NC0003719_Biomonitoring Inspection_20010806

North Carolina
Department of Environment and Natural Resources
Division of Water Quality
Fayetteville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr„ Secretary
Gregory J. Thorpe, Ph.D., Acting Director
August 6, 2001
Ms. Deborah R. Small
Plant Manager
Monsanto Company
P.O. Box 2307
Fayetteville, NC 28302
Subject: COMPLIANCE BIOMONITORING INSPECTION
Monsanto Company
NPDES Permit No. NC0003719
Cumberland County
Dear Ms. Small:
ATA
NCDENR
Enclosed you will fmd a copy of the Compliance Biomonitoring Inspection report for the inspection' conducted on
June 27, 2001. The inspection included the same objectives as that of a routine Compliance Evaluation Inspection plus an
Aquatic Toxicity (AT) test to_ evaluate the biological effect of the facility's discharge on test organisms. 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. From June 26 to June 27, a 24-hour composite sample was
collected at the combined outfall box by your facility. This sample was split between DWQ and Monsanto (contracting to
SIMALABS for the aquatic toxicity test) and used in an acute Pimephales promelas pass/fail toxicity test. DWQ's portion
of the split aquatic toxicity sample was sent to the Division of Water Quality Aquatic Toxicology Laboratory (located on
Reedy Creek Road in Raleigh). Each of the split samples Passed the fathead. minnow test, indicating that the effluent
would not be predicted to have water quality impacts on the receiving waters. Additionally, on June 27, the 24-hour
Outfallcombined effluent was also split for chemistry analyses for the following laboratory parameters: Biochemical
Oxygen Demand (BOD), Ammonia as nitrogen, Total Kjeldahl Nitrogen, Nitrite plus Nitrate as nitrogen, and Total
Phosphorus. The laboratory results_ of the pending chemistry analyses will be forwarded to you when they are completed
by the Division of Water Quality Chemistry Laboratory, located on Reedy Creek Road in Raleigh.
As stated in Hope Walters' inspection response letter (dated July 19, 2001), collections to the recommendations
have already been completed. If you have any questions, or comments concerning this report or require clarification on
part(s) of this, report, please feel free to contact me at 910/486-1541.
Dale Lopez . \
Environmental Specialist
DL: dl
Enclosures: FACILITY SITE REVIEW
Inspection response letter from Hope Walters (dated July 19, 2001)
cc: Kevin Bowden, DWQ, ESB, ATU,
Hope Walters, Monsanto, (ORC) .
225 GREEN STREET - SUITE 714 / SYSTEM BUILDING / FAYETTEVILLE, NC 28301-5043
PHONE [phone] FAX [phone] WWW.ENR.STATE.NC.US/EN IL' •
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER- 50% RECYCLED/10% POST CONSUMER PAPER
DENR TOLL FREE HOTLINE: [phone]

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
Inspector: S Facility Type: 2
Facility Evaluation Rating: 4 BI: N QA: N
Section B: Facility Data
Name and Location of Facility Inspected:
Monsanto Company WWTP
Entry Time: 09:00 AM
Exit Time/Date: /010627
Name(s), Title(s) of On -Site Representative(s):
Hope Walters --- (Certified Grade IV) --- "ORC"
Phone Number: [phone]
Name, Title and Address of Responsible Official:
Ms. Deborah R. Small
Plant Manager
Monsanto Company
P.O. Box 2307
Fayetteville, NC 28302
Section C: Areas Evaluated during Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated, N/A = Not Applicable)
Date: 010627
Inspection Type: B
Reserved:
Reserved:
Permit Effective Date: 001201
Permit Expiration Date: 011031
Contacted: No
Permit:
Facility Site Review:
:'Laboratory:
Pretreatment: N/A•
Self -Monitoring Program: S
Sludge Disposal: S
easiirement::
Effluent/Receiving -Waters:..:
omplianceShedule: N/.
Operation & Maintenance: :S::

Ms. Small
Page 3
August 6, 2001
SECTION D: SUMMARY OF FINDINGS/COMMENTS:
Monsanto Wastewater Treatment Plant (WWTP)
BIOMONITORING EVALUTATION INSPECTION
performed during the week of June 27, 2001
BRIEF DESCRIPTION OF THE MVIONSANTO WWTP:
The WWTP has a 1.25 MGD monthly average NPDES permit flow limit. It consists of the
following units:
Two flow equalization standing storage type tanks (each with 650,000.gallon capacity),
spill basin, pH adjustment, two rope oil skimmers, comminuter, two aeration basins (AB)
in series. AB 1 has seven aerators, 6 each with 150 HP and 1 each with 75 HP; AB2 has
five aerators (3 ea. with 75 HP and 2 ea. with 50 HP) and two mixers (75 HP each). One
clarifier (90 feet in diameter and 14 feet deep), one 6-inch Parshall Flume, sludge pump
station, dual aerobic digesters in series. Digester #1 had five'aerators (2 ea. with 40 HP
and 3 ea. with 75 HP). Digester #2 had three 25 HP aerators. Monsanto has a 1-MG
capacity Sludge Storage Basin. Sludge is taken to Land Application in Robeson County
(561.3 acres). Monsanto also has 339 acres in Cumberland County and 188.8 acres in
Bladen County. Monsanto has three bio-solids drying beds, each with 100,000 gallons
capacity, from which the solids can be taken to landfill.
PLANT TOUR---
1. The sample compositor for Plant Outfall 002 was set to sample 100 mL every 15 minutes, and it was
not flow -proportional.
2. Wonderware computer program was used for process control.
3. The Sludge Volume Index (SVI) for AB 1 was 190 mL/mg. The target was 180 to 200 mL/mg.
4. The Food to Microorganisms ratio (F/M) was 0.33.
5. At AB2 the VSS was 5,024 mg/L and the TSS was 5,394 mg/L. The SVI was 188 mL/mg. The
F/M ratio was 0.05.
6. The clarifier, with a 14-feet outer wall depth and a 16-feet cone depth, had a 3.5-feet sludge blanket at
7 AM on 06/27/01.
7. • During October 2001 a project is planned for putting in a new weir at the clarifier and check the rake
arm.
8. There is a torque indicator and alarm for the arm of the clarifier.

Ms. Small
Page 4
August 6, 2001
LABORATORY TOUR---
1. Expiration dates of the 5 gallon carboys of pH buffers:
pH 4 buffer
. June 2002
pH 7 buffer
November 2002
pH 10 buffer
November 2001
2. The pH was measured with a Fischer Accumet AR15. The 7 pH buffer had a mV reading of
-2.4 mV. A three-point calibration was performed daily using the 4, 7, and 10 pH buffers.
The slope was then checked with a different pH 7 buffer (expiration date was February 2003)..
3. The thermometer in the refrigerator is changed once per year using a NIST cross-checked
thermometer.
4. The thermometer used for reporting the Plant Outfall 002 effluent temperatures on the DMRs
has not been cross-checked with an NIST certified thermometer.
5. The Free Chlorine Residual test procedure used by the laboratory did not match with the
DMR Parameter Code of 50060 (Total Residual Chlorine).
6. The March 2001 DMR for Effluent 002 discharge was reviewed. Several of the DMR's
pound -per -day computer calculations, MGD x 8.341bs/gal x mg/L, showed very slight
differences from the calculated values using a hand-held calculator, (the laboratory
parameter's bench sheet mg/L multiplied by the flow values from the DMR multiplied by
8.34 lbs/gal).
RECOMMENDATIONS ---
As stated in Hope Walters' inspection response letter (dated July 19, 2001), corrections to the
recommendations have already been completed.
Name an Signature of Inspector
• Dale Lopez \�
Name and Signature of Review
Paul E. Rawl
Action Taken
Agency/Office/Telephone
NCDENR/Fayetteville/[phone]
Agency/Office/Telephone
NCDENR/Fayetteville/[phone]
Regulatory Office Use Only
Compliance Status
Noncompliance -
Compliance
Date
Date
Date

Ms. Small
Page 5
August 6, 2001
'Yes
Yes
'Yes
Yes
Yes
'Yes
Yes
'Yes
'Yes
Yes
FACILITY SITE REVIEW
No N/A 1 Treatment units properly operated and maintained.
No N/A 2. Standby power or other equivalent provision provided.
No N/A 3. Adequate alarm system for power or equipment failure is available.
4. Sludge disposal procedures appropriate:
No N/A a. Disposal of sludge according to regulations
No N/A b. State approval for sludge disposal received.
No N/A 5. Sufficient sludge disposed of to maintain treatment process equilibrium.
No N/A 6. The ORC and Backup Operator are officially designated with
NCDENR/DWQ Training and Certification Unit.
No N/A 7. Adequate spare parts and supplies inventory maintained.
No N/A 8. Plant has general safety structures such as rails around or covers over
tanks, pits, or wells.
No N/A 9. Plant is generally clean, free from open trash areas.
Yes No
Yes No
Yes No
• Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
izn
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10. Screening:
a. Manual
b. Mechanical
c. Buildup of debris
d. Screenings properly disposed of.
11. Grit Removal:
a. Excessive organic content in the grit chamber
b. Excessive odors
c. Grit properly disposed of.
12. Primary clarifier:
a. Excessive gas bubbles
b. Black and odorous wastewater
c. Poor suspended solids removed
d. Excessive buildup of solids in center well of circular clarifier
e. Weirs level
f. Weir blockage
g. Evidence of short-circuiting
h. Lack of adequate scum removal
i. Excessive floating sludge
j. Broken sludge scraper.

Ms. Small
Page 6
August 6, 2001
13. Trickling Filter:
Yes No N/A `a. Trickling filter pounding (indicating clogged media)
Yes No N/A b. Leak at center column of trickling filter's distribution arms
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 f. Odor
Yes No N/A g. Clogging of trickling filter's distribution arm orifices
Yes No N/A h. Filter flies, worms, or snails.
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes ' No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
14. Activated Sludge Basins/Oxidation Ditches:
N/A a. Dead spots
N/A b. Failure of surface aerators
N/A c. Air rising in clumps
N/A d. Dark foam or bad color
N/A e. Thick billows of white, sudsy foam
N/A f. Air rising unevenly
N/A g. Excessive air leaks in compressed air piping.
15.
N/A
N/A
N/A
N/A
Stabilization Ponds/Lagoons:
a. Excessive weeds including duckweed in stabilization ponds
b. Dead fish or aquatic organisms
c. Buildup of solids around influent pipe
d. Excessive scum is on the surface.
16. Secondary Clarifier:
N/A a. Excessive gas bubbles on surface
N/A . b. Level overflow weirs
N/A c. Weir blockage
N/A d. Evidence of short-circuiting
N/A e. Excessive buildup of solids in center well of circular clarifier
N/A f. Pin floc in overflow
N/A g. Effective scum rake
N/A h. Floating sludge on surface
N/A i. Excessive high sludge blanket
N/A j. Clogged sludge withdrawal ports on secondary clarifier.
N/A
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 backwashing
e. Recycled filter backwash water in excess of 5 percent
f. Formation of mudballs in filter media.

Ms. Small
Page 7
August 6, 2001
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes
Yes
Yes
Yes
Yes
Yes
Yse
No
No
No
No
No
No
No
• Yes No
Yes No
Yes No
Yes No
18.
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Chlorination Unit:
a. Sludge buildup in contact chamber
b. Gas bubbles
c. Floating scum and/or solids
d. Adequate ventilation of chlorine feeding room and storage area
e. NIOSH-approved 30 minute air pack
f. All standing chlorine cylinders chained in place
g. All personnel trained in the use of chlorine
h. Proper chlorine feed, storage, and reserves supply.
19. Ultraviolet radiation disinfection present and in use.
20. Dechlorination:
a. Proper storage of sulfur dioxide cylinders
b. Adequate ventilation of sulfur dioxide feeding room
c. Automatic sulfur dioxide feed or feedback control operating properly.
21. Aerobic Digester:
N/A a. Excessivefoaming in tank
N/A b. Noxious odor
N/A c. Mechanical aeration failure
N/A d. Clogging of diffusers.
N/A
N/A
22. Anaerobic Digester:
a. Floating cover tilting
b. Gas burner operative
23.
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
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 front of plant
f. Sludge disposal through county landfill.
g. Sludge land applied.
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 of filter press
d. Excessive moisture is in belt filter press sludge cake.

Ms. Small
Page 8
August 6, 2001
Yes No
Yes No
Yes No
N/AI
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:
Yes 'No N/A a. Excessive suspended solids, turbidity, foam, grease, scum, color, and
other macroscopic particulate matter present
,N/A b. Potential toxicity (dead fish, dead plant at discharge)
No N/A c. Outfall discharge•line easily accessible.
Yes
Yes
Yes
'Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No N/A
dal
No
No
No
No
No N/A
No
27.
N/A
No N/A
N/A
N/A
N/A
N/A
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%.
28. Sampling:
No N/A a. Sampling and analysis completed on parameters specified by permit
No N/A b. Composite sample temperatures maintained at 4 degrees Celsius or
less (but above freezing) during sampling
c. Contract laboratory used for sample analysis Fecal Coliforms are sent to
MicroBac. OCPSF Parameters are sent to SIMALABS
N/A d. Effluent composite samples obtained are flow proportional.
RECORDICEEPING AND REPORTING:
Yes
'Yes
'Yes
Yes
Yes
Yes
Yes
Yes
Yes
No N/A 1. Records and reports maintained as required by permit.
No N/A 2. All required information is available, complete, and current.
No N/A 3. ` Records maintained for 3 years and all sludge records maintained for 5 years.
No N/A 4. Analytical results consistent with data reported on DMRs.
5. Sampling and analyses data adequate and include:
No N/A a. Dates, times, and location of sampling
No N/A b. Name of individual performing sampling
No N/A c. Results of analyses and calibration
No N/A d. Dates of analyses
No N/A e. Name of person performing analyses.

N/AI
No N/A
Yes No N/A
No N/A
Yes No N/A
Ms. Small
Page 9
August 6, 2001
Yes
Yes
'Yes
(Yes
Yes
Yes
6. Monitoring records adequate and includes:
No N/A a. Monitoring charts kept for 3 years
No N/A b. Flowmeter calibration records kept for 3 years.
No N/A 7.
The pH meter is calibrated daily with two buffers and checked with a third buffer
and properly documented. A three point calibration and checked with another
pH 7 buffer.
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.
No N/A 10. The following NPDES permit required parameters are analyzed on site:
pH, Temperature, Dissolved Oxygen and Chlorine Residual.
Yes N/A 11. The NPDES permit required parameter Total Chlorine Residual is
Yes
analyzed by approved method.
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
Yes
Yes
Yes
Yes
13. Fecal coliform incubator maintained at 44.5 +/- 0.2 Degree Celsius and
the temperature maintained in a log for every day of operation.
Sent to the contract laboratory.
14. Plant records adequate and include:
a. O & M Manual
b. "As -built". engineering drawings
c. Schedules and dates of equipment maintenance repairs
d. Equipment data cards.
No N/A 15. Permittee is meeting compliance schedule.
No N/A 16. DMRs complete and include all NPDES permit required parameters.
Yes Ii o 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.
Yes No N/A 18. ORC visitation logs available and current.
'Yes
Yes
Yes
No N/A 19. ORC certified at a level equal to or greater than the classification of the
wastewater facility.
No N/A 20. Backup Operator certified at one level less than the classification of the
wastewater facility or greater.
No N/A 21. Current copy of the complete NPDES permit is on site.

Ms. Small
Page 10
August 6, 2001
Yes
IYes
No N/A 22. Facility description verified as contained in NPDES permit.
No N/A 23. Facility analyzes process control parameters for example: MLSS, MCRT,
Settleable Solids, and others that are applicable.
Yes No
NIA1
24. Industrial Waste Surveys (IWS) sent to all possible Significant Industrial Users
; (SIUs) within the last five years (especially new industries).
Revised 7/16/01
by Belinda Henson

MONSANTO
Food. Health a Hope
July 19, 2001
Dale Lopez •
DENR
225 Green Street — Suite 714
Fayetteville, N.C. 28301
Dear Dale:
JUL 2 3 2001
nr
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
EDAR CREEK ROAD
AYETTEVILLE,NORTH CAROUNA 28302
HONE (9SO'323-3300
An inspection of Monsanto's waste treatment plant and lab was conducted on June 27,
2001. During this visit you made five recommendations. These recommendations are
listed below and followed by the corrective action taken:
(1) Monthly DMR for March 2001, the sheet that reflects those BOD's that did not
meet the reporting standards are listed by analysis date instead of by composite
sample date (this caused some confusion).
> As per my conversation with Kitty Kramer "on June 28, 2001 it was
determined that no corrective action for this recommendation was needed.
The sheet that reflects those BOD's that did not meet the reporting
standards are listed by analysis date and not by composite sample date
and as such have been dated correctly.
(2) Isco Composite Effluent Sampler needs to be flow proportional instead of
sampling a determined amount of sample -during a set number of minutes.
> Vincent Bryant from Johnston Controls (representing ISCO) installed the
instrumentation on July 5, 2001 to convert the sampler to flow proportional.
See Attachment I as further documentation that demonstrates completion.
(3) Check temperature on Dissolved Oxygen probe against a NIST certified
thermometer.
> On July 2, 2001 a NIST Certified Thermometer was purchased from Fisher.
The temperature on the Dissolved Oxygen probe will be checked against the
NIST Certified Thermometer once per quarter to ensure accuracy. A work
instruction is being added to ensure uniformity. See Attachment II.
(4) Parshall Flume annually calibrated by the ISCO representative to compare
against a staff gauge.
> Vincent Bryant of Johnston Controls (representing ISCO)•performed the
annual calibration check on July 5, 2001. An external contractor will
calibrate the Parshall Flume and flow meter annually and Monsanto's
internal Electrical and Instrumentation group will continue to calibrate
quarterly. Attachment I shows supporting documentation.

� M•
(5) It was discovered during the inspection that Monsanto's Lab interpreted that
when analyzing Residual Chlorine they should use the FreeChlorine Method,
instead of the Total Chlorine Method since it was not specified in the NPDES
Permit.
> The NPDES Permit does not specify Total Residual Chlorine, it just asks
for Residual Chlorine, which was interpreted by the lab as Free Chlorine.
After communicating Mr. Lopez's concerns to the Chief Chemist, it was
decided that the Lab would transition to analyzing residual chlorine
samples by the Total Chlorine Method starting August 1, 2001.
Attachment III is a memo from the Lab stating their intentions to comply
with inspection recommendations.
If I can be of further assistance or any additional information is required do not hesitate
to give me a call. •
Sincerely,
Hope A. Walters
Environmental Operations Specialist
C: Deb Small
Manhar Patel
Ruth Trotman
Allan Baldwin
Donrie Dukes
Certified Mail # 7099. 3220 0001 1361 8549

UPDATE
INSPECTION REPORT
OPTION: TRX: 5IF KEY: NC0003719INSBIO 010627
SYSMSG: ***.DATA ADDED SUCCESSFULLY ***
PERMIT--- NC0003719.
FACILITY-- MONSANTO COMPANY
INS TYPE ..
BIO
INSPECTION
DATE: 010627 .
NEXT -PLANNED' .
INSPECTED BY:
LD
REG/"COUNTY=- 06 CUMBERLAND
LOC--•FAYETTEVILLE
REPORT. INSPECTION .DMR RESPONSE RECEIVED,,
DATE STATUS . • :STATUS, DUE DATE ' DATE •
010806 C - C
COMMENTS:

(3)
Dale Lopez
DENR
225 Green Street — Suite 714
Fayetteville, N.C. 28301
Dear Dale:
MONSANTO W
Food • Health • Hope
July 19, 2001
i
DER -FRO
JUL 2 3 2001
DWQ
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
AYETTEVILLE, NORTH CAROLINA 28302
HONE (910)32_3-33o0
An inspection of Monsanto's waste treatment plant and lab was conducted on June 27,
2001. During this visit you made five recommendations. These recommendations are
listed below and followed by the corrective action taken:
(1) Monthly DMR for March 2001, the sheet that reflects those BOD's that did not
meet the reporting standards are listed by analysis date instead of by composite
sample date (this caused some confusion).
> As per my conversation with Kitty Kramer on June 28, 2001 it was
determined that no corrective action for this recommendation was needed.
The sheet that reflects those BOD's that did not meet the reporting
standards are listed by analysis date and not by composite sample date
and as such have been dated correctly.
(2) Isco Composite Effluent Sampler needs to be flow proportional instead of
sampling a determined amount of sample during a set number of minutes.
> Vincent Bryant from Johnston Controls (representing ISCO) installed the
instrumentation on July 5, 2001 to convert the sampler to flow proportional.
See Attachment I as further documentation that demonstrates completion.
Check temperature on Dissolved Oxygen probe against a NIST certified
thermometer.
> On July 2, 2001 a NIST Certified Thermometer was purchased from Fisher.
The temperature on the Dissolved Oxygen probe will be checked against the
NIST Certified Thermometer once per quarter to ensure accuracy. A work
instruction is being added to ensure uniformity. See Attachment II.
(4) Parshall Flume annually calibrated by the ISCO representative to compare
against a staff gauge.
> Vincent Bryant of Johnston Controls (representing ISCO) performed the
annual calibration check on July 5, 2001. An external contractor will
calibrate the Parshall Flume and flow meter annually and Monsanto's
internal Electrical and Instrumentation group will continue to calibrate
quarterly. Attachment I shows supporting documentation.

(5)
It was discovered during the inspection that Monsanto's Lab interpreted that
when analyzing Residual Chlorine they should use the Free Chlorine Method,
instead of the Total Chlorine Method since it was not specified in the NPDES
Permit.
> The NPDES Permit does not specify Total Residual Chlorine, it just asks
for Residual Chlorine, which was interpreted by the lab as Free Chlorine.
After communicating Mr. Lopez's concerns to the Chief Chemist, it was
decided that the Lab would transition to analyzing residual chlorine
samples by the Total Chlorine Method starting August 1, 2001.
Attachment III is a memo from the Lab stating their intentions to comply
with inspection recommendations.
If I can be of further assistance or any additional information is required do not hesitate
to give me a call. _
Sincerely,
Hope A. Walters
Environmental Operations Specialist
C: Deb Small
Manhar Patel
Ruth Trotman
Allan Baldwin
Donrie Dukes
Certified Mail # 7099 3220 0001 1361 8549

Attachment I

JOHNSTON, INC. Website: www.jinc.com
132 CORPORATE BOULEVARD / P.O. BOX 580 / INDIAN TRAIL, NORTH CAROLINA 28079
TOLL FREE 800-947-0852 / LOCAL 704-821-6777 / FAX [phone]
July 18, 2001
Mrs. Hope Walters
MONSANTO
PO Box 2307
Fayetteville, NC 28302
Dear Mrs. Walters:
It was my pleasure to speak with you concerning your current environmental monitoring
needs. In accordance to your request I have provided a letter detailing the work I performed
at your" facility on July 5, 2001.
I calibrated the Fisher -Porter Flow Meter installed at your effluent location.. This flow meter
is paired with a Parshall flume. This meter is functioning properly. I also set your ISCO
3710FR Sampler to collect flow proportional samples. This was accomplished by connecting
a 4-20 mA input device to the sampler and getting my flow signal from the 4-20mA output
of the flow meter. All the equipment was functioning properly upon completion.
If I may be of assistance in any manner, please feel free to give me a call at my Clinton office
[phone].
Regards,
JOHNSTON, INC.
\I; 60-,Ri-1< 04-
Vincent K. Bryant
Technical Sales Associate
VKB:dg
FIELD OFFICES: CLINTON, NC • CHARLESTON, SC • LYNCHBURG, VA

Attachment II

' REMIT TO: INQUIRE AT: •" [phone]
F• ACCT# 553184-001 3970 JOHNS CREEK COURT
isher -_ P.O BOX. 360153 .SUWANEE GA
S• is• PITTSBURGH PA 30024
CIenIIIIC -15250-6153
D-U-N-S-00-432-1519
FEIN 23-2942737
ORIGINAL INVOICE
'
PLEASE REFER TO THIS INVOICE •
NUMBER ON YOUR REMITTANCE
2292849
CUSTOMER PURCHASE ORDER NUMBER - RELEASE NUMBER
HOPE/MC/070201
INV. DATE
07/02/2001
ORDER NO. `
A11838749 - - .
- ACCOUNT NO.
- 553184-001
CSO
ATL
F.O.B.
SHIPPING POINT
ORDER ENTRY DATE
07/02/2001
PAGE
1
DUPLICATE
SOLD TO: - SHIP TO: INVOIC_ E TYPE:.
NOR PSD - CON
HOPE A. WALTERS HOPE WALTERS
MONSANTO INC " MONSANTO NORTH CAROLINA mosA
ACCOUNTS PAYABLE - CEDAR CREEK RD • wawa.
s� z"
PO BOX 23.07 - FAYETTEVILLE NC 28302 _ - DUE: 08/01/2001
FAYETTEVILLE NC 28302 TERMS: NET 30 DAYS FROM INVOICE DATE.
_ " - PAYABLE IN U.S. CURRENCY.
' Visit the Fisher Web Site: W W W.FISHERSCI.COM
DESCRIPTION
CATALOG
NUMBER
QUANTITY
SHIPPED
UNIT PRICE
AMOUNT
-
CALLER -HOPE WALTERS
PHONE-910-433-4237
CREDIT CARD TRANSACTION
-- DO. NOT PROCESS
FROM: SED ON
W/CRT..
AN ASTERISK HAS
CONTACT YOUR CUSTOMER
ABOVE 'AND IWCLUDE
-
FOR PAYMENT
07/02/2001
15 041E *
BEEN PLACED BY THOSE ITEMS
SERVICE REPRESENTATIVE
DEPT. NBR.
"
1 EA
FOR WHICH MSDS(S)
IF ADDITIONAL
279.63
WILL HE PROVIDED
INFORMATION
279.63
279.63
NEEDED.
'•
,
- SHIPMENT NBR: 001
THERMOMTR-1TO+101C 1/10
TOTAL INVOICE AMOUNT
(*) FOR YOUR REFERENCE,
UNDER SEPARATE. COVER.
PLEASE USE REMIT TO ADDRESS
I
SEE REVERSE SIDE -FOR ADDITIONAL TERMS AND CONDITIONS
PAST DUE BALANCES ARE SUBJECT TO "A FINANCE CHARGE. THIS SHIPMENT WAS DELIVERED IN PERFECT CONDITION AND SIGNED FOR
BY THE TRANSPORTATION COMPANY. CONSIGNORS RESPONSIBILITY CEASES UPON DELIVERY OF GOODS TO CARRIER. DO NOT
ACCEPT SHIPMENT SHOWING EVIDENCE OF DAMAGE OR SHORTAGE UNTIL AGENT OF CARRIER ENDORSES NOTATION TOTHIS,EFFECT
ON FACE OF TRANSPORTATION RECEIPT. WITHOUT THIS DOCUMENTARY EVIDENCE CLAIM CANNOT BE FILED. SELLER CERTIFIES THAT
ALL GOODS (OR SERVICES) COVERED BY THIS INVOICE WERE PRODUCED IN COMPLIANCE W FH ALL APPLICABLE REQUIREMENTS OF
SECTIONS 6, 7, AND 12 OF THE FAIR LABOR STANDARDS ACTS OF 1938, AS AMENDED, AND OF THE REGULATIONS AND OI JERS OF THE
UNITED STATES DEPARTMENT OF LABOR ISSUED UNDER SECTION 14 THEREOF.
NO CREDIT WILL BE ALLOWED FOR MERCHANDISE RETURNED WITHOUT PRIOR AUTHORIZATION. .
-
-
-
THE PRICES SHOWN ON THIS INVOICE ARE NET OF DISCOUNTS PROVIDED AT THE TIME OF PURCHASE. SOME PRODUCTS MAY BE
SUBJECT TO ADDITIONAL DISCOUNTS AGREED UPON BETWEEN THE PARTIES. SEE REVERSE SIDE FOR DISCOUNT OR PRICE
REDUCTION DISCLOSURE REQUIREMENTS. -.
•

Ever Ready Thermometer Co., Inc.
E4 /' t 228 Lackawanna Avenue
c , � ,. West Paterson, NJ 07424
AA�oY [phone] FAX [phone] http://www.ertco.com
Thermoter Cali • rat
n
e rt
This is to certify that the instrument described below has been examined and tested in our calibration laboratory using accurately controlled
constant temperature equipment; using NIST calibrated primary reference thermometers, in accordance with ISO/EC Guide 25, which is
based in part on ASTM E-77-92, "Standard Test Method For Calibration And Verification Of Liquid In Glass Thermometers" and NIST
Special Publication 250-23, "Liquid In Glass Thermometer Calibration Services". This calibration meets the requirements of ISO/EC Guide
25, ANSI/NCSLZ540-1-1994, the ISO 9000/QS 9000 Series OF Quality Standards, and MIL STD 45662A (ISO 10012-1).
Customer Information
FISH SCfi{�-
POBOX 53570
PITTSBURGP
Purchase Order:
Instrument Description
Serial Number. '3117
Inscription: ERT
Date Completed: 96/07/2QP.a „ Immersion: TOTAL.IMM
Product Number. 005-FC - . Scale Range: 1 TP-VM,:til Scale Divisions:
Results of Physical Examination
This instrument has been examined under a microscope for strains in the glass, if any, were judged to be minimal and of no detriment to
the functionality of the instrument.
The capillary of this thermometer has been examined under magnification and no foreign material, moisture, or other evidence of
contamination were discovered. No discernible capillary irregularities were noted.
It has been determined that the instrument is in good working order and is therefore suitable for calibration.
Calibration Results
Test Temoerature Reading Of This Instrument Correction Emeraent Column d eemrerature Standard Uncertainty
0.00 C 0.00 C 0.00 C NA .01
10.000 10.000 0.000 NA .04
20.00 C 20.00 C 0.00 C NA, .04
30.00 C 30.00 C 0.00 C NA .04
37.00 C 37.00 C 0.00 C NA .04
40.00 C 40.00 C 0.00 C NA .04
50.00 C 50.00 C 0.00 C NA .04
56.00 C 56.00 C 0.00 C NA .04
60.00 C 60.00 C 0.00 C NA .04
70.00C 70.000 0.000 NA .04
80.000 79.98C 0.02C NA .04
90.00 C 90.00 C 0.00 C NA .04
100.00 C 100.00 C 0.00 C NA .07
Page 1 of 2
This certificate may not be reproduced in full or in part without the written approval of
Ever Ready Thermometer Company, Inc.

The above readings Were made under magnification and resolved to the nearest .01 C.The uncertainties of our calibration system are as follows: From -85 to -
45C, +/- .12C; From -40 to <OC, +/-.06C; At OC, +/- .01 C; From >0C to 100C, +/- .04C; From >100 to 200C, +/- .07C; From >200 to 300C, +/- .13C; From
>300 to 400C, +/- .2C. The estimated uncertainties quoted above were determined in accordance with the guidelines given in NIST Publication IR 5341 and
take into account the type of thermometer tested, the precision with which its reading can be resolved, and the degree of confidence one can have in its
indications under similar conditions of usage.
For further discussion of accuracies attainable with such thermometers, see MST Special Publication 250-23 and NIST Publication IR 5341.
Laboratory Environmental Conditions: Temperature 23C +/- 2C (73F +/- 2F). Relative Humidity - Between 30% and 60%. All temperatures
in this report are based on the International Temperature Scale of 1990 (ITS-90).
**IMPORTANT NOTE: The readings and corrections noted above apply forthe
condition of 22 Degreession indicated
(73F), provided that the ice If
point reading, taken after exposure for not fewer than three days to a tempthe same amount.
the ice point reading is found to be higher (or lower) than stated, all other readings will be higher (lower) by
The calibration performed and documented by this report of test is a full scale calibration and no limitations of use are imposed on this
instrument.
Traceability Information
The NIST Primary Reference Thermometers and Transfer Standards used in this test are given below:
Test Point 0: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 10: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 20: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 30: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point 37: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point 40: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 50: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 56: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 60: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 70: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 80: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 90: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 172
Test Point: 100: C NIST Reference Themometer Standard 128239 Transfer Standard Serial # 174
This Calibration is directly traceable to NIST.
If additional information regarding this calibration is required, please contact this laboratory.
ri
Clifton Thomas
Quality Control Manager
Batch Number: 169654
Suggested Calibration Due Date: 06/07/2002
Page 2 of 2
IThis certificate may not be reproduced in full or in part without the written approval of
Fver Ready Thermometer Company, Inc.

WASTE TREOPIPIT AREA -WORK IN$TRIXT1(04
APPROVALS:
VOA 1.28
REVISION NO: 0
ISSUE DATE: July 31 2001'
AUTHOR: Allan Baldwin
TITLE: Quarterly D.D. Meter temperature Verinartion
STANDARDIZATION METHOD:
1. Fill a 1000trd beaker with tap water.
2 Place 1000m1 beaker of water On stirrer with large stir bar and turn on stirrer.'
3. Place the probe of the D.O. Meter to- be checked into the water.
4. Place N1STtraCeable thermometer in the water.
5. Allow probe and thennometer to sit in the stiring water for 5 mins.
6. Record Temp. of meter and the thermometer quarterly in the op. meter calibration log
book.
7. Metter reading and thermometer reading must be within plus or minus 10%: if outside of
this range meter must be immediately removed from service and shipped back to YS1
for recertification.
8. Meters wiH be certified annually for Temp. by YS1.

Attachment III

MONSANTO
Food • Health • Hope"
From Curt West
(Name -Location -Phone)
Date : July 2, 2001
Subject : Chlorine Analysis
Reference : June 2001 State Inspection
TO : Hope Walters
cc:
This memo is in response to the question raised by Dale Lopez during the state inspection on June 27, 2001,
regarding the chlorine analysis method being utilized at the Fayetteville Plant. The Fayetteville Plant's permit
states residual chlorine and that has been interpreted as meaning free chlorine, therefore the residual chlorine
method is the analysis that is performed. Dale Lopez's interpretation is that total chlorine is the method that
should be performed. The Fayetteville Plant is in the process of obtaining a new permit. The new permit will
state total chlorine. The Fayetteville Plant will transition to performing chlorine analyses by the total chlorine
method by August 1, 2001.

v �.
Dale Lopez
DENR
225 Green Street — Suite 714
Fayetteville, N.C. 28301
Dear Dale:
MONSANTO
Food • Health • Hope
August 8, 2001
DENR F
UG • 9 2001
DQ
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROUNA 28302
PHONE (9I01323-3300
An inspection of Monsanto's waste treatment plant and lab was conducted on June 27,
2001. During this visit you made five recommendations. On July 19, 2001 I sent in a
letter listing the recommendations followed by the corrective action taken. The only
issue that the letter did not resolve was the rounding problem found on the monthly DMR
reports. Attached you will find a letter from Monsanto's I.T. Depai ttiient stating what
was causing the problem and how it was resolved. The June 2001 DMR reflected the
change made and all computer calculations matched hand calculations, so the problem
has been resolved.
If I can be of further assistance or any additional information is required do not hesitate
to give me a call.
Hope A. Walters
Environmental Operations Specialist
C: Deb Small
Manhar Patel
Ruth Trotman
Allan Baldwin
Donrie Dukes
Certified Mail # 7099 3220 0001 1361 8624

MONSANTO
Food • Health • Hope"
From Mike Herholz
Date : August 7, 2001
Subject : Water Report
Reference : Calculation Discrepancy
TO : Hope Walters
cc:
The calculation results displayed on the water report were different than those calculated manually
because of significant digits that were not displayed. For example, on a hypothetical day lets say that
the effluent flow reading was 781,056 gallons. This value is divided by 1000000 to produce MGD.
The result is 0.781056. This value is displayed on the report to 3 significant digits, or 0.781.
Assuming the COD result for this hypothetical day is 408 ppm, the report calculation result is a value
of 2,657.5 Ibs/day. The values that are on the report are automatically calculated by Microsoft Excel
which was using all of thesignificant digits, not just those displayed. Excel would produce a value of
2,657.7 lbs/day for our hypothetical day.
To eliminate the discrepancy, I have configured Excel to use only the significant digits that are
displayed on the report. This should result is the same values regardless of whether the calculation is
performed manually or by Excel.
Please let me know if I can be of further assistance.