NC0001899_staff comments_19931011

MEMORANDUM
North Carolina Division of Environmental Management
Water Quality Section/Rapid Assessment Group
October 11, 1993
TO: Greg Nizich
THROUGH: Carla Sanderson4
C1
FROM: Dave Goodrich
SUBJECT: Response to Comments for Allied Signal Draft NPDES Permit
NPDES No. NC0001899
Chatham County
030607
This is in response to Allied Signal's questions regarding the draft NPDES permit
referenced above. I assume Betsy Johnson also sent her comments to you regarding these points.
She asked me to comment on only the questions regarding OCPSF parameters and their
monitoring.
The permittee wants to know what form should be used to report mass calculations of
OCPSF parameters. In the past, the laboratory reporting form has been adequate for documenting
results of organic sampling. If Allied Signal would supplement that form with a one or two -page
attachment showing mass calculation (including the flow used to calculate mass), that would
suffice.
The assumption that "a monthly average would be calculated only when two or more
sample events are conducted within the same month" is basically correct. However, quarterly
sampling in this case may be representative of a monthly average in terms of compliance.
There is no objection to adding a condition to the permit which states that any laboratory
results which document non -detectable levels of an OCPSF parameter will be considered to be zero
for purposes of compliance. I am not sure that is necessary, however. I had thought that such a
clause was already found in the boilerplate language of NPDES permits.
Allied Signal has requested that EPA Methods 624 and 625 be specified in the NPDES
permit. Methods 601 and 602 may be more appropriate to use since they often result in lower
limits of analytical detection. Again, I thought this was addressed in boilerplate language.
cc: Betsy Johnson

e:4-5is `- 'ee I c; S4
Comment'
6rec�
'AIL' iIOR A`lDUMM4
vi s;U1 I,1' 1 v1eii i.a.ia
3eptemc . :6.
To: Greg Nizich
prom: Larry Ausley
Subject: Review of draft permit comments, Allied Signal Inc., Allied Fibers
NCC001399 Chatham County
The Aquatic Toxicology Unit has reviewed the subject permit and has the following comments on the
issues/questions raised by the facility, relative to whole effluent toxicity monitoring:
Part 1, Sec -ion B, Schedule of Compliance
Should the permit become effective between October and December 1993, the first acute toxicity test for
pipe 001 would be expected for January, 1994.
For pipe 002, should the facility be able to sample its first five discrete discharge events within the 1992
calendar year, annual testing should begin in 1994.
Outfall 001
Part II, Section D, Representative Sampling
The acute toxicity sample may be collected from the discharge pipe to the Haw River.
Part 11, Section D, Reporting
Toxicity information reported on the MR-1 form for pipe 001 should include the parameter code
TAA3D if Daphnia pulex is used as the test organism and TAA3B if Ceriodaphnia dubia is used as the
test organism and the test result (LC50).
Part III, Section E, Acute Toxicity Permit Limit
The toxicity limitation for pipe 001 should read 90% throughout the permit to agree with permitting
policy being modified during development of the permit (i.e. maximum limits of 90% effluent). The
permittee has the option of performing the analysis with Daphnia pulex or Ceriodaphnia dubia though
the appropriate parameter code should be reported on the MR-1.
cc:Tim Donnelly
Central Files
attachment
Environmental Sciences Branch Water Quality Section

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
To:
From:
Subject:
September 15 1993
Betsy Johnson
Instream Assessment Unit
Greg Nizich
Permits and Engineering
Allied Signal Draft Comments
Permit # NC0001899
Chatham County
Please comment on the attached letter regarding the draft permit for the subject facility.
Please advise if additional information is required.
Enclosure
cc: Instream Assessment Unit

09/14/93 11:33
01
%cril a i FIBERS DIVISION - MONCURE PLANT
MaiUng Address:
F.O. BOX 166, MONCURE, NORTH CAROLINA 27559
Shipping Address;
PEA RIDE ROAD, MONCURE, NORTH CAROLINA 27559
FAX COVER SHEET
TO: t
FROM: i3;
DATE: V/9/93 TIME: ill ,S m l p.m.
RECEIVER'S FACSIMILE NUMBER: 73 z I
NUMBER OF PAGES:(including the cover sheet)
COMMENTS:
If all pages are not transmitted legibly,
please lel us know as soon as possible.
FACSIMILE OPERATOR:
Allied Fibers Facsimile Numbers:
Administration (Main) Purchasing Quality Control Technical
[phone] [phone] [phone] [phone]
Allied Fibers Telephone Number: [phone]
M688SB•18

09/14/93 11:34
02
AlliedFibers
Allisd•6IQnsi Inc,
Fibers Division
P.Q. Box 106
Monoura, NG 27659
Telephone [phone]
racalfiluG [phone]
September 14, 1993
Ms. Coleen H. Sullins, Supervisor
NPDES Permits & Engineering
North Carolina Department of Environment,
Health and Nature], Resources
Division of Environmental Management
P. O. Box 27687
Raleigh, North caroling 27611-7687
RE: Draft Permit
NPDES Permit #Nc0001899
Allied5ignal FIBERS
Dear Ms. Sullins:
Signal
A11iedSi na1 appreciates ppx'aciates your reapanse to its comments regarding the preliminary
"draft" permit and the resulting changes that were made in the draft permit.
After careful review of the August, 1993 draft permit there are still several
questions about the monitoring and reporting requirements.
�hTPDES DRAFT PERMIT, PART I, SECTION B, SCHEDULE OF COMPLIANCE
o Clarification is requested on the date when effluent sampling ie to begin.
The draft permit states that the permittee shall comply with Final Effluent
Limitations specified for discharge by the effective date of the permit,
which was specified in the Public Notice as September 30. 1993. Does this
mean that monitoring required by this permit is to begin on October 1,
1993? If so, Allied requests an additional 30 days to finalize
arrangements with contract labs for parameter testing.
Part III Section E. states that the first acute toxicity teat is to be
performed after thirty days from the affective date of the permit. Allied
understands that the first acute toxicity test for outfall 001 will be
required in January, 1994.
Acute toxicity monitoring for outfall 002 is to be conducted during the
first five discrete discharge events after the effective date of the
permit. Assuming the effective date ie October and all five tests are
conducted between October and December and no toxicity is observed, does
the annual test requirement begin in January, 1994?
0UTP'ALL 001
NPDES DRAFT PERMIT, PART II, SECTION D, MONITORING AND RECORDS
o Representative Sampling
This is to Confirm that all composite and grab samples for testing at
outfall 001 will be collected at the effluent V-notch weir with the
exception of chloroform, which will be collected above the chlorine contact
chamber and acute toxicity samples, which will be collected from the
discharge pipe to the Haw River.
oti-t,3
1 1

09/14/93 11:34
03
COMMENTS ON OUTFALL 001
NPtES DRAFT PERMIT, PART II, $ECTION p, MONITORING AND RECORDS
Q Item 2. hevoLLtag
(It is underetocd that DEM Form MR-1 is to be used to record conventional/
nonconventional pollutant testing results along with flow and sampling
jS information and DEM Farm AT-1 is to be used for reporting Acute Toxicity
results. In addition, Part III of the draft permit states that all toxicity
i testing results should also be entered on the Form MR-1 for the month in
which the testing was performed. Guidance is requested on the type of
information that is to be reported on Form MR-1.
A DEM reporting form was not ,identified for reporting quarterly OCPSF
testing results. Perhaps the contract laboratory's report may be acceptable
for reporting purposes since it typically includes the date analyzed,
compound, test method, quantitation limit and results concentration. What
form is to be used for reporting mass calculations?
Since the measurement frequency for OCPSF compound sampling to quarterly,
assumed that a monthly average would be calculated only when two or
more sample events are conducted within the same month. when calculating
a monthly average, any number preceded by less than (‹) will be averaged
as zero.
o Item 4. Test Procedure$
AlliedSignal is still concerned about the OCPSF quarterly pollutant
analysis and the test procedures required to demonstrate compliance
with extremely low permit limitations. Allied's goal ie to ensure that
meaningful analytical results are received using sound EPA approved
analytical methods to identify pollutants with a high degree of certainty
rather than using methods that give low limits of detection with the
possibility of interferences. The use of analytical methods solely to
achieve low limits of detection can lead to results that can be easily
misinterpreted as the wrong amount of the wrong compound.
The OCPSF guidelines are used to propose mass limitations on outfall 001
using "procesa waste water flows" which comprise only a portion of the
total outfall flow. The extremely low parts per billion OCPSF limits result
in very low allowable mass limits being imposed on outfall 001 - in moat
situations less than 0.018 lba/day Daily Max. On average OCPSF process
flows comprise only 10% of the total flow in 001 and storm water events
cause additional dilution.
The low concentrations imposed by the guidelines combined with additional
non-OCPSF proceee flows will result in situations where the detection limit
of EPA approved analytical protocols will not be sufficiently low enough
to verify that a particular pollutant ie in compliance with the permit
limits. For example, if total discharge flows are 0.80 MGD a typical non -
detectable analytical result using GC/MS will indicate that a pollutant was
not detectable at a detection level of 10 ppb, With these results the masa
loading for the pollutant could only be reported ae leas than 0.068
lbs/day. Numerous daily maximum allowable loadings imposed in the draft
permit are lower than this value,
To address situations such as these, AlliedSignal requests that an
additional condition be put in the permit which states that when an
approved analytical, protocol is followed and a non -detectable or below
quantitation limit is obtained, the result will be considered to be in
compliance with the numerical permit limit for that pollutant.

09/14/93 11:35
04
0 Item 4. Test Procedures (continued)
To ensure that organic parameters are identified with a high degree
of certainty, hlliedSignal requests that EPA methods #624 and #625 that use
GC/MS for analysis be specified in the permit for OCPSF parameters.
The limits of detection for GC/MS methods on the Attachment 1 were provided
by Allied's contract laboratory. Deviations from the specified detection
limit for an EPA approved method due to a matrix interference would be
indicated on the lab's analytical report and on the monthly DMR.
NPDES DRAFT PERMIT, PART III, SECTION E, ACUTE TOXICITY PERMIT LIMIT
o There appears to be some inconsistencies between the condition's in Part
III, Section E and the conditional described on the Effluent Limitations And
Monitoring Requirements page. Specifically, Section E. allows the choice
of using either Daphnia puler or Ceriodaphnia for the teat and indicates
that the LC50 of the effluent may at no time be less than 94%. The Effluent
Limitations and Monitoring for outfali 001 indicates in parentheses that
Daphnid 48 hr should be used for acute toxicity and the LC50 of the
effluent should be 90%. Does Daphnid refer to the use of either species?
Please advise of 94% vs. 90% apparent inconsistency.
Thank you for your consideration of these comments. If you have any questions,
please call me at [phone].
Sincerely,
74",
W. L. Bbyer, Stervisor
Environmental & Industrial Hygiene
Attachment
Cc:
R, G. Ferree
P. A. McCaig
A. T. Roy
J. E. Williamson
3

09/14/93 11:36
05
ATTACH r 1
14'7ZX U1 7JT CfARACTERIBTICH MTNIXUX ANALYTICAL LSVHL (u41.11
Acenaphthene 10
Acrylonitrile 100
Benzene 5
carbon Tetrachloride 5
Chl orobens;ene 5
1,2,4-Trlchlorobenzene 10
Hexachlorobenzene 10
2,2-Dichloroethane 5
1,1,1-Trichloroethane 5
Hexachloroethane 10
1,1-Dichloroethane 5
1,112-Trichloraethane 5
chloroathatne 10
chloroform 5
2-Chlorophenol 10
1,2-D.ichlorobensene 5
1,3-Dichlorobenrene 5
1,4-Dichlorobenzene 5
1,1-Dichl0roethylene 5
1,2-trans-Di.chloroethylene 5
2,4-Dirhlorophenol 10
1,2-piahloropropane 5
• 1,3-Dichloropropy1ene 5
2,4-Dimethylphenol 10
2,4-Dinitrotaluene 10
2, d-D.1nitratoluens 10
Bthylbenzene 5
Fluoranthene 10
Methylene Chloride 5
Methyl Chloride 5
Nexachlorobutadione 70
Naphthalene 10
Nitrobenzene i0
2-Nitrophenol 10,
4-Nitrophenol 50
2,4-Dinitropheno1 50
4,6-Dinitro-o-creso1 50
Phenol 10
Bis(2-ethylhexyl)phthalate S0
Din-n-butyl phthalate 10
Diethyl phthalate 10
Dimethyl phthalate 10
aenza(a)anthracene** I0
Benzb(a)pyrene** 10
3,4-Bentofluoranthene** 10
Denzo(k)t'luoranthene** 10
Chrymen e * * _ 10
Acenaphthylene 10
Anthrecene 10
Pluorena 10
Phenanthrene 10
Pyrene 10
Tetrachloroethylene 5
Toluene 5
Trichloroethylone 5
Vinyl Chloride 10
Total PMI's** 10
** TotaI PAH's (Palynuclear Aromatic Hydrocarbons) are comprised of:
Senzo(a)anthracenelBeneo(a)pyrene:3,4-Bonzofluoranthene;Benzo(k)fluoranthene,
Chrysene,D2benz (a,h) anthracene and Indeno (1,2,3-cd) pyrene,
WLB:wgh9/13/93

PA-
Spanceac1 -b
41iie d fee. — c Gv &cow, �.•'t_� ? e‘ �(LS!-'� Apr ✓t.t
coD_
5 195 rC._
c�. __situult toe u 5k?.40 - .61.4c. Sf .4- .,
.}-- UC
! `r:.ir..c_ AC 5 LA,- v k : SGt.-S S" Uvt' i [n_ 1ZA
1L.r-ev —. `%--.-.LC
tsie -..1 ak1- 4t —
'HALLw
C 4 _,_0vbU5
e.cJ yr Sa
/s/
2-�..jt.--
Mesh.
7
Sc. 1.Y..5 E . C va. (,A..1. c45 c. &fit `^J1 Q P5f.: : c�
cl,�cccvliy mo,_e�
W (l re vet 4 -
de, cc' •u,.
}‘iQ ~S
rvtccam,l.��C�/; hem — o. 7 Nb
1 k_ alk. w 5

Z --
liiee gbe ss
(�J �;.(�►-e rl / Polio AI alkt 5 45
vv u. I Cu ') 7-,n „a.av,A
53Gv o
6 u s e-�-ect
PVbCO5 (-(o 00
t
kiko
---s> 76Qc - ' & oc 3cal"44 /4ital
13.0D KN • - .
ftv-N crC S'w t,Us ekce S p
SCnuvIcl `pQ re —a u.w- % 0
cunsli> C.;.,S...vl t- 1"9' ..
\c..rt- 47 oyAh ,l
f d a s4- cke }-eck; a,L Le rei (fq cPre l`3 4.
"re.Ave vre--
(Jl S re.1 cam.. -et. 4Ov'",et K9..
Lj n i Jori c�A v t a QYare-`t LA, 1 1 c W �/jp S
5u vyAl i'= d`4C r 0Zt`rvu c — c 5 6JU
.ESE s¢d.-c clka., k, a e.w

MEMORANDUM
To: Ruth Swanek
Through: Jay Sauber
From: Howard Bryant
Subject: Long-term BOD
North Carolina Division of Environmental Management
Water Quality Section / Intensive Survey Group
June 28, 1993
Analysis forAllied Signal, Fiber Division (001)
County: Chatham
NPDES # NC0001899
Receiving Stream: Haw River
Sub -basin: 030607
DAY BOD NH3-N
0
5
10
15
20
25
30
35
40
50
60
70
80
90
100
110
120
140
1.47
2.57
3.28
4.80
5.38
6.08
7.03
7.39
8.11
8.66
9.14
9.42
9.75
10.23
10.57
10.84
11.42
Date Collected: January 26, 1993
1300-1300
cc: Central Files
Regional Water Quality Supervisor
0.06
0.06
0.14
0.16
0.20
TKN-N
3.2
3.0
0.7
3:4
2.3
NOX-N TN-N
6.90
5.40
6.80
5.80
5.80
10.1
8.4
7.5
9.2
8.1
0.17 1.0 5.90 6.9
0.01
0.06
0.05
0.5 5.50 6.0
0.7 6.20 6.9
4.0 6.60 10.6
Collected by: Rowe Test evaluation: excellent
pH: 7.4 Seeded: seeded

DIVISION OF ENVIRONMENTAL MANAGEMENT
RALEIGH REGIONAL OFFICE
MEMORANDUM
TO:
THROUGH!
FROM:
SUBJECT:
February 22, 1993
Greg Nizich
Tim Donnelly
Judy Garrett C`
Staff Report
Allied-Signal Inc., NC0001899
Chatham County
Staff of the Raleigh Regional Office have reviewed the
letter from W.L. Boyer, Environmental and Industrial Hygiene
Supervisor with Allied-Signal Inc. and offer the following
responses to Mr. Boyer's comments:
1) COD- This comment should be addressed by the Technical
Support Branch. .The wasteload indicates that this limit is
f'Q' derived from the OCPSF regulation.• ••
2) Instream monitoring- For the reasons given by the
Company and because the discharge comprises less than 1
percent of the stream flow, we recommend eliminating the.
stream monitoring for D.O., Conductivity and Temperature for
discharge 001.
3) Acute Toxicity -The company is correct. The Acute Toxicity
sample does not have to be taken on the same day as other
composites.
4) pH- We have no objection to requiring continuous pH
monitoring in the permit as requested by the permittee. The
permit boiler plate should then contain language addressing
the allowed pH excursions contained in 40 CFR 401.17.
vj 5) Radioactivity- This comment should be addressed by the
� 1
Technical Services Branch.
6) Quarterly Pollutant Analysis-
Metals- We have no objection to removing the quarterly
metals requirements if the limits were not based on

Memo to Greg Nizich from Judy Garrett RE: Allied Fibers
Page 2
historical data and if the technical services branch
concurs.
Regulated wastestream volume- it appears that the
wasteload should be reevaluated using 8,000 gpd of
wastewater from the process.
Chloroform- regardless of the source of the chloroform,
we feel these limits should remain. This parameter could
be limited based on water quality criteria even if it was
not limited by the effluent guidelines.
Reporting of low concentrations of pollutants- The
facility should report any pollutants which are reported
to them below detection level, as less than the
corresponding lbs/day calculated from the detection
level. We would not then consider any number reported as
less than a number as a violation of the permit limit.
We do however, expect the laboratory to achieve the
lowest detection possible for each pollutant. If
deviations from the accepted lowest detection levels
occur, an explanation as described in the letter may be
appropriate. When calculating a monthly average, any
number preceded by less than(<) should be averaged as a
zero.
B. Discharge No. 002
Temperature- Upstream and Downstream Temperature
monitoring for Discharge No: 002 should be eliminated
since the discharge flows into a swampy area prior to
discharge to Shaddox Creek.
Total Residual Chlorine- We recommend leaving this
language in the permit if it is standard language for
this type of discharge. If the Company never adds
chlorine to the water, they will never have to monitor
for Total Residual Chlorine.
Fluoride and Zinc- Requirements for these parameters were
based on the modeler's review of the Annual Pollutant
Analysis results and should remain. We would recommend
that the monitoring for Zinc be changed to Quarterly.
Acute Toxicity- We recommend that the monitoring for this
outfall be in accordance with standard requirements for
this type of discharge.
In addition, we would request that the Company supply the
Division with information about the possible contaminants
contained in the air condensate and air dryer wastewater.
Since this condensate/moisture contacts the process, it
is possible that these wastestreams should be regulated
as OCPSF.
If you have questions, please advise.

FACILITY
OCPSF Flow
7Q10s
Qavg
PF
Parameter
Acenaphthene
Acrylonitrile (c)
Benzene (c)
Carbon Tetrachloride (c)
Chlorobenzene
1,2,4-Trichlorobenzene
Hexachlorobenzene (c)
1,2-Dichloroethane (c)
1,1,1-Trichooroethane
Hexachloroethane (c)
1,1-Dichloroethane
1,1,2-trichloroethane (c)
Chloroethane
Chloroform (c)
2-Chlorophenol
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethylene (c)
1,2-trans-Dichloroethylene
2,4-Dichlorophenol
1,2-Dichloropropane
1,3-Dichloropropylene
2,4-Dimethylphenol
2,4-Dinitrotoluene (c)
2,6-Dinitrotoluene
Ethylbenzene
Flouranthene
Allied Fibers
0.008 MGD
40 cfs
1848 cfs
0.244 cfs
OCPSF3.XLS
Flow is based on processes only
Limit Limit Fedl
Daily Monthly Daily Monthly State
max avg max avg
ug/I ug/I #/d #/d stdrd
Human Hlth
Standard Standard
Aquatic Organisms
Life
Ng/I Ng/I
59 22 0.004 0.001 FC no stdrd
242 96 0.016 0.006 FC no stdrd
136 37 0.009 0.002 SS no stdrd
38 18 0.003 0.001 SS no stdrd
28 15 0.002 0.001 FC no stdrd
140 68 0.009 0.005 FC no stdrd
28 15 0.002 0.001 FC no stdrd
211 68 0.014 0.005 FC no stdrd
54 21 0.004 0.001 FC no stdrd
54 21 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
54 21 0.004 0.001 FC no stdrd
268 104 0.018 0.007 FC no stdrd
46 21 0.003 0.001 FC no stdrd
98 31 0.007 0.002 FC no stdrd
163 77 0.011 0.005 FC no stdrd
44 31 0.003 0.002 FC no stdrd
28 15 0.002 0.001 FC no stdrd
25 16 0.002 0.001 FC no stdrd
54 21 0.004 0.001 FC no stdrd
112 39 0.007 0.003 FC no stdrd
230 153 0.015 0.010 FC no stdrd
44 29 0.003 0.002 FC no stdrd
36 18 0.002 0.001 FC no stdrd
285 113 0.019 0.008 FC no stdrd
641 255 0.043 0.017 FC no stdrd
108 32 0.007 0.002 1/40/NOE( 325.000
68 25 0.005 0.002 FC no stdrd
2700.00
0.66
71.40
4.42
21000.00
no stdrd
0.00
99.00
no stdrd
8.90
no stdrd
42.00
no stdrd
470.00
400.00
17000.00
2600.00
2600.00
3.20
no stdrd
790.00
39.00
1700.00
2300.00
9.10
no stdrd
29000.00
370.00
Allowable
conc. Aquatic
Life
pg/I
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
r�o stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
34698.35
no stdrd
Human Hlth Allowable
Allowable Aquatic Life
conc
Organisms
Ng/I
288263.19
3225.62
348953.47
21601.88
2242047.07
no stdrd
3.76
483843.05
no stdrd
43497.00
no stdrd
205266.75
no stdrd
2297032.67
42705.66
1814990.48
277586.78
277586.78
15639.37
no stdrd
84343.68
4163.80
181499.05
245557.54
44474.46
no stdrd
3096160.23
39502.73
#/day
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
70.553
no stdrd
Page 1

FACILITY Allied Fibers
OCPSF Flow 0.008 MGD
7Q10s 40 cfs
Qavg 1848 cfs
PF 0.244 cfs
Parameter
Methylene Chloride (c)
Methyl Chloride
Hexachlorobutadiene (c)
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
4, 6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl) phthalate (c)
Dibutyl phthalate
Diethyl phthalate
Dimethyl phthalate
Benzo(a)anthracene (c, PAH)
Benzo(a)pyrene (c, PAH)
3,4-Benzofluoranthene (c, PAH)
Benzo(k)fluoranthene (c,PAH)
Chrysene (c, PAH)
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene (c)
Toluene
Trichlororethylene (c)
Vinyl Chloride (c)
OCPSF3 .XLS
Flow is based on processes only
Limit Limit Fedl
Daily Monthly Daily Monthly State
max avg max avg
ug/I ug/I #/d #/d stdrd
Standard
Aquatic
Life
pg/I
89 40 0.006 0.003 FC no stdrd
190 86 0.013 0.006 FC no stdrd
49 20 0.003 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
68 27 0.005 0.002 FC no stdrd
69 41 0.005 0.003 FC no stdrd
124 72 0.008 0.005 FC no stdrd
123 71 0.008 0.005 FC no stdrd
277 78 0.018 0.005 FC no stdrd
26 15 0.002 0.001 FC no stdrd
279 103 0.019 0.007 FC no stdrd
57 27 0.004 0.002 FC no stdrd
203 81 0.014 0.005 FC no stdrd
47 19 0.003 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
61 23 0.004 0.002 FC no stdrd
61 23 0.004 0.002 FC no stdrd
59 22 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
59 22 0.004 0.001 FC no stdrd
67 25 0.004 0.002 FC no stdrd
56 22 0.004 0.001 FC no stdrd
80 26 0.005 0.002 SS/AQ 11.000
54 21 0.004 0.001 SS no stdrd
268 104 0.018 0.007 SS no stdrd
Human Hlth
Standard Allowable
Organisms conc. Aquatic
Life
pg/I pg/I
1600.00
no stdrd
49.70
no stdrd
1900.00
no stdrd
no stdrd
14000.00
765.00
4600000.00
5.90
12000.00
120000.00
2900000.00
0.05
0.05
0.05
0.05
0.05
no stdrd
110000.00
14000.00
no stdrd
11000.00
8.85
200000.00
92.40
525.00
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
1174.41
no stdrd
no stdrd
Human Hlth Allowable
Allowable Aquatic Life
conc
Organisms
Ng/I
7819685.67
no stdrd
242898.99
no stdrd
202851.88
no stdrd
no stdrd
1494698.04
81674.57
##########
28835.09
1281169.75
12811697.51
##########
239.48
239.48
239.48
239.48
239.48
no stdrd
11744056.05
1494698.04
no stdrd
1174405.61
43252.64
21352829.19
451586.85
2565834.36
#/day
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
no stdrd
2.388
no stdrd
no stdrd
Page 2

FACILITY
OCPSF Flow
7Q10s
Qavg
PF
Parameter
PAH (total -pg/I) (c)
** Total Chromium
** Total Copper
** Total Cyanide
** Total Lead
** Total Nickel
** Total Zinc*
Allied Fibers
0.008 MGD
40 cfs
1848 cfs
0.244 cfs
Daily
max
ug/I
Monthly
avg
ug/I
aromatic hydrocarbons
2770
3380
1200
690
3980
2610
1110
1450
420
320
1690
1050
*Total Zinc for Rayon Fiber Manufacture
that uses the viscose process and Acrylic
Fiber Manufacture that uses zinc
chloride/solvent process is 6,796 ug/L and
3,325 ug/L for maximum for any one day
and maximum for monthly average, respectively.
OCPSF3.XLS
Flow is based on processes only
Human Hlth
Limit Limit Fedl Standard Standard
Daily Monthly State Aquatic Organisms
max avg Life
#/d #/d stdrd pg/I pg/I
SS no stdrd 0.03
0.185 0.074 SS 50.000 no stdrd
0.226 0.097 SS -AL 7.000 no stdrd
0.080 0.028 SS 5.000 no stdrd
0.046 0.021 SS 25.000 no stdrd
0.266 0.113 SS 88.000 no stdrd
0.174 0.070 SS -AL 50.000 50.00
Allowable
conc. Aquatic.
Life
pg/I
no stdrd
5338.21
747.35
533.82
2669.10
9395.24
5338.21
Human Hlth Allowable
Allowable Aquatic Life
conc
Organisms
pg/I #/day
152.00 no stdrd
no stdrd 10.854
no stdrd 1.520
no stdrd 1.085
no stdrd 5.427
no stdrd 19.104
5338.21 10.854
** Metal should only be limited if Total metal bearing wasteflow:
process contains metal bearing wasteflow.
Cyanide should only be limited if Total cyanide bearing wasteflow:
process contains cyanide bearing wasteflow.
Page 3

MEMORANDUM
TO:
FROM:
THROUGH:
SUBJECT:
February 26, 1992
Dale Overcash
Permits and Engineering
Betsy Johnson
Technical Sup
rt Branch
Mike Scoville M��S
Ruth Swanek QC:1)
Comments on draft permit for Allied Fibers.
NPDES No. NC0001899
Chatham County
Outfall 001
COD limit:
Neste Resins does not have a COD limit. There should be consistency between the two permits.
However, P&E developed the limit and may revise it if warranted.
Instream monitoring:
Monitoring for DO, Temp., and Cond. should remain in the permit. The permit may be revised to
require upstream and downstream monitoring on the Haw River rather than specific sites. The
permittee and the regional office should work together to determine monitoring locations. Note:
Neste Resins monitors 75 feet above and below their discharge.
Acute toxicity:
It is recommended that the toxicity samples be drawn on the same day as the quarterly OCPSF
samples in order to correlate the results.
pH:
Effluent monitoring for pH may be monitored continuously rather than as weekly grab samples.
Radioactivity:
Limits for radioactivity are based on the observed data from the pollutant analysis. Per our SOP, a
limit is required when the effluent data is within 1/l0th of the water quality standard. Upon written
request we will review the effluent data after 1 year. If all samples are below detection, the
monitoring requirement will be dropped.
Quarterly Pollutant Analysis:
Chloroform may be sampled above the chlorine contact chamber. However, chlorine monitoring
should be added to the permit. Current chlorine data indicates that there is excess chorination at the
plant. Steps should be taken to reduce the chlorine levels to acceptable levels, i.e., 28 ug/l, to avoid
chlorine toxicity. Allied should consider dechlorination or alternate disinfection. This should
alleviate chloroform problems as well.

-2-
Outfall 002:
Temperature:
Instream monitoring for temperature may be dropped.
Chlorine:
The chlorine comment in the permit may be dropped. However, it does not require monitoring since
chlorine is not used so there is no harm keeping it.
Zinc and fluoride monitoring may be reduced to quarterly. The data will be reviewed after 1 year.
Acute Toxicity:
The episodic toxicity testing of the first five events during the first year of the permit should remain
as permitted to be consistent with other episodic discharges of this type.

To:
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 24, 1992
Betsy Johnson - Technical Support Branch
Tim Donnelly - Raleigh Regional Office
Kent Wiggins - Facility Assessment Unit
Ken Eagleson - Environmental Sciences Branch
Jay Sauber - Environmental Sciences Branch
Ray Kelling - DEM Chemistry Lab
,bdc
vJMAUL
From: Rosanne Barona
Permits and Engineering
Subject: NC0001899
Allied Chemical - Fiber Division
Chatham County
Allied Chemical has submitted comments on their draft permit. Please provide comments
to the items noted on the attached letter. A draft permit is also attached. Please respond by February
24, 1992.
cc: Permit File

AlliedFibers
Allied-Signal Inc.
Fibers Division
P.O. Box 166
Moncure, NC 27559
Telephone [phone]
Facsimile [phone]
January 14, 1992
Ms. Rosanne Barona
Department of Environment,
Health and Natural Resources
Division of Environmental Management
512 N. Salisbury Street
Raleigh, North Carolina 27604
Dear Ms. Barona:
^iS gnal
Allied-Signal Inc. appreciates the opportunity to submit the attached
comments on the draft NPDES Permit No. NC0001899 for its facility in Moncure,
North Carolina.
After careful review of the draft permit, we have several questions on
monitoring requirements, discharge limitations and toxicity testing.
Thank you for your consideration of these comments. I will be available the
week of January 13th to discuss these comments and recommendations. In my absence
from the plant during the time period of January 20th through January 29th,
please call Doug McCaig, General Supervisor E&I/Utilities.
Sincerely,
W. L. Boyer,"Supervisor
Environmental & Industrial Hygiene
Attachment
cc: D. A. McCaig
A. T. Roy
R. W. Thomas
J. E. Williamson

Page 1 of 4
Allied-Signal Inc.
Moncure Plant (NPDES Permit No. NC0001899)
Subject: Comments to draft NPDES Permit No. NC0001899
A. Draft effluent characteristics, discharge limitations and monitoring
requirements for Outfall serial number 001.
Effluent Characteristic: COD
Comments:
The discharge limitation of 38.5 lbs/day monthly average is nearly the same
as the BOD discharge limitation and it does not consider the historic COD/BOD
ratio that shows the COD to be several times greater than the BOD. A suggested
methodology for establishing an acceptable permit limit would be the use of the
historic COD/BOD ratio from the permit application, which is 8.02 (38.5/4.8).
Using the historic ratio times the permit limit for BOD the alternate COD limit
for monthly average would be 257.4 lbs/day and the daily max. would be 511.7
lbs/day.
Effluent Characteristic: Temperature, Dissolved Oxygen, & Conductivity
Our objection to the in -stream monitoring requirements is based primarily
on previous NPDES in -stream monitoring requirements that jeopardized the safety
of our operators. Sampling from bridges in the area posed hazards due to the
narrow lanes and lack of sufficient walkways. Climbing down the embankments such
as bridge embankments was difficult due to dense undergrowth in the summer and
slippery conditions in the winter. Previous sampling was conducted on Allied-
Signal property, having to sample at unidentified sites one mile upstream and
downstream includes additional concerns. These areas may not be accessible by
automobile. In addition, written permission would probably be required from
private property owners and for safety reasons two operators may be required to
conduct the sampling.
No procedures were specified for the in -stream sampling. In addition, we
don't believe representative data can be collected from a river bank. For large
industrial discharges that flow into a small receiving water it appears that the
water quality impact could be significant enough to warrant periodic sampling at
various points across the receiving water. This is not the situation with the
Allied-Signal discharge and we do not believe the benefit of measuring these
three parameters justifies the risk associated with sampling.
Our review of the U.S. Geological Survey Map for the Moncure Quadrangle
indicates that NCSR 1011 (Old US 1) is less than one mile downstream of the
Allied-Signal discharge. The draft permit indicates this as an upstream sample
point.
Effluent Characteristic: Acute Toxicity
Comments:
It is assumed that the acute toxicity sample does not have to be collected
on the same day as the other NPDES samples. Our flow proportional samplers will
not be able to provide sufficient sample quantity for all the testing.
Effluent Characteristic: �H
Commets:
Allied-Signal requests continuous effluent pH monitoring at Outfall 001
pursuant to 40 CFR Section 401.17. The pH exceptions allowed in Section 401.17
would give the plant some needed flexibility to operate the wastewater treatment
plant during the summer when the polishing pond experiences rapid pH increases
due to algae activity.

Page 2 of 4
A. Draft effluent characteristics, discharge limitations and monitoring
requirements for Outfall.serial number 001 (continued).
Effluent Characteristic: Radioactivity
Comments:
This effluent characteristic is not appropriate for this facility because
no manufacturing or processing of radioactive material occurs. The cause of the
total beta value of 27.5+/- 9.7 that was detected in the 1989 priority pollutant
analysis is unknown. This is not a routinely monitored parameter and the only
result is from this one test. Please advise us of the rationale for requiring
monitoring, the water quality concern and the basis for setting the permit
limitation.
Allied-Signal recommends that this parameter be dropped from the permit or
dropped after two quarters of analysis if the results are less than 50 pCi/L.
Effluent Characteristic: Quarterly Pollutant Analysis
Comments:
OCPSF guidelines state that limitations for metals must be included in
permits for facilities that have "metal bearing waste streams" specifically
identified in the regulation. The Moncure Plant does not have any of the
identified metal bearing waste streams and there is no reason to include metal
limitations in this permit. Metals will be monitored as part of the annual
pollutant monitoring requirement.
It appears a process related flow of 7,000 gallons/day was used to
calculate the effluent limitations. On January 30, 1991 a revised schematic of
water flow and a revised Form 2C, Section II were submitted to show that process
wastewater flows were 8,000 gpd. Usually a 1,000 gallon flow discrepancy is
insignificant, however, in the case of very low permit limitations and rounding
off procedures the use of correct flow data is extremely important.
Chloroform limitations of 0.001 lbs/day monthly avg. and 0.003 lbs/day
daily max. were established for "process related" wastewater per OCPSF
guidelines. While these limits are acceptable for pre -chlorinated wastewater,
effluent testing data shows that chloroform is generated from chlorine
disinfection in quantities that would exceed the permit limitations. Although the
data is limited to one study, it showed that chloroform was below detection
levels in the clarifier overflow, but was 7 ppb in the effluent due to
chlorination (0.4 mg/L residual chlorine level). OCPSF guidelines were intended
to limit process related contaminants and were not intended to limit substances
formed by disinfection. The acute toxicity test will determine if substances in
the effluent will be harmful. Accordingly, we request that the sample location
for the chloroform quarterly grab sample be changed to upstream of the chlorine
contact chamber.
Since the majority of the Moncure Plant's effluent flow is non -process
wastewater, one would expect to see very low concentrations of the listed
pollutants. Several analytical and reporting problems are foreseen that need to
be clarified prior to issuance of this permit. For example, if the pollutants are
reported as "not found" or "below quantification level" (BQL) by EPA analytical
methods at the appropriate detection limits, would the permitee use zero
concentration to calculate mass reporting requirements for the monthly NPDES
report or calculate the mass using the detection limit for the method and include
a less than sign with the mass? What if the lab used an EPA approved method,
but could not reach the specified detection limit for the method due to matrix
interference. Is this considered a violation? If so, how can a detection limit
problem lead to a violation if the compound in question has never been used at
the plant? Assume the flow is very high and the analytical result is reported
as less than the EPA specified detection limit for the method (or lab reports
BQL), but the detection limit times the flow results in a mass greater than the
permit limit. How is this reported? As a suggestion, perhaps a comment
could be entered on the report stating that the analytical method detection limit
in conjunction with the high flow does not allow the calculation of mass within
the permit discharge requirement.

Page 3 of 4
B. Draft effluent characteristics, discharge limitations and monitoring
requirements for Outfall serial number 002.
Effluent Characteristic:
Tem e
Comments: rature
Sam
cerns
expressed fornOutfall over
001 upstream
addition, d the downstreammonitoring
tfromgOas ut previously
primarily firepond overflow and storm water runoff. Since this water is
discharged at ambient temperature, it is unreasonable to re fall 002 is
monitoring for temperature. The water from Outfall 002 enters require
in-stream
the east side of the plant and there is no discernible discharge to Shaddox
swampy area on
Creek. There is no reason to believe this discharge would affect the receiving
water temperature. We request that all temperature measurements (discharge,
upstream and downstream) be deleted for Outfall 002.
Effluent Characteristics: Comments: Total Residual Chlorine Fluoride and Zinc
Chlorine has never been added to this discharge and there are no plans to
add chlorine to cooling water. The reference to total residual chlorine should
be deleted from the permit.
Fluoride has been detected in raw river water at 0.15 mg/L during the
recent CT Study for the potable water treatment plant so one is bound to detect
fluoride in the outfall. Since no fluoride compounds are used in the plant that
monitoring parameter.
could reach the outfall, we see no reason for including this as an effluent
Zinc containing corrosion inhibitors were eliminated as cooling water
additives prior to 1985. Based on effluent data (only one zinc excursion from
1980 to 1985) zinc was removed from the Outfall 002 monitoring requirements in
1986 (previous permit limit was 1.0 mg/L).
Outfall 002 is firepond overflow, this rep Since the primary source of water for
on the zinc concentration water from the Haw River. irement lBad sedmonl monitor ng data
generated from 1980 to 1985, elimination of zinc water treatment chemicals from
the plant and piping of cooling tower blowdown to the wastewater treatment plant,
we request that zinc monitoring not be included in the permit for Outfall 002.
Effluent Characteristics:
Comments:
Acute Toxicit
Due to the sources of water being discharged through Outfall 002 there is
no reason to believe this water would exhibit acute toxicity to the Fathead
Minnow. Since an acute toxicity test has never been conducted on this discharge,
we believe that a maximum of two acute toxicity tests on samples collected during
rainfall events will be sufficient to characterize the water
qualit
requests that the frequency of acute toxicity testing for the f rst.year Alliedyear
reduced to twice. Additional acute toxicity monitoring would be conducted after
concurrence with the state should either of the tests fail to meet minimum
organism survival.
•

Page 4 of 4
C. STANDARD CONDITIONS FOR NPDES PERMITS
Comments:
SECTION D. MONITORING AND RECORDS
4. • Test Procedures
A clarification of SECTION D requirements is needed. We agree the intent
of monitoring is to use test procedures that will detect acceptable pollutant
concentrations that can be used to calculate reporting levels that are below the
permit discharge requirement. The most sensitive methods may not be the best
methods for all effluents. The extremely low OCPSF limits in this permit dictate
that analytical detection levels be very low. For some pollutants in the
semivolatiles category analytical methods may not be available at many commercial
laboratories to meet the 1 ppb and below levels that will be needed for high
flows. Matrix interferences may also cause problems in trying to detect certain
pollutants by GC. Past effluent testing has always used Method 604 (GC analysis
with confirmation by MS) with detection limits of 10 ppb. Therefore, we have no
experience with GC analysis or its ability to meet 1 ppb detection limits.
Allied-Signal believes it is very important to resolve concerns over detection
limits and ensure that we are in agreement on the interpretation of analytical
results in determining permit compliance.