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Home My WebLink AboutNC0003719_Wasteload Allocation_19870828NPDES DOCUHENT SCANNING COVER SHEET NC0003719 Cedar Creek site WWTP NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Staff Comments Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: August 28, 1987 This document is printed on reuse paper - igrzore any content on the reirerse side PERMIT NO.: NCO° o 3 "j 13 FACILITY NAME: rn v n s anr60 Facility Status: / EXISTING) PROPOSED (circle one) NPDES WASTE LOAD ALLOCATION Permit Status RENEW, MODIFICATION UNPERMTTED NEW (circle one Major Minor Pipe No: o° o v Z) pv 3 vui; o,�i Design Capacity (MGD)• OO;z; t, 7' pc3e o,03 Domestic (% of Flow)- Industrial (% of Flow)- / 0 0 Comments - RECEIVING STREAM: pock. r rP v e r Class- C, Sub -Basin- 0 3- 0 G' -IS-- Reference USGS Quad: H n� 3 (please attach) County: C um Ley' 1cc Regional Office: As Fa Mo Ra Wa Wi WS (circle one) Requested By: b • OU e fc c sl-. Prepared By: t • V 0c(t Reviewed By: Date - Date: Date: Modeler Date Rec. # 3 5ii1, 1 ` a-23/ 4,4,c Drainage Area (mil) 3 i' Avg. Streamflow (cfs)- 7Q10 (cfs 7qf Winter 7Q10 (cfs) 30Q2 (cfs) Toxicity Limits: IWC �' 7 % (circle one) 7 / Chronic Instream Monitoring: CB/� -6eryi.0l7 ) .0 .� ODj Parameters Upstream Location Downstream Location Cii•idaC 4/7/— ee ,�,� Ca s i7E s Effluent Characteristics Summer Winter BOD5 (mg/1) NH3 N (mg/1) , D.O. (mg/1) ,-1 TSS (mg/1) F. Col. (/100m1) /( j e, pH (SU) ? /lin ED Comments: Jet- 6c-iluL1 eD S la e r r7Lir c� � --------------------- WASTELOAD ALLOCATION APPROVAL FORM Permit Number ~ Facility Name Type of Waste Status Receiving Stream Stream Class Subbasin County Regional Office Requestor Date of Request Quad NC0003719 MONSANTO INDUSTRIAL EXISTING CAPE FEAR RIVER C 030615 CUMBERLAND FAYETTEVILLE D. OVERCASH 4-11-85 : Wasteflow (mgd): 5-Day BOD (mg/l): Ammonia Nitrogen (mg/l): Dissolved Oxygen (mg/l): TSS (mg/1): Fecal Coliform (0/100ml): pH (SU): Upstream (Y/N): Y Downstream (YIN): Y . Request No. :2231 ______________ Drainage Area (sq mi) : 4395 Average Flow (cfs) : 43q ~ MCA �e Summer 7010 (cfs) : 791 ��J ) \� �c�J-1i J Winter 7010 (cfs) : 30Q2 (cfs) : �� -��.i� w�"� �'^�°°` MONITORING IMITS Location: SEE ATTACHED MAP ` Location: SEE ATTACHED MAF ---------------------------------- COMMENTS ------------------------------- RECOMMEND UPSTREAM/DOWNSTREAM MONITORING FOR TEMPERATURE, LV7? ]XYGE BOD5 AND CONDUCTIVITY - , , _ � Recommended by Reviewed by: Tech. Support Supervisor I Regional Supervisor Permits & Engineering 9� _ 2__ _'�� Ca^ - �(z Y/�7 RETURN TO TECHNICAL SERVICES BY 4C+041 1Jes;yn c“,t,t Via it S O h 01- I,? C C vlic,T /1415� +tt e, C K4Q o÷ I vole, e. o (MIXING ZONE) • Facility Name NO.4,3 fr6O rld(Ai /s 9. H. /Y) t;-A . tiowevr/', fey'' a tee 4 ,P6-/yJ 0,73 ' flr1 i s �� c /,.eir, "WC- c v a �I oyc.,40,10.e. oaI /no ✓I5 C ,7 '` t,s"e C� vwCVC/��tKG Sa i /e. at Permit it NG DOO 37/ TOXICITY TESTING REQUIREMENT The permittee shall conduct acute toxicity tests on a basis using protocols defined in E.P.A. Document 600/4-85/013 entitled "t.- Acute Toxicity of Effluents to Freshwater and Marine Organisms". The mon oring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test, using effluent collected as a 24 hour composite. There may be no sig- nificant mortality in an effluent concentration of 95Z. Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The first test will be performed within thirty days from issuance of this permit. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Technical Services Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine must be measured and reported if chlorine is used for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indi- cate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited docu- ment, such as minimum control organism survival and appropriate environmen- tal controls, shall constitute an invalid test and will require immediate retesting. Failure to submit suitable test results will constitute a fail- ure of permit condition. 7Q10 79' / cfs Permitted Flow 0.73 MGD Basin & Sub -Basin 0 3- O G`/ Receiving StreaipCc,,/oe ft ct /' I v e r County rurnh•he Recommend by• Date WLA # 2231 Limits for Monsanto (NC0003719) Pipe 001 Daily Avg. Daily Max. Flow (MGD) 0.15 TSS (lbs/day) 37.5 pH (S.U.) 6-9 No zinc or copper added to the cooling water Monitoring: Chromium, Residual Chlorine, Zinc 56.3 6-9 Pipe 002 Summer Winter Daily Avg. Daily Max. Daily Avg. Daily Max. Flow (MGD) 0.70 0.70 BOD5 (lbs/day) 350 700 700 1400 NH3-N (lbs/day) 23 46 46 92 TSS (lbs/day) 623 1208 641 1242 COD (lbs/day) 3470 5608 4715 7624 DO (mg/1) 5 5 5 5 pH (S.U.) 6-9 6-9 6-9 6-9 Monitoring : Fecal Coliform, Total Nitrogen, Total Phosphorus, and Glyphosate Pipe 003 Daily Avg. Daily Max. Flow (MGD) 0.03 BOD5 (lbs/day) 5 10 NH3-N (lbs/day) 1 2 TSS (lbs/day) 67 134 COD (lbs/day) 40 80 DO (mg/1) 5 5 pH (S.U.) 6-9 6-9 Monitoring: Glyphosate Pipes 001, 002, 003: Discharge shall not increase the receiving water's temperature by more than 2.8°C and in no case cause it to exceed 32°C. Facility Name Permit # fJc_0037/7 TOXICITY TESTING REQUIREMENT . The permittee shall conduct acute toxicity tests on a A. 0 f. basis using protocols defined in E.P.A. Document 600/4-85/013 entitled " Acute Toxicity of Effluents to Freshwater and Marine Organisms". The monitoring shall be performed as a Daphnia pulex or Ceriodaphnia ifs hour static test, using effluent collected as a 24 hour composite. The Lc50 of this effluent usi g the previously stated methodology may not at any time be less than I�'%. Effluent samples for self -monitoring purposes must be obtained dur- ing representative effluent discharge below all waste treatment. The first test will be performed within thirty days from issuance of this permit. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Technical Services Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 Test data shall be complete and accurate and include all supporting chemi- cal/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine must be measured and reported if chlorine is used for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indi- cate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited docu- ment, such as minimum control organism survival and appropriate environmen- tal controls, shall constitute an invalid test and will require immediate retesting. Failure to submit suitable test results will constitute a fail- ure of permit condition. 7Q10 cfs 1K Permitted Flow 3 MGD Basin & Sub -Basin C,'}- js Receiving Stre ' ; - Rtat County (7 cBojak 001 ct4 003 aN.1� (MIXING ZONE) Facility Name Qt5Q.h Permit // /C000 3'll'7 TOXICITY TESTING REQUIREMENT The permittee shall conduct acute toxicity tests on aI U Q basis using protocols defined in E.P.A. Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms". The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test, using effluent collected as a 24 hour composite. ntration- A-9552-- Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge below all waste treatment. The first test will be performed within thirty days from issuance of this permit. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Fonn (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Technical Services Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine must be measured and reported if chlorine is used for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indi- cate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited docu- ment, such as minimum control organism survival and appropriate environmen- tal controls, shall constitute an invalid test and will require immediate retesting. Failure to submit suitable test results will constitute a fail- ure of permit condition. 7Q10 7/f cfs APermitted Flow Q7-3 MGD Basin & Sub -Basin C I5 Receiving S ream CAE FE,f} R County B n4ku/? Co I oe O o3 r toSGt,vjO Li, S Co cts fjcj l c-Cs oOO c-c5 Is +?C SCeos old wG_sty l i'?. cc) Wu- 5 4-4_I U-r,•.1 I . 3.07 m (rD => %lol Lk) rt s+e_i'10 `I r Tat O.f7 0.ti,® $4-I b(cX wo O.7Y a.3 1 (W (;ricrp) f(ar-A-) e4..Uvs(1 1. 3c. c r 5 iUe,) CrG O IS 6.o3 of1ryv�, �JC wf .3 w 4Lk c5P_.P442S r -nk c(tftx) Go, (d t.01 rp `f .70, o/o/ 14.76 -t- otot c(.7`-1- `� ?r p,oror X--0.ole-= 4/.76 0.01a, k = Af,71 )(_ 46 7 c�s 0.0(o/ �►.2,GtX d,o(Of (f 3�-t-X G.bfUl X — 1.34( x= I33 J3 /�`u n Sr1 U -S ~ SUMMER MONSANTO @ 350 LBS/DAY OF BOD5 TRIBG @ AVERAGE FLOW ---- MODEL RE8ULT9 ---------- Discharger : CAPE FEAR MODEL ReceivingStream On The End D.O. is 5.02 mg/l. The End CBOD is 1.81 mg/l. The End NBOD is 0.35 mg/l. WLA WLA WLA DO Min CBOD NBOD DO Waste Flow (mg /l) Milepoint Reach # (mg /l) (mg/l) (mg/l) (mgd) Segment 1 5.02 21.25 to, Reach 1 15 13.50 5.00 16.00000 Reach 2 0 0.00 0.00 0.00000 Reach 3 0 0.00 0.00 0.00000 Reach 4 0 0.00 0.00 0.00000 Reach 5 28 4.50 5.00 6.00000 Reach 6 0 0.00 0.00 0.00000 Reach 7 131 18.00 5.00 0.88000 Reach 8 0 0.00 0.00 0.00000 *** MODEL SUMMARY DATA *** -Discharger a CAPE FEAR MODEL Receiving Stream Summer 7010 u 657. Design Temperatur e v 2'7.. 2ubbasin Stream Class: Winter 70:t0 1 LEN8 T H 1 VELOCITY 1 DEPTH ► Kd 1 Kd 1 Kn 1 Kn 1 K:2 1 K2 1 1 mile 1 fps 1 ft :design! 220° ldesign1 020° ;design! H20° 1 Segment 1 1 0.751 0.418 1 6.45 1 0.34 1 0.25 1 0.51 1 0.301 0.59 1 0.51 1 Reach 1 1 1 113 Segment 1 1 0.601 0.438 1 6.57 1 0.34 1 0.25 1 0.51 1 0.301 0.59 1 0.51 1 Reach 2 1 1 1 11 Segment 1 1 2.001 0.438 1 8.49 1 0.34 1 0.25 1 0.51 1 0.301 0.40 1 0.34 1 3111 Reach 3 1 1 1 1 1 1 11 Segment 1 1 3.901 0.438 111.03 1 0.34 1 0.25 1 0.51 1 0.301 0.27 1 0.23 1 Reach 4 1 1 1 1 1 1 1 1 33 Segment 1 1 0.401 0.441 110.89 1 0.34 1 0.25 1 0.51 1 0.301 0.28 1 0.24 1 Reach 5 1 1 1 1 1 1 1 Segment 1 1 2.601 0.593 111.78 1 0.34 1 0.25 1 0.51 1 0.301 0.29 1 0.25 1 Reach 6 1 1 1 1 Segment 1 1 2.201 0.593 111.79 1 0.34 1 0.25 1 0.51 1 0.301 0.29 1 0.25 1 Reach 7 1 1 1 1 1 1 Segment 1 1 8.801 0.394 111.79 1 0.34 1 0.25 1 0.51 1 0.301 0.23 1 0.20 1 Reach 8 1 1 1 1 1 1 1 Flow 1 CBOD 1 1'.113UD 1 D.O. 1 cfs 1 mg/1 1 mg/1 1 mq/1 Segment 1 Reach 1 Waste i 24.800 i 15.2 »�'•»y 1 13.500 : 5,000 Headwaters 1 65 f� ..000 1 3. 600 1 0.630 1 6.490 Runoff Tributary 1 0.000 1 0. 0 0 0 1 0.000 1 0.000 . p. 1 0.000 1 0.000 i 0.000 1 0.000 Segment 1 Reach 2 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary r1 4(81 .. t0r00 1 5.100 1 0 n 8 'i 0 1 0.000 6.730 .}' Runoff rlf f 1 0 .. 000 1 0.000 1 0.000 1 1..� n 1„i 00 Segment 1. Reach c::h 3 Waste I 0.000 ; 0.000 I 0.000 { 0.000 Tributary 1 0a000 ; 0„000 ; 0„000 1 0a000 * Runoff 1 0.000 ; 0.000 ; 0.000 ; 0.000 Segment 1 Reach 4 Waste 1 0.000 ; 0.000 ; 0a000 ; 0„000 Tributary i 0„000 ; 0„000 ; 0„000 ; 0„000 • Runoff I 0.000 I 0.000 I 0.000 I 0.000 000 Segment :l Reach 5 Waste t 9.300 1 2P.500 I 4.500 t 3.000 Tributary I 0.000 ; 0.000 ; 0.000 ; 0.000 * Runoff c'r a c�rc�rc�l c�r „ cMrc_rc�r 0„ c lc�rc�l 0.000 Segment 1 Reach 6 Waste ► 0.000 Tributary 1400.000 * Runoff I 0.000 0.000 3.600 0.000 0.000 ; 0.000 0.480 1 6.640 0.000 t 0.000 Segment 1 Reach 7 Waste I 1.364 1131.000 I 18.000 I 5.000 Tributary I 0a000 ; 0.000 ; 0„000 ; 0„000 * Runoff I 0.000 ; 0.000 ; 0.000 ; 0.000 Segment 1 Reach 8 Waste I 0.000 ; 0.000 ; 0.000 0.000 Tributary 1 0.000 ; 0.000 ; 0.000 0.000 * Runoff I 0.000 ; 0.000 1 0.000 0.000 Runoff flow is in cfs/crti 1e ^ ` 8UMMER MONSANTO @ 350 LBS/DAY OF BOD5 33 CFS C.C. / 258 CFS R.F.C. --------_- MODEL RESULTS ---------- Discharger o CAPE FEAR MODEL Receiving Stream : The End D.O. is 4.95 mg/l. The End CBOD is 1.66 mg/l. The End NBOD is 0.31 mg/l. WLA WLA WLA DO Min CBOD NBOD DO Waste Flow (mg/l) Milepoint Reach # <mg/l> (mg/l) (mg/l) (mgd> Segment 1 4.95 21.25 8 Reach 15 13.50 5.00 16.00000 Reach 2 0 0.O0 0.00 0.00000 Reach 3 0 0.00 0.00 0.00000 Reach 4 0 0.00 0.00 0.00000 Reach 5 23 4.50 5.00 6.00000 Reach 6 0 0.00 0.00 0.00000 Reach 7 131 18.00 5.00 0.88000 Reach 8 0 0.00 0.00 0.00000 SUMMER M1ONSS ANTO@ - 350'+�LB /DAY OF. BODS 33 Ci� S C n C. l G58 CFS R n F r C u *** MODEL.. SUMMARY DATA *** D:charq r CAPE FEAR Mor)EL.. Subbasin RC ceivinLg Streamn St1 eE fi1 CJ.a�'•a'sn Summer 7010 n 657. Winter 7010 Design Temperature: 27. !LENGTH! VELOCITY 1 DEPTH! Kd 1 Kd 1 Kn 1 Kn 1 K2 1 K2 1 1 mile 1 fps ft Idesignl 820° ldesignl 8200 !design: 220' 1 Segment 1 1 0.751 0.418 1 6.45 1 0.34 1 0.25 1 0.51 1 0.301 0.59 1 0.51 1 Reach 1 1 1 1 1 1 1 1 3 Segment 1 1 0.601 0.432 1 6.53 1 0.34 1 0.25 1 0.51 1 0.301 0.59 0.51 1 Reacts 2 1 1 1 Segment 1 1 2.001 0.432 1 8.34 1 0.34 1 0.25 t 0.51 1 0.301 0.41 1 0.35 Reach 3 1 1 1 Segment 1 1 3.901 0.432 110.73 1 0.34 1 0.25 1 0.51 1 0.301 0.28 1 0.24 1 Reach 4 1 1 1 31 1 Segment 1 1 0.401 0.435 110.85 1 0.34 1 0.25 1 0.51 1 0.301 0.28 1 0.24 1 Reach 5 1 I 1 i Segment 1 1 2.601 0.536 :11.47 1 0.34 1 0.25 1 0.51 1 0.301 0.28 1 0.24 1 Reacts 6 J 1 1 1 i Segment 1 1 2.201 0.536 111.47 1 0.34 1 0.25 1 0.51 1 0.301 0.28 1 0.24 1 Reach 7 1 1 Segment 1 1 8.801 0.353 111.47 1 0.34 1 0.25 1 0.51 1 0.301 0.23 1 0.20 1 Reach 8 i i i i i 1 Flow 1 C :cOD 1 NI3OD 1 D.O. 1 c: f 1 mall 1 mg/1 1 mg/1 Segment :1. Reach 1 Waste 1 24.800 1 15.200 1 13..500 1 5.000 11 ea c.1 wt: rW t` ss 1 S 7 . t;? 0 c:) 1 3.600 Via; 0 1 0.630 1 6.490 Tributary 1 0.000 1 0.000 1 0.000 1 0.000 Runoff 1 0.000 1 0.000 1 0.000 1 0.000 "aacLme: i st 1 Reach 2 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary 1 33.000 1 5.100 1 0.870 1 6.730 ri Runoff 1 0.000 1 0.000 1 0.000 )f:) 1 0.000 t ,- • Segment 1 Reach 3 Waste 1. «yt 1 0.000 1 0.000 0.000 1 0.000 Tributary bi«f a t 1 0.000 1 0.000 ! 0.000 1 0.000 • Runoff 1 0.000 1 0.000 1 0.000 1 0.000 Waste Segment I ReaReach4 W a s t e 1 0.000 3 0.000 1 0.000 1 0.000 Tributary 1 0.000 1 0.000 : 0.000 1 0,000 3 Runoff 1 0.000 1 0.000 I 0.000 1 0.000 Segment 1 Reach 5 Waste 1 9.300 I 22..500 Tributary 1 0.000 1 0.000 * Runoff 1 0.000 1 0.000 1 4.500 I 5.000 0.000 1 0.000 0.000 1 0.000 Segment 1 Reach 6 Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary 1258.000 1 3.600 1 0.480 1 6.640 • Runoff 1 0.000 1 0.000 1 0.000 1 0.000 Segment 1 Reach 7 Waste 1.364 1131.000 1 1 S. 000 1 5.000 Tributary 1 0.000 1 0.000 1 0.000 1 0.000 * Runoff 1 0.000 I 0.000 1 0.000 1 0.000 Segment :1. Reach S Waste 1 0.000 1 0.000 1 0.000 1 0.000 Tributary 1 0.000 1 0.000 1 0.000 1 0.000 • Runoff 1 0.000 1 0.000 1 0.000 1 0.000 * Runoff flow is in cfs/mile Monsanto MONSANTO AGRICULTURAL COMPANY A UNIT OF MONSANTO COMPANY P.O. BOX 2307 FAYETTEVILLE, NORTH CAROLINA 28302 PHONE (919) 323-3300 Mr. David Vogt N. C. Dept. of Natural Resources and Community Development Division of Environmental Management 512 N. Salisbury Street Raleigh, N. C. 27611 Dear Mr. Vogt: July 24, 1987 JUL 2 1', GH The following is in response to your letter of June 29, 1987. The proposed reduction of the daily BOD discharge limit from 675 lbs/ day to 117 lbs/day is a major concern for the Fayetteville Plant. The desire to limit the discharge of oxygen consuming materials to the Cape Fear River during low flow conditions is understandable. The proposed 117 lbs/day BOD limit would require the wastewater treatment facility to operate in excess of design conditions (96.5% efficiency) in order to meet the proposed limit when the plant is operating at capacity. Based on past treatment facility per- formance, the plant's ability to comply with the proposed limit at capacity is marginal at best and would likely result in periods when non compliance would be a severe problem as reflected in the first six months operation in 1987. During this period we would have exceeded the proposed BOD discharge limits the following number of times: Daily Maximum - 48 Monthly Average - 6 The proposed BOD limits provide little or no opportunity to iden- tify and respond to an operating problem before it becomes a major compliance issue. ustiat Considering the above information, Monsanto requests that the pro- posed BOD monthly average limit be raised to 350 lbs/day (700 lbs/ day maximum) reflecting the' wastewater treatment facility design capability (96.5% efficiency at 10,000 lbs/day BOD loading). Any limit below this should only be considered when actual low flow conditions exist. -2- Your favorable consideration of this request is appreciated. Please advise if there is any information we can provide to assist in your evaluation. Yours tr ly, J. F. Hart Plant Manager at cc: Trevor Clements - Raleigh Chuck Keffer - St. Louis Dale Overcash - Raleigh Tommy Stevens - Fayetteville Steve Tedder - Raleigh Tom Wilson - Fayetteville State of North Carolina Department of Natural Resources and Community Development Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor S. Thomas Rhodes, Secretary Phillip M. Pruett Monsanto Agricultural Company P.O. Box 2307 Fayetteville, NC 28302 Dear Mr. Pruett: June 29, 1987 (51,kr„g. 114-1) R. Paul Wilms Director This letter is in response to the concerns that Monsanto outlined during our joint meeting on 6-16-87. As we discussed at that time, the information contained within this letter is not a formal declaration of Monsanto's limits, but rather, it should provide you with an explanation of the hydrologic assumptions and modeling procedures that were used in arriving at Monsanto's proposed water quality limits. As I informed you on the telephone, the Division of Environmental Man- agement (DEM) and the Division of Water Resources (DWR) have been working on a joint project assessing the downstream hydrology and water quality of the Cape Fear River under different Jordan Lake release scenarios. This project was an outgrowth of the problems that the lake and river experienced during last year's drought. I have included a draft copy of DEM's section of this report for your review. Please remember that this is a draft and cannot be considered official until the Director of DWR approves it for release to the public. In regard to Monsanto's questions regarding the model used for this analysis, I have included an overview of our modeling procedure (Appendix A). This information details our general model as well as its specific adaptation for the section of the Cape Fear River from Fayetteville to Lock and Dam #3. Also included are copies of the model output used in arriving at water quality limits for both of the Fayetteville municipal WWTPs and Monsanto (Appendix B). The proposed water quality limits and toxicity testing requirement are found in Appendix C. Again, all limits and require- ments are tentative and cannot be considered official until the wasteload allocation has been finalized via established DEM permitting procedures. Pollution Prevention Pays P.07 Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer Technical Services concurs with the Fayetteville Regional Office in suggesting that Monsanto investigate the possibility of tying into the Rockfish Creek WWTP plant. Since this plant is presently running at approximately half of design capacity, there should be no problem with a flow addition from Monsanto. Additional wasteflow can also be assimilated better at this location because of the higher velocity associated with this section of the river. If I can be of further assistance, please do not hesitate to contact me. Sincerely, . g61141 t) 14r . David Vogt DV:gh cc: Steve Tedder Trevor Clements Tommy Stevens Dale Overcash Monsanto WLA File APPENDIX A. WASTELOAD MODELING I. Criteria The combined discharge of oxygen -consuming waste must protect a dissolved oxygen concentration of 5 mg/1 in the Cape Fear River under a selected target flow at Lillington and with tributaries at 7 day 10 year low flow conditions. II. The General Model 1) The classical Streeter -Phelps DO equation is used to simulate BOD decay instream. This model assumes: a) one -dimensional -system b) steady-state conditions c) advective transport only d) CBOD and NBOD as different components of ultimate BOD The integrated form of the equation is: D = Do e-k2*x/u + kd (e-kd*x/u-e-k2*x/u) CBOD + kn (ekn*x/u-ek2*x/u) D k2-kd k2-kn Where: D = DO deficit at milepoint X (mg/1) Do = Initial DO deficit (mg/1) K2 = reaeration rate (per day) U = velocity (miles/day) X = distance (miles) Kd = CBOD deoxygenation rate (per day) Kn = NBOD deoxygenation rate (per day) CBOD = initial CBOD concentration ( mg/1) NBOD = initial NBOD concentration (mg/1) (in the above, 16.3636 * velocity (fps) = velocity (mile/day) 2) Velocity An empirical velocity equation was developed from a cross -sectional data set of 125 stream observations of time of travel in North Carolina. V = 0.124 Q actual 0.75 * slope 0.29 Q average 0.35 Where: Q actual = 7Q10 + wasteflow (cfs) Q average = average stream flow (cfs) Slope = stream bed gradient (fpm) V = velocity (fps) 3) Reaction Rates a) CBOD deoxygenation rate, Kd (20°C, base e) Kd is calculated by using a corrected bottle rate as defined in the 1987 NC -EPA wasteload allocation agreement. Kd = Kdb + V N H Where: Kd = CBOD deoxygenation rate (per/day) Kdb = bottle rate (0.2 or 0.4/day) (If CBOD concentration is < 50 mg/1 then Kdb = 0.2/day, if CBOD concentration is > 50 mg/1 then Kdb = 0.4/day) H = stream depth (ft) N = coefficient of bed activity N can be determined from the following equation: N = e (-2.8501 + 0.5980 * In (slope) N varies from 0.1 for stagnant or deep waters to 0.6 or higher for rapidly flowing streams. b) NBOD deoxygenation rate, Kn (20°C, base e) Kn is calculated in accordance with the stream gradient (slope) as defined in the 1987 NC -EPA wasteload allocation agreement. If slope < 20 fpm then Kn = 0.3/day If slope > 20 fpm then Kn = 0.5/day c) Reaeration rate, K2 (20°C, base e) Reaeration is determined by Tsivoglou's empirical relationship: for Q < 10 cfs, K2 = 1.8 * slope * velocity for 10 cfs < Q < 25 cfs, K2 = 1.3 * slope * velocity for Q > 25 cfs-, K2 = 0.88 * slope * velocity d) Temperature corrections for:rate coefficients Kd (DT) = Kd (2 0°C) * 1.047DT-20 Kn (DT) = Kn (20°C) * 1.080 DT-20 K2 (DT) = K2 (20°C) * 1.022 DT-20 Where: DT = design temperature III. Model Procedures Specific to the Cape Fear River from Cross Creek to Lock and Dam # 3. 1) Velocity a) Power functions were developed to predict velocity as a function of flow. Data used in the formulation of these equations were obtained from USGS rating tables for gaging stations at the Route 24 Bridge/Fayetteville and Lock and Dam #3. Data plots and regression analysis statistics are shown in Appendix A.1. Velocities were extrapolated for reaches located between these two sites. The specified velocity equations are: @ Rt 24 Bridge: velocity = 0.0049 * flow 0.6814 @ Lock & Dam #3: velocity = 0.0022 * flow 0.7369 b) Depth As with velocity, power functions relating depth as a function of flow were formulated using USGS data. Data plots and regression statistics are shown in Appendix A.2. Interpolation was again done for interior reaches. The specified depth equations are: @ Rt 24 Bridge: depth = 1.040 * flow 0.2796 @ Lock & Dam #3: depth = 3.255 * flow 0.1828 c) Based on previous analyses, literature values, and EPA recommendations, Kd was set at 0.25/day. d) Based on the same criteria as in c), Kn was set at 0.3/day. e) Since the Cape Fear River is essentially a channel between Fayetteville and Lock & Dam #3, the O'Conner-Dobbins reaeration equation was used. This is specified by: K2 = 12.9 * VO.S H1.5 Where: V = velocity (fps) H = depth (ft) APPENDIX A.1.1 Log10 of Velocity as a Function, of Log10 of Flow at Route 24 Bridge. A:ert_24 LOG_VEL (Y Scale = * .1) LQG_FLQW (X Scale = * 1) 3r32-t: w r w r r r G o C{ 2.84+ a 2.36+ o G 1.88+ 1.4 + .92 + .44 + [1 : -- . t_)'+ + G : - . 53 + C� : _!1.01+ oo - 1 r 4 9+ G + + + +..�-��...� ..�.......�........�»....�. ��.. �....�.......�� .'.. *.ram 3.17 3.28 3.38 3.49 3.59 3.70 3.80 3.91 APPENDIX A.1.2. Regression Statistics for Log,0 Velocity vs. Log10 of Flow at Route 24 Bridge. SIMPLE LINEAR MODEL FOR FILE- A:ERT 24 VARIABLES = LOG FLOW (IND.) AND LOG_VEL - (DEP.) INTERCEPT =-2.310983 SLOPE = .4813778 R-SQUARE = .9784516 PEARSON' S R = .9891671 STANDARD ERROR OF ESTI MATE = 2.707609E-02 SIGNIFICANCE OF EQUATION: F = 726.5158 WITH 1, 16 D.F. STANDARD ERROR OF SLOPE -- 2.527932E-02 CONFIDENCE INTERVAL FOR SLOPE BASED ON T-STAT. W/ 16 D.F. . 481-T ( .025) < 8 <ti . 681 +T ( .025) SUMMARY STATISTICS LOG FLOW (IND.), LOG_VEL (DEP.) SUMX = 64.36973 SUMY = 2.262417 N = 18 SUMX' 2 = 1.147205 SUMY :.2= .5443491 SUMXY= .78163 ANOVA TABLE D.F. MS REGRESSION .5326193 1 .5326193 E_RF:OF: 1 . 172934E-02 16 7.331 148E-04 TOTAL .5443491 1.: *##*#*#* , ' APPENDIX A.I.3. Log of V� �m � ��'�uw�. 10 ��~~�~x ""="+�^^�" --�l0 ^ A:ELOCK3 LOG_VEL (Y Scale = * .1) LOG FLOW (X Scale = * 1) 2.3 +: ! o 1.07+ ! -.16 + ! o -1.39+ o ! oo -2.62+ ! om -3.85+ o o / -5.08+ o o o / o Cr oo -6.31+ o | -7.54+ o ! -8.77+ ! -10 +o o o : : 2.29 2.53 2.77 3.01 3.25 3.50 8.74 3.98 APPENDIX A.1.4. Regression Statistics for Log10 of Velocity vs. Log10 of Flow at Lock & Dam #3. SIMPLE LINEAR MODEL FOR FILE- A : ELOCK3 VARIABLES = LOG_FLOW (IND.) AND LOG_VEL (DEP.) INTERCEPT =-2.65476 SLOPE = .7368919 R--SDUARE = .9239389 PEAR SON ' S R = .9612174 STANDARD ERROR OF ESTIMATE -- 8.687908E-02 SIGNIFICANCE OF EQUATION: F = 230.7992 WITH 1, 19 D.F. STANDARD ERROR OF SLOPE = 4.850501E-02 CONFIDENCE INTERVAL FOR SLOPE BASED ON T-STAT. W/ 19 D.F. . 7:37-T ( .049) {:: B < . 737+T ( .049) SUMMARY STATISTICS LOG_FLOW (IND.), LOG_VEL (DEP.) SUMX = 65.3703 SUMY =-7.5791 16 N -- 21 SUM X'"•2 = 3.208169 SUMY'''-2 = 1.885478 SUM X Y= 2.364074 ANOVA TABLE MS F:EGRESE I ON 1.742067 1 1.742067 ERROR .1434115 19 7.547975E--03 TOTAL 1.885478 20 'f-******* APPENDIX A.2.1. Log10 of Depth as a Function of Log10 of Flow at Route 24 Bridge. A : ERT_24 LOG_DEF' (Y Scale = * 1) LOG_FLOW (X Scale = * 1) 1.13+: 1.11-+- 1.09+ 1.06+ �I 1.04+ 1.02+ 1 + .98 + i .95 + .93 + . 90`i +0 (_I 3.17 3.28 3.38 3.49 3.59 3.70 0 0 ct 0 0 3.80 3.91 APPENDIX A.2.2. Regression Statistics for Log 10 of Depth vs. Log IO of Flow at Route 24 Bridge. SIMPLE LINEAR MODEL FOR FILE- A:ERT_24 VARIABLES = LOG -FLOW (IND.) AND LOG_DEP (DEP.) INTERCEPT = SLOPE = R-SQUARE = PEARGON'S R = 1.685649E-02 .2795569 .8825473 .9394398 STANDARD ERROR OF ESTIMATE = SIGNIFICANCE OF EQUATION: F = STANDARD ERROR OF SLOPE = 2.730821E-02 120.2251 WITH 1, 16 D.F. 2.549604E-02 CONFIDENCE INTERVAL FOR SLOPE BASED ON T-STAT. W/ 16 D.F. .28-T( .025) < B < .28+T( .025) SUMX = Si1MX^2= SUMMARY STATISTICS LOG -FLOW (IND.), LOG_DEP (DEP.) 64.36973 SUMY = 18.29842 N = 18 1.147205 SUMY^2= .1015882 SUMXY= .3207091 ANOVA TABLE SS D.F. REGRESSION ERROR TOTAL 8.965642E-02 1.193181E-02 .1015882 MG 1 8.965642E-02 16 7.457384E-04 17 ******** . APPENDIX A.2.3. Log Q of Depth as a Function of LoglQ A:ELOCK3 LOG_DEP (Y Scale = * 1) LOG FLOW (X Scale = * 1) 1.27+: ! 1.23+ ! 1.2 + ! o 1.17+ o ! 1.13+ o o o ! o 1.1 + | oo o 1.06+ o o / o o 1.03+ ! o o o ^99 + o 1 .96 + o ! .92 +o 2.29 2.53 2.77 3.01 3.25 3.50 APPENDIX A.244. Regression Statistics for Log10 of Depth vs. Log10 of Flow at Lock & Dam #3. SIMPLE LINEAR MODEL FOR FILE- A:ELOCK3 VARIABLES = LOG_FLOW (I ND .) AND LOG_DEP (DEP.) INTERCEPT = .5125795 SLOPE = .1828631 R--SQUARE = .6972622 PEARSON"S R = .8350221 STANDARD ERROR OF ESTIMATE ...= 4.901231E-02 SIGNIFICANCE OF EQUATION: F = 43.76058 WITH 1, 19 D.F. STANDARD ERROR OF SLOPE -- 2.764296E--02 CONFIDENCE INTERVAL FOR SLOPE BASED ON T--- 7TAT . W/ 19 D.F. . 183--T ( .028) < roc < .:l 83+T ( .028) SUMMARY STATISTICS LOG__FL OW (I ND .) , LOG-DEP (DEP. SUMX = 65.2703 SLIMY = 22.71798 N =- 21 SUMX''•2= 3.208169 SUMY'''2 = .1538556 SUMXY= .5866557 ANOVA TABLE SS D.F. MS REGRESSION .1072777 1 .1072777 ERROR .0465779 19 2.401469E--03 TOTAL .1538556 20 3E# *# if *-lE•!4 Discharger Receiving Stream APPENDIX B. Model Output for Summer Season. ---------- MODEL RESULTS CAPE FEAR MODEL The End D.O. is The End CIHOD is The End NBOD is 4.95 mg/l. 1.43 mg/ 1 . 0.25 mg/1. Segment 1 Reach 1 Reach 2 Reach 3 Reach 4 Reach 5 Reach 6 Reach Reach O DO Min (mg/1) 4.95 SUMMER WLA CBOt) Milepaint Reach # (mg/1) 19.49 S Cross Crete c Pre° f ►s L Crte.1c UJ W T P VA Set.v++c 15 ) i_) 0 23 0 0 WLA NBOD (mg/1) WLA DO Waste Flow (mg/1) (mgd) 13.50 5.00 0.00 0.00 0.00 0.00 0.00 0.00 4.50 5.00 0.00 0.00 18.00 0,00 0,00 gc y 16.00000 0.000i)0 0.00000 0.0C)000 6.00000 0.00000 0.88000 0.00000 *** MODEL SUMMARY DATA *** Discharger : CAPE FEAR MODEL Subbasin : Receiving Stream : Stream Class: Summer 7010 : 657. Winter 7010 : Design Temperature: 27. ILE116TH1 VELOCITY 1 DEPTH: Kd 1 Kd 1 Kn 1 Kn 1 K2 : K2 1 : mile 1 fps 1 ft !design! 820' :design: 820' :design: 220' 1 Segment 1 1 0.75: 0.418 1 6.45 1 0.34 1 0.25 1 0.51 1 0.301 0.59 1 0.51 1 Reach 1 1 1 1 1 Segment 1 : 0.601 0.425 1 6.49 1 0.34 1 0.25 1 0.51 1 0.301 0.59 1 0.51 1 Reach 2: 1 1 1 1 Segment 1 1 2.001 0.425 1 8.17 1 0.34 1 0.25 1 0.51 1 0.301 0.42 1 0.36 1 Reach 3 1 1 1 1 1 Segment 1 1 3.901 0.425 110.39 1 0.34 1 0.25 1 0.51 1 0.301 0.29 1 0.25 1 Reach 4 1 • Segment 1 1 0.401 0.429 110.81 1 0.34 1 0.25 I 0.51 1 0.301 0.28 1 0.24 1 Reach 5 Segment 1 1 2.601 0.476 111.11 : 0.34 1 0.25 1 0.51 : 0.301 0.28 1 0.24 1 Reach 6 1 Segment 1 1 2.201 0.476 111.11 : 0.34 : 0.25 r 0.51 1 0.30: 0.28 1 0.24 1 Reach 7 1 1 Segment 1 1 8.801 0.311 :11.11 1 0.34 1 0.25 : 0.51 : 0.30: 0.23 1 0.19 Reach 8 1 1 1 1 1 Flow . CBOD cfs mg/1 Segment 1 Reach 1 Waste . 24.800 . 15.200 Headwaters . 657.000 . 3.600 Tributary . 0.000 ; 0.000 * Runoff . 0.000 . 0.000 NBOD ; D.O. mg/1 . mg/1 13.500 . 5. 000 0.630 . 6.49u 0.000 0.000 . 0.000 Segment 1 Reach 2 Waste 1 0.000 : 0.000 : 0.000 j 0.000 Tributary . 18.000 . 5.100 : 0.870 . 6.730 * Runoff 1 0.000 10 1 0.000 1 0.000 I 0.000 Segment 1 Reach 3 Waste . 0.000 ; 0.000 . 0.000 p 0.000 Tributary . 0„000 ; 0.000 ; 0.000 ; 0.000 • Runoff . 0.00: . 0,000 . 0.000 ; 0.000 Segment 1 Reach 4 Waste : 0„000 ; 0.000 1 0.000 ; 0.000 Tributary 0.000 ; 0.000 : 0.000 1 0.000 * Runoff 0.000 . 0.000 I 0.000 I 0.000 Segment 1 Reach 5 Waste . 9.300 1 2 a . SO{_1 Tributary . 0„000 . 0.000 * Runoff 1 0.000 . 0.000 Segment 1 Reach 6 Waste . 0.000 Tributary . 116.000 * Runoff . 0.000 Segment 1 Reach 7 Waste . 1.364 .• Tributary I 0.000 * Runoff 1 0.000 4.500 : 5.000 0.00() 1 0.000 0.000 : 0.000 0.000 ; 0.000 : 0.000 3.600 . 0.480 . 6.640 0.000 . 0.000 : 0.000 55.000 . 18.000 0.C10 1 ; 0.000 0.000 00 ; ().000 5.000 0.000 0.000 Segment 1 Reach) 8 Wasted . 0.000 1 0.000 1 0.000 1 0.000 Tributary 1 0.000 : 0.000 1 0.000 ; 0.000 * Runoff 1 0.000 : 0.000 . 0.000 1 0.000 * Runoff flow is in cfs/mile SUMMER Sera # I Reach # 1 Seq Mi D. O. CLOD : NBOD Flow 1 1 1 c�r . t=rsa 6.44 4.02 1.10 681.80 1 1 0.07 6.42 4.01 1 .09 681 .80 1 1 0.15 6.41 3.99 1.09 681.80 1 1 U . 22 6.40 3.98 1.08 681.80 1 1 0.30 6.39 3.96 1.07 681.80 1 1 0.38 6.38 3.95 1.07 681.80 1 1 0.45 6.37 3.93 1.06 681.80 1 1 0.53 6.36 3.92 1.06 681.80 1 1 0.60 6.35 3.90 1.05 681.80 1 1 0.67 6.34 3.89 1.04 681.80 1 1 0.75 6.33 3.87 1.04 681.80 1 2 0.75 6.34 3.90 1.03 699.80 1 2 0.81 6.33 3.89 1.03 699.80 1 2 0.87 6.32 3.88 1.02 699.80 1 2 0.93 6.32 3.87 1.02 699.80 1 2 0.99 6.31 3.86 1.02 699.80 1 2 1.05 6.30 3.85 1.01 699.80 1 2 1.11 6.29 3.84 1.01 699.80 1 2 1.17 6.29 3.82 1.00 699.80 1 2 1.23 6.28 3.81 1.00 699.80 1 2 1.29 6.27 3.80 0.99 699.80 1. 2 1.36.27 3.79 0.99 699.80 1 3 1.35 6.27 3.79 0.99 699.80 :I. 3 1.55 6.23 3.75 0.98 699.80 1 3 1.75 6.20 3.72 0.96 699.80 3 1.95 6.18 3.68 0.95 699.80 1 3 2.15 6.15 3.64 c^3.93 699.80:I. 3 2.35 6.12 3.61 0. 92 699.80 1 3 2.55 6.09 3.57 0.91 699.80 1 3 P.75 6.07 3.54 0.89 699.80 1 3 2.95 6.04 3.50 0.88 699.80 1 3 3.15 6.02 3.47 0.87 699.80 1 3 3.35 5.99 3.43 0.86 699.801 4 3.35 .99 3.43 0.86 699.80 i. 4 3.74 5.94 13! 0.83 699.80 1 4 4.13 5.88 0.81 699.80 1 4 4.52 5.83 0.79 699.80 1 4 4.91 5.78 0.76 699.80 1 4 5.30 5.74 i . 74 699.80 1 4 5.69 5.69 3c_r . 72 699.80 1 4 6.08 5.65 0.70 699.80 1 4 6.47 5.61 2.94 0.68 699.80 1 4 6.86 5.58 2.88 0.66 699.80 1 4 7.25 5.54 2.83 0.65 699.80 1 5 7.25 5.53 3.09 0.70 709.10 1 5 7.29 5.53 3.08 0.69 709.10 1 .., 7.33 5.53 3.08 0.69 709.10 1 , 7.37 5.52 3.07 0.69 709.10 1 5 7•41 5.5c. 3.06 0.69 709.10 � ~ 1 5 7.45 1 5 7.49 1 5 7.53 1 5 7.57 1 5 7.61 1 5 7.65 1 6 7.65 1 6 7.91 1 6 8.17 1 6 8.43 1 6 8.69 1 6 8.95 1 6 9.21 1 6 9.47 1 6 9.73 1 6 9.99 1 6 10.25 1 7 10.25 1 7 10.47 1 7 10.69 1 7 10.91 1 7 11.13 1 7 11.35 1 7 11.57 1 7 11.79 1 7 12.01 1 7 12.23 1 7 12.45 1 8 12.45 1 8 13.33 1 8 14.21 1 8 15.09 1 8 15.97 1 8 16.85 1 8 17.73 1 8 18.61 1 8 19.49 1 8 20.37 1 8 21.25 � Seg # | Reach # | Seg Mi 5.51 3.06 0.69 709.10 5.51 3.05 0.68 709.10 5.51 3.05 0.68 709.10 5.50 3.04 0.68 709.10 5.50 3.03 0.68 709.10 5.49 3.03 0.68 709.10 5.65 3.11 0.65 825.10 5.63 3.07 0.64 825.10 5.61 3.04 0.63 825.10 5.58 3.00 0.62 E325.10 5.56 2.97 0.61 825.10 5.54 2.93 0.60 825.10 5.52 2.90 0.59 825.10 5.50 2.97 0.59 825.10 5.48 2.83 0.58 825.10 5.46 2.80 0.57 825.10 5.44 2.77 0.56 825.10 5.44 2.86 0.59 826.46 5.42 2.83 0.58 826.46 5.41 2.80 0.57 826.46 5.39 2.77 0.57 826.46 5.38 2.75 0.56 826.46 5.36 2.72 0.55 826.46 5.35 2.69 0.55 826.46 5.34 2.67 0.54 826.46 5.32 2.64 0.53 826.46 5.31 2.62 0.53 826.46 5.30 2.59 0.52 826.46 5.30 2.59 0.52 826.46 5.21 2.44 0.48 826.46 5.14 2.30 0.45 826.46 5.08 2.17 0.41 826.46 5.03 2.04 0.38 826.46 4.99 1.92 0.36 826.46 4.97 1.81 0.33 826.46 4.95 1.71 0.31 826.46 4.95 1.61 0.29 826.46 4.95 1.51 0.27 826.46 4'.95 1.43 0.25 826.46 D.O. CBOD | NBOD Flow | APPENDIX C.1. PROPOSED WATER QUALITY LIMITS FOR THE MONSANTO COMPANY. Pipe 001 Daily Avg. Daily Max. Flow (MGD) 0.15 Total Susp. Residue (lbs/day) 37.5 pH (S.U.) 6-9 No zinc or copper added to the cooling water Monitoring: Chromium, Residual Chlorine, Zinc 56.3 6-9 Pipe 002 Summer Winter Daily Avg. Daily Max. Daily Avg. Daily Max. Flow (MGD) 0.70 0.70 BOD5 abs/day) 117 234 234 468 NH3-N (lbs/day) 23 46 46 92 TSS (lbs/day) 623 1208 641 1242 COD (lbs/day) 3470 5608 4715 7624 DO (mg/1) 5 5 5 5 pH (S.U.) 6-9 6-9 6-9 6-9 Monitoring : Fecal Coliform, Total Nitrogen, Total Phosphorus, and Glyphosate Pipe 003 Daily Avg. Daily Max. Flow (MGD) 0.03 BOD5 (lbs/day) 5 10 NH3-N (lbs/day) 1 2 TSS (lbs/day) 67 134 COD (lbs/day) 40 80 DO (mg/1) 5 5 pH (S.U.) 6-9 6-9 Monitoring: Glyphosate • • APPENDIX C.2. Proposed Toxicity Testing Requirement for Monsanto Company Facility Name Monsanto Permit INC0003719 TOXICITY TESTING REQUIREMENT The permittee shall conduct acute toxicity tests on a Quarterly basis using protocols defined in E.P.A. Document 600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms". The monitoring shall be performed as a Daphnia pulex or Ceriodaphnia 48 hour static test, using effluent collected as a 24 hour composite. The LC50 of this effluent using the previously stated methodology may not at any time be less than 14 %. Effluent samples for self -monitoring purposes must be obtained dur- ing representative effluent discharge below all waste treatment. The first test will be performed within thirty days from issuance of this permit. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DEM Form AT-1 (original) is to be sent to the following address: Attention: Technical Services Branch North Carolina Division of Environmental Management P.O. Box 27687 Raleigh, N.C. 27611 Test data shall be complete and accurate and include all supporting chemi- cal/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine must be measured and reported if chlorine is used for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indi- cate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited docu- ment, such as minimum control organism survival and appropriate environmen- tal controls, shall constitute an invalid test and will require immediate retesting. Failure to submit suitable test results will constitute a fail- ure of permit condition. Comment: As agreed upon in our joint meeting, the LC50 of 144 is based upon 0.73 MGD, (pipes 002 & 003) but effluent samples will be taken at "end of pipe" (after pipes 001, 002, and 003 are combined). Even though pipe 001 is not used in calculation of the LC50, it will still be subject to a biocide review and may be regulated separately via this process. Monsanto MONSANTO AGRICULTURAL COMPANY A UNIT OF MONSANTO COMPANY P.O. BOX 2307 FAYETTEVILLE, NORTH CAROUNA 28302 PHONE (919) 323-3300 R. Paul Wilms, Director Division of Environmental Management Water Quality Division P. 0. Box 27687 Raleigh, N. C. 27611 Dear Mr. Wilms: March 9, 1987 ;,,A; 1 1907 I want to thank you for allowing the Monsanto Company the opportunity to comment on the draft NPDES permit for the Fayetteville Plant. Attached are Monsanto's comments on the draft NPDES permit dated February 6, 1987, Permit No. NC0003719. It is felt that all of the comments made are reasonable and should be in- corporated into the new NPDES permit. If additional information is desired on the comments made please let me know. I can be reached at 323-3300, ext. 210. Yours truly, P. M. Pruett at Attachment ADDENDUM During a review of Monsanto's comment submittal concerning the draft of NPDES permit No. NC0003719, it was discovered that the 001 sample was being obtained from the wrong location. Instead of sampling the non -contact cooling water. blowdown a sample was being taken from the plant's chemical sewer system. To the best of our knowledge this has been going on since mid 1982. Thus, all data submitted on the 001 outfall from mid 1982 to the present is in error. We are currently sampling several locations daily to generate suffic- ient data to allow us to make a knowledgeable evaluation. We have encountered some difficulty in finding a location that allows good mixing of streams and an accurate measurement of the 001 flow. At present it appears, at a minimum, the plant will have to order and install new inline flow totalizers to be used in building a representative data base while generating new 2C data for submittal. Additionally, with the resolution of the Cape Fear River 7Q1P being so close at hand, it is felt that it would be in the best interest of all parties concerned to postpone the issuance of Monsanto's NPDES permit. The time needed by Monsanto will depend primarily on delivery of flow tota- lizers and priority pollutant results. Hopefully, during this time the 7Q10•for the Cape Fear River will be estab- lished so we will be able to receive a 5 year permit. While the new permit process is on hold the plant will continue to routinely sample all parameters listed for the 001 discharge, as at present. Your concurrence with this approach will be appreciated. COMMENTS ON DRAFT NPDES PERMIT DATED FEBRUARY 6, 1987 PERMIT NO. NC 0003719 STATE OF NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT COMMENTS BY MONSANTO COMPANY P.O. BOX 2307 FAYETTEVILLE, NC 28302 March 6, 1987 COMMENTS ON DRAFT NPDES PERMIT NO. NC 0003719 I. SUPPLEMENT TO PERMIT COVER SHEET A. The description of contributions to 001 outfall should duplicate the description in the prior permit: "Continue the discharge of non -process water consisting of wastewater from water treatment and neutralization facilities, boiler blowdown and cooling tower blowdown at the point of the existing discharge into the Cape Fear River (outfall No. 001)." B. The description of outfall 003 should be revised to read: "Continue to operate a wastewater treatment system consisting of pH control and filtration units installed to treat the effluent from the glyphosate incinerator/wet wash scrubber system (outfall No. 003), except that the incinerator and this treatment system need be run only as required to maintain compliance with the limits of this permit." Normally, biological control of pollutants is practiced, so that the incinerator functions on a backup basis. II. PART I.A. - LIMITATIONS/MONITORING - 001 OUTFALL A. The footnote "(1)" in the title should be deleted as it appears to have no function. B. Revise the description of 001 outfall to be "non -process water" per the previous permit. The term "non -contact cooling water" does not fully describe the contributions to this discharge. C. We request that the Flow limit in the permit be deleted. While flow measurement in an NPDES permit is often required, a limit on flow is not required and serves no environmental protection need. It also unnecessarily exposes Monsanto to the possibility of violation. While it is agreed that a high -side estimate of flow is needed to assess the safety of biomonitoring findings, this may be done separate from permit limitations, with verification by a permit monitoring and reporting requirement. Page 1 of 9 D. The characteristic of "Total Suspended Residue" should be revised to "Total Non -Filterable Residue," reflecting, we believe,'the intent of the DNR. The official methods as presented in "Standard Methods for the Examination.of Water and Wastewater," 16th Edition, do not define a'Total Suspended Residue method. E. Delete Zinc as a parameter limited by this permit. The stipulation immediately below precludes use of zinc as an additive to cooling water. F. The term "Toxicity" should be replaced with the term "Biomonitoring." This is the term more often used in NPDES permits and more properly reflects the test, content and intent of this monitoring requirement. The footnote, "1/," should be elaborated to reflect the intention that biomonitoring be performed on the combined plant effluent and not on the 001 discharge alone. Add the clarification: "To be performed on the combined discharge of the plant, just prior to discharge to the Cape Fear River." G. The reference to "Chromium" should be deleted from the sentence: "THERE SHALL BE NO CHROMIUM, ZINC OR. COPPER ADDED TO THE COOLING WATER." Reduced levels of chromium are in fact used for cooling water treatment, and this section otherwise adequately controls and limits the discharge of chromium. H. The frequency for pH and chlorine monitoring should be changed to 2/month in. concert with the other monitoring frequencies. This represents a doubling of frequency from the present permit and would allow Monsanto to meet this need in a cost-effective manner, while providing adequate monitoring frequency. III. PART I.A. - LIMITATIONS/MONITORING - 002 OUTFALL, SUMMER AND WINTER A. The footnote "(1)" in the titles should be deleted as they appear to have no function. B. Delete the Flow limit. in the permit. Seediscussion in II.C. above. The characteristic. of "Total Suspended Solids" should be revised. to "Total Non -Filterable Residue." See discussion in. II.II.. above. Page 2of 9 D. The term "Toxicity" should be replaced with the term "Biomonitoring," and the footnote "1/" should be elaborated to reflect the intention that biomonitoring be performed on the combined plant effluent and not on the 002 discharge alone. See discussion in II.F. above. Additionally, the footnote reference, "1/," should be added to the table of Winter limitations. E. The frequency for pH monitoring should be changed to 2/month in concert with the other monitoring frequencies. This would allow Monsanto to meet this need in a cost-effective manner, while providing adequate monitoring frequency. IV. PART I.A. - LIMITATIONS/MONITORING - 003 OUTFALL A. The footnote "(1)" in the title should be deleted as it appears to have no function. B. Delete the flow limit in the permit. See discussion in II.C. above. C. The characteristic of "Total Suspended Solids" should be revised to "Total Non -Filterable Residue." See discussion in II.D. above. D. The term "Toxicity" should be replaced with the term "Biomonitoring" and the footnote "1/" should be elaborated to reflect the intention that biomonitoring be performed on the combined plant effluent and not on the 003 discharge alone. See discussion in II.F. above. E. The frequency for pH monitoring should be changed to 2/month in concert with the other monitoring frequencies. This would allow Monsanto to meet this need in a cost-effective manner, while providing adequate monitoring frequency. F. Add a footnote to the "Measurement Frequency" column, to indicate "When operating." V. PART I.B. - SCHEDULE OF COMPLIANCE A. Both paragraphs of this section should be marked "N/A," or "Not Applicable." VI. PART I.C. - MONITORING AND REPORTING A. We propose that the DEM replace the term "characteristic," as used twice in Part I.C.1., with the term "representative." We believe that this more properly reflects the intention of the DEM regarding sampling and flow measurements. Page 3 of 9 VII. PART II.A. - GENERAL CONDITIONS - MANAGEMENT REQUIREMENTS A. The requirements of Part II.A.2. on "Noncompliance Notification" are overly restrictive'and should be revised to reflect the Federal regulations on twenty-four hour reporting at 40 CFR 122.41(1)(6). Specifically, 24-hour reporting should be required only for those parameters high -lighted in the permit to require such reporting or those exceedances which may endanger health or the environment. We particularly object to the general and indeterminate language of paragraph II.A.2.a. The separate requirements for permit compliance, compliance with NPDES regulations, and for CERCLA reporting of releases to the environment preclude the need for this rather general language. B. In Part II.A.5., Bypassing, the sentence beginning with "All permittees who " and ending " bypass or overflow" should be deleted. There is no history of problems that warrants this direction and so there is no need for such a general requirement in this permit. Further, there is separate language in the permit to prohibit by-passes and to require reporting and control of by-passes. We perceive that this sentence was incorporated in permit language due to concerns related to municipal permits, but it is not proper or needed in this industrial discharge permit. C. In Part II.A.7., "Power Failures," we request that you add the word "reasonably"- before "adequate" in the first sentence. It would be difficult if not impossible to provide for virtually every conceivable or unconceivable power outage contingency, but we agree that reasonable planning and preparation should be done. VIII. PART II.B. - RESPONSIBILITIES A. Regarding Part II.B.6. - "Civil and Criminal Liability," the federal district court in New Jersey held on August 8, 1985, that the upset defense was not valid unless the permit specifically included such a provision and made reference to it in a provision such as Part II.B.6. (Student Publi.c Interest. Research Group of New Jersey (NJPIRG), et al. v. AT&T Bell Laboratories, (617 F.Supp. 1190) (23 ERC 1201, 1213)(D. N.J.). The court relied on the language in 40 CFR 122.41 which states that all the conditions applicable to NPDES permits "shall be incorporated into the permits either expressly or by reference" and "by reference" means by a specific citation to the regulations. According to the Bell decision, it is essential that•the word "upset" be included in Part II.B.6. and that the permit include a specific condition on upsets which can be found at 40 CFR 122.41(n). Page 4 of 9 We request that the State modify Part II.B.6. to include "upsets" as a defense against civil and criminal liability. In addition, we request the State include in its permit the following provisions on "upsets": 1) Definition. "Upset" means an exceptional incident in which there is unintentional and temporary noncompliance with technology -based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include non-compliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation. 2) Effect of an upset. An upset constitutes an affirmative defense to an action brought for noncompliance with such technology -based permit effluent limitations if the requirements of II.B.4.c. of this permit are met. No determination made during administrative review of claims that noncompliance was caused by upset, and before an action for noncompliance, is final administrative action subject to judicial review. 3) Conditions necessary for a demonstration of upset. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that: (a) An upset occurred and that the permittee can identify the cause(s) of the upset; (b) The permitted facility was at the time being properly operated; (c) The permittee submitted notice of the upset as required in II.A.2. of this permit. (d) The permittee complied with any remedial measures required under II.A.4. of this permit. 4) Burden of proof. In permittee seeking to upset has the burden any enforcement proceeding the establish the occurrence of an of proof. B. In Parts II.B.6. and II.B sentence to the permit: .7, the DNR proposes to add this "Furthermore, the permittee is responsible for consequential damages, such as fish kills, even though the responsibility for effective compliance may be temporarily suspended". Page 5 of 9 Such a provision does not appear to be provided for in regulations, and so should be deleted as it is unauthorized. IX. PART III.B. - CONSTRUCTION A. We request that you return this sentence to the permit, as per the prior permit: "If no objections to Final Plans and Specifications have been made by the DEM after 30 days following receipt of the plans or issuance of this permit, whichever is latter, the plans may be considered approved and construction authorized". X. PART III.D. - GROUNDWATER MONITORING A. This entire section on groundwater monitoring is new. We object to including this provision on the basis that it does not relate to discharges to the surface waters of the State of North Carolina, which is what is covered by this permit and is regulated by the North Carolina Water Pollution Control Regulations. Further, the reference to "current" groundwater standards is unacceptably confusing. We assume that the intention of the DEM is to reference and incorporate those standards promulgated at time of permit issue. XI. PART III.E. - LIMITATIONS REOPENER A. This part of the draft permit provides as follows: "This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent guideline or water quality standard issued or approved under sections 301(b)(2)(c) and (d),. 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved: (1) Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or (2) Controls any pollutant not limited in the permit. In addition, in Part II.B 5. of the draft permit, entitled "Toxic Pollutants," the permitcontains the standard reopener clause providedfor in. the. Federal. Regulations. The provision. of . Part III.E. of the permitis not.. provided for in North. Carolinaregulations and,therefore,is illegal and ._� void.. This provision in.. the draft permit is based.. on 40 CFR 122.44(c) of. the- Federal. Regulations. This.. provision, however, Page 6 of.9 is taken from section 40 CFR 122.44(c)(1) which specifically provides that it is to be used in those permits which are written and issued on or before June 30, 1981. Since this permit will obviously be issued a minimum of five years after June 30, 1981, the use of such language is in contravention of the Federal Regulations. Therefore, the use of this provision is not only improper under Federal Regulations, it is also improper under North Carolina Regulations. The reopener clause in Part II.B.5 of the draft permit is based on Section 40 CFR 122.44(b) of the Federal Regulations and is proper as far as the federal regulations are concerned. Since this provision is not provided for the state regulations, there is obviously a legal question whether or not such a reopener clause can be put into the state permit; however, Monsanto has no objections to including the reopener clause of Part II.B.5. in the draft permit. Monsanto recommends that the language of Part III.E. be stricken from the draft permit. • XII. PART III.G. - TOXICITY TESTING REQUIREMENT A. This part should more properly be termed "Biomonitoring Requirements," more closely reflecting industry practice and the intent of this discharge -characterization. Monsanto further requests that this part be revised in •three respects: 1) The numerical acute toxicity target should be removed as a limit in the permit, becoming instead a screening mechanism for determining the need for further evaluation. 2) The screening targets should be revised to LC50 > 16.7%. summertime, 13.9% wintertime. 3) The permit should provide for possible frequency reduction of biomonitoring after two years. Monsanto's major concern with the proposed effluent toxicity testing requirementscenters on. the use of a numerical toxicity limit to judge the safety ofthe plant's discharge. While Monsanto supports North Carolina's efforts tointegrate biological assessment techniques into its water quality. management program,, the -state-of-the-art of aquatic hazard assessment has notyet reached a level of understanding or precision tosupport the inclusion of numerical toxicity- limits 1. permits.: Significant_.• ` o�� \t4s)".' C;,s° r uncertainty still exists regarding: 1) the frequency of sampling required to characterize effluent variability, 2) the precision of EPA's proposed methodologies, 3) how precision can be incorporated into numerical limits and 4) the ability to extrapolate from laboratory to field results. Further, methodology for isolating and identifying the cause(s) of a toxicity finding are not yet well developed. A finding of less than a violable limit could cause Monsanto to be in continuing violation in spite of timely and energetic efforts to remedy the situation. Monsanto is also concerned that the acceptable level of acute toxicity proposed in the NPDES permit (i.e. LC 50 > 23%) is incorrect. Based upon a maximum discharge flow rate of 0.88 MGD and a 7 day 10 year low flow(7Q10 _for the Cape Fear River near Monsanto og_525 MGG) m er) and ( 633-MGD (winter), the correct LC50 value would be > 16.7% 'during summer and > 13.9% during winter flow conditions. Since appropriate decisions regarding safety of an effluent can be made without having to include numerical toxicity limits in permits, Monsanto believes that a numerical toxicity limit should not be included in its NPDES permit. Instead, the acute LC50 criteria of > 16.7% (summertime) and > 13.9% (wintertime). should be used by the State and Monsanto as an initial screening mechanism for evaluating Monsanto's acute monitoring data and for determining the need, ifany, for further evaluation. Consideration should also be given to reducing the testing frequency from quarterly to annual, or at most twice per year, if the first two years of monitoring data indicate no detrimental effects would be expected in the'receiving stream as a result of Monsanto's discharge. Questions regarding Monsanto's response to the biomonitoring testing issue should be directed to Donald Grothe or Richard Kimerle at (314) 694-1000. They were involved in assisting the EPA in developing it's "Technical Support Document For Water Quality -Based Toxics Control." State of North Carolina Department of Natural Resources and Community Development Division of Water Resources 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor S. Thomas Rhodes, Secretary February 13, 1987 Mr. P. M. Pruett Monsanto Agricultural Company P. 0. Box 2307 Fayetteville, North Carolina 28302 Dear Mr. Pruett: John N. Morris Director Thank you for your letter of January 27 expressing the concern of the Monsanto Company about releases of water from Jordan Lake to augment flows and improve water quality in the Cape Fear River below the dam. Jordan Lake provides an enormous benefit for wastewater dischargers downstream. The project is designed to maintain a flow of 600 cubic feet per second at Lillington under all but the most extreme drought conditions. This compares to a historic low flow of about 11 cfs. As authorized by Congress, about two-thirds of the conservation pool of Jordan Lake is set aside to store water for downstream flow augmentation. A separate element of the conservation pool is set aside for water supply use. For this reason, use of the lake for water supply will not diminish the amount of water reserved for downstream flow augmentation. The Division of Environmental Management is currently studying the flow augmentation capacity of Jordan Lake to determine under what recurrence interval of extreme drought conditions the 600 cfs target could not be met at Lillington, and to develop a more efficient plan for managing the flow augmentation storage pool to maintain the best possible downstream water quality. I am providing a copy of your letter to Mr. Trevor Clements of the Division of Environmental Management so that he will have your statement available to him in his review of water quality in the Cape Fear River. Thank you for your interest in the management of North Carolina's natural resources. cc: r. Trevor Clements Sincerely yours, -5;7ro RECEIVED t. Morris FEB 187 P.O. Box 27687, Raleigh, North Carolina 27611.7687 Telephone 919-7334064 CHNICAL SERVICES BRANCH An Equal Opportunity Affirmative Action Employer John Morris Director Water Resources P. 0. Box 27687 Raleigh, N. C. 27611 Dear Mr. Morris: Monsanto FEB 2 1,987 MONSANTO AGRICULTURAL COMPANY A UNIT OF MONSANTO COMPANY DIVISION OF WATER RESOURCES P.O. BOX 2307 FAYETTEVILLE, NORTH CAROLINA 28302 PHONE (919) 323-3300 January 27, 1987 ni14 = 15S5 70to = Li7 c-{-S t`.7-26?c4::)=t57 f5 QHoA.G,,,t This is in response to a request by the North Carolina Water Quality Committee -- to write you and convey Monsanto's concerns about the water allocation project for the Jordan Lake. The major concern Monsanto has is that the Jordan Lake 100 MGD water project would lower the 7Q10 of the Cape Fear River. This was brought to our atten- tion by an employee of DEM, who was doing the modeling for our plant's NPDES permit. We were informed that our NPDES permit limits could be dropped to 5 ppm BOD5 and 2 ppm NH3N. These numbers would force us to totally redesign our waste treatment facility. Additionally, we were informed that even before the drought in the summer of 1986, the 600 CFS limit was not being met and that the removal of 100 MGD would make the meeting of that limit even harder. Since voicing Monsanto's concern at the Water Quality Committee meeting, we have been informed by Kimberly Brewer that the 100 MGD water project will have no effect on the 7Q10 of the Cape Fear Rvier. We were also informed by Trevor Clements that although there was some problems with meeting the 600 CFS limit before that, he thinks that problem has been resolved. However, it appears to us that if all of the concerns about the 7Q10 of the Cape Fear River have been resolved that the state would be issuing 5 year permits instead of the planned 2 year permit. To summarize Monsanto's feeling on the 100 MGD Jordan Lake Water project is simply that if its not going to ever affect us, we don't have any concerns. If the project changes the 7Q10, our NPDES permit, or causes us to have to spend additional money on our waste treatment facility, we would have a number of concerns, as would many other facilities in the Cape Fear Valley Region. If you would like additional information please let me know. Yours truly, 4(12-44021f P. M. Pruett Environmental/IH Supv. at DIVISION OF ENVIRONMENTAL MANAGEMENT June 17, 1987 MEMORANDUM TO: Mick Noland THROUGH: Steve Tedder Trevor Clements FROM: David Vogt SUBJECT: DO Violations in the Cape Fear River Between Fayetteville and Lock and Dam #3 Per your request, I am providing you with DO profiles (attached) compiled from -Monsanto's upstream self -monitoring data. As you are probably aware, the lowest DOs in this section of the river occur in the backwater above Lock and Dam #3. Since data for DEM's ambient network station at this site (B8300000) is collected in a sidestream channel around the dam (where rapid reaeration is occuring), the DO data from the Monsanto station better represents the oxygen -consuming dynamics of the backwater. In most instances, however, the corresponding self -monitoring DO datum from Monsanto's downstream site was considerably higher than the upstream datum. This is hard to rationalize since the plants average waster l ow is usually less than 0.5 HGD and this goes into a river flow normally above SOO cfs (see attached). In addition, the downstream site does not reflect the full exertion of the industrial BOD waste component of their effluent. Thus I believe that their argument of improving the water quality of the river is not based'on good scientific evidence. Since the new model incorporates the section of the Cape .Fear River from the Cross Creek WWTP to Lock and Dam #3, upstream self -monitoring data from the Cross Creek facility for the same period of record was compared with the Monsanto upstream data. There were no DO violations in the Cross Creek facility's data; this demonstrates that the two F'WC facilities are impacting the river quite significantly. Moreover, since the model predicts the DO sag point to be immediately above the dam, Monsanto, even with its relatively small discharge, is assumed to be contributing to the overall degradation of dissolved oxygen in the river. This was verified by running the model both with and without Monsanto's discharge and observing the net impact on instream DO and BOD. Please contact me if you need further assistance on this matter. cc: Dale Overcash Monsanto WL A File Month Summer Season Dissolved Oxygen Self -monitoring Data from Monsanto's Upstream Site. 1984 1985 Avg. Min. Avg. Min. May 5.9 5.3 4.9 4.0 June 5.6 4.1 4.1 3.5 July 5.0 4.3 5.0 3.8 August 4.5 3.9 5.1 4.0 September 5.1 4.2 4.8 2.6 October 5.5 4.9 Questioning Monsanto's Theory of River Improvement: 1986 Avg. Min. 4.7 3.9 3.1 2.7 2.8 2.1 3.6 2.2 4.7 4.2 5.5 4.2 1) Use a mass balance to determine what effluent DO would be required to balance the upstream and downstream DO readings, i.e.: DO_eff=DO_ds*Q_ds - DO_s.:s*Q_us Q_eff where: DO_eff = effluent DO concentration (mg/1) DO_ds = downstream DO concentration (mg/1) Q ds = downstream flow (Q_eff+Q_us) (cfs) DO_us = upstream DO concentration (mg/1) Q_us = upstream flow (cfs) Q_eff = effluent flow (cfs) 2) Eliminate bias by picking the lowest DO reading from the above table (2.1 mg/1 )and use the matching Monsanto flow for that day (which is 7-23-86) and the recorded USGS flow at Lock and Dam #3 for the next day (since it takes 1=>1.5 days for the water at Monsanto to get to Lock and Dam #3). then, DO_eff = 6.9*865.81 - 2.1*865. 0 0.81 = 5,133 mg/1 (which is preposterous!) • • Sae w«,. G 04- C4 /e 14 I model Chi s CPeek to w-' P bow.t si-/Y t (t2iieii4 cd- L1�I1n To.a a ox 37 i.i It S (14+ vs ,c) ,1Ii Cite v , l l Cross 0,7S m\Nes L%ck4 C,etk .�.0 Ai tic s e'c v 0.4 f+,l es .�.�, rv.tics ntonSa. 4 &O 2.3 1411I($ Cf 10 •.70.tics NA�, 6 TC�fr 0 --r) Cie ek wwTP yr3+1ec . r►tOres 0l0) I 1 s Tom[ Qt "Na -Re e aker lO�c. E „i.,, [" ? Yek,k -Lt1• Cre et< wwTP AO /4S 1 wea An of 0note's** fe...-4,4,ecl ,n7L ke CI Ow rftea's, Moot *poi a± etc ke.et S.hJ 4 G'44 b in 1 eAi400 6-s Get. Lt. Daw. 3 PA tvi7C - 010 IlciA440 Ilef C.. (LP Zo t• CO- aMinektA .L-11 Ak..s p feel s e.. ) e e.s.1742.4t covv4-ecci- 9. .00 3 (-f(ocess) --(114-C-tnet r) ;:19 fife: 602_ u6es ef 0 Au _.Ek I's 4.1 0_863 3,07 • V le 0,; C. I I ovi ga-4044.710 X It41f Ltd.e._ _cwt. to_LA .v _11-oasci _.wout4 6010044 7e0 6, (8 tit() 161 --trasa_ •/ 141 II— 4 efiket4.4 ez4J 8- fenr1) 3 Co ciz 771 anisaptio 42,4 -flow 44)444 cc. -rwc. = . = •06 17 0 .6/0 • ) 112,3C. .. L Ct. aL.A..1.--175 AAA- 41DK 'tot ti (770 sel a `—tr.A.e.. 2,0 Ai 4e._ 63.0.4.c- iut4 01.471 te,f _Is y _Low' .;77t P°7 GWdI(e) N1713 = 0.?0 *i►34 -'IF_ f P_It6 = a ooz %AEI bk._e dtio -oJ _IS_Pj LViskir..L. Its/ e..S-5 Gv _6 003 sLAIJ eto 014.Q J ±4717:5 --T-ss coD ? old ( I , • ___/__ re 141 _If _ _ Suvywne •e• I / 451_/. qtq... . u. ft(us .e DIVISION OF ENVIRONMENTAL MANAGEMENT June 5, 1987 MEMORANDUM TO: Steve Tedder THROUGH: Trevor �� Clements FROM: David Vogt WO - SUBJECT: WLAs For Fayetteville And Monsanto After our meeting yesterday with representatives from Fayetteville, I did sensitivity analyses for Monsanto. With the limits we proposed to Fayetteville (Cross Creek WWTP ai 16 MGD=>8 & 3, Rockfish Creek WWTP Qi 6 MGD=>15 & 1), the maximum allowable limits for Monsanto would be 20 & 4. Limits higher than 20 & 4 would necessitate lowering the limits for the two Fayetteville facilities. I have shown the proposed and existing summer limits for Monsanto (in production units) in the following table: Design Flow=0.73 MGD* Design Flow=2.3 MGD Proposed Limits (lbs/day)** Existing Limits (lbs/day)** BOD5 NH3-N BOD5 NH3-N Daily Avg 122 24 675 36 Daily Max 244 48 1350 72 * Monsanto has requested a design flow reduction in their permit renewal application. ** Winter limits would be 2 x summer limits. These are only limits for oxygen -consuming waste - other limits will also be worked up for the permit. Actually, Monsanto should have no problem meeting 20 & 4 limits. Self --monitoring effluent data for 1986 shows that Monsanto's summer average for GODS was 40 lbs/day and for ammonia 10.3 lbs/day. The . a a highest monthly averages for summer BUDS and NH3 were 48 lbs/day and 27.5 lbs/day, respectively. Referring to the above table, it can be seen that, for the most part, these values fall within the production limits that correspond to 20 & 4 limits. Comparing self -monitoring data and proposed limits for the winter season produces similar results. We need to keep in mind, however, that this will not be true if either of the Fayetteville facilities expands. For instance, with the most likely scenario of Cross Creek WWTP going to 20 MGD while Rockfish Creek WWTP stays at 6 MGD, maintaining the limits of all three facilities would • produce an instream DO concentration of 4.8 mg/1. Of course, additional flow increases would only serve to exacerbate the depression of instream DO. • Furthermore, Monsanto's existing permit does not contain a DO limit. The proposed limits of 20 & 4 were modeled with 5 mg/1 effluent a� Tt DO; therefore we will need to add 'a DO limit to the modified permit. It is also recommended that the permit retain the temperature monitoring requirement for pipes 002 & 003 (see attached memo from the Region). Once limits are decided for Monsanto, I can proceed with processing the WLAs for the two Fayettevile facilities. Facility Name: , / Y 16 ?'54- n0 Existing Proposed NPDES WASTE LOAD ALLOCATION Permit No.: NG o06,37(q Pipe No.: O o p_ Design Capacity (MD): Of 70 Receiving Stream: Cr -Fur Reference USGS Quad: N 23 County: Cumbe, /a 41 Industrial (% of Flow) : /00 A Domestic (% of Flow) : ever Class: ('_ Sub -Basin: 03 -oG (3— (Please attach) Requestor: . ovetCasL Regional Office Fief) (Guideline limitations, if applicable, are to be listed on the back of this form.) Design• • Drainage Area (mi2): �� Q Sr Avg. Streamflow (cfs) : 43 (11p 7Q10 (cfs) Co 0 0 Winter 7Q10 (cfs) 30Q2 (cfs) Location of D.O. minimum (miles below outfall) : _ - Ir.ti-1 .yr /�^lrr� • Effluent ' Characteristics Monthly Average Comments Boric AM Gnold G i3#1 't"ss co 3470 0/d Orr asa-t� if1I/d Et , _ CQas.u�! Comments: set,. Slope (fpm ) 1<2 (base e. oer day): Effluent Characteristics :'onthly , Lveracle Comments , $oX..0 _13$3 14 1U tiA , Coo 11/d Tss 4414% co_b '471S 4t/d -/ irga(tosid-e:t dbi4 _ G-Q s. Reviewed By: eiQ �Leel— Date: WASTELOAD ALLOCATION APPROVAL FORM Request No. : 40?3/46 Facility Name Type of Waste Status Receiving Stream Stream Class Subbasin County Regional Office Requestor Date of Request Quad MONSANTO 002 GLYPHOSATE EXISTING CAPE FEAR RIVER C 030615 CUMBERLAND FAYETTEVILLE DALE OVERCASH H23 Wasteflow BOD5 NH3 TSS COD Glyphosate pH (mgd) : (#/d) : (#/d) : (#/d) : (#/d) : (#/d) (SU) . Drainage Area (sq mi) : 4395 Summer 7Q10 (cfs) . *600 Winter 7Q10 (cfs) . Average Flow (cfs) : 4340 30Q2 (cfs) : RECOMMENDED EFFLUENT LIMITS summer 0.7 595 60 623 3470 41 6-9 Upstream (Y/N): N Downstream (Y/N): N Location: Location: winter 0.7 1353 600 623 3470 41 6-9 MONITORING COMMENTS THESE ARE THE EXISTING LIMITS, ADJUSTED TO ACCOUNT FOR MONSANTO'S REQUESTED INCREASE IN THEIR NH3 LIMIT. GLYPHOSATE LIMITS ARE BASED ON THE NEW GUIDELINES PERMIT SHOULD INCLUDE A TOXICITY REOPENER AND SHOULD INCLUDE TOXICITY MONITORING (SEE ATTACHED). PEMINT SHOULD BE SHORT TERM. LIMITS WILL CHANGE WITH NEW DESIGN FLOWS IN THE CAPE FEAR RIVER. Recommended by Reviewed by: Tech. Support Supervisor Regional Supervisor Permits & Engineering Date Date Date Date _�/42. _ g Facility Name: Ebcisting O Proposed 0 NPDES WASTE LOAD ALLOCATION 1lo,Js p+Jro Permit No.: /sk (Job '%%i Design Capacity (t4GD) : D. 030 , Industrial (% of Receiving Stream: CRPa PEAL RAU Flow) : Class: Reference USGS Quad: K Z3 (Please attach) . TS pm is (Guideline limitations, if applicable, are to be listed on the back of this form.) Pipe No C. Engineer D0 3 Date Rec . Date 7/3nek , s County: CuotiEIGAb /001. Domestic (% of Flow) : Sub -Basin: 03 -O6 - Requestor: etiaci►S4 Regional Office fat) • Design 11emp • Drainage Area (mi ) : 43`i 5 Avg. Streamflow (cfs) : "f3e1ci 7Q10 (cfs) (00 Winter 7Q10 (cfs) 30Q2 (cfs) Location of D.O. minimum (miles below outfall): Velocity (fps) : Slope (fpm) K1 (base e, per day) : K2 (base e. oer day) : Effluent Characteristics Monthly Average Comments BaD s d 7 4- cl) kJif-3 , - Cp-i At ',~Iss , Crig tion Pared By: on 0 Convents: %Da:11 max Effluent s Characteristics Sage 4VP comments B� s S`f oft r N 03 TS s 13 y # ,. co.') '0# /S. z *I/caw 64_9 Lo sat JO tI _ t-? S.a.S' car s ation O e r pie- fie c e/ v/ 4.Ps. 'i`'p a rre� 6 c 44J e. �- "td `�e.�cc e eJI 3 l S �we er'S e U(At4 '00 Reviewed By: (144,0 et- Z. r `G f`Ccon,rKe.,�.� A 14 ✓yton, !d/'i. (See �, 3 The- t � S c.��, , e. S �i�cc.� ��f' � n C ✓'t �_ 5 � `�'�-e 424. Q t Date: 4_ n0 cK.s WASTELOAD ALLOCATION APPROVAL FORM Request No. : as 3/ Facility Name Type of Waste Status Receiving Stream Stream Class Subbasin County Regional Office Requestor Date of Request Quad MONSANTO 003 INCINERATOR EXISTING CAPE FEAR RIVER C 030615 CUMBERLAND FAYETTEVILLE DALE OVERCASH H23 Wasteflow BODS NH3 TSS COD Glyphosate pH TEMPERATURE (mgd) : (#/d) : (#/d) : (#/d) : (#/d) : (#/d) (SU) . Drainage Area (sq mi) Summer 7Q10 (cfs) Winter 7Q10 (cfs) Average Flow (cfs) 30Q2 (cfs) RECOMMENDED EFFLUENT LIMITS mo.avg 0.03 27 67 40 2.8 6-9 ** Upstream (Y/N): N Downstream (Y/N): N Location: Location: da.max. 0.03 54 134 80 15.2 6-9 ** MONITORING : 4395 : °600 : 4340 COMMENTS TEMPERATURE: THE DISCHARGE SHALL NOT INCREASE THE RECEIVING WATER'S TEMP. BY MORE THAN 2.8 C AND IN NO CASE CAUSE IT TO EXCEED 32 C. MONSANTO SHOULD MONITOR 003 FOR NH3. PERMIT SHOULD INCLUDE A TOXICITY REOPENER AND TOXIC MONITORING. PEMINT SHOULD BE SHORT TERM. LIMITS WILL CHANGE WITH NEW DESIGN FLOWS IN THE CAPE FEAR RIVER. Recommended by ( Zi4 Date 0 Reviewed by: Tech. Support Supervisor Date Regional Supervisor Date _:< �Z/17 Permits & Engineering LQ� Date — 3I.11._— Division of Environmental Management December 16, 1986 MEMORANDUM To: Dale Overcash / From: Meg Kerr Subject: Requirements for Monsanto Permit I have completed my analysis for the short-term renewal of Mon- santo's permit. Limits are attached. They reflect the existing limits with slight modifications in response to the company's application. Please note the following special conditions: q { X.A. t. "5 1. Toxicity monitoring - Monsanto should monitor all pipes quar- terly 3. Limits for Cu and Zn for pipe 001 should be removed if the com- pany can provide monitoring data showing that they are absent from the discharge. 4. Pipe 003 should be monitored quarterly for NH3. 5. Monsanto should be notified that these limits will likely change as new target flows are identified on the Cape Fear River. cc. Steve Tedder : 5 <.r. aI( ,tip iv e, &Ae co,„, 6- a-Ot 0 P LlrNAu -J eRo Toxicity Testing Requirement Monsanto The effluent discharge shall at no time exhibit chronic toxicity using test procedures outlined in the North Carolina Cerioclaphnia chronic effluent bioassay procedure (North Carolina Chronic Bioassay Procedure-Revised*December, 1986) . The effluent concentration at which there may be no observable inhibition of reproduction or significant mortality is 23% (defined as treatment two in the procedure document) . The permit holder shall perform quarterly monitoring using this procedure to establish compliance with this permit condition. All data submitted as part of this monitoring requirement will be submitted with the daily monitoring results of the other permit conditions in the month following any toxicity evaluation. Additionally a copy of this material is to be sent to the following address: Attention: Technical Services Branch North Carolina Division of Environmental Management Post Office Box 27687 Raleigh, North Carolina 27611 Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests as well as all dose/respor a data. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Environmental Management indicate potential impacts to the receiving stream, the permit may be reopened and these monitoring requirements modified to include additional testing as increased frequency, alternate test reqirements or both. note: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate retesting. Failure to submit suitable test results will constitute a failure of permit condition. Facility Name: 1 1od3A,.%rn Existing �C.1 Proposed o NPOES WASTE LOAD ALLOCATION Engineer SvJ Pate Rec 3F 4/II/SS- 31 s' Date 7/3//g4 Permit No .: k ed03719 Pipe�I'b .: 6o ( County: Cu-ULP,JD MJAi- G.mier C.,1Mj HLo Design Capacity (MGD): (9. /5 Industrial (% of Flow): /Qp Domestic (% of Flow): Receiving Stream : _ t FE0 ei%ia Class : C Sub -Basin : Reference USGS Quad: / 3 (Please attach) Requestor: ovaci sm sr. PRULS (Guideline limitations, if applicable, are to be listed on the back of this form.) 03 - 04 -is Regional Office /40 Design Tom.: Drainage Area (mil) : '137 5- 7Q10 (cfs) C 01) Winter 7Q10 (cfs) Location of D.O. minimum (miles below outfall): Velocity (fps): Kl (base ?, per day): Avg. Streamflow (cfs) : 'if 3 30Q2 (cfs) Slope (fpm) K2 (base e, oer day): Effluent Characteristics Monthly Average Comments ' "S3 37.S7Vd Cr a.:2f# d n A.2 S. #/ 4 F -.n 111 o r c 2. S G Q.r�{n i .7 /I 4 Comments: 1' c L-8Y Effluent i Characteristics __q 2,verage Comments /SS 56,.34141 C r 5.0 #/dam - v1 3 c #/44 6-1 S.u.C,-, laN rust toe tece,✓ , ,,wJe�S II -CeAre(c ✓ tom b aSC. CaleSe; c t -�v _ ejxcee�Y 6., \-J eca] e SLee pi--0 Reviewed By: Date: cin (707 WASTELOAD ALLOCATION APPROVAL FORM Request No. Facility Name Type of Waste Status Receiving Stream Stream Class Subbasin County Regional Office Requestor Date of Request Quad MONSANTO 001 NON -CONTACT COOLING EXISTING CAPE FEAR RIVER C 030615 CUMBERLAND FAYETTEVILLE DALE OVERCASH • : H23 Wasteflow TSS Cr Zn pH temperature Drainage Area (sq mi) Summer 7Q10 (cfs) Winter 7Q10 (cfs) Average Flow (cfs) 30Q2 (cfs) RECOMMENDED EFFLUENT LIMITS . mo.avg. (mgd): (#/d) : (#/d) : (#/d) (SU) . 0.15 37.5 2.25 2.25 6-9 ** Upstream (Y/N): N Downstream (Y/N): N Location: Location: da.max. 0.15 56.3 5.0 5.0 6-9 ** MONITORING COMMENTS . 0. . 0. : 4340 •- DEC %'' 1986 FAME! i 'v, c. . TEMPERATURE - DISCHARGE SHALL NOT INCREASE THE RECEIVING WATER'S TEMPERATURE BY MORE THAN 2.8 C AND IN NO CASE CAUSE IT TO EXCEED 32 C. PERMIT SHOULD INCLUDE A TOXICITY REOPENER AND SHOULD INCLUDE TOXICITY MONITORING (SEE ATTACHED). MONSANTO SHOULD MONITOR THIS DISCHARGE FOR CR AND ZN AND SHOULD HAVE THE LIMITS REMOVED IF THEY CAN DEMONSTRATE THAT METALS ARE ABSENT. Recommended by Reviewed by: Tech. Support Supervisor Regional Supervisor Permits & Engineering Date Date Date Date P _1_Z23 b_