NC0003719_Permit (Modification)_19960408

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
April 8, 1996
Ms. Deborah Small
Monsanto
P.O. Box 2307
Fayetteville, North Carolina 28302
Dear Ms. Small:
Alr7A
CDEHNR
Subject: NPDES Permit Modification
Permit No. NC0003719
Monsanto
Cumberland County
This correspondence is in response to your March 15, 1996 request for a permit modification. The
Division concurs with collecting outfall 002 Dissolved Oxygen effluent samples at the combined
outfall box located below outfalls 001 and 002. In accordance with this determination, your NPDES
permit has been modified to reflect the appropriate changes.
Attached to this correspondence are the amended summer and winter Effluent Limitations and
Monitoring Requirements pages for outfall 002 which should be inserted into your permit. The old
Effluent Limitations and Monitoring Requirements pages should be discarded. All other terms and
conditions contained in the issued permit remain unchanged and in full effect. These permit
modifications are issued pursuant to the requirements of North Carolina General Statutes 143-215.1
and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection
Agency. This permit modification becomes effective immediately.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such demand is made, this decision shall be final and binding.
If you have any questions, please contact Jeanette Powell of my staff at [phone], extension
537.
Sincerely,
fin-- A. Preston Howard, Jr., P.E.
cc: Central Files
Fayetteville Regional Office, Water Quality Section
Mr. Roosevelt Childress, EPA
Permits and Engineering Unit
Facilities Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Part I
5. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SUMMER (April 1 - October 31)
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
002. Such discharges shall be limited and monitored by the pennittee as specified below:
Jftluent Characteristics
Flow
Total Suspended Solids
BOD, 5 Day, 20° C
COD
NH3 - N
Fecal Colifonn (geometric mean)
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorous
Glyphosate
Residual Chlorine
Acute Toxicity 2
pH 3
Dissolved Oxygen4
Temperature
Conductivity
Footnotes-
1
2
Discharge
Monthly Avg,
1.25 MGD
457.0 lbs/day
**
5000.0 lbs/day
35.0 lbs/day
Limitations
Daily Max,
914.0 lbs/day
**
8000.0 lbs/day
70.0 lbs/day
Monitoring
Measurement
Frequency
Continuous
3/week
3/week
3/week
3/week
3/week
Quarterly
Quarterly
2/month
3/week
Quarterly
3/week
***
***
***
Requirements
Sample Sample
Type Location 1
Recording I or E
Composite E
Composite E
Composite E
Composite E
Grab E
Composite E
Composite E
Composite E
Grab E
Composite E
Grab E
Grab E,U,D
Grab E,U,D
Grab U,D
NC0003t719
Sample Locations: E - Effluent, I - Influent, U - Upstream, two miles from outfall, D - Downstream, 100 yards upstream of Lock and Dam #3.
Acute Toxicity (Fathead Minnow) P/F at 90%, February, May, August, November; See Part I.A.4 of this permit. Samples for toxicity testing shall be
collected at the combined outfall box located below outfalls 001 and 002.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/l. Effluent samples for dissolved oxygen testing shall be collected
at the combined outfall box located below outfalls 001 and 002.
** Summer BOD5 limits shall be phased as follows: Effective Dates Monthly Avg. (lbs/day) Daily Max. (lbs/da_v-)
April 1, 1996 - October 31, 1996 350.0 700.0
April 1,1997 - October 31,1997 275.0 550.0
April 1,1998 - permit expiration 200.0 400.0
***Effluent monitoring (if required) shall be conducted three times per week. Upstream and downstream monitoring shall be conducted three times per week
during June, July, August, and September, and once per week during the rest of the year.
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE TREATMENT SYSTEM EXCEPT AS PRE -APPROVED ADDITIVES TO BIOCIDAL
COMPOUNDS OR THAT WHICH RESULTS FROM THE NORMAL DEGRADATION OF PIPING AND EQUIPMENT USED IN PROCESS UNITS.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

Part I
6. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - WINTER (November 1 - March 31)
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall serial number
002. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow
Total Suspended Solids
BOD, 5 Day, 20° C
COD
NH3 - N
Fecal Coliform (geometric mean)
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorous
Glyphosate
Residual Chlorine
Acute Toxicity 2
pH 3
Dissolved Oxygen 4
Temperature
Conductivity
Discharge
Monthly Avg,
1.25 MGD
457.0 lbs/day
**
5000.0 lbs/day
70.0 lbs/day
Limitations
Daily Max,
914.0 lbs/day
**
8000.0 lbs/day
140.0 lbs/day
Monitoring
Measurement
Frequency
Continuous
3/week
3/week
3/week
3/week
3/week
Quarterly
Quarterly
2/month
3/week
Quarterly
3/week
***
***
***
Requirements
Sample Sample
Type Location 1
Recording I or E
Composite E
Composite E
Composite E
Composite E
Grab E
Composite E
Composite E
Composite E
Grab E
Composite E
Grab E
Grab E,U,D
Grab E,U,D
Grab U,D
NC00031i 9' '
Footnotes:
1 Sample Locations: E - Effluent, I - Influent, U - Upstream, two miles from outfall, D - Downstream, 100 yards upstream of Lock and Dam #3.
2 Acute Toxicity (Fathead Minnow) P/F at 90%, February, May, August, November, See Part I.A.4 of this permit. Samples for toxicity testing shall be
collected at the combined outfall box located below outfalls 001 and 002.
3 The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4 The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/1. Effluent samples for dissolved oxygen testing shall be collected at
the combined outfall box located below outfalls 001 and 002.
** Winter BOD5 limits shall be phased as follows:
Effective Dates
permit issuance - March 31, 1996
November 1, 1996 - March 31, 1997
November 1, 1997 - March 31,1998
November 1,1998 - permit expiration
Monthly Avg. (lbs/day)
700.0
700.0
550.0
400.0
Daily Max. (lbs/day)
1400.0
1400.0
1100.0
800.0
***Effluent monitoring (if required) shall be conducted three times per week. Upstream and downstream monitoring shall be conducted three times per week
during June, July, August, and September, and once per week during the rest of the year.
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE TREATMENT SYSTEM EXCEPT AS PRE -APPROVED ADDITIVES TO BIOCIDAL COMPOUNDS
OR THAT WHICH RESULTS FROM THE NORMAL DEGRADATION OF PIPING AND EQUIPMENT USED IN PROCESS UNITS.
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.

2002 r-ef1erii l
2 e
MONSANTO
Food • Health • Hope
February 3, 2000
Mr. Dave Goodrich, Supervisor
Division of Water Quality
Permitting Department
1617 Mail Service Center
Raleigh, NC 27699-1617
Reference: NPDES Permit # NC 0003719
Subject: Zinc Data: OCPSF Sampling
Dear Mr. Goodrich:
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROLINA 28302
PHONE [phone]
•
•t
L..J�•..-
DENR - WATER QUAI.ITY
POINT SOURCE BRANCH
As a follow-up to our recent discussions, and as instructed, Monsanto Company's Fayetteville
Plant is submitting the required data on Zinc sources. As explained earlier, the attached data
history support Monsanto's claim that the elevated Zinc value during the August, 1999 OCPSF
analysis resulted from the PWC of Fayetteville water works supplied potable water as the
principal and background source of water used in it's process. The attached information
substantiates this claim as following conclusions are drawn from extensive data analysis:
A) Table 1 History: Outlines the fact that progressively Zinc loading increased as
Monsanto transitioned to exclusive use of the PWC supplied water (e.g.
Ibs/day Zinc loading increased from 2.15 Ibs to 3.39 Ibs - an increase of
58%)
B) Table 2 Recent History: December 1999: Supports the claim that the incoming
PWC water loading above at 3.55 Ibs/dav was more than 2.5 times the
combined loading from the chemical waste sources (DuPont, Monsanto,
Wellman) of 1.37 Ibs/day.
C) Table 3 Recent History: January 2000: Additionally confirms the findings
outlined in B above.
D) Table 4 As a follow-up to your request, duplicate sampling and analysis by the
Burlington Research labs and the Savannah Tabs indicate some biases
which you appropriately predicted due to QA/QC factors, it is, however,
evident that directionally the loadings of Zinc favorably support claims
in the A to C reasoning above. Furthermore, both labs confirm that
other than Zinc, metals (Ni, Pb, Cu & Cr) remain well below the limits.
(See graphs on metals).
Furthermore, the 1998/1999 Zinc source profile attached within the Appendix clearly
estimates the extent of Zinc contributions to Monsanto's waste treatment where incoming
PWC water supply is the overriding contributor

Mr. Goodrich
II February 3, 2000
Based on these findings, Monsanto requests that consideration be given to the "background"
source (PWC water) in assessing any further actions, especially since the metal contents of
"chemical based" influents historically have, in total, always amounted to less than the
OCPSF mandated levels.
Additionally, Monsanto requests that a complete consideration be given in assessing any
negative actions against Monsanto.
Also, Monsanto's concerns are further heightened, especially in light of the supporting data,
that meeting the stipulated limits on Zinc may not be feasible for the duration of permit
(expiring December 31, 2000) due to such elevated levels in Zinc from the background PWC
water supply. It is, therefore, requested that permit conditions be modified.
In conjunction with the above rationale, we additionally offer our corporate review of the
OCPSF Regulations as they apply to our operations specifically to Zinc (See Attachment II).
This attachment references the subpart 1 "Direct discharge point sources that use end -of -pipe
biological treatment". Metals and cyanide only apply to that portion of the waste water that
comes from a waste stream specifically mentioned in Appendix A. I have included Zinc waste
streams from Appendix A. Note that PET (Polyethylene Terephthalates: Manufactured by
DuPont, Wellman) manufacture is NOT shown for Zinc and, therefore, should not be limited.
Again we should not have a Zinc limit based on the regulations. We, therefore, request your
concurrence and ask for a permit revision to acknowledge this. Also, our Louisiana facility,
which as you know, also manufactures glyphosate while treating other waste water, does
NOT have a Zinc limit for the very same reason.
We appreciate your patience and considerations in allowing us to submit a thorough
evaluation of the cause leading up to this situation. We are committed, as you are, in
safeguarding the integrity of the environment as we continue to operate while protecting the
water quality resources of North Carolina.
Sincerely,
ManharN. Patel
Environmental Safety & Health
Business Unit Manager
sms
cc: Susan Wilson - Environmental Engineering
Permitting Section
Mr. Shannon Langley - Compliance Supervisor
Paul Rawls - Supervisor
Division Water Quality - Fayetteville, NC

A) History:
PWC Water Data: Zinc
Sample at Incoming Header
Table 1
1996*
1997
1998
1999
PWC Water Usage (M
Gallons/Year)
353
536
572
499
Average Zinc (Ibs/day)
2.15
_
3.08
3.45
3.11
* Switchover year from river water to PWC supply.
B) Recent Data: Individual Influent Data: Zinc (Period 12/1/99 to 12/20/99)
Lab = Burlington Research
Table 2
Averages
Flow MGD I Zinc Conc M9/litre I Zinc Ibs/day
DuPont
.198
.582
.950
Wellman
.002
.232
.004
Monsanto
.619
.080
.413
Sub -Total: Chemical Stream
1 .819
-
I 1.367
Other: Cooling Tower B/D
.394
.762
2.448
PWC Water
1.4
.304
3.549
C) Period: 1/1/2000 - 1/10/2000
Table 3
Flow MGD
Zinc Conc
(mg/litre)
Zinc Ibs/day
DuPont
.164
.368
.502
Wellman
.003
.208
.005
Monsanto
.578
.253
1.216
Sub Total: Chemical Streams
I .745
,
.758
I 1.723
Other: Cooling Tower B/D
.400
.758
1.99
PWC Water
1.29
.305
3.07

PWC
Supplied
Water
Header
Flow =1.47 MGD
Zinc = 3.44 Ibs/day
1998/1999: Zinc Profile
(Averages)
Cooling
Tower
Blowdown
IDuPont
i
Flow = .394 MGD
Zinc = 2.448 Ibs/day
Flow = .198 MGD
Zinc = .950 Ibs/day
Wellman I
Flow = .002 MGD
Zinc = .004 Ibs/day
Other Misc.
'Monsanto
Flow = .619 MGD
Zinc = .413 Ibs/day
• Softeners
• Sanitary
• Gen. Purpose
• Boilers
Monsanto's
Waste
Treatment
System
Est. Flow = .05 MGD
Est. Zinc = <.5 Ibs/day
((cop S a..1 Cy fr 2 (a; ,u 6- D l . 4-7
CIO QS✓t -/ cam.. 43 15 1`1c1 3,44 i‘id.,3
1
Outfal I
Zinc
Daily Monthly
Max Avg.
Limits: 5.77 2.32

co
z
0
a
9.000
8.000
7.000
6.000
5.000
4.000
3.000
2.000
1.000
0.000
ZINC LBS/DAY
01 /05/2000
0 0 0 0 0 0
N CD CD CD
CV CV CV N N
I,- 0 N V I� (7)
O r
1-
DATE
DAILY INFLUENT ZINC LBS
—s— DAILY EFFLUENT ZINC LBS

INFLUENT/EFFLUENT - ZINC LBS/DAY
INFLUENT TO WASTE TREATMENT PLANT = PWC,DUPONT, WELLMAN, TECH PROCESS, COOLING TOWER
EFFLUENT = CLARIFER OVERFLOW
TOTAL
DATE SOURCE ZINC FLOW ZINC INFLUENT
(MGD) LBS/DAY ZINC
01/04/2000
01/05/2000
01/07/2000
PWC 0.32 1.290 3.443
DUPONT 0.18 0.018 0.027
WELLMAN 0.20 0.003 0.005
TECH PROCESS 0.05 0.649 0.249
COOLING TOWER 0.69 0.320 1.841
CLARIFIER OVERFLOW 0.24 0.953 1.908
PWC 0.29 1.290 3.120
DUPONT 0.18 0.243 0.365
WELLMAN 0.28 0.002 0.005
TECH PROCESS 0.05 0.632 0.264
COOLING TOWER 0.66 0.431 2.372
CLARIFIER OVERFLOW 0.25 0.850 1.772
PWC 0.26 1.290 2.797
DUPONT 0.42 0.239 0.837
WELLMAN 0.10 0.004 0.003
TECH PROCESS 0.06 0.645 0.323
COOLING TOWER 0.58 0.394 1.906
CLARIFIER OVERFLOW 0.26 0.978 2.121
5.565
6.125
5.866

INFLUENT/EFFLUENT - ZINC LBS/DAY
INFLUENT TO WASTE TREATMENT PLANT = PWC,DUPONT, WELLMAN, TECH PROCESS, COOLING TOWER
EFFLUENT = CLARIFER OVERFLOW
TOTAL
DATE SOURCE ZINC FLOW ZINC INFLUENT
(MGD) LBS/DAY ZINC
01/10/2000 PWC 0.21 1.290 2.259 7.254
DUPONT 0.35 0.260 0.759
WELLMAN 0.06 0.004 0.002
TECH PROCESS 0.61 0.651 3.312
COOLING TOWER 0.33 0.335 0.922
01/12/2000
CLARIFIER OVERFLOW 0.22 1.041 1.910
PWC 0.23 1.290 2.474 5.809
DUPONT 0.60 0.118 0.590
WELLMAN 0.10 0.004 0.003
TECH PROCESS 0.10 0.651 0.516
COOLING TOWER 0.58 0.460 2.225
01/14/2000
CLARIFIER OVERFLOW 0.29 0.957 2.315
PWC 0.29 1.290 3.120 6.352
DUPONT 0.30 0.248 0.620
WELLMAN 0.10 0.004 0.003
TECH PROCESS 0.07 0.633 0.359
COOLING TOWER 0.62 0.435 2.249
01/17/2000
CLARIFIER OVERFLOW 0.28 1.046 2.443
PWC 0.33 1.290 3.550 7.904
DUPONT 0.33 0.214 0.589
WELLMAN 0.11 0.002 0.002
TECH PROCESS 0.26 0.628 1.362
COOLING TOWER 0.63 0.457 2.401
CLARIFIER OVERFLOW 0.23 0.940 1.803

INFLUENT/EFFLUENT - ZINC LBS/DAY
INFLUENT TO WASTE TREATMENT PLANT = PWC,DUPONT, WELLMAN, TECH PROCESS, COOLING TOWER
EFFLUENT = CLARIFER OVERFLOW
TOTAL
DATE SOURCE ZINC FLOW ZINC INFLUENT
(MGD) LBS/DAY ZINC
01/19/2000
PWC 0.35 1.290 3.766
DUPONT 0.34 0.244 0.692
WELLMAN 0.11 0.003 0.003
TECH PROCESS 0.07 0.546 0.301
COOLING TOWER 0.64 0.368 1.964
CLARIFIER OVERFLOW 0.24 0.999 2.000
6.725

PWC INCOMING WATER
1999
MONTH MONTHLY PWC DAILY AVERAGE ZINC Incoming ZINC
(mgd) (MGD) (Ibs/day) (Ibs/month))
JANUARY 44 1.4 3.479 107.85
FEBUARY 40 1.4 3.561 99.71
MARCH 45 1.4 3.585 111.14
APRIL 42 1.4 3.759 112.77
MAY 38 1.2 3.002 93.06
JUNE 46 1.5 3.841 115.23
JULY 43 1.4 3.269 101.34
AUGUST 46 1.5 3.615 112.07
SEPTEMBER 42 1.4 3.258 97.74
OCTOBER 31 1.0 2.218 68.76
NOVEMBER 42 1.4 3.713 111.39
DECEMBER 40 1.3
YTD TOTALS 499 1,131.05
MONTHLY AVG. 42 3.11 94.25

INCOMING ZINC FROM PWC
1998
MONTH MONTHLY PWC DAILY AVERAGE ZINC INF. ZINC MONTHLY (Ibs)
(MGaI/Month) (mgd) (Ibs/day)
JANUARY 44 1.4 2.685 83.23
FEBUARY 40 1.3 2.597 72.73
MARCH 47 1.5 3.292 102.06
APRIL 50 1.6 3.542 106.27
MAY 46 1.5 3.849 119.31
JUNE 47 1.5 3.737 112.11
JULY 48 1.6 3.375 104.62
AUGUST 47 1.5 3.651 113.19
SEPTEMBER 48 1.5 3.508 105.24
OCTOBER 47 1.5 3.318 102.85
NOVEMBER 57 1.9 4.452 133.57
DECEMBER 50 1.6 3.909 121.19
YTD TOTALS 572 1,276.38
MONTHLY 48 3.49 106.37
AVG.

INCOMING ZINC FROM PWC
1997
MONTH MONTHLY PWC DAILY AVERAGE ZINC INF.
(MGaI/Month) (mgd) (Ibs/day)
JANUARY 46 1.5 3.803
FEBUARY 41 1.3 2.635
MARCH 46 1.5 3.040
APRIL 44 1.4 3.086
MAY 46 1.5 3.577
JUNE 48 1.5 3.446
JULY 49 1.6 3.827
AUGUST 42 1.4 2.779
SEPTEMBER 42 1.4 2.968
OCTOBER 41 1.3 2.404
NOVEMBER 38 1.2 2.308
DECEMBER 52 1.7 3.132
YTD TOTALS 536
ZINC MONTHLY fibs)
117.90
73.78
94.23
92.58
110.90
103.39
118.63
86.14
89.04
74.51
69.24
97.09
1,127.43
MONTHLY 45 3.08 93.95
AVG.

INCOMING ZINC FROM PWC
1996
MONTH MONTHLY PWC DAILY AVERAGE ZINC INF. ZINC MONTHLY (Ibs)
(MGaI/Month) (mgd) (Ibs/day)
JANUARY 29.426 0.9 2.058 63.81
FEBUARY 29.426 0.9 2.296 64.28
MARCH 29.426 0.9 2.106 65.28
APRIL 29.426 0.9 2.272 68.16
MAY 29.426 0.9 2.383 73.87
JUNE 29.426 0.9 1.876 56.29
JULY 29.426 0.9 2.153 66.75
AUGUST 29.426 0.9 2.486 77.06
SEPTEMBER 29.426 0.9 1.813 54.39
OCTOBER 29.426 0.9 1.947 60.37
NOVEMBER 29.426 0.9 2.098 62.94
DECEMBER 29.426 0.9 2.351 72.89
YTD TOTALS 353 786.08
MONTHLY AVG. 29 2.15 66

Nov-96
Aug-96
May-96
Feb-96
Nov-97
Aug-97
May-97
Effluent Metals
Feb-97 Nov-98
Date
Aug-98
May-98
Feb-98
1-0—LEAD NICKEL (ZINC —XE—CYANIDE —*—COPPER —111--CHROMIUM]
Nov-99
Aug-99
May-99
Feb-99

Savannah Lab versus Burlington Lab Comparison
STL = SAVANNAH LABS
BR = BURLINGTON RESEARCH
STL BR STL BR STL BR STL BR STL BR
DATE SOURCE ZINC ZINC NICKEL NICKEL LEAD LEAD COPPER COPPER CHROMIUM CHROMIUM
01/04/2000 PWC 0.3100 0.3200 < 0.04 < 0.002 < 0.005 < 0.0002 0.0330 0.0250 < 0.010 0.0007
DUPONT 0.2100 0.1800 < 0.04 0.0060 < 0.005 0.0013 0.0410 0.0370 < 0.010 0.0066
WELLMAN 0.2400 0.2000 < 0.04 0.0090 0.0180 0.0120 0.2300 0.2000 < 0.010 0.0110
TECH PROCESS 0.0570 0.0460 < 0.04 0.0070 < 0.005 0.0005 < 0.020 < 0.002 0.0110 0.0110
CLARIFIER 0.2900 0.2400 < 0.04 0.0100 0.0062 0.0021 < 0.020 0.0060 < 0.010 0.0056
OVERFLOW
COOLING 0.7400 0.6900
TOWER
01/05/2000 PWC 0.3400 0.2900 < 0.04 0.0020 < 0.005 0.0004 0.0330 0.0280 < 0.010 0.0058
DUPONT 0.2300 0.1800 < 0.04 0.0060 < 0.005 0.0018 0.0350 0.0280 < 0.010 0.0110
WELLMAN 0.3700 0.2800 < 0.04 0.0130 0.0320 0.0180 0.3100 0.2700 < 0.010 0.0170
TECH PROCESS 0.0640 0.0500 < 0.04 0.0080 < 0.005 0.0003 < 0.020 < 0.002 0.0130 0.0120
CLARIFIER 0.3300 0.2500 < 0.04 0.0100 < 0.005 0.0029 < 0.020 0.0060 < 0.010 0.0110
OVERFLOW
COOLING 0.8400 0.6600
TOWER
01/07/2000 PWC 0.3100 0.2600 < 0.04 0.0030 < 0.005 0.0002 0.0280 0.0280 < 0.010 0.0048
DUPONT 0.5800 0.4200 < 0.04 0.0170 < 0.005 0.0014 0.0430 0.0340 0.0120 0.0170
WELLMAN 0.1400 0.1000 < 0.04 0.0060 0.0073 0.0055 0.1800 0.1400 < 0.010 0.0150
TECH PROCESS 0.0720 0.0600 < 0.04 0.0070 < 0.005 0.0006 < 0.020 0.0030 0.1000 0.0120
CLARIFIER 0.3500 0.2600 < 0.04 0.0100 < 0.005 0.0030 < 0.020 0.0050 0.0100 0.0088
OVERFLOW
COOLING 0.7700 0.5800
TOWER

DATE
01/10/2000
01/12/2000
01 / 14/2000
01/17/2000
SOURCE
PWC
DUPONT
WELLMAN
TECH PROCESS
CLARIFIER OVERFLOW
COOLING TOWER
PWC
DUPONT
WELLMAN
TECH PROCESS
CLARIFIER OVERFLOW
COOLING TOWER
PWC
DUPONT
WELLMAN
TECH PROCESS
CLARIFIER OVERFLOW
COOLING TOWER
PWC
DUPONT
WELLMAN
TECH PROCESS
CLARIFIER OVERFLOW
COOLING TOWER
Savannah Lab versus Burlington Lab Comparison
STL = SAVANNAH LABS
BR = BURLINGTON RESEARCH
STL BR STL BR STL BR STL BR STL BR
ZINC ZINC NICKEL NICKEL LEAD LEAD COPPER COPPER CHROMIUM CHROMIUM
0.2600 0.2100 < 0.04 0.0030 < 0.005 0.0003 0.0310 0.0290 < 0.010 0.0047
0.4500 0.3500 0.04300 0.0340 < 0.005 0.0016 0.0340 0.0270 < 0.010 0.0130
0.0800 0.0640 < 0.04 0.0040 < 0.005 0.0031 0.0760 0.0660 < 0.010 0.0130
0.8200 0.6100 < 0.04 0.0130 < 0.005 0.0027 < 0.020 0.0100 0.0210 0.0140
0.3000 0.2200 < 0.04 0.0150 < 0.005 0.0027 < 0.020 0.0050 < 0.010 0.0120
0.6800 0.3300
0.2600 0.2300 < 0.04 0.0660 < 0.005 0.0002 < 0.020 0.0160 < 0.010 0.0180
0.7600 0.6000 0.0970 0.0860 0.0053 0.0019 0.0380 0.0320 < 0.010 0.0110
0.1600 0.1000 < 0.04 0.0050 0.0083 0.0038 0.0740 0.0630 < 0.010 0.0110
0.1200 0.0950 < 0.04 0.0220 < 0.005 0.0003 < 0.020 0.0020 0.0110 0.0160
0.3900 0.2900 < 0.04 0.0210 < 0.005 0.0024 < 0.020 0.0050 < 0.010 0.0089
0.7200 0.5800
0.3000 0.2900 < 0.04 < 0.002 < 0.005 0.0003 0.0300 0.0290 < 0.010 0.0092
0.3700 0.3000 0.0480 0.0460 < 0.005 0.0012 0.0230 0.0200 0.0120 0.0160
0.1600 0.0970 < 0.04 0.0140 0.0140 0.0100 0.3000 0.2100 < 0.010 0.0130
0.0820 0.0680 < 0.04 0.0120 < 0.005 0.0002 < 0.020 0.0020 0.0120 0.0160
0.3500 0.2800 0.1600 0.1500 < 0.005 0.0031 < 0.020 0.0060 < 0.010 0.0160
0.7300 0.6200
0.3800 0.3300 < 0.04 < 0.002 < 0.005 0.0003 0.0480 0.0490 < 0.010 0.0074
0.3900 0.3300 0.0460 0.0420 < 0.005 0.0013 0.0350 0.0330 < 0.010 0.0170
0.1400 0.1100 < 0.04 0.0330 0.0067 0.0049 0.1400 0.1200 < 0.010 0.0140
0.0790 0.2600 < 0.04 0.0850 < 0.005 0.0042 < 0.020 0.0080 0.0180 0.0140
0.3300 0.2300 0.0980 0.0140 0.0054 0.0017 < 0.020 0.0040 0.0110 0.0240
0.7000 0.6300

DATE
SOURCE
01/19/2000 PWC
DUPONT
WELLMAN
TECH PROCESS
CLARIFIER
OVERFLOW
COOLING TOWER 0.7100 0.6400
Savannah Lab versus Burlington Lab Comparison
STL = SAVANNAH LABS
BR = BURLINGTON RESEARCH
STL BR STL BR STL BR STL BR STL
ZINC ZINC NICKEL NICKEL LEAD LEAD COPPER COPPER CHROMIUM
0.3700 0.3500 < 0.04 < 0.002 < 0.005 0.0003 0.0480 0.0490 < 0.010
0.3800 0.3400 0.0450 0.0430 < 0.005 0.0012 0.0370 0.0330 < 0.010
0.1400 0.1100 < 0.04 0.0050 0.0097 0.0050 0.1500 0.1200 < 0.010
0.0740 0.0660 < 0.04 0.0120 < 0.005 0.0005 < 0.020 < 0.002 0.0180
0.3300 0.2400 0.0950 0.0890 0.0076 0.0042 < 0.020 0.0080 0.0100
BR
CHROMIUM
0.0057
0.0150
0.0140
0.0180
0.0150

ATTACHMENT II

02/U3/UU 17:0 FAA 314 b 4 Sbzu tan ruusLmiiur =AM
410 c Pic it
- C.PS Res gsik-RoA .•
jsubpartj}Direct Discharge Point Sources That Use End -of -Pipe Biological
Treatment
§414.90 Applicability; description of the subcategory of direct discharge 4)
see ywt.A
%skis ego$
Monpuelo
point sources that use end -of -pipe biological treatment.
The provisions of this subpart are applicable to thepr e s wastewater
discha !es resulting from the manufacture of the OCPSF . • • . •�w • rodu_ct
-,•�...:
blot ical Tel or installs end -of -pipe biological treatment to comply with
BPT effluent Iiintitations.
§414.91 Toxic pollutant effluent limitations and standards for direct
discharge point sources that use end -of -pipe biological treatment,
(a) Any point source subject to this subpart must achieve discharges not
exceeding the quantity (mass) determined by multiplying the process wastewater
flow subject to this subpart times the concentrations in the following table.
(b) in the case of chromium, co er lead nickel -nc and total nide, the
discharge quantity (mass s all be determined by multiplying the concentrations
listed in the following table for these pollutants times he ew from meta rft�
waste streams for thungla and times the flow from cyanide bearing waste
streams for total cyanide. The metal -be rim waste streams and _ ani�ear 9
waste streams are de tr�ea .
•
eta —plus any additi a PSF process wastewater streams identified by the
perrnitting.authority on a case -by -case basis as metal or cyanide bearing based
upon a determination that such streams contain significant amounts of .the
pollutants identified above. Any such streams designated as metal or cyanide
bearing must be treated independently of other metal or cyanide bearing waste
screams unless the permitting authority determines that the combination of such
streams, prior to treatment, with the Appendix A waste streams will result in
substantial reduction of these pollutants. This determination must be based upon
a review of relevant engineering, production, and sampling and analysis
information.
Effluent characteristics
.
Effluent limitations BAT and
NSPS1
Maximum for
any one day
Maxinsim for
for any
monthly
average
• 22
Acenaphdhene
`�
Acenaphthylone
59
_ 22
Ada rlonitrlte —
242
� 96
Antluacene
•
s9
22
Benzene
135
_ _ 37
8enzo(a)anthracene —
59
22
_
3,47Benzotiuoranthene
61 '
23
Benzo(k)flucian hene •
59
22

02 03/00 17:48 FAi 314 8U4 66ZU t,Jn rug: i-uiu' iLLa
•
•
ihionocarbamates, N-Ethyl-o-isopropyl/isopropyl xanthate + Ethylamine
Toluene diamine (mixture)/Catalytic hydrogenation of dinitrotoluene
Methylated urea -formaldehyde resins (textile)/Methylation of urea -formaldehyde adduct
Methylated urea -formaldehyde glyoxol (textile resin)/Reaction of methylated urea -formaldehyde +
glyoxal
—47` Zinc "
Methylhydroabietate, diets -alder adducts/Derivatives of abietic esters from rosin
Acrylic resins/Emulsion or solution polymerization to coatings
Acrylic resins (latex)/Emulsion polymerization of acrylonitrile with polybutadiene
Acrylic fibers (85% polyacrylonitrile) by solution polymerization/Wet spinning
® -Goo, 40,04:x A,
-f-o 1..tP.44 414
p7'E rmAtecsekgt
Alkyd Resins/Condensation polymerization of phthalic anhydride + glycerin + vegetable oil esters 5 r0A- 1104
Benzene/By-product of styrene by ethylbenzene dehydrogenation
Benzene/By-product of vinyl toluene (from ethyltoluene)
n-butyl alcohol/Hydrogenation of n-Butyraldehyde, Oxo process
Coumarin (benz-a-pyrone)/Salicylaldehyde, Oxo process
Cycloparaffins/Catalytic hydrogenation of aromatics in kerosene sotvent
Dithiocarbamates, zinc salt/Reaction of zinc oxide + Sodium dithiocarbamates
Dialkyldithiocarbamates, metal salts/Diakylamines + Carbon disulfide
Dithiocarbamates. metal salts/Dithiocarbamic acid + metal oxide
1 hiuram (dimethyldithiocarbamate) hexasulfide/DimethyIdithiocarbamate
Fluorescent brighteners/Coumarin based
Ethyl acetate/Redox reaction (Tschenko) of acetaldehyde
EthyibenzenelBenzene alkylation in liquid phase
Ethylbenzyl chloridc/Chloromethylation (Hydrogen chloride + formaldehyde, zinc
ethylbenzene •
2-Ethyl hexanol/Aklol condensation -hydrogenation of n-Butyraldehyde
Glyoxal-urea formaldehyde textile re-sin/Condensation to N-bis (hydroxymethyl) ureas + N,N'-
(Dihydroxyethyl) ureas
Isobutanot/Hydrogenation of isobutyrakiehyde, Oxo process
IsopropanoUCatalytic hydrogenation of acetone
Methallylidene diacetate/Condensation of 2-Methypropenal + acetic anhydride
Methanot/Low pressure sythesis from natural gas via synthetic gas
Methyl chloride/Hydrochlorination of methanol
Methylethyl ketone/Dehydrogenation of sec-Butanol
Naphthenic acid salts
Nylon
Nylon 6 & 66 copolymers/Polycondensation of Nylon salt + Caprolatam
Nylon 6 fiber/Extrusion (melt spinning)
Oxo alcohols, C12-C15/Hydroformylation & hydrogenation of.C11-C14 olefins
Phenolic urethan resins/Phenol + excess formaldehyde + Methylene aniline diisocyanate
Polystyrene (crystial) modified/Polystyrene + sulfonation, chlorornethylation and/or amination
Rayon/1r fscose process
SAN resin/Emulsion polymerization
Silicones: Silicone rubbers/Hydrolysis and condensation of chlorosilanes
Silicones: Silicone specialties (grease, dispersion agents, defoamers & other products)
Silicones_ Silicone resins/Hydrolysis & condensation of methyl, phenyl & vinyl chlorusilanes
Silicones: Silicone fluids/Hydrolysis of chlorosilanes to acyclic & cyclic organosloxanes
Stearic acid, metal salts/Neutralization with a metallic base
Styrene/Dehydrogenation of ethylbenzene
Styrene-butadiene resin/Emulsion polymerization
Vinyl acetate/Reduction of acetylene + acetic acid
Vinyl toluene/Dehydrogenation (thermal) of ethyltoluene
Xylenes, mixed/By-product vinyl toluene (from ethyltoluene)
Cyanide
+ sulfur
�a
(es 1.1 , d +,saet'
p c- Pi F
chloride) of

MONSANTO
Food • Health • Hope
February 9, 2000
Mr. Paul Rawls
NC DENR
Division of Water Quality
Wachovia Building, Suite 714
Fayetteville, NC 28301-5043
Dear Mr. Rawls:
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILLE, NORTH CAROUNA 28302
PHONE [phone]o0
Thank you for giving us the opportunity to discuss the Zinc issue with Ms. Kramer and
yourself. Per your request and in support of clarifying the water usage transition history
from river water to the PWC water the tables below are attached.
River
PWC
Total Water Used
% River Water Used
% PWC Water Used
1996
1997
1998
1999
% Zinc Increase
from 1996 to 1999
Water Usage
1996 MGD 1997 MGD
269 52
353 536
622
43%
57%
Lbs/Day
588
9%
91%
Incoming Zinc
Lbs/Month
1998 MGD
6
572
578
1%
99%
1999 MGD
0
499
499
0%
100%
LbslYear
2.15
3.08
3.49
3.11
31%
66
94
106
94
30%
786
1127
1276
1131
31%
We hope that this data will further indicate the basis of conclusions we have drawn and
shared with you and indicated in our letter to Mr. Dave Goodrich on February 3, 2000.
sms
Attachments
xc: Mr. Dave Goodrich
Ms Susan Wilson
Ms. Shannon Langley
•
.
Manhar N. Patel
Environmental Safety Health
Business Unit Manager

MONSANTO
Food • Health • Hope
1
June 28, 2000
Ms. Christy Jackson
N. C. Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES #0003719 PERMIT RENEWAL APPLICATION
MONSANTO COMPANY
AGRICULTURAL SECTOR
P.O. Box 2307
CEDAR CREEK ROAD
FAYETTEVILIE, NORTH CAROUNA 28302
PHONE19101323-3300
Enclosed please find a copy of the renewal application for the Monsanto Fayetteville
Plant NPDES permit. Per the requirements of North Carolina General Statute
143.215.1 and under Section B. General Conditions, Item #10 of the current permit,
this application is being submitted more than 180 days prior to the current permit
expiration date of December 31, 2000.
The information included in this application addresses the current plant configuration
and identifies anticipated expansions during the life cycle of the permit. Monsanto
is anxious to assist NC DENR in renewing this permit in a timely and appropriate
manner. To that end, we respectfully request that you provide us with a written
statement of completeness within 30 days of receipt of this application.
Additionally, we are willing to provide an overview of the submittal and a tour of the
plant to your permit writer. Ruth Trotman, Environmental Coordinator (433-4242)
and Hope Walters, Waste Treatment Specialist (435-4237) of my staff are available
should you have questions concerning this renewal application.
Thank you for your cooperation in this effort.
Deborah R. Small
Plant Manager
Enclosure
I ^«
H, L; . J U N 2 9 2000
L.

INTRODUCTION
• General Information
Monsanto Company (Monsanto) operates an industrial manufacturing facility in Fayetteville, North
Carolina in Cumberland County which produces herbicide products. Wastewater discharges from the
facility are regulated under the National Pollutant Discharge Elimination System (NPDES). Monsanto is
currently operating under NPDES permit number NC0003719.
Monsanto is authorized to discharge from one final outfall (002) directly to the Cape Fear River. The
stormwater outfall (001) mixes with 002 as it enters the river. The outfall line is submerged and extends
approximately 80 feet offshore. The discharge depth of the outfall pipe is approximately 20 feet below
the surface.
The following information and the NPDES Application Form - Standard C, Major Manufacturing or
Commercial Facilities are being submitted for permit renewal 180 days prior to the expiration of the
existing permit.
This information has been compiled and presented in order to facilitate a thorough and timely review by
the NC DENR, Water Quality Division.
• Site Location and Property Description
The Monsanto Fayetteville facility is located between Highway 53E/210S and the north bank of the Cape
Fear River. It is located on approximately 228 acres of land of which 60 are developed and 168 remain
undeveloped. See Tab Location Map for the location of the permitted outfalls including stormwater
outfalls.
• Description of Outfalls
Monsanto is currently required to monitor discharges from three outfalls, 001, 002 & 003. Outfall 003 is
the discharge from the incinerator operation and has been shutdown. A brief waste stream description
for each outfall follows.
Outfall A - Consists of stormwater runoff from the parking lot, paved areas around the
warehouses, electrical substations and roof drains from the administrative and storage buildings.
Outfall B1 - Consists of stormwater from the paved roadway used for in -plant transportation.
Outfall B2 - Consists of from the paved roadway used for in -plant transportation, roof drains,
and the paved areas just north of the Roundup® process area and adjacent to the maintenance
shop.
Outfall B3 - Consists of stormwater from an enclosed and diked raw material storage facility
and a diked area surrounding an abandoned, empty storage tank.
Outfall C - Consists of stormwater from the railroad spurs used to transport materials. No
unloading activities occur in this area.
Outfall D - Consists of stormwater from railroad spurs used to transport materials. No
unloading activities occur in this area.

0
Outfall E - Consists of stormwater from a building that is abandoned. At one time it was used
for a reverse osmosis process for water treatment.
Outfall F - Consists of stormwater from developed and undeveloped land throughout the plant
property including the plant process areas. This water discharges to Outfall 001.
Outfall G - Consists of stormwater from activities associated with waste water treatment basins,
fuel oil storage and paved roadways used for in plant transportation.
Outfall 001- Consists of stormwater from developed and undeveloped land throughout the
plant property including the plant process areas. This water discharges to the Cape Fear River.
Outfall 002 - Consists of sanitary waste, treated process waste from the Glyphosate process
areas, utility wastewater, scrubber effluent, cooling tower blowdown, boiler blowdown, steam
condensate and sanitary and treated process waste from two adjacent facilities, DuPont and
Wellman.
Outfall 003 - Consists of pH control and filtration units installed on the glyphosate
incinerator/wet wash scrubber system. This system is no longer in operation. Monsanto
requests the removal of this outfall from the new permit.
Extensive sampling was conducted for all outfalls and submitted with the permit renewal application in
1992. Outfalls A through G indicated low levels or less than detectable amounts of pollutants. Based on
this documentation the State decided that stormwater sampling would only be required from Outfall 001.
For ease of accessibility, this sample is taken from the manhole designated SW-1 which is immediately
upstream from Outfall 001.

PRESENT OPERATING STATUS
The wastewater collection and treatment network consists of the following key systems: Outfall 001
stormwater and Outfall 002 effluent from the biotreatment system. The two are segregated until the flows
reach the Outfall box at the river, they then mix together and are discharged to the river via the same pipe.
These systems are described below:
Monsanto's Fayetteville wastewater treatment system is an activated sludge treatment sludge which
consists of equalization, pH adjustment and nutrient addition, aeration, clarification and sludge digestion
and disposal. The waste treatment system treats industrial and sanitary discharges from three chemical
production companies: Monsanto's Roundup® facility, DuPont, andWellman Chemical. This wastewater
must be treated prior to its discharge to the Cape Fear River.
The wastewater treatment method used is a biological process that is divided into five steps:
1. Collection and equalization of raw wastewater
DuPont and Monsanto chemical wastewater travel through separate lines into either of two Equalization
(EQ) Tanks. These Equalization tanks have a capacity of 660,500 gallons each or a combined storage of
1,300,000 gallons. The combined flow is then metered into the pH Control pit. The Chem -Lift station
collects chemical waste flows from Wellman and a Monsanto utilities sump but bypasses EQ tanks for the
pH Control Pit. The only other wastewater treated is domestic sewers from Wellman and Monsanto that
directly enter the biological aeration basins.
2. pH adjustment and nutrient addition
The pH Control Pit is divided into two chambers for nutrient and rough pH adjustment, followed by oil
and grease removal along with fmal pH adjustment. Caustic is added in the first chamber to adjust the
pH. Anhydrous ammonia is also added in the first chamber as a nutrient. Defoaming chemicals can also
be added at this point as needed. The capacity of the pH Control pit is 120,000 gallons.
3. Aeration
Activated sludge is used by the biotreatment system to process wastes. The raw wastewater is combined
with air and microorganisms and the soluble wastes are oxidized through biochemical reactions. This
reduces the `oxygen demand' of the water so it can be safely discharged. There are two aeration basins
that are operated in a modified series mode; i.e., most of the wastewater passes through the first basin
and then the second basin, though a small stream of raw wastes is diverted directly to that second basin.
Additional oxygen is needed during the summer months. An oxygen system has been added to aeration
basin 1. It is used on an as needed basis. The capacities of the basins are as follows; aeration basin 1
has a capacity of 3,500,000 gallons and aeration basin 2 has the capacity of 1,200,000 gallons.
4. Clarification
After several days of detention time, this activated sludge is then settled in a clarification process to
remove suspended solids from the treated water. Sometimes the solids don't settle very well, therefore
coagulant - Nalco 8185 is added at the distribution box where the flow is leaving aeration basin 2 and
entering the clarifier. This allows for improved settling of solids and less solids in the effluent stream.
This clarified effluent is discharged into the Cape Fear River. The concentrated solids are recycled back
into the aeration basins in order to maintain a `steady state' waste treatment operation. This is return
activated sludge (RAS). However, because the microbes are feeding on the wastewater chemicals, their
biomass is growing. Therefore a waste activated sludge (WAS) stream is diverted from the RAS for
further treatment. The capacity of this 90 foot clarifier is 700,000 gallons.
5. Aerobic sludge digestion and disposal
Excess biomass is oxidized by aerating the WAS (waste activated sludge) in basins without influent feed.
This reduces the amount of solids that have to be disposed. WAS is treated in two digester basins that
8

are configured in a series operation. The capacity of digester 1 is 375,000 gallons and the capacity for
digester 2 is 550,000 gallons. After several weeks of detention time, the sludge is pumped to a sludge
storage basin. The sludge storage basin has a capacity of 1,000,000 gallons. After settling, the sludge is
pumped to sludge drying beds for dewatering or is pumped into tanker trucks and taken to surrounding
permitted farms for land application. There are three sand drying beds with a capacity of 100,000
gallons each. All decant from the storage basin and beds is returned to the aeration basin 2. The solids
from the drying beds and/or liquid sludge from the sludge storage basin (3-5 % solids) are land applied
per NC permit WQ0001959.
9

DESCRIPTION OF MANUFACTURING PROCESSES
• Glyphosate Manufacturing Facility
Glyphosate is the active ingredient in Roundup® herbicide and is manufactured in the glyphosate
technical production unit. This unit uses Glyphosate Intermediate (GI) (produced at another
Monsanto location) to produce glyphosate in either a powdered form (which is packaged as a
bagged product) or the liquid isopropylamine salt of glyphosate. The unit oxidizes GI in the
presence of a catalyst to form glyphosate; the isopropylamine salt of glyphosate is formed by
reacting glyphosate with isopropylamine. Formaldehyde is in the wastewater influent to the
biotreatment system for removal; however, virtually all of it is biodegradable. Salts of
phosphoric (and phosphorous) acid will be present in measurable quantities, after neutralization,
in the wastewater effluent because of the nature of the manufacturing sources. Additionally
formic acid is in the wastewater sent to the biotreatment system for removal. Other discharges
to waste treatment include scrubber blowdown, evaporator discharges and reactor purge that can
contain trace amounts of the chemicals listed above.
Dry Ammonium Glyphosate Facility
The glyphosate formed in the glyphosate manufacturing facility is further processed in the dry
ammonium glyphosate production facility. Glyphosate is reacted with aqua ammonia to form
ammonium glyphosate. Sodium sulfite can be added after reaction to inhibit the formation of an
impurity. Sulfuric acid is used as a pH adjustment for the dry ammonium glyphosate scrubber.
Discharges to the wastewater treatment system can include scrubber blowdown, and trace
amounts of the chemicals listed above.
Wellman
Partially Oriented Yarn (POY) is produced from fiber grade polyethylene terephthalate (PET)
resin manufactured at Wellman's Palmetto plant in Darlington, SC. The resin is trucked to the
Fayetteville Wellman Plant where it is dried and heated under pressure to approximately 300°C.
The resin is then extruded through die plates, cooled with air, sprayed with a lubricating finish
and wound onto a paper tube. The finished product is a 45 pound bobbin of undrawn POY yarn
which is shipped to customers.
DuPont
Batch Plant Operations:
The Batch Plant was constructed in 1975 and uses dimethyl terephthalate (DMT) and ethylene
glycol (EG) as the basic raw materials. The Batch Plant produces primarily film grade
polyethylene terephthalate (PET) but small quantities of other specialty polymers are also
produced in the batch reactors.
Ten reactor trains are used for the batch esterification and polymerization processes. EG and
EG prepared with process catalysts and additivies are mixed with DMT in the esterinterchange
reactor where the polymerization process is initiated. This reaction is conducted in two stages,
the first at atmospheric pressure and the second under vacuum. During the esterification step,
methanol is generated and removed from the process. The methanol is collected and returned to
the DMT manufacturer for recycle. Upon completion of the esterification step, the mixture is
transferred by pressure into another vessel for polymer addition where the polymer chain is
10

lengthened. The PET polymer from this process is extruded, quenched and cut into chips which
are transferred to silos for storage prior to shipment to customers.
Crude EG, which is recovered from the esterification and polymerization processes, is purified
by the batch process in two distillation columns. This recovered EG is then reused to make
additional PET.
Continuous Polymerization (CP) Plant
The CP Plant was constructed in 1995 and started up in January 1996. Raw materials for the
continuous process include terephthalic acid (TA), EG and isophthalic acid (IPA). EG is
combined with TA and IPA to make a slurry, which is fed to the esterifier where it is heated to
make an oligomer. The oligomer is transferred to the polymerization, and polymerization takes
place in several steps involving additives and heat. In the final stages of polymer fmishing, the
polymer is filtered, extruded, quenched, chipped, dried and sent as polymer chips to the Solid
State Process (SSP). The SSP involves heating the PET chip to modify the polymer chain.
Upon completion of the SSP, the chips are placed in silos prior to shipment to customers.
Supporting Facilities
The above facilities also generate wastewater which does not come in contact with process
contaminants. These non -contact streams include demineralized water treatment blowdown,
boiler blowdown and cooling tower blowdown. In addition, there are sanitary wastes streams
which are routed to the biological treatment system Other contributions to wastewater include
scrubber effluent, laboratory activities, wash down from maintenance activities such as steam
cleaning of equipment and minor leaks from equipment being repaired. For general
housekeeping purposes and to clean residual amounts of minor leaks and spills, various areas of
the plant are periodically washed by spraying them down with water. This water is routed
through a process area chemical sewer to the biotreatment system.
The following list of chemicals further identifies compounds which may be present in the
discharge.
a) Ammonia may be added as a nutrient to the biological treatment plant and may be present at
low levels in the sanitary wastewater. It is neutralized before discharge.
b) Chlorine may be used to disinfect cooling towers.
c) Sodium hydroxide is used as a neutralizing chemical and its salts, for example a sodium
phosphate, will be in the wastewater effluent.
d) Sulfuric acid, as a neutralized salt such as sodium sulfate, will be in the wastewater effluent.

POTENTIAL FACILITY CHANGES
Monsanto expects the facility will continue to undergo modifications in the upcoming permit term. These
modifications will consist of production expansions, as well as changes to utility/treatment systems. The
Fayetteville facility is proposing to incorporate these changes in two phases, of which Phase II is in three
parts depending on which expansions take place. In lieu of a permit modification, Monsanto requests to
send a letter of notification to begin using the new proposed permit limits as outlined in the tab "Permit
Methodology" as each phase occurs.
Phase I
Phase I is proposed as the current permit limitations. During the term limit of Phase I it is anticipated
that process improvements will contribute to incremental production increases. However, Monsanto will
be able to operate within the constraints of the Phase I permit limits.
Phase II (A, B & C)
/L-03
� Phase A -Glyphosate Tech Expansion (96 MM lbs)
Phase B - DuPont Expansion (495 MM lbs)
Phase C - Glyphosate Tech and DuPont Expansion
• Conventional Tech
Modification of one of the existing evaporator systems is planned for 2002 - 2004 and will
increase the production to an annual rate of 96M. An increase of 9,000 lbs/hr of water is
expected with this phase.
• DuPont
Projected production rates for the next four years will more than double current production as
listed in the chart below. Projection of waste load allocation is available in the attached
proposed limits section.
Total Site Production X (1000
lbs.)
Change relative to
1999
2000
380,000
+121,000
2001
445,000
+186,000
2002
495,000
+236,000
2003
495,000
+236,000
2004
545,000
+286,000
• Wellman
No anticipated changes for the next five years.
Company Confidential

•s
0.16
0.007
POTABLE
WATER
0.09
0.0035
0.06
DUPONT
PROCESS
0.206
0.0035
WELLMAN
PROCESS
0.032
SANITARY
0.034
0.01
0.74
0.468
SOFTENER
DEMIN.
WATER
BLOWDOWN
0.37
0.01
EFFLUENT
TREATMENT
0.740
ATMOSPHERE
.024
TECH./DRY/FORM
PROCESS
0.37
BOILER
.37
.04
BLOWDOWN
PROCESS
0.33
.002
COOLING
TOWER
0.022
ATMOSPHERE
0.41
PWC 1.377 MGD
FIRE
POND
t
ATMOSPHERE
.002
BLOWDOWN
.058
X WATER FLOW RATES ARE BASED
ON 1999 ACTUAL FLOW DATA
PRODUCT
• .020
STORM WATER
OUTFALL 001
ATMOSPHERE
0.012
4---X = SAMPLE POINT
DISCHARGE
002
0.972 MGD
x
TO
RIVER
HIHr REVIEV AI CCINENTS
B�
A
8R
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PLANT BOUNDARY ; — - --
WWI' 55
DRAINAGE AREA 2 1
APPROX. 6,4 ACRES t
t OK IMPERVIOUS
ALPHA AVENUE
BRAVO AVENUE
CHARLIE AVENUE
DELTA AVENUE
ECHO AVENUE
FOXTROT AVENUE
GOLF AVENUE
HOTEL AVENUE
INDIA AVENUE
JULIETTE AVENUE
WELLMAN
ppyrl�Ipolr(Eei
FENCED NNID
PARKING
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DRAINAGE AREA 14
\\ APPROX. 56 ACRES
07. IMPERVIOUS
TWELFTH STREET
ELEVENTH STREET
TENTH STREET
/
J
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STA 'TION'
EIGHTH STREET
PARKING
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STATION
FRAINAGE AREA 4
PROX, 8,6 ACRES
40% IMPERVIOL�
10,4144E 10E11 IS
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244 *[144144
SEVENTH STREET
OUTFALL
H
PARKING
IPA AILCAR
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STORES
DRAINAGE AREA 3
APPROX. 23.2 ACRES
64% IMPERVIOUS
0
PROPERTY
LINE TYP.
DRAINAGE AREA
APPRQX. 5.8 A
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0
AI T. SHOP
DRAINAGE AREA 5
APPROX. 7,1 ACRES
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DRAIN E AREA 7
APPRO)1 60 ACRES
32X Ifs ERVIOUS
ECHO AVN.
WASTE TREATMENT
RIVER WATER • PLANT
INTAKE • _ OUTFALL
RIVER
CAE
SIXTH STREET
FIFTH STREET
FOURTH STREET
setAt
/
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131
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1
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�DRAINAGE AREA 12
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//' 4Z IMPERVIOUS
t
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1 :LL
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FIRST STREET
DRAINAGE AREA 11
APPROX.1ACRE
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SCALE: 1"
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BY
DATE
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SITE PLAN
FAYETTEVILLE SITE
DRAWN
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DESIGNED
E.ANO.
` BT
PLANT
DATE
' ZE
APPROVED DATE
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APPROVED
NUMBER
DATE
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743
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11
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DESIGN FILE NAME
PRINTS ISSUED TD FIELD BT DATE RC V A IG5-D
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PRODUCTION DATA (POUNDS)
Monsanto:
1997
Dry Ammonium Glyphosate
7,954,845
Glyphosate Technical
61,067,967
1998
Dry Ammonium Glyphosate
20, 646,148
Glyphosate Technical
64,388,928
1999
Dry Ammonium Glyphosate
25,089,776
Glyphosate Technical
59,499,147
DuPont:
Polyethylene Terephthalate (PET)
1997
363,000,000
1998
355,000,000
1999
259,000,000
Wellman:
Partially Oriented Yarn
1997
143,410,600
1998
120,060,700
1999
118,129,300
Company Confidential
16