NC0003719_Inspection_20020315

Michael F. Easley, Governor
Ms. Deborah R. Small
Monsanto Company
P.O. Box 2307
Fayetteville, NC 28302
ATA
NCDENR
North Carolina Department of Environment and Natural Resources
- March 15, 2002
SUBJECT: Compliance Evaluation Inspection
Monsanto Company
Wastewater Treatment Plant
NPDES Permit No. NC0003719
Cumberland County
Dear Ms. Small:
C/®Y')t tiz/U
3/i61/4a
fag
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
Enclosed is a copy of the Compliance Evaluation Inspection conducted March 5.2002..
As part of the inspection a tour of the Wastewater Treatment Plant was conducted. All observations
and recommendations are in Part D. Summary of Findings/Comments of this inspection report. The
cooperation of Mr. Donald Allbright, Grade IV ORC, and Mr. Allan Baldwin, Grade III Backup ORC
was appreciated. During the inspection a copy of the NPDES Compliance Reminders were reviewed
and left with Mr. Allbright. As a reminder preservation of the Waters of the State can only be
acquired through consistent NPDES permit compliance.
Please review the attached report. If you or your staff have any questions do not hesitate
to contact me at 910-486-1541.
Sincerel
o?
Belinda S. Henson
Environmental Chemist
/bsh
Enclosures
cc: Mr. Donald Allbright, ORC, Monsanto Company
Fayetteville Regional Office
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us/ENR
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

NPDES COMPLIANCE INSPECTION REPORT
North Carolina Division of Water ,Quality.
Fayetteville Regional Office
Section A. National Data System Coding
Transaction Code: N NPDES NO. NC0003719 Date: 020305 . Inspection Type: C
Inspector: S Facility Type: 2 Reserved:
Facility Evaluation Rating:.4 BI: N QA: N Reserved:
Section B: Facility Data.
Name and Locatiozrof Facility Inspected:
Monsanto Company WWTP
Entry Time/Date: 9:50am/020305 Permit Effective Date: 020301
Exit Time/Date: 12:40pm/020305 Permit Expiration Date: 06103.1 ,
Name(s), Title(s) of On -Site Representative(s):
Donald Allbright (Certified Grade IV Operator) -. "ORC"
Allan Baldwin (Certified Grade III Operator) - "Backup Operator"
Phone Number(s): [phone]
Name, Title and Address of Responsible Official
Ms. Deborah Small, Plant Manager
Monsanto Company
PO Box 2307
Fayetteville, NC:28302
Contacted: no
Section C: Areas Evaluated During Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not •Evaluated, N/A = Not Applicable).
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Small
Page 3
March.15, 2002
Section D: Summary of Findings/Comments:
1.' The facility accepts wastewater from. the following industries located on the complex site: Wellman,
Dupont'and DAK. The majority of the wastewater flow generated comes from Dupont and DAK. The
Monsanto site has ceased production of glyphosate, an ingredient in Roundup. All cleanup and waste
produced is pumped to the spill basin and fed into the plant in small amounts to reduce possible
NPDES permit violations.
2. The influent flow travels to two (2) 650,000 gallon equalization tanks. The flow travels from the tanks
to ari area where pH adjustment, oil skimming and addition of ammonia if needed.
3. The oil skimmer appeared to be operational'with the exception of the tank which houses the excess oil:
It was leaking. The tank did have a containment area'but the leak appeared to be an ongoing problem.
The tank should be repaired as soon .as possible and the containment area pumped out and oil
properly disposed of.
1. Aeration Basin Systems #1 and #2 appeared -to be operating adequately. The influent flows into AB 1
and then into AB 2. The domestic waste stream is introduced into AB.2 through.a comminutor first to
remove any paper products or debris. :The domestic waste.stream flow is approxiinately.10,000 gallons
per day. The most recent Mixed Liquor 'Suspended Solids (MLSS) result -was 4500:mg/L. AB 1 has
seven (7), aerators which appeared to be operational. Liquid. Oxygen is_notadded to the AB 1 presently
and plans are to remove the Oxygen tanks Since plans are to end the usage of this in the treatment.:. AB
2 has five (5) aerators and two (2) mixers. ; A coagulant is added to the MLSS before it enters the
clarifier.: Approximately 20 gallons per day of coagulant is added to assist with solids settling in the
clarifier. •
5. Clarifier #1 was operational. The sludge depth was approximately one•(1) foot with a tank depth of
fifteen (15)feet. Clarifier #2 has not been operational for years.
6. The effluent appeared to be free of solids or foam. . . .
7. The effluent outfall was easily accessible. There -are two pipes located. at the outfall.. One pipe is a
discharge for the effluent and the other is a discharge for the stormwater.
8 The effiuent composite sampler refrigerator temperature was 3 degrees C: The acceptable temperature
range of samples during storage is 1:0 - 4.4:degrees C. The sampler is also flow proportional as more
flow travels by the sensor the more sample it picks up (constant flow/variable volume).
9. The Fischer Porter effluent flow meter was calibrated by facility staff November- 31, 2001. The accuracy
of the meter was documented at +/- 5%.
10, The facility has two digesters which operate in a series. They appeared to be operating adequately. After
sludge is;digested it is pumped int the aerated biosolids holding basin. All sludge is land applied under
permit #; WQ0001959. Synagro is the contract company which land applies the sludge.

Small
Page 4
March 15, 2002
11. A compliance evaluation report for the period January 2001 through December 2001 did not reveal any
violations.
12. The facility has a certified laboratory on site which analyzes the following NPDES.permit required
parameters: Temperature, pH, Dissolved Oxygen, Total Residual Chlorine, BOD, TSS and Ammonia.
All other parameters are analyzed by "Microbac" with the exception of Toxicity which is analyzed by
"Similabs".
13. Laboratory records were reviewed for the month July 2001. All data reviewed appeared to be adequate.'
14. An ORC log was not on site for Mr: Allbright. As a reminder in part as per Administrative Code
Section: 15A NCAC 2B .0506(c)(3)"A log demonstrating visitation at the proper frequency for
the assigned classification, including dates and times of visits."
Please respond in writing to our office to items #3 and #14 by April 19,
2002.
Name and Signature of Inspector
Belinda S. Henson
Name and Signature of Reviewer
Action Taken
Agency/Office/Telephone Date
DENR/Fayetteville/[phone] 3 - l £' -'
Agency/Office/Telephone Date
DENR/F ayetteville/[phone]
Regulatory Office Use Only
Compliance Status
Noncompliance
_Compliance
Date

(Ye., No N/A
No N/A
Section Dt Summary Of Findings/Commeuts
Brief Facility Description:
An existing 1.25 MGD WWTP consisting of flow equalization, spill basin pH adjustment, oil
skimming, comminutor, dual aeration basins clarifier, parshall flume, sludge pump station, dual
aerobic digesters, aerated biosolids holding basin, land biosolids drying -beds. —
FACILITY SITE REVIEW
No N/A 1. Treatment units properly operated and maintained.
Yes No N/A 2. Standby power or other equivalent provision provided.
No N/A 3. Adequate alarm system for power or equipment failure available.
4. Sludge disposal procedures appropriate:
a. Disposal of sludge according to regulations
b. State approval for sludge disposal received.
No N/A 5. Sufficient sludge disposed of to maintain treatment process equilibrium.
�j No N/A 6. The ORC and Backup Operator are officially designated with
NCDENR/DWQ Training and Certification Unit.
Tep No N/A, 7. Adequate spare parts and supplies inventory maintained.
Qres, No N/A:, 8. Plant has general safety structures such as rails around or covers over
tanks, pits, or wells.
No N/ik 9: Plant is generally clean, free from open trash areas.
Yes No
Yes No N/A
Yes No N/A
Yes No N/A,
10. Screening:
• a. Manual
b. Mechanical.
c. Buildup ofdebris
d. Screenings properly disposed of
11. Grit Removal: . .
Yes No (0) a. Excessive organic content in the grit chamber
Yes No N/A b. Excessive odors
Yes No N/A c. Grit properly disposed of.

Page 2
12. Primary clarifier:
Yes No C a. Excessive gas bubbles
Yes No N/A b. Black and odorous wastewater
Yes No N/A c. Poor suspended solids'removed
Yes No N/A d. Excessive buildup of solids in center well of circular clarifier
Yes No N/A e. Weirs level
Yes No N/A £ Weir blockage
Yes No NIA g. Evidence of short circuiting
Yes No N/A h. Lack of adequate scum removal
Yes No N/A i. Excessive floating sludge
Yes No N/A 1. Broken sludge scraper.
13. Trickling Filter:
Yes No a. Trickling filter ponding(indicating clogged media)
Yes No N/A b. Leak at center column of trickling filter's distribution arras
Yes No N/A c. Uneven distribution of flow on trickling -filter surface
Yes No N/A. d. Uneven or discolored growth •
Yes No N/A . e. .Excessive sloughing of growth
Yes No N/A £ . Odor
Yes No . N/A g. Clogging of trickling filter's distribution arm orifices
Yes No N/A h. Filter flies, wouins, or snails.
14. Activated Sludge Basiins/Oxidation Ditches:
(ftcs No N/A a. Dead spots
Yes j N/A b. Failure of surface aerators
Yes 1010 N/A c. Air rising in clumps •
Yes N/A d. Dark foam or bad color
Yes ED N/A e. Thick billows of white, sudsy foam
Yes No .). £ Air rising unevenly
Yes No / g. Excessive air leaks in compressed air piping.
15. Stabilization Ponds/LagoOns:
Yes No a. Excessive weeds including duckweed in stabilization ponds
Yes No N/A b. Dead fish or aquatic organisms
Yes No N/A c. Buildup of solids around influent pipe
Yes No N/A d. Excessive scum on surface.

Page 3
16. Secondary Clarifier:
Yes 1C) N/A a. Excessive gas bubbles on surface
Yes 'go) N/A b. Level overflow weirs
Yes (0 N/A c. Weir blockage
Yes N/A d. Evidence of short circuiting
Yes 1 c N/A e. Excessive buildup of solids in center well of circular clarifier
Yes ail N/A f. Pin floc in overflow
No N/A g. Effective scum rake
Yes , . N/A h. Floating sludge on surface'
Yes N/A i. Excessive high sludge blanket •
Yes N/A j. Clogged sludge withdrawal ports on secondary. clarifier.
Yes Ni.
Yes No
Yes No
Yes No
Yes No
Yes No
N/A
N/A
N/A
N/A
N/A
17. Filtration: -
a. Filter surface clogging
b. Short filter run
c. Gravel displacement of filter media
d. Loss of filter media during back -washing'
e. Recycled filter backwash water in excess of 5 percent
f. Formation of mudballs in filter media.
18. Chlorination Unit:
Yes No 0) a. Sludge buildup in contact chamber
Yes No N/A b. Gas bubbles
Yes No N/A c. Floating scum and/or solids
Yes No .NIA d. Adequate ventilation of chlorine feeding room and storage area
Yes. No N/A e. NIOSH-approved 30 minute air pack
Yes No N/A f. All standing chlorine cylinders chained in place
Yes No N/A g. All personnel trained in the use of chlorine
Yes No N/A h. Proper chlorine feed, storage, and reserve supply.
Yes No
N/A)
19. Ultraviolet radiation disinfection present and in use.
20. Dechlorination:
Yes No N/l a. Proper storage of sulfur dioxide cylinders
Yes No b. Adequate ventilation of sulfur dioxide feeding room
Yes No N/A c. Automatic sulfur dioxide feed or feedback control operating
properly.
21. Aerobic Digester:
Yes e N/A a. Excessive foaming in tank
Yes a) N/A b. Noxious odor
Yes N/A c. Mechanical aeration failure
Yes No IV d. Clogging of diffusers.

Page 4
Yes No
Yes No N/A
Yes No (01
Yes No
Yes No FA)
Yes No ao
Yes No N/A
Yes CEO N/A
es No N/A
Yes No
Yes. No N/A
Yes No N/A
Yes No NIA
Yes No U\
Yes No N/A
. Yes No N/A
• Yes (NO) N/A
Yes �� N/A
No N/A
�P`s No N/A
� No N/A
Ye No N/A
T No N/A
Yes N/A
Yes To N/A
Yes G@ N/A
22. Anaerobic Digester:
a. Floating cover tilting
b. Gas burner operative
23. Sludge Drying and/or disposal:
a. Poor sludge distribution on drying beds
b. Vegetation in drying beds
c. Dry sludge remaining in drying beds
d. Dry sludge stored on site
e. Filtrate from sludge drying beds returned to
f. Sludge disposal through county landfill.
g.. Sludge land applied.
front of plant
24. Filter Press:
a. High level of solids in filtrate from filter presses or vacuum filters
b. Thin filter cake caused by poor dewatering
c. Sludge buildup on belts and/or rollers offilter press
d. Excessive moisture in belt filter press sludge cake.
25. Polishing Ponds or Tanks:
a. Objectionable odor, excessive foam, floating solids, or oil sheens on
water surface
b. Solids or scum accumulations in tank or at side of pond
c. Evidence of bypassed polishing ponds or tanks because of low
capacity.
26. Plant Effluent:
a. Excessive suspended solids, turbidity, foam, grease, scum, color, and
other macroscopic particulate matter present
b. Potential toxicity (dead fish, dead plant at discharge)
c. Outfall discharge line easily accessible.
27. .Flow Measurement: •
a. Proper placement of flow measurement device
b. Flow meter calibrated
c. Buildup of solids in flume or weir
d. Broken or cracked flume or weir
e. Clogged or broken stilling wells
f. Weir plate edge corroded or damaged
g. Flow measurement error less than 10%.

Page 5
28. Sampling:
es No N/A a. Sampling and analysis completed on parameters specified by permit
es' . No N/A r b. Composite sample temperatures maintained at 4 degrees Celsius or
less (but above freezing) during sampling
('e3 No N!A c. Contract laboratory used for sample analysis
es No . N/A d. Effluent composite samples obtained are flow proportional.
RECORDKEEPENG AND REPORTING
es No N/A 1. Records and reports maintained asrequired by permit.
es No N/A 2. All required information available; complete, and current.
YejJ. No N/A 3. Records maintained for 3 years and all sludge records maintained for 5
years.
CreNo N/A 4.. Analytical results consistent with data reported on DMRs.
5. Sampling and analyses data adequate and include:
• es ' No N/A a. Dates, times, and location of sampling
T'ep No N/A b. Name of individual performing Sampling
�es No N/A c. Results of analyses and calibration
i es No N/A d. Dates of analyses
CY:e4 No N/A e. Name of person performing analyses.
6. Monitoring records adequate and include:
Yes No N/A a. Monitoring charts kept for 3 years
Yes) No NIA b. Flowmeter calibration records kept for 3 years.
es o N/A 7. The pH meter is calibrated daily with two buffers arid checked with a
third buffer and properly documented.
e No N/A 8. Expiration dates of pH buffers adequate.
( ) No N/A 9. All thermometers used in NPDES permit reporting is calibrated
annually with an NIST.certified thermometer or a traceable
thermometer annually and documented.
Ces No N/A 10. The following NPDES permit required parameters are analyzed on site:
pH, Temperature, Dissolved Oxygen and Chlorine Residual.

Page 6
Yes) No N/A 11. The NPDES permit required parameter Total Chlorine Residual is
analyzed by approved method.
Yes No N/A . 12. BOD incubator temperature maintained at 20 +/- .1 Degrees Celsius
and the temperature maintained in a log for every day of operation.
Yes No N/A 13. Fecal coliform incubator maintained at 44.5 +/- 0.2 Degree Celsius and
the temperature maintained in a log for every day of operation.
14. Plant records adequate and include:
es No N/A a. 0 & M Manual
es No N/A b. "As -built engineering drawings t vvt� i v11-.t f'q'nc
(Ka No N/A c. Schedules and dates of equipment maintenance repairs
Yes No d. Equipment data cards..
Yes No
15. Perrnittee is meeting compliance schedule.
es No N/A 16. DMRs complete and include all NPDES permit required parameters.
Yes No N/A 17. The facility has.a permitted flow greater than 5 MGD and is required
to operate seven days per week 24 hours a day.
es No N/A 18. ORC visitation logs available and current.
No N/A 19. ORC certified at a level equal to or greater than the classification of
the wastewater facility.
'es�No N/A 20. Backup Operator certified at one level less than the classification of
the wastewater facility or greater.
Yes No N/A 21. Current copy of the complete NPDES permit on site.
e`s No N/A 22. Facility description verified as contained in NPDES permit.
es No N/A 23. Facility analyzes process control parameters for example: l\'LLSS,
MCRT, Settleable Solids and others that are applicable.
Yes No NO 24. Industrial Waste Surveys (1WS)sent to all possible Significant
Industrial Users (SIUs) within the last five years (especially new
industries).
Revised 7/16/01
by Belinda Henson

Belinda S. Henson
DENR
225 Green Street — Suite 714
Fayetteville, N.C. 28301
Dear Belinda:
MONSANTO N
Food • Health • Hope
April 15, 2002
MONSANTO COMPANY
AGRICULTURAL SECTOR
Y.}V. BOX 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROUNA 28302
APR I 6 2002 PHONE [phone]
D r1
An inspection of Monsanto's waste treatment plant and lab was conducted on March 5,
2002. During this visit you made two recommendations. These recommendations are
listed below and followed by the corrective action taken:
1. Oil skimmer leaking in need of repair: Item # 3 Summary of Findings/
Comments;
We are currently looking to replace the existing oil skimmer with another that we
have on plant site. If this skimmer meets the specs and can be used we will have it
installed and the containment area cleaned and disposed of by the end of April. If
this skimmer will not work we will be looking to purchase and install a new one.
If this is the case I will respond with another letter informing you of the date for
completing this project.
2. ORC log not on site: Item # 14 Summary of Findings/ Comments;
At the time of the inspection a log was being keep electronically on Mr. Allbrights
computer. We have now transferred all this data to a hard copy including ORC
time on site, arrival and departure time, back up ORC time on site plus certified
operator time on site.
If I can be of further assistance or any additional information is required do not hesitate to
give me a call.
Sincerely,
M)
Donald R. Allbright
ORC

MONSANTO W
Food • Health • Hope
C: Deb Small
Erin Ahlers
Manhar Patel
Ruth Trotman
Allan Baldwin
Certified Mail # 7099 3220 0001 1361 8938
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROUNA 28302
PHONE [phone]

MONSANTO [II]
Food • Health • Hope
August 21, 2002
Belinda S. Henson
DENR
225 Green Street — Suite 714
Fayetteville, N.C. 28301
Dear Belinda:
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROUNA 28302
PHONE [phone]
An inspection of Monsanto's waste treatment plant and lab was conducted on March 5,
2002. During this visit you made a recommendation to repair the oil skimmer. I
responded with the following statement:
1. Oil skimmer leaking in need of repair: Item # 3 Summary of Findings/
Comments;
We are currently looking to replace the existing oil skimmer with another that we
have on plant site. If this skimmer meets the specs and can be used we will have it
installed and the containment area cleaned and disposed of by the end of April. If
this skimmer will not work we will be looking to purchase and install a new one.
If this is the case I will respond with another letter informing you of the date for
completing this project.
This letter is to inform you that a new oil skimmer has been purchased and installed. The
new oil skimmer was put on line 8-20-02. Diked area was also cleaned. If I can be of
further assistance or any additional information is required do not hesitate to give me a
call [phone].
Sincerely,
" ov.e.9� r1Z
Donald R. Allbright
ORC
Certified No. 7099 3220 0001 1361 5883
cc: Manhar Patel (File)