NC0004308_WASTELOAD ALLOCATION_19920715

NPDE S DOCUWE NT SCANNINS COVER $MEET
NPDES Permit:
NC0004308
ALCOA — Badin Works
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Monitoring Report
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
July 15, 1992
MIXIIS document is printed on reuse paper -ignore any
cowwtexxt on the reverse aide

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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
William W. Cobey, Jr., Secretary
July 15, 1992
A. Preston Howard, Jr., P.E.
Acting Director
This is rough and probably has some typos and
grammatical errors, but the meeting is thursday and
wanted to get a copy to you as soon as possible. If I am
to modify the draft as outlined in time for the meeting,
will need to get comments back as soon as possible.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jeffrey J. Lettrich, Attorney
Aluminum Company of America
1501 ALCOA Building
Pittsburgh, PA 15219
Subject: NPDES Permit No. NCO004308
Aluminum Company of America
Badin Facility
Stanly County
Dear Mr. Lettrich:
In accordance with your Petition for Contested Case Hearing filed on May 29, 1992, we
are forwarding herewith a draft permit outlining modifications the Division is willing to make to the
subject permit. These modifications are as follows:
• PERMIT COVER SHEET:
Since the request involved a modification to an existing permit, the expiration date
has been revised to the original expiration date of May 31, 1994.
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Lettrich
Page Two
• SUPPLEMENT TO PERMIT COVER SHEET, PARAGRAPH 2:
Provided that the flow from the lagoon (Outfall 005) does not exceed the capacities
of the treatment facilities, an oil/water separator, the proposed lagoon dewatering
does not require an Authorization to Construct. The Supplement To Permit cover
sheet has been revised.
• MAP SHOWING OUTFALLS 002, 005, 007, 008, 009 AND 010:
The map has been modified to show the correct location of outfall 004. Outfalls
006 (NC0081949), 007 (NC0081957) and 008 (NC0076775) will be deleted from
the permit upon issuance of pen -nits currently being processed by the Division and
upon formal request by ALCOA.
• MAP SHOWING OUTFALL 004:
The map has been removed and outfall 004 shown in its correct location as
described above.
• PAGE A.(1) EFFLUENT LIMITATIONS AND MONITORING
REQUIREMENTS - BOILER HOUSE:
The permit states that "The temperature of the effluent shall be such as not to cause
an increase in the temperature of the receiving stream of more than 2.8°C and in no
case cause the ambient water temperature to exceed 32°C." If the ambient
upstream water temperature exceeds 32°C, then ALCOA would not be considered
the cause of the temperature exceedence and no enforcement action would be
taken. (Don, see Coleen's note on Draft)
• PAGE A.(3) EFFLUENT LIMITATIONS AND MONITORING
REQUIREMENTS:
As requested, the current limits for outfall 005 will remain in effect until Phase I
activities are begun. Phase I limits will be implemented when lagoon dewatering
begins. Phase II limits will be implemented at the completion of lagoon
dewatering.
The Division cannot concur with ALCOA's request to change the language of the
discharge from "contaminated wastewater" to "compressor condensate wastewater"
for outfall 005. Because the lagoon was used as a treatment system in the past
and may still harbor residual waste, the term " compressor condensate
wastewater" is considered inappropriate for Phase I.
• PAGE A.(4) EFFLUENT LIMITATIONS AND MONITORING
REQUIREMENTS: (Refer to Page of Letter)
• PAGE A.(7) EFFLUENT LIMITATIONS AND MONITORING
REQUIREMENTS:
The Division cannot concur with the request for a modification in the limits for
outfall 009 in regards to cyanide concentrations in light of the fact that the data
collected do not appear to be sufficient to warrant granting such a request.

Page Three
Mr. Lettrich
However, this request will be taken into consideration upon review of the discharge
monitoring reports during the permit renewal process in 1993 and 1994.
• PAGE 4 of 14, SECTION B. (1)(a) DUTY TO COMPLY:
The North Carolina NPDES program is a delegated federal program to the state. As
a delegated state program, we are required to issue permits in accordance with and
enforceable under federal rules and regulations. The Duty to Comply requirement
is a federal regulation, see Chapter 40 of the Code of Federal regulations Part
122.41 (a)(1). Additionally, under North Carolina Administrative Code, 15 NCAC
2B .0208, toxic substances in surface waters are not allowed to be injurious to
aquatic life or wildlife, recreational activities, public health or impair the surface
waters for any designated use. Under N.C.G.S. 143-215, the Environmental
Management Commission is authorized and directed to develop, adopt, modify and
revoke effluent standards and limitations as it determines necessary to prohibit,
abate or control water pollution. The effluent standards or limitations may provide
prohibitions for toxic wastes.
• PAGE 6 of 14, SECTION B. (10) EXPIRATION OF PERMIT:
This is standard language on all permits. In review of your comments, we agree
that the language is confusing. We are currently in the process of reviewing our
boiler plates to clarify ambiguous language.
• PAGE 8 of 14, SECTION C. (4) BYPASSING OF TREATMENT
FACILITIES:
Section C. (4)(b) states that "The permittee may allow any bypass to occur which
does not cause effluent limitations to be exceeded..." This should not cause a
violation in that ALCOA has stated that such an anticipated bypass would create
sufficient dilution to lower cyanide concentrations levels well below the permit
limitations.
• PAGE 10 of 14, SECTION D. (2) REPORTING:
The correct mailing address is:
Division of Environmental Management
Water Quality Section
Attention: Central Files
Post Office Box 29535
Raleigh, North Carolina 27626-0535
• PART 111, SECTION C, PARAGRAPHS (a) and (b):
The definition of Toxic Pollutants is in Part II, Section A, definition # 12. This
definition states that Toxic Pollutant means any pollutant listed as toxic under
section 307 (a)(1). Please also see 40 CFR 122.2.

Page Four
Mr. Lettrich
• PART 111, SECTION E, PHASE I TOXICITY MONITORING:
The Division accepts ALCOA's request to modify the acute toxicity requirement for
outfall 005 from Fathead Minnow using a 24 hour composite sample to
Ceriodaphnia dubia using a grab sample for both Phase I and Phase II toxicity
requirements. Given the short duration of the lagoon dewatering, only one acute
toxicity test will be required for the discharge during Phase I.
We concur with your request that the permit be modified to require toxicity testing
during the actual dewatering of the lagoon. The language has been modified as
follows: "The samples will be collected of the dewatering discharge and the tests
performed within a week of the lagoon dewatering phase."
• PART 111, SECTION F, PHASE II TOXICITY MONITORING:
During Phase II, Quarterly Chronic Toxicity (Ceriodaphnia) monitoring will be
required at an effluent concentration of 90% during the months of March, June,
September and December. A grab sample may also be used for this test.
(Don, I am still trying to clarify the issue with TSB concerning
complex vs noncomplex)
Since this discharge is to be continuous, the Division feels that Chronic Toxicity
monitoring would be appropriate. ALCOA will be required to monitor the
discharge at 90% effluent concentration on a quarterly basis for the duration of the
permit. As requested, a grab sample will be allowed.
Attached is a draft of the revised permit. If any terms or conditions adjudicated proposed
by this modification are unacceptable to you, you should notify us within thirty (30) days following
receipt of this letter. If this permit modification is acceptable, ALCOA 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. The original Notice of Withdrawal form should be submitted to the Office of
Administrative Hearings.
Please examine the enclosed draft permit and ensure that the changes are acceptable to you.
When you have withdrawn your request for Contested Case Hearing, the modified permit will be
issued. If the proposed modifications are not acceptable to you, please notify us within thirty days
and we will proceed with the adjudicatory process.
If you have any questions concerning this permit, please contact Charles M. Lowe at
telephone number 919-733-5083.
Sincerely,
A. Preston Howard, Jr. P.E.
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
Permits and Engineering Unit
Central Files
Compliance

4
DIVISION OF ENVIIZ(-)NA�NTAL MANAGEMENT
June 17, 1992
u - LO '7• W 1 10
TO: Coleen Sullins
Charles Lowe
FROM: JSusa A. Wilso
THROUGH: Ruth Swan&&
Carla Sanderson(
SUBJECT: ALCOA
Comments on Draft Permit
NCO004308
The Technical Support Branch has received the copy of ALCOA's comments on the draft
permit for NPDES.NC0004308. Technical Support will limit its comments to items that
are related to wasteldad allocations, although 005 was the only outfall which Technical
Support modified this permitting period.
Effluent Limitations and Monitoring Requirements:
Technical Support finds no reason to change the language regarding temperature for outfall
002. The permit clearly states that "the temperature of the effluent shall be such as not to
cause an increase in the temperature of the receiving stream of more than 2.8°C and in no
case cause the ambient water temperature to exceed 32°C." If the ambient upstream water
temperature is 33°C, then ALCOA is not the cause of the temperature exceedance and no
enforcement action would be taken.
Technical Support concurs with ALCOA's request to implement their current limits for
Outfall 005 (which is storm water and NCCW), then Phase I limits when the lagoon
dewatering begins, and Phase I1limits after completion of lagoon dewatering (which will
consist of storm water, NCCW, and compressor condensate wastewater).
Technical Support cannot concur with ALCOA's request to change the language of the
discharge from "contaminated wastewater" to "compressor condensate wastewater" for
outfall 005. Because the lagoon was used as a treatment system in the past which may still
harbor residual waste, the term "compressor condensate wastewater" is not appropriate
during Phase I.
Technical Support, in consultation with the Environmental Sciences Branch, accepts
ALCOA's request to modify the acute toxicity testing requirement for 005 from Fathead
Minnow using a 24 hour composite sample, to Ceriodaphnia dubia using a grab sample for
both Phase I and Phase II toxicity requirements. Based on the Environmental Sciences
Branch comments, and given the short duration of the lagoon dewatering, only one acute
toxicity test will be recommended for the discharge during Phase I.

The requirement for toxicity testing, for outfall 005, during the first five discrete discharge
events is inappropriate for Phase II based on ALCOA's comments. Since this discharge is
to be continuous, chronic toxicity monitoring would be appropriate. Because the discharge
is to a unnamed tributary to Little Mountain Creek, ALCOA would be required to monitor
the discharge at 90% effluent concentration on a quarterly basis for the duration of this
permit. ALCOA, as requested, may use a grab sample for this test. The toxicity tests
specific to ALCOA's Phase I and Phase II discharge are attached and should be inserted
into their permit.
ALCOA also requests a modification in the limits for outfall 009, to reflect the more
stringent requirements presented in A (6) of the draft permit. ALCOA already has the
diffuser in place and is performing the requirements of A (7). Technical Support does not
concur with this request at this time, since ALCOA seems to want this modification on a
conditional basis, and the data collected dow not appear to be sufficient to grant this
request. This request will be taken into consideration upon renewal of the permit,
however.
cc: Mike Parker, MRO
Larry Ausley, ESB

Facility Name A LCOA
Perrmit # KC000430B Pipe # 005
PHASE I
ACUTE TOXICITY MONITORING
The permittee shall conduct one acute toxicity test using protocols defined as definitive in E.P.A.
Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine
Organisms." The monitoring shall be performed as a Daphnia pjl_a or Ceriodanhnia 48 hour static
test, using effluent collected as a grab sample. Effluent samples for self -monitoring purposes must
be obtained during representative effluent discharge below all waste treatment. The test will be
performed within thirty days during the lagoon dewatering phase.
The parameter code for this test if using Daphnia pulex is TAA3D. The parameter code for this test
if using QerigdUhnia is TAA3B. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. 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 test data from either these monitoring requirements 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.
7Q10 0-0 cfs
Permitted Flow _ - OR - MGD
IWC too. o %
Basin & Sub -basin u3o-zo8
Receiving Stream aT wrn-e Lay. Czeerc
County - 5rA9 Ly .
Recommended by:
Date Wj77ZI2- -

ixoA Permit # r C'X0S3o8 Pi # WS
Facility Name pe
PHASE H
CHRONIC TOXICITY MONITORING (QRTRLY)
The permittee shall conduct chronic toxicity tests using test procedures outlined in:
1.) The North Carolina Cerihnia 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
2%. The permit holder shall perform auarterU monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed at the beginning of the
PHASE H discharge during the months of &R. 5up1 5s JE _ . 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.
7Q10 0-0 cfs
Permitted Flow - VA A - MGD
IWC 100.0 %
Basin & Sub -basin o3o$
Receiving Stream 1. jTZit
County s N+_
QCM PIF Version 10191
Recommended
.� ._.
Date &.11-7137,

Facility Name ALCOA Permit # OcAW5306 Pipe # DOS
PHASE II
CHRONIC TOXICITY MONITORING (QRTRLY)
The pecmittee shall conduct chronic toxicity tests using test procedures outlined in:
1.) The North Carolina EedQ&phnia 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
30 %. The permit holder shall perform guarter monitoring using this procedure to establish
compliance with the permit condition. The first test will be performed at the beginning of the
PHASE H discharge during the months of MA _Jut 5 —PF _. 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 doseJresponse 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.
7Q10 0-0 cfs
Permitted Flow - MA - MGD
1WC _ 100.0 - %
Basin & Sub -basin _ v_39-o6
Receiving Stream Uf LjjjLF, rtJ- UEeK
County STA N L-Y
QCM P1F Version 10191
Recommended by
.r
Date � 17

DIVISION OF ENVIRONMENTAL MANAGEMENT
June 12, 1992
MEMORANDUM
TO: Don Safrit
THROUGH: Ken Eagleson
FRONT: Larry Ausley �r1
SUBJECT: Comments on ALCOA -Badin adjudication
NCO004308 Stanly County
I have reviewed the package of comments submitted by ALCOA in adjudication
of their draft permit. With regard to proposed monitoring of effluent toxicity of
pipe 005, the facility has raised several issues.
The. information presented by the facility on sampling as grabs versus
composites seems reasonable, with concurrence by the regional office that grab
samples would be representative of both the "Phase I " and"Phase 2" discharges.
It would now seem to me that the key issue in the matter is whether or not the
wastestream should be classified "complex" and therefore require whole effluent
toxicity penlut limitations. Staff of the Technical Support Branch have reviewed
this situation with regard to the wasteload allocation of the facility. They have
assumed that the Phase 1 discharge may contain residual waste from the time that
the lagoon was used as a treatment system. Making this assumption the waste
could be termed complex and toxicity monitoring would be appropriate. Due the
short duration of the Phase 1 discharge, I would consider a single monitoring of
acute toxicity to provide information to the Division of the potential impact of the
waste appropriate.
For the Phase 2 discharge, again consideration would have to be made of
whether the wastewater would be considered complex and therefore require toxicity
monitoring.
Option 1. Non-cornpiex-If the judgment is made that the waste is not complex
but that there is some reason for evaluating toxicity, appropriate testing could be
described in the permit based on IWC of the discharge, probably as quarterly
monitoring only versus a pen -nit limitation.
Option 2. Complex -Since ALCOA has claimed that the discharge would be
continuous, it would be appropriate to include a quarterly toxicity limitation for the
life of the permit. Standard operating procedure for toxicity perlitting could then
be followed based on IWC of the discharge. The appropriate test species to use in
this case would therefor be governed by the test performed. Should the eventual
limit be instituted as an "acute pass/fail" the suggested use of Ceriodaphniu dabia
versus fathead minnow as the test species would be considered acceptable by this
office.
I hope that the logic I have applied here can help to resolve ALCOA's
disagreements with their permit. If I can provide you with further information,
please give me a call at [phone].
cc:Rex Gleason
Susan Wilson
Central Files

Monday, June 8, 1992
MEMORANDUM
To: Trevor=C-lements�
Assistant Chief for Technical Support
From: Donald Safrit, P.E., Super isor
Permits and Engineering nit
Subject: ALCOA - Badin Facility
Permit No. NCO004308
Stanly County
In accordance with Water Quality Section procedures, please review the attached petition
filed with the Office of Administrative Hearings. Please evaluate the objections raised by
the permittee and provide me with your comments within ten (10) working days of your
receipt of this package.
The items under adjudication are:
Expiration date, stormwater, wrong map, temperature of discharge
and receiving stream, Phase I monitoring requirements, acute toxicity,
Duty to Comply, Bypassing language, DMR submittals, etc...
Miscellaneous comments:
It appears that a mistake was made and the permit was indeed issued without f
consideration of their concerns. Please review and provide written comments
If you have any questions, please contact Charles Lowe
cc: Office of the Attorney General
Donald Safrit
Charles Lowe

Adjudications 1

NPDES FACILITY AND PERMIT DATA
RETRIEVE OPTION TRXID 6NU KEY NC0004308
PEf'SONAL DATA FACILITY APPLYING FOR PERMIT REGION
FACILITY NAME> ALUMINUM COMPANY OF AMERICA COUNTY> STANLY 03
ADDRESS: MAILING (REQUIRED) LOCATION CREQUIRED)
STREET: PO BOX 576 STREET: HIGHWAY 740
CITY: BADIN ST NC ZIP 28009 CITY: BADIN ST NC ZIP 28009
TELEPHONE [phone] DATE FEE PAID: 09/24/91 AMOUNT: 400.00
STATE CONTACT> LOWE PERSON IN CHARGE L. E. TATE
1=PROPOSED,2=EXIST,3=CLOSED 2 1=MAJOR,2=MINOR 1 1=MUN,2=NON-MUN 2
LRT: 3524390 LONG: 08006560 N=NEW,M=MODIFICATION,R=REISSUE> M
DATE APP RCVD 09/24n1 WASTELOAD REDS 10/23/91
DATE STAFF REP REQS 10/23/91 WASTELOAD RCVD 03/02/92
DATE STAFF REP RCVD 11/12/91 SCH TO ISSUE 05/01/92
DATE TO P NOTICE 03/17/(32 DATE DRAFT PREPARED 03/03/92
DATE OT AG COM REQS / / DATE DENIED
DATE OT AG COM RCVD / / DATE RETURNED
DATE TO EPA / / DATE ISSUED 05/07/92 RSSIGN/CHANGE PERMIT
DATE FROM EPA / / EXPIRATION DATE 08/31/94
FEE CODE C 3 ) 1=(>10MGD),2=(>1MGD),3=(>0.1MGD),4=(<0.1MGD),5=SF,6=(GP25,64,79),
7=(GP49,73)8=CGP76)9=(GP13,34,30,52)0=(NOFEE) DIS/C 16 14 73 21 CONBILL C )
COMMENTS: 00 HOLDING FOR DRAFT COMMENTS FROM MRO & TSB
MESSAGE:

CIF A I ' F i 'n`
A:C. 'A 5. �1 a
L53A_ DL=-+= %! .I
C
May 29, 1992 �';���. -, VIA _CERTIFIED MAIL
4•'
Office of Administrative Hearings
Post Office Drawer 27447
424 N. Blount Street
Raleigh, North Carolina 27611-7447
Re: Aluminum Company of America, Badin Works
NPDES Permit No. NCO004308
Petition for a Contested Case Hearing
Dear Sir:
Enclosed for filing is a Petition for a Contested Case
Hearing. This petition concerns NPDES Permit No. NCO004308
issued to Aluminum Company of America, Badin Works, by the
Department of Environment, Health and Natural Resources,
Division of Environmental Management.
V r trul you'rs,
Je fr_ y J. Lettrich
Attorney
Enclosure
cc: George T. Everett, Ph.D, Director VIA CERTIFIED MAIL
Division of Environmental Management
Department of Environment, Health and Natural Resources
512 N. Salisbury Street
Raleigh, NC 27611
D. Rex Gleason, P.E. VIA CERTIFIED MAIL
Department of Environment, Health and Natural Resources
Division of Environmental Management
Mooresville Regional Office
919 N. Main Street
P. 0. Boa 950, Mooresville, NC 28115-0950 pR
4 1992
J. P. Hupy - Knoxville
H. J. van der Meyden - Badin Works
J. D. Morton - Pittsburgh Office, 19
WATER -Q A ICY
SECT1

STATE OF NORTH CAROLINA
COUNTY OF STANLY
ALUMINUM COMPANY OF AMERICA
.Petitioner,
v.
DEPARTMENT OF ENVIRONMENT,
HEALTH AND NATURAL RESOURCES,
DIVISION OF ENVIRONMENTAL
MANAGEMENT,
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
PETITION
FOR A
CONTESTED CASE HEARING
Aluminum Company of America, a Pennsylvania corporation
("Alcoa"), hereby requests a contested case hearing as provided by
N.C. Gen. Stat. § 150B-23 based on actions of the Department of
Environment, Health and Natural Resources, Division of Environmental
Management (the "DEM").
1. Effective May 7, 1992, the DEM issued to Alcoa a
modification of NPDES Permit No. NCO004308 (the "Permit").
2. Pursuant to 15 N.C. Admin. Code S§ 2H .0100-.0114,
Procedures for Permits, Approvals for Wastewater Discharges to the
Surface Waters (the "Rules"), on April 16, 1992, Alcoa submitted
and the DEM subsequently received comments on the draft
modification of the Permit. Said comments are attached hereto and
made a part hereof as Exhibit "A" (the "Comments").
3. To the best of Alcoa's knowledge and belief, the DEM
issued the Permit without consideration of the Comments, failing .to
act as required under the Rules.

4. The DEM failed to use proper procedure and therefore
substantially prejudiced Alcoa's rights by failing to -consider the
Comments.
5.. The DEM has acted erroneously, arbitrarily and
capriciously in that DEM's failure to consider the Comments has
resulted in issuance of the Permit with errors and
inconsistencies.
WHEREFORE, in order to obtain a thorough review of the
Comments, Alcoa respectfully requests that this matter be set for a
contested case hearing pursuant to the provisions of the N.C. Gen.
Stat. § 150B-23.
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:
Date
Sign lure
r
Title
29 Z
ate
,�',, e £ ey J. Lettrich
Attorney for
Aluminum Company of America
1501 Alcoa Building
Pittsburgh, PA 15219
My Commission Expires: Telephone: [phone]
NMnaf Seal
Jak=,ieGne L MuRt-ir, notary PLbOo
Pm�`x rSt:. W�?r+rny Gxin y
My Co LS.��on F�:res Jan. 24,1 %5
Me=..r, Penn;yP an Ass., on of na;anas
(SEAL)
- 2 -

RECEIVED
APR 201992 --_
1992 April 16 &AA FF'IED MAIL
RETURN RECEIPT REQUESTED
P 844 036 844
State•of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attention: George T. Everett, Director
RE. COMMENTS ON DRAFT MODIFICATION OF NPDES PERMIT NO. NC0004308
ALUMINUM COMPANY OF AMERICA - BADIN, NC
Gentlemen:
The Aluminum Company of America (Alcoa) is providing the following
written comments to the draft copy of Permit No. NC0004308 dated
1992 March 6. This draft constitutes the modification of an
existing permit to facilitate the dewatering of an on -site lagoon
through an existing permitted outfall.
In order to reclaim the lagoon site in an environmentally sound
manner, it is necessary to remove the water and allow for
prospective contractors to test their dewatering methods on the
residue in the bottom of the lagoon. The dewatering of the lagoon
constitutes Phase I. Once the lagoon has been dewatered, the
discharge will consist of stormwater runoff and compressor
condensate (Phase II).
Once Alcoa has evaluated the results of an on -going pilot test and
selected a treatment technology for oily wastewater to include the
previously mentioned compressor condensate, an application will be
made for the construction and operation of a future wastewater
treatment facility.
If you have any questions or comments, please feel free to contact
me at [phone].
Sincerely,
t
H. J. van de y en, .G.
Senior Hydrogeologist
cc. C. A. Carter P. R. Atkins - Pittsburgh 19
L. D. Russell J. D. Morton - Pittsburgh 19
L. E. Tate �C. M. Benhart - Pittsburgh 12
J. P. Hupy - Knoxville 12

COMMENTS ON DRAFT PERMIT NC0004308
PART A
Permit Cover Sheet
• The draft permit states
authorization to discharge
August 31, 1994." Alcoa's
L&,i�;,tight on May 31, 1994.
Page 2
that "the permit and the
shall expire at midnight on
current permit expires at
Alcoa requests clarification on the expiration date
stated in the draft permit. If this draft constitutes a
modification of our. current permit, why has the
expiration date changed. If this draft permit in effect
constitutes a new permit, then why is the expiration date
not five years from the effective date of the permit.
Supplement to Permit Cover Sheet, Paragraph 2
• The text of this paragraph suggests that the discharge of
accumulated stormwater in the lagoon can not commence
until an Authorization to Construct has been received
from NC DEM for wastewater treatment facility
construction and the construction has been completed,
i.e. "After receiving....." The lagoon is presently
filled close to capacity. With the onset of the rainy
summer months, it is vital that the lagoon can be
dewatered in a timely manner to avoid safety problems.
Alcoa's present activities for selecting a permanent
waste water treatment facility are in the pilot testing
phase. It is not possible at this time to submit a
completed package of the future oily water treatment
system, have this package reviewed and approved by NC
DEM, and receive an Authorization to Construct prior to
requiring the capability to dewater the lagoon.
Alcoa requests that this paragraph be modified to
indicate that the lagoon can be dewatered prior to
receiving an Authorization to Construct for the future
wastewater treatment facility.
Page No. Discharge Points 002, 005, 007, 008, 009 and 010 Map
• Please add Discharge Point 004 to this map. The correct
location of Discharge Point 004 is shown on the attached
map.
Page No. Discharge Point 004 Map
• Please delete this map. It show Discharge Point 004 in
the wrong location. The correct location of Discharge
Point 004 is shown on the attached map.

COMMENTS ON DRAFT PERMIT NCO004308 Page 3
Page No. A.(l) - Effluent Limitations and Monitoring Requirements
• The effect of the discharge from outfall 002 on the
temperature of the receiving stream (Yadkin -River) is
measured by comparing temperature measurements collected
at upstream and downstream locations. The Yadkin River
is in effect Badin Lake in the area of discharge. As
indic@Lte by Alcoa's monitoring records, it is possible
that the temperature of Badin Lake, as measured at both
the upstream and downstream locations, may exceed 32°C.
Alcoa request that the temperaturerequirement for
outfall 002 be modified to take into account the
possibility of the lake temperature exceeding 32°C.
Page No. A.(3) - Effluent Limitations and Monitoring Requirements
• The draft permit sets limitations and requirements
"beginning on the effective date of the permit and
lasting until completion of lagoon dewatering (PHASE I)"
which allow for the discharge.of "approximately 1.50
million gallons of accumulated storm water and
contaminated waste water."
It is possible that the actual dewatering of the lagoon
may not commence on the effective date of the permit. In
this case the discharge through outfall 005 would
constitute the "normal" discharge permitted under our
present permit. The effluent limitations and monitoring
requirements for the "normal" discharge are Flow, pH and
Oil & Grease. Until actual dewatering is started, there
is no reason for having the expanded list of monitoring
requirements described in this draft permit to be in
effect.
Alcoa request that the draft permit be modified to
indicate that the current permit's effluent limitations
and monitoring' requirements for Outfall 005 remain in
effect until the day the Phase I activities are actually
started.
While the dewatering of the lagoon is taking place, the
"normal" discharge will continue through Outfall 005.
Alcoa requests that the effluent limitations and
monitoring requirements indicate that the discharge
Outfall 005 during Phase I is comprised of "normal
effluent" AND effluent resulting from dewatering of the
lagoon.
• The reference to "contaminated wastewater" is
inappropriate. The lagoon contains storm water and
compressor condensate wastewater. To the best of Alcoa's
knowledge, the wastewater has not been contaminated by
other outside sources. Therefore, the wording of the

COMMENTS ON DRAFT PERMIT NC0004308
Page 4
draft permit is not appropriate. Alcoa requests that the
language be modified to read "compressor condensate
wastewater".
• For comments regarding the acute toxicity monitoring
requirements during Phase I activities, please refer to
comments on Part III, E.
Page No. A.(4) - Effluent Limitations and Monitoring Requirements
• The requirement for conducting acute toxicity monitoring
during Phase II activities is not clear. This
requirement will only need "to be performed if the
effluent is acutely toxic during Phase I testing." The
Phase I toxicity testing constitutes weekly samples. It
is not clear what would constitute the effluent to be
deemed acutely toxic. One failed test? Five failed
tests? A statistically significant percentage of failed
Phase I tests?
Alcoa requests that the criteria for classifying the
Phase I effluent as acutely toxic be defined in the
permit.
For further comments regarding the acute toxicity
monitoring requirements during Phase II activities,
please refer to the comments on Part III, F.
Page No. A. (7) - Effluent Limitations and Monitoring Requirements
• Alcoa is presently operating a diffuser system at outf all
009. Since the raising and replacing the storm sewer
pipe feeding this outfall was completed (under Special
Order by Consent No. WQ 89-41), the cyanide
concentrations in the discharge have been ranging from
less than 0.005 mg/L to 0.054 mg/L based on a review of
our DMRs. The range in results may reflect natural
variation in the concentrations, laboratory variation, or
other factors. ' Through future activities it may be
possible for Alcoa to provide, during the active life of
the permit, statistically valid evidence that the cyanide
concentrations are below the discharge limit required
without_ a diffuser (i.e. 0.031 mg/L). In this case,
Alcoa believes that it would be appropriate that the
effluent limitations and monitoring requirements of Page
A. (6) become effective.
Alcoa is requesting revising the time frame that permit
condition A. (7) will be in effect to allow for the
possibility to change to permit condition A., (6) if it
can be demonstrated that the cyanide concentrations meet
the discharge limit of 0.031 mg/L.
r �Ci4 ✓i'_L i" 4i:1 r rtl �l�+i �l:/.jam f ..•i/' if J�` 'F
J ,

COMMENTS ON DRAFT PERMIT NCO004308
Page 5
PART II
Page 4 of 14; Section B. (1) (a) Duty to Comply
• Regarding the statement "even if the permit has not yet
been modified to incorporate the requirement", Alcoa
1Cy4c5L that DEM provide information on the regulatory
autharity which enables it to require compliance of items
not included in the permit.
Page 6 of 14, Section B. (10) Expiration of Permit
• The sentence "Any discharge that has not requested....."
is confusing. It appears that the word "discharge"
should be replaced with "permittee" since it is the
Permittee who requests renewal, and not the discharge.
Alcoa requests that the wording of this sentence be
checked for correctness.
Page 8 of 14, Section C. (4) Bypassing of Treatment Facilities
• During heavy rain storms the diffuser system at outfall
009 is bypassed because the flow exceeds the combined
capacity of the two diffuser pumps. Because of the
volume of water flowing through outfall 009 during rain
storms, there is no feasible alternative to the bypass.
An effluent sample collected during a bypass on 1991
August 2 had a cyanide concentration of 0.005 mg/L, well
below the discharge limit without the diffuser system
(copy attached). Alcoa believes that the effluent
cyanide concentration during a bypass of the diffuser
system at outfall 009 does not exceed the effluent limit
without the diffuser system.
Page 10 of 14, Section D. (2) Reporting
• It is Alcoa's understanding that the current address for
submitting DMRs is:
Division of Environmental Management
Water Quality Section
Attention: Central Files
P. 0. Box 29535
Raleigh, North Carolina 27626-0535
This differs from the address stated in the draft permit.
Please provide us with the appropriate address for
submitting DMRs.

COMMENTS ON DRAFT PERMIT NCO004308
PART III
Section C, Paragraphs (a) -an
Page 5
d
Alcoa requests that the permit include reference to those
regulations which identify what constitutes a toxic
pollutant.
Section E. ACUTE TOXICITY MONITORING (WEEKLY)
• The 24 hour composite effluent sample requirement for
acute toxicity testing is inappropriate because the
lagoon has been shown to be vertically and horizontally
homogeneous based on little variation in pH, total
suspended residue, and total/hydrocarbon oil & grease.
These results were submitted with the application for
permit modification. since the lagoon is homogeneous,
there is no clear reason as to why the effluent sample
should be a 24 hour composite.
The requirement for using Fathead Minnow for the acute
toxicity testing during Phase I is not considered
appropriate. Ceriodaphnia_ Dubia has been used
successfully since 1990 at the Badin Works facility as an
indicator of toxicity.
Alcoa requests that the requirements for Acute Toxicity
monitoring during Phase I activities be changed to a
Ceriodaphnia Dubia test using effluent collected -as a
single grab sample.
• Regarding the sentence "The first test will be performed
within the first week of discharge". As stated above in
the comments to Page A. ( 3 ) there is presently an active,
permitted discharge from outfall 005. The dewatering of
the lagoon will constitute an additional discharge
through this outfall.
Alcoa requests that this sentence be modified to indicate
that the first toxicity test will be performed within the
first week of starting dewatering of the lagoon.

COMMENTS ON DRAFT PERMIT NC0004308
Page 7
Section F. ACUTE TOXICITY MONITORING (EPISODIC)
• The requirements for conducting acute toxicity monitoring
during Phase II are not clear.
The acute toxicity monitoring requirements for Phase II
are only required if Phase I monitoring determines that
the effluent is acutely toxic. The Phase I monitoring
requires a 24 hour composite sample (see Part III, E.)
while the Phase II monitoring calls for a grab sample.
Alcoa requests that the test procedures for the Phase I
and Phase II acute toxicity monitoring be made consistent
and use a single grab sample.
As described above in the comments to Part III, E., the
requirement for using Fathead Minnow for the acute
toxicity testing during Phase I is not considered
appropriate. Cerioda hnia Dubia has been used
successfully since 1990 at the Badin Works facility as an
indicator of toxicity. Alcoa requests that Ceriodaphnia
Dubia be used for the Phase II acute toxicity monitoring.
The Phase II monitoring refers to sampling "during the
first five discrete discharge events...." During Phase
II the discharge of Outfall 005 will be comprised of,
just like it is right now, storm water and compressor
condensate. This outfall has continuous discharge.
There are NO discrete discharge events. Alcoa requests
that this requirements of distinct events be deleted
because it is not applicable to Outfall 005.

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Discharge Points 002, 005, 0079
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REPORT OF LABORATORY ANALYSIS
IRE ASSURANCI OF OLOAL11T
Mr. William McCaskill August 19, 1991
Page 2 PACE Project dumber: 61080850
NPDES
PACE Sample Number: 92 0087496 92 0087500 92 0087518
Date Collected: 08/07/91 08/07/91 08/07/91
Date Received: 08/08/91 08/08/91 08/08/91
NWV NWV
NPDES Creek Creek
Parameter Units MDL 009 Upstream Downstrear
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Cyanide, Total mg/L 0.005 0.616 ND 0.008
Fluoride, Total mg/L 0.1 43.2 0.60 1.60
Solids, Settleable ml/L 0.1 0.2 - -
PACE Sample Number: 92 0087526
Date Collected: 08/02/91
Date Received: 08/08/91
NPDES
009
Parameter Units MDL By Pass
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Cyanide, Total mg/L 0.005 0.005
Fluoride, Total mg/L 0.1 2.50
MDL Method Detection Limit
ND Not detected at or above the MDL.
These data have been reviewed and are approved for release.
Charles M. Cabaniss
Manager, Inorganic Chemistry
1700 Limrersrly Cammererat PIKe Oflices Ssrrnp. Minromas. M.wwsots Chartctte. North Caroms
Chariorte. NC 2B217 Tampa. hands Ashardla. Narm Caratms
TEL: [phone] aws Cay, lows Nsw Wk. New votk
FAX: [phone] San Frwcma, C9forms Pimblxp. Psmsylearus
Kwass City. Musawt Oamrn. Coando
las AnQalas, COfai
An Enuar Ooomwvtr Empayar

STATE OF NORTH CAROLINA
COUNTY OF STANLY
ALUMINUM COMPANY OF AMERICA
Petitioner,
v.
DEPARTMENT OF ENVIRONMENT,
HEALTH AND NATURAL RESOURCES,
DIVISION OF ENVIRONMENTAL
MANAGEMENT,
Respondent.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
PETITION
FOR A
CONTESTED CASE HEARING
CERTIFIg.
.ATE OF SERVICE
I certify that this Petition has been served on the State
agency named below by sending a copy of it via United States
certified mail, return receipt requested, with sufficient postage,
this 29th day of May, 1992.
George T. Everett, Ph.D, Director
Division of Environmental Management
.Department of Environment, Health and Natural Resources
512 N. Salisbury Street
Raleigh, NC 27611
D. Rea Gleason, P.E.
Department of Environment, Health and Natural Resources
Division of Environmental Management
Mooresville Regional Office
919 N. Main Street
P. 0. Boa 950, Mooresville, NC 28115-0950
W--V 9
of rey J. Lettrich

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
542 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor George T. Everett, Ph.D
William W. Cobey, Jr., Secretary Director
L. E. Tate
A.lurmntmn Company of America
P. O. Box 576
Badin, NC 28009
Dear Mr. Tate:
May 1, 1992
Subject: NPDES Permit No.NCG004308
Stanly County
In accordance with your application for discharge permit received on September 24, 1991,
we are forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215 .1 and the Memorandum of
Agreement between North Carolina and the US Environmental Protection agency dated December
6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Adrriinistrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611 -
7447. Unless such demand is made, this decision shall be final and binding.
Please take notice this permit is not transferable. Part 11, EA. addresses the requirements to
be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Environmental Management or permits required by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental permit
that may be required.
If you have any questions concerning this permit, please contact Charles M. Lowe at
telephone number 919/733-5083.
cc: Mr. Jim Patrick, EPA
Mooresville Regional Office
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
�r-`4^q t►rr-f�
'TR4" Ella Copy
,

--A
_ DIVISION OF ENVI
May 28, 1992
MEMO TO:
FROM:
Coleen Sullins
D. Rex Gleason
PREPARED BY:
l
Michael Parker7%li�
SUBJECT:
Draft Permit Comments
Aluminum Company of America
NPDES Permit No. NCO004308
Stanly County
(ALCOA)
This Office has conducted a review of the comments submitted
via letter dated April 15, 1992 by H. J. van der Meyden, P.G.,
Senior Hydrogeologist, ALCOA concerning the subject draft Permit.
Subsequent to the submittal of these comments, the Permit was
reissued on May 1, 1992 without a formal response to Mr. van der
Mey.den's concerns. Our response will follow the same order as
found in Mr. van der Meyden's letter.
1. Permit expiration date.
ALCOA's request involved a modification to the current
Permit, which should not have changed the existing
expiration date. Recommend that the expiration date of May
31, 1994 remain in the Permit.
2. Discharge from lagoon prior to obtaining an A to C.
ALCOA's modification request is to allow for dewatering an
existing lagoon through a currently permitted outfall so
that closure activities can begin. Analytical data supplied
by ALCOA provided documentation that the water contained in
the lagoon did not contain waste constituents at levels
which would violate the permitted effluent limitations
promulgated by Technical Support. The permittee has
treatment in -place at outfall 005 (oil/water separator),
And,, provided the flow from the lagoon does not exceed the
capacity of the treatment facilities, the proposed discharge
should not require the issuance of an A to C.

Page Two
3. Outfalls 002, 005, 007, 008, 009 and 010.
Outfalls 007 and 008 are for discharges associated with
Falls powerhouse (NC0076775) and Narrows Powerhouse
(NC0081957-), respectively. The Division is currently
processing NPDES Permit applications for these
facilities. ALCOA intends to formally request that these
outfalls be deleted from the subject Permit upon issuance of
the Falls Powerhouse and Narrows Powerhouse Permits. As
requested, a corrected map showing the location of outfall
004 should be added to the Permit.
4. Monitoring requirement for temperature at outfall 002.
Recommend the Permit allow for the possible instream
temperature exceedances due to lake conditions unrelated to
the discharge. The Permit should also specify upstream and
downstream monitoring locations to insure reliable data is
obtained. Stratified measurements may be more accurate,
especially during the summer months when surface
temperatures are high.
5. Effluent requirements for outfall 005.
Recommend the Permit be modified to allow existing
effluent limitations to remain in effect until the discharge
from the lagoon has commenced.
6. Description of.waste stream at outfall 005 is inappropriate.
Recommend that verbiage be changed as requested.
7. Criteria for determining effluent toxicity.
Defer comment to Technical support.
S. Outfall 009 Cyanide limitation.
Since a diffuser system (approved by DEM) currently exists
for this outfall, the monitoring listed on page A(6) is
inappropriate. Technical Support must concur with regards to
ALCOA's request to change the cyanide monitoring limitation.
9. Duty to Comply.
Defer comment to P & E.

Page Three
10. Expiration of Permit.
Standard verbiage, recommend remain as written.
11. By-passing of Treatment Facilities.
A discharge from Outfall 009 is precipitated by a stormwater
event as it passes through an area containing scrap aluminum
processing materials. These materials have been found to
contain cyanide in various levels. Due to the existence of a
swimming area adjacent to the outfall, the Division'approved
the installation of a dual line diffuser system to convey
the stormwater into the main body of the lake. The diffuser
system is capable of handling most rainfall events, however,
occazionally, rainfall events occur that overload the
diffuser pumping system. Due to the size of the area which
drains to this outfall, there does not appear to be a
feasible alternative for the occasional by-pass. Any cyanide
present in the stormwater during periods of heavy rainfall
should be diluted considerably resulting in reduced cyanide
concentrations. Furthermore, no "treatment" facilities exist
at this outfall by which a by-pass can occur. A decision as
to whether a discharge from outfall '009 (during a storm
event which exceeds the diffuser's capability) is considered
a by-pass should be made by P & E, and the Permit modified
accordingly.
12. Reporting.
The recently issued Permit (and draft) list an address
for the Division that is no longer in effect. The new
address should be included in the Permit.
13. Toxin Pollutants.
Standard verbiage. Defer comment to P & E.
14. Acute Toxicity Monitoring.(Weekly).
Defer comment regarding this item to Technical Support.
15. Acute Toxicity Monitoring (Episodic).
Ditto comments for item No. 14
If you have any -questions, please advise.
MLP

i�P
f 57
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0JI.j`�1j1-I�RL'�\'r 's • . - -. `5 ti
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th
4
1992 'A ri1 16 �Noff
CERTIFIED P 4�v �DIR a RETURN'RECEIPT' REQUESTED _
P 844 036 844
? Y^:
State of North Carolina
ei7 •t Ya^i , n•
Department of Environment, Health and Natural Resources
Division of Environmental Management
AP
Post Office Box 29535 R
Raleigh, North Carolina 27626-0535 WATER QUALITY
Attention: George T. Everett, Director SECTION
RE. COMMENTS ON DRAFT MODIFICATION OF NPDES PERMIT NO. NC0004308
ALUMINUM COMPANY OF AMERICA - BADIN, NC
Gentlemen:
The Aluminum Company of America (Alcoa) is providing the following
written comments to the draft copy of Permit No. NC0004308 dated
1992 March 6. This draft constitutes the modification of an
existing permit to facilitate the dewatering of an on -site lagoon
through an existing permitted outfall.
In order to reclaim the lagoon site in an environmentally sound
manner, it is necessary to remove the water and allow for
prospective contractors to test their dewatering methods on the
residue in the bottom of the lagoon. The dewatering of the lagoon
constitutes Phase I. Once the lagoon has been dewatered, the
discharge will consist of stormwater runoff and compressor
condensate (Prase II).
Once Alcoa has evaluated the results of an on -going pilot test and
selected a treatment technology for oily wastewater to include the
previously mentioned compressor condensate, an application will be
made for the construction and operation of a future wastewater
treatment facility.
If you have any questions or comments, please feel free to contact
me at [phone].
Sincerel
ti,-)
H. J. van de ey en, P.G.
_!,nz
Senior Hydrogeologist
CC. C. A. Carter
P.
R.
Atkins
- Pittsburgh
19
L. D. Russell
J.
D.
Morton
- Pittsburgh
19 0
L. E. Tate
C.
M.
Benhart
- Pittsburgh
12
J.
P.
Hupy -
Knoxville 12

4
� COMMENTS ON DRAFT PERMIT NCO004308 Page 2
PART A
Permit Cover Sheet
• The draft permit states that "the permit- and the
authorization to discharge shall expire at midnight on
August 31, 1994." Alcoa's current permit expires at
midnight on May 31, 1994. ill,:, pal •Ihcm br\. trar, 5c4dL,je
Alcoa requests clarification on the expiration date
stated in the draft permit. If this draft constitutes a
modification of our current permit, why has the
expiration date changed. If this draft permit in effect
constitutes a new permit, then why is the expiration date
not five years from the effective date of the permit.
Supplement to Permit Cover Sheet, Paragraph 2
• The text of this paragraph suggests that the discharge of
accumulated stormwater in the lagoon can not commence
until an Authorization to Construct has been received
from NC DEM for wastewater treatment facility
construction and the construction has been completed,
i.e. "After receiving....." The lagoon is presently
filled close to capacity. With the onset of the rainy
summer months, it is vital that the lagoon can be
dewatered in a timely manner to avoid safety problems.
Alcoa's present activities for selecting a permanent
waste water treatment facility are in the pilot testing
phase. It is not possible at this time to submit a
completed package of the future oily water treatment
system, have this package reviewed and approved by NC
DEM, and receive an Authorization to Construct prior to
requiring the capability to dewater the lagoon.
Alcoa requests that this paragraph be modified to
indicate that the lagoon can be dewatered prior to
receiving an Authorization to Construct for the future
wastewater treatment facility.
Page No. Discharge Points 002, 005, 007, 008, 009 and 010 Map
• Please add Discharge Point 004 to this map. The correct
location of Discharge Point 004 is shown on the attached'A�-,
map.
Page No. Discharge Point 004 Map
• Please delete this map. It show Discharge Point 004 in�``�
the wrong location. The correct location of Discharge
Point 004 is shown on the attached map.�U��hQ

COMMENTS ON DRAFT PERMIT NCO004308 Page 3
Page No. A.(1) - Effluent Limitations and Monitoring Requirements
• The effect of the discharge from outfall 002 on the
temperature of the receiving stream (Yadkin River) is
measured by comparing temperature measurements -collected
at upstream and downstream locations. The Yadkin River
is in effect Badin Lake in the area of discharge. As
indicate by Alcoa's monitoring records, it is possible
that the temperature of Badin Lake, as measured at both
the upstream and downstream locations, may exceed 32°C.
Alcoa request that the temperature requirement for
outfall 002 be, modified to take into account the
possibility of the lake temperature exceeding 32°C. 0t,
Page No. A.(3) - Effluent Limitations and Monitoring Requirements
• The draft permit sets limitations and requirements
"beginning on the effective date of the permit and
lasting until completion of lagoon dewatering (PHASE I)"
which allow for the discharge of "approximately 1.50
million gallons of accumulated storm water and
contaminated waste water."
It is possible that the actual dewatering of the lagoon
may not commence on the effective date of the permit. In
this case the discharge through outfall 005 would
constitute the "normal" discharge permitted under our
present permit. The effluent limitations and monitoring
requirements for the "normal" discharge are Flow, pH and
Oil & Grease. Until actual dewatering is started, there
is no reason for having the expanded list of monitoring
requirements described in this draft permit to be in
effect. U,�-
Alcoa request, that the draft permit be modified to
indicate that the current permit's effluent limitations
and monitoring requirements for Outfall 005 remain in
effect until the day the Phase I activities are actually
started. 0l�-
While the dewatering of the lagoon is taking place, the
"normal" discharge will continue through Outfall 005.
Alcoa requests that the effluent limitations and
monitoring requirements indicate that the discharge
Outfall 005 during Phase I is comprised of "normal
effluent" AND effluent resulting from dewatering of the
lagoon.
The reference to "contaminated wastewater" is
inappropriate. The lagoon contains storm water and
compressor condensate wastewater. To the best of Alcoa's
knowledge, the wastewater has not been contaminated by
other outside sources. Therefore, the wording of the

COMMENTS ON DRAFT PERMIT NC0004308 Page 4
draft permit is not appropriate. Alcoa requests that the
language be modified to read "compressor condensate
wastewater". - ,,j,.; _ a r as J. Yr-- P_F,J-
• For' comments regarding the acute toxicity monitoring
requirements during Phase I activities, please refer to
comments on Part III, E.
Page No. A.(4) - Effluent Limitations and Monitoring Requirements
+ The requirement for conducting acute toxicity monitoring
during Phase II activities is not clear. This
requirement will only need "to be performed if the
effluent is acutely toxic during Phase I testing." The 1
Phase I toxicity testing constitutes weekly samples. It
is not clear what would constitute the effluent to be?�,5{��a
deemed acutely toxic. One failed test? Five failedl
tests? A statistically significant percentage of failed
Phase I tests?
Alcoa requests that the criteria for classifying the
Phase I effluent as acutely toxic be defined in the
permit.
• For further comments regarding the acute toxicity
monitoring requirements during Phase II activities,
please refer to the comments on Part III, F.
Page No. A. (7) - Effluent Limitations and Monitoring Requirements
• Alcoa is presently operating a diffuser system at outfall
009. Since the raising and replacing the storm sewer
pipe feeding this outfall was completed (under Special
Order by Consent No. WQ 89-41), the cyanide
concentrations in the discharge have been ranging from
less than 0.005 mg/L to 0.054 mg/L based on a review of
our DMRs. The range in results may reflect natural
variation in the concentrations, laboratory variation, or
other factors. Through future activities it may be
possible for Alcoa to provide, during the active life of
the permit, statistically valid evidence that the cyanide
concentrations are below the discharge limit required
without a diffuser (i.e. 0.031 mg/L). In this case,-01
�Vl`
Alcoa believes that it would be appropriate that the,,G,(,k�
effluent limitations and monitoring requirements of Page
C�e,e '
A. (6) become effective.
Alcoa is requesting revising the time frame that permit
condition A. (7) will be in effect to allow for the
possibility to change to permit condition A. (6) if it
can be demonstrated that the cyanide concentrations meet
the discharge limit of 0.031 mg/L.
F�►�c.; r�r1 i
a�'s�
T�
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r. ���!/C, 5;! Lv -
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7

.14 COMMENTS ON DRAFT PERMIT NCO004308
PART II
Page .5
Page,4 of 14, Section B. (1) (a) Duty to Comply
• Regarding the statement "even if the permit has not yet
been modified to incorporate the requirement", Alcoa
request that DEM provide information on the regulatory
authority which enables it to require compliance of items
not included in the permit.
Page 6 of 14, Section B. (10) Expiration of Permit
• The sentence "Any discharge that has not requested,...."
is confusing. It appears that the word "discharge" ,,��
should be replaced with "permittee" since it is the.,L�',,,
Permittee who requests renewal, and not the discharge: ,p�`
Alcoa requests that the wording of this sentence be
checked for correctness.
Page 8 of 14, Section C. (4) Bypassing of Treatment Facilities
• During heavy rain storms the diffuser system at outfall
009 is bypassed because the flow exceeds the combined
capacity of the two diffuser pumps. Because of the
volume of water flowing through outfall 009 during rain
storms, there is no feasible alternative to the bypass.
An effluent sample collected during a bypass on 1991
August 2 had a cyanide concentration of 0.005 mg/L, well
below the discharge limit without the diffuser system
(copy attached). Alcoa believes that the effluent
cyanide concentration during a bypass of the diffuser
system at outfall 009 does not exceed the effluent limit
without the diffuser system.
Page 10 of 14, Section D. (2) Reporting
• It is Alcoa's understanding that the current address for
submitting DMRs is:
Division of Environmental Management
Water Quality Section
Attention: Central Files
P. O. Box 29535
Raleigh, North Carolina 27626-0535
This differs from the address stated in the draft permit.
Please provide us with the appropriate address for
submitting DMRs.

.,r COMMENTS ON DRAFT PERMIT NCO004308
PART III
Page 6
Section C, Paragraphs (a) and (b)
• The definition of a "toxic pollutant" needs
clarification. Is a toxic pollutant identified as a
constituent listed in 40 CFR 122, Appendix D, Table II
and III ? or are there other constituents included as
well ? i fYketie- 11 +� ct tt(Ld (� re�`j Ob ,0-�oa(3j)
Alcoa requests that the permit include reference to those
regulations which identify what constitutes a toxic
pollutant.
Section E. ACUTE
• The 24
TOXICITY MONITORING (WEEKLY)
hour composite effluent sample requirement for
acute toxicity testing is inappropriate because the
lagoon has been shown to be vertically and horizontally
homogeneous based on little variation in pH, total
suspended residue, and total/hydrocarbon oil & grease.
These results were submitted with the application for
permit modification. Since the lagoon is homogeneous,
there is no clear reason as to why the effluent sample
should be a 24 hour composite. 4P((r6 -0V-
The requirement for using Fathead Minnow for the acute
toxicity testing during Phase I is not considered
appropriate. Ceriodaphnia Dubia has been used
successfully since 1990 at the Badin Works facility as an
indicator of toxicity. 0(G
Alcoa requests that the requirements for Acute Toxicity
monitoring during Phase I activities be changed to a
Ceriodaphnia Dubia test using effluent collected as a
single grab sample.
Regarding the sentence "The first test will be performed
within the first week of discharge". As stated above in
the comments to Page A. ( 3 ) there is presently an active,
permitted discharge from outfall 005. The dewatering of
the lagoon will constitute an additional discharge
through this outfall.
Alcoa requests that this sentence be modified to indicate
that the first toxicity test will be performed within the
first week of starting dewatering of the lagoon.- %-

COMMENTS ON DRAFT PERMIT NC0004308
Page 7
Section F. ACUTE TOXICITY MONITORING (EPISODIC)
The requirements for conducting acute toxicity monitoring
during Phase II are not clear.
The acute toxicity monitoring requirements for Phase II
are only required if Phase I monitoring determines that
the effluent is acutely toxic. The Phase I monitoring ,jam
requires a 24 hour composite sample (see Part III, E.)r��
while the Phase II monitoring calls for a grab sample.
Alcoa requests that the test procedures for the Phase I
and Phase II acute toxicity monitoring be made consistent
and use a single grab sample. `A
As described above in the comments to Part III, E., the
requirement for using Fathead Minnow for the acute
toxicity testing during Phase I is not considered
appropriate. Ceriodaphnia Dubia has been used
successfully since 1990 at the Badin Works facility as an
indicator of toxicity. Alcoa requests that Ceriodaphnia
Dubia be used for the Phase II acute toxicity monitoring.
The Phase II monitoring refers to sampling "during the
first five discrete discharge events...." During Phase
II the discharge of Outfall 005 will be comprised of,
just likeRit is right now, storm water andLcompressor
condensate-!.-:, This outfall has continuous discharge.
There aWNO discrete discharge events. Alcoa requests
that this requirements of distinct events .be deleted
because it is not applicable to Outfall 005.

Pin
C O R P O R A T E 0 REPORT OF LABORATORY ANALYSIS
THE ASSURANCE OF QUALITY
Mr. William McCaskill August 19, 1991
Page 2 PACE Project Number: 610808509
NPDES
PACE Sample Number: 92 0087496 92 0087500 92 0087518
Date Collected: 08/07/91 08/07/91 08/07/91
Date Received: 08/08/91 08/08/91 08/08/91
NWV NWV
NPDES Creek Creek
Parameter Units MDL 009 Upstream Downstream
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Cyanide, Total mg/L 0.005 0.616 ND 0.008
Fluoride, Total mg/L 0.1 43.2 0.60 1.60
Solids, Settleable ml/L 0.1 0.2 - -
PACE Sample Number: 92 0087526
Date Collected: 08/02/91
Date Received: 08/08/91
NPDES
009
Parameter Units MDL By Pass
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Cyanide, Total mg/L 0.005 0.005
Fluoride, Total mg/L 0.1 2.50
MDL Method Detection Limit
ND Not detected at or above the MDL.
These data have been reviewed and are approved For release.
Charles M. Cabaniss
Manager, Inorganic Chemistry
1700 University Commercial Place
Charlotte, NC 28213
TEL: [phone]
FAX: [phone]
Offices Serving: Minneapolis, Minnesota
Tampa, Florida
Iowa City, Iowa
San Francisco, California
Kansas City, Missouri
Los Angeles, California
Charlotte, North Carolina
Asheville, North Carolina
New York, New York
Pittsburgh, Pennsylvania
Denver. Colorado
An Equal Opportunity Employer

EQU ES
T R
�,DESWASTELOAD ALLOCATION
PERMIT NO.: NCO004308
PERIVII= NAME: Aluminum Company of America
FACILITY NAME: Aluminum Company of America
Facility Status: Existing
Permit Status: Modification
Major Minor
Pipe No.: 0057
Design Capacity: ** MGD
Domestic (% of Flow):
Industrial (% of Flow): 100 %
Comments:
Adding outfall 011 Facility already has outfalls 002 010, see attached
permit. —
SeGci.�� oa� also .
RECEIVING STREAM: UT_ L i Try NtrN . �
Class: C
Sub -Basin: 03-07-08
Reference USGS Quad: F 18 NE (please attach)
County: Stanly
Regional Office: Mooresville Regional Office
Previous Exp. Date: 00/00/00 Treatment Plant Class:
Modeler
Date Rec.
#
koizAl5 t
S
l
Drainage Area (mi) NL (or") Avg. Streamflow (cfs):
7Q10 (cfs) j Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % Acute/Chronic
Instream Monitoring:
Parameters
Upstream Location
Downstream Location
Recommended Limits PRASE I (During lagoon discharge) - ooS
Daily Max.
Flow: **
Oil & Grease (mg/1):
C0
PH (SU):
6-9
TSS (mg/1):
60
Turbidity (NTU):
50
Fluoride (µg/1): ++
monitor
Aluminum (µg/1): ++
monitor
Copper (µg/1):
monitor
Zinc (µg/l):
monitor
Toxicity testing
Acute full range
monitoring (24hr
fathead minnow)
WE
Monthly Average Freq.
Instantaneous
30 weekly
weekly
30 weekly
weekly
weekly
weekly
weekly
weekly
weekly
Recommended Limits PRASE n(After completion of lagoon discharge) - 006
Classification changes within three miles: Flow: **
Oil & Grease (mg/1):
No change pH (SU).
TSS (mg/1):
PLOTTTurbidity (NT'f)):
Toxicity:
Requested by: Charles M. Lowe Date: 10/23/91 `
Prepared by: Date: 2 Z
Reviewed by: (�Ct�c. CtAA4,Lk d PYL Date:AA
Comments:
Daily Max. Monthly Average Freq
Instantaneous
60 30 2/mon
6-9 2/mon
60 30 2/mon
50 2/mon
Should the effluent be acutely toxic during
Phase I, then acute full range testing during
the first five events would be required.
FiaW oonl u .OSO b. NI FLoW LIMIT is iA4po6ep
ON 8UTFAI L 006 DUE To AaLAsIury of Sro" e%eWS, AUI-e EksV45 VZ uM&rAnoNS
" 66 1AM16D 0/1 005 04 19E F"'K DUE -ro -7)W NEW S1bA4,,WA7M eEq"AT1vV5

Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
FACT SHEET FOR WASTELOAD ALLOCATION
ALCOA
NC0004308 - vo5
Industrial - 100%
Existing
Renewal
UT Little Mountain Creek
C
030708
StaMRWY
MR
C. Lowe
10/23/91
F18NE, Badin
Request # 6544
11. G DEPT. Or NATMAL
PMWU*C0 AND
cuummily nrtsi3OrMarr
FEB 1 01992
VISO flE fjH"UEATAI MANAGEMENT
Stream Charade rILLE 03ML IFFIrA
USGS #
Date:
Drainage Area (mi2): NA (ditch)
Summer 7Q10 (cfs): 0.0
Winter 7Q10 (cfs): 0.0
Average Flow (cfs):
30Q2 (cfs):
IWC W:
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
ALCOA wishes to modify their current outfall. 005 to include the drainage of a lagoon on the
property. This modification will be on a short term basis. Outfall 005 is permitted for storm water
runoff from the facility and surrounding landscape. After the lagoon is drained, compressor
condensate (appx. 200 gpd) and storm water will be discharged from 005.
The lagoon was used as a treatment scenario and discharged to outfall 003. This outfall no longer
discharges. In 1988-89, the lagoon was drained. Since that time all wasteflow to the lagoon has
ceased with the exception of compressor condensate and natural stormwater flow and groundwater
recharge. ALCOA did composite samples of the lagoon and tested for metals, BOD, fluoride,
NH3-N, etc. The Phase I limits for 005 will reflect those constituents found in detectable
amounts. After the lagoon is drained the facility will dispose of the sludge and fill in the lagoon.
The facility should be aware that compliance must be met for the combined waste streams
discharging to 005 (this was ALCOA's choice to discharge the lagoon water and compressor
condensate out of the same outfall as the stormwater). Discharge from the lagoon itself must not
exceed 50,000 gpd.
Recommended by: 14
Date:
Reviewed by
Instream Assessment: Date: 1 /,9
Regional Supervisor:' Date: /
Permits & Engineering: Date:
%2-
RETURN TO TECHNICAL SERVICES BY: MAR 0 5 1992

2
TOXICS/METALS/CONVENTIONAL PARAMETERS
Existing Limits OUTFALL 005
Daily Max. Monthly Avg. Freq.
Flow: monitor only instantaneous
Oil and Grease (mg/1): 60 30 1/mon
pH (SU): 6-9 1/mon
Recommended Limits PHASE I (During lagoon discharge) - oe5
Daily Max.
Monthly Average Freq.
Flow: **
Instantaneous
Oil & Grease (mg/1):
60
30 weekly
pH (SU):
6-9
weekly
TSS (mg/1):
60
30 weekly
Turbidity (NTU):
50
weekly
Fluoride (µg/1): ++
monitor
weekly
Aluminum (µg/1): ++
monitor
weekly
Copper (µg/1):
monitor
weekly
Zinc (µg/l):
monitor
weekly
Toxicity testing
Acute full range
weekly
monitoring (24hr
fathead minnow)
** Flow from the lagoon must not exceed 0.050 MGD. No flow limit is imposed on outfa11005 due to variability
of storm events.
++ Outfall 005 goes to a ditch, under a road (culvert) and to a ditch to Little Mountain Creek (appx. 150-200 ft).
ALCOA owns all the property surrounding the ditch except for the land at the road.
Recommended Limits PHASE II (After completion of lagoon discharge) - 005
Daily Max. Monthly Average Freq
Flow: ** Instantaneous
Oil & Grease (mg/1): 60 30 2/mon
pH (SU): 6-9 2/mon
TSS (mg/1): 60 30 2/mon
Turbidity (NTU): 50 2/mon
Toxicity: Should the effluent be acutely toxic during
Phase I, then acute full range testing during
the first five events would be required.
More extensive limitations may be imposed on 005 in the future due to the new stormwater regulations currently
being proposed.
Limits hanger Due To:
Discharge constituent modification
Parameter Affected
TSS ,S S,F,A1,Cu,Zn,Toxicity
Parameter(s) are water quality limited. For some parameters, the available load capacity of the immediate
receiving water will be consumed. This may affect future water quality based effluent limitations for additional
dischargers within this portion of the watershed.
OR
_X_ No parameters are water quality limited, but this discharge may affect future allocations.

MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Ad of Existing Treatment
Has the facility demonstr!!:27
facilities? Yes No ability to meet the proposed new limits with existing treatment
If no, which parameters cannot be met? 04Z "64,-&,ae- 7P—' idt'
Would a "phasing in" of the new limits be appropriate? Yes No t.,
If yes, please provide a schedule (and basis for that schedule) with the regional
office recommendations:
If no, why not?
Special Instructions or Conditions
Wasteload sent to EPA? (Major) _N_ (Y or N)
(If yes, then attach schematic, toxics spreadsheet, copy of model, or, if not modeled, then old
assumptions that were made, and description of how it fits into basinwide plan)
Additional Information attached? N_ (Y or N) If yes, explain with attachments.

Facility Name A i. cyA Permit # IJ Cep*30 5 Pipe # 005
WEEKO
ACUTE TOXICITY MONITORING (�)
W 6E�U.
The permittee shall conduct acute toxicity tests on a basis using protocols defined as
definitive in E.P.A. Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to
Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow
(Pimephales promelas) 24 hour static test, using effluent collected as a 24 hour composite.
Effluent samples for self -monitoring purposes must be obtained during representative effluent
discharge below all waste treatment. The first test will be performed within tie
IN& F 04T wefilof 1A19G94e4&.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this
permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it
was performed, using the appropriate parameter code. 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 test data from either these monitoring requirements 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.
7Q10 0• o cfs
Permitted Flow NA MGD
IWC t00.0 %
Basin & Sub -basin D Wl yi&
Receiving Stream 11 , L . ra e_ Arm CiL6r€ K.
County Sranr c��
MAM Fathead 24 Version 10191
Recommended by:
Date �' 1 Z

lP05C- _T (SµoauP FIAA'�,e T 141.21CA 6 -fom(
Facility Name AL, ►A Permit # Woo+5o8 Pipe # 0o5
ACUTE TOXICITY MONITORING (EPISODIC)
The permittee shall conduct FIVE acute toxicity tests using protocols defined as definitive in
E.P.A. Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales
promelas) 24 hour static test, using effluent collected as a single grab sample. Effluent samples
for self -monitoring purposes must be obtained below all waste treatment. Sampling and
subsequent testing will occur during the first five discrete discharge events after the effective date
of this permit. After monitoring of the fast five toxicity tests, the permittee will conduct one test
annually, with the annual period beginning in January of the next calendar year. The annual test
requirement must be performed and reported by June 30. If no discharge occurs by June 30,
notification will be made to the Division by this date. Toxicity testing will be performed on the
next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this
permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it
was performed, using the appropriate parameter code. 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 either these monitoring requirements 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.
Failure to submit suitable test results will constitute noncompliance with monitoring requirements.
7Q 10 0.0 - cfs
Permitted Flow ,,l l 4 MGD
IWC c. r %
Basin & Sub -basin D S
Receiving Stream UT 1 _ 6l.4 L('kPPK
County vi t 6
EAM Fathead 24 Version 10191
Recommended by:
Date O l j a z

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MEMO
TO'.
DATE: to -z'
r
SUBJECT-.
Applicant desires to dewater a lagoon that is no longer in use. The lagoon
has accumulated approximately 1,500,000 gallons of stormwater and
condensate that is contaminated as described in the proposal. Permit will
remain as is with the exception of the addition of the new outfall to
dewater the lagoon. Flow limitation has been left to our discretion but
applicant desires to discharge as much as 50,000 GPD.
From:
North Carolina Department of Environment,
Health and Natural Resources g
t Printed on RecyCled Paper
k

TABLE OF CONTENTS
TITLE PAGE(S)
BACKC-ROUND INFORMATIONW 1 - 3
AITA.r� A 4
Data to be furnished to State
upon application for permanent
amendment of Permit NC0004308
ATTAaZEW B
Laboratory analyses of lagoon
water layer (requested by
NCDEHNR)
ATTACHMENT C
Flow record for discharge
:. number 005 (NPDES Permit
NC0004308)
ATI'A ril P D
CLOSURE DOCUM= FOR ALCOA LAGOON
D
5
0
with
coverletter
LIT
AavA rou�� �P�(ti L, ooti9 K7� 0(�b1�
or Li A AJr
Like C Alto N o boS
W ct�wu►T�D d� �-1r►� - SA 17 ,T
wAs n�oT R U , t�aUG CAu` ;ate
(2.
ABoaz-r .
zo

BACKGROUND INFORMATION
FOR PERMIT NUMBER NC0004308 AMENDMENT
(ALCOA DISCHARGE NUMBER 005)
In 1988, the Aluminum Company of America (ALCOA) ceased operation
of an aerated lagoon for treatment of five (5) was-ewater streams as discussed
in section three (3) of the CLOSURE DOCUMENT (see ATTACHMENT D). All influent
flows to the lagoon were terminated (with the exception of approximately
200 GPD of compressor condensate). The basin contents were subsequently
discharged under the NPDES permit which then existed for the lagoon. A
copy of the CLOSURE DOCUMENT (Preliminary Engineering Outline) is included
as ATTACHMENT D.
The previously unknown influent flow to the lagoon of a compressor
condensate flow was discovered upon start of plans (in 1990) to close the
lagoon site. Over the past three (3) years, approximately 150,000 to 200,000
gallons of compressor condensate and between 1,000,000 and 1,300,000 gallons
of stormwater run-off and spring water have accumulated in the lagoon.
In order to remove the biological sludge regaining in the lagoon and
proceed with final closure of the lagoon, it is necessary that the water
which has accumulated in the lagoon be discharged. This will allow the
sludge removal contractor to:
1) collect samples of the sludge,
2) verify the proposed dewatering method,
3) assess the quantity of residue to be removed and
4) furnish a removal cost.
- 1 -

Therefore ALCOA submits this REQUEST FOR TEMPORARY AMENDMENT TO NPDFS
PERMIT NUMBER NC0004308 for its discharge number 005 until completion of
construction of new oily wastes treatment facilities. The 005 discharge
presently consists of non -contact cooling water of potable water quality
and stormwater flows. An Oil Separator, based upon American Petroleum
Institute (API) design criteria, is present in the 005 discharge at a point
approximately twenty (20) feet upstream of the flow measurement flume in
the 005 discharge.
As part of the CLOSURE process, ATTACHMENT A displays the
characterization of the various wastewater influents to the new oily wastes
treatment facilities which will be submitted to the NCDEHNR by 1 October
1991 for use in generation of permit limits for permanent amendment to
N. C. Permit Number NC0004308. Upon issue of the final permit limits, Ai,COA
will modify a currently planned treatability study as needed and proceed
with treatability testing of compressor condensate and other oily wastewater
flows currently removed from the site by vendors but which will be received
by the new oily wastes facility in -the future. During the treatability
study, effluents from the dual pilot units (approximately 600 GPD/5 day
week) will be temporarily discharged to the lagoon and -subsequently pumped
to the 005 discharge site located near the southeast end of the lagoon.
-2--
ti.5

A general description of the overall closure procedure and history
of the lagoon is included in the LAGOON CLOSURE DOCUMENT (see Attachment
D)• Characteristics of the liquid and sludge now present in the lagoon
are displayed as APPENDIX A and B of that document. During a 25 July 1991
meeting to start review of the CLOSURE PLAN, the Mooresville personnel of
the NCDEHMR requested additional analyses of the liquid in the lagoon.
Contact with the'Raleigh office of NCDEHNR on 29 July 1991 resulted in further
additions to that list. The analytical data presented as ATrACHMERF B (for
I IF
` the lagoon sample collected on 26 July 1991) responds to'the requests of
both offices.
If approved by the State, it is proposed to employ a low volume pump
to remove the accumulated water now in the lagoon. If necessary, an orifice
will be used to limit the discharge of the -pump to an expected 20 to 50
GPM discharge rate to be set by the State. In no case will the pump discharge
rate be allowed to exceed twenty (20 %) percent of the minimum flow rate
observed from 005 over the past twelve (12) months. At this pumping rate,
discharge of the lagoon contents will require up to eight (8) weeks. A
copy of the flow record developed for the 005 discharge site in 1990 is
included as ATTACHMENT' C.
2� n� b�"24 r,N Q. OVa
r _ Z
yirs �.�2 pa`t
hf�yPM p �•D�Z �S�
4o wi-rN 5o aoc) �?D 35 4PM
Zoo 4?p CW1?, C9.4j>
- 3 - Zoo L, 11M

ATTACE ME T A
CHARACTERIZATION DATA TO BE FURNISHED
IN ORDER TO ALLOW THE STATE OF NORTH CAROLINA
TO ISSUE A PERMANENT AMENDMENT TO
NPDES PERMIT NUMBER NCO004308
1) Listing and origin of sources of wastewater
2) GPD from each source
3) Laboratory analyses as follows (according to previous cormunication with
NCDEHNR):
a) pH
b) Total Oil & Grease
c) Hydrocarbon Oil & Grease
d) Cyanide
e) Total Suspended Residue
f) Fluoride
g) Total Phosphorous
h) BOD
i) Total Kjeldahl Nitrogen
j) Ammonia Nitrogen
k) Nitrate Nitrogen
1) Nitrite Nitrogen
m) Aluminum
n) Arsenic
o) Barium
p) Cadmium
q) Chromium
r) Copper
s) Lead
t) Mercury
u) Nickel
v) Silver
w) Zinc
- 4 -

• ,-/� CERTIFIED
ENVIRONMENTAL SERVICES
�l
ATTACHMENT B
LABORATORY DATA TABULATION'
REPORT DATE: 12 August 1991 FOR:
Aluminum Company of America
SAMPLE DATE: 26 July 1991 P. O. Box 576, Highway 740
Badin, N. C. 28009
SAMPLE SOURCE: ALCOA LAGOON
(Horizontal and Vertical
Ccmposite of contents)
PARAM=
RESULTS
pH ..
6.9
Tbtal Oil & Grease
less than 5.0
Hydrocarbon Oil & Grease
less than 5.0
Cyanide
less than 0.005
Total Suspended Residue
7.0
Fluoride
4.2
Total Phosphorous
0.068
BCD
less than 3.0
Total Kjeldahl Nitrogen
less than 1.0
Ammonia Nitrogen
less than 1.0
Nitrate Nitrogen
less than 0.05
Nitrite Nitrogen
less than 0.01
Aluminum
0.39
Cadmium
less than 0.002
Chromium
less than 0.007
Cyr
0.024
Lead
less than 0.017
Mercury
less than 0.0002
Nickel
less than 0.008
Zinc
0,023
NUM: (1) All Results except
pH are in mg/1
(2) Analyses performed
by Research and Analytical Laboratories,
Kernersville, N. C.
(3) Samples collected by and transported to laboratory by
Joel A. Newton, Sr.
in accordance,with standard practices
published by USEPA
concerning collection, preservation
and holding of wastewater samples.
- 5 -
kt
�_ y 632. FERNWOOD ROAD
KNOXVIU.E, TENN. 37923
(615) 6931-4629

ATTACHMENT T C
RECORDED FLAWS FROM ALCOA DISCHARGE 005
JULY, 1989 THROUGH JUNE, 1991
NPDES PERMIT NUMBER NCO004308
MONTH
YEAR
FLOW
j
IN MGD
AVERAGE
MAXIMUM
July
89
0.222
0.336
August
89
0.316
0.316
September
89
0.379
0.379
October
89.
0.295
0.295
November
89
0.277
0.277
December
89
0.212
0.212
January
90.
0.291
0.291
February
90
0.263
0.263
March
90
0.291
0.291
April
90
0.263
0.263
May
90
0.383
0.383
June
90
0.263
0.263
July
90
0.187
0.187
August
90
0.321
0.321
September
90
0.212
0.212
October
90
0.291
0.291
November
90
0.187
0.187
December
90
0.033
0.033
January
91
0.263
0.263
February
91
0.224
0.224
'March
91
0.367
0.367
April
91
0.229
0.263
May
91
0.266
0.306
June
91
0.268
0.383
AVERAGE
0.263
0.275
MAXIMUM
0.383
0.383
MINIMUM *
0.187
0.187
* December, 1990 excluded.
6
i

ATrACH+iIWr D
CLOSURE D O C'U M E N T
Reproduced with permission of
Lamar Dunn & Associates, Inc.
Knoxville, 'IN

CLOSURE DOCUMENT
ALCOA LAGOON
BADIN, NC
Prepared for:
ALUMINUM COMPANY OF AMERICA, INC.
HIGHWAY 740, P.O. BOX 576
BADIN, NC 28009
Prepared by.
UMAR DUNN & ASSOCIATES, INC.
64W Papermili Road
SuFle 204
y Knoxville, Tennessee 37919
[phone]
Revision id: 25 January 1991

Trmz PAGES(E)
1.0 INTR0OUCTION 1
2.0 LAGOON BACKGROUND DATA 2, 4, 5
FIGURE 1 LAGOON FLOW SC�E?v1LTIC 3
3.0 lt�'ERISLUDGE CHA..R C RISTICS 6
3.1 GENERAL DATA/HISTORY 6
3.2 SAMPLING/ANALYSIS O? SUJDGE AND LAGOON]
LIQUID CONTENT 6, 7, 8
3.3 PERMANENT OILY WASTES TREATMENT FACILITIES 8
4.0 CLOSURE PROCEDURE 9
5.0 GUIDELINE FOR CLOSURE 10,11
APPENDIX A ANALYTICAL DATA, SIl= MMPLE
COLLECTED NOVEMBER, 1989 12 - 21
APPENDIX B ANALYTICAL DATA, LAGO N LIQUID
CONTENTS DECEMBER, 1990 22 - 23
APPENDIX C-1 ANALYTICAL DATA, TREAiABILITY
GRAVITY OIL SEPARATION 24
APPENDIX C-2 ANALYTICAL DATA, TREATABILITY
ULTRAFILTRATION 25

The Aluminum Company of America (ALCOA), Bailin, North Carolina facilities
has treated certain wastewater flows through an aerated lagoon since 1971. All
of the processes which produced wastewater received by the lagoon except one
source have been modified to totally eliminate water use. The one flow stream
still in existence is Condensate from Air Ccrnpressors. .It is ALCQA'S desire to
close the lagoon and provide new treatment facilities for Compressor Condensate.
This report displays and discusses the pertinent information required of a
CLOSURE PLAN as follows:
1) The CLOSURE PLAN provides background data, applicable laboratory
results and the plan of action in order to allow State of N.C./local
regulatory approval of the construction techniques and final disposal
modes selected.
2) The CLOSURE PLAN provides engineering drawings and specifications
necessary to allow ALCQA to procure contractor bids for closure
services and allow the selected contractor(s) to execute the PLAN
.to completion.
Closure of the lagoon will involve:
1) Discharge ofpresent lagoon contents to a tributary of Little
Mountain Creek as per the limits at the Old NPDES Permit and/or other
criteria to be set upon review of this document by the State of North
Carolina and Stanly County,
2) Removal and ultimate disposal of lagoon sludge plus 6" of lagoon
bottom dirt in the Sternly County Landfill or another site as
indicated by the State or Alcoa , and
3) fill, grading and seeding of the lagoon area to eliminate the lagoon
basin and ancillary structures.
-1-
A _-
0

Figure 1 displays a simplified flow schematic for the lagoon and ancillary
structure. The lagoon exhibits an approximate volume of 3,900,00 gallons (3.9
MG) has dimensions of 290 feet (north to south) by 210 feet (east to west) by
15 feet depth. The 240' x 195, surface area slopes at 3:1 ratio to a 150' x 100'
clay sealed bottom. Aeration is (was) provided by means of nine (9) Helixors
each of which are nine (9') high and supplied by three (3) each Gardener -Denver
centrifugal blowers operated at 1875 RPM to produce an estimated 180 CFWblower
at 9psi. An oil skimmer, followed by chemical flocculator with phi control and
ferric chloride feed is present on the influent headworks.
Free oils were removed via the headworks oil skim-er. Emulsified oils were
de -emulsified by means of Ferric Chloride (FeC13) addition and/or oxygen
oxidation of double bonds in caster oil molecules.
The lagoon was originally designed to provide twenty (20) days aerated
detention in order to meet its NPDES permit of:
<181,000 GPD
TSS 696 mg/l
Fluoride 5.1 mg/l
BOD5 38 mg/l
Thtal Oil & Crease 10 mg/l
Effluent D.O. >5.0 mg/l
Over the years, several modifications to the lagoon were performed in order to
insure consistent compliance with .these NPDES limits and protect against
discharge of other unregulated pollutants.
A discussion of these modifications follows. The primary pollutant
received by the lagoon was AAA Castor Oil and cooling tower blowdown/cleaning.
-2-

4FIGURE 1
ALCOA BADIN WORKS
LAGOON
i FLOW SCHEMATIC
1) COOLING TOWER
I 2) COMPRESSOR COOLING WATER
3) COMPRESSOR CONDENSATE
4) POT .SHELL WASHINGS
.I 1
OIL
SKIMMER
al
�i
I�
B
L
(:D--
0
2
I E
R
3
S
�l
TO MIXER
HEADERS
RECORDER
1) INGOT MOLD CLEANING
2) CAUSTIC CLEANING OF INGOTS
IN —GROUND
I TANK
t
CHEMICAL
ADDITION
FLOCCULATOR
HZSOq
STORAGE
H 2 SO4
FEED
PUMP,
Fe Cl,Fe C13
FEED STORAGE
PUMP
NUTRIENT
ADDITION
AS NEEDED
PERIODIC SLUDGE
REMOVAL TO SAND
BEDS AND THEN TO
STANLEY COUNTY LANDFILL
KEY:
1 FLOW OR pH SENSOR
PARSHALL O HELIXOR
FLUME
J, o EFFLUENT STAND PIPE
TO c FIXER
CREEK $ LEVEL SENSOR
- 3-

Initially the number of Helixors and their placement pattern were modified to
provide more dissolved oxygen as well as a sludge settling zone at the discharge
end of the lagoon. Since the wastewater was nutrient deficient, a program of
nitrogen/phosphorous/potassium addition was implemented to encourage bacterial
and algal growths in sufficient quantities to treat the waste load. Due to the
seasonal algal growth characteristics, the nutrient addition program was varied
during the calendar year. Settled sludge removal was initiated when the lagoon
reached 56°F each year in order to preclude anaerobic resolubilization of settled
biological sludges (ie: to prevent effluent HOD and TSS violations). Since the
degradation time required for biological castor oil oxidation is over 120 days,
it was necessary to incorporate that castor•oil passing through the headworks
oil skimmer into the sludge. With the extremely high "sludge age" of the settled
sludge, the linoleic, ricinoleic and oleic acid ccuponents of castor oil were
anaerobically (and aerobically) degraded to acetic acid. The acetic acid was
then quickly utilized by aerobic bacteria and algal as an energy source. In this
manner, a non -degradable oil was converted to biologically compatible short
chain acid molecules and subsequently oxidized or converted to biological sludge.
In order to protect this highly specialized, therefore sensitive lagoon biology
and the receiving stream from toxic shock, the use of FeC13 as a coagulate was
selected in lieu of other coagulants after careful consideration of
anaerobic/aerobic biochemistry, natural buffer pH, oil coagulation potential,
Protection fran cyanide shock and coagulant -toxicity. The reader is advised that
cyanide levels noted in the lagoon sludge, influent and effluent have always been
below detection limits. The lagoon biological chemistry had the ability to
oxidize small quantities of cyanide to carbon dioxide and nitrogen gas. However
-4-

the potential existed for cyanide discharge at levels sufficient to inhibit the
lagoon biology. Due to the long acclimation period required for the lagoon
biology (60 days) it was necessary to provide a method to complex any cyanide
which might have been present to non -toxic form.
FeCl3 addition with pH control to 7.12 was therefore selected in order to:
1) Provide oil/water emulsion breakage capabilities,
2) flocculate freed oil or other contaminants and allow the solids to
settle to the lagoon bottom where solids were later vacuumed out and
trucked to sand beds for dewatering before ultimate disposal in the
Stanley County Landfill,
3) allow chemical coagulation operation of the lagoon at the natural
buffer pH which the lagoon exhibited prior to commencement of FeC13
feed,
4) provide iron to form an immobile cyanide complex -should cyanide be
received by the lagoon (ie=excess CN was reacted with iron to form
Prussian Blue),
5) provide a "tough", "reflocculating" and "heavy" flocculated product
.(specific gravity 1.17) which would form and settle acceptably in
the moderate turbulence of the lagoon,
6) provide an easily dewatered sludge for sand bed application and,
7) provide polishing treatment for remaval of fluoride, aluminum or
other metal contaminants.
Thus the lagoon biological population was "matched" to the receiving stream and
protected against toxicity or nutrient starvation while converting the waste
ccniponents to ecologically stable and naturally occurring forms.
During the last ten (10) years, the lagoon effluent met the above
requirement as well as the NIPDFS permit. it is now desired to "decommission"
the facilities with the same consideration of the environment.
-5-

3 . D sum cwawmRisrlcs
3.1 [, DAZVUISICIRY
Since 1971 the lagoon has received up to 180,000 GPD. Over the years,
ALMA has reduced the wastewater volume to the present (estimated) 1 GPM or less.
Originally the lagoon received flow and contaminants as follows:
ITEM V IV ME CON MUNANP
1) Pot Shell Washings <50,000 GPD Caustic
Aluminum
Fluoride
Rust
Castor Oil
Cyanide
2) Cooling tower
cleaning and
blowdow_n <50,000 GPD Caustic
Biocide
Biological Slime
Dissolved Solids
3) Cc�ressor
Condensate <2000 GPD Compressor Oil
1 —
4) Compressor Cooling
Water (Non -Contact) <100,000 GPD No Pollutants
5) Caustic Mold
Cleaning <1500 gal/quarter Aluminum High pH
During the time period, 1971 through 1988, all flows to the lagoon.except
compressor condensate (#3 above) have been eliminated. Therefore the only
contaminant remaining is compressor oil in a water volume of less than 2000 GPD.
In 1988 the lagoon was emptied but has since partially refilled with rain water
and a small volume of compressor condensate.
3.2 SAmKiNG/ANALYSIS op surcE AND iA000N LIQUID owrE r
Since 1988 the lagoon has been operated as an aerobic/anaerobic lagoon
with zero discharge. During that time contained in the lagoon has risen to
approximately 1.5 MG (ten foot water depth).
-6-

M
In the summer of 1988, while the lagoon was empty, samples of sludge were
collected at six (6) sites in the lagoon and blended into a single sample for
analysis as displayed in Appendix A.
With the exception of 1% by weight total oil and grease content, the sludge
is typical of a waste activated sludge. It easily meets the 111OX drinking water"
criterion for disposal in local or industrial landfills. The sludge sample
analyses indicated no organic, pesticide, herbicide, ,129 list" or PCB
contamination. Note that only the TCLP data of Appendix A was developed by the
extraction method. All other data is to be viewed as "total content" data -
not just the "extractible portion". Bence, after State and Local approval, the
dewatered sludge will be routed to a landfill as a "non -hazardous waste as
defined by 1OX drinking water -criteria".
In January 1991 samples of accwnulated water in the lagoon were collected
for analyses, as displayed in Appendix B. The "wastewater" in the lagoon is
actually an extremely dilute mixture of rain water with campressor condensate.
WT-dle future plans will provide -up to 4000 GPD capacity to treat the condensate,
the actual condensate volume is estimated at 500 cols/minute maximum flow (200
ME
Appendix B data was developed from analysis of samples of lagoon wastewater
as follows. Six (6) sites equally spaced within the lagoon areas were'sampled
at:
1) The surface of the water,
2) two (2) feet below the surface and
3) seven (7) to eight (8) -feet below the surface.
The six (6) surface samples were combined into a single "surface coposite"
for analysis. Likewise the six (6) "two foot" samples were combined a single
-7-

"two foot composite". Similarly, the six (6) "seven foot" samples were combined
into a single "seven foot composite" for analysis. finally, a portion of each
of the eighteen (18) alliquots was combined to form a "lagoon composite" stele.
All four (4) composite samples were analyzed for BOD5, TSS, pH and oil & grease.
All parameters were well below the limits of the old NPDES Permit. Thus the
present rainwater/compressor condensate which has collected in the' lagoon is
proposed for discharge to a tributary of Little Mountain Creek after State
approval of the request to do so.
The Prelminary Engineering Report developed as a result of treatability
studies, is submitted with the Enclosure Document. it is proposed to
simultaneously implement Closure and Construction of Permanent Facilities. Upon
regulatory approval of the Closure Plan and the Preliminary Engineer Concept of
Punt Facilities, Final Engineering Plans and Project Specifications will
be developed for the Permanent Oily Waste Treatment Facility and sutzni.tted to
the State for approval. .
A

Engineering drawings and specifications necessary to remDve materials in
and around the lagoon and reclaim the lagoon site are included with this
document. There will be at least seven (7) steps in the closure.
STEP 1: Sample and define the sludge and water in the lagoon.
See Section 3.2, Appendix A and B
SAP 2:A Develop final engineering plans and specifications together
with the Closure Document (narrative closure plan which
together with engineering plans will allow regulatory
review/approval).
STEP 2:B Perform treatability studies to guide selection of new
treatment equipment for. cm pressor condensate. A gravity,
coalescing oil separator and ultrafilter have been tested at
the site. The results of those tests are included as Appendix
C-1 (ultrafilter) and C-2 (gravity oil separator). Based upon
a 30 mg/1 oil and grease effluent limit, the ultrafilter will
easily meet the limits. Preliminary test results from the
separator tests indicate that this technology is not
acceptable. Therefore an ultrafilter is proposed to receive
the compressor condensate.
STEP 3 Implement results of treatability study after State approval
of plans and specifications.
STEP 4 Discharge lagoon contents to a tributary of Little Mountain
Creek at 50 to 100 GPM via temporary submersible pumps.
STEP 5 Obtain contractor bids to close the lagoon.
STEP 6 Initiate lagoon closure plan.
STEP 7 Request final regulatory inspection of project during
performance and at completion.
im

The reclamation of the lagoon site will exhibit the following points.
1) A norUraest to southeast downFrdrd slope will be developed while
maintaining a one (1) to two (2) foot rise along the centerline of
the slope in order to direct surface water around rather than across
the reclamated site.
2) All constructed materials in and around the lagoon will be removed
and either salvaged, muted to landfill or used as fill in the
reclamated site. only concrete, masonry or stone materials frrm
the area of the lagoon will be used for reclamation -- no metal, wood
or plastic. Fill materials obtained outside the lagoon area will
be free of stones larger than six (6") inches and will not contain
metal, wood, plastic, leaves, garbage, rubber, glass or any hazardous
material as defined by the Hazardous Wastes Regulations of the State
of N.C.
3) The reclamated site will exhibit at least five (5) feet of compacted
dirt over all fill material and dirt employed for fill will not
exhibit excess moisture as to prevent immediate compaction of fill
dirt.
4) The sludge now in the bottom of the lagoon and six (6 ") of soil
beneath the sludge will be removed and routed to landfill after
-dewatering or fixation of the water in the sludge. An estimated 700
yds3 of material will be removed.
5) Water h6w in the lagoon will be discharged at 50 to 100 GPM after
State of N.C. approval by another contractor so no more than three
(3") inches of water will retrain in the lagoon covering the sludge.
6) Appropriate silt and erosion control measures will be Toyed during
construction.
7) The reclamated area will be reseeded.
8) A catch basin at the southeast corner of the reclamation site will
collect storm water which will be routed around the site - thus
preventing erosion of the roadway and sidewalk to the southeast of
the site. Piping from the catch basin will route water under the
sidewalk to the existing stormwrater collection site at the southeast
corner of the reclamation.
9) Upon completion of the project, the area will again be closed by
fencing.
10) The areas to the immediate north and west of the site will be left
as is so as not to disrupt stormwater run-off routes in existence.
-10-

11) As a part of the project, an open fiberglass mixing basin to the
north of the site wi11 be removed to demolition. The effluent of
the manhole serving that mixing basin will be plugged with concrete.
12) All effluent piping frcn the lagoon Parshall Flume structure will
be removed and all inf luent piping to the lagoon will be plugged with
concrete.
13) The effluent Parshall Flume channel and discharge pipe will be
plugged with concrete and then covered with at least two (2) feet
of dirt (effluent piping between the flume and discharge point will
be removed) .
14) No existing storm sewers will be disturbed.
15) All sidewalk pavement disrupted during construction will be replaced.
16) All electrical service to the lagoon area will be disabled and
disconnected at the source(s).
17) No chemicals, feed equipment, pumps, blowers or basins will be left
at the site.
18) If requested by Alcoa or the State, soil samples of the cleaned
lagoon bottom will be collected and analyzed as required before
actual fill operations are started in the lagoon basin at the expense
of Alcoa.
19) State and other regulatory inspection/i.nput will be requested during
and after the project.
20) A listing of Salvage Materials and Demolitions is included in the
Specifications as -section I, 1.03 and on the drawings.
-11-

41 ••D. z1 •
: *6-NOT, Mi
• V. 1 rD. • r• •• od
M �•
• M• •� r• • • 7I• r.
* ANALYTICAL LIST:
RC RA CHARACTERISTICS
TcTP
129 LIST
ALL HEAVY NET AIS
. MPS
CN AND PHENCL
PEST CIDES
HERBICIDES
70DWMINERAL OIL & GREASE
A•GE .
NLURIENTS
WATER CONTENr
DRINKING Wn E• CRITERIA
• Mn. Ila, Sn and Th
Xylem, E1'
-12-

•ORr= RAT I ONE;
1. _ `r' 'T 1 C r ^ I._.
. LABORA I Oft Y ti;�= hW : C.;.'.-�
a I7 I_r T P. I A I-_ r7— r_ .1 P. 1Z_ 1—,
103 Warpknuse Mart, 02, Bav 14
;:nallannc9a, Tenna gs r 37421
(015) 8?4--E ; G?
-:US T OMLr< 5-76
CERTIFIED NVIRONMENTAL SEW
632 FERNWCOD ROA7,
KNOXVI LL E , TN 37723
AT TENT i ON :.I OEL A. NT JTON , SR,
;L.agnon Si udse
ANALYSIS
PRIORITY POLLUTANTS
vc l at. i i eS
All ha I ❑i, Atinni5s i piec. t. i r•n Lim its
. r.
L. A I? r'. J C—) - - F--'3 ':? -7 r? ❑ — 'Ery , %. 1.
DATE RECO. : ; i /?9/S9
SAMPLE OAT;_: 11/09/6?
Ci_IST 0.0.
Acids
F^eno i �7. i7rz2
Ali other acids .............. ........ & .02.
Base/Neutrals
Nanktna l ene . . . . . . . . . . . . . . . . . . . . . . . . . . ter. Lill
Ant.hracene.'...........................0.022
?is(2 ethylKexyi)phthaiate............ 0.13
Ali other base/neutrais..............<; .C2
est A i ces and FCBI S
Ail below, Methods Detection Limits
METHODS DETECTION LIMITS ENCLOSED.
ALL RESULTS RECORDED IN PPM OR MG/i_. UNLESS OTHERW I ST STAI E7 .
),>O(XXX):),,Xx:>:Y,X)(Y,Y,Y.XXY.XX)(XX):):Y,XY,XY.XXXXX)(XX>:)O(XXY.XY,XY.XY,XXXYX)(XXXY.):Y.X):XXY,3:Y,Y.XX>:Y.X):X),
We hereby Certify that the analvt.iCaI proc:edureS employed
are those anwrovec by tha Environmental Protection Agency or
other appiicanIe metinads for these analyses,.
ANALYTICAL i \";l_1STR ' A:. RESEARCH LABORATOR I F. S
—13—
at

ZERO HEAD SPACE EX7RA[TiON
|'AB0,�AT017Y NUMR�k-:' 897�G-56�1
Arsenic
Barium.
Car3,miu m
[inromium
Leao
Mercury
�eier).ium
5iiver
Tin
Berv||ium
Nickei
Zin'c
Mec�"� ���v| Kezz�e
Benz.ene
To|uenc
Xvierie
<OOD2
mg/i
<O�
(OOD5
mro/i
O�O
me/|
n�/|
<OOOO2
mc4/�
<O.002
Tr. P/i
<O.O1
ms/i
(O.8
m9/|
(O.4,
ms/|
_ ,0 2
ns/i
OO7
m9/|
<JO�
mq/|
<O.O
mg/I
�ODI
i
{O.G, z") mg/I
NOTEA/| resji-ts recoroe6 in mg/L (ppm) un|ess otin ermise
state6
—l�—

SAMPLE NUMBER: 89790-5641
TOTAL ANALYSIS
pH...............................................
6.2
COD ..............................................
240,797
TKN..............................................
250
Total Solids..... ..............................
29 %
AmmoniaNitrogen .................................
33.3
Phosphate........................................
0.34
Fluoride.........................................
0.14
Oil& Grease .....................................
1.30 %
Hydrocarbon Oil & Grease .........................
0.19 %
Chloride .........................................
666
Sulfide ..........................................
4.31
Sulfate..........................................
2293
Nitrate...........................................
199
Nitrite..........................................
<0.005
Aluminum.........................................
7200
Calcium ..........................................
3.27
.Iron.. .. ........
1.89 %
Magnesium......................:.................
144
Manganese.........................................
30.8
Potassium ........................................
53.6
Sodium...........................................
379
Barium...........................................
<0.1
RCRA ANALYSIS
Ignitibility....... . ........................... >140 OF
Reactivity ...... (Phenol) ......................... 1.972
Cyanide........................................... <0.031
Sulfide .......................................... 4.31
Methoxychlor..................................... <0.1
NOTE: All results recorded in mg/Kg (ppm) based on
wet weight of solids unless otherwise stated.
-15-

AXALYTICAL INDUSTRIAL RESHARCH LABORATORIES
4295 CROMWELL Rd Ste 614
CHATTANOOGA, TN 37421-2177
[phone]
PRIORITY POLQTANTS
METHODS DETECTION LIMITS RECORDED IN µg/L (ppb)
SAMPLE I.D.: 5641
ANALYSIS PERFORMED BY OSEPA METHODS 624 & 625
YOIATILES
*HDL
PQL RESULTS
2.
Acrolein . . . . . . . . . . . . . . . . . .
0.6
0.60
ND
3.
Acrylonitrile. . . . . . . . . . . . . . . . .
0.5
0.50
ND
4.
Benzene . . . . . . . . . . . . . . . . . . . .
1.0
1.00
ND
6.
Carbon Tetrachloride . . . . . . . . . . . .
2.8
2.80
ND
7.
Chlorobenzene . . .
6.0
5.99
ND
10.
1,2-Dichloroethane . . . . . . . . ,
2.8
2.80 ..
ND
11.
1,1,1-Trichloroethane . . . . . . .
3.8
3.80
ND
13.
1,1-Dichloroethane . . . . . . . . . . . . . .
4.7
4.70
ND
14.
1,1,2-Trichloroethane . . . . . . . . . . . .
5.0
5.00
ND
15.
1,1,1,2-Tetrachloroethane . . . . . . . . . .
6.9
6.89
ND
16.
Chloroethane . . . . . . . . . . . . . . . . .
0.52
0.52
ND
23.
Chloroform (Trichloromethane) . . . . . . . .
1.6
1.60'
ND
29.
1,1-Dichloroethylene . . . . . . . . . . . . .
2.8
2.80
ND
30.
1,2-Trans-Dichloroethylene . . . . . . . . . .
1.6
1.60
ND
32.
1,2-Dichloropropane . . . . . . . . . . . . .
6.0
5.99
ND
33.
1,2-Dichloropropylene (1,3-Dichloropropene)
5.'0
5.00
ND
38.
Ethylbenzene . . . . . . . . . . . . . . . . .
1.
1.00
ND
44.
Methylene Chloride (Dichloromethane)
2.8
2.80
ND
45.
Methyl Chloride (Chloromethane) . . . . . . .
0.08
0.08
ND
46.
Methyl Bromide (Bromomethane) . . . . . . . .
1.18
1.18
ND
47.
Bromoform (Tribromomethane) . . . . . . . . .
4.7.
4.70
ND
48.
Dichlorobromomethane . . . . . . . . . . . . .
2.2
2.20
ND
49.
*Trichlorofluoromethane . . . . . . . . . . .
3.0
3.00
ND
50.
*Dichlorodifluoromethane . . . . . . . . . . .
1.81
1.81
ND
51.
Chlorodibromomethane . . . . . . . . . . . . .
3.1
3.10
ND
85..
Tetrachloroethylene . . . . . . . . . . . . .
4.1
4.10
ND
86.
Toluene . . . . . . . . . . . . . . . . .
1.0
1.00
ND
87.
Trichloroethylene . . . . ... . . . . . . . .
1.9
1.90
ND
88.
Vinyl Chloride (Chloroethylene) . . . . . . .
0.18
0.18
ND
Xylenes (total) . . . . . . . . . . . . . . .
2.
2.
ND
NOTE: All above listed detection limits and results are measured
in
Mg/L-
*NB:.These compounds are no longer included
as
priority
pollutants, but are included for those
agencies
that
may
still require them.
MDL Method Detection Limit. Applicable
to Reagent Water
PQL = Practical Quantitation Limit. Dependent
on sample
matrix. This should be considered the MDL when the
sample matrix is not reagent water.
-16-

ANALYTICAL INDUSTRIAL RESEARCH LABORATORIES
4295 CROMWELL RD Ste 614
CHATTANOOGA, TN 37421-2177
[phone]
SAMPLE I.D.2 5641
CUSTOMER I.D.S CBS
*XDL
PQL
RESULTS
{
µq/L
)
21.
2,4,6-Trichlorophenol
2.7
2.70
ND
22.
Parachloro-meta-Cresol . . . . . .
3.0
3.00
ND
31.
2,4-Dichlorophenol . . . . . . . . . . . .
2.7
2.70
ND
34.
2,4-Dimethylphenol . . . . . . . . . . . . . .
2.7
2.70
ND
57.
2-Nitrophenol .'
3.6
3.60
ND
58.
4-Nitrophenol . . . . . . . . . . . . . . . .
2:A,
2.40
ND
59.
2,4-Dinitrophenol . . . . . . . . . . . .
42
42.00
ND
60.
4,6-Dinitro-o-Cresol . . . . . . . .. . . . . .
24
24.00
ND
64.
Pentachlorophenol . . . . . . . . . . . . . .
3.6
3.60
ND
65.
Phenol . . . . . . . . . . . . . . . . . . . .
1.5
1.50
52.
2-Chlorophenol . . . . . . . . . . . . . . . .
2.
2.
ND
r
-17-

ANALYTICAL INDUSTRIAL RESEARCH LABORATORIES
4295 CROMWELL Rd, Ste 612
CHATTANOOGA, TN 37421-2177
[phone]
ETROD 625 BASE/NEUTRAL$
SAMPLE X.D.: 5641
CUSTOMER I.D.:CES
•MDL
PQL
RESULTS
(
µ9/L
?
1..
Acenaphthene . . . . . . . . . . . . . . . . .
1.9
1.90
ND
5.
Benzidine . . . . . . . . . . . . . . . . . .
4.4
4.40
ND
8.
1,2,4-Trichlorobenzene . . . . . . . . . . . .
1.9
1.90
ND
9.
Hexachlorobenzene . . . . . . . . . . . . . .
1.9
1.90
ND
12.
Hexachloroethane . . . . . . . . . . . . . . .
1.6
1.60
ND
17.
Bis(Chloromethyl) Ether . . . . . . . . . . .
0.6
0.60
ND.
18.
Bis(2-Chloroethyl) Ether . . . . . . . . . . .
5.7
5.70
ND
19.
2-Chloroethyl Vinyl Ether (mixed) . . . . . .
3.9
3.90
ND
20.
2-Chloronaphthalene . . . . . . . . . . . . .
0.94
0.94
ND
25.
1,2-Dichlorobenzene . . . . . . . . . . . . .
1.9
1.90
ND
26.
1;3--Dichlorobenzene . . . . . . . . . . . . .
1.9
1.90
ND
27.
1,4-Dichlorobenzene . . . . . . . . . . . . .
4.4
4.40
ND
28.
3,3-Dichlorobenzidine
16.5
16.50
ND
35.
2,4-Dinitrotoluene . . . . . .-. . . . . . . .
5.7
5.70
ND
36.
2,6-Dinitrotoluene . . . . . .
1.9
1.90
ND
37.
1,2-Diphenylhydrazine
100.0
99.99
ND
40.
4-Chlorophenyl Phenyl Ether . . . .
4.2
4.20
ND
41.
4-Bromophenyl Phenyl Ether . . . . . . . . . .
1.9
1.90
ND
42.
Bis(2-Chloroisopropyl) Ether . . . . . . . . .
5.7
5.70
ND
43.
Bis(2-Chloroethoxy) Methane . . . . . . . . .
5.3
5.30
ND
52.
Hexachlozobutadiene . . . . . . . . . . . . .
0.9
0.90
ND
53'.
Hexachlorocyclopentadiene . . . . . . . . . .
18'.0
18.00
ND
54.
Isophorone . . . . . . . . . . . . . . . . . .
2.2
2.20
ND
55.
Naphthalene . . . . . ... . . . . . . . . . .
1.6
1.60
51.
56.
Nitrobenzene ..: . . . . . . . . . . .
1.9
1.90
ND
61.
N-Nitrosodimethylamine . . . . . . . . . . . .
0.15
0.15
ND
39..
Fluoranthene . . . . . . . . . . . . .
2.2
2.20
ND
62.
N-Nitrosodiphenylamine
1.9
1.90
ND
63.
N-Nitrosodi-n-Propylamine . . . . . . . . . .
0.46
0.46
ND
66.
Bis(2-Ethylhexyl) Phthalate . . . . . . . . .
2.5
2.50
130.
67.
Butyl Benzyl Phthalate . . . . . . . . . . . .
2.5
2.50
ND
68.
Di-n-Butyl Phthalate . . . . . . . . . . . . .
2.5
2.50
ND
69.
Di-n-Octyl Phthalate . . . . . . . . . . . . .
2.5
2.50
ND
70.
Diethyl Phthalate . . . . . . . . . . . . . .
22.0
22.00
ND
71.
Dimethyl Phthalate . . . . . . . . . . . . . .
1.6
1.60
ND
72.
Benzo(a) Anthracene(1,2-Benzanthracene) . . .
1.
1.00
ND
73.
Benzo(a) Pyrene (3-,4-Benzopyrene) . . . . . .
2.5
2.50
ND
74.
3,4-Benzofluoranthene . . . . . . . . . . . .
4.8
4.80
ND
75.
Benzo(k)Fluoranthene (11,12-Benxofluoranthene)
2.5
2.50
ND
76.
Chrysene . . . . . . . . . . . . . ... . . . .
2.5
2.50
ND
77.
Acenaphthylene . . . . . . . . . . . . . . . .
1.9
1.90
ND
78.
Anthracene . . . . . . . . .
1.9
1.90
22.
79.
Benzo(ghl)Perylene (1,12-Benzoperylene) . . .
4.1
4.10
ND
80.
Fluorene . . . . . . . . . . . . . . . . . . .
1.9
1.90
ND
81.
Phenanthrene . . . . . . . . . . . .
5.4
5.40
ND
82.
Dibenzo(a,h) Anthracene(1,2,5,6-Dibenzanthracene)2.5
2.50
ND
83.
Indeno (1,2,3-cd)Pyrene (2,3-o-Phenylenepyrene)
3.7
3.70
ND
84.
Pyrene . . . . . . . . . . . . . . . . . . . .
1.9
1.90
ND
-la-

• ANALYTICAL INDUSTRIAL RESEARCH LABORATORIES
4295 CROMWELL Rd, et! 612
CHATTANOOGA, TH 37421-2177
[phone]
608 PESTICIAESPCB
SAMPLE I.D. 5641
*MDL PQL RESULTS
89.
Aldrin . . . . . .
. . . . . . . . . . . . . .
1.9
1.90
ND
90.
Dieldrin . . . . .
. . . . . .
2.5
2.50
ND
91.
Chlordane (technical mixture & Metabolites)
2.
2.00
ND
92.
4-, 4-DDT . . . . . .
. . . . . . . . . . . . . .
4.7
4.70
ND
93.
4,4-DDE (p,p-DDX)
. . . . . . . . . . . . .
5.6
5.60
ND
94.
4,4-DDD (p,p-TDE)
. . . . . . . . . . . . . .
2.8
2.80
ND
95.
a-Endosulfan-Alpha
. . . . . . . . . . . . . .
0.014
0.01
ND
96.
b-Endosulfan-Beta
. . . . . . . . . . . . .
0.004
0.00
ND
97.
Endosulfan Sulfate
. . . . . . . . . . . . . .
5.6
5.60-
ND
98.
Endrin . . . . .
. . . . . . . . . . . . .
0.006
0.01
ND
99.
Endrin Aldehyde .-..
. . . . . . . . . . . . .
0.023
0.02
ND
100.
Heptachlor . . . .
. . , . ... . . . . . . . .
1.9
1.90
ND
101.
Heptachlor Epoxide
. . . . . . . . . . . . . .
2.2
2.20
ND
102.
a-BHC-Alpha
...
0.003'
0.00
ND
103.
b-BHC-Beta . . . .
. . . . . . . . . . . . . .
4.2
4.20
ND
104.
r-BHC (Lindane)-Gamma . . . . . . . . . . . .
0.004
0.00
ND
105.
g-BHC-Delta
0.004
0.00
ND
106.
PCB-1242 (Arochlor
1242) . . . . . . . , . . .
0.065
0.07
ND
107.
PCB-1254 (Arochlor
1254) . . . . . . . . . . .
0.065
0.07
ND
108.
PCB-1221 (Arochlor
1221) . . . . . . . . .
0.065
0.07
ND
109.
PCB-1232 (Arochlor
1232) , . . . . . . . . . .
0.065
0.07
ND
110.
PCB-1248 (Arochlor
1248) . . . . . . . . . . .
6.065
0.07
ND
Ill.
PCB-1260 (Arochlor'1260)
. . . . . . . . . .
. 0.065
0.07
ND
112.
PCB-1016 (Arochlor
1016) . . . . . . . . . .
. 0.065
0.07
ND
113:
Toxaphene . . . .
. ... . . . . . . . . . .
. 0:24
0.24
ND
129.
2,3,7,8-Tetrachlorodibenzo-p-Dioxin(TCDD) .
. 0.002
0.00
ND
NB: ALL RESULTS AND MDL IN µg/Kg
-19-

PRIORITY POLLUTANTS (Cont.) Page 5
ANALYSIS PERFORMED BY USEPA METHOD NO's 624 and 625
Metal Analysis by Method 1310, 3010, 30501 and 7000
TOTAL METALS
114.
Antimony ...............................
286
ppb
115.
Arsenic ...............................
< 10
ppb
117.
Beryllium ..............................
< 1
ppb
118.
Cadmium ................................
8.75
ppb
119.
Chromium ..............................
120
ppb
120.
Copper......... .........................
110
b
122.
Lead ................... I...............
85.4
ppb
123.
Mercury .................................
<0.2
ppb
124.
Nickel ..............................
420
ppb
125.
Selenium ..............................
< 5
ppb
126.
Silver .................................
2.71
ppb
127.
Thallium ...............................
< 10
ppb
128.
Zinc ...................................
430000
ppb
OTHERS
116. Asbestos .............................. <0.1 MFL
121. Cyanide............ .................. < 20 ppb
-20-

i ANALYTICAL INDUSTRIAL RESEARCH LABORATORIES
4295 CROMWELL Rd, Ste 612
CHATTANOOGA, TN 37421-2177
[phone]
SAMPLE I.D.: 5641
CERTIFIED ENVIRONMENTAL SERVICE
OTHER ORGANICS (TOTAL)
MDL
PQL
RESULT
(
A9/Rq
)
o-Cresol . . . . . . . . .
. . . . . . 5.
5.
ND
m-Cresol . . . . . . . . . .
. . . . . . 5.
5.
ND
p-Cresol . . . . . . . . . .
.. . . . . . 5.
5.
ND
Total Cresols . . . . . . . . . .
. . . . . . 5.
5.
ND
2,4;5-Tri.chlorophenol . . . . . .
. . . . . . 5.
5.
ND
Pyridine ... . . . . . . .
. . . . . ." 5.
5.
ND
Methoxychlor .. . . . . . . .
5.
5.
ND
2,4-D . . . . . . . .
2.
2.
ND
2,4,5-tp,Silvex . . . . . . . . .
. . . . . . 2.
2.
ND
-21-

APPENDIX B
ALCOA BADIN WORKS
LAGOON
LIQUID ANALYSES
I SAMPLE
A. PLAN VIEW
,x
SITES
XI X2 X3
X4 X5 X6
B. ELEVATION VIEW
r-SURFACE-7
,
SLUDGE
1IRESULTS (SEE SECTION 3.2 OF THIS REPORT)
1 SURFACE. OF LAGOON. (6 ALIQLOTS)
2 2' BELOW -SURFACE 6 ALIQUO'S
3 7' BELOW SURFACE 6 ALIQUG-S)
4 LAGOON COMPOSITE 18 ALIQUOTS)
-22-

APPENDIX B
LAGOON LIQUID ANALYSES
SITE
PARAMETER (mg/l except pH
pH
TOT. O+G
MIN. 0+G
TOT. S.S.
EC' -
LAGOON SURFACE
7.4
<5
<5
11
2' BELOW SURFACE
7.2
14
<5
18
7' BELOW SURFACE
7.1
17
<5
16
LAGOON COMPOSITE
7.1
8.3
<5
20
<
COMPRESSOR CONDENSATE
5.7
324
227
-
-23-
}
3
3
3
3

APPENDIX C-1
TREATABILITY RESULTS
GRAVITY SEPARATION OF COMPRESSOR CONDENSATE (C. C.
ITEM TOTAL O&G, MINERAL O&G,
GRAVITY SEPARATION
Raw Untreated C.C.
Gravity Separation 8 Hours
Gravity Separation 8 Hours
after pH to 1.5
Oil Concentration in Oil Layer
-24-
340
290
270
None FonTed
230
220
WC
3--,t*6

4
APPENDIX C-2
TREATABILITY RESULTS
ULTRAFILTRATION OF COMPRESSOR COMMCATE (C.C.)
ULTRAFILTRATION
Raw untreated C.C. 360 200
Raw 200Micron Screened C.C. 360 200
Pexmeate at Start 6.4 <5.0
Pezmeate after 5 Hours 13 <5.0
Oil Concentration in Reject after
5 hours (40.1 volume reduction) 4300 2900
-25-
T
1b