NC0005177_WASTELOAD ALLOCATION_19931216

NPDES DOCUNENT SCANNIMG COVER SHEET
NPDES Permit: NC0005177
FMC Lithium
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: December 16, 1993
Thin aocumerLt In priatea a.X2L z eufse psper-InpM40we BUxy
coaterit on the wew8ree eiae

DIVISION OF ENVIRONMENTAL MANAGEMENT
December 16, 1993
MEMORANDUM
TO: Randy Kepler
THRU: Ruth Swanek
Carla Sanderso W
FROM: CJacquelyn M:_Nowell�
SUBJECT: FMC-Lithium Corporation- Request for Alternative Monitoring Schedule
NPDES Permit No. NCO005177
Gaston County
The Instream Assessment Unit has reviewed the October 1 Ith letter from the subject
facility requesting modifications and alternatives to the limits and monitoring frequencies
recommended in the draft permit. The monitoring schedules given were based on North
Carolina regulation 15A NCAC 213.0508 which determines frequency of tests and
measurements of dischargers based on the standard industrial classification (SIC) and
treatment plant classification. The monitoring frequencies recommended for FMC-Lithium
were the minimum requirements for industrial dischargers with an SIC Code of 2819 and
2869 and a.treatment plant class of M. We have re-evaluated the FMC data and have the
following recommendations:
1)BOD5 - Based on the results of a calibrated water quality model for the
Crowders Creek Basin, new limits for BOD5 and dissolved oxygen (DO) were assigned to
FMC. Due to predicted instream DO levels below 5 mg/1 in Abernethy Creek downstream
of FMC's discharge, effluent limits for BOD5 and DO were deemed necessary. FMC has
requested that BOD5 be sampled monthly instead of 3/week as recommended. We will
concur with the frequency reduction for BOD5 to monthly monitoring, since this parameter
has been sampled on a monthly basis in the past.
2)per( - In regards to DO monitoring,since the model indicates that effluent DO is
primarily the cause for the predictions of low DO instream, we cannot agree to only
quarterly monitoring for this constituent. It is not the intention to place undue hardship on
the facility, however, for the protection of water quality of Abernethy Creek, more frequent
monitoring than quarterly is necessary. We will recommend wepkly monitLnniz f r D
rather than 3/week"as previously recommended.
3) 1 ni m - A further review of compliance data has shown that selenium has
been consistently recorded at levels below detection for several years. We concur with the
deletion of the selenium limit at-all wasteflows.
4) Nickel - We recommend the deletion Qf effluenl monitoring for nickel since data
has shown that this constituent has been recorded as below detection in the last two priority
pollutant scans.
5) Bromodichloromcthane and DibromS?,hlorgmethane - Data analyses has
indicated that both these carcinogens are present in FMC's effluent in concentrations that
exceed EPA criteria. Since both_parameters_are limes based on water quality protection,

- Page 2 -
FMC memo
we will recommend that FMC monitor both I romodichlorometh_ane and
djb.Mmochlorogrkthane on a monthly basis rather than quarterly as requested.
6) Total Nitro yen and Total Phosphorus - The following recommendation for TP
and TN was inadvertently omitted from the wasteload allocation and should be placed into
the draft permit: To reduce nutrient enrichment in the three eutrophic arms of Lake Wylie,
the Lake Wylie Management Plan recommends all existing point source dischargers to the
Crowders Creek watershed with a permitted design flow greater than 0.050 MGD will be
required to apply state of art nutrient removal technology. FMC-Lithium will be allowed a
five year time frame to come into compliance with a TP limits of 0.5 mg/1 and TN limits of
4 mg/l (summer) and 8 mg/l (winter).
7)For the other parameters listed under the proposed monitoring schedule, we will
concur with FMC's proposed frequencies since these were the schedules under the old
permit. This includes total suspended residue, bromoform, chloroform, chlorides,
chromium, conductivity, copper, NH3, total dissolved solids, zinc, and pH.
Please contact me if there any questions concerning these monitoring frequency
changes.
cc: Coleen Sullins
Rex Gleason
Central Files
a.

FWC- L�1�i••J
M3
/`�/c1K0aElc�e.�aY�IA`�' c0 V��� LaG�- �O� fe*f�iicYa�[Vl_
70
AL
ZG avy v
uw,vfi l Zvv
J
��LKc�S, d �T.�,;ni h a.vt' �d✓�G1-t �lu�_ 12h�f.+ti S o�a�wr,f- �.��..sf�+�

FMC Corporation
,A
'Lithim-n Division
Highway 161r:'i`
Box 795
Bessemer City North Carolina 28016J �,� x�` ��9J
704 868 5300 Fax [phone]
1�r F.s '•' :� Ar
S.Lu
October 11 , 1993
Mr. Steve W. Tedder, Chief
Water Quality Section
Division of Environmental Management
NC Department of Environment, Health and Natural
Resources L}/
P.O. Box 27687
Raleigh, NC, 27611-7687
Dear Mr. Tedder:
Thank you for taking the time to talk with us several
days ago about our NPDES Permit and our SOC for
compliance with the bioassay testing program. Following;
your request, we are addressing this letter directly to
you. This is to present our comments on the renewal of
our NPDES Permit NCO005177 and to addresss the matter of
continuance of our SOC EMC WQ No. 91-05 .
Our permit renewal is scheduled to be issued on November
15 , 1993.
SOC EXTENSION:
+ We are requesting that the compliance condition of SOC WQ
No. 91-05 be extended at least until the expiration date
of the SOC, which is December 31 , 1993 . If possible, we
would like to have this date and the expiration date be
extended four months -until April 30, 1994 .
PERMIT CHANGES:
1 . As per your suggestion, we are requesting that the
bioassay compliance regirement be waived and a monthly
monitoring-only requirement be inserted in its place
for the first 12 months of the new permit. We also
request authorization to do .additional testing to
provide for quarterly averaging, where it is deemed
useful .
2 . We are requesting permission to continue the use of
"grab" sampling for testing the outfall 'and the
upstream and downstream waters . All of these sampling
points are remote and electrical power is not
available. Wastewaters are discharged through a large
treatment pond, where short term variations in
concentration are smoothed out. The pond serves as a
compositing mechanism.

Page 2
October 11 , 1993
3 . We believe the testing requirements for chemical
constituents in the outfall and the receiving stream
upstream and downstream to be excessive and
unwarranted. The testing program includes eight new
constituents to be analyzed and in many cases , calls
for a testing frequency of three times per week.
Excluding the bioassay testing, the proposed total
number of determinations to be made over a month' s
period is nearly four times that we are now doing.
This represents an significant increase in testing
costs and will require considerably more manpower for
field work and sample preparation.
We propose an alternate testing schedule which is
attached.
Your serious consideration of these proposals will be
greatly appreciated. Please call our Mr. Arthur Gillespie
or Gerald Scott, should you have technical questions
concerning these requests .
Sincerely yours,
J. E. McLeod B�j/� f�
3 Plant Manager
cc. G. W. Matthews
A. S. Gillespie
R. Ahuja
P. L. Schroeder
C . Navarrete
G. R. Scott
R. Bridgeman-Mooresville
R. Gleason-Mooresville

FMC TESTING PROPOSAL
FOR RENEWED PERMIT
NC 000 5177
TEST FMC PROPOSAL DRAFT PERMIT OLD PERMIT COMMENTS
Flow Cont./Rec (E-I ) Same Same
BOD, 5-Day Monthly (E ) • 3/Week (E ) Monthly (E,U,D)
Total Suspended 2/Month (E ) 3/Week (E ) 2/Month (E,U,D)
Residue
Bromodichloromethane Quarterly ( E ) - 3/Week (E) None
Dibromochloromethane Quarterly ( E ) 3/Week (E ) None
Selenium" None 3/Week (E ) 2/Month Not found by prior
analyses
Dissolved Oxygen Quarterly ( E ) 3/Week (E) None
Bromoform xQuarterly (E) Quarterly (E) None
Chloroform / Quarterly (E ) Quarterly (E) None
Chlorides Monthly (E,U,D) 2/Month (U,D) Monthly (E,U,D)
Chromium Monthly (E ) 2/Month (E) None
Conductivity Weekly (E,U,D) 3/Week (E ,U,D) Weekly (E ,D)
Copper Monthly (E ) 2/Month (E,U,D) Monthly (E )
NH3 as N Monthly (E ) 2/Month (E ) Monthly (E,U,D)
Nickel None 2/Month ( E) None Not found by prior
analyses, last 3 years
Total Dissolved Solids Monthly (E,U,D) 2/Month (U,D) Monthly (E,U,D)
Total Phosphous }Quarterly (E ) Quarterly (E ) Quarterly (E )
Total Nitrogen X Quarterly (E ) Quarterly (E ) Quarterly (E )
(NO2 + NO3 +TKN)
Zinc Monthly ( E ) 2/Month (E ) None
Chronic Toxicity Quarterly (E) Quarterly (E ) Quarterly See accompanying letter
pH Weekly (E ) 3/Week Weekly
*All sampling except flow is to be done by grab sampling. The treatment pond serves as a
compositing mechanism.

Page 1
Note for Jackie Nowell
From: Carla Sanderson
Date: Mon, Nov 29, 1993 7:40 AM
Subject: FW: FMC Corp - Lithium -nc0005177
To: Jackie Nowell
Please see Randy's note below - due date for Lithium response. See 2B.0505 (c)(3) for
composite vs grab. You may also want to contact someone over in operator training (Cindy
F.'s group) to see if the treatment pond of this kind could serve as a compositing mechanism.
As far as a decrease in monitoring requirments - what data do they have to support less
monitoring needed?
From: Randy Kepler on Mon,Nov 29, 1993 6:58 AM
Subject: RE: FMC Corp- Lithium-nc0005177
To: Carla Sanderson
Go ahead and let Jackie get to it as long as I can get the permit out first or second week of
Dec.
From: Carla Sanderson on Wed, Nov 24, 1993 12:36 PM
Subject: FMC carp- Lithium -nc0005177
To: Randy Kepler
Cc: Jackie Nowell
Are you still going to try and issue this permit in Nov.?Which I guess means Mon or Tues
of next week. If so, I will try to get something to you today. If not, it may wait until next
week when Jackie can get to it. Let me know. Thanks!

Division of Environmental Management
November 2, 1993
MEMORANDUM
To: Coleen Sullins
Through: Larry Ausley
Ken Eagleson
From: Matt Matthews rv'
Subject: Whole Effluent Toxicity Testing Permit Language
Lithium Corporation
NPDES No. NC0005177
Gaston County
Please find attached whole effluent toxicity testing permit language for the subject
facility. The requirement specified by the first attachment (CHRONIC TOXICITY
MONITORING (QRTRLY)) should be in effect for the first two years of the permit.
The requirement specified by the second attachment (CHRONIC TOXICITY
PASS/FAIL PERMIT LIMIT(QRTRLY)) should be in effect from two years past the
effective date of the permit through the remainder of the life of the permit.
If there are any questions, please contact me at 733-2136.
cc: Central Files
Rex Gleason, MRO
NOV 9
f
i°i

CHRONIC TOXICITY MONITORING (QRTRLY)
The permittee shall conduct chronic toxicity tests using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration defined as treatment two in the North Carolina procedure document is
78%. The permit holder shall perform quarterly monitoring using this procedure to establish
compliance with the permit condition. The tests will be performed during the months of January,
April,July, and October. Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally,DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Rd.
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
QCM PIF Version 10191

CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent bioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *September 1989) or subsequent versions.
The effluent concentration at which there may be no observable inhibition of reproduction or
significant mortality is 78% (defined as treatment two in the North Carolina procedure document).
The permit holder shall perform Quarterly monitoring using this procedure to establish compliance
with the permit condition. The tests will be performedduring the months of January, April, July,
and October. Effluent sampling for this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGP3B. Additionally, DEM Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual
chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Environmental Management indicate potential impacts to the receiving stream, this
permit may be re-opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test
and will require immediate retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
QCL PIF Version 9191