NC0004944_Application_19980521

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0004944
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
;Permit Application
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
May 21, 1998
This document is printed on reuse paper - ignore any
content on the reYerse side

NPDES
Discharge
Application
HNA Holdings, Inc.
Salisbury, North Carolina
NPDES No. NC0004944
Prepared by
CH2M HILL
May 1998
142188

May 21,1998
142188
Mr. David Goodrich
NPDES Permits Supervisor
Division of Water Quality
P.O. Box 29535
512 N. Salisbury Street
Raleigh, NC 27626
Subject: HNA Holdings, Inc.
Salisbury, North Carolina
NPDES Permit Renewal (Permit Number NC0004944)
Dear Mr. Goodrich:
HNA Holdings, Inc., formerly Hoechst Celanese Corporation, owns and operates a
polyester manufacturing facility in Salisbury, North Carolina. Process wastewater and
stormwater is discharged to North Second Creek in accordance with National Pollutant
Discharge Elimination System (NPDES) Permit number NC0004944, which expires
November 30,1998. Three copies of this letter and the attached permit application are being
submitted for renewal of the NPDES permit. Also enclosed is a check in the amount of Four
Hundred Dollars ($400.00) for the permit renewal fee.
Facility Location
The HNA Salisbury facility is located on the south side of U.S. Highway 70 approximately 4
miles west of Salisbury, North Carolina, near the intersection of Highway 70 and State
Highway 801. The facility's location is presented on Figure 1 in Attachment A, which also
shows nearby transportation routes and surface waters.
Plant Overview
HNA manufactures polyester in the form of chip and fiber at its Salisbury, North Carolina,
facility. Primary raw materials in these manufacturing processes include terephthalic acid,
ethylene glycol, and fiber finish oils (see Figure 2 in Attachment A). Process wastewater,
groundwater, sanitary wastewater, cooling tower blowdown, and water treatment plant
blowdown are treated onsite before being discharged to North Second Creek.

Mr. David Goodrich
Page 2
May 21,1998 •
142188
Wastewater treatment consists of primary solids removal (bar screen), equalization,
biological treatment (activated sludge), and clarification, followed by a series of polishing
ponds, as presented on Figure 3 in Attachment A. Waste biological sludge is aerobically
digested and dewatered. Dewatered solids are disposed of off site by Waste Management.
Recovered groundwater from the interior system contains primarily ethylene glycol and is
anaerobically pretreated before being discharged to the equalization tank for treatment in
the WWTP. Recovered groundwater from the perimeter system contains mainly 1,4-
dioxane and is treated using ultraviolet light and hydrogen peroxide before being
discharged through Outfall 001 to North Second Creek.
The plant discharges stormwater associated with industrial activity through five outfalls (A,
B, C, D, and 5) as presented on Figure 1 in Attachment A. The five stormwater outfalls are
monitored according to the NPDES permit, the Stormwater Pollution Prevention Plan, and
correspondence from the Division of Environmental Management to Davis and Floyd, Inc.
dated March 3,1992.
Regulatory Setting
As part of a basinwide approach to water quality management, DWQ issued a draft Yadkin -
Pee Dee River Basinwide Water Quality Management Plan in December 1997. The plan
presents DWQ's rationale, approaches, and long-term water quality management strategies
for the river basin. The plan identifies North Second Creek as "support threatened" and
states that the stream has limited assimilative capacity for additional loading of oxygen
consuming wastes. The plan recommends that a field calibrated model be considered for
assessing the potential impact of new or expanding discharges. Since HNA is not proposing
a plant expansion at this time, existing modeling conducted as part of the last permit
application should be adequate.
Proposed Permit Conditions
Outfall 001
The facility's process, sanitary, and some stormwater flows are discharged through Outfall
001. A summary of statistical parameters for data collected for the NPDES permit is
presented in Attachment B.
Flow
Table 1 presents estimated flows for the facility. Groundwater flows have increased since
the last permit application was submitted. Figures B-1 and B-2 in Attachment B present
monthly average groundwater flow rates for the interior and perimeter recovery systems.

Table 1
HNA Holding Company - Salisbury, NC
Calculated Permit Limits
CONFIDENTIAL
Wastestream
Effluent
Guideline
Basis
Parameter
Effluent Guideline
Mass -based Limit i83
Monthly
Average
Daily
Maximum
Monthly
Average
Daily
Maximum
Finish
Best Professional Judgment (BPJ) Guided by
Organic Chemicals, Plastics, and Synthetic Fibers
(OCPSF) Subpart C - Other Fibers
Flow
BOD
TSS
0.114 mgd
18 mg/L
36 mg/L
48 mg/L
115 mg/L
17.1 Ib/d
34.2 lb/d
45.6 Ib/d
109.3 Ib/d
Bandcaster
Best Professional Judgment (BPJ) Guided by
OCPSF/Subpart C - Other Fibers
Flow
BOD
TSS
0.080 mgd
18 mg/L
36 mg/L
48 mg/L
115 mg/L
12.0 lb/d
24.0 lb/d
32.0 Ib/d
76.7 Ib/d
Cooling Towers
Best Professional Judgment (BPJ) Guided by
OCPSF/Subpart D - Resins
Flow
BOD
TSS
0.148 mgd
24 mg/L
40 mg/L
64 mg/L
130 mg/L
29.6 Ib/d
49.4 lb/d
79.0 Ib/d
160.5 Ib/d
Process
Best Professional Judgment (BPJ) Guided by
OCPSF/Subpart D - Resins
Flow
BOD
TSS
0.082 mgd
24 mg/L
40 mg/L
64 mg/L
130 mg/L
16.4 Ib/d
27.4 Ib/d
43.8 Ib/d
88.9 Ib/d
Groundwater
Best Professional Judgment (BPJ) Guided by
OCPSF/Subpart D - Resins
Flow
BOO
TSS
0.616 mgd
24 mg/L
40 mg/L
64 mg/L
130 mg/L
123.3 lb/d
205.5 lb/d
328.8 (b/d
667.9 Ib/d
Domestic Wastewater
Secondary Treatment Regulation
Flow
BOD
TSS
0.050 mgd
30 mg/L
30 mg/L
45 mg/L
45 mg/L
12.5 Ib/d
12.5 Ib/d
18.8 Ib/d
18.8 lb/d
Boilers and Chillers
Best Professional Judgment (BPJ) Guided by
Wastestream Characteristics
Flow
BOD
TSS
0.116 mgd
2.4 mg/L
53 mg/L
3.6 mg/L
79.5 mg/L
2.3 lb/d
51.3 lb/d
3.5 Ib/d
76.9 Ib/d
WTP Blowdown
Best Professional Judgment (BPJ) Guided by
Wastestream Characteristics
Flow
BOO
TSS
0.09 mgd
2.4 mg/L
53 mg/L
3.6 mg/L
79.5 mg/L
1.8 Ib/d
39.8 Ib/d
2.7 Ib/d
59.7 Ib/d
Process Stormwater
Combined Wastewater (b)
Best Professional Judgment (BPJ) Guided by
Wastestream Characteristics
(a) Mass -based limits = Flow x Effluent Guideline x 8.34
ID) Concentration -based limits = Summation of mass -based limits _ Combined Flow _ 8.34
Flow
BOO
TSS
Flow
BOD
TSS
0.304 mgd
2.4 mg/L
53 mg/L
1.600 mgd
17 mg/L
41 mg/L
3.6 mg/L
79.5 mg/L
42 mg/L
101 mg/L
6.1 Ib/d
134.4 Ib/d
221 lb/d
544 lb/d
9.1 lb/d
201.6 Ib/d
563 lb/d
1351 Ib/d
p:lebllprojects\HCClsalisbury\Limits.xls new 5/21/98

Mr. David Goodrich
Page 4
May 21,1998
142188
The maximum monthly average flow rates for the interior and perimeter systems for
periods representative of normal operations were 0.036 and 0.58 mgd, respectively, for a
total of 0.616 mgd.
Sanitary flow rates were reestimated for this permit application. HNA has approximately
1300 personnel on site during any given day. The facility has showers and a cafeteria.
DWQ's rules (15NCAC 2H.0219) suggest 25 gpd/person, with an additional 10 gpd/person
for showers. An additional 5 gpd/person was added, since the facility has a cafeteria. The
estimated sanitary flow is 0.05 mgd.
Other flows were based on process knowledge, and are similar to flows presented in the last
permit application. The resulting long term average (LTA) flow rate during plant
operational periods is 1.6 mgd. The LTA flow is comparable to the previous three year
average flow of 1.52 mgd (January, 1995 through December, 1997). The estimated LTA flow
is nearly identical to the actual flows during the last three years.
Conventional Pollutants
pH
The facility has maintained compliance with effluent pH limitations for the previous three
years. However, pH values increase to the upper limit of 9 during the summer months. The
polishing ponds typically have algae blooms during the summer which is causing the
elevated pH values. HNA would like permission to monitor for pH at both the clarifier
overflow and polishing pond effluent. If the polishing pond effluent pH exceeds the upper
permit limit of 9, the clarifier overflow pH values for the previous 30 days would be
reviewed, and if no values exceed the upper limit of 9, then clarifier effluent pH values
would be used for compliance purposes. The retention time in the polishing pond system is
approximately 30 days assuming polishing pond volumes of 5.6,18.2, and 20 million gallons
for Ponds 2, 3, and 4, and an average flow rate of 1.5 MGD. HNA is aware of at least one
other facility in North Carolina with the pH monitoring conditions discussed above.
BOD and TSS
Table 1 summarizes the facility's process flow rates and estimated BOD and TSS limitations
using Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) guidelines, secondary
treatment regulation, and best professional judgement. Wastewater from the facility's
bandcaster and finish processes are regulated by 40 CFR 414 Subpart C — Other Fibers.
Wastewater from cooling towers, other process wastewaters, and recovered groundwater
are regulated by 40 CFR 414 Subpart D — Thermoplastic resins. BOD and TSS allocations for
wastewater from boilers and chillers, water treatment plant blowdown, and process
stormwater are based on intake water quality (NPDES Renewal Correspondence, Davis and
Floyd, Inc. to Division of Environmental Management dated February 15, 1991).

a
/011
Mr. David Goodrich
Page 5
May 21,1998
142188
TSS limitations were based on OCPSF and secondary treatment regulations. Table 1
presents estimated BOD and TSS loads based on OCPSF and secondary treatment
regulations. HNA recommends that the winter BOD limit and TSS limits be updated to
reflect the current water balance.
Water quality based limits for BOD were determined for the previous permit application
based on DWQ's draft wasteload allocation dated May 24,1993. DWQ's modeling analysis
predicted a minimum DO of 5 mg/1 (DWQ's water quality standard for DO) based on a
discharge of 1.574 mgd, 131 lb/day BOD, and 171b/day ammonia nitrogen. The modeling
used a typical CBOD decay rate and CBOD/BOD ratio. These values were adjusted using
site specific information, and a minimum BOD limit of 150 lb/d was established. The water
quality based limit for BOD is lower than the OCPSF based value. Therefore, the summer
BOD limit is based on water quality standards, and the winter limit is based on OCPSF
regulations.
Ammonia Nitrogen
The facility is currently required to monitor for ammonia nitrogen three times per week
with limits of 23 lb / d monthly average and 46 lb /day daily maximum. Limits in the current
permit are based on the oxygen demand modeling DWQ conducted for the current permit
as discussed above. Since the facility has relatively low levels of ammonia nitrogen in the
effluent (average of 5 lb/day for the previous three years), a monitoring frequency of once
per week is requested.
Metals
The facility currently is required to monitor twice a month for the metals presented in Table
2. The NC water quality standard or action level also is presented in Table 2. HNA
recommends that monitoring for chromium, nickel and silver be dropped since detection of
these metals has seldom occurred (note: a less than symbol was erroneously omitted for
silver on June 20,1995. This discharge monitoring report will be corrected). Iron and zinc
have been detected periodically at levels below the water quality standard or action level
when accounting for the in -stream dilution. Therefore, HNA recommends monitoring for
iron and zinc be reduced to quarterly. HNA recommends that copper and manganese
monitoring remain at twice per month. HNA also recommends monitoring for metals using
a grab sample with clean sampling techniques since inadvertent contamination can occur
using composite sampling equipment. In addition, the facility equalizes influent
wastewater. Therefore, grab sample results should adequately reflect effluent variability.
OCPSF Priority Pollutants
The facility currently monitors for OCPSF priority pollutants either monthly or quarterly.
Approximately 25 of the priority pollutants were required to be monitored monthly for one
year, and then quarterly. HNA wanted additional data on those priority pollutants and
continued to monitor monthly.

Mr. David Goodrich
Page 6
May 21,1998
142188
Table 2
Summary of WWTP Metals Monitoring Data
(Values in mg/L)
NC Water NC
# of Standard Quality - Action
Parameter Count Detects Average Maximum Deviation Standard Level
Chromium 63 0 0 0 0 0.050
Copper 63 62 0.0876 0.16 0.0290 0.007
Iron 63 62 0.222 0.57 0.109 1
Manganese 65 63 0.0894 0.666 0.0801 0.200
Nickel 63 4 0.000651 0.011 0.00252 0.025 ---
Silver 63 0 0 0 0 0.00006
Zinc 63 33 0.0294 0.12 0.0352 0.050
Priority pollutants detected in the effluent within the previous three years include bis (2-
ethylhexyl) phthalate (BEHP), benzene, and methylene chloride (note: a less than symbol
was erroneously omitted for acylonitrile and polynuclear aromatic hydrocarbons on one
occasion. This discharge monitoring report will be corrected). Benzene and methylene
chloride detected values were below the permit limits.
BEHP is a common sampling and laboratory contaminant and can originate from latex or
vinyl gloves, flexible plastic tubing, and other plastic components. The facility has been
researching the presence of BEHP in the effluent. BEHP has not been tied to a raw material.
Both grab and composite samples have been collected. Of nine grab samples collected,
BEHP was detected in three samples at low levels (values of 10.5,19.5, and 35 ug/L).
However, BEHP has been detected in composite samples as high as 120 ug/1. The facility
has been using a submersible pump for collection of composite samples. The pump has a
di -electric fluid on the motor side, which is coupled to the pump via a shaft. The facility
recently discovered that the di -electric fluid is 1.6 percent BEHP. The di -electric fluid likely
is contacting the sample through the shaft. Therefore, the submersible pump has been
replaced with a typical composite sampler with a peristaltic pump. Plastic tubing is only
used at the pump head. HNA will further evaluate BEHP after collection of samples using
the new composite sampler. HNA requests that the BEHP monitoring requirement remain
at quarterly.

Mr. David Goodrich
Page 7
May 21,1998
142188
HNA also requests a quarterly monitoring requirement for benzene and methylene chloride.
HNA recommends that the remaining priority pollutants be monitored annually, since these
pollutants have not been detected in the effluent in the past three years.
Toxicity Testing
The current NPDES permit requires an acute toxicity test with an LC50 greater than 34
percent effluent. The IWC for the WWTP outfall is 3.4 percent based on a 7Q10 of 68.5
MGD. Since discharge and river flows are essentially unchanged, HNA recommends that
the toxicity testing requirement remain unchanged with the permit renewal.
In -stream Monitoring
The facility's current permit requires in -stream monitoring upstream and downstream of
Outfall 001. The facility joined the Yadkin River Basin Association, and as a member of that
association, is no longer required to conduct in -stream monitoring once the associations
monitoring program in underway (planned for June, 1998). Therefore, DWQ should be
issuing a letter rescinding the in -stream monitoring requirement, and in -stream monitoring
should not be included in the renewed permit.
It should be noted that DO, pH, and conductivity measurements upstream and downstream
of Outfall 001 are comparable during the winter and summer months suggesting that the
facility's discharge is not significantly effecting DO, pH, and conductivity of the river. In
addition, the data support the current water quality limits, and HNA recommends that
these limits remain the same. A summary of the data is presented in Attachment B.
Proposed Permit Requirements
Table 3 summarizes permit limits and monitoring requirements which HNA is requesting.
Stormwater Discharges
DWQ stated in a telephone conversation with Kristen Jenkins, CH2M HILL, on March 11,
1998, that EPA Form 2F is not required for permit renewals, and only data which has been
collected, but not submitted, should be reported in the permit application. The facility has
not collected any stormwater samples to date during 1998, and all data prior to 1998 has
been reported.
The Stormwater Pollution Prevention Plan was implemented in November, 1994. In
addition, no changes have occurred which would affect stormwater discharges since the
stormwater pollution plan was implemented.

Mr. David Goodrich
Page 8
May 21,1998
142188
Table 3
Requested Permit Conditions
Parameter Monthly Average Limit Daily Maximum Limit Monitoring Frequency
Flow 2.305 MGD Continuous
BOD — Summer 150 lb/day 300 lb/day Daily
BOD —Winter 221 lb/day 563 lb/day Daily
TSS 578 lb/day 1460 lb/day Daily
NH3-N — Summer and Winter 23 lb/day 46 lb/day Weekly
Benzene 0.602 lb/day 39.83 ug/I Quarterly
Methylene Chloride 0.651 lb/day 1.447 lb/day Quarterly
Bis (2-ethylhexyl) phthalate 60.2 ug/I Quarterly
Iron Quarterly
Zinc Quarterly
Copper 2/month
Manganese - 2/month
Note: Proposed changes are in "bold italics"
The facility is also requesting that the stormwater outfalls which are required to be
monitored (A, B, C, D, and 5) be listed in the revised permit. The facility received DWQ
approval to collect grab stormwater samples instead of composite samples due to the
number of outfalls. Therefore, we are requesting that the permit state that stormwater
sampling be conducted with grab samples.
Additional Permit Verbiage
The current NPDES permit includes limits for several pollutants which are below acceptable
detection levels. Therefore, the facility is requesting that the following verbiage is included
in the renewed permit:
Analytical data which is reported as less than the detection level shall be averaged as zero.

Mr. David Goodrich
Page 9
May 22,1998
142188
Please feel free to contact me at (704) 636 - 6000 or one of our technical contacts shown
below if you have any questions or require additional information.
Plant Senior Environmental Engineer , Stephen Lamb, [phone] ext-4862
CH2MHILL Consultant, Kristen Jenkins, [phone] ext 228
Sincerely,
HNA Holdings, Inc.
10i•
Tony ranecky
Plant Manager
CLT\E:\HCC\SALISBUR\PERMIT\perm2letdoc
Enclosures
C: Kristen Jenkins/CH2M HILL
Bill Kreutzberger/CH2M HILL

•
Attachment A:
Figures

ATUScarlett1142188.PR.20YFigure 2
4120/98
U.S. HIGHWAY 70
Figure 1
Facility Location
HNA Holdings, Inc. —Salisbury Plant

ATLIScarlet8142188.PR.20Wigure 2 5/20198
Terephthalic
Acid
Ethylene
Glycol
Finish
Oil
Polymer
Production
Polymer
Production
Id Chip
Production
Polymer
Production
— —
Filament
Production
Legend
Raw MaterialProduct
— — — Wastewater
Staple
Production
N. Product to
Customers
Product to
► Customers
— —►I
t
► Product to
Customers
1111 _ — — ► Wastewater
to Treatment
Figure 2
HNA Holdings, Inc. —Salisbury Plant
Production Process Flow Diagram

Sanitary _
Waste
Process
Waste
Solid Waste
To Landfill
Comminutor
Chlorine Contact
Bar Screen
I
Cooling Tower
Blowdown
PWP
Grit Removal
i
1
1
1
i
•
•
•
•
i
•
Equalization
Blowdown
Pumped Lift
Station
Anaerobic
Pretreatment
Anaerobic
Pretreatment
Aeration Basin "A"
Aeration Basin "B"
Aeration Basin "C"
Solids to
Landfill
Interior Groundwate
Recovery System
Return Activated Sludge
Clarifier 1
Clarifier 2
Sludge Dewatering
Storm Water
Weirs (5)
Direct
Discharge
Polishing Pond # 1
Out of Service
Perimeter GW
Recovery System
Aerobic Digester
Equalization
r
Polishing Pond # 2
Polishing Pond # 3
Polishing Pond # 4
Outfall
001
Figure 3: HNA Holdings Inc. Salisbury
Waste Treatment Process Flow Diagram
S.C. Lamb 5/7/98
ref: PWP.PPT

rotNI
Attachment B:
Summary of statistical data

WWTP Summary
Parameter
Required
Frequency
Sample
Count
# of
Detections
# of
Exceedances
Minimum
Average
Maximum
Standard
Deviation
Daily Limit
Monthly
Limit
Flow (MGD)
Daily
1096
0.395
1.52
2.78
0.233
2.305
pH
Daily
1096
1
7.05
7.90
9.02
0.319
6 - 9
6 - 9
D.O. (ppm)
Daily
1096
1
4.60
( 8.81
14.2
2.19
5
5
BOD (ppm)
Daily
1095
1.00
8.21
23.0
3.93
---
---
BOD (Ibs/day)
Daily
1095
1
11.70
102
364
46.91
300
150
COD (ppm)
Daily
1097
8.00
60.4
199
30.1
---
---
COD (Ibs/day)
Daily
1096
101.9
742
2088
308.6
---
---
TS (ppm)
Daily
471
141
506
7861
387
---
---
TSS (ppm)
Daily
1096
1.00
13.8
76.0
8.94
---
---
TSS (Ibs/day)
Daiy
1096
12.54336
168
733
95
1349
505
NH3-N (mglL)
3/week
465
0
0.37
2.40
NA
NH3-N (Ibs/day)
3/week
465
0.000
4.67
34.6
4.95
46
23
PAHs (Ibs/day)
M/Q
41
0.000
0.0000
0.000
PAHs (uq/L)
M/Q
41
0
0.00
0.0
0.00
0.09
45
Fecal Coliform (# per 100 mL)
Weekly
156
1
6.00
68.9
1 418
47.4
400
200
1,1 Dichloroethylene (ug/L)
M/Q
41
0
0
0
0
1.908
NA
1,1.2 Trichloroethane (uq/L)
M/Q
41
0
0
0
0
20.1
NA
1,2 Dichloroethane (uq/L)
M/Q
41
0
0
0
0
12.72
NA
1,2 Dichloropropane (ug/L)
M/Q
41
0
0
0
0
1.52
NA
1,3 Dichloropropylene (Ibs/day)
M/Q
41
0
0
0
0
29 uq/L
472 Ibs
2,4 Dinitrotoluene (uq/L)
M/Q
42
0
0
0
0
3.68
NA
3,4 Benzoftuoranthene
(c,PAH) (uq/L)
M/Q
45
0
0
0
. 0
---
---
4,6 Dinitrocresol (uglL)
M/Q
42
0
0
0
0
39.3
NA
Acrylonitrile (uq/L)
M/Q
40
0
0.00
0.0
0.0
1.975
NA
Benzene (uq/L)
M/Q
40
3
0
0.38
5.04
1.3
NA
NA
Benzene (Ibs/day)
M/Q
40
3
0
0.005300
0.077
0.0189
39.83 ug/L
0.0602 Ibs
Benzo(a)anthracene
(c, PAH) (uq/L)
M/Q
42
0
0
0
0
---
NA
Benzo(a)pyrene(c, PAH) (uq/L)
M/Q
45
0
0
0
0
---
-
Benzo(k)fluoranthene
(c, PAH) (uq/L)
M/Q
45
0
0
0
0
---
---
Bis(2, ethylhexyl)phthalate (ib/d)
M/Q
45
37
0
0.370582
1.56
0.38
NA
NA
Bis(2, ethylhexyl)phthalate (ug/L)
M/O
45
37
7
0
29.4 I
120
30.2
60.2
NA
Carbon Tetrachloride (uq/L)
M/O
40
0
0
0
0
8.501
NA
Crysene(c, PAH) (uq/L)
M/O
45
0
0
0
0
---
---
Hexachlorobutadiene (uq/L)
M/Q
42
0
0
0
0
14.893
NA
Hexachlorobenzene (uq/L)
M/Q
40
0
0
0
0
0.25
NA
Nitrobenzene (uq/L)
M/Q
42
0
0
0
0
50 ug/L
0.439 Ibs
Phenolic Compounds (uq/L)
M/Q
44
0
0
0
0
7.5
7.5
Tetrachtoroethylene (Ibs/d)
M/Q
41
0
0
0
0
26.8 uq/L
0.358 tbs
Toluene (Ibs/d)
M/Q
41
0
0
0
0
32.2 uq/L
0.423 Ibs
Vinyl Chloride (uq/L)
WO
41
0
0
0
0
67
NA
1,1 Dichloroethane (Ibs/day)
0
20
0
0
0
0
0.96
0.358
1,1,1 Trichloroethane (Ibs/day)
0
20
0
0
0
0
0.878
0.342
1,2 Dichlorobenzene (Ibs/day)
0
21
0
0
0
0
2.651
1.352
1.2 trans-Dichloroethylene (Ibs/de
0
20
0
0
0
0
0.878
0.342
1,2.4 Trichlorobenzene (Ibs/day)
0
20
0
0
0
0
2.277
1.106
1,3 Dichlorobenzene (Ibs/day)
0
21
0
0
0
0
2.651
1.352
1,4 Dichlorobenzene Ms/day)
Q
21
0
0
0
0
0.455
0.244
Page 1 of 2

WWTP Summary
e
Parameter
Required
Frequency
Sample
Count
# of
Detections
# of
Exceedances
Minimum
Average
Maximum
Standard
Deviation
Daily Limit
Monthly
Limit
,1,4 Dichlorophenol (Ibs/day)
0
20
0
0
0
0
1.821
0.634
2 Chlorophenol (lbs/day)
Q
21
0
0
0
0
1.594
0.504
2 Nitrophenol (Ibs/day)
Q
20
0
0
0
0
1.122
1.717
2,4 Dimethylphenol (Ibs/day)
Q
20
0
0
0
0
0.588
0.293
2,6 Dinitrotoluene (lbs/day)
Q
20
0
0
0
0
10.425
4.147
4 Nitrophenol (Ibs/day)
Q
20
0
0
0
0
2.017
1.171
Acenapthene (Ibs/day)
0
20
0
0
0
0
0.96
0.358
Acenapthytene (Ibs/day)
Q
20
0
0
0
0
0.96
0.358
Anthracene (lbs/day)
Q
20
0
0
0
0
0.96
0.358
Chlorobenzene (Ibs/day)
Q
21
0
0
0
0
0.455
0.244
Chloroethane (Ibs/day)
Q
21
0
0
0
0
4.358
1.691
Chloroform (Ibs/day)
0
21
0
0
0
0
0.748
0.342
Dibutylphthalate (Ibs/day)
0
20
0
0
0
0
0.927
0.439
Diethylphthalate (Ibs/day)
Q
20
0
0
0
0
3.301
1.317
Dimethylphthatate (Ibs/day)
0
20
0
0
0
0
0.764
0.309
2,4 Dinitrophenol (Ibs/day)
0
20
0
0
0
0
2.00
1.155
Ethylbenzene (Ibs/day)
Q
21
0
_
0
0
0
1.756
0.52
Fluoranthene (Ibs/day)
Q
20
0
0
0
0
1.106
0.407
Fluorene (Ibs/day)
0
,
20
0
0
0
0
0.96
0.358
Hexachloroethane (Ibs/day)
Q
20
0
0
0
0
0.878
0.342
Methyl Chloride (Ibs/day)
0
21
0
0
0
0
3.09
1.399
Methylene Chloride (ug/l)
0
21
2
0
0.57
6.27
1.81
NA
NA
Methylene Chloride (lbs/day)
0
21
2
0
0.01
0.09
0.02
1.447
0.651
Naphthalene (Ibs/day)
0
20
0
0
0
0
0.96
0.358
Phenanthrene (Ibs/day)
0
20
0
0
0
0
0.96
0.358
Phenol (Ibs/day)
0
20
0
0
0
0
0.423
0.244
Pyrene (lbs/day)
Q
20
0
0
0
0
10.9
0.407
Trichloroethytene (Ibs/day)
Q
21
0
0
0
0
0.878
0.342
Chromium (lb/d)
NA
75
0
0
0
0
0
NA
NA
Chromium (mg/L)
2/month
75
0
0
0
0
0
NA
NA
Copper (lb/d)
NA
75
74
0
1.058
1.926
0.358
NA
NA
Copper (mq/L)
2/month
75
74
0
0.084
0.160
0.029
NA
NA
Iron (lb/d)
NA
76
76
0.762
2.962
8.322
1.393
NA
NA
Iron (mq/L)
2/month
76
76
0.063
0.234
0.570
0.106
NA
NA
Manganese (lb/d)
NA
75
75
0.356
1.128
9.176
1.008
NA
NA
Manganese (mq/L)
2/month
75
75
0.027
0.089
0.666
0.074
NA
NA
Nickel (lb/d)
NA
75
4
0
0.007
0.141
0.029
NA
NA
Nickel (mg/L)
2/month
75
4
0
0.001
, 0.011
0.002
NA
NA
Silver (lb/d)
NA
75
0
0
0
0
NA
NA
Silver (mq/L)
2/month
75
0
0
0
0
NA
NA
Zinc (lb/d)
NA
75
35
0
0.313
1.587
0.426
NA
NA
Zinc (mq/L)
2/month
75
35
0
0.025
0.120
0.034
NA
NA
Notes
of the daily maximum permit limit
Bold border indicates an exceedance
Page 2 of 2

WWTP Stream Summary
Upstream
Downstream
Parameter
Sample
Frequency
Count
Minimum
Maximum
Average
Standard
Deviation
Minimum
Maximum
Average
Standard
Deviation
Temperature (°C)
3/week
260
0.10
24.00
15.9
6.2
0.50
24.80
16.6
6.2
Conductivity (umhos/cm)
3/week
260
8.0
318.00
86.6
17.9
40
170.00
98.3
15.6
D.O. (mg/L)
3/week a
260
5.10
15.0
8.7
1.9
5.1
13.70
8.4
1.7
a 3/week during June, July, August, and September, 1/week during the remaining months of the year.

50000
45000
40000
35000
sz 30000
0
a
u)
c
o
25000
co
cn
0
LT- 20000
15000
10000
5000
Figure B-1
Interior System Treated Groundwater Monthly Average Flows
Average flow = 0.036 mgd for
period of 10/95 through 8/97
0 • i 1 I 4 1 I 4 4 I 1 I 1 1 I 4 I I I i l 1 I t 1 } I 1 I 4 l I
cn cn cn cn cn cA cn cn cn Li) cn cn CO cO co co co co co co co co co co r. r � r` ti ti n
rn rn rn rn rn rn rn rn a� rn CD rn 9 9 9 9 cgs rn 9 rn rn rn rn rn 9 9 9 9 cgs rn 9
03 �- 03 = - m w te
• 0 m 03 m c0 = = II
' 0 m Gs cu `o. co m
u_ 2 ¢ 2 —J < v) 0 Z o � u- M ¢ 2 • < to O z o u. 2 < g
Gwflows.xls Chart1 4/8/98

700000
600000
500000
SZ
a 400000
co
C
o
W
a)
0 300000
T.
200000
100000
Figure B-2
Perimeter System Treated Groundwater Monthly Average Flows
Average flow = 0.58 mgd for
period of 11/95 through 8/97
0 •,
to to 10 to 10 10 in 1n ►0 to 10 c0 co co co co c0 c0 CD c0 CD CD c0 n t` f� 1'- n n n ..
D) 9 t7) rn CI) lA rn rn6. 9 a) D) rn O) rn Q) rn rn rn rn rn rn rn rn t7) lA tT O) t3) rn fA
LL 2 < g -' < U) O z in � Ii .e Q g - < co 0 Z CI -`ui IL 2 < g � -) Q
I I I I I 1 I I I I I I I
1 I I I I- 1 1 1 1 1 1 1 I I
Gwflowsl .xls Chart1 4/8/98