NC0003719_Staff Comments_19890425

NPDES DOCU 4ENT SCANNINO COVER SWEET
NPDES Permit:
NC0003719
Cedar Creek site WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
CStaff
Comments r;°
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 25, 1989
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DIVISION OF ENVIRONMENTAL MANAGEMENT
April 25, 1989
MEMORAND M
TO: David Foster
THRU: Trevor Clements
FROM: David Vogt"V
SUBJECT: OCPSF Monitoring for Monsanto Company
NPDES NC0003719, Cumberland Co.
Per your request, I am providing comments on Monsanto's proposed monitoring
schedule for the sampling of organic chemicals, plastics, and synthetic fibers
(OCPSF) as mandated by the recent final ruling for federal guidelines: 40 CFR
Parts 414 and 416. After reviewing their proposal, I would like to offer the
following recommendations:
A) A once per month sample is acceptable, but Monsanto should prepare ahead
of time for certain contingencies such as plant closings due to vacation
periods, sampling technicians off sick, etc. With only a datum per pipe
per month, it is imperative that the sample be taken as scheduled.
B) Outfall sampling should be performed for a minimum of twelve consecutive
months.
C) Sampling should be done on Wednesdays.
D) Only composite samples should be taken.
Please contact me if you desire further clarification of this matter.
Attachment
cc: Tommy Stevens, FRO
Monsanto WLA
Central Files

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Monsanto
MONSANTO AGRICULTURAL COMPANY
A UNIT OF MONSANTO COMPANY
P.O. BOX 2307
FAYETTEVILLE, NORTH CAROLINA 28302
PHONE [phone]
April 3, 1989
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DNRCD State of North Carolina
Permitting Department
Mr. David Foster
P. 0. Box 27687
Raleigh, North Carolina 27611
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subject: Monsanto's NPDES permit impact v/s OCPSF regulated
compounds.
Ref.: NPDES permit No. NC0003719.
Dear Mr. Foster:
BACKGROUND
As a follow-up to the discussions with NC-DNRCD permitting
department, the impacts of the OCPSF regulated compounds in the
NPDES permit were highlighted. Monsanto opted to withdraw the
permit renewal application for a flow increase and instead estab-
lished other alternatives which will allow Monsanto to operate
within the currently permitted parameters stated in the NPDES
permit No. NC 0003719.
SITUATION
In the future, however, should a permit renewal be necessary it
is evident that it will also be modified to include the OCPSF
regulated list of compounds with corresponding discharge levels
stipulated by the NPDES permitting authority of the State of
North Carolina.
STATUS
ICIA and FII, both of which are polyester and fibers manufactur-
ing operations, have a contract with Monsanto which allows their
aqueous waste streams to be discharged for treatment by Monsanto
owned and operated waste treatment facility regulated by a single
NPDES permit. Both ICIA's and Monsanto's recently expanded
facility are now on stream and have resumed normal operations.

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PROPOSED PLAN
It is proposed that an extensive sampling plan be implemented and
coordinated by Monsanto to characterize each of the major in-
fluent streams coming into the waste treatment facility. As out-
lined in the proposed sampling plan, attached to: this memo, the
sampling and analyses will be conducted by an EPA approved
laboratory - Davis & Floyd Inc. - under the designated sar::oling
and analytical protocol. The proposed sampling will continue at
a once/month/sample for the 4 influents and 1 outfall streams for
a maximum of 6 months - a total of 30 samples. Sample analyses
will be reviewed every 2 months and if necessary sampling plan
will be modified to add or delete existing sample points and/or
frequency. Additional samples, other than the stipulated ones,
may become necessary to zero -in on the actual source of pol-
lutants of any significance.
ACTIONS REQUESTED FROM THE PERMITTING DEPARTMENT - N.C. DNRCD
1. The permitting department or designates review this proposal
and provide inputs prior to sampling plan implementation tar-
get for mid -May, 1989.
2. Recognize that this plan is voluntary on the part of Monsanto
and as such is an initial attempt to be exploratory in ap-
proach and, therefore, is kept simple and cost effective.
3. Consider the data obtained. from this plan as valid input
towards any future permit preparation or renewal.
4. Submit your input and comments to our attention once you have
evaluated this approach as soon as possible.
at
Attachment
cc: M. W. Bailey - Monsanto
J. F. Hart
J. R. Klieve
T. D. Wilson
H. M. Iwerks - ICIA
K. R. Reekstin
W. J. Bethea - FII Inc.
C. M. Spangler
Tommy Stevens - Fayetteville - DNRCD
Manhar N. Patel

ICIA - Victrex Waste C. FII-Chemical Waste
ICIA - Chemical Waste
D . Monsanto" s
Waste Stream
\i V V
Monsanto's
Waste Treatment
System
Final Outfall
SAMPLING PLAN: Starting May 15, 1989
1. Sample using existing composite samplers at streams A, B, C,
D and E.
2. Use services of Davis & Floyd Inc. to obtain complete sets of
samples, prepare, ship and analyze each set of samples in
their approved labs.
3. Analyze each sample for at least 57 compounds and 6 metals
listed in Part 414.91 of the OCPSF Guidelines (other analyses
added as necessary).
4. Review data after each set and evaluate any mid -course
changes necessary after at least two sets of samples have
been analyzed.
5. Record all information necessary and pertaining to capacity
of operations at all facilities to include % on stream time,
% capacity produced, downtime impacts, etc.
6. Compile all data after six months and share information with
the permitting department of N. C. DNRCD in Raleigh with
proposed actions for future permit renewal.