.53
0.0007
7/20/1999
0.0280
1.25
0.6004
8/11/1999
0.0460
1.11
0.0006
9/22/1999
0.0560
1.13
0.0008
10/2811999
0.0450.
3.66
0.0020
11/17/1999
0.0430
2.16
0.0011
12/30/1999
0.0310
2.58
0.0010
2/8/2000
0.0340.
7.65
0.0031
3/29/2000
0.0400
6.77
0.0033
4/24/2000
0.0240
3.89
0.0011
5/19/2000
0.0090
1.99
0.0002
6127/2000
0.0050
4.50
0.0003
7/21 /2000
0.0050
3.55
0.0002
8/16/2000
0.0076
2.73
0.0002
9/22/2000
0.0058
3.55
0.0002
10/31/2000
6.0060
2.73
0.0002
1/4/2001
6.0081
1.46
0.0001
2/27/2001
0.0260
2.03
6.0006
3/28/2001
.0.0120
3.55
0.0005
4/27/2001
0.0050
4.50
0.0003
6/27/2001
0.0058
6.84
0.0005
7/31 /2001
0.0050
2.73
0.0002
8/28/2001
0.0050
1.46'
mow
10/24/2001
0.0050
2.03
0.0001
11/19/2001
0.0050
1.46
0.0001
1/2/2002
0.0050
0.99
0.0001
4/8/2002
0.0276
NA
NA
3/27/2003
0.0050
NA-
NA
12/16/2003
0.00002
NA.
NA
Maximum
0.0610
15.2
0.0033
Average
0.0214
3.63
0.0007
Note:
NA - Not Analyzed

Ms. Donna Davis
Director of Utilities
Stanly County
Page 6 of 7
TABLE 3
Historical ABL Fluoride Loadings
Alcoa Badin Works
Badin, North Carolina
Fluoride
Seep Flow
Fluoride
Concentration
Rate
Loading
Date
(mg//L)
(gpm)
(lbs/day)
1/21/1998
NA
15.15
NA
2%25/1998 _
NA
14.83
NA
3/26/1998
NA
10.03
NA
4/30/1998
NA
8.07
NA
5/26/1998
18.00
2.22
0.48
6/15/1998
20.00
3.13
0.75
7/20/1998
23.69
0.98
0.28
8/24/1998 .
24.00
0.97
0.28
9/23/1998
21.31
0.98
0.25
10/23%1998
15.00
1,29
0.23
11 /10/1998
16.54
1.80
0.36
12/7/1998
14.44
1.81
0.31
1 /11/1999
13.37
3.30
0.53
2/10/1999
12.40
4.26
0.63
3/2911999
12.39
4.03
0.60
4/19/1999
15.40
2.45
0.45
5/28/1999
15.50
2.16
0.40
6/23/1999
13.46
2.53
0.41
7/2011999
14.00
1.25
0.21
8/11/1999
19.00
1.11
0.25
9/22/1999
17.00
1.13
0.23
10/28/1999
14.31
3.66
0.63
11117/1999
15.44
2.16
0.40
12130/,1999
15.40
2.58
0.48
2/8/2000
11.11 _
7.65
1.02
3/29/2000
14.46
6.77
1.18
4/24/2000 :
16.49
3.89
0.77
5/19/2000
'18.51
1.99
0.44
6/27/2000
24.00
4.50
1.30
7/21/2000
22.00
3.56
0.94
8/16/2000
27.00
2.73
0.88
9/22/2000
24.00
.3.55
1.02
10131 /2000
18.00
2.73
0.59
1 /4/2001 .
16.00
1.46
0.28
2/27/2001
16.00
2.03
0.39
3/28/2001
16.00
3.55
0.68
4/27/2001
14.00
4.50
0.76
6/27/2001
16.00
6.84
1.31
7/31%2001
19.00
2.73
0.62
8/28/2001
21.00
1.46
0.37
10/24/2001
16.00
2.03
0.39
11 /19/2001
16.00
1.46
0.28
1/2/2002
15.00
0.99
0.18
3/27/2003
21.00
NA
NA
12/16/2003
15.40
NA
NA
Maxifnum
27 •
15.2
1.31
Average
17.3
3.63
0.55 ,
Note: NA - Not Analyzed
k

4l 5/2016 Stanly County, NC Mail - Acoa Landfill Leachate Change
L
STANLY COUNTY Donna Davis <[e-mail]>
Alcoa Landfill Leachate Change
5 messages
Donna Davis <[e-mail]> Fri, Feb 19, 2016 at 11:30 AM
To: "Sifford, Barbara" <barbara.sifford@ncdencgov>, 'Bell, Wes" <wes.bell@ncdencgov>
Good morning,
An Alcoa representative recently sent me this letter regarding like changes to the concentration of contaminant
in the landfill leachate that is discharged to the Greater Badin WWiP. Please let me know if there are in
concerns from your perspective with the changes. Thank you.
Donna Davis
Stanly County Utilities
1000 N 1st Street
Suite 12
Albemarle, NC 28001
[phone]
in Notice Letter 02 2016.pdf
4045K
Bell, Wes <[e-mail]> Fri, Mar4, 2016 at 3:14 PM
To: Donna Davis <[e-mail]>
Good afternoon,
I would contact Teresa Rodriguez at [e-mail] or by phone at 919-807-6387 to discuss
Alcoa's letter. Teresa may have to get the permit writer for the Greater Badin WWTP involved also. Teresa is
handling the permit renewal for Alcoa and we have emailed her a copy of Alcoa's letter from your email.
Hopefully Teresa can provide additional guidance for you in this matter.
Wes
From: Donna Davis [mailto:[e-mail]]
Sent: Friday, February 19, 2016 11:31 AM
To: Sifford, Barbara <[e-mail]>; Bell, Wes <[e-mail]>
Subject: Alcoa Landfill Leachate Change
[Quoted text hidden]
Pursuant to North Carolina General Statutes, Chapter 132, email correspondence to and from this address may
be considered public record under North Carolina Public record Laws and may be disclosed to third parties.
Mips:llmail.google.comhnaillcaliJN?ui=2&ik=dl8e9c82ce&view=pt&searclr-inbou&R=152fa5ea365e4c6e&siml=152fa5ea365e4c6e&siml=15434a46b6611491&... V2

40512016
Stanly County, NC Mail - Alcoa Landfill Leachate Change
Donna Davis <[e-mail]>
To: [e-mail]
Ms. Rodriguez,
Wed, Apr 20, 2016 at 1:07 PM
I just wanted to follow up Wes Bell's forwarding of our information to you. Are there any additional steps Greater
Badin needs to take regarding these changes. Thanks.
Donna Davis
[Quoted text hidden]
Rodriguez, Teresa <[e-mail]>
To: Donna Davis <[e-mail]>
Mon, Apr 25, 2016 at 10:15 AM
Ms. Davis, the pretreatment group looked at this and calculated expected loadings for fluoride and cyanide
into the POTW and concluded that unless you think the POTW has potential to cause violations for fluoride or
cyanide this will not be a situation that would require a pretreatment program. If you have any questions you
can contact Deborah Gore, PERCS Unit Supervisor at 919-807-6383.
Teresa
From: Donna Davis [mailto:[e-mail]]
Sent: Wednesday, April 20, 2016 1:08 PM
To: Rodriguez, Teresa <Teresa. Rod [e-mail]>
Subject: Fwd: Alcoa Landfill Leachate Change
[Quoted text hidden]
Donna Davis <[e-mail]>
To: "Rodriguez, Teresa" <Teresa.Rodriguez@ncdenrgov>
Ms. Rodriguez,
Thank you very much for you review and assistance.
Donna Davis
Stanly County Utilities
(Quoted text hidden]
Mon, Apr 25, 2016 at 1:20 PM
hdps://mail.google.comlmail/ca/u/0/?ui=2&i k=dl8e9c82c0&view=pt&search=i nbox&th= 152fa5ea365e4c6e&sim1= 152fa5ea365e4c6e&situ 1= 15434a46b8b11491&... 212

From: Gore, Deborah
To: Rodriguez. Teresa
Cc: Basinoer. Corey: Pitner. Andrew
Subject: RE: Alcoa Landfill Leachate Change
Date: Monday, February 22, 2016 3:08:37 PM
Attachments: imaae002.ono
I put some numbers into a headworks spreadsheet. I checked BIMS for average flow = 0.473 MGD
(permitted flow 0.55 MGD)
The cyanide is not an issue. Even at the maximum concentration (0.041 mg/1) and flow (0.0288
MGD), its only 0.0098 pounds/day and there is 88.6% of the allowable load remaining.
Fluoride. I didn't have any site specific removal rate information, but Durham County includes
fluoride in their HWA so I used their average removal rate of 13.9 %. I also assumed a concentration
of 1.0 mg/I (about 3.9 pounds) from uncontrollable since drinking water is fluoridated. Based on the
stream standard of 1.8 mg/I the maximum allowable load for fluoride is 11.2 pounds/day.
At the maximum concentration (48.2 mg/1) and maximum flow (0.0288 MGD) there would be 11.6
pounds from Alcoa and the WWTP would violate the stream standard.
At the average concentration (22.7 mg/1) and max flow there would be 5.4 pounds from Alcoa and
the WWTP would have 15.9 %of the allowable remaining.
At the average concentration and the average flow (.0072 mgd) there would be 1.4 pounds from
Alcoa and the WWTP would have 52.5 % of the allowable load remaining.
When we enter limits in the allocation table, if there are daily max and monthly average, we enter
the monthly average since that's typically what the WWTP has to worry about.
Based on averages fluoride would appear not to be an issue either. The DMR indicates and average
in 2015 (4 data points) of 0.59 ug/I — not sure if it's really mg/I (?). This is not a situation that would
require a pretreatment program unless the POTW believes the discharge from Alcoa has the
potential to cause violations of the POTW's NPDES permit.
Let me know if you have any further questions,
Deborah
Deborah Gore
PERCS Unit Supervisor
Division of Water Resources
Department of Environmental Quality
919-807-6383 office
919-807-6489 fax
[e-mail]
1617 Mail Service Center
Raleigh, NC 27699-1617

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Rodriguez, Teresa
Sent: Monday, February 22, 2016 8:51 AM
To: Gore, Deborah <[e-mail]>
Subject: FW: Alcoa Landfill Leachate Change
Deborah, would there be any pretreatment issues associated with this proposal?
Thanks,
Teresa
From: Bell, Wes
Sent: Friday, February 19, 2016 11:37 AM
To: Basinger, Corey <rorey bacinger(@ncdenr.eov>; Rodriguez, Teresa
<Teresa Rodrig i (can d nr.eov>
Cc: Pitner, Andrew <andrew pitner(a)ncdenr.eov>
Subject: FW: Alcoa Landfill Leachate Change
Comments?
From: Donna Davis [mailto-ddavis(lstanlycounty
Sent: Friday, February 19, 2016 11:31 AM
To: Sifford, Barbara <barbara.sifford(@ncdenr.gov>; Bell, Wes <wpc b II(@ncdenr eov>
Subject: Alcoa Landfill Leachate Change
Good morning,
An Alcoa representative recently sent me this letter regarding like changes to the
concentration of contaminant in the landfill Leachate that is discharged to the Greater Badin
W WTP. Please let me know if there are in concerns from your perspective with the changes.
Thank you.
Donna Davis
Stanly County Utilities
1000 N 1s' Street
Suite 12

0
Albemarle, NC 28001
[phone]
Pursuant to North Carolina General Statutes, Chapter 132, email correspondence to and ,from this
address may considered public record under North.Carolina Public record Laws and may be
disclosed to third parties.

ALCOA INC.
2300 North Wright Rd.
Alcoa TN, 37701
May 25, 2016
Ms. Deborah Gore
PERCS Unit Supervisor
North Carolina Department of Environmental Quality
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
VIA ELECTRONIC MAIL
Re: Completion of the Regulatory Review for the Modification of the Existing Seep Collection
System at the Alcoa/Badin Landfill; Alcoa, Inc.; Badin, North Carolina
Dear Ms. Gore:
Per your conversation via telephone with Mr. Michael Worden on May 23, 2016, Alcoa, Inc. ("Alcoa")
is seeking to complete our internal regulatory review process of the proposed modification to the
existing seep collection system at the Alcoa/Badin Landfill to the Stanly County Publically Owned'
Treatment Works (the "POTW").
As you may be aware, Alcoa's Badin Works Plant (the "Plant') requested in 2005 that the Stanly County
POTW in Badin, North Carolina receive a flow of collected seep water from the Alcoa/Badin Landfill.
In a letter dated November 28, 2005 from Ms. Donna Davis with Stanly County, the county notified
Alcoa that is was ready to receive the discharge and that NCDENR Division of Water Quality
specifically acknowledged the NPDES permit NCO074756 (see Attachment 1). After receiving this
approval the collected seep water was conveyed via below grade piping to the POTW sanitary sewer
system connection on Wood Street in Badin, North Carolina.
In 2015, Alcoa began evaluating upgrades and modifications to the existing seep collection system.
Alcoa proposed to replace the existing three individual seep collection points with a trench based seep
collection system. This upgrade to a trench system will improve overall seep capture and collection
efficiency. This greater efficiency is achieved by intercepting seep water below grade immediately
down gradient to the landfill. Second, the use of a below grade collection system will dramatically
decrease the potential inflow of surface storm water into the collection system during rain or flooding
events. A layout of the proposed trench based seep collection system is provided as Attachment 2.
Alcoa provided notification to Stanly County of the proposed change in a letter dated January 15, 2016
(see Attachment 3).
As provided in Attachment 4, the North Carolina Department of Environmental Quality (NCDEQ)
received correspondence from Stanly County concerning the change in the discharge from the existing
seep collection system. It is our understanding that on February 19, 2016, Ms. Donna Davis, Director of
Stanly County Utilities provided the Division of Water Resources (DWR), Water Quality Regional
Operations Section (WQROS), Mooresville Regional Office (MRO), and Ms. Barbara Sifford,

Ms. Deborah Gore
NCDEQ
May 25, 2016
Page 2 of 2
Wastewater Consultant with the NCDEQ, DWR Operator Certification Section, MRO with a copy of
Alcoa's January 15, 2016, letter (Attachment 4). Ms. Davis asked if NCDEQ has "concerns from your
perspective with the changes". Mr. Bell forwarded the information via email to Ms. Teresa Rodriguez,
Engineer, with the NCDEQ, DWR, Water Quality Permitting Section, Complex Permitting Branch.
On April 20, 2016, Ms. Davis followed up with Ms. Rodriguez by asking if "there are any additional
steps Greater Badin needs to take regarding these changes". On April 25, 2016, Ms. Rodriguez
responded by email with the following:
"the pretreatment group looked at this and calculated expected loadings for fluoride and cyanide
into the POTW and concluded that unless you think the POTW has potential to cause violations
for fluoride or cyanide this will not be a situation that would require a pretreatment program. "
In a conversation with Ms. Rodriguez via telephone on May 23, 2016, Ms. Rodriguez indicated that she
forwarded the email containing the January 15, 2016, letter to your office. Per our conversation on May
23, 2016, NCDEQ's opinion is that the proposed modification to the existing seep collection system is in
compliance with Stanly County NPDES permit. This information was summarized in an email from
your office to Ms. Rodriguez on February 22, 2016. Mr. Corey Basinger, Regional Supervisor with the
NCDEQ, DWR, WQROS, MRO and Mr. Andrew Pitner, Assistant Regional Supervisor with the
NCDEQ, DWR WQROS, MRO were copied on that email (see Attachment 5).
It is our further understanding that no concerns were made pertaining to the proposed modification to the
existing seep collection system. It is Alcoa's understanding that multiple NCDEQ, DWR staff have
reviewed the proposed changes and they had no issues or concerns. Based upon these internal
assessments NCDEQ agreed with Stanly County's request to accept the change in the discharge from the
seep collection system. If Alcoa's understanding is incorrect, please advise us as soon as possible.
Alcoa appreciates the time and effort your office has spent on this project and we look forward to
working with you and your staff in the future. Should you have any questions or comments, please
contact me at [phone] at your convenience.
Sincerely,
'Oe " — ,
Michael Worden
for
Robert A. Prezbindowski
Alcoa Remediation
cc: Mr. Robert McDaniel, NCDEQ, DWM, HWS, Facility Management Branch
Ms. Teresa Rodriguez, NCDEQ, DWR, WQPS, Complex Permitting Branch

40=*+
Stanly County
1000 N Fint Strat 1•R,�
ALBEMARLE, NORTH CAROLINA
280
Phont (704) 9863600
\ovember 'a. 2005
\Ir Timoth.\ \1 hite. REM
Environeering. Inc
16350 Park Ten Place
Suite 1.10
Houston. Teas 77O84
Dear Mr. \\'hite
'The Greater Badin \;astewater 1'reatntent Plant is read% to begin receiving tloil from the
AlcoaiBadin landfill. This discharge from the landfill teas speciticaliv acknowledged by the
\orth Carolina Department of I moronnlcnt and \atural Resources Division oft\'ater Qualitt ill
the N'PDf S Permit \('0074756 issued March 22, 2004 and effective Ma} I. 2004 .As a result of
the preliminary analysis of the seepage from the Alcoa'Badm landfill, monitoring for fluoride.
c\anide and wxicih have been added to the routine testing required by permit I [owe\er. the
permit writers sat.\ no need to require a pre-treatment program for this by-product Further. it
was e\plained to both parties that should the need arise in the future duc the quality of the
ellluent Gont the landfill, the POT\1tlould become subject to a pre-treatment program at that
tittle
I have enclosed for \our review a copy of the \PDES permit \00074756. If \ou hate an\
questions related this matter, please contact our offices at [phone]
Sincere[.\ Yours.
�nAIALA
Donna L Da\is
Director
cc Robert Prezbindowski
File

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