NC0004308_PLAN OF ACTION_19980630

NPDES DOCUNENT SCANNINIi COVER SHEET
NPDES Permit:
NC0004308
ALCOA — Badin Works
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
(Plan
of Action ,
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
June 30, 1998
Thies document to prixxted on reuae paper - igrnore asvy
content on the r*e%rerse mitle

Cyanide & alcoa F I lIa
Subject: Cyanide & alcoa
Date: Tue, 30 Jun 1998 IT' )2.51 -0400
From: "Dianne Reid" <dianne_re1d ct h2o.enr.state.nc.us> Internal
To: Dave Goodrich <dave_goodrich a h2o.enr.state.nc.us>
T got a copy of ALCOA's summary of the meeting and noticed that there
was one thing missing. Remember that I noted that the testing with the
low-level methodology was done after a "moderate 'lag time", well it was
3 months later (page 12 of the technical report). The maximum holding
time for "traditional" analysis is 14 days. No other portion of the
report discussed holding time or a clear review of the methods, so I
wonder if this was the only place that holding time could be a problem.
This concern was not discussed in ALCOA's summary and if they come to
you and want to use the low-level procedure, they must have addressed
this issue. As they noted, EPA has told other states that WAD is
acceptable for analysis of free cyanide; however, Lydia is not aware of
a state using microdiffusion. Not anything we need to do, just want you
to be aware of that if they ask for the microdiffusion methodology.
1 of 1 8/15/98 9:28 AM

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Aluminum Company of America
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ALCOA
1998 June 24
Dave Goodrich
=
Division of Water Quality
North Carolina Department of Environment and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
_
Re. Cyanide Issues Meeting Understanding
Dear Mr. Goodrich,
Aluminum Company of America (Alcoa) would like to thank the Division of
Water Quality (DWQ) for the opportunity to discuss various issues related to the cyanide
water quality standard and the triennial review during our meeting on 1998 June 10 in
Raleigh, The meeting attendees included Dianne Reid, Greg Thorp, and Colleen Sulivan
from DWQ, Bill Snee and Henk van der Meyden from Alcoa and Mr. George Everett of
the Manufacturer's and Chemical Industry Council. This letter serves to confirm Alcoa's
understanding of the items discussed.
Alcoa understands that as part of the triennial review the water quality standard
for cyanide, which has been interpreted as total cyanide, will be changed to a free cyanide
criterion. This is consistent with the 1984 U.S. EPA Ambient Water Quality Criteria
Document for Cyanide, U. S. EPA's "Final Water Quality Guidance for the Great Lakes
System; Final" published on March 23, 1995, and the water quality standards adopted by
numerous other states.
Alcoa recognizes that any rule changes resulting from the triennial review will not
ue aduptCu tiritll August VUl1. In the Intl[lrll, L VY VYII: ili:UW ll Ll use vi approved IIIC
cyanide analytical methods to measure conformity with the current cyanide water quality
standards. The free cyanide analytical method will be available for use in new, renewed
and modified permits and in existing permits, with DWQ approval, unless the existing
permit expresses the cyanide limit more restrictedly (i.e., total cyanide).
DWQ has been tracking EPA's activities related to the new Ligand Exchange
Method to measure free cyanide. Once this method is codified as an approved method
under 40 CFR Part 136, DWQ will allow its use. Alcoa understands that there has been a
recent change in the regulatory language of 15A NCAC 2B .0103 and that the current
regulation allows for the use of analytical methods listed in "Standard Methods for the
Examination of Water and Wastewater, 19th edition (1996)" or subsequent editions to
measure conformity with the water quality standards. The weak acid dissociable (WAD)
P.O. Box 576 Badin, North Carolina 28009 USA

method for the determination of free cyanide is listed in this document as Standard
Methods No. 4500-CN I.
In addition, DWQ will discuss the use of the WAD method with the chemists
within the Department of Environment and Natural Resources and advise Alcoa as to the
acceptability of using this method to measure free cyanide. The DWQ staff provided
Alcoa with a paper documenting the close correlation between the WAD method and the
Ligand Exchange method. Ms. Lydia Dow of EPA Region IV has provided guidance to
the State of Tennessee during their most recent triennial review stating that the WAD
method is an acceptable method to measure free cyanide based on Ms. Dow's
consultation with U. S. EPA Headquarters and the EPA's Athens, Georgia laboratory.
Finally, DWQ typically addresses the use of specific analytical methods in a
facility's NPDES permit. Alcoa has reviewed its NPDES Permit; the permit specifies
effluent limitations and monitoring requirements for "total cyanide." Alcoa believes that
its permit language is a reflection of DWQ's past interpretation of the cyanide water
quality standard. Alcoa understands that it would have to seek a permit modification to
change the effluent limitation to read "cyanide" in order to enable use of the WAD
method at this time. Alcoa's current NPDES permit expires August 31, 1999. At this
time, Alcoa will not request modification of its permit but will wait until the permit is
renewed in 1999.
We would like to again thank the DWQ staff for their time and consideration in
this matter. If you have any questions or have a different understanding regarding the
issues discussed at the meeting, please feel free to contact me at [phone].
Sincerely,
Hen van der Meyden, P.G.
Staff Hydrogeologist
cc. B. Snee - EHS Services
S. Myers - Badin
B. Cox - Badin
J. Lettrich - Pittsburgh
D. Reid - DWQ
James Meyers - DWQ